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
                   iii
                 SIC Code 36

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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.
SIC Code 36                              iv                               September 1995

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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
September 1995                       v                             SIC Code 36

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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
SIC Code 36                           vi                          September 1995

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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
SIC Code 36
viii
September 1995

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Sector Notebook Project
             Electronics and Computer Industry
                   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
IX
                               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
xi
SIC Code 36

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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
xii
September 1995

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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.
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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.
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                                    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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                                   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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              Electronics and Computer Industry
                                     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.
September 1995
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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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Sector Notebook Project
             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
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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
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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

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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.
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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
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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.
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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.

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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

-------
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

-------
 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

-------
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

-------
 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

-------
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

-------
 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

-------
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
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                      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.
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              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
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                                   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
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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.
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             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.
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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
SIC Code 36                          66                           September 1995

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Sector Notebook Project	Electronics and Computer Industry


            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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 Electronics and Computer Industry	Sector Notebook Project


            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).
SIC Code 36                          68                           September 1995

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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
69
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 Electronics and Computer Industry	Sector Notebook Project
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
71
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 Electronics and Computer Industry
                        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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Sector Notebook Project	Electronics and Computer Industry
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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Sector Notebook Project	Electronics and Computer Industry


             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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 Electronics and Computer Industry	Sector Notebook Project
       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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       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.
September 1995                             77                                   SIC Code 36

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 Electronics and Computer Industry	Sector Notebook Project
       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.
September 1995
                         103
SIC Code 36

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 Electronics and Computer Industry	Sector Notebook Project


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

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 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

-------
 Electronics and Computer Industry
                       Sector Notebook Project
                                    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.
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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

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             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
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            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)
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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.
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            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.
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             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.
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             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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             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.
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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 MA36Q—Semiconductors, 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)-I—Semiconductors, Printed Circuit
Boards, and Other Electronic Components, Bureau of the Census Bulletin Board Service,
Washington, D.C.
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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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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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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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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.
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