Sector Notebook Project Electronics and Computer Industry
This report is one in a series of volumes published by the U.S. Environmental
Protection Agency (EPA) to provide information of general interest regarding
environmental issues associated with specific industrial sectors. The documents
were developed under contract by Abt Associates (Cambridge, MA), and Booz-
Allen & Hamilton, Inc. (McLean, VA). This publication may be purchased from the
Superintendent of Documents, U.S. Government Printing Office. A listing of
available Sector Notebooks and document numbers is included on the following
page.
All telephone orders should be directed to:
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 512-1800
FAX (202) 512-2250
8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be
directed to:
U.S. Government Printing Office
P.O. Box 371954
Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as
public and academic libraries, Federal, State, local, and foreign governments, and
the media. For further information, and for answers to questions pertaining to these
documents, please refer to the contact names and numbers provided within this
volume.
Electronic versions of all Sector Notebooks are available free of charge at the
following web address: www.epa.gov/oeca/sector. Direct technical questions to the
"Feedback" button at the bottom of the web page.
Cover photograph by Steve Delaney, EPA. Photographs courtesy of Automata Company,
Sterling, VA. Special thanks to Emad Youssef.
September 1995 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
EPA/310-R-95-002
EPA Office of Compliance Sector Notebook Project
PROFILE OF THE ELECTRONICS AND COMPUTER INDUSTRY
September 1995
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401MSt.,SW(MC2221-A)
Washington, DC 20460
SIC Code 36 ii September 1995
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Sector Notebook Project
Electronics and Computer Industry
Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance.
Questions relating to the Sector Notebook Project can be directed to:
Seth Heminway, Coordinator, Sector Notebook Project
US EPA Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017
Questions and comments regarding the individual documents can be directed to the
appropriate specialists listed below.
Document Number
EPA/310-R-95-001.
EPA/310-R-95-002.
EPA/310-R-95-003.
EPA/310-R-95-004.
EPA/310-R-95-005.
EPA/310-R-95-006.
EPA/310-R-95-007.
EPA/310-R-95-008.
EPA/310-R-95-009.
EPA/310-R-95-010.
EPA/310-R-95-011.
EPA/310-R-95-012.
EPA/310-R-95-013.
EPA/310-R-95-014.
EPA/310-R-95-015.
EPA/310-R-95-016.
EPA/310-R-95-017.
EPA/310-R-95-018.
EPA/310-R-97-001.
EPA/310-R-97-002.
EPA/310-R-97-003.
EPA/310-R-97-004.
EPA/310-R-97-005.
EPA/310-R-97-006.
EPA/310-R-97-007.
EPA/310-R-97-008.
EPA/310-R-97-009.
EPA/310-R-97-010.
EPA/310-R-98-001.
EPA/310-R-98-002.
EPA/310-R-98-003.
EPA/310-R-98-004.
EPA/310-R-98-005.
Industry
Dry Cleaning Industry
Electronics and Computer Industry*
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry*
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry*
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry*
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.
Air Transportation Industry
Ground Transportation Industry
Water Transportation Industry
Metal Casting Industry
Pharmaceuticals Industry
Plastic Resin and Man-made Fiber Ind.
Fossil Fuel Electric Power Generation Ind.
Shipbuilding and Repair Industry
Textile Industry
Sector Notebook Data Refresh-1997
Aerospace Industry
Agricultural Chemical, Pesticide, and
Fertilizer Industry
Agricultural Crop Production Industry
Agricultural Livestock Production Ind.
Oil and Gas Exploration and ProductionDan Chadwick
Industry
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Jane Engert
Anthony Raia
Jane Engert
Rob Lischinsky
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Seth Heminway
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Anthony Raia
Belinda Breidenbach
Seth Heminway
Anthony Raia
Amy Porter
Phone (202)
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-5021
564-6045
564-5021
564-2628
564-7067
564-7003
564-7072
564-7017
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-6045
564-7022
564-7017
564-6045
564-4149
Ginah Mortensen (913)551-7864
Ginah Mortensen (913)551-7864
564-7054
September 1995
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Electronics and Computer Industry Sector Notebook Project
EPA/310-R-98-008. Local Government Operations John Dombrowski 564-7036
*Spanish translations available.
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Sector Notebook Project Electronics and Computer Industry
ELECTRONICS AND COMPUTER INDUSTRY
(SIC 36)
TABLE OF CONTENTS
Page
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
IA Summary of the Sector Notebook Project 1
I.E. Additional Information 2
II. INTRODUCTION TO THE ELECTRONICS/COMPUTER INDUSTRY 4
II. A. Introduction, Background, and Scope of the Notebook 4
II.B. Characterization of the Electronics/Computer Industry 5
II.B.I. Industry Size and Geographic Distribution 6
II.B.2. Product Characterization 9
II.B.3. Economic Trends 10
III. INDUSTRIAL PROCESS DESCRIPTION 13
III.A. Industrial Processes in the Electronics/Computer Industry 13
III.A.I. Semiconductor Manufacturing 13
III.A.2. Printed Wiring Board Manufacturing 24
III.A.3. Cathode Ray Tube Manufacturing 31
III.B. Raw Materials Inputs and Pollution Outputs 39
III.C. Management of Chemicals in Wastestream 41
IV. CHEMICAL RELEASE AND TRANSFER PROFILE 43
IV.A. EPA Toxic Release Inventory for the Electronics/Computer Industry
46
IV.A.I. TRI Data for Semiconductor Industry 46
IV.A.2. TRI Data for Printed Wiring Board Industry 50
IV.A.3. TRI Data for Cathode Ray Tube Industry 54
IV.B. Summary of Selected Chemicals Released 57
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Electronics and Computer Industry Sector Notebook Project
ELECTRONICS AND COMPUTER INDUSTRY
(SIC 36)
TABLE OF CONTENTS (CONT'D)
Page
IV.C. Other Data Sources 66
IV.D. Comparison of Toxic Release Inventory Between Selected Industries
68
V. POLLUTION PREVENTION OPPORTUNITIES 71
V. A. Identification of Pollution Prevention Activities in Use 72
V.B. Pollution Prevention Techniques for the
Electronics/Computer Industry 73
V.B.I. Examples of Source Reduction and Recycling
Options for Electroplating Operations 73
V.B.2. Examples of Source Reduction and Recycling
Options for Etching Operations 77
V.B.3. Examples of Source Reduction and Recycling
Options for Semiconductor Manufacturing 77
V.B.4. Examples of Source Reduction and Recycling
Options for Printed Wiring Board Manufacturing 78
V.B.4.a. General Operations 78
V.B.4.b. Cleaning Operations 80
V.B.4.C. Electroplating Operations 80
V.B.5. Examples of Source Reduction and Recycling
Options for Cathode Ray Tube Manufacturing 80
V.C. Pollution Prevention Case Studies 81
VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS 85
VI. A. General Description of Major Statutes 85
VLB. Industry Specific Requirements 97
VI.B.l. Notable State Regulations 101
VI.C. Pending and Proposed Regulatory Requirements 101
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Sector Notebook Project Electronics and Computer Industry
ELECTRONICS AND COMPUTER INDUSTRY
(SIC 36)
TABLE OF CONTENTS (CONT'D)
Page
VII. COMPLIANCE AND ENFORCEMENT HISTORY 104
VILA. Electronics/Computer Industry Compliance History 108
VII.B. Comparison of Enforcement Activity Between
Selected Industries 110
VII.C. Review of Major Legal Actions 115
VII.C.I. Review of Major Cases 115
VII.C.2. Supplemental Environmental Projects 116
VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES 118
VIII.A. Sector-Related Environmental Programs and Activities 118
VIII.A.l. Federal Activities 118
VIII.A.2. State Activities 120
VIII.B. EPA Voluntary Programs 122
VIII.C. Trade Association Activity 127
VIII.C.I. Environmental Programs 127
VIII.C.2. Trade Associations 128
IX. BIBLIOGRAPHY/OTHER MATERIALS AVAILABLE 132
September 1995 vii SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
ELECTRONICS AND COMPUTER INDUSTRY
(SIC 36)
EXHIBITS INDEX
Page
Exhibit 1 Facility Size Distribution of Electronics/Computer Industry 7
Exhibit 2 Top 10 Worldwide Electronics/Computer Industry Companies 7
Exhibit 3 Geographic Distribution of and Number of Companies in the
Electronics/Computer Industry (SIC 3671, 3672, and 3674) 9
Exhibit 4 Percentage of Companies in the Electronics/Computer Industry
(SIC 3671, 3672, and 3674) by Region 9
Exhibit 5 Doping Processes 15
Exhibit 6 Photolithography Process 18
Exhibit 7 Chemicals Used in Photolithography for Semiconductors 19
Exhibit 8 Plastic Package Components 22
Exhibit 9 Chemicals Used in Lamination, Drilling, and Cleaning 26
Exhibit 10 Chemicals Used in Photolithography for
Printed Wiring Boards 27
Exhibit 11 Materials Used During Etching 28
Exhibit 12 Materials Used in Copper and Tin-Lead Electro- and
Electroless Plating Processes 29
Exhibit 13 Color CRT Manufacturing Process 33
Exhibit 14 Semiconductor Pollution Outputs 39
Exhibit 15 Printed Wiring Board Pollution Outputs 39, 40
Exhibit 16 Cathode Ray Tube Pollution Outputs 40
Exhibit 17 Source Reduction and Recycling Activity for SIC 36 42
Exhibit 18 Top 10 TRI Releasing Semiconductor Manufacturing
Facilities (SIC 3674) 47
Exhibit 19 Top 10 TRI Releasing Electronics/Computer
Industry Facilities 47
Exhibit 20 TRI Reporting Semiconductor Manufacturing Facilities
(SIC 3674) by State 48
Exhibit 21 Releases for Semiconductor Manufacturing Facilities
(SIC 3674) in TRI, by Number of Facilities
(Releases Reported in Pounds/Year) 49
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Sector Notebook Project
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ELECTRONICS AND COMPUTER INDUSTRY
(SIC 36)
EXHIBITS INDEX (CONT'D)
Exhibit 22 Transfers for Semiconductor Manufacturing Facilities
(SIC 3674) in TRI, by Number of Facilities
(Transfers Reported in Pounds/Year) 50
Exhibit 23 Top 10 TRI Releasing Printed Wiring Board Manufacturing
Facilities (SIC 3672) 51
Exhibit 24 TRI Reporting Printed Wiring Board Manufacturing Facilities
(SIC 3672) by State 51
Exhibit 25 Releases for Printed Wiring Board Manufacturing Facilities
(SIC 3672) in TRI, by Number of Facilities
(Releases Reported in Pounds/Year) 52, 53
Exhibit 26 Transfers for Printed Wiring Board Manufacturing Facilities
(SIC 3672) in TRI, by Number of Facilities
(Transfers Reported in Pounds/Year) 53, 54
Exhibit 27 Top 10 TRI Releasing Cathode Ray Tube Manufacturing
Facilities (SIC 3671) 55
Exhibit 28 TRI Reporting Cathode Ray Tube Manufacturing Facilities
(SIC 3671) by State 55
Exhibit 29 Releases for Cathode Ray Tube Manufacturing Facilities
(SIC 3671) in TRI, by Number of Facilities
(Releases Reported in Pounds/Year) 56
Exhibit 30 Transfers for Cathode Ray Tube Manufacturing Facilities
(SIC 3671) in TRI, by Number of Facilities
(Transfers Reported in Pounds/Year) 56, 57
Exhibit 31 Pollutant Releases (Short Tons/Year) 67
Exhibit 32 Summary of 1993 TRI Data: Releases
and Transfers by Industry 69
Exhibit 33 Toxic Release Inventory Data for Selected Industries 70
Exhibit 34 Hazardous Wastes Relevant to the Electronics/Computer
Industry 100
Exhibit 35 Five-Year Enforcement and Compliance Summary for the
Electronics/Computer Industry 109
Exhibit 36 Five-Year Enforcement and Compliance Summary for Selected
Industries Ill
September 1995
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SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
ELECTRONICS AND COMPUTER INDUSTRY
(SIC 36)
EXHIBITS INDEX (CONT'D)
Exhibit 37 One-Year Enforcement and Compliance Summary for Selected
Industries 112
Exhibit 38 Five-Year Inspection and Enforcement Summary by Statute for
Selected Industries 113
Exhibit 39 One-Year Inspection and Enforcement Summary by
Statute for Selected Industries 114
Exhibit 40 Supplemental Environmental Projects
Electronics/Computer Industry (SIC 36) 117
Exhibit 41 Electronics/Computer Industry Facilities (SIC 36)
Particpating in the 33/50 Program 123
SIC Code 36
September 1995
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Sector Notebook Project
Electronics and Computer Industry
ELECTRONICS AND COMPUTER INDUSTRY
(SIC 36)
LIST OF ACRONYMS
AFS - AIRS Facility Subsystem (CAA database)
AIRS - Aerometric Information Retrieval System (CAA database)
BIFs - Boilers and Industrial Furnaces (RCRA)
BOD - Biochemical Oxygen Demand
CAA - Clean Air Act
CAAA - Clean Air Act Amendments of 1990
CERCLA - Comprehensive Environmental Response, Compensation and
Liability Act
CERCLIS - CERCLA Information System
CFCs - Chlorofluorocarbons
CO - Carbon Monoxide
COD Chemical Oxygen Demand
CSI - Common Sense Initiative
CWA - Clean Water Act
D&B - Dun and Bradstreet Marketing Index
ELP - Environmental Leadership Program
EPA - United States Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act
FINDS - Facility Indexing System
HAPs - Hazardous Air Pollutants (CAA)
HSDB - Hazardous Substances Data Bank
IDEA - Integrated Data for Enforcement Analysis
LDR - Land Disposal Restrictions (RCRA)
LEPCs - Local Emergency Planning Committees
MACT - Maximum Achievable Control Technology (CAA)
MCLGs - Maximum Contaminant Level Goals
MCLs - Maximum Contaminant Levels
MEK - Methyl Ethyl Ketone
MSDSs - Material Safety Data Sheets
NAAQS - National Ambient Air Quality Standards (CAA)
NAFTA - North American Free Trade Agreement
NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP - National Oil and Hazardous Substances Pollution Contingency Plan
NEIC - National Enforcement Investigation Center
NESHAP - National Emission Standards for Hazardous Air Pollutants
NO2" Nitrogen Dioxide
NOV - Notice of Violation
September 1995
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Electronics and Computer Industry
Sector Notebook Project
ELECTRONICS AND COMPUTER INDUSTRY
(SIC 36)
LIST OF ACRONYMS (CONT'D)
NOX - Nitrogen Oxide
NPDES - National Pollution Discharge Elimination System (CWA)
NPL - National Priorities List
NRC - National Response Center
NSPS - New Source Performance Standards (CAA)
OAR - Office of Air and Radiation
OECA - Office of Enforcement and Compliance Assurance
OPA - Oil Pollution Act
OPPTS - Office of Prevention, Pesticides, and Toxic Substances
OSHA - Occupational Safety and Health Administration
OSW - Office of Solid Waste
OSWER - Office of Solid Waste and Emergency Response
OW- Office of Water
P2 - Pollution Prevention
PCS - Permit Compliance System (CWA Database)
POTW - Publicly Owned Treatments Works
RCRA - Resource Conservation and Recovery Act
RCRIS - RCRA Information System
SARA - Superfund Amendments and Reauthorization Act
SDWA - Safe Drinking Water Act
SEPs - Supplementary Environmental Projects
SERCs - State Emergency Response Commissions
SIC - Standard Industrial Classification
SO2 - Sulfur Dioxide
TOC - Total Organic Carbon
TRI - Toxic Release Inventory
TRIS - Toxic Release Inventory System
TCRIS - Toxic Chemical Release Inventory System
TSCA - Toxic Substances Control Act
TSS - Total Suspended Solids
UIC - Underground Injection Control (SDWA)
UST - Underground Storage Tanks (RCRA)
VOCs - Volatile Organic Compounds
SIC Code 36
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Sector Notebook Project Electronics and Computer Industry
ELECTRONICS AND COMPUTER INDUSTRY
(SIC 36)
I. Introduction to the Sector Notebook Project
LA. Summary of the Sector Notebook Project
Environmental policies based upon comprehensive analysis of air,
water, and land pollution are an inevitable and logical supplement to
traditional single-media approaches to environmental protection.
Environmental regulatory agencies are beginning to embrace
comprehensive, multi-statute solutions to facility permitting,
enforcement and compliance assurance, education/outreach, research,
and regulatory development issues. The central concepts driving the
new policy direction are that pollutant releases to each environmental
medium (air, water, and land) affect each other, and that
environmental strategies must actively identify and address these
inter-relationships by designing policies for the "whole" facility. One
way to achieve a whole facility focus is to design environmental
policies for similar industrial facilities. By doing so, environmental
concerns that are common to the manufacturing of similar products
can be addressed in a comprehensive manner. Recognition of the need
to develop the industrial "sector-based" approach within the EPA
Office of Compliance led to the creation of this document.
The Sector Notebook Project was initiated by the Office of Compliance
within the Office of Enforcement and Compliance Assurance (OECA)
to provide its staff and managers with summary information for
eighteen specific industrial sectors. As other EPA offices, States, the
regulated community, environmental groups, and the public became
interested in this project, the scope of the original project was
expanded. The ability to design comprehensive, common sense
environmental protection measures for specific industries is dependent
on knowledge of several inter-related topics. For the purposes of this
project, the key elements chosen for inclusion are: general industry
information (economic and geographic); a description of industrial
processes; pollution outputs; pollution prevention opportunities;
Federal statutory and regulatory framework; compliance history; and
a description of partnerships that have been formed between
regulatory agencies, the regulated community, and the public.
September 1995 1 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
For any given industry, each topic listed above could alone be the
subject of a lengthy volume. However, in order to produce a
manageable document, this project focuses on providing summary
information for each topic. This format provides the reader with a
synopsis of each issue, and references where more in-depth
information is available. Text within each profile was researched from
a variety of sources, and was usually condensed from more detailed
sources pertaining to specific topics. This approach allows for a wide
coverage of activities that can be further explored based upon the
citations and references listed at the end of this profile. As a check on
the information included, each notebook went through an external
review process. The Office of Compliance appreciates the efforts of all
those that participated in this process and enabled us to develop more
complete, accurate, and up-to-date summaries. Many of those who
reviewed this notebook are listed as contacts in Section IX and may be
sources of additional information. The individuals and groups on this
list do not necessarily concur with all statements within this notebook.
I.E. Additional Information
Providing Comments
OECA's Office of Compliance plans to periodically review and update
the notebooks and will make these updates available both in hard copy
and electronically. If you have any comments on the existing
notebook, or if you would like to provide additional information,
please send a hard copy and computer disk to the EPA Office of
Compliance, Sector Notebook Project, 401 M St., SW (2223-A),
Washington, DC 20460. Comments can also be uploaded to the
Enviro$en$e Bulletin Board or the Enviro$en$e World Wide Web for
general access to all users of the system. Follow instructions in
Appendix A for accessing these data systems. Once you have logged
in, procedures for uploading text are available from the on-line
Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
The scope of the existing notebooks reflect an approximation of the
relative national occurrence of facility types that occur within each
sector. In many instances, industries within specific geographic
regions or States may have unique characteristics that are not fully
captured in these profiles. For this reason, the Office of Compliance
encourages State and local environmental agencies and other groups to
SIC Code 36 2 September 1995
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Sector Notebook Project Electronics and Computer Industry
supplement or re-package the information included in this notebook to
include more specific industrial and regulatory information that may
be available. Additionally, interested States may want to supplement
the "Summary of Applicable Federal Statutes and Regulations" section
with State and local requirements. Compliance or technical assistance
providers may also want to develop the "Pollution Prevention" section
in more detail. Please contact the appropriate specialist listed on the
opening page of this notebook if your office is interested in assisting us
in the further development of the information or policies addressed
within this volume.
If you are interested in assisting in the development of new notebooks
for sectors not covered in the original eighteen, please contact the
Office of Compliance at 202-564-2395.
September 1995 3 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
II. INTRODUCTION TO THE ELECTRONICS/COMPUTER INDUSTRY
This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition
of the Electronics/Computer industry. The type of facilities described
within the document are also described in terms of their Standard
Industrial Classification (SIC) codes. Additionally, this section
contains a list of the largest companies in terms of sales.
II. A. Introduction, Background, and Scope of the Notebook
The electronics/computer industry is classified by the U.S. Bureau of
Census as SIC code 36. SIC 36 includes manufacturers of electrical
distribution equipment, household appliances, communication
equipment, electrical industrial apparatus, radio and television
receiving equipment, electronic components and accessories, electrical
wiring and lighting equipment, and other electrical equipment and
supplies. The electronics/computer industry is comprised of five
major sectors: telecommunications, computers, industrial electronics,
consumer electronics, and semiconductors. Many segments of the
electronics/computer industry are interdependent and share common
manufacturing processes.
The Department of Commerce provides the following three-digit
breakout for industries in SIC 36:
SIC 361 - Transformers
SIC 362 - Motors/Generators
SIC 363 - Household Appliances
SIC 364 - Electrical Wiring and Lighting Equipment
SIC 365 - Household Audio and Video Equipment and
Audio Recordings
SIC 366 - Communication Equipment
SIC 367 - Printed Wiring Boards (also commonly called
Printed Circuit Boards), Semiconductors,
Integrated Circuits, and Cathode Ray Tubes
SIC 369 - Storage Batteries, Primary Batteries (wet and dry).
In 1988, the U.S. Bureau of Census reclassified some of the
manufacturing of computer parts, such as semiconductors, printed
wiring boards, and integrated microcircuits, and included them with
the component industries in SIC code 36. For the purpose of this
profile, computer equipment (SIC 35) and the electronics/computer
SIC Code 36 4 September 1995
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Sector Notebook Project Electronics and Computer Industry
industry (SIC 36) have been combined because of the overlapping
industry segments. Currently there is no SIC code for electronic
assemblies manufactured by the electronic manufacturing services
industry (EMSI), otherwise known as contract assemblies. Electronic
assemblies are sometimes classified under SIC 3679 as indicated by the
Institute for Interconnecting and Packaging Electronic Circuits (IPC).
Due to the vast size of the electronics and computer industries, this
profile will focus on the distinct equipment and products that raise
environmental concerns.
II.B. Characterization of the Electronics/Computer Industry
The electronics/computer industry produces a variety of products
such as batteries, televisions, computer chips/components, and
household appliances. During the manufacture of many of these
products, chemicals are released into the environment. This profile
will focus on three products:
SIC 3674 - Semiconductors and Related Devices
SIC 3672 - Printed Wiring Boards (PWBs)
SIC 3671 - Cathode Ray Tubes (CRTs).
The profile focuses on semiconductors and not integrated circuits
because integrated circuits are used to produce semiconductors and
most electronic devices manufactured today are multiple
devices/circuit chips. Semiconductors, although accounting for only a
small portion of total industry sales, are crucial to all electronic
products and to the U.S. economy and pose numerous environmental
concerns. PWBs and CRTs also raise environmental concerns from
their manufacturing processes.
The following sections describe the size and geographic distribution,
product characterization, and economic trends of the
electronics/computer industry and specifically semiconductors, PWBs,
and CRTs. The information provided in the following sections was
compiled from a variety of sources including the Bureau of Census,
documents developed by The World Bank, U.S. International Trade
Commission, and the U.S. Department of Commerce.
September 1995 5 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
II.B.I. Industry Size and Geographic Distribution
Variation in facility counts occur across data sources due to many
factors, including reporting and definitional differences. This
document does not attempt to reconcile these differences, but rather
reports the data as they are maintained by each source.
Size Distribution
The U.S. has the largest electronics (including computer) workforce in
the world, although Japan, the Republic of Korea, and other Asian
nations are experiencing rapid growth in their electronics workforces.
The size of the U.S. domestic electronics workforce for SIC 36 was
estimated to be 2.39 million in 1991, while the number of worldwide
employees was estimated to be four million. In addition, the
electronics/computer industry is estimated to provide four million
additional jobs to people who support and service U.S. electronics
firms. The electronics/computer industry provides more jobs than any
other manufacturing sector in the U.S., three times as many jobs as
automotive manufacturing, and nine times more than the steel
industry. The electronics/computer industry has not, however,
experienced growth in domestic employment for the past two and one-
half years. In fact, since 1989, the industry has lost 210,000 jobs.
IPC states that this stagnation in job growth is caused primarily by two
factors: increased productivity and increased competition by foreign
manufacturers that may have fewer government regulations. IPC also
notes that the U.S. electronic manufacturing services industry or
contract assembly industry is one of the fastest growing industries in
the country, employing over 150,000 people.
The following exhibit lists the segments of the industry highlighted in
this profile, as well as the number of facilities with fewer than and
greater than 20 employees. Just under 50 percent of semiconductor
and PWB manufacturing facilities have greater than 20 employees.
SIC Code 36 6 September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 1
Facility Size Distribution of Electronics/Computer Industry
SIC Code
3674
Semiconductors and
Related Devices
3672
Printed Wiring Boards
3671
Cathode Ray Tubes
Number of
Facilities with
<20 Employees
484
734
120
Number of
Facilities with
> 20 Employees
439
591
69
Percentage of
Facilities with
> 20 Employees
48%
45%
37%
Source: Based on 1992 Bureau of the Census data. Preliminary Report Industry Series.
Exhibit 2 lists the top ten electronics/computer industry companies
worldwide according to a 1992 addition of Electronic News. The
companies are listed in descending order of electronic sales during the
latest available four quarters in 1992. Many of these top ten companies
are not from the United States. However, a representative from the
Electronic Industries Association (EIA) noted that many of these
international companies have manufacturing facilities in the United
States. Corporations that are among the top 25 in terms of electronic
sales include AT&T, General Motors, Xerox, Apple Computer, Hewlett
Packard, Motorola, and General Electric.
Exhibit 2
Top 10 Worldwide Electronics/Computer Industry Com
Company Name
IBM
Matsushita Electric
Toshiba
NEC
Fujitsu
Philips
Hitachi
Siemens
Sony
Alcatel Alsthom
1992 Electronic
Sales in Millions of
Dollars
$53,600
$48,668
$29,232
$28,375
$25,879
$25,747
$25,107
$24,550
$22,959
$20,892
panies
Source: Based on 1992 Electronic News.
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Geographic Distribution
Exhibit 3 displays the number of electronics/computer industry
facilities in each State for SIC 3671, 3672, and 3674. As seen in Exhibit
4, approximately 38 percent (3,689) of the facilities in the
electronics/computer industry are located in EPA Region IX1. Region
V has approximately 13 percent of the electronics/computer industry
facilities. Across the U.S., approximately 60 percent of the facilities in
the electronics/computer industry are located in six States: California
(34 percent), Texas (6.5 percent), Massachusetts (6.4 percent), New
York (4.5 percent), Illinois (4.4 percent), and Pennsylvania (4 percent).
The U.S. semiconductor industry is concentrated in California, New
York, and Texas, specifically to be near primary users, transportation
routes, utility and telecommunication infrastructures, and engineering
experts. Texas, Oregon, and Colorado also received a large portion of
capital investments by semiconductors producers during 1986-1992.
Manufacturers have selected these States because of low tax rates, land
values, and energy prices.
California has the largest concentration of industry workers,
accounting for almost one-third of the semiconductor industry's
employment. Texas, Arizona, New York, and Massachusetts also have
high employment in the semiconductor industry. The majority of
PWB manufacturers are located in Texas, California, Illinois, New
York, Minnesota, and Massachusetts. According to Dun & Bradstreet,
approximately 51 manufacturers produce cathode ray tubes (CRTs) in
the U.S.; most of them are located in Illinois, Indiana, Ohio, Kentucky,
Pennsylvania, and California (1994).
Regions include the following States: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI);
III (DC, DE, MD, PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN,
OH, WI); VI (AR, LA, NM, OK, TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT,
WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, WA).
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Exhibit 3
Geographic Distribution of and Number of Companies in the
Electronics/Computer Industry (SIC 3671, 3672, and 3674)
153
Source: Based on 1992 Bureau of the Census data.
Exhibit 4
Percentage of Companies in the Electronics/Computer Industry
(SIC 3671, 3672, and 3674) by Region
Region I:
Region II:
Region III:
Region IV:
Region V:
10.8%
8.0%
6.0%
7.6%
13.1%
Region VI:
Region VII:
Region VIII:
Region IX:
Region X:
7.2%
1.4%
3.4%
37.6%
4.8%
II.B.2. Product Characterization
Semiconductors
Although semiconductors account for only a small portion of
electronics/computer industry sales, this product is crucial to all
electronic products and to the U.S. economy. Semiconductors can
serve one of two purposes: they act as a conductor, by guiding or
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moving an electrical current; or as an insulator, by preventing the
passage of heat or electricity. Semiconductors are used in computers,
consumer electronic products, telecommunication equipment,
industrial machinery, transportation equipment, and military
hardware. Typical functions of semiconductors in these products
include information processing, display purposes, power handling,
data storage, signal conditioning, and conversion between light and
electrical energy sources. According to EPA's Design for the
Environment (DfE) initiative, computers are the principal end use of
semiconductors, constituting 40 percent of the market in 1992.
Printed Wiring Boards
Computers are also the major U.S. market for PWBs, with
communications being the second largest application market. The
Institute for Interconnecting and Packaging Electronic Circuits (IPC)
indicates that nearly 39 percent of printed wiring boards produced in
1993 were used by the computer market, while 22 percent were used
by the communication industry. PWBs and assemblies are used in
many electronic products such as electronic toys, radios, television
sets, electrical wiring in cars, guided-missile and airborne electronic
equipment, computers, biotechnology, medical devices, digital
imaging technology, and industrial control equipment.
Cathode Ray Tubes
According to EPA's Common Sense Initiative (CSI) subcommittee, the
CRT industry produces tube glass, color picture tubes and single
phosphor tubes, television sets, and computer displays. Currently,
nearly all projection television tube and computer display
manufacturers and the majority of CRT glass manufacturers are
located outside the United States. Therefore, this CRT industry profile
focuses on the production of color picture tubes, single phosphor
tubes, and rebuilt tubes (collectively called CRTs and categorized
under SIC 3671). These products are the video display component of
televisions, computer displays, military and commercial radar, and
other display devices.
II.B.3. Economic Trends
For the past two decades, worldwide production of electronics
(including computers) has grown faster than any other industrial
sector. The American Electronics Association (AEA) estimates that
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domestic sales of U.S. electronics companies increased from $127
billion to $306 billion during the period from 1980 to 1990. According
to the U.S. Department of Commerce, the value of shipments (sale of
computer products and services) in the computer industry declined
during the 1990-1991 recession, but has experienced growth since then.
The value of shipments increased two percent in 1993 to $8.3 billion
and is expected to increase another two percent in 1994, to $8.48
billion. U.S. exports of the electronics/computer industry have
increased at an average rate of 18 percent since 1977.
EIA indicates that the U.S. electronics/computer industry has
experienced a 13 percent growth in production in 1994. Japan now
holds the largest share of global consumer electronics production; 49
percent in 1990. Although the U.S. produced a little over 10 percent of
global consumer electronics equipment, it is one of the two largest
consumers of such products, with purchases totaling $33 billion in
1990.
Semiconductors
The U.S. semiconductor industry has experienced growth since 1992.
The U.S. global market share of semiconductors, semiconductor
processing equipment, and computer systems fell between 1980 to
1991. Japanese firms gained most of the market share lost by U.S.
firms. Although the U.S. continues to be the world's largest consumer
of electronics products, as a result of Japan's growth in consumer
electronics production, Japan is now the world's largest consumer of
semiconductors. The U.S. is the second largest market in the world for
semiconductors, with consumption at $17.4 billion in 1990. The five
largest U.S. producers are Motorola, Intel, Texas Instruments, National
Semiconductor, and Advanced Micro Devices. According to the
Department of Commerce, the value of shipments of U.S.
semiconductors is estimated to be $37.6 billion in 1993 and is expected
to grow 12 percent in 1994 to over $42.1 billion.
Printed Wiring Boards/Electronic Assemblies
Japan and the U.S. now have equal market shares, 27 percent each.
IPC notes that the U.S. was the largest PWB market in the world with a
value of approximately $5.5 billion in 1993. According to the
Department of Commerce, the value of printed wiring board
shipments produced in the U.S. was $6.75 billion in 1993 and is
expected to grow by three percent, to $6.95 billion, in 1994. According
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to IPC, the U.S. electronic manufacturing services industry or contract
assemblies industry generates over $9 billion in revenue.
Cathode Ray Tubes
According to 1994 U.S. Industrial Outlook data, the total value of CRT
shipments was $3 billion in 1993 and is expected to increase six percent
to $3.2 billion in 1994. The total value of CRT shipments is expected to
increase more than 3.5 percent per year due to a projected rising
demand for television sets and computer displays.
