FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
1
of
40
Electrical
and
Electronic
Components
(
40
CFR
469)
Detailed
Investigation
for
2004/
2005
Planning
Process
Executive
Summary
During
the
Screening
Level
Review
phase
of
the
2004/
2005
planning
process,
electrical
and
electronic
components
was
one
of
eight
industrial
categories
identified
solely
through
Factor
4
concerns.
Issues
driving
the
concerns
include:
1)
significant
process
changes
resulting
in
changes
in
the
typical
pollutants
discharged,
including
a
shift
from
aluminum
to
copper,
and
2)
confusion
over
applicability
with
effluent
guidelines
for
metal
finishing.
Based
on
information
reported
to
the
Toxic
Release
Inventory
(
TRI)
and
the
Permit
Compliance
System
(
PCS),
toxic
discharges
from
electrical
and
electronic
component
facilities
are
low
relative
to
other
industrial
categories.
In
addition,
generally,
a
few
facilities
drive
the
toxic
weighted
pound
equivalent
(
TWPE)
loading
estimates
from
both
TRI
and
PCS.

The
information
in
the
record
at
this
time
does
not
support
a
decision
to
revise
these
effluent
guidelines.
In
the
event
that
stakeholders
provide
additional
data
and
supporting
information
during
subsequent
review
cycles,
EPA
will
reevaluate
them
at
that
time.
In
the
absence
of
revisions
to
the
effluent
guidelines,
these
concerns
could
be
addressed
through
improved
information
dissemination
and
outreach
by
EPA.
The
Agency
could
prepare
a
fact
sheet
with
answers
to
these
and
other
frequently
asked
questions
(
FAQs),
including
a
table
of
potentially
overlapping
guidelines
and
specifically
discussing
the
copper
discharge
and
treatment
information.
The
fact
sheet
could
also
include
the
names
of
current
contacts
within
EPA's
Office
of
Water.
The
Agency
could
announce
the
availability
of
this
fact
sheet
at
the
regular
meetings
for
permit
writers
and
pretreatment
coordinators
held
by
the
Office
of
Wastewater
Management
(
OWM),
and
through
internet
postings
and
email
alerts
to
the
Engineering
and
Analysis
Division
(
EAD)
stakeholders
mailing
list.
Finally,
due
to
the
relatively
small
number
of
facilities
discharging
the
bulk
of
the
TWPE,
EPA
could
also
provide
assistance
to
permit
writers
in
preparing
BPJ­
based
permits.

Overview
This
report
presents
information
for
the
following
topics:
Background
Industry
and
Related
Subcategories
Wastewater
Characteristics
and
Pollutant
Sources
Pollutants
Discharged
Treatment
Technology
and
Pollution
Prevention
Concerns
Identified
Pre­
Proposal
Concerns
Identified
in
Comments
to
Proposal
Followup
Contacts
Possible
Solutions
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
2
of
40
Attachments
provide
the
following
supporting
information:
EPA
Databases
and
References
Used
in
this
Review
Point
Source
Categories
Identified
Solely
Through
Factor
4
Guidelines
Applicability
and
Regulatory
History
PCS
Discharges
TRI
Discharges
Reported
Pollutant
Loadings
Permitting
Guidance
for
Semiconductor
Manufacturing
Facilities
Background
In
preparation
for
proposing
the
Preliminary
Effluent
Guidelines
Program
Plan
for
2004/
2005
("
Preliminary
Plan,"
published
in
February
2004),
EPA
analyzed
four
factors
identified
in
the
draft
"
National
Strategy
for
Industrial
Clean
Water"(
Edocket
OW­
2003­
0074­
0215).
See
Attachment
A
for
more
background
about
the
304(
m)
planning
Process.
The
four
factors
focus
on:
1
Potential
impacts
to
human
health
and
the
environment.
Preliminary
results
are
summarized
in
the
"
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0410).
2
Identification
of
an
applicable
and
demonstrated
technology,
process
change,
or
pollution
prevention
alternative
that
can
effectively
reduce
pollutants
discharged.
Preliminary
results
are
summarized
in
the
"
Factor
2
Analysis:
Technology
Advances
and
Process
Changes
 
Status
of
Screening
Level
Review
Phase."
(
Edocket
OW­
2003­
0074­
0287).
3
Evaluation
of
the
cost,
performance,
and
affordability
of
the
technology,
process
change,
or
pollution
prevention
measures
identified
using
the
second
factor.
4
Implementation
and
efficiency
concerns.
Preliminary
results
are
presented
in
the
"
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0329)

When
all
of
the
results
were
integrated
prior
to
proposing
the
Preliminary
Plan,
EPA
determined
that
8
point
source
categories
with
existing
effluent
guidelines
had
been
identified
solely
through
Factor
4
concerns.
(
See
list
in
the
Attachment
B.)
In
order
to
determine
the
best
course
of
action
to
address
these
concerns,
EPA
performed
an
analysis
of
issues
and
potential
solutions
for
each
of
the
8
categories.
The
results
of
that
analysis
for
Electrical
and
Electronic
Components
are
presented
in
this
report.

Industry
and
Related
Subcategories
The
Electrical
and
Electronic
Components
point
source
category
is
regulated
at
40
CFR
Part
469.
See
Attachment
C
for
the
applicability
and
regulatory
background.
This
point
source
category
includes
facilities
reporting
under
Standard
Industrial
Classification
(
SIC)
major
group
36,
Electronic
and
Other
Electrical
Equipment
and
Components,
Except
Computer
Equipment.
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
3
of
40
Specifically,
it
includes
SIC
3671,
Electron
Tubes,
and
SIC
3674,
Semiconductors
and
Related
Devices.
No
specific
subcategories
were
identified
during
the
Factor
4
analysis.

°
SIC
3671:
Electron
Tubes
Establishments
primarily
engaged
in
manufacturing
electron
tubes
and
tube
parts.
Establishments
primarily
engaged
in
manufacturing
X­
ray
tubes
and
parts
are
classified
in
Industry
3844.

°
SIC
3674:
Semiconductors
and
Related
Devices
Establishments
primarily
engaged
in
manufacturing
semiconductors
and
related
solid­
state
devices.
Important
products
of
this
industry
are
semiconductor
diodes
and
stacks,
including
rectifiers,
integrated
microcircuits
(
semiconductor
networks),
transistors,
solar
cells,
and
light
sensing
and
emitting
semiconductor
(
solid­
state)
devices.

The
following
tables
present
the
facilities
in
this
category
that
report
to
the
Permit
Compliance
System
(
PCS)
and
to
the
Toxic
Release
Inventory
(
TRI).
(
Note:
Since
this
industry
ranked
low
during
the
screening
phase,
EPA
did
not
verify
any
of
the
information
reported
to
PCS
and
TRI,
and
has
used
it
as
reported.
Although
information
in
PCS
and
TRI
is
limited,
it
can
provide
insight
into
this
industry.
See
Attachment
A
for
more
details
about
PCS
and
TRI.)
Table
1
shows
the
number
of
facilities
identified
for
this
industry.
Table
2
lists
the
facilities
reporting
to
PCS
under
these
SIC
codes.
Table
3
lists
the
facilities
reporting
to
TRI
under
these
SIC
codes.
Attachments
C
and
D
list
these
facilities
along
with
their
reported
discharges.

Table1.
Number
of
Facilities
SIC
1997
Census
PCS
TRI
Total
Major
Minor
Total
Reporting
No
reported
discharge
Direct
discharge
Indirect
discharge
Both
direct
&
indirect
3671
159
5
1
4
1
4
0
4
5
3674
1099
13
4
9
150
51
4
91
4
Source:
PCSLoads2000,
TRIReleases2000
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
4
of
40
Table
2.
Electrical
&
Electronic
Components
Facilities
Reporting
to
PCS,
Sorted
by
State
SIC
Facility
NPDES
ID
Facility
Name
Facility
City
&
State
3674
MO0000299
MEMC
INC
ST
PETERS
(
also
reports
to
TRI)
ST.
PETERS,
MO
3674
PA0011134
AGERE
SYSTEMS
INC
ALLENTOWN,
PA
3671
PA0008508
BURLE
INDUSTRIES
INC
LANCASTER,
PA
3674
PA0001201
POWEREX
INC
YOUNGWOOD,
PA
3674
VT0000400
IBM
CORPORATION
(
also
reports
to
TRI)
ESSEX
JUNCTION,
VT
Table
3.
Electrical
&
Electronic
Components
Facilities
Reporting
to
TRI
SIC
Facility
TRI
ID
Facility
Name
City
State
3674
85202MTRLN2200W
MOTOROLA
MESA
MESA
AZ
3674
85248NTLCR4500S
INTEL
CORP.
CHANDLER
AZ
3674
85224MTRLN1300N
MOTOROLA
CHANDLER
CHANDLER
AZ
3674
85283MTRLN7204S
MOTOROLA
TEMPE
TEMPE
AZ
3674
85226NTLCR5000W
INTEL
CORP.
CHANDLER
CAMPUS
CHANDLER
AZ
3674
85022SGSTH1000E
ST
MICROELECTRONICS
INC.
PHOENIX
AZ
3674
85008SCLLC5005E
SCI
L.
L.
C.
(
ON
SEMICONDUCTOR)
PHOENIX
AZ
3674
85024SMTMS19801
SUMITOMO
SITIX
OF
PHOENIX
PHOENIX
AZ
3674
85008MTRLN5005E
MOTOROLA
SCG
PHOENIX
AZ
3674
85034FLPCH3701E
FLIP
CHIP
TECHS.
PHOENIX
AZ
3674
85706BRRBR6730S
TEXAS
INSTRUMENTS
TUCSON
TUCSON
AZ
3671
92127SNYMN16450
SONY
ELECTRONICS
INC.
SONY
TECH.
CENTER
SAN
DIEGO
SAN
DIEGO
CA
3671
94070MCDVS301IN
COMMUNICATIONS
&
POWER
INDS.
EIMAC
DIV.
SAN
CARLOS
CA
3674
95538MRCNX4311S
AXT
INC.
FREMONT
CA
3674
92658RCKWL4311J
CONEXANT
SYS.
INC.
NEWPORT
BEACH
CA
3674
90245NTRNT233KA
INTERNATIONAL
RECTIFIER
EL
SEGUNDO
CA
3674
95678NCLCT7501F
NEC
ELECTRONICS
INC.
ROSEVILLE
CA
3674
92390HXFTM41915
INTERNATIONAL
RECTIFIER
HEXFET
AMERICA
FACILITY
TEMECULA
CA
3674
93905NTGRT1566M
INTEGRATED
DEVICE
TECH.
INC.
SALINAS
CA
3674
95131GLNTT350WT
AGILENT
TECHOLOGIES
SAN
JOSE
CA
3674
95052NTLCR3601J
INTEL
CORP.
D2
FACILITY
SANTA
CLARA
CA
3674
91320RCKWL2427W
CONEXANT
SYS.
INC.
NEWBURY
PARK
CA
3674
95050PRCSN1500S
ANALOG
DEVICES
INC.
SANTA
CLARA
SITE
SANTA
CLARA
CA
SIC
Facility
TRI
ID
Facility
Name
City
State
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
5
of
40
3674
95054SLCNX2201L
SILICONIX
INC.
SANTA
CLARA
CA
3674
92127NRTHR16350
STMICROELECTRONICS,
INC.
SAN
DIEGO
CA
3674
95060SLCNS2300D
TEXAS
INSTRUMENTS
INC.
SANTA
CRUZ
CA
3674
92704MCRSM2830S
MICROSEMI
CORP.
SANTA
ANA
CA
3674
92123KYCRM8611B
KYOCERA
AMERICA
INC.
SAN
DIEGO
CA
3674
93291VLTGM8711W
VOLTAGE
MULTIPLIERS
INC.
VISALIA
CA
3674
95035HDWYT497SH
HEADWAY
TECHS.
INC.
MILPITAS
CA
3674
94560VNTKN39201
AGILENT
TECHS.
NEWARK
CA
3674
92121PPLDM5502O
APPLIED
MICRO
CIRCUITS
CORP.
SAN
DIEGO
CA
3674
95035LNRTC1630M
LINEAR
TECH.
CORP.
MILPITAS
CA
3674
80906HNYWL1150E
ATMEL
CORP.
COLORADO
SPRINGS
CO
3674
80525GLNTT4380S
AGILENT
TECHS.
INC.
FORT
COLLINS
CO
3674
80020MCRSM800HO
MICROSEMI
CORP.
COLORADO
BROOMFIELD
CO
3674
32819TTMCR9333S
CIRENT
SEMICONDUCTOR
ORLANDO
FL
3674
83706MCRNT2805E
MICRON
TECH.
INC.
BOISE
ID
3674
83201MRCNM2300B
AMI
SEMICONDUCTOR
INC.
POCATELLO
ID
3674
83651ZLGNC26011
ZILOG
INC.
NAMPA
ID
3674
83687MCRNT900EK
MICRON
TECH.
INC.
NAMPA
ID
3671
46953THMSN3301S
THOMSON
MULTIMEDIA
INC.
MARION
IN
3674
46904DLCLC1800E
DELPHI
DELCO
ELECTRONICS
SYS.
BYPASS
FACILITY
KOKOMO
IN
3674
01821MBLSL4SUBU
ASE
AMERICAS
INC.
BILLERICA
MA
3674
02172NTRDC580PL
MICRO
USPD
INC.
WATERTOWN
MA
3674
04106NTNLS5FODE
NATIONAL
SEMICONDUCTOR
CORP.
SOUTH
PORTLAND
ME
3674
04106NTNLS333WE
FAIRCHILD
SEMICONDUCTOR
CORP.
SOUTH
PORTLAND
ME
3674
55425VTCNC2800E
POLARFAB
L.
L.
C.
BLOOMINGTON
MN
3674
65201MCLMB5400R
3M
COLUMBIA
COLUMBIA
MO
3674
63376MNSNT501PE
MEMC
ELECTRONIC
MATERIALS
INC.
ST.
PETERS
PLANT
O
FALLON
MO
3674
64063TTTCH777NB
FABTECH
INC.
LEES
SUMMIT
MO
3674
27703CRRSR4600S
CREE
INC.
DURHAM
NC
3674
27409RFMCR7914P
RF
MICRO
DEVICES
FAB
1
GREENSBORO
NC
3674
87124NTLCR4100S
INTEL
CORP.
MS
F7T­
109
RIO
RANCHO
NM
3674
87113SGNTC9201P
PHILIPS
ELECTRONICS
N.
A.
CORP.
ALBUQUERQUE
NM
3674
87113SLMXN5031S
SILMAX
L.
L.
C.
ALBUQUERQUE
NM
3671
14845TSHBWWESTI
TOSHIBA
DISPLAY
DEVICES
INC.
HORSEHEADS
NY
3674
12533BM
EASTF
IBM
HOPEWELL
JUNCTION
NY
3674
10710LCTRN21GRA
ELECTRONIC
DEVICES
INC.
YONKERS
NY
3671
45875PHLPS700NO
PHILIPS
DISPLAY
COMPONENTS
CO.
OTTAWA
OH
3671
45373MRCNM1400W
AMERICAN
MATSUSHITA
ELECTRONIC
CO.
TROY
OH
3674
45039CNCNN537GR
SUMITOMO
SITIX
SILICON
INC.
CINCINNATI
MAINEVILLE
OH
3674
44281HBRSS8711W
OHIO
BRASS
CO.
WADSWORTH
OH
3674
97210WCKRS7200N
WACKER
SILTRONIC
CORP.
PORTLAND
OR
3674
97124NTLCR2501N
INTEL
CORP.
RONLER
ACRES
CAMPUS
HILLSBORO
OR
SIC
Facility
TRI
ID
Facility
Name
City
State
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
6
of
40
3674
97124NTRGR3131N
INTEGRATED
DEVICE
TECH.
INC.
HILLSBORO
OR
3674
97302MTSBS3990F
MITSUBISHI
SILICON
AMERICA
SALEM
OR
3674
97303SLTCS1351T
MITSUBISHI
SILICON
AMERICA
SALEM
OR
3674
97007NTLCR3585S
INTEL
CORP.
ALOHA
OR
3674
97402HYNDS1830W
HYUNDAI
SEMICONDUCTOR
AMERICA
INC.
EUGENE
OR
3674
97303SLTCP1430T
MITSUBISHI
SILICON
AMERICA
SALEM
OR
3674
97330HWLTT1000N
HEWLETT­
PACKARD
CO.
CORVALLIS
OR
3674
97030FJTSM21015
FUJITSU
MICROELECTRONICS
INC.
GRESHAM
OR
3671
18512THMSNKEYST
THOMSON
CONSUMER
ELECTRONICS
SCRANTON
PA
3671
15666SNYLCOLDRT
SONY
ELECTRONICS
INC.
MOUNT
PLEASANT
PA
3674
18707GSLDS125CR
INTERSIL
CORP.
MOUNTAIN
TOP
PA
3674
19612TTMCR2525N
LUCENT
TECHS.
READING
READING
PA
3674
19090SPRGL3900W
ALLEGRO
MICROSYSTEMS
W.
G.
INC.
WILLOW
GROVE
PA
3674
18103TTMCR555UN
LUCENT
TECHS.
INC.
ALLENTOWN
PA
3674
19355SLCNP175GR
SILICON
POWER
CORP.
MALVERN
PA
3674
02818CHRRY2000S
SEMICONDUCTOR
COMPONENTS
IND.
OF
RI
INC.
EAST
GREENWICH
RI
3674
02908MRCNS15CLA
AMERICAN
SILICON
PRODS.
INC.
PROVIDENCE
RI
3671
29602HTCHL575MA
HITACHI
ELECTRONIC
DEVICES
(
USA)
INC.
GREENVILLE
SC
3674
78721MTRLN3501E
MOTOROLA
ED
BLUESTEIN
AUSTIN
TX
3674
78741DVNCD5204A
ADVANCED
MICRO
DEVICES
INC.
FAB
25
AUSTIN
TX
3674
78735MTRLN6501W
MOTOROLA
OAK
HILL
FACILITY
AUSTIN
TX
3674
78754SMSNG12100
SAMSUNG
AUSTIN
SEMICONDUCTOR
AUSTIN
TX
3674
75091MMCST6800H
MEMC
SOUTHWEST
INC.
SHERMAN
TX
3674
77477TXSNS12201
TEXAS
INSTRUMENTS
INC.
STAFFORD
TX
3674
78741DVNCD5204E
ADVANCED
MICRO
DEVICES
INC.
AUSTIN
TX
3674
75243TXSNS13500
TEXAS
INSTRUMENTS
INC.
DALLAS
TX
3674
78245DVNCD8611M
SONY
SEMICONDUCTOR
SAN
ANTONIO
TX
3674
75081HNYWL830EA
HONEYWELL
SENSING
&
CONTROL.
RICHARDSON
PLANT
RICHARDSON
TX
3674
75006SGSTH1310E
ST
MICROELECTRONICS
INC.
CARROLLTON
TX
3674
75090MMCST6416U
MEMC
SOUTHWEST
INC.
SHERMAN
TX
3674
76017NTNLS1111W
NATIONAL
SEMICONDUCTOR
ARLINGTON
TX
3674
75090TXSNS6400H
TEXAS
INSTRUMENTS
SHERMAN
TX
3674
78251VLSTC9651W
PHILIPS
SEMICONDUCTORS
SAN
ANTONIO
TX
3674
75034HTSNN1000H
HUTSON
INDS.
INC.
FRISCO
TX
3674
78406SMTCH121IN
SEMTECH
CORPUS
CHRISTI
CORP.
CORPUS
CHRISTI
TX
3674
75244DLLSS4350B
DALLAS
SEMICONDUCTOR
CORP.
DALLAS
TX
3674
75038TCCRL1801H
TECCOR
ELECTRONICS
L.
L.
P.
IRVING
TX
3674
84088NTNLS3333W
FAIRCHILD
SEMICONDUCTOR
WEST
JORDAN
UT
3674
23150WHTKS6000T
INFINEON
TECHS.
RICHMOND
SANDSTON
VA
3674
20110DMNNS9600G
DOMINION
SEMICONDUCTOR
L.
L.
C.
MANASSAS
VA
3674
05452BM
1000R
IBM
CORP.
ESSEX
JUNCTION
VT
3674
98607WFRTC5509N
WAFERTECH
L.
L.
C.
CAMAS
WA
3674
98682SHMRC4111N
SEH­
AMERICA
INC.
VANCOUVER
WA
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
7
of
40
The
111
reporting
facilities
are
located
in
22
states,
with
the
highest
concentrations
occurring
in
California
(
20%),
Texas
(
17%),
Arizona
(
11%),
Oregon
(
9%),
and
Pennsylvania
(
9%).
It
is
worth
noting
that
Region
IX
covers
the
2
states
printed
in
bold,
and
over
30%
(
33)
of
the
reporting
facilities
are
located
in
this
Region.
Another
20%
(
22)
facilities
are
located
in
Region
VI.
The
map
on
the
following
page
shows
the
locations
of
the
facilities
reporting
to
TRI
or
PCS.

