December 2023 — 12-14-2023-OCIDA-Board-Packet-reduced-FINAL.pdf =============================================================== ONONDAGA COUNTY INDUSTRIAL DEVELOPMENT AGENCY 335 MONTGOMERY STREET FLOOR 2M, SYRACUSE, NY 13202 1- PHONE: 315.435.3770 • FAX: 315.435.3669 • ONGOVED.COM Regular Meeting Agenda December 14, 2023 8:30AM Call to Order the Regular Meeting of the Agency A. Approval of Minutes-November 9, 2023 B. Treasurer’s Report C. Payment of Bills D. Conflict of Interest Action Items: 1. Armoured One, LLC and North Midler Properties, LLC (3101-18-06A) Modification Meeting Armoured One, LLC and North Midler Properties, LLC are requesting an extension of the end date of their Sales and Use Tax Exemption Agency Action Requested: a. A resolution of the Board authorizing an extension to the Sales and Use Tax Exemption for Armoured One, LLC and North Midler Properties, LLC. Representative: Robert Petrovich, OCIDA Executive Director 2. COR Inner Harbor Company, LLC (3101-15-14A) Modification Meeting COR Van Rensselaer Street Company II, LLC and COR Van Rensselaer Street Company III, Inc. are requesting a one-year extension of the sales and use tax exemption in connection with Parcels B2-4 and C-2, Inner Harbor Project. ONONDAGA COUNTY INDUSTRIAL DEVELOPMENT AGENCY 335 MONTGOMERY STREET FLOOR 2M, SYRACUSE, NY 13202 1- PHONE: 315.435.3770 • FAX: 315.435.3669 • ONGOVED.COM Regular Meeting Agenda December 14, 2023 8:30AM Call to Order the Regular Meeting of the Agency A. Approval of Minutes-November 9, 2023 B. Treasurer’s Report C. Payment of Bills D. Conflict of Interest Action Items: 1. Armoured One, LLC and North Midler Properties, LLC (3101-18-06A) Modification Meeting Armoured One, LLC and North Midler Properties, LLC are requesting an extension of the end date of their Sales and Use Tax Exemption Agency Action Requested: a. A resolution of the Board authorizing an extension to the Sales and Use Tax Exemption for Armoured One, LLC and North Midler Properties, LLC. Representative: Robert Petrovich, OCIDA Executive Director 2. COR Inner Harbor Company, LLC (3101-15-14A) Modification Meeting COR Van Rensselaer Street Company II, LLC and COR Van Rensselaer Street Company III, Inc. are requesting a one-year extension of the sales and use tax exemption in connection with Parcels B2-4 and C-2, Inner Harbor Project. Agency Action Requested: a. A resolution of the Board authorizing the extension of the sales and use tax exemption for COR Van Rensselaer Street Company II, LLC and COR Van Rensselaer St. Company III, Inc. (COR Inner Harbor Company, LLC Sub Project 1) Representative: Robert Petrovich, OCIDA Executive Director 1 3. Destiny USA Real Estate, LLC (3101-13-05B) Modification Meeting The Company requesting a release of a portion of the Land from the Agency’s leasehold interest of the property and consent to sell its Project Facility to EH26, LLC. Agency Action Requested: a. A resolution of the Board approving the subdivision of the Project Facility, authorizing a release of a portion of the Agency’s leasehold interest in the Project Facility and consenting to the sale and assignment of the right, title and interest in a project facility by Destiny USA Real Estate, LLC to EH26, LLC. Representative: Amanda Fitzgerald, OCIDA Legal Counsel, Barclay Damon Agency Action Requested: a. A resolution of the Board authorizing the extension of the sales and use tax exemption for COR Van Rensselaer Street Company II, LLC and COR Van Rensselaer St. Company III, Inc. (COR Inner Harbor Company, LLC Sub Project 1) Representative: Robert Petrovich, OCIDA Executive Director 1 3. Destiny USA Real Estate, LLC (3101-13-05B) Modification Meeting The Company requesting a release of a portion of the Land from the Agency’s leasehold interest of the property and consent to sell its Project Facility to EH26, LLC. Agency Action Requested: a. A resolution of the Board approving the subdivision of the Project Facility, authorizing a release of a portion of the Agency’s leasehold interest in the Project Facility and consenting to the sale and assignment of the right, title and interest in a project facility by