Regulatory Challenges Facing the Industry in Managing Hazardous Air Pollutants

Smylie, Mike; Souza, Sara
(ENVIRON, Santa Clara, CA)

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Managing air emissions of hazardous air pollutants (HAPs) from semiconductor operations has long been an issue confronting the industry. With the move from 200 mm to 300 mm tools, the industry faces increased challenges as it looks for ways to effectively manage hazardous air pollutant emissions. A number of state and local regulatory districts have begun to focus on further control of HAPs. For example, the California Bay Area Air Quality Management District (BAAQMD) has proposed new toxic air contaminant regulations, which will have a significant impact on air permit requirements and subsequent control technology. In these new regulations, the trigger levels for required site-specific health risk assessments will be decreased for a number of chemicals routinely used in the semiconductor industry. The implementation of these regulations will result in more facilities being impacted by control requirements, longer lead times and increased costs for obtaining permits to operate, and more information available for public review. This presentation will review the state of HAP regulatory standards in a number of geographic areas with large concentrations of semiconductor operations. In addition, the presentation will provide information on the BAAQMD’s proposed Toxics New Source Review (NSR) Program that may serve as a model for other regulatory agencies to follow. Information will be provided on a number a new elements in the regulations including the consideration of acute health risks in the site-specific health risk screening analysis, a lowered Toxic Best Available Control Technology threshold for non-cancer risks, updated toxicity values and exposure assessment procedures, and expanded requirements for discretionary risk management actions.

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