U.
S.
Census
data
indicates
that,
between
1992
and
1997,
there
was
an
almost
16%
decrease
in
the
number
of
electron
tube
manufacturing
facilities
and
an
almost
20%
increase
in
the
number
of
facilities
manufacturing
semiconductors
and
related
devices.
Value
of
goods
shipped
has
increased
in
both
sectors,
by
almost
23%
for
electron
tubes
and
by
144%
for
semiconductors.
See
Table
4
below.
Advance
comparative
statistics
for
1997
to
2002
for
the
broader
category
represented
by
NAICS
code
334
(
facilities
that
manufacture
computer
and
electronic
products)
show
an
almost
10%
decrease
in
the
number
of
establishments
and
a
19%
decrease
in
the
value
of
shipments
(
not
adjusted
for
inflation).
See
Table
5
below.

Table
4.
1992
and
1997
Census
Data
SIC
Industry
Sector
Number
of
Establishments
Value
of
Shipped
Goods
(
billions
of
dollars)

1997
1992
%
Change
1997
1992
%
Change
3671
Electron
Tubes
159
189
­
15.9
3.9
3.1
22.7
3674
Semiconductors
&
related
devices
1,099
920
19.5
0.079
0.032
144
Source:
1997
U.
S.
Economic
Census
Table
5.
1997
and
2002
Census
Data
NAICS
Industry
Segment
Number
of
Establishments
Value
of
Goods
Shipped
(
billions
of
dollars)

2002
1997
%
Change
2002
1997
%
Change
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
8
of
40
334
Computer
and
Electronic
Product
Manufacture
15,698
17,43
5
­
9.96
354
439
­
19.4
Source:
2002
U.
S.
Economic
Census
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
10
of
40
Wastewater
Characteristics
and
Pollutant
Sources
Information
on
wastewater
characteristics
and
pollutant
sources
are
provided
in
the
sections
that
follow,
organized
by
the
four
subcategories
identified
in
the
effluent
guidelines.
Table
6
provides
information
on
wastewater
flows,
organized
by
the
SIC
categories
covered
by
the
effluent
guidelines.
Table
7
presents
sources
of
process
wastewater
and
the
associated
pollutants,
organized
by
the
four
subcategories
identified
in
the
effluent
guidelines.

Semiconductor
Subcategory:
Pollutants
include
fluoride,
toxic
organics,
arsenic,
and
suspended
solids.
Toxic
metals
associated
with
electroplating
processes
are
regulated
under
Part
433
(
Metal
Finishing).
Water
is
used
in
acid
formulations,
rinses,
exhaust
gas
collection,
solvents,
acid
baths,
and
equipment
cleaning.
Changes
in
the
manufacturing
process
since
the
promulgation
of
the
existing
effluent
guidelines
have
introduced
chemical
mechanical
planarization
(
CMP),
which
uses
a
combination
of
chemical
and
mechanical
forces
to
remove
oxide
deposits
from
silicon
wafers.
Copper
CMP
results
in
significant
amounts
of
copper
wastes.
(
The
current
guidelines
do
not
limit
copper
discharges.)

Electronic
Crystals
Subcategory:
Pollutants
include
fluoride,
toxic
organics,
arsenic,
and
suspended
solids.
The
major
sources
of
wastewater
are
rinse
and
wash
steps
that
occur
at
various
process
stages.

Cathode
Ray
Tube
Subcategory:
Pollutants
include
cadmium,
chromium,
lead,
zinc,
toxic
organics,
fluoride,
and
suspended
solids.
The
major
sources
of
wastewater
are
rinse
and
wash
steps
that
occur
at
various
process
stages.

Luminescent
Materials
Subcategory:
Pollutants
include
cadmium,
zinc,
antimony,
and
suspended
solids.
The
major
sources
of
wastewater
are
rinse
and
wash
steps
that
occur
at
various
process
stages.

Table
6.
Wastewater
Flows
SIC
Number
of
Major
Facilities
Reporting
Nonzero
Flows
Median
Facility
Flow
2000
(
MG)
Range
of
Facility
Flows
2000
(
MG)
Total
Flow
2000
(
MG)

3671
1
191
NA
191
3674
4
1,651
59
­
15,493
18,853
Source:
PCSLoads2000.
NA:
no
range
calculated;
only
one
facility
reported
a
nonzero
flow.
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
11
of
40
Table
7.
Sources
of
Process
Wastewater
in
Electrical
and
Electronic
Components
Waste
water
Pollutants
Semiconductors:

Acid
wastes
from
etching
and
cleaning
Fluoride,
low
pH,
toxic
organics
Water
rinses
Fluoride
(
low
levels),
toxic
organics
Equipment
cleaning
waste
toxic
organics,
may
have
high
pH
if
caustic
cleaning
agent
is
used.

Scrubber
wastes
Toxic
organics
Stripper
quench
rinses
Toxic
organics
Chemical
mechanical
planarization
(
CMP)
Copper
Electronic
Crystals:

Crystal
growing
operations
Sodium
hydroxide,
sodium
carbonate
Etching
Fluoride,
toxic
organics
Manufacture
of
gallium
or
indium
arsenic
crystals
Arsenic
Cutting
and
grinding
operations
Suspended
solids
Equipment
cleaning
Toxic
organics
Cathode
Ray
Tubes:

Glass
panel
wash
Fluoride
Mask
degrease
Toxic
organics
Photoresist
application
Chromium
Phophor
application
Cadmium,
zinc
Glass
funnel
and
mount
cleaning
Fluoride
Tube
coating
Suspended
solids
from
graphite
emulsions
Tube
Salvage
Lead,
cadmium,
zinc,
fluoride,
chromium,
suspend
solids
Luminescent
Materials:
Waste
water
Pollutants
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
12
of
40
Lamp
phosphor
process
Antimony,
fluoride,
suspended
solids
Blue
and
green
phosphor
process
Cadmium,
zinc,
suspended
solids
Sources:
Development
Documents
for
Electrical
and
Electronic
Components
Phases
I
and
II,
EPA,
1983
&
1984;
Assessing
the
Environmental
Impact
of
Copper
CMP,
Maag
et
al,
2000
Pollutants
Discharged
Pollutant
discharges
to
surface
waters
as
reported
to
PCS
and
TRI
were
evaluated
as
part
of
the
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts.
Pounds
reported
as
discharged
were
converted,
wherever
possible,
to
their
toxic
weighted
pound
equivalents
to
provide
a
sense
of
relative
hazard
associated
with
those
discharges.
(
Note:
indirect
discharge
amounts
reflect
reductions
that
are
expected
to
occur
at
the
receiving
treatment
facility.)
Both
TRI
and
PCS
contain
information
about
pollutants
discharged
by
electrical
and
electronic
components
facilities.

PCS:
Of
the
five
facilities
reporting
to
PCS,
discharges
from
a
single
facility
in
Pennsylvania
accounts
for
88%
of
the
pounds
of
pollutants
discharged.
When
looking
at
toxic
weighted
discharges,
discharges
reported
to
PCS
by
a
single
facility
in
Missouri
accounts
for
66%
of
the
PCS
toxic
weighted
pound
equivalents
(
TWPE)
discharged
by
this
industry.
A
second
facility
in
Vermont
discharges
an
additional
30%
of
the
PCS
TWPE.

TRI:
Of
the
108
facilities
reporting
to
TRI,
the
pounds
of
pollutants
discharged
are
fairly
evenly
distributed,
with
no
single
facility
discharging
more
than
9%
of
the
total.
When
looking
at
toxic
weighted
discharges,
a
single
facility
in
South
Carolina
accounts
for
34%
of
the
reported
TWPE
discharge.
Two
other
facilities,
one
in
Missouri
and
one
in
California
contribute
another
15%
each.

Overall:
Of
the
111
facilities
reporting
discharges
in
this
category,
discharges
from
a
single
facility
in
Pennsylvania
accounts
for
32%
of
the
total
pounds
discharged.
The
remaining
discharges
are
distributed
fairly
evenly,
with
no
other
facilities
contributing
more
than
6%
of
the
total.
When
looking
at
toxic
weighted
discharges,
47%
of
the
TWPE
discharged
comes
from
a
single
facility
in
Missouri.
Another
31%
TWPE
is
discharged
from
two
facilities,
one
in
Vermont
(
21%)
and
another
in
South
Carolina.

Discharged
pollutants
can
be
characterized
as
nonconventional,
conventional,
or
priority
pollutants.
Table
8
below
shows
the
relative
contributions
of
each
pollutant
type.
See
Attachment
D
for
the
discharges
in
toxic
weighted
pounds
as
reported
to
PCS
by
each
facility
and
see
Attachment
E
for
the
discharges
in
toxic
weighted
pounds
as
reported
to
TRI
by
each
facility
See
Attachment
F
for
a
breakout
of
these
discharges
by
pollutant.
A
discussion
of
each
pollutant
type
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
13
of
40
discharged
follows
the
table.

Table
8.
Pollutant
Discharges
Reported
to
PCS
and
TRI
Pollutant
Category
&
Primary
Pollutants
PCS
LBS
PCS
TWPE
TRI
Pounds
TRI
TWPE
All
Pollutants
9,094,696
23,714
4,205,438
9,800
Priority
18,612
18,340
6,243
7,372
SILVER
786
12,941
(
71%)
0
0
LEAD
15
34
2,569
5,754
(
78%)

ARSENIC
642
2,228
(
12%)
389
1,349
(
18%)

COPPER
2,946
1,847
(
10%)
206
129
Nonconventional
8,893,786
5,374
4,199,195
2,428
TOTAL
FLUORIDE
145,775
5,102
(
95%)
0
0
MANGANESE
18,957
1,335
(
55%)

AMMONIA
AS
NITROGEN
73,775
135
(
3%)
405,891
611
(
25%)

ETHYLENE
GLYCOL
0
0
186,118
249
(
10%)

NITROGEN,
NITRATE
TOTAL
(
AS
N)
0
0
3,441,214
213
(
9%)

Conventional
182,297
1
0
0
BOD
5­
DAY
(
CARBONACEOUS)
77,341
 
 
 
TOTAL
SUSPENDED
SOLIDS
74,414
 
 
 
OIL
AND
GREASE
30,542
 
 
 
Priority
Pollutants
Priority
pollutants
are
the
highest
toxic
weighted
pound
equivalents
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
14
of
40
(
TWPE)
discharged
from
this
category,
accounting
for
over
three
fourths
of
the
TWPE
discharges
reported
to
PCS
and
TRI.
Silver
discharges
in
PCS
contributes
the
most
(
71%)
to
those
toxic
discharges,
while
discharges
of
lead
generate
the
most
(
78%)
of
the
TWPE
reported
to
TRI.
Arsenic
contributes
an
additional
12%
to
18%
of
the
reported
toxic
weighted
discharges.

Nonconventional
Pollutants
Over
98%
of
the
pounds
of
discharged
pollutants
reported
to
TRI
and
PCS
are
primarily
nonconventional
pollutants.
The
pollutants
contributing
the
most
to
the
TWPE
discharges
are
fluoride
in
PCS
and
manganese
in
TRI.
Ammonia
as
nitrogen
also
contributes
TWPE
according
to
both
databases.

Conventional
Pollutants
Only
2%
of
the
discharged
pounds
reported
to
PCS
are
conventional
pollutants,
primarily
biochemical
oxygen
demand
(
BOD),
and
total
suspended
solids
(
TSS).
However,
toxic
weights
are
not
available
for
conventional
pollutant
parameters.
No
information
on
conventional
pollutants
is
available
through
TRI.

For
purposes
of
comparison,
the
toxic
weighted
pound
equivalents
(
TWPE)
for
Electrical
and
Electronic
Components
are
presented
in
the
following
tables
along
with
the
industries
reporting
the
highest
discharges
in
each
database.
Table
9
presents
the
information
reported
to
PCS
and
Table
10
presents
the
information
reported
to
TRI.
For
a
description
of
the
derivation
of
the
values
in
these
tables,
see
the
memo
in
the
public
record
titled
"
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005,"
which
is
available
through
Edocket
at
document
number
OW­
2003­
0074­
0391.

