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Texas Instruments

TI Response to Request for Additional Information

Texas Instruments Incorporated

TEXAS

INSTRUMENTS

U.S. Environmental Protection Agency
Regulatory Reinvention Pilot Projects
FRL-5197-9
Water Docket - Mail Code 4101
401 M Street, S.W.
Washington, D.C. 20460

Re: Response to EPA Comments on Texas Instruments Incorporated XL Proposal dated March 5, 1996

Dear Madam or Sir:

Texas Instruments Incorporated (TI) appreciates this opportunity to address the issues raised by EPA during its technical review of TI's XL Proposal. TI has given considerable thought to the issues raised and continues to believe that approval and implementation of its XL Proposal will demonstrate that a company's dedication to ensure that its resources are managed efficiently can foster sound environmental management of those resources as well. This continues to be the overall objective of TI's Project XL concept. As the RCRA regulatory scheme developed, regulatory disincentives to otherwise efficient and environmenally sound management of resources were created as a result of the Agency's efforts to prevent practices that could have a detrimental impact on the environment. TI maintains that companies, such as TI, with a demonstrated commitment to protection of the environment and an environmental stewardship benchmark, should be encouraged rather than discouraged to make optimal use and re-use of resources.

Enclosed with this letter is a point-by-point response by TI to the issues raised by EPA during its technical review of TI's XL Proposal. I encourage you and other EPA representatives to contact me if you have any questions concerning these repsonses to want to explore any of the issues in greater depth. Further, TI would be happy to meet with you and others at EPA to address any of these issues. Please do not hesitate to contact me at 214/997-2605. TI looks forward to EPA's response on TI's XL Proposal.

Sincerely,

 

Joe Downing
Corporate Environmental, Air Programs Manager

EPA'S ADDITIONAL INFORMATION REQUEST

No. 1

TI has identified a candidate list of five or more solvent and hydrocarbon streams for possible reuse (Attachment B, par. 4 of original XL proposal). The technical reviewers request information on the types and quantities of chemicals subject to regulation as RCRA waste that TI anticipates repurifying as part of their XL project.

TI's Response:

Processes within the electronics industry and, in particular, the semiconductor industry are in a constant state of change and evolution. The average product life cycle is 12 months, and each product development involves the use of a slightly different chemical mix. This everchanging nature of the production process makes it difficult to project the precise chemicals and quantities that would be a part of the repurification process. Included as Attachment 1 is a listing of the types and quantities of chemicals that would be affected if the Project XL program were in place today. Because TI's proposed stewardship approach to reuse and reycling is intended to be an evolving process designed to maximize resource utilization and minimize waste generation, TI will continue to look for other substances that could be reused or recycled that otherwise would be managed as waste. Set forth below is information about the nature of the chemicals that could be repurified or reused if approval of TI's XL proposal were granted today.

Typically there are three categories of organic liquid solvent processes used in the wafer manufacturing process: photoresist, photoresist strippers, stripper rinses. In each of these categories a variety of different materials are used within each fab and from fab to fab. They are also used differently within the fab (number of bath lives, counter current reuse, with different combinations of chemicals in each of the three categories).

As a result, there exist not a handful of solvents, but rather a large number of waste streams that are recyclable. Some are recyclable for the same components. However, with ever impending process changes necessary to actuate process improvements, EPA coded components will also change on a continuing basis.

Section 1 of Attachment 1 groups currently used chemicals by the process categories of organic liquid solvents that can be repurified or reused. Under each category, a list of chemicals with the potential voumes reclaimable under current operating parameters is listed. As the process chnages, the list can be updated. This results in a more functional, living XL project that will allow the environmental specialist and the process engineer to work the issues as they evolve.


















































































