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									                     Clean Manufacturing and Pollution Prevention
                             Technical Assistance Report
 Indiana Department of Environmental Management                          Indiana Clean Manufacturing Technology & Safe Materials Institute
 Office of Pollution Prevention & Technical Assistance                   Purdue University
 800-988-7901                                                            765-463-4749
 www.in.gov/idem/oppta/                                                   www.ecn.purdue.edu/CMTI/



 May 10, 2004

 Company identification tag: SM2551
 Date of initial on-site technical assistance: 03/04/04
 Date of Completion of Pollution Prevention Opportunity Assessment: 04/23/04
 Company SIC code (3-digit): 344
 Manufacturing sector: Metal Products
 CMTI Process Engineer: Terry Gray

 Executive Summary

 The Indiana Clean Manufacturing Technology and Safe Materials Institute (CMTI) has identified one
 pollution prevention (P2) opportunity at the company, the replacement of aerosol paint cans with paint
 sticks. CMTI recommends that the company considers implementing this P2 opportunity. Additional
 details concerning this opportunity can be found in the body of this report.

              P2 Opportunity                         Savings        Capital                            Reductions
                                                   (dollars/yr.) Investment &          VOCs             HAPs      Haz. Waste
                                                                Implementation         (tons)           (tons)      (gal.)
                                                                     Costs
  1     Use paint sticks in place of                     $4,789             $30              0.15             0.07                  13.8
        aerosol cans

I. Description of Major Processes

 The major processes involved in the production of bar, rod, and tube steel stock includes:

          Oxy-Fuel Cutting. The two Oxy-fuel cutting units (burnies) use a mixture of natural gas and
           oxygen to cut steel stock. The units can also be operated in the plasma mode.

          Cutting and Sawing. Stock is cut to customer specifications in metalworking units.

          Color Coding. The company uses approximately 750 aerosol cans of paint to color code cut
           steel products. This allows employees and customers to identify the characteristics (type,
           grade, hardness) of the steel at a distance. The used aerosol containers are placed in a machine
           that punches a hole in the bottom and allows the paint residue to flow out into a collection
           container. The waste paint is managed as a hazardous waste and treated off-site.

 The company cuts approximately 6,500,000 pounds of steel a year.




                                                                                                                                        1
   Facility Process Map

                                                                                     VOC/HAP
                                                                                     Empty cans
      Combustion                  Spent                                              Paint waste
      air emissions            metalworking          VOC/HAP/PM
      Quench water                fluids
                                                      air emissions                      Out
        to sewers               Scrap steel

          Out                      Out                    Out                     Aerosol Can Puncturing


                                                                                          In
    Oxy-Fuel                   Cutting &              Color
                               Sawing                 Coding
    Cutting
                                                                                     Spent aerosol
                                                                                         cans
                                   In
          In                                               In
                                                                                       Product
                                                                                    Cut Steel Stock
      Steel Stock              Metalworking           Color Coding
                                  Fluids               Paint from
                                                      Aerosol Cans


II. Description of Air Emissions and Chemical Releases
   Combustion gases from the Oxy-Fuel Cutting is collected, filtered and returned to the plant air.
   Quench water from the process is collected and discharged to the sanitary sewer. Spent metalworking
   fluids from the cutting and sawing units are collected and transported to an off-site recycling facility.
   Scrap steel is collected and transported to an off-site facility for recycling. Volatile organic
   compounds (VOCs), hazardous air pollutants (HAPs), and particulate matter (PM) are released from
   the color coding and aerosol can puncturing operations into the plant air. VOCs released include
   propane, butane, ethylbenzene, xylene, and methyl ethyl ketone. The individual HAPs are
   ethylbenzene, xylene, and methyl ethyl ketone. The aerosol can puncturing operation also generates
   hazardous paint waste that is removed and treated off-site and empty aerosol cans are treated as solid
   wastes and removed with the scrap steel for off-site recycling.

III. Compliance Related Technical Assistance Provided
   Questions concerning storm water permits, universal waste, and industrial waste water disposal were
   addressed at the time of the site visit. The company is in the process of completing the “No Exposure”
   exclusion from storm water permitting form provided to them by the CMTI engineer. The company
   generates a small amount of spent fluorescent light bulbs. A copy of the Universal Waste Guidance
   Document was supplied to the company at the time of the site visit. Contact quench water from the
   clean out of the Oxy-Fuel Metal Cutters and waste water from the floor cleaning machines is disposed
   by pouring down a sanitary sewer. Any changes to the type of detergent used for floor cleaning should
   be directed to the local agency responsible for industrial waste water disposal. The Indiana
   Department of Environmental Management’s Compliance and Technical Assistance Program (CTAP)
   provides free and confidential compliance assistance to Indiana companies. If the company has
   additional questions concerning compliance related issues, please contact CTAP at (800) 988-7901.

