United States
Environmental Protection
Agency
Office of the
Administrator
[Mail Code 1802]
EPA-1OO-F-00-020
July 2000
(http://www.epa.gov)
&EPA
WHAT IS
PROJECT XL?
SUMMARY OF
THE IBM-VT
PROJECT
SUPERIOR
ENVIRONMENTAL
PERFORMANCE
Project XL: IBM
Essex Junction, Vermont
Project XL, which stands for "excellence and Leadership," is a national
initiative that tests innovative ways of achieving better and more cost-effective
public health and environmental protection. The information and lessons
learned from Project XL are being used to assist the U.S. Environmental
Protection Agency (EPA) in redesigning its current regulatory and policy-
setting approaches. Project XL encourages testing of cleaner, cheaper, and
smarter ways to attain environmental results superior to those achieved under
current regulations and policies, in conjunction with greater accountability to
stakeholders. It is vital that each project tests new ideas with the potential for
wide application and broad environmental benefits. As of July 2000, twenty-six
pilot experiments are being implemented and over thirty additional projects are
in various stages of development.
IBM's Essex Junction, Vermont, semiconductor facility recently introduced a
new, innovative copper metallization step into their semiconductor chip
manufacturing process. This new process is significantly more energy efficient
than its predecessor, produces chips that are faster and more energy efficient,
and greatly reduces the use of Perfluorinated Compounds (PFCs), which are
greenhouse gases, for chamber cleaning. However, because this process uses an
electroplating technique, the treatment of the rinsewaters, which are combined
with other process wastewaters generated at the facility, generates sludge that is
currently regulated under the Resource Conservation and Recovery Act
(RCRA) as F006 waste. IBM maintains that the F006 classification fails to
provide any additional environmental protection, and imposes a regulatory
burden on a process that does not use any materials that were the basis for the
original listing and therefore should not be subject to those regulations.
Through Project XL, IBM seeks a site-specific exemption from the RCRA F006
listing for the copper metallization process. In addition, IBM has engaged in
other voluntary efforts to reduce greenhouse gas emissions in its remaining
silicon dioxide chamber cleaning processes.
Several benefits will result directly from the site-specific exemption for the
copper metallization process. These benefits include:
• A reduction in the quantity of waste defined as hazardous generated by the
Essex Junction facility;
• A rationalization of the RCRA F006 listing as it applies to this process;
• The minimization of the use of PFCs, which are greenhouse gases, used as
chamber cleaning compounds in the manufacturing process;
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FLEXIBILITY
STAKEHOLDER
INVOLVEMENT
APPROACHES TO
BE TESTED
CONTACTS
• A decrease in the IBM, State of VT, and EPA administrative requirements.
Perhaps the most notable benefit to this XL project is that it highlights and
promotes a new process - copper metallization - which has the potential to
impact the electronics industry in profound ways. This new process is
approximately 30-40% more energy efficient than the previous one and
produces a chip that is approximately 25% more energy efficient than its
predecessor. If this process is eventually used by other semiconductor facilities,
the results of this project may encourage more efficient production methods
with corresponding reductions in waste generation per unit output, as well as
other benefits associated with energy efficiency, such as natural resource
conservation, air quality improvements, and decreased impact on climate
change.
IBM has proposed that EPA exempt the wastewater treatment sludge produced
from this new copper metallization process from the RCRA F006 definition
through a site-specific rulemaking. Through this proposal, IBM seeks to
exempt the manufacturing process — specifically copper metallization — rather
than delisting the wastewater treatment sludge, which would normally occur
through EPA's delisting process under RCRA regulations.
IBM solicited input on this project from a wide range of stakeholders including
local and national environmental groups, neighborhood associations, and
industry trade associations. Stakeholders were notified of this project by direct
mail, telephone, and announcement in the local press. Additional information is
available from the project contacts as well as EPA's website.
The Agency is evaluating whether IBM's process is capable of generating a
hazardous waste rather than conducting an "end of pipe" analysis of the
wastewater treatment sludge. This approach can provide the Agency with a
new methodology for evaluating the applicability of its regulations to specific
activities.
Regional Contact: JohnMoskal 617-918-1826
EPA/XL HQ: Chad Carbone 202-260-4296
State Contact: Paul Van Hollebeke 802-241-3629
Project Sponsor: Jay M. Dietrich 802-769-4046
More information about Project XL is available on the Internet at
FOR ELECTRONIC http://www.epa.gov/ProjectXL, or via Project XL's Information Line at 202-
INFORMATION 260-5754
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