Destiny USA Real Estate, LLC to EH26, LLC. Representative: Amanda Fitzgerald, OCIDA Legal Counsel, Barclay Damon 4. Active Project Review Annual assessments of projects as required by General Municipal Law Section 874(12). • Flex-Hose annual assessment. Agency Action Requested a. A resolution of the Board determining no recapture and authorizing the execution and delivery of an amendment to Project Agreement in connection with a certain project for Flex-Hose Company, Inc. and FHC Properties, LLC. Representative: Robert Petrovich, OCIDA Executive Director 5. Micron New York Semiconductor Manufacturing, LLC (3101-23-07A) Agency Action Requested: a. A resolution of the Board adopting the Final Scoping Document. Representative: Jeff Davis, OCIDA Legal Counsel, Barclay Damon 6. Appointments OCIDA Board to Appoint Svetlana Dyer as Agency Secretary and Agency Public Hearing Officer. Agency Action Requested: a. A resolution of the Board appointing Svetlana Dyer as Agency Secretary and Agency Public Hearing Officer. Representative: Robert Petrovich, OCIDA, Executive Director Adjourn 2 2 4. Active Project Review Annual assessments of projects as required by General Municipal Law Section 874(12). • Flex-Hose annual assessment. Agency Action Requested a. A resolution of the Board determining no recapture and authorizing the execution and delivery of an amendment to Project Agreement in connection with a certain project for Flex-Hose Company, Inc. and FHC Properties, LLC. Representative: Robert Petrovich, OCIDA Executive Director 5. Micron New York Semiconductor Manufacturing, LLC (3101-23-07A) Agency Action Requested: a. A resolution of the Board adopting the Final Scoping Document. Representative: Jeff Davis, OCIDA Legal Counsel, Barclay Damon 6. Appointments OCIDA Board to Appoint Svetlana Dyer as Agency Secretary and Agency Public Hearing Officer. Agency Action Requested: a. A resolution of the Board appointing Svetlana Dyer as Agency Secretary and Agency Public Hearing Officer. Representative: Robert Petrovich, OCIDA, Executive Director Adjourn 2 2 DRAFT Onondaga County Industrial Development Agency Regular Meeting Minutes November 9, 2023 A regular meeting of the Onondaga County Industrial Development Agency was held on Thursday, November 9, 2023, 355 Montgomery Street, Floor 2M, Syracuse, New York. Patrick Hogan called the meeting to order at 8:36 am with the following: PRESENT: Patrick Hogan Fanny Villarreal Elizabeth Dreyfuss Kevin Ryan DELAYED: Janice Herzog ABSENT: Susan Stanczyk Cydney Johnson ALSO PRESENT: Robert M. Petrovich, Executive Director Nancy Lowery, Secretary Nate Stevens, Treasurer Karen Doster, Recording Secretary Svetlana Dyer, Assistant Secretary Alexis Rodriguez, Assistant Treasurer Len Rauch, Economic Development Jeff Davis, Barclay Damon Law Firm Amanda Fitzgerald, Barclay Damon Law Firm Paul Reichel, Bond Schoeneck & King Vince Raymond, VIP Structures APPROVAL OF REGULAR MEETING MINUTES – OCTOBER 12, 2023 Upon a motion by Elizabeth Dreyfuss, seconded by Fanny Villarreal, the OCIDA Board approved the regular meeting minutes of October 12, 2023. Motion was carried. (Janice Herzog arrived at meeting) TREASURER’S REPORT Nate Stevens gave a brief review of the Treasurer’s Report for the month of October 2023. 3 DRAFT Onondaga County Industrial Development Agency Regular Meeting Minutes November 9, 2023 A regular meeting of the Onondaga County Industrial Development Agency was held on Thursday, November 9, 2023, 355 Montgomery Street, Floor 2M, Syracuse, New York. Patrick Hogan called the meeting to order at 8:36 am with the following: PRESENT: Patrick Hogan Fanny Villarreal Elizabeth Dreyfuss Kevin Ryan DELAYED: Janice Herzog ABSENT: Susan Stanczyk Cydney Johnson ALSO PRESENT: Robert M. Petrovich, Executive Director Nancy Lowery, Secretary Nate Stevens, Treasurer Karen Doster, Recording Secretary Svetlana Dyer, Assistant Secretary Alexis Rodriguez, Assistant Treasurer Len Rauch, Economic Development Jeff Davis, Barclay Damon Law Firm Amanda Fitzgerald, Barclay Damon Law Firm Paul Reichel, Bond Schoeneck & King Vince Raymond, VIP Structures APPROVAL OF REGULAR MEETING MINUTES – OCTOBER 12, 2023 Upon a motion by Elizabeth Dreyfuss, seconded by Fanny Villarreal, the OCIDA Board approved the regular meeting minutes of October 12, 2023. Motion was carried. (Janice Herzog arrived at meeting) TREASURER’S REPORT Nate Stevens gave a brief review of the Treasurer’s Report for the month of October 2023. 