June 8, 2010 

Todd D. Ramaly 

RCRA Program Section- Environmental Scientist 

U.S. EPA- Region 5 

77 West Jackson Boulevard 

Mail Code: LR-8J 

Chicago, IL 60604 

Dear Mr. Ramaly. 

As previously noted in the letter sent to you April 22, 2010, Tokusen U.S.A.., Inc Scottsburg 

<,IFS America> is seeking a name change on the ASC delisting of the F006 sludge. In our 

conversation, you expressed concern regarding the amount of shut down time in which the 

facility was closed and the apparent changes in process. Please consider the following 

information in regards to making a decision on the name change. 

Please note that all processes are essentially the same as when the facility was purchased. 

Tokusen has taken steps to renovate, update, and improve a significant amount of the equipment. 

Areas contributing to the wastewater treatment operation have not changed. The attached draft 

-Process Description" details the waste water contributions. Flow rates have yet to be 

determined. The constituents of concern are the same, although brand names have changed. 

Tire cord and saw wire are brass coated carbon steel wire. Brass coated steel wire products 

utilize the same starting material and processes. The difference is that tire cord utilizes larger 

diameter filaments that are stranded together where as saw wire is a fine single filament wire. 

TIRE CORD VS SAW WIRE 

Operation of lire Cord Facility Operation of Saw Wire Facility 

Wire Rod Pickling/Zinc Phosphate Coating Wire Rod Pickling /Zinc Phosphate Coating 

I 'tDry Wire Drawing I 1 stDry Wire Drawing 

2 11Dry Wire Drawing Heat Treatment (Patenting) 

Heat Treatment (Patenting) Zinc Phosphate Coating 

Brass Plating 2nd Dry Wire Drawing 

L Wet Draw Heat Treatment (Patenting) 
Stranding 1 I Brass Plating 

LWet Draw 

STEEL ROD PREPARATION (PICKLING) TIRE CORD AND SAW WIRE 

Tire cord and saw wire use the same starting material - carbon steel wire rod. The steel rod 

arrives at the facility coiled on rolls that weigh approximately two (2) metric tons. The rod is 

cleaned in a hydrochloric acid bath to remove mill scale and rust. After rinsing, the coil is coated 

with a zinc phosphate surface treatment for preservation and lubrication. The zinc phosphate 

surface treatment has several brand names depending on the manufacturer of the product. The 

initial delisting petition mentions this as a "bonder -. This step of the operation is the same for 

tire cord and saw wire. 

DRY DRAW 

The cleaned rod is reduced in diameter by a cold-forming process, which draws the rod through 

progressively smaller dies to produce an intermediate material of a specified diameter. To 

facilitate the drawing process, a dry powdered lubricant is applied to the wire as it passes through 

each die. 

Tire Cord Dry Draw: The ASC facility used two dry draw operations to achieve the necessary 

diameter reduction. This was conducted in a series. As wire came off the 1st operation. it was 

taken up on a spool and loaded onto a second drawing operation. Wire was then moved to the 

patenting ovens for heat treatment. 

Saw Wire: Due to saw wire being a fine single filament wire that is drawn to smaller diameter 

than tire cord, additional steps must be taken in the process. The 1 stdraw is followed by a heat 

treat (patenting) operation to improve the draw ability of the wire. As mentioned above, a zinc 

phosphate coating is needed to act as a protector and a lube carrier. Tokusen has renovated (»le 

the four brass plating lines into an in-line zinc phosphate line. The in-line zinc phosphate is 

essentially the same as the dip tank in the pickling operation. The wire is spooled up and 

returned to Dry Drawing for the 2 n0drawing operation. 

HEAT TREATMENT (PATENTING) 

A heat treatment process is required to restore the malleability of the cold drawn wire, and make 

it suitable for further drawing. Multiple lines of wire are pulled through a furnace to anneal the 

wire prior to quenching. Each furnace burns natural gas, and recovers waste heat via a 

recuperator. The natural gas combustion products are discharged to the atmosphere as emission 

sources. 