Photoresist and Photoresist Strippers


Relative Concentrations


Annual Gallons


Annual Pounds


cyclopentanone


N-methyl pyrolidonone


dimethyl acetamide


cresols


propylene glycol monomethyl ether acetate


isopropanol


novalak resin


cyclohexanone


methyl ethyl ketone


ethyl lactate


anisol


isoamyl acetate


ethylene glycol monoethyl ether acetate


methyl amyl ketone


n-butyl acetate


xylenes


ethylbenzene


0-100%


0-60%


0-100%


0-300 ppm


0-60%


0-60%


0-15%


0-100%


0-20%


0-90%


<0.01%


<0.01%


<0.01%


<0.01%


<0.01%


<0.01%


<0.01%


24,000


31,000


88,000


100


84,000


2,000


20,000


18,000


5,000


5,000


traces


traces


traces


traces


traces


traces


traces


180,000


254,200


642,400


800


630,000


1,800


120,000


135,000


32,500


40,000


--------


--------


--------


--------


--------


--------


--------


Sub TTL


277,100


2,036,700


Photoresist and Photoresist Strippers


Relative Concentrations


Annual Gallons


Annual Pounds


acetone


methanol


cyclopentanone


N-methyl pyrolidonone


dimethyl acetamide


cresols


propylene glycol monomethyl ether


isoproanol


novalak resin


xylene


cyclohexanone


methyl ethyl ketone


0-100%


0-50%


0-5%


0-5%


0-10 ppm


0-5%


0-5%


0-100%


0-5%


0-5%


0-100%


0-5%


38,000


5,000


1,000


1,500


4,000


1


5,000


280,000


100


500


200


1,000


228,000


33,000


7,500


12,300


29,200


8


37,500


2,240,000


600


3,500


1,500


6,500


Sub TTL


336,301


2,599,608


TOTAL


613,401


4,636,308


2,318 tons

Attachment 1 - Example 1

































































































Dallas Wafer Fab 1

DFAB1 West - PGMEA


Propylene Glycol Monomethyl ether and acetate is used to as a resist
edge bead remover and solvent stripper. The waste would contain the following
type of components:


Propylene Glycol Monomethyl ether acetate


<80%


photoresist resins: novalak resin


<20%


containing traces of cresols


<5%


ethyl lactate from the resist


<5%


anisole


<1%


ethylene glycol monoethyl ether acetate


<5%


methyl amyl ketone


<10%


Potential Total Annual Volume Generated


45 tons


EPA waste codes that would be applicable


D001


D023


D024


D025


D026


Recyclable through USPCI-San Antonio and ROMIC-East Palo Alto

 

Attachment 1 - Example 2


























































































Dallas Wafer Fab 1

DFAB1 West - PGMEA


Propylene Glycol Monomethyl ether acetate is used as an edge bead remover
and cup cleaner. The waste would contain the following chemical components:


Propylene Glycol Monomethyl ether acetate


<90%


acetone


<10%

methyl n-amyl ketone <1%

ethyl lactate


<5%

photoresist resins: novalak resin containing traces of cresols <10%

ethylene glycol monoethyl ether acetate


<1%

Potential Total Annual Volume Generated 60 tons

EPA waste codes that would be applicable


D001


D023


D024


D025


D026


F003


Recyclable through USPCI-San Antonio and ROMIC-East Palo Alto

Attachment 1 - Example 3


































































Dallas Wafer Fab 1

DFAB1 East - Acetone


An acetone/methanol mixture is used in a wafer cleaning process. The
waste would contain the following components:


acetone


70%

methanol 30%
Potential Total Annual Volume Generated 30 tons

EPA waste codes that would be applicable


D001


F003


Recyclable through USPCI-San Antonio and ROMIC-East Palo Alto

Footnote: This process was first examined on 6/17/96 and is currently
under evaluation to be changed to use different solvents.

















































































































Lubbock Metal Oxide Semiconductor Fab

LMOS-RER 500


RER 500 is used as a photoresist edge bead remover. The waste would
contain the following components:


ethyl lactate


<70%


methyl ethyl ketone


<6.5%


acetone


<0.1%


photoresist: novalak resin w/cresols


<1%


cresols


<1 ppm


propylene glycol monomethyl ether acetate


<20%


n-butyl acetate


<0.5%

xylenes <0.5%
ethylbenzene <0.1%

Potential Total Annual Volume Generated

30 tons

EPA waste codes that would be applicable


D001


D023


D024


D025


D026


F003


F005


Recyclable through ROMIC-East Palo Alto

 