Table
9.
Electrical
and
Electronic
Components
TWPE
Reported
to
PCS
Compared
to
Top
Ranking
Results
40
CFR
Part
Point
Source
Category
PCS
Reported
TWPE
PCS
Rank
423
Steam
electric
power
generation
2,933,209
1
414
Organic
chemicals,
plastics
and
synthetic
fibers
1,805,928
2
422
Phosphate
manufacturing
1,095,321
3
415
Inorganic
chemicals
manufacturing
853,568
4
421
Nonferrous
metals
manufacturing
434,925
5
440
Ore
mining
and
dressing
383,560
6
410
Textile
mills
296,601
7
419
Petroleum
refining
198,251
8
40
CFR
Part
Point
Source
Category
PCS
Reported
TWPE
PCS
Rank
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
15
of
40
455
Pesticide
chemicals
manufacturing,
formulating
178,977
9
418
Fertilizer
manufacturing
116,464
10
469
Electrical
and
Electronic
Components
23,714
17
Table
10.
Electrical
and
Electronic
Components
TWPE
Reported
to
TRI
Compared
to
Top
Ranking
Results
40
CFR
Part
Point
Source
Category
TRI
Reported
TWPE
TRI
Rank
414
Organic
chemicals,
plastics
and
synthetic
fibers
7,303,782
1
423
Steam
electric
power
generation
1,856,645
2
421
Nonferrous
metals
manufacturing
978,450
3
430
Pulp,
paper
and
paperboard
(
Phase
II)
628,785
4
415
Inorganic
chemicals
manufacturing
624,250
5
429
Timber
products
processing
404,926
6
419
Petroleum
refining
385,347
7
455
Pesticide
chemicals
manufacturing,
formulating
324,393
8
428
Rubber
manufacturing
166,343
9
463
Plastic
molding
and
forming
106,189
10
469
Electrical
and
Electronic
Components
9,789
27
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
16
of
40
Treatment
Technology
and
Pollution
Prevention
Control
of
toxic
organics
is
achieved
through
solvent
management.
End­
of­
pipe
treatment
generally
consists
of
neutralization
and
precipitation/
clarification.

Facilities
that
manufacture
electrical
and
electronic
components
use
large
amounts
ultra
pure
water
(
UPW)
in
their
processes.
Since
production
of
UPW
is
expensive,
pollution
prevention
efforts
in
this
industry
have
focused
on
water
efficiency
and
reuse.
Table
11
presents
water
conservation
and
pollution
prevention
alternatives.

Table
11.
Water
Conservation
and
Pollution
Prevention
Alternatives
for
Electrical
and
Electronic
Components
Process
Water
Conservation/
Pollution
Prevention
Alternatives
Rinsing
°
Evaluate
number
of
rinses
and
duration
based
on
level
of
contamination
to
eliminate
unnecessary
rinses.
°
Use
counter­
current
or
spray
rinsing
to
improve
efficiency.
°
Switch
from
continuous
flow
to
on­
demand
rinsing.

Water
reclamation/
Materials
recovery
°
Use
membrane
technologies
(
microfiltration,
ultrafiltration,
reverse
osmosis,
&
electrodialysis)
to
recycle
and
recover
process
water.
°
Recover
reusable
materials,
such
as
copper
and
chromium,
from
process
wastewater.
°
Treat
spent
rinse
water
at
the
DI
water
generating
plant
and
reuse
in
process.

Once­
through
cooling
°
Use
air­
cooled
models
to
eliminate
water­
usage
for
single­
pass
cooling.

Source:
Energy
and
Water
Efficiency
for
Semiconductor
Manufacturing,
Pacific
Northwest
Pollution
Prevention
Resource
Center,
2000.

Concerns
Identified
Pre­
Proposal
The
Electrical
and
Electronic
Components
point
source
category
was
identified
by
several
responders
surveyed
by
the
Agency
in
the
process
of
preparing
the
2004/
2005
Plan.
Their
suggestions
are
summarized
below.

Permitting
Authorities
(
Section
2.5
of
the
"
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0329)
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
17
of
40
EPA
permit
writers
and
pretreatment
coordinators
suggest
that
these
guidelines
need
to
be
revised
due
to
significant
changes
since
the
guidelines
were
promulgated.
EPA
permit
writers
and
pretreatment
coordinators
also
suggest
that
the
semiconductor
manufacturing
portion
of
this
industry
be
looked
at
because
there
have
been
major
changes
in
the
industry.
There
are
two
new
circumstances
in
this
portion
of
the
industry
that
raise
concerns:
1)
the
industry
is
moving
from
aluminum
to
the
more
toxic
copper
to
build
internal
components;
and
2)
the
industry
is
increasingly
using
new
process
operations,
one
of
which
is
chemical­
mechanical
planarization
(
CMP),
(
a
polishing
step
resulting
in
the
abrasive
removal
of
metals)
which
generates
more
or
different
pollution
than
the
processes
considered
during
the
development
of
the
existing
standards.

Concerns
Identified
in
Comments
to
Proposal
No
concerns
for
the
Electrical
and
Electronic
Components
point
source
category
were
received
in
comments
sent
in
response
to
the
Preliminary
Plan.

Followup
Contacts
Jesse
Pritts,
EPA/
OST/
EAD
(
202)
566­
1038
Keith
Silva
EPA/
Region
9
(
415)
972­
3509
Dave
J.
Knight,
Washington
State,
(
360)
407­
6277
Possible
Solutions
EPA
appreciates
all
comments
and
suggestions
provided
by
the
stakeholders
and
EPA
Regional
staff.
However,
as
with
any
comments
received
by
the
Agency,
EPA
can
not
address
these
suggestions
without
adequate
supporting
data.
Information
in
PCS
and
TRI
does
not
indicate
that
electrical
and
electronic
component
facilities
are
discharging
significant
quantities
of
copper
relative
to
other
industries.
In
addition,
generally,
a
few
facilities
drive
the
TWPE
estimates
from
both
TRI
and
PCS.
In
the
event
that
stakeholders
provide
additional
data
and
supporting
information,
on
these
or
any
of
the
issues
identified
above,
EPA
will
reevaluate
them
at
that
time.
In
the
absence
of
revisions
to
the
effluent
guidelines,
these
concerns
could
be
addressed
through
improved
information
dissemination
and
outreach
by
EPA.

Unclear
distinction
between
these
guidelines
and
metal
finishing:
There
is
confusion
between
the
guidelines
for
this
point
source
category
and
those
for
metal
finishing
(
40
CFR
433).
In
1998,
EAD
and
Permits
Division
of
the
Office
of
Wastewater
Management
(
OWM)
issued
permitting
guidance
for
semiconductor
manufacturing
facilities.
This
memorandum
and
the
10­
page
attachment
are
included
here
as
Attachment
G.
This
memo
can
be
disseminated
to
address
this
problem.
The
Agency
could
also
prepare
a
fact
sheet
with
answers
to
frequently
asked
questions
(
FAQs),
including
a
table
of
potentially
overlapping
guidelines.
The
Engineering
and
Analysis
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
18
of
40
Division
(
EAD)
can
share
these
concerns
with
OWM
to
assist
them
in
increasing
the
consistency
of
application
of
effluent
guidelines.

Transition
from
aluminum
to
copper
processes:
Since
the
changes
in
semiconductor
manufacturing
technology
from
aluminum
to
copper
materials
occurred
after
the
development
of
the
existing
regulations,
there
are
no
limits
on
copper
discharges.
Copper
may
be
present
in
wastewater
as
a
dissolved
solid
or
in
particulate
form.
Little
information
is
available
in
the
TRI
and
PCS
databases
regarding
copper
discharges
for
the
electric
and
electronic
components
industry;
see
tables
12
and
13.
Based
on
the
1997
Economic
Census
totals
for
the
industry,
only
9
percent
of
the
facilities
report
wastewater
discharges
to
TRI
and
1.4
percent
report
to
PCS.
Of
the
18
facilities
reporting
to
PCS,
13
are
classified
as
minor
dischargers.
The
following
treatment
options
are
available
for
the
removal
of
copper
(
both
discussed
in
Maag,
Boning,
&
Voelker,
2000):

°
pH
adjustment
followed
by
gravity
settling
This
process
removes
copper
from
wastewater
by
producing
a
sludge.
Depending
on
whether
the
copper
has
come
into
contact
with
electroplating
rinse
water,
this
sludge
may
or
may
not
be
considered
hazardous
waste.

°
activated
carbon
oxidant
removal,
filtration,
and
ion
exchange
This
system
is
currently
being
tested
by
the
industry.

Table
12.
Copper
Discharges
Reported
to
TRI
by
Electrical
and
Electronic
Component
Manufacturing
Facilities
SIC
Sector
#
Facilities
Pollutant
Discharge
Status
Pounds
TWPE
3671
Electron
Tubes
1
Copper
Compounds
Direct
31
19
1
Copper
Compounds
Indirect
14
8.6
3674
Semiconductors
and
Related
Devices
1
Copper
Indirect
1.4
0.86
2
Copper
Compounds
Indirect
160
100
Source:
TRIReleases
2000
database.
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
19
of
40
Table
13.
Copper
Discharge
Data
in
PCS
for
Electrical
and
Electronic
Component
Manufacturing
Facilities
SIC
Sector
#
Facilities
Pounds
TWPE
3671
Electron
Tubes
1
45
28
3674
Semiconductors
and
Related
Devices
3
2,901
1,819
Source:
PCSLoads2000
database.
Copper
is
reported
as
Copper,
Total
as
Cu.

Summary
of
Potential
Solutions:
The
concerns
raised
for
this
industry
could
be
addressed
through
improved
information
dissemination
and
outreach
by
EPA.
The
Agency
could
prepare
a
fact
sheet
with
answers
to
frequently
asked
questions
(
FAQs)
which
could
be
posted
on
EPA's
web
site.
In
addition,
the
Agency
could
announce
the
availability
of
this
fact
sheet,
and
the
name
of
the
current
EAD
staff
available
to
answer
questions
at
the
regular
meetings
for
permit
writers
and
pretreatment
coordinators
held
by
OWM
and
also
through
email
alerts
to
the
EAD
stakeholder
mailing
list.
Finally,
due
to
the
relatively
small
number
of
facilities
discharging
the
bulk
of
the
TWPE,
EPA
could
also
provide
assistance
to
permit
writers
in
preparing
BPJ­
based
permits.
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
20
of
40
Attachment
A
EPA
Databases
and
References
Used
in
this
Review
Overview
of
the
304(
m)
Planning
Process
CWA
Section
304(
m)(
1)
requires
EPA
to
establish
a
schedule
for
the
annual
review
and
revision
of
all
existing
effluent
guidelines
and
to
identify
categories
of
point
sources
discharging
toxic
or
non­
conventional
pollutants
for
which
EPA
has
not
published
effluent
guidelines.
To
accomplish
this
review,
EPA
conducted
a
screening­
level
analysis
using
readily
available
information
from
EPA's
Permit
Compliance
System
(
PCS)
and
Toxics
Release
Inventory
(
TRI)
databases.
EPA
estimated
the
mass
of
pollutants
discharged
from
each
category,
weighted
the
pollutant
releases
based
on
chemical
toxicity,
and
ranked
the
categories
based
on
the
toxicweighted
pollutant
releases.

In
addition
to
reported
discharges
in
PCS
and
TRI,
EPA
used
other
readily
available
data,
as
well
as
information
from
public
outreach,
including
industry
categories
recommended
by
stakeholders
for
regulatory
development
or
regulatory
revision,
to
evaluate
implementation
and
efficiency
considerations.

For
additional
details
on
EPA's
screening­
level
analysis
refer
the
following
documents
in
EPA
Docket
Number
OW­
2003­
0074:


Memorandum:
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005,
DCN
548,
Section
3.0;


Development
of
PCSLoads
2000,
DCN
620,
Section
2.1.2
(
this
document
explains
how
pollutant
loads
were
calculated
from
PCS
data);
and

Evaluation
of
RSEI
Model
Runs,
DCN
618,
Section
2.1.1.

Information
from
EPA's
Permit
Compliance
System
(
PCS)
and
Toxics
Release
Inventory
(
TRI)
databases
were
used
to
create
the
PCSLoads2000
and
TRIReleases2000
databases.
These
databases
were
the
primary
source
of
information
used
to
conduct
this
review.
Since
this
industry
ranked
low
during
the
screening
phase,
however,
EPA
did
not
verify
any
of
the
information
reported
to
PCS
and
TRI,
and
has
used
it
as
reported.

TRIReleases2000
The
Toxic
Release
Inventory
(
TRI)
is
the
major
source
of
data
for
the
TRIReleases2000
database.
TRI
is
the
common
name
for
Section
313
of
the
Emergency
Planning
and
Community
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
21
of
40
Right­
to­
Know
Act
(
EPCRA).
Each
year,
facilities
that
meet
certain
thresholds
must
report
their
releases
and
other
waste
management
activities
for
listed
toxic
chemicals.
That
is,
facilities
must
report
the
quantities
of
toxic
chemicals
recycled,
collected
and
combusted
for
energy
recovery,
treated
for
destruction,
or
disposed
of.
A
separate
report
must
be
filed
for
each
chemical
that
exceeds
the
reporting
threshold.
The
TRI
list
of
chemicals
for
reporting
year
2000
includes
more
than
600
chemicals
and
chemical
categories.
For
this
review,
EPA
used
data
for
reporting
year
2000,
because
they
were
the
most
recent
available
at
the
time
the
review
began.

There
are
three
criteria
that
a
facility
must
meet
to
be
required
to
submit
a
TRI
report
for
that
reporting
year.
The
criteria
are:

(
1)
SIC
Code
Determination:
Facilities
in
SIC
Codes
20
through
39,
seven
additional
SIC
codes
outside
this
range,
and
federal
facilities
must
concern
themselves
with
TRI
reporting.
EPA
rarely
checks
or
refutes
facility
claims
regarding
the
SIC
code
identification.
The
primary
SIC
code
determines
TRI
reporting.

(
2)
Number
of
Employees:
Facilities
must
have
10
or
more
full­
time
employees
or
their
equivalent.
EPA
defines
a
"
full­
time
equivalent"
as
a
person
that
works
2,000
hours
in
the
reporting
year
(
there
are
several
exceptions
and
special
circumstances
that
are
well­
defined
in
the
TRI
reporting
instructions).

(
3)
Activity
Thresholds:
If
the
facility
is
in
a
covered
SIC
code
and
has
10
or
more
full­
time
employee
equivalents
it
must
conduct
an
activity
threshold
analysis
for
every
chemical
and
chemical
category
on
the
current
TRI
list.
The
facility
must
determine
whether
it
manufactures,
processes,
OR
otherwise
uses
each
chemical
at
or
above
the
appropriate
activity
threshold.
Reporting
thresholds
are
not
based
on
the
amount
of
release.
All
TRI
thresholds
are
based
on
mass,
not
concentration.
Different
thresholds
apply
for
persistent
bioaccumulative
toxic
(
PBT)
chemicals
than
for
non­
PBT
chemicals.

In
TRI,
facilities
report
annual
loads
released
to
the
environment
of
each
toxic
chemical
or
chemical
category
that
meets
reporting
requirements.
They
must
report
onsite
releases
to
air,
receiving
streams,
disposal
to
land,
underground
wells,
and
several
other
categories.
They
must
also
report
the
amount
of
toxic
chemicals
in
wastes
transferred
to
off­
site
locations,
including
discharges
to
POTWs
and
other
off­
site
locations,
such
as
commercial
waste
disposal
facilities.

For
this
review,
EPA
focused
on
the
amount
of
chemicals
facilities
reported
either
discharging
directly
to
a
receiving
stream
or
transferring
to
a
POTW.
For
facilities
discharging
directly
to
a
stream,
the
loads
were
taken
directly
from
the
reported
TRI
data
for
calendar
year
2000.
For
facilities
that
transfer
toxic
chemicals
to
POTWs,
EPA
first
adjusted
the
TRI
pollutant
loads
reported
to
be
transferred
to
POTWs
to
account
for
pollutant
removal
that
occurs
at
the
POTW
prior
to
discharge
to
the
receiving
stream.
This
adjustment
was
made
using
POTW
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
22
of
40
removal
efficiencies
from
EPA's
Risk
Screening
Environmental
Indicators
(
RSEI)
model
(
see
Section
2.1.1
of
the
docket
for
more
information
on
TRI
and
the
RSEI
model).

