SEPA— United States Environmental Protection Agency Electrical & Electronic Components (40 CFR Part 469) Detailed Study Report November 2022 ------- THIS PAGE INTENTIONALLY LEFT BLANK ------- U.S. Environmental Protection Agency Office of Water (4303T) 1200 Pennsylvania Avenue, NW Washington, DC 20460 EPA-821-R-22-005 DCN 11197 ------- THIS PAGE INTENTIONALLY LEFT BLANK ------- Contents 1. Electrical and Electronic Components (40 CFR Part 469) 1 1.1 Overview of Existing E&EC Effluent Limitations Guidelines and Standards (ELGs) 1 1.1.1 Phase I: Semiconductors and Electronic Crystals 3 1.1.2 Phase II: Cathode Ray Tubes and Luminescent Materials 4 1.1.3 Wastewater Treatment Technology Bases for Pollutant Limitations in the E&EC Category 5 1.1.4 Other Point Source Categories Related to E&EC 6 1.2 E&EC Industry Profile 7 1.2.1 Facilities and Wastewater Discharge Practices 7 1.2.2 1983 E&EC Process Operations 8 1.2.3 Current E&EC Process Operations 11 1.3 References 15 2. Discharge Regulatory Framework 17 2.1 Indirect Dischargers Subject to the Pretreatment Standards Under the National Pretreatment Program 17 2.1.1 Pretreatment Standards 17 2.1.2 Pretreatment Control Authorities 17 2.1.3 Local limits and other potentially applicable pretretment standards 18 2.2 Direct Dischargers Subject to NPDES Permitting 18 2.3 E&EC Facility Discharge Requirements 19 2.3.1 Indirect Dischargers 20 2.3.2 Direct Dischargers 21 2.3.3 Solvent Management Plans in Lieu of Monitoring 21 2.3.4 Data Quality and Limitations 22 2.4 References 22 3. Wastewater Characterization 23 3.1 E&EC Wastewater Discharge Characterization and Identification of Parameters of Interest 23 3.1.1 E&EC Wastewater Discharge Characterization Data 23 3.1.2 Parameters of Interest 25 3.2 Wastewater Characterization Data Discussion 31 3.2.1 E&EC Wastestreams 31 3.2.2 Data Quality and Limitations 31 3.3 Additional E&EC Wastewater Characterization Review 32 3.4 E&EC Wastewater Treatment Technologies 33 ------- 3.5 References 36 4. Potential Impacts from E&EC Wastewater Discharges 37 4.1 Waste Management and Wastewater Treatment Prior to Discharge 37 4.2 Potential Emerging Parameters of Interest 37 4.2.1 PFAS 38 4.2.2 Gallium and Germanium 39 4.3 Potential Impacts from Indirect Discharges of E&EC Wastewater 40 4.4 Potential Impacts from Direct Discharges of E&EC Wastewater 41 4.5 Summary of Findings from EPA's Review of the E&EC Category 41 4.6 References 43 Attachments Attachment A : Summary of E&EC Permitting Information Attachment B : Summary of E&EC Wastewater Discharge Characterization Attachment C : Review of Potential Impacts from Indirect and Direct Discharges of E&EC Wastewaters ------- List of Figures Figure 1. 1983 Silicon Integrated Circuit Production 9 Figure 2. Basic Manufacturing Processes for Electronic Crystals in 1983 10 Figure 3. Updated Silicon Integrated Circuit Production 13 List of Tables Table 1. Regulated Pollutants for E&EC Category 2 Table 2. TTO Pollutants for Subpart A (Semiconductors) and Subpart B (Electronic Crystals) 4 Table 3. TTO Pollutants for Subpart C (CRTs) 4 Table 4. Wastewater Treatment Technology Bases for the E&EC Category 5 Table 5. Facility Information for 1983 Industry Profile 7 Table 6. Summary of Facility Contacts for the Semiconductor Industry 14 Table 7. E&EC Permitted Facilities in E&EC Study Permit Database 19 Table 8. Solvent Management Plans E&EC Permitted Facilities in E&EC Study Permit Database 21 Table 9. Data Collection by Point Source Category and E&EC Subcategory 24 Table 10. Data Collection by State 24 Table 11. Analytes by Pollutant Category 25 Table 12. E&EC Industry Parameters of Interest - Indirect Dischargers 27 Table 13. E&EC Industry Parameters of Interest - Direct Discharges 29 Table 14. Summary of Wastewater Treatment Technologies for Electrical and Electronic Components Wastewater 35 ------- Abbreviations BAT Best Available Technology Economically Achievable BCT Best Conventional Pollutant Control Technology BODs five-day biological oxygen demand BPT Best Practicable Control Technology Currently Available C4 controlled collapse chip connection CFR Code of Federal Regulations ClUs categorical industrial users COD chemical oxygen demand CMP chemical mechanical planarization CP chemical precipitation CRTs cathode ray tubes CVD chemical vapor deposition DMR discharge monitoring report E&EC Electrical & Electronic Components ELG effluent limitations guidelines and standards EPA Environmental Protection Agency ERG Eastern Research Group, Inc. LCD liquid crystal display LED light-emitting diode MGD million gallons per day NACWA National Association of Clean Water Agencies NPDES National Pollutant Discharge Elimination System NSPS New Source Performance Standards OLED organic light-emitting diode PFAS per- and polyfluoroalkyl substances PFBS perfluorobutane sulfonic acid PFOA perfluorooctanoic acid PFOS perfluorooctane sulfonic acid POTW publicly owned treatment works PSES Pretreatment Standards for Existing Sources ------- PSNS Pretreatment Standards for New Sources SIC Standard Industrial Classification TFT-LCD thin-film transistor liquid crystal display TRI Toxics Release Inventory TSS Total Suspended Solids V ------- 1. Electrical and Electronic Components (40 CFR Part 469) As part of the 2015 Annual Review, EPA initiated a preliminary review of the Electrical and Electronic Components (E&EC) Category in response to stakeholder comments received during a 2014 National Association of Clean Water Agencies (NACWA) conference regarding the applicability of the effluent limitations guidelines and standards (ELGs) to the manufacture of sapphire crystals. Stakeholders expressed concerns about potential new pollutants of concern in the wastewater discharges from the manufacture of sapphire crystals (now commonly used in electronic devices), which they believe EPA did not consider during the development of the E&EC ELGs. While the E&EC ELGs do not specifically mention sapphire crystals, from the 2015 Annual Review EPA determined that Subpart B - Electronic Crystals covers wastewater discharges generated from growing sapphire crystals and producing sapphire crystal wafers. Sapphire crystals are a crystal or crystalline material used in the manufacture of electronic devices because of their unique structural and electronic properties, and therefore, meet the applicability requirements of Subpart B. Additionally, EPA determined that sapphire-crystal wafer production likely generates wastewater in the form of slurries and acids and confirmed that nanodiamonds (the manufacture of which could also be covered by this rule) are used in sapphire crystal polishing slurries. In addition, EPA, at that time, identified several facilities in the U.S. that are currently manufacturing sapphire crystals and wafers. Following these preliminary findings, EPA determined that further review of the E&EC ELGs was appropriate. EPA promulgated the E&EC ELGs (40 CFR part 469) in 1983. Given the age of the ELGs and the changes that have occurred in the industry since their promulgation, EPA expanded the 2016 Annual Review to include the entire E&EC Category, not just sapphire crystal manufacturing. The 1983 ELGs set limitations for four subcategories: semiconductors, electronic crystals, cathode ray tubes (CRTs), and luminescent materials. EPA further evaluated each of the four subcategories to: • Understand the current U.S. E&EC industry and the extent to which it has changed since the promulgation of the ELGs. • Identify which E&EC manufacturers discharge wastewater, whether they discharge directly or indirectly, what pollutants are discharged, and what electronics and electrical components they manufacture. • Further understand and identify changes to the manufacturing steps associated with new E&EC operations since the 1983 rulemaking that may impact wastewater characteristics or management. • Evaluate advancements in wastewater treatment technologies employed by facilities in the E&EC industry. Section 1.1 provides details on the E&EC ELGs. Section 1.2 describes the industry profile, including facility types, process operations, and wastewater discharge practices in 1983 and the present. 1.1 Overview of Existing E&EC Effluent Limitations Guidelines and Standards (ELGs) EPA promulgated the existing E&EC ELGs (40 CFR part 469) in 1983, which established the Best Practicable Control Technology (BPT), Best Available Technology Economically Achievable (BAT), Best Conventional Pollutant Control Technology (BCT), Pretreatment Standards for Existing Sources (PSES), New Source Performance Standards (NSPS), and Pretreatment Standards for New Sources (PSNS) for the E&EC industry. EPA divided the E&EC Industry into four subcategories based on manufacture of the following products: semiconductors, electronic crystals, CRTs, and luminescent materials. EPA promulgated the E&EC ELGs in two phases: Phase I, published in April 1983, contains the ELGs for Subparts A (semiconductors) and B (electronic crystals) (U.S. EPA, 1983a); and Phase II, published in 1 ------- December 1983, contains the ELGs for Subparts C (CRTs) and D (luminescent materials) (U.S. EPA, 1983b). Table 1 lists the regulated pollutants by subcategory for the 1983 E&EC ELGs. Table 1. Regulated Pollutants for E&EC Category Subpart Subcategory Total Toxic Organics3 Antimony Arsenicb Cadmium Chromium Fluoride Lead T. Q. 1/1 £ o c M BPT (Best Practicable Control Technology) A Semiconductors ~ ~ B Electronic Crystals ~ ~ ~ ~ ~ BAT (Best Available Technology Economically Achievable) A Semiconductors ~ ~ B Electronic Crystals ~ ~ ~ BCT(Best Conventional Pollutant Control Technology) A Semiconductors ~ B Electronic Crystals ~ ~ PSES (Pretreatment Standards for Existing Sources) A Semiconductors ~ B Electronic Crystals ~ ~ C Cathode Ray Tubes ~ ~ ~ ~ ~ ~ NSPS (New Source Performance Standards) A Semiconductors ~ ~ ~ B Electronic Crystals ~ ~ ~ ~ ~ C Cathode Ray Tubes ~ ~ ~ ~ ~ ~ ~ ~ D Luminescent Materials ~ ~ ~ ~ ~ ~ PSNS (Pretreatment Standards for New Sources) A Semiconductors B Electronic Crystals 2 ------- Table 1. Regulated Pollutants for E&EC Category Subpart Subcategory Total Toxic Organics3 Antimony Arsenicb Cadmium Chromium Fluoride Lead =C CL TSS Zinc C Cathode Ray Tubes D Luminescent Materials Sources: U.S. EPA, 1983a; U.S. EPA, 1983b. TSS - Total Suspended Solids a Total toxic organics (TTO) indicates the sum of the concentrations for each of the toxic organic compounds which are found in the wastewater discharge at a concentration greater than 10 |ig/L. Table 2 and Table 3 provide the list of regulated toxic organic compounds for Subparts A, B, and C. b For Subpart B the arsenic limitation only applies for facilities manufacturing gallium-, or indium-arsenide crystals. EPA established the E&EC ELGs specific to each subcategory based on their different raw materials, final products, manufacturing processes, geographical location, plant-size and age, wastewater characteristics, non-water quality environmental impacts, treatment costs, energy costs, and solid waste generation (U.S. EPA, 1983a; U.S. EPA, 1983b). The following subsections describe the two phases of the E&EC ELG development in more detail, the wastewater treatment technology bases for the ELGs, and other point source categories related to E&EC. 1.1.1 Phase I: Semiconductors and Electronic Crystals In April 1983, EPA promulgated the Phase I E&EC ELGs for Subpart A (Semiconductors) and Subpart B (Electronic Crystals) (U.S. EPA, 1983a). As part of this rulemaking, EPA gathered industry analytical data to characterize wastewater discharges from semiconductor and electronic crystal manufacturing facilities. EPA excluded 95 pollutants from regulation because they were 1) non-detectable with 1983 EPA analytical methods (82 pollutants), 2) present in concentrations too small to be effectively treated (antimony, beryllium, cadmium, mercury, selenium, thallium, zinc, and cyanide), or 3) subject to Metal Finishing ELGs (nickel, copper, chromium, and lead).1 In addition to the exclusion of the ninety-five pollutants for both subparts, another toxic pollutant was excluded for the Semiconductor subpart only. This pollutant was arsenic and was excluded as it was present in concentrations too small to be effectively treated. EPA ultimately established limitations for fluoride (Subpart B only), toxic organics, arsenic (Subpart B only), pH, and total suspended solids (subpart B only).2 Since semiconductor and electronic crystal manufacturers use a wide variety of solvents, EPA identified several toxic organics that may be present in the untreated wastewater. Therefore, EPA established limitations for total toxic organics (TTO). EPA defined TTO, for Subparts A and B, as the sum of the concentrations of toxic organics listed in Table 2 with discharge concentrations greater than ten (10) micrograms per liter (|ag/L) per pollutant (U.S. EPA, 1983a). 1 See Section 1.1.4 for a discussion on the overlap between the E&EC and Metal Finishing ELGs. 2 The E&EC ELGs reference the regulated pollutants for each subpart as the only pollutants of concern identified during the rulemaking (U.S. EPA 1983a; U.S. 1983b). 3 ------- Table 2. TTO Pollutants for Subpart A (Semiconductors) and Subpart B (Electronic Crystals) List of TTO Pollutants for Semiconductors and Electronic Crystals anthracene 1,3-dichlorobenzene Isophorone toluene bis(2-ethylhexyl)phthalate 1,4-dichlorobenzene methylene chloride 1,2,4-trichlorobenzene butyl benzyl phthalate Dichlorobromoethane Naphthalene 1,1,1-trichloroethane carbon tetrachloride 1,2-dichloroethane 2-nitrophenol 1,1,2-trichloroethane chloroform 1,1-dichloroethylene 4-nitrophenol trichloroethylene 2-chlorophenol 2,4-dichlorophenol pentachlorophenol 2,4,6-trichlorophenol di-n-butyl phthalate 1,2-diphenylhyd razine Phenol 1,2-dichlorobenzene ethyl benzene tetrachloroethylene Source: U.S. EPA, 1983a. 1.1.2 Phase II: Cathode Ray Tubes and Luminescent Materials In December 1983, EPA promulgated the Phase II E&EC ELGs for Subpart C (CRTs) and Subpart D (Luminescent Materials) (U.S. EPA, 1983b). EPA gathered industry analytical data to characterize wastewater discharged from the manufacture of CRTs and luminescent materials. EPA originally divided the Electron Tube subcategory into CRTs and Receiving and Transmitting Tubes (RTT) subcategories; however, EPA determined RTT manufacturing operations do not discharge wastewaters and only promulgated limitations for CRTs. Further, EPA did not establish limitations for existing source direct dischargers in the CRT subcategory. Only one facility directly discharged, and it operated a chemical precipitation plus filtration treatment system and the discharge of toxic pollutants was less than two pounds per day after treatment. Similarly, EPA did not establish limitations or pretreatment standards for existing dischargers in the Luminescent Materials subcategory due to the small number of facilities in the subcategory (five) and because the amount of toxic metals discharged to surface water (less than one pound per facility per day) and toxic pollutants introduced to publicly operated treatment works (POTWs) was insignificant at the time of promulgation (U.S. EPA, 1983b). For CRT manufacturing, EPA excluded 116 pollutants from regulation because they were either non- detectable by 1983 EPA analytical methods (106 pollutants) or present in concentrations too small to be effectively treated (antimony, arsenic, beryllium, copper, mercury, nickel, selenium, silver, thallium, cyanide) (U.S. EPA, 1983b). EPA established limitations for cadmium, chromium, lead, zinc, TTO, fluoride, pH, and total suspended solids for the CRT manufacturing subcategory. Similar to semiconductors and electronic crystals, CRT manufacturers use a wide variety of solvents, and EPA identified several toxic organics that may be present in the untreated wastewater. Therefore, EPA established limitations for TTO. For the CRT subcategory, EPA defined TTO as the sum of the concentrations of the toxic organics listed in Table 3 with concentrations greater than ten (10) micrograms per liter (|ag/L) per pollutant (U.S. EPA, 1983b). Table 3. TTO Pollutants for Subpart C (CRTs) List of TTO Pollutants for CRTs Chloroform methylene chloride 1,1,1-trichloroethane bis(2-ethylhexyl)pthalate Toluene trichloroethylene Source: U.S. EPA, 1983b. 4 ------- For luminescent material manufacturing, EPA excluded 123 pollutants from regulation because they were either non-detectable with 1983 EPA analytical methods (114 pollutants) or present in concentrations too small to be effectively treated (arsenic, beryllium, copper, mercury, nickel, selenium, silver, thallium, cyanide). EPA established limitations for cadmium, antimony, zinc, fluoride, pH, and total suspended solids for the luminescent material subcategory (U.S. EPA, 1983b). No limitations were established for TTO. 1.1.3 Wastewater Treatment Technology Bases for Pollutant Limitations in the E&EC Category The E&EC ELGs established pollutant limitations for the E&EC Category generally based on solvent management3 (to control TTO), neutralization, chemical precipitation with clarification (hydroxide), in- process control for specific pollutants,4 and filtration. EPA only established limitations for CRT manufacturing operations for PSES, NSPS, and PSNS. For luminescent materials manufacturing, limitations were established for NSPS and PSNS. Table 4 presents the general wastewater treatment technology basis by subcategory and level of control. Table 4. Wastewater Treatment Technology Bases for the E&EC Category Chemical In Process Subpart Subcategory Solvent Management Neutralization Precipitation with Clarification3 Control for Lead and Chromium Filtration BPT (Best Practicable Control Technology) A Semiconductors B Electronic Crystals BAT (Best Available Technology Economically Achievable) A Semiconductors B Electronic Crystals BCT(Best Conventional Pollutant Control Technology) A Semiconductors B Electronic Crystals PSES (Pretreatment Standards for Existing Sources) A Semiconductors B Electronic Crystals s C Cathode RayTubes 3 In the E&EC ELGs, EPA defined solvent management as a practice of preventing spent solvent baths (containing TTO) from entering other process wastewater. While the ELGs allow for some solvent bath contamination (e.g., drag out), plants are required to transfer solvent baths to drums or tanks for disposal. 4 In-process control includes the collection of lead- and chromium- bearing wastes for resale, reuse, or disposal. 5 ------- Table 4. Wastewater Treatment Technology Bases for the E&EC Category Subpart Subcategory Solvent Management Neutralization Chemical Precipitation with Clarification3 In-Process Control for Lead and Chromium Filtration NSPS (New Source Performance Standards) A Semiconductors S S B Electronic Crystals S S S C Cathode RayTubes S S D Luminescent Materials S S PSNS (Pretreatment Standards for New Sources) A Semiconductors B Electronic Crystals S C Cathode RayTubes S S D Luminescent Materials Source: U.S. EPA 1983a; U.S. EPA, 1983b. a EPA based all subparts on end-of-pipe or final effluent chemical precipitation with clarification except Subpart A (Semiconductors), which was based on in-plant chemical precipitation and clarification of the concentrated fluoride stream. In addition, contract hauling of the concentrated fluoride stream was considered an acceptable alternative for compliance. 1.1.4 Other Point Source Categories Related to E&EC As stated previously, EPA promulgated the existing E&EC ELGs (40 CFR part 469) in 1983. EPA promulgated the Electroplating ELGs in 1974 and amended them in 1977, 1979, 1981 and 1983 (40 CFR part 413) and promulgated the Metal Finishing ELGs in 1983 (40 CFR part 433). During promulgation of the E&EC and Metal Finishing ELGs and the amendments of the Electroplating ELGs, EPA considered that some facilities may generate wastewater from metal finishing and/or electroplating operations as well as E&EC operations; therefore, facilities may be covered under multiple ELGs. The Metal Finishing ELGs apply to discharges resulting from six core process operations, and 40 additional process operations for those facilities using at least one of the six core process operations (U.S. EPA, 1983c). The six core metal finishing process operations are electroplating, electroless plating, anodizing, coating, etching and chemical milling, and printed circuit board manufacturing (U.S. EPA, 1983c). Following the amendments of the Electroplating ELGs, EPA limited the applicability of the Electroplating Category ELGs to facilities that apply metal coatings via electrodeposition that began operation before July 15, 1983, and discharge wastes to POTWs. All other facilities performing electroplating operations are subject to regulations under the Metal Finishing Category (U.S. EPA, 1983c). Most semiconductor manufacturing facilities use one or more of the six core metal finishing operations while processing silicon wafers. The Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Metal Finishing Point Source Category states that the ELGs for the Metal Finishing Category, the Electroplating Category, and/or the E&EC Category cover all industries 6 ------- listed under SIC Major Group 36.5 Specifically, the E&EC ELGs cover processes unique to electronics manufacturing (e.g., semiconductor manufacturing, electronic crystal production), while the Metal Finishing and Electroplating ELGs cover the remaining processes used to manufacture the products in SIC Major Group 36 (U.S. EPA, 1983c). As described in the Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Metal Finishing Point Source Category, when overlap occurs between the Metal Finishing or Electroplating ELGs and E&EC ELGs, the Metal Finishing ELGs apply for the discharge of four pollutants (nickel, copper, chromium, and lead) (U.S. EPA, 1983c). For example, for a semiconductor manufacturing facility generating electroplating wastewater, the subpart A E&EC ELGs would apply for pollutants provided in Table land the Metal Finishing ELGs would apply for four pollutants associated with metal finishing processes (nickel, copper, chromium, and lead). 1.2 E&EC Industry Profile As part of the 2016 Annual Review, EPA reviewed the 1983 E&EC industry profile and updated the characteristics of the current E&EC industry. This section presents the facility type, wastewater discharge practices, and process operations for E&EC facilities in 1983 and currently. EPA developed an industry profile for the E&EC industry as part of the development of the Phase I and Phase II E&EC ELGs in 1983. To complete the industry profile, EPA gathered information through literature searches, EPA regional office contacts, wastewater treatment technology vendors, and plant surveys and evaluations. This section describes the 1983 facility information EPA gained from its data collection efforts. 