EPA'S ADDITIONAL INFORMATION REQUEST

No. 2

TI seeks flexibility from current hazardous waste and solid waste definitions (Attachment B, par. 2 of the original XL proposal). Can TI achieve its desired objective to repurify, reuse, and recycle through existing legal mechanisms (e.g., possibilities cited include a delisting per 40 CFR 260.20 and 260.22; an exemption per 40 CFR 261.2(e); or a waiver per 40 CFR 260.31)? Or is TI proposing a specific regulatory alternative that would require the regulatory flexibility XL offers?

TI's Response:

TI has resarched extensively the ability to use and reuse, under existing regulations, resources tht currently must be characterized as hazardous waste. Unfortunately, none of the existing regulatory alternatives provide a viable solution to the resource management dilemma TI and others in the electronics industry face.

TI has researched extensively the ability to use and reuse, under existing regulations, resources that currently must be characterized as hazardous waste. Unfortunately, none of the existing regulatory alternatives proivde a viable solution to the resource management dilemma TI and others in the electronics industry face.

The delisting procedure may be viable for static processes but does not work for constantly and rapidly changing processes. TI reseaerched and considered at length the potential applicability of 40 CFR 261.2(e) for the process wastes currently generated that can be recycled but, because of the need to repurify and/or reformulate the stream prior to reintroduction into the process, does not believe the materials qualify for the definitional exclusion. TI also evaluated the potential utility of the 40 CFR 260.30 variance procedure. Again, due to the dynamic nature of TI's processes, a case-by-case pre-approval process is unworkable due to time constraints and the changing nature of the streams generated. TI also considered other regulatory possibilities, including closed loop recycling, but concluded they simply do not achieve sufficient flexibility for a dynamic process.

Further, what TI is proposing in its XL project is not intended to be a fix to a particular problem but rather a paradigm shift in the definition of waste that places greater trust as well as responsibility in the regulated community to use and reuse resources in an environmentally responsible manner.

Although TI envisions the project agreement will outline the ultimate parameters under which TI would operate its XL program, TI is in essence proposing an alternative to the current regulatory process for defining solid waste and hazardous waste. TI has not developed specific lanaguage as an alternative to the current regulatory definitions but rather identified the barriers touse and reuse that it proopses to remove. There are at least two alternative approaches TI anticipates discussing with the agency if the proposal is approved -- one would be to receive relief from those specific provisions (focusing on the definitions of recycling activities that currently constitute hazardous waste management) that disincentivize use and reuse by categorizing nonwaste (using a common sense meaning), as hazardous waste, with the attendant cost, paperwork, and stigma; the second would be to go outside the current regulatory framework and start from scratch in outlining the waste determination process. TI believes the latter, more innovative approach will yield greater benefits all around. Of course, TI recognizes that there may be a need for certain safeguards on the process, e.g., restrictions on burning for energy recovery and uses constituting disposal, which restrictions could be part of the project agreemen

EPA'S ADDITIONAL INFORMATION REQUEST

No. 3

TI proposes that repurification will be operated at the servie providers location of choice (Attachment B, par. 2 of the original XL proopsal). Technical reviewers request more information regarding the identity and location of these service providers, as well as information to assist the reviweers in quantifying any shifting of risk burdens associated with repurification at these facilities.

TI's response:

As mentioned earlier, the potential resource streams and mixes may vary and therefore, the vendor (service provider) witht he technology to repurify/recycle these streams may vary also. If TI's XL Project were in place today, the two vendors identified below would be utilized.

ROMIC Environmental Technologies Corporation
2081 Bay Road
East Palo Alto, CA 94303-1316
(415) 324-1638
EPA ID# CAD009452657Attn: Ron Tressen

USPCI/Laidlaw Environmental Services

4303 Profit Drive
San Antonio, TX 78219
(210) 304-3000
EPA ID# TXDO52649027
State ID# 31905
Attn: Lynne Crane

TI has discussed the proposed XL project with these vendors. It is important to realize however, that as TI's recyclable resources continue to evolve, the associated service provider may likewise evolve or change. TI anticipates no shifting of risk or burden associated with the use of these facilities since these facilities currently conduct the operations imilar to the proposed repurification. TI will evaluate and address the potential for shifting of risk burdens as each potential service provider is identified in the future.

