Draft 

Programmatic Environmental Assessment for 

Modernization and Internal Expansion of Existing 

Semiconductor Fabrication Facilities

under the

CHIPS Incentives Program

December 2023

Department of Commerce

National Institute of Standards and Technology

CHIPS Program Office

Herbert C. Hoover Building 

1401 Constitution Ave, NW 

Washington, D.C. 20230 
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TABLE OF CONTENTS

1.0 INTRODUCTION.......................................................................................................................... 1

1.1 Programmatic Scope .............................................................................................................. 2

1.2 Purpose and Need................................................................................................................... 2

1.3 Public Involvement ................................................................................................................ 3

2.0 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES.............................. 4

2.1 Scope...................................................................................................................................... 4

2.2 Semiconductor Manufacturing Overview.............................................................................. 6

2.2.1 Cleanrooms............................................................................................................ 6

2.2.2 Manufacturing Processes....................................................................................... 7

2.2.3 Utilities/Resources Used in Manufacturing......................................................... 14

2.2.4 Materials Used in Manufacturing ........................................................................ 14

2.2.5 Manufacturing Waste Streams............................................................................. 15

2.3 No Action Alternative .......................................................................................................... 16

2.4 Proposed Action Alternative ................................................................................................ 16

2.4.1 Modernization to Produce an Improved Product................................................. 16

2.4.2 Expansion of Cleanroom Space........................................................................... 17

2.4.3 Modernization to Increase Production................................................................. 17

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES.................. 18

3.1 Affected Environment Methodology ................................................................................... 19

3.2 Environmental Consequences Methodology........................................................................ 19

3.2.1 Types of Effects................................................................................................... 19

3.2.2 Significance Criteria ............................................................................................ 19

3.3 Relevant Environmental Laws and Regulations .................................................................. 20

3.4 Climate Change and Climate Resilience.............................................................................. 23

3.4.1 Affected Environment.......................................................................................... 23

3.4.2 Environmental Consequences.............................................................................. 28

3.5 Air Quality ........................................................................................................................... 29

3.5.1 Affected Environment.......................................................................................... 29

3.5.2 Environmental Consequences.............................................................................. 35

3.6 Water Quality ....................................................................................................................... 36

3.6.1 Affected Environment.......................................................................................... 36

3.6.2 Environmental Consequences.............................................................................. 40

3.7 Human Health and Safety .................................................................................................... 42

3.7.1 Affected Environment.......................................................................................... 42

3.7.2 Environmental Consequences.............................................................................. 50

3.8 Hazardous and Toxic Materials............................................................................................ 51

3.8.1 Affected Environment.......................................................................................... 51

3.8.2 Environmental Consequences.............................................................................. 54

3.9 Hazardous Waste and Solid Waste Management ................................................................. 55

3.9.1 Affected Environment.......................................................................................... 56

3.9.2 Environmental Consequences.............................................................................. 61

3.10 Utilities................................................................................................................................. 63

3.10.1 Affected Environment.......................................................................................... 63

3.10.2 Environmental Consequences.............................................................................. 65

3.11 Environmental Justice .......................................................................................................... 67

3.11.1 Affected Environment.......................................................................................... 67
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3.11.2 Environmental Consequences.............................................................................. 71

3.12 Socioeconomics ................................................................................................................... 73

3.12.1 Affected Environment.......................................................................................... 73

3.12.2 Environmental Consequences.............................................................................. 74

3.13 Summary of Potential Effects .............................................................................................. 75

4.0 CUMULATIVE EFFECTS ......................................................................................................... 79

4.1 Clustering of Semiconductor Fabrication Facilities in the U.S............................................ 79

4.2 Economic effects of the CHIPS Act in the U.S.................................................................... 80

4.3 Climate change trends affecting the semiconductor industry and sector greenhouse gas 

emissions.............................................................................................................................. 81

4.4 Trends in corporate responsibility and environmental stewardship in the semiconductor 

industry................................................................................................................................. 82

4.5 Summary of Cumulative Effects.......................................................................................... 83

5.0 REFERENCES............................................................................................................................. 84

APPENDIX A: ENVIRONMENTAL DUE DILIGENCE PROCESS AND BEST MANAGEMENT 

PRACTICES FOR MODERNIZATION AND INTERNAL EXPANSION PROJECTS AT 

EXISTING SEMICONDUCTOR FABRICATION FACILITIES ........................................A-1

APPENDIX B: USE OF PFAS IN SEMICONDUCTOR FABRICATION FACILITIES AND 

EMERGING PFAS STANDARDS ...........................................................................................B-1

APPENDIX C: SEMICONDUCTOR FABRICATION CHEMICALS AND MATERIALS LISTED 

ON THE TOXIC SUBSTANCES CONTROL ACT INVENTORY.....................................C-1

LIST OF TABLES

Table 2.2-1. Semiconductor Manufacturing Process and Equipment ......................................................... 11

Table 3.3-1. Regulatory Requirements Addressed in the Draft PEA.......................................................... 21

Table 3.3-2. Executive Orders Considered in Preparation of the Draft PEA.............................................. 22

Table 3.4-1. 100-Year Global Warming Potential of Select Greenhouse Gases ......................................... 28

Table 3.7-1. Potential Hazards in the Semiconductor Manufacturing Process........................................... 47

Table 3.8-1. Hazardous Process Chemicals Used in Semiconductor Manufacturing ................................. 54

Table 3.9-1. Traditional and Progressive Waste Management Methods of Major Semiconductor 

Manufacturing Waste Streams.............................................................................................. 58

Table 3.11-1. Tools for Identifying Communities with EJ Concerns*........................................................ 70

Table 3.13-1. Summary of Potential Effects............................................................................................... 76

LIST OF FIGURES

Figure 2.1-1. Existing Semiconductor Fabrication Facilities in the U.S....................................................... 5

Figure 2.2-1. Example Clean Room Airflow System ................................................................................... 7

Figure 2.2-2. Front-End Semiconductor Manufacturing Process ............................................................... 10

Figure 3.4-1. Average Temperatures at the Earth’s Surface from 1880 to 2022 ......................................... 24

Figure 3.4-2. Average Annual Direct Greenhouse Gas Emissions from Semiconductors and Related 

Devices Manufacturing Facilities (NAICS Code 334413), 2014-2022 ............................... 26
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Figure 3.4-3. Composition of Direct Greenhouse Gas Emissions from Semiconductors and Related 

Devices Manufacturing Facilities (NAICS Code 334413), 2014-2022 ............................... 26

Figure 3.4-4. Composition of Direct GHG Emissions by Constituent for Semiconductors and Related 

Devices (NAICS Code 334413), 2014-2022........................................................................ 27

Figure 3.5-1. Air Pollution Abatement Concepts and Comparative Costs.................................................. 35

Figure 3.7-1. Hierarchy of Safety Hazard Controls.................................................................................... 43

Figure 3.7-2. Incidence Rates of Nonfatal Occupational Injuries and Illnesses per 100 Workers in the 

Semiconductor and Related Device Manufacturing Sector ................................................. 45

Figure 3.9-1. Waste Managed by Method and Year in the Semiconductor and Related Device 

Manufacturing Sector........................................................................................................... 59

Figure 3.9-2. TRI Chemicals Transferred by Semiconductor Fabrication Facilities in 2022 by Weight 

(lb.)....................................................................................................................................... 60

Figure 3.9-3. TRI Chemicals Released by Semiconductor Fabrication Facilities in 2022 by Weight (lb.) 61
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ACRONYMS AND ABBREVIATIONS

BG block group

BLS United States Bureau of Labor Statistics

BMP best management practice

BPSG borophosphosilicate glass

CAA Clean Air Act

CDC Centers for Disease Control and Prevention

CEQ Council on Environmental Quality

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

CHIPS Creating Helpful Incentives to Produce Semiconductors

CMP Chemical Mechanical Polishing

CO2e carbon dioxide-equivalent

CPO Creating Helpful Incentives to Produce Semiconductors Program Office

CT census tract

CVD Chemical Vapor Deposition

CWA Clean Water Act

DOC United States Department of Commerce

DUV Deep Ultraviolet

E&EC Electrical and Electronic Components

EHS Extremely Hazardous Substances

EJ environmental justice

ELGS Effluent Limitations Guidelines and Standards

EO Executive Order

EPA United States Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act

EUV Extreme Ultraviolet

F-HTF fluorinated heat transfer fluid

FLIGHT Facility Level Information on Greenhouse Gases Tool

FR Federal Register

GDP Gross Domestic Product

GHG greenhouse gas

GHGRP Greenhouse Gas Reporting Program

GWP global warming potential

HAP hazardous air pollutants

HFCs hydrofluorocarbons

HIA Health Impact Assessment

HVAC Heating, Ventilation, and Air Conditioning

IR Infrared
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ISO International Organization for Standardization

L liter

lb. pounds

LED Light-Emitting Diode

LEPC Local Emergency Planning Committees

LQG Large Quantity Generator

MACT Maximum Achievable Control Technology

mm millimeter

MMT million metric tons

NAAQS National Ambient Air Quality Standards

NAICS North American Industry Classification System

NASA National Aeronautics and Space Administration

NEPA National Environmental Policy Act

NESHAP National Emission Standards for Hazardous Air Pollutants

NFPA National Fire Protection Association

NIOSH National Institute for Occupational Safety and Health

NIST National Institute of Standards and Technology

nm nanometers

NOAA National Oceanic and Atmospheric Administration

NOFO Notice of Funding Opportunity

NPDES National Pollutant Discharge Elimination System

NSPS New Source Performance Standards

NSR New Source Review

OSHA Occupational Health and Safety Administration

PBT persistent, bio-accumulative and toxic

PCB polychlorinated biphenyls

PEA Programmatic Environmental Assessment

PFAS per- and polyfluoroalkyl substances

PFC perfluorocarbon

POTWs Publicly Owned Treatment Works

POU point of use

PPA Pollution Prevention Act of 1990

PPE personal protective equipment

PSD Prevention of Significant Deterioration

PTE Potential to Emit

PVD Physical Vapor Deposition

RCRA Resource Conservation and Recovery Act

RF Radio Frequency

RMMs Risk Management Measures
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RMP risk management plan

ROC Region of Comparison

ROI Region of Influence

RPC Remote Plasma Clean

RSEI Risk-Screening Environmental Indicators

RTO regenerative thermal oxidizer

SEMI Semiconductor Equipment and Materials International

SERC State and Emergency Response Commissions

SIA Semiconductor Industry Association

SIP State Implementation Plan

SME Semiconductor Manufacturing Equipment

SQG Small Quantity Generator

TEPC Tribal Emergency Planning Committees

TERC Tribal Emergency Response Commissions

TMAH Tetramethylammonium hydroxide

TO Thermal Recuperative Oxidizer

tpy tons per year

TRI Toxic Release Inventory

TSCA Toxic Substances Control Act

U.S. United States

U.S.C. United States Code

UL Underwriters Laboratory

UPS uninterruptable power supply

UPW ultra-pure water

USCB United States Census Bureau

UV Ultraviolet

VOC volatile organic compounds

WOTUS Waters of the United States

WQS water quality standards

WSC World Semiconductor Council

°C degrees Celsius

°F degrees Fahrenheit

μg microgram
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1.0 INTRODUCTION

The Creating Helpful Incentives to Produce Semiconductors (CHIPS) Incentives Program was authorized 

by Title XCIX—Creating Helpful Incentives to Produce Semiconductors for America of the William M. 

(Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (Pub. L. 116-283, as amended 

by the CHIPS Act of 2022 (Division A of Pub. L. 117-167) (the “CHIPS Act” or “Act”). The CHIPS 

Incentives Program aims to boost American semiconductor research, development, and production by 

investing across the country, including in high-tech production of semiconductors essential to national 

defense and other critical manufacturing sectors. More specifically, the Act provides $50 billion to the 

Department of Commerce (Department) to help revitalize the United States (U.S.) semiconductor industry, 

including $39 billion dedicated to semiconductor manufacturing initiatives. The Act will bolster U.S. 

leadership in semiconductors, promote innovation in wireless supply chains, and advance technologies of 

the future. CHIPS financial assistance will be provided for American semiconductor research, development, 

manufacturing, and workforce development (NIST, 2023). 

The CHIPS Incentives Program is administered by the CHIPS Program Office (CPO) within the National 

Institute of Standards and Technology (NIST) of the Department. The CHIPS Incentives Program 

Commercial Fabrication Facilities Notice of Funding Opportunity (NOFO) was published in February 2023 

and amended in June 2023. The NOFO solicits applications for the construction, expansion, or 

modernization of commercial facilities for the front- and back-end fabrication of leading-edge, currentgeneration, and mature-node semiconductors; commercial facilities for wafer manufacturing; and 

commercial facilities for materials used to manufacture semiconductors and semiconductor manufacturing 

equipment, provided that the capital investment equals or exceeds $300 million. The potential amount 

available under the NOFO is up to $38.22 billion for direct funding and up to $75 billion in direct loan or 

loan guarantees.

The National Environmental Policy Act (NEPA), as amended (42 United States Code [U.S.C.] 4321 et seq.), 

requires federal agencies to consider the potential consequences of major federal actions to both the natural 

and human environments as part of their planning and decision-making processes. A Programmatic 

Environmental Assessment (PEA) can be utilized by a federal agency when the actions under a specific 

program are routine actions done repeatedly and therefore are likely to have similar impacts that can be 

similarly evaluated because of like technologies and construction practices. This helps agencies to eliminate 

repetitive discussions of the same issues, focus on the actual issues ripe for decision, and exclude from 

consideration issues already decided or not yet ripe at each level of environmental review (40 CFR 1501.11 

& 1502.4(b)). This PEA will address financial assistance for the proposed modernization or internal 

expansion of an existing current-generation or mature-node commercial facility (hereinafter referred to as 

“facility”) within its existing facility footprint (hereinafter referred to as the “Proposed Action”). The 

Proposed Action being evaluated would not include facilities that manufacture equipment used in currentgeneration and mature-node semiconductor fabrication facilities, nor does it include facilities that perform 

only research and development or fabless firms (i.e., firms that produce their own designs for 

semiconductors but do not have their own production facilities).

An applicant must be a “covered entity” as defined by the NOFO to be eligible to receive CHIPS financial 

assistance. An applicant is required to complete a multi-step application process as outlined in the NOFO. 

One step of the application process is the completion of an Environmental Questionnaire that includes 26 

questions on the project scope, local environment, potential for environmental effects, and permits required 

for construction of improvements and operation of the upgraded facility. CPO conducts a merit review of 

any application that meets the eligibility requirements outlined in the NOFO, including an evaluation of the 

applicant’s responses to the Environmental Questionnaire. If an applicant proceeds through merit review, 

the Department will provide the applicant a Preliminary Memorandum of Terms for review and negotiation 

prior to or upon entering the due diligence phase for the application. CPO is responsible for completion of 

the NEPA process before financial assistance can be provided and may require applicants to commit to 
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appropriate best management practices (BMPs) within the industry to reduce environmental effects 

resulting from implementation of modernization and/or internal expansion projects. BMPs are listed in 

Appendix A. The NEPA review informs the decision of whether to provide financial assistance for the 

proposed project. 

1.1 PROGRAMMATIC SCOPE

Programmatic consideration of environmental effects and mitigation is a pathway for more meaningful and 

efficient NEPA review. A programmatic approach provides the most benefit when proposals share a 

common technology, context, and federal action (e.g., providing financial assistance). To that end, CPO is 

preparing this PEA under NEPA to examine the expected direct, indirect, and cumulative effects of actions 

associated with modernization and internal expansion at existing current-generation and mature-node 

semiconductor fabrication facilities. This Draft PEA provides the public and responsible agencies with 

information about the Proposed Action and potential effects on the environment. 

CPO recognizes that many current-generation semiconductor manufacturers may seek financial assistance 

to only upgrade their existing equipment and thus could be covered by this PEA. Proposed modernization 

and internal expansion projects will vary in terms of project or activity size, complexity, geographic location 

and timing. For a proposed project to be covered under this PEA, CPO will evaluate the project for 

consistency with the scope of this PEA using an inclusion analysis document (e.g., memo, form, or 

checklist). This analysis document will include the relevant information learned from a site-specific review 

and serves as the NEPA analysis documentation for the administrative record as applied to specific projects. 

If the proposed project includes activities outside of the scope of this PEA, then an additional or tiered 

NEPA document may be required. This PEA can be used as a planning tool to support tiered, site-specific 

analyses by narrowing the spectrum of environmental impacts to focus on project-level reviews as needed. 

The following scenarios describe the possible application of the PEA to a proposed project and whether 

additional environmental review under NEPA is required:

1. All proposed project activities are described in the PEA or the activities are similar enough to the

activities analyzed in the PEA to support a conclusion that their impacts will not be different from those

described in the PEA; therefore, no additional NEPA review required;

2. One or more proposed project activities are within the scope of the PEA and others are not; therefore,

additional NEPA review would be required; and

3. None of the proposed project activities are within the scope of the PEA; therefore, additional NEPA 

review would be required.

1.2 PURPOSE AND NEED

The purpose of the Proposed Action is to invest in U.S. production of strategically important semiconductor 

chips, and assure a sufficient, sustainable, and secure supply of older and current generation chips for 

national security purposes and for critical manufacturing industries. As part of this effort, CPO aims to 

increase semiconductor manufacturing capacity and strengthen the security of the U.S. supply chain via the 

modernization of semiconductor production within the existing facility footprint of eligible currentgeneration and mature-node semiconductor fabrication facilities. Such projects include the replacement or 

upgrade of existing equipment, the addition of new semiconductor manufacturing equipment within the 

existing facility footprint, and expansion of cleanroom space. 

The Proposed Action is needed to address decades of decline in the U.S. semiconductor manufacturing 

sector and to promote the production of a domestic supply of advanced semiconductors for chips, which 

are critical to U.S. economic and national security. Chips are an integral part of a consumer’s everyday life. 

They are found in household items, such as coffee makers, garage door openers, and refrigerators, as well 

as in more complex products such as mobile phones, pacemakers, and automobiles. They are fundamental 
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to the operation of virtually every military system, including communications and navigations systems and 

complex weapons systems such as those found in sophisticated fighter jets. Semiconductors are key to the 

technologies of the future, including artificial intelligence and 5G. The U.S., however, no longer produces 

the world’s most advanced semiconductors and has lost the ability to produce key supply chain inputs such 

as lithography tools, substrates, and some specialty chemicals. The U.S. fabricates only 10 percent of global 

chip capacity today, and provides only 3 percent of global packaging, assembly, and test capacity (DOC, 

2022).

1.3 PUBLIC INVOLVEMENT

This Draft PEA is available for download and review on the Department’s CHIPS Incentives Program 

website at National Environmental Policy Act (NEPA) | NIST. The 30-day public review and comment 

period will close on January 25, 2024. Comments submitted within the 30-day public comment period will 

be part of the Administrative Record. CPO will consider any relevant, substantive comments received 

before finalizing the document. 

Comments will be accepted until January 25, 2024. Please follow the online instructions for submitting 

comments. For additional submission methods, the full public comment policy, information about 

Confidential Business Information or multimedia submissions, and general guidance on making effective 

comments, please visit the CHIPS Incentives Program website at National Environmental Policy Act 

(NEPA) | NIST. Additionally, questions on this PEA can be directed to Mr. David Frenkel by email at 

chipsnepa@chips.gov.
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2.0 DESCRIPTION OF THE PROPOSED ACTION AND 

ALTERNATIVES

The National Environmental Policy Act (NEPA) requires federal agencies to analyze reasonable alternatives 

to the proposed agency action. To be considered a reasonable alternative, the Creating Helpful Incentives 

to Produce Semiconductors for America (CHIPS) Program Office (CPO) determined that a proposed 

alternative must:

• Be technically feasible;

• Not violate any federal statute or regulation;

• Be consistent with reasonably foreseeable funding levels; and

• Meet national, regional, and local data needs.

The Department of Commerce’s (Department’s) Proposed Action evaluated in this Programmatic 

Environmental Assessment (PEA) is for CPO to provide funding for the modernization and expansion of 

current-generation and mature-node semiconductor fabrication facilities within their existing facility

footprint. Specifically, the PEA covers proposed project activities that will take place within existing 

buildings. The CHIPS Act authorizes the Department to provide financial assistance to incentivize the U.S. 

production of strategically important semiconductor chips, particularly those using leading-edge 

technologies, and to ensure a sufficient, sustainable, and secure supply of older and current generation chips 

for national security purposes and for critical manufacturing industries. The Proposed Action addressed by 

this PEA falls within that scope. Therefore, this PEA only considers one action alternative and the No Action

alternative.

2.1 SCOPE

Through the CHIPS Incentives Program, CPO proposes to provide financial assistance for modernization 

and internal expansion of private industry current-generation and mature-node semiconductor fabrication 

facilities. This could be accomplished by one or more of the following activities that are included in the 

scope of this PEA:

• Replacing existing equipment;

• Upgrading of existing equipment;

• Adding new semiconductor manufacturing equipment; 

• Expanding cleanroom space and adding new cleanroom equipment; or

• Disposing of equipment that is replaced.

Any of the activities noted above must occur within the existing facility footprint to be covered by this 

PEA. No additional land disturbance would occur.

Current-generation facilities produce semiconductors using up to 28-nanometer (nm) process technologies 

and include logic, analog, radio frequency, and mixed-signal devices (not leading edge). Mature-node 

facilities fabricate generations of: (a) logic and analog chips that are not based on fin field-effect transistor 

(FinFET), post-FinFET transistor architectures, or any other sub-28 nm transistor architectures; (b) discrete 

semiconductor devices such as diodes and transistors; (c) optoelectronics and optical semiconductors; and 

(d) sensors. This PEA does not cover facilities that manufacture equipment that is used in current-generation 

and mature-node semiconductor fabrication facilities, nor does it include facilities that perform only 

research and development or fabless firms.

The action area, or geographic scope, of the PEA encompasses U.S. states with existing facilities. Figure 

2.1-1 below depicts the distribution of existing facilities throughout the U.S. using the best available 

industry data; however, this may not be an exhaustive list. There are no existing facilities in Alaska or

Hawaii.
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Source: SIA, 2023.

Figure 2.1-1. Existing Semiconductor Fabrication Facilities in the U.S.
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The time period in which projects under the Proposed Action would occur would vary by project, depending 

on the size and complexity of the project and the specific activities funded. 

2.2 SEMICONDUCTOR MANUFACTURING OVERVIEW

The process of creating a semiconductor chip consists of thousands of steps and can take more than 90 days 

from design to production. Semiconductor chip manufacturing is conducted in cleanrooms to maintain 

quality and purity.

2.2.1 Cleanrooms

In most cases, semiconductor cleanrooms must comply with International Organization for Standardization 

(ISO) 14644-1 Cleanroom Classifications, Class 4-6 requirements (Thomas, 2023). These classifications

stipulate a maximum allowed particle count between 352-35,200 particles 0.5 micrometer (μm) or smaller. 

Semiconductor cleanrooms must also meet the requirements of ISO 14644-2, which imposes a quality 

control system in order to maintain these standards. However, not all processes require such stringent 

control; for example, the testing of manufactured wafers could be performed in ISO Class 7 or ISO Class 8 

cleanrooms (Thomas, 2023).

Depending on the end use of the manufactured chips, semiconductor cleanrooms also may have to meet 

industry-specific requirements such as American Society for Testing and Materials International standards 

for automotive applications and National Aeronautics and Space Administration (NASA) standards for 

aerospace applications. These standards ensure that the chips produced are of consistent quality for the 

intended application.

Powerful heating, ventilation, and air conditioning (HVAC) and filtration systems achieve allowable limits 

in cleanrooms by utilizing High Efficiency Particulate Air (HEPA) or Ultra-low Penetration Air (ULPA) 

filters to remove airborne particles. Equipment within the cleanroom may also have its own filtration system 

to remove particles from exhaust. An example of the airflow system for a cleanroom is shown below in 

Figure 2.2-1. 
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Source: Sakraida, 2008

MERV: Minimum Efficiency Reporting Value, a measure of a filter’s 

ability to capture larger particles between 0.3 and 10 μm.

Figure 2.2-1. Example Clean Room Airflow System

Semiconductor cleanrooms also must be controlled for other factors that can affect the quality of the final 

product such as: 

• Static – Electrostatic discharge damages the conductive properties of semiconductors. Static 

dissipative materials for flooring, wall panels, furniture, and more must be used. 

• Humidity – Uncontrolled humidity in semiconductor cleanrooms can result in inconsistent bake-out 

times, surface swelling and corrosion, and evaporation of solvents. A consistent relative humidity 

between 35 and 65 percent is necessary.

• Out-gassing – Semiconductor cleanroom equipment can introduce airborne contaminants into the 

space. This must be controlled with proper equipment cleaning and maintenance, as well as consistent 

use of air filtration systems.

2.2.2 Manufacturing Processes

The semiconductor chip manufacturing process begins with wafer production. Wafers are typically 99.999 

percent pure silicon, sliced from a cylinder of silicon (known as an ingot) to the appropriate thickness. 

Wafers may also be created from other materials such as gallium nitride, gallium arsenide, germanium, and 

silicon carbide which may be used for certain high-temperature or high-speed chips (e.g., defense 

applications) (Khan et al., 2021). The wafers are then polished to create an extremely smooth surface and 

transported to semiconductor fabrication facilities such as those that are covered under this PEA. Facilities 

dedicated solely to wafer production are not covered under this PEA. 
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Once the wafer is at a semiconductor fabrication facility, the semiconductor fabrication process continues 

with the following essential steps as described below for a standard silicon wafer in Figure 2.2-2: 

• Oxidation: After cleaning, the wafer is placed in a high temperature environment where pure oxygen 

and/or water vapor is used to form a thin protective film of silicon dioxide on the wafer and 

impurities and pollutants are removed. Dry or wet oxidation methods can be used. 

• Lithography: The wafer is then covered with a light-sensitive coating called photoresist which is 

comprised of a polymer, a sensitizer, and a solvent. There are two types: positive and negative. 

Positive resist becomes more soluble when exposed to ultraviolet (UV) light, so that it can be 

removed through the etching step. Positive resist is used in semiconductor manufacturing because of 

its higher resolution capability. The coated wafer is inserted into a lithography machine where it is 

exposed to deep UV (DUV) or extreme UV (EUV) light. Light is projected onto the wafer through a 

photomask, a transparent plate containing a circuit pattern to transfer the pattern to the chip. This 

causes the chemical change and degradation in the photoresist layer using the desired pattern. 

• Etching: The wafer is baked to harden undissolved photoresist and developed to dissolve portions hit 

by light so that the photoresist coating is washed away to reveal a three-dimensional pattern. Etching 

is then performed in places where the photoresist has dissolved to transfer the circuit pattern 

permanently onto the wafer substrate below. Dry or wet etching methods can be used; dry methods 

use gases to expose the pattern, while wet methods use chemical baths. 

• Deposition: Deposition is the process of adding thin layers of material onto the wafer's surface. There 

are several deposition techniques, such as chemical vapor deposition (CVD) and physical vapor 

deposition (PVD), which can be used to deposit a wide range of materials, including metals, 

insulators, and semiconductors. The process creates metal (conducting) layers or dielectric 

(insulating) layers. Deposition may involve the use of fluorinated gases and/or nitrous oxide (N2O)

(EPA, 2023a; Khan et al., 2021). 

• Ion implantation: Once patterns are etched, the wafer is bombarded with positive or negative ions 

(such as arsenic or phosphorous). These embedded impurities are called dopants and they give 

different parts of the wafer different levels of conductivity to make functional transistors in chips. 

Heat processing activates the ions. 

• Metallization and Interconnects: Metal layers are deposited onto the wafer's surface, which serve as 

electrical connections between the various components of the device. These metal layers can be 

deposited using a variety of techniques, such as sputtering or CVD. The metal layers are then 

patterned and etched to form the desired interconnect structures. 

• Passivation: Passivation involves the deposition of a protective layer onto the wafer's surface. This 

layer serves to protect the delicate underlying structures from damage and contamination during the 

packaging process and subsequent use. Common passivation materials include silicon dioxide, silicon 

nitride, and polyimide, which offer good adhesion, low moisture permeability, and compatibility with 

the underlying semiconductor materials. 

• Chemical Mechanical Planarization: Once one layer is complete, it is flattened and the process 

repeats to add a new layer; as a result, at the end of the overall manufacturing process, a single chip 

may contain dozens of layers. 

• Dicing: The wafer which contains dozens of chips in a grid pattern is sliced into individual chips to 

remove the chips from the wafer.

• Testing and Quality Control: Tests of the chips include temperature, speed and operation to ensure 

the semiconductor performs properly. 
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The process described above is known as “front-end semiconductor manufacturing” and refers to the 

process steps from a blank wafer to a completed wafer; all subsequent steps are referred to as back-end 

manufacturing. As a wafer proceeds through the front-end process, hundreds of individual process tools, or 

Semiconductor Manufacturing Equipment (SME), are used and require a range of chemicals, water, and 

energy as inputs. Within each type of SME, a facility will typically have up to a dozen or more pieces of 

equipment from different suppliers. Table 2.2-1 summarizes the types of SME used in the manufacturing 

steps as well as the general industry trends for pollution control and conservation of water and energy. 

After the front-end semiconductor manufacturing process is complete, the chips are transported offsite to a 

packaging facility where each chip is mounted, interconnected, and encapsulated in a protective housing. 

The housing is a protective metal container with a cooling system to ensure the chips do not overheat. 

Separate packaging facilities are not covered under this PEA. If, however, packaging or wafer production 

occurs at the same facility as chip production, then they could be covered under this PEA. 
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Figure 2.2-2. Front-End Semiconductor Manufacturing Process
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Table 2.2-1. Semiconductor Manufacturing Process and Equipment

Production 

Process Semiconductor Manufacturing Equipment (SME) Pollution Control, Water and Energy Conservation Trends

Oxidation • Wet or dry thermal oxidation equipment

• Plasma-enhanced CVD equipment 

• Electrochemical anodic oxidation equipment

• Diffusion/oxidation furnaces 

Manufacturers are increasingly using single wafer cleaning 

processes, which increases energy and water consumption per 

wafer; however, facilities also are increasing process and nonprocess (cooling and abatement) water reuse to offset this 

increased water demand.

Lithography • Wafer and photomask handlers, including Front Opening 

Unified Pod (FOUPs) and other types of automated wafer 

handling systems

• Resist processing (tracks) coat photoresists on wafers 

(typically by spin-coating, which spins the wafer to spread 

deposited photoresist), develop them (dissolve portions hit 

by light), and bake them (harden undissolved photoresist to 

prepare for etching)

• Scanners and steppers are used to produce light that passes 

through the photomask (e.g., EUV scanners, argon fluoride 

[ArF] scanners, ArF immersion scanners, krypton fluoride 

steppers, and i-line steppers)

• Mask aligners

• Electron-beam lithography (chip- and/or mask making)

• Laser lithography (mask-making) 

• Ion-beam lithography (mask-making) 

• Imprint lithography

Transition to increased use of EUV lithography over DUV 

lithography may initially greatly increase the energy 

consumption per mask step; however, EUV reduces process 

complexity which, depending on the productivity of the EUV 

lithography tools, would reduce the consumption of water, 

chemicals, and energy needed in the process.
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Production 

Process Semiconductor Manufacturing Equipment (SME) Pollution Control, Water and Energy Conservation Trends

Etching • Dry (gas) etching which may include equipment for 

conductor etching, dielectric etching, ion milling, and/or 

dry stripping

• Dry cleaning equipment 

• Wet etching and wet cleaning equipment

Currently, per- and polyfluoroalkyl substances (PFAS) are used 

in lithography and etching. PFAS compounds contain the stable 

carbon–fluorine bond, making decomposition into smaller, 

nontoxic molecules difficult.

PFAS compounds are resistant to hydrolytic, photolytic, and 

oxidative reactions which limits wastewater treatment 

technologies to high temperature processes (high cost) or 

adsorption onto a media. Adsorption has limitations on the 

ability to remove small molecules and requires disposal of the 

media. To determine the removal efficiency of such 

technologies, analytical methods for the detection of PFAS 

compounds in wastewater are needed; however, currently 

available methods for detection are limited to only a few 

chemistries. This has posed challenges to permitting and 

control authorities who have begun to include PFAS monitoring 

requirements in permits.

See Appendix B for more detailed information on PFAS use in 

semiconductor fabrication facilities. 

Deposition 

and 

Passivation

• CVD equipment including those for plasma CVD, low 

pressure CVD, high temperature CVD, and atomic layer 

deposition.

• PVD

• Electrochemical coating

• Spin-coating

• Rapid thermal processing

• Tube-based diffusion and deposition

• Deposition (non-integrated circuits)

Deposition and dry etching use high global warming potential 

(GWP), fluorinated greenhouse gases (GHGs) (F-GHGs) 

including perfluorochemicals (PFCs), hydrofluorocarbons 

(HFCs), and nitrous oxide (N2O). Facilities are reducing these 

emissions through process optimization, alternative 

chemistries, and/or abatement.

Ion 

Implantation

• Low to Medium Current Ion Implanters

• High Current Ion Implanters

• High Voltage Ion Implanters

• Ultra-High Dose Doping Ion Implanters

There are no notable pollution control or water and energy 

conservation trends for ion implantation.
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Production 

Process Semiconductor Manufacturing Equipment (SME) Pollution Control, Water and Energy Conservation Trends

Metallization 

and 

Interconnects 

• Sputtering

• CVD

• Interconnects for silicon-based chips were historically 

made of aluminum, but now are typically made of copper 

and cobalt. 

• Spin-coating is most typically used to deposit insulator 

layers between metal interconnects

The number of chip-to-chip interconnects is expected to 

continue to increase, increasing the demand for materials and 

the need for PFC abatement. Changes in metallization over

time may include new formulations for copper electrochemical 

deposition, including extending copper plating bath life or 

recycling for reuse.

Chemical 

Mechanical 

Planarization

• Chemical mechanical planarization tools use chemical 

slurries and polishing pads to press and flatten the wafer

Facilities are trending towards more three-dimensional

structures over the traditional planar structure, requiring more 

masking, deposition, etching, and polishing steps per wafer to 

achieve the required transistor density on the device. This 

requires more tools, cleanroom area, and ultra-pure water 

(UPW) to support a given number of wafers, which drives more 

water, energy, and chemical demand.

Dicing • Wafer bonders and aligners are used to join silicon wafers 

prior to dicing 

• Dicing tools

There are no notable pollution control or water and energy 

conservation trends for dicing. 

Testing and 

Quality 

Control

• Memory test

• Systems-on-a-chip (SoC) test 

• Burn-in test

• Linear and discrete test

• Handlers & probers

• Inspection and measuring equipment, including scanning 

electron microscopes, atomic force microscopes, optical 

inspection systems, and wafer probes 

• Certain metrology and inspection systems

There are no notable pollution control or water and energy 

conservation trends for testing and quality control. 

Sources: Bassler, 2022; EPA, 2022a; IEEE, 2015; IEEE, 2016; IEEE, 2023; Khan et al., 2021
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2.2.3 Utilities/Resources Used in Manufacturing

An average semiconductor fabrication facility uses millions of gallons of water per day. Water consumption 

in semiconductor fabrication facilities will typically fall into five categories: 1) process water (about 48 

percent of demand); 2) cooling water (23 percent); 3) abatement technologies to remove hazardous gases 

from SME (20 percent); 4) UPW treatment losses (9 percent); and 5) non-industrial use (< 1 percent). Most 

of the process water used in a facility is purified to provide UPW and supplied to various wet processing 

semiconductor manufacturing equipment. Cooling towers are the single largest loss of process water from 

semiconductor fabrication (IEEE, 2023).

All SME and associated support equipment, such as vacuum pumps and local exhaust abatement, require 

energy to operate. Lithography, etching, and deposition tend to be the most energy intensive process steps. 

Energy is also used for generating nitrogen, which is used to protect wafers from moisture and oxygen as 

described below, and for purifying other bulk gases. Cleanrooms require energy for recirculation air flow, 

temperature and humidity control, and make-up air to meet contamination control requirements. Large 

semiconductor facilities can use up to 100 megawatt-hours of power every hour. Reliable power is essential 

to support the manufacturing process. Any electricity supply issue, such as a power outage or voltage sag, 

can disrupt operations and lead to wasted batches of semiconductors. An uninterruptable power supply 

(UPS) senses when the main power is fluctuating or cut. Its internal circuitry is fast enough to assume the 

power load so that downstream devices are not affected. The UPS then uses the power stored in its batteries 

to act as a bridge until power to the main is restored or until gas or diesel generators can be fired up to 

temporarily support the load.

2.2.4 Materials Used in Manufacturing

The most commonly used bulk gases are nitrogen, hydrogen, helium, and argon. A modern semiconductor 

fabrication facility can use up to 50,000 cubic meters of nitrogen per hour for inerting and purging gas to 

protect wafers from moisture and oxygen. Hydrogen is used for wafer annealing, deposition, and plasma 

cleaning in lithography. Helium, being a highly thermally conductive and inert gas, is used to protect wafers 

from thermal damage and chemical reactions. Argon is also an inert gas with a low ionization energy; 

therefore, it is used as a plasma gas for etching and deposition reactions as well as in lithography (Air 

Products PLC, 2022).

The semiconductor fabrication process uses a wide range of raw materials, and the following is a list of the 

most frequently used materials and their purpose:

• Silicon (Si): Silicon’s properties as a semiconductor makes it the foundation of the modern 

semiconductor industry.

• Alloy 42: Alloy 42 is an alloy of iron, nickel, manganese, and cobalt used to manufacture lead frames.

• Aluminum (Al): Aluminum is used to create the wiring that connects semiconductor components

because it adheres well to silicon dioxide.

• Boron (B): As a hard semi-metallic element with one less valence electron than silicon, boron is 

commonly used for doping.

• Borophosphosilicate glass (BPSG): BPSG is a compound used to isolate conductive lines and circuit 

components.

• Copper (Cu): As a better conductor than gold, copper is used to create lead frames for plastic 

packages and is used for metal lines in semiconductor devices (IEEE, 2020).

• Gallium arsenide (GaAs) and Gallium nitride (GaN): Gallium arsenide and gallium nitride are 

compound semiconductor materials capable of operating at higher temperatures than silicon; 
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however, use in semiconductor devices is complicated because of the toxicity of these compounds

(IEEE, 2020; EPA, 2022a).

• Germanium (Ge): Germanium was the first semiconductor material used to create transistors and 

diodes; however, germanium has largely been replaced by silicon materials.

• Gold (Au): As the most malleable of metals, gold conducts heat and electricity well and is often used 

in wire bonding to connect the integrated circuit to its package leads.

• Kovar: Kovar is an iron-nickel-manganese-cobalt alloy used to manufacture lead frames.

• Lead (Pb): Lead is used to solder the external leads of integrated circuit packages.

• Phosphorus (P): Phosphorus is used as a doping agent since it provides a valence electron when it 

bonds with silicon.

• Platinum silicate (PtSi): Platinum silicate is a substance used as a metal coating between a silicon 

substrate and metal circuit components.

• Polysilicon: Polysilicon is a highly pure, polycrystalline form of silicon used as a conductor and 

resistor.

• Sichrome (SiCr): Sichrome is a compound of silicon and chromium used as a film resistor (IEEE, 

2020).

• Silicon carbide (SiC): Silicon carbide is an alternative silicon compound semiconductor material that 

is more energy efficient and can handle higher voltages, temperatures, and frequencies compared to 

silicon (Pretz, 2020).

• Silicon dioxide (SiO2): Silicon dioxide is a silicon compound used to isolate layers of an integrated 

circuit.

• Silicon nitride (Si3N4): Silicon nitride is a compound often used as the final layer of a circuit due to 

its ability to protect against moisture, corrosion, and physical damage.