1.2.1 Facilities and Wastewater Discharge Practices During the 1983 E&EC rulemaking, EPA determined that the majority of facilities under the E&EC Category manufactured semiconductors (Subpart A) (approximately 72 percent). EPA estimated that about 20 percent of facilities within the E&EC Category manufactured electronic crystals (Subpart B), leaving the remaining 8 percent of facilities under the combined totals for Subparts C (CRTs) and D (luminescent materials). Table 5 provides the facility count and discharge type determined during the 1983 E&EC rulemaking. Table 5. Facility Information for 1983 Industry Profile Subpart Manufacturing Process Facility Count3 Dischargers Direct Indirect A Semiconductor Manufacturing 257 11 180 B Electronic Crystals 70 6 64 C Cathode Ray Tubes 24 1 23 5 SIC Major Group 36 includes Semiconductor and Related Manufacturing (SIC code 3674), Electron Tube Manufacturing (SIC code 3671), and Electronic Component Manufacturing (SIC code 3679). 7 ------- Table 5. Facility Information for 1983 Industry Profile Subpart Manufacturing Process Facility Count3 Dischargers Direct Indirect D Luminescent Materials 5b 2 2 Total 356 86 269 Source: U.S. EPA, 1983a; U.S. EPA, 1983b a EPA determined the number of facilities using a Semiconductor Industry Association (SIA) listing of plants involved in manufacturing semiconductor products in August 1979. b EPA identified one facility with zero discharges. As shown in Table 5, in 1983, 76 percent of all facilities in the E&EC industry discharged to POTWs, including 70 percent of semiconductor manufacturing facilities, 91 percent of electronic crystal manufacturers, and 96 percent of CRT manufacturing facilities. EPA only reviewed five luminescent materials manufacturers, where 40 percent discharged to surface waters and 40 percent discharged to POTWs, while 20 percent achieved zero discharge (U.S. EPA, 1983a; U.S. EPA, 1983b). 1.2.2 1983 E&EC Process Operations EPA reviewed information on the process operations for the four subcategories established in 1983: semiconductor manufacturing, electronic crystal manufacturing, cathode ray tube manufacturing, and luminescent materials manufacturing. The following sections summarize EPA's findings by subcategory. 1.2.2.1 Semiconductor Manufacturing In general, semiconductor manufacturing facilities coat and chemically etch/pattern silicon (or other semiconducting materials) wafers for the desired E&EC products. In 1983, semiconductor manufacturing involved a series of processes, possibly repeated two to 20 times, starting from a raw silicon wafer (silicon was the primary wafer type, although other composition wafers were used) and ending in a microchip designed for assembly in a specific electronic product. Figure 1 presents the sequence of process operations for manufacturing silicon integrated circuits (a semiconductor type), as identified in 1983. 8 ------- Source: Adapted from U.S. EPA 1983a and ERG, 2016a. Figure 1.1983 Silicon Integrated Circuit Production 9 ------- 1.2.2.2 Electronic Crystals Manufacturing As part of the 1983 regulations EPA defined electronic crystal manufacturing as "the growing of crystals and/or production of crystal wafers for use in the manufacture of electronic devices". In general, electronic crystal manufacturing involves forming a crystalline boule and then slicing, rinsing, lapping (e.g., grinding), polishing, etching, and cleaning the crystal prior to shipping to a semiconductor manufacturer or other electronics customers. Figure 2 shows diagrams of typical manufacturing process flows in 1983 for the manufacture of quartz crystals (a type of piezoelectric crystal), and three types of semiconducting crystals: silicon, gallium arsenide, and gallium phosphide. EPA only identified one sapphire crystal producer in 1983; therefore, sapphire crystal manufacturing was not a focus of the rulemaking. EPA reviewed sapphire crystal manufacturing as part of the 2015 Annual Review. That review suggested that sapphire crystals are currently a common type of electronic crystal manufactured and used in the E&EC industry (U.S. EPA, 1983a, U.S. EPA, 2016a). Quartz Crystal Manufacturing Silicon, Gallium Arsenide, and Gallium Phosphide Crystal Manufacturing Abrasive Slurry Waste (Water and Oil Based): Powder from Crystal Material Alumina + Ethylene Glycol Abrasant Various Acids, Bases, and Solvents Source: Adapted from U.S. EPA, 1983a. Figure 2. Basic Manufacturing Processes for Electronic Crystals in 1983 10 ------- 1.2.2.3 Cathode Ray Tubes and Luminescent Materials Manufacturing In 1983, CRT manufacturing operations differed depending on the type of CRT (e.g., color television (TV) tubes, single phosphor tubes) being manufactured. The manufacture of each type of CRT was highly complex and often automated (U.S. EPA, 1983b). The 1983 E&EC ELGs define luminescent materials as "those that emit electromagnetic radiation (light) upon excitation by such energy sources as photons, electrons, applied voltage, chemical reactions, or mechanical energy. These luminescent materials are used for a variety of applications, including fluorescent lamps, high-pressure mercury vapor lamps, color TV picture tubes and single phosphor tubes, lasers, instrument panels, postage stamps, laundry whiteners, and specialty paints" (U.S. EPA, 1983b). EPA based its 1983 analyses related to these two subcategories on those materials used as coatings in fluorescent lamps and color TV picture tubes and single phosphor tubes (U.S. EPA, 1983b). 1.2.3 Current E&EC Process Operations Since 1983, EPA has observed changes in E&EC process operations in all four subcategories. EPA evaluated economic census data, analyzed DMR and TRI data, performed a literature search, searched for available NPDES reports, reviewed IBISWorld reports, met with industry trade associations and NACWA members, contacted individual facilities, and attended industry conferences, to determine the nature of current E&EC process operations. The following sections summarize EPA's findings by subcategory. 1.2.3.1 Semiconductor Manufacturing Discussion with the Semiconductor Industry Association (SIA) indicated that while the semiconductor manufacturing (Subpart A) process sequence in general has not changed significantly, semiconductor manufacturing facilities (the semiconductor manufacturing industry refers to these facilities as fabrication plants or "fabs") have added several process steps over the past 30 years to optimize semiconductor manufacturing, incorporate newer technologies, and achieve smaller node size. The node size, which indicates how densely individual transistors can be packed on a chip, has decreased roughly three orders of magnitude since 1970, to the point where the industry can produce microchips with over one-billion transistors per square centimeter. When the number of transistors on a chip increases, the computational capabilities increase, speed increases, and energy consumption decreases. Since 2010, the node size decreased from 32 nanometers (nm) to less than 3 nm (estimated for 2022 operations) (ERG, 2016a; ERG, 2016b). In addition to the node size decreasing, the semiconductor industry has increased the silicon wafer size over the past 30 years, from a diameter of 125 millimeters (mm) to 300mm (ERG, 2016a; ERG, 2016b). Furthermore, as the technology advances (smaller nodes, larger wafers), semiconductor manufacturing facilities must replace machines, tools, and monitoring systems to support new processes. More specifically, to increase the number of microprocessors obtainable from a single wafer over the past 30 years, semiconductor manufacturing facilities have integrated new steps within the semiconductor manufacturing process sequence including dry etching, metal deposition processes (e.g., plating, chemical vapor deposition (CVD), copper metallization), chemical mechanical planarization (CMP), and controlled collapse chip connection (C4) bump. SIA indicated that wastewater is generated from these new processes but did not provide further details. In addition to new process steps, SIA stated that the existing semiconductor process sequence could be repeated up to 90 times, whereas in 1983 the sequence was repeated only up to 20 times. Figure 3 provides the 1983 process flow diagram from the E&EC ELGs with updated semiconductor manufacturing operations based on EPA's discussions with SIA (ERG, 2016a; U.S. EPA, 1998; U.S. EPA 1983a). To further understand existing processes, EPA contacted six semiconductor facilities with significant discharges based on reported 2014 DMR and TRI data. EPA inquired about the facility's age, size, manufacturing processes, end-products, process chemistries, wastewater generation, and wastewater treatment technologies. Table 6 presents a summary of information EPA obtained from these facility contacts. The facility contacts generally stated that the final products in semiconductor manufacturing 11 ------- have continued to shrink in size causing some fabrication processes to change (e.g., tooling, lithography patterns, new coating layers, CVD) (McCoy, 2016; Heironimus, 2016; Aldrich, 2016). Most of the contacts indicated that process chemistries (i.e., chemicals used in E&EC processes) have not changed substantially over the past 30 years; however, one facility stated that the chemistry changes would likely involve trading out one acid for another acid (McCoy, 2016). 12 ------- Source: Adapted from ERG, 2016a. Note: Process steps in black writing and grey boxes represent the 1983 semiconductor manufacturing operations and process steps in white/red writing and red boxes represent updated semiconductor manufacturing operations since 1983. Figure 3. Updated Silicon integrated Circuit Production 13 ------- Table 6. Summary of Facility Contacts for the Semiconductor Industry Facility Name Location Manufacturing Process Year Size3 Type Wastewater Generation Processes Wastewater T reatmentb East Fishkill Facility Hopewell Junction, NY Semiconductor 300 mm fab 1963 40 MGD 168,000 wafers/yr Direct • Ultrapure water reject • Photolithography (i.e., solvents, rinses) • Polishing • Clarifiers • CP (polymer) • Microfiltration • Acid base slurry treatment • Calcium hydroxide precipitation (Fluoride treatment) • Recycle 10 to 11 million gal/month (i.e., for use in 2nd/3rd rinses) Powerex, Inc. Youngwood, PA Semiconductor 1965 0.1 MGD Indirect • Rinsing after etching • Cleaning products throughout process • Contact did not provide wastewater treatment information. Micron Technology, Inc. Manassas, VA Semiconductor 300 mm fab 1997 5 MGD Indirect • Throughout manufacturing process (rinse water) • Clarifiers • pH adjustment • Chloride treatment • Lime addition with filter tank Samsung Austin Semiconductor Austin, TX Semiconductor 1996 1.3 billion gal/yr Indirect • Ultrapure water reject • Rinsing after etching • Cleaning products throughout process • Clarifiers • CP (sodium hydroxide, lime, caustic, sulfuric acid, ferric chloride) • Filter presses • Future Wastewater Treatment: Ion Exchange (Cu Treatment)0 Freescale Semiconductor - Oak Hill Facility Austin, TX Semiconductor 1991 240,000 wafers/yr Indirect • Ultrapure water reject • Rinsing after etching • pH adjustment • Recycle a portion of rinse water (i.e., for use in cooling tower, scrubber) Intel Corporation Chandler, AZ Semiconductor 12 in wafer 1994 5.4 MGD Indirect • Wet edging • Abatement technologies • Rinsing after etching • Cleaning products throughout process • Fluoride Treatment (i.e., creates calcium fluoride cake) • Stripper scrubber (NHs Treatment) • Zeolite resin (NH3 Treatment) • Electrowinning System (Cu Treatment) Source: Aldrich, 2016; Heironimus, 2016; Kang, 2016; Marone, 2016; McCoy, 2016; Wasielewski, 2016. a MGD- million gallons per day discharged; Production rate (i.e., number of wafers). b CP-Chemical Precipitation. c Future Wastewater Treatment - The facility is considering installing ion exchange for copper treatment in effluent (i.e., performing pilot studies). 14 ------- 1.2.3.2 Electronic Crystals Manufacturing EPA reviewed electronic crystal manufacturing as part of the 2015 Annual Review and determined sapphire crystal manufacturing has likely increased in the U.S. since the 1983 E&EC rulemaking. EPA also determined that sapphire crystal wafer production generates wastewater in the form of slurries and acids from processing steps including wafer lapping, wafer grinding, and polishing similar to the processing steps for the production of other types of electronic crystals. Wafer lapping involves using an abrasive liquid slurry mixture to form a smooth, polished surface, while wafer grinding uses oil- or water-based slurries for coarse removal of material. Polishing slurries are used for surface polishing and removing abrasives; however, these slurries may introduce water, oil, and acid-based additives, as well as harsh chemicals, to the process wastewater. However, EPA's information on the wastewater constituents associated with sapphire crystal manufacturing is limited as the chemicals used in the preparation of sapphire wafers have not been thoroughly studied (U.S. EPA, 2016a). For its 2016 Annual Review, EPA conducted a targeted literature review using the keyword list (U.S. EPA, 2018), and did not identify any further information with regards sapphire crystal manufacturing. However, EPA identified one paper with specific information regarding treatment of wastewater from electronic crystal polishing (Sturgill, 2000). Sturgill primarily discusses pollution prevention and recycling of gallium and arsenic from gallium arsenide (GaAs) polishing wastes, but the introduction provides a general description of GaAs crystal manufacturing. Sturgill states that boules (i.e., ingots of crystalline GaAs) are cut into wafers, and then the wafers are etched, lapped, and polished (Sturgill, 2000). Sturgill's GaAs crystal manufacturing process steps are similar to electronic crystal manufacturing process steps depicted in Figure 2 identified during the 1983 rulemaking. This information suggests the electronic crystal manufacturing process steps have not changed substantially over the past 30 years; however, as identified during the 2015 Annual Review, sapphire crystal manufacturing has likely increased. 1.2.3.3 Cathode Ray Tubes and Luminescent Materials Manufacturing EPA reviewed existing manufacturing operations for Subpart C, CRTs, and Subpart D, luminescent materials, through internet searches and the literature review. The research indicates that CRT manufacturing has decreased dramatically due to their replacement with newer technologies, such as liquid crystal display (LCD), thin-film transistor liquid crystal display (TFT-LCD), plasma display, and organic light-emitting diode (OLED) for TV and other electronic applications (IBISWorld, 2016; Sood, 2005). Similarly, luminescent materials consisted of fluorescent lamp phosphors in 1983 (i.e., used in TV, video game displays, and lamp applications); however, most of these applications have been replaced with other technologies, such as light-emitting diode (LED) lamps and the CRT replacement technologies listed previously (IBISWorld, 2016; ERG, 2016a; Sood, 2005). In addition, NACWA members confirmed that CRT and luminescent materials are phasing out of production (U.S. EPA, 2016b). 1.3 References 1. Aldrich, Sean. 2016. Telephone communication with Sean Aldrich, Intel Corporation, and Anna Dimling, ERG. (April 5). EPA-HQ-OW-2015-0665-0330. 2. ERG. 2016a. Eastern Research Group, Inc. Notes from Meeting with the Semiconductor Industry Association (SIA). Chantilly, VA. (July). EPA-HQ-OW-2015-0665-0333. 3. ERG. 2016b. Eastern Research Group, Inc. Memorandum from Anna Dimling, ERG, to Jezebele Alicea, U.S. EPA. Re: Summary of Semiconductor Presentations and Posters at 2016 ASMC SEMI Conference, Saratoga Springs, NY. Chantilly, VA. (June 13). EPA-HQ-OW- 2015-0665-0332. 4. Heironimus, Jason. 2016. Telephone communication with Jason Heironimus, Freescale Semiconductor Oak Hill Facility, and Anna Dimling, ERG. (April 7). EPA-HQ-OW-2015-0665- 0334. 15 ------- 5. IBISWorld. 2016. IBISWorld Industry Report 33441b: Circuit Board & Electronic Component Manufacturing in the US. (June). EPA-HQ-OW-2015-0665. DCN 08342. 6. Kang, Josh. 2016. Telephone communication with Josh Kang, Samsung Austin Semiconductor, and Anna Dimling, ERG. (March 24). EPA-HQ-OW-2015-0665. DCN 08344. 7. Marone, Gary. 2016. Telephone communication with Gary Marone, Global Foundries East Fishkill Facility, and Anna Dimling, ERG. (March 24). EPA-HQ-OW-2015-0665-0343. 8. McCoy, John. 2016. Telephone communication with John McCoy, Micron Technology Inc., and Anna Dimling, ERG. (March 24). EPA-HQ-OW-2015-0665-0344. 9. Sood, A. and Tellis, G. 2005. Technical Evolution and Radical Innovation. Journal of Marketing. 69: 152-168. (July). EPA-HQ-OW-2015-0665-0347. 10. Sturgill, J.A., Swartzbaugh, J.T., and Randall, P.M. 2000. Pollution Prevention in the Semiconductor Industry through Recovery and Recycling of Gallium and Arsenic from GaAs Polishing Wastes. Clean Products and Processes. 2: 18-27. EPA-HQ-OW-2015-0665-0348 11. U.S. Census Bureau. 2016a. United States Census Bureau: 2007 NAICS Definition for 334411 Electron Tube Manufacturing. EPA-HQ-OW-2015-0665-0350. 12. U.S. Census Bureau 2016b. United States Census Bureau. Economic Census. EPA-HQ-OW- 2015-0665-0351. 13. U.S. EPA. 1983a. Development Document for Effluent Limitations Guidelines for the Electrical and Electronic Components Point Source Category- Phase I. Washington, D.C. (April). EPA Report Number 440/1-84/075. EPA-HQ-OW-2015-0665-0268. 14. U.S. EPA. 1983b. Development Document for Effluent Limitations Guidelines for the Electrical and Electronic Components Point Source Category- Phase II. Washington, D.C. (December). EPA 440/1-84/075. EPA-HQ-OW-2015-0665-0352. 15. U.S. EPA. 1983c. Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Metal Finishing Point Source Category. Washington, D.C. EPA-HQ-OW-2004-0032-0110. 16. U.S. EPA. 1998. Permitting Guidance for Semiconductor Manufacturing Facilities. EPA-821- R-09-007. Washington, DC. (April). EPA-HQ-OW-2015-0665-0353. 17. U.S. EPA. 2016a. The 2015 Annual Effluent Guidelines Review Report. Washington, D.C. (June). EPA-821-R-16-002. EPA-HQ-OW-2015-0665-0299. 18. U.S. EPA. 2016b. Summary Notes from EPA's Meeting with the National Association of Clean Water Agencies (NACWA). (December). EPA-HQ-OW-2015-0665-0355. 19. U.S. EPA. 2018. Effluent Guidelines Planning Review Report Supporting the Final 2016 Effluent Guidelines Program Plan. (April). EPA-HQ-OW-2015-0665-1056. 20. Wasielewski, Ryan. 2016. Telephone communication with Ryan Wasielewski, Powerex Inc., and Anna Dimling, ERG. (April 4). EPA-HQ-OW-2015-0665-0354. 16 ------- 2. Discharge Regulatory Framework E&EC facilities commonly are indirect dischargers (i.e., they discharge their wastewater to a POTW) but some are direct dischargers (i.e., they discharge treated wastewater to waters of the US. The regulatory framework applicable to each type of discharger is described below. 2.1 Indirect Dischargers Subject to the Pretreatment Standards Under the National Pretreatment Program The majority of facilities are indirect dischargers that discharge their wastewater to a local or regional publicly owned treatment works (POTW). These facilities are subject to the national pretreatment program in 40 CFR Part 403. The national pretreatment program is a component of the NPDES program. It is a cooperative effort of federal, state, and local environmental regulatory agencies established to protect water quality. Similar to how EPA authorizes the NPDES permit program to state, tribal, and territorial governments to perform permitting, administrative, and enforcement tasks for discharges to surface waters (NPDES program), EPA and authorized NPDES state pretreatment programs approve local municipalities to perform permitting, administrative, and enforcement tasks for discharges into the municipalities' POTWs. The national pretreatment program is designed to protect POTWs infrastructure and reduce conventional and toxic pollutant levels discharged by industries and other nondomestic wastewater sources into municipal sewer systems and into the environment. 2.1.1 Pretreatment Standards Pretreatment standards are pollutant discharge limits which apply to industrial users (Ills). Pretreatment requirements are substantive or procedural requirements applied to Ills. ELGs are uniform national standards developed by EPA for specific industrial categories. The standards applicable to indirect dischargers (also called categorical pretreatment standards) are listed under each ELG as pretreatment standards for existing sources (PSES) and pretreatment standards for new sources (PSNS). The E&EC ELG establishes PSES and PSNS for the E&EC industrial category. These technology-based standards apply regardless of whether or not the POTW has an approved pretreatment program or whether or not the nondomestic discharger has been issued a control mechanism or permit. Nondomestic dischargers subject to categorical pretreatment standards are categorical industrial users (ClUs). Thus, all indirect discharging E&EC facilities are ClUs. 2.1.2 Pretreatment Control Authorities Where a POTW has an approved local pretreatment program, the POTW is the control authority. Where a POTW has not received approval, the control authority is the approved state or, in unapproved states, the EPA. The control authorities: • Develop legal authority for their jurisdiction, local limits, standard operating procedures, and an enforcement response plan to establish and maintain an approved pretreatment program. • Regulate Ills by: ¦ issuing control mechanisms, ¦ conducting monitoring and inspections, ¦ receiving and reviewing reports and notifications, ¦ reviewing requests for net/gross variances, 17 ------- ¦ evaluating compliance with program requirements, and taking enforcement as appropriate, and ¦ submitting regular reports to approval authorities to describe the implementation of their pretreatment program. The control authority is responsible for administering and enforcing pretreatment standards and requirements. The control authority's primary goals are: to prevent the discharge of pollutants into the POTW that would result in interference and pass through at the POTW's wastewater treatment plant; and to ensure that Ills comply with all applicable pretreatment program requirements. 