Comment submitted by Michael Aucott, New Jersey Department of Environmental Protection

Document ID: EPA-HQ-OPPT-2005-0036-0023
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: September 08 2006, at 03:08 PM Eastern Daylight Time
Date Posted: September 13 2006, at 12:00 AM Eastern Standard Time
Comment Start Date: July 11 2006, at 09:43 AM Eastern Standard Time
Comment Due Date: September 11 2006, at 11:59 PM Eastern Standard Time
Tracking Number: 801c8e31
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Thank your for the opportunity to comment. A correction is recommended to a statement made on page 39041 of Federal Register/Vol 71, No. 132/Tuesday July 11, 2006/Proposed Rules. This statement, in the first column, in section E., of that page is "The mercury content of mercury switches varied from 0.7 to 1.5 grams, with an average of 0.8 grams per switch." As part of research conducted by the New Jersey Department of Environmental Protection Division of Science, Research & Technology, approximately 600 mercury switches, or "bullets" removed from motor vehicles were examined. It was found that there were three types of switches, which differed slightly in appearance and weight. Three switches of each type were cut open and the mercury weighed. Switch type 1 contained a mean of 1.25 +/- 0.1 grams mercury. Switch type 2 contained a mean of 0.80 +/- 0.04 grams mercury. Switch type 3 contained a mean of 1.55 +/- 0.03 grams mercury. A weighted average was calculated of all three types, taking into consideration the different numbers of switches of each type. The weighted average of mercury content of all switches was found to be approximately 1.2 grams. Based on these data, the value of 0.8 grams noted in the Proposed Rule is incorrect. The 1.2 gram average value is referenced on page i of Mercury Switch Data Collection Pilot Project: Final Report, March, 2004, which is available at http://www.state.nj.us/dep/dsr/hg-switch/ Michael Aucott, NJDEP, September 8, 2006

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