1. Presentations May 23 – 25, 2005 Portland, Maine For related information visit: http://www.newmoa.org/prevention/mercury/conferences

2. Mercury Use in Switches, Relays & Measuring Devices Terri Goldberg, NEWMOA/IMERC

3. Overview Source of Information Mercury Use in Switches & Applications Mercury Use in Relays & Applications Mercury Use in Measuring Devices Where to go for more information

4. Data Source State Notification Requirements Clearinghouse -- IMERC Mandatory Reporting to Sell in States with Notification Online Database Non-compliance Data Summarized in Series of Fact Sheets – IMERC webpage Amount per component & total in all units sold in US in 2001

5. What Are Mercury Switches? Switches are products or devices that open or close an electrical circuit, or a liquid or gas valve. Mercury Float Switch: actuated by rising or falling liquid levels Mercury Tilt Switch: actuated by a change in the switch position Mercury Pressure Switch: actuated by a change in pressure Mercury Temperature Switch: actuated by a change in temperature Mercury Flame Sensors

6. Amount of Mercury in Switches Tilt Switches: can range from about 0.05 grams to almost 5 grams Float Switches: can range from more than 0.1 to more than 65 grams (float switch units with up to six individual switches) Miscellaneous Switches: 0.005 to 5 grams Flame Sensors: more than 1 gram

7. Uses of Switches Tilt Switches: cars; recreational vehicles; electric, gas & water meters; space heaters, manufacturing/miscellaneous Float switches: pumps & pump systems Other Switches: motor vehicles Pressure controls: fire control units, manufacturing/ miscellaneous

8. Total Mercury Use in Switches – US Sales, CY 2001, Pounds Tilt Switches: 14,302 Flame Sensors/Switches: 3,853 Pressure Controls: 2,099 Float Switches: 13,282 Other Switches: 13,772 Total Mercury in Switches: 47,308 (over 23.6 tons) Mercury Use in Thermostats: 25,945 (about 13 tons) Note: UNDERREPORTING

9. What are Mercury Relays? Relays products or devices that open or close electrical contacts to effect the operation of other devices in the same or another electrical circuit; often used to turn on & off large current loads by supplying relatively small currents to a control circuit Mercury Displacement Relays Mercury Wetted Reed Relays Mercury Contact Relays

10. Amount of Mercury in Relays Various Relays (individually): 0.005 to more than 1 gram Units with 1 to 6 Poles/Relays: 0.01 – > 1 grams Relay Controls (can have 8-32 relays): 0.12 - 0.32 grams

11. Uses of Mercury Relays Telecommunications Circuit Boards Rotating Electrical Connectors Chemical Analyzer Manufacturing/Miscellaneous Cooking Equipment

12. Total Mercury Use in Relays – US Sales, CY 2001, Pounds All Relays & Relay Controls: 62,208 (about 31 tons) UNDERREPORTING

13. Total Combined Mercury Use— CY 2001, US Sales Total Mercury Use in Switches & Relays: ~54.5 tons Total Mercury Use in Switches, Relays, & Thermostats: ~67.5 tons

14. State Bans on Sales of Mercury Switches, Relays, & Thermostats Phase Outs/Bans on Sale of Mercury Switches & Relays: CT, ME, IL, RI, VT Specific Phase Outs/Bans on Sale of Mercury Auto Switches: CA, ME, WA, OR Phase Outs/Bans on Sale of Mercury Thermostats: CA, CT, ME, RI, VT Restrictions on Sales of Thermostats: OR, WA

15. Examples Reported Phase-Outs of Mercury Use in Switches & Relays Switch used in hydraulic level device in RVs -- Coachmen Car Anti-lock braking system – Daimler Chrysler Car Light Switches— Ford & GM Trailer Braking Systems – Hopkins Hood & Luggage Door Switches – International Truck & Engine Fire Control Units – Joslyn Clark Controls Vaccum Pump Pressure Switch – PACCAR, Inc.

16. Which Measuring Devices Contain Mercury? Barometers Hydrometers Manometers Psychrometers & Hygrometers Sphygmomanometers Strain Gauges Thermometers

17. Amount of Mercury in Measuring Devices Barometer: 395-622 grams Thermohydrometer: > 1 gram Manometer: 28-74 grams Psychrometer: 5.2-6 grams Sphygmomanometer: 104.2-124.5 grams Strain Gauge: > 1 gram Thermometers (including fever, laboratory, medical, industrial, & cooking): >0 - 0.005 - >1 gram

18. More on Thermometers Fever thermometers: ~0.5 grams Laboratory thermometers: ~ 3 grams Industrial thermometers: much more than 1 gram (maximum amount reported as 117 grams)

