January/Febraury 2009
Tighter mercury emissions regulations have put pressure on the automobile recycling chain—from steelmakers to scrap shredders to auto dismantlers—and a system designed to encourage the removal of vehicle mercury switches.
By Ann C. Logue
It's hard to believe that something the size of a gumdrop can cause so much trouble. As the U.S. EPA tightens mercury emission regulations on steelmakers, the steelmakers are relying on the other players in the automobile recycling chain to reduce the amount of mercury in steel scrap. The source of the problem is the mercury switch—a tiny device, each one containing about a gram of mercury, that was used to activate convenience lights and antilock brake systems in many cars and trucks built before 2003.
An estimated 67 million switches remain in older vehicles in the United States, according to the EPA. When a mercury switch enters an electric-arc furnace in a shipment of steel scrap, the agency explains, the mercury vaporizes and gets emitted into the environment. The particles eventually enter bodies of water, where they react with microorganisms and become methylmercury, a highly toxic form of mercury that builds up in small aquatic creatures. The larger fish and other creatures that eat them accumulate higher concentrations of methylmercury that, when consumed, can be harmful to human heath. At particular risk are fetuses and young children, who can suffer serious neurological damage if exposed to high concentrations of methylmercury. To minimize these risks, the EPA and the U.S. Food and Drug Administration advise women who are pregnant or who could become pregnant, nursing mothers, and young children to avoid or limit their consumption of certain fish, including swordfish, shark, and king mackerel.
The EPA's concern is the mercury emissions from EAFs, and the easiest and least expensive way for steelmakers to control them is to prevent the mercury from entering the furnace in the first place. They want to ensure, to the extent practicable, that the shredded scrap they buy from processors and brokers is free of mercury-containing switches. The shredders point out that the vast majority of vehicles they receive are already flattened or baled, making it impossible for them to find and remove the switches. They turn to their feeder yards and to auto dismantlers, which purchase end-of-life vehicles, remove fluids and resalable parts, and often crush the hulks before selling them to shredder yards.
The auto dismantlers have their own concerns. Switch removal is a time- and labor-intensive process, they say—not to mention the challenge of determining whether a particular vehicle's make, model, and year indicate it contains one or more switches in the first place. "Part of the problem is that there is no way to look at a car and know, 'That one has a switch' and 'That one doesn't,'" says Steve Levetan, senior vice president at Pull-A-Part, an auto dismantler headquartered in Atlanta. At the end of the chain are the automakers, who installed the switches—which were a few cents cheaper than the alternatives—even though mercury's effects were well-known.
In an effort to solve the supply-chain conundrum, a consortium of industry, government, and environmental groups established the National Vehicle Mercury Switch Removal Program in August 2006. Steelmakers and automakers together provided $4 million in funding to create a program that pays an incentive—initially set at $1—for each convenience-light switch auto dismantlers and scrapyards remove and return to the program administrator, End of Life Vehicle Solutions (Farmington Hills, Mich.), until the fund runs out. The stakes went up for steelmakers in June 2008, when the EPA issued an area source rule that requires firms that operate EAFs to either participate in the NVMSRP—and agree to purchase scrap only from program members—or have a site-specific plan to control mercury, which has much more onerous compliance requirements.
In mid-2008, NVMSRP participants began examining the program's progress toward its initial goal—collecting 4 million mercury switches in three years.
There's a Hole in the Bucket
The NVMSRP's success is based on two criteria, explains Danielle Waterfield, ReMA's assistant counsel and director of government affairs: the number of switches pulled and the number of program participants.
Program participation is difficult to gauge. As of Sept. 30, 2008, 2,361 companies had registered with ELVS, up from 1,014 participants at the end of 2007. That's out of as many as 7,000 dismantling firms in the United States, according to some estimates. Though more participation is better, it's not purely a numbers game: Not all dismantlers do work that's eligible for the program. Some firms specialize in certain makes and models—luxury European automobiles, for instance—that might not contain any mercury switches. Others take all comers.
In terms of switches pulled and returned to ELVS, the numbers to date are not where they need to be, says Mary Blakeslee, consultant to the Environmental Council of the States (Washington, D.C.), one party to the NVMSRP agreement. The NVMSRP data show that ELVS received 1.6 million switches from August 2006 to September 2008, which is 40 percent of the 4 million switches estimated as recoverable in the three-year period.