• Silver (Ag): Silver is a better conductor than copper and gold, silver is used to increase thermal and 

electrical conductivity in circuits while also helping prevent the chemical degradation of die pads and 

bonding fingers.

• Spin-on glass: Spin-on glass is a glass compound used to smooth the surface of semiconductor 

wafers.

• Tin (Sn): Tin is used similarly as lead, to solder the external leads of integrated circuit packages

(IEEE, 2020).

2.2.5 Manufacturing Waste Streams

Waste streams from the manufacturing process are discussed at a facility level rather than for each process 

step because facilities may combine, treat, and reuse waste streams at various points in the manufacturing 

process using a variety of methods. This section summarizes the general contents of waste streams and 

reuse and treatment methods prior to discharge.

Semiconductor fabrication facilities employ a range of chemistries throughout the manufacturing process.

Chemicals used may include sulfuric acid, phosphoric acid, litho developer (containing 

Tetramethylammonium hydroxide [TMAH]), polar and non-polar organic solvents, nitric acid, citric acid

and many others. The use of such chemistries generates wastes and wastewater, including concentrated salt 

solutions, or brine, that require treatment prior to disposal. These waste streams are treated and reused;

treated and disposed; or disposed without treatment. Common constituents of wastewater streams include 
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hydrofluoric (HF) acid; ammonium [NH4]

+, solvents including isopropyl alcohol (IPA), glycols, ethers, and 

polar and non-polar photoresist; metals; concentrated sulfuric acid (H2SO4); other acidic and alkaline 

compounds; suspended solids include silicon; litho developing waste containing TMAH; and concentrated 

phosphoric acid (IEEE, 2023). 

GHG and carbon emissions are primarily driven by the facility’s energy use, which is in turn driven by 

water purification and treatment systems, including brine management (IEEE, 2023). Additionally, 

deposition and dry etching use high GWP gases, such as F-GHGs (including PFCs), hydrofluorocarbons 

(HFCs), and nitrous oxide (N2O) as well as fluorinated heat transfer fluids. EPA has estimated that between 

10 to 80 percent of these F-GHGs pass through the manufacturing tool chambers unreacted and are released 

into the air (EPA, 2023a). Section 3.5 Air Quality of this PEA provides a detailed description of emissions 

control technologies and practices. 

2.3 NO ACTION ALTERNATIVE

Under the No Action Alternative, CPO would not provide funding for the applicant’s proposed project. The 

No Action Alternative therefore assumes that the applicant would not complete the proposed 

modernization/expansion project, and the facility would continue production at the same rate, using the 

same equipment, and within its existing facility footprint. For the purpose of this analysis only, CPO would 

assume that applicable permit conditions and regulatory standards would be met by the facility. 

2.4 PROPOSED ACTION ALTERNATIVE

The Proposed Action evaluated in this PEAis for CPO to provide federal financial assistance to an applicant 

for its proposal to modernize and expand an existing current-generation and mature-node semiconductor 

fabrication facility within its existing facility footprint. An applicant may propose any combination of 

equipment upgrades, equipment replacement, and equipment additions, described in Section 2.2 of this 

Draft PEA, in its modernization and expansion project, as long as the existing footprint of the facility is not 

changed. The resulting modernization and/or expansion of the facility could increase production of the 

facility’s current product; continue production at the same rate but produce an improved product; expand 

production and improve the product; or reduce production but improve the product. Possible project 

scenarios are described below in Section 2.4.1. 

As part of the due diligence process to receive CHIPS Incentives Program funding, an applicant must

demonstrate compliance with all existing facility permits. Upon completing modernization and/or internal 

expansion projects, the facility would be required to comply with any additional or amended permit

conditions based on any changes to the facility’s operations. Additionally, the facility may be required to 

commit to appropriate best management practices (BMPs) within the industry to reduce environmental 

effects resulting from implementation of the modernization and/or internal expansion project. The resourcespecific analysis in this PEA indicates whether adhering to BMPs and/or using the best available 

technologies would be required to remain consistent with the environmental effects described. BMPs are

included in Appendix A. 

2.4.1 Modernization to Produce an Improved Product

Modernization of a facility can lead to an improved product. For example, until approximately five years 

ago, gallium nitride semiconductor devices had only been demonstrated in 150-millimeter (mm), or smaller, 

wafer diameter facilities with less advanced processing capabilities and very limited production capacities. 

Technology advancements now allow gallium nitride devices to be produced at a 200-mm wafer size. 

Upgrading a facility’s equipment to support gallium nitride semiconductor production at the newer 200-

mm wafer size would assist in meeting the rapidly increasing demand for gallium nitride semiconductor 

chips used in electric vehicles and 5G/6G mobile communications. 
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2.4.2 Expansion of Cleanroom Space

Converting a portion of the internal space within the fabrication facility into new cleanroom space could 

allow a facility to increase production within its existing facility footprint. Interior spaces that can be 

converted into cleanroom spaces include storage space, office space, and obsolete processing spaces. New 

semiconductor manufacturing equipment would be added to the new cleanroom space to increase the 

number and types of semiconductors that can be manufactured at the facility. 

Supporting infrastructure at the facility may need to be upgraded or refreshed to support the additional 

capacity. This could include replacement of existing gas storage tanks with new gas tanks, installation of 

new gas storage tanks in previously existing auxiliary spaces, upgrades to water purification systems, and 

wastewater treatment systems, as well as upgrades to electrical connections, wiring, installation of new air 

handler units and replacement or change out of existing air handler units. All of these improvements to 

auxiliary process support infrastructure must occur on previously disturbed spaces within the existing 

facility footprint, such as existing concrete pads or other areas already significantly modified from the 

previous natural state (e.g., conversion of a parking lot space into a gas tank storage space would be covered 

as the area being modified had previously been converted from its natural state to a human-made structure.)

2.4.3 Modernization to Increase Production 

Some facilities would not require an increase in cleanroom space in order to increase production volumes. 

For instance, a facility might undergo manufacturing equipment replacement if the equipment has reached 

or exceeded industry lifecycles, has limited remaining capability, or utilizes lagging technology. The 

supporting fabrication facility infrastructure systems would need to be refreshed or upgraded to handle new 

manufacturing equipment or types of semiconductor wafers. Infrastructure upgrades needed to support 

increased production could include chilled water, UPW, high temperature water, chemical and gas 

distribution, process cooling water, high voltage distribution, air emission/scrubber infrastructure, building 

improvements, and overall facility control systems. The facility refurbishment could also include the 

purchase and installation of the latest semiconductor manufacturing equipment, replacing tools that are 

obsolete, less capable, and significantly more expensive to operate and maintain. The new equipment that 

is being installed is also likely to be more space efficient, allowing the facility to allocate valuable 

cleanroom space for additional capacity and capability into the future, increasing the economic 

competitiveness of the facility. 

Upgrades to the facility could also include improvements to environmental, health, and safety systems. This 

could include removal of equipment and services that do not meet the highest safety standards, and upgrades 

to the fire alarm, emergency power, and manufacturing chemical distribution systems equipment. Projects 

that would abate GHG emissions could include conversions of certain CVD tools to remote nitrogen 

trifluoride (NF3) plasma clean sources and installation of combustion abatement units.
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3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES

This chapter discusses the existing conditions for resource areas that may be affected by the Proposed 

Action and the environmental consequences of the Proposed Action and No Action alternatives.

Resource Areas Considered but not Carried Forward for Full Analysis

All potentially relevant environmental resource areas were considered for analysis in this Draft 

Programmatic Environmental Assessment (PEA). To focus the analysis, potential effects to the following 

resource areas were not analyzed in detail as they are anticipated to be negligible or non-existent based on 

the scope of proposed projects to be covered under this Draft PEA. Further environmental analysis will be 

conducted if there are exceptional instances in which potential effects to these resource areas could occur: 

• Land Use: Under the Proposed Action, equipment modernization and internal expansion would occur 

within the existing facility footprint and not alter existing land use. Temporary storage areas may be 

needed for construction; however, these staging, or laydown, areas will be restricted to already 

disturbed areas. Accordingly, direct effects to land use are not analyzed. Federal funding for 

modernization could induce additional private investment to expand semiconductor manufacturing at 

existing or new locations, which could affect future land use. As a result, potential cumulative effects 

to land use are discussed in Chapter 4.0 Cumulative Effects of this Draft PEA.

• Cultural and Historic Resources: The first semiconductor device was first developed in 1901; 

however, modern production of semiconductors began around 1960. Existing facilities for 

semiconductor fabrication and research largely consist of newer buildings that likely are not eligible 

for the National Register of Historic Places. Additionally, because the funding under the Proposed 

Action must be used to modernize equipment and expand production within the existing facility 

footprint, archaeological sites, tribes, or traditional cultural properties are unlikely to be affected. 

• Geology, Topography, and Soil: Under the Proposed Action, equipment modernization and internal 

expansion will occur within the existing facility footprint and would not cause disturbance of 

geological resources. 

• Coastal Barrier Resources and Wild and Scenic Rivers: Under the Proposed Action, equipment 

modernization and internal expansion will occur within the existing facility footprint and not include 

disturbance to coastal barrier resources or rivers.

• Wetlands and Floodplains: Under the Proposed Action, equipment modernization and internal 

expansion will occur within the existing facility footprint and will not include disturbance to wetlands 

and floodplains. 

• Terrestrial Biological Resources: As the Proposed Action will occur within the existing facility 

footprint in industrial settings, the action will not modify, physically disturb, or disrupt any terrestrial 

vegetation, terrestrial wildlife, or terrestrial special status species such as migratory birds. Terrestrial 

biological resources will not be affected by the Proposed Action.

• Visual Resources: As the Proposed Action will occur within the existing facility footprint in industrial 

settings, no permanent changes to visual resources are expected to occur.

• Transportation and Traffic: This PEA covers proposed projects where the anticipated operational 

change in peak and average daily traffic falls below any local, state, and federal thresholds for 

conducting a Traffic Impact Analysis or equivalent study.
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3.1 AFFECTED ENVIRONMENT METHODOLOGY

The affected environment sections describe the existing conditions from a nationwide, programmatic 

perspective and discuss specific components of regulations related to the existing conditions where 

appropriate. 

3.2 ENVIRONMENTAL CONSEQUENCES METHODOLOGY

The environmental consequences analysis considers how the condition of a resource may change as a result 

of implementing the two alternatives and describes the potential effects in terms of type (i.e., direct, indirect, 

cumulative, beneficial, adverse), context, duration, and intensity, which are considered in combination to 

determine significance. 

3.2.1 Types of Effects 

According to the Council on Environmental Quality’s (CEQ’s) National Environmental Policy Act (NEPA) 

Regulations under 40 Code of Federal Regulations (CFR) 1500-1508, direct and indirect effects are defined 

as:

Direct effects: Effects that are caused by the action and occur at the same time and place 

(40 CFR 1508.8(a)). 

Indirect effects: Effects that are caused by the action and occur later in time or are farther 

removed in distance but are still reasonably foreseeable. Indirect effects also include 

“induced changes” in the human and natural environments (40 CFR 1508.8(b)).

Identified effects may be either adverse or beneficial or both. The CEQ NEPA Regulations describe the 

need for identifying and differentiating between adverse and beneficial effects, but do not define these 

terms. Under this Draft PEA, both adverse and beneficial effects are defined as:

Adverse effects: Those effects having a negative and harmful effect on the analyzed 

resource. An adverse effect causes a change that moves the resource away from a desired 

condition or detracts from its appearance or condition. 

Beneficial effects: Those effects having a positive and supportive effect on the analyzed 

resource. A beneficial effect constitutes a positive change in the condition or appearance of 

the resource or a change that moves the resource toward a desired condition.

3.2.2 Significance Criteria

Significance criteria provide a structured framework for assessing effects, supporting conclusions regarding 

the significance of effects, and comparing effects between alternatives. To aid federal agencies in 

determining significance, the regulations published by CEQ in 1978 established broad criteria directing 

agencies to base such determinations on evaluations of both the context and intensity of the effect(s) of a 

proposed action. In the 2020 regulations, CEQ replaced the terms “context” and “intensity” but preserved 

their fundamental concepts [85 Federal Register 43322 (July 16, 2020)]. Like the 1978 regulations, the 

2020 CEQ regulations establish two broad criteria for evaluating significance. The 2020 CEQ regulations 

direct agencies to analyze: (i) the potentially affected environment (formerly “context”) and (ii) the degree 

of the effects (formerly “intensity”) of the proposed action [40 CFR 1501.3(b)]. 

Evaluation of the affected environment refines the former “context” and focuses on the proposed action’s 

setting, geographic extent of the affected area (e.g., a site-specific project likely involves effects on the local 

area), and the occurrence and condition of the physical, ecological, and socioeconomic resources [40 CFR 

1501.3(b)(1)]. The second criterion, similar to the “intensity” or “severity” concept, directs agencies to 

consider the “degree” of effect on these resources [40 CFR 1501.3(b)]. 
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The 2020 regulations further explain that agencies should consider whether effects will be short-term or 

long-term; will be adverse or beneficial; will affect public health and safety; or will cause a violation of 

federal, state, tribal or local law protecting the environment [40 CFR 1501.3(b)(ii)-(iv)]. Agencies should 

also consider whether the proposed action is related to other “connected actions” (defined at 40 CFR § 

1501.9(e)(1)) in determining significance [40 CFR 1501.3(b)]. Analyses prepared under the 2020 

regulations, therefore, require express consideration of both the affected environment and the degree to 

which the proposed action is likely to affect resources within the affected environment. 

To aid in consideration of the affected environment or “context,” the CHIPS Program Office (CPO) 

considered whether potential effects would be:

• Localized – Effects would affect the resource in the immediate vicinity of the semiconductor 

fabrication facility.

• Regional – Effects would affect the resource on a regional level, extending well past the immediate 

vicinity of the semiconductor fabrication facility. 

• National – Effects would affect the resource on a nationwide level, extending well past the region in 

which the facility is located.

To aid in determination of the degree to which effects on resources would occur, or their “intensity,” CPO 

considered both their potential duration and the potential magnitude of effects. In addition to the definitions 

below, effects could be continuous (i.e., constant) or intermittent (i.e., recurring or periodic). Continuous 

and intermittent effects could occur temporarily or in the short or long term. 

• Temporary – Effects would occur only during the time that a semiconductor fabrication facility is 

under active construction for modernization, equipment replacement, or internal expansion. 

• Short-term – Effects would likely continue beyond the time of active construction but would not last 

more than several months.

• Long-term – Effects would likely continue well beyond the time of construction for several months or 

longer, but not indefinitely. 

• Permanent – Effects would last indefinitely or for the life of a semiconductor fabrication facility.

Four impact descriptors are used to categorize the potential magnitude of effects: negligible, minor, 

moderate, and major, as defined below: 

• Negligible – Minimal impact on the resource would occur; any change that might occur would be 

barely perceptible and would not be easily measurable. 

• Minor – Change in a resource would occur, but no substantial resource impact would result; the 

change in the resource would be detectable but would not alter the condition or appearance of the 

resource. 

• Moderate – Noticeable change in a resource would occur and this change would alter the condition or 

appearance of the resource; the integrity of the resource would remain intact. 

• Major – Substantial impact or change in a resource would occur that is easily defined and highly 

noticeable and that measurably alters the condition or appearance of the resource; the integrity of the 

resource may not remain intact.

3.3 RELEVANT ENVIRONMENTAL LAWS AND REGULATIONS

Tables 3.3-1 and 3.3-2 below list the relevant laws, regulations, and Executive Orders (EOs) that could 

apply to modernization and internal expansion of existing semiconductor fabrication facilities. These laws, 

regulations and EOs are referenced throughout this Draft PEA.
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Table 3.3-1. Regulatory Requirements Addressed in the Draft PEA

Environmental 

Law and 

Regulations

Responsible 

Agency Summary

Site-Specific 

Compliance 

Requirements

Clean Water 

Act (CWA)

33 United 

States (U.S.) 

Code (U.S.C.) 

1251 et seq. 

U.S. 

Environmental 

Protection 

Agency 

(EPA), U.S. 

Army Corps of 

Engineers 

(USACE), and 

State Agencies

The CWA established the basic structure for 

regulating pollutant discharges into the waters 

of the U.S. The National Pollutant Discharge 

Elimination System (NPDES) (Section 402) 

regulations apply to point sources that 

discharge pollutants to waters of the U.S., 

including stormwater from any construction 

activities that disturb more than 5 acres of 

land. Section 404 regulates the discharge of 

dredged or fill material into waters of the U.S., 

including wetlands.

NPDES Permit 

(Section 402) and 

Section 404 

Permit

Clean Air Act 

(CAA)

42 U.S.C. 

7401 et seq.

EPA and 

State/Local 

Air Pollution 

Control 

Agencies

The CAA is designed to control air pollution 

on a national level. The CAA established 

various permitting programs which are mostly 

implemented by states, local agencies, and 

approved tribes and sometimes implemented 

by EPA Regional Offices.

Title V Operating 

Permit, New 

Source Permit, 

and Green House 

Gas (GHG) 

Permit

Toxic 

Substances 

Control Act 

(TSCA)

15 U.S.C. 

2601 et seq.

EPA TSCA requires reporting, record-keeping and 

testing requirements, and restrictions relating 

to chemical substances and/or mixtures 

including the use, and disposal of specific 

chemicals including polychlorinated biphenyls 

(PCBs).

TSCA reporting, 

recordkeeping, 

and testing 

Emergency 

Planning and 

Community 

Right-toKnow Act 

(EPCRA)

42 U.S.C. 

1100 et seq. 

EPA EPCRA helps communities plan for chemical 

emergencies by requiring industry and federal 

facilities to report on the storage, use, and 

releases of certain chemicals substances that, 

because of their quantity, concentration, or 

physical, chemical or toxic characteristics, 

may present a danger to public health and 

welfare or the environment if released into the 

environment.

Toxics Release 

Inventory (TRI) 

Program and Tier 

II Reporting 

Occupational 

Safety and 

Health Act

29 U.S.C. 651 

et seq.

Occupational 

Health and 

Safety 

Administration 

(OSHA)

OSHA ensures safe and healthy working 

conditions by authorizing the enforcement of 

the standards for worker health and safety and 

public safety. 

Compliance with 

OSHA standards 
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Environmental 

Law and 

Regulations

Responsible 

Agency Summary

Site-Specific 

Compliance 

Requirements

Resource 

Conservation 

and Recovery 

Act (RCRA)

29 U.S.C. 651 

et seq.

EPA RCRA authorizes the EPA to regulate 

hazardous waste and non-hazardous solid 

waste. Hazardous waste is regulated from 

cradle to grave, including the generation, 

transportation, treatment, storage, and 

disposal. 

EPA hazardous 

waste generator 

ID number; 

accumulation 

time and quantity 

limits; 

recordkeeping 

and reporting 

requirements

American 

Innovation and 

Manufacturing 

Act (AIM)

42 U.S.C. 7675 

et seq.

EPA AIM directs EPA to reduce production and 

consumption of hydrofluorocarbons (HFCs) in 

the U.S. by 85 percent over 15 years 

beginning in 2021.

Adherence to 

HFC production 

and consumption 

allowances; 

recordkeeping 

and reporting 

requirements

Compliance with the EOs listed in Table 3.3-2 has been considered in the preparation of this Draft PEA

based on federal funding of the facility’s proposed scope of action.

Table 3.3-2. Executive Orders Considered in Preparation of the Draft PEA

Executive Orders Summary Additional Information

EO 14096,

Revitalizing Our 

Nation's 

Commitment to 

Environmental 

Justice for All and 

EO 12898, Federal 

Actions to Address 

Environmental 

Justice in Minority 

Populations and 

Low-Income 

Populations

EO 14096 reaffirms the goals of EO 12898 

to advance environmental justice by 

directing federal agencies to consider 

measures to address and prevent 

disproportionate and adverse environmental 

and health impacts on communities, 

including the cumulative impacts of 

pollution and climate change and to actively 

facilitate meaningful public participation 

and just treatment of all people in agency 

decision-making. 

For more information see 

Section 3.11 Environmental 

Justice of this Draft PEA 

EO 13045 Protection 

of Children from 

Environmental 

Health Risks and 

Safety Risks 

Requires federal agencies to identify and 

assess environmental health risks and safety 

risks that may disproportionately affect 

children and ensure that policies, programs, 

activities, and standards address 

disproportionate risks to children.

For more information see 

Section 3.11 Environmental 

Justice of this Draft PEA
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Executive Orders Summary Additional Information

EO 13693, Planning 

for Federal 

Sustainability in the 

Next Decade

Requires federal agencies to improve 

environmental and energy efficiency and 

sustainability, including reducing 

greenhouse gas emissions, fleet 

performance, energy conservation, solid 

waste diversion, and pollution prevention

For more information see 

Section 3.4 Climate Change 

and Resiliency of this Draft 

PEA

EO 14008, Tackling 

the Climate Crisis at 

Home and Abroad

Builds on the Paris Agreement’s three 

overarching objectives: a safe global 

temperature, increased climate resilience, 

and financial flows aligned with a pathway 

toward low greenhouse gas emissions and 

climate-resilient development.

For more information see 

Section 3.4 Climate Change 

and Resiliency and Chapter 

4.0 Cumulative Effects on the 

Environment of this Draft PEA

EO 13690, 

Establishing a 

Federal Flood Risk 

Management 

Standard and a 

Process for Further 

Soliciting and 

Considering 

Stakeholder Input 

Establishes U. S. policy to improve the 

resilience of communities and Federal 

assets against the impacts of flooding. 

Establishes a new Flood Risk Management 

Standard to ensure that agencies expand 

management from the current base flood 

level to a higher vertical elevation and 

corresponding horizontal floodplain to 

address current and future flood risk and 

ensure that projects funded with taxpayer 

dollars last as long as intended. 

Applies to federal investments 

for new construction and 

substantial improvement.

EO 13990, 

Protecting Public 

Health and the 

Environment and 

Restoring Science to 

Tackle the Climate 

Crisis

Directs federal agencies to review and, if 

necessary, revise or suspend regulations and 

policies that may hinder environmental 

protection or public health. 

Reinstated EO 13653, Preparing 

the United States for the Impacts 

of Climate Change 

3.4 CLIMATE CHANGE AND CLIMATE RESILIENCE

This section describes the affected environment and the consequences of climate change and climate

resiliency on the Proposed Action and the No Action Alternative. 

3.4.1 Affected Environment

Climate refers to the predictable, average weather, temperature, and precipitation patterns that characterize 

a region, while climate change refers to long-term shifts in the climate of a given region or the Earth as a 

whole. These shifts can be natural, anthropogenic (i.e., caused by human activities), or both (UNFCC, No 

Date-a). 

Climate resiliency and adaptation refer to “changes in processes, practices and structures to moderate 

potential damages to or benefit from opportunities associated with climate change” (UNFCC, No Date-b). 

It is the capacity of countries and communities to successfully cope with current and future impacts from 

climate changes, while working to prevent those impacts from worsening. 

Since the 19th century, increased burning of fossil fuels to provide the energy demanded by a rapid increase 

in the human population and its economic activities (e.g., production and consumption) has been the major 

driver of observed climate change (IPCC, 2023). As a result of rising anthropogenic greenhouse gas (GHG) 
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emissions over the past two centuries, and a concomitant increase in GHG concentrations in the atmosphere, 

the average temperature at the Earth’s surface has risen about 1.1°C above its level before the industrial 

revolution. The planetary surface is now the warmest it has been in the last 100,000 years, and the last 

decade (2011-2020) is the warmest on record (Figure 3.4-1) (NASA Earth Observatory, 2022; WMO, 

2021). 

Source: NASA Earth Observatory, 2022

Figure 3.4-1. Average Temperatures at the Earth’s Surface from 1880 to 2022

Among the observed present and predicted future consequences of climate change are increasing and more 

intense droughts, water scarcity, flooding, increasing and more severe wildfires, melting polar ice and 

glaciers, more catastrophic storms, and declining biodiversity (U.N., No Date). 

3.4.1.1 Regulatory Framework for Climate Change and Climate Resilience

Executive Orders

On February 19, 2021, President Biden’s Executive Order (EO) 13990, Protecting Public Health and the 

Environment and Restoring Science to Tackle the Climate Crisis, reinstated the Obama Administration’s 

Climate Change EO 13653, Preparing the United States for the Impacts of Climate Change, and the White 

House CEQ's 2016 Final Guidance for Federal Departments and Agencies on Consideration of GHG 

Emissions and the Effects of Climate Change in National Environmental Policy Act (NEPA) Reviews. The 

CEQ guidance directs federal agencies to quantify the direct and indirect GHG emissions of a proposed 

action and weigh climate change impacts in considering alternatives and in evaluating mitigation measures. 

In January 2023, CEQ published a notice of interim guidance and request for comments in the Federal 

Register on consideration of GHG emissions and climate change in NEPA documents (CEQ, 2023a). The

notice directs federal agencies to quantify reasonably foreseeable GHG emissions whenever possible and 

place those emissions in appropriate context when analyzing a proposed action’s climate impacts. 

In May 2021, President Biden’s EO 14030 Climate-Related Financial Risk, reinstated the Obama 

Administration’s EO 13690, Establishing a Federal Flood Risk Management Standard and a Process for 

Further Soliciting and Considering Stakeholder Input. This EO establishes the Federal Flood Risk 

Management Standard (Standard), “a flexible framework to increase resilience against flooding and help 

preserve the natural values of floodplains,” through amendments to EO 11988, Floodplain Management. 
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Laws and Regulations

In 2021, Congress passed the American Innovation and Manufacturing Act (AIM). It directs the United 

States (U.S.) Environmental Protection Agency (EPA) to reduce production and consumption of

hydrofluorocarbons (HFCs) in the U.S. by 85 percent over the next 15 years, a measure expected to avoid 

up to 0.5°C of global warming by 2100. (EPA, 2023b). In September 2021, EPA issued a final rule to 

implement these requirements, which can be found under 40 CFR Part 84. EPA issued HFC production and 

consumption allowances in accordance with the final rule for the 2024 calendar year. From 2024-2028, 

these allowances will be capped at 40 percent below their baseline historic levels (40 CFR Part 84 and EPA, 

2023b).

EPA’s Mandatory Greenhouse Reporting for GHG emissions regulations are under 40 CFR Part 98. 

Subparts C and I pertain to reporting requirements for the Electronics Manufacturing Sector, which 

encompasses Semiconductors and Related Devices. Facilities emitting more than 25,000 metric tons (MT) 

of CO2e annually are required to report emissions of fluorinated GHGs and fluorinated heat transfer fluids, 

as well as carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) combustion emissions from each 

stationary combustion unit. Semiconductors and Related Devices, North American Industry Classification 

System (NAICS) Code 334413, is a free-standing reporting category under the program. This category 

includes semiconductor fabrication facilities that are within the scope of this PEA as well as wafer 

production facilities and facilities that manufacture other products including transistors, solar cells, and 

other optoelectronic devices. EPA makes reporting information publicly available through its GHG 

Reporting Program (GHGRP) and associated databases.

3.4.1.2 Greenhouse Gas Emissions from the Semiconductor Manufacturing Sector

GHG emissions from semiconductor manufacturing include direct and indirect emissions. Sources of 

direct GHG emissions include onsite stationary combustion and manufacturing processes. If a facility uses 

a Continuous Emissions Monitoring System (CEMS) to measure both the process emissions and the 

combustion emissions, then the combustion emissions are reported with the process emissions. Indirect 

GHG emissions result from onsite electricity consumption from offsite fossil fuel energy generation (EPA, 

2023c). Both direct GHG and indirect GHG emissions must be included for a full accounting of the carbon 

footprint associated with the semiconductor industry sector.

CPO analyzed data from the GHGRP databases for the years 2014-2022 for Semiconductors and Related 

Devices (NAICS Code 334413). Semiconductor fabrication facilities first reported direct emissions under 

the program in 2014, when the total direct emissions for the category were 6.18 MMT CO2e. Direct GHG 

emissions reached their peak in 2015 at 6.4 MMT CO2e and a low of 5.9 MMT CO2e in 2016 and 2017. In 

2022, total direct GHG emissions for NAICS Code 334413 were 6.2 MMT CO2e. On average during this 

period, manufacturing processes contributed 88 percent and onsite stationary combustion sources represent 

12 percent of the total direct emissions (Figure 3.4-2). 

During the period of 2014-2022 for NAICS Code 334413, fluorinated gases contributed 84 percent of the 

average GHG direct emissions, CO2 contributed 12 percent, and N2O contributed 4 percent as depicted in 

Figure 3.4-3. Figure 3.4-4 shows the percentage breakdown of average annual direct emissions from 2014-

2022 attributable to specific GHG constituents. At 46 percent, perfluorocarbons (PFCs) comprise by far the 

highest percentage of direct emissions. Sulfur hexafluoride (SF6) is next at 12 percent of direct emissions, 

while CO2 from onsite stationary combustion sources also contributes 12 percent. 
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Source: EPA, 2023c

Figure 3.4-2. Average Annual Direct Greenhouse Gas Emissions from Semiconductors 

and Related Devices Manufacturing Facilities (NAICS Code 334413), 2014-2022

Source: EPA, 2023c

Figure 3.4-3. Composition of Direct Greenhouse Gas Emissions from Semiconductors 

and Related Devices Manufacturing Facilities (NAICS Code 334413), 2014-2022
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Source: EPA, 2023c 

Figure 3.4-4. Composition of Direct GHG Emissions by Constituent

for Semiconductors and Related Devices (NAICS Code 334413), 2014-2022

DOE’s 2018 Manufacturing Energy and Carbon Footprint (last updated in 2021) for the Semiconductor and 

Related Devices Manufacturing Industry (NAICS Code 334413) estimates 5.3 MMT CO2e of indirect 

GHG emissions from manufacturing resulting from electricity consumption supplied from offsite fossil fuel 

generation (DOE, 2021). Combining the average annual direct GHG emissions from 2014-2022 of 6.2 

MMT CO2e with the estimated indirect GHG emissions of 5.3 MMT CO2e provides the best available 

estimate for the total GHG footprint of approximately 11.5 MMT CO2e annually. According to EPA’s 

Greenhouse Gas Equivalencies Calculator this level is equivalent to the annual CO2e emissions of 2.5 

million gasoline-powered cars, energy use of 1.5 million homes, three coal-fired power plants, or 29 gasfired power plants. Offsetting this level of emissions would, for example, require 3,198 wind turbines 

operating (and displacing fossil fuel emissions) for a year (EPA, 2023d). 

Fluorinated Gas Emissions

Most of the GHG emissions from semiconductor fabrication facilities are fluorinated gases such as PFCs 

and SF6. The use of fluorinated gases did not begin in the semiconductor industry until the late 1980’s. 

Under normal operating conditions, EPA estimates that 10 to 80 percent of these gases pass through the 

manufacturing process unreacted and are released into the atmosphere. Once released, the lifetime of 

these chemical compounds in the atmosphere can range from 270 to 50,000 years (EPA, 2023e). Global 

warming potential (GWP) is a measure of how much energy the emission of 1 ton of a gas will absorb 

over a given period of time (in this case, 100 years), relative to the emission of 1 ton of carbon dioxide 

(CO2) (EPA, 2023f). Table 3.4-1 shows the 100-year GWP of select GHGs associated with 

semiconductor manufacturing. 

Hydrofluorocarbons (HFCs) are widely used in semiconductor facilities to print circuits on wafers, to 

clean chemical vapor deposition (CVD) chambers, and as fluorinated heat transfer fluids (FHTFs) 

(Ruberti, 2023). As shown in Figure 3.4-4, HFCs represent, on average, 6 percent of the GHG emissions 

from semiconductor and related device manufacturing facilities. These chemicals were adopted by the 

semiconductor industry as alternatives to ozone-depleting refrigerants (chlorofluorocarbons or CFCs). 

However, as noted above, some HFCs have a high GWP which, molecule for molecule, can be up to 
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thousands of times greater than CO2 (EPA, 2023b). The average annual emissions of HFCs for the 

semiconductor and related devices sector from 2014 to 2022 was 0.4375 MMT CO2e (EPA, 2023c). 

Table 3.4-1. 100-Year Global Warming Potential of Select Greenhouse Gases 

Greenhouse Gas

Global Warming Potential 

(GWP)-100 Year

PFC-14 7,390

PFC-116 12,200

PFC-218 8,830

Sulfur Hexafluoride (SF6) 22,800

Carbon Dioxide (CO2) 1

Nitrogen Trifluoride (NF3) 17,200

Nitrous Oxide (N2O) emissions 298

HFC-23 14,800

HFC-32 675

HFC-41 92

HFC-125 3,500

FHF-43-10mee 1,640

HFC 143a 4,470

Source: 40 CFR Part 98 Subpart A, Table A-1

Many semiconductor facilities have identified means of abating GHG emissions through removal or 

destruction technologies, source reduction and process improvement, and use of alternative chemicals

(EPA, 2023e). EPA’s 2022 GHG Reporting Database for Semiconductors and Related Devices (NAICS 

Code 334413) shows that 24 semiconductor fabrication facilities reported using GHG abatement systems, 

with removal or destruction efficiencies ranging from 0.34 to 70 percent. Another 27 semiconductor 

fabrication facilities reported that they did not use GHG abatement systems (EPA, 2023c). Per 40 CFR 

98.93, the effect of abatement systems is included in GHG emissions estimates. 

3.4.2 Environmental Consequences

This section discusses the potential effects from climate change and climate resilience under the No Action 

Alternative and the Proposed Action Alternative.

3.4.2.1 No Action Alternative

Under the No Action Alternative, federal financial assistance for the modernization and internal expansion 

of the semiconductor fabrication facility would not be made available and no modernization and internal 

expansion would take place. The facility would continue to operate as it does at present, in the same manner 

and at the same scale. Without financial assistance to modernize the facility and install upgraded 

manufacturing tools that are more energy-efficient, these upgrades would not occur. Reduction of GHG 

emissions through energy efficiency and improved process tools and/or installation of GHG abatement 

systems would not occur. 

Under the No Action Alternative there would continue to be a negligible to minor, adverse, long-term, 

global effect on GHG emissions and resultant climate change and climate resiliency. Overall, there would 

be no new effects to climate change and climate resiliency under the No Action Alternative.
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3.4.2.2 Proposed Action Alternative

Under the Proposed Action, the semiconductor fabrication facility would modernize equipment and 

potentially expand production. If the modernization and internal expansion would require the use of 

additional energy that would be directly or indirectly (i.e., via electricity) provided by fossil fuels such as 

natural gas or coal-fired power plants, there would be additional fuel combustion and thus increased GHG 

emissions. With modernization, production capacities could increase, which would result in increased direct 

GHG emissions, including CO2, methane, nitrous oxide (N2O), HFCs, and other fluorinated gases. Crucial 

facility processes are heavily dependent upon high-GWP HFCs, and to the extent the use of HFCs would 

be increased, there would be a greater potential to contribute to GHG emissions. Although GHG emissions 

could increase as a result of improving and expanding production capacities associated with modernization, 

CHIPS Act funding represents an opportunity for facilities to modernize their tools and change processes 

to minimize direct emissions from semiconductor manufacturing processes. 

Abatement of direct GHG emissions, including N2O and HFCs, resulting from the manufacturing process 

has the potential to reduce overall GHG emissions from semiconductor fabrication facilities. EPA cites: 1) 

process improvements/source reduction; 2) alternative chemicals; and 3) destruction technologies as 

available approaches for reducing GHG emissions. Examples of projects that could abate GHG emissions 

are conversions of certain chemical vapor deposition (CVD) tools to remote NF3 plasma, Remote Plasma 

Clean (RPC) sources, and installation of combustion abatement units (EPA, 2023b). 

Due to the semiconductor manufacturing industry’s heavy reliance on electricity for its manufacturing 

processes, many companies are shifting to renewable energy sources, which could result in a substantial

reduction in facility GHG emissions Addition information on energy use by the semiconductor 

manufacturing industry can be found in Section 3.10 Utilities of this Draft PEA.

A facility may implement appropriate best management practices (Appendix A) to reduce GHG emissions.

Direct GHG emissions could be reduced from the installation of improved process technologies, emissions 

abatement equipment, and onsite renewable energy generation. Indirect GHG emissions could be reduced 

from increased use of off-site renewable energy. However, production increases would increase GHG 

emissions. Thus, the effects could be adverse or beneficial, but given the high GWP of some of the GHG 

constituents from semiconductor fabrication facilities, effects are more likely to be adverse. 

Under the Proposed Action, a facility modernization and expansion project would have a negligible to 

minor, long-term, global effect on climate change from GHG emissions. As discussed above, modernization 

projects present an opportunity for facilities to modernize their tools and change processes to minimize 

direct emissions from semiconductor manufacturing processes. Even if such improvements are not made, 

however, the marginal increase in GHG emissions from an individual modernization project would be 

negligible compared to overall U.S. emissions and emissions from the semiconductor industry sector. 

3.5 AIR QUALITY

This section describes the affected environment and environmental consequences for air quality under the 

Proposed Action and No Action Alternatives. 

3.5.1 Affected Environment

Air quality is the measure of the atmospheric concentration of defined pollutants in a specific area. An air 

pollutant can be any substance in the air that can cause harm to humans or the environment. Air pollutant 

sources can be natural, including smoke from wildfires, dust, and wind erosion, or human-made, including 

emissions from vehicles, industrial facilities, agriculture, construction sites, dust from unpaved roads, or 

smoke from human-caused wildfires. Air quality can also be affected by an area’s surface topography, air 

basin size, prevailing meteorological condition, and climate conditions.
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Air pollutant emissions from semiconductor fabrication facilities are regulated under state and federal law, 

and facilities must follow regulatory standards to control emissions from process equipment vents and 

storage tanks. Emission limits are based on factors including the manufacturing processes performed, the 

raw materials and chemicals used in the facility, and local air quality conditions. Semiconductor fabrication 

facilities also are sources of GHG emissions as discussed under Section 3.4 Climate Change and 

Resiliency of this Draft PEA.

3.5.1.1 Regulatory Framework

The Clean Air Act (CAA) (42 U.S.C. §7401 et seq.) is the primary regulatory driver for promoting air 

quality in the U.S to protect human health and the environment. With ambient air quality provisions under 

the National Ambient Air Quality Standards (NAAQS) and stationary source air pollutant control provisions 

under the National Emission Standards for Hazardous Air Pollutants (NESHAP), these requirements form 

the basis for maintaining a healthy level of air quality in the U.S. 

Under Title V of the CAA, EPA established a national, federally enforceable operating permit program. 

EPA promulgated implementing regulations under 40 CFR Part 70 that require each state or local permitting 

authority to develop a federally enforceable facility operating permit program. Title V is intended to further 

facilitate and enhance air quality planning, emission controls, and compliance, and to improve existing 

emission inventories. EPA typically delegates its permitting authority to the states, and thus, permits are 

generally issued by states or local agencies, although some are issued by EPA Regions (SMAQMD, 2017).

NAAQS

The CAA requires the EPA to set NAAQS for the following six common air pollutants, known as “criteria 

air pollutants” (40 CFR §7409): 

1. particulate matter, 

2. photochemical oxidants (including ozone), 

3. carbon monoxide, 

4. sulfur oxides, 

5. nitrous oxides, and 

6. lead. 

The CAA identifies two types of NAAQS: primary standards that provide public health protection, 

including protecting the health of sensitive populations such as asthmatics, children, and the elderly; and 

secondary standards that provide public welfare protection, including protection against decreased visibility 

and damage to animals, crops, vegetation, and buildings. NAAQS also address potential adverse effects 

from short-term exposure to higher levels of emissions by providing high and low averaging time standards, 

with lower averaging times corresponding to higher emission levels and higher averaging times 

corresponding to lower emission levels. 

Delegated CAA programs to the state require the state to administer NAAQS compliance through 

development of a State Implementation Plan (SIP). Areas that comply with NAAQS are designated within 

the SIP as “attainment areas”, and those that are not in compliance are designated as “nonattainment areas”. 