2.1.3 Local limits and other potentially applicable pretretment standards The federal regulations in 40 CFR 403.5(c)(1) require POTWs with approved pretreatment programs or POTWs developing a pretreatment program to develop local limits that enforce the general and specific prohibitions in 40 CFR 403.5 (a)(1) and (b). Additionally, some states and EPA Regions may have additional requirements for the development of local limits for specific parameters. EPA's Local Limits Development Guidance (U.S. EPA, 2004) provides a detailed outline of the process for developing local limits. Additionally, some states may have additional requirements for the development of local limits for specific parameters. While 40 CFR Part 469 does not have a pH limit for indirect dischargers, many POTWs do include pH requirements in their permits for indirect dischargers. The federal regulations in 40 CFR 403.5(b)(2) prohibits indirects dischargers from discharging "pollutants which will cause corrosive structural damage to the POTW, but in no case Discharges with pH lower than 5.0, unless the works is specifically designed to accommodate such Discharge." Note that if the POTW's collection system is designed to handle a lower pH, the control authortity may accept wastewater with a pH less than 5.0 as long as the control authority has an approved and adopted local limit for the lower pH. Additionally, 40 CFR Part 403 does not contain an upper pH limit; however, discharges with a pH greater than 12.5 will require the industrial user to meet the hazardous waste reporting requirements in 40 CFR 403.12(p). As a result, most control authorities set their upper pH limit below 12.5. E&EC indirect dischargers are required to conduct self-monitoring and submit monitoring reports to the pretreatment control authority. The federal regulations in 40 CFR 403.12(g)(1) require self-monitoring to be performed at least twice a year, but more frequent monitoring may be required by the control authority. 2.2 Direct Dischargers Subject to NPDES Permitting Any E&EC facility that directly discharges pollutants from a point source to a water of the US is subject to the NPDES permit program. NPDES permits are issued by the EPA or authorized states. Most NPDES permits are issued by the authorized state. These permits must include applicable technology-based effluent limits from the E&EC ELG (40 CFR part 469) based on Best Practicable Control Technology (BPT), Best Available Technology Economically Achievable (BAT), Best Conventional Pollutant Control Technology (BCT), or New Source Performance Standards (NSPS) for the E&EC industrial subcategory. Additionally, the NPDES permit is required to include permit limits and conditions where necessary that protect water quality in the receiving stream. As a result, more stringent water quality-based effluent limitations and/or limits for additional pollutants and/or other requirements may be included in the NPDES permit compared to the requirements in the ELG. E&EC direct dischargers must submit DMRs to the permitting authority in compliance with the NPDES permit. 18 ------- 2.3 E&EC Facility Discharge Requirements EPA contacted permitting agencies (states, EPA regions, and pretreatment control authorities) to better understand permits and pretreatment requirements applicable for direct and indirect discharging E&EC facilities. As a follow-up to these conversations, the permitting agencies and control authorities provided copies of the permits and associated documents, including the permit applications, fact sheets, and solvent management plans. Additionally, EPA reviewed public databases for copies of this information. EPA developed a permit summary database to track the various permit conditions included in E&EC permits, implementing the quality control procedures described in Section 2.3.4 to ensure data were transcribed accurately. While the database is not a census of all permitted E&EC facilities, it is a robust representation of the E&EC industry. All collected documents as well as the final permit database are available in the supporting docket.6 Table 7 shows the number of direct and indirect permitted facilities in the E&EC permit database by E&EC subcategory, includings those facilities that are subject to multiple subcategories or are also permitted under additional ELGs (i.e., 40 CFR part 433 and/or 40 CFR part 471). This distribution shows that the E&EC industry is comprised primarily of indirect dischargers (97%) and a few direct dischargers (3%). E&EC facilities are also predominantly semiconductor manufacturers (65%), followed by crystal manufacturers (10%), and several integrated plants manufacturing both electronic crystals and semiconductors or performing both E&EC and other manufacturing operations (24%). EPA did not collect any permits from any cathode ray tube manufacturing facilities and collected permits from only two luminescent materials manufacturing facilities; this is consistent with the decline in the cathode ray tube and fluorescent lamps industries since the early 1980s when the E&EC regulations were promulgated. Table 7. E&EC Permitted Facilities in E&EC Study Permit Database Point Source Category and Number of Facilities Permitted Subcategory Existing Source New Source Unknown Indirect Dischargers 469 A 6 58 9 469 B 3 6 2 469 D 0 2 0 469 A, 469 B 0 4 2 469 A, 433 4 11 0 469 B, 433 1 1 0 469 A, 469 B, 433 0 1 0 469 B, 433, 471 0 1 0 Research and Development Facility 0 0 1 Total 14 84 14 Direct Dischargers 469 A 0 1 1 6 https://www.regulations.gov/docket/EPA-HQ-QW-2021-0547 19 ------- Table 7. E&EC Permitted Facilities in E&EC Study Permit Database Point Source Category and Number of Facilities Permitted Subcategory Existing Source New Source Unknown 469 B 1 0 0 469 A, 433 0 1 0 Total 1 2 1 40 CFR 469 A - E&EC Semiconductor Subcategory 40 CFR 469 B - E&EC Electronic Crystals Subcategory 40 CFR 469 D - E&EC Luminescent Materials Subcategory 40 CFR 433 - Metal Finishing Point Source Category 40 CFR 471 - Nonferrous Metals Forming and Metal Powders Point Source Category For each E&EC permit reviewed, the study database also captured the list of pollutants included in the permit, the limit for each pollutant, and the monitoring frequency for each pollutant. Where either stated in the permit, stated in the fact sheet, or otherwise determined by reviewing the permit documents, the basis of the permit limits (ELG, local limits, or water quality criteria) was also noted in the permit database. A summary of the pollutants listed in E&EC permits is included in Table A-l through Table A-4 of Attachment A. 2.3.1 Indirect Dischargers Table A-l and Table A-2 in Attachment A summarize permit information for E&EC indirect discharge facilities that are permitted either solely under the ELG at 40 CFR part 469 or under both 40 CFR part 469 and 40 CFR part 433, respectively. Some observations on the data are described below. With respect to inclusion of the E&EC ELGs, all indirect discharge permits included limits for the pollutants regulated at 40 CFR part 469 where applicable (i.e., arsenic for certain 40 CFR Subpart B facilities and additional metals for 40 CFR Subpart C and D facilities) with one exception. All of the indirect discharge permits EPA reviewed, that should contain a limit for TTO (40 CFR 469 Subparts A, B, and C facilities), had a limit except for one. The one permit that did not include a TTO limit was for a facility that submitted a solvent management plan and was submitting certification statements in lieu of monitoring for TTO. Note that the TTO limit should have been included in the permit for this facility because the facility was still subject to the limit in the event a sample was collected by either the facility or the Control Authority. Most of the permits for indirect discharge facilities contain limits for parameters in addition to those required in 40 CFR Part 469. For those facilities that are subject to multiple ELGs (Table A-2), permit writers included limits for all pollutants in each of the ELGs. In some cases, the permit writer adjusted the limit using the combined wastestream formula to account for the comingling of wastestreams prior to treatment and discharge. In addition, as discussed in Section 2.1 above, Control Authorities are required to calculate local limits to protect the POTW and collection system. Because the calculations are based on site specific conditions, the pollutants regulated by local limits varies by Control Authority. As a result, permit writers may use local limits to control discharges from indirect dischargers when the ELG(s) does not include a limit for the pollutant. Several of the indirect discharging facilities have local limits for TTO in their permits, and six of these facilities are subject to a TTO local limit that is more stringent that the TTO limit in 40 CFR Part 469. Using 20 ------- the criteria outlined in Section 2.1 above, Control Authorities may develop TTO local limits as needed to protect their POTWs and collection systems from all industrial discharges. Of the 112 indirect discharge permits EPA reviewed, 105 included a local limit for pH. The pH limits ranged from a lower limit of 5.0 S.U. to an upper limit of 12.5 S.U. As discussed in Section 2.1, these pH limits are consistent with both Federal pretreatment program requirements and local limits developed by Control Authorities. Additionally, the permit writer for each Control Authority may use best professional judgement when determining the monitoring frequency for each pollutant. The federal regulations at 40 CFR 403.12(h) require indirect dischargers to monitor for pollutants regulated in the ELG at least once every six months. Permit writers may use best professional judgement to place a more frequent monitoring frequency in the permit. Additionally, permit writers may require "monitoring only" of some parameters. This is usually done when the permit writer wants to gather additional information about the industrial user's discharge, for example to characterize a new or changed operation, gather additional data for calculating limits in the future, or verify that a pollutant is not present in an industrial user's discharge. 2.3.2 Direct Dischargers Table A-3 and Table A-4 of Attachment A include information about the parameters included in the permits for direct dischargers. As discussed in more detail in Section 4 of this report, the parameters included in these permits are site specific and are often based on water quality criteria. 2.3.3 Solvent Management Plans in Lieu of Monitoring The E&EC regulations allow a facility to submit a solvent management plan and submit certification statements in lieu of monitoring for TTO. However, this option must be included as a permit condition. Based on the documents reviewed, 77 of the 112 indirect discharging facilitities have submitted a solvent management plan. Additionally, one of the the four direct discharging facilities has submitted a solvent management plan. A summary of the solvent management plans by E&EC subcategory is provided in Table 8. As noted in Table 8, 23 of the solvent managent plans reviewed by EPA covered the disposal of all toxic organics and not just the toxic organics listed in the ELG. Table 8. Solvent Management Plans E&EC Permitted Facilities in E&EC Study Permit Database Point Source Category and Subcategory Number of Facilities Submitting Solvent Management Plans Number of Solvent Management Plans Covering all Toxic Organics Indirect Dischargers 469 A 51 13 469 B 7 3 469 D 1 1 469 A, 469 B 4 0 469 A, 433 10 4 469 B, 433 2 2 469 A, 469 B, 433 0 0 469 B, 433, 471 1 0 Research and Development Facility 1 1 Total 77 23 21 ------- Table 8. Solvent Management Plans E&EC Permitted Facilities in E&EC Study Permit Database Point Source Category and Subcategory Number of Facilities Submitting Solvent Management Plans Number of Solvent Management Plans Covering all Toxic Organics Direct Dischargers 469 A 1 0 469 B 0 0 469 A, 433 0 0 Total 1 0 40 CFR 469 A- E&EC Semiconductor Subcategory 40 CFR 469 B - E&EC Electronic Crystals Subcategory 40 CFR 469 D - E&EC Luminescent Materials Subcategory 40 CFR 433 - Metal Finishing Point Source Category 40 CFR 471 - Nonferrous Metals Forming and Metal Powders Point Source Category 2.3.4 Data Quality and Limitations All data sources used to develop the E&EC permit database were provided by control authorities (states, EPA regions, and pretreatment control authorities), E&EC facilities and EPA websites, which are assumed to be accurate, reliable, and fit for use. After confirming a data source met these data acceptance criteria, EPA imported the permit information directly into the database or did manual data entry depending on the source's formatting. Once a data source was entered into the database, a second person confirmed the data acceptance criteria and checked the entries for accuracy and completeness. EPA encountered several limitations when assessing permitting information for this study. EPA was not able to identify or review any permitting information from facilities permitted under 40 CFR 469 Subcategory C and only reviewed permitting data from one facility permitted under Subcategory D. 2.4 References 1. U.S. EPA. 2004. Local Limits Development Guidance. (July). EPA-HQ-OW-2021-0547. DCN EEC0600. 22 ------- 3. Wastewater Characterization EPA collected wastewater discharge characterization data from 98 indirect and four direct discharging facilities permitted under 40 CFR 469, resulting in a dataset of approximately 84,000 records for 291 analytes. EPA obtained discharge data for most of these E&EC facilities by reaching out to their permitting authorities. EPA gathered additional data from state permitting databases, EPA's Enforcement and Compliance History Online (ECHO) website, and by directly contacting E&EC dischargers. EPA requested a minimum of one year's sampling data from permitting authorities and dischargers. While the database is not a census of all indirect discharging E&EC facilities in the U.S., it is a robust representation of the E&EC industry. EPA is not aware of any additional direct discharging E&EC facilities. EPA stored the wastewater characterization data in an Access database, implementing the quality control procedures described in Section 2.3.4 to ensure data were transcribed accurately and that sources were representative of the E&EC industry. All original sampling documents as well as the final access database are available in the supporting docket.7 This section describes EPA's analysis and discussion of the E&EC wastewater discharge characterization data. 3.1 E&EC Wastewater Discharge Characterization and Identification of Parameters of Interest This section provides summary statistics for EPA's wastewater characterization database and describes the Agency's analysis to identify E&EC industry "parameters of interest" that warrant additional analysis in Section 4 of this report. 3.1.1 E&EC Wastewater Discharge Characterization Data EPA compiled a series of summary statistics tables (Table 9 through Table 11) to describe the E&EC wastewater discharge characterization database. Table 9 provides the distribution of wastewater characterization data by discharge status and by point source category and subcategory. This distribution is comprised of 102 facilities, predominantly indirect dischargers (96%) and a few direct dischargers (4 percent). Facilities identified by permitting authorities as semiconductor manufacturers comprise the majority of E&EC facilities (67%), followed by electronic crystal manufacturers (9%), and several integrated plants manufacturing both electronic crystals and semiconductors or performing both E&EC and metal finishing operations (22%). EPA did not collect wastewater characterization data from any cathode ray tube manufacturing facilities and collected data from only two luminescent materials manufacturing facilities; this is consistent with the decline in the cathode ray tube and fluorescent lamps industries since the early 1980s when the E&EC regulations were promulgated. Table 9 also shows that most records are non-detected results (approximately 77 percent). 7 https://www.regulations.gov/docket/EPA-HQ-QW-2021-0547 23 ------- Table 9. Data Collection by Point Source Category and E&EC Subcategory Point Source Category and Subcategory Number of Facilities Number of Records (Total) Number of Records (Detected) Indirect Dischargers 469 A 67 41,556 11,464 469 A, 433 15 20,380 2,954 469 A, 469 B 3 361 146 469 A, 469 B, 433 1 196 37 469 B 8 1,550 522 469 B, 433 2 14,526 1,173 469 D 2 1,931 825 Total 98 80,500 17,121 Direct Dischargers 469 A 1 182 182 469 A, 433 2 2,711 1,634 469 B 1 529 523 Total 4 3,422 2,339 40 CFR 469 A - E&EC Semiconductor Subcategory 40 CFR 469 B - E&EC Electronic Crystals Subcategory 40 CFR 469 D - E&EC Luminescent Materials Subcategory 40 CFR 433 - Metal Finishing Point Source Category EPA focused on identifying and acquiring data from facilities located in regions with high concentrations of E&EC dischargers (e.g., California, Pacific Northwest, Texas) (Table 10). EPA also collected data from other regions of the U.S. and believes the current data set is representative of the national industry. EPA is not aware of any additional 40 CFR 469 direct discharging facilities beyond the four already identified. Table 10. Data Collection by State State Number of Facilities Number of Records (Total) Indirect Dischargers CA 61 15,835 IL 1 39 Ml 1 250 MN 1 275 MO 1 242 NC 4 380 NY 2 1,304 OR 8 2,418 PA 2 47 TX 10 54,488 VA 2 3,575 WA 5 1,647 Total 98 80,500 Direct Dischargers NY 1 1,651 24 ------- Table 10. Data Collection by State State Number of Facilities Number of Records (Total) OR 1 529 TX 1 182 VT 1 1,060 Total 4 3,422 EPA received data for 122 unique analytes detected in E&EC wastewater (Table 11). Approximately 170 additional analytes, consisting of organic compounds and a few metals, were never detected in routine pollutant scans conducted at E&EC facilities. Table 11. Analytes by Pollutant Category Pollutant Category Number of Analytes with at Least One Detected Result Number of Analytes with no Detected Results Indirect Dischargers Anions 8 0 Classical Wet Chemistry 22 0 Metals 32 5 Organic Compounds 53 163 Direct Dischargers Anions 2 0 Classical Wet Chemistry 10 0 Metals 14 8 Organic Compounds 8 8 3.1.2 Parameters of Interest This section describes the approach EPA used to identify parameters of interest for the E&EC Study. In this analysis, "parameters of interest" refer to analytes that warrant additional analysis in Section 4 of this report. In the first step of this analysis, EPA identified pollutants detected in E&EC wastewater discharges. Table B-l and Table B-2 of Attachment B present summary statistics for analytes detected at least once in wastewater discharges from indirect and direct discharging E&EC facilities, respectively. In the second step, EPA applied the following criteria to identify the subset of parameters of interest: 1. Pollutants currently regulated under 40 CFR 469. • Indirect dischargers: total toxic organics, arsenic, cadmium, antimony, zinc, fluoride, chromium, lead (40 CFR 469 A, B, C, and D). • Direct dischargers: total toxic organics, arsenic, pH, fluoride, total suspended solids (40 CFR 469 A and B). 25 ------- 2. Parameters that are frequently detected and that are either (1) nutrients or (2) have a relatively high toxic weighting factor8. • Frequency of detection: ¦ Parameters detected in at least 25 percent of facilities measuring for the pollutant, AND ¦ Parameters detected in at least 25 percent of results. • Potential environmental concern: ¦ Parameters with a toxic weighting factor of at least 0.001, OR ¦ Parameters that are nutrients (phosphates, ammonia, phosphorus, nitrates, nitrites, nitrogen, total Kjeldahl nitrogen). Table B-3 and Table B-4 in Attachment B list the detected parameters and the results of the selection criteria for indirect and direct dischargers, respectively. Table 12 and Table 13 lists the parameters of interest for indirect and direct dischargers. In addition to the parameters of interest listed in Table 12 and Table 13, EPA identified per- and polyfluoroalkyl substances (PFAS) for review. PFAS in E&EC discharges were identified in EPA's PFAS Strategic Roadmap, which summarizes its review of and plan to address potential industrial sources. See Section 4.2.1 for more information. 8 Toxic weighting factors are derived from chronic aquatic life criteria and human health criteria established for the consumption of fish; they are used to compare the toxicity of one pollutant relative to another and are normalized based on the toxicity of copper (ERG, 2007). 26 ------- Table 12. E&EC Industry Parameters of Interest - Indirect Dischargers Pollutant Units Number of Facilities Measuring Number of Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Total Toxic Organics Total Toxic Organics mg/L 57 27 836 182 N/A 0.00092 0.957 0.0752 0.01675 Classical Wet Chemistry Ammonia mg/L 30 30 618 607 0.00111 0.05 1,300 87.9 36.1 Nitrogen, Total mg/L 3 3 12 12 N/A 9.14 25.3 16.6 17.4 Phosphorus, Total mg/L 18 17 142 139 N/A 0.102 202 6.35 1.72 Total Kjeldahl Nitrogen mg/L 8 8 133 131 N/A 0.28 274 76.8 58.5 Anions Fluoride, Total mg/L 36 27 907 783 0.03 0.00054 114 9.02 6.8 Nitrates mg/L 6 6 40 40 0.000747 0.16 12.3 4.56 4.28 Nitrates/Nitrites mg/L 9 9 52 51 N/A 0.5 12.44 4.38 4.37 Nitrites mg/L 6 6 40 38 0.0032 0.026 4.19 0.455 0.265 Metals Aluminum, Total mg/L 10 9 26 20 0.06 0.0215 0.434 0.119 0.0755 Antimony, Total mg/L 18 7 161 17 0.01 0.0000951 0.129 0.0186 0.009 Arsenic, Total mg/L 53 35 1,159 482 3.47 0.000063 6.16 0.192 0.062 Barium, Total mg/L 11 10 26 25 0.00199 0.000723 0.039 0.0131 0.0127 Boron, Total mg/L 8 7 228 218 0.00834 0.047 5 0.311 0.27 Cadmium, Total mg/L 64 17 1,072 157 22.8 0.0000116 0.1928 0.00522 0.002 Chromium, Total mg/L 68 42 1,211 280 0.07 0.0000133 0.82 0.0192 0.005 27 ------- Table 12. E&EC Industry Parameters of Interest - Indirect Dischargers Pollutant Units Number of Facilities Measuring Number of Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Copper, Total mg/L 67 57 1,309 996 0.623 0.00015 5.64 0.213 0.05 Gallium, Total mg/L 1 1 3 2 0.13 0.025 0.269 0.147 0.147 Iron, Total mg/L 7 7 33 16 0.0056 0.00684 1.91 0.208 0.0671 Lead, Total mg/L 66 33 1,062 199 2.24 0.00002 0.44 0.0200 0.005 Manganese, Total mg/L 9 8 22 21 0.103 0.000599 0.0337 0.0103 0.00431 Molybdenum, Total mg/L 36 25 169 76 0.2 0.00014 3.74 0.0921 0.00793 Nickel, Total mg/L 69 48 1,170 753 0.1 0.000154 2.99 0.118 0.01 Potassium, Total mg/L 4 4 401 401 0.00105 0.754 181 36.7 35.6 Selenium, Total mg/L 42 19 441 116 1.12 0.00008 0.6 0.0181 0.006 Tellurium, Total mg/L 1 1 14 14 0.04 0.053 0.624 0.234 0.157 Titanium, Total mg/L 3 3 3 3 0.02 0.001 0.00504 0.0025 0.00146 Zinc, Total mg/L 67 60 1,284 1,009 0.04 0.000751 22 0.112 0.03 a Toxic weighting factors are derived from chronic aquatic life criteria and human health criteria established for the consumption of fish; they are used to compare the toxicity of one pollutant relative to another and are normalized based on the toxicity of copper (ERG, 2007). N/A- Not Available 28 ------- Table 13. E&EC Industry Parameters of Interest - Direct Discharges Pollutant Units Number of Facilities Measuring Number of Facilities with Detects Number Results Number Detects Toxic Weightin g Factor3 Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Total Toxic Organics Total Toxic Organics mg/L 2 2 60 54 N/A 0.00013 0.02 0.00657 0.00378 Classical Wet Chemistry Ammonia mg/L 2 2 180 105 0.00111 0.01 13 4.784 5.3 Cyanide, Total mg/L 2 2 73 29 1.11 0.004 0.16 0.0190 0.01 Phosphorus, Total mg/L 1 1 45 45 N/A 0.077 0.248 0.148 0.141 Total suspended solids mg/L 3 3 224 224 N/A 1.08 61 7.29 5.15 Anions Fluoride, Total mg/L 4 4 227 227 0.03 0.17 19 9.74 10 Phosphates mg/L 1 1 30 30 N/A 0.01 0.12 0.0488 0.04 Metals Aluminum, Total mg/L 1 1 45 39 0.06 0.1 0.9 0.179 0.1 Cadmium, Total mg/L 1 1 28 28 22.8 0.0002 0.056 0.00521 0.002 Chromium, Total mg/L 3 2 165 120 0.07 0.00011 0.56 0.0126 0.00107 Copper, Total mg/L 2 2 105 102 0.623 0.013 0.092 0.0284 0.0255 Iron, Total mg/L 2 2 105 94 0.0056 0.044 0.345 0.114 0.104 Lead, Total mg/L 2 2 135 91 2.24 0.001 0.05 0.00155 0.001 Nickel, Total mg/L 2 1 105 90 0.1 0.008 0.186 0.0274 0.0215 Silver, Total mg/L 2 1 45 30 16.5 0.01 0.02 0.0147 0.01 Tungsten, Total mg/L 1 1 45 26 0.00525 0.11 0.21 0.145 0.135 Zinc, Total mg/L 2 2 150 106 0.04 0.008 0.05 0.0181 0.02 29 ------- Table 13. E&EC Industry Parameters of Interest - Direct Discharges Pollutant Units Number of Facilities Measuring Number of Facilities with Detects Number Number T°f. Weightin Results Detects g Factor3 Organic Compounds Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Bromodichloromethane mg/L 1 1 15 10 0.03 0.001 0.003 0.00163 0.00165 Bromoform mg/L 1 1 15 15 0.00457 0.005 0.022 0.0119 0.01 Chloroform mg/L 1 1 15 10 0.00208 0.001 0.002 0.00141 0.00105 PH PH SU 4 4 364 364 N/A 3.37 10.91 7.22 7.2 a Toxic weighting factors are derived from chronic aquatic life criteria and human health criteria established for the consumption of fish; they are used to compare the toxicity of one pollutant relative to another and are normalized based on the toxicity of copper (ERG, 2007). N/A- Not Available 30 ------- 3.2 Wastewater Characterization Data Discussion Section 3.2 discusses E&EC industry wastewaters (wastestream generation, composition, exceedances) and the data quality and limitations of the E&EC wastewater characterization database. 