How to Prepare Your Facility for PFAS Regulations on The Horizon

John Goetze

This presentation will summarize rule changes on the horizon and guide industry environmental managers on how to proactively prepare for regulatory changes that may affect their facilities. EPA has recently released a multitude of regulatory goals and draft rules relating to Per- and Polyfluoroalkyl substances (PFAS).

The semiconductor industry has used PFAS in photolithography and other processes for decades; historically being dependent on Perfluorooctane sulfonic acid (PFOS) but replacing this compound with other fluorocarbons over time. New regulations impact a wide variety of fluorocarbons, rather than targeting only a few individual compounds. Proposed new rules for PFAS at the Federal level include:

• PFAS reporting rule for activities dating back to 2011 for manufacturers and importers

• Enhanced reporting required under the Toxic Release Inventory (TRI) program

• Restrict PFAS discharges to water using Effluent Limitations Guidelines (ELGs)

• Inclusion of PFAS in Resource Conservation and Recovery Act (RCRA) hazardous waste regulations

State-specific regulatory updates germane to the industry will also be reviewed. The presentation will advise on prudent data gathering actions and environmental release characterizations so that facilities can assess the level of effort required to adapt to regulations on the horizon.

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