Attainment is when air quality within an area is equal or better than the NAAQS level and proposed actions 

must maintain clean air; whereas nonattainment is when air quality is worse than the NAAQS level and 

these areas must take actions to improve air quality and attain and there is no air quality data, the area is 

treated as in attainment. Emission control standards for semiconductor fabrication facilities typically are 

set within the SIP and are influenced by whether the facility is within an attainment area or nonattainment 

area.
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General Conformity Rule

The purpose of the CAA’s General Conformity rule (40 CFR Part 93 Subpart B) is to ensure that: 

• Federal activities do not cause or contribute to new violations of NAAQS;

• Federal actions do not worsen existing violations of the NAAQS; and 

• Attainment of the NAAQS is not delayed.

Under the General Conformity Rule, applicants for federal financial assistance for semiconductor 

fabrication facility modernization and internal expansion projects under the CHIPS Incentives Program 

must work with the state agency responsible for a nonattainment or maintenance area to ensure federal 

actions conform to the state’s air quality plans established in the SIP. 

Major and Minor Sources

A “major source” of air pollution is defined under the CAA §112 as any stationary source or group of 

stationary sources located within a contiguous area and under common control that “emits or has the 

potential to emit 10 tons per year (tpy) of any single hazardous air pollutant (HAP), 25 tpy of any 

combination of HAPs, or more than 100 tpy of any criteria pollutant”. Sources that emit less than these 

thresholds are designated as “minor sources”. Lower thresholds for major sources may apply in 

nonattainment areas where air quality is worse than the NAAQS. 

National Emission Standards for Hazardous Air Pollutants

EPA developed NESHAPs to federally regulate sources and source categories that emit HAPs that pose 

risks to human health. HAPs are a list of 187 pollutants identified by the EPA that are known or suspected 

to cause cancer or other serious health effects, such as reproductive effects or birth defects, or adverse 

environmental effects. HAPs generally originate from stationary sources, but there are also mobile sources 

of HAPs (e.g., internal combustion engines) and indoor sources of HAPs (e.g., building materials and 

cleaning processes). 

In 2008, EPA issued amendments to the NESHAP for semiconductor manufacturing (40 CFR Part 63 

Subpart BBBBB). These amendments established a new MACT standard for existing and new combined 

process vent streams containing inorganic and organic HAPs. The amendments also clarify the emission 

requirements for process vents by adding definitions for organic, inorganic, and combined HAP process 

vent streams that contain both organic and inorganic HAPs. Under the regulations, controls on the emission 

of air pollutants from process vents and storage tanks at new, reconstructed, or existing sources at 

semiconductor fabrication facilities, as defined at 40 CFR Part 63 Part BBBBB, are required. There are 

separate control requirements for process vents containing organic pollutants, such as methanol, and process 

vents containing inorganic pollutants, such as hydrogen chloride (HCl or hydrochloric acid) or hydrogen 

fluoride (HF or hydrofluoric acid) (EPA, 2007). Emissions from process vents containing organic air toxics 

must be reduced by 98 percent or to below 20 parts per million (ppm) by volume, and emissions from 

inorganic process vents are required to be reduced by 95 percent or to below 0.42 ppm by volume. 

Emissions from storage tanks greater than 1,500 gallons are required to be reduced to the same level of 

control as inorganic process vents (EPA, 2007).

New Source Performance Standards

New source performance standards (NSPS) implement CAA §111(b) and are issued for categories of 

sources that EPA has listed because they cause, or contribute significantly to, air pollution, which may 

reasonably be anticipated to endanger public health or welfare. The primary purpose of the NSPS is to attain 

and maintain ambient air quality by ensuring that the best demonstrated emission control technologies are 

installed as industrial infrastructure is modernized (42 U.S.C. §7411).
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Since 1970, the NSPS have been successful in achieving long-term emissions reductions across numerous 

industries by assuring cost-effective controls are installed on new, reconstructed, or modified sources (EPA, 

2023g). Some of the proposed semiconductor manufacturing modernization projects would involve 

upgrades to tools covered by NSPS. Most semiconductor facilities must also comply with 40 CFR Subparts 

60 Db-Dc (boilers), JJJJ, (stationary spark ignition internal combustion engines) and KKKK (generators). 

Compliance with NSPS is required for both minor and major sources.

New Source Review

The New Source Review (NSR) program, commonly referred as the “preconstruction permitting program”, 

is a CAA program that requires industrial facilities to install modern pollution control equipment for newly 

built facilities and existing facilities that are undergoing expansion or renovations that significantly increase 

emissions. Under the NSR program, if so delegated, the state or local air pollution agency issues the required 

permits. If not delegated, EPA Regional offices will issue the permits. There are three types of NSR 

permitting requirements. A source may have to meet one or more of these permitting requirements:

• Prevention of Significant Deterioration (PSD) permits are required for new or major sources

making a major modification in attainment or unclassifiable areas;

• Nonattainment NSR permits are required for new major sources or major sources making a major 

modification in nonattainment areas; and

• Minor source permits are required for pollutants from stationary sources that do not require PSD or

nonattainment NSR permits. The purpose of minor NSR permits is to prevent the construction of 

sources that would interfere with attainment or maintenance of a NAAQ or violate the control 

strategy in nonattainment areas. 

The following are specific minor sources that are also included in minor source permit requirements:

• True minor source: a source that emits, or has the potential to emit, regulated NSR pollutants in 

amounts that are less than the major source thresholds, but equal to or greater than the minor NSR 

thresholds under 40 CFR § 49.153, without the need to take a federally enforceable restriction to 

reduce its Potential to Emit (PTE) to such levels.

• Synthetic minor source: a source that has the potential to emit regulated NSR pollutants in amounts 

that are at or above the thresholds for major sources but has implemented a federally enforceable 

restriction so that its PTE is less than such amounts for major sources. 

• Synthetic minor HAP source: is a source that otherwise has the potential to emit HAPs in amounts 

that are at or above those for major sources of HAPs, but that has implemented a federally 

enforceable restriction so that its PTE is less than such amounts for major sources. 

The designation of synthetic minor source is allowed for both regulated NSR pollutants and HAPs. Once a 

permittee has accepted an enforceable emission limitation, it must comply with that limitation. This is 

necessary to ensure that it is legally prohibited from operating as a major source. If the permittee applies 

for a synthetic minor source or synthetic minor HAP source, it must comply with the same public 

participation requirements and the same procedures for final permit issuance and administrative and judicial 

review found under 40 CFR 49.157 and 40 CFR 49.159, respectively.

3.5.1.2 Air Emissions Sources and Characterization

A variety of air pollutants may be emitted from semiconductor manufacturing facilities. These include acid 

fumes and organic solvent emissions from cleaning, rinsing, resist drying, developing, and resist stripping; 

HCl emissions from etching; and other various emissions from spent etching solutions, spent acid baths, 

and spent solvents (EPA, 2001a). Processes related to semiconductor manufacturing, such as water 
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purification and industrial wastewater treatment, may also generate air emissions at semiconductor 

facilities.

In a November 1994 Semiconductor Industry Association (SIA) report to EPA that was ultimately used to 

develop the NESHAP standards for semiconductor fabrication facilities, the 20 participating facilities were 

reported to have been using 29 different chemicals listed as HAPs. Ion bed regeneration for deionized water 

production used the greatest amount of HAP chemicals out of any source in the facilities. Within the 

semiconductor fabrication process, lithography operations used the most HAP chemicals and wet etching 

used the second most. The other parts of the semiconductor fabrication process with substantial HAP 

chemical use were diffusion, crystallization, and some cleaning operations (EPA, 2001a).

SIA reported that five chemicals comprised 95 percent of the total HAP chemical use: HCl, HF, glycol 

ethers, methanol, and xylene. Of the 95 percent total HAP chemical use, 76 percent were acids (87 percent 

HCl), 23 percent were organics (32 percent xylene, 29 percent methanol, and 22 percent glycol ethers), and 

1 percent were inorganics (metals, hydrides, and chlorine). Inorganics other than acids comprise only a 

small percentage of HAP chemicals used at semiconductor fabrication facilities. Reported human health 

effects from exposure to some of these HAPs include respiratory effects, eye irritation, neurological effects, 

blurred vision, headache, dizziness, central nervous system depression, nausea, cardiopulmonary effects, 

renal damage, lack of muscle coordination, and unconsciousness. For more information on health effects 

from exposures, refer to Section 3.7 Human Health and Safety of this Draft PEA (EPA, 2001a). Another 

SIA report showed that 10 chemicals comprised approximately 93.8 percent of all listed HAPs emitted: 

methanol, ethylbenzene, ethylene glycol, methylene chloride, glycol ethers, perchloroethylene, HCl, HF, 

trichloroethylene, and xylene. Methanol was emitted in the greatest amounts (EPA, 2001a).

In general, each manufacturing tool has an exhaust system that may include point of use (POU) devices 

tied to ductwork that is then connected to control equipment. POU control systems are designed for treating 

air emissions from the outlet of the manufacturing process to remove the compounds of interest and prevent 

them from entering the main exhaust ductwork (EPA, 2001a).

Cleanrooms have more stringent air quality requirements than average industrial spaces; therefore, most 

semiconductor fabrication facilities have a limited number of air exhaust streams. These air exhaust streams 

are characteristically high-volume, low-velocity streams resulting in dilute pollutant concentrations. In 

general, the HAP emissions from a semiconductor fabrication facility consist of two different classes: acids 

and organics. These two classes of emissions are separated at the facility so they can be treated by the 

appropriate control device. Each facility has an exhaust system which may include POU devices connected 

to ductwork that directs emissions to the appropriate control equipment, which includes scrubbers and 

oxidizers (EPA, 2001a).

According to a study on facility-by-facility HAP emissions accounting conducted by the SIA, the industry 

also has uncontrolled emission points within the semiconductor manufacturing process. Approximately 

65.1 megagrams per year (Mg/yr) (71.6 tpy) of uncontrolled emissions were identified by the 11 studied 

facilities. Of this amount, 54.0 Mg/yr (59.3 tpy) (or about 83 percent of the uncontrolled emissions) were 

associated with cleaning, photoresist formulation (mixing), ceramic layering activities, and other activities 

(EPA, 2001a).

Under the GHGRP, owners and/or operators of electronics manufacturing facilities that emit equal to or 

greater than 25,000 metric tons of CO2e per year from fluorinated GHGs and N2O emissions must report 

these emissions from all electronics manufacturing processes and any other sources at the facility to the 

EPA. See Section 3.4 of this Draft PEA for more information.

3.5.1.3 Emissions Control Equipment

To meet air permitting requirements, the semiconductor manufacturing industry uses air pollution control 

measures that include add-on control devices and preventive measures. Add-on control devices are used on 
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air discharge streams to reduce or remove pollutants and include oxidizers and scrubbers that are described 

in more detail below. In addition, POU control devices can be used on individual process tools. Preventive 

measures include product substitution and reformulation, work practice procedures, and equipment 

modifications.

A catalytic oxidizer is used to convert harmful gases into harmless substances. It is a combustion device 

that controls volatile organic compounds (VOCs), HAPs, and odorous emissions by reacting oxygen with 

pollutants over a specially designed catalyst and converting the pollutants into CO2, water/steam, and usable 

heat. A catalyst is a substance that is used to accelerate the rate of a chemical reaction, allowing the reaction 

to occur faster and at a lower temperature range. The catalyst may be a precious metal, such as platinum or 

palladium, or it may be a basic metal, such as metal oxides or metal carboxylates using iron, vanadium, or 

molybdenum (CP, 2023).

Thermal Recuperative Oxidizers (TOs) destroy air pollutants emitted from process exhaust streams at 

temperatures ranging from 760°C (1,400 °F) to 815°C (1,500 °F). TOs utilize a multi-pass shell-and-tube 

type heat exchanger fabricated of heavy-duty stainless steel. Oxidation is achieved as pollutants pass 

through the combustion chamber and are mixed and held at elevated temperatures. Thermal oxidation 

promotes a chemical reaction of the air pollutant with oxygen at elevated temperatures. This reaction 

destroys the VOC emission in the air stream by converting it to CO2, water/steam, and heat (CP, 2023; 

CMM, 2023). 

In a regenerative thermal oxidizer (RTO), process exhaust fumes are forced into a recuperative oxidizer 

inlet manifold (with a high-pressure supply fan) and directed into the cold side of a high efficiency, stainless 

steel, multi-pass shell-and-tube type heat exchanger. The pollutant laden air passes through the combustion 

chamber, is thoroughly mixed for temperature uniformity, and is held at the elevated set-point temperature

for a residence time of 0.5 to 1.0 seconds. VOC/HAP emission control takes place within the combustion 

chamber where auxiliary fuel is introduced if necessary (CMM, 2023).

Scrubbers are used to remove gaseous and particulate contaminants generated during various process steps, 

such as chemical vapor deposition (CVD) and etching, to ensure that the exhaust gases are clean and safe 

to release into the environment. Wet scrubbers use a liquid scrubbing solution, such as water, to remove 

pollutants from the exhaust gases. Dry scrubbers use a solid or gaseous scrubbing medium, such as activated 

carbon or sorbents, to remove pollutants from the exhaust gases. Hybrid scrubbers are scrubbers that use a 

combination of liquid and solid or gaseous scrubbing mediums to remove pollutants from the exhaust gases 

(Abachy, 2022).

Ammonia abatement systems are designed to remove ammonia from a liquid waste stream. Some systems 

allow for ammonia removal from air streams with a very small percentage of nitrogen oxide (NOx) 

formation. NOx formation is further reduced by the use of secondary catalyst systems without the use of 

costly reactants and chemicals (CP, 2023). Selective Catalytic Reduction (SCR) is the secondary catalyst 

system used to selectively reduce harmful NOx by converting them to nitrogen across a catalyst.

There are a number of opportunities available to reduce air emissions and move toward net-zero GHG 

emission status in the semiconductor manufacturing industry. Many manufacturers have already achieved 

substantial reductions by employing one or more of these pollution abatement concepts. Figure 3.5-1 shows 

a comparison of 10 pollution abatement concepts along with their respective strategies to reduce air 

emissions in comparison to their relative cost of implementation.
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Source: McKinsey, 2022a

1

For an average 200-millimeter (mm) to 300-mm high-volume facility with trailing node size. Value reflects higher 

potential for process optimization in older, trailing node facilities. Cost strongly dependent on facility location and 

availability of renewables. Not including potential emissions from onsite power generation.

Note: Scope 1 emissions are those from direct or controlled sources at the manufacturing facility; Scope 2 emissions 

are from generation of purchased electricity, steam, heating, and cooling equipment. An Abatement lever is an 

abatement technique or technology.

Figure 3.5-1. Air Pollution Abatement Concepts and Comparative Costs

3.5.2 Environmental Consequences

This section discusses the potential effects to air quality under the No Action Alternative and the Proposed 

Action Alternative.

3.5.2.1 No Action Alternative

Under the No Action Alternative, the semiconductor fabrication facility would not modernize or expand 

because it would not receive financial assistance from the CHIPS Incentives Program. No changes in the 

amount or pollutant load of air emissions would occur because the same existing equipment and processes 

would be used in the same configuration. There would be no changes to local or regional air quality. The 

facility would continue to produce semiconductors at the same rate, using the same equipment within the 

existing facility footprint. Under the No Action Alternative, laws, regulations, and permitting requirements 

would remain in place, and facility would be expected to continue to comply with all regulations and permit 

requirements. The effects of the No Action Alternative would be direct, adverse, negligible to minor, longterm in duration, and localized to regional in extent.
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3.5.2.2 Proposed Action Alternative

Under the Proposed Action, the semiconductor fabrication facility modernization and expansion project 

would have the potential to cause adverse effects on air quality from increases in the quantity of pollutants 

generated from semiconductor production processes. Increases in pollutant loads and changes in the types 

of pollutants emitted to the air could be caused by increases in semiconductor production due to the 

implementation of the Proposed Action to expand the manufacturing space within the existing facility

footprint for additional and/or new equipment, and modernization of manufacturing processes. An increase 

in air pollution due to construction activities would be short-term and minor since the modernization would 

occur within the existing facility footprint and the only anticipated emission effects would be from operation 

of light duty construction equipment such as cranes, light trucks, and generators while the modernization is 

in progress. The implementation of modernized equipment and processes under the Proposed Action may 

also offer the opportunity for use of improved abatement or best available control technologies that result 

in a reduction in existing air pollutant levels for the same semiconductor output depending on planned 

expansions, or increased semiconductor output that would not cause emissions to exceed existing pollutant 

levels. This opportunity must also account for additional emissions from potential ancillary and other 

supporting systems.

These effects would not exceed the localized or regional air quality standards because facilities would still 

need to comply with air permit limits. Treatment of criteria and HAPs to meet existing air permit 

requirements would be achieved through use of emissions control technologies as discussed in Section 

3.5.1.3 of this Draft PEA. For some potential pollutants, existing emissions control technologies would be 

utilized with satisfactory results. There is potential for air quality effects to be reduced with the 

implementation of the Proposed Action if the proposed project included new abatement equipment and best 

available control technologies practices to treat air emissions or prevent pollutants from entering the 

atmosphere. 

As part of the due diligence process to receive CHIPS Incentives Program funding, an applicant would be 

required to demonstrate compliance with all existing facility permits. Upon completing modernization 

and/or internal expansion projects, the facility would still be required to comply with permit limits, although 

permit limits may be revised if the proposed project triggers new source requirements. Additionally, a 

facility may implement appropriate best management practices (Appendix A) as provided by CPO or as 

conditions of revised permits stemming from implementation of the Proposed Action.

Overall, the effects of modernization and internal expansion at a semiconductor fabrication facility under 

the Proposed Action would be direct and long term and localized to regional because of increases in air 

emissions resulting from increased production. These effects would be adverse and negligible when 

compared to current conditions, but they could be beneficial and minor if new air pollution control measures

and best available control technologies were introduced with the modernization to reduce the overall 

pollutant load in air emissions from facility operations.

3.6 WATER QUALITY

This section describes the affected environment and consequences to water quality under the Proposed 

Action and the No Action Alternative. 

3.6.1 Affected Environment

Water quality describes the condition of water, including chemical, physical, and biological characteristics. 

The most common standards used to monitor and assess water quality convey the health of ecosystems, 

safety of human contact, extent of water pollution, and condition of drinking water. Water quality standards 

(WQS) are provisions of state, territorial, authorized tribal, or federal law approved by the EPA that describe 

the desired condition of a water body and the means by which that condition will be protected or achieved 

(EPA, 2022a). States, territories, and authorized tribes establish WQS for U.S. waters to protect human 
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health and aquatic life. WQS form a legal basis for controlling pollutants entering the waters of the U.S. 

(WOTUS). WOTUS includes, waters which are currently used, or were used in the past, or may be 

susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and 

flow of the tide, the territorial seas, or interstate waters; impoundments of waters; tributaries of waters that 

are relatively permanent, standing or continuously flowing bodies of water; wetlands adjacent to the 

preceding waters; and intrastate lakes and ponds that are relatively permanent, standing or continuously 

flowing bodies of water with a continuous surface connection to the preceding waters (33 CFR 328; 40 

CFR 120). 

Groundwater is subsurface water found beneath the water table in soils and geologic formations. 

Groundwater is the most prevalent source of available freshwater that supports potable, agricultural, and 

industrial uses, especially in areas that lack access to surface water resources. Groundwater quality is 

impacted by interactions with soil, sediments, rocks, surface waters, and the atmosphere. Groundwater 

quality may also be significantly affected by agricultural, industrial, urban, and other human actions.

3.6.1.1 Regulatory Framework

There are numerous laws and regulations that protect water quality at the federal, state, and regional levels.

At the federal level, the primary law protecting the "chemical, physical, and biological integrity of the 

nation's waters" is the Clean Water Act (CWA) (EPA, 2023h). Water quality is regulated within the context 

of meeting standards established for compliance with the CWA, specifically:

• Section 303(d) – this section mandates states to develop lists of all impaired waterbodies and 

prioritize these waters for establishment of plans to restore degraded areas. EPA is also authorized to 

assist states, territories, and authorized tribes in listing impaired waters and developing Total 

Maximum Daily Loads (TMDLs) for these waterbodies.

• Section 305(b) – This section requires states to report on the overall condition of aquatic resources.

• Section 401 – This section establishes the authority for EPA to develop effluent limitations guidelines 

for existing sources, standards of performance for new sources, and pretreatment standards for new 

and existing sources. Effluent limitations guidelines and standards (ELGs) for semiconductor 

fabrication facilities are included in the Electrical and Electronic Components (E&EC) Category 

under 40 CFR Part 469.

• Section 402 – This section establishes the National Pollutant Discharge Elimination System (NPDES) 

program to address water pollution by regulating point sources that discharge pollutants to waters of 

the U.S. unless authorized by an NPDES permit. A NPDES permit contains limits on what can be 

discharged as well as monitoring and reporting requirements, and other provisions to ensure that the 

discharge does not degrade water quality or human health. EPA can authorize state, tribal, and 

territorial governments to administer the NPDES program to include permitting, administration, and 

enforcement.

• Section 403 – This section establishes National Pretreatment Standards to control pollutants which 

pass through or interfere with treatment processes in Publicly Owned Treatment Works (POTWs), or 

which may contaminate sewage sludge. The national pretreatment program is a cooperative effort of 

federal, state, and local environmental regulatory agencies established to protect water quality and 

designed to reduce conventional and toxic pollutant levels discharged by industries into municipal 

sewer systems and into the environment. EPA and authorized NPDES state pretreatment programs 

approve local municipalities to perform permitting, administration, and enforcement for discharges to 

the municipalities’ POTW.

In a recent report, EPA found that the majority of semiconductor fabrication facilities are indirect 

dischargers of wastewater to local or regional POTWs (EPA, 2022a). These facilities are subject to the 

general pretreatment regulations for existing and new sources of pollution under 40 CFR Part 403 and the 
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standards for E&EC Point Source Category under 40 CFR Part 469. Some facilities may generate 

wastewater from metal finishing and/or electroplating operations as well as E&EC operations; therefore, 

facilities also may be subject to ELGs for the Metal Finishing and Electroplating Point Source Categories

under 40 CFR part 433 and part 413, respectively. 

Pretreatment permits are issued by the POTW if it has an approved local pretreatment program by the state 

or EPA. Pretreatment permits issued to semiconductor fabrication facilities may contain local limits for 

specific parameters in addition to limits that enforce the general and specific prohibitions in 40 CFR 403.5 

and the technology-based pretreatment standards in 40 CFR Part 469, E&EC ELGs. Indirect discharging 

semiconductor fabrication facilities are required to conduct self-monitoring and submit monitoring reports 

to the pretreatment control authority (POTW, state, or EPA) at least twice a year. Monitoring reports 

generally include the nature and concentration of pollutants with effluent limitations, records of measured 

or estimated average and maximum daily flows for the reporting period, and pollution prevention 

documentation. 

Any semiconductor fabrication facility that directly discharges pollutants from a point source to a water of 

the U.S. is subject to the NPDES permit program, with permits issued by EPA or authorized states (EPA, 

2022b). These permits must include applicable technology-based ELGs for the industry per 40 CFR Part 

469 as well as any necessary permit limits and conditions to protect water quality in the receiving water 

body. 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 ELGs. Direct dischargers must also submit discharge monitoring reports to the permitting authority 

in compliance with the NPDES permit.

Indirect discharging semiconductor fabrication facilities pretreat their industrial wastewater through 

processes such as neutralization or chemical precipitation with clarification prior to discharging to a POTW 

(EPA, 2022b). Direct discharging facilities use treatment processes including solvent management, 

neutralization, chemical precipitation with clarification, filtration, and in-process control for specific 

pollutants, such as collection of metal-bearing wastes for resale, reuse, or disposal (EPA, 2022b). Most 

facilities implement a solvent management plan which is designed to prevent most organic contaminants 

from entering the wastewater. Some facilities recover organic solvents for reuse or resale. 

3.6.1.2 Wastewater Characterization

Wastewater generated from semiconductor fabrication and related facility operations can be treated and 

reused, treated and discharged, or transported offsite for treatment, disposal, or reuse. Segregation of waste 

allows facilities to treat, dispose, or reclaim wastes in more cost-effective manners. Facilities keep 

wastewaters with different wastes separated prior to treatment and segregate solvents-containing wastes for 

disposal. Automated water treatment systems are programmed to accept or divert wastewaters based on 

input from influent monitoring instrumentation. Diverted flows can then be separately captured, managed, 

or discharged as needed. Common wastewater streams and handling methods include (IEEE, 2023; ISMI, 

2006):

• Hydrofluoric (HF) Acid Wastewater: Can contain ozone and/or ammonia (these constituents often 

require additional treatment measures) and is treated onsite, producing calcium-based solid waste 

which can be reused elsewhere outside of the semiconductor facility.

• Ammonium [NH4]

+ Wastewater: Can contain hydrogen peroxide and is treated onsite, producing 

ammonium sulfate solution for offsite recycle/disposal.

• Solvent Wastewater: Contains isopropyl alcohol (IPA) and other solvent waste (e.g., glycols, ethers, 

polar and non-polar photoresist) and can be corrosive and/or contain hydrogen peroxide or PFAS 

substances. Solvent collection systems prevent untreated liquid waste from mixing with other 
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wastewater streams. Solvents not treated onsite are shipped offsite to vendors for re-use after 

purification or to approved treatment and disposal facilities. 

• Metal Wastewater: Can contain metals and metallic compounds. Metal collection systems allow for 

on or offsite treatment or recycling (e.g., copper solid produced from concentrated waste by 

electrowinning).

• Acidic or Caustic Wastewater: Can contain acidic or caustic solutions from processes or facility 

maintenance. Wastewater streams from various processes are combined and neutralized by sulfuric 

acid or sodium hydroxide before discharging. 

• Concentrated Sulfuric Acid (H2SO4) Waste: Waste sulfuric acid can contain impurities. Can be 

collected in tanks for onsite or offsite reuse in other industries. Onsite reuse typically is only in waste 

treatment; unless it is refined to electronic grade for reuse.

• Wastewater Containing Suspended Solids (e.g., silicon from backside grinding, silicon dioxide 

from chemical mechanical polishing [CMP]): Can be combined with acid wastewater or sent to a 

solids removal system with the clarified water sent for reuse.

• Lithography Developer Waste (contains TMAH): Can be treated on or offsite. Typically, 

concentrated organic solvents are segregated from other wastewaters and sent offsite for reuse or 

disposal. Treatment methods include biological treatment to digest the TMAH, or recovery of the 

TMAH in a segregated drain and treatment system for reuse offsite.

• Concentrated Phosphoric Acid Waste: Can be collected in tanks for treatment onsite or sent offsite 

for reuse. Onsite reuse typically is only as a nutrient for biological treatment. Onsite treatment may 

include neutralization to lower pH, precipitation to remove metals, and filtration to remove solids and 

impurities.

Pollutants currently regulated under 40 CFR 469 include (EPA, 2022b): 

• Indirect dischargers: Total Toxic Organics and arsenic.

• Direct dischargers: Total Toxic Organics, arsenic, pH, fluoride, and total suspended solids. 

The ELGs for Total Toxic Organics are based on the sum of the concentrations for each of the regulated 

toxic organic compounds that are found in the wastewater discharge at a concentration greater than 10 

micrograms/Liter (μg/L). The regulated toxic organic compounds are listed at 40 CFR 469. The Metal 

Finishing Category effluent limitations guidelines (40 CFR 433) also apply to semiconductor fabrication 

facilities that are generating electroplating wastewater and include limits for nickel, copper, chromium, and 

lead. 

Since the 1980s, the semiconductor industry has incorporated up to 49 additional chemical elements into 

semiconductor manufacturing operations (EPA, 2022b). For example, the semiconductor industry has 

developed several new process chemistries for photolithography over the past 30 years that use new solvent 

systems, such as ethyl lactate and propylene glycol monomethyl ether acetate (PGMEA). In addition, some 

chemically amplified photoresists and antireflective coatings can contain perfluoroalkyl substances (PFAS). 

While most photolithography waste is handled as solvent and incinerated, some facilities send 

approximately 40 percent of waste antireflective coating (containing PFAS) to wastewater treatment

facilities. For more information about the use of PFAS in semiconductor fabrication facilities and emerging 

PFAS standards, see Appendix B. In addition, some facilities may be discharging more substantial 

quantities of certain previously considered and/or regulated pollutants, including copper and fluoride, due 

to manufacturing process changes while phasing out the use of other pollutants, such as organic chemicals.

A recent EPA report 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 (EPA, 2022b). Most noteworthy of the new pollutants 
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are PFAS and elements such as germanium and gallium, which are toxic, persistent, and can bioaccumulate. 

EPA’s review shows that the industry continues to rely on traditional technologies for wastewater treatment; 

however, the industry is actively evaluating new technologies (e.g., biological, ion exchange, reverse 

osmosis, electrowinning) and wastewater management practices (e.g., rinse recycle, reverse osmosis reject 

recycle) aimed at treating some of the newer pollutants and conserving water. EPA concluded that the 

existing ELGs are sufficient to prevent interference or upset at POTWs and to protect water quality of 

receiving waters, but that additional study will be required to identify any new pollutants of concern as new 

technologies are developed and new chemicals are used in semiconductor fabrication. 

According to the Effluent Guidelines Program Plan 15 released in 2023, EPA intends to continue to monitor 

discharges of PFAS from E&EC facilities through the POTW Influent Study, updated Toxics Release 

Inventory (TRI) reporting requirements for PFAS, and NPDES permit monitoring requirements for 

federally-issued permits and state permits as more states include monitoring for PFAS in permits. These 

data will help EPA identify any significant sources of these chemicals in future reviews. EPA will revise the 

ELGs for the Metal Finishing and Electroplating Point Source Categories (40 CFR part 433 and part 413, 

respectively) to address wastewater discharges of PFAS from chromium finishing operations (EPA, 2023i) 

3.6.2 Environmental Consequences

This section discusses the potential effects to water quality under the No Action Alternative and the 

Proposed Action Alternative.

3.6.2.1 No Action Alternative

Under the No Action Alternative, no new effects would occur to water quality from the semiconductor 

manufacturer modernizing its equipment and facilities with financial assistance received from the CHIPS 

Incentives Program. The No Action Alternative assumes that the proposed projects would not be 

implemented, and therefore no changes in the amount or pollutant load of facility wastewater would occur. 

Since laws, regulations, and permitting requirements would remain in place, no new effects would occur to 

water quality.

3.6.2.2 Proposed Action Alternative

A proposed project involving equipment and facility modernization and internal expansion within an 

existing facility footprint with CHIPS financial assistance would have the potential to affect water quality 

through changes in the volume and/or pollutant load of generated wastewater. Wastewater from 

semiconductor fabrication may contain a variety of pollutants including organic compounds, heavy metals, 

nitrogen, and phosphorus. The semiconductor fabrication facility would have the potential to cause a large 

effect on water quality and is thus subject to strict environmental regulations and permitting as discussed 

in Section 3.6.1.1 of this Draft PEA. To satisfy national and local regulations, the facility’s wastewater 

would have to be properly treated prior to discharge. 

Semiconductor manufacturing facilities use a number of management practices to control the toxic 

compounds found in wastewater, including solvent management plans, segregation of wastes, and waste 

disposal alternatives. Segregation of waste allows facilities to treat, dispose, or reclaim wastes in more costeffective manners, by keeping wastewaters containing different pollutants separate prior to treatment and 

segregating certain pollutant-containing wastewaters for disposal. With new and modernized equipment, 

effective effluent segregation could include (IEEE, 2023): 

• Segregating out high concentrated wastes with subsequent disposal (or ideally reuse) to reduce 

contamination and complexity of the wastewater treatment and reclamation. 

• Segregating higher purity streams to allow for recycling those within the process or reusing within the 

facility.
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• Segregating streams with specific contaminants which are of concern for environmental regulatory 

compliance, relatively easy to treat (e.g., N-methyl-pyrrolidone [NMP]), or difficult to treat (e.g., 

TMAH) to achieve a more sustainable and cost-effective wastewater management solution.

Such practices could result in fewer toxic compounds in wastewater, resulting in minor, beneficial effects. 

Heavy metals are among the most harmful water pollutants due to their non-degradable properties. Despite 

the national and international standards stipulated by the World Health Organization (WHO) and the EPA 

that drinking water should not exceed very low maximum concentrations, heavy metals can accumulate in 

the ecosystem and enter the human body through food. Heavy metals present in wastewaters, such as 

cadmium, chromium, arsenic, lead, zinc, copper and mercury are highly toxic for human health even at 

trace levels (Vidu et al., 2020). In concentrations higher than a few μg/L, heavy metals affect the normal 

development and function of organs, poisoning the body and damaging internal organs and tissues by 

various mechanisms such as enzymes denaturation, ion replacement, and protein inactivation.

Removing heavy metals from wastewaters is a challenging process that requires constant attention and 

monitoring. Modernized, onsite equipment has the potential to remove heavy metal ions from wastewater; 

methods could include adsorption treatments (using different adsorbents, i.e., carbon-based, carboncomposites, minerals, magnetic, and biosorbents), membrane treatments (i.e., nanofiltration, 

microfiltration, reverse osmosis, forward osmosis, and electrodialysis), chemical treatments (i.e., chemical 

precipitation, coagulation-flocculation, and flotation), electric treatments (i.e., electrochemical reduction, 

advanced oxidation, and ion exchange), and photocatalysis. 

For example, CMP uses a large amount of water and accounts for approximately 40 percent of water 

consumption in the semiconductor industry (Lee et al., 2022). In addition, CMP generates 30–50 liter (L) 

of waste slurry containing chemicals per 200 mm wafer. After CMP, the wastewater containing various 

chemicals and slurry particles is disposed of after removing the particles through electrodecantation and 

electrocoagulation. CMP wastewater produced during CMP and post-CMP cleaning processes, contain 

abrasive particles and chemicals such as silica, alumina, magnesia, ceria, and zirconia. Chemical agents, 

such as surfactants, buffing agents, complexing (or chelating) agents, and corrosion inhibitors, are also 

present in the wastewater. Onsite industrial treatments via pretreatment systems include precipitation of 

metals or sorption of pollutants onto the precipitated materials. Precipitated materials are gravitationally 

settled, separated and disposed of in landfills. The waste materials that are not removed are discharged into 

municipal sewer systems, and they enter municipal wastewater treatment plants that often use biological 

treatments designed to remove the nutrients (e.g., carbon, nitrogen, and phosphorous), but are also capable 

of removing the nanomaterials.

As part of the due diligence process to receive CHIPS Incentives Program funding, applicants would be 

required to demonstrate compliance with all existing facility permits. Following modernization and/or 

expansion related projects, facilities would still be required to comply with permit limits, although permit 

limits may be revised if the proposed project triggers new source requirements. Permit violations at existing 

direct and indirect discharging facilities were determined by EPA to be rare, isolated exceedances that do 

not represent consistent issues at any specific facility or across the industry (EPA, 2022b). This level of 

compliance would be expected to continue following implementation of the modernization and expansion 

projects. 

EPA found that most pollutants are detected in screening data used for permit development and are observed 

at concentrations that do not pose a threat to cause interference or upset at the POTW or were at 

concentrations lower than local water quality standards (EPA, 2022b). The industry continues to rapidly 

change as new technologies are developed and new chemicals used in the semiconductor manufacturing 

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 EPA has not identified any new industry-wide potential 

parameters of concern for wastewater discharges (EPA, 2022b).
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CPO will review the compliance history of companies during the due diligence phase as described in 

Appendix A to determine if there are ongoing, systemic water quality permitting issues. There is the 

potential for effects to be reduced with the implementation of the Proposed Action if the proposed project 

includes new pollution control equipment and practices to treat wastewater or to prevent pollutants from 

entering wastewater.

Under the Proposed Action, the proposed semiconductor fabrication facility modernization and expansion 

project would cause direct, adverse effects on water quality from the introduction of pollutants associated 

with increased production. Long-term changes in the volume and concentration of wastewater would have 

localized effects for direct dischargers and regional effects for indirect dischargers. Effects to water quality 

would be minor because the facility would still be required to comply with wastewater discharge permit 

limits and conduct routine monitoring to confirm compliance. The modernization of equipment and the 

facility under the Proposed Action would have direct, long-term, localized to regional effects on water 

quality; these effects would be adverse and minor compared to current conditions. If the proposed action 

included new measures to reduce the pollutant load in the wastewater there could potentially be beneficial

and minor effects. 

3.7 HUMAN HEALTH AND SAFETY

This section describes the affected environment and environmental consequences to human health and 

safety of the Proposed Action and the No Action Alternative. 

3.7.1 Affected Environment

A proposed project under the Proposed Action would occur within the existing facility footprint, so the 

affected environment for human health and safety is onsite at the applicant’s facility.

3.7.1.1 Health and Safety Regulatory Frameworks

Numerous federal, state, and local laws and regulations aim to protect human health and safety at 

semiconductor manufacturing facilities. The Occupational Safety and Health Administration (OSHA) 

promulgates health and safety regulations for general industry (29 CFR Part 1910). These regulations 

address a wide range of topics related to workplace safety, including hazard communication, electrical 

safety, machinery and equipment safety, personal protective equipment (PPE), and training requirements. 

Semiconductor fabricators establish safety procedures in accordance with OSHA and typically apply the 

hierarchy of safety hazard controls from the National Institute for Occupational Safety and Health (NIOSH) 

(NIOSH, 2023). The NIOSH hierarchy of controls is shown in Figure 3.7-1 below. 
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Source: NIOSH, 2023

Figure 3.7-1. Hierarchy of Safety Hazard Controls

OSHA standards most relevant to the semiconductor manufacturing sector include:

• Subpart G, Occupational Noise Exposure – 1910.95 establishes guidelines and standards to protect 

workers from excessive noise in the workplace.

• Subpart H, Hazardous Materials – 1910.119 establishes requirements for preventing or minimizing 

the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.

• Subpart H, Hazardous Materials – 1910.124 establishes general requirements for dipping and coating 

operations. The standards cover: dip tank construction and entry; ventilation, air recirculation, exhaust 

hoods; first aid training, treatment, and supplies; required hygiene facilities; dip tank cleaning, 

inspection, and maintenance.

• Subpart I, PPE – 1910.132 establishes general requirements for PPE. The employer is responsible for 

ensuring the proper application, the adequacy, and selection of PPE based on hazard assessment. The 

employer must provide PPE and associated training to employees. 1910.134 establishes specific 

respiratory protection requirements.

• Subpart Z, Toxic and Hazardous Substances –

o 1910.1018 Inorganic arsenic

o 1910.1020 Access to employee exposure and medical records

o 1910.1025 Lead
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During OSHA inspections of semiconductor industry sites between October 2021 and September 2022, 

most citations (violations) were for Hazard Communication, followed closely by Respiratory Program 

(OSHA, 2023). 

EPA promulgates Chemical Accident Prevention Provisions to protect public health and the environment 

(40 CFR Part 68). Facilities holding more than a threshold quantity of a regulated substance in a covered 

process are required to develop and implement a risk management program and submit a risk management 

plan (RMP) to EPA. The RMP must identify the potential effects of a chemical accident, steps the facility 

is taking to prevent an accident, and emergency response procedures. Additional laws and regulations which 

govern the use of hazardous and toxic materials in the U.S. are summarized in Section 3.8.1.1 of this Draft 

PEA.

National Fire Protection Association (NFPA) 318, Standard for the Protection of Semiconductor Fabrication 

Facilities, provides standards to safeguard facilities containing clean rooms from fire and related hazards to 

protect against injury, loss of life, and property damage. It applies to fabrication processes, including 

research and development areas in which hazardous materials are used, stored, and handled and containing 

a clean room, or clean zone, or both (NFPA, 2022).

