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. 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.

Materials Lifecycle Solutions 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. 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.

Materials Lifecycle Solutions 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. 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.

Materials Lifecycle Solutions 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 NON- MAJOR 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. 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 NON- MAJOR 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.

Materials Lifecycle Solutions MACT DEVELOPMENT BRIEF HISTORY SEMICONDUCTOR MACT ORIGINALLY SCHEDULED FOR NOVEMBER, DELAYED UNTIL NOVEMBER, 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. BRIEF HISTORY SEMICONDUCTOR MACT ORIGINALLY SCHEDULED FOR NOVEMBER, DELAYED UNTIL NOVEMBER, 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.

Materials Lifecycle Solutions 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 & NO x 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. 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 & NO x 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.

Materials Lifecycle Solutions 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). 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).

Materials Lifecycle Solutions 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. 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.

Materials Lifecycle Solutions 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). 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).

Materials Lifecycle Solutions MACT DEVELOPMENT TODAY’S STATUS DELIST PETITION ON HOLD BY EPA. NOT LOOKING GOOD. DRAFT MACT REGULATIONS BY EPA IN FOURTH QUARTER, MACT HAMMER FALLS MAY, FINAL MACT REGULATION SHOULD BE HERE BEFORE THEN. FIRST ENVIRONMENTAL LAW SUIT AGAINST EPA, INCLUDES SEMICONDUCTOR MACT. TODAY’S STATUS DELIST PETITION ON HOLD BY EPA. NOT LOOKING GOOD. DRAFT MACT REGULATIONS BY EPA IN FOURTH QUARTER, MACT HAMMER FALLS MAY, FINAL MACT REGULATION SHOULD BE HERE BEFORE THEN. FIRST ENVIRONMENTAL LAW SUIT AGAINST EPA, INCLUDES SEMICONDUCTOR MACT.

Materials Lifecycle Solutions MACT DEVELOPMENT WHAT IS MACT LOOKING LIKE TODAY? INORGANIC HAPs - WET SCRUBBERS, WITH LESS THAN 20 PPM v OUTLET CONCENTRATION AS HCl. ORGANIC HAPs - VOC CONTROLS, WITH LESS THAN 20 PPM v OUTLET CONCENTRATION AS TOTAL VOCs. CHEMICAL STORAGE TANKS (E.G. HYDROCHLORIC ACID FOR RO/DI) - 99% CONTROL OR 1 PPM v OUTLET. SIA SUBMITTING FURTHER DATA TO MODIFY THESE REQUIREMENTS. WHAT IS MACT LOOKING LIKE TODAY? INORGANIC HAPs - WET SCRUBBERS, WITH LESS THAN 20 PPM v OUTLET CONCENTRATION AS HCl. ORGANIC HAPs - VOC CONTROLS, WITH LESS THAN 20 PPM v OUTLET CONCENTRATION AS TOTAL VOCs. CHEMICAL STORAGE TANKS (E.G. HYDROCHLORIC ACID FOR RO/DI) - 99% CONTROL OR 1 PPM v OUTLET. SIA SUBMITTING FURTHER DATA TO MODIFY THESE REQUIREMENTS.

Materials Lifecycle Solutions MACT DEVELOPMENT WHAT IS MACT LOOKING LIKE TODAY? NO REQUIREMENTS FOR WASTEWATER TREATMENT, BOILERS, DIESEL GENERATORS, AND WASTE STORAGE TANKS. WHAT IS MACT LOOKING LIKE TODAY? NO REQUIREMENTS FOR WASTEWATER TREATMENT, BOILERS, DIESEL GENERATORS, AND WASTE STORAGE TANKS.

Materials Lifecycle Solutions 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. ITEMS TO DETERMINE EPA NEEDS TO DETERMINE IF MACT REGULATIONS APPLY TO AREA SOURCES (SYNTHETIC AND NATURAL MINOR SOURCES). MONITORING AND RECORD KEEPING REQUIREMENTS.

Materials Lifecycle Solutions 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? 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?