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III. INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the
electronics/computer industry, including the materials and equipment
used, and the processes employed. The section is designed for those
interested in gaining a general understanding of the industry, and for
those interested in the inter-relationship between the industrial process
and the topics described in subsequent sections of this profile
pollutant outputs, pollution prevention opportunities, and Federal
regulations. This section does not attempt to replicate published
engineering information that is available for this industry. Refer to
Section IX for a list of reference documents that are available.
This section specifically contains a description of commonly used
production processes, associated raw materials, the byproducts
produced or released, and the materials either recycled or transferred
off-site. This discussion, coupled with schematic drawings of the
identified processes, provide a concise description of where wastes
may be produced in the processes. This section also describes the
potential fate (air, water, land) of these waste products.
III.A. Industrial Processes in the Electronics/Computer Industry
The products discussed in this section, semiconductors, printed wiring
boards (PWBs), and cathode ray tubes (CRTs), pose significant
environmental concerns during the manufacturing processes and/or
comprise a large portion of the electronics/computer industry. This
section will describe and distinguish these products as well as the
steps followed to manufacture them. This discussion also includes an
explanation of the wastes generated during the manufacturing
processes.
III.A.I. Semiconductor Manufacturing
Semiconductors are made of a solid crystalline material, usually
silicone, formed into a simple diode or many integrated circuits. A
simple diode is an individual circuit that performs a single function
affecting the flow of electrical current. Integrated circuits combine two
or more diodes. Up to several thousand integrated circuits can be
formed on the wafer, although 200-300 integrated circuits are usually
formed. The area on the wafer occupied by integrated circuits is called
a chip or die.
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Information in this section is from a variety of sources including the
following: U.S. EPA's DfE initiative, U.S. EPA Common Sense
Initiative (CSI), California Department of Toxic Substances Control,
McGraw Hill Encyclopedia of Science and Technology, Integrated
Circuits, Making the Miracle Chip, Microchip Fabrication: A Practical Guide
to Semiconductor Processing, and Microelectronics and Computer
Technology Corporation (MCC). The semiconductor manufacturing
process is complex and may require that several of the steps be
repeated to complete the process. To simplify this discussion, the
process has been broken down into five steps:
Design
Crystal processing
Wafer fabrication
Final layering and cleaning
Assembly.
The primary reason that semiconductors fail is contamination,
particularly the presence of any microscopic residue (including
chemicals or dust) on the surface of the base material or circuit path.
Therefore, a clean environment is essential to the manufacture of
semiconductors. Cleaning operations precede and follow many of the
manufacturing process steps. Wet processing, during which
semiconductor devices are repeatedly dipped, immersed, or sprayed
with solutions, is commonly used to minimize the risk of
contamination.
Step One: Design
As with any manufacturing process, the need for a particular type of
product must be identified and process specifications must be
developed to address that need. In the case of semiconductors, the
circuit is designed using computer modeling techniques. Computer
simulation is used to develop and test layouts of the circuit path.
Then, patterning "masks," which are like stencils, are fabricated,
manufacturing equipment is selected, and operating conditions are set.
All of these steps occur prior to actually producing a semiconductor.
Step Two: Crystal Processing
Wafers, which consist of thin sheets of crystalline material, are the
starting point of semiconductor production. Silicon, in the form of
ingots, is the primary crystalline material used in the production of 99
percent of all semiconductors. Silicon crystals are actually "grown"
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using controlled techniques to ensure a uniform crystalline structure.
Because crystals of pure silicon are poor electrical conductors,
controlled amounts of chemical impurities or dopants are added
during the development of silicon ingots to enhance their
semiconducting properties. Dopants are typically applied using
diffusion or ion implantation processes (See Exhibit 5). Dopants
eventually form the circuits that carry the flow of current.
Diffusion is a chemical process which exposes the regions of the
silicon surface to vapors of the metal additive (dopant) while
maintaining high temperatures. The process ends when the
additives (represented by the arrow in Exhibit 5) migrate to the
proper depth and reach the appropriate concentration in the
silicon wafer.
Ion implantation is a process that allows for greater control of
the location and concentration of dopants added to the wafer.
Metal dopants are ionized and accelerated to a high speed. As
shown in Exhibit 5, the ions penetrate the silicon surface and
leave a distribution of the dopant.
Exhibit 5
Doping Processes
\
r n
Thermal Diffusion
Ion Source
u
Ion Implantation
Source: Based on 1990 Microchip Fabrication: A Practical Guide to Semiconductor Processing.
Either doping process can be used in semiconductor manufacturing.
Antimony, arsenic, phosphorus, and boron compounds are the dopant
materials most commonly used for silicon-based semiconductors.
Other dopants include aluminum, gallium, gold, beryllium,
germanium, magnesium, silicon, tin, and tellurium. Wastes including
antimony, arsenic, phosphorus, and boron may be generated in the
wastewater as a result of ion implantation or diffusion. Excess dopant
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gases, contaminated carrier gases, and out-gassed dopant gases from
semiconductor materials may also be generated.
Most semiconductor manufacturers obtain single crystal silicon ingots
from other firms. Ingots are sliced into round wafers approximately
0.76 mm (0.03 inches) thick and then rinsed. The wafers are further
prepared by mechanical or chemical means. A wafer's surface may be
mechanically ground, smoothed, and polished, as well as chemically
etched so that the surface is smooth and free of oxides and
contaminants. Chemical etching removes organic contaminants using
cleaning solvents and removes damaged surfaces using acid solutions.
Chemical etching is usually followed by a deionized water rinse and
drying with compressed air or nitrogen. In some cases, bare silicon
wafers are cleaned using ultrasound techniques, which involve
potassium chromate or other mildly alkaline solutions.
Etching is a method of cutting into, or imprinting on, the surface of a
material. Several etching processes can be used on semiconductors, as
well as integrated circuits and printed wiring boards. Wet etching
uses acid solutions to cut patterns into the metal. Dry etching involves
reactive gases and is rapidly becoming the method of choice for high
resolution. Dry etching processes use various halogenated or
nonhalogenated gaseous compounds.
In the semiconductor industry, dry plasma etching, reactive ion
etching, and ion milling processes are being developed to overcome
the limitations of wet chemical etching. Dry plasma etching, the most
advanced technique, allows for etching of fine lines and features
without the loss of definition. This process forms a plasma above the
surface to be etched by combining large amounts of energy with low
pressure gases. The gases usually contain halogens.
Materials used during the wet etching process may include acids
(sulfuric, phosphoric, hydrogen peroxide, nitric, hydrofluoric, and
hydrochloric), ethylene glycol, hydroxide solutions, and solutions of
ammonium, ferric, or potassium compounds. Materials used during
the dry etching process may include chlorine, hydrogen bromide,
carbon tetrafluoride, sulfur hexafluoride, trifluoromethane, fluorine,
fluorocarbons, carbon tetrachloride, boron trichloride, hydrogen,
oxygen, helium, and argon. Typical solvents and cleaning agents
include acetone, deionized water, xylene, glycol ethers, and isopropyl
alcohol. The most commonly used cleaning solution in semiconductor
manufacturing includes a combination of hydrogen peroxide and
sulfuric acid.
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Acid fumes and organic solvent vapors may be released during
cleaning, etching, resist drying, developing, and resist stripping
operations. Hydrogen chloride vapors may also be released during
the etching process.
Step Three: Wafer Fabrication
Wafers are usually fabricated in batches of 25 to 40. Wafer preparation
begins with an oxidation step.
Oxidation is a process in which a film of silicon dioxide is
formed on the exterior surface of the silicon wafer. Thermal
oxidation takes place in a tube furnace with controlled, high
temperatures and a controlled atmosphere. Oxidation is a
reaction between the silicon wafer surface and an oxidant gas
such as oxygen or steam. This process may be needed as a
preliminary step before diffusion or ion implantation (doping).
This layer protects the wafer during further processing.
Following oxidation, the wafer surface is thoroughly cleaned
and dried.
Materials used during oxidation, include silicon dioxide, acids
(hydrofluoric), and solvents. Materials such as oxygen, hydrogen
chloride, nitrogen, trichloroethane, and trichloroethylene may also be
used. Wastes that may be generated from this process include: organic
solvent vapors from cleaning gases; rinsewaters with organic solvents
from cleaning operations; spent solvents (including F003); and spent
acids and solvents in the wastewater.
Next, patterns are imprinted onto the substrate using
photolithography (also referred to as lithography) and etching
processes. Photolithography is the most crucial step in semiconductor
manufacturing because it sets a device's dimensions; incorrect patterns
affect the electrical functions of the semiconductor.
Photolithography is a process similar to photoprocessing
techniques and other etching processes in that a pattern is
imprinted. The silicon wafer is coated uniformly with a thin
film of resist. A glass plate or mask is created with the circuit
pattern, and the pattern is imprinted in one of several ways.
One type of optical photolithography is the projection of x-rays
through a special mask close to the silicon slice. Another type
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of optical photolithography, one that does not need a mask, is
electron-beam direct patterning, which uses a controllable
electron beam and an electron sensitive resist. Once the pattern
is developed, some areas of the wafer are clear and the rest are
covered with resist (See Exhibit 6).
Exhibit 6
Photolithography Process
Process Step
Purpose
Cross Section
I
1. Alignment and
exposure
Precise alignment of mask to wafer
and exposure to U.V. light. Negative
resist is polymerized.
Z. Development Removal of unpolymerized resist.
3. Etch
Selective removal of top surface layer.
4. Photoresist Cleaning of photoresist from the
Removal wafer's surface.
5. Final Inspection of wafer for correctness of
Inspection image transfer from photoresist to top
layer.
Source: Based on 1990 Microchip Fabrication: A Practical Guide to Semiconductor Processing.
Two types of photoresists can be used during semiconductor
production:
Positive photoresists are chemicals that are made more soluble,
with regard to a solvent (i.e., developer), after exposure to
radiation. During development, the developer removes the
resist that was exposed to radiation.
Negative photoresists are chemicals that polymerize and
stabilize upon exposure to radiation. During development, the
developer removes the resist that was protected from radiation.
After photolithography, chemical developers are used to remove
unnecessary coatings or resist material that remains on the substrate.
Development can be conducted by liquid methods (dip, manual
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immersion, or spray coating) or dry methods (plasma). The wafer is
then etched in an acid solution to remove selected portions of the
oxide layer to create depressions or patterns. The patterns are areas in
which dopants will be applied. The wafer is rinsed, typically by
immersing in a stripping solution to remove unwanted photoresist,
and then dried. See Exhibit 7 for a list of materials used during the
photolithography process.
Exhibit 7
Chemicals Used in Photolithography for Semiconductors
Photoresists
Developer
Solvents and
Cleaning Agents
Positive:
Ortho-diazoketone
Polymethacrylate
Polyfluoroalkylmethacrylate
Polyalkylaldehyde
Polycyanoethylacrylate
Polymethylmethacrylate
Poly (hexafluorobutylmeth-
acrylate)
Negative:
Isoprene
Ethyl acrylate
Glycidylmetharcylate
Copolymer-ethylacrylate
Positive:
Sodium hydroxide
Potassium hydroxide
Silicates
Ethylene glycol
Ethanolamine
Isopropyl alcohol
Phosphates
Tetramethyl-ammonium
hydroxide
Alkyl amine
Ethyl acetate
Methyl isobutyl ketone
Negative:
Xylene
Aliphatic Hydrocarbons
N-Butyl acetate
Cellosolve acetate
Isopropyl alcohol
Stoddard solvent
Glycol ethers
Deionized water
Detergent
Isopropyl alcohol
Acetone
Ethanol
Hydrofluoric acid
Sulfuric acid
Hydrogen peroxide
Hydrochloric acid
Nitric acid
Chromic acid
Ammonium hydroxide
Hexamethyldisilazane
Xylene
Cellosolve acetate
n-Butyl acetate
Ethylbenzene
Chlorofluorocarbons
Chlorotoluene
Glycol ethers
Source: Based on EPA DfE 1993: Industry Profile and Description of Chemical Use for the
Semiconductor Industry: Preliminary Draft.
During the next step, dopants are applied to the patterned wafer
surface typically using diffusion or ion implantation. See Step two for
a list of materials used and wastes generated during the doping
process.
Additional layers of silicon may also be applied to the wafer using
deposition techniques, typically epitaxial growth or chemical vapor
deposition.
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Epitaxyl allows the growth of another layer of silicon on top of
the wafer. A silicon layer is grown using high temperatures
and dopant compounds. This top layer of silicon is where the
final device will be formed. Not all semiconductors need this
layer.
Chemical vapor deposition deposits a thin coating on materials
by a chemical process. Vapor deposition is a low pressure
process that combines appropriate gases in a reactant chamber
at elevated temperatures to produce a uniform film thickness.
Materials that may be used during deposition include silane, silicon
tetrachloride, ammonia, nitrous oxide, tungsten hexafluoride, arsine,
phosphine, diborane, nitrogen, and hydrogen.
Wastes that may be generated from these processes include: acid
fumes from etching operations; organic solvent vapors from cleaning
resist drying, developing, and resist stripping; hydrogen chloride
vapors from etching; rinsewaters containing acids and organic solvents
from cleaning, developing, etching, and resist stripping processes;
rinsewaters from aqueous developing systems; spent etchant solutions;
spent solvents (including F003) and spent acid baths.
Many products require that steps two through three be repeated
several times in order to create the specified structure.
Step Four: Final Layering and Cleaning
Once the wafer is patterned, the wafer surface is coated with thin
layers of metal by a process called metallization. These metal layers
perform circuit functions within the finished semiconductor. External
connections to the silicon wafer are provided by evaporation of thin
metal films onto areas of the semiconductor chip surface in a vacuum.
Almost every metal can be used to make this electrical connection to
the silicon; aluminum, platinum, titanium, nickel/chromium, silver,
copper, tungsten, gold, germanium, and tantalum are most common.
Argon gas is also used in some operations. Sputtering and high
vacuum evaporation are two types of metallization.
Sputtering (also called partial vacuum evaporation) is a
physical, rather than chemical process. This process occurs in a
vacuum chamber which contains a target (solid slab of the film
material) and the wafers. Argon gas is introduced in the
chamber and ionized to a positive charge. The positively
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charged argon atoms accelerate toward and strike the target,
dislodging the target atoms. The dislodged atoms are deposited
onto the wafer surface. A uniform thickness of the coating is
produced over the silicon slice.
High vacuum evaporation is a process that uses an electron
beam, a ceramic bar heated by thermal resistance, or a wire
heated by electrical resistance. This method coats the surface of
the wafer with metal.
Photolithography and etching are also used to remove any
unnecessary metal using chlorinated solvents or acid solutions.
Wastes generated include: acid fumes and organic solvent vapors
from cleaning, etching, resist drying, developing, and resist stripping;
liquid organic waste; aqueous metals; and wastewaters contaminated
with spent cleaning solutions.
In the next step, passivation is used to apply a final layer of oxide over
the wafer surface to provide a protective seal over the circuit. This
coating protects the semiconductor from exterior influences and may
range in thickness from a single layer of silicon dioxide to a relatively
thick deposit of special glass. It also insulates the chip from unwanted
contact with other external metal contacts. Materials used to form the
passivation layer are silicon dioxide or silicon nitride.
After all layers have been applied to the wafer, the wafer is typically
rinsed in deionized water. The back of the wafer is then mechanically
ground (also called lapping or backgrinding) to remove unnecessary
material. A film of gold may be applied to the back of the wafer by an
evaporation process to aid the connection of leads to the bonding pads
during a later process step.
Testing with alcohol compounds is conducted to ensure that each chip
is performing the operation for which it was designed. Chips that do
not meet specifications are marked with an ink droplet for discard
during assembly operations. The wafer is cleaned again after testing,
using solvents such as deionized water, isopropyl alcohol, acetone,
and methanol.
Wastes generated from these processes include: spent solvents and
acids in the wastewater and rinsewater from cleaning, developing,
etching, resist stripping, and rinsing processes; acid fumes and organic
solvent vapors from cleaning, rinsing, resist drying, developing, and
resist stripping; spent silicon dioxide or nitride; hydrogen chloride
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vapors from etching; rinsewaters from aqueous developing systems;
spent etchant solutions; spent acid baths; and spent solvents.
Step Five: Assembly
Semiconductors are assembled by mounting chips onto a metal frame,
connecting the chips to metal strips (leads), and enclosing the device to
protect against mechanical shock and the external environment. There
are many types of packaging; such as plastic or ceramic. Plastic
packages comprised more than 90 percent of the market in 1990.
Each package contains five parts: the die (e.g., chip), the lead frame of
the package, the die-attach pad, the wire bond, and the molded
encapsulant (i.e., plastic housing) (See Exhibit 8). This section
describes how plastic packages are assembled. All semiconductor
packages whether plastic or ceramic share the same basic parts and are
assembled using the same general processes.
Exhibit 8
Plastic Package Components
Molded encapsulant
Lead fram
ire bond
Die attach pad
Source: Based on 1993 Environmental Consciousness: A Strategic Competitiveness Issue
for the Electronics Industry.
The lead frame consists of a rectangular-shaped metal frame connected
to metal strips or leads. The leads connect the chip to the electronic
product. Plastic package lead frames are fabricated from sheets of
metal, either copper or alloy 42, that is either punched or etched. The
lead frame and leads provide the connections for the electronic
components.
The punching process consists of an array of small mechanical
punches that remove sections of the metal sheet until the lead
frame is complete. The leads are cleaned with water-based
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cleaning systems. In the past, manufacturers used chlorinated
fluorocarbons (CFCs) or other solvents to remove cutting fluids.
The lead frame is coated with a layer of photoresist, exposed,
and developed. The manufacturer etches the lead frame,
removes the photoresist, and cleans the lead frame again with
water based cleaning systems.
If the lead frames are etched, the process is similar to that used
during PWB manufacturing. Acids or metal chlorides are
usually used during etching. Sometimes ammonia is used to
stabilize the metal chloride. The photoresist contains solvents
(such as trichloroethylene or TCE) that are baked out and
generate VOC emissions. Developers that are typically used
include either an amine or metal hydroxide. Once the
photoresist is removed, it is cleaned with solvents such as a
mild hydrochloric acid (HCL) solution or with a brightener that
contains sulfuric acid.
Wastes generated during punching or etching may include: spent
organic vapors generated from cleaning, resist drying, developing,
and resist stripping; spent cleaning solutions; rinsewaters
contaminated with organic solvents; and spent aqueous developing
solutions. Scrap copper or alloy 42 may be recycled during the
punching process.
The chip is then attached to an "attach pad," with a substance such as
an epoxy material (thermoset plastic). Once mounted, the chips are
inspected. The chip parts are bonded to the leads of the package with
tiny gold or aluminum wires. A package may have between 2 and 48
wire bonds. The assembly is cleaned and inspected again. The
combined components are then placed into a molding press, which
encases the chip, wire bonds, and portions of the leads in plastic. The
plastic-molding compound used in the press contains primarily fused
silica. After the molding compound cures and cools around the
package, the package is heated again to ensure that the plastic is
completely cured. Excess material is removed using a chemical or
mechanical deflash process. M-Pyrol is one organic solvent used
during the deflash process. The final steps in package fabrication
include trimming and forming the leads.
Waste generated during these steps includes excess epoxy/thermoset
plastic; antimony trioxide (from the molding process); and spent
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organic solvents. Excess gold or aluminum from trimming processes
can be reclaimed and reused.
Final computer tests are conducted to evaluate whether the product
meets specifications. Even though the chips are produced using the
same process, some may work better (e.g., faster) than others. As a
result, packages are separated into low- and high-quality circuits.
Often, low-quality circuits can still be sold. Final process steps include
marking the circuits with a product brand. The finished product is
then packaged, labeled, and shipped according to customer
specifications.
III.A.2. Printed Wiring Board Manufacturing
Printed wiring boards (PWBs) are the physical structures on which
electronic components such as semiconductors and capacitors are
mounted. The combination of PWBs and electronic components is an
electronic assembly or printed wiring assembly (PWA). According to
Microelectronics and Computer Technology Corporation's (MCC)
Environmental Consciousness: A Strategic Competitiveness Issue for the
Electronics and Computer Industry, PWB manufacturing is the most
chemical intensive process in the building of a computer workstation.
PWBs are subdivided into single-sided, double-sided, multilayer, and
flexible boards. Multilayer boards are manufactured similarly to
single and double-sided boards, except that conducting circuits are
etched on both the external and internal layers. Multilayer boards
allow for increased complexity and density. PWBs are produced using
three methods: additive, subtractive, or semi-additive technology.
The subtractive process accounts for a significant majority, perhaps 80
percent, of PWB manufacturing.
The conventional subtractive manufacturing process begins with a
board, consisting of epoxy resin and fiberglass, onto which patterns
are imaged. In most operations, conducting material, usually copper,
is bonded onto the substrate surface to form copper-clad laminate.
After drilling holes through the laminate and making those holes
conductive, unwanted copper is etched off, leaving copper patterns.
The patterns on the board form the electric circuits that conduct
electricity. Multilayer boards typically use metals such as platinum,
palladium, and copper to form electric circuits. Specialized PWBs may
use nickel, silver, or gold.
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Additive technology is used less often than substractive technology
because it is a more difficult and costly production process. This
capital-intensive technology is used primarily for small
interconnection components used in multi-chip devices. The
production process begins with a base plate upon which a dielectric
material is deposited. An interconnecting layer of copper is plated
onto the dielectric layer which connects the layers of dielectric material
and copper. Copper posts are plated-up and another layer of dielectric
material is deposited exposing the posts. The next interconnect layer is
plated and makes contact with the posts. Layers of dielectric material,
copper, and copper posts are added to complete the interconnect. A
lithographic process, similar to the one used in semiconductor
manufacturing, diminishes the spaces and widths of the PWB.
This section provides a simplified discussion of the steps commonly
performed during conventional subtractive manufacturing. The actual
steps and materials used by a PWB manufacturer vary depending on
customer requirements and the product being manufactured. The
information provided in this section comes from various sources,
including documents developed by MCC, IPC, EPA's Center for
Environmental Research Information, EPA's DfE Program, California
Department of Toxic Substances, EPA's CSI, and EPA's Office of
Research and Development. PWB manufacturing can be grouped into
five steps:
Board preparation
Application of conductive coatings (plating)
Soldering
Fabrication
Assembly.
Step One: Board Preparation
Board preparation begins with a lamination process. Two-side etched
copper dielectric boards (consisting usually of fiberglass and epoxy
resin) are separated by an insulating layer and laminated or bonded
together, usually by heat and pressure. Photographic tools are used to
transfer the circuit pattern to the PWB, and computer control programs
are used to control the drilling, routing, and testing equipment.
Preparing the copper-clad board involves drilling holes to establish an
electrical path between the layers and to mount components. The
boards are then mechanically cleaned to remove drilling wastes (i.e.,
fine particulate contaminants, such as copper). Vapor degreasing,
abrasive cleaning, chemical cleaning with alkaline solutions, acid dips,
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and water rinses are techniques used to clean the boards and prepare
them for the next process, electroless plating. See Exhibit 9 for a list of
materials used during lamination, drilling, and cleaning processes.
Exhibit 9
Chemicals Used in Lamination, Drilling, and Cleaning
Lamination
Drilling
Cleaning
Epoxies
Sulfuric Acid
Potassium Permanganate
Ammonium bifluoride
Oxygen
Fluorocarbon gas
Acetone
1,1,1 -Trichloroethane
Silica (and other abrasives)
Sulfuric acid
Ammonium hydroxide
Hydrochloric acid
Source: Based on EPA DIE 1993: Industry Profile and Description of Chemical Use for the
Printed Wiring Board Industry: Preliminary Draft.
Wastes generated include: airborne particulates, acid fumes, and
organic vapors from cleaning, surface preparation, and drilling; spent
acid and alkaline solutions; spent developing solutions, spent etchants,
and waste rinsewaters in the wastewater; and scrap board materials
and sludges from wastewater treatment. Drilling and routing dust
(copper, aluminum, and gold) are collected and recycled.
Step Two: Electroless Plating
The first process in this step is to prepare the surfaces of the drilled
holes. The holes are prepared by an etchback process to remove
smeared epoxy resin and other contaminants using one of the
following: sulfuric or hydrochloric acid; potassium permanganate; or
carbon tetrafluoride, oxygen and nitrogen. The holes are then coated
with a material such as copper or graphite carbon, by a chemical
process called electroless plating.
Electroless plating coats a uniform conducting layer of copper or other
material on the entire surface including the barrels of the holes of the
prepared board without outside power sources. According to Printed
Circuit Board Basics, this coating of copper is not thick enough to carry
an electrical current, but provides a base upon which additional
copper can be deposited electrolytically. According to DfE, copper is
the industry standard, but many are switching to direct metallization
processes. Chemical deposition is the technique used to coat the
board. After the electroless plating, the boards are dried to prevent the
board from oxidation (e.g., rusting). The board may also be cleaned to
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prepare for a following electroplating processing. See Exhibit 12 for a
list of materials used. Waste generated include: spent electroless
copper baths; spent catalyst solutions; spent acid solutions; waste
rinsewaters; and sludges from wastewater treatment.
Step Three: Imaging
During imaging, circuit patterns are transferred onto the boards
through photolithography or a stencil printing process. Photoresist
(i.e., a light sensitive chemical) is applied to the board in areas where
the circuit pattern will not be set. The board is exposed to a radiation
source and developed to remove the unwanted areas of the resist
layer. Stencil printing uses a printing process, such as silk screening,
to apply a protective film that forms the circuit pattern.
After photolithography, the boards are subjected to a light etching
process, typically using ammoniacal etchants, to remove rust inhibitor
(applied by the company that produced the material from which the
board is made) or other metals (usually copper). After the stencil
printing process, the protective film is dried, and the exposed copper
is etched away. Sulfuric acid and hydrogen peroxide are common
etchants used during imaging. After plating or etching, the
photoresist is removed with an photoresist stripper.
See Exhibits 10 and 11 for a list of materials used during
photolithography and etching processes. Wastes generated during the
cleaning and etching processes include: RCRA listed F001, F002, F003,
F004, and F005 depending on the concentration of the spent solvents
and the mixture of spent halogenated and non-halogenated solvents;
spent resist material; and wastewater containing metals (copper).
Other wastes generated include organic vapors and acid fumes, spent
developing solutions, spent resist material, spent etchant, spend acid
solutions, and sludges from waste water treatment.
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Exhibit 10
Chemicals Used in Photolithography for Printed Wiring Boards
Resists
Photopolymer
Developers
Photopolymer
Strippers
Mylar
Vinyl
Photoresists
Isopropyl alcohol
Potassium bicarbonate
Sodium bicarbonate
1,1,1 -Trichloroethane
Amines
Glycol ethers
Sodium hydroxide
Potassium hydroxide
Methylene chloride
Source: Based on EPA DIE 1993: Industry Profile and Description of Chemical Use for the
Printed Wiring Board Industry: Preliminary Draft.
Exhibit 11
Materials Used During Etching
Ammonia
Ammonium chloride
Ammonium hydroxide
Ammonium persulfate
Ammonium sulfate
Boric acid
Carbon tetrafluoride
Chlorine
Cupric chloride
Hydrochloric acid
Hydrofluoric acid
Hydrogen peroxide
Lead
Nickel
Nickel chloride
Nickel sulfamate
Nitrate
Nitric acid
Nitrogen
Orthophosphate
Oxygen
Peptone
Permanganates
Sodium citrate
Sodium hydroxide
Stannous chloride
Sulfuric acid
Tin
Source: Based on EPA DIE 1993: Industry Profile and Description of Chemical Use for the
Printed Wiring Board Industry: Preliminary Draft.
Step Four: Electroplating
Electroplating is a process in which a metal is deposited on a substrate
through electrochemical reactions. Electroplating is required to build
up the thickness and strength of the conducting layers to provide
reliable electrical conductivity between inner layers or from one side
of the PWB to the other. Electroplating can also protect against
corrosion, wear, or erosion. This process involves immersing the
article to be coated/plated into a bath containing acids, bases, or salts.
The industry standard for this process is copper, although many are
switching to direct metallization techniques according to DfE.
The electroplating process for PWBs usually begins with the copper
laminate which is coated with a plating resist (photolithography), by
stenciling, leaving the area exposed to form the circuit pattern. The
resist prevents the conductive material from adhering to other areas of
the board and forms the circuit pattern.
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The PWB plating process typically uses as copper and tin-lead as
plating materials, although silver, nickel, or gold can be used. Copper
in a plating bath solution is deposited to a sufficient thickness, and a
solvent or aqueous solution is applied to remove the plating resist.
The copper coating forms interconnections between the layers and
provides electrical contact for electronic parts mounted or assembled
on the PWB surface. PWB manufacturers then typically electroplate a
tin or tin-lead solder on the board to protect the circuit pattern during
the following etching or stripping processes. An acid etch solution
(ammoniacal, peroxide solutions, sodium persulfate, cupric chloride,
or ferric chloride) removes the exposed copper foil, leaving the thicker
copper plating to form the circuit pattern. Ammoniacal and cupric
chloride are the primary etchants used by PWB manufacturers.
Fluoroboric acid is used in the tin-lead plating process to keep the
metals dissolved in the solution and to ensure a consistent deposition
of the tin-lead alloy onto the circuit board.
After the plating bath, the board is rinsed with water, scrubbed, and
then dried to remove the copper, spray etch solutions, and other
materials. Rinsing ends the chemical reactions during plating and
prevents contamination or dragout from being released in the next
bath or rinse water (dragout is the plating solution that sticks to parts
after taken out of the plating bath). Dragout can occur in any bath
step, not just in one plating bath. The tin-lead layer is generally
removed and the panel is electrically tested for discontinuities in the
electrical pathway and shorts. See Exhibit 12 for a list of materials
used during the electroplating process.
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Sector Notebook Project
Exhibit 12
Materials Used in Copper and Tin-Lead Electro- and
Electroless Plating Processes
Type of Plating
Electroplating
Chemicals
Electroless
Chemicals
Copper
Tin-Lead
Copper pyrophosphate
Orthophosphate
Pyrophosphate
Nitrates
Ammonia
Acid copper
Copper sulfate
Sulfuric acid
Tin-Lead
Fluoroboric acid
Boric acid
Peptone
Hydrochloric acid
Palladium chloride
Stannous chloride
Metallic tin pellets
Sodium hydroxide
Copper sulfate
Formaldehyde
Tin chloride
Sodium hypophosphite
Sodium citrate
Source: Based on EPA DIE 1993: Industry Profile and Description of Chemical Use for the
Printed Wiring Board Industry: Preliminary Draft.
The primary RCRA hazardous wastes generated during plating
include: photoresist skins, F006 sludge from plating wastewater
treatment, D008, F007, and F008 from plating and etching; spent acid
solutions, waste rinsewaters, spent developing solutions, spent
etchant, and spent plating baths in the wastewater; organic vapors
from spent developing solution and spent resist removal solution; and
acid and ammonia fumes. According to IPC, photoresist skins or the
stripped resist material are exempt from categorical F006 classification
if the skins stripping is separate from electroplating and if the boards
are rinsed and dried.
Step Five; Soldering Coating
Solder coating is used to add solder to PWB copper component before
component assembly. Fabricators use several methods of solder
coating, but all of them involve dipping the panel into molten solder.
The solder, an alloy consisting of 60 percent tin and 40 percent lead,
coats the pads and holes not covered by solder mask. The excess
solder is removed with a blast of hot oil or hot air. However, the hot
oil or hot air does not remove the solder that has formed a chemical
(intermetallic) bond with the copper. The removal of the excess solder
is called "solder leveling." The most common process is hot-air
leveling. According to Printed Circuit Board Basics: Quick and Easy
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Guide, final solder coating thicknesses of 50 to 1,200 microinches can be
achieved with most solder-leveling processes. Solder is only applied
to desired areas so there is no metal or "objectionable fluid"
discharged to the wastestream, according to MCC. MCC considers it
to be the most environmental friendly solder application method.
Step Six; Electrical and Mechanical Testing
A cross section is cut from a sample panel from each lot using a
grinding process called routing, and the plated holes are examined
with a photomicrograph. Individual circuit boards are cut out of
panels that pass quality control. Routing generates dust which may
contain copper, lead, or other metals plated to the panel, but the dust
is recycled. Electrical tests, dimensional and visual inspections, and
quality audits are performed to ensure compliance with customer
requirements. Finally, the finished PWBs are packaged, labeled, and
shipped to the customer which in most cases is the original equipment
manufacturer (OEM) or contract electronic assembly company.
Step Seven; Printed Wiring Board Assembly and Soldering
After the PWBs are manufactured, the electrical components are
attached during assembly. Adhesives are applied to the boards, and
then the components are attached and soldered to the boards.
Components are attached to the PWB by a process called soldering.
There are several different kinds of soldering processes, including
wave, dip, and drag. In wave soldering, the PWA is passed over the
crest of a wave of molten solder, thereby permanently attaching the
components to the board. A type of chemical known as "flux" is used
before soldering to facilitate the production of the solder connection.