IV. Clean Manufacturing and Pollution Prevention Opportunities
   The Clean Manufacturing & Pollution Prevention Opportunity Assessment revealed one opportunity
   for the company to reduce air emissions, hazardous waste generation, and operating costs:
                                                                                                               2
       1. Use Paint Sticks in Place of Aerosol Cans: Replace aerosol paint containers used for color
          coding of steel stock with a paint stick. The use of the paint sticks would completely
          eliminate VOC, HAP, and PM air emissions, hazardous waste paint generation, and the scrap
          aerosol can solid waste stream. CMTI located a company that manufactures paint sticks.
          According to the Material Safety Data Sheet (MSDS), the paint sticks have 0% VOCs
          pursuant to the Clean Air Act, Section 111 and is not hazardous pursuant to the OSHA
          Hazard Communication Standard of 29 CFR 1910.1200. The main ingredient is Linseed Oil
          and depending upon the color of the paint stick, varying amounts of carbon black, aluminum,
          copper and/or zinc. The only item of concern may be that waste or rags soaked in this
          substance may spontaneously combust if improperly discarded. Each paint stick is
          cylindrical, with a diameter of 11/16” and a length of 4-3/4”.
             a. Economic and Technical Feasibility. Potential savings in raw material costs resulting
                from the replacement of aerosol cans with paint sticks is estimated to be $4,720 per year.
                Note: This calculation is based on the use of one paint can used by the company as
                representative of all of the paints used. A 1:1 replacement ratio between a 12 oz. (by
                weight) aerosol can with one paint stick is also used. (e.g. one paint stick replaces one
                aerosol can). In addition, hazardous waste disposal costs will be reduced by
                approximately $69 per year, for a total potential annual savings of $4,789. The company
                may be required to provide a brief training session for employees on the proper use of
                the paint stick. This should be a minimal one time cost, estimated to be $30 maximum.
                See the attachment A for the specific calculations.

             b. Potential Environmental Impacts. Replacing the aerosol cans with the paint stick
                would potentially eliminate 0.15 tons of VOC emissions (propane, butane, ethylbenzene,
                xylene, and methyl ethyl ketone), 0.07 tons of total HAP emissions (ethylbenzene,
                xylene, and methyl ethyl ketone), and 56.4 lbs of PM emissions per year. This would
                also completely eliminate the purchase of, puncturing, and disposal of 750 aerosol cans
                per year. The generation of 13.8 gallons of hazardous waste paint per year from the can
                puncturing system would also be eliminated. See the attachment A for the specific
                calculations.

V. Recommendations
 The analysis performed by the Indiana Clean Manufacturing Technology and Safe Materials Institute
 (CMTI) revealed that the one opportunity identified at the company has an attractive payback period
 of less than one month, along with reductions in both costs and emissions. It is recommended that the
 company consider implementing the use of paint sticks in place of aerosol cans for the color coding of
 its products.

                                                 Economic Feasibility
  Opportunity                         Savings (dollars/yr.)   Capital Investment    Payback Period (yrs.)   Other start up costs
  1 Use paint sticks in place of                    $4,789                     $0                   0.008                      $30
      aerosol cans



                                          Potential Environmental Impacts
                                         VOCs (tons/yr.)                  HAPs (tons/yr.)              Haz. Waste (gal./yr.)
  Opportunity                      Before After Reduction        Before     After    Reduction    Before    After      Reduction
  1 Use paint sticks in place of      0.15  0.00         0.15      0.07      0.00         0.07      13.8       0.0           13.8
     aerosol cans


                                                                                                                               3
ATTACHMENTS

Calculations
Economic and Environmental Analysis
Pollution Prevention Opportunity Checklist
CTAP Brochure

PROVIDED ON-SITE

Sector Guide for Metal Products
CMTI Brochure




                                             4
                                                  Attachment A

Calculations

One Time Costs Related to Project:
Initial employee training costs           Assume $15/hour for 2 hours                              $30.00
Operational Costs Related to Project:
Raw material costs of material A,
aerosol paint, per pound (Before
Column)                                   $7.25/can X 1 can/12 oz. paint X 16 oz/lb. =              $9.67
Assume one paint stick replaces one
aerosol can