Differenceill this operation is that saw wire wvill go through the heat treatment proceWetwice. 
IN-LINE ZINC PHOSPHATE AND BRASS PLATING 

ASE' operation had tour (4) plating lines after the heat treat operation. As wire came out of the 

furnace, it continued into an acid clean, caustic clean, copper plating, zinc plating, and a diffuser 

(allows the copper to migrate into the zinc laver to create brass). 

TOKUSEN U.S.A., Inc. Scottsburg <JFSAmerica> has renovated one of the brass plating lines 

into an in-line zinc phosphate line. The annealed wire continues from the heat treatment into the 

in-line zinc phosphate line. This operation is essentially the same as the pickling operation 

except that it is an in-line operation compared to a dip tank operation. 

The remaining three Brass Plating lines are the same as the original lines in the delisting petition. 

WET DRAW 

Brass plated wire is transported to Wet Draw area. The wire is loaded on the Wet Drawing 

machines where it is drawn through a series of dies that are submerged in a liquid lubricant. The 

lubricant is circulated from the central pit to each drawing machine and returned to the tank. The 

Wet Draw operation does not contribute to the waste water operation. 

For Saw Wire, this is the final operation and the drawn wire filament is transported to the 

Packaging area. 

For tire cord, the wire is sent to the stranding operation where smaller diameter wire is twisted 

together to form a wire cord. 

WASTE WATER TREATMENT 

All diluted rinse waters and some waste acid and waste caustic are sent to the waste water 

treatment plant. The constituents of concern in this type of operation are the heavy metals 

dissolved in solution. In this case it is the dissolved iron, copper, and zinc. The most common 

method for heavy metal removal is to adjust the pH using lime and/or caustic soda in order to 

precipitate out the metal hydroxide. The precipitant is then dewatered through a filter press. 

This is the same approach taken in the original delisting and what is currently employed at the 

Scottsburg facility. 

CONCLUSION 

Brass coated carbon steel wire has many product names that share the same processes. Tire cord 

and saw wire fiIU into this category. The only differences being the additional heat treatment and 

in-line zinc phosphate operation. 
The constituents of concern do not change between a Saw wire and - lire cord operation. Process 

chemistries will not change although chemical manufactures and brand names may. The 

additional zinc phosphate on the in-line phosphate line should offset the copper and zinc treated 

from the renovated plating line. Copper plating remains a non-cyanide alkaline copper mixture 

of cupric pyrophosphate 

TOKUSEN U.S.A., Inc. Scottsburg <JFS America > proposes having a verification period in 

which a -to be determined- number of roll offs are sampled, tested, and the results submitted to 

Region 5 EPA and the State of Indiana. When the verification period has been satisfactorily 

completed then the current delisting can be resumed. 

Thank you for your time and if you have any questions please contact me at (501) 327-6800 ext. 

474 or email at dvarherry @ 

Signature 

David Yarberry 

Environmental Engineer 

TOKUSEN U.S.A., Inc 
DRAFT 

TOKUSEN U.S.A., Inc. Scottsburg <JFS America> 

PROCESS DESCRIPTION 

Tokusen USA, Inc. owns and operates a saw wire manufacturing facility. The wire is 

used for cutting silicon ingots. The operating process for the facility is described below. 

PICKLING 

Raw wire rod material is brought to Tokusen by truck, and is staged for processing in 

the Rod Warehouse. As required by production schedules, the coils of rod are cleaned in 

a hydrochloric acid solution, and coated with a zinc phosphate surface treatment for 

preservation and lubrication. A wet scrubber collects and cleans vapors from the acid 

tanks in the pickling process, and discharge to the atmosphere as emission point source. 

1ST DRY DRAW 

The cleaned rod is reduced in diameter by a cold-forming process, which draws the rod 

through progressively smaller dies to produce an intermediate material of a specified 

diameter. To facilitate the drawing process, a dry powdered lubricant is applied to the 

wire as it passes through each die. 

