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 lt2 or gt12.5)
• Ignitable (Flashpoint lt 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- PCBs, 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 companys 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
• Dont 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.