Managing Motor Vehicle Mercury Switches in New Jersey

Great Lakes Regional Pollution Prevention RoundtableSummer Conference, August 25, 2005

New York Academy of SciencesMike Aucott, Ph.D., Division of Science, Research & Technology

NJ Dept. of Environmental Protection: Michael.Aucott@dep.state.nj.us

NJ Mercury Switch Data Collection

Pilot Project

(report available at www.state.nj.us/dep/dsr/mercury)

Under-hood light and switch assembly

Anti-lock brake G-sensor

Switch assemblies

“Mercury-free” hulks awaiting shredding

Hulks entering hammer mill

Shred and researchers

Shred

Steel manufacturing plant

Scrap metal feedstock

Mercury Switch Data Collection Pilot Project, Results & Findings:• Mercury switches were removed from 358 vehicles to

produce low mercury content scrap• Vehicles contained an average of 0.8 switches each• Several minutes were required to examine vehicle to

determine presence of switch and to remove it• Total cost of switch removal, handling, transportation, proper

disposal estimated to be $3.00 per switch• Preliminary data from associated stack test project indicated

approximately 50% reduction from steel manufacturing facility operating on low mercury content scrap

• Desirable to implement a switch removal program on a regional basis

• See http://www.state.nj.us/dep/dsr/mercury and click on “Mercury Switch Data Collection Pilot Project” to view or download

New Jersey State Vehicle

Switch Removal Project

Shipping container for state vehicle switch removal project

State Vehicle Switch Removal Project:

Results & Findings:• Project not complete

• Results so far indicate:– Approximately 600 cars, virtually all domestic,

most between 5 & 10 years old, are removed from service each year.

– All cars are checked, and mercury switches are removed; to date there have been 0.56 switches per car.

New Jersey Switch Removal Act

§§1-9 C.13:1E-99.82 to 13:1E-99.90

§9 Note to 52:18A-18

P.L. 2005, CHAPTER 54, approved March 24, 2005

Requirements of the law include:

• Manufacturers must provide switch containers to vehicle recyclers within 30 days of enactment

• Manufacturers of vehicles sold in NJ must develop a mercury minimization plan and submit to the NJDEP within 90 days of effective date

• Plan must include minimum $2 payment to vehicle recycler for each switch removed and $0.25 per switch to the NJDEP

• Manufacturers must begin implementation of plan(s) within 30 days of approval by NJDEP

• By 30 days after plan approval, recyclers must remove all mercury switches prior to delivery to a scrap recycling facility

Implementation Status:

• Manufacturers have provided containers and instructional materials, including a DVD, introductory letter, dismantling brochure and universal waste labels, to over 200 facilities that have been verified as end-of-life vehicle recyclers

• The NJDEP is developing additional outreach to recyclers• Recyclers are now removing switches• Three Mercury Minimization Plans, from Subaru, Nissan,

and the Alliance of Automobile Manufacturers (representing all major U.S. and European manufacturers) have been submitted to the NJDEP and are now under review.

Future Research Directions :

• Are there other significant sources of mercury input to the scrap metal stream, e.g. discarded stoves, other appliances, industrial equipment? Additional mercury materials accounting studies at iron and steel plants and recyclers may answer this question.

• Are there other important flows and significant releases of mercury to the environment associated with scrap metal processing? Further studies of mercury content and fate of non-ferrous scrap and of non-metallic residue shredder residue (fluff) may answer this question.

Future Research Directions, cont’d. Are there better management approaches for mercury capsules or switch assemblies than recycling?

– Current plans are to send mercury capsules and switch assemblies to mercury recycling facilities, which melt the switches, etc. and recover the mercury. Recovered mercury is then returned to commerce. Capsules are relatively easy to process. But some assemblies, e.g. ABS G-sensors, are more difficult to recycle – capsules are hard to remove, and assembly materials are not amenable to retorting.

– The total amount of mercury contained in switch assemblies is small compared to quantities of mercury stored elsewhere and potentially available to commerce.

– Can mercury switch assemblies, and capsules, be safely treated, managed, or disposed in other ways that will ensure long-term sequestration of mercury, and that will be cheaper and less energy-intensive than recycling?

– Alternative approaches that are technically and economically feasible may nevertheless present legal and public perception problems.

Scrap metal feedstock

Non-ferrous shred

Non-metallic shredder residue (fluff)

ABS G-sensorMercury-containing capsules