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.