Operational Costs Related to Project:
Raw material costs of material A, paint
stick, per pound (After Column)           $0.96/paint stick X 1 paint stick/0.081 lbs =            $11.85
Operational Costs Related to Project:
Raw material usage of material A,
aerosol paint, pounds/month (Before
Column)                                   62.5 cans/mo. X 0.75 lbs/can =                            47.00
Operational Costs Related to Project:
Raw material usage of material A,
paint in paint stick, pounds/month
(After Column)                            62.5 paint sticks/mo. X 0.081 lbs/paint stick =            5.00
Air Emissions Table: Pounds of VOCs
emitted per pound of material A used      Per MSDS, aerosol paint is 51.76% Volatile (w/w less
(Before)                                  water and exempt solvents)                                 0.52
Air Emissions Table: Pounds of VOCs
emitted per pound of material A used
(After)                                   Per MSDS, paint stick has no air VOCs                      0.00
Air Emissions Table: Pounds of total      Per MSDS, aerosol paint has the following HAPs:
HAPs emitted per pound of material A      Ethylbenzene: 2%, Xylene: 9%, and MEK: 13% for
used (Before)                             total HAP percentage of 24%, w/w                           0.24
Air Emissions Table: Pounds of total
HAPs emitted per pound of material A
used (After)                              Per MSDS, paint stick has no HAPs                          0.00
Air Emissions Table: Pounds of PM         Assuming that the paint is 20% solids by weight, then
emitted per pound of material A used      0.2 lbs of solids is contained in each pound of paint.
(Before)                                  Assume 50% transfer efficiency                             0.10
Air Emissions Table: Pounds of PM
emitted per pound of material A used
(After)                                   Assume the paint stick releases no PM to air               0.00




                                                                                                            5
                                                                                               Attachment B

Economic and Environmental Analysis
Company ID: SM2551
Project Number:

One Time Costs Related to Project
Cost of new equipment                                                                      $0.00
Installation costs (outside engineering & labor)                                           $0.00
Installation costs (in-house engineering & labor)                                          $0.00
Cost of installation related materials                                                     $0.00
Cost of down time during installation                                                      $0.00
Cost of removal/disposal of old equipment                                                  $0.00
Less cash received from sale of old equipment                                              $0.00
Required permit revisions (consultant fees)                                                $0.00
Required permit revisions (in-house labor)                                                 $0.00
Required permit revisions (permit revision fees)                                           $0.00
Initial employee training costs                                                           $30.00
Less tax credits                                                                           $0.00
Less grants received                                                                       $0.00                          Total One Time Costs                               $30.00 A

Operational Costs Related to Project                                                   Before      After      Savings
Raw material costs (per pound or per gallon) Material A                                    $9.67     $11.85       ($2.18)
Raw material usage (pounds, gallons)(per month) Material A                                    47          5           42
Raw material costs (per pound or per gallon) Material B                                    $0.00      $0.00        $0.00
Raw material usage (pounds, gallons)(per month) Material B                                     0          0            0
Raw material costs (per pound or per gallon) Material C                                    $0.00      $0.00        $0.00
Raw material usage (per month) Material C                                                      0          0            0 Savings in Material Usage Costs (per month)        $393.32
Labor costs (for operation only)(per month)                                                $0.00      $0.00        $0.00
Equipment maintenance costs (outside labor)(per month)                                     $0.00      $0.00        $0.00
Equipment maintenance costs (in-house labor)(per month)                                    $0.00      $0.00        $0.00
Equipment maintenance costs (parts)(per month)                                             $0.00      $0.00        $0.00
Employee training costs (per month)                                                        $0.00      $0.00        $0.00
Electricity usage costs (per month)                                                        $0.00      $0.00        $0.00
Natural gas usage costs (per month)                                                        $0.00      $0.00        $0.00
Water usage costs (per month)                                                              $0.00      $0.00        $0.00
Waste water discharge fees (per month)                                                     $0.00      $0.00        $0.00
Non-hazardous waste disposal costs (per month)                                             $0.00      $0.00        $0.00
Hazardous waste disposal costs (per month)                                                 $5.73      $0.00        $5.73
Other costs (e.g., personal protective equipment, hygiene testing, etc.) (per month)       $0.00      $0.00        $0.00 Total Savings in Operational Costs (per month)     $399.05 B

Regulatory Costs Related to Project                                                    Before      After      Savings
Air permit fees (per year)                                                                 $0.00      $0.00       $0.00   Savings in air permit fees (per month)              $0.00
Air permit recordkeeping and reporting cost (in-house labor)( per month)                   $0.00      $0.00       $0.00
Annual hazardous waste fees (per year)                                                     $0.00      $0.00       $0.00   Savings in hazardous waste fees (per month)         $0.00
Hazardous waste recordkeeping and reporting cost (in-house labor)( per month)              $0.00      $0.00       $0.00
Waste water permit fees (per year)                                                         $0.00      $0.00       $0.00   Savings in waste water permit fees (per month)      $0.00
Waste water permit recordkeeping and reporting cost (in-house labor)( per month)           $0.00      $0.00       $0.00   Total Savings in Regulatory Costs (per month)       $0.00 C