Reporting
facilities
are
not
required
to
sample
and
analyze
wastestreams
to
determine
the
quantities
of
toxic
chemicals
released.
They
may
estimate
releases
based
on
mass
balance
calculations,
published
emission
factors,
site­
specific
emission
factors,
or
other
approaches.
Facilities
are
required
to
indicate,
by
a
reporting
code,
the
basis
of
their
release
estimate.
TRI's
reporting
guidance
is
that
for
chemicals
reasonably
expected
to
be
present
but
measured
below
the
detection
limit,
facilities
should
use
one
half
the
detection
limit
to
estimate
the
mass
released.
The
guidance
is
slightly
different
for
dioxins
and
dioxin­
like
compounds
in
that
it
allows
nondetects
to
be
treated
as
zero.

TRI
provides
the
option
for
facilities
to
report
releases
as
specific
numbers
or
as
ranges,
if
appropriate.
Specific
estimates
are
encouraged
if
data
are
available
to
ensure
the
accuracy;
however,
EPA
allows
facilities
to
report
releases
in
the
following
ranges:
1
to
10
pounds,
11
to
499
pounds,
and
500
to
999
pounds.
For
this
analysis,
EPA
used
the
mid­
point
of
each
reported
range
to
represent
a
facility's
releases.

EPA
weighted
the
direct
and
indirect
pollutant
releases
to
surface
waters
using
toxic
weighting
factors
(
TWFs)
developed
by
Office
of
Water/
Engineering
and
Analysis
Division
(
EAD),
to
calculate
toxic
weighted
pound
equivalents
(
TWPE)
for
each
reported
release.
See
4.2.3
and
4.2.4
for
more
discussion
of
TWFs
and
calculation
of
TWPE.
EPA
compiled
data
taken
from
TRI,
the
adjusted
releases
from
POTWs
to
surface
waters,
the
calculated
TWPE,
and
the
relationship
between
SIC
codes
and
point
source
category
into
a
Microsoft
Access
 
database
named
TRIReleases2000.
Some
corrections
were
made
to
this
database
as
further
study
was
conducted
on
the
TRI
data.
Limitations
of
TRI
are
discussed
in
Section
IV
of
the
Technical
Support
Document
for
this
planning
process.

PCSLoads2000
The
Permit
Compliance
System
(
PCS)
is
the
major
source
of
data
for
the
PCSLoads2000
database.
PCS
is
a
computerized
management
information
system
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance
(
OECA).
It
was
created
to
track
permit,
compliance,
and
enforcement
status
of
facilities
regulated
by
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
program
under
the
Clean
Water
Act
(
CWA).

More
than
65,000
industrial
facilities
and
water
treatment
plants
have
obtained
permits
for
water
discharges
of
regulated
pollutants.
To
provide
an
initial
framework
for
setting
permit
issuance
priorities,
EPA
developed
a
major/
minor
classification
system
for
industrial
and
municipal
wastewater
discharges.
Major
discharges
almost
always
have
the
capability
to
impact
receiving
waters
if
not
controlled
and,
therefore,
have
been
accorded
more
regulatory
attention
than
minor
discharges.
There
are
approximately
6,400
facilities
(
including
sewerage
systems)
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
23
of
40
with
major
discharges
for
which
PCS
has
extensive
records.
Permitting
authorities
classify
discharges
as
major
based
on
an
assessment
of
six
characteristics:

(
1)
toxic
pollutant
potential;
(
2)
ratio
of
discharge
flow
to
stream
flow;
(
3)
conventional
pollutant
loading;
(
4)
public
health
impact;
(
5)
water
quality
factors;
and
(
6)
proximity
to
coastal
waters.

Facilities
with
major
discharges
must
report
compliance
with
NPDES
permit
limits
via
monthly
Discharge
Monitoring
Reports
(
DMRs)
submitted
to
the
permitting
authority.
The
permitting
authority
enters
the
reported
DMR
data
into
PCS,
including
the
type
of
violation
(
if
any),
concentration
and
quantity
values,
and
the
Quarterly
Non­
Compliance
Report
(
QNCR)
indicators.
Minor
discharges
may,
or
may
not,
adversely
impact
receiving
water
if
not
controlled.
Therefore,
EPA
does
not
require
DMRs
for
facilities
with
minor
discharges.
For
this
reason,
the
PCS
database
includes
data
only
for
a
limited
set
of
minor
dischargers
when
the
states
choose
to
include
these
data.
As
a
consequence,
extensive
data
are
not
available
for
minor
discharges
in
PCS.

Parameters
in
PCS
include
water
quality
parameters
(
such
as
pH
and
temperature),
specific
chemicals,
bulk
parameters
(
such
as
BOD
5
and
TSS),
and
flow
rates.
Although
other
pollutants
may
be
discharged,
PCS
only
contains
data
for
the
parameters
identified
in
the
facility's
NPDES
permit.
Facilities
typically
report
monthly
average
pounds
per
day
discharged,
but
also
report
daily
maxima,
and
pollutant
concentrations.

For
this
review,
EPA
used
data
for
reporting
year
2000,
to
correspond
to
the
data
obtained
from
TRI.
EPA
used
its
Effluent
Data
Statistics
(
EDS)
system
program
to
calculate
annual
pollutant
discharges
using
the
monthly
reports
in
PCS.
Because
units
of
measure
vary
widely
in
PCS,
EPA
developed
the
EDS
system
to
estimate
mass
loadings
based
on
data
stored
in
PCS.
The
EDS
system
uses
existing
PCS
reported
mass
loading
values
or
multiplies
reported
discharge
flows
and
effluent
concentrations
to
estimate
loadings
for
each
outfall
(
discharge
pipe),
taking
into
account
the
various
units
of
concentration
and
flow
rates.

Where
concentrations
were
reported
as
below
detection
limit
(
BDL)
EPA
assumed
the
parameter
concentration
was
equal
to
zero
for
parameters
never
detected
by
the
facility
in
2000.
For
parameters
sometimes
detected
and
sometimes
not,
the
"
BDL"
concentration
was
set
equal
to
half
of
the
detection
limit.
.
The
EDS
system
program
sums
the
monthly
loads
to
calculate
annual
discharges,
interpolating
(
using
average
reported
loads)
for
months
with
missing
reports.

EPA
weighted
the
calculated
annual
pollutant
discharges
using
EAD's
TWFs
to
calculate
TWPE
for
each
reported
discharge,
as
it
did
for
the
reported
TRI
releases.
See
sections
4.2.3
and
4.2.4
for
more
discussion
of
TWFs
and
calculation
of
TWPE.
EPA
compiled
data
taken
from
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
24
of
40
PCS,
the
calculated
TWPE,
and
the
relationship
between
SIC
codes
and
point
source
category
into
a
Microsoft
Access
 
database
named
PCSLoads2000.
As
further
study
was
conducted
on
the
PCS
data,
some
corrections
were
made.

Other
Information
Sources
In
addition
to
TRI
and
PCS,
EPA
used
the
following
sources
of
information
in
its
review
of
this
industry:

°
1997
Economic
Census
data;
and
2002
Economic
Census
data.

°
Contacts
with
reporting
facilities
to
verify
reported
releases
and
facility
categorization.

°
US
EPA,
1983.
Development
Document
for
Effluent
Limitations
Guidelines
for
the
Electrical
and
Electronic
Components
Point
Source
Category
Phase
I.
440183075.

°
US
EPA,
1984.
Development
Document
for
Effluent
Limitations
Guidelines
and
Standards
for
the
Electrical
and
Electronic
Components
Point
Source
Category
Phase
II.
440184075.

°
Pendergast,
James
F.
and
Sheila
E.
Frace.
1998.
Permitting
Guidance
for
Semiconductor
Manufacturing
Facilities.
Memorandum
to
regional
water
management
division
directors.
(
April)
(
Attachment
G).

°
Maag,
Benoit,
Duane
Boning
and
Bettina
Voelker,
2000.
Assessing
the
Environmental
Impact
of
Copper
CMP.
Accessed
at
<
http://
wwwmtl
mit.
edu/
Metrology/
PAPERS/
PAPERS/
SemiInternationalOct2000/>
on
July
8,
2004.

°
Pacific
Northwest
Pollution
Prevention
Resource
Center,
2000.
Energy
and
Water
Efficiency
for
Semiconductor
Manufacturing.
Accessed
at
<
http://
www.
pprc.
org/
pprc/
pubs/
topics/
semicond/
semicond.
html>
on
July
12,
2004.
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
25
of
40
Attachment
B
Point
Source
Categories
Identified
Solely
Through
Factor
4
Industry
Formal
Comment
Process
Previous
Suggestions
(
Sec.
2.4)
Draft
Strategy
Outreach
Comments
on
Draft
Strategy
(
Sec.
2.2)
Comments
on
2002/
2003
Plan
(
Sec.
2.3)
Permitting
Authorities
(
Sec.
2.5)
AMSA
&
ASIWPCA
(
Sec.
2.6)

Coal
Mining



Coil
Coating

Dairy
Products
Processing

Electrical
and
Electronic
Components

Fruits
and
Vegetable
Processing


Metal
Molding
and
Casting




Mineral
Mining
and
Processing

Seafood
Processing



FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
26
of
40
Attachment
C
Applicability
and
Regulatory
History
Applicability
of
40
CFR
Part
469
Subpart
A
 
Semiconductor
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
all
process
operations
associated
with
the
manufacture
of
semiconductors,
except
sputtering,
vapor
deposition,
and
electroplating.

Subpart
B
 
Electronic
Crystals
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
manufacture
of
electronic
crystals.

Subpart
C
 
Cathode
Ray
Tube
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
manufacture
of
cathode
ray
tubes.

Subpart
D
 
Luminescent
Materials
Subcategory.
The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
the
manufacture
of
luminescent
materials
REGULATORY
BACKGROUND
Regulatory
History
The
Electronic
and
Electrical
Component
Point
Source
Category
consists
of
21
subcategories.
Seventeen
of
these
subcategories
were
excluded
from
regulation
under
Paragraph
8
of
the
Revised
Settlement
Agreement.

Semiconductor
Subcategory:
Effluent
Guidelines
for
BPT,
BAT,
BCT,
NSPS,
PSES,
and
PSNS
were
promulgated
(
Subpart
A)
in
1983.

Electronic
Crystals
Subcategory:
Effluent
Guidelines
for
BPT,
BAT,
BCT,
NSPS,
PSES,
and
PSNS
were
promulgated
(
Subpart
B)
in
1983.

Cathode
Ray
Tube
Subcategory:
Effluent
Limitations
and
Standards
for
NSPS,
PSES,
and
PSNS
for
the
Cathode
Ray
Tubes
Subcategory
(
Subpart
C)
were
promulgated
in
1984.
Existing
direct
dischargers
in
the
Cathode
Ray
Tubes
Subcategory
were
excluded
from
regulation
under
Paragraph
8
of
the
Revised
Settlement
Agreement.
The
only
direct
discharger
in
this
subcategory
discharged
less
than
two
pounds
per
day
after
treatment.

Luminescent
Materials
Subcategory:
Effluent
Limitations
and
Standards
for
NSPS
and
PSNS
for
the
Luminescent
Materials
Subcategory
(
Subpart
D)
were
promulgated
in
1984.
Existing
dischargers
in
the
Luminescent
Materials
Subcategories
were
excluded
from
regulation
under
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
27
of
40
Paragraph
8
of
the
Revised
Settlement
Agreement.
The
two
direct
dischargers
in
this
subcategory
each
discharged
less
than
one
pound
per
day
after
treatment.
The
indirect
dischargers
were
excluded
on
the
basis
that
their
toxic
discharges
to
POTWs
were
insignificant.

Related
Effluent
Guidelines
EPA
believes
that
semiconductor
manufacturing
can
be
divided
into
two
sections
for
the
purposes
of
applying
the
requirements
of
40
CFR
Part
469
and
Part
433:
Metal
Finishing.
Requirements
in
part
433
only
cover
the
process
after
wafer
fabrication
which
is
used
to
deposit
a
layer
of
metal
onto
the
surface
of
the
wafer
to
provide
contact
points
for
final
assembly.
Metal
Finishing
applies
to
the
following
processes:

°
Electroplating;
°
Electroless
Plating;
°
Anodizing;
°
Coating
(
chromating,
phosphating,
and
coloring);
°
Chemical
Etching
and
Milling;
and
°
Printed
Circuit
Board
Manufacture.

For
some
semiconductor
manufacturing
operations,
effluent
limitations
and
standards
for
Electrical
and
Electronic
Components
(
40
CFR
part
469)
may
be
effective
and
applicable
to
wastewater
discharges
from
the
metal
finishing
operations
(
40
CFR
part
433)
listed
above.
In
such
cases,
the
part
433
limits
shall
not
apply
and
the
part
469
regulations
shall
apply.
EPA
clarified
this
overlap
in
a
memorandum
dated
April
21,
1998
(
3).
New
technologies
in
semiconductor
manufacturing
include
electroplating­
type
operations
that
add
microscopic
amounts
of
metal
to
selective
portions
of
the
wafer.
These
operations
are
distinguished
from
the
electroplating
operations
that
occur
in
the
final
assembly
process,
which
is
separate
from
wafer
fabrication.
EPA
concluded
that
processes
performed
in
a
fab
cleanroom
before
final
assembly,
including
the
electroplating­
type
operations,
are
to
be
regulated
under
40
CFR
part
469.
Part
433
(
Metal
finishing)
only
applies
to
processes
after
wafer
fabrication,
in
which
a
layer
of
metal
is
deposited
onto
the
surface
of
the
wafer
to
provide
contact
points
for
final
assembly.

Existing
Limitations
Existing
regulations
do
not
include
limits
on
conventional
parameters
for
any
of
the
four
subcategories.
BOD
and
oil
and
grease
were
detected
at
concentrations
below
treatability.
Fecal
coliform
was
not
present
in
the
discharges
from
any
of
the
subcategories.
In
addition,
the
existing
regulations
do
not
include
limits
on
copper.

Limitations
for
toxic
organics
(
TTO)
were
established
for
new
and
existing
sources
in
the
Semiconductors
and
Electronic
Crystals
Subcategories.
EPA
detected
several
toxic
organics
in
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
28
of
40
process
wastes
resulting
from
solvent
cleaning
and
developing
and
stripping
photoresist.
TTO
is
the
sum
of
the
mass
of
each
of
the
following
toxic
organic
compounds
which
are
found
at
a
concentration
greater
than
0.010
mg/
l:

°
1,2,4
Trichlorobenzene;
°
Chloroform;
°
1,2
Dichlorobenzene;
°
1,3,
Dichlorobenzene;
°
1,4,
Dichlorobenzene;
°
Ethylbenzene;
°
1,1,1
Trichloroethane;
°
Methylene
chloride;
°
Naphthalene;
°
2
Nitrophenol
phenol;
°
Bis
(
2­
ethylhexyl)
phthalate;
°
Tetrachloroethylene;
°
Toluene;
°
Trichloroethylene;
°
2
Chlorophenol;
°
2,4
Dichlorophenol;
°
4
Nitrophenol;
°
Pentachlorophenol;
°
Di­
n­
butyl
phthalate;
°
Anthracene;
°
1,2
Diphenylhydrazine;
°
Isophorone;
°
Butyl
benzyl
pthalate;
°
1,1
Dichloroethylene;
°
2,4,6
Trichlorophenol;
°
Carbon
tetrachloride;
°
1,2
Dichloroethane;
°
1,1,2
Trichloroethane;
and
°
Dichlorobromomethane.

Performance
Standards
for
toxic
organics
(
TTO)
were
established
for
new
sources
in
the
Cathode
Ray
Tubes
Subcategory.
EPA
detected
six
toxic
organics
in
process
wastes
resulting
from
the
use
of
solvents
for
cleaning
and
degreasing
operations,
and
from
the
application
of
toluene­
based
laquer
coatings.
TTO
is
the
sum
of
the
mass
of
each
of
the
following
toxic
organic
compounds
which
are
found
at
a
concentration
greater
than
0.010
mg/
l:


1,1,1­
Trichloroethane;


Chloroform;


Methylene
chloride;


Bis(
2­
ethylhexyl)
phthalate;


Toluene;
and

Trichloroethylene.

The
following
is
a
list
of
the
technology
basis
of
existing
regulations
for
each
of
the
four
subcategories.
Table
C­
1
presents
the
effluent
guidelines
for
the
semiconductors
and
electronic
crystals
subcategories.
Table
C­
2
presents
the
guidelines
for
cathode
ray
tubes
and
luminescent
materials
manufacturing.