The data come with several caveats, however. First, the program uses state-by-state data on annual vehicle registrations to estimate the number of deregistered cars and the number of mercury switches they might contain, says Richard Bell, ELVS president and manager of emissions and recycling planning and compliance for Ford Motor Co. (Dearborn, Mich.). That said, a deregistered car is not always scrapped. It could be exported for reuse or recycling, or it could be sitting in a garage or on blocks in somebody's driveway. Further, no one knows how many switches are sitting in buckets at dismantling firms at any one time.
Bell isn't surprised by the slow ramp-up in participation or collections because of the amount of education involved and the work of distributing collection buckets and mailers to dismantlers. "We spent the first year of the program achieving that," he says, and he now expects collections to accelerate.
Raising the Stakes
Why has the NVMSRP so far not reached the hoped-for levels of success? Program participants have several theories, starting with the $1 incentive payment. Dismantlers say that doesn't cover the time and labor the work requires. They have lists of the vehicle models where convenience lights were an option, they say, but they still need to physically inspect any cars and trucks they receive that are on those lists to see if the switches are there, then remove any ones they find.
In the dismantling business, Levetan says, "for every other part that's removed from a vehicle, there's a specific economic incentive," and $1 for a mercury switch is "inadequate." Pull-A-Part has been removing mercury switches at its 21 locations since before the incentive payment kicked in, Levetan says, because company executives knew it was "the right thing to do" and the firm could afford to do it. Still, a better payment would improve industry participation, he says. "A voluntary program that's coupled with a viable incentive is the best way to really deal with this."
After looking at the mid-2008 numbers, the NVMSRP's Implementation Fund Coordination Committee—a subcommittee that includes auto dismantlers, scrap processors, environmental groups, and state environmental agencies—agreed to sweeten the pot, raising the incentive from $1 to $4 per switch starting in August 2008. After the change, collections more than doubled, rising to 83,454 in September 2008 from the 31,148 collected in September 2007 and up more than 60 percent from the 51,344 collected in August 2008. Blakeslee isn't sure how much of the increase is due to the incentive, how much is due to better awareness of the program, and how much is from the mix of cars brought in for dismantling.
The higher payment will deplete the fund more quickly, which might encourage dismantlers to remove and return the switches sooner, but it could reduce participation rates once the money runs out. There are no plans to add money to the fund. Waterfield recommends that ReMA members who are collecting mercury components send them in now, even if their collection buckets are not full, to increase their chances of receiving payment before the fund runs out.
Creating Buy-In
Levetan points out that Pull-A-Part is a rarity in the dismantling industry because of its size and its commitment to the environment. The industry is fragmented, and many mom-and-pop yards might not be aware of the NVMSRP or might feel the requirements are too burdensome or costly. Further, some companies aren't interested in anything that might raise their profile with environmental regulators.
With the EPA's new, tougher emissions regulations, though, steel mills are feeling the heat. They and their scrap suppliers are trying various promotions and enticements to increase buy-in among the dismantlers and ensure their participation. "Part of ReMA's commitment to the NVMSRP is to encourage dismantlers to get involved," Waterfield says. Most recently, the association created a 16-by-20-inch poster for scrap shredders to post at their facilities that's designed to catch the attention of dismantlers as they proceed to the shredder's scales. ReMA also distributed a brochure shredders can hand out to their suppliers, the dismantlers. "Because dismantlers eventually all end up at the shredder's door," she says, this is a logical way for ReMA to support the shredders, "who are strongly encouraging their dismantler suppliers to get involved."
One change to the program should make tracking participation much easier: Mills, scrap brokers, and scrap shredders can now sign up with ELVS, indicating their intent to purchase end-of-life vehicles and shredded scrap only from other NVMSRP participants, who are listed on the ELVS Web site.
Recent industry consolidations have put several large scrap companies under the ownership of steel companies, creating even more emphasis on participation. The David J. Joseph Co. (Cincinnati), a scrap processor and broker now owned by steelmaker Nucor Corp. (Charlotte, N.C.), has been working to ensure that any scrap going into its parent company's mills is free of mercury-containing convenience light switches as much as possible. DJJ has removed and recycled 27,584 switches—60 pounds of mercury—in three years at its own scrapyards and auto-dismantling facilities. The company also uses the ELVS online database—which provides data on the number, weight, and type of switches dismantlers and recyclers have removed and returned—to track its suppliers, says Chris Bedell, senior vice president and general counsel. "A scrap company that has quality standards—and usually that translates over to the environmental side—will definitely have a competitive advantage," he says. Ideally, scrapyards will place more value on a car hulk coming from a program participant than one from a nonparticipant, he says, but his company makes it easy: "If you don't participate, DJJ brokers won't buy your shredded scrap."
