The World Leader in High-Performance Signal Processing Solutions 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 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.