Not only does flux clean the surface and remove oxidized material, it
prevents oxidation from occurring during the solder process. After the
solder has been applied, flux residue may be removed from the board.
According to a leading PWB manufacturer, deionized water instead of
CFCs (such as Freon 113) and trichloroethane (TCA), are now used to
remove flux. Although the residue may not affect the PWB's
performance, it may lower the board's cosmetic quality. After
soldering, the board may be cleaned and dried. Many assemblies,
however, are looking at no-clean soldering operations.
The wastes generated during assembly include: solder dross, post-
solder scrap boards, filters, gloves, rags, and spent gaseous or semi-
gaseous solvents from cleaning processes. The wastes that may be
generated during soldering, flux application, and cleaning include:
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organic vapors and CFCs (although CFC usage will be eliminated by
1996); copper, lead, spent solvents, and spent deionized water into the
wastewater; solder dross; and wastewater treatment sludge. Solder
dross is primarily oxidized solder skin that forms on any molten
solder exposed to oxygen and can be recycled off-site.
III.A.3. Cathode Ray Tube Manufacturing
Cathode Ray Tubes (CRTs) have four major components: the glass
panel (faceplate), shadow mask (aperture), electron gun (mount), and
glass funnel. The glass funnel protects the electron gun and forms the
back end of the CRT. In response to electrical signals, the electron gun
emits electrons that excite the screen. The shadow mask forms a
pattern on the screen. The shadow mask itself is a steel panel with a
mask pattern applied through one of several kinds of
photolithography.
This section summarizes the manufacturing process for color CRTs.
Information used to describe CRT manufacturing comes from a variety
of sources such as MCC, EPA's Common Sense Initiative (CSI),
Corporate Environmental Engineering, and EPA's Effluent Guideline
Division. For this discussion, the process is grouped into six steps:
Preparation of the glass panel and shadow mask
Application of the coating to the glass panel interior
Installation of the electron shield
Preparation of the funnel and joining to the glass panel/shadow
mask assembly
Installation of the electron gun
Finishing.
Color CRTs
Exhibit 13 presents the steps for manufacturing a color CRT. The
names of the operations may vary by manufacturer, but the basic
processing sequence is identical in all color CRT manufacturing
facilities. Lead in CRT display components and end-of-life concerns
have been the most significant environmental issues in CRT
manufacturing.
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Exhibit 13
Color CRT Manufacturing Process
^-
Aperture Masks
1 . Mask Degrease
6. Photoresist
Exposure and
Development
7. Carbon Black
Application
10. Phosphor
Exposure and
Development
15. Shield Attachment
1
t
20. Panel-Funnel
Fusion
t
22. Attach, Mount,
and Assembly
*
23. Exhaust and Seal
*
-^
*
S
^
-
Glass Panels
2. Panel and Mask
Mate
5. Photoresist
Application
8. Stripping Agent
Application and
Harhon Reverse
1 1 . Lacquer Coat
Electron Shields
14. Shield Degrease
19. Frit Application
Electron Guns
- 21 Mount Assemble
Clean, and Age
24. Age and Test
-^-
--
*-
-^
*
3. Anneal
9. Phosphor
Application
12.Aluminize
13. Panel Clean
18. Seal Surface Clean
25. External Coat and
Implosion Band
i
^
1
J
i
Glass runnels
1
-J T
16. Funnel Wash
1
T
^.
^ 17. Internal Coat
~^~ 26. Test and Ship
Source: Based on 1995 EPA Common Sense Initiative (CSI) documents.
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Step One: Preparation of the Panel and Shadow Mask
The shadow mask is constructed from a thin layer of aluminum steel
(referred to as a flat mask) which is etched with many small slits or
holes, and a metal frame that supports the flat mask. The shadow
mask serves as a template for preparing a pattern on the glass panel
surface. Shadow masks are commonly manufactured overseas and
shipped to CRT manufacturers in the United States. The shadow mask
is then molded to match the contour of the glass panel's interior
surface and "blackened" in an oven to provide corrosion resistance.
Finally, the shadow mask is welded to a blackened metal frame,
usually steel, that provides support. Degreasing solvents and caustics
are frequently used for cleaning the shadow mask assembly and
production equipment. Oils are used for lubricating the press and
other production equipment.
The front end glass panel is purchased from a glass manufacturer and
shipped to the CRT manufacturer. Metal "pins," provided as part of
the glass panel, are attached to the inside of the glass to serve as
connection points for the shadow mask.
The shadow mask is carefully positioned inside the glass panel. Steel
springs are then placed over the pins in the glass panel and attached to
"hook-plates" or "clips" located on the mask assembly frame. With the
glass panel and shadow mask assembly positions fixed in relation to
each other, the springs are welded to the hook-plates. The glass panel
and mask must remain as a matched pair through the remaining
processes. The glass panel and shadow mask preparation operation
frequently uses organic solvents or caustic cleaners for degreasing, oil
for equipment maintenance, and oxidizers, such as hydrogen peroxide,
for cleaning reclaimed masks.
Wastes generated during this step include spent solvents in the
wastewater, vapors from solvent degreasing tanks, and waste glass
from breakage.
Step Two: Application of Coating to Panel Interior
For the panel-mask to create images, a special coating is applied to the
interior surface through a process called screening. Screening, the
most complex part of the manufacturing process, is comparable to a
photographic development process.
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The screening operation begins with a panel wash. The mask is
removed and the glass panel is washed to remove dust, oil, grease,
and other contamination. The glass panel wash commonly uses acids
and caustics followed by deionized water rinses for cleaning the glass.
The glass panel undergoes the carbon stripe process, which uses
organic photoresist, chromate, deionized water, dilute acids and
oxidizers, carbon slurry with binding agents, and surfactants to
produce the black and clear striped pattern called the "black matrix."
The clear areas will eventually be filled with color-producing
phosphors. The glass panels are coated with a photoresist, which
contains chromate (a toxic heavy metal compound) as a catalyzer. The
panel is spun to even out the photoresist and then dried.
The shadow mask is re-inserted in the glass panel and a series of
exposures are made on the panel surface using ultraviolet (UV) light in
a photolithography process. The light passes through the mask
openings to imprint the mask pattern on the photoresist. The mask
also shadows the areas of the photoresist that will not be exposed.
When UV light contacts the photoresist, polymerization occurs, and
the exposed areas become less soluble in water than the non-exposed
areas.
After the exposure, the shadow mask is removed and the glass panel is
sprayed with water to remove the non-polymerized material. The
imprinted pattern of exposed photoresist remains on the glass panel.
The glass panel is then coated and developed again. The resulting
image is essentially a "negative image" of the original photoresist
exposure pattern.
During the phosphor stripe process, three phosphor colors (green,
blue, and red) are used to make a color CRT and are applied using the
same steps as the carbon stripe process. The phosphor stripe process
uses various chemicals, including phosphor slurries containing metals
(such as zinc compounds) and organic photoresists, chromate,
deionized water, dilute oxidizers, and surfactants. The phosphor
materials that are spun off the panels and removed in the developers
are recovered and reclaimed either onsite or by a phosphor vendor.
The reclaiming process involves the use of acids and caustics, chelating
agents, and surfactants.
Two coatings are then added to the glass panel, which now has the
black matrix and the three phosphor colors on it: lacquer (a wax-like
layer) to smooth and seal the inside surface of the screen, and
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aluminum to enhance brightness. The panel is then ready to be joined
to the back end of the CRT, known as the funnel. In preparation for
joining, the panel edges must be cleaned to remove all traces of
contaminants. A clean edge is critical to ensuring a good panel-to-seal
connection in the finished CRT. The shadow mask and glass panel are
reattached. Chemicals used in these processes include organic solvents
and alcohol, caustics, silica-based coatings, aluminum, acids,
ammonia, and deionized water. The material removed in the cleaning
process is sent to a smelter to recover metals and sulfites.
Wastes generated during this step include: vapors from the lacquer
area; wastewater containing deionized water, acids, oxidizers, carbon
slurry, surfactants, chromate, phosphor solutions, chelating agents,
caustics, organic solvents, alcohol, silica-based coatings, ammonia,
zinc, and aluminum; process cooling waters, liquid wastes from
precipitation, washing, filtration, and scrubber blowdown; lacquer
wastes from spun off and over-sprayed lacquer; and lacquer
remaining in lacquer containers.
Step Three: Installation of the Electron Shield
Most CRT manufacturers employ an internal electron shield to
prevent stray electrons from reaching outside the screen area.
Computer monitor CRTs often use external shielding, which is
installed on the outside of the CRT's glass bulb. Before installation, the
shields are cleaned with degreasing solvents or caustic cleaners. The
internal-type electron shield is made of thin aluminum and is typically
welded to the shadow mask assembly before the panel and shadow
mask are connected with the funnel. Metal (steel) springs are also
welded to the mask frame at this time. The springs provide an
electrical connection between the mask and the funnel interior surface.
Wastes generated from these processes include electron shield
degrease wastewaters and metals from the welding.
Step Four: Preparation of the Funnel and Joining to Panel-Mask Assembly
The back end of the CRT (funnel) is purchased from a glass vendor
and washed prior to use. The funnel is made of high lead content
glass and the resulting wash water contains elevated lead levels. After
the funnel is washed, the interior surface is coated with a black
graphite coating which is a good electrical conductor and a non-
reflective coating. The seal edge of the funnel is cleaned to facilitate
bonding with the panel, and frit or solder glass is applied in a bead
along the entire surface of the seal edge. The frit, approximately 70
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percent lead, has the consistency of toothpaste or caulking. The
viscosity of the frit is controlled by the addition of organic solvents.
The frit serves as an adhesive to join the panel-mask assembly to the
funnel.
After the frit is applied, the panel-mask assembly is connected to the
funnel, and the whole glass package is placed in a positioning clamp to
hold the two parts in place. The connected panel-mask and funnel
assembly is then exposed to high temperatures in an oven to fuse the
frit joint between the panel and funnel at the seal edges. The frit forms
a strong bond between the two pieces of glass. During the frit-seal
fusion process, the organic chemicals from the screening operation
and in the frit are "burned out" of the CRT. The organic materials
must "burn" cleanly to minimize any remaining residue. Wastes
generated include wastewaters contaminated with spent black graphic,
lead, and chemicals associated with the funnel wash, frit application,
and seal surface cleaning. Wastes generated include frit contaminated
clothing, instruments and utensil used to prepare the frit, unusable frit
glass, and waste glass from breakage.
Step Five; Installation of the Electron Gun
Each CRT contains three guns: one dedicated to each of the phosphor
colors used in the screen (red, green, and blue). To produce an
electron gun, several metal components are assembled and loaded
onto spindles to align the various elements. Glass parts are placed into
fixture blocks and heated. When the glass reaches the proper
temperature, the metal parts are embedded in the glass. The
combination of metal parts and glass make up the gun. The guns are
cleaned with organic solvents or caustic cleaners before they are
mounted in the neck of the CRT funnel. Materials commonly found in
the gun assemblies include metals, high lead glass stem (for electrical
connection feed-through and exhaust purposes), ribbon connectors,
and other manufacturer-specific parts.
The gun assembly is then inserted in the neck of the CRT funnel. The
gun is aligned and the CRT funnel neck is fused to the gun by rotating
the parts in front of open flame burners. An additional component is
welded to the gun assembly to allow for removal of gases from the
electron gun in subsequent steps. Wastes generated from this step
include waste glass from breakage and wastewaters contaminated
with spent organic solvents and caustic cleaners from mount cleaning.
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Step Six; Finishing
The CRT "bulb" is still open to the atmosphere after the gun mount is
sealed in the neck of the funnel. To complete the tube, the gases are
removed by applying a vacuum to the bulb. Organic solvents are used
to clean and maintain the vacuum pumps.
The bulb is "aged" by an electronic treatment applied to the gun or
mount. The CRT is then coated with an external carbon black paint,
and a metal band is placed around the outside of the panel with
adhesives for implosion protection and safety. The band also provides
mounting brackets for installing the CRT. The finished tube is tested
in a high voltage testing station, and the CRT tested thoroughly to
ensure that it meets all specifications before shipment. Each tube is
packaged prior to shipment to the customer. Wastes generated from
finishing processes include spent solvents and VOC emissions.
In some cases where the bulb face needs a special application, such as
reference lines for an oscilloscope, a separate panel and funnel are
used. A photoresist and mask are used to apply the reference lines on
the panel. The single phosphor is applied in the same way as for a
one-piece bulb, using a settling solution that contains potassium
silicate and, usually, an electrolyte.
Tube Salvage
Cathode ray tubes may or may not be salvaged. Picture tube salvage
operations reclaim spent or rejected picture tubes and return them to
production. Salvage operation processes include a panel-funnel acid
defrit, acid cleaning of panels and funnels (i.e., nitric acid), and
cleaning of the shadow mask. These reclaimed components are
returned to the process for reuse or are returned to the glass
manufacturer for recycling. A product with knocks, scratches, chips,
etc., is repaired. New necks are spliced onto funnels. Electron guns
are usually discarded. Glass that cannot be used because of serious
defects is recycled back to a glass plant directly or is sent off-site for
cleaning and segregation before going to a glass plant.
CRT technology is a mature and efficient process; however, the use of
a new technology called Flat Panel Displays (FPD) is becoming more
common. FPDs offer certain environmental advantages over CRTs
because of the tenfold reduction in glass used and substantial power
savings. Existing performance deficiencies, such as poorer screen
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Electronics and Computer Industry
brightness and substantially higher prices, are limiting the widespread
incorporation of FPDs into electronics products.
III.B. Raw Materials Inputs and Pollution Outputs
Outputs from the electronics and computer industry manufacturing
processes affect the land, air, and water. Exhibits 14-16 describe the
wastes generated during each manufacturing process.
Exhibit 14
Semiconductor Pollution Outputs
Process
Crystal
Preparation
Wafer
Fabrication
Final
Layering and
Cleaning
Assembly
Air
Emissions
Acid fumes,
VOCs, dopant
gases
VOCs and
dopant gases
Acid fumes
and VOCs
VOCs
Process Wastes
(Liquids/Waste Waters)
Spent deionized water, spent solvents, spent
alkaline cleaning solutions, spent acids, spent
resist material
Spent solvents, spent acids, aqueous metals, spent
etchant solution, and spent aqueous developing
solutions.
Spent deionized water, spent solvents, spent
acids, spent etchants, spent aqueous developing
solutions, spent cleaning solutions, aqueous
metals, and D007 (chromium).
Spent cleaning solutions, spent solvents, aqueous
developing solutions, and P & U wastes.
Other Wastes
(Solids/RCRA)
Silicon,
F003
Spent solvents
Spent epoxy
material and
spent solvents
September 1995
39
SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
Exhibit 15
Printed Wiring Board Pollution Outputs
Process
Board
Preparation
Electroless
Plating
Imaging
Electroplating
Air
Emissions
Particulates,
acid fumes,
and VOCs
Organic
vapors and
acid fumes
Acid fumes,
ammonia
fumes, and
VOCs
Process Wastes (Liquids/Waste Waters)
Spent acids and spent alkaline solutions
Spent electroless copper baths, spent
catalyst solutions, spent acid solutions
Spent developing solutions, spent resist
material, spent etchants, spent acid
solutions, and aqueous metals
D008 (lead), D002, D003, spent etchants,
spent acid solutions, spent developing
solutions, spent plating baths
Other Wastes
(Solids/RCRA)
Sludge and scrap
board material
Waste rinse water
and sludges from
waste water
treatment
F001-5, depending
on concentration and
mixture of solvents.
Sludges from waste
water treatment
F006, F007, and F008
Exhibit 15 (cont'd)
Printed Wiring Board Pollution Outputs
Process
Solder Coating
PWB
Assembly And
Soldering
Air Emissions
VOCs and CFCs
VOCs and CFCs
Process Wastes
(Liquids/Waste Water)
Metals (nickel, silver, and copper), D008
(lead) , flux residue, spent deionized water,
spent solvents
Other Wastes
(Solids/RCRA)
Solder dross,
scrap boards,
filters, gloves,
rags, waste
water treatment
sludge
SIC Code 36
40
September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 16
Cathode Ray Tubes Pollution Outputs
Process
Preparation of
the Panel and
Shadow Mask
Application of
Coating to
Panel Interior
Installation of
Electron
Shield
Preparation of
Funnel and
Joining to
Panel-Mask
Assembly
Installation of
Electron Gun
Finishing
Air Emissions
Solvent vapors
Vapors from
lacquer area
VOCs
Process Wastes
(Liquid/Waste Waters)
Spent solvents
Spent photoresists, deionized water,
acids, oxidizers, carbon slurry,
surfactants, chromate, phosphor
solutions, chelating agents, caustics,
solvents, alcohol, coatings, ammonia,
aluminum, and process cooling waters
Electron shield degrease and metals
Funnel wash, seal surface cleaning, and
frit application wastewaters
Spent solvents and caustic cleaners
Spent solvents
Other Wastes
(Solids/RCRA)
Glass (lead) from
breakage
Lacquer wastes
Frit contaminated
clothing,
instruments,
utensils, unusable
frit glass (lead) ,
glass (lead) from
break-age
Glass from
breakage
September 1995
41
SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
III.C. Management of Chemicals in Wastestream
The Pollution Prevention Act of 1990 (EPA) requires facilities to report
information about the management of TRI chemicals in waste and
efforts made to eliminate or reduce those quantities. These data have
been collected annually in Section 8 of the TRI reporting Form R
beginning with the 1991 reporting year. The data summarized below
cover the years 1992-1995 and are meant to provide a basic
understanding of the quantities of waste handled by the industry, the
methods typically used to manage this waste, and recent trends in
these methods. TRI waste management data can be used to assess
trends in source reduction within individual industries and facilities,
and for specific TRI chemicals. This information could then be used as
a tool in identifying opportunities for pollution prevention compliance
assistance activities.
While the quantities reported for 1992 and 1993 are estimates of
quantities already managed, the quantities reported for 1994 and 1995
are projections only. The EPA requires these projections to encourage
facilities to consider future waste generation and source reduction of
those quantities as well as movement up the waste management
hierarchy. Future-year estimates are not commitments that facilities
reporting under TRI are required to meet.
Exhibit 17 shows that the electronics/computer industry managed
about 122 million pounds of production-related waste (total quantity
of TRI chemicals in the waste from routine production operations) in
1993 (column B). Column C reveals that of this production-related
waste, 44 percent was either transferred off-site or released to the
environment. Column C is calculated by dividing the total TRI
transfers and releases by the total quantity of production-related
waste. In other words, about 81 percent of the industry's TRI wastes
were managed on-site through recycling, energy recovery, or
treatment as shown in columns D, E and F, respectively. The majority
of waste that is released or transferred off-site can be divided into
portions that are recycled off-site, recovered for energy off-site, or
treated off-site as shown in columns G, H, and I, respectively. The
remaining portion of the production-related wastes (6.7 percent),
shown in column J, is either released to the environment through
direct discharges to air, land, water, and underground injection, or it is
disposed off-site.
SIC Code 36 42 September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 17
Source Reduction and Recycling Activity for SIC 36
A
Year
1992
1993
1994
1995
B
Production
Related
Waste
Volume
(106 Ibs.)
121
122
121
129
c
% Reported
as Released
and
Transferred
49%
44%
D
E
F
On-Site
%
Recycled
8.27%
9.38%
7.63%
8.87%
% Energy
Recovery
0.41%
0.20%
0.13%
0.59%
%
Treated
70.75%
72.12%
74.99%
74.45%
G
H
I
Off-Site
%
Recycled
3.21%
3.41%
4.33%
4.61%
% Energy
Recovery
3.96%
3.77%
3.88%
3.65%
%
Treated
4.83%
4.41%
3.58%
3.04%
J
Remaining
Releases
and
Disposal
8.52%
6.70%
5.44%
4.78%
September 1995
43
SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
This section is designed to provide background information on the
pollutant releases that are reported by this industry. The best source
of comparative pollutant release information is the Toxic Release
Inventory System (TRI). Pursuant to the Emergency Planning and
Community Right-to-Know Act (EPCRA), TRI includes self-reported
facility release and transfer data for over 600 toxic chemicals. Facilities
within SIC Codes 20-39 (manufacturing industries) that have more
than 10 employees, and that are above weight-based reporting
thresholds are required to report TRI on-site releases and off-site
transfers. The information presented within the sector notebooks is
derived from the most recently available (1993) TRI reporting year
(which then included 316 chemicals), and focuses primarily on the on-
site releases reported by each sector. Because TRI requires consistent
reporting regardless of sector, it is an excellent tool for drawing
comparisons across industries.
Although this sector notebook does not present historical information
regarding TRI chemical releases over time, please note that in general,
toxic chemical releases have been declining. In fact, according to the
1993 Toxic Release Inventory Data Book, reported releases dropped by
42.7 percent between 1988 and 1993. Although on-site releases have
decreased, the total amount of reported toxic waste has not declined
because the amount of toxic chemicals transferred off-site has
increased. Transfers have increased from 3.7 billion pounds in 1991 to
4.7 billion pounds in 1993. Better management practices have led to
increases in off-site transfers of toxic chemicals for recycling. More
detailed information can be obtained from EPA's annual Toxics
Release Inventory Public Data Release book (which is available
through the EPCRA Hotline at 1-800-535-0202), or directly from the
Toxic Release Inventory System database (for user support call 202-
260-1531).
Wherever possible, the sector notebooks present TRI data as the
primary indicator of chemical release within each industrial category.
TRI data provide the type, amount, and media receptor of each
chemical released or transferred. When other sources of pollutant
release data have been obtained, these data have been included to
augment the TRI information.
SIC Code 36 44 September 1995
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Sector Notebook Project Electronics and Computer Industry
TRI Data Limitations
The reader should keep in mind the following limitations regarding
TRI data. Within some sectors, the majority of facilities are not subject
to TRI reporting because they are not considered manufacturing
industries, or because they are below TRI reporting thresholds.
Examples are the mining, dry cleaning, printing, and transportation
equipment cleaning sectors. For these sectors, release information
from other sources has been included.
The reader should also be aware that TRI "pounds released" data
presented within the notebooks is not equivalent to a "risk" ranking for
each industry. Weighting each pound of release equally does not
factor in the relative toxicity of each chemical that is released. The
Agency is in the process of developing an approach to assign
toxicological weightings to each chemical released so that one can
differentiate between pollutants with significant differences in toxicity.
As a preliminary indicator of the environmental impact of the
industry's most commonly released chemicals, the notebook briefly
summarizes the toxicological properties of the top five chemicals (by
weight) reported by each industry.
Definitions Associated With Section IV Data Tables
General Definitions
SIC Code -- the Standard Industrial Classification (SIC) is a statistical
classification standard used for all establishment-based Federal
economic statistics. The SIC codes facilitate comparisons between
facility and industry data.
TRI Facilities -- are manufacturing facilities that have 10 or more full-
time employees and are above established chemical throughput
thresholds. Manufacturing facilities are defined as facilities in
Standard Industrial Classification primary codes 20-39. Facilities must
submit estimates for all chemicals that are on the EPA's defined list
and are above throughput thresholds.
Data Table Column Heading Definitions
The following definitions are based upon standard definitions
developed by EPA's Toxic Release Inventory Program. The categories
below represent the possible pollutant destinations that can be
reported.
September 1995 45 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
RELEASES -- are an on-site discharge of a toxic chemical to the
environment. This includes emissions to the air, discharges to bodies
of water, releases at the facility to land, as well as contained disposal
into underground injection wells.
Releases to Air (Point and Fugitive Air Emissions) Include all air
emissions from industry activity. Point emissions occur through
confined air streams as found in stacks, ducts, or pipes. Fugitive
emissions include losses from equipment leaks, or evaporative losses
from impoundments, spills, or leaks.
Releases to Water (Surface Water Discharges) - encompass any
releases going directly to streams, rivers, lakes, oceans, or other bodies
of water. Any estimates for stormwater runoff and non-point losses
must also be included.
Releases to Land -- includes disposal of waste to on-site landfills,
waste that is land treated or incorporated into soil, surface
impoundments, spills, leaks, or waste piles. These activities must
occur within the facility's boundaries for inclusion in this category.
Underground Injection is a contained release of a fluid into a
subsurface well for the purpose of waste disposal.
TRANSFERS is a transfer of toxic chemicals in wastes to a facility
that is geographically or physically separate from the facility reporting
under TRI. The quantities reported represent a movement of the
chemical away from the reporting facility. Except for off-site transfers
for disposal, these quantities do not necessarily represent entry of the
chemical into the environment.
Transfers to POTWs are wastewaters transferred through pipes or
sewers to a publicly owned treatments works (POTW). Treatment and
chemical removal depend on the chemical's nature and treatment
methods used. Chemicals not treated or destroyed by the POTW are
generally released to surface waters or landfilled within the sludge.
Transfers to Recycling are sent off-site for the purposes of
regenerating or recovering still valuable materials. Once these
chemicals have been recycled, they may be returned to the originating
facility or sold commercially.
SIC Code 36 46 September 1995
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Sector Notebook Project Electronics and Computer Industry
Transfers to Energy Recovery -- are wastes combusted off-site in
industrial furnaces for energy recovery. Treatment of a chemical by
incineration is not considered to be energy recovery.
Transfers to Treatment -- are wastes moved off-site for either
neutralization, incineration, biological destruction, or physical
separation. In some cases, the chemicals are not destroyed but
prepared for further waste management.
Transfers to Disposal are wastes taken to another facility for
disposal generally as a release to land or as an injection underground.
IV.A. EPA Toxic Release Inventory for the Electronics/Computer Industry
The follow section provides TRI data for the semiconductor, printed
wiring board (PWB) and cathode ray tube (CRT) industries. The
manufacture of these products results in the release of similar
substances, including solvents, acids, and heavy metals. The
commonly released solvents include acetone, xylene, and methanol.
Commonly released acids include sulfuric, hydrochloric, and nitric. A
significant amount of ammonia is also released by the
electronics/computer industry.
IV.A.I. TRI Data for Semiconductor Industry
The following exhibits present TRI data pertaining to semiconductor
manufacturing. Exhibit 18 presents the top ten facilities in terms of
TRI releases. Many of these companies are also among the top
companies in terms of sales. Exhibit 19 presents the top TRI releasing
facilities for all of electronics and other electric facilities. Exhibit 20
displays the number of TRI-reporting semiconductor manufacturing
facilities per State. As expected, California and Texas contain the
largest number of semiconductor manufacturing facilities.
The TRI database contains a detailed compilation of self-reported,
facility-specific chemical releases. The top reporting facilities for this
sector are listed below. Facilities that have reported only the SIC codes
covered under this notebook appear on the first list. The second list
contains additional facilities that have reported the SIC code covered
within this report, and one or more SIC codes that are not within the
scope of this notebook. Therefore, the second list includes facilities
that conduct multiple operations some that are under the scope of
September 1995 47 SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
this notebook, and some that are not. Currently, the facility-level data
do not allow pollutant releases to be broken apart by industrial
process.
Exhibit 18
Top 10 TRI Releasing Semiconductor Manufacturing Facilities (SIC 3674)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Pounds
225,840
203,120
159,465
142,256
138,950
134,208
112,250
82,854
81,719
80,545
Facility Name
Micron Semiconductor Inc.
Motorola Inc.
Intel Corp.
Texas Instruments Inc.
AT&T Microelectronics
Intel Corp.
Advanced Micro Devices Inc.
IBM Corp. E. Fishkill Facility
Dallas Semiconductor Corp.
Sgs-Thomson Microelectronics Inc.
City
Boise
Mesa
Hillsboro
Dallas
Reading
Rio Rancho
Austin
Hopewell Junction
Dallas
Carrollton
State
ID
AZ
OR
TX
PA
NM
TX
NY
TX
TX
Source: US EPA, Toxics Release Inventory Database, 1993.
Exhibit 19
Top 10 TRI Releasing Electronics/Computer Industry Facilities
SIC Codes
3671
3671
3469, 3674,
3089, 3694
3672, 3471
3671
3672
3674
3674
3672
3674
Total TRI
Releases in
Pounds
861,508
378,105
297,150
274,950
257,954
255,395
225,840
203,120
193,720
159,465
Facility Name
Zenith Electronics Corp.
Rauland Div.
Philips Display Components
Co.
Delco Electronics Corp.
Bypass
Photocircuits Corp.
Toshiba Display Devices Inc.
IBM Corp.
Micron Semiconductor Inc.
Motorola Inc.
Hadco Corp. Owego Div.
Intel Corp.
City
Melrose Park
Ottawa
Kokomo
Glen Cove
Horseheads
Endicott
Boise
Mesa
Owego
Hillsboro
State
IL
OH
IN
NY
NY
NY
ID
AZ
NY
OR
Source: US EPA, Toxics Release Inventory Database, 1993.
Note: Being included on this list does not mean that the release is associated with non-compliance
with environmental laws.
SIC Code 36
48
September 1995
-------
Sector Notebook Project
Electronics and Computer Industry
Exhibit 20
TRI Reporting Semiconductor Manufacturing Facilities (SIC 3674) by State
State
AZ
CA
CO
FL
ID
MA
MD
ME
MN
MO
NC
NH
NM
NY
OH
Number of
Facilities
9
56
4
2
3
9
2
1
4
1
2
2
2
6
4
State
OR
PA
PR
RI
SC
TX
UT
VT
WA
WI
Number of
Facilities
7
7
1
1
1
20
3
1
1
1
Source: US EPA, Toxics Release Inventory Database, 1993.
Exhibits 21 and 22 show the chemical releases and transfers for the
semiconductor industry. Sulfuric acid and hydrochloric acid, two of
the most commonly-released chemicals, are used during etching and
cleaning processes. Solvents such as acetone, glycol ethers, xylene,
and Freon 113 are used during photolithography and cleaning
processes. 1,1,1-trichloroethane is used during oxidation and
ammonia is used during photolithography and cleaning. A significant
amount of methyl ethyl ketone is released during the degreasing and
cleaning processes. Most of these solvents are released into the air.
Facilities with zero releases of certain chemicals are reported here
because transfers of the chemical may have been reported.
September 1995
49
SIC Code 36
-------
Electronics and Computer Industry
Sector Notebook Project
Exhibit 21
Releases for Semiconductor Manufacturing Facilities (SIC 3674) in TRI,
by Number of Facilities (Releases Reported in Pounds/Year)
Chemical Name
Sulfuric Acid
Hydrochloric Acid
Hydrogen Fluoride
Phosphoric Acid
Nitric Acid
Acetone
Ammonia
Glycol Ethers
Xylene (Mixed Isomers)
Ethylene Glycol
Methanol
Freon 113
1,1,1 -Trichloroethane
Methyl Ethyl Ketone
Tetrachloroethylene
Ammonium Nitrate
(Solution)
Ammonium Sulfate
(Solution)
Lead
Phenol
Toluene
Trichloroethylene
Copper
Ethylbenzene
Methyl Isobutyl Ketone
1 ,2-Dichlorobenzene
1 ,2,4-Trichlorobenzene
Antimony Compounds
Chlorine Dioxide
Cobalt Compounds
Isopropyl Alcohol
(Manufacturing)
Lead Compounds
N-Butyl Alcohol
Nickel Compounds
Nitrilotriacetic Acid
P-Xylene
Totals
# Facilities
Reporting
Chemical
125
78
71
69
57
53
42
27
25
16
16
10
8
6
4
3
3
3
3
3
3
2
2
2
2
2
1
1
1
1
1
1
1
1
1
Fugitive Air
13644
8262
4940
4039
5403
121794
42770
41317
9952
1688
31049
41211
1691
1332
514
0
250
0
50
25170
14009
0
175
750
200
0
18
5
5
0
0
21
0
5
0
370,264
Point Air
88209
69429
55479
25674
47628
890290
101717
212900
252661
9316
135566
73335
82366
128250
55034
0
0
0
2745
33580
21896
0
1300
9325
49234
6519
5
5
2
0
0
84
0
5
430
2,352,984
Water
Discharges
17
3
9902
0
23
1460
42082
500
0
1600
0
0
0
0
1
0
0
0
0
0
0
12
0
0
0
0
1
0
0
0
0
0
0
0
0
55,601
Under-
ground
Injection
250
0
0
0
0
659
17805
0
139
0
129
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
18,983
Land
Disposal
139
10
5
5
5
5
8600
82000
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
90,774
Total
Releases
102259
77704
70326
29718
53059
1014208
212974
336717
262752
12604
166744
114546
84058
129587
55549
0
250
0
2795
58750
35905
12
1475
10075
49434
6519
24
10
7
0
0
105
0
10
430
2,888,606
Average
Releases
per
Facility
818
996
991
431
931
19136
5071
12471
10510
788
10422
11455
10507
21598
13887
0
83
0
932
19583
11968
6
738
5038
24717
3260
24
10
7
0
0
105
0
10
430
Source: US EPA, Toxics Release Inventory Database, 1993.