Nucor was a diamond sponsor of the 2008 Automotive Recyclers Association (Fairfax, Va.) convention, where Nucor and DJJ had a booth to promote the NVMSRP. The booth featured contests in which people guessed the weight of switches on display as well as awards for companies that turned in the most switches in a one-month period.
Eric Logsdon, DJJ's corporate environmental manager, helps train the company's suppliers about mercury switch removal. He tries to de-emphasize the $4 incentive, he says, because the money will run out well before the mercury problem is eliminated. After all, even after 4 million switches are collected, there are an estimated 63 million left to go. "At our outreach and training, we try to tie mercury back to the individual person," he says, talking about how it affects water, hunting, fishing, and the human body. He hopes dismantlers will see a benefit far beyond $4 a switch.
Short-and Long-Term Goals
It's questionable whether the NVMSRP can meet its goal of collecting 4 million mercury switches by July—and it's uncertain how much the program is helping steelmakers meet their emissions requirements. Switch collection might slow down due to the recession and drop in metals prices. In an economic downturn, people keep their cars longer, which can reduce the flow of end-of-life vehicles and the volume of switches gathered. Further, as ferrous prices drop, dismantlers might hang onto their car hulks, awaiting higher prices.
As for emissions control, NVMSRP participation is not a certification or guarantee that the vehicle or the shredded scrap is free of mercury. There's no such thing as mercury-free scrap, Waterfield points out, because mercury is a naturally occurring element that exists all around us. And though the ELVS database is an excellent method for monitoring compliance, most mills also set their own contractual requirements, including site visits, on their suppliers.
Tom Malone, president of Brookfield Resource Management (Elmsford, N.Y.), says the program works well for his dismantling company. "Once you get a system down" for removing the switches, "it's pretty straightforward," he says.
As of Oct. 16, 2008, the ELVS database reported that Brookfield's employees had pulled 15,555 switches containing 34.2 pounds of mercury. Malone says buyers haven't asked him about participation, most likely because they use the ELVS Web site, although he says it's possible that some don't bother to check. One entity has been asking, though: the New York State Department of Environmental Conservation. The company wants to be "very proactive with the state" in positioning itself as a responsible steward of the environment, Malone says, and the data about his company's switch removal on the ELVS site strengthens its case. If the NVMSRP falls short of its goals, participants worry that state and federal governments could impose more burdensome regulations to control this source of mercury. •
Ann C. Logue is a Chicago-based writer.
| Canada's Switch Out Program
Steelmakers, scrap recyclers, and scrap brokers source their materials from around the globe. Contributing to their mercury control efforts is Canada's Switch Out program (www.switchout.ca), operated by the Clean Air Foundation. This voluntary, Toronto-based program for Canadian auto dismantlers and scrap recyclers is similar to the National Vehicle Mercury Switch Recovery Program, but it does not offer an incentive payment. Also, Switch Out requires the removal of ABS switches, but the NVMSRP does not. Leonard Shaw, executive director of the Canadian Association of Recycling Industries (Ottawa, Ontario), says he's pleased with the program’s results so far: It collected 200,935 switches from more than 660 recyclers between 2001 and the end of October 2008. Given that Canada has about one-tenth the number of cars as the United States, that collection rate is slightly higher than the NVMSRP. Unfortunately, the U.S. EPA does not yet recognize Switch Out as a pre-approved mercury reduction program under the June 2008 EAF area source emissions control rule, creating an extra burden on U.S. buyers of Canadian scrap. "We have to contact the Canadian shredders to get specific information about the removal of switches," says Chris Bedell, senior vice president and general counsel for The David J. Joseph Co. (Cincinnati), even if those companies are Switch Out participants. "They are removing switches in the same manner as the American recyclers," he says, but the EPA requires additional documentation. Steelmakers have asked the EPA to approve the Switch Out program and give it the same pre-approved status as the NVMSRP. |
Tighter mercury emissions regulations have put pressure on the automobile recycling chain—from steelmakers to scrap shredders to auto dismantlers—and a system designed to encourage the removal of vehicle mercury switches.