3.2.1 E&EC Wastestreams EPA compared wastewater discharge characteristics from indirect and direct dischargers and found that direct dischargers generally had lower effluent concentrations of pollutants than indirect dischargers (e.g., total toxic organics, fluoride, cadmium, zinc; see Table 13 and Table 14). Direct dischargers have additional wastewater treatments in place which would result in lower discharge concentrations (SIA, 2016). EPA collected wastewater discharge characterization data from 40 CFR 469 B (electronic crystals) and 469 D (luminescent materials) facilities but was unable to contact manufacturers or industry trade associations to discuss modern wastestreams generated by these facilities. According to EPA's 1983 Development Document for Effluent Limitations Guidelines and Standards for the E&EC Point Source Category (Phase One) the major source of wastewater from electronic crystal manufacturing is from rinses associated with crystal fabrication. Fabrication steps generating wastewater include slicing, lapping, grinding, polishing, etching, and cleaning. Wastewater may also be generated from crystal growth operations. The major pollutants of concern in the 1983 development document were total toxic organics, fluoride, arsenic, total suspended solids, and pH (U.S. EPA, 1983). EPA's 1984 Development Document for the E&EC Point Source Category (Phase Two) states that most luminescent material wastewater is from various crystallization, washing, and filtration steps associated with production of intermediate and final product powders. The major pollutants of concern for luminescent materials manufacturers were pH, total suspended solids, antimony, cadmium, and zinc. EPA did not obtain wastewater discharge characterization data for cathode ray tube manufacturers; the 1984 development document discusses that most cathode ray tube manufacturing wastewater is from wash and rinse operations. Hydrofluoric acid was commonly cited in both the 1983 and 1984 development documents as a fluoride source for cathode ray tube and luminescent materials subcategories (U.S. EPA, 1984). Figure B-l and Figure B-2 in Attachment B provide box and whisker plots for indirect and direct discharge parameters of interest, respectively, to better visualize the distribution of detected concentrations. For pollutants regulated under 40 CFR 469, EPA found that the upper quartile values for detected concentrations were consistently below the most stringent daily maximum effluent limitations for both indirect and direct dischargers. While there are a few instances of detected concentrations that exceed the daily maximum effluent limitations (arsenic, antimony, chromium, fluoride, and zinc for indirect dischargers, and pH for direct dischargers), these are infrequent, site-specific instances of treated effluent excursions and exceedances. 3.2.2 Data Quality and Limitations EPA required wastewater characterization presented in Section 3 to meet three criteria for inclusion in the database: 1. Wastewater (outfall) represents E&EC process wastewater discharge 2. Analytes identified and units included in the data source 3. Wastewater characterization data provided by control authorities, E&EC facilities, and EPA websites are assumed to be accurate and reliable, all other sources should be investigated After confirming a data source met these data acceptance criteria, EPA imported the wastewater discharge results directly into the database or did manual data entry depending on the source's formatting. Once a data source was entered into the database, a second person confirmed the data 31 ------- acceptance criteria and checked the entries for accuracy and completeness. After quality control, EPA moved mass-based sampling data along with temperature and flow data into an "excluded from analysis" table as such results, while acceptable, were not used for analysis. EPA consolidated similar pollutant names (e.g., nickel vs. nickel, total), units (e.g., ng/l to mg/l), and populated supplemental fields (used for analysis queries) such as "pollutant category" and "toxic weighting factor" before finalizing the database. EPA encountered several limitations when assessing wastewater characterization data for this study. EPA was not able to collect any wastewater characterization data from facilities permitted under 40 CFR 469 Subcategory C and collected data from only two facilities permitted under Subcategory D. EPA is also interested in PFAS wastewater characteristics for the E&EC industry but was able to collect data from only one facility (see Table B-l). EPA inquired on PFAS discharges when possible but was unable to secure a larger PFAS monitoring data set. 3.3 Additional E&EC Wastewater Characterization Review To further understand current E&EC wastewater characteristics, EPA conducted a literature review, attended industry conferences, and contacted several facilities, trade associations, and NACWA members. SIA has indicated that as the industry has evolved it has adapted new tools, chemicals, materials, and operations. Since the 1980s, the semiconductor industry has incorporated up to 49 additional chemical elements into semiconductor manufacturing operations (ERG, 2016). EPA's research confirmed that new manufacturing processes, operation practices, and chemicals adopted by the E&EC industry that may result in discharges of some of the pollutants listed in Table 7 For instance, some semiconductor manufacturing facilities use copper metallization, which was introduced in the 1990s and is an alternative to aluminum interconnects (ERG, 2016). Similarly, a presentation at the ASMC SEMI Conference discussed a semiconductor manufacturing facility, which uses copper metallization for their Through-Silicon Via (TSV) process (Gopalakrishnan, 2016). Therefore, semiconductor facilities, which have incorporated copper metallization into manufacturing processes since the 1983 E&EC ELGs, may discharge copper in their wastewater because of this operational change (see Table 7). In addition, SIA provided information on the abatement of fluorinated greenhouse gases (used in chamber cleaning) resulting in fluoride in semiconductor wastewaters via wet scrubbers (ERG, 2016). EPA's research also identified that the semiconductor industry has developed several new process chemistries for photolithography over the past 30 years. Photolithography patterns a wafer using the steps illustrated in Figure 3. For example, industry uses new solvent systems, such as ethyl lactate and propylene glycol monomethyl ether acetate (PGMEA). Also, semiconductor manufacturing facilities commonly use aqueous developers for photoresists, which contain tetramethyl ammonium hydroxide (TMAH). CMP slurries, used to chemically and physically polish the wafer surface, typically contain low concentrations of engineered nanomaterials. In addition, some chemically amplified photoresists and antireflective coatings can contain perfluoroalkyl substances (e.g., PFAS). A study on treatment of PFAS in semiconductor wastewater points out that PFAS is primarily used in photolithography because of its unique properties, including optical characteristics and acid-generating efficiency (Tang, 2006). A study in the European Union indicated that for photolithography the semiconductor industry uses PFAS in photoresist (0.02 percent to 0.1 percent PFAS concentration), antireflective coating (0.1 percent PFAS concentration), and developer solutions (0.01 percent to 1.0 percent PFAS concentration) (Brooke, 2004). While most photolithography waste is handled as solvent and incinerated, Brooke indicates that some facilities send approximately 40 percent of waste antireflective coating (containing PFAS) to wastewater treatment. Despite rapid advances within the industry and changing operations and process chemistries, SIA indicated that semiconductor manufacturing requires specialized chemicals that operate precisely with advanced equipment and materials, and that offer distinctive functionality to accomplish high yield, high volume manufacturing. SIA asserted that chemical alternatives may not be available (or known) for use 32 ------- within the industry for certain operations. SIA indicated that researching chemical alternatives and incorporating them into a semiconductor manufacturing process might take 10 to 15 years. Through facilities contacted as part of the 2016 Annual Review EPA learned that some of the chemicals previously used in semiconductor manufacturing operations have been replaced. For instance, one facility noted that trichloroethylene had been phased out of operations 20 years ago (Wasielewski, 2016). Although some hazardous chemicals, PFAS for example, are difficult to replace in certain semiconductor manufacturing process steps. SIA stated that organic chemicals currently identified as TTO have been eliminated from lithography and the industry has tried to eliminate or minimize other constituents of concern in specific process steps (e.g., organic solvents, ozone depleting substances, lead from assembly or packaging) (ERG, 2016). NACWA members stated that pollutants such as ammonia, nitrogen, sulfate, fluoride, and copper are becoming more prevalent in discharges from E&EC facilities. Additionally, due to water conservation programs, E&EC facilities are using less water; therefore, increasing the relative concentration of pollutants in the water discharged to POTWs (U.S. EPA, 2016). In summary, through various data sources described previously, EPA determined that E&EC wastewater characteristics have changed since 1983. Research indicates that the industry may be discharging several new pollutants not considered at the time of the 1983 rulemaking, and that are not reported to DMR or TRI, including some toxic pollutants (e.g., TMAH, PFAS) that are used in various semiconductor manufacturing processes. In addition, industry may be discharging more substantial quantities of certain previously considered and/or regulated pollutants including copper and fluoride due to manufacturing process changes. Additionally, as indicated by SIA, some facilities may have phased out the use of other pollutants regulated as part of the 1983 ELGs, such as organic chemicals currently identified as TTO. 3.4 E&EC Wastewater Treatment Technologies The E&EC ELGs established limitations for the E&EC Category generally based on solvent management to control TTO, neutralization, chemical precipitation (hydroxide) with clarification, in-process control for specific pollutants, and filtration. See Section 1.1.3 for further details on the wastewater treatment technologies used to establish the E&EC ELGs. To understand current wastewater treatment technologies and practices, EPA contacted several facilities and trade associations, conducted a literature review, and reviewed information available in EPA's Industrial Wastewater Treatment Technologies (IWTT) database. For the facility contacts, EPA compiled a summary of the facility type, wastewater generation processes, and wastewater treatment technologies employed. Most of the facilities contacted use the wastewater treatment technologies established in the E&EC ELGs; however, some facilities employ, or plan to employ, more advanced wastewater treatment. Biological treatment, ion exchange, electrowinning, and zeolite resin systems are examples of such advanced wastewater treatments. Table 6 provides a summary of the wastewater treatment information obtained from the facility contacts. While some of the facilities contacted are direct dischargers, SIA indicated that the vast majority of semiconductor manufacturing facilities pretreat semiconductor wastewater, through processes such as pH adjustment or neutralization, prior to discharging to a POTW, and use dedicated solvent waste drains and collection systems (ERG, 2016). Most E&EC facilities also implement a solvent management plan which is designed to prevent most organic contaminants from entering the wastewater prior to discharge to the POTW. Some facilities will recover organic solvents for reuse or resale (e.g., isopropyl alcohol, n-methyl pyrrolidone) (ERG, 2016). SIA explained that some semiconductor manufacturing plants have implemented water reuse practices, such as using RO reject water in other process operations (e.g., scrubbers, cooling towers); however, no zero discharge semiconductor facilities exist in the U.S. to their knowledge (ERG, 2016). Similarly, NACWA stated that they were not aware of any E&EC zero discharge facilities (U.S. EPA, 2016). EPA also performed a targeted literature search and identified several wastewater treatment studies specific to the E&EC industry. 33 ------- One semiconductor manufacturing facility, the East Fishkill Facility in Hopewell Junction, New York, provided specific details on a heavy metal wastewater treatment plant it employs on site (Marone, 2016). The heavy metal wastewater treatment plant consists of calcium hydroxide precipitation (to remove fluoride and other metals), microfiltration, polymer flocculation, an acid/base slurry treatment step, and clarification. In addition, the facility operates an ammonia treatment plant for segregated industrial wastewater streams, where ammonia is removed, distilled, and marketed to another party (Marone, 2016). To identify additional emerging technologies that are being evaluated and/or implemented by the E&EC industry, EPA reviewed recent literature compiled in the IWTT database.9 EPA queried the IWTT database for treatment of E&EC wastewater, which produced five articles with pollutant removal data (Mehta, 2014; Kim, 2012; Kim, 2011; Huang, 2011; Ryu, 2008). Table 14 presents the parameter effluent concentration and percent removal data for all five articles. All but one of the studies were pilot scale (Ryu, 2008). However, EPA identified two studies that evaluated the performance of traditional chemical precipitation systems used by the industry, and three studies focused on more advanced technologies for the industry, including biological treatment or filtration technologies. In addition, most of the studies evaluated removal efficiency of pollutants that do not currently have E&EC ELGs, including ammonium- nitrogen, TOC, COD, and TMAH (Mehta, 2014; Kim, 2012; Kim, 2011; Huang, 2011; Ryu, 2008). 9 For more information on the IWTT database, go to https://www.epa.gov/eg/industrial-wastewater-treatment- technology-database-iwtt. 34 ------- Table 14. Summary of Wastewater Treatment Technologies for Electrical and Electronic Components Wastewater Wastewater Treatment Technology (Order of Unit Processes) Treatment Scale Parameter Effluent Concentration Percent Removal Reference Anaerobic Suspended Growth, Aerobic Suspended Growth, Clarification, Advanced Oxidation Processes (NEC), Anaerobic Suspended Growth, and Clarification Pilot Ammonium-nitrogen (NH4-N) 3 78.57% Mehta, 2014 Chemical oxygen demand NR 98.00% Nitrogen, Kjeldahl total (TKN) 27 83.64% Tetramethyl ammonium hydroxide (TMAH) NR 80.00% Total organic carbon (TOC) NR 98.00% Aerobic Suspended Growth, Clarification, Advanced Oxidation Processes (NEC), Anaerobic Suspended Growth, and Clarification Pilot Ammonium-nitrogen (NH4-N) 6.4 8.57% Nitrogen, Kjeldahl total (TKN) 26 96.53% Tetramethyl ammonium hydroxide (TMAH) NR 99.00% Total organic carbon (TOC) NR 98.00% Electrocoagulation Pilot Copper NR 95.00% Kim, 2012 Chemical Precipitation, Controlled Hydrodynamic Cavitation, and Clarification Pilot Calcium 23.4 90.71% Kim, 2011 Granular-Media Filtration, Membrane Filtration, and Reverse Osmosis Pilot Alkalinity (as CaC03) < 1.5 > 97.69% Huang, 2011 Ammonium-nitrogen (NH4-N) 1.62 84.57% Chemical oxygen demand 4.9 93.57% Chloride 21.1 92.19% Conductivity 69.2 97.35% Hardness (as CaC03) < 1.5 >99.12% Nitrate (as N) 0.73 51.33% 0.06 71.43% Silicate (Si04-2 as Si02) 0.98 88.28% Sulfate (as S04) 0.34 99.87% Suspended solids 1 97.50% Total dissolved solids (TDS) 53.5 95.18% Total organic carbon (TOC) 1.3 76.79% Turbidity 0.06 99.80% Chemical Precipitation and Clarification Full Ammonium-nitrogen (NH4-N) 17 88.96% Ryu, 2008 NR - Not Reported 35 ------- 3.5 References 1. Brooke, D., Footitt, A., Nwaogu, T. A. 2004. Environmental Risk Evaluation Report: Perfluorooctanesulphonate (PFOS). Environment Agency. EPA-HQ-OW-2021-0547. DCN 11130. 2. ERG. 2007. Eastern Research Group, Inc. Toxic Weighting Factors. (7 September). EPA- HQ-OW-2021-0547. DCN EEC0595 3. ERG. 2016. Eastern Research Group, Inc. Notes from Meeting with the Semiconductor Industry Association (SIA). Chantilly, VA. (July). EPA-HQ-OW-2015-0665-0333. 4. Gopalakrishnan, K., Peddaiahgari, A., Smith, D., Zhang, D., and England, L. 2016. Process Development and Optimization for High-Aspect Ration Through-Silicon Via (TSV) Etch. ASMC. 460 - 465. EPA-HQ-OW-2015-0665. DCN 08338. 5. Huang, C. J., Yang, B.M., Chen, K.S., Chang, C.C., and Kao, C.M. 2011. Application of Membrane Technology on Semiconductor Wastewater Reclamation: A Pilot-Scale Study. Desalination 278: 203- 210. EPA-HQ-OW-2015-0665-0336. 6. Kim, S., Park, J-Y., Lee, Y-W., Lee, J-J., Choi, Y-K., Hwang, K-W, Vella, P., Lee, W-K. 2011. Pretreatment of Electronics Wastewater for Reuse: Removal of Calcium Using Controlled Hydrodynamic Cavitation. WEFTEC. EPA-HQ-OW-2015-0665-0341. 7. Kim, K., Cui, F., Yoon, H., and Kim, M. 2012. Treatment of Copper Wastewater Using Optimal Current Electrochemical-Coagulation. Environmental Technology. 34(3): 343- 350. (May). EPA-HQ-OW-2015-0665-0342. 8. Marone, Gary. 2016. Telephone communication with Gary Marone, Global Foundries East Fishkill Facility, and Anna Dimling, ERG. (March 24). EPA-HQ-OW-2015-0665-0343. 9. Mehta, S., Chowdhury, N., Horner, D., Lau, A., and Schilling, B. 2014. A Combined Biological and Advanced Oxidation Process for the Treatment of Wastewaters from the Microelectronics Industry. WEFTEC. EPA-HQ-OW-2015-0665-0345. 10. Ryu, H. D., Daekeun, K., Lee, S. I. 2008. Application of Struvite Precipitation in Treating Ammonium Nitrogen from Semiconductor Wastewater. Journal of Hazardous Materials. 156: 163-169. EPA-HQ-OW-2015-0665-0346. 11. SIA. 2016. Semiconductor Industry Association. SIA Overview and Responses to EPA Water Office. (7 July). EPA-HQ-OW-2021-0547. DCN EEC0012. 12. Tang, C. Y., Shiang Fu., Q., Robertson, A.P., Criddle, C., Leckie, J. 2006. Use of Reverse Osmosis Membranes to Remove Perfluorooctane Sulfonate (PFAS) from Semiconductor Wastewater. Environmental Science & Technology. 40: 23 (7343 - 7349). EPA-HQ-OW- 2015-0665-0349. 13. U.S. EPA. 1983. Development Documents for Effluent Limitations Guidelines and Standards for the Electrical and Electronic Components Point Source Category Phase I. (March). EPA 440/1-83/075. EEC0597. 14. U.S. EPA. 1984. Development Documents for Effluent Limitations Guidelines and Standards for the Electrical and Electronic Components Point Source Category Phase II. (Feburary). EPA 440/1-84/075. EEC0598. 15. U.S. EPA. 2016. Summary Notes from EPA's Meeting with the National Association of Clean Water Agencies (NACWA). (December). EPA-HQ-OW-2015-0665-0355. 16. Wasielewski, Ryan. 2016. Telephone communication with Ryan Wasielewski, Powerex Inc., and Anna Dimling, ERG. (April 4). EPA-HQ-OW-2015-0665-0354. 36 ------- 4. Potential Impacts from E&EC Wastewater Discharges As discussed in Section 3, E&EC process wastewater contains a variety of pollutants including nutrients, fluorine, and metals. E&EC manufacturing processes continue to evolve, impacting their waste management practices and discharge concerns. Permit writers monitoring changes within the industry have identified a few industry-wide potential emerging parameters of interest, but largely have determined that the environmental impacts are limited to site-specific concerns with a particular publicly owned treatment works (POTWs) or receiving water. The following sections present a summary of the wastewater management practices used at E&EC facilities prior to discharge, an overview of potential emerging pollutants within the industry, and a discussion of the potential concerns associated with E&EC indirect discharges to POTWs and direct discharges to receiving waters. 