1. Recovering Mercury Switches from Cars Where we are today Where we are going 1 gram of mercury in each switch 1 million switches = 1 ton of mercury

2. The Switch >99% of mercury in vehicles is contained in convenience light assemblies (~90%) and anti-lock brake system (ABS) sensors (~9%) ABS

3. Extent of the Problem USEPA estimates Electric Arc Furnace (EAF) emissions of mercury at 10 tons/year An estimated 150 million (150 tons of mercury) mercury convenience light and ABS switches are in vehicles still on the road today (15 years left to take action) An estimated 10-12 million vehicles with mercury switches are shredded annually Combined state initiatives are capturing less than 500 lbs of mercury from switches/year; less than 5% of switches available from shredded vehicles

5. National Vehicle Recycling There are approximately 14000 readily identifiable vehicle dismantlers in the US (many more if small unregistered operators included) There are approximately 300 shredders There are approximately 75 Electric Arc Furnaces (EAF)

6. Recent Developments EPA adds mercury containing devices (mercury switches included) to the list of wastes that can be managed under the Universal Waste rules (effective 8/5/05) EPA developing MACT rule with provisions that would limit mercury to EAFs from vehicle shred feed EPA may add Best Management Practice requiring switch removal in dismantler storm water permits

7. New York State o46,000 switches, 102 lbs of mercury have been collected from 1999 to date oApprox 9 million registered cars on the road oNearly 700,000 cars/year are scrapped containing approximately 800 lbs/year of mercury from switches oOnly 50 of 800 registered dismantlers are participating in the collection program

8. NY – Results and Drivers State collection center provides low cost ($5/lb Hg in 450 switches), mail-in convenience, and metrics for dismantlers that voluntarily participate in the program Collaboration with shredders is getting increased numbers of dismantlers to participate

9. Mailer Box Collection DOT approved shipping container holds 450 switches removed from assemblies Mailer Box can be shipped directly from dismantler to collection center via FEDX ground. Easy verification of dismantler participation and amounts of switches from each dismantler

10. Mailer Box

11. Collection Center

12. NY – Program Drivers 1998 EPA Grant and workshops in 1998 and 2002 provided dismantlers statewide with switch program information and 500 free mailer boxes. 2004 Mercury Added Products Law requires dismantlers to remove and recycle mercury switches. 800 letters sent to dismantlers before July 12, 2005 effective date

13. NY – Drivers Proposed Legislation A03336 and S04256 “Mercury-free vehicles Act of 2005” would require auto manufacturers to pay for removal, replacement, collection and recovery of mercury switches in vehicles on the road or vehicles about to be scrapped. oStorm Water Permit required P2 plans for shredders and dismantlers; develop Best Management Practices to minimize release of toxics, including mercury from switches, in crushing operation, ASR shredder fluff piles, and shredded steel piles.

14. Switch Recovery Economics – Best Case ~$100 labor cost to collect and dismantle 454 switches from assemblies (1lb Hg) ~$30M in labor to collect and dismantle 150M switch assemblies ~$3M shipping cost for dismantled switches ~$3M recycling cost for dismantled switches ~ $36M total cost if mail-in system is used

15. Switch Recovery Economics –worst case* ~$12M in labor if switch assemblies are collected but not dismantled ~$18M to ship 5 gallon containers to collection center ~$182M for recycling of switch assemblies ~$212M total cost *assumes 150M switches are collected

16. Economic Considerations ~$150M cost to automakers for $1/switch if a national bounty were 100% effective ~$6Billion cost to EAFs for Hg controls if no switch recovery program in place; (note: shredders, dismantlers and landfills will continue to have release issues)

17. Economics – Shared Cost Approach* ~$12M Dismantlers collect assemblies ~$26M Auto manufacturers fund switch assembly collection containers, shipping and dismantling of assemblies ~$3M Auto manufacturers fund switch recycling to recover mercury

18. State Legislation - Enacted Arkansas* financial responsibility* California Maine*$1/switch * New York Minnesota*$150,000 for 2 year program* New Jersey*$2.25/switch* Rhode Island*$4/switch Texas* Cost of packaging, shipping, and recycling of switches* *Requires auto manufacturers to pay for programs

19. State Legislation - Proposed CaliforniaPlan to finance switch program Connecticut$1/switch IllinoisFinance program with incentives LouisianaPlan to finance switch program Massachusetts$3/switch, $15/ABS unit New YorkPlan to finance switch program North CarolinaPlan to finance switch program Pennsylvania$3/switch South CarolinaPlan to finance switch program Vermont*Study the problem* VirginiaPlan to finance switch program WashingtonPlan to finance switch program * Does not require auto maker financing

20. Voluntary Partnerships California Colorado Connecticut Florida Illinois Indiana Michigan Minnesota New York Ohio Oregon Pennsylvania Vermont Virginia Wisconsin 25 States have programs; combinations of enacted or proposed legislation and voluntary partnerships

21. Reference Materials EPA web site – http://epa.gov search “automotive mercury” Environmental Council of States (ECOS) http://ecos.org search “automotive mercury” Thomas Corbett NYSDEC Region 9 Office 270 Michigan Avenue Buffalo, New York 14203-2999 716-851-7292 tacorbet@gw.dec.state.ny.us