                                                                                                                          Pay Back Period (months)                              0.1 A/(B+C)

                                                                                                                          Annual Savings (Post Pay Back Period)            $4,788.60 (B+C)*12




                                                                                                                                                                                              6
                                                                             Attachment B

Economic and Environmental Analysis
                                                                           Before      After       Reduction
Pounds of VOCs emitted per pound or gallon of material used - Material A        0.52       0.00          0.52   VOC Reduction (pounds per month)                24.26
Pounds of HAPs emitted per pound or gallon of material used - Material A        0.24       0.00          0.24   HAP Reduction (pounds per month)                11.25
Pounds of PM emitted per pound or gallon of material used - Material A          0.03       0.00          0.03   PM Reduction (pounds per month)                  1.41
Pounds of SO2 emitted per pound or gallon of material used - Material A         0.00       0.00          0.00   SO2 Reduction (pounds per month)                 0.00
Pounds of NOx emitted per pound or gallon of material used - Material A         0.00       0.00          0.00   NOx Reduction (pounds per month)                 0.00
Pounds of CO emitted per pound or gallon of material used - Material A          0.00       0.00          0.00   CO Reduction (pounds per month)                  0.00
Pounds of Pb emitted per pound or gallon of material used - Material A          0.00       0.00          0.00   Pb Reduction (pounds per month)                  0.00
Pounds of VOCs emitted per pound or gallon of material used - Material B        0.00       0.00          0.00   VOC Reduction (pounds per month)                 0.00
Pounds of HAPs emitted per pound or gallon of material used - Material B        0.00       0.00          0.00   HAP Reduction (pounds per month)                 0.00
Pounds of PM emitted per pound or gallon of material used - Material B          0.00       0.00          0.00   PM Reduction (pounds per month)                  0.00
Pounds of SO2 emitted per pound or gallon of material used - Material B         0.00       0.00          0.00   SO2 Reduction (pounds per month)                 0.00
Pounds of NOx emitted per pound or gallon of material used - Material B         0.00       0.00          0.00   NOx Reduction (pounds per month)                 0.00
Pounds of CO emitted per pound or gallon of material used - Material B          0.00       0.00          0.00   CO Reduction (pounds per month)                  0.00
Pounds of Pb emitted per pound or gallon of material used - Material B          0.00       0.00          0.00   Pb Reduction (pounds per month)                  0.00
Pounds of VOCs emitted per pound or gallon of material used - Material C        0.00       0.00          0.00   VOC Reduction (pounds per month)                 0.00
Pounds of HAPs emitted per pound or gallon of material used - Material C        0.00       0.00          0.00   HAP Reduction (pounds per month)                 0.00
Pounds of PM emitted per pound or gallon of material used - Material C          0.00       0.00          0.00   PM Reduction (pounds per month)                  0.00
Pounds of SO2 emitted per pound or gallon of material used - Material C         0.00       0.00          0.00   SO2 Reduction (pounds per month)                 0.00
Pounds of NOx emitted per pound or gallon of material used - Material C         0.00       0.00          0.00   NOx Reduction (pounds per month)                 0.00
Pounds of CO emitted per pound or gallon of material used - Material C          0.00       0.00          0.00   CO Reduction (pounds per month)                  0.00
Pounds of Pb emitted per pound or gallon of material used - Material C          0.00       0.00          0.00   Pb Reduction (pounds per month)                  0.00
                                                                                                                Total VOC Reduction (tons per year)              0.15
                                                                                                                Total HAP Reduction (tons per year)              0.07
                                                                                                                Total PM Reduction (tons per year)               0.01
                                                                                                                Total SO2 Reduction (tons per year)              0.00
                                                                                                                Total NOx Reduction (tons per year)              0.00
                                                                                                                Total CO Reduction (tons per year)               0.00
                                                                                                                Total Pb Reduction (tons per year)               0.00


                                                                           Before      After
Electricity cost per Kw hours (per month)                                      $0.00      $0.00   Total Reduction in Electricity (Kw hours per year)       #DIV/0!
Natural gas cost per ccf (per month)                                           $0.00      $0.00   Total Reduction in natural gas (ccf per year)            #DIV/0!
Water cost per gallon (per month)                                              $0.00      $0.00   Total Reduction in water usage (gallons per year)        #DIV/0!
Waste water cost per gallon (per month)                                        $0.00      $0.00   Total Reduction in waste water (gallons per year)        #DIV/0!
Non-hazardous waste cost per ton (per month)                                   $0.00      $0.00   Total Reduction in non-hazardous waste (tons per year)   #DIV/0!
Hazardous waste cost per gallon (per month)                                    $5.00      $5.00   Total Reduction in hazardous waste (gallons per year)          13.75




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