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  • 100 W. Broadway, Suite 290, Long Beach, CA 90802 | p: (562) 597-0205 | f: (562) 597-0231 | www.sga-inc.net 1

    VIA ELECTRONIC MAIL

    January 25, 2017 Department of Toxic Substances Control Attention: Mr. Donn Deibert 1001 I Street P.O. Box 806 Sacramento, California 95812-0806 SUBMISSION OF QUARTERLY REPORT; Consent Order Item B-1.6 Dear Mr. Diebert, The following quarterly report for 2016 Q4 outlines the Thermostat Recycling Corporations (TRC) most recent outreach and pilot project activities. By this submission, S. Groner Associates, Inc. (SGA) is fulfilling obligations on behalf of the 25 signatories of the Consent Order listed below. If you have any questions regarding this submission, please feel free to contact me at (562) 597-0205 or the address below. Regards, Stephen Groner President, S. Groner Associates, Inc. 100 W. Broadway, Suite 290 Long Beach, CA 90802 Enclosures: CSLB License Number Forms cc: Mr. Rick Brausch

    1001 I Street P.O. Box 806 Sacramento, California 95812-0806

    Ms. Pauline Batarseh 1001 I Street P.O. Box 806 Sacramento, California 95812-0806

    Mr. Ryan Kiscaden Thermostat Recycling Corporation 500 Office Center Drive, Suite 400

    Fort Washington, PA 19034

  • 100 W. Broadway, Suite 290, Long Beach, CA 90802 | p: (562) 597-0205 | f: (562) 597-0231 | www.sga-inc.net 2

    Mr. Steve Hellem Thermostat Recycling Corporation 500 Office Center Drive, Suite 400

    Fort Washington, PA 19034

    (25) Companys Signatures representing;

    Bard Manufacturing Company, Inc. Burnham Holdings, Inc. Carrier Corporation Chromalox Crane Climate Master, Inc. Empire Comfort Systems General Electric Company Honeywell International Inc Hunter Fan Company Invensys, Inc. ITT Corporation Johnson Controls Lear Siegler Lennox International Inc. Lux Products The Marley-Wylain Company Nortek Global HVAC LLC Sears Holdings Thomas & Betts Corporation Trane Residential Systems Uponor, Inc. Valliant Corporation W.W. Grainger White-Rodgers

  • 100 W. Broadway, Suite 290, Long Beach, CA 90802 | p: (562) 597-0205 | f: (562) 597-0231 | www.sga-inc.net 3

    Introduction: During the fourth quarter (October December, 2016) S. Groner Associates (SGA) working on behalf of the Thermostat Recycling Corporation (TRC) focused on implementing the following tasks from DTSC-approved Outreach Plan and Pilot Plan as a part of the California TRC Program. The following report outlines those efforts undertaken during this quarter broken into audiences.

    Summary of Results:

    - Mercury-Added Thermostats Collected this Quarter: 3,603 - Mercury-Added Thermostats Collected this Year: 15,282 - Program Element/Participants to which the Collected Thermostats are Attributed:

    Information not attributed - Contractor State License Numbers: Included in appendices - Number and location (by street address) of collection bins: Included in appendices - New Collection Bins Placed: 33

    Mercury-Added Thermostats Collected this

    Quarter:

    3,603

    New Collection Bin Placed this Quarter:

    33

  • 100 W. Broadway, Suite 290, Long Beach, CA 90802 | p: (562) 597-0205 | f: (562) 597-0231 | www.sga-inc.net 4

    Outreach Activities: The following list provides a summary of the TRCs overall 4th Quarter Outreach and Pilot Project activities by audience:

    Contractors

    Conducted outreach phone calls to HVAC contractors to expand TRCs network of collection bins and increase program participation. The most frequently cited barriers to accepting a bin include:

    1. Rarely come across mercury thermostats. 2. Already have a means of disposing of mercury thermostats (either with a wholesaler

    or a specialty contractor).

    Conducted outreach phone calls to demolition contractors to expand TRCs network of collection bins and increase program participation. There was a single recurring barrier that emerged:

    1. We have not found any of these companies from this SIC code that handle mercury thermostats (from the list we are using Hoovers business data lists). A few indicated that they only specialize in substances such as mold or asbestos, while the majority cited that handling hazardous substances is not within the purview of their work. A number of the companies indicated that the mercury thermostats (and presumably other hazardous substances) are already removed before they begin the demolition.

