Hazardous Waste Management in the Semiconductor Industry

1. Hazardous Waste Management in the Semiconductor Industry Ron Scholtz- CHMM, REA Analog Devices, Inc. October 7, 2003

2. What is a Hazardous Waste? • Hazardous wastes are generated from the many types of semiconductor manufacturing processes. • Hazardous wastes are chemicals that can no longer be used, recycled, or resold and need to be disposed. • Regulated under the Federal Resource Conservation and Recovery Act (RCRA) as well as State of California regulations (Title 22) • Hazardous wastes have one or more of the following characteristics: • Corrosive (pH <2 or >12.5) • Ignitable (Flashpoint < 140F) • Reactive • Toxic

3. Waste Management Strategies • Minimize the generation of wastes as much as feasible. • Minimize the hazard of the waste generated as much as feasible. • Manage the waste on-site where possible (treatment). • Select the off-site disposal technology which reduces the long term liabilities as much as possible. • Recycle • Treatment • Incineration • Landfill • Ensure that the wastes are handled and disposed in accordance with all laws and regulations. • Ensure that off-site disposers are handling wastes properly and they present no unnecessary liabilities.

4. Corrosive Wastes • Typical corrosive wastes include: Sulfuric Acid, Hydrofluoric Acid, Phosphoric Acid, Nitric Acid, Ammonium Hydroxide, Hydrogen Peroxide, Tetramethyl Ammonium Hydroxide • Acids are used for etching, stripping, and cleaning wafers • Tetramethyl Ammonium Hydroxide is a positive photoresist developer • Corrosive wastes are treated in on-site in elementary acid neutralization systems • Flow through system • Uses Caustic and Acid to adjust pH to between 6 and 10 • Discharges to local POTW • Hydrofluoric Acid wastes are treated in on-site fluoride precipitation systems • Batch treatment process • Generate calcium fluoride filter cake- landfill • Treated water goes to POTW

5. Ignitable Wastes • Photoresists (PGMEA), Isopropyl Alcohol, Strippers, Acetone, n-Butyl Acetate, Xylene (old) • Strippers are a proprietary blends of organic acids or bases • Collected in drums or tanks • Sent off-site for recycle, fuel blending, or incineration

6. Contaminated Solids • Acid contaminated gloves and wipes- generated from used PPE, clean-up of small drips • Solvent contaminated gloves and wipes- generated from used PPE, wipe cleaning of parts, spill clean-up • Arsenic contaminated gloves and wipes- generated from ion implant maintenance activities • Lead contaminated gloves and wipes- generated from lead soldering housekeeping activities • Many waste minimization opportunities- human element • Pelletize and use as a fuel source • Others must be incinerated

7. “Special” Wastes • Not RCRA regulated, but must be properly disposed. • Expired Batteries- metals • Fluorescent Light Bulbs- mercury • Lighting Ballasts- PCB’s, oil, metals • Reject product- lead • Computer monitors- lead • Empty aerosol cans • Lead blocks • Asbestos construction materials • Cafeteria grease • Empty chemical bottles

8. Generator Requirements (40 CFR) • EPA ID number • Waste characterization and analysis • Proper storage- containment, containers, aisles • Security of storage areas • Employee training • Weekly inspections • Emergency response • Proper labeling- HW label, DOT hazard label, accumulation start date • Uniform hazardous waste manifest- DOT shipping requirements apply (49 CFR) • Approved transporters • Approved TSDF facilities for off-site disposal • Fees, reports

9. “Tiered Permitting” • California allows certain on-site treatment of hazardous wastes under the “tiered permitting” system rather than requiring a full TSDF permit. • Acid neutralization, HF precipitation, and bottle wash apply. • Conditionally Exempt, Conditionally Authorized, and Permit by Rule tiers. • Initial notification and permit approval • Annual report to lead agency- DTSC or CUPA • Tank and containment certifications • Closure cost estimate • Financial assurance certifications

10. Off-Site Disposal Facilities • It is very important that the off-site disposal facility has the ability, commitment, financial resources, and high level of compliance to handle a company’s wastes. • Always audit a new facility before sending any wastes to them. • Periodically audit existing facilities- changes in ownership • Use an audit checksheet • There are services available that provide audit reports • Comes down to a gut-check level of comfort • Sometimes TSDF facilities are not readily available in local areas or have limited capabilities • Don’t spread out the liability too much. Try to limit to only a few good facilities with multiple capabilities • Superfund, CERCLA, clean-up costs, liability- good key words when discussing options with management

11. Source Reduction • SB-14 Hazardous Waste Source Reduction and Management Review Act of 1989 • Requires a “Source Reduction Evaluation Review and Plan” every 4 years. Focuses on wastes that represent 5% or more of total. “Aqueous wastes” and “manifested wastes” • Requires a “Hazardous Waste Management Performance Report” covering the previous 4 years. • Must be made available to the public on request. The State focuses on several industry sectors each year. Semiconductor industry is currently being reviewed by the State DTSC. • A seminar (jointly with SESHA) and executive report will be generated by the State demonstrating success stories within the industry.

12. Source Reduction Approaches • Approaches include: • Input Changes- raw material changes • Operational Improvements- loss prevention, waste segregation, maintenance • Production Process Changes- changes in temperature, pressure, automation, equipment changes • Product Reformulations- changes in design, composition, or specification of final product • Administrative Steps- inventory control, employee programs • Other

13. Source Reduction Evaluation • Evaluation criteria includes: • Amount of waste reduced • Technical feasibility • Economic feasibility • Effects on product quality • Employee health and safety • Regulatory compliance • Releases and discharges to other media

14. Summary • Minimize the generation of wastes as much as feasible. • Minimize the hazard of the waste generated as much as feasible. • Manage the waste on-site where possible (treatment). • Select the off-site disposal technology which reduces the long term liabilities as much as possible • Ensure that the wastes are handled and disposed in accordance with all laws and regulations. • Ensure that off-site disposers are handling wastes properly and they present no unnecessary liabilities.