4.1 Waste Management and Wastewater Treatment Prior to Discharge E&EC facilities use a number of management practices to control their toxic wastes. These management practices include solvent management plans, segregation of wastes, and waste disposal alternatives. E&EC facilities may choose to develop a solvent management plan in lieu of monitoring for TTO if allowed by the permitting or control authority. These plans must meet the requirements in 40 CFR 469.13. The plan must specify "the toxic organic compounds used; the method of disposal used instead of dumping, such as reclamation, contract hauling, or incineration; and procedures for assuring that toxic organics do not routinely spill or leak into the wastewater." [40 CFR 469.13(b and d)]. Based on conversations with permitting agencies, EPA noted that E&EC facilities may no longer use the listed toxic organic compounds in their production process. For example, representatives from the City of Dallas noted that E&EC facilities that discharge to the City of Dallas do not use organics included on the list of TTOs in 40 CFR 469. Therefore, the city allows these facilities to develop solvent management plans and submit certification statements in lieu of monitoring for TTO. (ERG, 2020b). E&EC facilities may also choose to segregate their wastes. Segregation of waste allows facilities to treat, dispose, or reclaim wastes in more cost-effective manners. Examples of waste segregation commonly seen at E&EC facilities include keeping wastewaters with different wastes separate prior to treatment (e.g., segregated treatment of acid and fluoride-containing wastes) and segregating solvents-containing wastes for disposal. E&EC facilities typically manage their wastewater by either discharging to a POTW or direct discharging to a receiving stream. However, E&EC facilities may choose alternative disposal methods for some wastestreams. Materials that are classified as a hazardous waste may be hauled off-site for disposal in a hazardous waste landfill or treated by incineration. Solvents and acids may be segregated for reclamation as an alternative to discharge. EPA found that many E&EC facilities have worked to reduce, remove, or replace chemicals in their process. This has resulted in fewer toxic organic compounds in their wastewater. The replacement of chemicals at these facilities may be due to either production requirements or to comply with discharge permit requirements. One example of the facility changing chemicals used in their processes is Micron Technology, Inc. (Micron) in Manassas, VA. According to Virginia Department of Environmental Quality representatives, Micron was issued a sodium effluent discharge limit based on water quality limits needed to protect the drinking water use of the receiving stream. Micron switched from using sodium hydroxide to potassium hydroxide to meet a sodium discharge limit (ERG, 2020d). 4.2 Potential Emerging Parameters of Interest As the semiconductor industry continues to rapidly change, permitting and control authorities express concern that they are often reacting to control new pollutant discharges rather than proactively 37 ------- regulating new pollutants (ERG, 2020a). A few emerging pollutants, however, are beginning to gain the attention of permitting and control authorities as potential parameters of interest across the industry. Per- and polyfluoroalkyl substances (PFAS) and elements, such as germanium and gallium, with emerging increased usage within the industry represent examples of parameters that may merit further investigation in the future. 4.2.1 PFAS Interest in PFAS, driven largely by EPA's review of potential industrial sources for PFAS, is one example of an emerging pollutant within the semiconductor industry. PFAS are a family of thousands of synthetic organic chemicals that contain a chain of carbon-fluorine bonds, one of the strongest chemical bonds. Many PFAS are highly stable, water- and oil-resistant, and exhibit other properties that make them useful in a variety of consumer products and industrial processes. Due to these properties, PFAS do not easily degrade by natural processes and thus accumulate over time. According to the U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry (ATSDR), the environmental persistence and mobility of some PFAS, combined with decades of widespread use, have resulted in their global presence in surface water, groundwater, drinking water, rainwater, soil, sediment, ice caps, outdoor and indoor air, plants, animal tissue, and human blood serum (ATSDR, 2021). Certain PFAS can accumulate in the environment and human body over time and can lead to adverse human health impacts. The regulatory community has historically been interested in two groups of PFAS: (1) long-chain perfluoroalkane sulfonic acids (PFSAs), including perfluorooctane sulfonic acid (PFOS); and (2) long-chain perfluoroalkyl carboxylic acids (PFCAs), including perfluorooctanoic acid (PFOA). Long-chain PFAS, including PFOA and PFOS, were manufactured and used in the U.S. for many decades. Due to evidence of long-term persistence and adverse health outcomes with long-chain PFAS, EPA implemented restrictions on the manufacture, use, and import of certain long-chain PFAS in the U.S. and some manufacturers have voluntarily phased out these chemicals.10 More recently, manufacturers have developed, and industries have adopted alternative short-chain PFAS chemistries to replace long-chain PFAS. Many short-chain PFAS are structurally similar to their long-chain predecessors and manufactured by the same companies. Publicly available health, toxicity, and hazard assessments are limited to only a small fraction of alternate short-chain PFAS chemistries. Historically, photolithography processes in semiconductor manufacturing generated wastewater that could potentially contain elevated levels of PFOS (Tang, 2006). Due to its stability, integration with manufacturing tools, and unique functionality, PFOS was considered a critical ingredient in leading edge photoresists and antireflective coatings used in the photolithographic process for imprinting circuitry on silicon wafers (ERG, 2019). In May of 2017, the World Semiconductor Council (WSC) provided a joint statement detailing the elimination of the remaining uses of PFOS in the semiconductor manufacturing processes by its member companies. The WSC acknowledged that non-member companies may still be using PFOS (World Semiconductor Council Joint Statement, 2017). Then in February 2018 WSC released a statement to the United Nations Stockholm Convention on Persistent Organic Pollutants Review Committee, announcing that the phase-out of the use of PFOS had been completed and the industry no longer required the exemptions that had been granted for their use (World Semiconductor Council, 2018). Although the industry has largely, if not completely, eliminated the use of PFOS, it continues to use long chain fluorinated carbon (FC) compounds, including PFOA, while some member companies within the WSC and Semiconductor Industry Association (SIA) are transitioning to short chain FC compounds. The member companies that comprise the WSC have committed to phasing out the use of PFOA by 2025 (World Semiconductor Council and Semiconductor Industry Associations, 2019). The toxicity of these 10 See: https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/fact-sheet-20102015-pfoa-stewardship- program for more information. 38 ------- short chain replacement PFAS compounds are not well understood, and ongoing studies continue to investigate the potential environmental and health effects they may pose. Data on specific PFAS chemicals used, concentrations in discharges, and if PFAS discharges are controlled by solvent management plans is limited. Some permitting and control authorities are beginning to include PFAS monitoring requirements in permits; however, monitoring efforts have been limited by the lack of analytical methods for monitoring PFAS in wastewater discharges (ERG, 2020e). North Carolina is one region were PFAS monitoring requirements are beginning to become more prevalent. POTWs in North Carolina are required to monitor their influent for PFAS. To further understand the potential sources for PFAS in their influent, Durham County, NC surveyed their industrial dischargers on PFAS use and disposal practices. Survey results among E&EC dischargers in Durham County determined that two out of the three E&EC facilities had PFAS chemicals onsite and chose to manage their PFAS waste by hauling it offsite for disposal (ERG, 2020c and Cree, 2019). Another control authority, Clean Water Services in Hillsboro, OR, established quarterly sampling for PFAS by their industrial dischargers. Initial sampling results demonstrated a correlation between the PFAS in the influent at the POTW and the PFAS being discharged by one of their E&EC facilities. Subsequent sampling at the E&EC facility confirmed that that the PFAS source was process wastewater and not source water contamination (ERG, 2020a). EPA identified one direct discharge E&EC permit with PFAS monitoring requirements. GLOBALFOUNDRIES Essex Junction NPDES permit, issued on July 1, 2021, includes quarterly monitoring requirements for PFAS for the first year of the permit and annual monitoring beginning in 2022 (Vermont Department of Environmental Conservation, 2021a). Currently, EPA has not established ELG requirements on PFAS discharges and there are multiple ongoing studies regarding PFAS wastewater discharges from specific industrial categories. EPA is working across the Agency to better understand the potential impacts of these compounds. 4.2.2 Gallium and Germanium The use of new elements in the semiconductor manufacturing process continues to expand as the industry develops new technologies. Over the years, the semiconductor industry has grown from using approximately 11 elements in the 1980s, when the ELG was first developed, to currently using over 60 different elements during the semiconductor production process across the industry (Semiconductor Industry Association, 2016). No single facility uses anywhere near this many elements within a given process. Permitting and control authorities have expressed concern that as the industry continues to add novel constituents to production processes, they are required to make permitting decisions with limited guidance and information on how to determine appropriate levels of control prior to discharge (ERG, 2020a and Rydberg, 2021). As an example, gallium and germanium were mentioned as potential emerging elements of interest during EPA discussions with the state of New York. Gallium is used in photovoltaic applications, as integrated circuits, and in newer (3G, 4G, and 5G) cell phone technologies in greater quantities than previous generations (Foley et. a I, 2017). Gallium is set to surpass the use of silicon as the primary element used in power switching technologies as greater demands are placed on the need for higher power density and efficiency requirements (Rydberg, 2021). Germanium was used in some of the first transistors within the semiconductor industry. Today, germanium is primarily used during production of semiconductors for power transfer and power systems. Both gallium and germanium are considered technology critical elements which are defined as elements critical to emerging technologies (e.g., information and telecommunications technology, semiconductors, electronic displays, optic/photonic or energy-related technologies) whose use is rapidly increasing (Cobelo-Garcia, 2015). Minimal guidance is readily available to permitting and control authorities trying to evaluate the potential impacts these increased discharges of gallium and germanium may cause to POTWs or surfaces waters. There are no federal pretreatment standards, national recommended water quality criteria, or state water quality standards to follow for establishing gallium and germanium limits. Gallium ecological effects studies are limited; however, one acute toxicity study determined a mean LC5o value (the concentration value when 50 percent of specimens die) of 95.6 ± 14.3 mg/L after 96 hours of 39 ------- exposure for carp (Cyprinus Carpio Linnaeus) (Betoulle et al., 2002). Chronic mean LC5o values for developing rainbow trout (Oncorhynchus mykiss) were 3.5 mg/L after 28 days of exposure (Birge et al., 1980). Human health studies on gallium exposure have largely focused on inhalation of synthetic gallium arsenide (GaAs) by workers in the semiconductor industry. Human health concerns from long-term gallium exposure in drinking water or soils are largely unknown; however, gallium health effects and ecological effects are likely similar to those observed from aluminum given their similar chemical characteristics (Foley et al., 2017). There are limited ecological and human health effects studies on germanium. Mean LC5o values for chronic toxicity from germanium on developing rainbow trout (Oncorhynchus mykiss) are reported at 0.05 mg/L after 28 days of exposure (Birge et al., 1980). Germanium is considered nonessential as it has no known physiological role in human biochemical functions. Germanium does not appear to be carcinogenic and presents a low toxicity risk (Shanks et al., 2017). Although the increased use of gallium and germanium within the industry is known, there is minimal data available on process wastewater effluent concentrations. In wastewater characterization data compiled in support of this study, EPA identified only two facilities that were monitoring their discharges for gallium or germanium. GLOBALFOUNDRIES in Malta, NY detected gallium in two out of three indirect discharge samples and reported gallium concentrations ranging from 0.025 to 0.269 mg/L. GLOBALFOUNDRIES Hopewell Junction monitoring data did not detect germanium in any of the 15 samples reported between 2016 and 2019. Although monitoring data is limited, the use of gallium and germanium is likely to continue to increase and may merit further assessment in the future as potential emerging parameters of interest within the E&EC industry. 4.3 Potential Impacts from Indirect Discharges of E&EC Wastewater As discussed in Section 2, a limited number of pollutants are regulated under 40 CFR 469 for indirect dischargers. Regulated pollutants differ among the different subparts and include TTO, total fluoride, total antimony, total arsenic, total cadmium, total chromium, total lead, and total zinc. TTO, the only pollutant regulated in three out of four subparts within the E&EC ELG, is largely no longer a concern within the industry as the use and management of these chemicals and solvents have changed over time (ERG, 2020a). Across the industry, E&EC facilities have either phased out the use of TTO chemicals or manage TTO concerns through the use of solvent management plans which typically involve the transport of toxic organic wastes offsite for disposal (ERG, 2020b and ERG, 2020d). TTO concentrations reported in indirect discharges are well below ELG limits with 100 percent of detected concentrations below the 1.37 mg/L daily maximum ELG limit and 78 percent (142 out of 182) of detected concentrations at least two orders of magnitude lower. In addition to ELG limits, E&EC indirect permits also include local limits based on site-specific restrictions for the POTW or its receiving water (see Section 2). Common local limits in E&EC indirect permits include pH, oil and grease, total arsenic, total cadmium, total chromium, total copper, total cyanide, total lead, total mercury, total nickel, total silver, and total zinc. As part of this study, EPA reviewed 13 annual pretreatment reports from 2018 and 2019 and contacted multiple control authorities, E&EC facilities, and local and state regulatory entities to identify potential industry-wide concerns. During this review, EPA did not find any evidence that E&EC facilities have caused or contributed to consistent performance issues at POTWs that received E&EC wastewater. Pollutants highlighted by control authorities as potential parameters of interest included: ammonia, total copper, chloride, and sulfate. Pollutant-specific concerns were site-specific in nature and addressed by more restrictive local limits or site-specific treatment options. Table C-l presents the potential parameters of interest identified in indirect E&EC discharges and summarizes the concerns associated with their discharge to POTWs. Table C-l also highlights the range of local limits values included in the indirect discharge permits and summarizes the permit violations documented in EPA's review of the 2018 and 2019 pretreatment annual reports. EPA focused their review on local limits to highlight where control authorities felt additional or more stringent limits than 40 ------- those at 40 CFR 469 were needed to address site-specific concerns at the POTW. The range of local limits reported in indirect discharge permits provides an assessment of the level of control determined among control authorities necessary to mitigate any concerns that may lead to interference, upset or pass through at the POTW. Pollutants were selected for Table C-l based on the parameters of interest analysis described in Section 3, documented permit violations, or a specific interest in the pollutant identified during discussions with control authorities. 4.4 Potential Impacts from Direct Discharges of E&EC Wastewater Regulated pollutants for direct dischargers vary among the different subparts of 40 CFR 469 and include TTO, total fluoride, pH, TSS, total antimony, total arsenic, total cadmium, total chromium, total lead, and total zinc. Direct dischargers identified in the detailed study were regulated under either Subparts A or B which include limits for TTO, total fluoride, and pH. Similar to indirect dischargers, TTO is no longer a concern among direct dischargers with only three out of the four E&EC NPDES permits including a TTO limit and the maximum concentration detected among direct dischargers reported at 0.02 mg/L, well below the ELG daily maximum limit of 1.37 mg/L. Additional pollutants limits identified in the direct discharge permits were technology-based limits for 40 CFR 433 or site-specific receiving water quality concerns. Table C-2 presents the parameters of interest identified in direct E&EC discharges, the range of effluent limits reported in E&EC NPDES permits, and summarizes the potential environmental concerns associated with their discharge to surface waters. EPA focused their review on facility effluent limits beyond pollutants and concentrations regulated by the existing 40 CFR 469 ELG to highlight where permitting authorities felt additional and or stricter limits than those required under 40 CFR 469 were needed to address site-specific concerns in the receiving water. The range of effluent limits reported in direct discharge permits provides an assessment of the level of control determined among regulatory authorities necessary to mitigate any environmental concerns within receiving waters. Parameters were selected for Table C-2 based on the parameters of interest analysis described in Section 3. 4.5 Summary of Findings from EPA's Review of the E&EC Category As part of the 2016 Annual Review, EPA expanded the scope of its review beyond sapphire crystal manufacturing, considered in the 2015 Annual Review, to include the entire E&EC Category. Furthermore, EPA studied the E&EC industry to understand how the industry profile, wastewater discharges, and wastewater treatment have changed since promulgation of the ELGs in 1983. EPA analyzed all four subparts of the 1983 E&EC ELGs, with a specific emphasis on Subpart A, semiconductor manufacturing. EPA evaluated several publicly available data sources including DMR and TRI data, IBISWorld industry market reports, economic census data, and peer-reviewed journal articles (from the literature review and IWTT database). In addition, EPA contacted facilities, met with SIA, and attended industry conferences (e.g., 2016 ASMC SEMI conference, 2016 SEMICON West). From these data collection efforts, EPA determined that the majority of E&EC facilities are indirect dischargers (discharge to POTWs). They have implemented several new process operations using new chemicals and the resulting wastewater characteristics have likely changed over time. Further, the industry may also be phasing out the use of some currently regulated pollutants, including TTO. Specifically, relating to all four of the existing E&EC subcategories, from the 2016 Annual Review EPA determined: • Subpart A - Semiconductor Manufacturing. ¦ Over the past 30 years, discharge practices have not changed dramatically. Most semiconductor manufacturing facilities continue to discharge to POTWs. SIA and NACWA members stated they were not aware of any zero-discharge semiconductor manufacturing facilities (ERG, 2016, U.S. EPA, 2016). 41 ------- ¦ EPA did not identify significant changes in the overall semiconductor manufacturing process operation sequence, though semiconductor manufacturers have added updated processes (e.g., plating, CVS, copper metallization, CMP, C4 bump) and increased repetition of the sequence (from up to 20 times in 1983 to 90 times in 2016). ¦ EPA confirmed that updated manufacturing processes introduce new pollutants in the wastewater, due to new materials, lithography process chemistries, and advancement of tools required to keep up with rapidly changing technology demands. Most noteworthy of the new pollutants are PFAS and TMAH, which are toxic, persistent, and bioaccumulative (Tang, 2006; ERG, 2016). NACWA members also expressed concerns with higher concentrations of ammonia, nitrogen, sulfate, fluoride, and copper discharged from E&EC facilities (U.S. EPA, 2016). ¦ EPA's review of wastewater treatment technologies shows that the industry continues to rely on the traditional technologies identified at the time of the 1983 ELG rulemaking. However, the industry is actively evaluating new technologies (e.g., biological, ion exchange, reverse osmosis, electrowinning) and wastewater management practices (e.g., rinse recycle, RO reject recycle) aimed at treating some of the newer pollutants and conserving water. • Subpart B - Electronic Crystal Manufacturing. ¦ During the 2015 Annual Review, EPA determined that sapphire crystal manufacturing is a growing sector of the electronic crystal manufacturing industry and that the E&EC ELGs apply to this sector. Though EPA did not specifically focus on electronic crystals manufacturing during the 2016 Annual Review, EPA found at least one source that suggests that GaAs and sapphire crystal manufacturing process steps are similar in nature, and that the manufacturing process operation sequence has not changed substantially since 1983. ¦ EPA has not thoroughly investigated the processes, wastewater characteristics, discharges, or treatment associated with existing electronic crystal manufacturing. • Subpart C - CRT Manufacturing. ¦ EPA's research indicates that CRTs have mostly been replaced by newer technologies (e.g., LCD, OLED, plasma display) for TV applications (Robertson, 2018). The market for electron tube manufacturing has decreased significantly since 1983. In addition, several regulations and other efforts have been established for recycling CRTs, suggesting their accelerated phase out. ¦ While EPA has identified replacement technologies for CRTs, EPA has not evaluated current processes, wastewater generation, or treatment technologies. • Subpart D - Luminescent Materials Manufacturing. ¦ Luminescent materials consisted of fluorescent lamp phosphors in 1983 (applied, e.g., in TVs, video game displays, and lamps); however, most of these applications have been replaced with newer technologies, such as LEDs. ¦ While EPA has identified replacement technologies for luminescent materials, EPA has not evaluated current processes, wastewater generation, or treatment technologies. As part of its additional review of the E&EC Category, EPA did not identify any industry-wide concerns regarding accepting E&EC discharges at POTWs or in discharging E&EC process wastewater to surface waters. Pollutant issues identified by permit writers were site-specific in nature and did not appear to be representative of broader issues within the industry. E&EC facilities are known for their willingness to explore alternative "greener" chemicals when a potential issue is identified. Most pollutants detected in screening data used for permit development were observed at concentrations that did not pose a threat to cause interference or upset at the POTW or were at concentrations lower than local water quality standards. Permit violations documented among indirect and direct E&EC dischargers were rare, isolated 42 ------- exceedances that did not represent consistent issues at the facility or across the industry. The industry continues to rapidly change as new technologies are developed and new chemicals used in E&EC process. A few facilities are beginning to track and monitor potential emerging pollutants (e.g., PFAS and gallium), to the extent that they are able, but to date have not identified any new industry-wide potential parameters of concern for E&EC dischargers. 