1ST PATENTING 

Just prior to entering the patenting furnace, the wire is passed through a liquid cleaning 

bath to remove residual drawing lubricant. Then a heat transfer treatment process is 

required to restore the malleability of the cold drawn wire, and make it suitable for 

further drawing. Multiple lines of wire are pulled through a furnace to anneal the wire 

prior to quenching. Each furnace burns natural gas, and recovers waste heat via a 

recuperator. The natural gas combustion products are discharged to the atmosphere as 

emission sources. 

A controlled cooling process follows the furnaces called a fluidized sand bed. This unit 

controls the cooling temperature of the wire with a natural gas heated volume of zircon 

sand. The sand is "fluidized" by the injection of high volumes of air. At the same time, 

natural gas burners maintain the sand temperature. The combined discharge of the air 

injection and the natural gas combustion is filtered by a mechanical screen filter for 

particulate removal. 

IN-LINE PHOSPHATING 

The heat treated wire is conducted through an inline pickling and zinc phosphate 

treatment for preservation and lubrication. A wet scrubber collects and clean vapors 

from the sulfuric acid tanks in the pickling process. The scrubber is continuously 

overflowed with water. The water continuously flows to wastewater treatment. 
DRAFT 

2ND DRY DRAW 

The cleaned rod is reduced in diameter by a cold-forming process, which draws the rod 

through progressively smaller dies to produce an intermediate material of a specified 

diameter. To facilitate the drawing process, a dry powdered lubricant is applied to the 

wire as it passes through each die. 

2ND PATENTING 

A heat transfer treatment process is required to restore the malleability of the cold 

drawn wire, and make it suitable for further drawing. Multiple lines of wire are pulled 

through a furnace to anneal the wire prior to quenching. Each furnace burns natural 

gas, and recovers waste heat via a recuperator. The natural gas combustion products are 

discharged to the atmosphere as emission sources. 

A controlled cooling process follows the furnaces called a fluidized sand bed. This unit 

controls the cooling temperature of the wire with a natural gas heated volume of zircon 

sand. The sand is "fluidized" by the injection of high volumes of air. At the same time, 

natural gas burners maintain the sand temperature. The combined discharge of the air 

injection and the natural gas combustion is filtered by a mechanical screen filter for 

particulate removal. 

BRASS PLATING 

The final process in the P&B operation is electroplating the wire with a layer of brass. 

The plating process is conventional electroplating including sulfuric acid cleaner, rinse, 

sodium hydroxide etch, rinse, alkaline copper plating, rinse, acid zinc plating, rinse, 

thermal diffusion, phosphoric acid finisher, rinse, and vacuum dryer. 

The thermal diffusion process employees another fluidized bed similar to the patenting 

process. Once again, natural gas is used to heat a volume of zircon sand. The sand is 

fluidized by injection of high volumes of air. This hot bed of sand is used to form the 

"brass" by thermal diffusion of the copper and zinc. 

A wet scrubber collects and cleans the vapors from the sulfuric acid baths in the cleaning 

process. The scrubber is continuously overflowed with water. The water continuously 

flows to wastewater treatment. 

WET DRAWING 

Brass Plated wire from the P&B Area is transported to the Wet Drawing. The wire is 

loaded on the Wet Drawing machine where it is drawn through a series of dies that are 

submerged in a liquid lubricant. The lubricant is circulated from the central pit to each 

drawing machine and returned to the tank. The drawn wire filament is transported to 

the Packaging area. 

2 
DRAFT 

COOLING TOWERS 

The facility utilizes (2) cooling towers for the purposes of cooling process water for 

reuse. Particulate emissions are generated from these towers as dissolved particles are 

emitted to the atmosphere with the evaporating water. These towers are used as follows: 

Tower #1 is used to cool the equipment and drawing dies in the 1st and 2nd Dry 

Drawing Operation. Tower #2 is used to cool process liquids in the Brass Plating and 

Wet Drawing process. This cooling is accomplish via in-direct cooling (heat exchanger) 

Total cooling water flow to all towers is approximately (2000) gallons per minute (gpm). 

