materials lifecycle solutions mact development definitions hap - hazardous air pollutants: federal...

Materials Lifecycle Solutions

MACT DEVELOPMENTMACT DEVELOPMENTDEFINITIONS

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.


MACT DEVELOPMENTMACT DEVELOPMENTDEFINITIONS (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.



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.


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.



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.


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.


MACT DEVELOPMENTMACT DEVELOPMENTBRIEF 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.

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.



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.

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.



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


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).




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


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.



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).


MACT DEVELOPMENTMACT DEVELOPMENTTODAY’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.

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.


MACT DEVELOPMENTMACT DEVELOPMENTWHAT 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.

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.


MACT DEVELOPMENTMACT DEVELOPMENTWHAT 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.


MACT DEVELOPMENTMACT DEVELOPMENTITEMS 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.


MACT DEVELOPMENTMACT DEVELOPMENTISSUES

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?

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