3.7.1.2 Industry Standards

Semiconductor Equipment and Materials International (SEMI) standard S21 – Safety Guideline for Worker 

Protection describes methods for protection against hazards that workers may encounter as they work on 

or around equipment used for semiconductor manufacturing. SEMI S2 – Environmental, Health and Safety 

Guideline for Semiconductor Manufacturing Equipment, guides the manufacture and installation of tools 

for semiconductor fabrication facilities. S2 addresses environmental, health, and safety practices and 

incorporates several other standards, including equipment installation, gas effluent handling, exhaust 

ventilation, ergonomics, risk assessment, equipment decontamination, fire risk mitigation, and electrical 

design (SEMI, No Date). Additionally, SEMI S12 – Environmental, Health and Safety Guideline for 

Manufacturing Equipment Decontamination addresses decontaminating manufacturing equipment and 

parts that were or may have been exposed to hazardous materials and which are intended for further 

productive use. SEMI S16 – Guide for Semiconductor Manufacturing Equipment Design for Reduction of 

Environmental Impact at End of Life, provides design guides to minimize environmental impacts in 

consideration of end of life of semiconductor manufacturing equipment or its components.

Risk Management Measures (RMMs) practiced in the semiconductor industry are a result of numerous 

SEMI guidelines and collaboration between semiconductor fabricators and suppliers of process tools and 

chemicals. RMMs address chemical assessment, selection and control procedures, hazardous gas 

management systems, segregated exhaust systems, safety interlocks, and spill control/prevention (ISMI, 

2006). Environmental health and safety personnel at semiconductor fabrication facilities establish PPE 

programs and safety protocols through hazard assessments to identify the potential risks in accordance with 

RMMs.

3.7.1.3 Industry Injury and Illness Rates

According to 2021 data from the U.S. Bureau of Labor Statistics (BLS), the injury and illness rate for the 

U.S. semiconductor industry was 0.8 cases per 100 workers per year. This is much lower than the overall 

incidence rate for all U.S. employees, which is 2.9 cases per 100 workers (BLS, 2021). Over the last three 

decades, the injury and illness rate in the semiconductor manufacturing sector has steadily declined, as 

shown in Figure 3.7-2. The decline in injury and illness rates over the last 30 to 40 years are likely the 

result of a combination of increased regulation and regulatory scrutiny, public activism and lawsuits, 

development of stricter industry standards, and advances in semiconductor manufacturing technology, 

equipment safety features, and automation (Hicks, 2023). 
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Notes: 1994-1999 BLS data for NAICS Code 3674; 2003-2021 data for NAICS Code 334413; Data after 2021 were 

not available on the BLS website. 

Source: BLS, 2023

Figure 3.7-2. Incidence Rates of Nonfatal Occupational Injuries and Illnesses

per 100 Workers in the Semiconductor and Related Device Manufacturing Sector

3.7.1.4 Historical Health Risks

Semiconductor manufacturing in the U.S. and abroad has a legacy of causing harmful effects to worker 

health. Exposures to ethylene glycol ethers were identified in the late 1980s as a likely cause of increased 

risk of miscarriages of clean room workers (Hecht, 1992). While glycol ethers are not banned in the U.S., 

they are subject to new use reporting under Toxic Substances Control Act. 

Additionally, across several decades, workers at California semiconductor production companies had been 

subjected to chemical exposures, leading to a series of lawsuits in the 1990s and 2000s on the workrelatedness of employee cancers and their children’s birth defects. In the mid-1980s, International Business 

Machines Corporation (IBM) commissioned a research project that found excess risk for brain tumor 

mortality among its engineers and programmers. A similar study reported that electromagnetic radiation 

exposure increased the risk for brain tumors, especially in design, manufacture, repair, and installation jobs 

(Kim et al., 2014). While these are just some examples of historical health risks, there is a strong pattern of 

past chemical and radiation exposures to workers in the semiconductor industry. 

Many of the root causes of semiconductor manufacturing-associated health risks have been addressed over 

the last thirty years. Stricter storage tank regulations and monitoring requirements by EPA provide 

additional protection to water supplies and human health. Air emission regulations and limits are also 

stricter with rigorous monitoring and reporting. Regulations and reporting under the Toxic Substances 

Control Act (TSCA) and the Emergency Planning and Community Right-to-Know Act (EPCRA) provide 

communities with essential information about hazardous material use in their neighborhoods. The industry 

continues to replace highly mutagenic and toxic materials with less hazardous materials. 
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Clean rooms and equipment now incorporate advanced leak detection methods that rapidly alert personnel 

and shut down equipment. Radiation sources in modern equipment are encapsulated to prevent exposure 

with detection and shutdown mechanisms and several interlocks to prevent unauthorized access. 

Additionally, personal protective equipment has improved in recent decades to provide further worker 

protection (Hicks, 2023). Overall, modern health, safety, and environmental regulations plus improvements 

in semiconductor manufacturing equipment and processes have greatly improved the health and safety 

posture of the industry, as evidenced by the declining incidence rates of nonfatal occupational injuries and 

illnesses of workers shown in Figure 3.8-2.

3.7.1.5 Physical Hazards and Chemical Safety

Human health and safety concerns at semiconductor fabrication facilities involve physical and chemical 

occupational hazards. Physical hazards include ergonomic and auditory stress, slips or falls, electrostatic 

discharge, radiation, and pressurized source exposure (Beattie, 2021). Chemical hazards include the 

potential for direct and indirect exposure to hazardous materials; primarily organic solvents, acids, and 

metals (Kim et al., 2014). 

Fabrication facilities often use engineering controls, such as totally enclosed processes, automation, and 

chemical delivery systems, to create barriers between workers and the process. This separation minimizes 

worker exposure to chemical and physical hazards. In many cases, secondary and even tertiary back-up 

systems ensure the necessary protection will be provided if one control fails. Under normal operating 

conditions, workers are not exposed to chemical or physical hazards due to considerable control measures 

within a state-of-the-art semiconductor fabrication facility (ISMI, 2006). Advances in robotics and 

automation systems are helping eliminate opportunities for human error, which reduces safety incidents 

while fostering productivity. 

In modern fabrication facilities, automated chemical delivery systems typically distribute chemicals from 

a remote location to their point of use. Bulk chemical delivery systems (for commonly used process 

chemicals) minimize handling and eliminate the associated pouring and spill hazards. Processes such as 

etching, doping, and cleaning are carried out under appropriate fume hoods or under local exhaust 

ventilation to prevent dispersion into the air of dusts, fumes, mists, vapors, and gases in concentrations that 

could cause harmful exposure and/or reactivity hazards (ISMI, 2006).

Gas cabinets, specifically designed for use in the semiconductor industry, enclose and exhaust potentially 

hazardous leaks from gas cylinders. Gas cabinets safety features may include steel construction, self-closing 

doors, negative ventilation, automatic fire sprinkler systems, excess flow sensors, gas leak monitoring, and 

automatic shutoff (ISMI, 2006). 

Semiconductor manufacturing also involves several types of process and metrology equipment that 

commonly use more than one type of hazardous energy. By consensus of the suppliers and users of this 

equipment, the industry relies primarily on SEMI S2 and other documents in the SEMI Standards “S” series 

to guide the safe design of equipment. The industry has a strong safety record which demonstrates the 

effectiveness of the hazardous energy control design methodologies selected (SEMI ICRC, 2016).

The hazardous energies in the semiconductor industry include:

• Distributed Electrical (high voltages, high currents)

• Gravitational Energy (suspended, hinged loads)

• Stored Electrical (capacitors, batteries)

• Kinetic Energy (moving robots, linear drives, gears)

• Pressurized Liquids (hydraulic, pumped)

• Thermal / Cryogenic Energy (hot, cold temperatures)

• Compressed Gases (liquefied, pressurized)

• Chemical Energy (heat of reaction, toxicity)
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• Electromagnetic Radiation (X‐Ray, Radio Frequency (RF), Infrared (IR), Ultraviolet (UV), lasers)

• Stored Mechanical Energy (springs, elastic seals)

• Static Magnetic Fields (permanent magnets)

Accidents or exposures to hazardous energies can harm personnel, tools, the facility, and the environment. 

The semiconductor industry is highly automated, and few tasks are performed directly by workers during 

production. Modern equipment that produces hazardous energies encapsulate radiation sources in housings 

with leak detection sensors that can trigger an alarm and shut down equipment (Hicks, 2023). Human 

interaction with equipment that emits hazardous energies occurs mainly during scheduled or unscheduled 

downtime. Equipment must be ‘locked-out’ to prevent unexpected startup or re‐energization when work is 

performed in an area subject to risk of unexpected startup or re‐energization (SEMI ICRC, 2016).

Each clean room worker must follow strict clean room entry and exit procedures (Blackridge, 2023). These 

procedures are designed to protect workers from hazards in the clean room and to prevent particulate 

contamination of interim and final products. The protective suits worn by workers in the semiconductor 

industry are designed to protect the integrity of the semiconductor and its components, and also protect the 

workers from exposure to potentially hazardous materials (Nichols, 2016). PPE required within clean rooms 

includes gloves, safety glasses or goggles, face masks or shields, body coverings such as coveralls or aprons, 

and safety shoes. Certain tasks may require a hardhat, respirator, skin protection, radiation protection, or 

hearing protection devices. Workers who commonly handle hazardous chemicals and materials in a clean 

room environment must be properly trained in chemical handling, hygiene, hazard communication, and 

emergency response procedures pursuant to OSHA regulations (SEMI, 2018). 

Potential hazards associated with semiconductor manufacturing processes are summarized in Table 3.7-1.

Table 3.7-1. Potential Hazards in the Semiconductor Manufacturing Process 

Potential Hazard Hazard Description

Associated Production 

Processes

Machinery and 

Nuisance Dust

Possible employee exposure to machineryrelated hazards and nuisance dust during 

cutting, grinding, lapping, polishing, sanding, 

sorting, testing, and so forth.

• Lithography

• Backlapping and backside 

metallization

• Dicing

Electricity Various hazards associated with the use of 

high-voltage electrical equipment, including 

electric shock, electrocution, fires, explosions, 

and so forth.

• Doping

• Deposition

• Metal deposition

• Metal etching

• Testing and quality control

Lasers Laser hazards associated with the use of high 

energy lasers for annealing (ion implantation), 

marking, or scribing (causes additional 

vaporization hazard).

• Doping

• Dicing

RF Radiation RF is associated with induction heating and 

backside metallization. RF can be used as an 

ionizing and power source.

• Oxidation

• Etching

• Photoresist Stripping

• Doping

• Deposition

• Metal deposition

• Backside metallization
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Potential Hazard Hazard Description

Associated Production 

Processes

IR Radiation IR radiation (thermal energy or extreme heat)

is emitted from molten material or furnaces.

• Oxidation

• Doping

• Deposition

UV Radiation Possible exposure to UV radiation during 

photo exposure.

• Mask alignment and photo 

exposure

X-Ray Radiation Possible employee exposure to X-ray radiation: 

• during diffraction operations.

• when used as a source for photo exposure.

• during ion implantation.

• from e-beam evaporation.

• Mask alignment and photo 

exposure

• Doping

• Metal deposition

Flammable, 

Explosive, 

Pyrophoric Gases 

and Liquids

Possible ignition of flammable, explosive, and 

pyrophoric gases, resulting in fire or explosion. 

Employees may also be exposed to gases 

above permissible limits.

• Oxidation

• Doping

• Deposition

• Lithography

• Alloying and annealing

Toxic, Irritative, 

Corrosive, and 

Reactive Gases 

and Liquids

Possible exposure to toxic, irritative, and 

corrosive gases and liquids. Possible employee 

exposure to fluorinated, chlorinated, and other 

reactive gases used for dry etching.

• Oxidation 

• Soft and hard Bake 

• Doping

• Deposition

• Alloying and annealing

• Passivation

• Etching

Solvents Possible exposure to solvents used during 

cleaning, rinsing, stripping, package labeling, 

or maintenance operations. 

• Cleaning, rinsing or package 

labeling

• Lithography

• Developing

• Photoresist stripping

• Doping

• Metal deposition

• Silylation

• Testing

Acids and Caustic 

Solutions

Possible exposure to:

• acid and caustic solutions during cleaning. 

• caustic solutions and aerosols during 

developing.

• acids used for wet chemical 

etching/stripping.

• Cleaning

• Developing

• Etching

• Photoresist stripping

Photoresist 

Chemicals

Possible exposure to photoresist chemicals. • Lithography
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Potential Hazard Hazard Description

Associated Production 

Processes

Thermal burns Possible thermal burns due to contact with hot 

equipment or exposure to high temperatures.

• Soft and hard bake

• Doping

• Deposition

• Metal deposition

• Alloying and annealing

Reaction-Product 

Residues

Potential chemical exposures to maintenance 

personnel working on reaction chambers, 

pumps, and other associated equipment that 

may contain reaction-product residues. 

Substances such as arsenic, arsine, phosphine, 

etc., may be found in ion implantation 

equipment.

• Etching

• Doping

• Deposition

Metals Possible employee exposure to various metals 

during evaporator cleaning and maintenance 

operations. Possible employee exposure to 

mercury from lamp rupture.

• Metal deposition

• Alloying and annealing

• Backlapping and backside 

metallization

• Mask alignment and photo 

exposure

Noise Possible exposure to noise above permissible 

limits, which could temporarily or permanently 

damage hearing.

A combination of production 

processes can contribute to 

environmental noise levels.

Sources: OSHA, No Date.; UL, 2021

3.7.1.6 Noise

Semiconductor manufacturing facilities typically implement robust hearing conservation programs to 

protect workers in compliance with OSHA Standards. Noise abatement is also a critical component of 

campus design and building layout due to the sensitive nature of the manufacturing process. Facilities 

typically have a large number of concentrated noise sources associated with high volumes of intake and 

circulation air required to maintain cleanrooms and the complex exhaust and pollution-control systems. 

Sources include air units, exhaust fans, cooling towers, boilers, compressed air vents, emergency 

generators, pumps, valves, piping, and delivery traffic. Most facilities produce continuous noise, as they 

usually operate on a 24-hour a day schedule. It is common to locate noise-generating equipment in a central 

utility building or separate area of the campus yard. In addition, cleanroom air systems are often housed on 

a separate floor, protecting workers and vibration-sensitive manufacturing processes. Engineering controls 

to reduce noise may include silencers, enclosures or barriers, air flow straighteners, and reduced fan speeds 

(Gendreau and Wu, 1999). 

3.7.1.7 Chemicals of Concern

As discussed in Section 3.5.1.2 Wastewater Characterization of this Draft PEA, the semiconductor 

industry introduced new process chemistries as technological advances occurred. Certain chemicals in the 

industry are of emergent concern to human health. Notably, PFAS are used in a wide range of modern 

semiconductor production processes like lithography, etching, and cleaning. 

In 2021, the EPA released the PFAS Strategic Roadmap to characterize toxicities, understand exposure 

pathways, and identify new methods to avert and remediate PFAS pollution. Specific persistent, bioaccumulative and toxic (PBT) PFAS will likely be the focus of new regulations in the coming years, based 
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on a body of growing scientific evidence and the EPA’s directives to research, restrict and remediate their 

use (EPA, 2021a). Under the new framework, the EPA expects to allow the use of certain PBT PFAS in 

semiconductor manufacturing if they are used in closed systems with appropriate occupational safeguards 

and when disposal and consumer exposure risks are shown to be low (EPA, 2023j). For more information 

about the use of PFAS in semiconductor fabrication facilities and emerging PFAS standards, see Appendix 

B. 

In addition, there has been an effort in the industry to replace glycol ethers due to reproductive effects 

associated with exposures. Glycol ethers are solvents used in etching circuit patterns on silicon wafers. 

Solvents have included chemicals such as xylene, n-butyl acetate, acetone, and 1,1,1-trichloroethane as a 

substitute for glycol ethers (OSHA, No Date). 

3.7.2 Environmental Consequences 

This section discusses the potential effects to human health and safety under the No Action Alternative and 

the Proposed Action Alternative. 

3.7.2.1 No Action Alternative

The No Action Alternative assumes the proposed project would not be implemented, and therefore current 

health and safety aspects at the semiconductor facility would not change. The facility would continue to 

follow all regulations protecting worker health and safety. Thus, the No Action Alternative would have no 

new effects on health and safety. 

3.7.2.2 Proposed Action Alternative

CPO will evaluate the health and safety practices and safety compliance program of applicants, as described 

in Appendix A. CPO will review proposed equipment purchases and facility re-designs to promote 

installation of state-of-the-art safety features, such as leak detection/sensors, lock-out mechanisms, fireprotection systems, and similar controls to protect worker safety. 

Effects of Construction and Installation

Projects under the Proposed Action would modernize and expand fabrication spaces and equipment within 

the existing facility footprint. These actions could increase production, alter material chemistries used, and 

improve automation. Increased production would likely increase the volume of hazardous materials stored 

and used at these facilities. However, modernized equipment meeting the most recent industry and 

government standards for safety would incorporate engineering controls, physical barriers, and other safety 

features to protect workers from chemical and physical hazards. During construction and equipment 

installation, upgrades to the lighting, ventilation, fire suppression, piping and electrical systems, 

incorporation of automated chemical distribution systems, and new room layouts to enhance workflows 

have the potential to improve safety-related engineering controls. Facility reconfiguration provides 

opportunities to incorporate or enhance worker safety and health protections that could otherwise be 

unpractical. CPO will review applicant construction plans to ensure they include relevant health and safety 

features and follow industry standards. 

Increased vehicle traffic associated with construction workers and deliveries could temporarily increase 

noise along local roads. Installation of new equipment could generate noise during transport and 

positioning. Appendix A describes human health and safety BMPs that could be applied to reduce 

construction noise and promote safety at construction sites. Overall, noise and safety effects during 

construction would be direct, negligible to minor, temporary and localized as those terms are defined under 

Section 3.2.2 of this Draft PEA.
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Effects of Increased Production 

Modernization projects could increase production volumes, increase hazardous chemical use, and require 

additional workforce. These operational changes could result in long-term, increased safety and health risks 

that are negligible to minor because operators, maintenance and service personnel would be trained in the 

task they are intended to perform and follow facility-specific RMMs and RMPs. In addition, health and 

safety training would be required to address new processes and orient new staff in accordance with OSHA 

and SEMI standards. These standards also require worker access to adequate hygiene facilities and require 

updated health and safety plans. Worker protections and processes already in place at semiconductor 

fabrication facilities would continue to minimize illness and injury incidence rates under the Proposed 

Action. Emergency plans and safety procedures developed in accordance with OSHA, EPA, NFPA, and 

industry standards (Appendix A) could lower the potential for hazardous exposures and other safety and 

health risks associated with increased production. In general, adverse effects could be direct, long-term, 

negligible to minor, and localized, depending on the proficiency of the environmental, health, and safety 

program at a facility.

Effects of Equipment Disposal

Removal of existing equipment and utility connections would require purging or decontamination of 

hazardous materials and gases that would require development of task-specific safety plans. As described 

in Appendix A, adhering to industry standards SEMI S12 and S16 – Reduction of Environmental Impact 

at End of Life and Decontamination for decontamination and removal of manufacturing equipment would 

reduce health and safety risks. With proper training, planning, and controls, in accordance with laws, 

regulations, and industry standards, adverse effects to workers and technicians reconfiguring facilities and 

removing equipment during the implementation phase would likely be direct, negligible to minor, 

temporary, and localized. Measures to restrict access to active construction areas, use of lock-out/tag-out, 

and other engineering controls would further protect the workforce from hazards. 

Summary

Overall, modernization of equipment and facilities at semiconductor fabrication facilities under the 

Proposed Action would likely align with the low and falling rate of injuries and illnesses across the 

semiconductor manufacturing sector. The opportunity for fabrication facilities to modernize would be 

beneficial to address any prior safety deficiencies and would increase use of engineering controls, 

automation, lock-out mechanisms, sensors, and other safety features often incorporated into modern 

equipment. The use of these BMPs in the planning, construction, and operations phases to promote safe 

construction sites and install tools and equipment meeting current standards would further promote worker 

health and safety. The Proposed Action would provide direct, beneficial, negligible to minor, long-term, 

and localized effects for worker health and safety. 

3.8 HAZARDOUS AND TOXIC MATERIALS

This section describes the affected environment and consequences of hazardous and toxic materials use in 

semiconductor fabrication under the Proposed Action and the No Action Alternative. 

3.8.1 Affected Environment

The affected environment section discusses the customary hazardous and toxic materials used and the laws 

and regulations that govern their use. Hazardous and toxic materials used for semiconductor fabrication, if 

improperly stored, produced, transported, handled, or disposed of, may affect air quality, water quality, and 

human health and safety; these effects are analyzed separately in Sections 3.5, 3.6, and 3.7, respectively, 

of this Draft PEA. The environmental consequences section discusses the effects of construction, increased 
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semiconductor production, potential chemical substitution, and source reduction methods on hazardous or 

toxic materials.

3.8.1.1 Regulatory Framework

There are several federal laws and regulations applicable to hazardous and toxic materials in the U.S.:

TSCA

TSCA, 15 U.S.C. §2601 et seq., provides the U.S. Environmental Protection Agency (EPA) with authority 

to regulate the production, use, and disposal of chemicals that have the potential to cause harm to human 

health or the environment. TSCA § 8 (b) requires EPA to compile, keep current and publish a list of each 

chemical substance that is manufactured or processed, including imports, in the United States for uses under 

TSCA. This list is known as the “TSCA Inventory”, and it plays a central role in the regulation of most 

industrial chemicals in the United States. Many of the chemical substances used in semiconductor 

manufacturing facilities are listed on the TSCA inventory as reflected in Appendix C. Solvents, 

photoresists, etchants, deposition gases, cleaning agents, and dopants typically contain TSCA-regulated 

substances. 

EPCRA

EPCRA, 42 U.S.C. Chapter 116, authorized by Title III of the Superfund Amendments and Reauthorization 

Act (SARA), to help communities plan for chemical emergencies. It requires facilities to report storage, 

usage, and releases of hazardous substances to federal, state and local government in an effort to improve 

chemical safety and protect public health and the environment. Specific EPCRA requirements for facilities:

• Sections 301 to 303. Emergency Planning (40 CFR 355 Subpart B): Helps communities prepare for 

potential emergencies. Local and Tribal Emergency Planning Committees (LEPCs and TEPCs) are 

required to prepare and review chemical emergency response plans. State and Tribal Emergency 

Response Commissions (SERCs and TERCs) are required to oversee and coordinate local planning 

efforts. Facilities that maintain threshold quantities of “extremely hazardous substances” (EHS) (40 

CFR 355 Appendix A) onsite must cooperate in emergency plan preparation. 

• Section 304. Emergency Release Notification (40 CFR 355 Subpart C): Facilities must immediately 

report releases of a “reportable quantity” (RQ) of an EHS or Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA) “hazardous substance”. RQs for EHSs are 

listed in Appendices A and B of 40 CFR Part 355. RQs for CERCLA hazardous substances are listed 

in Table 302.4 of 40 CFR 302.4. In addition to initial notifications, notifying facilities must provide a 

follow-up report to update the original notification to provide additional information on response 

actions taken, known or anticipated health risks, and, if appropriate, advice regarding any medical 

care needed by exposure victims (EPA, 2023k). SERCs, TERCs, LEPCs, and TEPCs are required to 

make these reports available to the public.

• Sections 311 and 312. Hazardous Chemical Inventory Reporting (40 CFR Part 370): Requires 

facilities to submit a safety data sheet (SDS) for each OSHA “hazardous chemical” that meets or 

exceeds reporting thresholds to the facility’s SERC or TERC, LEPC or TEPC, and local fire 

department. Section 312 also requires facilities covered by Section 311 to submit an emergency and 

hazardous chemical inventory form annually.

• Section 313. TRI (40 CFR Part 372): Establishes a mandatory federal reporting program that tracks 

the release and waste management of “toxic chemicals” that may pose a threat to human health and 

the environment. Generally, chemical substances classified as TRI chemicals cause cancer or other 

chronic human health effects, substantial adverse acute human health effects, and/or substantial 

adverse environmental effects (EPA, 2023k). There are currently 770 individually listed chemicals 
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and 33 chemical categories covered by the TRI Program (EPA, 2023l). Section 3.9 of this Draft PEA 

discusses the transfer and release of TRI chemicals from the semiconductor industry in more detail. 

3.8.1.2 Hazardous and Toxic Material Use in Semiconductor Fabrication

Semiconductor fabrication facilities store, produce, and use hazardous materials. Hazardous process 

chemicals commonly used in semiconductor manufacturing are categorized in Table 3.8-1. Modern 

semiconductor facilities use totally enclosed processes, automated chemical delivery, gas management 

systems, segregated exhaust systems, safety interlocks, centralized chemical storage, and spill 

control/prevention measures. Process and engineering controls help prevent accidental releases (ISMI, 

2006). 

The semiconductor industry actively seeks to research and develop replacement chemicals that are less 

toxic to the environment (EPA, 2022a). Use of more environmentally friendly or biodegradable chemicals 

can reduce the potential safety and environmental hazards onsite. For example, traditional solvents contain 

N-methyl-pyrrolidinone (NMP), which is known to cause harm to reproductive systems. Therefore, some 

manufacturers have begun to replace traditional solvents with NMP-free varieties (UMC, 2021). In 

addition, the industry is under pressure to avoid or minimize use of certain PFAS substances, and leading 

firms are making efforts to find replacements to reduce the overall environmental and health hazards of 

semiconductor products (TSMC, 2022; Intel, 2023a; Samsung, 2023a). See Appendix B for more detailed 

information on PFAS use in semiconductor fabrication facilities. 

This section describes the hazardous and toxic materials used in semiconductor fabrication facilities 

including process steps such as photolithography, wet etching, dry etching, implant and diffusion, and 

cleaning (Bolmen, 1997). 

• The photolithography process uses the most chemicals during fabrication. Photoresists are the main 

set of chemicals used and consist of solvents, additives, polymers, and sensitizers. Chemical mixtures 

containing PFAS are used in the lithography and etching processes.

• Wet etching and cleaning processes use strong oxidizers, including hydrogen peroxide, and acids, 

such as HF. According to a study from the Semiconductor Industry Association, HF accounts for over 

40 percent of the total hazardous materials produced from this industry (Shen et al., 2018).

• Dry etching uses gases which can be highly toxic and highly reactive. When exposed to oxygen, 

highly reactive materials can cause physical hazards such as explosions which can also generate and 

release toxic materials. 

• During the implantation and diffusion process, dopant materials are added to the wafer which may 

create off-gasses during the process. 

• Chemical mechanical planarization uses chemical slurries that typically contain particles composed of 

alumina, silica, and ceria which are suspended in an acidic or basic solution (3M, 2011). Chemical 

slurries can be corrosive, reactive, and/or toxic based on composition. 

• Wafer cleaning involves strong acids and oxidizer mixtures to clean organic materials from the wafer 

surface. 

Raw materials used in manufacturing are discussed in Section 2.2.3 of this Draft PEA. Hazardous raw 

materials include silicon (flammable); gallium arsenide and lead (toxic); phosphorous (spontaneously 

combustible); and spin-on glass (flammable and combustible). 

Table 3.8-1 summarizes frequently used hazardous process chemicals according to their hazard class.
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Table 3.8-1. Hazardous Process Chemicals Used in Semiconductor Manufacturing

Chemical Category Use(s) Process Chemical Hazard Class

Aqueous solutions

(Commonly acids and 

bases)

To wet-etch or clean 

the surface of the 

wafer; as part of the 

photolithography 

process

Hydrochloric acid, HF, 

sulfuric acid, nitric 

acid, ammonium 

hydroxide, potassium 

hydroxide

8 Corrosive Material

Ammonium fluoride 6.1 Poisonous Materials

Hydrogen peroxide 5.1 Oxidizer

Specialty gases As precursors to deliver 

a substance such as 

arsenic or tungsten onto 

the wafer or into the 

silicon lattice (used in 

small quantities); to

dry-etch a pattern onto 

the surface of the wafer

Silane 2.1 Flammable Gas

Ammonia, nitrogen 

trifluoride, sulfur 

hexafluoride

2.2 Non-Flammable 

Compressed Gas

Ammonia, phosphine, 

tungsten hexafluoride, 

arsine, carbon 

monoxide, fluorine, 

chlorine, diborane

2.3 Poisonous Gas

Organic compounds

(Commonly solvents)

As constituents in 

specialty chemicals; to 

clean the wafer; as part 

of the photolithography 

process

Isopropanol, xylene, 

propylene glycol 

ethers, acetone

3 Flammable and 

Combustible Liquid

Metallic compounds Applied to the wafer in 

specific locations to 

create transistors; to 

plate wafers to provide 

electrical connections

Copper sulfate 9 Miscellaneous 

Hazardous Material

Sources: ISMI, 2006; 49 CFR Part 172; EPA, 2022a

3.8.2 Environmental Consequences 

This section discusses the potential effects of hazardous and toxic materials used in semiconductor 

fabrication facilities under the No Action Alternative and the Proposed Action Alternative.

3.8.2.1 No Action Alternative

Under the No Action Alternative, the semiconductor manufacturer would not modernize its facility, 

equipment and processes with CHIPS financial assistance. The No Action Alternative assumes that the 

proposed projects would not be implemented, and the rate of hazardous and toxic material use and their 

effects would not change. The No Action Alternative would have no new effects on hazardous material use.

3.8.2.2 Proposed Action Alternative

Effects of Facility-Specific Reduction and Substitution

A facility modernization and internal expansion project under the Proposed Action may affect the types and 

amounts of hazardous or toxic materials used. Recent sustainability reports from semiconductor 

manufacturers emphasize goals to improve source reduction and the reuse of hazardous materials (TSMC, 

2023; UMC, 2021). Modernization projects that enable tool or process innovation could allow for enhanced 
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reduction, reuse, and recycling of hazardous or toxic substances as compared to current conditions. These 

projects could result in direct, localized, long-term, and beneficial effects. In addition, process innovation 

could lead to procurement of materials that are safer and more sustainable (Samsung, 2023b). According to 

EPA’s “TRI Toxics Tracker”, process and equipment modifications were the most common category of 

source reduction activities in semiconductor and related device manufacturing from 2013-2022 (EPA, 

2023m).

Effects of Construction

Construction activities to modernize or internally expand operations would likely require the temporary 

onsite storage and use of hazardous materials, such as diesel fuel, welding gases, paint, adhesives, thinners, 

and solvents, all of which could increase the risk of accidental releases. However, accidental leaks and 

discharges from equipment, or through material handling and transfers, would be reduced through 

adherence to project-specific construction environmental, health, and safety plans. These plans would 

require onsite spill kits, spill reporting, and spill monitoring avoid, detect, and clean up spills. In addition, 

facilities undergoing modernization would likely have established environmental, health, and safety 

personnel and plans in place for hazardous material monitoring, safe storage, and spill mitigation. Any spills 

of hazardous material would be immediately contained and wastes would be disposed of in accordance with 

federal, state, and local regulations. An accidental spill could result in a temporary increase in the amount 

of hazardous waste generated at the facility site; therefore, if a spill were to occur, adverse effects could be 

direct, short-term, minor, and localized. 

Effects of Increased Production

Projects that increase production under the Proposed Action would likely increase the quantity of hazardous 

and toxic materials used. Some of these materials currently do not have less-toxic replacements, such as 

HF, which is a critical process chemical. The increased demand for hazardous materials by the 

semiconductor fabrication industry could also increase hazardous material production at supplier facilities. 

The volume of materials shipped to fabricator facilities would likely increase, causing indirect and regional

effects due to transport. Adverse effects would be minimized through the proper handling, storage, and use 

of hazardous and toxic materials in compliance with local, state and federal regulations. The increase in 

hazardous material use and storage at a facility could result in greater potential for environmental releases. 

However, automated chemical delivery systems and other engineering controls would lower the risk of 

accidental releases, as discussed in Section 3.7 of this Draft PEA.

Under the Proposed Action, semiconductor facility modernization and expansion projects could cause 

direct, adverse effects due to increases in the quantities of hazardous and toxic material associated with 

increased production. Effects could be long term, because the effects would last for several months or 

longer; localized to regional, because the effects have the potential to extend from the project site to the 

surrounding community; and negligible to minor due to active monitoring of hazardous substances of 

concern, reduction or substitution with less hazardous materials, and use of engineering controls such as 

automated chemical delivery systems. However, for projects included under the Proposed Action, some 

adverse effects could be offset through process and technology improvements which reduce hazardous 

and toxic materials. In addition, CPO will review the environmental compliance history of companies as 

described in Appendix A. 

3.9 HAZARDOUS WASTE AND SOLID WASTE MANAGEMENT

This section describes the affected environment and environmental consequences for hazardous and solid 

waste management under the Proposed Action and the No Action Alternative.
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3.9.1 Affected Environment

Semiconductor fabrication facilities generate both hazardous and nonhazardous solid waste that require 

proper management under the Resource Conservation and Recovery Act (RCRA). “Solid waste” is defined 

as any garbage or refuse; sludge from a wastewater treatment plant, water supply treatment plant, or air 

pollution control facility; and other discarded material resulting from industrial, commercial, mining, and 

agricultural operations, or from community activities (EPA, 2023n; 40 CFR 261.2). Solid waste 

encompasses more than physically solid materials, and can also be in liquid, semi-solid, and contained gas 

form. “Hazardous waste” is a subset of solid waste that is classified based on characteristics such as 

ignitability, corrosivity, reactivity, and toxicity that pose a substantial threat to human health, the 

environment, or both (EPA, 2023n; 40 CFR 261.3). 

3.9.1.1 Regulatory Framework 

The federal laws and regulations which govern solid and hazardous waste management in the U.S. are:

• RCRA, as amended (42 U.S.C. 6901, et seq.)

o Subpart B establishes criteria for the identification of hazardous waste and standards for 

hazardous waste generators. Generators are classified as very small quantity generators, Small 

Quantity Generators (SQGs), or Large Quantity Generators (LQGs) based on how much waste 

they generate each month (40 CFR 262). Permitted facilities are identified by their EPA ID 

number and subject to onsite accumulation quantity, time limits, and management requirements. 

There are requirements for personnel training, emergency planning, container emissions, land 

disposal restrictions, closure, waste minimization, packaging and labeling, tracking, reporting, 

and recordkeeping (EPA, 2023o).

o RCRA Subtitle C, establishes a system for controlling hazardous waste from the time it is 

generated until its ultimate disposal, i.e., “cradle to grave”. 

o RCRA Subtitle D (40 CFR 257), encourages states to develop waste management plans, sets 

criteria for solid waste disposal facilities, and prohibits the open dumping of solid waste. 

o State and local programs, authorized under RCRA, may potentially have more stringent 

requirements for storage, treatment, transport, and disposal of solid waste.

• Section 6607 of the Pollution Prevention Act of 1990 (PPA) requires data on source reduction 

activities and waste management via TRI reporting. 

• Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known 

as the Superfund law, addresses the cleanup of hazardous waste sites and chemical spills that pose a 

threat to public health and the environment. The law empowers EPA to remediate contaminated sites 

and holds responsible parties accountable for cleanup costs.

3.9.1.2 Historic Site Contamination

The semiconductor industry has a history of site contamination. For instance, after a 1979 spill of 4,100 

gallons of 1,1,1-trichloroethane (TCA) at IBM’s Endicott facility in New York, groundwater testing 

revealed extensive contamination from previous releases, including carcinogenic trichloroethylene (TCE) 

and tetrachloroethylene (PCE). The toxic plume contaminated soil and groundwater onsite and caused soil 

vapor intrusion in structures offsite. Adverse health impacts included cancer and birth defects (Forand et 

al., 2012). TCE was heavily used in the production of semiconductors and is the main toxin in 23 Santa 

Clara County Superfund sites (Nieve, 2018). TCE has been phased out due to health and environmental 

concerns. 
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3.9.1.3 Waste Management

Solid waste generated by semiconductor fabrication facilities can be categorized as either hazardous or 

nonhazardous waste. In modern facilities, solid nonhazardous and hazardous waste is minimized at the 

source, then segregated, re-used, recycled, or disposed of (ISMI, 2021). Nonhazardous waste can include 

plastic waste, metal waste, kitchen waste and general office waste (Intel, 2019). Hazardous waste can 

include acids, solvents, copper sulfate, containers, and others (UMC, 2021). Filters from hoods and local 

exhaust ventilation systems, sludge from scrubbers or wastewater treatment, and E-waste from 

semiconductor fabrication (electronic components such as defective chips or circuits) could also be sources 

of hazardous waste.

EPA’s National Biennial RCRA Hazardous Waste Report tracks the generation, management, and disposal 

of hazardous waste by facilities with reporting requirements. Semiconductor and Related Device 

Manufacturing that met the LQG threshold, under NAICS code 334413, reported disposal of approximately 

116,000 tons of hazardous waste in 2021 (EPA, 2021b). This accounted for 0.32 percent of hazardous waste 

generated in the U.S. in 2021 (EPA, 2021c). 

Progressive Waste Management

Solid waste generated from semiconductor fabrication and related facility operations can be managed 

through reuse, recycling, recovery, storage, treatment, or disposal. Generally, facility solid waste is 

transported offsite, where it is managed by a series of service providers that includes waste transporters, 

waste handlers, and waste treatment, storage, and disposal facilities (Jones, 2021). However, liquid waste 

requires treatment to remove solids prior to disposal (Veolia, 2023). Solvent and metal collection systems 

are used to segregate untreated liquids. Many liquid wastes can be neutralized, recycled, or reclaimed. When 

treatment is not possible (e.g., some solvents), spent chemicals are collected and shipped to vendors for 

purification and reuse or to permitted treatment and disposal facilities (ISMI, 2021). Semiconductor 

manufacturing-related waste is also discussed in Section 2.2.4 Manufacturing Waste Streams of this 

Draft PEA. 

Many semiconductor companies have circular economy initiatives that aim to increase recycling and 

decrease generation of hazardous waste (Intel, 2021; Intel, 2023a; Nikon, 2023; Samsung, 2020; UMC, 

2021). For example, Intel reported recycling 85 percent of hazardous waste generated in 2022. Hazardous 

waste was 42 percent of their total waste generated; recycling increased by 15 percent and generation 

decreased by 13 percent from 2021 (Intel, 2023a). 

Modernization projects that enable equipment or process innovation could allow waste recycling and reuse 

to replace or minimize the need for incineration or landfill disposals associated with current manufacturing 

processes. For example, the Samsung fabrication facility in Austin, Texas, earned a Gold-level Zero Waste 

to Landfill validation from Underwriters Laboratory (UL), a global safety agency, by applying new 

technology and shifting waste streams (Samsung, 2020). Sustainability improvements through the

modernization of equipment and facilities could eliminate or reduce certain solid waste streams through 

new and improved technology that allows source reduction, reuse, recovery, and closed-loop recycling. 

Most major semiconductor fabrication companies have set aggressive goals to divert most of their 

hazardous and solid waste from landfills, benefiting both their profit margins and the environment. 

Solid waste can also include obsolete, old, or unusable semiconductor manufacturing tools that could be 

reused, recycled, or landfilled. Tools could be reused if they are refurbished and sold. For example, Nikon 

has been buying and refurbishing old lithography equipment for close to 20 years. Nikon has been able to 

resell 449 systems, reducing landfill waste by 4,100 tons (Nikon, 2023). Tools could be disassembled to 

sell or recycle parts. According to Intel’s 22-23 Corporate Sustainability report, more than 1,000 tools and 

755,000 parts were harvested for reuse (Intel, 2023a). Examples of equipment used in the semiconductor 

industry that may need to be disposed and could be recycled include (Singh et al., 2023):
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• photolithography tools; 

• etch and clean systems;

• deposition and implantation machines;

• diffusion machines for thermal treatments;

• process control equipment; 

• wafer handling tools; and 

• planarization tools.