Semiconductors:
neutralization,
solvent
management,
in­
plant
precipitation
of
concentrated
fluoride
stream.
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
29
of
40
Electronic
Crystals
Manufacturing:
neutralization,
solvent
management,
and
end­
of­
pipe
precipitation/
clarification.

Cathode
Ray
Tubes:
solvent
management,
neutralization,
and
end­
of­
pipe
precipitation/
clarification.

Luminescent
Materials
Manufacturing:
neutralization,
precipitation/
clarification.

Table
C­
1.
Effluent
Guidelines
for
Semiconductors
and
Electronic
Crystals
Manufacturing
(
concentration­
based)

Pollutant
30­
day
Average
Limits
(
mg/
L)

BPT
BAT
BCT
NSPS
PSES
&
PSNS
TTO*
1.37a
1.37a
1.37a
1.37a
1.37a
pH
within
the
range
of
6
to
9
NA
within
the
range
of
6
to
9
within
the
range
of
6
to
9
NA
TSS
23b
NA
23b
23b
NA
Fluoride
17.4c
17.4
NA
17.4
NA
Arsenic
0.83d
0.83d
NA
0.83d
0.83d
Source:
Development
Document
for
Phase
I,
1983
NA
=
no
limit.
*
TTO
=
Total
Toxic
Organics.
aThe
limit
for
TTO
represents
a
daily
maximum
value.
bLimits
for
TSS
only
apply
to
the
Electronic
Crystals
Subcategory.
cThere
is
no
BPT
limit
for
Fluoride
for
the
Semiconductor
Subcategory.
dLimits
for
Arsenic
only
apply
to
facilities
with
gallium
or
indium
arsenide
crystal
manufacturing
operations.
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
30
of
40
Table
C­
2.
Effluent
Limitations
and
Standards
for
Cathode
Ray
Tubes
and
Luminescent
Materials
Manufacturing
(
concentration­
based)

Pollutant
30­
Day
Average
Limit
(
mg/
L)

NSPS
PSESa
PSNS
TTO*
1.58
NA
NA
pH
within
the
range
of
6
to
9
NA
NA
TSS
18
to
31
NA
NA
Cadmium
0.03
to
0.26
0.03
0.03
to
0.26
Chromiumb
0.26
0.30
0.26
Leadb
0.27
0.41
0.27
Zinc
0.33
to
0.67
0.56
0.33
to
0.67
Fluoride
18
18
18
Antimonyc
0.04
NA
0.04
Source:
Development
Document
for
Phase
II,
1984
NA
=
no
limit.
*
TTO
=
Total
Toxic
Organics
aPSES
limits
only
apply
to
the
Cathode
Ray
Tubes
Subcategory.
bLimits
for
chromium
and
lead
only
apply
to
the
Cathode
Ray
Tubes
Subcategory.
cLimits
for
antimony
only
apply
to
the
Luminescent
Materials
Subcategory.
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
31
of
40
Attachment
D
PCS
Discharges
SIC
NPDES
ID
NAME
CITY
Flow
(
MGD)
LBS/
YR
TWPE
Percent
of
Total
SIC
TWPE
Cumulative
Percent
of
Total
SIC
TWPE
3671
PA0008508
BURLE
INDUSTRIES
INC
LANCASTER,
1
4,191
194
100%
100%

3671
TOTAL
1
4,191
194
3674
MO0000299
MEMC
INC
ST
PETERS
ST.
PETERS
42
49,195
15,679
67%
67%

3674
VT0000400
IBM
CORPORATION
ESSEX
JUNCTION
5
1,016,235
7,192
31%
97%

3674
PA0011134
AGERE
SYSTEMS
INC
ALLENTOWN
4
8,014,405
470
3674
PA0001201
POWEREX
INC
YOUNGWOOD
0
10,670
178
3674
TOTAL
52
9,090,505
23,520
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
32
of
40
Attachment
E
TRI
Discharges
­
Primarily
Indirect
Reported
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facility
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
3671
29602HTCHL575MA*
HITACHI
ELECTRONIC
DEVICES
(
USA)

INC.*
GREENVILLE
SC
6,879
3,372
66%
66%

3671
18512THMSNKEYST
THOMSON
CONSUMER
ELECTRONICS
SCRANTON
PA
8,763
618
12%
78%

3671
92127SNYMN16450*
SONY
ELECTRONICS
INC.
SONY
TECH.

CENTER
SAN
DIE*
SAN
DIEGO
CA
13,210
224
4%
82%

3671
14845TSHBWWESTI*
TOSHIBA
DISPLAY
DEVICES
INC.*
HORSEHEADS
NY
282,008
213
4%
87%

3671
45875PHLPS700NO
PHILIPS
DISPLAY
COMPONENTS
CO.
OTTAWA
OH
4,999
213
4%
91%

3671
46953THMSN3301S
THOMSON
MULTIMEDIA
INC.
MARION
IN
12,633
209
4%
95%

3671
45373MRCNM1400W
AMERICAN
MATSUSHITA
ELECTRONIC
CO.
TROY
OH
4,301
201
4%
99%

3671
15666SNYLCOLDRT*
SONY
ELECTRONICS
INC.*
MOUNT
PLEASANT
PA
31,905
35
1%
99%

3671
94070MCDVS301IN*
COMMUNICATIONS
&
POWER
INDS.
EIMAC
DIV.*
SAN
CARLOS
CA
45
28
1%
100%

3671
Total
364,742
5,114
3674
65201MCLMB5400R
3M
COLUMBIA
COLUMBIA
MO
19,109
1,439
31%
31%

3674
95538MRCNX4311S
AXT
INC.
FREMONT
CA
406
1,338
29%
59%

3674
12533BM
EASTF*
IBM*
HOPEWELL
JUNCTION
NY
611,871
635
14%
73%

3674
98607WFRTC5509N
WAFERTECH
L.
L.
C.
CAMAS
WA
209,504
308
7%
79%

3674
46904DLCLC1800E
DELPHI
DELCO
ELECTRONICS
SYS.

BYPASS
FACILITY
KOKOMO
IN
8,165
212
5%
84%

3674
97210WCKRS7200N*
WACKER
SILTRONIC
CORP.*
PORTLAND
OR
1,339,480
83
2%
86%

3674
23150WHTKS6000T
INFINEON
TECHS.
RICHMOND
SANDSTON
VA
50,001
66
1%
87%

3674
78721MTRLN3501E
MOTOROLA
ED
BLUESTEIN
AUSTIN
TX
44,832
53
1%
88%

3674
05452BM
1000R*
IBM
CORP.*
ESSEX
JUNCTION
VT
177,749
42
1%
89%

3674
97124NTLCR2501N
INTEL
CORP.
RONLER
ACRES
CAMPUS
HILLSBORO
OR
11,248
35
1%
90%

3674
78741DVNCD5204A
ADVANCED
MICRO
DEVICES
INC.
FAB
25
AUSTIN
TX
23,538
30
1%
91%

3674
87124NTLCR4100S
INTEL
CORP.
MS
F7T­
109
RIO
RANCHO
NM
29,578
29
1%
91%
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facility
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
33
of
40
3674
78735MTRLN6501W
MOTOROLA
OAK
HILL
FACILITY
AUSTIN
TX
32,069
26
1%
92%

3674
92658RCKWL4311J
CONEXANT
SYS.
INC.
NEWPORT
BEACH
CA
19,094
25
1%
92%

3674
18707GSLDS125CR
INTERSIL
CORP.
MOUNTAIN
TOP
PA
25,158
24
1%
93%

3674
04106NTNLS5FODE
NATIONAL
SEMICONDUCTOR
CORP.
SOUTH
PORTLAND
ME
18,698
24
1%
93%

3674
80906HNYWL1150E
ATMEL
CORP.
COLORADO
SPRINGS
CO
15,728
22
0%
94%

3674
83706MCRNT2805E
MICRON
TECH.
INC.
BOISE
ID
31,746
22
0%
94%

3674
78754SMSNG12100
SAMSUNG
AUSTIN
SEMICONDUCTOR
AUSTIN
TX
22,092
22
0%
95%

3674
90245NTRNT233KA
INTERNATIONAL
RECTIFIER
EL
SEGUNDO
CA
18,602
21
0%
95%

3674
97124NTRGR3131N
INTEGRATED
DEVICE
TECH.
INC.
HILLSBORO
OR
13,055
18
0%
95%

3674
32819TTMCR9333S
CIRENT
SEMICONDUCTOR
ORLANDO
FL
11,182
17
0%
96%

3674
97302MTSBS3990F
MITSUBISHI
SILICON
AMERICA
SALEM
OR
79,632
15
0%
96%

3674
97303SLTCS1351T
MITSUBISHI
SILICON
AMERICA
SALEM
OR
29,776
14
0%
96%

3674
97007NTLCR3585S
INTEL
CORP.
ALOHA
OR
14,216
14
0%
97%

3674
63376MNSNT501PE
MEMC
ELECTRONIC
MATERIALS
INC.
ST.

PETERS
PLANT
O
FALLON
MO
124,010
13
0%
97%

3674
85202MTRLN2200W
MOTOROLA
MESA
MESA
AZ
15,941
11
0%
97%

3674
80525GLNTT4380S
AGILENT
TECHS.
INC.
FORT
COLLINS
CO
8,082
11
0%
98%

3674
85248NTLCR4500S
INTEL
CORP.
CHANDLER
AZ
17,647
10
0%
98%

3674
27703CRRSR4600S
CREE
INC.
DURHAM
NC
5,812
9
0%
98%

3674
98682SHMRC4111N
SEH­
AMERICA
INC.
VANCOUVER
WA
126,700
8
0%
98%

3674
75091MMCST6800H
MEMC
SOUTHWEST
INC.
SHERMAN
TX
53,664
7
0%
98%

3674
85224MTRLN1300N
MOTOROLA
CHANDLER
CHANDLER
AZ
14,429
6
0%
98%

3674
77477TXSNS12201*
TEXAS
INSTRUMENTS
INC.*
STAFFORD
TX
107,761
6
0%
98%

3674
95678NCLCT7501F
NEC
ELECTRONICS
INC.
ROSEVILLE
CA
12,174
5
0%
99%

3674
83201MRCNM2300B
AMI
SEMICONDUCTOR
INC.
POCATELLO
ID
2,994
5
0%
99%

3674
78741DVNCD5204E
ADVANCED
MICRO
DEVICES
INC.
AUSTIN
TX
6,140
4
0%
99%

3674
85283MTRLN7204S
MOTOROLA
TEMPE
TEMPE
AZ
2,745
4
0%
99%

3674
75243TXSNS13500
TEXAS
INSTRUMENTS
INC.
DALLAS
TX
17,302
3
0%
99%

3674
92390HXFTM41915
INTERNATIONAL
RECTIFIER
HEXFET
TEMECULA
CA
54,341
3
0%
99%
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facility
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
34
of
40
AMERICA
FACILITY
3674
97402HYNDS1830W
HYUNDAI
SEMICONDUCTOR
AMERICA
INC.
EUGENE
OR
8,146
3
0%
99%

3674
97303SLTCP1430T
MITSUBISHI
SILICON
AMERICA
SALEM
OR
5,924
3
0%
99%

3674
83651ZLGNC26011
ZILOG
INC.
NAMPA
ID
1,965
3
0%
99%

3674
93905NTGRT1566M
INTEGRATED
DEVICE
TECH.
INC.
SALINAS
CA
2,071
3
0%
99%

3674
19612TTMCR2525N*
LUCENT
TECHS.
READING*
READING
PA
44,206
3
0%
99%

3674
97330HWLTT1000N
HEWLETT­
PACKARD
CO.
CORVALLIS
OR
12,048
3
0%
99%

3674
95131GLNTT350WT
AGILENT
TECHOLOGIES
SAN
JOSE
CA
4,474
3
0%
99%

3674
85226NTLCR5000W
INTEL
CORP.
CHANDLER
CAMPUS
CHANDLER
AZ
1,979
3
0%
99%

3674
78245DVNCD8611M*
SONY
SEMICONDUCTOR*
SAN
ANTONIO
TX
10,158
2
0%
100%

3674
95052NTLCR3601J
INTEL
CORP.
D2
FACILITY
SANTA
CLARA
CA
4,062
2
0%
100%

3674
85022SGSTH1000E
ST
MICROELECTRONICS
INC.
PHOENIX
AZ
1,252
2
0%
100%

3674
75081HNYWL830EA
HONEYWELL
SENSING
&
CONTROL.

RICHARDSON
PLANT
RICHARDSON
TX
1,004
2
0%
100%

3674
85008SCLLC5005E
SCI
L.
L.
C.
(
ON
SEMICONDUCTOR)
PHOENIX
AZ
23,202
1
0%
100%

3674
75006SGSTH1310E
ST
MICROELECTRONICS
INC.
CARROLLTON
TX
6,480
1
0%
100%

3674
85024SMTMS19801
SUMITOMO
SITIX
OF
PHOENIX
PHOENIX
AZ
20,391
1
0%
100%

3674
20110DMNNS9600G
DOMINION
SEMICONDUCTOR
L.
L.
C.
MANASSAS
VA
20,081
1
0%
100%

3674
45039CNCNN537GR
SUMITOMO
SITIX
SILICON
INC.

CINCINNATI
MAINEVILLE
OH
19,001
1
0%
100%

3674
01821MBLSL4SUBU
ASE
AMERICAS
INC.
BILLERICA
MA
15,703
1
0%
100%

3674
02172NTRDC580PL
MICRO
USPD
INC.
WATERTOWN
MA
1
1
0%
100%

3674
87113SGNTC9201P
PHILIPS
ELECTRONICS
N.
A.
CORP.
ALBUQUERQUE
NM
13,250
1
0%
100%

3674
91320RCKWL2427W
CONEXANT
SYS.
INC.
NEWBURY
PARK
CA
502
1
0%
100%

3674
95050PRCSN1500S
ANALOG
DEVICES
INC.
SANTA
CLARA
SITE
SANTA
CLARA
CA
10,772
1
0%
100%

3674
85008MTRLN5005E
MOTOROLA
SCG
PHOENIX
AZ
8,483
1
0%
100%

3674
44281HBRSS8711W*
OHIO
BRASS
CO.*
WADSWORTH
OH
9
0
0%
100%

3674
95054SLCNX2201L
SILICONIX
INC.
SANTA
CLARA
CA
6,288
0
0%
100%

3674
04106NTNLS333WE
FAIRCHILD
SEMICONDUCTOR
CORP.
SOUTH
PORTLAND
ME
6,211
0
0%
100%

3674
75090MMCST6416U
MEMC
SOUTHWEST
INC.
SHERMAN
TX
5,949
0
0%
100%
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facility
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
35
of
40
3674
76017NTNLS1111W
NATIONAL
SEMICONDUCTOR
ARLINGTON
TX
5,137
0
0%
100%