4.6 References 1. ATSDR. 2021. U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry. Toxicological Profile for Perfluoroalkyls. (May 2021). DOI: 10.15620/cdc:59198. Available online at https://www.atsdr.cdc.Rov/toxprofiles/tp200.pdf. EPA-HQ-OW-2021-0547. DCN EEC0601. 2. Betoulle, S., Etienne, J.C., and Vernet, G.. 2002. Acute immunotoxicity of gallium to carp (Cyprinus carpio L.) Bulletin of Environmental Contamination and Toxicology, v. 68, no. 6, p. 817-823. Available online at http://dx.doi.org/10.1007/s00128-002-0Q28-3. EPA-HQ-OW- 2021-0547. DCN EEC0602. 3. Birge, W.J., Black, J.A., Westerman, A.G., and Hudson, J.E. 1980. Aquatic toxicity tests on inorganic elements occurring in oil shale, in Gale, Charles, ed., Oil shale symposium- Sampling analysis and quality assurance, March 1979, Proceedings: Cincinnati, Ohio, U.S. Environmental Protection Agency, EPA-600/9-80-022, p. 519-534. Available online at http://babel.hathitrust.orR/cRi/pt?id=coo.31924004323303;view=lup;seq=531. EPA-HQ- OW-2021-0547. DCN EEC0603. 4. Cree. 2019. Durham County Perfluorinated Chemicals (PFCs) Certification. (9 July). EPA-HQ- OW-2021-0547. DCN EEC0550. 5. Cobelo-Garcia, A.; Filella, M.; Croot, P.; Frazzoli, C.; Du Laing, G.; Ospina-Alvarez, N.; Rauch, S.; Salaun, P.; Schafer, J. 2015. COST action TD1407: network on technology-critical elements (NOTICE)—from environmental processes to human health threats. Environ. Sci. Pollut. Res. 22 (19): 15188-15194. EPA-HQ-OW-2021-0547. DCN EEC0604. 6. ERG. 2016. Eastern Research Group, Inc. Notes from Meeting with the Semiconductor Industry Association (SIA). Chantilly, VA. (July). EPA-HQ-OW-2015-0665-0333. 7. ERG. 2019. Review of the Use, Treatment, and Discharge of PFAS by the Semiconductor Industry for the Electrical and Electronic Components (E&EC) Category Detailed Study. (15 April). EPA-HQ-OW-2021-0547. DCN EEC0606. 8. ERG. 2020a. Eastern Research Group, Inc. Clean Water Services (CWS) Call Notes. (25 Feburary). EPA-HQ-OW-2021-0547. DCN EEC0408. 9. ERG. 2020b. Eastern Research Group, Inc. City of Dallas, TX Call Notes. (26 Feburary). EPA- HQ-OW-2021-0547. DCN EEC0409. 10. ERG. 2020c. Eastern Research Group, Inc. Durham County, NC Call Notes. (25 March). EPA- HQ-OW-2021-0547. DCN EEC0472. 11. ERG. 2020d. Eastern Research Group, Inc. State of Virginia Call Notes. (30 April). EPA-HQ- OW-2021-0547. DCN EEC0491. 12. ERG. 2020e. Eastern Research Group, Inc. Upper Occoquan Service Authority (UOSA), VA Call Notes. (16 November). EPA-HQ-OW-2021-0547. DCN EEC0529. 13. Foley, N.K., Jaskula, B.W., Kimball, B.E., and Schulte, R.F., 2017, Gallium, chap. H of Schulz, K.J., DeYoung, J.H., Jr., Seal, R.R., II, and Bradley, D.C., eds., Critical mineral resources of the United States—Economic and environmental geology and prospects for future supply: U.S. Geological Survey Professional Paper 1802, p. HI- H35. Available online at https://doi.org/10.3133/ppl802H. EPA-HQ-OW-2021-0547. DCN EEC0607. 43 ------- 14. Robertson, A. 2018. The Last Scan: Inside the desperate fight to keep old TVs alive. The Verge. Available online at https://www.theverge.com/2018/2/6/16973914/tvs-crt- restoration-led-gaming-vintage. EPA-HQ-OW-2021-0547. DCN 11129. 15. Rydberg, K. 2021. Albany County Sewer District Wastewater Discharge Permit No. 7 Gallium Discharge. Received by Craig Hurteau. (23 March). EPA-HQ-OW-2021-0547. DCN EEC0582. 16. Shanks, W.C.P., III, Kimball, B.E., Tolcin, A.C., and Guberman, D.E. 2017. Germanium and indium, chap. I of Schulz, K.J., DeYoung, J.H., Jr., Seal, R.R., II, and Bradley, D.C., eds., Critical mineral resources of the United States—Economic and environmental geology and prospects for future supply: U.S. Geological Survey Professional Paper 1802, p. II- 127, https://doi.org/10.3133/ppl802l. EPA-HQ-OW-2021-0547. DCN EEC0610. 17. Semiconductor Industry Association. 2016. SIA Overview and Responses to EPA Water Office. (7 July). EPA-HQ-OW-2021-0547. DCN EEC0012. 18. Tang, C.Y., et al. 2006. Use of Reverse Osmosis Membranes to Remove Perfluorooctane Sulfonate (PFOS) from Semiconductor Wastewater. Environmental Science & Technology. EEC0612. 19. U.S. EPA. 1983. Development Documents for Effluent Limitations Guidelines and Standards for the Electrical and Electronic Components Point Source Category Phase I. (March). EPA- HQ-0W-2021-0547. DCN EEC0597. 20. U.S. EPA. 1984. Development Documents for Effluent Limitations Guidelines and Standards for the Electrical and Electronic Components Point Source Category Phase II. (Feburary). EPA- HQ-0W-2021-0547. DCN EEC0598. 21. U.S. EPA. 2004. Local Limits Development Guidance. (July). EPA-HQ-OW-2021-0547. DCN EEC0600. 22. U.S. EPA. 2008. Municipal Nutrient Removal Technologies Reference Document. (September). EPA-HQ-OW-2021-0547. DCN EEC0614. 23. U.S. EPA. 2016. Summary Notes from EPA's Meeting with the National Association of Clean Water Agencies (NACWA). (December). EPA-HQ-OW-2015-0665-0355. 24. Vermont Department of Environmental Conservation. 2021a. Final Discharge Permit for GLOBALFOUNDRIES Essex Junction NPDES No. VT0000400. (24 June). EPA-HQ- OW-2021-0547. DCN EEC0591. 25. Vermont Department of Environmental Conservation. 2021b. Fact Sheet for Final Permit for GLOBALFOUN DRIES Essex Junction NPDES No. VT0000400. (June). EPA-HQ-OW-2021-0547. DCN EEC0592. 26. World Semiconductor Council. 2017. Joint Statement of the 21st Meeting of World Semiconductor Council. (18 May). EPA-HQ-OW-2021-0547. DCN EEC0618. 27. World Semiconductor Council. 2018. Semiconductor Industry Statement to the UN Stockholm Convention POP-Review Committee on Phase-Out of PFOS. (15 February). EPA- H Q-0 W-2021-0547. DCN EEC0611. 28. World Semiconductor Council and Semiconductor Industry Associations. 2019. Comments of the Associations of the World Semiconductor Council (WSC) on the Consultation Document on Proposed Amendments to the Prohibition of Certain Toxic Substances Regulations, 212 from PFOS, PFOA, LC-PFCAs, PBDEs, DP and DBDPE (18 February). EPA-HQ-OW-2021-0547. DCN EEC0619. 44 ------- Attachment A: Summary of E&EC Permitting Information ------- Table A-l and Table A-2 summarize permit information for E&EC indirect discharge facilities that are permitted either solely under the ELGs at 40 CFR 469 and under 40 CFR 469 and a combination of 40 CFR 433 and 40 CFR 471, respectively. For each parameter, the tables provide counts of facilities whose permits list each parameter (either for limitations or for monitoring only) as well as the basis of any limitations. For permits that include local limits, the tables list the minimum, maximum, and mean concentrations of those local limits. Note that the local limits include a variety of durations and frequencies including but not limited to daily maximum, monthly average, and instantaneous maximum limits. Parameters highlighted in yellow are pollutants regulated at 40 CFR 469; for Table A-l these include pollutants regulated at Subparts A, B, and D, and for Table A-2 these include pollutants regulated at Subparts A and B. Parameters highlighted in orange in Table A-2 are pollutants regulated at 40 CFR 433. A-l ------- Table A-l. Permit Information for E&EC Indirect Discharge Facilities Permitted Solely Under 40 CFR 469 Count of Facilities with Permit Limits Local Limits Parameter Count of Facilities with Parameter (N 92 permits) 40 CFR 469 ELG Limits Local Limits Local Limits More Stringent than ELG Limits Minimum Maximum Mean Units 1,2-Dichloroethane 2 N/A 2 N/A 0.5 0.5 0.5 mg/l 1,4-Dioxane 5 N/A 5 N/A 1 1 1 mg/l 2,4-Dinitrotoluene 2 N/A 2 N/A 0.13 0.13 0.13 mg/l Acrylonitrile 2 N/A 2 N/A 1 1 1 mg/l Aldrin 7 N/A 7 N/A 0.01 0.01 0.01 mg/l Alkalinity 1 N/A 0 N/A N/A N/A N/A N/A Aluminum 1 N/A 1 N/A 9.4 9.4 9.4 mg/l Ammonia 19 N/A 16 N/A 40 662 348 mg/l Antimony, Total 17 2 15 0 5 5 5 mg/l Arsenic, Total 74 7 71 6 0.047 15 1.21 mg/l Barium, Total 2 N/A 2 N/A 5 5 5 mg/l Beryllium 18 N/A 18 N/A 0.01 1 0.737 mg/l BOD5 13 N/A 10 N/A 240 1,880 1,144 mg/l Boron, Total 5 N/A 5 N/A 1 20 5.6 mg/l Bromide 1 N/A 1 N/A 0.1 0.1 0.1 mg/l BTEX 1 N/A 1 N/A 2.6 2.6 2.6 mg/l Cadmium, Total 71 2 71 1 0.01 15 1.8 mg/l A-2 ------- Table A-l. Permit Information for E&EC Indirect Discharge Facilities Permitted Solely Under 40 CFR 469 Count of Facilities with Permit Limits Local Limits Parameter Count of Facilities with Parameter (N 92 permits) 40 CFR 469 ELG Limits Local Limits Local Limits More Stringent than ELG Limits Minimum Maximum Mean Units Chlordane 9 N/A 9 N/A 0.01 0.03 0.0144 mg/l Chloride 12 N/A 6 N/A 175 880 404 mg/l Chlorinated Phenolics 1 N/A 1 N/A 0.189 0.189 0.189 mg/L Chlorine Demand 2 N/A 2 N/A 50 50 50 mg/l Chlorobenzene 2 N/A 2 N/A 0.2 0.2 0.2 mg/l Chloroform 2 N/A 2 N/A 0.2 0.2 0.2 mg/l Chromium, Hexavalent 1 N/A 1 N/A 10 10 10 mg/l Chromium, Total 71 N/A 71 N/A 0.5 25 5.77 mg/l Chronic pH Excursions 2 N/A 2 N/A 0 60 30 minutes COD 11 N/A 3 N/A 420 3,000 1,604 mg/l Copper, Total 73 N/A 73 N/A 0.13 17 3.59 mg/l Cyanide, Total 71 N/A 71 N/A 0.01 10 2.37 mg/l Dieldrin 7 N/A 7 N/A 0.01 0.01 0.01 mg/l Electrical Conductivity 1 N/A 1 N/A 712 712 712 umhos/cm Endosulfan 1 N/A 1 N/A 0.0013 0.0013 0.0013 mg/l Endrin 8 N/A 8 N/A 0.0006 0.01 0.00883 mg/l Fixed Dissolved Solids 1 N/A 1 N/A 4,270 4,270 4,270 mg/l A-3 ------- Table A-l. Permit Information for E&EC Indirect Discharge Facilities Permitted Solely Under 40 CFR 469 Count of Facilities with Permit Limits Local Limits Parameter Count of Facilities with Parameter (N 92 permits) 40 CFR 469 ELG Limits Local Limits Local Limits More Stringent than ELG Limits Minimum Maximum Mean Units Flash Cup 2 N/A 2 N/A 60 60 60 °C Flash Point 7 N/A 7 N/A 60 60 60 °C Flow 32 N/A 24 N/A 0.329 4,824,000 403,236 GPD Fluoride, Total 26 2 23 0 3 180 39.2 mg/l Formaldehyde 7 N/A 7 N/A 50 50 50 mg/l Hexachlorocyclohexane 8 N/A 8 N/A 0.0007 0.01 0.00884 mg/l Iron, Total 4 N/A 4 N/A 5 250 69.5 mg/l Lead, Total 70 N/A 70 N/A 0.04 40 4.6 mg/l Manganese, Total 8 N/A 8 N/A 0.5 6.1 4.08 mg/l Mercury, Total 75 N/A 75 N/A 0.000142 142 1.88 mg/l Molybdenum, Total 23 N/A 17 N/A 0.15 2.3 1.54 mg/l Nickel, Total 72 N/A 72 N/A 0.31 22 4.04 mg/l Nitrate 1 N/A 1 N/A No concentration-based limits Nitrobenzene 2 N/A 2 N/A 2 2 2 mg/l Oil and Grease 64 N/A 64 N/A 50 600 160 mg/l Organophosphate 2 N/A 2 N/A 1 1 1 mg/l PCBs 14 N/A 14 N/A 0.01 0.222 0.0212 mg/l A-4 ------- Table A-l. Permit Information for E&EC Indirect Discharge Facilities Permitted Solely Under 40 CFR 469 Count of Facilities with Permit Limits Local Limits Parameter Count of Facilities with Parameter (N 92 permits) 40 CFR 469 ELG Limits Local Limits Local Limits More Stringent than ELG Limits Minimum Maximum Mean Units Pentachlorophenol 2 N/A 2 N/A 0.04 0.04 0.04 mg/l Pesticides 6 N/A 6 N/A 0.01 0.01 0.01 mg/l PH 90 N/A 90 N/A 5 12.5 NC SU Phenolics 8 N/A 8 N/A 5 30 8.13 mg/l Phenols 19 N/A 19 N/A 1 500 50.8 mg/l Phosphorus, Total 2 N/A 2 N/A 9 9 9 mg/l Priority Pollutants 1 N/A 0 N/A N/A N/A N/A N/A Selenium, Total 44 N/A 43 N/A 0.006 9.37 1.68 mg/l Silver, Total 64 N/A 64 N/A 0.04 15 3.22 mg/l Sodium 1 N/A 1 N/A 140 140 140 mg/l Sulfate 6 N/A 6 N/A 400 3,660 1,365 mg/l Sulfides 18 N/A 17 N/A 0.1 10 2.38 mg/l TDS 14 N/A 6 N/A 1,000 4,270 1,809 mg/l Temperature 20 N/A 20 N/A 40 66 61.1 °C Total Detectable DDT 7 N/A 7 N/A 0.01 0.01 0.01 mg/l Total Kjeldahl Nitrogen 2 N/A 2 N/A 75 75 75 mg/l A-5 ------- Table A-l. Permit Information for E&EC Indirect Discharge Facilities Permitted Solely Under 40 CFR 469 Count of Facilities with Permit Limits Local Limits Parameter Count of Facilities with Parameter (N 92 permits) 40 CFR 469 ELG Limits Local Limits Local Limits More Stringent than ELG Limits Minimum Maximum Mean Units Total Petroleum Hydrocarbon 1 N/A 1 N/A 100 100 100 mg/l Toxaphene 7 N/A 7 N/A 0.01 0.01 0.01 mg/l Trichloroethylene 2 N/A 2 N/A 0.2 0.2 0.2 mg/l TSS 23 N/A 13 N/A 175 2,031 959 mg/l TTO 90 88 23 5 0.5 2.13 1.65 mg/l Zinc, Total 73 2 72 0 0.16 25 6.23 mg/l N/A - Not Applicable NC - Not Calculated A-6 ------- Table A-2. Permit Information for E&EC Indirect Discharge Facilities Permitted Under Both 40 CFR 469 and 40 CFR 433 Parameter Count of Facilities with Parameter (N 19 permits) Count of Facilities with Permit Limits Local Limits More 40 CFR 469 Local Stringent than ELG ELG Limits Limits Limits Minimum Local Limits Maximum Mean Units 1,2,4-Triazole 1 N/A 0 N/A N/A N/A N/A N/A Aldrin 2 N/A 2 N/A 0 0.01 0.005 mg/l Ammonia 5 N/A 4 N/A 25 150 66.3 mg/l Antimony, Total 3 N/A 3 N/A 5 5 5 mg/l Arsenic, Total 13 2 13 3 0.06 3 1.01 mg/l Benzene 1 N/A 0 N/A N/A N/A N/A N/A Beryllium 3 N/A 3 N/A 0.75 0.75 0.75 mg/l BOD5 3 N/A 2 N/A 230 240 235 mg/l Bromine, Iodine, Chlorine 1 N/A 1 N/A 100 100 100 mg/l Cadmium, Total 19 N/A 13 N/A 0.14 15 2.7 mg/l Cerium, Total 1 N/A 0 N/A N/A N/A N/A N/A Chlordane 2 N/A 2 N/A 0 0.01 0.005 mg/l Chloride 2 N/A 0 N/A N/A N/A N/A N/A Choline Hydroxide 1 N/A 0 N/A N/A N/A N/A N/A Chromium, Total 19 N/A 12 N/A 0.62 10 3.12 mg/l Cobalt, Total 1 N/A 1 N/A 0.012 0.02 0.016 mg/l COD 3 N/A 0 N/A N/A N/A N/A N/A Copper, Total 19 N/A 12 N/A 0.208 15 4.09 mg/l Cyanate 1 N/A 1 N/A 10 10 10 mg/l Cyanide, Total 19 N/A 12 N/A 0.04 10 2.09 mg/l Dieldrin 2 N/A 2 N/A 0 0.01 0.005 mg/l Endrin 2 N/A 2 N/A 0 0.01 0.005 mg/l Ethylenediaminetetraacetic acid 1 N/A 0 N/A N/A N/A N/A N/A A-7 ------- Table A-2. Permit Information for E&EC Indirect Discharge Facilities Permitted Under Both 40 CFR 469 and 40 CFR 433 Parameter Count of Facilities with Parameter (N 19 permits) Count of Facilities with Permit Limits Local Limits More 40 CFR 469 Local Stringent than ELG ELG Limits Limits Limits Minimum Local Limits Maximum Mean Units Flash Point 3 N/A 3 N/A 60 60 60 °C Flow 6 N/A 4 N/A 2,230 8,100,000 2,945,664 GPD Fluoride, Total 5 N/A 4 N/A 10 48 29 mg/l Formaldehyde 1 N/A 1 N/A 50 50 50 mg/l Gallium 1 N/A 0 N/A N/A N/A N/A N/A Hafnium 1 N/A 0 N/A N/A N/A N/A N/A Hexachlorocyclohexane 2 N/A 2 N/A 0 0.01 0.005 mg/l Hydrogen Peroxide 1 N/A 0 N/A N/A N/A N/A N/A Langelier Saturation Index 1 N/A 0 N/A N/A N/A N/A N/A Lead, Total 19 N/A 14 N/A 0.039 40 6.2 mg/l Mercuric Chloride 1 N/A 1 N/A 1 1 1 mg/l Mercury, Total 13 N/A 13 N/A 0.0002 2 0.328 mg/l Molybdenum, Total 3 N/A 3 N/A 3.7 6.58 5.62 mg/l Nickel, Total 18 N/A 12 N/A 0.2 12 3.25 mg/l Oil and Grease 10 N/A 10 N/A 100 300 154 mg/l PCBs 2 N/A 2 N/A 0 0.01 0.005 mg/l PH 15 N/A 15 N/A 5 12.5 NC SU Phenolics 2 N/A 2 N/A 5 30 17.5 mg/l Phenols 2 N/A 2 N/A 30 30 30 mg/l Phosphorus, Total 2 N/A 1 N/A 4.9 4.9 4.9 mg/l Ruthenium, Total 1 N/A 0 N/A N/A N/A N/A N/A Selenium, Total 9 N/A 9 N/A 0.2 4.48 1.54 mg/l Silver, Total 19 N/A 12 N/A 0.05 5 1.18 mg/l Sulfides 3 N/A 3 N/A 0.1 10 3.4 mg/l A-8 ------- Table A-2. Permit Information for E&EC Indirect Discharge Facilities Permitted Under Both 40 CFR 469 and 40 CFR 433 Parameter Count of Facilities with Parameter (N 19 permits) Count of Facilities with Permit Limits Local Limits More 40 CFR 469 Local Stringent than ELG ELG Limits Limits Limits Minimum Local Limits Maximum Mean Units TDS 3 N/A 0 N/A N/A N/A N/A N/A Temperature 4 N/A 4 N/A 40 65.6 56.4 °C Tetrachloroethylene 1 N/A 1 N/A 0.031 0.031 0.031 mg/l Tin, Total 1 N/A 0 N/A N/A N/A N/A N/A Total Detectable DDT 2 N/A 2 N/A 0 0.01 0.005 mg/l Total Kjeldahl Nitrogen 1 N/A 0 N/A N/A N/A N/A N/A Toxaphene 2 N/A 2 N/A 0 0.01 0.005 mg/l Trichloroethylene 1 N/A 1 N/A 0.026 0.026 0.026 mg/l Tritium 1 N/A 0 N/A N/A N/A N/A N/A TSS 5 N/A 2 N/A 150 300 225 mg/l TTO 18 18 2 1 1 2.13 1.57 mg/l Zinc, Total 19 N/A 12 N/A 2.55 25 6.57 mg/l Zirconium, Total 1 N/A 1 N/A 10 10 10 mg/l N/A - Not Applicable NC - Not Calculated A-9 ------- Table A-3 and Table A-4 summarize permit information for E&EC direct discharge facilities that are permitted either solely under the ELGs at 40 CFR 469 and under both 40 CFR 469 and 40 CFR 433, respectively. For each parameter, the tables provide counts of facilities whose permits list each parameter (either for limitations or for monitoring only) as well as the basis of any limitations. For permits that include local limits, the tables list the minimum, maximum, and mean concentrations of those local limits. Note that the local limits include a variety of durations and frequencies including but not limited to daily maximum, monthly average, and instantaneous maximum limits. Parameters highlighted in yellow are pollutants regulated at 40 CFR 469; for Table A-3 these include pollutants regulated at Subparts A and Band for Table A-4 these include pollutants regulated at Subpart A. Parameters highlighted in orange in Table A-4 are pollutants regulated at 40 CFR 433. A-10 ------- Table A-3. Permit Information for E&EC Direct Discharge Facilities Permitted Solely Under 40 CFR 469 Count of Count of Facilities with Permit Limits Local Limits Parameter Facilities with Parameter (N 3 permits) 40 CFR 469 ELG Limits Local Limits Local Limits More Stringent than ELG Limits Minimum Maximum Mean Units Acetone 1 N/A 0 N/A N/A N/A N/A N/A Aluminum 1 N/A 1 N/A 1 1 1 mg/l Ammonia 1 N/A 1 N/A 1.3 2.7 2 mg/l Arsenic, Total 1 0 1 0 0.1 0.1 0.1 mg/l BOD5 1 N/A 1 N/A 15 30 22.5 mg/l Bromine, Total 1 N/A 1 N/A 0.2 0.5 0.35 mg/l Bromobenzene 1 N/A 0 N/A N/A N/A N/A N/A Bromoform 1 N/A 0 N/A N/A N/A N/A N/A CBOD 1 N/A 1 N/A 8 8 8 mg/l Chlorine, Total Residual 1 N/A 1 N/A 0.1 0.5 0.3 mg/l Chloroform 1 N/A 0 N/A N/A N/A N/A N/A Chromium, Hexavalent 1 N/A 1 N/A 0.013 0.013 0.013 mg/l Chromium, Total N/A 2 N/A 0.02 0.5 0.19 mg/l cis-1,2 Dichloroethylene 1 N/A 1 N/A 0.01 0.01 0.01 mg/l Cobalt, Total 1 N/A 1 N/A 0.006 0.006 0.006 mg/l Copper, Total 1 N/A 1 N/A No concentration-based limits Cyanide, Total 1 N/A 1 N/A 0.06 0.06 0.06 mg/l Dichlorobromomethane 1 N/A 0 N/A N/A N/A N/A N/A Dichlorodifluoromethane 1 N/A 1 N/A 0.01 0.01 0.01 mg/l Dissolved Oxygen 1 N/A 0 N/A N/A N/A N/A N/A Ethylbenzene 1 N/A 0 N/A N/A N/A N/A N/A Fecal Coliform 1 N/A 1 N/A 200 400 300 MP N/100 ml Flow 2 N/A 2 N/A 520,000 6,000,000 2,406,667 GPD Fluoride, Total 3 2 2 1 7.3 7.3 7.3 mg/l Free Available Chlorine 1 N/A 1 N/A 0.2 0.5 0.35 mg/l A-ll ------- Table A-3. Permit Information for E&EC Direct Discharge Facilities Permitted Solely Under 40 CFR 469 Parameter Count of Facilities with Parameter (N 3 permits) Count of Facilities with Permit Limits Local Limits 40 CFR 469 ELG Limits Local Limits Local Limits More Stringent than ELG Limits Minimum Maximum Mean Units Germanium, Total 1 N/A 0 N/A N/A N/A N/A N/A Hafnium 1 N/A 0 N/A N/A N/A N/A N/A Iron, Total 1 N/A 0 N/A N/A N/A N/A N/A Lead, Total 1 N/A 1 N/A 0.08 0.08 0.08 mg/l Methyl Tert Butyl Ether 1 N/A 1 N/A 0.01 0.01 0.01 mg/l Molybdenum, Total 1 N/A 1 N/A 3.75 3.75 3.75 mg/l Nickel, Total 1 N/A 0 N/A N/A N/A N/A N/A N-Methyl-2-Pyrrolidone 1 N/A 1 N/A 0.02 0.02 0.02 mg/l Palladium, Total 1 N/A 1 N/A 0.1 0.1 0.1 mg/l PH 2 1 1 6.5 8.5 NC SU Phosphate, Total 1 N/A 1 N/A 10 15 12.5 mg/l Rhenium, Total 1 N/A 0 N/A N/A N/A N/A N/A Ruthenium, Total 1 N/A 0 N/A N/A N/A N/A N/A Silver, Total 1 N/A 0 N/A N/A N/A N/A N/A Solids, Settleable 1 N/A 1 N/A 0.1 0.1 0.1 mg/l Tantalum, Total 1 N/A 0 N/A N/A N/A N/A N/A TDS 1 N/A 1 N/A 1,628 4,884 3,318 mg/l Tetrachloroethylene 1 N/A 1 N/A 0.0012 0.0012 0.0012 mg/l Tin, Total 1 N/A 1 N/A 2 2 2 mg/l Titanium, Total 1 N/A 1 N/A 0.53 0.53 0.53 mg/l Toluene 1 N/A 0 N/A N/A N/A N/A N/A Trichloroethylene 1 N/A 0 N/A N/A N/A N/A N/A TSS 2 1 2 0 25 40 32.5 mg/l TTO 2 2 1 0 2.74 2.74 2.74 mg/l Tungsten, Total 1 N/A 1 N/A 3.75 3.75 3.75 mg/l A-12 ------- Table A-3. Permit Information for E&EC Direct Discharge Facilities Permitted Solely Under 40 CFR 469 Count of Count of Facilities with Permit Limits Local Limits Facilities with Parameter 40 CFR 469 Local Local Limits More Parameter (N 3 permits) ELG Limits Limits Stringent than ELG Limits Minimum Maximum Mean Units Vinyl chloride 1 N/A 0 N/A N/A N/A N/A N/A Xylene 1 N/A 0 N/A N/A N/A N/A N/A Zinc, Total 1 N/A 1 N/A 0.36 0.36 0.36 mg/l N/A - Not Applicable NC - Not Calculated A-13 ------- Table A-4. Permit Information for E&EC Direct Discharge Facilities Permitted Under Both 40 CFR 469 and 40 CFR 433 Count of Facilities Count of Facilities with Permit Limits Local Limits Parameter with Parameter (N 1 permit) 40 CFR 469 ELG Limits Local Limits Local Limits More Stringent than ELG Limits Minimum Maximum Mean Units Ammonia 1 N/A 0 N/A N/A N/A N/A N/A BOD5 1 N/A 0 N/A N/A N/A N/A N/A Cadmium, Total 1 N/A 1 N/A No concentration-based limits Chromium, Trivalent 1 N/A 1 N/A No concentration-based limits Copper, Total 1 N/A 1 N/A No concentration-based limits Cyanide, Free 1 N/A 1 N/A 0.65 1.2 0.925 mg/l Dichloroethene 1 N/A 0 N/A N/A N/A N/A N/A E. Coli 1 N/A 1 N/A 77 77 77 #/100 ml Ethyl Benzene 1 N/A 0 N/A N/A N/A N/A N/A Flow 1 N/A 1 N/A 8,000,000 8,000,000 8,000,000 GPD Fluoride, Total 1 1 1 1 28 28 28 mg/l Hydrogen Peroxide 1 N/A 1 N/A 10 15 12.5 mg/l Iron, Total 1 N/A 0 N/A N/A N/A N/A N/A Lead, Total 1 N/A 1 N/A No concentration-based limits Nickel, Total 1 N/A 1 N/A No concentration-based limits Nitrite plus Nitrate 1 N/A 0 N/A N/A N/A N/A N/A Nitrogen, Total 1 N/A 0 N/A N/A N/A N/A N/A Oil and Grease 1 N/A 1 N/A No concentration-based limits PFHpA 1 N/A 0 N/A N/A N/A N/A N/A PFHxS 1 N/A 0 N/A N/A N/A N/A N/A PFNA 1 N/A 0 N/A N/A N/A N/A N/A PFOA 1 N/A 0 N/A N/A N/A N/A N/A PFOS 1 N/A 0 N/A N/A N/A N/A N/A PH 1 0 1 1 6.5 8.5 NC SU Phosphorus, Total 1 N/A 1 N/A 0.8 0.8 0.8 mg/l A-14 ------- Table A-4. Permit Information for E&EC Direct Discharge Facilities Permitted Under Both 40 CFR 469 and 40 CFR 433 Count of Facilities Count of Facilities with Permit Limits Local Limits with Parameter 40 CFR 469 Local Local Limits More Parameter (N 1 permit) ELG Limits Limits Stringent than ELG Limits Minimum Maximum Mean Units Silver, Total 1 N/A 1 N/A No concentration-based limits Tetrachloroethylene 1 N/A 0 N/A N/A N/A N/A N/A Total Kjeldahl Nitrogen 1 N/A 0 N/A N/A N/A N/A N/A Trichloroethylene 1 N/A 0 N/A N/A N/A N/A N/A TSS 1 N/A 1 N/A 10.5 10.5 10.5 mg/l TTO 1 1 0 0 N/A N/A N/A N/A Ultimate Oxygen Demand 1 N/A 1 N/A No concentration-based limits Vinyl Chloride 1 N/A 0 N/A N/A N/A N/A N/A Whole Effluent Toxicity 1 N/A 1 N/A 7 7 7 % Xylene 1 N/A 0 N/A N/A N/A N/A N/A Zinc, Total 1 N/A 1 N/A No concentration-based limits N/A - Not Applicable NC - Not Calculated A-15 ------- Attachment B: Summary of E&EC Wastewater Discharge Characterization ------- Table B-l and Table B-2 provide summary statistics for all pollutants detected in wastewater discharges from E&EC indirect and direct discharge facilities. The tables include counts of facilities, counts of results, and statistics for detected concentrations (minimum, maximum, mean, and median concentrations). Detected concentrations are rounded to no more than 3 significant digits. The tables also present toxic weighting factors for pollutants where available. Toxic weighting factors are derived from chronic aquatic life criteria and human health criteria established for the consumption offish; they are used to compare the toxicity of one pollutant relative to another and are normalized based on the toxicity of copper (ERG, 2007). All columns are queried from the E&EC wastewater characterization Access database except for median concentration which was calculated in Excel. B-l ------- Table B-l. