Transcript Materials Lifecycle Solutions

MACT DEVELOPMENT
DEFINITIONS
HAP - HAZARDOUS AIR POLLUTANTS: FEDERAL LIST OF
188 COMPOUNDS AND COMPOUND CATAGORIES.
COMMON SEMICONDUCTOR INORGANIC HAPs - ARSINE
(PART OF ARSENIC COMPOUNDS), PHOSPHINE, HCl, HF
AND CHLORINE.
INORGANIC HAPs “NOT” - FLUORINE, SILICON
TETRAFLUORIDE, SILANE, AMMONIA, BORON
TRIFLUORIDE AND HYDROGEN.
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MACT DEVELOPMENT
DEFINITIONS (CONTINUED)
COMMON SEMICONDUCTOR ORGANIC HAPs METHANOL, XYLENES, ETHYL BENZENE, ETHYLENE
GLYCOL, MEK, MIBK AND GLYCOL ETHER COMPOUNDS.
ORGANIC HAPs “NOT” - PGMEA (DOES NOT MEET
GLYCOL ETHER COMPOUNDS DEFINITION), IPA,
PFC’S AND ACETONE.
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MACT DEVELOPMENT
DEFINITIONS (CONTINUED)
MACT - MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY,
WHICH IS TOP PERFORMING CONTROL TECHNOLOGY
FOR HAZARDOUS AIR POLLUTANTS (HAP).
PTE - POTENTIAL TO EMIT (MAXIMUM CAPACITY).
MAJOR HAPs SOURCE - SEMICONDUCTOR SITE WITH
PTE OF 10 TONS/YEAR OR MORE OF ONE HAP OR PTE
OF 25 TONS/YEAR OR MORE OF COMBINED HAPS.
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MACT DEVELOPMENT
DEFINITIONS (CONTINUED)
SYNTHETIC MINOR HAPs SOURCE - A NON-MAJOR
SEMICONDUCTOR SITE WITH PTE OF 10 TONS/YEAR OR
MORE OF ONE HAP OR PTE OF 25 TONS/YEAR OR MORE
OF COMBINED HAPS WITH NO CONTROL (I.E. IF CONTROL
IS REMOVED).
MINOR OR NATURAL MINOR HAPs SOURCE - A NONMAJOR SEMICONDUCTOR SITE WITH PTE OF LESS
THAN 10 TONS/YEAR OF ONE HAP OR PTE OF LESS
THAN 25 TONS/YEAR OF COMBINED HAPS WITH NO
CONTROL.
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MACT DEVELOPMENT
BRIEF HISTORY
SEMICONDUCTOR MACT ORIGINALLY SCHEDULED
FOR NOVEMBER, 1997. DELAYED UNTIL
NOVEMBER, 2000. STILL NOT OUT.
SIA/EPA IN NEGOTIATIONS SINCE EARLY 1990’S.
CURRENT CHAIR IS TIM HIGGS, INTEL.
ONLY A COUPLE OF MAJOR HAP SOURCES IN
UNITED STATES TODAY.
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MACT DEVELOPMENT
BRIEF HISTORY
EARLY PROPOSED MACT BY EPA WAS  99%
CONTROL FOR INORGANICS AND ORGANICS.
THIS FORCED USE OF THERMAL OXIDIZERS FOR
VOC CONTROL, WHICH CREATED MORE CO & NOx
AND USED MORE ENERGY THAN OTHER TYPES.
VERY DIFFICULT TO MEET DUE TO LOW INLET
CONCENTRATIONS OF HCl, HF AND CHLORINE
INTO WET SCRUBBERS, AND OUTLET
MEASUREMENT ISSUES.
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MACT DEVELOPMENT
BRIEF HISTORY
SIA ABLE TO TECHNICALLY CONVINCE EPA
OF:
1. INLET CONCENTRATIONS VERY LOW AND
IMPACTS CONTROL EFFICIENCY FOR BOTH
WET SCRUBBERS AND VOC CONTROL.
2. MACT SHOULD INCLUDE OUTLET
CONCENTRATION AS WELL AS CONTROL
EFFICIENCY (I.E. 95% OR OUTLET
CONCENTRATION OF 1 PPMv).
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MACT DEVELOPMENT
BRIEF HISTORY
SIA ABLE TO TECHNICALLY CONVINCE EPA
OF:
3. CONTINUOUS MONITORING IS DIFFICULT
TO DO AT LOW OUTLET CONCENTRATIONS.
4. ORGANIC HAPs SHOULD BE MEASURED
AS TOTAL VOCs.
5. INORGANIC HAPs - USE HCl AS SURROGATE.
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MACT DEVELOPMENT
BRIEF HISTORY
ONLY A FEW MAJOR SEMICONDUCTOR HAP
SOURCES, SO SUBMITTED DELIST PETITION IN
2000 TO REMOVE SEMICONDUCTOR INDUSTRY
FROM ANY MACT REGULATIONS.
EPA STANCE - NO MAJOR HAP SOURCES BEFORE
CONSIDERING DELIST PETITION.
ONE MAJOR SOURCE CANNOT BECOME MINOR
SOURCE (CO-LOCATED FACILITY WITH 1000’s
OF TONS/YEAR HAP EMISSIONS).
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MACT DEVELOPMENT
TODAY’S STATUS
DELIST PETITION ON HOLD BY EPA. NOT LOOKING
GOOD.
DRAFT MACT REGULATIONS BY EPA IN FOURTH
QUARTER, 2001.
MACT HAMMER FALLS MAY, 2002. FINAL MACT
REGULATION SHOULD BE HERE BEFORE THEN.
FIRST ENVIRONMENTAL LAW SUIT AGAINST EPA,
INCLUDES SEMICONDUCTOR MACT.
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MACT DEVELOPMENT
WHAT IS MACT LOOKING LIKE TODAY?
INORGANIC HAPs - WET SCRUBBERS, WITH LESS
THAN 20 PPMv OUTLET CONCENTRATION AS HCl.
ORGANIC HAPs - VOC CONTROLS, WITH LESS
THAN 20 PPMv OUTLET CONCENTRATION AS TOTAL
VOCs.
CHEMICAL STORAGE TANKS (E.G. HYDROCHLORIC
ACID FOR RO/DI) - 99% CONTROL OR 1 PPMv
OUTLET. SIA SUBMITTING FURTHER DATA TO
MODIFY THESE REQUIREMENTS.
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MACT DEVELOPMENT
WHAT IS MACT LOOKING LIKE TODAY?
NO REQUIREMENTS FOR WASTEWATER
TREATMENT, BOILERS, DIESEL GENERATORS,
AND WASTE STORAGE TANKS.
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MACT DEVELOPMENT
ITEMS TO DETERMINE
EPA NEEDS TO DETERMINE IF MACT REGULATIONS
APPLY TO AREA SOURCES (SYNTHETIC AND
NATURAL MINOR SOURCES).
MONITORING AND RECORD KEEPING
REQUIREMENTS.
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MACT DEVELOPMENT
ISSUES
HOW WILL MACT BE IMPLEMENTED BY LOCAL
AIR REGULATORY AUTHORITIES?
WHAT IMPACT WILL THERE BE FROM LAW SUIT?
CAN MACT BE ISSUED BEFORE MAY, 2002?
WHAT WILL HAPPEN WITH DELIST PETITION?
Materials Lifecycle Solutions