SIC Code 36
50
September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 22
Transfers for Semiconductor Manufacturing Facilities (SIC 3674) in TRI,
Number of Facilities (Transfers Reported in Pounds/Year)
by
Chemical Name
Sulfuric Acid
Hydrochloric Acid
Hydrogen Fluoride
Phosphoric Acid
Nitric Acid
Acetone
Ammonia
Glycol Ethers
Xylene (Mixed Isomers)
Ethylene Glycol
Methanol
Freon 113
1,1,1 -Trichloroethane
Methyl Ethyl Ketone
Tetrachloroethylene
Ammonium Nitrate
(Solution)
Ammonium Sulfate
(Solution)
Lead
Phenol
Toluene
Trichloroethylene
Copper
Ethylbenzene
Methyl Isobutyl Ketone
1 ,2-Dichlorobenzene
1 ,2,4-Trichlorobenzene
Antimony Compounds
Chlorine Dioxide
Cobalt Compounds
Isopropyl Alcohol
(Manufacturing)
Lead Compounds
N-Butyl Alcohol
Nickel Compounds
Nitrilotriacetic Acid
P-Xylene
Zinc Compounds
Totals
#
Reporting
Chemical
125
78
71
69
57
53
42
27
25
16
16
10
8
6
4
3
3
3
3
3
3
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
POTW
Discharges
147449
236415
11733
1103
56177
104090
944298
30889
3891
458412
14474
25
263
869
0
224302
1488462
0
2331
0
0
0
0
0
10
1413
0
0
0
5
0
10430
381
0
0
0
3,737,422
Disposal
500380
29599
198630
269124
99817
1582
52771
3345
824
2027
0
592
5
750
0
0
0
1500
0
0
0
18
146
0
0
0
18100
0
3780
0
6630
0
0
0
0
267300
1,456,92
0
Recycling
1039071
21664
525
200000
20910
136987
650
139100
31304
15194
27715
36937
75267
0
10215
0
122000
59125
0
0
59736
0
0
0
0
0
0
0
0
10165
0
0
3574
0
0
0
2,010,139
Treatment
169372
84745
151929
33594
62904
116610
10806
56330
127501
623
64502
2435
18264
2105
59628
0
0
13961
27
17000
0
166
190
9300
2157
32273
0
0
0
0
0
0
0
0
10380
0
1,046,802
Energy
Recovery
0
5
0
0
0
1075656
0
1049440
728688
102016
716413
5660
8000
276109
53000
0
0
0
94679
5970
0
0
16800
12190
93600
0
0
0
0
0
0
1433
0
0
0
0
4,239,659
Total
Transfers
1856272
372428
362817
503821
239808
1442137
1008525
1279104
892208
578272
823104
45649
101799
279833
122843
224302
1610462
74586
97037
22970
59736
184
17136
21490
95767
33686
18100
0
3780
10170
6630
11863
3955
0
10380
267300
12,498,154
Average
Transfer
per
Facility
14850
4775
5110
7302
4207
27210
24013
47374
35688
36142
51444
4565
12725
46639
30711
74767
536821
24862
32346
7657
19912
92
8568
10745
47884
16843
18100
0
3780
10170
6630
11863
3955
0
10380
267300
Source: US EPA, Toxics Release Inventory Database, 1993.
September 1995
51
SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
IV.A.2. TRI Data for Printed Wiring Board Industry
The following exhibits present TRI data pertaining to PWB
manufacturing. Exhibit 23 presents the top ten TRI-reporting PWB
manufacturing facilities in terms of TRI releases. IBM is one of these
companies which is also among the top ten electronics sales generating
companies. Exhibit 24 displays the number of TRI-reporting facilities
per State. California has the largest number of PWB manufacturing
facilities.
Exhibit 23
Top 10 TRI Releasing Printed Wiring Board Manufacturing Facilities (SIC 3672)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Pounds
255,395
193,720
127,283
120,864
96,191
79,250
74,653
68,456
67,050
65,088
Facility Name
IBM Corp.
Hadco Corp. Oswego Div.
Continental Circuits Corp.
Thomson Consumer Electronics
Inc.
Hadco Corp.
QLP Laminates Inc.
Synthane-Taylor
Circuit- Wise Inc.
American Matsushita Electronics
Corp.
Pec Viktron
City
Endicott
Oswego
Phoenix
Dunmore
Derry
Anaheim
La Verne
North Haven
Troy
Orlando
State
NY
NY
AZ
PA
NH
CA
CA
CT
OH
FL
Source: US EPA, Toxics Release Inventory Database, 1993.
SIC Code 36
52
September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 24
TRI Reporting Printed Wiring Board Manufacturing
Facilities (SIC 3672) by State
State
AZ
CA
CO
CT
FL
GA
IA
IL
IN
KS
MA
MD
MI
MN
MO
NC
NH
Number of
Facilities
9
82
3
7
11
2
2
18
3
1
9
1
1
14
4
1
9
State
NJ
NY
OH
OK
OR
PA
PR
SC
SD
TX
UT
VA
VT
WA
WI
Number of
Facilities
3
8
7
1
6
5
4
2
1
8
4
3
1
6
4
Source: US EPA, Toxics Release Inventory Database, 1993.
September 1995
53
SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
As seen in Exhibits 25 and 26, the top releases of acids from PWB
facilities include sulfuric acid, hydrochloric acid, and nitric acid, all of
which are used during cleaning, electroless plating and electroplating
operations. Hydrochloric acid is also used during etching. The acids
are primarily released to the air or recycled. Glycol ethers are released
during image application and cleaning; most of the releases are
emitted into the air. Freon 113 is used primarily for flux removal and
is released into the air. Nearly all Freon 113 transfers are recycled.
Acetone, a solvent used to clean the board before imaging, is released
primarily into the air. Ammonium sulfate solution is used during
electroplating, imaging, and etching processes and is released to the
water or transferred to POTWs. Metals such as lead and copper are
commonly used during electroplating, etching, and soldering (i.e.,
lead) processes. These metals and their compounds are primarily
recycled.
Exhibit 25
Releases for Printed Wiring Board Manufacturing Facilities (SIC 3672) in TRI, by
Number of Facilities (Releases Reported in Pounds/Year)
Chemical Name
Sulfuric Acid
Ammonia
Copper
Copper Compounds
Hydrochloric Acid
Nitric Acid
Glycol Ethers
Formaldehyde
Chlorine
Lead
Acetone
Freon 113
Lead Compounds
Ammonium Sulfate
(Solution)
Methyl Ethyl Ketone
Phosphoric Acid
Methanol
Dichloromethane
1,1,1 -Trichloroethane
2-Methoxyethanol
Hydrogen Fluoride
Nickel
Toluene
Zinc Compounds
Ammonium Nitrate
(Solution)
Barium Compounds
Ethylbenzene
Ethylene Glycol
# Facilities
Reporting
Chemical
208
117
89
73
70
59
25
22
16
12
10
9
7
6
6
6
5
4
3
3
2
2
2
2
1
1
1
1
Fugitive
Air
25640
80332
1345
6830
13268
7572
82099
3225
1545
250
117974
83258
760
0
13770
510
62978
51269
24930
5000
0
0
29425
750
0
250
250
600
Point Air
98477
480081
1860
7532
40342
12750
132118
14912
5992
750
70711
37550
1260
0
25023
505
7394
125288
8310
40960
250
0
14125
0
0
0
2600
1200
Water
Discharges
0
28029
27
1831
32189
0
23057
255
50
5
0
0
252
100000
0
0
0
5
0
0
0
0
0
0
0
0
0
0
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
250
0
8500
9739
27
0
0
0
0
3500
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total
Releases
124367
588442
11732
25932
85826
20322
237274
18392
7587
4505
188685
120808
2272
100000
38793
1015
70372
176562
33240
45960
250
0
43550
750
0
250
2850
1800
Average
Release
per
Facility
598
5029
132
355
1226
344
9491
836
474
375
18869
13423
325
16667
6466
169
14074
44141
11080
15320
125
0
21775
375
0
250
2850
1800
SIC Code 36
54
September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 25 (cont'd)
Releases for Printed Wiring Board Manufacturing Facilities (SIC 3672) in TRI, by
Number of Facilities (Releases Reported in Pounds/Year)
Chemical Name
Isopropyl Alcohol
(Manufacturing)
Methylenebis
(Phenylisocyanate)
Phenol
Silver
Tetrachloroethylene
Trichloroethylene
Xylene (Mixed Isomers)
1 ,2-Dichlorobenzene
Totals
# Facilities
Reporting
Chemical
1
1
1
1
1
1
1
1
Fugitive
Air
0
0
750
0
12900
14920
1000
1800
645,200
Point Air
0
0
750
0
22300
26000
16560
2130
1,197,730
Water
Discharges
0
0
250
0
0
0
0
185,950
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
Land
Disposal
0
0
0
0
0
0
0
0
22,016
Total
Releases
0
0
1750
0
35200
40920
17560
3930
2,050,896
Average
Releases
per
Facility
0
0
1750
0
35200
40920
17560
3930
Source: US EPA, Toxics Release Inventory Database, 1993.
Exhibit 26
Transfers for Printed Wiring Board Manufacturing Facilities (SIC 3672) in TRI,
by Number of Facilities (Transfers Reported in Pounds/Year)
Chemical Name
Sulfuric Acid
Ammonia
Copper
Copper
Compounds
Hydrochloric
Acid
Nitric Acid
Glycol Ethers
Formaldehyde
Chlorine
Lead
Acetone
Freon 113
Lead Compounds
Ammonium
Sulfate (Solution)
Methyl Ethyl
Ketone
Phosphoric Acid
Methanol
Dichloromethane
1,1,1-
Trichloroethane
2-Methoxyethanol
Hydrogen
Fluoride
Nickel
Toluene
Zinc Compounds
Ammonium
Nitrate (Solution)
Barium
Compounds
#
Reporting
Chemical
208
117
89
73
70
59
25
22
16
12
10
9
7
6
6
6
5
4
3
3
2
2
2
2
1
1
POTW
Discharges
34596
412348
18527
31441
1317
265
475285
64501
655
1025
2100
250
1559
338933
0
250
41902
253
0
0
0
251
8905
4334
73000
0
Disposal
15558
2513
77880
101998
750
8500
1350
0
0
13297
45
0
14454
0
250
0
170
0
0
0
0
0
0
10876
0
500
Recycling
85488
6102550
5159806
7949551
1056064
169722
6974
0
94152
268496
3000
77460
92233
0
0
0
0
71940
115750
0
0
381
0
0
0
0
Treatment
456242
212950
104791
263240
1453601
202665
240182
2500
111000
4231
1600
1700
5125
0
750
460
10746
2526
1410
0
5600
0
0
1087
0
0
Energy
Recovery
28400
0
0
0
3100
0
21792
0
0
40
188153
5
0
0
397048
0
0
38970
8180
12250
0
0
121600
0
0
0
Total
Transfers
620284
6730361
5361004
8346230
2514832
381152
745583
67001
205807
287089
194898
79415
113371
338933
398048
710
52818
113689
125340
12250
5600
632
130505
16297
73000
500
Average
Transfers
per Facility
2982
57524
60236
114332
35926
6460
29823
3046
12863
23924
19490
8824
16196
56489
66341
118
10564
28422
41780
4083
2800
316
65253
8149
73000
500
Source: US EPA, Toxics Release Inventory Database, 1993.
September 1995
55
SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
Exhibit 26 (cont'd)
Transfers for Printed Wiring Board Manufacturing Facilities (SIC 3672) in TRI,
by Number of Facilities (Transfers Reported in pounds/year)
Chemical Name
Ethylbenzene
Ethylene Glycol
Isopropyl Alcohol
(Manufacturing)
Methylenebis
(Phenylisocyanate)
Phenol
Silver
Tetrachloroethylene
Trichloroethylene
Xylene (Mixed
Isomers)
1 ,2-Dichlorobenzene
Totals
#
Reporting
Chemical
1
1
1
1
1
1
1
1
1
1
POTW
Discharges
0
9300
0
0
0
0
0
0
0
0
1,524,04
3
Disposal
5
230
3900
0
0
0
0
0
250
0
252,526
Recycling
0
0
0
0
0
3
0
0
0
0
21,253,57
0
Treatment
500
0
5460
16800
10340
0
1091590
61600
2360
0
4,271,05
6
Energy
Recovery
117430
0
0
0
22870
0
49020
0
559310
109810
1,677,97
8
Total
Transfers
117935
9530
9360
16800
33210
3
1140610
61600
561920
109810
28,976,12
7
Average
Transfer per
Facility
117935
9530
9360
16800
33210
3
1140610
61600
561920
109810
Source: US EPA, Toxics Release Inventory Database, 1993.
IV.A.3. TRI Data for Cathode Ray Tube Industry
Exhibits 27 present the top ten TRI-reporting CRT manufacturers in
terms of releases, and Exhibit 28 presents the number of TRI reporting
CRT manufacturing facilities by State. It is not surprising that few
facilities are reported in TRI because most manufacturing occurs
outside the United States. Exhibits 29 and 30 show TRI releases and
transfers per chemical. As expected, a significant amount of lead (used
during the frit sealing process) is released, much of which is
transferred off-site for disposal and recycling. Zinc compounds are
used during the phosphor stripe process and are transferred for
recycling. Nitric acid, which is used during tube salvaging, is released
into the air. Freon 113 is used as a cleaning agent during panel
shadow mask preparation and is also released into the air. Solvents
(i.e., acetone, methyl ethyl ketone, toluene, and methanol) are used for
cleaning and degreasing and are released primarily into the air or
transferred for recycling.
SIC Code 36
56
September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 27
Top 10 TRI Releasing Cathode Ray Tube Manufacturing Facilities (SIC 3671)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Pounds
861,508
378,105
257,954
78,756
47,000
43,055
42,323
24,901
21,613
6,250
Facility Name
Zenith Electronics Corp., Rauland Div.
Philips Display Components Co.
Toshiba Display Devices Inc.
Varian X-Ray Tube Prods.
Richardson Electronics Ltd.
Thomson Consumer Electronics
Varian Assoc. Inc. Power Grid Tube
Prods.
Clinton Electronics Corp.
Hitachi Electronic Devices USA Inc.
ITT Corp., ITT Electron Technology Div.
City
Melrose Park
Ottawa
Horseheads
Salt Lake City
Lafox
Marion
San Carlos
Loves Park
Greenville
Easton
State
IL
OH
NY
UT
IL
IN
CA
IL
SC
PA
Source: US EPA, Toxics Release Inventory Database, 1993.
Exhibit 28
TRI Reporting Cathode Ray Tube Manufacturing Facilities (SIC 3671) by State
State
CA
IL
IN
KY
MA
NY
OH
PA
RI
SC
UT
Number of
Facilities
1
4
2
1
1
1
1
2
1
1
1
Source: US EPA, Toxics Release Inventory Database, 1993.
September 1995
57
SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
Exhibit 29
Releases for Cathode Ray Tube Manufacturing Facilities (SIC 3671) in TRI, by
Number of Facilities (Releases Reported in Pounds/Year)
Chemical Name
Hydrochloric Acid
Acetone
Nitric Acid
Lead Compounds
Sulfuric Acid
Methanol
Trichloroethylene
Barium Compounds
Hydrogen Fluoride
Toluene
Zinc Compounds
Copper
Ammonia
Arsenic Compounds
Freon 113
Methyl Ethyl Ketone
1,1,1 -Trichloroethane
Chromium Compounds
Copper Compounds
Methyl Isobutyl Ketone
Methylenebis
(Phenylisocyanate)
Nickel
Nickel Compounds
Tetrachloroethylene
Xylene (Mixed
Isomers)
Totals
# Facilities
Reporting
Chemical
9
8
8
7
7
6
6
5
5
5
4
3
2
2
2
2
2
1
1
1
1
1
1
1
1
Fugitive Air
359
121559
2767
99
1580
41906
151543
6
1760
38856
205
10
1069
0
34718
72778
1484
0
10
139
0
5
0
0
70
470,923
Point Air
589
102405
77073
2637
152
35307
393048
5
4175
480286
5017
255
8411
0
5227
54045
35983
0
200
13777
0
5
0
0
70418
1,289,015
Water
Discharges
0
0
0
435
0
1550
0
476
0
1681
164
65
3103
2
0
0
5
146
5
0
0
0
50
0
0
7,682
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
01
0
0
0
0
0
1
Total
Releases
948
223964
79840
3171
1732
78763
544591
487
5935
520823
5386
330
12583
2
39945
126823
37472
146
215
13916
0
10
50
0
70488
1,767,620
Average
Releases per
Facility
105
27996
9980
453
247
13127
90765
97
1187
104165
1347
110
6292
1
19973
63412
18736
146
215
13916
0
10
50
0
70488
Source: US EPA, Toxics Release Inventory Database, 1993.
Exhibit 30
Transfers for Cathode Ray Tube Manufacturing Facilities (SIC 3671) in TRI, by
Number of Facilities (Transfers Reported in Pounds/Year)
Chemical Name
Hydrochloric Acid
Acetone
Nitric Acid
Lead Compounds
Sulfuric Acid
Methanol
Trichloroethylene
Barium
Compounds
Hydrogen Fluoride
Toluene
Zinc Compounds
Copper
Ammonia
Arsenic
Compounds
Freon 113
# Facilities
Reporting
Chemical
9
8
8
7
7
6
6
5
5
5
4
3
2
2
2
POTW
Discharges
250
173
0
1175
0
202029
250
255
39347
81
1397
61
0
0
0
Disposal
0
0
0
1924617
0
0
0
295228
0
0
56654
279
0
7388
0
Recycling
0
21712
0
487010
250
64240
151155
138785
0
626179
212504
80492
0
7579
7170
Treatment
250
60
333274
137506
20639
5000
150000
1850
215536
277
59710
0
0
0
0
Energy
Recovery
0
38674
0
0
0
5820
0
0
0
106983
0
0
0
0
0
Total
Transfers
500
60619
333274
2550308
20889
277089
301405
436118
254883
733520
330265
80832
0
14967
7170
Average
Transfers
per
Facility
56
7577
41659
364330
2984
46182
50234
87224
50977
146704
82566
26944
0
7484
3585
Source: US EPA, Toxics Release Inventory Database, 1993.
SIC Code 36
58
September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 30 (cont'd)
Transfers for Cathode Ray Tube Manufacturing Facilities (SIC 3671) in TRI, by
Number of Facilities (Transfers Reported in Pounds/Year)
Chemical Name
Methyl Ethyl Ketone
1,1,1-
Trichloroethane
Chromium
Compounds
Copper Compounds
Methyl Isobutyl
Ketone
Methylenebis
(Phenylisocyanate)
Nickel
Nickel Compounds
Tetrachloroethylene
Xylene (Mixed
Isomers)
Totals
# Facilities
Reporting
Chemical
2
2
1
1
1
1
1
1
1
1
POTW
Discharges
0
7
0
45
0
0
63
0
0
0
245,133
Disposal
0
0
162
0
0
4192
0
36
0
0
2,288,556
Recycling
0
10845
2
68700
0
0
24146
40260
0
0
1,941,029
Treatment
0
0
0
0
0
0
0
0
20600
0
944,702
Energy
Recovery
15549
0
0
0
1722
0
0
0
0
0
168,748
Total
Transfers
15549
10852
164
68745
1722
4192
24209
40296
20600
0
5,588,168
Average
Transfers
per Facility
7775
5426
164
68745
1722
4192
24209
40296
20600
0
Source: US EPA, Toxics Release Inventory Database, 1993.
IV.B. Summary of Selected Chemicals Released
The following is a synopsis of current scientific toxicity and fate
information for the top chemicals (by weight) that facilities within this
sector self-reported as released to the environment based upon 1993
TRI data. Because this section is based upon self-reported release data,
it does not attempt to provide information on management practices
employed by the sector to reduce the release of these chemicals.
Information regarding pollutant release reductions over time may be
available from EPA's TRI and 33/50 programs, or directly from the
industrial trade associations that are listed in Section IX of this
document. Since these descriptions are cursory, please consult the
sources referenced below for a more detailed description of both the
chemicals described in this section, and the chemicals that appear on
the full list of TRI chemicals appearing in Section IV. A.
September 1995
59
SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
The brief descriptions provided below were taken from the 1993 Toxics
Release Inventory Public Data Release (EPA, 1994), the Hazardous
Substances Data Bank (HSDB), and the Integrated Risk Information
System (IRIS), both accessed via TOXNET2. The information contained
below is based upon exposure assumptions that have been conducted
using standard scientific procedures. The effects listed below must be
taken in context of these exposure assumptions that are more fully
explained within the full chemical profiles in HSDB.
The following chemicals are those released in the greatest quantity by
the electronics/computer manufacturing industry:
Acetone
Ammonia
Dichloromethane
Freon 113
Glycol Ethers
Methanol
Methyl Ethyl Ketone
Sulfuric Acid
Toluene
Trichloroethylene
Xylene
2 TOXNET is a computer system run by the National Library of Medicine that includes a number of
toxicological databases managed by EPA, National Cancer Institute, and the National Institute for
Occupational Safety and Health. For more information on TOXNET, contact the TOXNET help line
at 1-800-231-3766. Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research
Information System), DART (Developmental and Reproductive Toxicity Database), DBIR (Directory
of Biotechnology Information Resources), EMICBACK (Environmental Mutagen Information Center
Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS
(Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical Substances), and
TRI (Toxic Chemical Release Inventory). HSDB contains chemical-specific information on
manufacturing and use, chemical and physical properties, safety and handling, toxicity and
biomedical effects, pharmacology, environmental fate and exposure potential, exposure standards
and regulations, monitoring and analysis methods, and additional references.
SIC Code 36 60 September 1995
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Sector Notebook Project Electronics and Computer Industry
Acetone
Toxicity. Acetone is irritating to the eyes, nose, and throat. Symptoms
of exposure to large quantities of acetone may include headache,
unsteadiness, confusion, lassitude, drowsiness, vomiting, and
respiratory depression.
Reactions of acetone (see environmental fate) in the lower atmosphere
contribute to the formation of ground-level ozone. Ozone (a major
component of urban smog) can affect the respiratory system, especially
in sensitive individuals such as asthmatics or allergy sufferers.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. If released into water, acetone will be degraded
by microorganisms or will evaporate into the atmosphere.
Degradation by microorganisms will be the primary removal
mechanism.
Acetone is highly volatile, and once it reaches the troposphere (lower
atmosphere), it will react with other gases, contributing to the
formation of ground-level ozone and other air pollutants. EPA is
reevaluating acetone's reactivity in the lower atmosphere to determine
whether this contribution is significant.
Physical Properties. Acetone is a volatile and flammable organic
chemical.
Note; Acetone was removed from the list of TRI chemicals on June 16, 1995
(60 FR 31643) and will not be reported for 1994 or subsequent years.
Freon 113 (Trichlorotrifluoroethane)
Toxicity. No adverse human health effects are expected from ambient
exposure to Freon 113. Inhalation of high concentrations of Freon 113
causes some deterioration of psychomotor performance (loss of ability
to concentrate and a mild lethargy), and an irregular heartbeat.
Chronic exposure to Freon 113 caused reversible weakness, pain, and
tingling in the legs of one occupationally-exposed woman. There is
some evidence of a higher incidence of coronary heart disease among
hospital personnel and refrigerant mechanics exposed to
fluorocarbons. Exposure to high concentrations of Freon 113 may
cause eye and throat irritation.
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Fluorocarbons are, however, considerably less toxic than the process
materials used in their manufacture (e.g., chlorine). In addition, under
certain conditions, fluorocarbon vapors may decompose on contact
with flames or hot surfaces, creating the potential hazard of inhalation
of toxic decomposition products.
Populations at increased risk from exposure to Freon 113 include
people with existing skin disorders, and people with a history of
cardiac arrhythmias.
The most significant toxic effect associated with Freon 113 is its role as
a potent ozone-depleter. Stratospheric ozone depletion causes an
increase in the levels of ultraviolet solar radiation reaching the earth's
surface, which in turn is linked to increased incidence of skin cancers,
immune system suppression, cataracts, and disruptions in terrestrial
and aquatic ecosystems. In addition, increased UV-B radiation is
expected to increase photochemical smog, aggravating related health
problems in urban and industrialized areas.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. All of the Freon 113 produced is eventually lost as
air emissions and builds up in the atmosphere. If released on land,
Freon 113 will leach into the ground and volatilize from the soil
surface. No degradative processes are known to occur in the soil.
Freon 113 is not very water soluble and is removed rapidly from water
via volatilization. Chemical hydrolysis, bioaccumulation and
adsorption to sediments are not significant fate processes in water.
Freon 113 is extremely stable in the lower atmosphere and will
disperse over the globe and diffuse slowly into the stratosphere where
it will be lost by photolysis. In this process, chlorine atoms are
released that attack ozone.
Glvcol Ethers
Due to data limitations, data on diethylene glycol (glycol ether) are
used to represent all glycol ethers.
Toxicity. Diethylene glycol is only a hazard to human health if
concentrated vapors are generated through heating or vigorous
agitation or if appreciable skin contact or ingestion occurs over an
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extended period of time. Under normal occupational and ambient
exposures, diethylene glycol is low in oral toxicity, is not irritating to
the eyes or skin, is not readily absorbed through the skin, and has a
low vapor pressure so that toxic concentrations of the vapor can not
occur in the air at room temperatures.
At high levels of exposure, diethylene glycol causes central nervous
depression and liver and kidney damage. Symptoms of moderate 0
diethylene glycol poisoning include nausea, vomiting, headache,
diarrhea, abdominal pain, and damage to the pulmonary and
cardiovascular systems. Sulfanilamide in diethylene glycol was once
used therapeutically against bacterial infection; it was withdrawn from
the market after causing over 100 deaths from acute kidney failure.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Diethylene glycol is a water-soluble, volatile
organic chemical. It may enter the environment in liquid form via
petrochemical plant effluents or as an unburned gas from combustion
sources. Diethylene glycol typically does not occur in sufficient
concentrations to pose a hazard to human health.
Methanol
Toxicity. Methanol is readily absorbed from the gastrointestinal tract
and the respiratory tract, and is toxic to humans in moderate to high
doses. In the body, methanol is converted into formaldehyde and
formic acid. Methanol is excreted as formic acid. Observed toxic
effects at high dose levels generally include central nervous system
damage and blindness. Long-term exposure to high levels of
methanol via inhalation cause liver and blood damage in animals.
Ecologically, methanol is expected to have low toxicity to aquatic
organisms. Concentrations lethal to half the organisms of a test
population are expected to exceed 1 mg methanol per liter water.
Methanol is not likely to persist in water or to bioaccumulate in
aquatic organisms.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Liquid methanol is likely to evaporate when left
exposed. Methanol reacts in air to produce formaldehyde which
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contributes to the formation of air pollutants. In the atmosphere it can
react with other atmospheric chemicals or be washed out by rain.
Methanol is readily degraded by microorganisms in soils and surface
waters.
Physical Properties. Methanol is highly flammable.
Methylene Chloride (Dichloromethane)
Toxicity. Short-term exposure to dichloromethane (DCM) is associated
with central nervous system effects, including headache, giddiness,
stupor, irritability, and numbness and tingling in the limbs. More
severe neurological effects are reported from longer-term exposure,
apparently due to increased carbon monoxide in the blood from the
break down of DCM. Contact with DCM causes irritation of the eyes,
skin, and respiratory tract.
Occupational exposure to DCM has also been linked to increased
incidence of spontaneous abortions in women. Acute damage to the
eyes and upper respiratory tract, unconsciousness, and death were
reported in workers exposed to high concentrations of DCM.
Phosgene (a degradation product of DCM) poisoning has been
reported to occur in several cases where DCM was used in the
presence of an open fire.
Populations at special risk from exposure to DCM include obese
people (due to accumulation of DCM in fat), and people with impaired
cardiovascular systems.
Carcinogenicity. DCM is a probable human carcinogen via both oral
and inhalation exposure, based on inadequate human data and
sufficient evidence in animals.
Environmental Fate. When spilled on land, DCM is rapidly lost from
the soil surface through volatilization. The remainder leaches through
the subsoil into the groundwater.
Biodegradation is possible in natural waters but will probably be very
slow compared with evaporation. Little is known about
bioconcentration in aquatic organisms or adsorption to sediments but
these are not likely to be significant processes. Hydrolysis is not an
important process under normal environmental conditions.
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DCM released into the atmosphere degrades via contact with other
gases with a half-life of several months. A small fraction of the
chemical diffuses to the stratosphere where it rapidly degrades
through exposure to ultraviolet radiation and contact with chlorine
ions. Being a moderately soluble chemical, DCM is expected to
partially return to earth in rain.
Methyl Ethyl Ketone
Toxicity. Breathing moderate amounts of methyl ethyl ketone (MEK)
for short periods of time can cause adverse effects on the nervous
system ranging from headaches, dizziness, nausea, and numbness in
the fingers and toes to unconsciousness. Its vapors are irritating to the
skin, eyes, nose, and throat and can damage the eyes. Repeated
exposure to moderate to high amounts may cause liver and kidney
effects.
Carcinogenicity. No agreement exists over the carcinogenicity of
MEK. One source believes MEK is a possible carcinogen in humans
based on limited animal evidence. Other sources believe that there is
insufficient evidence to make any statements about possible
carcinogenicity.
Environmental Fate. Most of the MEK released to the environment
will end up in the atmosphere. MEK can contribute to the formation of
air pollutants in the lower atmosphere. It can be degraded by
microorganisms living in water and soil.
Physical Properties. Methyl ethyl ketone is a flammable liquid.
Sulfuric Acid
Toxicity. Concentrated sulfuric acid is corrosive. In its aerosol form,
sulfuric acid has been implicated in causing and exacerbating a variety
of respiratory ailments.
Ecologically, accidental releases of solution forms of sulfuric acid may
adversely affect aquatic life by inducing a transient lowering of the pH
(i.e., increasing the acidity) of surface waters. In addition, sulfuric acid
in its aerosol form is also a component of acid rain. Acid rain can
cause serious damage to crops and forests.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
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Environmental Fate. Releases of sulfuric acid to surface waters and
soils will be neutralized to an extent due to the buffering capacities of
both systems. The extent of these reactions will depend on the
characteristics of the specific environment.
In the atmosphere, aerosol forms of sulfuric acid contribute to acid
rain. These aerosol forms can travel large distances from the point of
release before the acid is deposited on land and surface waters in the
form of rain.
Toluene
Toxicity. Inhalation or ingestion of toluene can cause headaches,
confusion, weakness, and memory loss. Toluene may also affect the
way the kidneys and liver function.
Reactions of toluene (see environmental fate) in the atmosphere
contribute to the formation of ozone in the lower atmosphere. Ozone
can affect the respiratory system, especially in sensitive individuals
such as asthma or allergy sufferers.
Some studies have shown that unborn animals were harmed when
high levels of toluene were inhaled by their mothers, although the
same effects were not seen when the mothers were fed large quantities
of toluene. Note that these results may reflect similar difficulties in
humans.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. The majority of releases of toluene to land and
water will evaporate. Toluene may also be degraded by
microorganisms. Once volatilized, toluene in the lower atmosphere
will react with other atmospheric components contributing to the
formation of ground-level ozone and other air pollutants.
Physical Properties. Toluene is a volatile organic chemical.
Trichloroethylene
Toxicity. Trichloroethylene was once used as an anesthetic, though its
use caused several fatalities due to liver failure. Short term inhalation
exposure to high levels of trichloroethylene may cause rapid coma
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followed by eventual death from liver, kidney, or heart failure. Short-
term exposure to lower concentrations of trichloroethylene causes eye,
skin, and respiratory tract irritation. Ingestion causes a burning
sensation in the mouth, nausea, vomiting and abdominal pain.
Delayed effects from short-term trichloroethylene poisoning include
liver and kidney lesions, reversible nerve degeneration, and psychic
disturbances. Long-term exposure can produce headache, dizziness,
weight loss, nerve damage, heart damage, nausea, fatigue, insomnia,
visual impairment, mood perturbation, sexual problems, dermatitis,
and rarely jaundice. Degradation products of trichloroethylene
(particularly phosgene) may cause rapid death due to respiratory
collapse.
Carcinogenicity. Trichloroethylene is a probable human carcinogen
via both oral and inhalation exposure, based on limited human
evidence and sufficient animal evidence.
Environmental Fate. Trichloroethylene breaks down slowly in water
in the presence of sunlight and bioconcentrates moderately in aquatic
organisms. The main removal of trichloroethylene from water is via
rapid evaporation.
Trichloroethylene does not photodegrade in the atmosphere, though it
breaks down quickly under smog conditions, forming other pollutants
such as phosgene, dichloroacetyl chloride, and formyl chloride. In
addition, trichloroethylene vapors may be decomposed to toxic levels
of phosgene in the presence of an intense heat source such as an open
arc welder.
When spilled on the land, trichloroethylene rapidly volatilizes from
surface soils. The remaining chemical leaches through the soil to
groundwater.
