### 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

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### 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 ' t Dry Wire Drawing I 1 st Dry Wire Drawing 2 11 Dry Wire Drawing H eat 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 st draw 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 n0 drawing 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 <J FS America> 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

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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.

1S T 

### 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.

1S T 

### 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

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### 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

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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 2 n d 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 HC HCl.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

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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. H2SO 4 Electroclean [4 units] Non-contact steam heated bath. Wire contact with H2SO 4 . 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 ?? gpdEquipment 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

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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