19. Total Mercury Use in Measuring Devices – US Sales; CY 2001; Pounds Barometers: 353 Hydrometer/Thermometer: 8 Manometers: 1,936 Psychrometers: 3 Sphygmomanometers: 4,002 Strain gauge: 1.5 Thermometers: 3,221 Replacement mercury: 118 Total for all Measuring Devices: 9,642.5 (about 4.8 tons) Note: UNDERREPORTING

20. Measuring Devices Phase-Outs Thermometers: Princo Thermometers: Taylor Precision Products

21. State Bans on Sales of Mercury Measuring Devices -- Examples Manometers: CT, ME, MN, VT, WA Thermometers: CA, CT, IN, IL, ME, MD, MA, MI, MN, NH, NY, OR, RI, WA, VT Instruments & Measuring Devices: CT, ME, RI, VT

22. More Information Draft “Mercury Use in Switches & Relays” (not yet published online) “Mercury Use in Measuring Devices” — www.newmoa.org/prevention/mercury/ imerc/FactSheets/measuring_devices.doc Mercury-added Products Database – www.newmoa.org/prevention/mercury/imerc/ notification/ Contact: Terri Goldberg, (617) 367-8558 x302

23. Presentations May 23 – 25, 2005 Portland, Maine

24. Reducing Mercury Switches and Relays in Illinois

25. Why focus on switches and relays? Wanted comprehensive mercury legislation initially Fever thermometer and novelty item ban signed into law in 2003 Switches and relays large source of mercury in manufacturing

26. Initial Proposal All switches and relays except those: –Required under Federal law or contract –Used to replace switches and relays that are components in larger products in use prior to July 1, 2007 and Larger product is used in manufacturing or Switch or relay is integrated into larger product

27. Opposition Thermostat manufacturer –TRC program –Voluntarily phasing out Electric utility company –Nuclear plants and emergency situations –Federal law provision Medical diagnostic equipment manufacturer –Component of larger product provision

28. Final Legislation Ban, as of July 1, 2007, on sale, offer of sale, distribution and offer of distribution Applies to: –Individual mercury switches and relays –Mercury switches and relays that are product components

29. Final Legislation Exemptions for Climate control thermostats Electrical generating facilities Medical diagnostic equipment Manufacturers may request exemptions for other uses Report to Governor and Legislature on climate control thermostats

30. Exemptions Submit request to IEPA by July 1, 2006 IL EPA to develop rules and prescribe forms for exemption requests Manufacturer must demonstrate: –End of life collection, transportation and processing system for switches, relays, instruments or pieces of equipment that is widely available and convenient exists

31. Exemptions AND The specific use or uses of the switch, relay, instrument, or piece of equipment provides a net benefit to the environment, public health, or public safety when compared to available non-mercury alternatives.

32. Exemptions Granted for 5 years With or without conditions Renewals – must demonstrate original reasons for exemption still exist IL EPA must consult with other states prior to granting exemptions –Joined IMERC in December 2004

33. Universal Waste Legislation designated mercury switches and relays as Universal Waste Required IL Pollution Control Board to adopt rules Rules went into effect 4/13/05

34. Becky Lockart Office of Pollution Prevention Illinois Environmental Protection Agency P.O. Box 19276 Springfield, IL 62794-9276 217-524-9642 Becky.Lockart@epa.state.il.us

35. Presentations May 23 – 25, 2005 Portland, Maine

36. Mercury P2 Program Reducing Mercury Containing Equipment

37. Mercury P2 Program Presenter: Patrick S Zombo Senior Environmental Planner c/o Consumers Energy Co. 1945 W Parnall Rd Jackson, MI 49201 phone 517 788 0647 fax 517 788 1064 email pszombo@cmsenergy.com

38. Go for the BIG FISH….. You’ll spend the same amount of time baiting the hook…… “Good Stuff”

39. Mercury P2 Presentation

40. Why Initiate MCE reduction program? Environmental Concerns: –Public awareness: Fish Advisories –Binational Toxics Strategy Workgroup –Michigan P2 Task Force Recommendations –Difficulty of dealing with Mercury emissions Waste Management Concerns: –Hg both Listed and Characteristic RCRA waste –Land Ban Restricted –Required EPA specified treatment technology or –Treatment to UTS –Expensive waste stream

41. Implement Voluntary Program Obtain Upper Management Support Incorporate existing related Programs –Mercury Regulator program –Corporate P2 Program –Strong Recycling Program Establish Mercury P2 Team –Program Champion –Environmental Coordinators Include Key Departments –FacilitiesLegalPurchasing –MaintenanceEnvironmental Get more help!