3674
92127NRTHR16350
STMICROELECTRONICS,
INC.
SAN
DIEGO
CA
5,145
0
0%
100%

3674
87113SLMXN5031S
SILMAX
L.
L.
C.
ALBUQUERQUE
NM
3,800
0
0%
100%

3674
95060SLCNS2300D
TEXAS
INSTRUMENTS
INC.
SANTA
CRUZ
CA
3,764
0
0%
100%

3674
10710LCTRN21GRA
ELECTRONIC
DEVICES
INC.
YONKERS
NY
3,680
0
0%
100%

3674
84088NTNLS3333W
FAIRCHILD
SEMICONDUCTOR
WEST
JORDAN
UT
3,460
0
0%
100%

3674
64063TTTCH777NB
FABTECH
INC.
LEES
SUMMIT
MO
20,070
0
0%
100%

3674
75090TXSNS6400H
TEXAS
INSTRUMENTS
SHERMAN
TX
3,083
0
0%
100%

3674
02818CHRRY2000S
SEMICONDUCTOR
COMPONENTS
IND.
OF
RI
INC.
EAST
GREENWICH
RI
2,835
0
0%
100%

3674
78251VLSTC9651W
PHILIPS
SEMICONDUCTORS
SAN
ANTONIO
TX
2,674
0
0%
100%

3674
80020MCRSM800HO
MICROSEMI
CORP.
COLORADO
BROOMFIELD
CO
2,277
0
0%
100%

3674
75034HTSNN1000H
HUTSON
INDS.
INC.
FRISCO
TX
90
0
0%
100%

3674
92704MCRSM2830S
MICROSEMI
CORP.
SANTA
ANA
CA
2,124
0
0%
100%

3674
19090SPRGL3900W
ALLEGRO
MICROSYSTEMS
W.
G.
INC.
WILLOW
GROVE
PA
2,100
0
0%
100%

3674
78406SMTCH121IN
SEMTECH
CORPUS
CHRISTI
CORP.
CORPUS
CHRISTI
TX
1,643
0
0%
100%

3674
75244DLLSS4350B
DALLAS
SEMICONDUCTOR
CORP.
DALLAS
TX
1,302
0
0%
100%

3674
18103TTMCR555UN*
LUCENT
TECHS.
INC.*
ALLENTOWN
PA
2,040
0
0%
100%

3674
92123KYCRM8611B
KYOCERA
AMERICA
INC.
SAN
DIEGO
CA
5
0
0%
100%

3674
97030FJTSM21015
FUJITSU
MICROELECTRONICS
INC.
GRESHAM
OR
811
0
0%
100%

3674
85034FLPCH3701E
FLIP
CHIP
TECHS.
PHOENIX
AZ
20
0
0%
100%

3674
83687MCRNT900EK
MICRON
TECH.
INC.
NAMPA
ID
0
0
0%
100%

3674
02908MRCNS15CLA
AMERICAN
SILICON
PRODS.
INC.
PROVIDENCE
RI
35,537
­
0%
100%

3674
19355SLCNP175GR
SILICON
POWER
CORP.
MALVERN
PA
­
­
0%
100%

3674
27409RFMCR7914P
RF
MICRO
DEVICES
FAB
1
GREENSBORO
NC
43
­
0%
100%

3674
55425VTCNC2800E
POLARFAB
L.
L.
C.
BLOOMINGTON
MN
887
­
0%
100%

3674
75038TCCRL1801H
TECCOR
ELECTRONICS
L.
L.
P.
IRVING
TX
57,549
­
0%
100%

3674
85706BRRBR6730S
TEXAS
INSTRUMENTS
TUCSON
TUCSON
AZ
337
­
0%
100%

3674
92121PPLDM5502O
APPLIED
MICRO
CIRCUITS
CORP.
SAN
DIEGO
CA
66
­
0%
100%

3674
93291VLTGM8711W
VOLTAGE
MULTIPLIERS
INC.
VISALIA
CA
­
­
0%
100%
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facility
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
36
of
40
3674
94560VNTKN39201
AGILENT
TECHS.
NEWARK
CA
79
­
0%
100%

3674
95035HDWYT497SH
HEADWAY
TECHS.
INC.
MILPITAS
CA
253
­
0%
100%

3674
95035LNRTC1630M
LINEAR
TECH.
CORP.
MILPITAS
CA
5
­
0%
100%

3674
Total
3,840,697
4,686
*
one
of
13
facilities
reporting
direct
discharges
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
37
of
40
Attachment
F
Reported
Pollutant
Loadings
SIC
Pollutant
Name
CAS
PCS
TRI
Indirect
TRI
Direct
Facilities
Reportin
g
Pollutant
Pounds
TWPE
Facilities
Reportin
g
Pollutant
Pounds
TWPE
Facilities
Reportin
g
Pollutant
Pounds
TWPE
SIC
3671
3671
TOTAL
SUSPENDED
SOLIDS
C009
1
1,476
3671
OIL
AND
GREASE
C035
1
658
3671
SUM
OF
CONVENTIONAL
POLLUTANTS
2,134
0
0
0
0
0
3671
TOTAL
FLUORIDE
16984488
1
1,204
42
3671
AMMONIA
AS
NITROGEN
7664417
1
5,309
8
3671
2­
BUTANONE
78933
1
2
0.000050
3671
NITROGEN,
NITRATE
TOTAL
(
AS
N)
14797558
7
68,964
4
2
280,953
17
3671
BARIUM
7440393
5
864
2
1
923
2
3671
CHLORINE,
TOTAL
RESIDUAL
7782505
1
5
2
3671
METHANOL
67561
1
2,450
0.023
3671
NITRIC
ACID
7697372
1
0
3671
PHOSPHORUS
7723140
1
580
3671
ETHYLENE
GLYCOL
107211
1
20
0.027
3671
HEXAVALENT
CHROMIUM
18540299
1
11
6
3671
SUM
OF
NONCONVENTIONAL
POLLUTANTS
1,796
48
77,612
16
281,878
19
3671
TOLUENE
108883
2
33
0.19
1
8
0.045
3671
ZINC
7440666
1
11
1
7
2,688
126
4
141
7
3671
SILVER
7440224
1
6
96
3671
LEAD
7439921
8
2,087
4,675
4
101
226
3671
CYANIDE
57125
1
1
1
SIC
Pollutant
Name
CAS
PCS
TRI
Indirect
TRI
Direct
Facilities
Reportin
g
Pollutant
Pounds
TWPE
Facilities
Reportin
g
Pollutant
Pounds
TWPE
Facilities
Reportin
g
Pollutant
Pounds
TWPE
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
38
of
40
3671
COPPER
7440508
1
45
28
1
14
9
1
31
19
3671
CHROMIUM
7440473
1
48
4
1
2
1
1
1
1
3671
ARSENIC
7440382
1
3
10
3671
ANTIMONY
7440360
1
111
1
3671
NICKEL
7440020
1
150
16
1
31
3
3671
SUM
OF
PRIORITY
POLLUTANTS
262
146
4,824
4,811
427
267
SIC
3674
3674
BOD
5­
DAY
(
CARBONACEOUS)
C003
3
77,341
3674
OIL
AND
GREASE
C035
3
29,885
3674
TOTAL
SUSPENDED
SOLIDS
C009
4
72,938
3674
SUM
OF
CONVENTIONAL
POLLUTANTS
180,163
0
0
0
0
0
3674
CHEMICAL
OXYGEN
DEMAND
(
COD)
C004
1
189,176
3674
2­
METHOXYETHANOL
109864
2
40
0.0043
3674
AMMONIA
AS
NITROGEN
7664417
2
73,775
135
33
393,094
592
2
7,488
11
3674
IRON
7439896
1
1,508
8
3674
XYLENE
1330207
1
0.079
0.00033
1
6
0.025
3674
TOTAL
KJELDAHL
NITROGEN
C021
1
53,137
3674
TOTAL
FLUORIDE
16984488
4
144,571
5,060
3674
TOTAL
DISSOLVED
SOLIDS
C010
1
7,954,801
3674
SULFURIC
ACID
7664939
1
0
0
3674
PHOSPHORUS
7723140
1
4,973
3674
N­
METHYL­
2­
PYRROLIDONE
872504
25
8,281
2
2,220
3674
NITROGEN,
NITRATE
TOTAL
(
AS
N)
14797558
62
839,677
52
6
2,251,620
140
3674
NITRIC
ACID
7697372
28
0
SIC
Pollutant
Name
CAS
PCS
TRI
Indirect
TRI
Direct
Facilities
Reportin
g
Pollutant
Pounds
TWPE
Facilities
Reportin
g
Pollutant
Pounds
TWPE
Facilities
Reportin
g
Pollutant
Pounds
TWPE
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Page
39
of
40
3674
METHANOL
67561
3
244
0.0023
3674
MANGANESE
7439965
1
18,957
1,335
3674
HYDROGEN
FLUORIDE
7664393
33
120,456
1
8,400
3674
CHLORINE,
TOTAL
RESIDUAL
7782505
2
253
123
1
5
2
3674
GLYCOL
ETHERS
N230
3
2,449
0.26
3674
ETHYLENE
GLYCOL
107211
24
185,838
248
2
260
0.35
3674
HYDROCHLORIC
ACID
7647010
8
0
0
1
5
0.00012
3674
COBALT
7440484
1
1
0.11
3674
SUM
OF
NONCONVENTIONAL
POLLUTANTS
8,422,193
5,326
1,569,041
2,230
2,270,000
151
3674
1,2­
DICHLOROBENZENE
95501
1
1
0.014
3674
TRICHLOROETHENE
79016
2
1
0.0062
1
29
0.18
3674
CHROMIUM
7440473
3
706
53
3674
ARSENIC
7440382
1
642
2,228
1
386
1,338
3674
ANTIMONY
7440360
1
2
0.010
3674
LEAD
7439921
2
15
34
3
316
707
2
65
146
3674
COPPER
7440508
3
2,901
1,819
3
161
101
3674
CYANIDE
57125
3
0.32
0.34
1
5
0.013
3674
ETHYLBENZENE
100414
1
0.20
0.00029
3674
NICKEL
7440020
3
6,696
729
1
22
2
1
1
0.11
3674
CADMIUM
7440439
2
69
180
3674
ZINC
7440666
3
6,541
306
1
5
0.23
3674
SILVER
7440224
3
780
12,845
3674
SUM
OF
PRIORITY
POLLUTANTS
18,350
18,194
919
2,149
73
146
FINAL
DRAFT
Electrical
&
Electronic
August
12,
2004
Attachment
G
Permitting
Guidance
for
Semiconductor
Manufacturing
Facilities
(
Converted
into
WordPerfect
from
a
PDF
file)
April
21,
1998
From:
James
F.
Pendergast,
Acting
Director
Permits
Division
Sheila
E.
Frace,
Acting
Director
Engineering
&
Analysis
Division
To:
Regional
Water
Management
Division
Directors
Subject:
Permitting
Guidance
for
Semiconductor
Manufacturing
Facilities
Introduction
Clarification
has
been
requested
by
semiconductor
manufacturing
facilities
regarding
the
scope
of
40
C.
F.
R.
Part
469,
Electrical
and
Electronic
Components
Point
Source
Category,
and
40
C.
F.
R.
Part
433,
Metal
Finishing
Point
Source
Category.
Currently,
semiconductor
manufacturing
facilities
are
regulated
by
Subpart
A
of
Part
469,
and
may
also
have
certain
unit
operations
regulated
by
Part
433.
Apparently
there
have
been
inconsistent
approaches
used
by
permitting
authorities
with
regard
to
when
to
apply
469
and
433
requirements
to
the
semiconductor
manufacturing
process.
There
have
also
been
concerns
raised
about
the
applicability
of
the
guidelines
considering
the
pace
of
advancements
and
the
introduction
of
new
technologies
in
the
semiconductor
industry.
This
guidance
is
intended
to
provide
an
overview
of
the
semiconductor
manufacturing
process,
discuss
the
overlap
between
Parts
469
and
433,
and
examine
new
and
emerging
manufacturing
technologies
and
how
these
processes
fit
into
the
regulatory
framework
of
Parts
469
and
433.
A
more
complete
discussion
of
these
issues
can
be
found
in
Attachment
1.

Semiconductor
Manufacturing
Processes
Semiconductor
manufacturing,
for
the
purposes
of
this
guidance,
can
be
grouped
into
three
categories:
(
1)
crystal
wafer
growth
and
preparation;
(
2)
semiconductor
fabrication
(
also
referred
to
as
wafer
fabrication);
and
(
3)
final
assembly.
The
semiconductor
fabrication
processes
are
typically
performed
in
a
clean
room
and
include
the
following
steps:
oxidation,
lithography,
etching,
doping
(
through
processes
such
as
vapor
phase
deposition
and
ion
implantation),
and
layering
(
through
processes
such
as
metallization).
During
the
fabrication
process,
wafers
may
be
cycled
through
several
of
these
steps
and
some
of
the
steps
may
be
repeated
for
various
purposes
at
different
points
in
the
process.

The
final
step
in
the
manufacture
of
semiconductors
consists
of
assembly
and
packaging
of
the
semiconductor
for
final
product.
In
assembly
and
packaging,
the
chips
proceed
from
one
operation
to
the
next,
undergoing
each
operation
only
once,
though
the
order
of
processes
depends
on
the
package
type
and
other
factors.
Semiconductor
assembly
and
packaging
processes
include
wafer
separation
and
sorting,
mounting
and
bonding
of
the
semiconductor
to
the
appropriate
mount
media,
electrically
interconnecting
the
semiconductor
to
the
package,
and
final
package
preparation.
Emerging
Technologies
Certain
semiconductor
manufacturers
have
recently
begun
performing
a
Controlled
Collapse
Chip
Connection
(
C4)
electroplating
process
to
add
selective
thin
metal
deposits
to
the
surface
of
the
wafer
to
act
as
connection
points
during
wafer
fabrication.
According
to
industry
personnel,
this
process
is
required
to
allow
for
increased
connection
points
caused
by
decreased
circuit
size
(
hence
an
increase
in
the
number
of
devices
per
semiconductor).

Several
semiconductor
manufacturers
recently
began
performing
a
new
process
for
using
copper
to
replace
aluminum
in
microprocessors
during
wafer
fabrication,
enhancing
electron
migration
and
reducing
the
width
of
the
circuitry.
These
sites
use
a
copper
metallization
process,
in
which
copper
is
applied
with
an
electroplating
operation
followed
by
a
rinse.
The
process
deposits
a
microscopic
layer
of
copper
on
selected
(
i.
e.,
circuitry)
portions
of
the
wafer.

Both
of
these
processes
are
part
of
a
sequence
of
photolithography,
etching,
and
copper
deposition
processes
performed
in
a
clean
room
environment.

Conclusion
There
are
new,
emerging
technologies
involved
in
semiconductor
wafer
fabrication
which
involve
electroplating
type
operations.
In
these
operations,
metal
is
applied
with
an
electroplating
operation
followed
by
a
rinse
which
may
lead
permitting
authorities
to
believe
the
40
CFR
Part
433
regulations
should
apply.
However,
as
described
above,
due
to
emerging
wafer
fabrication
technologies
the
electroplating
operations
in
wafer
fabrication
and
electroplating
operations
regulated
by
40
CFR
Part
433
can
be
distinguished:

°
In
the
wafer
fabrication
process,
electroplating
type
operations
add
microscopic
amounts
of
metal
to
selective
portions
of
the
wafer
to
enhance
the
circuitry
and
decrease
wafer
size.
°
In
the
final
assembly
and
packaging
process,
metal
layers
are
applied
electrolytically
through
an
electroplating
process
in
which
the
packages
are
mounted
on
racks.
Each
lead
connects
to
an
electric
potential
to
provide
contact
points
for
final
assembly.
The
racks
are
placed
in
the
electroplating
solution,
where
the
metal
is
applied.
This
process
is
followed
by
a
rinse.
This
is
typical
of
the
electroplating
processes
considered
in
the
development
of
the
Part
433
regulation.

After
carefully
reviewing
both
the
Part
469
and
433
regulations
and
their
associated
background
documents;
examining
past
regulatory
interpretations;
visiting
semiconductor
manufacturing
facilities;
speaking
with
the
industry;
and
reviewing
current
articles
and
books
on
the
processes,
the
Agency
believes
that
semiconductor
manufacturing
can
be
broken
into
two
sections
for
the
purposes
of
applying
the
requirements
of
40
CFR
Parts
469
and
433.
The
first
section
is
the
wafer
fabrication
process
and
the
second
section
is
the
final
assembly
and
packaging
process.
The
Agency
believes
that
the
metal
finishing
requirements
contained
in
part
433
only
cover
the
process
after
wafer
fabrication
which
is
used
to
deposit
a
layer
of
metal
onto
the
surface
of
the
wafer
to
provide
contact
points
for
final
assembly.
April
21,
1998
ATTACHMENT
1
1.0
INTRODUCTION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
2.0
SEMICONDUCTOR
MANUFACTURING
PROCESSES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
2.1
Silicon
Crystal
Growth
And
Wafer
Preparation
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2
2.2
Wafer
Fabrication
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2
2.2.1
Oxidation
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3
2.2.2
Lithography
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3
2.2.3
Etching
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
2.2.4
Doping
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
2.2.5
Layering
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5
2.2.6
Emerging
Technologies
in
Wafer
Fabrication
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
2.3
Semiconductor
Assembly
and
Packaging
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6
3.0
SUMMARY
OF
SITE
VISITS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
4.0
APPLICABILITY
AND
OVERLAP
OF
40
CFR
469
AND
40
CFR
433
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8
5.0
CONCLUSION
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
10
6.0
REFERENCES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
11
April
21,
1998
1
1.0
INTRODUCTION
This
report
presents
an
overview
of
semiconductor
manufacturing
processes
and
a
discussion
of
the
overlap
between
the
effluent
limitations
guidelines
and
standards
covering
semiconductor
manufacturing
(
Subpart
A
of
the
Electrical
and
Electronic
Component
Point
Source
Category
at
40
CFR
469.10)
and
those
covering
metal
finishing
operations
(
the
Metal
Finishing
Point
Source
Category
at
40
CFR
433).
This
report
focuses
on
new
and
emerging
manufacturing
processes
used
by
semiconductor
manufacturing
facilities
and
how
these
processes
fit
into
the
regulatory
framework
established
by
EPA
under
40
CFR
469
and
40
CFR
433.

