TO:	EPA Docket No. EPA-HQ-OAR-2006-0359

		

FROM:	Conrad Chin, EPA/SPPD 

DATE:	October 12, 2007

SUBJECT:	Teleconference with Foundry Industry Representatives on October
12, 2007, regarding EPA’s National Vehicle Mercury Switch Recovery
Program

I.	Participants

Foundry Representatives:

Christian Richter

Jeff Hannapel

Jeet Radia

EPA Representatives

Conrad Chin

Rhonda Minnick

EPA Contractor

Jeff Coburn

II.	Summary of Discussion

Representatives of the iron and steel foundry industry conducted a
conference call with EPA to discuss concerns with the mercury switch
removal requirements of the proposed iron and steel foundries area
source rule (72 FR 52984).  Conrad Chin introduced Rhonda Minnick, who
is EPA’s implementation coordinator of the National Vehicle Mercury
Switch Recovery Program.  Mr. Chin explained that the purpose of this
meeting was to afford representatives of the iron and steel foundry
industry an opportunity to explain their concerns directly to Ms.
Minnick.

Industry representatives indicated that many of the suppliers of the
area source foundries are not currently part of the National Vehicle
Mercury Switch Recovery Program.  As such, the industry representatives
believe that many area source foundries will be required to implement
burdensome, site-specific mercury switch removal plans.  Whereas large
iron and steel production facilities (“mini-mills”) have enough
purchasing power to force large suppliers to join the National Vehicle
Mercury Switch Recovery Program, smaller independent suppliers that
service the smaller foundries may be more reluctant to sign-up for the
program.  The small area source foundries may purchase scrap from many
different suppliers, and these small foundries do not have the buying
power to force the small, independent suppliers to join the National
Program.  The industry representatives also noted that the mercury
switch requirements, as proposed, pertains to all auto scrap not just to
“auto shred.”  Some types of auto scrap, such as engine blocks or
brake rotors, do not contain mercury switches and these types of scrap
should not be subject to the mercury switch removal requirements,
according to the industry representatives. 

According to the industry representatives, the scrap supply chain
includes the dismantlers (where mercury switch removal is most easily
carried out) and scrap processors (who may purchase from multiple
dismantlers and then shred the auto scrap for sale to foundries). 
Foundries may purchase directly from the scrap processor or they may
contact a scrap broker (who is a middle man who arranges scrap delivery
to the foundry from various suppliers/scrap processors).  There are many
dismantlers signed-up on the National Vehicle Mercury Switch Recovery
Program, but very few, if any, scrap processors or scrap brokers.  As
foundries do not purchase from the dismantlers, it is difficult to know
if they are receiving scrap from participants in the program, according
to the industry representatives.

The foundry representatives suggested that the implementation of the
mercury switch provision for the area source foundries be delayed to
allow more time for the National Vehicle Mercury Switch Recovery Program
to penetrate down to the smaller scrap suppliers.  As proposed, the
mercury switch requirement for iron and steel foundries becomes
effective one year after promulgation of the final rule.  Industry
representatives suggested that 3 years be allowed for the implementation
of the mercury switch removal requirements for the area source
foundries.

III.	Action Items

Rhonda Minnick stated that she would relay the foundries’ concerns to
her superiors and discuss with her superiors the potential impacts of a
delayed implementation schedule for iron and steel foundries on the
National Vehicle Mercury Switch Recovery Program.

Industry representatives agreed to continue to collect information from
scrap suppliers regarding the number of auto shred scrap suppliers used
by the foundries and the fraction of those suppliers that are currently
participants in the National Vehicle Mercury Switch Recovery Program.

A follow-up meeting will be scheduled to discuss the results of the
previous action items.

 

Meeting Minutes Memorandum – October 12, 2007, Foundries
Teleconference on the National Vehicle Mercury Switch Recovery Program

  PAGE  2 

Meeting Minutes Memorandum