42. Work The Plan Set Goals/Milestones Keep Team Informed Share Results Example: Identify potential MCE –Complete an Inventory –Identify types and quantities of MCE –Identify Location(s) –Identify Responsible Units Identify Alternative Equipment

43. Consumers Energy 1996 Inventory Numbers Represent Total Pounds t (Estimated Total is 2464 Pounds) Customer Gas Regulators 406 Ring Balances 88 Bottled/Stock Mercury 455.6 Misc. Equipment 141.7 Gas Extraction Apparatus 18.5 Chart Recorders 4 Various Meters537 Lab Use 11.1 Switches/Relays/Timers/Gauges 408.5 Manometers/Barometer 368.9 Thermostats/Thermometer 24.7

44. Electric Business Unit Manometers 348 Thermometers 3.5 Misc. Equipment 89.2 Flowmeters 201 Timers 318.8 Repair Equipment 30.1 Relays 48.3 Drum Level Meters 24 Gauges 0.59 Switches 35.3 Thermostats 16.31 Ring Balances 88 Bottled Mercury (In Stock) 356 Numbers Represent Total Pounds in Each Type of Equipment (Estimated Total is 1559 Pounds)

45. Gas Business Unit * Numbers Represent Total Pounds in Each Type of Equipment Used (Estimated Total is 808 Pounds) Customer Gas Regulators 406 Thermostats/Thermometers 1.3 Spare Meters 64 Switches 5.18 Flowmeters 248 Manometers 11.8 Misc. Equipment 23.6 Mercury Stock 43.64 4 Chart Recorders

46. OSD Business Unit Interference Removal Chemicals 2 Switches 0.312 Thermometers 1.46 Hg Sealed Pistons 0.06 56 Mercury Stock Gas Extraction Apparatus 18.5 Barometers 8.5 Thermostats 1.74 Mercury Fix Point 6.5 Thermocouple Juncs. 0.02 Stokes Gauges 2 Numbers Represent Total Pounds in Each Type of Equipment Used (Estimated Total is 97 lbs)

47. SBU Comparisons k Total Strategic Business Units of Consumers Energy Company (Estimated Total is 2464 Pounds) 1559 808 97 Mercury Quantities (lbs)

48. Comparison: In Service/Stock 1996 Strategic Business Units of Consumers Energy Company (Estimated Total is 2464 pounds) Mercury Quantities (lbs) 396.1 1162.9 99.4 708.9 58.0 39.0 (1559)(808)(97) equipment in service equipment in stock

49. Key Activities Recycle excess stock Hg Consolidate @ Key Locations: –Required Stock Hg –Required MCE Replace –Regulators –Flame Sensor Switches –Thermostats –Lab I&C equipment –Switches/relays etc from Meters

50. Key Activities Education Initiatives/Training –Meter Readers –Gas Service Workers –Lab Technicians –Purchasing Staff –Coordinators Purchasing Criteria –Equipment that is mercury Free –Lamps –Batteries

51. SBU COMPARISONS OF MERCURY QUANTITIES AS OF JANUARY 2005 Total Strategic Business Units of Consumers Energy Company 1996 Inventory - 2464 lbs 2005 Inventory - 853 lbs (65% Reduction) Mercury Quantities (lbs) 1559 808 97 695 138 20

52. Mercury P2 Program Progress Consumers Energy’s 7th progress report completed April, 2005. 98+% reduction in Elemental Stock Mercury in use in facilities since 1996 (baseline year). 65% reduction in Mercury and Mercury Equipment since 1996. Company stocks exclusively low Mercury (green) batteries and lamps. Over 340,742 pounds of Batteries recycled through 2004. Over 298,885 pounds of Lamps recycled through 2004.

53. MP2 Progress (continued) Meter Move out Program 38% complete Removal program for gas regulators strengthened. Discontinuation of use and removal of Mercury flame sensor switches and Mercury thermostats from repair stock. Removal of Mercury oven temperature gauges from repair stock. Systematic removal and replacement of Mercury relays, timers and switches during routine in ‑ house meter servicing.

54. MP2 Progress (continued) Heightened employee awareness of Mercury through training and updates. Over 80,000 students have seen “In Concert with the Environment” a Company sponsored energy awareness program. Consumers Energy program Inventory used as model by USEPA Region V. Consumers Energy program presented at regional seminars throughout the Midwest.

55. Mercury P2 Program Reducing Mercury Containing Equipment Thank You

56. Mercury P2 Program Presenter: Patrick S Zombo Senior Environmental Planner c/o Consumers Energy Co. 1945 W Parnall Rd Jackson, MI 49201 phone 517 788 0647 fax 517 788 1064 email pszombo@cmsenergy.com