Many semiconductor fabricators have invested in new technologies to reuse and recover materials, such as 

metals and solvents, from their processes (Shen et al., 2018). Table 3.9-1 summarizes semiconductor 

manufacturing waste streams with potential for progressive management methods. 

Table 3.9-1. Traditional and Progressive Waste Management Methods

of Major Semiconductor Manufacturing Waste Streams

Manufacturing Waste 

Stream Traditional Disposal Methods Progressive Management Methods

Ammonium sulfate Wastewater treatment Fertilizer manufacturing 

Calcium fluoride Landfill; cement kiln recycle Cement product; cement kiln recycle

Lithography-related solvents Fuel blend Cyclohexanone recovery; paint 

thinners 

Metal plating waste Landfill; wastewater treatment Metal recovery 

Specialty base cleaners Incineration Water recovery; organic high BTU 

fuel 

Spent sulfuric acid Wastewater treatment; stabilize 

and landfill 

Recovery offsite 

Source: Intel, 2019 

Releases of TRI-Listed Chemicals that include Chemical Waste

TRI reports are a means to quantify the amount of certain chemicals that move from a facility to offsite 

locations as chemical waste. Under EPA’s TRI program, facilities meeting certain employee, industry sector 

defined by NAICS codes, and chemical threshold criteria must annually report under EPCRA §313. 

Semiconductor manufacturing facilities covered under NAICS Code 334413, Semiconductor and Related 

Device Manufacturing, are required to report if the facility has 10 or more full time employees, and it 

manufactures, processes, or otherwise uses more than a threshold amount of a TRI-listed chemical. 

Industrial facilities report data about how they are managing chemical waste through:

• Environmental releases (into the air, water, and land)

• Recycling

• Energy recovery 

• Treatment

• Disposal 

Additionally, facilities report to EPA how they are reducing the amount of chemical waste that enters the 

environment and/or how they are preventing waste from being created in the first place. 

The term “release” is defined broadly. Onsite releases to the environment include spilling, leaking, 

pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing. 

“Release” also includes transfer of TRI-listed chemicals to offsite facilities for the purposes of recycling, 
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energy recovery, treatment, or disposal (EPA, 2023p). Except for offsite transfers for disposal, these 

amounts do not necessarily represent entry of the chemical into the environment. 

Figure 3.9-1 shows the waste managed by method and year for NAICS Code 334413. Under this sector, 

facilities largely treat their waste on- or offsite rather than dispose or recycle it. In 2022, approximately 70 

percent of all managed TRI wastes were treated (EPA, 2023m). In 2022, more waste was managed through 

recycling and energy recovery than in 2020. 

Source: EPA, 2023m

Note: TRI data under the NAICS code 334413 is not limited to semiconductor fabrication facilities

Figure 3.9-1. Waste Managed by Method and Year in the

Semiconductor and Related Device Manufacturing Sector

Figures 3.9-2 and 3.9-3 show the primary chemicals from semiconductor fabrication facilities that were 

transferred and released, respectively, based on TRI reports from 2022. TRI reports were filtered to include 

semiconductor fabrication facilities that fall under the Semiconductor and Related Device Manufacturing 

Sector (NAICS Code 334413). Facilities whose industrial activity could not be confirmed were filtered out. 

The 65 U.S. semiconductor fabrication facilities that were analyzed transferred approximately 18 million 

pounds (lb.) of TRI chemicals to offsite disposal, storage, or recovery facilities. These fabrication facilities 

released approximately 2.5 million lb. of TRI chemicals to the environment (EPA, 2022c).
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Source: EPA, 2022c 

Figure 3.9-2. TRI Chemicals Transferred by Semiconductor

Fabrication Facilities in 2022 by Weight (lb.)
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Source: EPA, 2022c 

Figure 3.9-3. TRI Chemicals Released by Semiconductor

Fabrication Facilities in 2022 by Weight (lb.)

EPA's Risk-Screening Environmental Indicators (RSEI), a screening-level tool that compiles TRI data along 

with other information, provides relative comparisons of potential health-related impacts from reported 

toxic chemical waste management activities. RSEI Hazard, also called toxicity-weighted pounds, is a 

descriptor of relative potential harm to human health and consists of the pounds of a chemical released to 

the environment or transferred off site, multiplied by the chemical's toxicity weight. The main types of 

chemicals with high RSEI Hazards values that were transferred or released by semiconductor fabrication 

facilities in 2022 include: heavy metals and heavy metal compounds, chlorine, sulfuric acid (acid aerosols), 

and hydrogen fluoride (EPA, 2022c; EPA, 2023m). 

3.9.2 Environmental Consequences 

This section discusses the potential effects of hazardous and solid waste management under the No Action 

Alternative and the Proposed Action Alternative.

3.9.2.1 No Action Alternative

The No Action Alternative assumes that the proposed modernization project would not occur. Increased 

hazardous and nonhazardous waste generation, associated with the Proposed Action below, would not 

occur. Accordingly, the No Action Alternative would have no new effects on the generation of hazardous 

wastes.
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3.9.2.2 Proposed Action Alternative

A proposed project involving internal expansion and facility modernization at an existing semiconductor 

fabrication facility has the potential to affect the amount and type of hazardous and nonhazardous solid 

waste generated. This could also affect human health and the environment. 

Effects of Construction and Installation

A modernization and expansion project may require construction within the existing facility footprint to 

build more cleanroom space or install supporting infrastructure. A temporary increase in nonhazardous solid 

waste generation could occur due to construction, renovation, and demolition. Nonhazardous waste could 

include cardboard, plastic, aluminum, and other construction material. Adverse effects to solid waste 

management from the construction of the Proposed Action project would be direct, short-term, minor, and 

localized in extent. Adverse effects could be reduced by separating construction waste and instituting a 

comprehensive recycling program.

Construction activities could require the onsite use and temporary storage of hazardous materials, which 

could increase the risk of an accidental spill at the facility, resulting in additional waste generation. 

However, BMPs as described in Appendix A could be implemented to reduce the likelihood of spills. Any 

accidental spills would result in a temporary increase in the amount of hazardous waste generated at the 

facility site; therefore, if a spill were to occur, adverse effects would be direct, temporary, minor to 

negligible, and localized.

Effects of Equipment Disposal

Facility modernization under the Proposed Action could include replacement of equipment that is obsolete, 

less capable, and less efficient to operate and maintain. Obsolete, old, or unusable semiconductor 

manufacturing tools could be reused, recycled, or landfilled. Tools could be reused if they are refurbished 

and sold. Tools also could be disassembled to sell or recycle parts. In some cases, tools or parts thereof may 

need to be landfilled. To satisfy the federal, state, and local regulations, decommissioned tools may need to 

be properly decontaminated. If decontamination and end-of-life disposal is required, facilities should 

uphold industry standards and safety guidelines, as described in Appendix A. Tools and parts discarded 

under the Proposed Action may meet the definition of RCRA “hazardous waste” and require treatment as 

such. 

SEMI, an industry association for semiconductor manufacturers, publishes standards for decontamination, 

recycling and reuse of manufacturing equipment. SEMI S12 and S16 can provide guidance on how to best 

reduce the environmental effects associated with equipment disposal (SEMI, 2023). If decommissioned 

equipment is landfilled as nonhazardous or hazardous waste, adverse effects are expected to be direct, shortterm, minor, and localized to regional in extent. 

Effects of Increased Production 

A proposed project involving internal expansion and facility modernization at an existing semiconductor 

fabrication facility that increases production will likely generate more hazardous and nonhazardous waste. 

Increased hazardous waste production may cause a Small Quantity Generator (SQG) to be reclassified as a 

LQG if the facility exceeds state or federal quantity limits. LQGs have more rigorous standards for waste 

storage, handling, reporting, and contingency planning. It is likely that personnel at SQG facilities would 

be experienced with many aspects of RCRA compliance, allowing them to efficiently build on existing 

requirements to meet stricter LQG standards. 

The facility may require more space for waste storage and adjusted disposal timelines. Since most 

fabrication facilities rely on waste management services, waste managers should ensure their local 

providers can meet their changing needs. A facility may need to ship waste further if it exceeds local waste 
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management capacity. As stated in Section 3.9.1 above, the LQGs in the Semiconductor and Related Device 

Manufacturing sector generated approximately 116,000 tons of hazardous waste in 2021 (EPA, 2021b). 

This accounted for 0.32 percent of hazardous waste generated in the U.S. in 2021 (EPA, 2021c). U.S. 

semiconductor fabrication facilities would remain a small percentage of the total hazardous waste produced 

annually in the U.S. even if a large number of them were to increase the amount of waste they generate. In 

addition, the Semiconductor and Related Device Manufacturing sector treats approximately 70 percent of 

managed TRI wastes, reducing the need for disposal (EPA, 2023m). It is expected that the additional 

hazardous wastes generated by a project would connect to existing waste streams and require similar 

management already in place at the facility.

Under the Proposed Action, semiconductor fabrication facility modernization and expansion projects are 

expected to cause minor increases in hazardous and solid waste volumes from associated construction, 

equipment disposal, and production if increases in production were to occur. However, modernization could 

include waste treatment technology improvements that could potentially reduce the amounts of hazardous 

and solid waste generated long-term to offset increases in production. CPO will evaluate each applicant’s 

waste management compliance history as described in Appendix A and adopt BMPs, where applicable, 

that would reduce waste generation. 

Overall, the effects of the Proposed Action on hazardous and solid waste management could be direct and 

indirect, short to long-term, and localized to regional in extent; these effects would be adverse and 

negligible to minor compared to current conditions, but they could potentially be beneficial and minor if 

new measures were introduced to reduce, reuse, and recover materials, thereby diverting waste from 

landfills. 

3.10 UTILITIES

This section describes the affected environment and environmental consequences of utilities used by 

semiconductor fabrication facilities, including electricity, natural gas, and water. 

3.10.1 Affected Environment

Semiconductor manufacturing processes consume substantial amounts of energy and water as discussed in 

Section 2.2.3 of this Draft PEA. Semiconductor manufacturers also are pursuing practices and projects to 

make their operations more sustainable, including reducing energy and water use (TSMC, 2023; UMC, 

2021; Samsung, 2023a; Global Foundries, 2023). 

E

3.10.1.1 Energy Use 

nergy consumption from semiconductor production is primarily for the operation of fabrication tools, air 

conditioning systems for cleanrooms, and other air handling equipment such as compressors, exhaust fans, 

and chillers. The high ventilation rates needed to achieve the air purification required in cleanrooms can be 

30 to 50 times more energy intensive than air handling systems in an average commercial building. The air 

conditioning systems for cleanrooms can consume about 30 to 65 percent of total energy used in a 

semiconductor fabrication facility (Yin et. al, 2020). Maintaining an ultra-clean environment in a cleanroom 

requires temperature and humidity controls that can also be energy intensive. Lithography, etching, ion 

implantation, and deposition tools have high power requirements and may be run continuously with little 

idle time. 

Electricity is typically sourced from a public utility; however, it can also be supplemented from onsite 

renewable sources such as wind or solar. Public utilities across the U.S. often supply electrical energy from 

a mixture of conventional and green energy sources, including but not limited to nuclear; fossil fuels such 

as natural gas or coal; solar array farms; hydroelectric; geothermal; wind; and biomass (PAPUC, No Date). 

Renewable energy can be supplied through the purchase of renewable energy certificates (RECs), power 

purchase agreements (PPA), and participation in green power programs. 
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The semiconductor manufacturing industry is increasingly sourcing energy from renewable sources 

(TechHQ, 2023). In 2022, one semiconductor fabrication facility in the U.S. achieved 100 percent 

renewable electricity through the use of solar hot and cooling water systems, geothermal energy, micro 

wind turbine systems, and solar parking lot canopies, among other technologies. Off-site renewable energy 

can also be supplied from solar, wind, hydroelectric, and geothermal sources for electricity through utility 

programs and RECs (Intel, 2023b). By investing in technology and modernization of semiconductor 

equipment, more than 2,000 energy conservation projects were completed in the last decade that amounted 

to a savings of 4.5 billion kilowatt-hours (kWh), which is equivalent to the electricity needed to power 

400,000 homes for one year. At another facility, installation of Light Emitting Diode (LED) fixtures in 

cleanrooms resulted in 80 to 95 percent savings in electricity operating costs (Intel, 2020). Chiller 

technology for cooling water can be converted from fixed pumps to new variable flow pump systems which 

can reduce energy use on average by 20 percent. Integrating sensors into equipment and conditioned spaces 

can provide real-time data to enable further optimization of energy use and thus, improve energy efficiency 

(Intel, 2020).

Natural gas also is used by semiconductor fabrication facilities to heat buildings and generate steam for 

humidity and is sourced by the public power grid (NXP, 2023; Global Foundries, 2023). Natural gas use 

can be reduced through waste heat recovery systems and adjusting air temperature and flow rates in outdoor 

air handling units (Samsung, 2023a).

Semiconductor manufacturing relies on the use of clean, dry air produced by energy-consuming dryer 

systems and compressors. Typically, compressing air results in a loss of over 80 percent of the energy as 

heat. The use of a centralized heat recovery system with the use of variable frequency compressors has the 

potential to improve energy performance by 20 percent (a variable frequency compressor can save energy 

compared to a fixed speed compressor). It is possible to source heat from equipment for other processes 

requiring heat (also known as heat recovery). Chiller condenser water can supply heat for incoming public 

utility water, reducing the load on cooling towers. Chillers can heat cleanroom air reducing fossil fuel use 

in boilers by over 30 percent. New higher temperature heat pumps can also replace old boiler systems (U.S.

Chamber of Commerce Foundation, No Date).

3.10.1.2 Water Use and Wastewater Generation

Water within a semiconductor manufacturing facility is used for processing, cooling, abatement, Ultra-pure 

Water (UPW), and non-industrial uses. Manufacturing process equipment uses the most water 

(approximately 48 percent for a typical semiconductor fabrication facility). Cooling systems to manage a 

facility’s heat load account for approximately 20 percent of overall water use. Evaporation from cooling 

towers causes the single largest loss of water, resulting in the loss of up to billions of gallons of water per 

year per manufacturing site. 

Water can be supplied to semiconductor fabrication facilities from local groundwater; reclaimed water; 

municipal water; surface water sources such as rivers, condensation, and rainwater; and/or third-party 

suppliers (Wang et al., 2023). Typical water conveyance, purification, treatment, and reclamation systems 

present within a modern semiconductor campus include (IEEE, 2023): 

• Raw Water Systems: Potable, Non-Potable Industrial Water, Fire Protection Water, Irrigation Water 

• Mechanical Systems: Process Heating and Cooling, Critical Process Cooling, Heating, Ventilation, 

and Air Conditioning including Cooling Towers responsible for water evaporation, Humidification 

and dehumidification within make-up air handlers 

• Purified Water: Softened Water, Reverse Osmosis Permeate, UPW, Critical UPW (i.e., specialized 

point-of-use treatment), Hot UPW, Functionalized UPW 
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• Wastewater Treatment and Waste Collection Systems: Facility-specific systems for treating and 

pre-treating wastewater flows to neutralize and/or remove hazardous substances (acids, metals, 

inhibitors, oxidizers, bases, organics, solvents, corrosives, specialty chemicals, etc.)

• Reclaim Systems: Depending on the configuration and complexity of the site there may be multiple 

reclaim systems of varying complexity, reclaiming up to 100 percent of the recoverable water. 

Based on a survey of 28 semiconductor facilities, most of the water (83 percent) delivered to semiconductor 

fabrication facilities comes from either surface water sources or municipal water systems that treat water to 

meet drinking water standards (Wang et.al., 2023). The Safe Drinking Water Act protects public health by 

regulating the nation’s public drinking water supply. This act authorizes the EPA to set national healthbased standards for drinking water to protect against both naturally occurring and man-made contaminants 

that may be found in drinking water (EPA, 2023q). However, UPW (used for wafer production, wet etching, 

solvent processing and planarization (MKS, 2023) requires a much higher state of purification (thousands 

of times purer than drinking water) that can only be obtained through energy-intensive chemical treatments 

(IEEE, 2023). It takes roughly 1,400 to 1,600 gallons of municipal water to make 1,000 gallons of UPW, 

with typical semiconductor fabrication facilities using up to 5 million gallons of UPW daily (Govindan, 

2022). 

Recycling of wastewater and process water is becoming more commonplace at semiconductor fabrication 

facilities. In 2022, conventional onsite treatment of wastewater enabled semiconductor fabrication facilities 

to recycle between 40 to 70 percent of received water. A near zero wastewater system at a facility can 

essentially provide a closed water loop that requires minimal amounts of makeup water to operate, 

potentially improving water recycling up to 98 percent (for example, a 10 million gallon per day water 

demand could be reduced to 200,000 gallon per day) (Johnson, 2021).

One example of best available technology developed to provide high efficiency water filtration is based on 

counterflow reverse osmosis, which enables much higher levels of water recovery than preexisting reverse 

osmosis technology. The technique reduces the amount of energy consumption for a given amount of water 

treated (Johnson, 2021). By treating wastewater through onsite reclamation using this technology, water 

can be returned to recharge local aquifers which reduces impacts to affected watersheds. For example, a 

facility in Arizona was able to return approximately 95 percent of water used in 2020 (City of Chandler, 

2021). 

3.10.2 Environmental Consequences 

This section discusses the potential effects to utilities under the No Action Alternative and the Proposed 

Action Alternative.

3.10.2.1 No Action Alternative

Under the No Action Alternative, a semiconductor fabrication facility would not receive funding for 

modernization or internal expansion of existing current-generation and mature-node commercial facilities. 

The facility would continue the use of existing equipment to maintain production at the same rate with the 

same emissions and operational profiles. As such, utility use would continue at current levels and no new 

effects on utilities would be anticipated under the No Action Alternative.

3.10.2.2 Proposed Action Alternative

Modernization or internal expansion actions may increase semiconductor production and associated energy 

and water use. Proposed projects involving equipment and facility modernization within an existing facility 

with financial assistance received from the CHIPS Incentives Program also have the potential to reduce the 

amount of energy and water used through new technologies and more efficient processes. 
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Achieving reduced energy consumption through equipment upgrades can be done with minimal impact to 

production. Efficiency improvements in direct equipment components such as dry pumps, local exhaust 

abatement, heat exchangers, and chillers can be implemented. Minimizing heat used for hot UPW by 

recycling water locally or maximizing heat recovery can substantially impact facility energy demand. The 

use of green fuels such as hydrogen fuel and onsite energy generation using solar and wind sources can 

offset fossil fuel-based energy use (IEEE, 2023). Reducing or reusing cooling tower evaporation through 

the use of variable speed pumps and motors and avoiding high-temperature dissipation would decrease the 

need for cooling, thereby reducing demand on HVAC systems (IEEE, 2023).

The intensive water consumption required by semiconductor fabrication facilities has the potential to limit 

water availability for local households, businesses, and wildlife in the community where a facility is located. 

Water demand can be reduced through technology improvements by implementing UPW recycling while 

ensuring water quality. This can be achieved by providing adequate segregation to prevent contamination 

and through targeted treatment. Equipment water demand should be reduced through each step or operation. 

Adding process steps and equipment may increase water demand. Optimizing fabrication equipment and 

using water-efficient systems could be solutions to ensure that wafer yield and environmental compliance 

for wastewater discharges are not compromised. 

As the semiconductor industry continues to grow and the demand for semiconductor chips rises, adverse 

effects may continue to occur as increased production creates an increased demand for energy and water. 

However, for proposed projects that are under consideration for CHIPS federal financial assistance, these 

adverse effects could be reduced through semiconductor facility modernization and recycling and 

reclamation projects which would reduce energy and water use. Adverse effects are likely to be greater in 

drought-prone, water scarce regions or where there is overdemand for electricity; for more information see 

Section 3.4, Climate Change and Resilience and Chapter 4.0, Cumulative Impacts of this Draft PEA.

Applicants are required to submit a Climate and Environmental Responsibility Plan which describes their 

plans for maximizing the use of renewable energy and water recycling. CPO plans to work with applicants 

to incorporate or increase energy and water saving technologies or practices where practicable as discussed 

in Appendix A. CPO would evaluate each proposed project’s energy and water use (in the context of the 

site’s climate change challenges and other potential cumulative effects,see Section 3.4, Climate Change 

and Resilience and Chapter 4.0, Cumulative Impacts of this Draft PEA) to ascertain whether the 

proposed project would pose a burden on local community resources and determine whether the rate of 

utility consumption would be sustainable over the long-term. Across the industry, companies are making 

progress to reduce costs for energy and water and meet local utility requirements through greater efficiency, 

reductions in electricity and natural gas use, reduction of freshwater withdrawal, and reclamation and reuse 

of water. Energy and water usage are interdependent, so as the demand for water is reduced, energy demand 

is also reduced (IEEE, 2023). The implementation of BMPs would provide opportunities to reduce impacts 

to utilities from semiconductor manufacturing over the long term (see Appendix A for a list of potentially 

applicable BMPs). 

Overall, effects of the Proposed Action on energy and water use would be direct, adverse, long term, minor, 

and localized to regional for a facility that increased production as part of its proposed project; however, 

effects would be reduced by installation of improved, more energy- and water-efficient process tools and 

related infrastructure and could potentially be beneficial and minor if the facility implemented overall 

improvements to reduce water and energy consumption through water reclamation, reuse, and recycling 

and use of renewable energy. Effects would also be long term, beneficial and minor if a facility upgraded 

its equipment and infrastructure without increasing production as new equipment would be more efficient...
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3.11 ENVIRONMENTAL JUSTICE 

This section describes the affected environment and consequences to Environmental Justice (EJ) from the 

Proposed Action and the No Action Alternative. 

3.11.1 Affected Environment

EPA defines “environmental justice” as “the fair treatment and meaningful involvement of all people 

regardless of race, color, national origin, or income with respect to the development, implementation, and 

enforcement of environmental laws, regulations, and policies” (EPA, 1998). The goal of “fair treatment” is 

not to shift risks among different populations but to identify potential disproportionately high and adverse 

effects on minority communities and low-income communities and identify alternatives that may mitigate 

these effects (EPA, 1998).

This section of the Draft PEA interprets the affected environment for EJ to include identification of any 

disproportionately high and adverse effects on minority communities and low-income communities along 

with alternatives that may mitigate those effects. 

3.11.1.1 Regulatory Framework

This section provides an overview of the regulatory framework for the consideration of effects to EJ under 

NEPA: 

• EO 12898, Federal Actions to Address EJ in Minority Populations and Low-Income Populations, 

requires federal agencies to consider as a part of their action any disproportionately high and adverse 

human health or environmental effects to minority and low-income populations (collectively referred 

to as “populations with EJ concerns” throughout this section). Federal agencies are required to ensure 

that these potential effects are identified and addressed. 

• EO 13175, Consultation and Coordination with Indian Tribal Governments, requires federal agencies 

to uphold the unique “government-to-government” sovereign relationship between the U.S. 

government and federally-recognized Native American (American Indian) tribes and Alaskan Natives 

in the development of policies that have tribal implications. 

• EO 14030, Climate Related Financial Risks, requires federal investments to account for climaterelated financial risks and address any disparate effects on disadvantaged communities and 

communities of color. 

• EO 14008, Tackling the Climate Crisis at Home and Abroad, requires federal agencies to consider 

measures to address and prevent disproportionate and adverse environmental and health effects on 

communities, including the cumulative effects of pollution and other burdens like climate change. EO 

14008 established the Climate and Economic Justice Screening Tool, which allows agencies to 

identify disadvantaged communities that are marginalized, underserved, and overburdened by 

pollution. The federal decision-making process also involves solicitation of input from federallyrecognized Indian tribes, as well as Alaskan Natives, on matters having substantial direct effects on 

them. 

• EO 13045, Protection of Children from Environmental Health Risks and Safety Risks, requires federal 

agencies to identify and assess environmental health risks and safety risks that may disproportionately 

affect children and ensure that policies, programs, activities, and standards address disproportionate 

risks to children.

3.11.1.2 Identification of Populations with EJ Concerns 

The affected environment for EJ must include identification of any disproportionately high and adverse 

effects on minority communities and low-income communities. While a site-specific analysis would 
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normally present race and income information for populations affected by the undertaking and identify 

minority or low-income populations that could be disproportionately affected, due to the programmatic 

nature of this PEA, site-specific information for the Proposed Action is unknown. Instead, this section 

presents the methodology that applicants and CPO must use to determine the presence of populations with 

EJ concerns at the specific locations where the Proposed Action would occur. 

CEQ’s EJ Guidance under NEPA states that “minority populations should be identified where either: (a) the 

minority population of the affected area exceeds 50 percent, or (b) the minority population percentage of 

the affected area is meaningfully greater than the minority population percentage in the general population 

or other appropriate unit of geographic analysis” (CEQ, 1997). CEQ also recommends the identification of 

a geographic unit of analysis that accurately represents the occurrence and distribution of minority and lowincome communities in the project area, generally referred to as the “Region of Influence” (ROI) (CEQ, 

1997). This is the region where potential effects with the greatest intensity and longest duration would occur 

from the implementation of the Proposed Action. 

Due to the site-specific nature of any given facility modernization and internal expansion proposal, the ROI 

could comprise one or more census tracts (CTs) or block groups (BGs). The type of geographic unit selected 

for analysis (i.e., either CT or BG) would depend on the project scope and location. These units are briefly 

described below: 

• Census Tracts are small, relatively permanent statistical subdivisions of a county or equivalent entity, 

generally with a population size between 1,200 and 8,000 people. A CT usually covers a contiguous 

area, and its boundaries usually follow visible and identifiable features (e.g., road, river). The spatial 

size of CTs varies widely depending on the density of settlement. CTs were designed to be relatively 

homogeneous units with respect to population characteristics, economic status, and living conditions. 

In addition, tribal CTs are defined for federally-recognized American Indian tribes with reservations 

or off-reservation trust land and can cross state and county boundaries. A single tribal CT typically 

consists of a population of less than 2,400. Tribal CTs may be completely different from the standard 

CTs defined for the same area (USCB, 2022). 

• Block Groups are statistical divisions of CTs and are generally defined to contain between 600 and 

3,000 people. BGs are composed of clusters of census blocks within the same CT. A census block is 

the smallest geographic area for which the U.S. Census Bureau (USCB) collects and tabulates 

decennial census data. A BG usually covers a contiguous area. Each CT contains at least one BG, and 

BGs are uniquely numbered within the CT. Tribal BGs are separate and unique geographic areas 

defined within federally-recognized tribal reservations and can cross state and county boundaries 

(USCB, 2022). 

Following the identification of the appropriate ROI, the race, ethnicity, and income data for the ROI would 

be compared with data for the Region of Comparison (ROC), or the “general population” as it corresponds 

to the CEQ definition. ROC is the unit of geographic analysis (e.g., county, state, or region) that provides a 

baseline for comparison of health and environmental effects on populations of EJ concerns with the effects 

on the “general population” of the region. The USCB American Community Survey (ACS) 5-year estimates 

are typically used to describe and compare the demographic characteristics of the ROI and ROC. The ROI 

may be considered a population with EJ concerns based on the factors described below. In addition to 

identifying and characterizing communities in accordance with federal guidance, consideration of statelevel EJ laws, policies, and guidance would also be required. Several states have released new or updated 

EJ policies focusing on public participation, permitting reforms, monitoring, and compliance. For example, 

in June 2022, the Maryland Department of the Environment released an EJ Screening Tool to enhance 

communication and outreach between the agency and overburdened or underserved communities in the 

state (ELI, 2023). In September 2020, New Jersey passed “An Act Concerning the Disproportionate and 

Public Health Impacts of Pollution on Overburdened Communities”, which requires EJ impact statements 
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for projects in EJ communities subject to the state’s Department of Environmental Protection permits 

(Gerrard and McTiernan, 2021). 

The federal criteria for identifying communities of EJ concern are described below:

Minority Populations

The CEQ defines “minority” as including the following population groups: American Indian or Alaskan 

Native; Asian or Pacific Islander; Black, not of Hispanic Origin; or Hispanic (CEQ, 1997). The CEQ defines 

a minority population in the following ways: 

• “...the minority population of the affected area exceeds 50 percent... (CEQ, 1997).” [As this 

definition applies to the Proposed Action and alternatives, if more than 50 percent of the population in 

the ROI consists of minorities, this would qualify as constituting a population with EJ concerns.] 

• “...the minority population percentage of the affected area is meaningfully greater than the minority 

population percentage in the general population or other appropriate unit of geographic analysis 

(CEQ, 1997).” [For purposes of this analysis, a discrepancy of 10 percent or more between minorities 

(the sum of all minority groups) in the ROI would be considered “meaningfully greater than” 

minorities in the ROC and would categorize the ROI as constituting a minority population with EJ 

concerns.] 

Low-Income Populations

“Low-income populations” are defined as households with incomes below the federal poverty level (ASPE, 

No Date). There are two slightly different versions of the federal poverty measure: poverty thresholds 

defined by the USCB and poverty guidelines defined by the Department of Health and Human Services. 

Poverty thresholds are defined by and updated each year by the USCB. The USCB uses a set of income 

thresholds that vary by family size and composition (number of children and elderly) to determine who is 

in poverty. If a family’s total income is less than the poverty threshold, then that family and every individual 

in it is considered in poverty. The same applies for a single individual. The official poverty definition 

considers pre-tax income and does not include capital gains or non-cash benefits such as public housing, 

Medicaid, and food stamps (CEQ, 1997). Poverty thresholds are primarily used for statistical purposes, 

such as calculating poverty population figures or estimating the number of Americans in poverty each year. 

CEQ EJ Guidance under NEPA recommends that USCB poverty thresholds be used to identify low-income 

populations (CEQ, 1997). As such, this section uses USCB poverty thresholds to identify low-income 

populations. 

Because CEQ guidance does not specify a threshold for identifying low-income populations, the same 

approach used to identify EJ minority populations is applied to low-income populations. The ROI would 

be defined as a low-income population or population with EJ concerns if:

• More than 50 percent of the ROI consists of families or persons below the poverty threshold; or 

• The percentage of low-income families or persons in the ROI is meaningfully greater than the 

percentage in the ROC. A discrepancy of 10 percent or more between the ROI and the ROC would be 

considered “meaningfully greater” and would categorize the ROI as constituting a low-income 

population with EJ concerns. 

Native American Tribes

As described above, the CEQ EJ Guidance under NEPA recommends that when selecting a geographic unit 

of analysis for EJ, consideration should be given to the spatial distribution of minority and low-income 

populations, which may reside in tightly clustered communities or may be evenly or unevenly distributed 

throughout the general population. As such, federal agencies are required to identify federally-recognized 
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tribes that reside in concentrated “pockets” or reservations in and outside the ROI and that engage in unique 

cultural and traditional practices (e.g., subsistence and ceremonial fishing) that are directly dependent on 

the resources occurring in the ROI. 

Additional Considerations

In addition to the factors described above, the tools listed in Table 3.11-1 below may be used to screen for 

the presence of communities with EJ concerns in the ROI, and to determine the possibility of 

disproportionately high and adverse effects on such communities. 

Table 3.11-1. Tools for Identifying Communities with EJ Concerns*

Tool Description

EJScreen EPA’s EJ mapping and screening tool provides high-resolution 

environmental and demographic information for the identification of 

areas with (EPA, 2023r):

• People of color and/or low-income populations; 

• Potential environmental quality issues;

• A combination of environmental and demographic indicators that is 

greater than usual; and 

• Other factors that may be of interest.

In addition to EJScreen, EPA has also developed other data and mapping 

tools and compiles several different state-level EJ mapping tools (EPA, 

2023r). 

Climate and 

Environmental Justice 

Screening Tool (CEJST)

CEQ’s CEJST provides socioeconomic, environmental, and climate 

information to inform decisions that may affect disadvantaged 

communities. The tool highlights CTs that are overburdened and 

underserved and identifies them as “disadvantaged.” Federallyrecognized tribes, including Alaska Native villages, are also considered 

disadvantaged communities (CEQ, 2023b). 

National Environmental 

Public Health Tracking 

Network (Tracking 

Network)

Centers for Disease Control and Prevention’s (CDC) Tracking Network 

provides environmental health data that includes the following (CDC, No 

Date):

• Health conditions and diseases (e.g., asthma);

• Contaminants in the environment (e.g., air pollution); 

• Climate (e.g., extreme heat events); 

• Community design (e.g., access to parks); 

• Behaviors (e.g., smoking);

• Population characteristics (e.g., age and income)

Health Impact Assessment 

(HIA) Resource and Tool 

Compilation

This is a compilation of tools and resources related to the HIA process 

that can be used to collect and analyze data, establish a baseline profile, 

assess potential health effects, and establish benchmarks and indicators 

for monitoring and evaluation. These resources include literature and 

evidence bases, data and statistics, guidelines, benchmarks, decision and 

economic analysis tools, scientific models, methods, frameworks, indices, 

mapping, and various data collection tools (EPA, 2016). 

AirNow Portal EPA’s AirNow portal provides local, state, national, and world-wide air 

quality data. It makes use of EPA’s Air Quality Index to designate the air 

quality as healthy or unhealthy in the selected area (EPA, 2023s).
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Tool Description

Social Vulnerability Index CDC’s and Agency for Toxic Substances and Disease Registry’s Social 

Vulnerability Index is a place-based index, database, and mapping tool 

that helps in the identification and characterization of communities that 

are less able to prepare for, respond to, and recover from public health 

crises. This index uses U.S. Census data to determine the social 

vulnerability of every CT (ATSDR, No Date). 

*Please note that this is not an exhaustive list but includes the commonly used tools for EJ analysis. The state in 

which the Proposed Action is located may have its own EJ screening tool or similar resources that should be 

consulted to ensure that EJ communities are also evaluated according to relevant state and local guidelines.

3.11.2 Environmental Consequences 

This section discusses the potential effects to EJ under the No Action Alternative and the Proposed Action 

Alternative.

3.11.2.1 No Action Alternative

Under the No Action Alternative, a semiconductor fabrication facility would not receive funding for 

modernization or internal expansion of existing current-generation and mature-node commercial facilities. 

The facility would continue the use of existing equipment to maintain production at the same rate with the 

same emissions and operational profiles. As such, no new effects to identified EJ communities would be

anticipated under the No Action Alternative.

3.11.2.2 Proposed Action Alternative

A proposed project involving equipment and facility modernization and expansion within the existing 

facility footprint that receives financial assistance from the CHIPS Incentives Program could potentially 

affect EJ communities by introducing new or increased health and safety hazards during the construction 

and operations, such as noise, unsafe traffic patterns, or pollution levels. EJ communities might be present 

in the project area. An EJ analysis would be conducted for the proposed project to ensure there would not 

be disproportionately high and adverse effects on EJ populations. This analysis would be documented by 

CPO during due diligence and prior to the proposed project receiving any funding. Consideration of the 

potential consequences for EJ requires three main components.

1. A demographic assessment of the affected community to identify the presence or absence of minority 

populations, low-income populations, and Native American tribes that may be affected. 

2. An assessment of all potential effects identified to determine if any could result in adverse effects to 

the affected environment. 

3. An integrated assessment to determine whether any disproportionately high and adverse effects exist 

for minority populations, low-income populations, and Native American tribes present in the ROI. 

In general, the types of potential effects on populations with EJ concerns could include:

• Social and economic benefits of direct, indirect and induced jobs created; 

• Health risks (especially to workers) from the proposed construction, expansion, and modernization 

activities; 

• Noise disturbances; 

• Restricted or delayed access to schools, residential areas, public transportation, or hospital and health 

care facilities due to traffic and time delays; and 
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• Effects to the unique cultural and traditional practices of Native American tribes. 

As discussed in Section 3.12 Socioeconomics, the Proposed Action would likely result in the creation of 

short-term construction jobs, some of which may be filled by populations with EJ concerns. Depending on 

the project location, the majority of the labor involved may be sourced from specialized contractors located 

outside the ROI; however, these revenues may also result in the creation of a relatively small number of 

jobs sourced from within the ROI. The Proposed Action also may lead to the creation of additional, longterm or permanent full-time positions at the facility. If populations with EJ concerns are hired to work on 

these proposed projects, they could experience negligible to minor health benefits through economic 

pathways in the short and long term. 

There may be short-term construction noise and air emissions associated with equipment removal, 

installation of new, modernized equipment, upgrades to existing equipment, or conversion of internal 

spaces to new cleanrooms. Because modernization projects would largely include renovation of interior 

spaces, outdoor heavy equipment operation would be minor (such as use of cranes to move heavy equipment 

and forklifts to move materials). As such, the effects from noise and air emissions associated with the 

construction equipment for each project would be negligible and temporary. Modernization projects would 

generally result in minor increases in staffing, resulting in negligible to minor effects on local traffic. 

Accordingly, commuter vehicle emissions, public transportation access, and traffic patterns would 

generally be unchanged and not pose adverse effects to local communities, including EJ communities, 

unless there is substantial increase in long-term workforce. 

The Proposed Action may result in the use of greater quantities of energy and water and generate more solid 

waste, hazardous waste, air contaminants, and wastewater. CPO would evaluate applicant proposals to 

ensure applicable federal, state, and local environmental permits are received and, where applicable, 

promote applicant commitments to BMPs or best available control technologies to minimize adverse effects 

of their operations on the health of EJ communities as outlined in Appendix A.

A recipient of CHIPS Incentives Program funding would be expected to conduct meaningful public 

engagement and outreach to EJ communities. The facility would be expected to design its projects to 

minimize the potential for adverse effects on the environment and the local community, including 

communities with EJ concerns as reflected in the facility’s required Climate and Environmental 

Responsibility Plan as described in Appendix A. This plan must include “a description of the applicant’s 

strategies for minimizing the potential for adverse impacts to the local community, including communities 

with environmental justice concerns.” 

In summary, effects to EJ from the Proposed Action could be both beneficial and adverse. Beneficial effects 

could result from the direct, indirect, and induced employment opportunities associated with the 

construction and operational phases of the proposed project. Such effects would be negligible to minor and 

range from short-term to long-term or permanent. Allocation of funds to provide training to disadvantaged 

individuals for their workforce development and job placement, as incentivized by the CHIPS Act, would 

result in minor to moderate, long-term beneficial effects to such populations. These beneficial effects would 

be regional in extent. 

Negligible, temporary, and localized adverse effects from noise and air emissions may occur on the health 

and well-being of populations with EJ concerns hired to work at the applicant facilities. Any potential for 

disproportionately high and adverse effects to such communities due to the increased quantities of wastes 

generated and the higher volumes of resources utilized by the facilities would be addressed in the due 

diligence process. Such effects may be minor to moderate, short-term to long-term, and localized or 

regional in extent and would depend on the scope and location of the facility modernization or internal 

expansion project. Such effects would be minimized by developing and implementing appropriate BMPs. 
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3.12 SOCIOECONOMICS

This section describes the affected environment and consequences to socioeconomics from the Proposed 

Action and the No Action Alternative. 

3.12.1 Affected Environment

The analysis of socioeconomic effects identifies those aspects of the social and economic environment that 

are sensitive to changes and that may be affected by semiconductor fabrication modernization projects. The 

affected environment for socioeconomics in a site-specific analysis would normally describe the 

socioeconomic characteristics of the project area, also called ROI, that could be potentially affected by the 

proposed project and compare it with the socioeconomic data for the ROC (see Section 3.10 

Environmental Justice for detailed descriptions of ROI and ROC). These characteristics include local 

demographics, labor force participation and employment, and income. However, due to the programmatic 

nature of this PEA, site-specific information for the Proposed Action is unknown. Instead, this section 

presents an overview of the U.S. semiconductor industry, the challenges facing it, and the economic 

implications of the CHIPS Act of 2022. 