3 Upon a motion by Fanny Villarreal, seconded by Elizabeth Dreyfuss, the OCIDA Board approved the Treasurer’s Report for the month of October 2023. Motion was carried. Upon a motion by Fanny Villarreal, seconded by Elizabeth Dreyfuss, the OCIDA Board approved the Treasurer’s Report for the month of October 2023. Motion was carried. PAYMENT OF BILLS Nate Stevens gave a brief review of the Payment of Bills Schedule #487. Upon a motion by Janice Herzog, seconded by Elizabeth Dreyfuss, the OCIDA Board approved the Payment of Bills Schedule #487 for $373,744.46 with PILOT payments to NY S&W Railway Corporation for $2,910.00, Onondaga County for $8,231.03, City of Syracuse for $7,276.80 and City of Syracuse Central School District for $11,988.90. Motion was carried. PAYMENT OF BILLS Nate Stevens gave a brief review of the Payment of Bills Schedule #487. Upon a motion by Janice Herzog, seconded by Elizabeth Dreyfuss, the OCIDA Board approved the Payment of Bills Schedule #487 for $373,744.46 with PILOT payments to NY S&W Railway Corporation for $2,910.00, Onondaga County for $8,231.03, City of Syracuse for $7,276.80 and City of Syracuse Central School District for $11,988.90. Motion was carried. CONFLICT OF INTEREST DISCLOSURE The Conflict of Interest was circulated and there were no conflicts. BLUEFORS CRYOCOOLER TECHNOLOGIES INC. (3101-22-08A) Amanda Fitzgerald stated the Agency approved additional financial assistance to the former Cryomech and now Bluefors project in the Town of DeWitt. She stated the Agency approved a sales and use tax in March that was extended through November 2023. She stated the company needs more time to close on the purchase of the neighboring parcel. She stated they have asked for an extension of the tax exemption through January of 2024 and anticipate closing on the straight lease transaction in January. Patrick Hogan asked what seems to be the problem. Paul Reichel stated Bluefors is acquiring the adjoining parcel and they need subdivision approvals to combine the parcels. He stated there is a delay in getting the surveys they need. He stated they have received the survey, started the subdivision process, met with the Town Board of DeWitt and they are moving forward. He stated the subdivision will occur in December or January and then they can close. Patrick Hogan stated he has heard this before and understands. 42 CONFLICT OF INTEREST DISCLOSURE The Conflict of Interest was circulated and there were no conflicts. BLUEFORS CRYOCOOLER TECHNOLOGIES INC. (3101-22-08A) Amanda Fitzgerald stated the Agency approved additional financial assistance to the former Cryomech and now Bluefors project in the Town of DeWitt. She stated the Agency approved a sales and use tax in March that was extended through November 2023. She stated the company needs more time to close on the purchase of the neighboring parcel. She stated they have asked for an extension of the tax exemption through January of 2024 and anticipate closing on the straight lease transaction in January. Patrick Hogan asked what seems to be the problem. Paul Reichel stated Bluefors is acquiring the adjoining parcel and they need subdivision approvals to combine the parcels. He stated there is a delay in getting the surveys they need. He stated they have received the survey, started the subdivision process, met with the Town Board of DeWitt and they are moving forward. He stated the subdivision will occur in December or January and then they can close. Patrick Hogan stated he has heard this before and understands. 