AREAS CONTRIBUTING WASTE WATER 

The primary process operations which contribute rinse water to the on-site WWTP are 

hydrochloric acid pickling, wire patenting, and brass electroplating. The individual 

sources of wastewater from these process operations include the following: 

• Spent acid and rinse water from hydrochloric acid pickling and phosphate 

coating; 

• Rinse water from preheating and cooling baths at the two wire patenting 

furnaces; 

• Rinse water from one inline pickling and zinc phosphating line; 

• Rinse water from three inline brass electroplating lines, including alkaline 

copper and acid zinc solutions, and sulfuric acid, sodium hydroxide, and 

phosphoric acid bath discharges; 

• Water from one hydrochloric acid and one sulfuric acid scrubber; and 

Process operations that follow the electroplating lines (Wet Draw) do not contribute 

wastewater to the WWTP. In addition, all boiler and sanitary wastewater from the 

facility is discharged directly to the municipal sanitary sewer system operated by the 

City of Scottsburg. A plant diagram showing the location of each process area is 

presented on GF-10000. 

Equipment Descriptions and Operating Ranges HP 

Tokusen USA, Inc., Scottsburg, Indiana 

Equipment Description Operating Range of 

Process Equipment Contributing to 

WWTP 

1. HCHCIickling Wire contacted with HCHCl.ome 

HCHClarried on wire, some 

evaporated to scrubber. 

Periodic discharge to holding tank in 

WWTP (approximately (?) gals. every 

(??) days). Minimal contribution to 

WWTP (<100 gals. per month); 

remaining volume shipped off-site as 

spent FeC12 solution. 

2. Water Rinse Used to rinse HCHCl fm wire. Discharge to WWTP at (??) gpd 

3. Zinc Phosphate Heated Zinc Phosphate solution 

deposits crystalline coating from 

wire. Some carried on wire. 

No discharge 

4. Water Rinse Used to rinse Zinc Phosphate Discharge to WWTP at (??) gpd 

3 
DRAFT 

from wire. 

5. Neutralizer Heated Sodium Nitrite solution 

neutralizes acidic zinc phosphate. 

No discharge 

6. Scrubbers Used to scrub vapors evaporated 

from HCI baths. 

Scrubber HP-1: (??) gpd 

Equipment Descriptions and Operating Ranges 

Plating Lines BP-1, BP-2, BP-3 ,and BP-4 

Tokusen USA, Inc., Scottsburg, Indiana 

Equipment Description Operating Range of Process 

Equipment Contributing to WWTP 

1. Pre-Furnace Rinse 

(2) units 

Steam-heated water bath to 

remove DD drawing lubricant 

from wire. 

BP-1/2 rinse: ?? gpd 

BP-3/4 rinse: ?? gpd 

2. Post Furnace Rinse 

(2) units 

City water bath to reduce 

heated wire to >150 deg F. 

BP-1/2 rinse: ?? gpd 

BP-3/4 rinse: ?? gpd 

3. Fluidized Bed Wire is passed through a bed 

of air-floated zircon sand for 

quenching, to set 

microstructure of wire. 

No cooling water on the fluidized 

bed. 

4. H2SO4Electroclean 

[4 units] 

Non-contact steam heated 

bath. Wire contact with 

H2SO4 . Some acid carried on 

wire, some evaporated to 

scrubber. 

As-needed the spent acid is gravity 

feed to a waste acid pit (lift station). 

Solids are settled and liquid is 

pumped to waste acid tank in 

WWTP. 

5. Water Rinse [4 units] Used to rinse H2SO4 from 

wire. 

Discharge to WWTP at ?? gpd 

6. NaOH Electroclean 

[4 units] 

Ambient temperature bath. 

Wire contact with NaOH. 

Some caustic carried on wire, 

some evaporated to scrubber. 