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Indirect Discharge Facilities Pollutant Units Number of Facilities Measuring Number ol Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Total Toxic Organics mg/L 57 27 836 182 N/A 0.00092 0.957 0.0752 0.01675 Classical Wet Chemistry Acidity, Total mg/L 1 1 40 36 N/A 16 56 35.4 38 Alkalinity mg/L 2 2 93 93 N/A 56 240 134 130 Ammonia mg/L 30 30 618 607 0.00111 0.05 1,300 87.9 36.1 BOD5 mg/L 28 25 750 690 N/A 0.3 4,178 86.6 46.85 Calcium hardness mg/L 1 1 5 5 N/A 696 828 768 784 Carbon dioxide, free mg/L 1 1 40 39 N/A 0.6 2.78 1.20 1.1 CBOD mg/L 1 1 4 3 N/A 14 18 16.3 17 COD mg/L 16 16 191 178 N/A 7 923 158 144.5 Conductivity umhos/cm 6 6 694 694 N/A 9.05 5,850 2,731 3,264.5 Cyanide, Total mg/L 51 22 933 111 1.11 0.0014 4.2 0.0756 0.025 Dissolved oxygen mg/L 1 1 40 40 N/A 12.21 39.4 23.4 24.49 Fixed dissolved solids mg/L 1 1 9 9 N/A 230 3,540 2,060 2,064 Hydrogen peroxide mg/L 1 1 79 79 N/A 3.8 780 488 500 Nitrogen, Total mg/L 3 3 12 12 N/A 9.14 25.3 16.6 17.4 Oil & Grease mg/L 24 12 291 161 N/A 0.2 2,701.7 29.7 4.8 Oil & Grease, non-polar mg/L 1 1 9 3 N/A 1.05 7.4 4.15 4 Oil & Grease, polar mg/L 1 1 9 5 N/A 1.2 10.6 3.53 2.1 Phosphorus, Total mg/L 18 17 142 139 N/A 0.102 202 6.35 1.72 B-2 ------- Table B-l. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Indirect Discharge Facilities Pollutant Units Number of Facilities Measuring Number ol Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Total dissolved solids mg/L 28 27 393 392 N/A 58 13,800 872 566 Total Kjeldahl Nitrogen mg/L 8 8 133 131 N/A 0.28 274 76.8 58.5 Total petroleum hydrocarbons mg/L 3 2 20 4 0.1 1.8 3.6 2.92 3.145 Total suspended solids mg/L 46 42 936 808 N/A 0.4 7,760 71.2 23 Anions Bromide mg/L 2 2 430 428 N/A 0.01 24 0.107 0.05 Chloride mg/L 28 27 419 418 0.0000243 1 7,090 222 138 Fluoride, Total (excluding Skorpios continuous monitoring data) mg/L 36 27 907 783 0.03 0.00054 114 9.02 6.8 Fluoride, Total (Skorpios continuous monitoring data) mg/L 1 1 96,160 96,160 0.03 0.92 100 14.4 17.92 Nitrates mg/L 6 6 40 40 0.000747 0.16 12.3 4.56 4.28 Nitrates/Nitrites mg/L 9 9 52 51 N/A 0.5 12.44 4.38 4.37 Nitrites mg/L 6 6 40 38 0.0032 0.026 4.19 0.455 0.265 Sulfates mg/L 11 11 169 169 0.0000056 5.9 3,470 698 599 Sulfides mg/L 11 4 144 21 N/A 0.027 0.92 0.237 0.19 Metals Aluminum, Total mg/L 10 9 26 20 0.06 0.0215 0.434 0.119 0.0755 Antimony, Total mg/L 18 7 161 17 0.01 0.0000951 0.129 0.0186 0.009 Arsenic, Total mg/L 53 35 1,159 482 3.47 0.000063 6.16 0.192 0.062 B-3 ------- Table B-l. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Indirect Discharge Facilities Pollutant Units Number of Facilities Measuring Number ol Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Barium, Total mg/L 11 10 26 25 0.00199 0.000723 0.039 0.0131 0.0127 Beryllium, Total mg/L 14 3 35 3 1.05 0.000000025 0.00072 0.000297 0.00017 Bismuth, Total mg/L 1 1 14 13 N/A 0.03 0.308 0.0967 0.066 Boron, Total mg/L 8 7 228 218 0.00834 0.047 5 0.311 0.27 Cadmium, Total mg/L 64 17 1,072 157 22.8 0.0000116 0.1928 0.00522 0.002 Calcium, Total mg/L 3 3 42 42 0.000028 1.49 481 274 279 Cerium, Total mg/L 1 1 40 38 N/A 0.051 0.846 0.232 0.1465 Chromium, Total mg/L 68 42 1,211 280 0.07 0.0000133 0.82 0.0192 0.005 Cobalt, Total mg/L 10 6 62 9 0.11 0.0000218 0.0139 0.00253 0.000625 Copper, Total mg/L 67 57 1,309 996 0.623 0.00015 5.64 0.213 0.05 Gallium, Total mg/L 1 1 3 2 0.13 0.025 0.269 0.147 0.147 Iron, Total mg/L 7 7 33 16 0.0056 0.00684 1.91 0.208 0.0671 Lead, Total mg/L 66 33 1,062 199 2.24 0.00002 0.44 0.0200 0.005 Magnesium, Total mg/L 2 2 2 2 0.000866 0.895 1.16 1.03 1.0275 Manganese, Total mg/L 9 8 22 21 0.103 0.000599 0.0337 0.0103 0.00431 Mercury, Total mg/L 45 24 592 111 110 0.000001 0.02 0.000953 0.00007 Molybdenum, Total mg/L 36 25 169 76 0.2 0.00014 3.74 0.0921 0.00793 Nickel, Total mg/L 69 48 1,170 753 0.1 0.000154 2.99 0.118 0.01 Potassium, Total mg/L 4 4 401 401 0.00105 0.754 181 36.7 35.6 Selenium, Total mg/L 42 19 441 116 1.12 0.00008 0.6 0.0181 0.006 Silver, Total mg/L 64 24 1,028 211 16.5 0.000026 0.4 0.00771 0.002 B-4 ------- Table B-l. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Indirect Discharge Facilities Pollutant Units Number of Facilities Measuring Number of Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Sodium, Total mg/L 4 4 401 401 0.00000549 26.2 207 118 119 Tellurium, Total mg/L 1 1 14 14 0.04 0.053 0.624 0.234 0.157 Tin, Total mg/L 9 4 22 4 0.3 0.000187 0.00565 0.00315 0.003385 Titanium, Total mg/L 3 3 3 3 0.02 0.001 0.00504 0.0025 0.00146 Total metals mg/L 3 2 22 5 N/A 0.00109 0.03813 0.00911 0.00212 Vanadium, Total mg/L 4 2 10 2 0.28 0.00337 0.00514 0.00426 0.004255 Zinc, Total mg/L 67 60 1,284 1,009 0.04 0.000751 22 0.112 0.03 Zirconium, Total mg/L 2 1 41 2 0.54 0.005 0.006 0.0055 0.0055 Organic Compounds 1,1,2-Trichloroethane mg/L 33 1 647 1 0.03 0.00274 0.00274 0.00274 0.00274 1,1-Dichloroethane mg/L 24 2 590 3 0.000514 0.00038 0.0006 0.000457 0.00039 1,1-Dichloroethene mg/L 32 1 646 2 0.47 0.0004 0.00115 0.000775 0.000775 1,2,4-Triazole mg/L 1 1 2 2 N/A 1 1.2 1.1 1.1 1,2-Dichlorobenzene mg/L 35 2 683 3 0.01 0.00104 0.0065 0.00457 0.00618 1,2-Dichloroethane mg/L 33 2 647 2 0.01 0.00082 0.00199 0.00141 0.001405 1,3-Dichlorobenzene mg/L 34 2 696 2 0.01 0.00559 0.00582 0.00571 0.005705 1,4-Dichlorobenzene mg/L 34 1 696 1 0.07 0.00602 0.00602 0.00602 0.00602 2,4-Dimethylphenol mg/L 21 1 545 2 0.00941 0.044 0.044 0.044 0.044 2-Hexanone mg/L 12 1 43 1 0.000375 0.00137 0.00137 0.00137 0.00137 2-Nitrophenol mg/L 31 1 594 1 0.00162 0.00041 0.00041 0.00041 0.00041 B-5 ------- Table B-l. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Indirect Discharge Facilities Pollutant Units Number of Facilities Measuring Number ol Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration 4-Bromophenyl phenyl ether mg/L 21 1 542 1 0.13 0.0013 0.0013 0.0013 0.0013 624 Volatiles mg/L 30 5 101 12 N/A 0.0025 12.1 1.12 0.02045 625 Semi Volatiles mg/L 26 1 83 1 N/A 0.0325 0.0325 0.0325 0.0325 Acetone mg/L 22 18 101 45 0.00000846 0.0091 37.7 2.71 0.182 Acrolein mg/L 26 1 582 3 0.98 0.00213 0.0305 0.0133 0.0074 Benzene mg/L 27 3 717 8 0.03 0.00107 0.00232 0.00149 0.00114 Benzidine mg/L 22 1 546 1 2818 0.0073 0.0073 0.0073 0.0073 Benzyl butyl phthalate mg/L 31 3 595 3 0.02 0.0013 0.009204 0.00410 0.0018 Bis(2-chloroisopropyl) ether mg/L 21 1 544 1 0.02 0.02797 0.02797 0.0280 0.02797 Bis(2-ethylhexyl) phthalate mg/L 34 18 605 86 0.25 0.000543 0.201 0.0375 0.0093 Bromodichloromethane mg/L 35 15 651 59 0.03 0.00016 0.0107 0.00233 0.002 Bromoform mg/L 25 7 590 32 0.00457 0.0004 0.00825 0.00168 0.00145 Bromomethane mg/L 25 2 591 3 0.05 0.00057 0.00103 0.000737 0.00061 Butanone mg/L 16 1 83 1 0.0000263 0.00485 0.00485 0.00485 0.00485 Carbon disulfide mg/L 12 3 39 6 2.8 0.000863 0.00487 0.00313 0.003635 Chlorobenzene mg/L 26 1 593 1 0.00293 0.00269 0.00269 0.00269 0.00269 Chloroform mg/L 37 24 658 93 0.00208 0.000207 0.75 0.0116 0.00238 Chloromethane mg/L 25 3 588 6 0.00536 0.00052 0.00439 0.00225 0.00217 Choline hydroxide mg/L 1 1 2 1 N/A 0.9 0.9 0.9 0.9 Dibromochloromethane mg/L 26 7 591 34 0.04 0.00062 0.0184 0.00200 0.00135 B-6 ------- Table B-l. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Indirect Discharge Facilities Pollutant Units Number of Facilities Measuring Number ol Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Dibutyl phthalate mg/L 32 6 595 12 0.01 0.000371 0.00797 0.00237 0.0015 Dichloromethane mg/L 36 8 775 15 0.00101 0.0004 0.176 0.0225 0.00225 Diethyl phthalate mg/L 24 8 552 17 0.000688 0.000342 0.0132 0.00315 0.0017 Dimethyl phthalate mg/L 21 2 545 2 0.00329 0.005051 0.0083 0.00668 0.0066755 Dioctyl phthalate mg/L 22 2 562 2 0.46 0.0019 0.002 0.00195 0.00195 Ethyl benzene mg/L 33 3 767 4 0.00141 0.00111 0.003 0.00192 0.00179 Isopropyl alcohol mg/L 3 1 39 3 N/A 2.6 12.1 7.12 6.66 Naphthalene mg/L 34 2 628 4 0.01 0.0013 0.008606 0.00418 0.0034 N-Methyl-2-pyrrolidone mg/L 2 1 106 87 N/A 0.32 5,000 103 9.4 N-Nitrosodipropylamine mg/L 19 1 542 1 1.1 0.0086 0.0086 0.0086 0.0086 Pentachlorophenol mg/L 31 1 593 1 0.55 0.005439 0.005439 0.00544 0.005439 PFOA mg/L 1 1 1 1 N/A 0.0000229 0.0000229 0.0000229 0.0000229 PFOS mg/L 1 1 1 1 N/A 0.00001 0.00001 0.00001 0.00001 Phenol mg/L 41 15 736 53 0.02 0.0000045 2.4 0.128 0.0027 Pyridine mg/L 4 1 9 1 0.00302 0.00357 0.00357 0.00357 0.00357 Tetrachloroethylene mg/L 34 2 651 7 0.23 0.00102 0.02376 0.00665 0.00196 Toluene mg/L 36 5 772 9 0.00563 0.00065 0.01023 0.00358 0.00208 Toxaphene mg/L 12 1 101 1 30017 0.000002 0.000002 0.000002 0.000002 Trichloroethylene mg/L 34 4 633 14 0.01 0.00044 0.21 0.0174 0.0017 Vinyl chloride mg/L 25 1 591 2 0.22 0.00076 0.00289 0.00183 0.001825 Xylenes, Total mg/L 18 1 194 1 0.00432 0.02 0.02 0.02 0.02 B-7 ------- Table B-l. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Indirect Discharge Facilities Pollutant Units Number of Facilities Measuring Number of Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration PH PH SU 86 86 4,449 4,449 N/A 2 13 7.65 7.46 a Toxic weighting factors are derived from chronic aquatic life criteria and human health criteria established for the consumption offish; they are used to compare the toxicity of one pollutant relative to another and are normalized based on the the toxicity of copper (ERG, 2007). N/A- Not Available ------- Table B-2. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Direct Discharge Facilities Pollutant Units Number of Facilities Measuring Number of Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Total Toxic Organics mg/L 2 2 60 54 N/A 0.00013 0.02 0.00657 0.00378 Classical Wet Chemistry Ammonia mg/L 2 2 180 105 0.00111 0.01 13 4.78 5.3 BOD5 mg/L 2 2 135 132 N/A 2 8.9 5.18 5.3 Cyanide, Total mg/L 2 2 73 29 1.11 0.004 0.16 0.0190 0.01 Dissolved oxygen mg/L 1 1 135 135 N/A 6 8.9 7.11 7.1 Hydrogen peroxide mg/L 1 1 90 90 N/A 0.15 3.41 0.677 0.5 Oil & Grease mg/L 1 1 30 30 N/A 2 3 2.09 2 Phosphorus, Total mg/L 1 1 45 45 N/A 0.077 0.248 0.148 0.141 Total dissolved solids mg/L 1 1 90 90 N/A 833 1,430 1,116 1,108 Total residual chlorine mg/L 1 1 45 1 0.5 0.1 0.1 0.1 0.1 Total suspended solids mg/L 3 3 224 224 N/A 1.08 61 7.29 5.15 Anions Fluoride, Total mg/L 4 4 227 227 0.03 0.17 19 9.74 10 Phosphates mg/L 1 1 30 30 N/A 0.01 0.12 0.0488 0.04 Metals Aluminum, Total mg/L 1 1 45 39 0.06 0.1 0.9 0.179 0.1 Cadmium, Total mg/L 1 1 28 28 22.8 0.0002 0.056 0.00521 0.002 B-9 ------- Table B-2. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Direct Discharge Facilities Pollutant Units Number of Facilities Measuring Number of Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration Chromium, Hexavalent, Total mg/L 1 1 46 3 0.51 0.011 0.014 0.013 0.014 Chromium, Total mg/L 3 2 165 120 0.07 0.00011 0.56 0.0126 0.00107 Cobalt, Total mg/L 1 1 45 1 0.11 0.006 0.006 0.006 0.006 Copper, Total mg/L 2 2 105 102 0.623 0.013 0.092 0.0284 0.0255 Iron, Total mg/L 2 2 105 94 0.0056 0.044 0.345 0.114 0.104 Lead, Total mg/L 2 2 135 91 2.24 0.001 0.05 0.00155 0.001 Molybdenum, Total mg/L 1 1 45 10 0.2 0.03 0.07 0.039 0.03 Nickel, Total mg/L 2 1 105 90 0.1 0.008 0.186 0.0274 0.0215 Ruthenium, Total mg/L 1 1 15 1 N/A 0.1 0.1 0.1 0.1 Silver, Total mg/L 2 1 45 30 16.5 0.01 0.02 0.0147 0.01 Tungsten, Total mg/L 1 1 45 26 0.00525 0.11 0.21 0.145 0.135 Zinc, Total mg/L 2 2 150 106 0.04 0.008 0.05 0.0181 0.02 Organic Compounds Acetone mg/L 1 1 15 2 0.00000846 0.006 0.007 0.0065 0.0065 Bromodichlorometh mg/L 1 1 15 10 0.03 0.001 0.003 0.00163 0.00165 ane Bromoform mg/L 1 1 15 15 0.00457 0.005 0.022 0.0119 0.01 Chloroform mg/L 1 1 15 10 0.00208 0.001 0.002 0.00141 0.00105 Dichlorodifluoromet hane mg/L 1 1 45 1 0.000593 0.001 0.001 0.001 0.001 B-10 ------- Table B-2. Summary Statistics for Pollutants Detected in Wastewater Discharges from E&EC Direct Discharge Facilities Pollutant Units Number of Facilities Measuring Number of Facilities with Detects Number of Results Number of Detects Toxic Weighting Factora Minimum Detected Concentration Maximum Detected Concentration Mean Detected Concentration Median Detected Concentration N-Methyl-2- pyrrolidone mg/L 1 1 45 2 N/A 0.02 0.07 0.045 0.045 Toluene mg/L 1 1 15 2 0.00563 0.003 0.003 0.003 0.003 PH PH SU 4 4 364 364 N/A 3.37 10.91 7.22 7.2 a Toxic weighting factors are derived from chronic aquatic life criteria and human health criteria established for the consumption of fish; they are used to compare the toxicity of one pollutant relative to another and are normalized based on the toxicity of copper (ERG, 2007). N/A - Not Available B-ll ------- Table B-3 and Table B-4 provide the results of the E&EC "parameters of interest" selection criteria for indirect and direct dischargers, respectively. To be selected as a "parameter of interest," a detected analyte must meet either Criteria 1 or Criteria 2.1/2.2. B-12 ------- Table B-3. "Parameters of Interest" Selection Criteria Results for E&EC Indirect Discharge Facilities Parameter Criteria 1 40 CFR 469 Regulated Pollutant (Y/N) Criteria 2 Pollutant of Interest? (Y/N) Criteria 2.1 Frequency of Detection Criteria 2.2 Potential Environmental Concern > 25% of Facilities (Y/N) > 25% of Results (Y/N) Toxic Weighting Factor > 0.001 (Y/N) Nutrient (Y/N) Total Toxic Organics Total Toxic Organics Y Y N N N Y Classical Wet Chemistry Acidity, Total N Y Y N N N Alkalinity N Y Y N N N Ammonia N Y Y Y Y Y BOD5 N Y Y N N N Calcium hardness N Y Y N N N Carbon dioxide, free N Y Y N N N CBOD N Y Y N N N COD N Y Y N N N Conductivity N Y Y N N N Cyanide, Total N Y N Y N N Dissolved oxygen N Y Y N N N Fixed dissolved solids N Y Y N N N Hydrogen peroxide N Y Y N N N Nitrogen, Total N Y Y N Y Y Oil & Grease N Y Y N N N Oil & Grease, non-polar N Y Y N N N Oil & Grease, polar N Y Y N N N Phosphorus, Total N Y Y N Y Y Total dissolved solids N Y Y N N N B-13 ------- Table B-3. "Parameters of Interest" Selection Criteria Results for E&EC Indirect Discharge Facilities Parameter Criteria 1 40 CFR 469 Regulated Pollutant (Y/N) Criteria 2 Pollutant of Interest? (Y/N) Criteria 2.1 Frequency of Detection Criteria 2.2 Potential Environmental Concern > 25% of Facilities (Y/N) > 25% of Results (Y/N) Toxic Weighting Factor > 0.001 (Y/N) Nutrient (Y/N) Total Kjeldahl Nitrogen N Y Y N Y Y Total petroleum hydrocarbons N Y N Y N N Total suspended solids N Y Y N N N Anions Bromide N Y Y N N N Chloride N Y Y N N N Fluoride, Total Y Y Y Y N Y Nitrates N Y Y N Y Y Nitrates/Nitrites N Y Y N Y Y Nitrites N Y Y Y Y Y Sulfates N Y Y N N N Sulfides N Y N N N N Metals Aluminum, Total N Y Y Y N Y Antimony, Total Y Y N Y N Y Arsenic, Total Y Y Y Y N Y Barium, Total N Y Y Y N Y Beryllium, Total N N N Y N N Bismuth, Total N Y Y N N N Boron, Total N Y Y Y N Y Cadmium, Total Y Y N Y N Y B-14 ------- Table B-3. "Parameters of Interest" Selection Criteria Results for E&EC Indirect Discharge Facilities Parameter Criteria 1 40 CFR 469 Regulated Pollutant (Y/N) Criteria 2 Pollutant of Interest? (Y/N) Criteria 2.1 Frequency of Detection Criteria 2.2 Potential Environmental Concern > 25% of Facilities (Y/N) > 25% of Results (Y/N) Toxic Weighting Factor > 0.001 (Y/N) Nutrient (Y/N) Calcium, Total N Y Y N N N Cerium, Total N Y Y N N N Chromium, Total Y Y N Y N Y Cobalt, Total N Y N Y N N Copper, Total N Y Y Y N Y Gallium, Total N Y Y Y N Y Iron, Total N Y Y Y N Y Lead, Total Y Y N Y N Y Magnesium, Total N Y Y N N N Manganese, Total N Y Y Y N Y Mercury, Total N Y N Y N N Molybdenum, Total N Y Y Y N Y Nickel, Total N Y Y Y N Y Potassium, Total N Y Y Y N Y Selenium, Total N Y Y Y N Y Silver, Total N Y N Y N N Sodium, Total N Y Y N N N Tellurium, Total N Y Y Y N Y Tin, Total N Y N Y N N Titanium, Total N Y Y Y N Y Total metals N Y N N N N Vanadium, Total N Y N Y N N B-15 ------- Table B-3. "Parameters of Interest" Selection Criteria Results for E&EC Indirect Discharge Facilities Parameter Criteria 1 40 CFR 469 Regulated Pollutant (Y/N) Criteria 2 Pollutant of Interest? (Y/N) Criteria 2.1 Frequency of Detection Criteria 2.2 Potential Environmental Concern > 25% of Facilities (Y/N) > 25% of Results (Y/N) Toxic Weighting Factor > 0.001 (Y/N) Nutrient (Y/N) Zinc, Total Y Y Y Y N Y Zirconium, Total N Y N Y N N 0 rganic Compounds 1,1,2-Trichloroethane N N N Y N N 1,1-Dichloroethane N N N N N N 1,1-Dichloroethene N N N Y N N 1,2,4-Triazole N Y Y N N N 1,2-Dichlorobenzene N N N Y N N 1,2-Dichloroethane N N N Y N N 1,3-Dichlorobenzene N N N Y N N 1,4-Dichlorobenzene N N N Y N N 2,4-Dimethylphenol N N N Y N N 2-Hexanone N N N N N N 2-Nitrophenol N N N Y N N 4-Bromophenyl phenyl ether N N N Y N N 624 Volatiles N N N N N N 625 Semi Volatiles N N N N N N Acetone N Y Y N N N Acrolein N N N Y N N Benzene N N N Y N N Benzidine N N N Y N N Benzyl butyl phthalate N N N Y N N B-16 ------- Table B-3. "Parameters of Interest" Selection Criteria Results for E&EC Indirect Discharge Facilities Parameter Criteria 1 40 CFR 469 Regulated Pollutant (Y/N) Criteria 2 Pollutant of Interest? (Y/N) Criteria 2.1 Frequency of Detection Criteria 2.2 Potential Environmental Concern > 25% of Facilities (Y/N) > 25% of Results (Y/N) Toxic Weighting Factor > 0.001 (Y/N) Nutrient (Y/N) Bis(2-chloroisopropyl) ether N N N Y N N Bis(2-ethylhexyl) phthalate N Y N Y N N Bromodichloromethane N Y N Y N N Bromoform N Y N Y N N Bromomethane N N N Y N N Butanone N N N N N N Carbon disulfide N Y N Y N N Chlorobenzene N N N Y N N Chloroform N Y N Y N N Chloromethane N N N Y N N Choline hydroxide N Y Y N N N Dibromochloromethane N Y N Y N N Dibutyl phthalate N N N Y N N Dichloromethane N N N Y N N Diethyl phthalate N Y N N N N Dimethyl phthalate N N N Y N N Dioctyl phthalate N N N Y N N Ethylbenzene N N N Y N N Isopropyl alcohol N Y N N N N Naphthalene N N N Y N N N-Methyl-2-pyrrolidone N Y Y N N N N-Nitrosodipropylamine N N N Y N N B-17 ------- Table B-3. "Parameters of Interest" Selection Criteria Results for E&EC Indirect Discharge Facilities Parameter Criteria 1 40 CFR 469 Regulated Pollutant (Y/N) Criteria 2 Pollutant of Interest? (Y/N) Criteria 2.1 Frequency of Detection Criteria 2.2 Potential Environmental Concern > 25% of Facilities (Y/N) > 25% of Results (Y/N) Toxic Weighting Factor > 0.001 (Y/N) Nutrient (Y/N) Pentachlorophenol N N N Y N N PFOA N Y Y N N N PFOS N Y Y N N N Phenol N Y N Y N N Pyridine N Y N Y N N Tetrachloroethylene N N N Y N N Toluene N N N Y N N Toxaphene N N N Y N N Trichloroethylene N N N Y N N Vinyl chloride N N N Y N N Xylenes, Total N N N Y N N PH PH N Y Y N N N B-18 ------- Table B-4. "Parameters of Interest" Selection Criteria Results for E&EC Direct Discharge Facilities Criteria 2 Criteria 1 40 CFR 469 Criteria 2.1 Frequency of Detection Criteria 2.2 Potential Environmental Concern Parameter Regulated Pollutant (Y/N) > 25% of Facilities (Y/N) > 25% of Results (Y/N) Toxic Weighting Factor > 0.001 (Y/N) Nutrient (Y/N) Pollutant of Interest? (Y/N) Total Toxic Organics Total Toxic Organics Y Y Y N N Y Classical Wet Chemistry Ammonia N Y Y Y Y Y BOD5 N Y Y N N N Cyanide, Total N Y Y Y N Y Dissolved oxygen N Y Y N N N Hydrogen peroxide N Y Y N N N Oil & Grease N Y Y N N N Phosphorus, Total N Y Y N Y Y Total dissolved solids N Y Y N N N Total residual chlorine N Y N Y N N Total suspended solids Y Y Y N N Y Anions Fluoride, Total Y Y Y Y N Y Phosphates N Y Y N Y Y B-19 ------- Table B-4. "Parameters of Interest" Selection Criteria Results for E&EC Direct Discharge Facilities Criteria 2 Criteria 1 40 CFR 469 Criteria 2.1 Frequency of Detection Criteria 2.2 Potential Environmental Concern Parameter Regulated Pollutant (Y/N) > 25% of Facilities (Y/N) > 25% of Results (Y/N) Metals Toxic Weighting Factor > 0.001 (Y/N) Nutrient (Y/N) Pollutant of Interest? (Y/N) Aluminum, Total N Y Y Y N Y Cadmium, Total N Y Y Y N Y Chromium, Hexavalent, Total N Y N Y N N Chromium, Total N Y Y Y N Y Cobalt, Total N Y N Y N N Copper, Total N Y Y Y N Y Iron, Total N Y Y Y N Y Lead, Total N Y Y Y N Y Molybdenum, Total N Y N Y N N Nickel, Total N Y Y Y N Y Ruthenium, Total N Y N N N N Silver, Total N Y Y Y N Y Tungsten, Total N Y Y Y N Y Zinc, Total N Y Y Y N Y B-20 ------- Table B-4. "Parameters of Interest" Selection Criteria Results for E&EC Direct Discharge Facilities Criteria 2 Criteria 1 40 CFR 469 Criteria 2.1 Frequency of Detection Criteria 2.2 Potential Environmental Concern Parameter Regulated Pollutant (Y/N) > 25% of Facilities (Y/N) > 25% of Results (Y/N) Toxic Weighting Factor > 0.001 (Y/N) Nutrient (Y/N) Pollutant of Interest? (Y/N) Organic Compound: Acetone N Y N N N N Bromodichloromethane N Y Y Y N Y Bromoform N Y Y Y N Y Chloroform N Y Y Y N Y Dichlorodifluoromethane N Y N N N N N-Methyl-2-pyrrolidone N Y N N N N Toluene N Y N Y N N PH PH Y Y Y N N Y B-21 ------- Table B-l and Table B-2 are box and whisker plots for detected concentrations for indirect and direct discharger parameters of interest, respectively. All plots were done in Excel and are grouped based on maximum concentration to ensure that box and whisker plots with larger maximum concentrations do not make plots with lower maximum concentrations unreadable. For box plots, the bottom and top of the box displays the 25th and 75th percentile concentrations defined as the interquartile range (IQR). The median is displayed as the horizontal line within the box. The whiskers show the relative distribution of data points outside of the IQR and represent 1.5 times the IQR. All points outside