EPA'S ADDITIONAL INFORMATION REQUEST

No. 4

The reviewers request information to support the proposition that TI's project will actually generate improved environmental results as pooposed to mere definitional changes that remove materials from RCRA jurisdiction.

TI's Response:

One of TI's primary environmental management goals is to eliminate wasted resources. Elimination of wasted resources by industry is protective of the environment, both in terms of conservatrion of natural resources and minimization of genration of waste that requires disposal and thereby creates the risk of environmental harm. There are a number of components involved in achieving TI's zero wasted resources goal, including waste minimization and pollution prevention efforts as well as the reuse and/or recycling (rather than disposal) of materials and natural resources which TI's Project XL proposal would promote. Current regulatory requirements make it easier and often less costly to manage as hazardous waste materials that would otherwise be usable/reusable resources. This results is unnecessarily using up limited landfill capacity for, or the incineration of, resources that could be put to economic use without anyu environmental detriment.

The environment benefits greatly by maximizing the use of materials used in a company's processes and the ntrual resources at its facilities. Fewer virgin materials need to be produced and the attendant process risks, waste generation, and transportation risks are thereby reduced. These types of environmental benefits and risk reductions are not easiy quantifiable. Unnecessarily categorizing a useful material as a wate serves no environmental purpose and, in fact, can result in unnecessary environmental harm.

With the successful implementation of TI's XL Project, TI wil be directing useful resources, such as repurified process streams, back into the economy while, at the same time, avoiding the disposal into the environment of a beneficial product. By the projections included on Attachment 1, as of June 1996, for process solvents alone, the annual amount of product that wil be directed away from dispoasl in the environment if TI implements its Project XO prposal is 2,300 tons, full implemetnation of a resource stewardship approach can be expected to yield far greater environment benefits. It is difficult, however, to project actual numbers for any given time periodin the future due to market fluctuations as well as to theimpact of TI's waste minimization policy.

EPA'S ADDITIONAL INFORMATION REQUEST

No. 5

TI proposes that excavated soil that does not evidence contamination need not be classified or characterized as waste (Attachment C, par, 2 of the original XL proposal). The reviewers request information on the type and level of contamination being referred to. Morevover, the reviewers request that TI provide, in more detailed terms, the alternative approach it envisions to manage these soils.

TI's Response:

Soils excavated and water extracted during consruction or remediation activity at a site often can be reused at the site for backfill, berming, and other beneficial applications or, in the case of water for process applications, including use as chiller or scrubber water. One aspect of TI's Project XL program would be to reevaluate when media is generated as a wate and, therefore, required to be classified as such. TI is proposing that media that will be reused on site, that does not evidence contamination, not be required to be classified as, characterized as, and amanged as a waste. For example, this aspect of the program seeks flexibility to move and reuse soil and other media on site, from one loation to anoterh, to be used as backfill or otherwise put to beneficial use. This approach facilitates the excavation and construction activities and reflects a common sense approach to the application of hazardous waste regulations. Thus, a significant volume of media is not unnecessarily being managed as waste, with the attendant expenses and impact on solid and hazardous waste landfills and waste generation numbers for the State and TI. Again, TI's goal is to minimize the waste of resources.

One example of the unnecessary problems caused by current requirements arose during the installation of a utility duct bank at TI's Expressway Site. The trench excavation performed in connection with this construction activity generated 4,260 cubic yards of waste soil as a result of current regulations which define this material as a "waste" once actively managed and caused TI to import fill-dirt for back-fill purposes.