42 Robert Petrovich asked how long the extension will be. Amanda Fitzgerald stated the proposal is through January 31, 2024. She stated if the project is not closing in January they will have to report back to the Agency for another extension. Upon a motion by Janice Herzog, seconded by Kevin Ryan, the OCIDA Board approved a resolution authorizing an extension of the temporary sales and use tax exemption for Bluefors Cryocooler Technologies Inc. Motion was carried. Robert Petrovich asked how long the extension will be. Amanda Fitzgerald stated the proposal is through January 31, 2024. She stated if the project is not closing in January they will have to report back to the Agency for another extension. Upon a motion by Janice Herzog, seconded by Kevin Ryan, the OCIDA Board approved a resolution authorizing an extension of the temporary sales and use tax exemption for Bluefors Cryocooler Technologies Inc. Motion was carried. C2 NY SENTINEL HEIGHTS SOLAR, LLC (3101-21-05A) Amanda Fitzgerald stated C2 NY Sentinel Heights Solar is a solar project where the Agency provided financial assistance and they closed in January 2023. She stated they put a mortgage on the property in connection with some new financing injected into the property and according to the straight lease transaction document they need Board’s consent to put the mortgage on the property. She stated the Board has seen these before but the difference here is the company has not asked the Agency join the mortgage. She stated the Agency is not being asked to be a party and is simply consenting to the mortgage being put on the property. Patrick Hogan asked Amanda Fitzgerald if she is comfortable with this. Amanda Fitzgerald stated yes. Upon a motion by Fanny Villarreal, seconded by Elizabeth Dreyfuss, the OCIDA Board approved a resolution consenting to a mortgage in connection with a project for C2 NY Sentinel Heights Solar, LLC and determining other matters in connection therewith. Motion was carried. C2 NY SENTINEL HEIGHTS SOLAR, LLC (3101-21-05A) Amanda Fitzgerald stated C2 NY Sentinel Heights Solar is a solar project where the Agency provided financial assistance and they closed in January 2023. She stated they put a mortgage on the property in connection with some new financing injected into the property and according to the straight lease transaction document they need Board’s consent to put the mortgage on the property. She stated the Board has seen these before but the difference here is the company has not asked the Agency join the mortgage. She stated the Agency is not being asked to be a party and is simply consenting to the mortgage being put on the property. Patrick Hogan asked Amanda Fitzgerald if she is comfortable with this. Amanda Fitzgerald stated yes. Upon a motion by Fanny Villarreal, seconded by Elizabeth Dreyfuss, the OCIDA Board approved a resolution consenting to a mortgage in connection with a project for C2 NY Sentinel Heights Solar, LLC and determining other matters in connection therewith. Motion was carried. TERMINATION OF PROJECT RPNY SOLAR 4, LLC (3101-23-01A) Robert Petrovich stated this action is a termination of the application for financial assistance by the applicant. He stated there has been a lot of back and forth with the applicant and the applicant has decided to withdraw. He stated he thinks the fundamental reason was the local access policy and the inability to be able to meet the criteria necessary in order to receive benefits. He stated the applicant is aware and agrees. 53 Kevin Ryan asked if the Agency is out of pocket on this. Robert Petrovich stated OCIDA is not being shorted because of the applicant’s initial deposit. He stated it is an important policy we try to adhere to. Upon a motion by Janice Herzog, seconded by Fanny Villarreal, the OCIDA Board approved a resolution acknowledging the withdrawal of the application submitted by RPNY 4, LLC and revoking any and all financial assistance granted to RPNY Solar 4, LLC in connection with the project associated with the project number. Motion was carried. G.A. BRAUN, INC. (3101-07-16A) SUCCESSOR REMARKETING AGENT APPOINTMENT TERMINATION OF PROJECT RPNY SOLAR 4, LLC (3101-23-01A) Robert Petrovich stated this action is a termination of the application for financial assistance by the applicant. He stated there has been a lot of back and forth with the applicant and the applicant has decided to withdraw. He stated he thinks the fundamental reason was the local access policy and the inability to be able to meet the criteria necessary in order to receive benefits. He stated the applicant is aware and agrees. 