the whisker range are plotted individually. Red lines indicate the most stringent daily maximum limitations for 40 CFR 469 regulated pollutants. B-22 ------- 300 250 oo 200 £ 150 100 50 Phosphorus, Total Total Kjeldahl Nitrogen Fluoride. Total Potassium, Total 30 ZD _ 1 £_ c o TO 15 c o» u : 1 u 4" ± • 0 • • Nitrates Nitrates/Nitrites Nitrogen, Total Zinc, Total £ 3 • • • • • : • • • « • 8 • • • • j — • • ! j- Arsenic, Total Boron, Total Copper, Total Figure B-l. Indirect Discharger "Parameters of Interest" Box and Whisker Plot B-23 ------- 4.5 4 3.5 «5 3 I 25 to c 2 Ol u o 1.5 u 1 0.5 0 t ± Iron, Total Molybdenum, Total Nickel, Total Nitrites 1.4 1.2 — 1 £ c 0.8 0 03 1 0.6 O C o u 0.4 0.2 Chromium, Total Selenium, Total Tellurium, Total TTO 0.7 0.6 1 °-5 £ | 0.4 re § 0.3 0.2 0.1 * I Aluminum, Total Antimony, Total Cadmium, Total Gallium, Total Lead, Total 0.045 0.04 0.035 "a o.o3 B | 0.025 m S 0.02 (U u o 0.015 u 0.01 0.005 0 Barium, Total Manganese, Total Titanium, Total Figure B-l, (continued). B-24 ------- 70 60 50 E, c 40 £ 30 20 10 Ammonia Fluoride, Total Total suspended solids 1.4 1.2 E, c 0.8 £ 0.6 0.4 0.2 Aluminum, Total Chromium, Total TTO Iron, Total 0.3 0.25 oS 0.2 E % 0.15 0.1 0.05 i. i t * Nickel, Total Phosphorus, Total Cyanide, Total Phosphates Tungsten, Total 0.1 0.09 0.08 0.07 00 — 0.06 C o s 0.05 § 0.04 c ° 0.03 0.02 0.01 0 • • • • • • ¦1 • - 1 ¦ 1 ¦ Bromoform Cadmium, Total Copper, Total Silver, Total Zinc, Total Figure B-2, Direct Discharger "Parameters of Interest" Box and Whisker Plots B-25 ------- 0.0005 Bromodichloromethane Chloroform Figure B-2. (Continued) B-26 4- pH ------- Attachment C: Review of Potential Impacts from Indirect and Direct Discharges of E&EC Wastewaters ------- Table C-l. Parameters of Interest for E&EC Indirect Dischargers Parameter Indirect Discharge Parameter of Interest Identified by Control Authority Local Limit Permit Range3 (mg/L) Number of Permit Violations'3 Potential Concern Fluoride, Total X 3 to 180 2 • Total Fluoride is regulated under 40 CFR 469 Subparts C and D for indirect dischargers. • Total Fluoride present in E&EC wastewater is from the use of hydrofluoric acid or ammonium bifluoride as an etchant or cleaning agent or as an intermediate powder in lamp phosphor production during the manufacturing process (U.S. EPA, 1983 and U.S. EPA, 1984). • There is no significant removal of fluoride by typical POTW treatment systems; therefore, pass-through of fluoride does occur (U.S. EPA, 1984). For Subparts A and B, in spite of pass-through, EPA determined that there is little likelihood of health or environmental effects from the introduction of fluoride into a POTW at the flows and concentrations observed from these industries (U.S. EPA, 1983). • Fluoride can be toxic to livestock and plants and can cause tooth mottling in humans (U.S. EPA, 1984). • Total fluoride concentrations in treated process water are typically below the daily maximum ELG limit of 35 mg/L. In EPA's wastewater characterization database, 97 percent (757/783 detected values) of total fluoride detected concentrations were less than 35 mg/L. • Both permit violations identified in the pretreatment annual reports were for one-time exceedances of the daily maximum value and were the result of equipment malfunctions and/or human error (Union Sanitary District, 2017 and City of Sunnyvale Environmental Services Department, 2019). • Control authorities did not identify total fluoride as a pollutant for further control or study. Ammonia X X 25 to 662 0 • Ammonia is a "conditional" pollutant of concern for POTW pretreatment evaluations due to the potential to cause toxicity issues in POTW effluent (U.S. EPA, 2004). • Uncontrolled loadings of ammonia can cause pass-through and interference problems at the POTW (U.S. EPA, 2004). C-l ------- Table C-l. Parameters of Interest for E&EC Indirect Dischargers Parameter Indirect Discharge Parameter of Interest Identified by Control Authority Local Limit Permit Range3 (mg/L) Number of Permit Violations'3 Potential Concern • Elevated ammonia concentrations in POTW influent can increase the amount of alkalinity consumed during nitrification processes within the POTW (U.S. EPA, 2004). • Detected ammonia concentrations in indirect E&EC discharges are generally within or less than the range of typical untreated domestic wastewater (i.e., 85 percent of detected ammonia concentrations are less than 50 mg/L)c. • Site-specific concerns for ammonia may be identified due to elevated ammonia concentrations (i.e., greater than 50 mg/L) in E&EC discharges or nutrient issues within the receiving water for the POTW effluent. Site- specific ammonia concerns are addressed through local limits and ammonia surcharges. For example, Micron, a semiconductor manufacturing facility who discharges to the Upper Occoquan Service Authority (UOSA), has a local limit for ammonia but, pays an ammonia surcharge to address excess ammonia loads (ERG, 2020e). • 20 indirect discharge permits included a local limit for ammonia. • No control authorities reported issues of interference or pass-through associated with ammonia. Nitrates X NLL 0 • Nutrients other than Ammonia • Nutrient loads in POTW influent can place a burden on POTWs to meet their nutrient discharge limits. Biological treatment processes designed to meet secondary treatment effluent standards • frequently do not remove total nitrogen or total phosphorus to levels low enough to protect certain receiving waters. Enhanced treatment may be required through either retrofitting the POTW to improve the biological treatment processes or to include additional chemical treatments to further precipitate phosphorus prior to discharge to surface waters (U.S. EPA, 2008). Nitrates/Nitrites X NLL 0 Nitrites X NLL 0 Nitrogen, Total X NLL 0 Phosphorus, Total X 4.9 to 9 0 Total Kjeldahl Nitrogen X 75 0 C-2 ------- Table C-l. Parameters of Interest for E&EC Indirect Dischargers Parameter Indirect Discharge Parameter of Interest Identified by Control Authority Local Limit Permit Range3 (mg/L) Number of Permit Violations'3 Potential Concern • Nutrient concerns from E&EC effluent are site-specific and are addressed through local limits at POTWs. • 3 indirect permits included local limits for nutrients other than ammonia. Aluminum, Total X 9.4 0 • Metals • Several metals are regulated for indirect dischargers under 40 CFR 469 Subpart C including total cadmium, total chromium, total lead, and total zinc. • Total cadmium and total zinc are also regulated under 40 CFR 469 Subpart D for indirect dischargers as well as total antimony. • Local limits for metals are often based on water quality concerns within the POTWs' receiving water. Local limits for metals are site-specific as several water quality standards and criteria for metals depend on the hardness, pH, and temperature of the receiving water (U.S. EPA, 2004). • Metals assigned local limits at greater than 90 indirect facilities include total arsenic, total cadmium, total chromium, total copper, total lead, total nickel, and total zinc. • Copper was the only metal specifically identified in EPA's discussions with control authorities as a potential industry-wide pollutant of interest (ERG, 2019b). • Total arsenic and total copper permit violations identified in the 2018 and 2019 pretreatment annual reports were isolated exceedances of the maximum allowable limits that were then resolved at the facilities (San Jose-Santa Clara Regional Wastewater Facility, 2019 and City of Sunnyvale, 2019). • The facility with the total zinc permit limit violation was unable to identify the source; this facility closed in 2018 (City of Sunnyvale, 2019). Antimony, Total X 0.04 to 5 0 Arsenic, Total X 0.047 to 15 1 Barium, Total X 5 0 Boron, Total X 1 to 20 0 Cadmium, Total X 0.01 to 15 0 Chromium, Total X 0.26 to 25 0 Copper, Total X X 0.13 to 17 1 Gallium, Total X NLL 0 Iron, Total X 5 to 250 0 Lead, Total X 0.039 to 40 0 Manganese, Total X 0.5 to 6.1 0 Molybdenum, Total X 0.15 to 6.58 0 Nickel, Total X 0.2 to 22 0 Potassium, Total X NLL 0 Selenium, Total X 0.006 to 9.37 0 Tellurium, Total X NLL 0 Titanium, Total X NLL 0 C-3 ------- Table C-l. Parameters of Interest for E&EC Indirect Dischargers Parameter Indirect Discharge Parameter of Interest Identified by Control Authority Local Limit Permit Range3 (mg/L) Number of Permit Violations'3 Potential Concern Zinc, Total X 0.16 to 25 1 Total Toxic Organics X 0.5 to 2.13 0 • TTO is regulated under 40 CFR 469 Subparts A, B, and C for indirect dischargers. • Meeting TTO permit limits are not a concern as TTO chemicals are no longer in use or many facilities manage toxic organics through solvent management plans. • 77 out of 112 indirect permits reported having solvent management plans. • TTO was only detected in 22 percent of indirect samples (182/836 detected values). When TTO was detected, it was at least 1 order of magnitude lower than the 1.37 mg/L daily maximum limit listed in 40 CFR 469 Subparts A and B. Chloride X 175 to 880 1 • Chloride in POTW influent can decay or prevent the formation of inorganic films and precipitates that protect sewer walls from chemical corrosion (U.S. EPA, 2004). • Chloride ions are used in copper electroplating baths to inhibit plating on areas where a reduced plating rate is desired (Dupont, 2016). Chloride ions may also be present from purchased or potable water used during manufacturing. • The Thousand Oaks City wastewater control authority, which permits discharges from two Skyworks semiconductor manufacturing facilities, stated that E&EC facilities have not had compliance issues except for slight chloride hits during droughts when water is imported (ERG, 2019b). • The City of Lompoc Regional Wastewater Reclamation Plant reported a permit violation for chloride from Raytheon in their 2018 Annual Pretreatment Report, but found no significant findings during inspection. Raytheon is reported as consistently achieving compliance (City of Lompoc, 2019). • Local limits are used to address site-specific concerns with chloride. For example, UOSA is concerned with the addition of salts, such as chloride, to C-4 ------- Table C-l. Parameters of Interest for E&EC Indirect Dischargers Parameter Indirect Discharge Parameter of Interest Identified by Control Authority Local Limit Permit Range3 (mg/L) Number of Permit Violations'3 Potential Concern its receiving water which is used as a drinking water source for Fairfax County. UOSA implemented local limits to manage salt loading into the reservoir (ERG, 2020e). • 6 indirect E&EC permits have local limits for chloride. Sulfate X 400 to 3,660 0 • Sulfate concentrations in POTW influent can form hydrogen sulfide within collection systems through anaerobic degradation when wastewater is allowed to stagnate. The formation of hydrogen sulfide can corrode metals (e.g., iron, copper, lead, and zinc) within the treatment system. Sulfate can also corrode and crack concrete through the formation of calcium sulfate (U.S. EPA, 2004). • Sulfate in E&EC wastewater is often from copper sulfate used in copper electroplating baths (Dupont, 2016). • Austin Water noted in their discussions with EPA that they are continuing to the watch sulfate concentrations from the five E&EC facilities within their system due to potential aquatic wildlife health concerns in their receiving waters. A sulfate limit has been discussed, but not implemented as a study is currently underway to reevaluate the issue (U.S. EPA, 2019). • 5 indirect permits have local limits for sulfate. C-5 ------- Table C-l. Parameters of Interest for E&EC Indirect Dischargers Parameter Indirect Discharge Parameter of Interest Identified by Control Authority Local Limit Permit Range3 (mg/L) Number of Permit Violations'3 Potential Concern PH 5 to 12.5 S.U. 6 • Discharges with a pH lower than 5.0 are prohibited under the General Pretreatment Regulations unless the POTW is specifically designed to accommodate such discharges. Upper pH limits are established by the POTW at a level that is both protective of the facility and avoids characterization of the discharge as hazardous waste (i.e., pH > 12.5) (U.S. EPA, 2004). • POTWs that accept Industrial wastewater with high pH values may observe a reduction in odor emissions, aid in nitrification, improved precipitation in clarifiers, and reduction in chloride and sulfate ions in influent to the POTWs system (U.S. EPA, 2004). • pH was the most frequent parameter reported for permit limit violations in EPA's review of the 2018 and 2019 pretreatment annual reports. Durations of pH permit limit violations from E&EC facilities were often brief (e.g., 2 minutes to less than 5 hours) and then brought back within compliance. NLL- No local limit. No indirect permits were identified with a local limit expressed as a concentration value. Some permits may contain a limit expressed as a load. a. Permit limits presented only include parameter concentration limits based on local limits. Local limits presented include a variety of durations and frequencies including but not limited to daily maximum, monthly average, and instantaneous maximum limits. Limits reported as loads, based on other regulations (i.e., 40 CFR 433), or listed as specific prohibitions are not presented. b. EPA identified permit limit violations for indirect E&EC dischargers by reviewing annual pretreatment reports from 2018 and 2019 from 13 wastewater control authorities. c. Ammonia concentrations in untreated domestic wastewater typically range from 10 to 50 mg/L (U.S. EPA, 2004). C-6 ------- Table C-2. Parameters of Interest for E&EC Direct Discharges Parameter NPDES Permit Number of Potential Concerns Limit Range3 Permit (mg/L) Violationsb Fluoride, Total 7.3 to 28 0 • Total fluoride is regulated under 40 CFR 469 Subparts A, B, C, and D for direct dischargers. • There are no national recommended water quality criteria (NRWQC) for total fluoride; however, EPA has established a drinking water maximum contaminant level (MCL) of 4 mg/L to be protective against bone disease and a secondary non-enforceable level of 2 mg/L for tooth mottling in children. • Fluoride can be toxic to livestock in drinking water at levels greater than 2 mg/L and toxic to plants in irrigation water at concentrations greater than 1 mg/L (U.S. EPA, 1984). • Texas and New York both have water quality standards for total fluoride. o Texas state water quality standard for human health for the consumption of water and organisms for total fluoride is 4 mg/L. The maximum concentration of total fluoride detected in NXP Ed Bluestein was 0.24 mg/L. o New York state water quality guidance limit for human health in freshwater for total fluoride is 1.5 mg/L with aquatic life guidance concentrations based on site- specific determinations using hardness values in receiving waters. o The permit for GLOBALFOUNDRIES Flopewell Junction included a site-specific daily maximum limit for total fluoride of 7.3 mg/L. The maximum concentration observed in effluent from GLOBALFOUNDRIES Flopewell Junction was 7 mg/L. • Total fluoride concentrations in direct discharges ranged from 0.17 mg/L to 19 mg/L, well below the daily maximum concentration of 32 mg/L required under 40 CRF 469 Subparts A and B. Ammonia 1.3 to 2.7 2 • Ammonia in surface waters can be toxic to aquatic organisms due to the potential for toxic buildup of ammonia in internal tissues and blood which can lead to death (U.S. EPA, 2013). Environmental factors such as pH and temperature can affect ammonia toxicity by altering the ability of aquatic organisms to excrete ammonia from their systems (U.S. EPA, 2013). • Ammonia concentrations in surface water also contribute to total nitrogen loads within a waterbody which can lead to problems with nutrient over-enrichment and cause indirect effects on aquatic life (U.S. EPA, 2013). C-7 ------- Table C-2. Parameters of Interest for E&EC Direct Discharges Parameter NPDES Permit Number of Potential Concerns Limit Range3 Permit (mg/L) Violationsb • Ammonia NRWQC are site-specific based on pH, temperature, and dependent on the life-stages of aquatic life present in the receiving water. • GLOBALFOUNDRIES Hopewell Junction's permit included water quality-based limits for seasonal monthly average ammonia concentrations of 1.3 mg/L (April to October) and 2.7 mg/L (November to March). • Ammonia was detected in 15 out of 90 samplesfrom GLOBALFOUNDRIES Hopewell Junction. Where 80 percent of detected values were less than 0.5 mg/L. • GLOBALFOUNDRIES Hopewell Junction reported two permit violations that exceeded the seasonal average monthly limit of 2.7 and 1.3 mg/L in March and April of 2021. • Ammonia monitoring is required in GLOBALFOUNDRIES Essex Junction' permit to support nutrients monitoring for the Lake Champaign Phosphorus TMDL. Phosphorus, Total 0.8 0 Total Phosphorus and Phosphates • Total phosphorus is an essential nutrient for plants and organisms; however, over- enrichment of phosphorus loads in surface waters can cause adverse effects such as algae blooms, accelerated plant growth, and problems with low dissolved oxygen concentrations in surface waters. • There are no NRWQC for total phosphorus or phosphates; however, EPA has developed multiple ecoregional criteria for total phosphorus based on site-specific criteria. • GLOBALFOUNDRIES Essex Junction has a site-specific limit for total phosphorus based on the WLA set for the wastewater treatment facility onsite in support of the Lake Chaplain PhosphorusTMDL. • Siltronic Corporation has daily and monthly limits for total phosphates; however effluent concentrations are historically well below the permit limit. In the permit renewal data for the past five years, the long term daily maximum concentration of total phosphate was less than 1.1 mg/L. (Oregon Department of Environmental Quality, 2009b). Phosphates 10 to 15 0 C-8 ------- Table C-2. Parameters of Interest for E&EC Direct Discharges Parameter NPDES Permit Limit Range3 (mg/L) Number of Permit Violationsb Potential Concerns TSS 10.5 to 40 2 • TSS is regulated under 40 CFR 469 Subparts B, C, and D for direct dischargers. • NRWQC for total suspended solids is expressed as a narrative criterion that states TSS should not lower the compensation point for photosynthetic activity by more than 10 percent in surface waters (U.S. EPA, 1986). • Site-specific limits for TSS were set for 2 of 4 the direct discharge facilities. Cyanide, Total 0.06 0 • Total cyanide is regulated under 40 CFR 433 for metal finishing processing facilities. • EPA has issued NRWQC for cyanide for both aquatic life and human health. Aquatic life NRWQC for freshwater are expressed as free cyanide with acute criteria set at 0.022 mg/L and chronic criteria at 0.0052 mg/L. The NRWQC for total cyanide for human health for the consumption of water and organisms is 0.004 mg/L and water only is 0.4 mg/L. • 1 direct discharge facility has a water quality-based permit limit for total cyanide. • 1 direct discharge facility has water quality-based permit limits for free cyanide ranging from 0.65 mg/L to 1.2 mg/L. • Total cyanide was detected in 29 out of 73 samples with 28 detects coming from GLOBALFOUNDRIES Essex Junction who is regulated under both 40 CFR 433 and 40 CFR 469 Subpart B. • Detected values ranged from 0.004 mg/L to 0.16 mg/L with 27 out of 29 detected values reported at concentrations equal to or lower than 0.01 mg/L. Arsenic, Total 0.1 0 Metals • No metals are regulated under 40 CFR 469 Subpart A • Total arsenic is regulated under 40 CFR 469 Subpart B for discharges from gallium or indium arsenide crystal manufacturing facilities. • Total cadmium and total zinc are both regulated under 40 CFR 469 Subparts C and D for direct dischargers. • Total chromium and total lead are both regulated under 40 CFR 469 Subparts C for direct dischargers. • Multiple metals in E&EC direct discharges have NRWQC for aquatic life and human health. NRWQC for metals are often presented as the dissolved concentration and are Aluminum, Total 1 0 Cadmium, Total NL 0 Chromium, Total 0.02 to 0.5 0 Copper, Total NL 0 Iron, Total NL 0 Lead, Total 0.08 0 Nickel, Total NL 0 Silver, Total NL 0 Tungsten, Total 3.75 0 Zinc, Total 0.36 0 C-9 ------- Table C-2. Parameters of Interest for E&EC Direct Discharges Parameter NPDES Permit Limit Range3 (mg/L) Number of Permit Violationsb Potential Concerns calculated based on site-specific environmental parameters such as the pH and or hardness of the surface water. • 3 out of the 4 direct dischargers included at least 1 or more water quality-based limits for a metal. • Detected concentrations for metals were below water quality-based limits identified in the permits with the following maximum concentrations detected for total metals: aluminum (0.9 mg/L), cadmium (0.056 mg/L), chromium (0.56 mg/L), lead (0.05mg/L), and zinc (0.05 mg/L). • Total arsenic was not detected in any of the 45 direct discharge samples in the wastewater characterization database. Total Toxic Organics 2.74 0 • TTO is regulated under 40 CFR 469 Subparts A, B, and C for direct dischargers. • There are no NRWQC for TTO. • 1 facility included a limit for TTO of 2.74 mg/L for a single grab sample. • 1 direct discharge E&EC facility has a solvent management plan to manage TTO discharges. • The maximum detected concentration of TTO in direct discharges was 0.02 mg/L. Bromodichloromethane NL 0 Disinfection byproducts: bromodichloromethane, bromoform, and chloroform • GLOBALFOUNDRIES Hopewell Junction's NPDES permit included monitoring action levels limits which require additional monitoring if the limits are exceeded within specified consecutive sampling events. • E&EC process wastewater at GLOBALFOUNDRIES Hopewell Junction is comingled with treated sanitary and groundwater. Due to the comingling of wastewaters, the exact source of chloroform is unknown. Bromoform NL 0 Chloroform NL 0 c-io ------- Table C-2. Parameters of Interest for E&EC Direct Discharges Parameter NPDES Permit Limit Range3 (mg/L) Number of Permit Violationsb Potential Concerns PH 6.5 to 8.5 S.U. 1 • In surface waters, pH plays a critical role in many chemical and biological processes. For example, the dissolved concentration of metals, and the resulting level of toxicity, are often controlled by the pH in surface waters (U.S. EPA, 1986). • The NRWQC for freshwater aquatic life is 6.5 to 9 S.U. • 2 facilities included site-specific limits for pH that were more restrictive than the limits required under 40 CFR 469. • GLOBALFOUNDRIES Essex Junction reported 1 exceedance of the daily pH maximum value of 8.5 in May 2021 with a daily pH value of 8.8. NL- No site-specific limit. No direct permits were identified with a site-specific limit expressed as a concentration value. Some permits may contain a limit expressed as a load. NPDES permit limit ranges presented exclude limits from 40 CFR 469. Permit limit violations were identified by reviewing discharge monitoring data available in ECHO from 1/1/2018 to 5/31/2021. C-ll ------- |