Section
2.0
of
this
report
presents
a
summary
of
semiconductor
manufacturing
processes,
including
the
new
and
emerging
processes.
Section
3.0
presents
a
summary
of
three
site
visits
conducted
by
EPA
at
semiconductor
fabrication
facilities.
Section
4.0
presents
a
discussion
of
the
applicability
of
40
CFR
469
and
40
CFR
433
and
the
overlaps
between
these
two
effluent
guidelines.
Section
5
presents
a
list
of
references
used
in
preparing
this
report.

2.0
SEMICONDUCTOR
MANUFACTURING
PROCESSES
Semiconductor
manufacturing
processes
can
be
broadly
grouped
into
three
main
process
areas:
silicon
crystal
growth
and
wafer
preparation,
semiconductor
fabrication,
and
semiconductor
assembly
and
packaging.
The
silicon
crystal
growth
and
wafer
preparation
processes
consist
of
growing
silicon
crystal
ingots
from
which
silicon
wafers
are
produced.
The
ingots
are
shaped
using
grinding
and
cutting
tools,
and
the
wafers
are
sliced
from
the
ingot.
Chemical
etching
and
polishing
steps
are
then
performed
to
remove
wafer
damage
and
contamination
from
the
grinding
and
cutting
steps,
and
provide
the
final
smooth
surface
where
device
features
can
be
photoengraved.
Section
2.1
presents
a
more
detailed
description
of
this
process.

Semiconductor
fabrication
processes
are
performed
to
impart
various
devices
into
the
semiconductor.
These
processes
are
typically
performed
in
a
clean
room
environment
and
include
vapor
phase
metal
deposition,
lithography,
ion
implantation,
etching,
and
metalization.
Emerging
manufacturing
processes
performed
during
fabrication
include
a
lead
"
bump"
process
to
provide
more
connection
points
from
the
semiconductor
and
a
copper
metalization
process
to
deposit
additional
metal
layers
on
the
semiconductor.
Section
2.2
presents
a
more
detailed
description
of
the
semiconductor
fabrication
processes.
Semiconductor
assembly
and
packaging
processes
include
wafer
separation
and
sorting,
mounting
and
bonding
of
the
semiconductor
to
the
appropriate
mount
media,
electrically
connecting
the
semiconductor
to
the
package,
and
final
package
preparation.
Section
2.3
presents
a
more
detailed
description
of
semiconductor
assembly
and
packaging
processes.
April
21,
1998
2
2.1
Silicon
Crystal
Growth
And
Wafer
Preparation
Wafers,
which
consist
of
thin
sheets
of
crystalline
material,
are
the
starting
point
for
semiconductor
production.
Wafers
may
be
manufactured
at
the
semiconductor
manufacturing
facility
or
purchased
separately
from
a
wafer
manufacturer.

Silicon,
in
the
form
of
ingots,
is
the
primary
crystalline
material
used
in
the
production
of
99
%
of
all
semiconductors.
Several
techniques
are
available
to
grow
silicon
crystal
ingots
from
seed
crystals.
Most
semiconductor
manufacturers
obtain
single
crystal
silicon
ingots
from
other
firms
(
1).

In
the
first
step
of
wafer
preparation,
ingots
are
shaped
into
wafer
form
through
a
series
of
cutting
and
grinding
steps,
usually
performed
using
diamond­
tipped
tools.
The
ends
of
the
silicon
ingots
are
removed
and
individual
wafers
are
cut
from
the
ingot.
The
wafers
may
then
be
polished
using
an
aluminum
oxide/
glycerine
solution
to
provide
uniform
flatness
in
a
process
called
lapping.

This
initial
shaping
of
the
wafers
leaves
imperfections
in
the
surface
and
edge
of
the
wafers
that
are
removed
in
an
etching
step.
Chemical
etching
involves
the
use
of
hydrofluoric,
nitric,
or
acetic
acids
as
well
as
alkaline
solutions
of
potassium
or
sodium
hydroxide.

A
final
polishing
step
is
performed
to
provide
a
smooth
surface
for
subsequent
processing.
In
this
step,
wafers
are
mounted
on
a
fixture,
pressed
against
a
polishing
pad
under
high
pressure,
and
rotated
relative
to
the
pad.
A
polishing
slurry,
typically
containing
silicon
dioxide
particles
in
sodium
hydroxide,
is
used.
This
step
is
both
a
chemical
and
mechanical
process;
the
slurry
reacts
chemically
with
the
wafer
surface
to
form
silicon
dioxide,
and
the
silica
particles
in
the
slurry
abrade
the
oxidized
silicon
away.

In
some
cases,
silicon
wafers
are
ultrasonically
cleaned
in
potassium
chromate
or
other
mild
alkaline
solutions
(
1).
In
the
final
wafer
preparation
step,
the
wafers
are
usually
rinsed
in
deionized
water
and
dried
with
compressed
air
or
nitrogen
(
1).

2.2
Wafer
Fabrication
Wafers
are
usually
fabricated
in
batches
of
25
to
40
(
1).
The
wafer
fabrication
process
includes
the
following
steps:
oxidation,
lithography,
etching,
doping,
and
layering.
During
the
fabrication
process,
wafers
may
be
cycled
through
several
of
these
steps
and
some
of
the
steps
may
be
repeated
for
various
purposes
at
different
points
in
the
process.
Between
any
of
these
steps,
contaminants
are
cleaned
off
the
wafer
using
either
spray
or
immersion
solutions
of
acids,
bases,
or
organic
solvents.
April
21,
1998
3
2.2.1
Oxidation
During
oxidation,
a
silicon
dioxide
layer
is
grown
on
the
wafer
to
provide
a
base
for
the
lithography
process.
This
layer
also
serves
to
insulate
and
protect
the
wafer
during
subsequent
processing.
Oxidation
processes
may
be
dry
or
wet,
and
occur
in
high­
temperature
furnaces
(
e.
g.,
>
600EC).
In
the
furnace,
the
silicon
wafer
surface
oxidizes
with
steam
(
i.
e.,
wet
oxidation)
or
a
gas
such
as
oxygen
(
i.
e,
dry
oxidation)
to
form
a
silicon
dioxide
layer.
In
the
dry
oxidation
process,
a
chlorine
source
(
chlorine
gas,
anhydrous
hydrochloric
acid,
or
trichloroethylene)
may
be
used
to
alter
oxide
characteristics.

2.2.2
Lithography
Lithography
is
the
process
of
imaging
a
circuit
pattern
onto
a
wafer.
Lithography
requires
resolution
of
less
than
1
micrometer.
This
multistep
process
is
typically
accomplished
by
the
use
of
a
photomask
with
a
thin
layer
of
light­
sensitive
resist
material
applied
to
the
wafer.
The
resist
is
typically
spun
onto
the
wafer
and
baked
to
remove
any
solvent
remaining
in
the
resist
material.
The
photomask
is
a
glass
emulsion
plate
with
a
circuit
design
on
top
of
it
made
with
a
hard­
surface
material
(
e.
g.,
chromium,
chromium
oxide,
iron
oxide).
Light
is
projected
through
the
voids
in
the
photomask
that
causes
the
mask
pattern
to
become
imaged
on
the
wafer.

One
of
three
types
of
lithography
is
typically
used:
optical,
electron
beam,
or
X­
ray.
Each
type
has
specific
advantages
and
disadvantages
depending
on
the
device
type
and
stage
of
the
manufacturing
process.
The
majority
of
applications
are
optical
systems
using
ultraviolet
(
UV)
light.
The
description
given
below
is
for
a
UV
system,
but
other
systems
use
a
similar
process.

In
an
optical
system,
the
resist
is
exposed
to
UV
light
through
the
photomask
that
contains
the
circuit
pattern.
The
resist
either
polymerizes
(
hardens)
when
exposed
to
light
(
if
a
negative
resist
is
used)
or
unpolymerizes
(
if
a
positive
resist
is
used).
After
exposure,
the
wafer
is
developed
in
a
solution
that
dissolves
the
excess
resist
and
is
then
rinsed
to
remove
excess
developer
solution.
The
majority
of
development
processes
use
liquid
immersion
or
spray
methods,
but
dry
plasma
methods
are
also
used.
The
resulting
wafer
has
a
silicon
dioxide
layer
exposed
for
the
circuit
pattern,
with
the
rest
of
the
wafer
being
covered
with
the
remaining
resist
coating.

Electron­
beam
systems
result
in
greater
resolution
than
optical
systems
and
can
be
used
to
apply
a
circuit
pattern
directly
on
a
wafer
without
resist.
Electron­
beam
systems
are
typically
used
to
create
the
photomasks
used
in
optical
systems.
X­
ray
systems
also
result
in
greater
resolution
than
optical
systems,
but
are
not
widely
used
in
manufacturing
applications
(
2).
April
21,
1998
4
2.2.3
Etching
After
the
unreacted
resist
is
removed,
the
wafer
is
placed
in
a
solution
that
etches
the
exposed
silicon
dioxide
layer
but
does
not
remove
the
resist,
creating
the
circuit
pattern
in
the
silicon
dioxide
layer.
This
pattern
forms
areas
in
which
dopants
will
be
applied
to
provide
the
required
electrical
properties.
Several
etching
processes
are
available.

Wet
chemical
etching
uses
acid
solutions
to
etch
the
exposed
layer
of
silicon
dioxide
at
ambient
or
elevated
temperatures.
However,
wet
etching
is
ineffective
for
etching
multiple
plasmadeposited
layers
and
dry
etching
techniques
have
been
developed
that
are
effective.

In
the
most
commonly
used
dry
etching
technique,
plasma
etching,
dry
plasma
etches
are
formed
above
the
target
layer
by
ionizing
process
gases
under
a
vacuum.
Although
dry
etching
usually
involves
reactive
halogenated
gases,
nonhalogenated
gases
may
also
be
used.
Chemicals
used
during
the
dry
etching
process
include
chlorine,
hydrogen
bromide,
carbon
tetrafluoride,
sulfur
hexafluoride,
trifluoromethane,
fluorine,
fluorocarbons,
carbon
tetrachloride,
boron
trichloride,
hydrogen,
oxygen,
helium,
and
argon
(
1).
Other
dry
etching
techniques
include
sputter
etching,
ion
milling,
reactive
etching,
and
reactive
ion
beam
etching.

After
etching,
the
remaining
photoresist
is
removed
using
dry
or
liquid
stripping
compounds.
The
wafers
are
then
cleaned
prior
to
doping.

2.2.4
Doping
To
create
the
desired
electronic
components
(
transistors,
resistors,
etc.),
impurities
(
called
dopants)
are
introduced
into
the
wafer
to
change
the
conductivity
of
the
silicon.
Dopants
are
introduced
according
to
the
silicon
dioxide
pattern
on
the
wafer
either
by
diffusion
or
by
ion
implantation
processes.

In
the
diffusion
process,
vaporized
metals
(
i.
e.,
dopants)
diffuse
into
exposed
regions
of
the
wafer.
Dopant
atoms
are
introduced
using
either
a
dopant­
containing
vapor
in
high­
temperature
furnaces
(
400­
1000EC)
or
a
dopant­
oxide
layer
coated
on
the
wafer.
Dopants
include
elements
such
as
arsenic,
boron,
and
phosphorus.
Other
dopants
include
aluminum,
antimony,
beryllium,
gallium,
germanium,
gold,
magnesium,
silicon,
tellurium,
and
tin
(
1).

The
ion
implantation
process
is
a
physical
deposition
process
that
provides
greater
control
of
the
number
and
depth
of
dopant
atoms
than
does
the
diffusion
process.
In
the
ion
implantation
process,
dopant
sources
(
e.
g.,
metals)
are
ionized
in
a
vacuum
chamber
at
ambient
temperature.
The
ionized
particles
are
then
accelerated
to
high
velocities
and
imbedded
into
the
wafer
by
an
ion
implanter.
The
strength
of
the
ion
implanter
determines
the
process
gas
usage,
which
commonly
includes
arsine,
phosphine,
and
boron
trifluoride.
April
21,
1998
5
2.2.5
Layering
After
the
doping
process,
the
wafer
may
be
covered
with
a
layer
of
material
that
acts
as
a
conductor
(
e.
g.,
aluminum),
a
semiconductor
(
e.
g.,
silicon),
or
an
insulator
(
e.
g.,
silicon
dioxide),
depending
upon
the
chip
design.
Prior
to
the
layering
step,
the
wafer
is
cleaned.
After
a
layer
is
applied,
the
wafer
may
undergo
the
steps
previously
described
to
impart
additional
electrical
properties
and
circuits
to
the
wafer.
The
primary
layering
methods
available
include
deposition,
metalization,
and
dielectric
and
polysilicon
film
deposition.

Deposition
processes
are
used
to
apply
additional
layers
of
silicon,
silicon
dioxide,
or
other
materials
to
the
wafer.
Deposition
processes
typically
employ
epitaxial
growth,
in
which
the
substrate
wafer
acts
as
a
seed
crystal
for
the
new
layer.
Dopants
may
be
added
to
provide
electrical
properties.
Two
techniques
used
for
epitaxial
growth
are
chemical
vapor
deposition
(
CVD)
and
molecular
beam
epitaxy
(
MBE),
with
CVD
being
more
common.

During
CVD,
materials
are
vaporized
in
a
high­
temperature
reactant
chamber
furnace
to
produce
a
thin
layer
on
the
wafer.
Materials
that
may
be
used
during
CVD
include
silane,
silicon
tetrachloride,
ammonia,
nitrous
oxide,
tungsten
hexafluoride,
arsine,
phosphine,
and
diborane
(
1).
Another
gaseous
deposition
technique
is
low­
pressure
CVD,
which
uses
elevated­
temperature
vacuum
chambers
that
may
use
nitrogen,
silane,
arsine,
tetraethylorthosilicate
(
TEOS),
dichlorosilane,
ammonia,
hydrogen
fluoride,
and
nitrous
oxide.

In
MBE,
silicon
and
one
or
more
dopants
are
evaporated
and
transported
to
the
substrate
at
high
velocity
in
a
vacuum.
This
process
is
typically
performed
at
lower
temperatures
than
CVD.
Metalization
is
a
process
by
which
the
wafer
is
coated
with
thin
layers
of
metal
to
make
circuits.
Metalization
techniques
include
evaporation
and
sputtering.
The
evaporation
method
uses
high
temperatures
to
vaporize
a
metal
that
condenses
on
the
wafer
surface.
Metals
used
in
metalization
include
aluminum,
platinum,
titanium,
nickel,
chromium,
silver,
copper,
tungsten,
gold,
and
germanium.
Evaporation
methods
include
electron­
beam
evaporation,
resistance
heating
evaporation,
and
inductive
heating
evaporation.
Argon
gas
is
also
used
in
some
operations
(
1).

In
the
sputtering
process,
ionized
gas
atoms
(
e.
g.,
argon)
chip
pieces
off
a
target
metal
that
deposit
on
the
wafer
to
form
a
layer.
Metals
used
in
sputtering
include
titanium,
platinum,
gold,
molybdenum,
tungsten,
nickel,
and
cobalt.
Any
unnecessary
metals
from
this
process
may
be
removed
by
solvents
or
acid
solutions.

Dielectric
and
polysilicon
films
are
deposited
onto
the
wafer
to
provide
conducting
regions
within
the
device,
electrical
insulation
between
metals,
and
protection
from
the
environment
(
2).
The
most
widely
deposited
films
are
polycrystalline
silicon,
silicon
dioxide,
and
silicon
nitride.
Doping
elements
such
as
arsenic,
phosphorus,
or
boron
also
may
be
added
using
this
process.
Oxygen
may
be
added
to
polysilicon
films
to
act
as
a
semi­
insulating
material
used
for
passivating
the
surface.
April
21,
1998
6
After
the
final
layering,
the
wafer
is
rinsed
in
water
and
the
wafer
back
is
mechanically
ground.
A
film
of
gold
may
then
be
applied
to
the
wafer
back
by
an
evaporation
process.