Xylene (Mixed Isomers)
Toxicity. Xylenes are rapidly absorbed into the body after inhalation,
ingestion, or skin contact. Short-term exposure of humans to high
levels of xylenes can cause irritation of the skin, eyes, nose, and throat,
difficulty in breathing, impaired lung function, impaired memory, and
possible changes in the liver and kidneys. Both short- and long-term
exposure to high concentrations can cause effects such as headaches,
dizziness, confusion, and lack of muscle coordination. Reactions of
xylenes (see environmental fate) in the atmosphere contribute to the
formation of ozone in the lower atmosphere. Ozone can affect the
September 1995 67 SIC Code 36
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respiratory system, especially in sensitive individuals such as asthma
or allergy sufferers.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. The majority of releases to land and water will
quickly evaporate, although some degradation by microorganisms will
occur.
Xylenes are moderately mobile in soils and may leach into
groundwater, where they may persist for several years.
Xylenes are volatile organic chemicals. As such, xylenes in the lower
atmosphere will react with other atmospheric components,
contributing to the formation of ground-level ozone and other air
pollutants.
IV.C. Other Data Sources
The Aerometric Information Retrieval System (AIRS) contains a wide
range of information related to stationary sources of air pollution,
including the emissions of a number of air pollutants which may be of
concern within a particular industry. With the exception of volatile
organic compounds (VOCs), there is little overlap with the TRI
chemicals reported above. Exhibit 31 summarizes annual releases of
carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter of
10 microns or less (PM10), total particulates (PT), sulfur dioxide (SO2),
and volatile organic compounds (VOCs).
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 31
Pollutant Releases (Short Tons/Years)
Industry
U.S. Total
Metal Mining
Nonmetal Mining
Lumber and Wood
Products
Wood Furniture and
Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastic
Products
Stone, Clay, Glass, and
Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Electronics/ Computer
Motor Vehicles, Bodies,
Parts, and Accessories
Dry Cleaning
CO
97,208,000
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
367
35,303
101
NO2
23,402,000
28,583
28,804
42,658
2,981
394,448
4,915
108,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
1,129
23,725
179
PMio
45,489,000
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
207
2,406
3
PT
7,836,000
140,052
167,948
63,761
3,178
113,571
1,031
39,082
44,860
36,877
5,355
171,853
83,017
22,490
3,136
293
12,853
28
SO2
21,888,000
84,222
24,129
9,149
1,606
341,002
1,728
182,189
132,459
648,153
29,364
339,216
238,268
373,007
4,019
453
25,462
152
voc
23,312,000
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
309,058
140,741
30,262
82,292
27,375
102,186
4,854
101,275
7,310
Source: U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
September 1995
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IV.D. Comparison of Toxic Release Inventory Between Selected Industries
The following information is presented as a comparison of pollutant
release and transfer data across industrial categories. It is provided to
give a general sense as to the relative scale of releases and transfers
within each sector profiled under this project. Please note that the
following table does not contain releases and transfers for industrial
categories that are not included in this project, and thus cannot be used
to draw conclusions regarding the total release and transfer amounts
that are reported to TRI. Similar information is available within the
annual TRI Public Data Release book.
Exhibit 32 is a graphical representation of a summary of the 1993 TRI
data for the electronics/computer industry and the other sectors
profiled in separate notebooks. The bar graph presents the total TRI
releases and total transfers on the left axis and the triangle points show
the average releases per facility on the right axis. Industry sectors are
presented in the order of increasing total TRI releases. The graph is
based on the data shown in Exhibit 33 and is meant to facilitate
comparisons between the relative amounts of releases, transfers, and
releases per facility both within and between these sectors. The reader
should note, however, that differences in the proportion of facilities
captured by TRI exist between industry sectors. This can be a factor of
poor SIC matching and relative differences in the number of facilities
reporting to TRI from the various sectors. In the case of
electronics/computer industry, the 1993 TRI data presented here
covers 406 facilities. These facilities listed SIC 36
Electronics/Computer Industry as a primary SIC code.
SIC Code 36 70 September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 32-bar graph
Summary of 1993 TRI Data: Releases
and Transfers by Industry
Total Pounds (millions)
""DO
600 -
500 -
400 -
300 -
200 -
100 -
1 nnn nnn
._, T
i
v- -T- --
r
I
r
36 32 25 34
24 27 2911
Total Releases | | Total
i
r-i
f
371
i
|
r
331
V
T
1 1 IN
286 281
30 26 333, 33
-800,000 j§
1
'o
600,000 PH
^H
CD
PH
00
CD
00
-400,000 g
^5
Pi
CD
M)
S
-200,000 fc
3
.n
4
Transfers V Avg. Releases/Facility
SIC
Range
36
24
32
27
25
Industry Sector
Electronic Equipment and
Components
Lumber and Wood
Products
Stone, Clay, and Concrete
Printing
Wood Furniture and
Fixtures
SIC
Range
2911
34
371
331
30
Industry Sector
Petroleum Refining
Fabricated Metals
Motor Vehicles, Bodies,
Parts, and Accessories
Iron and Steel
Rubber and Misc.
Plastics
SIC
Range
286
26
281
333,334
Industry Sector
Organic Chemical Mfg.
Pulp and Paper
Inorganic Chemical Mfg.
Nonferrous Metals
September 1995
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Sector Notebook Project
Exhibit 33-Comparative TRI Table
Toxic Release Inventory Data for Selected Industries
Industry Sector
Stone, Clay, and
Concrete
Lumber and Wood
Products
Furniture and
Fixtures
Printing
Electronics/Computer
s
Rubber and Misc.
Plastics
Motor Vehicle,
Bodies, Parts and
Accessories
Pulp and paper
Inorganic Chem. Mfg.
Petroleum Refining
Fabricated Metals
Iron and Steel
Nonferrous Metals
Organic Chemical
Mfg.
Metal Mining
Nonmetal Mining
Dry Cleaning
SIC
Range
32
24
25
2711-
2789
36
30
371
2611-
2631
2812-
2819
2911
34
3312-
3313
3321-
3325
333, 334
2861-
2869
10
14
7215,
7216,
7218
#TRI
Facilities
634
491
313
318
406
1,579
609
309
555
156
2,363
381
208
417
Releases
Total Releases
(106 pounds)
26.6
8.4
42.2
36.5
6.7
118.4
79.3
169.7
179.6
64.3
72.0
85.8
182.5
151.6
Average Releases
per Facility
(pounds)
41,895
17,036
134,883
115,000
16,520
74,986
130,158
549,000
324,000
412,000
30,476
225,000
877,269
364,000
Transfers
1993 Total (106
pounds)
2.2
3.5
4.2
10.2
47.1
45.0
145.5
48.4
70.0
417.5
195.7
609.5
98.2
286.7
Average Transfers
per Facility
(pounds)
3,500
7,228
13,455
732,000
115,917
28,537
238,938
157,080
126,000
2,676,000
82,802
1,600,000
472,335
688,000
Total
Releases +
Transfers
(106 pounds)
28.2
11.9
46.4
46.7
53.7
163.4
224.8
218.1
249.7
481.9
267.7
695.3
280.7
438.4
Average
Release+
Transfers per
Facility
(pounds)
46,000
24,000
148,000
147,000
133,000
104,000
369,000
706,000
450,000
3,088,000
123,000
1,825,000
1,349,000
1,052,000
Industry sector not subject to TRI reporting
Industry sector not subject to TRI reporting
Industry sector not subject to TRI reporting
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
SIC Code 36
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V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place.
Some companies have creatively implemented pollution prevention
techniques that improve efficiency and increase profits while at the
same time minimizing environmental impacts. This can be done in
many ways such as reducing material inputs, re-engineering processes
to reuse by-products, improving management practices, and
employing substitution of toxic chemicals. Some smaller facilities are
able to actually get below regulatory thresholds just by reducing
pollutant releases through aggressive pollution prevention policies.
In order to encourage these approaches, this section provides both
general and company-specific descriptions of some pollution
prevention advances that have been implemented within the
electronics/computer industry. While the list is not exhaustive, it does
provide core information that can be used as the starting point for
facilities interested in beginning their own pollution prevention
projects. When possible, this section provides information from real
activities that can, or are being implemented by this sector including
a discussion of associated costs, time frames, and expected rates of
return. This section provides summary information from activities
that may be, or are being implemented by this sector. When possible,
information is provided that gives the context in which the techniques
can be effectively used. Please note that the activities described in this
section do not necessarily apply to all facilities that fall within this
sector. Facility-specific conditions must be carefully considered when
pollution prevention options are evaluated, and the full impacts of the
change must examine how each option affects, air, land, and water
pollutant releases.
Pollution prevention (sometimes referred to as source reduction) is the
use of materials, processes, or practices that reduce or eliminate the
creation of pollutants or wastes at the source. Pollution prevention
includes practices that reduce the use of hazardous materials, energy,
water or other resources, and practices that protect natural resources
through conservation or more efficient use.
EPA is promoting pollution prevention because it is often the most
cost-effective option to reduce pollution and the environmental and
health risks associated with pollution. Pollution prevention is often
cost effective because it may reduce raw material losses; reduce
reliance on expensive "end-of-pipe" treatment technologies and
disposal practices; conserve energy, water, chemicals, and other
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inputs; and reduce the potential liability associated with waste
generation. Pollution prevention is environmentally desirable for
these very same reasons: pollution itself is reduced at the source while
resources are conserved.
V. A. Identification of Pollution Prevention Activities in Use
The electronics and computer industries have participated in many
pollution prevention projects and have been the focus of many case
studies. Pollution prevention techniques and processes used by these
industries can be grouped into four general categories:
Process or equipment modification
Raw material substitution or elimination
Waste segregation/separation/preparation
Recycling.
Each of these categories is briefly discussed below. Refer to Section
V.B. for a list of specific pollution prevention techniques and
associated costs, savings, and other information.
Process or equipment modification is used to reduce the amount of waste
generated. For example, manufacturers can change equipment or
processes to: enhance water conservation by installation of
countercurrent rinsing systems; reduce alkaline and acid concentration
in tanks by installing a pH controller; and reduce drag-out by
decreasing the withdrawal rate of parts from plating tanks.
Raw material substitution or elimination is the replacement of existing
raw materials with other materials that produce less waste, or a non-
toxic waste. Examples include substituting non-cyanide solution for a
sodium cyanide solution in copper plating baths and replacing
hexavalent chromium with trivalent chrome plating system.
Waste segregation/separation/preparation involves avoiding the mixture of
different types of wastes and avoiding the mixture of hazardous
wastes with non-hazardous wastes. This makes the recovery of
hazardous wastes easier by minimizing the number of different
hazardous constituents in a given waste stream. Also, it prevents the
contamination of non-hazardous wastes. A specific example is
segregation of wastewater sludge by metal contaminants.
Recycling is the use or reuse of a waste as an ingredient or feedstock in
the production process on-site. Examples of recycling include:
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recovering copper during the etching processes, recovering lead and
tin from printed wiring boards, and installing a closed-loop recycling
system to reuse freon (which is being phased-out) and reduce/reuse
water consumption.
V.B. Pollution Prevention Techniques for the Electronics/Computer Industry
This section provides examples of pollution prevention techniques
used in the electronics/computer industry. Much of the information
provided in this section is from the following EPA offices/programs:
the Common Sense Initiative (CSI), EPA's DfE Program, the Pollution
Prevention Information Center, the Office of Environmental
Engineering and Technology Demonstration, the Office of Pollution
Prevention, and Office of Research and Development. Other sources
include the Oregon Department of Environmental Quality and the
California Department of Toxic Substances and Control. Where
available, cost information is provided. However, source documents
did not always provide cost information.
V.B.I. Examples of Source Reduction and Recycling Options for Electroplating
Operations
Technique - Process or Equipment Modification
Option 1 - Modify rinsing methods to control drag-out by:
Increasing bath temperature
Decreasing withdrawal rate of parts from plating bath
Increasing drip time over solution tanks; racking parts to avoid cupping solution within
part cavities
Shaking, vibrating, or passing the parts through an air knife, angling drain boards
between tanks
Using wetting agents to decrease surface tension in tank.
Contact: Braun Intertec Environmental, Inc., and MN Office of Waste Management
(612) 649-5750.
Option 2 - Utilize water conservation methods including:
Flow restrictors on flowing rinses
Counter current rinsing systems
Fog or spray rinsing
Reactive rinsing
Purified or softened water
Dead rinses
Conductivity controllers
Agitation to assure adequate rinsing and homogeneity in rinse tank
Flow control valves.
Contact: Braun Intertec Environmental, Inc., and MN Office of Waste Management
(612) 649-5750.
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Option 3 - Implement counter flow rinsing and cascade rinsing systems to conserve
consumption of water. Costs and Savings: Costs: $75,000 to upgrade existing equipment
and purchasing new and used equipment. Waste Savings/Reduction: reduce water use and
wastewater treatment costs. Contact: Eastside Plating and OR Department of
Environmental Quality (800) 452-4011.
Option 4 - Use drip bars to reduce drag-out. Costs and Savings: Capital Investment:
SlOO/tank. Savings: S600/year. Contact: NC Department of Natural Resources &
Community Development, Gary Hunt (919) 733-7015.
Option 5 - Use drain boards between tanks to reduce generations of drag-out. Costs and
Savings: Capital Investment: S25/tank. Savings: S450/year . Contact: NC Department of
Natural Resources & Community Development, Gary Hunt (919) 733-7015.
Option 6 - Install racking to reduce generations of drag-out. Costs and Savings: Capital
Investment: zero dollars. Operating Costs: minimal. Savings: S600/year. Contact: NC
Department of Natural Resources & Community Development, Gary Hunt (919) 733-7015.
Option 7 - Employ drag out recovery tanks to reduce generations of drag-out. Costs and
Savings: Capital Investment: S500/tank. Savings: S4,700/year. Contact: NC Department
of Natural Resources & Community Development, Gary Hunt (919) 733-7015.
Option 8 - Install counter-current rinsing operation to reduce water consumption. Costs
and Savings: Capital Investment: $1,800-2,300. No direct costs. Savings: Sl,350/year.
Waste Savings/Reductions: reduce water use by 90-99%. Contact: NC Department of
Natural Resources & Community Development, Gary Hunt (919) 733-7015.
Option 9 - Redesign rinse tank to reduce water conservation. Costs and Savings: Capital
Investment: $100. No direct costs. Savings: $750/year. Contact: NC Department of
Natural Resources & Community Development, Gary Hunt (919) 733-7015.
Option 10 - Increase parts drainage time to reduce drag-out. Contact: City of Los Angeles
Hazardous and Toxic Material Project; Board of Public Works (213) 237-1209.
Option 11 - Regenerate plating bath by activated carbon filtration to remove built up organic
contaminants. Costs and Savings: Capital Investment: $9,192. Costs: $7,973/year.
Savings: $122,420/year. Waste Savings/Reduction: 10,800 gallons/year. Reduce volume
of plating baths disposed and requirements for virgin chemicals. Contact: EPA Hazardous
Waste Engineering Research Laboratory, Cincinnati, OH, Harry Freeman.
Option 12 - Install pH controller to reduce the alkaline and acid concentrations in tanks.
Contact: Securus, Inc., DBA Hubbard Enterprises.
Option 13 - Install atmospheric evaporator to reduce metal concentrations. Contact:
Securus, Inc., DBA Hubbard Enterprises.
Option 14 - Install process (e.g., CALFRAN) to reduce pressure to vaporize water at cooler
temperatures and recycle water by condensing the vapors in another container, thus
concentrating and precipitating solutes out. Costs and Savings: Waste Savings/Reduction:
reduce volume and quantity of aqueous waste solutions by recovering pure water. Contact:
CALFRAN International, Inc., (413) 525-4957.
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Sector Notebook Project Electronics and Computer Industry
Option 15- Use reactive rinsing and multiple drag-out baths. Costs and Savings: Savings:
Reduce cost of treating spent process baths and rinsewaters. Waste Savings/Reduction:
increase lifetime of process baths and reduce the quantity or rinsewater requiring treatment.
Contact: SAIC, Edward R. Saltzberg.
Option 16 - Improve control of water level in rinse tanks, improve sludge separation, and
enhance recycling of supernatant to the process by aerating the sludge. Costs and Savings:
Savings: S2,000/year. Waste Savings/Reduction: reduce sludge generation by 32%.
Contact: NJ Hazardous Waste Facilities Siting Commission, Hazardous Waste Source
Reduction and Recycling Task Force.
Option 17 - Install system (e.g., Low Solids Fluxer) that applies flux to printed wiring
boards, leaving little residue and eliminates the need for cleaning CFCs. Costs and Savings:
Waste Savings/Reduction: reduce CFC emissions over 50%. Contact: AT&T Bell
Laboratories, Princeton, NJ.
Option 18 - Install ion exchange system to reduce generation of drag-out. Costs and
Savings: Savings: Sl,900/year. Capital Investment: $78,000. Operating Costs:
S3,200/year. Contact: NC Department of Natural Resources & Community Development;
Pollution Prevention Pays Program Gary Hunt (919) 733-7015.
Option 19 - Employ reverse osmosis system to reduce generation of drag-out. Costs and
Savings: Savings: S40,000/year. Capital Investment: $62,000. Contact: NC Department
of Natural Resources & Community Development; Pollution Prevention Pays Program Gary
Hunt (919) 733-7015.
Option 20 - Use electrolytic metal recovery to reduce generation of drag-out. Costs and
Savings: Capital Investment: $1,000. Contact: NC Department of Natural Resources &
Community Development; Pollution Prevention Pays Program Gary Hunt (919) 733-7015.
Option 21- Utilize electrodialysis to reduce generation of drag-out. Costs and Savings:
Capital Investment: $50,000. Contact: NC Department of Natural Resources & Community
Development; Pollution Prevention Pays Program Gary Hunt (919) 733-7015.
Option 22 - Implement evaporative recovery to reduce generation of drag-out. Costs and
Savings: Capital Investment: $2,500. Contact: NC Department of Natural Resources &
Community Development; Pollution Prevention Pays Program Gary Hunt (919) 733-7015.
Option 23- Implement the electrodialysis reversal process for metal salts in wastewater.
Costs and Savings: Savings: $40,100/year in operating costs. Contact: Ionics, Inc.,
Separations Technology Division.
Technique - Raw Material Substitution
Option 1 - Substitute cyanide plating solutions with alkaline zinc, acid zinc, acid sulfate
copper, pyrophosphate copper, alkaline copper, copper fluoborate, electroless nickel,
ammonium silver, halide silver, methanesulfonate-potassium iodide silver, amino or thio
complex silver, no free cyanide silver, cadmium chloride, cadmium sulfate, cadmium
fluoborate, cadmium perchlorate, gold sulfite, and cobalt harden gold. Contact: Braun
Intertec Environmental, Inc. and MN Office of Waste Management (612) 649-5750.
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Option 2 - Substitute sodium bisulfite and sulfuric acid for ferrous sulfate in order to
oxidize chromic acid wastes, and substitute gaseous chlorine for liquid chlorine in order to
reduce cyanide reduction. Costs and Savings: Savings: S300,000/year. Waste
Savings/Reduction: reduces feedstock by 50%. Contact: Eastside Plating and OR
Department of Environmental Quality (800) 452-4011.
Option 3 - Replace hexavalent chromium with trivalent chromium plating systems.
Contact: City of Los Angeles Hazardous and Toxic Material Project; Board of Public Works
(213) 237-1209.
Option 4 - Replace cyanide with non-cyanide baths. Contact: City of Los Angeles
Hazardous and Toxic Material Project; Board of Public Works (213) 237-1209.
Option 5 - Replace conventional chelating agents such as tartarates, phosphates, EDTA, and
ammonia with sodium sulfides and iron sulfates in removing metal from rinse water which
reduces the amount of waste generated from precipitation of metals from aqueous
wastestreams. Costs and Savings: Costs: S178,830/year. Savings: S382,995/year. Waste
Savings/Reduction: 496 tons of sludge/year. Contact: Tyndall Air Force Base, FL, Charles
Carpenter (904) 283-2942; EG & G, Dan Sucia, Penny Wilcoff, & John Beller (208) 526-1149.
Option 6 - Replace methylene chloride, 1,1,1-trichloroethane, and perchloroethylene
(solvent-based photochemical coatings) with aqueous base coating of 1% sodium carbonate.
Costs and Savings: Waste Savings/Reduction: reduce solvent use by 60 tons/year.
Contact: American Etching and Manufacturing, Pacoima, CA.
Option 7 - Replace methanol with nonflammable alkaline cleaners. Costs and Savings:
Waste Savings/Reduction: eliminate 32 tons/year of flammable methyl alcohol. Contact:
American Etching and Manufacturing, Pacoima, CA.
Option 8 - Substitute a non-cyanide for a sodium cyanide solution used in copper plating
baths. Costs and Savings: Waste Savings/Reduction: reduce 7,630 pounds/year. Contact:
Highland Plating Company, Los Angeles, CA.
Technique - Recycling
Option 1 - Send drag-out waste to another company for waste exchange. Contact: NC
Department of Natural Resources & Community Development; Pollution Prevention Pays
Program Gary Hunt (919) 733-7015.
Option 2 - Reuse rinse water. Costs and Savings: Savings: Sl,500/year. Capital
Investment: S340/tank. No direct costs. Contact: NC Department of Natural Resources &
Community Development; Pollution Prevention Pays Program Gary Hunt (919) 733-7015.
Option 3- Reuse drag-out waste back into process tank. Contact: NC Department of
Natural Resources & Community Development; Pollution Prevention Pays Program Gary
Hunt (919) 733-7015.
Option 4- Recover process chemicals with fog rinsing parts over plating bath. Contact: City
of Los Angeles Hazardous and Toxic Material Project; Board of Public Works (213) 237-
1209.
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Option 5 - Evaporate and concentrate rinse baths for recycling. Contact: City of Los
Angeles Hazardous and Toxic Material Project; Board of Public Works (213) 237-1209.
Option 6 - Use ion exchange and electrowinning, reverse osmosis, and thermal bonding
when possible. Contact: City of Los Angeles Hazardous and Toxic Material Project; Board
of Public Works (213) 237-1209.
Option 7 - Use sludge slagging techniques to extract and recycle metals. Costs and Savings:
Capital Investment: $80,000 for 80 tons/year and $400,000 for 1,000 tons/year. Operating
Costs: SI8,000 per year for an 80 ton facility. Waste Savings/Reduction: reduces volume of
waste by 94%. Contact: City of Los Angeles Hazardous and Toxic Material Project; Board
of Public Works (213) 237-1209.
Option 8 - Use hydrometallurgical processes to extract metals from sludge. Contact: City
of Los Angeles Hazardous and Toxic Material Project; Board of Public Works (213) 237-
1209.
Option 9- Convert sludge to smelter feed. Contact: City of Los Angeles Hazardous and
Toxic Material Project; Board of Public Works (213) 237-1209.
Option 10 - Remove and recover lead and tin from boards by electrolysis or chemical
precipitation. Contact: Control Data Corporation and MN Office of Waste Management
(612) 649-5750.
Option 11 - Install a closed loop batch treatment system for rinsewater to reduce water use
and waste volume. Costs and Savings: Savings: S58,460/year. Capital Investment:
$210,000. Waste Savings/Reduction: 40,000 gallons/year (40%). Contact: Pioneer Metal
Finishing, Inc., Harry Desoi (609) 694-0400.
Option 12 - Install an electrolytic cell which recovers 92 percent of dissolved copper in drag-
out rinses and atmospheric evaporator to recover 95 percent of chromatic acid drag-out, and
recycle it into chromic acid etch line. Contact: Digital Equipment Corporation and Lancy
International Consulting Firm, William McLay (412) 452-9360.
Option 13- Oxidize cyanide and remove metallic copper to reduce metal concentrations.
Contact: Securus, Inc., DBA Hubbard Enterprises.
V.B.2. Examples of Source Reduction and Recycling Options for Etching
Operations
Technique - Raw Material Substitution
Option 1 - Substitute sodium persulfate etchant (acid etch solution) with hydrogen
peroxide/ sulfuric acid. Contact: ADC Products and MnTAP (612) 625-4949.
Technique - Recycling
Option 1 - Recover copper by electrolytic processes. Contact: ADC Products and MnTAP
(612) 625-4949.
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V.B.3. Examples of Source Reduction and Recycling Options for
Semiconductor Manufacturing
Technique - Process or Equipment Modification
Option 1 - Install a system (e.g., the CALFRAN process) to reduce pressure to vaporize
water at cooler temperatures, recycle water by condensing the vapors in another container,
and concentrate and precipitate solutes. Costs and Savings: Waste Savings/Reduction:
reduce volume and quantity of aqueous waste solutions by recovering pure water. Contact:
CALFRAN International, Inc. Springfield, MA 01101, Val Partyka (413) 525-4957.
Option 2 - Reduce chrome waste generation by :
Installing a rain cover over on outdoor tanks to reduce chrome waste
Treating on-site with caustics and sodium bisulfite to reduce chrome VI liquid to chrome
III sludge
Repairing water leaks in process rinse tank to reduce chrome waste.
Costs and Savings: Capital Investment: $30,000 for the rain cover, pipe repairs, and on-
site treatment system. Waste Savings/Reduction: Savings: $ 15,000/year in disposal costs,
and reduce 95% of chrome wastes from 6,000 gallons to two or three drums generated per
quarter. Contact: Wacker Siltronic Corporation and University of MN (612) 625-4949.
Technique - Raw Material Substitution
Option 1 - Replace chlorinated solvent baths with a non-hazardous product to reduce, and
later, eliminate use of chlorinated solvents. Costs and Savings: Waste Savings/Reduction:
reduce chlorinated solvent use by 93%, and then completely eliminate the use of the
chemical. Contact: Wacker Siltronic Corporation and University of MN (612) 625-4949.
Technique - Recycling
Option 1 - Convert an open-top still into a closed loop system to recycle Freon 113. Costs
and Savings: Costs: $20,000. Waste Savings/Reduction: $57,000/year in disposal and
feedstock costs, and reduce waste volume by 85%. Contact: Wacker Siltronic Corporation
and University of MN (612) 625-4949.
Option 2 - Use Athens system to reprocess sulfuric acid generated during wafer fabrication
operations. The acid is heated to boil off water and other impurities, purified through
distillation, and pumped back into wet stations to continue wafer processing. Costs and
savings: Annual savings/Reductions: $2.9 million from not purchasing sulfuric acid and
28% reduction in sulfuric acid generated in 1993. Contact: Intel or Alameda Instruments,
Inc. and Athens Corporation (manufacturers of this type of equipment).
V.B.4. Examples of Source Reduction and Recycling Options for Printed Wiring
Board Manufacturing
V.B.4.a. General Operations
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Technique - Process or Equipment Modification
Option 1 - Modify sludge pretreatment processes by:
Adding flow control valves
Installing metal recovery equipment
Adding of deionization system
Costs and Savings: Costs: lower chemical treatment costs. Waste Savings/Reduction:
$90,000 in disposal costs. Contact: Unisys Corporation and MnTAP (612) 625-4949.
Option 2 - Redesign board during board assembly. Contact: Capsule Environmental
Engineering Inc. and MN Office of Waste Management (612) 649-5750.
Option 3 - Install a system (e.g., CALFRAN process) to reduce pressure to vaporize water at
cooler temperatures, recycle water by condensing the vapors in another container,
concentrate and precipitate solutes. Costs and Savings: Waste Savings/Reduction: reduce
volume and quantity of aqueous waste solutions by recovering pure water. Contact:
CALFRAN International, Inc. Springfield, MA 01101, Val Partyka (413) 525-4957.
Option 4 - Alternatives to wet chemical processes include:
Mechanical cleaning as an alternative to chemical methods;
Process efficiency improvements for applying photopolymers, printing, and developing;
Alternative processes for connecting the PWB layers together; and
Alternatives to lead-based soldering involving the use of lasers, reactive gases, or
ultrasonics.
Contact: EPA CSI.
Technique - Raw Material Substitution
Option 1 - Substitute semiaqueous or aqueous photoresist for TCA and methylene chloride
during board manufacturing. Contact: Capsule Environmental Engineering Inc. and MN
Office of Waste Management (612) 649-5750.
Option 2 - Substitute no-clean fluxes for CFC 113 and TCA during board assembly.
Contact: Capsule Environmental Engineering Inc. and MN Office of Waste Management
(612) 649-5750.
Option 3 - Substitute aqueous clean fluxes for CFC 113 and TCA during board assembly.
Contact: Capsule Environmental Engineering Inc. and MN Office of Waste Management
(612) 649-5750.
Option 4 - Substitute semi-aqueous cleaning materials for CFC 113 and TCA during board
assembly. Contact: Capsule Environmental Engineering Inc. and MN Office of Waste
Management (612) 649-5750.
Option 5 - Substitute other solvents for CFC 113 and TCA during board assembly. Contact:
Capsule Environmental Engineering Inc. and MN Office of Waste Management (612) 649-
5750.
Technique - Waste Segregation/Separation/Preparation
Option 1 - Segregate wastewater sludge to prepare for metal recovery. Contact: Unisys
Corporation and MnTAP (612) 625-4949.
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Technique - Recycling
Option 1 - Remove and recover lead and tin from boards by electrolysis-chemical
precipitation. Contact: Control Data Corporation and MN Office of Waste Management
(612) 649-5750.
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V.BAb. Cleaning Operations
Technique - Process or Equipment Modification
Option 1 - Install a system (e.g., Low Solids Fluxer {LSF}) which applies flux to printed
wiring boards, leaves little residue, and eliminates the need for cleaning with CFCs. Costs
and Savings: Waste Savings/Reduction: reduce CFC emissions over 50%. Contact: AT&T
Bell Laboratories, Princeton, NJ.
Technique - Raw Material Substitution
Option 1 - Substitute for CFC 113 used in defluxing with:
Fully aqueous system using water soluble fluxes
Aqueous system using saponifiers to remove rosin based fluxes
Semi-aqueous system using terpenes as a solvent
Hydrogenated CFCs with chlorinated solvents
Contact: Medtronic Inc. and MN Technical Assistance Program (MnTAP) (612) 627-4848
Maria Scheller.
Option 2 - Substitute CFC 113 used in hand cleaning boards with:
Blend of HCFC and methanol dispensed from a trigger-grip device that limits the
amount of solvent lost to the atmosphere
Contact: Medtronic Inc. and MN Technical Assistance Program (MnTAP) (612) 627-4848
Maria Scheller.
V.B.4.C. Electroplating Operations
Technique - Raw Material Substitution
Option 1 - During tin-lead electroplating process, substitute fluoboric acid with:
Organic sulfonic acid (OSA) plating
Acid tin sulfate plating which eliminates lead use
Hot air leveling
Conductive, solderable polymer solutions
Contact: Capsule Environmental Engineering Inc. and MN Office of Waste Management
(612) 649-5750.
V.B.5. Examples of Source Reduction and Recycling Options for Cathode
Ray Tube Manufacturing
Technique - Process or Equipment Modification
Option 1- Reduce building of contamination in bath solutions by increasing process
efficiency (e.g., implement ion exchange technology). Contact: EPA CSI.
Technique - Raw Material Substitution
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Option 1 - Replace lacquer in panel preparation with a wax-like material similar to floor
wax. It provides the necessary coating without a high VOC content. One potential
drawback, however, is the use of ammonia. Contact: EPA CSI.
Option 2 - Replace Freon as a cleaning agent for removing particulate contaminants from
panel mask frames with air blow cleaning and an aqueous wash (nearly all CRT
manufacturers have implemented this change). Contact: EPA CSI.
Option 3 - Identify less hazardous cleaning chemicals, such as isopropyl alcohol, as
alternatives to acetone or chlorinated solvents in maintenance and cleanup processes.
Contact: EPA CSI.
Option 4 - Find substitutes for chromium-based photoresists. Contact: EPA CSI.
Option 5 - Identify alternatives to the lead-based frit used in sealing the funnel with the
panel mask. Contact: EPA CSI.
Technique - Recycling
Option 1 - Regenerate acids for glass cleaning and frit removal in waste glass recovery
operations using existing technologies and equipment. Contact: EPA CSI.
Option 2 - Reclaim and reuse photoresists from one of the panel preparation processes.
Contact: EPA CSI.
Option 3 - Recover soluble lead generated during the waste glass recovery operation by ion
exchange resins. Reuse in lead smelting operations. Contact: EPA CSI.
Option 4 - Improve phosphor solution recovery and recycling efficiencies to further reduce
discharge of metals to the environment. Contact: EPA CSI.
Option 5- Reduce or recover the following:
Chrome wastes
Cleaning materials (hydrofluoric acids)
EP effluent
Furnaces slag
Gullet dust
Fugitive dust
Refractory brick wastes
Alcohols
Contact: EPA CSI.
V.C. Pollution Prevention Case Studies
The electronics/computer industry is actively involved in pollution
prevention activities, especially for products such as semiconductors
and printed wiring boards. Pollution prevention techniques are
available and have been implemented successfully for processes such
as cleaning, etching, electroplating, and wastewater treatment.