53 Kevin Ryan asked if the Agency is out of pocket on this. Robert Petrovich stated OCIDA is not being shorted because of the applicant’s initial deposit. He stated it is an important policy we try to adhere to. Upon a motion by Janice Herzog, seconded by Fanny Villarreal, the OCIDA Board approved a resolution acknowledging the withdrawal of the application submitted by RPNY 4, LLC and revoking any and all financial assistance granted to RPNY Solar 4, LLC in connection with the project associated with the project number. Motion was carried. G.A. BRAUN, INC. (3101-07-16A) SUCCESSOR REMARKETING AGENT APPOINTMENT Amanda Fitzgerald stated the Agency was the issuer for variable rate demand bonds back in 2007 with the GA Braun Inc. project in the Town of Cicero. She stated this is an administrative action. She stated the marketing agent is currently M&T who is getting out of the remarketing agent business and assigning all of its remarketing agent responsibilities over to Bear Stearns. She stated in order to do that the Agency needs to officially appoint Bear Stearns as the new remarketing agent for the bonds and that is what is being asked of us here. She stated Bear Stearns has signed all of the requisite documents willing to accept the responsibilities of the remarketing agent in accordance with the closing documents. Upon a motion by Elizabeth Dreyfuss, seconded by Janice Herzog, the OCIDA Board approved a resolution appointing a successor remarketing agent for the Onondaga County Industrial Development Agency Variable Rate Demand Industrial Development Revenue Bonds (G.A. Braun, Inc. Project), Series 2007 and authorizing the execution and delivery of related documents in connection therewith. Motion was carried. SYRACUSE RESEARCH CORPORATION (3101-05-15B) – SUCCESSOR REMARKETING AGENT APPOINTMENT Amanda Fitzgerald stated the Agency was the issuer for variable rate demand bonds back in 2007 with the GA Braun Inc. project in the Town of Cicero. She stated this is an administrative action. She stated the marketing agent is currently M&T who is getting out of the remarketing agent business and assigning all of its remarketing agent responsibilities over to Bear Stearns. She stated in order to do that the Agency needs to officially appoint Bear Stearns as the new remarketing agent for the bonds and that is what is being asked of us here. She stated Bear Stearns has signed all of the requisite documents willing to accept the responsibilities of the remarketing agent in accordance with the closing documents. Upon a motion by Elizabeth Dreyfuss, seconded by Janice Herzog, the OCIDA Board approved a resolution appointing a successor remarketing agent for the Onondaga County Industrial Development Agency Variable Rate Demand Industrial Development Revenue Bonds (G.A. Braun, Inc. Project), Series 2007 and authorizing the execution and delivery of related documents in connection therewith. Motion was carried. SYRACUSE RESEARCH CORPORATION (3101-05-15B) – SUCCESSOR REMARKETING AGENT APPOINTMENT Amanda Fitzgerald stated this is the same request as GA Braun where M& T is getting out of the remarketing agent business and assigning all of their responsibilities, in most cases, to Bear Stearns, which is what we have here. She stated this is in connection with a 2005 bond issuance providing financing for a project in the Town of Cicero for Syracuse Research Corporation. 