3.12.1.1 Overview of the U.S. Semiconductor Industry 

Semiconductors are critical to nearly all industrial sectors and play an instrumental role in technologies that 

address a variety of national needs, such as defense weapon systems, medical equipment, automobiles, 

industrial machinery, consumer electronics, and environmental systems (CRS, 2022). Semiconductors play 

an integral role in emerging technologies in numerous related fields, such as artificial intelligence, high 

performance computing, and autonomous systems (SIA, 2022). In addition, chips are indispensable 

components of the renewable energy transition (Favino, 2022). The U.S. government and companies 

pioneered advancements in semiconductor technology through the 1960s and 1970s, and formerly led the 

world in semiconductor manufacturing (CRS, 2023). Six U.S.-headquartered or foreign-owned 

semiconductor manufacturing companies currently operate 20 fabrication facilities in the U.S. (CRS, 2022). 

The U.S. semiconductor industry accounts for nearly half of the global market share and remains the world 

leader for chips sales. Additionally, the industry maintains a highly competitive position in research and 

development (R&D), design, and manufacturing process technology (SIA, 2022). 

The U.S. semiconductor industry contributes substantially to U.S. Gross Domestic Product (GDP) and 

income. In 2021, the Gross Value Added (GVA) contribution of the U.S. semiconductor industry to the GDP 

totaled $276.9 billion. The industry also generated $165.1 billion in income in 2021, supporting 1.84 million 

U.S. jobs in 2021. The industry directly employs more than 277,000 domestic workers in R&D, design, and 

manufacturing activities, among others. For each U.S. worker directly employed by the semiconductor 

industry, an additional 5.7 indirect or induced jobs are supported across a wide and diverse distribution of 

downstream economic sectors, including construction, financial activities, and leisure and hospitality (SIA, 

2022). 

U.S. exports of semiconductors totaled $62 billion in 2021, making it the fourth-highest export behind only 

airplanes, refined oil, and crude oil. The R&D expenditures of the U.S. semiconductor industry have grown 

by nearly 7.2 percent from 2000 to 2020. In 2021, the industry’s investment in R&D totaled $50.2 billion. 

The semiconductor industry is second only to the U.S. pharmaceutical and biotechnology industry in terms 

of the rate of R&D spending as a percent of sales (SIA, 2022). 

On a global scale, the semiconductor industry reported $440.4 billion in sales in 2020, which grew by a 

record 26.2 percent to $555.9 billion in 2021. Per industry estimates, the worldwide semiconductor industry 

sales were projected to be between $618 - $633 billion in 2022. The market for semiconductors and related 

products is expected to continue growing in the future (SIA, 2022). 
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3.12.1.2 Challenges to the U.S. Semiconductor Industry

While the U.S. semiconductor industry continues to dominate many parts of the semiconductor supply 

chain, a variety of factors over the years have led to the concentration of semiconductor manufacturing in 

East Asia (CRS, 2023). The U.S. share of semiconductor fabrication capacity was 12 percent in 2020, down 

from 13.8 percent in 2015, continuing a long-term decline from around 40 percent in 1990. This decline is 

expected to continue as new facilities open globally in the next few years, particularly in East Asian 

countries – South Korea, Taiwan, Japan, and China (CRS, 2022). Some of the challenges currently 

encountered by the U.S. semiconductor industry include (CRS, 2023): 

• Decline in the U.S. position in semiconductor manufacturing and technology and potential rise in 

foreign industrial and technological competitiveness; 

• Inadequate domestic manufacturing capability to meet U.S. national security and economic needs;

• U.S. reliance on global supply chains and production concentrated in East Asia; 

• Supply chain disruptions due to the Coronavirus Disease 2019 (COVID-19) pandemic; 

• Sustaining the ability of the industry to improve semiconductor performance while decreasing cost 

through technological innovation; and 

• Retaining and growing high-skilled and high-paying semiconductor industry jobs in the U.S. 

3.12.2 Environmental Consequences

This section discusses the potential effects to socioeconomics under the No Action Alternative and the 

Proposed Action Alternative.

3.12.2.1 No Action Alternative

Under the No Action Alternative, a semiconductor manufacturing facility would not receive federal funding 

for modernization or internal expansion of existing current-generation and mature-node commercial 

facilities. The facility would continue the use of existing equipment to facilitate production at the same rate 

and would not produce chips needed by emerging technologies. While private investment could assist 

modernization activities, the pace could be slower when compared to receiving CHIPS financial assistance

under the Proposed Action. The socioeconomic effects of the No Action Alternative could result in fewer 

jobs and reduced contribution to GDP when compared to the Proposed Action Alternative. 

3.12.2.2 Proposed Action Alternative

The Proposed Action would have direct, beneficial, short-term effects on socioeconomics due to the 

creation of specialized employment opportunities associated with the removal of outdated equipment, 

installation of modernized equipment, upgrades to existing equipment, or conversion of internal spaces 

within the existing facility footprint to create new cleanrooms. Modernization projects would likely require 

both skilled tradespeople (electricians, pipe-fitters, heating/ventilation/cooling contractors, etc.), laborers, 

and specialized semiconductor manufacturing equipment installation technicians depending on the project 

scope. Where a facility’s production is expanded substantially, there would likely be creation of direct, fulltime well-paying jobs. Individuals hired to work on these proposed projects could experience negligible to

minor health benefits through economic pathways in the short and long term. Jobs and income are strongly 

associated with beneficial health outcomes such as an increase in life expectancy, improved child health 

status, improved mental health, and reduced rates of chronic and acute disease morbidity and mortality 

(HDA, 2004; Cox et al., 2004). 

Indirect economic effects would also result from directly affected industries, such as facilities that 

manufacture equipment and materials for semiconductor manufacturing. Such entities may be located 
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outside of the ROI, resulting in benefits that could extend over a much larger region. In addition, local retail 

stores and establishments where workers spend their wages should also benefit, potentially creating 

additional jobs. These benefits would primarily be experienced by businesses and populations located 

within the ROI in the vicinity of the facility. Induced effects could also occur when employees of the directly 

and indirectly affected industries spend the wages they receive. The magnitude of the direct and indirect 

beneficial effects would depend on the amount of funding received by the applicant facility; a greater 

funding amount would generate substantially larger direct, indirect, and induced economic effects.

The Proposed Action may result in one of the following scenarios for facilities receiving CHIPS financial 

assistance: increased production of their current product, continued production at the same rate but 

production of an improved product, both the expansion of production and product quality improvement, or 

reduction in production but improvement in product quality. This could result in indirect benefits to the 

end-use markets that rely on semiconductors, such as industries like automobile, communication, defense, 

information technology, manufacturing, medical technology, renewable energy, and aerospace. Increased 

modernization could ultimately reduce chip shortages among these industries, which would benefit U.S. 

consumers and the economy overall (SIA, 2022). These effects would also contribute to the GDP, create 

additional employment in sectors dependent on semiconductors, and increase overall earnings.

As such, the Proposed Action would have direct, minor, short-term to long-term beneficial effects on 

socioeconomics due to the creation of specialized employment opportunities. The indirect socioeconomic 

effects to downstream industries would be long-term, beneficial, and moderate. All socioeconomic effects 

would be regional to national in extent.

3.13 SUMMARY OF POTENTIAL EFFECTS

Table 3.13-1 below provides a summary of anticipated effects from the No Action and Proposed Action 

Alternatives. As part of the due diligence process to receive CHIPS Incentives Program funding, an 

applicant must demonstrate compliance with all existing facility permits. Upon completing modernization 

and/or internal expansion projects, the facility would be required to comply with any additional or amended 

permit conditions based on any changes to the facility’s operations. Additionally, the facility may be 

required to commit to appropriate best management practices (BMPs) within the industry (see Appendix 

A) to reduce environmental effects resulting from implementation of the modernization and/or internal 

expansion project.

Prior to issuing funding, the DOC would evaluate whether the proposed project and its associated effects 

are covered under the PEA or whether additional NEPA analysis is needed.
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Table 3.13-1. Summary of Potential Effects

Resource Area No Action Alternative Proposed Action Alternative

Climate Change 

and Resiliency

Ongoing emissions trends of 

GHGs from semiconductor 

manufacturing facilities 

would remain the same, and 

there would continue to be a 

negligible to minor, adverse, 

long-term, global effect on 

U.S. GHG emissions and 

resultant climate change and 

climate resiliency. Overall, 

there would be no new 

effects on climate change 

and resiliency from the No 

Action Alternative.

Effects to climate change and resiliency would be 

negligible to minor, long-term, and global. Direct 

and indirect GHG emissions could be reduced 

through use of energy-efficient technologies and 

implementation of BMPs; however, increased 

production, if implemented, would increase GHG 

emissions. Effects could be adverse or beneficial, but 

given the high GWP of some GHG constituents 

effects are more likely to be adverse.

Air Quality No changes in the amount or 

pollutant load of air 

emissions would occur 

because the same existing 

equipment and processes 

would be used in the same 

configuration. There would 

be no new effects to 

localized or regional air 

quality. 

An increases in semiconductor production may cause

an increase in pollutant loads and changes in the 

types of pollutants emitted, resulting in adverse 

effects on air quality. Effects on air quality would be 

direct; long term, because the effects would last for 

several months or longer; and localized to regional, 

because the effects have the potential to extend from 

the project site to the surrounding community. These 

effects would be adverse and negligible when 

compared to current conditions, but they could be 

beneficial and minor if new air pollution control 

measures were introduced with the modernization to 

reduce the pollutant load in air emissions.

Water Quality No changes in the amount or 

pollutant load of facility 

wastewater would occur and 

laws, regulations, and 

permitting requirements 

would remain in place; 

therefore, there would be no 

new effects to localized or 

regional water quality. 

A semiconductor fabrication facility modernization 

and expansion project would cause direct, adverse 

effects on water quality from the introduction of 

pollutants associated with increased production. 

Long-term changes in the volume and concentration 

of wastewater would have local effects for direct 

dischargers and regional effects for indirect 

dischargers. Effects to water quality would be minor 

because facilities would still be required to comply 

with wastewater discharge permit limits and conduct 

routine monitoring to confirm compliance.

Modernization of equipment and the facility would 

have direct, long-term, localized to regional effects 

on water quality; these effects would be adverse and 

minor compared to current conditions.
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Resource Area No Action Alternative Proposed Action Alternative

Human Health 

and Safety

The proposed project would 

not be implemented, but the 

facility would continue to 

follow all regulations 

protecting worker health and 

safety. There would be no 

new effects to human health 

and safety.

Effects of construction would be direct, negligible to 

minor, temporary, and localized. Effects of increased 

production would be direct, long-term, negligible to 

minor, and localized. Effects of decontamination and 

removal of manufacturing equipment would be 

direct, negligible to minor, temporary, and localized.

Hazardous and 

Toxic Materials

The rate of hazardous and 

toxic material use would not 

change; there would be no 

new effects on hazardous 

material use.

Effects of facility-specific reduction and substitution 

would be direct, localized, long-term, and beneficial. 

Effects of construction would be direct, short-term, 

minor, and localized. Effects of increased production 

would be indirect, adverse, and regional. Overall, 

effects to hazardous and toxic materials would be 

direct, adverse, negligible to minor, long-term, and 

localized to regional.

Hazardous 

Waste and Solid 

Waste 

Management

No new effects on the 

generation of hazardous 

waste would occur.

Overall effects from construction, equipment 

disposal, and increased production would be direct 

and indirect, short- to long-term, and localized to 

regional in extent. Effects would be adverse and 

negligible to minor compared to current conditions, 

but could be beneficial and minor of new measures 

were introduced to reduce, reuse, and recover 

materials. 

Utilities The facility would continue 

to use the same equipment at 

the same production rate and 

no new effects to utilities 

would occur.

Overall, effects to energy and water use would be 

direct, adverse, long-term, minor, and localized to 

regional for a project that increases production; 

effects would be reduced by improvements in 

technologies and practices. Effects would be longterm, beneficial, and minor for facilities that upgrade 

equipment and infrastructure without increasing 

production.

Environmental 

Justice

No new effects to identified 

Environmental Justice 

communiities would occur.

Effects to EJ from the Proposed Action could be both 

beneficial and adverse. Such effects would be 

negligible to minor, range from short-term to longterm or permanent, and regional. Negligible, 

temporary, and localized adverse effects from noise 

and air emissions may occur on the health and wellbeing of populations with EJ concerns hired to work 

at the applicant facilities. An EJ analysis would be 

conducted for proposed projects to ensure there 

would not be disproportionately high and adverse 

effects on EJ populations. This analysis would be 

documented by CHIPS during due diligence and 

prior to a proposed project receiving any funding.
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Resource Area No Action Alternative Proposed Action Alternative

Socioeconomics The No Action Alternative 

would result in fewer jobs 

and reduced contribution to 

GDP when compared to the 

Proposed Action Alternative.

The Proposed Action would provide an economic 

boost to the U.S. semiconductor industry by 

increasing production of advanced chips. The 

Proposed Action would have direct, beneficial, shortterm effects on socioeconomics due to the creation of 

specialized employment opportunities associated 

with the removal of outdated equipment, installation 

of modernized equipment, upgrades to existing 

equipment, or conversion of internal spaces within 

the existing footprint to create new cleanrooms. 

Indirect economic effects would also result from 

directly affected industries, such as facilities that 

manufacture equipment and materials for 

semiconductor manufacturing. Overall, direct effects

would be minor, short-term to long-term, and

beneficial due to the creation of specialized 

employment opportunities. The indirect 

socioeconomic effects to downstream industries 

would be long-term, beneficial, and moderate. All 

socioeconomic effects would be regional to national 

in extent.
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4.0 CUMULATIVE EFFECTS

Cumulative effects on the environment occur from the incremental impact of the Proposed Action when 

added to other past, present, and reasonably foreseeable future actions regardless of who undertakes such 

actions. Cumulative impacts can result from individually minor, but collectively substantial, actions taking 

place over time. 

Past, present, and future actions analyzed under cumulative impacts should have a connection to the 

Proposed Action for internal modernization of semiconductor fabrication facilities, where additive or 

synergistic effects (beneficial or non-beneficial) are possible that would affect local, regional, or global 

environmental resources. This discussion on cumulative impacts focuses on the following trends and 

foreseeable actions related to the overall semiconductor ecosystem: 

• Creation of semiconductor fabrication facility clusters in the U.S.

• Economic effects of increased semiconductor manufacturing in the U.S. (including CHIPS Incentives 

Program funding of new manufacturing facilities). 

• Semiconductor manufacturing industry emissions of greenhouse gases (GHGs) and climate change 

trends.

• Trends in corporate responsibility and environmental stewardship in the semiconductor 

manufacturing industry.

4.1 CLUSTERING OF SEMICONDUCTOR FABRICATION FACILITIES IN THE U.S.

Modernizing an existing semiconductor fabrication facility would likely not be enough of an investment in 

a given geographic area to induce the creation of new semiconductor clusters at that location. However, 

creating beneficial and sustainable semiconductor clusters is an initiative of the CHIPS Act. The goal of 

the CHIPS Act is to boost U.S. semiconductor research, development, and production and bolster U.S. 

innovation and investment in semiconductors, wireless supply chains, and technologies of the future. The 

Act provides federal funds to invest in regional innovation and technology hubs that will create jobs and 

spur economic development. These hubs, or clusters, often provide competitive advantages, including: 

• Attracting and concentrating specialized labor pools; 

• Increasing proximity of supplier and service firms to allow for economies of scale with regard to 

transportation, supply chains, infrastructure, communications and logistics; and 

• Advancing technologies through increased communication and knowledge sharing among firms, 

suppliers, and researchers (Shivakumar et al., 2023). 

While industrial clusters often confer economic benefits, the environmental effects of such density can 

sometimes be detrimental to affected communities (Fagbohunka, 2015). Clustering can cause 

direct/primary and indirect/secondary population growth leading to overcrowding and traffic resulting in 

increases in air pollution and wastewater flows within a concentrated area. Substantial increases in localized 

water and energy use could also occur in the case of semiconductor manufacturing. Water use is a great

concern because of the vast quantities of water required by semiconductor fabrication facility operations. 

There is the potential for major adverse cumulative effects to constrained fresh water supplies could occur 

(e.g., depletion of rivers, reservoirs, and aquifers) by concentrating several fabrication facilities in a cluster 

if local and state governments do not adequately model, plan, and develop water efficiency, conservation, 

and reclamation projects to meet all the water needs of their area.

Clustering also can provide opportunities for local and state agencies to develop more effective strategies 

to reduce or offset environmental impacts through large infrastructure projects that might not be financially 
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feasible for single semiconductor fabrication facilities. Such infrastructure projects could include local or 

regional water treatment and recycling projects, utility-scale renewable energy projects, regional 

transportation improvement projects, and improvements to or expansion of public transit options. The 

CHIPS Incentives Program prioritizes financial assistance that creates “spillover benefits that improve 

regional economic resilience and support a robust semiconductor ecosystem, beyond assisting a single 

company.” This means prioritizing local and state investment in inputs to industry cluster development that 

the market tends to underprovide, such as infrastructure, workforce development, and research and 

development (Muro et. al., 2023). Infrastructure projects funded by local and state governments are often 

focused on providing adequate transportation and utility capacity that can also incorporate environmental 

improvements. State and local environmental regulators can develop regulations, guidelines, and 

enforcement inspection schedules to address environmental concerns specific to the industry at that 

location’s environmental conditions. 

The CHIPS Incentives Program Notice of Funding Opportunity (NOFO) was published in February 2023 

and amended in June 2023 to fund large-scale semiconductor materials and manufacturing equipment 

facilities for which the capital investment equals or exceeds $300 million. A second NOFO was released in

September 2023 to strengthen the resilience of the semiconductor supply chain facilities for which the 

capital investment falls below $300 million. This federal funding opportunity focuses on bolstering 

domestic supply chains to create vibrant and sustainable semiconductor clusters. The goal of the second 

NOFO is to close the critical gaps in the supply chain landscape by making the critical investments in 

proposed projects that support the key U.S. semiconductor fabs with other regional entities like local and 

state governments. One key caveat with this funding opportunity is that applicants are required to 

demonstrate that their proposed projects have anchor institution supports, such as semiconductor fabrication 

facilities, which have the potential to create clustering effects. It is anticipated that most of the new 

clustering effects would occur around new leading edge semiconductor fabrication facilities and not around 

facilities receiving federal financial assistance for modernization or internal expansion of existing currentgeneration and mature-node semiconductor fabrication facilities. 

The Proposed Action of modernizing an existing semiconductor fabrication facility would likely not induce 

creation of new semiconductor clusters at that location. The potential for increased production at an existing 

facility would likely not be substantial enough to necessitate or prompt existing or new service partners or 

suppliers to relocate to that site. Many existing semiconductor fabrication facilities are also constrained by 

surrounding development that does not allow co-location of supporting service industries and suppliers. 

Modernization projects, due to their relatively small size, should not substantially increase water and energy 

use and wastewater generation. These proposed projects may also incorporate tooling and facility 

improvements to conserve water and energy. While the Proposed Action would help meet other goals of the 

CHIPS Incentives Program, it would likely not cause significant cumulative environmental impacts in 

association with existing or planned semiconductor clusters. 

4.2 ECONOMIC EFFECTS OF THE CHIPS ACT IN THE U.S.

The CHIPS Act resulted in the announcement of dozens of proposed projects to increase manufacturing 

capacity in the U.S. According to the Semiconductor Industry Association (SIA), over 60 new projects have 

been announced with over $210 billion in private investments across 22 states with an expected 44,000 new 

high-quality jobs (Casanova, 2022). In a 2021 SIA-Oxford economic study, for each U.S. worker directly 

employed by the semiconductor industry, an additional 5.7 jobs are supported in the wider U.S. economy. 

The industry is projected to need an additional 90,000 workers by 2025 (Eightfold AI, 2021). The Act 

provides workforce and education funding to assist in growing the semiconductor workforce. 

The CHIPS Act is also aimed at spurring growth in scientific research and allocates funds for material 

science, quantum computing, and biotechnology. The Department of Energy (DOE) is developing a plan to 

reduce energy use of microelectronics chips, circuits, architecture, and software by 1000 times in the next 

20 years under the CHIPS Act (Bui, 2023). 
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The Public Wireless Supply Chain Innovation Fund investments are also authorized through the CHIPS 

Act. The funds are aimed at fostering competition, lowering costs for consumers and network operations, 

supporting innovation across the global telecommunications ecosystem, and strengthening the 5G supply 

chain (NTIA, 2023). Expansion of 5G networks drives economic growth and provides benefits from 

expanded education and employment opportunities like remote learning and job-seeker services, higher 

wages, and telehealth services. By 2030, the Boston Consulting Group in collaboration with NTIA, 

estimates 5G development will contribute $1.4 trillion to $1.7 trillion to the U.S. gross domestic product 

(GDP) and create between 3.8 and 4.6 million jobs (Melo et al., 2021). 

While the CHIPS Act is an important component to spur private investments, private funding of 

semiconductor manufacturing projects will far exceed the financial assistance authorized under the CHIPS 

Act (i.e., private investments will remain the primary driver of growth in this sector over the next decade). 

A modernization project under the Proposed Action would increase jobs by a small fraction when compared 

to projects constructing entirely new leading-edge semiconductor fabrication facilities or initiatives to 

develop new clusters. A modernization project under the Proposed Action would also increase 

manufacturing productivity and foster production of advanced chips, but on a relatively small scale. 

Cumulatively, semiconductor facility modernization projects along with other initiatives under the Act and 

increased private investments in the U.S. semiconductor industry should reduce potential semiconductor 

shortages in the future, promote new semiconductor jobs and job training, increase economic growth, 

advance new technology, enhance national and economic security, and increase supply chain resilience to 

the semiconductor ecosystem. 

4.3 CLIMATE CHANGE TRENDS AFFECTING THE SEMICONDUCTOR INDUSTRY AND 

SECTOR GREENHOUSE GAS EMISSIONS

As described in Section 3.4 of this Draft PEA, consequences of climate change are increasing and resulting 

in more intense droughts, water scarcity, flooding, severe wildfires, melting polar ice and glaciers, more 

catastrophic storms, and declining biodiversity (U.N., No Date). 

The semiconductor industry in the U.S., through its direct, onsite emissions from manufacturing processes 

and offsite fossil energy used to generate the electricity it consumes is estimated to contribute approximately 

0.18 percent of aggregate annual U.S. greenhouse gas emissions (GHG) or approximately 11.5 million 

metric tons (MMT), expressed in CO2e. The sector provides 1.4 percent of total U.S. manufacturing 

employment (CRS, 2020) and directly contributed approximately 1.2 percent to the U.S. GDP in 2020 

(Oxford Economics, 2021). 

Indirect emissions from offsite fossil fuel combustion to generate electricity accounts for almost half of 

total GHG emissions from the semiconductor manufacturing sector. Direct emissions from the use of 

fluorinated compounds in onsite manufacturing processes are more difficult for manufacturers to reduce. 

Companies have greater options to reduce energy consumption or select from various electricity supply 

choices. Options may include reducing tool-related energy consumption by upgrading and replacing tools 

with more energy-efficient ones and/or implementing smart control systems to regulate operation of support 

facilities and manufacturing equipment for optimal integration and efficiency. Facility-related energy 

consumption can be reduced by implementing greater energy efficiency of buildings and replacing existing 

lighting in fabs with LED fixtures. Facilities can choose to reduce Scope 2 emissions by purchasing 

renewable energy credits or other methods of sourcing lower-carbon or carbon-free electricity (McKinsey, 

2022a). 

The annual total direct GHG emissions across the U.S. semiconductor sector have remained consistent 

between 5.9 and 6.4 MMT a year, with 2019 having the lowest levels (with 47 companies reporting) and 

2021 the highest (with 46 companies reporting). U.S. semiconductor sales grew 5 percent between 2014 

and 2020 adjusted for inflation, which is in line with the relatively flat increase in GHG emissions. Sector 
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GHG emissions will likely increase over the next decade based on the anticipated increase in new fab 

construction to expand semiconductor manufacturing. 

McKinsey predicted (based on a range of macroeconomic assumptions) that semiconductor markets will 

grow by an average of 6 to 8 percent a year up to 2030 (McKinsey, 2022b). Thus, the sector will likely 

increase its global share of GHGs when compared to current levels. Below, Section 4.4 describes the 

industry’s past, present, and future actions to address GHGs and other areas of environmental stewardship.

Applicants are required to submit a Climate and Environmental Responsibility Plan under the Notice of 

Funding Opportunity. Applicants are encouraged to use renewable energy to the maximum extent possible 

for operation of their proposed projects, and applicants constructing new fabs are encouraged to achieve a 

100 percent renewable energy goal through on-site generation, power purchase agreements, or utility green 

tariffs or equivalent approaches. 

A modernization project under the Proposed Action would be relatively minor in size since there would be 

no increase in the existing facility footprint; it would increase GHGs emissions only slightly when 

compared to levels associated with the expected growth of the industry in the U.S. and worldwide. Proposed 

projects receiving CHIPS federal financial assistance would be encouraged to reduce their GHG footprint 

through use of renewable energy and by incorporating more energy efficient manufacturing equipment as 

part of their modernization efforts. Overall, a project funded under the Proposed Action would contribute 

negligible cumulative effects on greenhouse gases and climate change. 

4.4 TRENDS IN CORPORATE RESPONSIBILITY AND ENVIRONMENTAL STEWARDSHIP IN 

THE SEMICONDUCTOR INDUSTRY

Industry organizations, such as the SIA and World Semiconductor Council (WSC), have promoted a variety 

of environmental stewardship programs over the last three decades. For example, under a Memorandum of 

Understanding (MOU) with the U.S. Environmental Protection Agency (EPA) in 2001, SIA members 

voluntarily reported on their emissions of perfluorochemicals (PFCs), a category of GHGs (EPA, 2001b). 

SIA members have reduced their aggregate U.S. emissions of fluorinated gases by more than 50 percent 

from their peak in 1999 under this agreement. Through the WSC, the global industry committed to a 10 

percent reduction of PFCs, and in 2011 the industry announced that it far surpassed this goal and achieved 

a reduction of 32 percent in absolute emissions. To build on this success, the global industry is implementing 

another reduction goal to reduce PFC emission rates by 85 percent by 2030 (with a baseline of 81 percent 

in 2021) (WSC, 2023). 

SIA also provides standards for energy conservation to reduce energy use, costs, and associated GHGs, 

most notably SEMI S23 - Guide for Conservation of Energy, Utilities and Materials Used by Semiconductor 

Manufacturing Equipment (first published in 2005) (Nguyen, 2021). The S23 standard allows device 

manufacturers to compare systems and consider energy efficiency in their equipment selection process, thus 

incentivizing equipment manufacturers to improve the efficiency of their products. It also provides an

objective basis for equipment manufacturers to evaluate their efforts and promote that progress in the 

marketplace (Jones, 2022). Additional SIA standards (E175 and E167) guide communication between 

production equipment and subsystems (vacuum pumps and gas abatement systems) to trigger energy saving 

modes (e.g., sleep modes) when systems are not in use. In 2022, the semiconductor industry formalized a 

commitment to sustainability by launching the Semiconductor Climate Consortium (SCC), governed by 

SIA (Hilson, 2022). The SCC enables members to collaborate and align on common approaches, technology 

innovations, and communications channels to continuously reduce greenhouse gas emissions. Transparency 

will come in the form of publicly reported progress annually, including on both direct and indirect GHG 

emissions. Members are setting near- and long-term decarbonization targets with the aim of reaching net 

zero emissions by 2050. All founding members have affirmed their support of the Paris Agreement – 

adopted in 2015 by 196 Parties at the UN Climate Change Conference (COP21) in Paris, France – the aim 

of which is to hold “the increase in the global average temperature to well below 2°C above pre-industrial 
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levels” and pursue efforts “to limit the temperature increase to 1.5°C above pre-industrial levels” (UNCC, 

No Date). 

SIA also published new and revised standards for water re-use in 2021. The standard provides guidance on 

how to incorporate wastewater segregation and water reuse and recycling into semiconductor tool and 

facility design, and strategies to reduce a facility’s water footprint (Kerr et al., 2021). 

Modernization activities under the Proposed Action would occur at an existing semiconductor site that is 

likely to have a mature environmental program that tracks and discloses environmental performance. 

Semiconductor industry commitments and standards to reduce emissions and water use and increase 

transparency would have beneficial cumulative impacts to the environment over the long term. 

Modernization activities under the Proposed Action would provide further opportunities for a facility to 

reduce its adverse environmental effects. Cumulatively, any changes (positive or negative) of these 

proposed projects to the environment would be minor when compared to the overall expected expansion of 

the U.S. semiconductor sector.

4.5 SUMMARY OF CUMULATIVE EFFECTS

Modernization activities under the Proposed Action would typically occur at an existing, mature 

semiconductor facility that would generally be ‘stand-alone’ and not likely to induce the types of cumulative 

adverse local effects that proposed geographic clusters might. Activities under the Proposed Action would 

likely include minor production increases with resulting minor environmental effects as compared to 

construction of new semiconductor fabrication facilities. A project funded under the Proposed Action could 

streamline production and increase tooling efficiency in line with the latest industry standards that could 

reduce energy and water use, as well as GHG emissions. Industry goals to reduce GHGs and ongoing trends 

to provide standards to reduce energy and water use would cumulatively provide beneficial impacts over 

the long term. Modernization actions under the Proposed Action would provide avenues to improve 

processes that would increase productivity and could also assist companies to meet their environmental 

goals, although any reductions in environmental effects would be minor when compared to the expected 

overall expansion of the industry.
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Guideline for Worker Protection. Accessed December 2023 at: www.semiviews.org. 

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Environmental, Health and Safety Guideline for Semiconductor Manufacturing Equipment. 

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Health & Safety Guideline for Semiconductor Manufacturing Equipment. Accessed September 

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International Studies. October 10. Accessed October 11, 2023 at: 

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(SIA, 2022). Semiconductor Industry Association. 2022. 2022 State of the U.S. Semiconductor Industry. 

Available online at: https://www.semiconductors.org/wp-content/uploads/2022/11/SIA_State-ofIndustry-Report_Nov-2022.pdf. 

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APPENDIX A: ENVIRONMENTAL DUE DILIGENCE PROCESS AND 

BEST MANAGEMENT PRACTICES FOR 

MODERNIZATION AND INTERNAL EXPANSION PROJECTS AT 

EXISTING SEMICONDUCTOR FABRICATION FACILITIES
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APPENDIX A

ENVIRONMENTAL DUE DILIGENCE PROCESS AND BEST 

MANAGEMENT PRACTICES FOR MODERNIZATION AND 

INTERNAL EXPANSION PROJECTS AT SEMICONDUCTOR 

FABRICATION FACILITIES

The environmental review process that the CHIPS Program Office (CPO) completes prior to starting the 

National Environmental Policy Act (NEPA) analysis is discussed in Section 1.0 of the Draft Programmatic

Environmental Assessment (PEA). This includes a merit review evaluation of the Environmental 

Questionnaire that includes 26 questions on the project scope, local environment, potential for 

environmental effects, and permits required for construction of improvements and operation of the upgraded 

facility.

Concurrent with the NEPA review, CPO conducts wider due diligence on the proposed project which 

includes reviewing facility environmental permits. CPO completes a review of the company’s 

environmental compliance status, history, and permitting pathway for the new project as part of due 

diligence. 

The Commercial Fabrication Facilities Notice of Funding Opportunity (NOFO) also requires the

submission of a Climate and Environmental Responsibility Plan that is also evaluated during merit review.

The Climate and Environmental Responsibility Plan must include the following contents according to the 

Commercial Fabrication Facilities NOFO. 

• Energy: A description of how the applicant will use renewable energy to the maximum extent 

possible. Transitioning to a clean energy supply will bring down the long-term cost of operations as 

the cost of using renewable energy decreases.

• Climate Resilience: A description of design features, construction methods, and operation strategies 

that the applicant will employ to increase resilience from weather- and climate-related risks (e.g., 

increased flooding, wildfires) that may occur over the lifetime of the facility.

• Water: A description of the applicant’s water conservation efforts, such as plans to fund water 

restoration projects, increase water reuse and recycle rates year over year, and other progressive 

strategies to achieve more ambitious water conservation goals over time.

• Sustainability Transparency: A description of the metrics and processes the applicant will use to 

measure, track, and report publicly on its climate and environmental responsibility goals and 

commitments.

• Community and Environmental Justice Impacts: A description of the applicant’s strategies for 

minimizing the potential for adverse impacts to the local community, including communities with 

environmental justice concerns.

CPO also evaluates site-specific aspects of a proposed project and provides its own validation of the 

environmental information provided by the applicants for inclusion in the permitting due diligence 

documentation. These additional considerations that are part of due diligence contribute to the development 

of Best Management Practices (BMP) recommendations for individual sites. Site-specific review includes

(where applicable and available), but is not limited to:

• Environmental justice (EJ) local population analysis using U.S. Environmental Protection Agency 

(EPA) EJScreen or other government tools.
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• Identification of Native American Tribes for Government-to-Government consultation, as applicable, 

through Bureau of Indian Affairs (BIA) resources, Housing and Urban Development Tribal Director 

Assessment Tool, or other relevant federal and state resources.

• Identification of whether projects are situated in nonattainment or maintenance areas pursuant to the 

National Ambient Air Quality Standards.

• Compliance history of the facility using the EPA Environmental Compliance History Online (ECHO).

ECHO provides facility-level compliance information with regard to Clean Air Act, Clean Water Act,

Resource Conservation and Recovery Act, and Safe Drinking Water Act, plus Toxic Release 

Inventory history and Clean Water Act Discharge Monitoring Report pollutant loadings.

• Federal, state, and local permitting databases.

• Wetlands inventories per the United States Geologic Survey (USGS) National Wetlands Inventory 

(NWI) database and other federal and state sources.

• Facility greenhouse gas (GHG) reporting through the EPA Greenhouse Gas Reporting Program 

(GHGRP).

• Facility-specific health and safety data or reports (where available). (Note: Enhanced OSHA reporting 

under 29 CFR Part 1904 with public access will commence on January 2, 2024).

• Company websites that may contain published environmental data as well as corporate sustainability 

reports.

• Federal, state, or local climate action plans as they pertain to the project. 

• Federal, state, or local water conservation plans and studies as they pertain to the project.

• Federal, state, or local traffic and transportation studies or plans as they pertain to the project.

Best Management Practices

Some proposed projects may require or include as a matter of practice the application of appropriate 

mitigation measures or BMPs to avoid or minimize environmental effects. 

Below is a list of BMPs that could be applied to semiconductor fabrication facility modernization and 

internal expansion projects categorized by the resource areas discussed in Chapter 3 of the PEA. The use 

of these BMPs will be determined on a project-specific basis. If an applicant proceeds past merit review 

and their project is to be covered under the PEA, CPO would provide a Preliminary Memorandum of Terms 

to include BMPs and best available technologies. Adhering to the BMPs and using the best available 

technologies would be required to remain consistent with the effect determinations described in Chapter 3

of the PEA.
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Table 1. Best Management Practices for Semiconductor Fabrication Facilities

Resource Area(s) Project Phase(s) Best Management Practice

• Climate Change and 

Climate Resilience

• Air Quality

• Utilities

• Planning

• Construction

• Operations

Reduce GHG and air pollutant emissions associated with electricity consumption by 

purchasing renewable energy or carbon-free electricity through Renewable Energy Credits 

or Power Purchase Agreements, or by installing on-site renewable energy projects.

• Climate Change and 

Climate Resilience

• Air Quality

• Utilities

• Planning

• Construction

• Operations

Reduce energy consumption and GHG and air pollutant emissions associated with 

electricity consumption through increased energy-efficiency measures:

• Enhancing building energy-efficiency through LEED design and building energy 

management systems.

• Upgrading/replacing old tools with more energy-efficient ones.

• Optimizing tool processes to reduce power consumption.

• Replacing less-efficient HVAC equipment with more efficient equipment.

• Replacing lighting with LED fixtures.

• Using smart regulation and coupling to increase efficiency between facility operations 

and manufacturing tools and equipment.

• Benchmark facility energy use performance.

• Climate Change and 

Climate Resilience

• Water Quality

• Utilities

• Planning

• Construction

• Operations

Reduce impacts to water supplies by implementing BMPs under EPA’s “WaterSense at 

Work: Best Management for Commercial and Institutional Facilities” (EPA, 2012): 

• Conducting a facility water use assessment.

• Creating an action plan to reduce water losses and increase water efficiency of fixtures, 

equipment, systems, and processes.

• Educating employees about water-saving behaviors.

• Reusing onsite alternative water that would otherwise be discarded or discharged to the 

sewer. 

• Air Quality • Construction Use low sulfur fuels in construction equipment in accordance with Federal, state, or local 

requirements. 

• Air Quality • Construction Reduce fugitive dust by covering exposed material piles, installing wind breaks, water 

spray, street sweeping, and paving frequented haul roads. See EPA’s “Fugitive Dust 

Control Measures and Best Practices” (EPA, 2022d).

• Air Quality • Construction Minimize use of fossil-fueled generators and preferentially use land-based power sources to 

reduce air emissions where practicable. 
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Resource Area(s) Project Phase(s) Best Management Practice

• Air Quality • Construction Ensure adequate maintenance of construction equipment, including proper engine 

maintenance, and proper maintenance of pollution control devices.

• Air Quality • Construction The applicant and its contractors will reduce construction equipment idling to the 

maximum extent practicable.

• Air Quality • Planning

• Construction

• Operations

Implement outgassing abatement systems (such as thermal, catalytic, or plasma systems) to 

reduce process gas emissions for new or existing tools. Consider outgassing systems 

process optimization.

• Water Quality • Planning

• Construction

Incorporate facility effluent segregation processes that allow for enhanced water treatment, 

testing, and recycling.

• Water Quality • Planning

• Construction

Facility compliance with SEMI F98 – Guide for Water Reuse in Semiconductor Industry .

• Water Quality • Construction

• Operations

Implement and maintain BMPs identified in applicable Spill Prevention Control and 

Countermeasure (SPCC) and Stormwater Pollution Prevention Plans (SWP3).

• Human Health and 

Safety

• Planning

• Construction

Limit construction activities, including operation of heavy machinery, to normal business 

hours or hours specified in local noise ordinances.

• Human Health and 

Safety

• Planning

• Construction

Where feasible, avoid engaging in outdoor construction activities within 200 feet of noisesensitive receptors such as schools, hospitals, residential areas, nursing homes, etc.

• Human Health and 

Safety

• Planning

• Construction

Ensure equipment at the project site uses the manufacturer’s standard noise control devices 

(i.e., mufflers, baffling, and/or engine enclosures). 

• Human Health and 

Safety

• Planning

• Construction

When applicable, adopt measures to minimize traffic impacts during construction such as 

providing warning signage, limiting the use of public right-of-ways for staging of 

equipment or materials, use of flag-persons when needed, and coordinating detours if 

traffic access points will be obstructed.

• Human Health and 

Safety

• Planning

• Construction

Implement fencing, signage, and other necessary site safety controls to reduce unauthorized 

access to construction zones. The applicant and its contractors will develop a projectspecific construction safety plan and ensure all workers are trained in its provisions.

• Human Health and 

Safety

• Planning

• Construction

• Operations

Install tools and equipment in accordance with SEMI S2 to addresses environmental, 

health, and safety practices and incorporates several other standards, including but not 

limited to: equipment installation, gas effluent handling, exhaust ventilation, ergonomics, 

risk assessment, equipment decontamination, fire risk mitigation, and electrical design. 
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Resource Area(s) Project Phase(s) Best Management Practice

• Human Health and 

Safety

• Planning

• Operations

Operate tools in accordance with SEMI S21 – Safety Guideline for Worker Protection. S21 

describes methods for protection against hazards that workers may encounter as they work 

on or around equipment used for semiconductor manufacturing.

• Human Health and 

Safety

• Planning

• Construction

Conduct decontamination and removal of manufacturing equipment in accordance with

SEMI S12 and S16. These standards can provide guidance to reduce the environmental 

effects and health and safety risks associated with equipment decommissioning. 