Soil borings were completed for characterization purposes. TI concluded that, although the soils would not be characteristic hazardous waste, the presence of low level solvents (gneally in the 5 to 200 ppb range), the soure of which TI conservatively assumed to be spent solvent, nevertheless would be classified as listed F001-F005 wastes . Since EPA allows authorzed States to determine when the level of hazardous waste in media, which is a listed waste as a result of the "contained-in" policy, is de minimis and no longer "contained-in," TI characteirzed this otherwise usable resource, the soil, as a Class 2 industrial waste under the Texas Natural Resource Conservation Commission's (TNRCC) determinations. Additionally, once the soil became a waste, TI unnecessarily used limited landfill capacity for the disposal of these "wasted" soils.

The reality is this soil was and is a resource which was wasted. TI's XL Project Proposal affords RCRA the opportunity to fulfill the concept underlying its acronym -- Resource Conservation and Recovery. Under TI's XL Project the soil would have been evaluated to determine if it could be utilized as the reosurce that it is, if so TI would use this resource in a manner which is protective of human health and the environment. If TI does not have a beneficial use for such as resource, only then the material would be characteized under the existing waste regulations and disposed as applicable.

If there is no beneficial on-site use for the media, TI will treat the material as waste, and classify and characterize it in accordance with federal and state regulations using process knowledge and/or analytical data, as applicable. If the media indicates signs of conamiantion and is "hazardous," TI will evaluate the representative level of contamination and appropriately manage the media.

EPA'S ADDITIONAL INFORMATION REQUEST

No. 6

The reviewers request clarification regarding the scope of the TI proposal. Does TI anticipate an open-ended project with Attachments B and C serving as examples? Or does TI anticipate conducting a project consisting of two discrete elements?

TI's Response:

TI's proposal is intended to foster a resource stewardship approach,which utlimately is a process rather than anyindividual project. The lements described in Attachments B and C are indeed examples of teh beneficia. results that can be derived from teh stewardship approach. To meet the "cleaner, cheaper, smarter" intent of the EPA's Project XL initiative, TI envisions that its resource stewadship approach wil etatail an ongoing search for clearner, cheaper and smarter opoprtunities throughout our operations. As TI moves toward its goal of "Zero Wastes Resoures" we anticipate identifying other opoprtunities that are cleaner, cheaper and smarter ways of managing resources that would afford similar enhanced environmental opportunities. As new opportunities within the parameters agreed upon for determining if a material is to be managed as a waste are identified, they would be reviewed with the various stakeholder teams.

EPA'S ADDITIONAL INFORMATION REQUEST

No. 7

Finally, the reviewers requested clarification on whether local environmental organizations and/or local community groups have been contacted by TI in connection with this proopsal. If the repurification is to take place off-site, the reivewers urge that the populations/regulatory authorities around these off-site faciities be considered stakeholders.

TI's Response:

The first part of this information request was asddressed int he original XL Proposal submittal under "Project Criteria" number 3. To recap, TI has met with the regulatory stakeholders. These regulatory stakeholders include the Texas Natural Resource Conservation Commission, Region VI EPA, the City of Richardson and the Dallas LEPC. Please see the letters of support in Attachment A of the orgiinal Project XL proposal.

As discussed with Pasky Pascual, the local community stakeholders will be brought into the XL project once TI's project as been accepted and the project details have been addressed. From past experience, TI has found the commuinity be well educated and informed. They ask though qeustions and expect, and deserve, detailed answers. TI will not be prepared to answer detailed, specific questions until the XL Project is accepted and the project details have evolved. Meeting with the community now would be premature and we believe could position TI and the EPA's XL Project for failure. Another concern is tht if we meet with the community now, before our XL Projet is approved, and the project is never approved, TI as well as the Agency could experience a loss of credibility with our community.

To address the second part of this information request, TI has identified vendors (see request #3) that would be used for repurification today, if the projet were approved. These vendors have been informally contacted and the XL Program and process, including stakeholder buy-in requirements, have been discussed. TI has received a verbal indication from the prospective vendors of their willingness to support and participate in this XL Projec. In one case, the state agency was contacted and verbal support was communicated. Once TI's XL Project is approved, TI together with its vendor(s) intend to meet with the additional stakeholders impacted by the vendor's acctivities. The reasons for nort meeting with all potential stakeholders at this preliminary stage of the proposal mirror the reasons for deferring community contact outlined in the first part of this response (above).


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