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California's Assessment of the Semiconductor Industry Source Reduction
Planning Efforts provides additional information and case studies on
pollution prevention techniques. Eastside Plating, Unisys
Corporation, and Wacker Siltronic Corporation are examples of
companies with successful pollution prevention programs. The
pollution prevention activities employed in these three case studies
provided each company with significant savings.
Eastside Plating, Portland, Oregon's oldest and largest electroplating
facility, demonstrated that complying with environmental laws and
implementing pollution prevention activities is cost effective. Eastside
used three major pollution prevention techniques: water conservation,
material substitution, and machinery automation and upgrade.
The first activity addressed the challenge of diminishing the use of
water. Ninety percent of water required for electroplating is used
during the rinsing process (to clean the wafer, end chemical reactions,
and prevent contaminants from being released into the next bath).
Eastside modified the rinsing process by installing two systems that
conserve water: counter flow and cascade rinsing systems. Counter
flow rinsing recycles and reuses water throughout a multiple tank
system, reducing significantly the volume of water required. Fresh
water is only introduced in the last tank of the system. Cascade
rinsing also reduces the volume of water required. This system uses
one tank with a center divider which allows the water to spill into the
other side. During cascade rinsing, the tank is filled and drained
slowly and continuously in order to reduce water consumption.
Overflow from one tank can be used as the water supply for another
compatible rinsing system.
Eastside also reduced chromium and cyanide wastes through material
substitution. The reducing agent for chromic acid wastes was changed
from ferrous sulfate to bisulfite and sulfuric acid, which reduced the
volume of sludge produced. Cyanide wastes are reduced more
efficiently with gaseous instead of liquid chlorine.
Finally, three major waste treatment components were upgraded or
automated: the cyanide oxidation tank, chromium reduction tank, and
the acid/alkali neutralization tank. The goal of automating and
upgrading this equipment was to increase efficiency, separate tank
flow, and eliminate contamination of acid/alkali neutralization tank.
Automated metering equipment was installed and reduced the
expensive caustic chemicals required to treat acid wastes by 50
percent. The cyanide and chromic acid oxidation tanks were
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redesigned as gravity flow systems to equalize flow rate and to
eliminate the risks associated with plumbing failure. To prevent cross
contamination of the tanks, the plumbing was segregated.
Other important steps taken by Eastside Plating to enhance pollution
prevention included collaborating with suppliers on modifications to
reaction and neutralization tanks, working with regulators to solve
problems, and providing employee education.
The new rinsing systems, materials substitution, and upgrade/
automation of equipment cost Eastside $75,000. Overall, Eastside
implemented changes to the operation which has saved the company
more than $300,000 annually. In addition, pollution prevention and
waste minimization has resulted in a cleaner facility, increased
productivity, and a better product.
Unisys is a manufacturer of both large and small computers. In 1986,
Unisys implemented pollution prevention/waste minimization
techniques associated with the automated copper plating process in its
printed circuit board manufacturing plant in Roseville, Minnesota.
Unisys worked with Minnesota Technical Assistance Program
(MnTAP) to reduce the two to three drums of wastewater treatment
sludge produced each day.
MnTAP recommended several changes in the pretreatment process
such as: segregation of the wastestreams; addition of flow control
valves; installation of metal recovery equipment; and addition of a
deionization system. Wastestream segregation involved changing the
plumbing to separate the wastestreams containing metal contaminants.
Another modification reduced overall water usage through the
installation of flow control valves. Metal recovery techniques, such as
ion exchange and electrolytic metal recovery, reclaim copper from
metal-bearing wastestreams. The deionization systems allow the
pretreatment process to operate more efficiently. Ion exchange and
electrolytic recovery is enhanced by deionization by removing hard
water ions in the process and rinse tanks. The modifications ensure
environmental compliance, lower treatment chemical costs, and reduce
sludge disposal costs by an estimated $90,000 per year. In addition,
the pollution prevention and waste minimization changes have
allowed Unisys to expand its plating line.
Wacker Siltronic Corporation, a semiconductor manufacturer,
successfully implemented pollution prevention and waste
minimization techniques similar to those employed by Unisys and
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Eastside. In order to maintain cleanliness in silicon wafer production,
Wacker made extensive use of chloride solvent baths. Once the
disposal of chlorinated solvent wastes at a Oregon hazardous waste
facility was prohibited by Federal regulations, Wacker sought to
recycle the solvents. However, the potential liability associated with
transporting thousands of gallons of solvents to a recycling facility led
Wacker to seek other alternatives. A six month pilot project was first
implemented to decrease chlorinated solvent use which resulted in the
elimination of 93 percent of Wacker's chlorinated solvent waste.
Ultimately, Wacker eliminated completely the use of chlorinated
solvents through replacement with non-hazardous cleaning products.
Wacker used to generate 2000 gallons of chrome VI waste each month,
which needed to be sent off-site for disposal. Reduction of chrome
waste to two to three drums each quarter involved three techniques:
installation of a rain cover over the outdoor tanks; on-site treatment of
chrome VI waste using caustics and sodium bisulfite; and repairing
water leaks in the process rinse tank. The rain cover cost $7,000, but
reduced the volume of waste shipments by 25 percent. The new
treatment of the chrome VI liquid reduced it to a less hazardous
chrome III sludge which can be dried and sent off-site for disposal.
Repair of small leaks in the rinse tanks resulted in a 50 percent
reduction of wastes. The cover, pipe repairs, and on-site treatment
system cost $30,000 and led to a 95 percent reduction of chrome waste
as well as annual savings of $15,000. The initial costs were recovered
within three years.
A final pollution prevention waste minimization technique involved
recycling Freon 113. An open-top still was converted into a closed-
loop system at a cost of $20,000. The conversion reduced the volume
of Freon waste by 85 percent and saves the company $57,000 each year.
Overall, Wacker states that pollution prevention and waste
minimization has resulted in annual savings of $300,000.
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VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal statutes and regulations that may
apply to this sector. The purpose of this section is to highlight, and
briefly describe the applicable Federal requirements, and to provide
citations for more detailed information. The three following sections
are included.
Section IV. A contains a general overview of major statutes
Section IV.B contains a list of regulations specific to this
industry
Section IV.C contains a list of pending and proposed regulations
The descriptions within Section IV are intended solely for general
information. Depending upon the nature or scope of the activities at a
particular facility, these summaries may or may not necessarily
describe all applicable environmental requirements. Moreover, they
do not constitute formal interpretations or clarifications of the statutes
and regulations. For further information, readers should consult the
Code of Federal Regulations (CFR) and other State or local regulatory
agencies. EPA Hotline contacts are also provided for each major
statute.
VI.A. General Description of Major Statutes
Resource Conservation And Recovery Act
The Resource Conservation And Recovery Act (RCRA) of 1976 which
amended the Solid Waste Disposal Act, addresses solid (Subtitle D)
and hazardous (Subtitle C) waste management activities. The
Hazardous and Solid Waste Amendments (HSWA) of 1984
strengthened RCRA's waste management provisions and added
Subtitle I, which governs underground storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR
Parts 260-299) establish a "cradle-to-grave" system governing
hazardous waste from the point of generation to disposal. RCRA
hazardous wastes include the specific materials listed in the
regulations (commercial chemical products, designated with the code
"P" or "U"; hazardous wastes from specific industries/sources,
designated with the code "K"; or hazardous wastes from non-specific
sources, designated with the code "F") or materials which exhibit a
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hazardous waste characteristic (ignitibility, corrosivity, reactivity, or
toxicity and designated with the code "D").
Regulated entities that generate hazardous waste are subject to waste
accumulation, manifesting, and recordkeeping standards. Facilities
that treat, store, or dispose of hazardous waste must obtain a permit,
either from EPA or from a State agency which EPA has authorized to
implement the permitting program. Subtitle C permits contain general
facility standards such as contingency plans, emergency procedures,
recordkeeping and reporting requirements, financial assurance
mechanisms, and unit-specific standards. RCRA also contains
provisions (40 CFR Part 264 Subpart S and §264.10) for conducting
corrective actions which govern the cleanup of releases of hazardous
waste or constituents from solid waste management units at RCRA-
regulated facilities.
Although RCRA is a Federal statute, many States implement the RCRA
program. Currently, EPA has delegated its authority to implement
various provisions of RCRA to 46 of the 50 States.
Most RCRA requirements are not industry specific but apply to any
company that transports, treats, stores, or disposes of hazardous waste.
Here are some important RCRA regulatory requirements:
Identification of Solid and Hazardous Wastes (40 CFR Part
261) lays out the procedure every generator should follow to
determine whether the material created is considered a
hazardous waste, solid waste, or is exempted from regulation.
Standards for Generators of Hazardous Waste (40 CFR Part
262) establishes the responsibilities of hazardous waste
generators including obtaining an ID number, preparing a
manifest, ensuring proper packaging and labeling, meeting
standards for waste accumulation units, and recordkeeping and
reporting requirements. Generators can accumulate hazardous
waste for up to 90 days (or 180 days depending on the amount
of waste generated) without obtaining a permit.
Land Disposal Restrictions (LDRs) are regulations prohibiting
the disposal of hazardous waste on land without prior
treatment. Under the LDRs (40 CFR 268), materials must meet
land disposal restriction (LDR) treatment standards prior to
placement in a RCRA land disposal unit (landfill, land
treatment unit, waste pile, or surface impoundment). Wastes
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subject to the LDRs include solvents, electroplating wastes,
heavy metals, and acids. Generators of waste subject to the
LDRs must provide notification of such to the designated TSD
facility to ensure proper treatment prior to disposal.
Used Oil Management Standards (40 CFR 279) impose
management requirements affecting the storage, transportation,
burning, processing, and re-refining of the used oil. For parties
that merely generate used oil, regulations establish storage
standards. For a party considered a used oil marketer (one who
generates and sells off-specification used oil directly to a used
oil burner), additional tracking and paperwork requirements
must be satisfied.
Tanks and Containers used to store hazardous waste with a
high volatile organic concentration must meet emission
standards under RCRA. Regulations (40 CFR Part 264-265,
Subpart CC) require generators to test the waste to determine
the concentration of the waste, to satisfy tank and container
emissions standards, and to inspect and monitor regulated
units. These regulations apply to all facilities who store such
waste, including generators operating under the 90-day
accumulation rule.
Underground Storage Tanks (USTs) containing petroleum and
hazardous substance are regulated under Subtitle I of RCRA.
Subtitle I regulations (40 CFR Part 280) contain tank design and
release detection requirements, as well as financial
responsibility and corrective action standards for USTs. The
UST program also establishes increasingly stringent standards,
including upgrade requirements for existing tanks, that must be
met by 1998.
Boilers and Industrial Furnaces (BIFs) that use or burn fuel
containing hazardous waste must comply with strict design and
operating standards. BIF regulations (40 CFR Part 266, Subpart
H) address unit design, provide performance standards, require
emissions monitoring, and restrict the type of waste that may be
burned.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to
questions and distributes guidance regarding all RCRA regulations. The
RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., EST,
excluding Federal holidays.
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Comprehensive Environmental Response, Compensation, And Liability Act
The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), a 1980 law commonly known as Superfund,
authorizes EPA to respond to releases, or threatened releases, of
hazardous substances that may endanger public health, welfare, or the
environment. CERCLA also enables EPA to force parties responsible
for environmental contamination to clean it up or to reimburse the
Superfund for response costs incurred by EPA. The Superfund
Amendments and Reauthorization Act (SARA) of 1986 revised various
sections of CERCLA, extended the taxing authority for the Superfund,
and created a free-standing law, SARA Title III, also known as the
Emergency Planning and Community Right-to-Know Act (EPCRA).
The CERCLA hazardous substance release reporting regulations (40
CFR Part 302) direct the person in charge of a facility to report to the
National Response Center (NRC) any environmental release of a
hazardous substance which exceeds a reportable quantity. Reportable
quantities are defined and listed in 40 CFR 302.4. A release report may
trigger a response by EPA, or by one or more Federal or State
emergency response authorities.
EPA implements hazardous substance responses according to
procedures outlined in the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) (40 CFR Part 300). The NCP
includes provisions for permanent cleanups, known as remedial
actions, and other cleanups referred to as "removals." EPA generally
takes remedial actions only at sites on the National Priorities List
(NPL), which currently includes approximately 1300 sites. Both EPA
and States can act at other sites; however, EPA provides responsible
parties the opportunity to conduct removal and remedial actions and
encourages community involvement throughout the Superfund
response process.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, answers questions
and references guidance pertaining to the Superfund program. The CERCLA
Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., EST, excluding
Federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created the Emergency Planning and Community Right-to-Know Act
(EPCRA, also known as SARA Title III), a statute designed to improve
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community access to information about chemical hazards and to
facilitate the development of chemical emergency response plans by
State and local governments. EPCRA required the establishment of
State emergency response commissions (SERCs), responsible for
coordinating certain emergency response activities and for appointing
local emergency planning committees (LEPCs).
EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish
four types of reporting obligations for facilities which store or manage
specified chemicals:
EPCRA §302 requires facilities to notify the SERC and LEPC of
the presence of any "extremely hazardous substance" (the list of
such substances is in 40 CFR Part 355, Appendices A and B) if it
has such substance in excess of the substance's threshold
planning quantity, and directs the facility to appoint an
emergency response coordinator.
EPCRA §304 requires the facility to notify the SERC and the
LEPC in the event of a release exceeding the reportable quantity
of a CERCLA hazardous substance or an EPCRA extremely
hazardous substance.
EPCRA §§311 and 312 require a facility at which a hazardous
chemical, as defined by the Occupational Safety and Health Act,
is present in an amount exceeding a specified threshold to
submit to the SERC, LEPC, and local fire department material
safety data sheets (MSDSs) or lists of MSDSs and hazardous
chemical inventory forms (also known as Tier I and II forms).
This information helps the local government respond in the
event of a spill or release of the chemical.
EPCRA §313 requires manufacturing facilities included in SIC
codes 20 through 39, which have ten or more employees, and
which manufacture, process, or use specified chemicals in
amounts greater than threshold quantities, to submit an annual
toxic chemical release report. This report, commonly known as
the Form R, covers releases and transfers of toxic chemicals to
various facilities and environmental media, and allows EPA to
compile the national Toxic Release Inventory (TRI) database.
All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
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EPA's EPCRA Hotline, at (800) 535-0202, answers questions and distributes
guidance regarding the emergency planning and community right-to-know
regulations. The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30
p.m., EST, excluding Federal holidays.
Clean Water Act
The primary objective of the Federal Water Pollution Control Act,
commonly referred to as the Clean Water Act (CWA), is to restore and
maintain the chemical, physical, and biological integrity of the nation's
surface waters. Pollutants regulated under the CWA include "priority"
pollutants, including various toxic pollutants; "conventional"
pollutants, such as biochemical oxygen demand (BOD), total
suspended solids (TSS), fecal coliform, oil and grease, and pH; and
"non-conventional" pollutants, including any pollutant not identified
as either conventional or priority.
The CWA regulates both direct and indirect discharges. The National
Pollutant Discharge Elimination System (NPDES) program (CWA
§402) controls direct discharges into navigable waters. Direct
discharges or "point source" discharges are from sources such as pipes
and sewers. NPDES permits, issued by either EPA or an authorized
State (EPA has presently authorized forty States to administer the
NPDES program), contain industry-specific, technology-based and/or
water quality-based limits, and establish pollutant monitoring and
reporting requirements. A facility that intends to discharge into the
nation's waters must obtain a permit prior to initiating its discharge. A
permit applicant must provide quantitative analytical data identifying
the types of pollutants present in the facility's effluent. The permit will
then set forth the conditions and effluent limitations under which a
facility may make a discharge.
A NPDES permit may also include discharge limits based on Federal
or State water quality criteria or standards, that were designed to
protect designated uses of surface waters, such as supporting aquatic
life or recreation. These standards, unlike the technological standards,
generally do not take into account technological feasibility or costs.
Water quality criteria and standards vary from State to State, and site
to site, depending on the use classification of the receiving body of
water. Most States follow EPA guidelines which propose aquatic life
and human health criteria for many of the 126 priority pollutants.
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Storm Water Discharges
In 1987 the CWA was amended to require EPA to establish a program
to address storm water discharges. In response, EPA promulgated the
NPDES storm water permit application regulations. Storm water
discharge associated with industrial activity means the discharge from
any conveyance which is used for collecting and conveying storm
water and which is directly related to manufacturing, processing or
raw materials storage areas at an industrial plant (40 CFR
122.26(b)(14)). These regulations require that facilities with the
following storm water discharges apply for a NPDES permit: (1) a
discharge associated with industrial activity; (2) a discharge from a
large or medium municipal storm sewer system; or (3) a discharge
which EPA or the State determines to contribute to a violation of a
water quality standard or is a significant contributor of pollutants to
waters of the United States.
The term "storm water discharge associated with industrial activity"
means a storm water discharge from one of 11 categories of industrial
activity defined at 40 CFR 122.26. Six of the categories are defined by
SIC codes while the other five are identified through narrative
descriptions of the regulated industrial activity. If the primary SIC
code of the facility is one of those identified in the regulations, the
facility is subject to the storm water permit application requirements.
If any activity at a facility is covered by one of the five narrative
categories, storm water discharges from those areas where the
activities occur are subject to storm water discharge permit application
requirements.
Those facilities/activities that are subject to storm water discharge
permit application requirements are identified below. To determine
whether a particular facility falls within one of these categories, the
regulation should be consulted.
Category i: Facilities subject to storm water effluent guidelines, new
source performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products
(except wood kitchen cabinets); SIC 26-paper and allied products
(except paperboard containers and products); SIC 28-chemicals and
allied products (except drugs and paints); SIC 29-petroleum refining;
and SIC 311-leather tanning and finishing.
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Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal
mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
mining.
Category iv: Hazardous waste treatment, storage, or disposal
facilities.
Category v: Landfills, land application sites, and open dumps that
receive or have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle parts;
and SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation;
SIC 41-local passenger transportation; SIC 42-trucking and
warehousing (except public warehousing and storage); SIC 43-U.S.
Postal Service; SIC 44-water transportation; SIC 45-transportation by
air; and SIC 5171-petroleum bulk storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in the
disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products;
SIC 21-tobacco products; SIC 22-textile mill products; SIC 23-apparel
related products; SIC 2434-wood kitchen cabinets manufacturing; SIC
25-furniture and fixtures; SIC 265-paperboard containers and boxes;
SIC 267-converted paper and paperboard products; SIC 27-printing,
publishing, and allied industries; SIC 283-drugs; SIC 285-paints,
varnishes, lacquer, enamels, and allied products; SIC 30-rubber and
plastics; SIC 31-leather and leather products (except leather and
tanning and finishing); SIC 323-glass products; SIC 34-fabricated metal
products (except fabricated structural metal); SIC 35-industrial and
commercial machinery and computer equipment; SIC 36-electronic
and other electrical equipment and components; SIC 37-transportation
equipment (except ship and boat building and repairing); SIC 38-
measuring, analyzing, and controlling instruments; SIC 39-
miscellaneous manufacturing industries; and SIC 4221-4225-public
warehousing and storage.
Pretreatment Program
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Another type of discharge that is regulated by the CWA is one that
goes to a publicly-owned treatment works (POTWs). The national
pretreatment program (CWA §307 (b)) controls the indirect discharge
of pollutants to POTWs by "industrial users." Facilities regulated
under §307 (b) must meet certain pretreatment standards. The goal of
the pretreatment program is to protect municipal wastewater
treatment plants from damage that may occur when hazardous, toxic,
or other wastes are discharged into a sewer system and to protect the
quality of sludge generated by these plants. Discharges to a POTW are
regulated primarily by the POTW itself, rather than the State or EPA.
EPA has developed technology-based standards for industrial users of
POTWs. Different standards apply to existing and new sources within
each category. "Categorical" pretreatment standards applicable to an
industry on a nationwide basis are developed by EPA. In addition,
another kind of pretreatment standard, "local limits," are developed by
the POTW in order to assist the POTW in achieving the effluent
limitations in its NPDES permit.
Regardless of whether a State is authorized to implement either the
NPDES or the pretreatment program, if it develops its own program, it
may enforce requirements more stringent than Federal standards.
EPA's Office of Water, at (202) 260-5700, will direct callers with questions
about the CWA to the appropriate EPA office. EPA also maintains a
bibliographic database of Office of Water publications which can be accessed
through the Ground Water and Drinking Water resource center, at (202) 260-
7786.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) mandates that EPA establish
regulations to protect human health from contaminants in drinking
water. The law authorizes EPA to develop national drinking water
standards and to create a joint Federal-State system to ensure
compliance with these standards. The SDWA also directs EPA to
protect underground sources of drinking water through the control of
underground injection of liquid wastes.
EPA has developed primary and secondary drinking water standards
under its SDWA authority. EPA and authorized States enforce the
primary drinking water standards, which are, contaminant-specific
concentration limits that apply to certain public drinking water
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supplies. Primary drinking water standards consist of maximum
contaminant level goals (MCLGs), which are non-enforceable health-
based goals, and maximum contaminant levels (MCLs), which are
enforceable limits set as close to MCLGs as possible, considering cost
and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR
Parts 144-148) is a permit program which protects underground
sources of drinking water by regulating five classes of injection wells.
UIC permits include design, operating, inspection, and monitoring
requirements. Wells used to inject hazardous wastes must also comply
with RCRA corrective action standards in order to be granted a RCRA
permit, and must meet applicable RCRA land disposal restrictions
standards. The UIC permit program is primarily State-enforced, since
EPA has authorized all but a few States to administer the program.
The SDWA also provides for a Federally-implemented Sole Source
Aquifer program, which prohibits Federal funds from being expended
on projects that may contaminate the sole or principal source of
drinking water for a given area, and for a State-implemented Wellhead
Protection program, designed to protect drinking water wells and
drinking water recharge areas.
EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
and distributes guidance pertaining to SDWA standards. The Hotline
operates from 9:00 a.m. through 5:30 p.m., EST, excluding Federal holidays.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) granted EPA authority to
create a regulatory framework to collect data on chemicals in order to
evaluate, assess, mitigate, and control risks which may be posed by
their manufacture, processing, and use. TSCA provides a variety of
control methods to prevent chemicals from posing unreasonable risk.
TSCA standards may apply at any point during a chemical's life cycle.
Under TSCA §5, EPA has established an inventory of chemical
substances. If a chemical is not already on the inventory, and has not
been excluded by TSCA, a premanufacture notice (PMN) must be
submitted to EPA prior to manufacture or import. The PMN must
identify the chemical and provide available information on health and
environmental effects. If available data are not sufficient to evaluate
the chemical's effects, EPA can impose restrictions pending the
development of information on its health and environmental effects.
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EPA can also restrict significant new uses of chemicals based upon
factors such as the projected volume and use of the chemical.
Under TSCA §6, EPA can ban the manufacture or distribution in
commerce, limit the use, require labeling, or place other restrictions on
chemicals that pose unreasonable risks. Among the chemicals EPA
regulates under §6 authority are asbestos, chlorofluorocarbons (CFCs),
and polychlorinated biphenyls (PCBs).
EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
questions and distributes guidance pertaining to Toxic Substances Control
Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST,
excluding Federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments, including the Clean Air
Act Amendments (CAAA) of 1990, are designed to "protect and
enhance the nation's air resources so as to promote the public health
and welfare and the productive capacity of the population." The CAA
consists of six sections, known as Titles, which direct EPA to establish
national standards for ambient air quality and for EPA and the States
to implement, maintain, and enforce these standards through a variety
of mechanisms. Under the CAAA, many facilities will be required to
obtain permits for the first time. State and local governments oversee,
manage, and enforce many of the requirements of the CAAA. CAA
regulations appear at 40 CFR Parts 50-99.
Pursuant to Title I of the CAA, EPA has established national ambient
air quality standards (NAAQS) to limit levels of "criteria pollutants,"
including carbon monoxide, lead, nitrogen dioxide, particulate matter,
ozone, and sulfur dioxide. Geographic areas that meet NAAQS for a
given pollutant are classified as attainment areas; those that do not
meet NAAQS are classified as non-attainment areas. Under §110 of
the CAA, each State must develop a State Implementation Plan (SIP) to
identify sources of air pollution and to determine what reductions are
required to meet Federal air quality standards.
Title I also authorizes EPA to establish New Source Performance
Standards (NSPS), which are nationally uniform emission standards
for new stationary sources falling within particular industrial
categories. NSPS are based on the pollution control technology
available to that category of industrial source but allow the affected
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industries the flexibility to devise a cost-effective means of reducing
emissions.
Under Title I, EPA establishes and enforces National Emission
Standards for Hazardous Air Pollutants (NESHAP), nationally
uniform standards oriented towards controlling particular hazardous
air pollutants (HAPs). Title III of the CAAA further directed EPA to
develop a list of sources that emit any of 189 HAPs, and to develop
regulations for these categories of sources. To date, EPA has listed 174
categories and developed a schedule for the establishment of emission
standards. The emission standards will be developed for both new
and existing sources based on "maximum achievable control
technology" (MACT). The MACT is defined as the control technology
achieving the maximum degree of reduction in the emission of the
HAPs.
Title II of the CAA pertains to mobile sources, such as cars, trucks,
buses, and planes. Reformulated gasoline, automobile pollution
control devices, and vapor recovery nozzles on gas pumps are a few of
the mechanisms EPA uses to regulate mobile air emission sources.
Title IV establishes a sulfur dioxide emissions program designed to
reduce the formation of acid rain. Reduction of sulfur dioxide releases
will be obtained by granting to certain sources limited emissions
allowances, which, beginning in 1995, will be set below previous levels
of sulfur dioxide releases.
Title V of the CAAA of 1990 created a permit program for all "major
sources" (and certain other sources) regulated under the CAA. One
purpose of the operating permit is to include in a single document all
air emissions requirements that apply to a given facility. States are
developing the permit programs in accordance with guidance and
regulations from EPA. Once a State program is approved by EPA,
permits will be issued and monitored by that State.
Title VI is intended to protect stratospheric ozone by phasing out the
manufacture of ozone-depleting chemicals and restrict their use and
distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs), will be phased out entirely by the year
2000, while certain hydrochlorofluorocarbons (HCFCs) will be phased
out by 2030.
EPA's Control Technology Center, at (919) 541-0800, provides general
assistance and information on CAA standards. The Stratospheric Ozone
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Information Hotline, at (800) 296-1996, provides general information about
regulations promulgated under Title VI of the CAA, and EPA's EPCRA
Hotline, at (800) 535-0202, answers questions about accidental release
prevention under CAA §112(r). In addition, the Technology Transfer
Network Bulletin Board System (modem access (919) 541-5742)) includes
recent CAA rules, EPA guidance documents, and updates of EPA activities.
VLB. Industry Specific Requirements
Clean Air Act (CAA)
Under the CAA, the National Ambient Air Quality Standards
(NAAQS) have been established for six pollutants. The only one that
significantly impacts the electronics/computer industry is the standard
for ozone. While the electronics/computer industry is not a major
source of ozone, it is a major source of volatile organic compounds
(VOC). A source defined as "major" in ozone nonattainment areas
must install Reasonable Available Control Technology (RACT) as
prescribed in the applicable State Implementation Plan (SIP). A major
source is both defined by the size of the source's emissions and the
category of the nonattainment area. A determination of the necessary
RACT requirements is made on the basis of a case by case review of
each facility. In an attempt to issue uniform guidelines, EPA has
begun to issue Control Technology Guidance (CTG) for each industrial
category. The following CTGs may apply to the semiconductor
industry:
Miscellaneous Metal Parts and Products
Plastic Parts
Alternative Control Technology (ATG) for Solvent Cleaning.
Clean Water Act (CWA)
The National Pollution Discharge Elimination System (NPDES) permit
program regulates the discharge of pollutants to the waters of the
United States. A permit is required if a source discharges directly to
surface waters. Facilities must provide the results of biological toxicity
tests and any information on its "effluent characteristics." The
electronics/computer industry must test for all 126 priority pollutants
listed in 40 CFR 122, Appendix D. Facilities must provide quantifiable
data only for discharges of priority pollutants which the applicant
knows or has reason to believe will be greater than trace amounts.
Priority pollutants likely to be discharged by facilities in the
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electronics/computer industry include copper, lead, lead compounds,
silver, chromium, and trichloroethylene.
Quantitative testing is required for non-conventional pollutants if they
are expected to be present in discharges. Examples of hazardous
substances and non-conventional pollutants likely to be discharged by
the electronics/computer industry include butyl acetate, xylene,
formaldehyde, tin-total, nitrate/nitrites, titanium-total, and chlorine-
total residual.
The electronics/computer industry must satisfy the following
technology-based effluent limitation guidelines:
40 CFR Part 469 applies to discharges from all processes
associated with semiconductor manufacturing except
sputtering, vapor deposition, and electroplating.
40 CFR Part 433 applies to semiconductor manufacturing plants
that perform any of six metal finishing operations -
electroplating, electroless plating, anodizing, coating, chemical
etching, milling, and printed wired board manufacturing.
40 CFR Part 433 applies to discharges associated with the
manufacture of printed wiring boards (PWB), except indirect
discharging job shops and independent PWB manufacturers
who discharge to POTWs, which are covered by Part 413.
40 CFR Part 469, Subpart C applies to discharges from display
manufacturing.
40 CFR Part 469, Subpart D applies to discharges from the
manufacturing of luminescent materials which are used in
coatings in fluorescent lamps and cathode ray tubes.
Luminescent materials include, but are not limited to, calcium
halophosphate, zinc sulfide, and zinc-cadmium.
40 CFR Part 413 applies to electroplating of common metals,
chemical etching and milling, and electroless plating. Subpart
A refers to discharges of pollutants from processes that involve
ferrous or nonferrous material electroplated with (or any
combination of) copper, nickel, chromium, zinc, tin, lead,
cadmium, iron, or aluminum. Subpart F applies to process
wastewaters from chemical milling or etching of ferrous or
nonferrous materials. Subpart G applies to process wastewaters
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from the electroless plating of a metallic layer on a metallic or
nonmetallic substrate.
Facilities that discharge to POTWs must comply with categorical and
general pretreatment requirements:
40 CFR Part 413, Subpart B applies to electroplating of precious
metals or to discharges from a process in which a ferrous or
nonferrous material is plated with, or a combination of, gold,
silver, iridium, palladium, platinum, rhodium, or ruthenium.
Resource Conservation and Recovery Act (RCRA)
Many wastes generated by the electronics/computer industry are
considered RCRA toxicity characteristic (TC) hazardous wastes due to
constituents such as silver, trichloroethylene, and lead. The greatest
quantities of RCRA listed waste and characteristic hazardous waste
present in the electronics/computer industry are identified in Exhibit
30. For more information on RCRA hazardous waste, refer to 40 CFR
Part 261.
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Electronics and Computer Industry
Exhibit 34 Hazardous Wastes Relevant to the Electronics/Computer Industry
EPA Hazardous
Waste No.
Hazardous Waste
D006 (cadmium)
D007 (chromium)
D008 (lead)
DO 11 (silver)
Wastes which are hazardous due to the characteristic of toxicity for each of the
constituents.
F001
Halogenated solvents used in degreasing: tetrachloroethylene, methylene chloride,
1,1,1-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent
solvent mixtures/blends used in degreasing containing, before use, a total of 10
percent or more (by volume) of one or more of the above halogenated solvents or
those solvents listed in F002, F004, and F005; and still bottoms from the recovery of
these spent solvents and spent solvent mixtures.
F002
Spent halogenated solvents; tetrachloroethylene, methylene chloride,
trichloroethylene, 1,1,1-trichloroethane chlorobenzene, 1,1,2-trichloro-1,2,2-
trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-
trichloroethane; all spent solvent mixtures/blends containing, before use, one or
more of the above halogenated solvents or those listed in F001, F004, F005; and still
bottoms from the recovery of these spent solvents and spent solvent mixtures.
F003
Spent non-halogenated solvents: xylene, acetone, ethyl acetate, ethyl benzene, ethyl
ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all
spent solvent mixtures/blends containing, before use, only the above spent non-
halogenated solvents; and all spent solvent mixtures/blends containing, before use,
one or more of the above non-halogenated solvents, and, a total of 10% or more (by
volume) of one of those solvents listed in F001, F002, F004, F005; and still bottoms
from the recovery of these spent solvents and spent solvent mixtures.
F004
Spent non-halogenated solvents: cresols and cresylic acid, and nitrobenzene; all
spent solvent mixtures/blends containing, before use, a total of 10% or more (by
volume) of one or more of the above non-halogenated solvents or those solvents
listed in F001, F002, and F005; and still bottoms from the recovery of these spent
solvents and spent solvent mixtures.