• S12 – Environmental, Health, and Safety Guideline for Manufacturing Equipment 

Decontamination, addresses decontaminating manufacturing equipment and parts that 

were or may have been exposed to hazardous materials and which are intended for 

further productive use. 

• S16 – Guide for Semiconductor Manufacturing Equipment Design for Reduction of 

Environmental Impact at End of Life, provides design guides to minimize environmental 

impacts in consideration of end of life of semiconductor manufacturing equipment or its 

components.

• Hazardous and Toxic 

Materials

• Construction Establish plans to eliminate and minimize oil or fuel spills from construction equipment. 

• Hazardous and Toxic 

Materials

• Construction Properly maintain potential sources of spills and leaks, keeping them in good operating 

condition. Regularly inspect areas where spills might occur to ensure that spill response 

procedures are in view and adequate stocks of cleanup equipment are readily accessible.

• Hazardous and Toxic 

Materials

• Operations Update the facility spill prevention and response plan to reflect changes in hazardous 

materials resulting from facility modernizations and expansions.

• Hazardous and Toxic 

Materials

• Planning

• Construction

• Operations

Install closed loop automated chemical delivery systems to reduce worker exposure to 

hazardous materials. SEMI F22 and F106 present best management practices for chemical 

delivery systems:

• F22 – Guide for Bulk and Specialty Gas Distribution Systems

• F106 – Test Method for Determination of Leak Integrity of Gas Delivery Systems by 

Helium Leak Detector

• Hazardous and Toxic 

Materials

• Planning

• Construction

• Operations

Install and maintain hazardous chemical leak sensors and alarms in accordance with SEMI 

S15 – Safety Guideline for the Evaluation of Toxic and Flammable Gas Detection Systems

and SEMI F1 – Specification for Leak Integrity of High-Purity Gas Piping Systems and 

Components.
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Resource Area(s) Project Phase(s) Best Management Practice

• S15 provides considerations for the evaluation of fixed gas detection systems used to 

monitor for safety of plant personnel, product and materials, the local environment and 

community.

• F1 defines the leak testing requirements and leakage rates for high-purity gas piping 

systems and components used in semiconductor manufacturing.

• Hazardous Waste and 

Solid Waste Management

• Construction

• Operations

Handle, manage, and dispose of all solid and hazardous waste in accordance with 

requirements of local, state, and Federal laws, regulations, ordinances, and industry 

standards. Ensure that all debris is separated and disposed of in a manner that maximizes 

recycling and is consistent with applicable regulations. In accordance with SEMI S12, the 

following should be determined prior to decontamination of the manufacturing equipment:

the anticipated waste stream(s) to be generated; the owner of each waste stream; the proper 

location(s) for reuse, recycling or disposal; responsible party(ies) for packaging and 

removal; and the needs of all parties involved with the handling, storage, and packaging of 

wastes generated during decontamination procedures.

• Hazardous Waste and 

Solid Waste Management

• Operations Eliminate or reduce certain solid waste streams through new and improved technology that 

allows source reduction, reuse, recovery, and closed-loop recycling. In accordance with 

SEMI S2, equipment should be designed to: prevent the mixing of incompatible waste 

streams with partitions, double-contained lines, or other similar design features; prevent 

unintended releases; allow connection to a central waste collection system or segregated 

collection system to facilitate recycling or reuse; and address construction material and 

component reuse, refurbishment, and recycling.

• Environmental Justice

(EJ)

• Planning Identify potential EJ communities and assess any disproportionate health effects the project 

may have on those communities. Conduct community outreach sessions with EJ 

populations to understand their concerns. Develop site-specific impact abatement strategies 

to lessen effects on EJ communities.
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REFERENCES

(EPA, 2012). U.S. Environmental Protection Agency. 2012. WaterSense at Work: Best Management for 

Commercial and Institutional Facilities. Available online at: 

https://www.epa.gov/sites/default/files/2017-02/documents/watersense-at-work_final_508c3.pdf. 

(EPA, 2022d). U.S. Environmental Protection Agency. 2022. Fugitive Dust Control Measures and Best 

Practices. Available online at: https://www.epa.gov/system/files/documents/2022-02/fugitive-dustcontrol-best-practices.pdf. 

(SEMI, 2007). Semiconductor Equipment and Material International. June 2007. SEMI S15 Safety 

Guideline for the Evaluation of Toxic and Flammable Gas Detection Systems. Accessed 

December 2023 at: http://www.semiviews.org. 

(SEMI, 2012a). Semiconductor Equipment and Material International. October 2012. SEMI F106 Test 

Method for Determination of Leak Integrity of Gas Delivery Systems by Helium Leak Detector. 

Accessed December 2023 at: http://www.semiviews.org. 

(SEMI, 2012b). Semiconductor Equipment and Material International. August 2012. SEMI S16 Guide for 

Semiconductor Manufacturing Equipment Design for Reduction of Environmental Impact at End 

of Life. Accessed December 2023 at: http://www.semiviews.org. 

(SEMI, 2015). Semiconductor Equipment and Material International. November 2015. SEMI S12 

Environmental, Health, and Safety Guideline for Manufacturing Equipment Decontamination. 

Accessed December 2023 at: whttp://www.semiviews.org. 

(SEMI, 2018a). Semiconductor Equipment and Material International. May 2018. SEMI F22 Guide for 

Bulk and Specialty Gas Distribution Systems. Accessed December 2023 at: 

http://www.semiviews.org.

(SEMI, 2018b). Semiconductor Equipment and Material International. August 2018. SEMI S21 Safety 

Guideline for Worker Protection. Accessed December 2023 at: http://www.semiviews.org. 

(SEMI, 2021). Semiconductor Equipment and Material International. May 2021. SEMI F1 Specification 

for Leak Integrity of High-Purity Gas Piping Systems and Components. Accessed December 

2023 at: http://www.semiviews.org.

(SEMI, 2023a). Semiconductor Equipment and Material International. September 2023. SEMI F98 Guide 

for Water Reuse in Semiconductor Industry. Accessed December 2023 at:

http://www.semiviews.org. 

(SEMI, 2023b). Semiconductor Equipment and Material International. March 2023. SEMI S2 

Environmental, Health and Safety Guideline for Semiconductor Manufacturing Equipment. 

Accessed December 2023 at: http://www.semiviews.org. 
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APPENDIX B: USE OF PFAS IN SEMICONDUCTOR FABRICATION 

FACILITIES AND EMERGING PFAS STANDARDS
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USE OF PFAS IN SEMICONDUCTOR FABRICATION FACILITIES

AND EMERGING PFAS STANDARDS

INTRODUCTION

Per- and polyfluoroalkyl substances (PFAS) are a group of manufactured organic chemicals composed of a 

chain of carbon-fluorine (C-F) bonds—one of the strongest chemical bonds (AWWA, 2019). There are more 

than 3,000 PFAS manufactured and used in the United States (U.S.). Novel PFAS compounds are frequently

developed in laboratories and manufactured in factories. PFAS are divided into two primary types: longchain, which contain six or more linked carbon atoms and short-chain, which contain fewer than six carbon 

atoms. 

In general, PFAS are highly stable, water- and oil-resistant, and exhibit other properties that make them 

useful in nonstick and water-repellant applications. Due to these properties, PFAS have been widely used 

in various industries and products since the 1940s. PFAs can be found in household items, personal care 

products, food and food packaging, fire extinguishing foam, and manufacturing or chemical production 

facilities(EPA, 2023a). Facilities that manufacture PFAS are referred to as primary manufacturing facilities, 

while facilities that use PFAS to manufacture other products are secondary manufacturing facilities (EPA, 

2023a). 

The characteristic stability of PFAS chemicals also makes them resistant to natural degradation processes, 

including hydrolytic, photolytic, and oxidative reactions, earning them the name "forever chemicals." In 

other words, they are persistent, resisting chemical decomposition or biodegradation. Their subsequent

accumulation in the environment, in ecological food chains, and in organisms is known as bioaccumulation 

(EPA, 2023a). Although they are not naturally occurring, PFAS chemicals can be present in our water, soil, 

air, and food. PFAS can enter the environment via dust, surface water, soil, and groundwater from 

manufacturing and processing, waste disposal, and the use of PFAS-containing products (EPA, 2023a). 

Once in the environment, PFAS may be incidentally inhaled or ingested by animals or humans. Ingestion 

is the primary exposure pathway for the general population (ATSDR, 2019). Dermal absorption of PFAS 

through the skin is possible but limited and is of minimal concern as an exposure pathway (ATDSR, 2019).

Environmental or occupational exposure to certain PFAS may lead to adverse health outcomes (EPA, 

2023a). Human health effects from exposure to certain levels of PFAS may include impacts to reproductive,

immune, and/or endocrine (i.e., hormone) systems, as well as an increased risk of cancer, high cholesterol, 

or obesity (EPA, 2023a). People have higher exposure risk if they work at, live, or recreate near a PFASproducing facility. Pregnant women, lactating women, and children tend to drink more water per pound of 

body weight than the average person and as a result they may have higher PFAS exposure compared to 

other people if it is present in their drinking water. Some PFAS, such as perfluorooctanoic acid (PFOA),

can cross the placenta and enter umbilical cord blood (ATSDR, 2019). Infants and young children can be 

exposed through breast milk, formula, water, or food that contains PFAS, as well as through household 

items and environmental sources (EPA, 2023a). Children exposed to certain levels of PFAS may experience

developmental effects or delays. In the U.S. and other industrialized countries, most people have measurable 

amounts of protein-bound and free PFAS chemicals in their blood (ATSDR, 2019).

Only a small portion of PFAS, primarily PFOA and perfluorooctane sulfonate (PFOS), are well-studied in 

terms of their transport and fate in the environment, exposure to humans and animals, and/or toxicological 

effects in humans and animals. Note that in the U.S. as of 2015, PFOA and PFOS have both been replaced 

with other short-chain PFAS (ATSDR, 2019; EPA, 2023a; HHS, 2023). Like other PFAS, PFOA and PFOS 

are released to the environment in and around primary and secondary manufacturing facilities (ATSDR, 

2019). PFOS has been found in surface water and sediment downstream of manufacturing facilities; in 

wastewater treatment plant effluent and sewage sludge; and in landfill leachate in several U.S. cities. In 

addition, PFOA and PFOS products may contain PFAS precursors in the form of impurities or residuals 
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that can be converted to PFOA or PFOS post-release through biotic or abiotic environmental processes.

PFOA and PFOS have been found in relatively remote areas, including in oceans and the Arctic, suggesting 

the long-range transport potential of PFAS chemicals. PFOS has been shown to bioaccumulate in both 

terrestrial and aquatic animals, but PFOA has been shown to bioaccumulate in terrestrial animals only, 

including humans.

The 2015-2016 National Health and Nutrition Examination Survey (NHANES) found that average blood 

levels of PFOA and PFOS, respectively, in U.S. citizens 12 years and older was 1.56 and 4.72 parts per 

billion (ppb) (ATSDR, 2019). 95% of the U.S. population has PFOA and PFOS blood levels less than 4.2 

and 18.3 ppb, respectively. PFOA and PFOS bind to tissue proteins and accumulate primarily in the blood, 

but also in the liver, kidneys, and brain. Persistence of PFAS chemicals in humans and animals is measured 

as a biological half-life, which is the amount of time in years it takes for half (50 percent) of a particular

chemical to be metabolized and/or eliminated from the body (ATSDR, 2019). The biological half-life of 

PFOA and PFOS, respectively, is approximately 2-10 years and 3-17 years (ATSDR, 2019). Most PFAS are 

not metabolized by the body and are excreted primarily via urine, but also via menstruation, breast milk, 

and feces.

METHODS FOR THE DETECTION OF PFAS IN THE ENVIRONMENT

Due to the large and ever-increasing number and variety of PFAS compounds, the vast majority of PFAS 

are not well researched, making it difficult for governments to set PFAS regulatory limits. Detection of 

PFAS in the environment is difficult and costly because each type of PFAS often requires the development 

and validation of a unique set of detection methodologies. Two EPA detection methods (numbers 537.1 and 

533) can detect up to 43 PFAS compounds (of the more than 3,000 known to exist) in drinking (potable) 

water (EPA, 2023i). Four other EPA methods (numbers 8327, OTM-45, SW-846, and TO-15) are suitable 

for PFAS detection in non-potable water (wastewater, surface or groundwater), and air emissions, including 

volatiles or semi/non-volatiles (EPA, 2023i; EPA, 2023f; MIDEQ, 2014). Table 1 lists all PFAS that can be 

detected in the environment via current EPA Methods; note that available documentation for Methods SW846 and TO-15 does not list specific PFAS chemicals that can be detected using Methods SW-846 and TO15. One method (number 1633) for the detection of PFAS in non-potable water, soil, biosolids (treated 

sewage sludge), sediment, landfill leachate (forms when rainwater filters chemicals out of waste), or fish 

tissue is in development. EPA is considering developing new methods for the detection of PFAS in ambient 

air, as well as methods to quantify large groups of PFAS and PFAS precursors in various environmental 

samples (EPA, 2023i; EPA, 2023d; EPA, 2023e; EPA, 2023g). Once detected in the environment, PFAS 

tend to elude conventional remediation technologies due to their innate chemical properties, requiring the 

development of novel techniques and increasing remediation difficulty, time, and cost (Ross et. al, 2018).

Despite these challenges, the environmental and human health effects of PFAS call for regulatory attention. 

In response to emerging health concerns, the U.S. Environmental Protection Agency (EPA) and state 

agencies are updating and developing additional PFAS standards to regulate the manufacture and use of 

PFAS (EPA, 2023a).
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Table 1. EPA Methods for the Detection of PFAS in the Environment

EPA Method Number(s) Analyte Name Analyte Acronym

Analyte 

CAS 

Number

537.1, 533 11-chloroeicosafluoro-3-oxaundecane-1-sulfonic acid 11Cl-PF3OUdS (F-53B Minor) 763051-92-9

533, 8327, OTM-45 1H,1H, 2H, 2H-Perfluorodecane sulfonic acid 8:2 FTS 39108-34-4

533, 8327, OTM-45 1H,1H, 2H, 2H-Perfluorohexane sulfonic acid 4:2 FTS 4:2FTS

533, 8327, OTM-45 1H,1H, 2H, 2H-Perfluorooctane sulfonic acid 6:2 FTS 27619-97-2

OTM-45 1H,1H,2H,2H-perfluorododecane sulfonate 10:2 FTS 120226-60-0

OTM-45 2-(N-ethylperfluoro-1-octanesulfonamido)-ethanol N-EtFOSE 1691-99-2

OTM-45 2-(N-methylperfluoro-1-octanesulfonamido)-ethanol N-MeFOSE 24448-09-07

OTM-45 2-perfluorodecyl ethanoic acid 10:2 FDEA 53826-13-4

OTM-45 2-perfluorohexyl ethanoic acid 6:2FTCA or 6:2 FHEA 53826-12-3

OTM-45 2-perfluorooctyl ethanoic acid 8:2 FTA or FOEA 27854-31-5

OTM-45 2H-perfluoro-2-decenoic acid 8:2 FTUCA or FOUEA 70887-84-2

OTM-45 2H-perfluoro-2-octenoic acid 6:2 FHUEA 70887-88-6

OTM-45 3:3 Fluorotelomer carboxylic acid 3:3 FTCA 0356-02-05

537.1, 533, OTM-45 4,8-dioxa-3H-perfluorononanoic acid ADONA 919005-14-4

OTM-45 5:3 Fluorotelomer carboxylic acid 5:3 FTCA 914637-49-3

OTM-45 7:3 Fluorotelomer carboxylic acid or 3-perfluoropheptyl

propanoic acid

7:3 FTCA or FHpPA 812-70-4

537.1, 533, OTM-45 9-chlorohexadecafluoro-3-oxanonane-1-sulfonic acid 9Cl-PF3ONS (F-53B Major) 756426-58-1

OTM-45 Decafluoro-4-(pentafluoroethyl)cyclohexanesulfonate) PFecHS 67584-42-3

537.1, 533, OTM-45 Hexafluoropropylene oxide dimer acid HFPO-DA (Gen X) 13252-13-6

537.1 N-ethyl perfluorooctanesulfonamidoacetic acid NEtFOSAA 2991-50-6

OTM-45 N-ethyl perfluorooctanesulfonamidoacetic acid EtFOSAA 2991-50-6

8327 N-ethylperfluoro-1-octanesulfonamidoacetic acid N-EtFOSAA 2991-50-6

OTM-45 N-ethylperfluorooctanesulfonamide EtFOSA 4151-50-2

537.1 N-methyl perfluorooctanesulfonamidoacetic acid NMeFOSAA 2355-31-9

OTM-45 N-methyl perfluorooctanesulfonamidoacetic acid MeFOSAA 2355-31-9

8327 N-methylperfluoro-1-octanesulfonamidoacetic acid N-MeFOSAA 2355-31-9
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EPA Method Number(s) Analyte Name Analyte Acronym

Analyte 

CAS 

Number

OTM-45 N-Methylperfluorooctanesulfonamide MeFOSA 31506-32-8

533, OTM-45 Nonafluoro-3,6-dioxaheptanoic acid NFDHA 151772-58-6

8327, OTM-45 Perfluoro-1-decanesulfonic acid PFDS 335-77-3

8327, OTM-45 Perfluoro-1-nonanesulfonic acid PFNS 68259-12-1

8327 Perfluoro-1-octanesulfonamide PFOSA 754-91-6

OTM-45 Perfluoro-1-octanesulfonamide FOSA 754-91-6

533, OTM-45 Perfluoro-3-methoxypropanoic acid PFMPA 377-73-1

533, OTM-45 Perfluoro-4-methoxybutanoic acid PFMBA 863090-89-5

OTM-45 Perfluoro-n-hexadecanoic acid PFHxDA 67905-19-5

OTM-45 Perfluoro-n-octadecanoic acid PFODA 16517-11-6

533, OTM-45 Perfluoro(2-ethoxyethane)sulfonic acid PFEESA 113507-82-7

537.1, 533, 8327, OTM-45 Perfluorobutanesulfonic acid PFBS 375-73-5

533, 8327, OTM-45 Perfluorobutanoic acid PFBA 375-22-4

537.1, 533, OTM-45 Perfluorodecanoic acid PFDA 335-76-2

OTM-45 Perfluorododecane sulfonate PFDoS 79780-39-5

537.1, 533, OTM-45 Perfluorododecanoic acid PFDoA 307-55-1

8327 Perfluorododecanoic acid PFDoDA 307-55-1

533, 8327, OTM-45 Perfluoroheptanesulfonic acid PFHpS 375-92-8

537.1, 533, OTM-45 Perfluoroheptanoic acid PFHpA 375-85-9

537.1, 533, 8327, OTM-45 Perfluorohexanesulfonic acid PFHxS 355-46-4

537.1, 533, 8327, OTM-45 Perfluorohexanoic acid PFHxA 307-24-4

537.1, 533, 8327, OTM-45 Perfluorononanoic acid PFNA 375-95-1

537.1, 533, 8327, OTM-45 Perfluorooctanesulfonic acid PFOS 1763-23-1

537.1, 533, 8327, OTM-45 Perfluorooctanoic acid PFOA 335-67-1

533, 8327, OTM-45 Perfluoropentanesulfonic acid PFPeS 2706-91-4

533, 8327, OTM-45 Perfluoropentanoic acid PFPeA 2706-90-3

537.1 Perfluorotetradecanoic acid PFTA 0376-06-07
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EPA Method Number(s) Analyte Name Analyte Acronym

Analyte 

CAS 

Number

8327, OTM-45 Perfluorotetradecanoic acid PFTeDA 0376-06-07

537.1, 8327, OTM-45 Perfluorotridecanoic acid PFTrDA 72629-94-8

537.1, 533 Perfluoroundecanoic acid PFUnA 2058-94-8

8327, OTM-45 Perfluoroundecanoic acid PFUnDA 2058-94-8

Sources: EPA, 2023i; EPA, 2023d; EPA, 2023e; EPA, 2023g
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PFAS IN SEMICONDUCTOR FABRICATION FACILITIES

Semiconductor fabrication facilities use PFAS as an essential material in several steps in the fabrication 

process. Semiconductor device fabrication is a highly specialized manufacturing process, the steps of which

vary depending on the manufacturer and the type of chip being produced. However, all manufacturers use 

PFAS in multiple steps within the fabrication process (Isaacs, 2023). Table 2 summarizes the key PFAS use 

applications in semiconductor fabrication. The general process for semiconductor manufacturing is broken 

down into six general steps: deposition, photoresist coating, lithography, etching, ion implantation, and 

packaging. Of the six steps, PFAS are utilized during the photoresist coating, lithography, etching, and 

packaging steps. Photoresist coating is the application of a light-sensitive coating, known as photoresist, to 

the wafer. Lithography involves exposing the photoresist to an ultraviolet light (UV) patterned blueprint – 

changing the solubility of the exposed photoresist. After lithography, the wafer is etched to partially remove 

the photoresist to define the now-exposed pattern. Etching is typically wet or dry; in wet etching, the wafer 

is washed in a chemical bath, while dry etching uses gases to define the exposed pattern. The final step, 

packaging, includes the separation of each chip from the wafer, the addition of baseboards substrates to the 

chips, the topping of the chips with heat-dissipating elements, and the packaging of the chips for distribution 

to clients (Timings, 2021). 

While PFAS are used throughout the semiconductor fabrication process, the most abundant use occurs 

during photolithography, which includes the photoresist coating, lithography, and etching steps (Jones, 

2022; Timings, 2021). Two crucial PFAS-containing substances used in photolithography include photoacid generators (PAGs) and top antireflective coatings (TARCs), the largest single source of PFAS in 

semiconductor manufacturing. PAGs are used in chemically amplified photoresists (CAP), a necessary 

component for the manufacturing of advanced semiconductors (Ober et al., 2022). PAGs utilize fluorine to 

enable greater solubility and development during the etching process. PAGs use short-chain perfluoroalkyl 

acid compounds (fewer than four C-F bonds) (Jones, 2022). TARCs are applied in conjunction with 

photoresist coatings. TARCs eliminate UV reflections to increase the precision of lithography (Ober et al., 

2022). TARCs must not intermix with the photoresist and must be easily removed; various specialized PFAS 

enable these properties (Jones, 2022; Hsu et al., 2008). Supplementary examples of PFAS usage during 

photolithography include providing thermal stability and low surface energy to substances and acting as 

surfactants (leveling agents) to improve coating uniformity (Jones, 2022; SEMI, No date). 

Beyond photolithography, PFAS are used in various direct and indirect processes during semiconductor 

fabrication. Two Toxic Substances Control Act (TSCA)-listed PFAS, hexafluoroethane (CAS number 76-

16-4)) and perfluorocyclobutane (CAS number 115-25-3) are used for etching (EPA, 2023j). In the 

packaging step, PFAS-containing, heat-dissipating elements such as fluorinated heat transfer fluids (F-HTF) 

are used for their ability to be simultaneously electrically non-conductive, compatible with all materials of 

construction including sensitive electrical components, within suitable toxicity and flammability limits, and 

resistant to catastrophic contamination (Jones, 2022). The packaging of chips for distribution additionally 

uses PFAS materials to seal against moisture, provide environmental and mechanical isolation and stability, 

and reduce stress on solder joints. Packaging uses PFAS in some packaging flux (a liquid used to eliminate 

oxides and other contaminants) surfactants, and adhesives. PFAS can also be present in manufacturing 

equipment, such as high-purity water distribution systems (Jones, 2022). Three additional TSCA-listed 

PFAS, hexafluorocyclobutene (CAS number 697-11-0), octaflurorcyclopentene (CAS number 559-40-0), 

and polytetrafluoroethylene (CAS number 9002-84-0), are used in miscellaneous semiconductor fabrication 

processes (EPA, 2023a). 

Wastewater discharge from semiconductor manufacturing facilities presents the greatest risk for PFAS 

contamination of the environment. While most photolithography waste is handled as a solvent and 

incinerated, only 40 percent of TARC waste is treated. TARCs currently account for over 50 percent of total 

PFAS used in photolithographic processes worldwide and thus contribute a large portion of the PFAS found 

in wastewater discharges. Worldwide PFAS discharges from photolithography are estimated to be between 

2,830 and 38,400 pounds/year (Jones, 2022). Currently, semiconductor fabrication facilities use onsite 
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abatement systems for air emissions and wastewater pretreatment or treatment systems before discharging 

wastewater; however, the industry is actively continuing to research PFAS treatment technologies for 

wastewater. Furthermore, analytical methods for the detection of PFAS compounds in wastewater are 

needed to determine the removal efficiency of such treatment technologies. The current detection methods 

are limited to a few PFAS compounds (Jones, 2022). 

Over the past two decades, the semiconductor manufacturing industry has replaced or reduced the use of 

certain PFAS. Long-chain PFAS compounds, such as PFOS, have been replaced by short-chain PFAS. 

Another long-chain PFAS, PFOA, was phased out in the U.S. by 2015 and is projected to be eliminated 

globally by 2025 (EPA, 2022; WSC, 2018). Additionally, the global semiconductor industry has worked to 

limit non-essential uses of PFAS. However, PFAS compounds are challenging to replace entirely. Due to 

the chemical stability of PFAS there are currently few adequate substitutes for PFAS in semiconductor 

fabrication (SEMI, No date). In most photolithography processes, PFAS-free alternatives are expected to 

take from 15 to 20 years to develop while PAGs are projected to take more than 25 years (Jones, 2022). 

FEDERAL PFAS REGULATIONS

At the federal level, there are several proposed and upcoming regulations pertaining to the use and 

environmental release of PFAS by industrial facilities.

WASTEWATER

In January of 2023, EPA released Effluent Guidelines Program Plan 15 (Plan 15), which describes analyses, 

studies, and rulemakings related to effluent limitations guidelines and pretreatment standards. Notably, Plan 

15 details EPA’s intent to collect and publish nationwide data on industrial discharges of PFAS to publiclyowned treatment works (POTWs) in a POTW Influent Study. In addition, EPA will continue monitoring the 

Electrical and Electronic Components (E&EC) Category for PFAS discharge data through implementation 

of the POTW Influent Study. The POTW Influent Study will help EPA verify sources of PFAS wastewater 

and assess the need for control measures at the source (EPA, 2023j; EPA, 2022). 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 (EPA, 2022).

DRINKING WATER

In March of 2023, EPA proposed the National Primary Drinking Water Regulation (NPDWR) to establish 

federally enforceable standards for six types of PFAS known to occur in drinking water (88 FR 18638): 

• PFOA; 

• PFOS; 

• perfluorononanoic acid (PFNA); 

• hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX Chemicals); 

• perfluorohexane sulfonic acid (PFHxS); and 

• perfluorobutane sulfonic acid (PFBS). 

EPA anticipates finalizing the rule by the end of 2023 (EPA, 2023h). In 2022, EPA also established nonregulatory, non-enforceable interim drinking water health advisories for four PFAS: PFOA, PFOS, 

hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (known as GenX Chemicals), and 

perfluorobutane sulfonic acid (PFBS) and its related compound potassium perfluorobutane sulfonate (EPA, 

2023b). The purpose of drinking water health advisories is to provide information on contaminants that can 

cause human health effects and are known or anticipated to occur in drinking water. 
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TSCA

In October of 2023, EPA published a final rule under TSCA requiring any person who, since January 1, 

2011, has manufactured or imported PFAS or PFAS-containing articles to report usage, production volume, 

disposal, exposure, and hazard information to EPA (EPA, 2023c).

EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT (EPCRA)

EPA released a final rule under EPCRA and the Pollution Prevention Act pursuant to the National Defense 

Authorization Act for Fiscal Year 2020 that added certain PFAS to the list of Lower Thresholds for 

Chemicals of Special Concern (EPA, 2023c). This rule, effective on November 30, 2023, will increase

reporting of PFAS to the Toxics Release Inventory (TRI) by eliminating an exemption (de minimis) that 

allowed facilities to avoid reporting information on PFAS when those chemicals were used in small 

concentrations. Under this new rule, certain PFAS will be subject to the same reporting requirements as 

other chemicals of special concern and EPA will receive more comprehensive data on PFAS. Chemicals of 

special concern are excluded from the de minimis exemption, may not be reported on Form A (Alternate 

Threshold Certification Statement), and have limits on the use of range reporting.

STATE PFAS STANDARDS

Many states have already implemented restrictions or set standards for use of PFAS in product 

manufacturing and to regulate concentrations of PFAS in drinking water by parts per trillion (ppt) (NCSL, 

2023). These states include Alaska, Arizona, California, Colorado, Connecticut, Delaware, Illinois, Iowa, 

Kentucky, Maine, Massachusetts, Michigan, Minnesota, New Hampshire, New Jersey, New Mexico, New 

York, North Carolina, Ohio, Rhode Island, Vermont, and West Virginia. Some states also have begun to 

monitor for PFAS in industrial wastewater effluent. North Carolina requires PFAS monitoring of POTW 

influent, and Hillsboro, Oregon, has established quarterly PFAS sampling requirements for industrial 

dischargers. In addition, EPA identified one permit issued in 2021 by the Vermont Department of 

Environmental Conservation to GlobalFoundries that includes quarterly PFAS monitoring requirements for 

the first year and annual PFAS monitoring beginning in 2022 (EPA, 2022). Current standards for states in 

which semiconductor fabrication facilities may be modernized using Creating Helpful Incentives to 

Produce Semiconductors (CHIPS) and Science Act of 2022 grant funding are listed in Table 3.
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Table 2. Key PFAS Use Applications in Semiconductor Fabrication

Semiconductor 

Fabrication Process(es)

Use Application 

for PFAS Function

Types of PFAS-Containing 

Materials in Use PFAS Criticality

Photolithography PAGs Precursor for the photoacid catalyst needed for 

CARs, barrier layer 

polymers (PBO/PI), 

bottom anti-reflective 

coatings (BARCs), and 

color filter resists. 

Perfluoroalkyl-sulfonates C4 

or lower and C4 or lower 

substituted superacid anions, 

such as C1. For some 

advanced resists, these are 

bound to polymers. 

PFAS component of PAGs 

generates strong acids that do not 

show side reactions that interfere 

with the chemical amplification 

process. 

Photolithography Photoresists –

polymers 

Control pattern profile in 

extreme ultraviolet (EUV) 

lithography. 

C1 PFAS polymer Increases absorbance, improves 

dissolution properties, and 

increases resolution. 

Photolithography Pattern collapse 

mitigation/

EUV anti-collapse 

rinses 

Prevent pattern collapse. PFAS-containing materials 

are used in a number of 

different formulations that 

are used to mitigate pattern 

collapse issues, including 

fluorinated surfactants, 

surface modification 

treatment materials, 

displacement fluids, and 

organic solvents.

Low surface tension and high 

contact angle to reduce capillary 

forces. 

Photolithography TARCs Control of thin film 

interference effects in 

resists. 

Fluorinated water and 

developer-soluble polymers

High fluorine content is needed 

to achieve the low refractive 

index needed to effectively 

suppress film interference 

effects. 
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Semiconductor 

Fabrication Process(es)

Use Application 

for PFAS Function

Types of PFAS-Containing 

Materials in Use PFAS Criticality

Photolithography Surface 

protectors/

immersion 

barriers 

(immersion 

topcoats) 

Protection of the resist 

from immersion liquid and 

of the exposure process 

equipment from 

contamination. Prevent 

water film pulling and 

resist component leaching 

in immersion topcoats. 

Spin-on barriers: waterinsoluble and developersoluble polymers with 

fluorinated side chains. 

Embedded barriers (in situ 

top coats): oligomeric or low 

molecular weight polymeric 

highly fluorinated 

compounds. Fluoroalcohol 

methacrylate polymers with 

high water contact angles 

(>90o). 

Soluble in casting solvents and 

developer, insoluble in water, 

and do not intermix with 

photoresists. 

Hydrophobicity and control of 

contact angle, inertness under 

193 nanometer (nm) radiation, 

and transparency. 

Photolithography Surfactants Improved coating 

uniformity in photoresists, 

PBO/PI, BARCs, and color 

filter resists.

Longer-chain PFAS (C6-C8) 

and telomer alcohols form 

polymer backbones. Now 

mostly replaced by C4 

pendant chains. 

Low surface tension and control 

of contact angle. 

Photolithography PBO/PI Provide protection from 

electrical, thermal, 

mechanical, and moisturerelated impacts. 

Water-insoluble C1 PFAS 

polymers

C1 PFAS groups, attached to the 

polymer backbone, provide 

solubility in environmentallyfriendly casting solvents and 

enable aqueous development. 

Plasma etch, chamber 

clean, and deposition

Back end of line 

(BEOL) 

interconnect 

patterning

(damascene 

process) 

Definition of trench and 

via patterns in dielectric 

films before filling with 

metal.

Octafluorocyclobutane 

(C4F8)/(RC318)

Hexafluoro-1,3-butadiene 

(C4F6)

Tetrafluoromethane 

(CF4)/(R14)

Trifluoromethane 

(CHF3)/(R23)

Selectivity to mask materials, 

selectivity to different dielectrics 

(ability to stop on certain layers), 

and profile control of trench/via 

sidewalls.
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Semiconductor 

Fabrication Process(es)

Use Application 

for PFAS Function

Types of PFAS-Containing 

Materials in Use PFAS Criticality

Plasma etch, chamber 

clean, and deposition

High-aspect-ratio 

channel (3D 

NAND) 

Definition of ultra-highaspect-ratio channel in 

multiple dielectric layers.

C4F8

C4F6

CF4

CHF3

Selectivity to mask materials, 

selectivity to different 

dielectrics, profile control of 

channel, and high-etch-rate 

anisotropic process.

Plasma etch, chamber 

clean, and deposition

Waveguide 

fabrication in 

silicon photonics 

processes 

Patterning of waveguides 

into silicon and siliconbased dielectric materials.

CF4

CHF3

Selectivity to mask materials and 

ability to reduce line-edge and 

line-width roughness of 

patterned features to reduce 

transmission losses caused by 

scattering.

Plasma etch, chamber 

clean, and deposition

Front end of line 

(FEOL) hard 

mask patterning 

Transfers lithographic 

patterns into a hard mask 

for subsequent definition 

of transistors.

CF4

CHF3

Selectivity to mask materials, 

ability to reduce line-edge and 

line-width roughness of 

patterned features to reduce 

transmission losses caused by 

scattering, and ability to detect 

process endpoints from the 

optical emission signature of 

carbon-containing byproducts 

such as C-O and C-N.

Plasma etch, chamber 

clean, and deposition

FEOL spacer 

patterning

Define spacer structures 

(dielectric encapsulation 

that protects the sidewalls 

of transistor features).

CHF3 High selectivity to transistor gate 

materials and underlying 

substrate.

Plasma etch, chamber 

clean, and deposition

Through-silicon 

via etch

Create deep via structures 

through entire wafers for 

packaging applications.

C4F8

C4F6

Thermal resistance, inertness 

toward aggressive chemicals, 

nonflammability, low vapor 

pressure and off-gassing at high 

operating temperatures and low 

pressures, and good stick-slip 

behavior.
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Semiconductor 

Fabrication Process(es)

Use Application 

for PFAS Function

Types of PFAS-Containing 

Materials in Use PFAS Criticality

Plasma etch, chamber 

clean, and deposition

Cleaning 

processes for 

chemical vapor 

deposition (CVD) 

and physical 

vapor deposition 

(PVD) chambers 

Remove deposit buildup 

on chamber walls to ensure 

reproducibility and prevent 

yield loss caused by 

contamination.

CF4

Hexafluoroethane 

(C2F6)/(R116)

Octafluoropropane 

(C3F8)/(R-218)

N/A

Plasma etch, chamber 

clean, and deposition

Deposition 

precursors for 

atomic layer 

deposition (ALD)

Improved volatility and 

stability of ligands for the 

uniformity of metal 

deposition and 

reproducibility of 

processes.

Transition metal compounds 

containing the tfac (1,1,1-

trifluoro-2,4-pentanedionate) and hfac 

(1,1,1,5,5,5-hexafluoro- 2,4-

pentane-dionate) ligands

No known viable alternatives.

Plasma etch, chamber 

clean, and deposition

Surface treatment 

processes for areaselective ALD 

processes

Remove metal-oxide 

contaminants from 

surfaces before deposition.

N/A Unknown

Miscellaneous wet 

chemical processes 

(wet chemical etching; 

planarization; 

electroplating; and wafer 

cleaning, rinsing and 

drying)

Wet etching Facilitate entry of the wet 

etchant into - and reaction 

products out of - a 

capillary space by reducing 

the surface tension of the 

fluid and the contact angle 

with the solid. Adsorb to a 

surface to prevent the 

deposition of metals that 

are introduced into the 

solution during an etching 

process or to suppress 

etching of one material 

while another material is 

preferentially removed. 

Aqueous etch/clean 

formulations 

Organic-based etch 

formulations

PFAS additives are critical for 

some, but not all wet-etch 

applications. The requirement for 

a PFAS additive depends on the 

physical dimensions and aspect 

ratio of the device feature being 

etched, and the particular set of 

materials exposed to the etchant 

during etching. 
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

B-14

Semiconductor 

Fabrication Process(es)

Use Application 

for PFAS Function

Types of PFAS-Containing 

Materials in Use PFAS Criticality

Mitigate the formation of 

air bubbles. 

Miscellaneous wet 

chemical processes 

Chemical 

mechanical 

planarization 

(CMP) 

Surfactants and surfaceactive materials disperse 

the particles, provide 

slurry stability, control the 

wettability of films and 

polishing pads, and reduce 

corrosion.

Oxide CMP slurries

Metal CMP slurries

Post-CMP cleaning solutions

Fluorinated surfactants are 

critical to achieving CMP 

performance requirements in 

certain situations. In particular, 

they enable selective film 

inhibition and the wetting of 

low-surface-energy substrates. 

Miscellaneous wet 

chemical processes 

Cleaning/

stripping

Some wafer clean/strip 

formulations and cleaning 

operations conducted on 

parts outside of clean 

rooms require organic 

solvents to provide the 

necessary solvency and 

fluid-handling 

characteristics. 

In some applications, these 

mixtures comprise 

fluorinated organic solvents 

and/or fluorinated organic 

alternatives.

PFAS-containing solvent 

mixtures are critical for some, 

but not all solvent-clean 

applications. The requirement for 

a PFAS depends on the material 

properties of the substance that 

needs removing. 

Miscellaneous wet 

chemical processes 

Plating and 

electroless plating 

Surfactants and surfaceactive materials reduce 

surface tension to improve 

wetting and access to the 

plating bath solution; and 

mitigate hydrogen gas 

inclusion and bubble 

and/or mist formation.

Fluorinated surfactants Fluorinated surfactants can 

achieve low aqueous surface 

tensions. Fluoroalkyl acid 

surfactants are uniquely strong 

acids that remain ionized and 

hydrophilic even if the pH of the 

plating solution approaches zero. 
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

B-15

Semiconductor 

Fabrication Process(es)

Use Application 

for PFAS Function

Types of PFAS-Containing 

Materials in Use PFAS Criticality

Lubrication Oils and greases 

in vacuum pumps 

Effective lubrication of 

bearings, gears, and seals.

Perfluoropolyether (PFPE) 

oil

Greases containing PFPE 

base oils with 

polytetrafluoroethylene 

(PTFE) thickener

Thermal resistance, inertness 

toward aggressive chemicals, 

nonflammability, low vapor 

pressure and outgassing at high 

operating temperatures and low 

pressures, stability under high 

shear forces, low aggression to 

metals and elastomers. No 

known viable alternative for 

PTFE-thickened greases 

Lubrication Greases and solids 

used in vacuum 

processing 

environments 

Lubrication within lowpressure and hightemperature environments 

that require high purity for 

low wafer contamination.