    Conducted outreach phone calls to general contractors to expand TRCs network of collection bins and increase program participation. The most frequently cited barriers to accepting a bin include:

    1. Rarely deal with thermostats (mercury or not). 2. When they do come across mercury thermostats, they take them to wholesalers.

    Conducted outreach phone calls to environmental compliance contractors to expand TRCs network of collection bins and increase program participation. Environmental compliance contractors were contacted because some of the larger general contractors indicated they partner with these entities to dispose of hazardous/universal waste. Please note that there is no specific SIC code for this specific type of contractor. Previous to this quarter we found two contractors that accept mercury thermostats, but but have not found any directly via the

    Companies contacted: HVAC contractors: 250 Collection bins placed with HVAC contractors: 24 Companies contacted: demolition contractors: 174 Collection bins placed with demolition contractors: 0

    Companies contacted: general contractors: 230 Collection bins placed with general contractors: 3

    Companies contacted: environmental compliance contractors: 143 Collection bins placed with environmental compliance contractors: 0

  • 100 W. Broadway, Suite 290, Long Beach, CA 90802 | p: (562) 597-0205 | f: (562) 597-0231 | www.sga-inc.net 5

    Hoover list using various SIC codes that may overlay this industry type. No additional bin orders were secured after contacting a total of 143 companies.

    Sent follow-up emails to HVAC and general contractors that expressed interest during outreach phone calls.

    Researched SIC codes for contractors to generate a Hoovers database that can be sorted by industry type, business size, and location.

    Phone and email correspondence with HVAC and general contractors that have recently signed up for a collection bin to answer their program-related questions.

    Continued to maintain the contractors landing page as a way for California contractors to sign up for a collection bin or find a drop off location.

    1. Developed collection bin sign-up form for contractors landing page to gather data regarding the effectiveness of different tactics.

    2. Backed up pages and updated plugins. 3. The page received a total of 20 unique visitors, 56 page views, and zero bin order

    placements.

    Wholesalers

    Drafted wholesaler pilot partner instruction letter and wholesaler pilot program invoice form.

    Identified how many wholesaler locations in California are not participating in the mercury thermostat collection program or have not returned a collection bin in 2016. Corresponded with Renee Avila from DTSC to send outreach letters to these wholesaler locations.

    Retailers

    Contacted 121 additional retail locations to offer a collection bin; 9% of these accepted (11 locations total; seven for the pilot program and four non-pilot, non-incentive locations) (see Appendix F). The most frequently cited barriers to accepting a bin include:

    1. Dont sell enough thermostats and/or rarely come across mercury thermostats 2. Decisions have to be made through corporate office 3. Process of getting/sending in bins is too time consuming 4. Not enough space to host the bin

    Sent follow-up emails to retail locations that expressed interest during outreach phone calls.

    Developed a letter for retail pilots that provides information about the program.

    Developed a retail pilot agreement contract for participating retail locations.

    Developed and sent an informational flyer to retail managers to increase program participation.

    Consumers reached (impressions CA only): 3,994,843 Web Site Visits (all pageviews: micro sites + web site): 2,968 Collection bins placed with retailers: 6

  • 100 W. Broadway, Suite 290, Long Beach, CA 90802 | p: (562) 597-0205 | f: (562) 597-0231 | www.sga-inc.net 6

    Contacted Lowes, OSH, and Home Depot as possible retail chain collection partners. OSH declined to participate in the TRC program because they are a mercury thermostat collection partners with another program. Two calls were made to Home Depots corporate environmental compliance division but no response was received. Spoke with Lowes corporate office and were redirected to their administrative support division; follow up calls were placed but no response was received.

    Approached ACE Hardware and TrueValue stores as an alternative to the big box chain stores. Because both ACE and TrueValue locations are run by franchisees, each location has more autonomy to opt in to the program without receiving corporate approval. In order to reach consumers in key areas throughout the state (such as the pilot locations), we broadened our outreach to other independent hardware and home improvement stores.

    Created shelf-