F005
Spent non-halogenated solvents: toluene, methyl ethyl ketone, carbon disulfide,
isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent
solvent mixtures/blends containing, before use, a total of 10% or more (by volume)
of one or more of the above non-halogenated solvents or those solvents listed in
F001, F002, or F004; and still bottoms from the recovery of these spent solvents and
spent solvents mixtures.
F006
Wastewater treatment sludges from electroplating operations except from the
following processes: (1) sulfuric acid anodizing of aluminum; (2) tin plating on
carbon steel; (3) zinc plating (segregated basis) on carbon steel; (4) aluminum or
zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with tin,
zinc, and aluminum plating on carbon steel; and (6) chemical etching and milling of
aluminum.
F007
Spent cyanide plating bath solutions from electroplating operations.
F008
Plating bath residues from the bottom of plating baths from electroplating
operations where cyanides are used in the process.
F009
Spent stripping and cleaning bath solutions from electroplating operations where
cyanides are used in the process.
Source: Based on 1994 Sustainable Industry: Promoting Strategic Environmental Protection in the
Industrial Sector, Phase 1 Report.
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VI.B.I. Notable State Regulations
California's Hazardous Waste Source Reduction and Management Review
Act of 1988, commonly referred to as SB 14, requires generators that
produce over 12,000 kilograms of hazardous waste or 12 kilograms of
extremely hazardous waste to produce two documents every four
years. The documents include a Source Reduction Plan and a
Management Performance Report. The Act intends to promote
hazardous waste reduction at the source and recycling. For more
information on the compilation of these reports by the semiconductor
industry, see the October 1994 Assessment of the Semiconductor Industry
Source Reduction Planning Efforts, by the California Department of Toxic
Substances Control.
According to Daryl Burn of the California Air Resources Board, the
Board has promulgated Rule 830, Semiconductor Manufacturing
Operations, which regulates VOC emissions from semiconductor
manufacturing facilities. VOCs are released during wafer preparation,
photolithography, and cleaning operations. Rule 830 was developed
in 1988 for the Bay Area Air Quality Management District (San
Francisco area) because a large concentration of semiconductor
manufacturing facilities are located in South Bay and San Francisco.
The Board does not provide assistance to facilities to help achieve
compliance.
VI.C. Pending and Proposed Regulatory Requirements
SDWA/Underground Injection Control Wells (UIC)
New regulations are being developed for UIC which will amend 40
CFR 144 and 146. The regulations will establish minimum Federal
requirements for the permitting, operating, monitoring, and closure of
several types of shallow injection wells. Restrictions will be imposed
on the operation of certain types of shallow disposal wells, especially
those that inject industrial wastes. Computer manufacturing facilities
located in areas without sewer systems that rely on shallow waste
injection wells to dispose of industrial and non-sanitary wastes will be
impacted by these regulations.
Resource Conservation and Recovery Act (RCRA)
RCRA prohibits the land disposal of most hazardous wastes until they
meet a waste specific treatment standard. While most hazardous
SIC Code 36 104 September 1995
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Sector Notebook Project Electronics and Computer Industry
wastes have already been assigned treatment standards, EPA must still
promulgate additional rule makings to address newly listed wastes
and to make changes to the land disposal restrictions (LDR) program.
Rules are required every time EPA lists a waste.
The Phase III LDR rulemaking proposes to establish treatment
standards for some newly listed wastes and RCRA equivalent
treatment standards for certain formerly characteristic hazardous
wastes that are injected into UIC wells under the Safe Drinking Water
Act (SDWA) or managed in Subtitle D surface impoundments prior to
discharge pursuant to the Clean Water Act (CWA). By consent decree,
EPA must promulgate the final rule for Phase III by January 1996.
Phase IV will similarly consider restrictions on other newly listed or
identified wastes from land disposal and evaluate what, if any,
treatment standards may be needed to mitigate the impact of sludges,
leaks, and air emissions from surface impoundments that manage
decharacterized wastes. In addition to considering restrictions on the
land disposal of the previously exempt Bevill wastes and wastes from
wood preserving, Phase IV will also consider adjustments to the
treatment standards applicable to wastes that exhibit the toxicity
characteristic for a metal constituent. Subject to the same consent
decree, Phase IV has been assigned a judicial deadline of June 1996 for
promulgation of a final rule.
Clean Air Act (CAA)
Lead NAAQS may impact the electronics/computer industry in the
future. It is believed that emissions from the use of lead in soldering
and other processes are not significant enough to subject facilities to air
pollution control requirements. However, EPA has not yet studied the
electronics/computer industry as a source of lead emissions.
Clean Air Act Amendments of 1990 (CAAA)
EPA promulgated a final NESHAP for chromium emissions from new
and existing electroplating operations on January 25, 1995. The 1990
CAA Amendments (CAAA) list chromium compounds as a criteria air
pollutant under §112. The purpose of the rule is to limit chromium
emissions to the level of Maximum Achievable Control Technology
(MACT) (60 FR 4948).
September 1995 105 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
A NESHAP for halogenated solvent cleaning was issued December 2,
1994. The regulation applies to organic halogenated solvent cleaners
(degreasers) using specified halogenated HAP solvents.
Several hazardous air pollutants (HAP) which are used in printed
wired board manufacturing as well as semiconductor manufacturing
and assembly are scheduled for MACT standards. According to IPC
and EPA, these HAPs include: ethylene glycol; hydrochloric acid;
hydrofluoric acid; lead compounds; and nickel compounds.
EPA is in the process of identifying industries that emit any substantial
quantities of the 189 HAPs. Regulations that apply specifically to the
semiconductor industry are expected in 1997.
Clean Water Act (CWA)
EPA is scheduled to propose effluent limitation guidelines and
standards for metal products and machinery. These guidelines and
standards will address facilities that generate wastewater while
processing metal parts, products, and machinery. The proposal will
also include facilities that generate wastewater during the following
processes: manufacturing, assembly, repairing, rebuilding, and
maintenance. Phase I of these guidelines and standards covers seven
industries. The industries relevant to SIC code 36 and 35 are stationary
industrial equipment (electrical equipment) and electronic equipment
(including communication equipment). A notice of proposed rule
making is expected to be published by November 1994, and final
action on this proposed regulation is scheduled for May 1996.
SIC Code 36 106 September 1995
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Sector Notebook Project Electronics and Computer Industry
VII. COMPLIANCE AND ENFORCEMENT HISTORY
Background
To date, EPA has focused much of its attention on measuring
compliance with specific environmental statutes. This approach
allows the Agency to track compliance with the Clean Air Act, the
Resource Conservation and Recovery Act, the Clean Water Act, and
other environmental statutes. Within the last several years, the
Agency has begun to supplement single-media compliance indicators
with facility-specific, multimedia indicators of compliance. In doing
so, EPA is in a better position to track compliance with all statutes at
the facility level, and within specific industrial sectors.
A major step in building the capacity to compile multimedia data for
industrial sectors was the creation of EPA's Integrated Data for
Enforcement Analysis (IDEA) system. IDEA has the capacity to "read
into" the Agency's single-media databases, extract compliance records,
and match the records to individual facilities. The IDEA system can
match Air, Water, Waste, Toxics/Pesticides/EPCRA, TRI, and
Enforcement Docket records for a given facility, and generate a list of
historical permit, inspection, and enforcement activity. IDEA also has
the capability to analyze data by geographic area and corporate
holder. As the capacity to generate multimedia compliance data
improves, EPA will make available more in-depth compliance and
enforcement information. Additionally, sector-specific measures of
success for compliance assistance efforts are under development.
Compliance and Enforcement Profile Description
Using inspection, violation, and enforcement data from the IDEA
system, this section provides information regarding the historical
compliance and enforcement activity of this sector. In order to mirror
the facility universe reported in the Toxic Chemical Profile, the data
reported within this section consists of records only from the TRI
reporting universe. With this decision, the selection criteria are
consistent across sectors with certain exceptions. For the sectors that
do not normally report to the TRI program, data have been provided
from EPA's Facility Indexing System (FINDS) which tracks facilities in
all media databases. Please note, in this section, EPA does not attempt
to define the actual number of facilities that fall within each sector.
Instead, the section portrays the records of a subset of facilities within
the sector that are well defined within EPA databases.
September 1995 107 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
As a check on the relative size of the full sector universe, most
notebooks contain an estimated number of facilities within the sector
according to the Bureau of Census (See Section II). With sectors
dominated by small businesses, such as metal finishers and printers,
the reporting universe within the EPA databases may be small in
comparison to Census data. However, the group selected for inclusion
in this data analysis section should be consistent with this sector's
general make-up.
Following this introduction is a list defining each data column
presented within this section. These values represent a retrospective
summary of inspections and enforcement actions, and solely reflect
EPA, State, and local compliance assurance activities that have been
entered into EPA databases. To identify any changes in trends, the
EPA ran two data queries, one for the past five calendar years (August
10, 1990 to August 9, 1995) and the other for the most recent twelve-
month period (August 10, 1994 to August 9, 1995). The five-year
analysis gives an average level of activity for that period for
comparison to the more recent activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media
databases. These databases do not provide data on whether
inspections are State/local or EPA-led. However, the table breaking
down the universe of violations does give the reader a crude
measurement of the EPA's and States' efforts within each media
program. The presented data illustrate the variations across regions
for certain sectors.3 This variation may be attributable to State/local
data entry variations, specific geographic concentrations, proximity to
population centers, sensitive ecosystems, highly toxic chemicals used
in production, or historical noncompliance. Hence, the exhibited data
do not rank regional performance or necessarily reflect which regions
may have the most compliance problems.
3 EPA Regions include the following States: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR,
VI); III (DC, DE, MD, PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI,
MN, OH, WI); VI (AR, LA, NM, OK, TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT,
WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, WA).
SIC Code 36 108 September 1995
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Sector Notebook Project Electronics and Computer Industry
Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) -- this system assigns a common
facility number to EPA single-media permit records. The FINDS
identification number allows EPA to compile and review all permit,
compliance, enforcement, and pollutant release data for any given
regulated facility.
Integrated Data for Enforcement Analysis (IDEA) -- is a data
integration system that can retrieve information from the major EPA
program office databases. IDEA uses the FINDS identification number
to "glue together" separate data records from EPA's databases. This is
done to create a "master list" of data records for any given facility.
Some of the data systems accessible through IDEA are: AIRS (Air
Facility Indexing and Retrieval System, Office of Air and Radiation),
PCS (Permit Compliance System, Office of Water), RCRIS (Resource
Conservation and Recovery Information System, Office of Solid
Waste), NCDB (National Compliance Data Base, Office of Prevention,
Pesticides, and Toxic Substances), CERCLIS (Comprehensive
Environmental and Liability Information System, Superfund), and
TRIS (Toxic Release Inventory System). IDEA also contains
information from outside sources such as Dun and Bradstreet and the
Occupational Safety and Health Administration (OSHA). Most data
queries displayed in notebook Sections IV and VII were conducted
using IDEA.
Data Table Column Heading Definitions
Facilities in Search -- are based on the universe of TRI reporters
within the listed SIC code range. For industries not covered under TRI
reporting requirements, the notebook uses the FINDS universe for
executing data queries. The SIC code range selected for each search is
defined by each notebook's selected SIC code coverage described in
Section II.
Facilities Inspected indicates the level of EPA and State agency
inspections for the facilities in this data search. These values show
what percentage of the facility universe is inspected in a 12 or 60
month period. This column does not count non-inspectional
compliance activities such as the review of facility-reported discharge
reports.
September 1995 109 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
Number of Inspections -- measures the total number of inspections
conducted in this sector. An inspection event is counted each time it is
entered into a single media database.
Average Time Between Inspections -- provides an average length of
time, expressed in months, that a compliance inspection occurs at a
facility within the defined universe.
Facilities with One or More Enforcement Actions expresses the
number of facilities that were party to at least one enforcement action
within the defined time period. This category is broken down further
into Federal and State actions. Data are obtained for administrative,
civil/judicial, and criminal enforcement actions. Administrative
actions include Notices of Violation (NOVs). A facility with multiple
enforcement actions is only counted once in this column (facility with 3
enforcement actions counts as 1). All percentages that appear are
referenced to the number of facilities inspected.
Total Enforcement Actions -- describes the total number of
enforcement actions identified for an industrial sector across all
environmental statutes. A facility with multiple enforcement actions is
counted multiple times (a facility with 3 enforcement actions counts as
3).
State Lead Actions -- shows what percentage of the total enforcement
actions are taken by State and local environmental agencies. Varying
levels of use by States of EPA data systems may limit the volume of
actions accorded State enforcement activity. Some States extensively
report enforcement activities into EPA data systems, while other States
may use their own data systems.
Federal Lead Actions -- shows what percentage of the total
enforcement actions are taken by the U.S. EPA. This value includes
referrals from State agencies. Many of these actions result from
coordinated or joint State/Federal efforts.
Enforcement to Inspection Rate -- expresses how often enforcement
actions result from inspections. This value is a ratio of enforcement
actions to inspections, and is presented for comparative purposes only.
This measure is a rough indicator of the relationship between
inspections and enforcement. This measure simply indicates
historically how many enforcement actions can be attributed to
inspection activity. Related inspections and enforcement actions under
the Clean Water Act (PCS), the Clean Air Act (AFS) and the Resource
SIC Code 36 110 September 1995
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Sector Notebook Project Electronics and Computer Industry
Conservation and Recovery Act (RCRA) are included in this ratio.
Inspections and actions from the TSCA/FIFRA/EPCRA database are
not factored into this ratio because most of the actions taken under
these programs are not the result of facility inspections. This ratio
does not account for enforcement actions arising from non-inspection
compliance monitoring activities (e.g., self-reported water discharges)
that can result in enforcement action within the CAA, CWA and
RCRA.
Facilities with One or More Violations Identified indicates the
number and percentage of inspected facilities having a violation
identified in one of the following data categories: In Violation or
Significant Violation Status (CAA); Reportable Noncompliance,
Current Year Noncompliance, Significant Noncompliance (CWA);
Noncompliance and Significant Noncompliance (FIFRA, TSCA, and
EPCRA); Unresolved Violation and Unresolved High Priority
Violation (RCRA). The values presented for this column reflect the
extent of noncompliance within the measured time frame, but do not
distinguish between the severity of the noncompliance. Percentages
within this column can exceed 100 percent because facilities can be in
violation status without being inspected. Violation status may be a
precursor to an enforcement action, but does not necessarily indicate
that an enforcement action will occur.
Media Breakdown of Enforcement Actions and Inspections four
columns identify the proportion of total inspections and enforcement
actions within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA
databases. Each column is a percentage of either the "Total
Inspections," or the "Total Actions" column.
VILA. Electronics/Computer Industry Compliance History
The exhibit below contains a Regional breakdown of the inspection
and enforcement action over the last five years in the
electronics/computer industry. As expected, the largest number of
electronics/computer industry facilities is located in Region IX.
However, other Regions (i.e., Regions I and II) inspected a greater
number of electronics facilities than Region IX. Also, Regions IX and X
have significantly higher enforcement to inspection ratios than the
other Regions. In addition, 100 percent of Region VI and VII
enforcement actions are led by the Federal government and 100
percent of Region VIII were enforcement actions were State-lead.
September 1995 111 SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
Exhibit 35
Five Year Enforcement and Compliance Summary for the Computer Industry
A
Computers
SIC 35
Region I
Region II
Region III
Region IV
Region V
Region VI
Region VII
Region VIII
Region IX
Region X
Total/Average
B
Facilities in
Search
2
2
4
8
2
1
3
22
C
Facilities
Inspected
2
2
3
3
1
1
12
D
Number of
Inspections
15
11
49
17
2
1
95
E
Average
Number of
Months
Between
Inspections
8
11
5
30
63
63
8
15
F
Facilities
w/one or
more
Enforcement
Actions
2
1
1
4
G
Total
Enforcement
Actions
6
5
4
15
H
State Lead
Actions
0%
80%
100%
100%
92%
I
Federal Lead
Actions
0%
20%
8%
J
Enforcement
to Inspection
Rate
0.18
0.12
0.29
2.00
0.16
SIC Code 36
112
September 1995
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Sector Notebook Project Electronics and Computer Industry
VII.B. Comparison of Enforcement Activity Between Selected Industries
Exhibits 36 and 37 below present five and one year enforcement and
compliance summaries for selected industries. The exhibits show that
the number of inspections for the electronics/computer industry is low
in comparison to other industries, and the average time between
inspections is longer than other industries.
Exhibit 38 and 39 present five and one year inspection and
enforcement summaries by statute. As expected, a significant
percentage of inspections and enforcement actions involving
electronics facilities are RCRA-related. This is in part due to the large
amount of solvents used and sludges generated during various stages
of the manufacturing process. The exhibit also shows a significantly
lower percentage of Clean Air Act and Clean Water Act inspections
and actions. This is somewhat surprising in light of the VOC
emissions and the wastewaters and rinsewaters contaminated with
spent solvents and acids generated by this industry.
September 1995 113 SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
Exhibit 36
Five Year Enforcement and Compliance Summary for Selected Industries
A
Industry Sector
Metal Mining
Non-metallic Mineral
Mining
Lumber and Wood
Furniture
Rubber and Plastic
Stone, Clay, and Glass
Nonferrous Metals
Fabricated Metal
Electronics/Computers
Motor Vehicle
Assembly
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Iron and Steel
Dry Cleaning
B
Facilities in
Search
873
1,143
464
293
1,665
468
844
2,346
405
598
306
4,106
548
412
156
374
933
C
Facilities
Inspected
339
631
301
213
739
268
474
1,340
222
390
265
1,035
298
316
145
275
245
D
Number
of
Inspections
1,519
3,422
1,891
1,534
3,386
2,475
3,097
5,509
777
2,216
3,766
4,723
3,034
3,864
3,257
3,555
633
E
Average Number
of Months
Between
Inspections
34
20
15
11
30
11
16
26
31
16
5
52
11
6
3
6
88
F
Facilities
w/One or More
Enforcement
Actions
67
84
78
34
146
73
145
280
68
81
115
176
99
152
110
115
29
G
Total
Enforcement
Actions
155
192
232
91
391
301
470
840
212
240
502
514
402
726
797
499
103
H
State Lead
Actions
47%
76%
79%
91%
78%
70%
76%
80%
79%
80%
78%
85%
76%
66%
66%
72%
99%
I
Federal
Lead
Actions
53%
24%
21%
9%
22%
30%
24%
20%
21%
20%
22%
15%
24%
34%
34%
28%
1%
J
Enforcement to
Inspection Rate
0.10
0.06
0.12
0.06
0.12
0.12
0.15
0.15
0.27
0.11
0.13
0.11
0.13
0.19
0.25
0.14
0.16
SIC Code 36
114
September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 37
One Year Enforcement and Compliance Summary for Selected Industries
A
Industry Sector
Metal Mining
Non-metallic Mineral
Mining
Lumber and Wood
Furniture
Rubber and Plastic
Stone, Clay, and Glass
Nonferrous Metals
Fabricated Metal
Electronics/Computers
Motor Vehicle Assembly
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Iron and Steel
Dry Cleaning
B
Facilities in
Search
873
1,143
464
293
1,665
468
844
2,346
405
598
306
4,106
548
412
156
374
933
C
Facilities
Inspected
114
253
142
160
271
146
202
477
60
169
189
397
158
195
109
167
80
D
Number of
Inspections
194
425
268
113
435
330
402
746
87
284
576
676
427
545
437
488
111
E
Facilities w/One or More
Violations
Number
82
75
109
66
289
116
282
525
80
162
162
251
167
197
109
165
21
Percent*
72%
30%
77%
41%
107%
79%
140%
110%
133%
96%
86%
63%
106%
101%
100%
99%
26%
F
Facilities w/One or More
Enforcement Actions
Number
16
28
18
3
19
20
22
46
8
14
28
25
19
39
39
20
5
Percent*
14%
11%
13%
2%
7%
14%
11%
10%
13%
8%
15%
6%
12%
20%
36%
12%
6%
G
Total
Enforcement
Actions
24
54
42
5
59
66
72
114
21
28
88
72
49
118
114
46
11
H
Enforcement
to Inspection
Rate
0.13
0.13
0.58
0.55
0.14
0.20
0.18
0.15
0.24
0.10
0.15
0.11
0.12
0.22
0.26
0.09
0.10
* Percentages in Columns E and F are based on the number of facilities inspected (Column C). Percentages can exceed 100% because violations and actions can occur
without a facility inspection.
September 1995
115
SIC Code 36
-------
Electronics and Computer Industry
Sector Notebook Project
Exhibit 38
Five Year Inspection and Enforcement Summary by Statute for Selected
Industries
Industry Sector
Metal Mining
Non-metallic
Mineral Mining
Lumber and Wood
Furniture
Rubber and Plastic
Stone, Clay and
Glass
Nonferrous
Metals
Fabricated Metal
Electronics/
Computers
Motor Vehicle
Assembly
Pulp and Paper
Printing
Inorganic
Chemicals
Organic
Chemicals
Petroleum
Refining
Iron and Steel
Dry Cleaning
Number of
Facilities
Inspected
339
631
301
293
739
268
474
1,340
222
390
265
1,035
302
316
145
275
245
Total
Inspections
1,519
3,422
1,891
1,534
3,386
2,475
3,097
5,509
777
2,216
3,766
4,723
3,034
3,864
3,237
3,555
633
Enforcement
Actions
155
192
232
91
391
301
470
840
212
240
502
514
402
726
797
499
103
Clean Air Act
% of Total
Inspections
35%
65%
31%
52%
39%
45%
36%
25%
16%
35%
51%
49%
29%
33%
44%
32%
15%
% of Total
Actions
17%
46%
21%
27%
15%
39%
22%
11%
2%
15%
48%
31%
26%
30%
32%
20%
1%
Clean Water Act
% of Total
Inspections
57%
31%
8%
1%
13%
15%
22%
15%
14%
9%
38%
6%
29%
16%
19%
30%
3%
% of Total
Actions
60%
24%
7%
1%
7%
5%
13%
6%
3%
4%
30%
3%
17%
21%
12%
18%
4%
Resource Conservation
and Recovery Act
% of Total
Inspections
6%
3%
59%
45%
44%
39%
38%
56%
66%
54%
9%
43%
39%
46%
35%
37%
83%
% of Total
Actions
14%
27%
67%
64%
68%
51%
54%
76%
90%
75%
18%
62%
53%
44%
52%
58%
93%
FIFRA/TSCA/
EPCRA/Other*
% of Total
Inspections
1%
<1%
2%
1%
3%
2%
4%
4%
3%
2%
2%
2%
3%
5%
2%
2%
<1%
% of Total
Actions
9%
4%
5%
8%
10%
5%
10%
7%
5%
6%
3%
4%
4%
5%
5%
5%
1%
Actions taken to enforce the Federal Insecticide, Fungicide, and Rodenticide Act;
the Toxic Substances and Control Act, and the Emergency Planning and
Community Right-to-Know Act as well as other Federal environmental laws.
SIC Code 36
116
September 1995
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Sector Notebook Project
Electronics and Computer Industry
Exhibit 39
One Year Inspection and Enforcement Summary by Statute for Selected
Industries
Industry Sector
Metal Mining
Non-metallic
Mineral Mining
Lumber and
Wood
Furniture
Rubber and
Plastic
Stone, Clay, and
Glass
Nonferrous
Metals
Fabricated Metal
Electronics/
Computers
Motor Vehicle
Assembly
Pulp and Paper
Printing
Inorganic
Chemicals
Organic
Chemicals
Petroleum
Refining
Iron and Steel
Dry Cleaning
Number of
Facilities
Inspected
114
253
142
293
271
146
202
477
60
169
189
397
158
195
109
167
80
Total
Inspections
194
425
268
160
435
330
402
746
87
284
576
676
427
545
439
488
111
Enforcement
Actions
24
54
42
5
59
66
72
114
21
28
88
72
49
118
114
46
11
Clean Air Act
% of Total
Inspections
47%
69%
29%
58%
39%
45%
33%
25%
17%
34%
56%
50%
26%
36%
50%
29%
21%
% of
Total
Actions
42%
58%
20%
67%
14%
52%
24%
14%
2%
16%
69%
27%
38%
34%
31%
18%
4%
Clean Water Act
% of Total
Inspections
43%
26%
8%
1%
14%
18%
21%
14%
14%
10%
35%
5%
29%
13%
19%
35%
1%
%of
Total
Actions
34%
16%
13%
10%
4%
8%
3%
8%
7%
9%
21%
3%
21%
16%
16%
26%
22%
Resource Conservation
and Recovery Act
% of Total
Inspections
10%
5%
63%
41%
46%
38%
44%
61%
69%
56%
10%
44%
45%
50%
30%
36%
78%
% of
Total
Actions
6%
16%
61%
10%
71%
37%
69%
77%
87%
69%
7%
66%
36%
49%
47%
50%
67%
FIFRA/TSCA/
EPCRA/Other
% of Total
Inspections
<1%
<1%
<1%
<1%
1%
<1%
1%
<1%
<1%
1%
<1%
<1%
<1%
1%
1%
<1%
<1%
%of
Total
Actions
19%
11%
6%
13%
11%
3%
4%
2%
4%
6%
3%
4%
6%
1%
6%
6%
7%
Actions taken to enforce the Federal Insecticide, Fungicide, and Rodenticide Act; the
Toxic Substances and Control Act, and the Emergency Planning and Community
Right-to-Know Act as well as other Federal environmental laws.
September 1995
117
SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
VII.C. Review of Major Legal Actions
This section provides a listing of major legal cases and supplemental
enforcement projects that pertain to the Electronics/Computer
Industry. Information in this section is provided by EPA's Enforcement
Accomplishments Report, FY 1991, FY 1992, FY 1993 and the Office of
Enforcement.
VII.C.I. Review of Major Cases
This section provides summary information about major cases that
have affected this sector. As indicated in the EPA's Enforcement
Accomplishments Report, FY 1991, FY 1992, FY 1993 publications, 16
significant enforcement actions involving the electronics/computer
industry were resolved between 1991 and 1993. CERCLA violations
comprised nine of these cases, the most of any statute. Following
CERCLA violations were five cases involving CWA violations, three
involving RCRA violations, and one involving a TSCA violation. Two
of the sites were Superfund sites. Several of the settlements required
reimbursement of Superfund response costs or payment of the
remedial costs. The companies against which the cases were brought
are primarily manufacturers of electrical components such as printed
wiring boards. The other companies performed electroplating
operations and manufactured electrical equipment.
Four of the sixteen actions resulted in the assessment of a penalty.
Penalties ranged from $25,000 to $300,000. The average penalty was
approximately $178,125. In a case involving General Electric, the
company was subject to a penalty and agreed to pay for removal and
disposal of PWB electrical equipment over a period of three years at an
estimated cost of one million dollars. In the case of U.S. v.
Electrochemical Co., Inc., the court stated it would suspend $225,000 of
a $250,000 fine if the company would clean up the contaminated area.
Although many cases involved civil penalties, four of the cases
involved criminal convictions, resulting in penalties and/or jail
sentences for the owners and operators of the facilities. All of these
cases involved electroplating facilities and CWA violations. In one
case, U.S. v. Robert H. Schmidt and Lawrence B. Schmidt, the owner
was sentenced to 30 months in prison, followed by two years of
probation. His son, the plant supervisor, was sentenced to 24 months
of jail and two years of probation. Father and son were subject to
penalties of $50,000 and $25,000 respectively.
SIC Code 36 118 September 1995
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Sector Notebook Project Electronics and Computer Industry
VII.C.2. Supplemental Environmental Projects
Below is a list of Supplementary Environmental Projects (SEPs). SEPs
are compliance agreements that reduce a facility's stipulated penalty in
return for an environmental project that exceeds the value of the
reduction. Often, these projects fund pollution prevention activities
that can significantly reduce the future pollutant loadings of a facility.
In December, 1993, the Regions were asked by EPA's Office of
Enforcement and Compliance Assurance to provide information on the
number and type of SEPs entered into by the Regions. Exhibit 40
contains a representative sample of the Regional responses addressing
the electronics and computer industries. The information contained in
the chart is not comprehensive and provides only a sample of the types
of SEPs developed for the electronics and computer industries.
September 1995 119 SIC Code 36
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Electronics and Computer Industry
Sector Notebook Project
Exhibit 40
Supplemental Environmental Projects
Electronics (SIC 36)
Case Name
Lane Electronic
Cooperative
Eugene, OR
Cirtech, Inc.
Universal Circuits
Trojan Battery
G & W Electric
Company
Blue Island, IL
Manu-Tronics
Kenosha, WI
Anchor Electric
Co.
Manchester, NH
EPA
Region
10
9
9
9
5
5
1
Statute/
Type of
Action
TSCA
RCRA
EPCRA
EPCRA
EPCRA
EPCRA
EPCRA
Type of
SEP
Pollution
Reduction
Pollution
Prevention
Pollution
Prevention
Pollution
Prevention
Pollution
Prevention
Pollution
Prevention
Estimated
Cost to
Company
S 9,775
S 9,900
S 97,000
S 81,700
540,000
Expected Environmental Benefits
Early disposal of PCBs or PCB contaminated electrical
equipment.
Purcahse and install a device to eliminate copper from the
waste stream and to reduce the hazardous waste stream.
Will allow corrosive etch water to be reused.
Implement a waste water recycling project which
permanently reduces the consumption of water. Sponsor
and conduct an outreach program
Eliminate wastewater discharges. Operate a battery
recycling center.
Implement process modifications designed to eliminate
the use of 72,000 Ibs/yr of
1,1,1 ,-trichloroethane.
Modify the industrial processes eliminate the use and
release of 25,000 Ibs/yr of Freon 113.
Purchase, install, and operate an aqueous washer system in
place of current vapor degreaser. Change will result in
virtual elimination of the use of
1,1,1 ,-trichloroethane.
Final
Assessed
Penalty
S 9,775
511,400
S 68,000
S 34,000
551,000
Final
Penalty
After
Mitigation
S 4,888
S 7,630
S 7,825
S 3,400
513,650
SIC Code 36
120
September 1995
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Sector Notebook Project Electronics and Computer Industry
VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector
and public agencies to voluntarily improve the sector's environmental
performance. These activities include those independently initiated by
industrial trade associations. In this section, the notebook also
contains a listing and description of national and regional trade
associations.
VIII.A. Sector-Related Environmental Programs and Activities
VIII.A.I. Federal Activities
Common Sense Initiative (CSI)
The Common Sense Initiative (CSI), a partnership between EPA and
private industry, aims to create environmental protection strategies
that are cleaner for the environment and cheaper for industry and
taxpayers. As part of CSI, representatives from Federal, State, and
local governments; industry; community-based and national
environmental organizations; environmental justice groups; and labor
organizations, come together to examine the full range of
environmental requirements affecting the following six selected
industries: automobile manufacturing; computers and electronics, iron
and steel, metal finishing, petroleum refining; and printing.
CSI participants are looking for solutions that:
Focus on the industry as a whole rather than one pollutant
Seek consensus-based solutions
Focus on pollution prevention rather than end-of-pipe controls
Are industry-specific.
The Common Sense Initiative Council (CSIC), chaired by EPA
Administrator Browner, consists of a parent council and six
subcommittees (one per industry sector). Each of the subcommittees
have met and identified issues and project areas for emphasis, and
workgroups have been established to analyze and make
recommendations on these issues.
September 1995 121 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
Design for the Environment (DfE)
DfE is an EPA program operated by the Office of Pollution Prevention
and Toxics. DfE is a voluntary program which promotes the use of
safer chemicals, processes, and technologies in the earliest product
design stages. The DfE program assists industry in making informed,
environmentally responsible design choices by providing
standardized analytical tools for industry application and providing
information on the comparative environmental and human health risk,
cost, and performance of chemicals, processes, and technologies. DfE
also helps small businesses by analyzing pollution prevention
alternatives and disseminating the information to industry and the
public. By helping to translate pollution prevention into meaningful
terms, DfE contributes to building the institutional structure in
corporations to support pollution prevention. DfE activities fall into
two broad categories: (1) the industry-specific projects which
encourage businesses to incorporate pollution prevention into their
designs; and (2) long-term projects that translate pollution prevention
into terms that make sense to professions such as chemistry, chemical
engineering, marketing, accounting, and insurance.
DfE currently is working with the PWB industry because it is a critical
component of the electronics, automotive, and defense industries.
Also, MCC's lifecycle assessment of a computer work station study
recognized that chemical processes such as those used in PWB
fabrication are a significant source of hazardous waste and consume
large amounts of water and energy. The potential for improvement in
those areas led EPA's DfE Program to sponsor a project to assist the
PWB industry in evaluating substitute materials and processes for
making PWB holes conductive. DfE also plans to help the PWB
industry identify multi-media environmental issues and the trade-offs
of competing environmental objectives.