As-needed the spent caustic is 

gravity feed to waste caustic pit (lift 

station). Solids are settled and 

liquid is pumped to waste caustic 

tank in WWTP. 

7. Water Rinse [4 units] Used to rinse NaOH from 

wire. 

Discharge to WWTP ?? gpd 

8. Scrubbers [2 units] Used to scrub acid vapors and 

mists from baths. 

Discharge to WWTP at ?? gpd 

9. Copper Electroplating 

[3 units] 

Alkaline Copper plating 

solution deposits metallic 

copper on wire. 

No discharge. 

10. Water Rinse [3 units] Used to rinse copper solution 

from wire. 

Discharge to WWTP at ?? gpd 

11. Zinc Phosphating 

[1 unit] 

Heated Zinc Phosphate solution 

deposits crystalline coating from 

wire. Some carried on wire. 

No discharge. 

12. Water Rinse [1 units] Used to rinse zinc phosphate 

solution from wire. 

Discharge to WWTP at ?? gpd 

13. Zinc Electroplating 

[4 units] 

Acid Zinc plating solution 

deposits metallic zinc on wire. 

No discharge 

14. Water Rinse [4 units] Used to rinse zinc solution 

from wire. 

Discharge to WWTP at ?? gpd 
Equipment Descriptions and Operating Ranges 

Plating Lines BP-1, BP-2, BP-3 ,and BP-4 

Tokusen USA, Inc., Scottsburg, Indiana 

15. Phosphoric Acid Rinse 

[4 units] 

Used to remove diffusion 

scale from wire. 

Discharge to WWTP at ?? gpd 

DRAFT 

WASTE WATER TREATMENT OPERATION 

CONTINUOUS FLOW SYSTEM 

Continuous flow systems such as the rinse tanks and scrubber overflows are collected at 

lift stations and pumped to the Equalization Tanks in the Waste Water Treatment Plant 

(WWTP). 

CONCENTRATED SOLUTIONS 

The acid and caustic electrocleaning conducted on the brass plating lines are designed to 

remove scale developed during the patenting (heating) operation and to provide for a 

clean surface for the copper and zinc plating to adhere to. During this operation, the 

acid and caustic baths increase substantially in both dissolved and un-dissolved iron 

compounds. The caustic material is metered directly into the continuous flow system 

Acid is designated a spent product and may be shipped offsite as beneficial reuse. 

PLATING LINE CONTAINMENT 

Collection sumps are under each area of the plating lines. The sumps are designed to 

catch leaks and wash down water from the lines. The sumps are periodically pumped to 

the rinse water lift station. 

WASTE WATER EQUIPMENT 

WWTP Equipment Descriptions and Operating Ranges 

Tokusen USA, Inc., 

Conway, Arkansas 

Tanks Process Description Operation Range 

1. T-27 & 28 

Main Rinse Water Collection 

Tanks 

Equalization tanks receive waste rinse 

waters from Pickling, Patenting, and 

Plating processes. 

12,500 gallon fiberglass tanks 

2. T-29 

Outside Extra Rinse Water 

Collection Tank 

Overflow / Emergency holding tank. 25,500 gallon double 

contained tank 

4. T-26 Lime Slurry Tank Storage tank for Lime Slurry. 7,500 gallon tank 

5 
DRAFT 

WWTP Equipment Descriptions and Operating Ranges 

Tokusen USA, Inc., 

Conway, Arkansas 

5. T-31 Reactor Tank Mixing tank for pH adjustment 4,300 gallon tank 

6. T-30 Clarifier Clarifier for solids removal 1,200 gallon Lamella Clarifier 

7. T-24 & 25 Sludge Thickening 

Tanks 

Collection tank for solids blow down 

from clarifier. 

15,000 gallon tanks 

8. T-33 Final pH Adjust Tank Mixing tank for final pH adjust. 1,100 gallon steel tank 

Dewatering Equipment Process Description Operating Range 

9. Filter Press Dewatering process sludge. 50 Cubic Foot capacity