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33.4 Potential Technologies and Strategies
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The State of California has been a large supporter of environmental efforts in the semiconductor eld. California s Department of Toxic Substance Control (DTSC); the Of ce of Pollution Prevention and Technology Development (OPPTD); and the Semiconductor Environmental, Safety, and Health Association (SESHA) co-sponsored a mini-conference bringing DTSC and semiconductor facilities together to share pollution-prevention strategies and provide the industry with the latest regulatory updates. The conference provided companies with opportunities to further reduce hazardous waste generation by sharing various waste minimization approaches. Conference topics included
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Industrial Ecology: Promises and Challenges Waste of one facility can be a
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raw material for another. A Kalundborg, Sweden case study was presented, noting how ve industrial businesses collaborated for mutual economic and environmental bene t. Waste Minimization: Is it Cost Effective during Decommissioning and Decontamination Facilities should identify the tasks and decisions to be made at each step of the decommissioning process to identify savings from waste minimization. Chemical Management Services in the Silicon Valley Chemical management services provide a strategic, long-term bene t that contract with a service provider to supply and manage the customer s chemicals and related services. The provider s compensation is tied primarily to quantity and quality of services delivered, not chemical volume. These chemical services are often performed more effectively and at a lower cost than companies can do themselves. This approach provides an excellent source-reduction opportunity. Senate Bill 14 Update Source-reduction measures implemented by semiconductor facilities as reported in the latest Senate Bill 14 documents were discussed with
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the intent that other facilities could learn and apply the successful pollutionprevention measures that others had implemented. Common Violations during CUPA Inspections This was a practical presentation focusing on the violations Certi ed Uni ed Program Agencies (CUPA) inspectors commonly nd, and the appropriate avoidance techniques. Universal Waste and Senate Bill 20 This discussion about California s universal waste rule included what wastes were designated as universal wastes, and the standards for their management. Additionally, an update was provided on Senate Bill 20, which establishes a program for collection and recycling of covered electronic devices. Pollution Prevention in the European Union (WEEE and Restriction of Hazardous Substances [RoHS] Directives) The European Union set various dates at which electronic companies must comply with the EU s directives on electronic- and electrical-equipment manufacturers to take back end-of-life equipment (WEEE), and restrictions of the use of certain hazardous substances in electrical or electronic components (RoHS). In addition to these strategies, several other viable source-reduction options were identi ed at the conference. Waste minimization in this sector involves the use of processes, practices, or products that reduce or eliminate the generation of pollutants and wastes. The techniques that can be considered for waste minimization in the industry are
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Product changes Product substitution, product conservation, and change in product
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composition Input-material changes Material substitution and fewer contaminants in materials used Technology changes Change in production processes and equipment, piping, and waste-separation Operating practices and process changes Prevention of material or product losses, waste-stream segregation, production scheduling, and over ow controls Production-process changes Changes in temperature, pressure, automation, equipment Product reformulations Changes in design, composition, or speci cation of nal product Recycling and reuse Reuse in same or another process and usable by-product production Administrative steps Inventory control, employee programs
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The evaluation of source-reduction criteria includes
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Amount of waste reduced Technical feasibility Economic feasibility Effects on product quality
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Employee health and safety Regulatory compliance Releases and discharges to other media
33.5 Implementation and Approach
The implementation of waste minimization in the electronics and semiconductor eld is a four-step process based on the hierarchy of solid waste management:
1 2 3 4
Minimize the generation of wastes as much as feasible. Minimize the hazard of the waste generated as much as feasible. Manage the waste on-site where possible (treatment). Select the off-site disposal technology which reduces the long-term liabilities as much as possible, rst examining recycling options, followed by treatment, incineration, and nally land ll methods as a last resort.
Hazardous wastes are one of the major waste streams generated in this sector. It is important to ensure that the wastes are handled and disposed of in accordance with all laws and regulations and that off-site disposers are handling wastes properly and they present no unnecessary liabilities. In terms of off-site disposal facilities it is very important that the facility has the ability, commitment, nancial resources, and high level of compliance to handle a company s wastes. Steps to accomplish this include
Always audit a new facility before sending any wastes to them. Periodically audit existing facilities changes in ownership. Use an audit check sheet. There are services available that provide audit reports. Comes down to a gut-check level of comfort. Sometimes Toxic Substance Disposal Facilities (TSDF) facilities are not readily available in local areas or have limited capabilities. Don t spread out the liability too much. Try to limit to only a few good facilities with multiple capabilities. Superfund, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), clean-up costs, liability good key words when discussing options with management. In regards to source reduction Senate Bill 14 (The Hazardous Waste Source Reduction and Management Review Act of 1989) requires a source-reduction evaluation review and plan every 4 years. This focuses on wastes that represent 5 percent or more of the total, including aqueous wastes and manifested wastes. The process requires a hazardous waste management performance report covering the previous 4 years as well and it must be made available to the public on request.
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