Industry/Government Partnerships
In 1993, the initial results of a six month lifecycle assessment of a
computer workstation was released in a report called Environmental
Consciousness: A Strategic Competitiveness Issue for the Electronics and
Computer Industry; Comprehensive Report: Analyses and Synthesis, Task
Force Reports, and Appendices. The study was conducted by
Microelectronics and Computer Technology Corp. (MCC),
SEMATECH (sponsored by the Semiconductor Industry Association),
EPA, and the Department of Energy (DOE).
SIC Code 36 122 September 1995
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Sector Notebook Project Electronics and Computer Industry
As a result of the assessment, the Department of Defense funded an
industry led effort, the first phase of which involved development of
the Electronics Industry Environmental Roadmap, which prioritizes the
electronics and computer industries' environmental needs over the
next ten years. The goal of the Roadmap is to assist U.S. companies to
compete with foreign competitors who have established partnerships
with their governments. MCC produced the Electronics Industry
Environmental Roadmap in November 1993. MCC has received funding
from the Department of Defense Advanced Research Projects Agency
(ARPA) and EPA to continue to working with industry task groups to
compile information, learn the needs of industry, and to suggest
possible solutions to environmental/economic problems.
VIII.A.2. State Activities
Several States are actively involved in promoting pollution prevention
by initiating partnerships with industry to develop and implement
pollution prevention and waste minimization practices. Following is a
description of some State pollution prevention initiatives related to the
electronics/computer industry.
The Minnesota Technical Assistance Program (MnTAP) is supported
by a grant to the University of Minnesota's School of Public Health.
MnTAP staff and interns assists Minnesota businesses in the
electronics and computer industries by identifying effective waste
reduction opportunities. MnTAP researches treatment options, makes
on-site visits to discuss recommendations, and coordinates
documentation. MnTAP developed a checklist for businesses to
evaluate their waste streams and identify waste reduction
opportunities. MnTAP gathered vendor and technical information
that may assist facilities in the industry in their evaluations in addition
to a list of recycling vendors if the options on the checklists are not
feasible to implement. Pollution prevention techniques for the
electronics and computer industries that were recommended by
MnTAP include material substitution, process modification, and
recycling.
The State of Minnesota's Office of Waste Management (OWM) also
has a Pollution Prevention Research Award Program. The program is
part of Minnesota's efforts to promote pollution prevention. OWM
contracts with private industry to investigate available pollution
prevention alternatives in the electronics and computer industries.
The process involves literature searches, telephone surveys, case study
September 1995 123 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
development, and working with trade associations and MnTAP. In
July 1992, four cases studies were written as part of a report on
alternatives to cyanide solutions in electroplating. OWM encourages
implementation of pollution prevention techniques such as material
substitution, recycling, process modification, wastewater treatment,
electroplating, and the recycling of spent printed wiring boards.
The North Carolina Department of Natural Resources and
Community Development has a Pollution Prevention Pays Program.
The program provides technical, cost (operating and capital), economic
benefit, and environmental benefit information to the public and
facilities in the electronics and computer industries. The program
recommends equipment modification, recycling, and process
modification/pollution prevention techniques for the treatment of
wastewater generated by electroplating processes.
The City of Los Angeles' Board of Public Works has a Hazardous and
Toxic Materials Project (HTMP). HTMP provides fact sheets to the
public and facilities in the electronics and computer industry
describing different strategies to reduce the cost and quantity of waste
generated. Pollution prevention techniques include material
substitution, process modification, and recycling. HTMP also provides
information on vendors who provide alternative waste management
services.
The City of Santa Monica's Department of General Services provides
fact sheets and information on pollution prevention to businesses. The
City outlines pollution prevention techniques for printed circuit board
manufacturing in fact sheets. The fact sheets rate waste reduction
practices in terms of easiest, more difficult, and most difficult to
implement. The fact sheets also provide contacts from the Department
of Health Services, small business assistance loan programs, and
California agencies with waste reduction programs.
Other pollution prevention initiatives that have targeted the electronics
and computer industries include: the Hazardous Waste Reduction
Program of the Oregon Department of Environmental Quality (DEQ);
the New Jersey Hazardous Waste Facilities Siting Commission of the
Hazardous Waste Source Reduction and Recycling Taskforce; and the
San Diego County Department of Health Services.
SIC Code 36 124 September 1995
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Sector Notebook Project Electronics and Computer Industry
VIII.B. EPA Voluntary Programs
33/50 Program
The "33/50 Program" is EPA's voluntary program to reduce toxic
chemical releases and transfers of 17 chemicals from manufacturing
facilities. Participating companies pledge to reduce their toxic
chemical releases and transfers by 33 percent as of 1992 and by 50
percent as of 1995 from the 1988 baseline year. Certificates of
Appreciation have been given to participants who met their 1992 goals.
The list of chemicals includes 17 high-use chemicals reported in the
Toxics Release Inventory.
Thirty-four companies and 72 facilities listed under SIC 36 (the
electronics/computer industry) are currently participating in the 33/50
program. They account for approximately 17 percent of the 406
companies under SIC 36, which is slightly higher than the average for
all industries of 14 percent participation. (Contact: Mike Burns 202-
260-6394 or the 33/50 Program 202-260-6907)
Exhibit 41 lists those companies participating in the 33/50 program
that reported under SIC code 36 to TRI. Many of the participating
companies listed multiple SIC codes (in no particular order), and are
therefore likely to conduct operations in addition to
electronics/computer industry. The table shows the number of
facilities within each company that are participating in the 33/50
program; each company's total 1993 releases and transfers of 33/50
chemicals; and the percent reduction in these chemicals since 1988.
September 1995 125 SIC Code 36
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Electronics and Computer Industry
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Exhibit 41
Electronics/Computer Industry Facilities (SIC 36)
Participating in the 33/50 Program
Parent Facility name
Aluminum Company Of America
American Telephone & Telg Co
Amp-Akzo Corporation
Benton International Inc
Boeing Company
Buckbee-Greig Holding Corp
Burle Industries Inc
Eaton Corporation
General Motors Corporation
Gti Corporation
Hadco Corporation
Harris Corporation
Hewlett-Packard Company
IBM
Intel Corporation
Itt Corporation
Litton Industries Inc
Lucerne Products Inc
Martin Marietta Corporation
Motorola Inc
National Semiconductor Corp.
North American Philips Corp
Photocircuits Corporation
Raytheon Company
Rockwell International Corp
Seh America Inc.
Sony USA Inc
Talley Industries Inc
Tektronix Inc
Texas Instruments Incorporated
Thomson Consumer Electronics
Varian Associates Inc
Westinghouse Electric Corp
Zenith Electronics Corporation
Parent City
Pittsburgh
New York
Chadds Ford
North Haven
Seattle
Minneapolis
Lancaster
Cleveland
Detroit
San Diego
Salem
Melbourne
Palo Alto
Armonk
Santa Clara
New York
Beverly Hills
Hudson
Bethesda
Schaumburg
Santa Clara
New York
Glen Cove
Lexington
Seal Beach
Vancouver
New York
Phoenix
Beaverton
Dallas
Indianapolis
Palo Alto
Pittsburgh
Glenview
ST
PA
NY
PA
CT
WA
MN
PA
OH
MI
CA
NH
FL
CA
NY
CA
NY
CA
OH
MD
IL
CA
NY
NY
MA
CA
WA
NY
AZ
OR
TX
IN
CA
PA
IL
SIC Codes
3674
3672, 3661
3672
3672
3728, 3769,
3672
3672
3671,3663,
3699
3674
3651,3694,
3679, 3672,
3471
3674
3672
3674
3674
3674
3674
3670, 3674
3672
3699, 3674
3672, 3761,
3812
3674
3674
3674
3672, 3471
3674
3669, 3672
3674, 3339
3674
3672, 3822,
3548
3672
3674
3671
3671
3672,3812
3671
#of
Participating
Facilities
1
3
3
1
1
1
1
1
3
1
2
3
2
6
3
2
1
1
1
4
3
2
2
2
1
1
2
1
1
5
4
3
3
1
1993 Releases
and Transfers
(Ibs.)
2,403,017
512,618
51,196
26
4,789,875
500
12,200
450,211
16,751,198
13,961
63,469
110,355
7,400
1,411,304
18,105
735,332
332,264
2,505
223,286
226,357
23,173
1,281,928
292,178
706,045
1,007,043
53,140
869,577
3,804
12,393
344,225
2,110,314
67,417
1,137,198
917,894
% Reduction
1988 to 1993
51
50
1
2
50
**
*
50
*
91
**
50
1
50
7
**
***
73
50
6
50
92
50
50
100
51
***
*
25
43
50
28
25
* = not quantifiable against 1988 data.
** = use reduction goal only.
*** = no numerical goal.
SIC Code 36
126
September 1995
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Sector Notebook Project Electronics and Computer Industry
Energy Star Computer Program
The Energy Star Computer program is a voluntary partnership
between the EPA and computer companies that manufacture energy-
efficient computer equipment such as desktop computers, printers,
and monitors. The companies that participate in this program
comprise 70 percent of all U.S. sales of desktop computers and 90
percent of laser printers. In order for a computer to qualify and
display the EPA Energy Star logo, it must operate on low power when
inactive and can "sleep" or "power-down," and then awaken by
touching the mouse or keyboard. The program requires that the
central processing unit, printer, and monitor of the computer must
enter a standby mode when not in use and use no more than 30 watts.
Energy-efficient computers were available to the public and businesses
as of June 1993.
Computer equipment is the fastest growing user of electricity in the
commercial sector. Currently, computers account for five percent of
commercial electricity consumption, and this is expected to grow to 10
percent by the year 2000. The Energy Star sleep feature can reduce
electricity consumption by 50 to 75 percent. In addition, the efficient
systems generate less heat while the computer sleeps, which reduces
electricity needed to cool a building by five to ten percent. These
computers are predicted to diminish electricity consumption by 25
billion kilowatts hours per year by the year 2000. The reduction of
electricity use would eliminate the need for 10 coal-fired plants and
reduce carbon-dioxide emissions by up to 20 million tons. An
Executive Order, which was issued in April 1993 and took effect in
October 1993, directed the U.S. government to purchase only Energy
Star computer equipment where available and if performance needs
are met. Implementation of the Executive Order is expected to save
$40 million annually. (Contact: Maria Tikoff (202) 233-9178)
Environmental Leadership Program
The Environmental Leadership Program (ELP) is a national initiative
piloted by EPA and State agencies in which facilities have volunteered
to demonstrate innovative approaches to environmental management
and compliance. EPA has selected 12 pilot projects at industrial
facilities and Federal installations which will demonstrate the
principles of the ELP program. These principles include:
environmental management systems, multimedia compliance
assurance, third-party verification of compliance, public measures of
accountability, community involvement, and mentoring programs. In
return for participating, pilot participants receive public recognition
September 1995 127 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
and are given a period of time to correct any violations discovered
during these experimental projects. (Contact: Tai-ming Chang, ELP
Director (202) 564-5081 or Robert Fentress (202) 564-7023)
Motorola ELP Project
Motorola is participating in a pilot phase of the Environmental
Leadership Program with EPA and the State of Texas. Their Oak Hill
facility located in Austin, Texas, will encompass two key projects, both
in the pursuit of better environmental compliance. They are
mentoring another facility and applying an environmental
management system that aims to go beyond compliance status.
(Contact: Steve Hoover (202) 564-7007)
Project XL
Project XL was initiated in March 1995 as a part of President Clinton's
Reinventing Environmental Regulation initiative. The projects seek to
achieve cost effective environmental benefits by allowing participants
to replace or modify existing regulatory requirements on the condition
that they produce greater environmental benefits. EPA and program
participants will negotiate and sign a Final Project Agreement,
detailing specific objectives that the regulated entity shall satisfy. In
exchange, EPA will allow the participant a certain degree of regulatory
flexibility and may seek changes in underlying regulations or statutes.
Participants are encouraged to seek stakeholder support from local
governments, businesses, and environmental groups. EPA hopes to
implement fifty pilot projects in four categories including facilities,
sectors, communities, and government agencies regulated by EPA.
Applications will be accepted on a rolling basis and projects will move
to implementation within six months of their selection. For additional
information regarding XL Projects, including application procedures
and criteria, see the May 23, 1995 Federal Register Notice. (Contact:
Jon Kessler at (202) 260-4034)
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal of
preventing pollution by encouraging U.S. institutions to use energy-
efficient lighting technologies. The program has over 1,500
participants which include major corporations; small and medium
sized businesses; Federal, State and local governments; non-profit
groups; schools; universities; and health care facilities. Each
participant is required to survey their facilities and upgrade lighting
SIC Code 36 128 September 1995
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Sector Notebook Project Electronics and Computer Industry
wherever it is profitable. EPA provides technical assistance to the
participants through a decision support software package, workshops
and manuals, and a financing registry. EPA's Office of Air and
Radiation is responsible for operating the Green Lights Program.
(Contact: Susan Bullard at (202) 233-9065 or the Green Light/Energy
Star Hotline at (202) 775-6650)
WasteWi$e Program
The WasteWi$e Program was started in 1994 by EPA's Office of Solid
Waste and Emergency Response. The program is aimed at reducing
municipal solid wastes by promoting waste minimization, recycling
collection, and the manufacturing and purchase of recycled products.
As of 1994, the program had about 300 companies as members,
including a number of major corporations. Members agree to identify
and implement actions to reduce their solid wastes and must provide
EPA with their waste reduction goals along with yearly progress
reports. EPA in turn provides technical assistance to member
companies and allows the use of the WasteWi$e logo for promotional
purposes. (Contact: Lynda Wynn (202) 260-0700 or the WasteWi$e
Hotline at (800) 372-9473)
Climate Wise Recognition Program
The Climate Change Action Plan was initiated in response to the U.S.
commitment to reduce greenhouse gas emissions in accordance with
the Climate Change Convention of the 1990 Earth Summit. As part of
the Climate Change Action Plan, the Climate Wise Recognition
Program is a partnership initiative run jointly by EPA and the
Department of Energy. The program is designed to reduce
greenhouse gas emissions by encouraging reductions across all sectors
of the economy, encouraging participation in the full range of Climate
Change Action Plan initiatives, and fostering innovation. Participants
in the program are required to identify and commit to actions that
reduce greenhouse gas emissions. The program, in turn, gives
organizations early recognition for their reduction commitments;
provides technical assistance through consulting services, workshops,
and guides; and provides access to the program's centralized
information system. At EPA, the program is operated by the Air and
Energy Policy Division within the Office of Policy Planning and
Evaluation. (Contact: Pamela Herman (202) 260-4407)
September 1995 129 SIC Code 36
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NICE3
The U.S. Department of Energy and EPA's Office of Pollution
Prevention are jointly administering a grant program called The
National Industrial Competitiveness through Energy, Environment,
and Economics (NICE^). By providing grants of up to 50 percent of
the total project cost, the program encourages industry to reduce
industrial waste at its source and become more energy-efficient and
cost-competitive through waste minimization efforts. Grants are used
by industry to design, test, demonstrate, and assess the feasibility of
new processes and/or equipment with the potential to reduce
pollution and increase energy efficiency. The program is open to all
industries; however, priority is given to proposals from participants in
the pulp and paper, chemicals, primary metals, and petroleum and
coal products sectors. (Contact: DOE's Golden Field Office (303) 275-
4729)
VIII.C. Trade Association Activity
Many trade associations have been involved in researching ways to
reduce pollution associated with the manufacturing of
semiconductors, printed wiring boards, and cathode ray tubes.
Following is description of the trade association environmental
programs or partnerships. A list of some of the major trade
associations and contacts is also provided.
VIII.C.I. Environmental Programs
The Semiconductor Industry Association (SIA), in association with
EPA and DOE, released a report in March 1993 called Environmental
Consciousness: A Strategic Competitiveness Issue for the Electronics and
Computer Industry. This report contains the initial results of a six
month, lifecycle assessment of a computer workstation. The report
indicates that the industry should pursue the development of pollution
prevention and waste minimization techniques in the printed wired
board (PWB) manufacturing industry. As a result of this study, EPA
provided funding to the Institute for Interconnecting and Packaging
Electronic Circuits (IPC) and Microelectronics and Computer
Technology Corporation (MCC) to redesign PWB manufacturing
processes in order to reduce the amount of chemicals used during
production.
SIC Code 36
130
September 1995
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Sector Notebook Project
Electronics and Computer Industry
According to IPC, environmental research is also being conducted by
the Interconnection Technology Research Institute (ITRI) and by many
independent companies.
According to SIA, the Department of Defense has awarded
SEMATECH $10 million to perform research into pollution prevention
and environmentally friendly microchip manufacturing processes. As
part of a separate initiative, SIA produced a report, The National
Technology Roadmap for Semiconductors. The Roadmap acts as a guide
for R&D investment decisions.
SIA's Roadmap calls for reducing the use of approximately 60
hazardous chemicals in various stages of the manufacturing process
(e.g., mask making, photolithography, cleaning, leadframe plating,
deflashing, and soldering). The chemicals include solvents, acids,
toxics, alcohols, and other organic and inorganic substances. The goal
of the Roadmap is to phase out ozone depleting substances and targeted
ethylene glycol ethers during the next 15 years. The Roadmap identifies
46 projects for implementation in 1994 that involved process
modifications. The majority of the process modifications center
around alternatives to wet chemical processes and continued progress
in development of alternative technologies for applying layers of
silicon to the wafer. The development of water-based (or gas process)
cleaners and resists is also a priority.
VIII.C.2.
Trade Associations
Electronic Industries Association (EIA)
2500 Wilson Boulevard
Arlington, VA 22201
Phone: (703) 907-7500
Fax: (703) 907-7501
Members: 1200
Staff: 150
Budget: $25,000,000
Contact: Peter McCloskey
EIA was founded in 1924, and represents manufacturers of electronic
components, parts, systems, and equipment for communications,
industrial, government, and consumer use. EIA publishes a free,
semiannual EIA Publications Index that contains price, content, and
ordering information for their publications. EIA works to develop
sound environmental practices by promoting research, workshops,
and tool development through a variety of industry committees.
September 1995
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Sector Notebook Project
American Electronics Association (AEA)
5201 Great American Parkway, Suite 520
Santa Clara, CA 95054
Phone: (408) 987-4200
Fax: (408) 970-8565
Members: 3500
Staff: 140
Budget: NA
Contact: J. Richard Iverson
AEA was founded in 1943, and is a trade association that represents
the U.S. electronics/computer industry. Formerly known as the West
Coast Electronic Manufacturer Association (WEMA), AEA's programs
and services include: public affairs, educational meetings conferences,
and executive summits. AEA publishes an annual directory; a
monthly association and trade news publication, American Electronics
Association, which includes legislative briefs, industry statistics, and a
calendar of events; a periodic California Legislative Bulletin; and
handbooks, manuals, and surveys. In addition, AEA sponsors an
annual Systems/USA trade show.
National Electronic Manufacturing Association
(NEMA)
2101 L Street, NW, Suite 300
Washington, DC 20037
Phone: (202) 457-8400
Fax: (202) 457-8411
Members: 600
Staff: 100
Budget: $10,000,000
Contact: Malcolm O'Hagan
NEMA was established in 1926. NEMA represents companies that
manufacture equipment used for the generation, transmission,
distribution, control, and utilization of electric power. NEMA was
formed by the merger of Associated Manufacturers of Electrical and
Supplies and the Electronic Power Club. NEMA's areas of interest
include: electrical machinery; motors; and industrial automation,
construction, utility, medial diagnostic imaging, transportation,
communication, and lighting equipment. NEMA's objectives are to
maintain and enhance the quality and reliability of products, ensure
safety standards in the manufacturing and use of products, and to
organize and act upon members' interest in areas such as energy
conservation, efficiency and foreign competition. NEMA conducts
regulatory and legislative analysis on issues of concern to electronic
manufacturers, and compiles periodic summaries of statistical data on
sales and production. In addition, NEMA publishes a periodic
directory; a free, semiannual catalog of its publications and materials;
Tech Alert bimonthly; and manuals, guidebooks, and other material on
wiring, equipment installation, lighting, and standards.
SIC Code 36
132
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Sector Notebook Project
Electronics and Computer Industry
Semiconductor Equipment and Materials
International (SEMI)
805 E. Middlefield Road
Mountain View, CA 94043
Phone: (415) 964-5111
Fax: (415) 967-5375
Members: 1750
Staff: NA
Budget: NA
Contact: William H. Reeds
SEMI was founded in 1970, and represents firms, corporations, and
individuals who participate in supplying fabrication equipment,
materials, or services to the semiconductor industry. SEMI operates an
industry data collection program, conducts SEMI Technical Education
Programs, and provides an annual Information Services Seminar (ISS)
forecast. SEMI is the former Semiconductor Equipment and Materials
Institute. SEMI publishes an annual Book of SEMI Standards, the annual
Business Outlook for the Semiconductor Equipment and Materials Industry,
a bimonthly newsletter providing general industry news; a quarterly
newsletter, SEMI Outlook, that provides information on industry
trends, analyses, and opinions; and the SEMICON Technical
Proceedings which contains the proceedings and paper topics from the
Institute's technical symposia.
Institute for Interconnecting and Packaging
Electronic Circuits (IPC)
2215 Sanders Road, Suite 200 South
Northbrook, IL 60062
Phone: (708) 677-2850
Fax: (708) 677-9570
Members: 1900
Staff: 42
Budget: NA
Contact: Thomas Dammrich
Founded in 1957, IPC represents companies that produce and use
electronic interconnections for electronic equipment. IPC's primary
members are independent PWB manufacturers and contract assembly
companies that mount components onto bare PWBs to produce printed
wiring assemblies (PWAs) or electronic assemblies. IPC also
represents original equipment manufacturers (OEMs), suppliers,
academia, and technical members of the industry. IPC has over 100
committees, that cover all aspects of the industry including: technical
standards; specifications and guidelines; education and training;
technology research and development; market research and
publications; management practices; environmental and safety
programs; and government regulations.
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Sector Notebook Project
Semiconductor Industry Association (SIA)
4300 Stevens Creek Boulevard
Suite 271
San Jose, CA 95129
Phone: (408) 246-2711
Fax: (408) 246-2830
Members: 40
Staff: 14
Budget: $2,000,000
Contact: Andrew Procassini
SIA represents companies that produce semiconductor products
including discrete components, integrated circuits, and
microprocessors. This association compiles industry trade statistics
and maintains a private library and sponsors the Semiconductor
Research Corporation and SEMATECH. SIA's publications include the
following: Circuit, a free, quarterly newsletter; Semiconductor
Yearbook and Directory, which contains a review of programs
sponsored by the association, key industry statistics, analyses by
industry experts, public policy discussions, and sales volume; and
essays, research reports, and proceedings.
Computer and Communications Industry
Association (CCIA)
666 11th Street, NW
Washington, DC 20001
Phone: (202) 783-0070
Fax: (202) 783-0534
Members: 60
Staff: 10
Budget: $1,000,000
Contact: A.G.W. Biddle
Comprised of computer manufacturers, CCIA provides information
processing and telecommunication-related products and services.
CCIA represents the interests of its members before Congress, Federal
agencies, and the courts in the areas of domestic and foreign trade, tax
policy, Federal procurement policy, and telecommunication policy. It
hosts policy briefings on legislative and regulatory matters to keep
members aware of policy, political, technological, and market and
economic developments and trends. CCIA publishes CEO Report
semimonthly and Federal Procurement Policy Report, International Trade
Report, and Telecommunication Report on a monthly basis.
SIC Code 36
134
September 1995
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Sector Notebook Project Electronics and Computer Industry
IX. BIBLIOGRAPHY/OTHER MATERIALS AVAILABLE
For further information on selected topics within the electronic and computer
industries, a list of publications are provided below:
General Profile
1992 Census of Manufacturers Industry Series: Preliminary Report, Bureau of the Census,
November 1994. (MC92-1 - 36 E(P)).
1987 Census of Manufacturers Industry Series 36A: Electronic Transmission and
Distribution Equipment, Bureau of the Census, April 1990. (MC87-I-36A).
1987 Census of Manufacturers Industry Series 36B: Household Appliances, Bureau of the
Census, April 1990. (MC87-I-36B).
1987 Census of Manufacturers Industry Series 36C: Electric Lighting and Wiring
Equipment, Bureau of the Census, April 1990. (MC87-I-36C).
1987 Census of Manufacturers Industry Series 36D: Communication Equipment, Bureau
of the Census, April 1990. (MC87-I-36D).
1987 Census of Manufacturers Industry Series 36E: Electronic Components, Bureau of the
Census, April 1990. (MC87-I-36E).
1987 Census of Manufacturers Industry Series 36F: Miscellaneous Electrical Equipment
and Supplies, Bureau of the Census, April 1990. (MC87-I-36F).
1992 Globalisation of Industrial Activities: Four Case Studies: Auto Parts, Chemicals,
Construction and Semiconductors. Organization for Economic Co-Operation and
Development, Paris, 1992.
American Electronics Association (AEA), Personal communication with Roger Stabeele,
February 8, 1994.
Annual 1993 Current Industrial Reports MA36QSemiconductors, Printed Circuit
Boards, and Other Electronic Components, Bureau of the Census Bulletin Board Service,
Washington, D.C., 1994.
Annual 1992 Current Industrial Reports MA36Q(92)-ISemiconductors, Printed Circuit
Boards, and Other Electronic Components, Bureau of the Census Bulletin Board Service,
Washington, D.C.
September 1995 135 SIC Code 36
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Electronics and Computer Industry Sector Notebook Project
Burris, G.R., Manager of Corporate Environmental Engineering, Indianapolis, IN.
Background information on cathode ray tubes, 1995.
Developing The Electronics Industry, Bjorn Wellenius, The World Bank, 1993.
Dun & Bradstreet, Dun's Market Identifiers, DIALOG Information Services, 1994.
Electronic Industry Environmental Roadmap, Microelectronics and Computer
Technology Corporation (MCC), Austin, TX, 1994.
Electronic Industries Association (EIA), Arlington, VA, News release dated January 2,
1995.
Electronic Market Data Book, EIA, Arlington, VA, ,1994.
Encyclopedia of Associations, 27th ed., Deborah M. Burek, ed., Gale Research Inc.,
Detroit, Michigan, 1992.
Enforcement Accomplishments Report, FY1991, U.S. EPA, Office of Enforcement
(EPA/300-R92-008), April 1992.
Enforcement Accomplishments Report, FY 1992, U.S. EPA, Office of Enforcement
(EPA/230-R93-001), April 1993.
Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of Enforcement
(EPA/300-R94-003), April 1994.
Federal Environmental Regulations Potentially Affecting The Computer Industry, U.S.
EPA, Office of Pollution Prevention and Toxics (EPA 744-B-93-002), April 1994.
Getting A Charge Out Of The Waste Stream, David Hurd, New York State Department
of Economic Development, February 1992.
Industry and Trade Summary: Semiconductors, U.S. International Trade Commission,
December 1993.
Institute for Interconnecting and Packaging Electronic Circuits (IPC), Washington, DC.
Background information on printed wiring boards, 1995.
Options Proposed for Managing Discarded Fluorescent and Other Lights that Contain
Mercury, Environmental Fact Sheet, U.S. EPA, Solid Waste and Emergency Response
(EPA 530-F-94-022), July 1994.
Polychlorinated Biphenyl (PWB) Information Package, TSCA Information Service, April
1993.
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Sector Notebook Project Electronics and Computer Industry
Standard Industrial Classification Manual, Office of Management and Budget, 1987.
U.S. Industrial Outlook 1994, Department of Commerce 1994.
Process Descriptions, Release Profiles, and Pollution Prevention
1992 Toxic Release Inventory (TRI) Public Data Release, U.S. EPA, Office of Pollution
Prevention and Toxics, April 1994. (EPA/745-R94-001)
Circuit Board Packet, U.S. EPA, Pollution Prevention Information Center.
Case Studies from the Minnesota Technical Assistance Program and the Oregon Hazardous
Waste Reduction Program: Metal Finishing, U.S. EPA, Office of Environmental
Engineering and Technology Demonstration and the Office of Pollution Prevention,
November 1989.
Case Studies from the Pollution Prevention Information Center (PPIC): Electroplating,
U.S. EPA, Office of Environmental Engineering and Technology Demonstration and
the Office of Pollution Prevention, November 1989.
Electroplating Packet, U.S. EPA, Pollution Prevention Information Center.
Facility Pollution Prevention Guide, U.S. EPA, Office of Research and Development
(EPA/600/R-92/088), May 1992.
"Etching Away with Ion Beams", The Washington Post, Elizabeth Corcoran, April 18,
1995, p. Dl.
Guidelines for Waste Reduction and Recycling: Metal Finishing, Electroplating, and
Printed Circuit Board Manufacturing, Oregon Department of Environmental Quality,
Hazardous Waste Reduction Program, July 1989.
Green Lights: Third Annual Report, U.S. EPA, Office Air and Radiation (EPA 430-R-94-
005), March 1994.
Hazard Assessment and Control Technology in Semiconductor Manufacturing II,
American Conference of Government Industrial Hygienists, 1993.
Industry Profile and Description of chemical for the Semiconductor Industry, March 1993.
Industry Profile for the Metal Finishing Industry: Preliminary Draft, U.S. EPA, Office of
Pollution Prevention and Toxics, Design for the Environment, June 24, 1994.
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Electronics and Computer Industry Sector Notebook Project
Industry Profile and Description of Chemical Use for the Printed Wiring Board Industry:
Preliminary Draft, U.S. EPA, Office of Pollution Prevention and Toxics, Design for
the Environment, March 1993.
Industry Profile and Description of Chemical Use for the Semiconductor Industry:
Preliminary Draft, U.S. EPA, Office of Pollution Prevention and Toxics, Design for
the Environment, March 1993.
Light Brief: Green Lights Program, U.S. EPA, Office Air and Radiation (EPA 430-F-92-
009), August 1992.
Lighting Waste Disposal, U.S. EPA Office Air and Radiation, January 1994.
McGraw-Hill Encyclopedia of Science & Technology, vols. 4, 6, 7, 9, 11, 14, 16, 17,18, 19
McGraw-Hill Book Company, New York, New York, 1987, 1992.
Metals Handbook: Cleaning and Finishing Stainless Steel, 9th ed., American Society for
Metals, 1982.
Metals Handbook: Fabrication of Wrought Stainless Steel, 9th ed., American Society for
Metals, 1982.
Microchip Fabrication: A Practical Guide to Semiconductor Processing, 2nd ed., Peter
Van Zant, McGraw Hill, Inc. 1990.
Metal Industries - Metal Finishing Manufacturing Packet, U.S. EPA, Pollution
Prevention Information Center.
Pollution Prevention 1991 Progress on Reducing Industrial Pollutants, U.S. EPA, Office
of Pollution Prevention (EPA 21 P-3003), October 1991.
Pollution Prevention in Metal Manufacturing: Saving Money Through Pollution
Prevention, U.S. EPA, Office of Pollution Prevention and Toxics (EPA/530-SW-
89/056), October 1989.
Pollution Prevention Research Project: Evaluation of Alternatives to Halogenated Solvents
for Cleaning and Drying Printed Circuit Boards-Final Report, Minnesota Office of Waste
Management and Capsule Environmental Engineering Inc., July 30, 1992.
Printed Circuit Board Basics: Quick and Easy Guide, 2nd Ed., Michael Flatt, 1992.
Semiconductor Business: The Economics of Rapid Growth and Decline, Franco Malerba,
University of Wisconsin, 1985.
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Sector Notebook Project Electronics and Computer Industry
Semiconductor Technology for the Non-Technologist, 2nd ed., Robert I. Scace, U.S.
Department of Commerce, September 1990.
Sustainable Industry: Promoting Strategic Environmental Protection in the Industrial
Sector, Phase 1 Report, U.S. EPA, Office of Emergency and Remedial Response, June
1994.
Title II Section 313 Release Reporting Guidance: Estimating Chemical Releases from
Semiconductor Manufacturing, U.S. EPA, Office of Pesticides and Toxic Substances
(EPA 560/4-88-004e), January 1998.
Contacts* Organization Telephone
John Kim EPA Region IX Inspector 415-744-1263
Greg Arthur EPA Region IX Inspector 415-744-1900
Bill Hurley AEA 408-987-4200
Debbie Boger EPA Design for the Environment 202-260-0880
Steven Pederson MCC 512-250-2758
Karen Phillips EPA Region IX Inspector 415-749-4979
Dave Dellarco EPA Region X, Office of Policy, 206-553-4978
Planning, and Pollution Prevention
Daryl Burns CA Air Resource Board 916-445-0960
Jack Bean EPA Region IX, Air Quality Manager 415-749-4748
Michael Avery West Coast Circuits, Inc. 408-728-4271
Christopher Rhodes IPC 708-677-2850
Melissa Coggeshall Carey EIA 703-907-7501
George Burris Thompkins Consumer Electronics 317-587-4335
BillRowe Zenith 708-450-4122
Many of the contacts listed above have provided valuable background information and
comments during the development of this document. EPA appreciates this support and
acknowledges that the individuals listed do not necessarily endorse all statements made within
this notebook.
September 1995 139 SIC Code 36
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