2.2.6
Emerging
Technologies
in
Wafer
Fabrication
Semiconductor
manufacturing
facilities
recently
began
performing
a
Controlled
Collapse
Chip
Connection
(
C4),
or
"
lead
bump",
electroplating
process
to
add
lead
bumps
to
the
surface
of
the
wafer
to
act
as
connection
points.
According
to
industry
personnel,
this
process
is
required
to
allow
for
increased
connection
points
caused
by
decreased
circuit
size
(
hence
an
increase
in
the
number
of
devices
per
semiconductor).
This
process
is
followed
by
a
rinse
that
is
shared
with
other
semiconductor
fabrication
processes
in
a
clean
room
environment.
This
process
also
shares
a
wet
air
pollution
control
device
with
other
semiconductor
fabrication
processes.

Several
semiconductor
manufacturers
recently
began
performing
a
new
process
for
using
copper
to
replace
aluminum
in
microprocessors,
enhancing
electron
migration
and
reducing
the
width
of
the
circuitry.
These
sites
use
a
copper
metalization
process
in
which
copper
is
applied
with
an
electroplating
operation
followed
by
a
rinse.
This
process
is
part
of
a
sequence
of
photolithography,
etching,
and
copper
deposition
processes
performed
in
a
clean
room
environment.
The
process
deposits
a
microscopic
layer
of
copper
on
selected
(
i.
e.,
circuitry)
portions
of
the
wafer.

2.3
Semiconductor
Assembly
and
Packaging
The
final
step
in
manufacturing
semiconductors
consists
of
assembly
and
packaging
of
the
semiconductor
into
the
final
product.
The
semiconductors,
at
this
stage
called
chips
or
dies,
can
be
mounted
onto
the
surface
of
a
ceramic
substrate
as
part
of
a
circuit,
connected
directly
onto
a
printed
wiring
board,
or
incorporated
into
a
protective
package
(
4).
Assembly
and
packaging
consists
of
backside
preparation,
die
separation
and
sorting,
die
attach,
wire
bonding,
inspection,
plating,
trimming,
marking,
and
final
testing
(
4).
In
assembly
and
packaging,
the
chips
proceed
from
one
operation
to
the
next,
undergoing
each
operation
only
once,
though
the
order
of
processes
depends
on
the
package
type
and
other
factors.

Backside
preparation
consists
of
wafer
thinning
and
gold
deposition.
Chips
may
be
thinned
through
either
a
physical
(
i.
e.,
grinding
or
polishing)
or
chemical
(
i.
e.,
etching)
removal
process.
Some
chips
require
the
application
of
a
gold
layer
for
subsequent
attachment
to
the
package
via
eutectic
techniques.
In
this
case,
the
gold
is
usually
applied
in
the
fabrication
area
by
evaporation
or
sputtering
(
4).
After
backside
preparation,
the
wafer
is
separated
into
individual
chips
by
sawing
or
scribe­
andbreak
techniques.

After
separation,
the
functioning
die
are
identified,
sorted,
and
placed
in
carriers
for
subsequent
processing.
The
die
are
attached
to
the
package
using
either
a
gold­
silicon
eutectic
layer
or
an
epoxy
adhesive
material.
Thin
wires
are
then
bonded
between
the
chip
bonding
pads
and
the
April
21,
1998
7
inner
leads
of
the
package.
The
bonded
die
is
inspected
for
alignment,
bond
placement,
contamination,
die­
attach
quality,
and
bonding
quality
(
4).
The
outer
package
leads
are
coated
with
a
conductive
layer
to
improve
the
solderability
into
a
printed
wiring
board
and
to
provide
a
protective
coating
against
oxidation
or
corrosion.
The
leads
are
coated
with
either
lead­
tin
solder,
tin
plate,
or
gold
plate.
The
lead­
tin
solder
is
applied
either
by
dipping
the
packages
into
a
pot
of
molten
solder
or
by
wave
soldering.
The
tin
and
gold
layers
are
applied
electrolytically
through
an
electroplating
process
in
which
the
packages
are
mounted
on
racks
with
each
lead
connected
to
an
electric
potential.
The
racks
are
placed
in
the
electroplating
solution,
where
the
metal
is
applied.
This
process
is
followed
by
a
rinse.
The
electroplating
process
(
including
the
rinse)
is
typically
the
primary
source
of
process
wastewater
in
the
semiconductor
assembly
and
packaging
process.

After
the
conductive
layer
is
applied,
the
packages
go
through
a
trimming
operation
to
separate
the
leads
from
supports.
The
packages
are
then
marked
to
code
information
on
the
outside
of
the
package
enclosure,
after
which
they
undergo
a
series
of
tests,
including
electrical
and
environmental.

3.0
SUMMARY
OF
SITE
VISITS
At
the
request
of
members
of
the
semiconductor
manufacturing
industry,
EPA
and
its
technical
contractor,
Eastern
Research
Group,
Inc.
(
ERG),
conducted
site
visits
at
three
semiconductor
manufacturing
facilities.
The
purpose
of
these
visits
was
to
observe
operations
performed
at
semiconductor
fabrication
facilities
and
to
review
issues
relating
to
the
implementation
of
40
CFR
469
and
40
CFR
433
at
fabrication
facilities
that
perform
electroplating
operations.

The
first
facility
was
producing
0.25­
micron
microprocessors
for
personal
computers.
This
facility
receives
6­
inch
or
8­
inch
diameter
silicon
wafers,
and
performs
the
fabrication
processes
previously
described.
The
wafers
are
sent
off
site
for
assembly
and
packaging
processes.
At
the
time
of
the
visit,
the
facility
was
evaluating
implementing
the
lead
bump
process.
This
facility
contains
a
class
1
clean
room
(
less
than
one
particle
per
cubic
meter)
with
300,000
square
feet
of
surface
area.
The
clean
room
was
designed
such
that
large
portions
(
up
to
half)
of
the
clean
room
may
be
closed
for
construction
without
hampering
production.
This
allows
the
facility
to
continuously
upgrade
their
manufacturing
capabilities
to
reflect
newer
generation
technology.
Because
of
this
dynamic
nature,
the
basic
utilities
servicing
the
clean
room
(
e.
g.,
power,
ultrapure
water,
and
waste
and
wastewater
removal)
are
flexible.
Feed
lines
and
waste
removal
lines,
as
well
as
air
pollution
control
devices,
are
typically
set
up
to
service
specific
process
lines
within
the
clean
room.
The
following
types
of
waste
streams
are
generated
in
the
clean
room
and
segregated
for
subsequent
treatment:
hydrofluoric
acid
wastes,
solvents,
developing
solutions,
wastewater
with
high
dissolved
solids/
low
fluoride
content,
and
general
wastewater
streams.
The
facility
has
a
water
purification
system
consisting
of
ion
exchange
and
reverse
osmosis.
Because
of
the
product
specifications,
the
facility
requires
ultrapure
water
in
all
of
their
processes.
The
facility
uses
counter­
flow
rinses
when
possible
and
does
not
allow
much
impurity
build­
up
in
the
water.
The
facility
treats
process
wastewater
in
a
neutralization
system.
April
21,
1998
8
The
facility
also
has
a
specific
fluoride
removal
system
for
hydrofluoric
acid
wastes,
as
well
as
a
solvent
recovery
system.
Effluent
from
the
neutralization
system
is
discharged
to
a
reverse
osmosis
system
purchased
by
the
facility
and
operated
by
their
publicly
owned
treatment
works
(
POTW).

The
second
facility
manufactures
a
variety
of
semiconductors
and
microprocessors.
The
facility
receives
silicon
wafers
and
performs
the
fabrication
operations
described
above.
No
assembly
and
packaging
operations
were
observed
during
the
site
visit;
however,
these
may
be
performed
on
site.
The
site
visit
focused
on
fabrication
operations
performed
to
manufacture
memory
chips,
which
require
fewer
operations
and
metal
layers
than
the
microprocessors
produced
at
the
first
facility.
The
second
facility
was
constructed
in
1955,
and
is
one
of
the
oldest
semiconductor
manufacturing
facilities
in
the
world.
The
facility
has
been
upgraded
several
times;
the
operations
observed
during
the
site
visit
have
been
in
place
since
the
early
1980s.
The
facility
operates
eight
clean
rooms,
ranging
from
class
10
to
class
1000,
with
two
of
these
performing
electroplating
operations
in
addition
to
the
fabrication
operations
described
in
Section
2.0.

The
third
facility
visited
was
conducting
research
into
the
copper
metalization
process.
The
site
visit
focused
on
this
emerging
activity
and
site
personnel
provided
information
pertaining
to
the
copper
metalization
process.

4.0
APPLICABILITY
AND
OVERLAP
OF
40
CFR
469
AND
40
CFR
433
The
applicability
statement
at
40
CFR
469.10
explains
the
coverage
of
the
semiconductor
discharge
requirements
by
stating:

The
provisions
of
this
subpart
are
applicable
to
discharges
resulting
from
all
process
operations
associated
with
the
manufacture
of
semiconductors,
except
sputtering,
vapor
deposition,
and
electroplating
(
emphasis
added).

The
preamble
to
the
final
rule
(
48
FR
15382)
explains
that
these
process
operations
are
subject
to
the
electroplating
and
metal
finishing
requirements
at
Parts
413
and
433
respectively.
The
technical
support
document,
however,
contains
a
more
detailed
description
of
the
applicability
of
these
discharge
requirements.
The
following
discussion
is
based
on
the
document
titled
Development
Document
for
Effluent
Limitations
Guidelines
and
Standards
for
the
Electrical
and
Electronic
Components
Point
Source
Category
(
Phase
I)
(
EPA
440/
1­
83/
075)
and
on
a
regulatory
interpretation
from
Mr.
L.
Keith
Silva,
Pretreatment
Coordinator
for
USEPA
Region
9,
to
Mr.
John
E.
Watson,
Water
Quality
Supervisor
for
the
city
of
Phoenix,
Arizona
(
February
23,
1995).

During
the
manufacture
of
semiconductors,
material
is
selectively
added
and
etched
on
a
silicon
wafer.
Page
4­
4
of
the
Development
Document
explains
that:

The
etchant
produces
depressions,
called
holes
or
windows,
where
the
diffusion
of
dopants
later
occurs.
Dopants
are
impurities
such
as
boron,
phosphorus
and
other
April
21,
1998
9
specific
metals.
These
impurities
eventually
form
circuits
through
which
electrical
impulses
can
be
transmitted.
As
stated
by
Mr.
Silva
in
his
regulatory
interpretation
of
this
issue,
this
discussion
indicates
that
sputtering,
vacuum
deposition,
and
electroplating
are
regulated
under
40
CFR
Part
469
when
those
process
operations
are
associated
with
the
photolithographic­
etching­
diffusion­
oxide
process
sequence
in
the
semiconductor
fabrication
process.
These
operations
may
occur
a
number
of
times
depending
on
the
application
of
the
semiconductor.

Page
4­
5
of
the
Development
Document
explains
that
the
electroplating
and
metal
finishing
requirements
apply
to
those
process
operations
associated
with
wafer
assembly:

After
the
diffusion
processes
are
completed,
a
layer
of
metal
is
deposited
onto
the
surface
of
the
wafer
to
provide
contact
points
for
final
assembly.
The
metals
used
for
this
purpose
include
aluminum,
copper,
chromium,
gold,
nickel,
platinum,
and
silver.
The
processes
associated
with
the
application
of
the
metal
layer
are
covered
by
the
electroplating
or
metal
finishing
effluent
limitations
and
standards.

The
Development
Document
for
40
CFR
469
explains
that
"
the
electroplating
and
metal
finishing
requirements
apply
to
those
process
operations
that
prepare
the
wafer
for
final
assembly."
(
5)
The
document
specifically
discusses
electroplating
used
to
deposit
a
layer
of
metal
on
the
surface
of
the
wafer
to
provide
contact
points
for
final
assembly.
This
operation
has
traditionally
been
performed
in
the
assembly
process,
as
opposed
to
the
fabrication
process,
of
semiconductor
manufacturing.

With
the
recent
development
of
the
copper
metalization
and
lead
bump
processes
(
described
in
Section
2.2),
electroplating
operations
more
frequently
are
performed
in
the
fabrication
process.
The
copper
metalization
and
lead
bump
operations
are
electroplating,
in
which
a
metal
is
electrochemically
deposited
on
a
substrate,
and
could
potentially
be
regulated
under
40
CFR
433.
Both
operations
are
performed
in
clean
room
environments,
using
the
same
tools
(
i.
e.,
process
sinks)
as
40
CFR
469
operations.
Both
operations
share
ancillary
equipment
(
e.
g.,
air
pollution
control
scrubbers,
cleaning
equipment)
with
40
CFR
469
operations.

The
wastewater
discharge
rates
from
the
copper
metalization
and
lead
bump
operations
are
typically
less
than
1%
of
the
discharge
rates
from
the
40
CFR
469
operations
(
6).
Since
this
is
generally
such
a
small
percentage
of
the
total
flow,
it
may
be
difficult
to
demonstrate
compliance
if
both
40
CFR
469
and
433
are
used
to
regulate
wastestreams
in
the
wafer
fabrication
area.
In
such
cases
the
facilities
may
have
to
monitor
at
the
source.
For
a
facility
such
as
the
first
facility,
this
would
require
installing
dedicated
sinks
for
electroplating,
dedicated
ancillary
equipment,
and
dedicated
piping
systems.
Given
that
the
manufacturing
processes
at
the
first
facility
are
upgraded
every
one
to
two
years,
this
may
require
complex
and
costly
retrofits
or
may
not
be
technically
feasible.
April
21,
1998
10
5.0
CONCLUSION
There
are
new,
emerging
technologies
involved
in
semiconductor
wafer
fabrication
which
involve
electroplating
type
operations.
In
these
operations,
metal
is
applied
with
an
electroplating
operation
followed
by
a
rinse
which
may
lead
permitting
authorities
to
believe
the
40
CFR
Part
433
regulations
should
apply.
However,
as
described
above,
due
to
emerging
wafer
fabrication
technologies
the
electroplating
operations
in
wafer
fabrication
and
electroplating
operations
regulated
by
40
CFR
Part
433
can
be
distinguished:

°
In
the
wafer
fabrication
process,
electroplating
type
operations
add
microscopic
amounts
of
metal
to
selective
portions
of
the
wafer
to
enhance
the
circuitry
and
decrease
wafer
size.
°
In
the
final
assembly
and
packaging
process,
metal
layers
are
applied
electrolytically
through
an
electroplating
process
in
which
the
packages
are
mounted
on
racks.
Each
lead
connects
to
an
electric
potential
to
provide
contact
points
for
final
assembly.
The
racks
are
placed
in
the
electroplating
solution,
where
the
metal
is
applied.
This
process
is
followed
by
a
rinse.
This
is
typical
of
the
electroplating
processes
considered
in
the
development
of
the
Part
433
regulation.

After
carefully
reviewing
both
the
Part
469
and
433
regulations
and
their
associated
background
documents;
examining
past
regulatory
interpretations;
visiting
semiconductor
manufacturing
facilities;
speaking
with
the
industry;
and
reviewing
current
articles
and
books
on
the
processes,
the
Agency
believes
that
semiconductor
manufacturing
can
be
broken
into
two
sections
for
the
purposes
of
applying
the
requirements
of
40
CFR
Parts
469
and
433.
The
first
section
is
the
wafer
fabrication
process
and
the
second
section
is
the
final
assembly
and
packaging
process.
The
Agency
believes
that
the
metal
finishing
requirements
contained
in
part
433
only
cover
the
process
after
wafer
fabrication
which
is
used
to
deposit
a
layer
of
metal
onto
the
surface
of
the
wafer
to
provide
contact
points
for
final
assembly.
April
21,
1998
11
6.0
REFERENCES
(
1)
EPA.
1995a.
Profile
of
the
Electronics
and
Computer
Industry.
U.
S.
Environmental
Protection
Agency,
Office
of
Compliance,
EPA/
310­
R­
95­
002.
Washington,
D.
C.

(
2)
Sze,
S.
M.,
ed.
1983.
VLSI
Technology.
McGraw­
Hill
Publishing
Company,
New
York,
New
York
(
3)
Letter
from
Ms.
Julia
Hatcher
and
Ms.
Ann
Claassen,
Latham
&
Watkins
Attorneys
at
Law,
to
Mr.
Tudor
Davies
and
Mr.
Eric
Schaeffer,
U.
S.
EPA.
October
10,
1997.

(
4)
Van
Zant,
P.,
1990.
Microchip
Fabrication.
McGraw­
Hill
Publishing
Company,
New
York,
New
York
(
5)
Letter
from
Mr.
Keith
Silva,
EPA
Region
IX,
to
Mr.
John
Watson,
City
of
Phoenix.
February
23,
1995.

(
6)
Information
provided
to
EPA
by
the
Semiconductor
Industry
Association.
December
16,
1997.