Greases containing PFPE 

base oils with PTFE 

thickener

Greases containing multiplyalkylated cyclopentane 

(MAC) base oils with PTFE 

thickener

PTFE in solid lubricants

Thermal resistance, inertness 

toward aggressive chemicals, 

nonflammability, low vapor 

pressure and outgassing at high 

operating temperatures and low 

pressures, complete oxidation 

resistance, and good stick-slip 

behavior. No known viable 

alternative for PTFE-thickened 

greases and PTFE solids.

Lubrication Greases and solids 

used to lubricate 

robotic systems, 

O-rings, and seals

Effective lubrication and 

sealing within lowpressure and hightemperature environments 

that require high purity for 

low wafer contamination.

Greases containing PFPE 

base oils with PTFE 

thickener

PTFE in solid lubricants

Thermal resistance, inertness 

toward aggressive chemicals, 

nonflammability, low vapor 

pressure and outgassing at high 

operating temperatures and low 

pressures, complete oxidation 

resistance, and good stick-slip 

behavior. No known viable 

alternative for PTFE-thickened 

greases and PTFE solids.
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

B-16

Semiconductor 

Fabrication Process(es)

Use Application 

for PFAS Function

Types of PFAS-Containing 

Materials in Use PFAS Criticality

Lubrication Greases used in 

photo-lithography 

applications

Effective lubrication of 

moving parts within 

environments exposed to 

UV light.

Greases containing PFPE 

base oils with PTFE 

thickener

Low outgassing and UV stability. 

No known viable alternative for 

PTFE- thickened greases.

Lubrication Greases used to 

lubricate gears 

and bearings

Effective lubrication. Greases containing PFPE 

base oils with PTFE 

thickener

Thermal resistance, inertness 

toward aggressive chemicals, 

nonflammability, low vapor 

pressure and outgassing at high 

operating temperatures and low 

pressures, stability under high 

shear forces, and low aggression 

to metals and elastomers. No 

known viable alternative for 

PTFE- thickened greases

Lubrication Greases and solids 

used to lubricate 

linear guides, 

slides, ball screws, 

and valves

Effective lubrication of 

mechanical parts that move 

at high speeds within 

environments that require 

high purity for low wafer 

contamination. 

Greases containing PFPE 

base oils with PTFE 

thickener

PTFE in solid lubricants

Thermal resistance, inertness 

toward aggressive chemicals, 

nonflammability, low vapor 

pressure and outgassing at high 

operating temperatures and low 

pressures, and good stick-slip 

behavior. No known viable 

alternative for PTFE-thickened 

greases and PTFE solids.
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

B-17

Semiconductor 

Fabrication Process(es)

Use Application 

for PFAS Function

Types of PFAS-Containing 

Materials in Use PFAS Criticality

Heating and cooling Heat transfer 

fluids (HTFs)

Fluorinated- HTFs (FHTFs) are used to transfer 

heat between process 

equipment and chillers to 

provide precise 

temperature control for 

specific manufacturing 

operations.

F-HTF classes include:

• PFPEs

• Perfluorocarbons (PFCs)

• Hydrofluorocarbons 

(HFCs)

• Hydrofluoroethers (HFEs)

• Hydrofluoroolefins 

(HFOs)

• Fluorinated ketones

• Other fluorinated liquids

F-HTFs are electrically 

nonconductive, compatible with 

all construction materials 

including sensitive electrical 

components, nonflammable, and 

useful within the operational 

range required for the 

manufacturing and testing of 

semiconductor products. No 

known viable alternative can 

meet all these requirements at 

once.

Heating and cooling Refrigerants Fluorinated refrigerants are 

used within closed systems 

that undergo repeated 

phase changes to help 

transfer heat from process 

equipment to a facility’s 

central cooling system.

Fluorinated refrigerant 

classes include:

• PFCs

• HFCs

• HFOs

• Fluorinated ketones

• Other fluorinated liquid

The most critical performance 

requirement of the refrigerant is 

the ability to maintain the lowest 

operational set point while 

avoiding a catastrophic phase 

shift to a solid form, as the 

refrigerant must remain in a 

gaseous or liquid form to remain 

pumpable and useful for 

temperature control.

Sources: SIA, 2023a; SIA, 2023b; SIA, 2023c; SIA, 2023d; SIA, 2023e
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

B-18

Table 3. State PFAS Standards

State Regulatory Authority Drinking Water Standards

Arizona None None

Colorado Colorado PFAS Policy 20-1

5 Colorado Code of Regulation (CCR)

1002-31, Section 31.11(1)(a)(iv) and 5 

CCR 1002-41, Section 41.5(A)(1)

PFBS: 400,000 ppt

PFHxS: 700 ppt

PFNA, PFOA, and PFOS

(combined): 70 ppt

Idaho None None

Kansas None None

Minnesota Minnesota’s PFAS Blueprint PFBA: 2,000 ppt

PFBS: 4,000 ppt

PFHxS: 47 ppt

PFOA: 35 ppt

PFOS: 15 ppt

New Hampshire New Hampshire House Bill 1264 PFHxS: 18 ppt

PFNA: 11 ppt

PFOS: 15 ppt

PFOA: 12 ppt 

New York Public Water Systems and New York 

State (NYS) Drinking Water Standards 

for PFAS and Other Emerging 

Contaminants

1,4-dioxane: 1,000 ppt

PFAS: 10 ppt

PFOA: 10 ppt

Ohio Ohio PFAS Action Plan for Drinking 

Water

HFPO-DA: 21 ppt

PFBS: 2,100 ppt

PFHxS: 140 ppt

PFNA: 21 ppt

PFOA and PFOS (combined): 70 ppt

Oregon Unregulated Contaminant Monitoring 

Rule (UCMR3)

PFHxS, and PFNA, PFOA, and 

PFOS, (combined): 30 ppt

Texas None None

Utah None None

Vermont Act 21 (Senate Bill 49): Vermont 2019 

PFAS Law

Perfluoroheptanoic acid (PFHpA), 

PFHxS, PFNA, PFOA, PFOS

(combined): 20,000 ppt

Sources: BCLP, 2022; MNPCA, No date; NHGC, 2020; NYSDOH, 2022; NCSL, 2023; OHEPA, No date; ORHA, No date;

TriHydro, 2023; and VTGA, 2019.
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

B-19

ACRONYMS

3D NAND high-aspect-ratio channel 

ALD atomic layer deposition

BEOL back end of line 

BARC bottom anti-reflective coating

CAP chemically amplified photoresists

CAS Chemical Abstracts Service

CCR Colorado Code of Regulations 

CHIPS Creating Helpful Incentives to Produce Semiconductors 

CMP chemical mechanical planarization

CVD chemical vapor deposition

C-F carbon-fluorine 

EPA United States Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act

EUV extreme ultraviolet 

FEOL front end of line 

F-HTF fluorinated heat transfer fluids

HFC hydrofluorocarbon 

HFE hydrofluoroether 

HFO hydrofluoroolefins

HFPO-DA hexafluoropropylene oxide dimer acid

HTF heat transfer fluid

MAC multiply-alkylated cyclopentane 

NHANES National Health and Nutrition Examination Survey 

nm nanometer 

NYS New York State

PAG photo-acid generator

PBO/PI barrier layer polymers 

PFAS Per- and Polyfluoroalkyl Substances 

PFBS perfluorobutane sulfonic acid

PFC perfluorocarbon 

PFHpA perfluoroheptanoic acid 

PFHxS perfluorohexane sulfonic acid

PFNA perfluorononanoic acid 
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

B-20

PFOA perfluorooctanoic acid

PFOS perfluorooctane sulfonate

PFPE Perfluoropolyether 

POTW publicly-owned treatment works

Ppb parts per billion

ppt parts per trillion

PTFE polytetrafluoroethylene

PVD physical vapor deposition

TARC top antireflective coating

TSCA Toxic Substances Control Act

UCMR3 Unregulated Contaminant Monitoring Rule

U.S. United States

UV ultraviolet light
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

B-21

REFERENCES

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Science and Guidance for Clinicians on Per- and Polyfluoroalkyl Substances (PFAS). Available 

online at: https://www.atsdr.cdc.gov/pfas/docs/clinical-guidance-12-20-

2019.pdf#:~:text=Most%20PFAS%20are%20not%20volatile%20so%20showering%20does,is%2

0of%20minimal%20concern%20as%20an%20exposure%20route. 

(AWWA, 2019). American Water Works Association. 2019. Per- and Polyfluoroalkyl Substance (PFAS). 

Accessed September 2023 at https://www.awwa.org/Portals/0/AWWA/ETS/Resources/PerandPolyfluoroalkylSubstances(PFAS)-OverviewandPrevalence.pdf?ver=2019-08-14-090234-

873.

(BCLP, 2022). Bryan Cave Leighton Paiser. 2022. PFAS Update: State-By-State Regulation of PFAS 

Substances Iin Drinking Water. Accessed September 2023 at: https://www.bclplaw.com/enUS/events-insights-news/pfas-update-state-by-state-regulation-of-pfas-substances-in-drinkingwater.html.

(EPA, 2022). Electrical & Electronic Components (40 CFR Part 469) Detailed Study Report. Available 

online at: https://www.epa.gov/system/files/documents/2023-01/11197_EEC Study 

Report_508.pdf. 

(EPA, 2023a). U.S. Environmental Protection Agency. 2023. Our Current Understanding of the Human 

Health and Environmental Risks of PFAS. Accessed September 2023 at:

https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas.

(EPA, 2023b). U.S. Environmental Protection Agency. 2023. Drinking Water Health Advisories for 

PFOA and PFOS. Accessed November 2023 at: https://www.epa.gov/sdwa/drinking-waterhealth-advisories-pfoa-and-pfos. (EPA, 2023c). U.S. Environmental Protection Agency. 2023. 

Key EPA Actions to Address PFAS. Accessed November 2023 at: https://www.epa.gov/pfas/keyepa-actions-address-pfas.

(EPA, 2023d). U.S. Environmental Protection Agency. 2023. Method 533: Determination of Per- and 

Polyfluoroalkyl Substances in Drinking Water by Isotope Dilution Anion Exchange Solid Phase 

Extraction and Liquid Chromatography/Tandem Mass Spectrometry. Accessed November 2023 

at: https://www.epa.gov/dwanalyticalmethods/method-533-determination-and-polyfluoroalkylsubstances-drinking-water-isotope.

(EPA, 2023e). U.S. Environmental Protection Agency. 2023. Method 537.1: Determination of Selected 

Per- and Polyfluorinated Alkyl Substances in Drinking Water by Solid Phase Extraction and 

Liquid Chromatography/Tandem Mass Spectrometry (LC/MS/MS). Accessed November 2023 at: 

https://cfpub.epa.gov/si/si_public_record_Report.cfm?dirEntryId=343042&Lab=NERL.

(EPA, 2023f). U.S. Environmental Protection Agency. 2023. Municipal Solid Waste Landfills. Accessed 

September 2023 at: https://www.epa.gov/landfills/municipal-solid-waste-landfills.

(EPA, 2023g). U.S. Environmental Protection Agency. 2023. Other Test Method 45 (OTM-45) 

Measurement of Selected Per- and Polyfluorinated Alkyl Substances from Stationary Sources. 

Available online at: https://www.epa.gov/sites/default/files/2021-

01/documents/otm_45_semivolatile_pfas_1-13-21.pdf.

(EPA, 2023h). U.S. Environmental Protection Agency. 2023. Per- and Polyfluoroalkyl Substances 

(PFAS): Proposed PFAS National Primary Drinking Water Regulation. Accessed December 2023 

at: https://www.epa.gov/sdwa/and-polyfluoroalkyl-substances-pfas.
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

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(EPA, 2023i). U.S. Environmental Protection Agency. 2023. PFAS Analytical Methods Development and 

Sampling Research. Accessed September 2023 at: https://www.epa.gov/water-research/pfasanalytical-methods-development-and-sampling-research.

(EPA, 2023j). U.S. Environmental Protection Agency. 2023. TRI Non-CBI PFAS List. Available online 

at: https://www.epa.gov/system/files/documents/2023-01/Copy%20of%20tri_noncbi_pfas_list_1_6_2023_final%20%28002%29.xlsx.

(HHS, 2023). U.S. Department of Health and Human Services: National Toxicology Program. 2023. 

Immunotoxicity Associated with Exposure to Perfluorooctanoic Acid (PFOA) or Perfluorooctane 

Sulfonate (PFOS). Available online at: 

https://ntp.niehs.nih.gov/whatwestudy/assessments/noncancer/completed/pfoa.

(Hsu et al., 2008). Hsu, S.H., Vermeir, I., Scholze, M., Voigt, M., Gierth, J., Mittermeier, A., Mäge, I., 

and Voelkel, L. 2008. Challenges of non-PFOS top antireflective coating material. Proc. SPIE, 

6923 69232M. Accessed September 2023 at: https://doi.org/10.1117/12.772600.

(Isaacs, 2023). Isaacs, D. 2023. Technical Papers Highlight Need to Maintain Essential Uses of PFAS in 

Semiconductor Industry. Semiconductor Industry Associations. Accessed December 2023 at:

https://www.semiconductors.org/technical-papers-highlight-need-to-maintain-essential-uses-ofpfas-in-semiconductor-industry/.

(Jones, 2022). Jones. E.T. 2022. SIA PFAS Consortium. The Impact of a Potential PFAS Restriction on 

the Semiconductor Sector: Final Report. RINA Tech UK Limited. Accessed September 2023 at:

https://www.semiconductors.org/wp-content/uploads/2023/04/Impact-of-a-Potential-PFASRestriction-on-the-Semiconductor-Sector-04_14_2023.pdf.

(MIDEQ, 2014). Michigan Department of Environmental Quality Water Resources Division. 2014. What 

are biosolids, how are they used, and are they safe? Available online at: 

https://www.michigan.gov/-

/media/Project/Websites/egle/Documents/Programs/WRD/Biosolids/biosolids-what-howsafe.pdf?rev=b54e28b954a54dd8a43153688a1151b3.

(MNPCA, No date). Minnesota Pollution Control Agency. 2023. Minnesota’s PFAS Blueprint. Accessed 

September 2023 at: https://www.pca.state.mn.us/air-water-land-climate/minnesotas-pfasblueprint.

(NCSL, 2023). National Conference of State Legislatures. 2023. Per- and Polyfluoroalkyl Substances 

(PFAS): State Legislation and Federal Action. Accessed September 2023 at: 

https://www.ncsl.org/environment-and-natural-resources/per-and-polyfluoroalkyl-substances.

(NHGC, 2020). New Hampshire General Court. 2020. House Bill 1264. Bill Status System. Accessed 

October 2023 at:

https://gencourt.state.nh.us/bill_status/legacy/bs2016/bill_status.aspx?lsr=2641&sy=2020&sortop

tion=&txtsessionyear=2020&txtbillnumber=HB1264.

(NYSDOH, 2022). New York State Department of Health. 2022. Public Water Systems and NYS 

Drinking Water Standards for PFAS and Other Emerging Contaminants. Accessed September 

2023 at: 

https://www.health.ny.gov/environmental/water/drinking/emerging_pfas_publicwater.htm#:~:text

=In%202020%2C%20NYS%20set%20maximum,for%201%2C4%2Ddioxane.

(Ober et al., 2022). Ober, C.K., Kafer, F., and Deng, J. 2022. Review of essential use of fluorochemicals 

in lithographic patterning and semiconductor processing. J. of Micro/Nanopatterning Mater. 

Metrol., 21(1), 010901. Accessed September 2023 at: 

https://doi.org/10.1117/1.JMM.21.1.010901.
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B-23

(OHEPA, No date). Ohio Environmental Protection Agency. No date. PFAS Action Plan for Drinking 

Water. Accessed September 2023 at: https://epa.ohio.gov/monitor-pollution/pollution-issues/pfasaction-plan.

(ORHA, No date). Oregon Health Authority. No date. Per - and Polyfluoroalkyl Substances (PFAS). 

Accessed September 2023 at: 

https://www.oregon.gov/oha/PH/HEALTHYENVIRONMENTS/DRINKINGWATER/OPERATI

ONS/Pages/PFAS.aspx.

(Ross et. al, 2018). Ian Ross, Jeffrey McDonough, Jonathan Miles, Peter Storch, Parvathy Thelakkat 

Kochunarayanan, Erica Kalve, Jake Hurst, Soumitri S. Dasgupta, and Jeff Burdick. 2018. A 

review of emerging technologies for remediation of PFASs. Remediation. 2018;28:101–126. 

Available online at: https://cswab.org/wp-content/uploads/2020/09/Emerging-RemediationTechnologies-Ross-2018.pdf.

(TriHydro, 2023). TriHydro. 2023. Colorado PFAS Policy 20-1: Reporting Requirements in Water

Discharge Permits. Accessed September 2023 at: https://www.trihydro.com/news/newsdetails/2021/01/18/colorado-pfas-policy-20-1-reporting-requirements-in-water-discharge-permits.

(SIA, 2023a). Semiconductor Industry Association. June 28, 2023. PFAS-Containing Fluorochemicals 

Used in Semiconductor Manufacturing Plasma-Enabled Etch and Deposition. Semiconductor 

PFAS Consortium Plasma Etch and Deposition Working Group. Available online at: 

https://www.semiconductors.org/wp-content/uploads/2023/06/FINAL-Plasma-Etch-andDeposition-White-Paper.pdf.

(SIA, 2023b). Semiconductor Industry Association. July 26, 2023. PFAS-Containing Heat Transfer Fluids 

Used in Semiconductor Manufacturing. Semiconductor PFAS Consortium Heat Transfer and 

Thermal Test Fluid Working Group. Available online at: https://www.semiconductors.org/wpcontent/uploads/2023/07/Final-Heat-Transfer-Fluids-Paper.pdf.

(SIA, 2023c). Semiconductor Industry Association. May 18, 2023. PFAS-Containing Lubricants Used in 

Semiconductor Manufacturing Semiconductor PFAS Consortium Lubricants Working Group. 

Available online at: https://www.semiconductors.org/wp-content/uploads/2023/05/FINAL-PFASContaining-Lubricants-Used-in-Semiconductor-Manufacturing.pdf.

(SIA, 2023d). Semiconductor Industry Association. June 2, 2023. PFAS-Containing Wet Chemistries 

Used in Semiconductor Manufacturing. Semiconductor PFAS Consortium Wet Chemicals 

Working Group. Available online at: https://www.semiconductors.org/wpcontent/uploads/2023/08/FINAL-PFAS-Containing-Wet-Chemistries-Used-in-SemiconductorManufacturing.pdf.

(SIA, 2023e). Semiconductor Industry Association. September 21, 2023. PFAS Release Mapping from 

Semiconductor Manufacturing Photolithography Processes. Semiconductor PFAS Consortium 

Photolithography Working Group. Available online at: https://www.semiconductors.org/wpcontent/uploads/2023/09/PFAS-Release-Mapping-from-Semiconductor-PhotolithographyProcesses-Rev.0.pdf.

(SEMI, No date). SEMI PFAS Working Group. No date. PFAS Explainer. Accessed September 2023 at: 

https://www.semi.org/en/ehs_PFAS/PFAS_in_Semiconductor_Mfg#:~:text=PFAS%20can%20be

%20present%20in%20the%20equipment%20used%20to%20make,hydrogen%20for%20EUV%2

0exposure%20systems.

(Timings, 2021). Timings, J. 2021. 6 Crucial Steps in Semiconductor Manufacturing. AMSL. Accessed 

September 2023 at: https://www.asml.com/en/news/stories/2021/semiconductor-manufacturingprocess-steps.https://www.asml.com/en/news/stories/2021/semiconductor-manufacturingprocess-steps.
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

B-24

(Wang et. al, 2017). Zhanyun Wang, Jamie C. DeWitt, Christopher P. Higgins, and Ian T. Cousins. 2017. 

A Never-Ending Story of Per- and Polyfluoroalkyl Substances (PFASs)? Environ. Sci. Technol., 

51, 2508−2518. Available online at: https://pubs.acs.org/doi/pdf/10.1021/acs.est.6b04806.

(WSC, 2018). World Semiconductor Council. 2018. Joint Statement of the World Semiconductor 

Council. Accessed September 2023 at: http://www.semiconductorcouncil.org/wpcontent/uploads/2018/05/22nd-WSC-Joint-Statement-San-Diego-CA-FINAL-1.pdf.
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

C-1

APPENDIX C: SEMICONDUCTOR FABRICATION CHEMICALS AND 

MATERIALS LISTED ON THE TOXIC SUBSTANCES 

CONTROL ACT INVENTORY
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

C-2

SEMICONDUCTOR FABRICATION CHEMICALS AND

MATERIALS LISTED ON THE

TOXIC SUBSTANCES CONTROL ACT (TSCA) INVENTORY

TSCA Inventory Name 

(Systematic Name) Alternate Name(s)

Chemical 

Abstracts 

Service 

(CAS) 

Number Purpose

1,2-Ethanediol Ethylene glycol 107-21-1 Cooling medium; 

Dehumidifying agent

1,3-Butadiene, 1,1,2,3,4,4-

hexafluoroHexafluoro-1,3-Butadiene;Hexafluoro-1,3-butadiene; 1,3-

Butadiene, 1,1,2,3,4,4-

hexafluoro685-63-2 Dry etching

1H-Benzotriazole N/A 95-14-7 Chemical 

Mechanical 

Planarization

1-Propene, 1,1,2,3,3,3-

hexafluoroHexafluoropropylene 116-15-4 Miscellaneous

2(3H)-Furanone, dihydro- Butyrolactone; GammaButyrolacton (GBL)96-48-0 Cleaning 

2,4-Pentanedione, 

1,1,1,5,5,5-hexafluoroN/A 1522-22-1 Thin film deposition

2,4-Pentanedione, 1,1,1-

trifluoro1,1,1-Trifluoropentane-2,4-dione

367-57-7 Thin film deposition

2-Heptanone Heptan-2-one; Methyl n-amyl 

ketone; Methyl Amyl Ketone

110-43-0 Lithography 

(photoresist solvent)

2-Pentanone, 4-methyl- Methyl isobutyl ketone 108-10-1 Photolithography

2-Propanol Isopropyl alcohol 67-63-0 Wafer Cleaning 

2-Propanol, 1-methoxy-, 2-

acetate

PGMEA (PM Acetate) 

(C6H12O3); Propylene glycol 

monomethyl ether acetate, 1-

Methoxy-2-propyl acetate 

108-65-6 Photolithography, 

Photoresistor 

thinners

2-Propanol, 2-methyl- Tert-butyl alcohol (TBA); tertButanol; tert-Butyl alcohol75-65-0 Cleaning 

2-Propanone Acetone 67-64-1 Wafer Cleaning 

2-Pyrrolidinone, 1-methyl- N-Methyl-2-pyrrolidone (NMP);

C5H9NO

872-50-4 Photolithography

4-

Morpholinecarboxaldehyde

Morpholine-4-carbaldehyde 4394-85-8 N/A

Acetic Acid N/A 64-19-7 Wet & Dry Etching

Acetic acid, 2,2,2-trichloro- Trichloroacetic acid 76-03-9 Miscellaneous

Acetic acid, butyl ester N-butyl acetate 123-86-4 Photolithography
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

C-3

TSCA Inventory Name 

(Systematic Name) Alternate Name(s)

Chemical 

Abstracts 

Service 

(CAS) 

Number Purpose

Components are listed Alloy 42 (alloy of iron, nickel, 

manganese, and cobalt)

N/A Raw material

Alcohols, C12-14-secondary, 

ethoxylated

Tergitol 84133-50-6 Miscellaneous

Aluminum N/A 7429-90-5 Raw material

Aluminum, triethyl- Triethylaluminum 97-93-8 Deposition, atomic 

layer (ALD)

Aluminum, trimethyl- Trimethylaluminum;

Trimethylalumane 

75-24-1 Thin film deposition

Ammonia NH3 7664-41-7 Thin Film 

Deposition; 

Miscellaneous

Ammonium fluoride ((NH4)F) 12125-01-8 Wet & Dry Etching

Ammonium hydroxide ((NH4)(OH)) 1336-21-6 Wafer Cleaning 

Antimony oxide Antimony trioxide (Sb2O3) 1309-64-4 Thin Film Deposition

Argon N/A 7440-37-1 Carrier Gas

Arsine (AsH3) N/A 7784-42-1 Thin Film Deposition

Benzene, dimethyl- Xylene 1330-20-7 Wafer Cleaning 

Benzene, methyl- Toluene 108-88-3 Miscellaneous

Borane, tribromo- Boron tribromide 10294-33-4 Miscellaneous

Borane, trichloro- Boron trichloride 10294-34-5 Thin Film Deposition

Borane, trifluoro- Boron trifluoride 7637-07-2 Thin Film Deposition

Boric acid (H3BO3), triethyl 

ester

Triethylborate (TEB) 150-46-9 Thin Film Deposition

Boric acid (H3BO3), trimethyl 

ester

Trimethylborate 121-43-7 Thin Film Deposition

Boron N/A 7440-42-8 Raw material

Components are likely listed Borophosphosilicate glass 

(BPSG) 

N/A Raw material

Bromine N/A 7726-95-6 Miscellaneous

Butane, 1,1,1,2,3,4,4,4-

octafluoroOctafluorobutane, 2H,3HPerfluorobutane 

75995-72-1 Dry etching

Calcium oxide (CaO) Lime 1305-78-8 Miscellaneous

Carbon dioxide N/A 124-38-9 Thin Film Deposition

Carbon monoxide N/A 630-08-0 Thin Film Deposition
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

C-4

TSCA Inventory Name 

(Systematic Name) Alternate Name(s)

Chemical 

Abstracts 

Service 

(CAS) 

Number Purpose

Carbon oxide sulfide Carbonyl sulfide (COS); carbon 

oxysulfide; carbonyl sulfide; 

carbon oxide sulfide 

463-58-1 Precursor for sulfur 

doping; Metalorganic chemical 

vapor deposition 

(MOCVD); Surface 

passivation; Gas 

sensing

Cerium hydroxide Cerium(3+) trihydroxide 

(Ce(OH)3) 

15785-09-8 Chemical 

Mechanical 

Planarization

Chlorine N/A 7782-50-5 Wet & Dry Etching

Chlorine fluoride Chlorine trifluoride; ClF3 7790-91-2 Wet & Dry Etching

Chromium oxide Chromium trioxide; chromic 

acid; CrO3

1333-82-0 Wet & Dry Etching

Components are listed Chromium silicon; sichrome N/A Raw material

Copper N/A 7440-50-8 Raw material

Components are likely listed Cupraselect (C10H13CuF6O2Si) N/A Thin Film Deposition

Cupric sulfate Copper sulfate; copper (II) 

sulfate

7758-98-7 Electrodeposition

Cyclobutane, 1,1,2,2,3,3,4,4-

octafluoroC4F8; halocarbon 318 115-25-3 Wet & Dry Etching

Cyclobutene, hexafluoro- C4F6 697-11-0 Miscellaneous

Cyclohexanone Cyclohexanone 108-94-1 Photolithography

Cyclopentanone Cyclopentane 120-92-3 Photolithography

Cyclopentene, 

1,2,3,3,4,4,5,5-octafluoroOctafluorocyclopentene 559-40-0 Miscellaneous

Diborane N/A 19287-45-7 Thin Film Deposition 

(doping agent)

Disilane H2Si2 1590-87-0 Thin Film Deposition

Ethanamine, N,N-diethyl- Triethylamine 121-44-8 Miscellaneous

Ethanaminium, 2-hydroxyN,N,N-trimethyl-, hydroxide 

(1:1)

Choline hydroxide 123-41-1 Wet & Dry Etching

Ethane, 1,1,1,2,2,2-

hexafluoroHexafluoroethane; perfluoroethane; PFC-116

76-16-4 Etching and Wafer 

Cleaning

Ethanedioic acid Oxalic Acid 144-62-7 Miscellaneous

Ethanol N/A 64-17-5 Miscellaneous

Ethanol, 2,2',2''-nitrilotris- Triethanolamine 102-71-6 Thin Film Deposition
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

C-5

TSCA Inventory Name 

(Systematic Name) Alternate Name(s)

Chemical 

Abstracts 

Service 

(CAS) 

Number Purpose

Ethanol, 2-amino- Ethanolamine 141-43-5 Wet Etching

Ethanol, 2-butoxy- Butoxy ethanol; Ethylene glycol 

monobutyl ether; Ethylene 

glycol monobutyl; 2-Butoxy 

ethanol 

111-76-2 N/A

Ethanol, tantalum(5+) salt 

(5:1)

Tantalum ethoxide 6074-84-6 Thin Film Deposition

Ethene, 1,1,2,2-tetrachloro- Perchloroethylene (PCE); 

Tetrachloroethylene

127-18-4 Miscellaneous

Ethene, 1,1,2,2-tetrafluoro-, 

homopolymer

Polytetrafluoroethylene (PTFE) 9002-84-0 Lubrication

Ethene, 1,1,2,2-tetrafluoro-, 

homopolymer

Teflon; Polytetrafluoroethylene 9002-84-0 Miscellaneous

Ethene, 1,1,2-trichloro- Tricholoroethylene 79-01-6 Miscellaneous

Ethene, 1,2-dichloro-, (1E)- Trans-1,2-dichloroethylene; 

Trans L-C

156-60-5 Miscellaneous

Ethyne Acetylene 74-86-2 Miscellaneous

Ferrate(3-), hexakis(cyano-

.kappa.C)-, potassium (1:3), 

(OC-6-11)-

Potassium ferricyanide 13746-66-2 Wet & Dry Etching

Fluorine N/A 7782-41-4 Chemical vapor 

deposition, Plasma 

etching, cleaning

(Fluorine

compounds)

Formaldehyde, polymer with 

2-(chloromethyl)oxirane and 

4,4'-(1-methylethylidene)

bis[phenol]

SU-8 Series Resists 

(Organic Resin Solution)

28906-96-9 Photolithography

Gallium arsenide (GaAs) N/A 1303-00-0 Raw material

Gallium nitride (GaN) N/A 25617-97-4 Raw material

Germane, tetrafluoro- Germanium tetrafluoride 7783-58-6 Thin Film Deposition

Germanium N/A 7440-56-4 Raw material

Gold (Au) N/A 7440-57-5 Raw material

Helium N/A 7440-59-7 Carrier Gas

Heptane N/A 142-82-5 Miscellaneous

Hydrobromic acid Hydrogen bromide 10035-10-6 Thin Film Deposition
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

C-6

TSCA Inventory Name 

(Systematic Name) Alternate Name(s)

Chemical 

Abstracts 

Service 

(CAS) 

Number Purpose

Hydrochloric acid Hydrogen chloride; 

muriatic acid 

7647-01-0 Thin Film 

Deposition/

Usually in Single

Wafer and Batch

processing

Hydrochloric acid Muriatic acid (27.92%) 7647-01-0 Wafer Cleaning 

Hydrofluoric acid Hydrogen fluoride 7664-39-3 Wet & Dry Etching

Hydrogen H2 1333-74-0 Carrier Gas

Hydrogen peroxide H2O2 7722-84-1 Wafer Cleaning 

Components are listed Kovar (alloy of iron, nickel, 

manganese, & cobalt)

N/A Raw material

Lead Pb 7439-92-1 Raw material

Metaphosphoric acid 

(H6P6O18), sodium salt (1:6)

Sodium hexametaphosphate 10124-56-8 Miscellaneous

Methanaminium, N,N,Ntrimethyl-, hydroxide (1:1)Tetramethylammonium 

hydroxide

75-59-2 Photolithography

Methane CH4 74-82-8 Miscellaneous

Methane, dichloro- Methylene chloride 75-09-2 Miscellaneous

Methane, fluoro- Methylene fluoride; methyl 

fluoride

593-53-3 Miscellaneous; Wet 

& Dry Etching

Methane, tetrafluoro- CF4 75-73-0 Wet & Dry Etching

Methane, trifluoroiodo- Trifluoriomethane; 

Trifluoroiodomethane

2314-97-8 Miscellaneous

Methanol Methyl alcohol 67-56-1 Miscellaneous

Components are listed Naptha N/A Miscellaneous

Neon N/A 7440-01-9 Miscellaneous

Nitric acid N/A 7697-37-2 Wet & Dry Etching

Nitrogen N2 (gas or liquid) 7727-37-9 Carrier Gas

Nitrogen fluoride (NF3) Nitrogen trifluoride 7783-54-2 Wet & Dry 

Etching/Remove 

silicon and siliconcompounds 

Nitrogen oxide (N2O) Nitrous oxide 10024-97-2 Thin Film Deposition

Nitrogen oxide (NO) Nitric oxide 10102-43-9 Thin Film Deposition

Components are likely listed Nova Strip N/A Miscellaneous
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

C-7

TSCA Inventory Name 

(Systematic Name) Alternate Name(s)

Chemical 

Abstracts 

Service 

(CAS) 

Number Purpose

Octadecyltrichlorosilane n-octadecyltrichlorosilane,

Trichloro(octadecyl)silane

112-04-9 Self-assembled 

monolayer thin films 

on silicon dioxide 

substrates

Octane n-Octane 111-65-9 N/A

Oxygen O2 (general grade) 7782-44-7 Wet & Dry Etching

Perchloric acid N/A 7601-90-3 Wafer Cleaning 

Permanganic acid (HMnO4), 

potassium salt (1:1)

Potassium permanganate 7722-64-7 Wet & Dry Etching

Phosphine N/A 7803-51-2 Thin Film Deposition 

(doping agent)

Phosphorane, pentafluoro- Phosphorus pentafluoride 7647-19-0 Thin Film Deposition

Phosphoric acid N/A 7664-38-2 Wet & Dry Etching

Phosphoric acid, triethyl 

ester

Triethylphosphate 78-40-0 Thin Film Deposition

Components are listed Phosphoric Etch (phosphoric 

acid 39%, nitric acid 38%, water 

21-25%)

N/A Wet & Dry Etching

Phosphoric trichloride Phosphorous oxychloride 

(POCl3)

10025-87-3 Thin Film Deposition

Phosphorous acid, trimethyl 

ester

Trimethylphosphite 121-45-9 Thin Film Deposition

Phosphorous trifluoride N/A 7783–55–3 Thin Film Deposition

Phosphorus Phosphorous 7723-14-0 Thin Film Deposition

Phosphorus P 7723-14-0 Raw material

Potassium chloride KCl 7447-40-7 Miscellaneous

Potassium hydroxide (K(OH)) Potassium hydroxide 1310-58-3 Wet & Dry Etching

Potassium iodide KI 7681-11-0 Wet & Dry Etching

Propane N/A 74-98-6 Miscellaneous

Propane, 1,1,1,2,2,3,3,3-

octafluoroC3F8; Perfluoropropane; Octafluoropropane; R-218

76-19-7 Thin film deposition

Propanoic acid, 2-hydroxy- Lactic acid 50-21-5 Miscellaneous

Propanoic acid, 2-hydroxy-2-

methyl-, methyl ester

Methyl 2-hydroxyisobutyrate 

(HBM)

2110-78-3 Lithographpy 

(photoresist thinner)

Propanoic acid, 2-

methylpropyl ester

2-Methylpropyl propanoate;

isobutyl propionate

540-42-1 Etching

Silanamine, 1,1,1-trimethylN-(trimethylsilyl)-

Hexamethyldisilizane 999-97-3 Photolithography
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

C-8

TSCA Inventory Name 

(Systematic Name) Alternate Name(s)

Chemical 

Abstracts 

Service 

(CAS) 

Number Purpose

Silane Monosilane, silicon hydride, 

silicon tetrahydride, silicane

7803–62–5 Thin Film Deposition

Silane, dichloro- Dichlorosilane (Cl2H2Si) 4109-96-0 Thin Film Deposition

Silane, methyl- Methylsilane 992-94-9 Thin Film Deposition

Silane, tetrachloro- N/A 10026-04-7

Silane, tetrachloro- Silicon tetrachloride (SiCl4) 10026-04-7 Thin Film Deposition

Silane, tetrafluoro- Silicon tetrafluoride (SiF4) 7783-61-1 Thin Film Deposition

Silane, tetramethyl- Tetramethylsilane (EPA Registry 

Name)

75-76-3 Precursors for low-K 

barrier films; etch 

hard masks; and 

carbon-doped silicon 

films and silicon 

carbide-like films

Silane, trichloro- Trichlorosilane 10025-78-2 Thin Film Deposition

Silane, trimethyl- Trimethyl silane 993-07-7 Thin Film Deposition

Silica Silicon dioxide (SiO2) 7631-86-9 Miscellaneous

Silicic acid (H4SiO4), 

tetraethyl ester

Teos (C8H20O4Si) 78-10-4 Thin Film Deposiition

Silicon N/A 7440-21-3 Raw material

Silicon carbide SiC 409-21-2 Raw material

Silicon nitride Si3N4 12033-89-5 Raw material

Silver Ag 7440-22-4 Raw material

Components are listed Slope Etch (water, acetic 

acid, ammonium fluoride, 

and hydrofluoric acid)

N/A Wet & Dry Etching

Sodium chloride NaCl 7647-14-5 Miscellaneous

Sodium hydroxide (Na(OH)) 1310-73-2 Wet & Dry Etching

Components are listed Spin-on glass N/A Raw material

Components are listed SU-8 Series Resists 

(Organic Resin Solution)

N/A Photolithography

Sulfonium, (thioditedded4,1-phenylene)bis[diphenyl-,

(OC-6-11)-

hexafluoroantimonate(1-) 

(1:2)

SU-8 Series Resists 

(Organic Resin Solution)

89452-37-9 Photolithography
DRAFT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR

SEMICONDUCTOR FABRICATION FACILITIES

C-9

TSCA Inventory Name 

(Systematic Name) Alternate Name(s)

Chemical 

Abstracts 

Service 

(CAS) 

Number Purpose

Sulfonium, diphenyl[4-

(phenylthio)phenyl]-, 

(OC-6-11)-

hexafluoroantimonate(1-) 

(1:1)

SU-8 Series Resists 

(Organic Resin Solution)

71449-78-0 Photolithography

Sulfur dioxide N/A 7446-09-5 Miscellaneous

Sulfur fluoride (SF6), (OC-6-

11)-

Sulfur hexafluoride 2551-62-4 Thin Film 

Deposition/

Plasma etching

processes

Sulfuric acid N/A 7664-93-9 Wafer Cleaning 

Sulfuric acid, ammonium 

iron(2+) salt (2:2:1)

Ferrous ammonium sulfate 10045-89-3 Miscellaneous

Sulfurous acid, sodium salt 

(1:1)

Sodium bisulfite (anhydrous) 7631-90-5 Miscellaneous

Tantalum N/A 7440-25-7 Physical vapor 

deposition (PVD)

Thiophene, tetrahydro-, 1,1-

dioxide

Tetrahydrothiophene-1,1-

dioxide, Sulfolane

126-33-0 Semiconductor 

cleaning

Tin Sn 7440-31-5 Raw material

Titanium N/A 7440-32-6 Photocatalytic 

baseline 

Titanium chloride (TiCl4) (T4)-Titanium tetrachloride;

Titanium(4+) tetrachloride 

7550-45-0 Thin Film Deposition

Tungsten fluoride (WF6), (OC6-11)-

Tungsten hexafluoride 7783-82-6 Thin Film Deposition

Components are listed Ultraslope Etch (water, 

ammonium fluoride, and 

hydrofluoric acid)

N/A Wet & Dry Etching

Xenon N/A 7440-63-3 Etching and 

Deposition

Sources: EPA, 2023; CPO, 2023

REFERENCES

(CPO, 2023). Creating Helpful Incentives to Produce Semiconductors Program Office. September to 

December 2023. Correspondence with CPO semiconductor experts. 

(EPA, 2023). U.S. Environmental Protection Agency. 2023. TSCA Chemical Substance Inventory: How 

to Access the TSCA Inventory. Download the non-confidential TSCA Inventory. Accessed 

September 22, 2023, at: https://www.epa.gov/tsca-inventory/how-access-tscainventory#download.