64 Elizabeth Dreyfuss asked how long the bonds are for. Amanda Fitzgerald stated she is guessing 20 years considering we are more than 15 years out for both of them but she will get the exact answer to that. Patrick Hogan asked if we got out of bonding a long time ago. Amanda Fitzgerald stated the restrictions for an IDA to issue bonds are much stricter now then they were in the early 2000’s so we don't often see it. Upon a motion by Fanny Villarreal, seconded by Janice Herzog, the OCIDA Board approved a resolution appointing a successor remarketing agent for the Onondaga County Industrial Development Agency Variable Rate Demand Civic Facility Revenue Bonds Series 2005 and authorizing the execution and delivery of related documents in connection therewith. Motion was carried. ENGINEERING SERVICES – CONTRACT AUTHORIZATION Amanda Fitzgerald stated this is the same request as GA Braun where M& T is getting out of the remarketing agent business and assigning all of their responsibilities, in most cases, to Bear Stearns, which is what we have here. She stated this is in connection with a 2005 bond issuance providing financing for a project in the Town of Cicero for Syracuse Research Corporation. 64 Elizabeth Dreyfuss asked how long the bonds are for. Amanda Fitzgerald stated she is guessing 20 years considering we are more than 15 years out for both of them but she will get the exact answer to that. Patrick Hogan asked if we got out of bonding a long time ago. Amanda Fitzgerald stated the restrictions for an IDA to issue bonds are much stricter now then they were in the early 2000’s so we don't often see it. Upon a motion by Fanny Villarreal, seconded by Janice Herzog, the OCIDA Board approved a resolution appointing a successor remarketing agent for the Onondaga County Industrial Development Agency Variable Rate Demand Civic Facility Revenue Bonds Series 2005 and authorizing the execution and delivery of related documents in connection therewith. Motion was carried. ENGINEERING SERVICES – CONTRACT AUTHORIZATION Robert Petrovich stated as the Board knows we are looking to develop and advance the readiness of White Pine South or Caughdenoy Industrial Park regarding supply chain opportunities that may be coming forward in connection with the Micron project. He stated we have been working with Barton & Loguidice as our consultant, the Board approved this relationship previously, to locate the municipal pump station to serve the greater service area of Clay for municipal sewers as part of increased development. He stated we are also working with Barton & Loguidice to advance wetland delineation, site programming, design for construction pads, etc., all things SEQR and all the things necessary that we need to do to try to advance the site for supply chain. He stated this additional funding is to advance that initiative. Upon a motion by Elizabeth Dreyfuss, seconded by Kevin Ryan, the OCIDA Board approved a contract with Barton and Loguidice, D.P.C. in the amount of $17,000 for engineering services at Caughdenoy Industrial Business Park. Motion was carried. 75 ENGINEERING SERVICES – CONTRACT AMENDMENT Robert Petrovich stated as the Board knows we are looking to develop and advance the readiness of White Pine South or Caughdenoy Industrial Park regarding supply chain opportunities that may be coming forward in connection with the Micron project. He stated we have been working with Barton & Loguidice as our consultant, the Board approved this relationship previously, to locate the municipal pump station to serve the greater service area of Clay for municipal sewers as part of increased development. He stated we are also working with Barton & Loguidice to advance wetland delineation, site programming, design for construction pads, etc., all things SEQR and all the things necessary that we need to do to try to advance the site for supply chain. He stated this additional funding is to advance that initiative. Upon a motion by Elizabeth Dreyfuss, seconded by Kevin Ryan, the OCIDA Board approved a contract with Barton and Loguidice, D.P.C. in the amount of $17,000 for engineering services at Caughdenoy Industrial Business Park. Motion was carried. 75 ENGINEERING SERVICES – CONTRACT AMENDMENT Robert Petrovich stated this is an $18,690 increase in our authorization for services in connection with the demolition activities that are occurring along Burnet Road. He stated there has been some twists and turns and asbestos and to get to the end need to increase this amount. He stated he is comfortable putting this before the Board for authorization. Upon a motion by Janice Herzog, seconded by Fanny Villarreal, the OCIDA Board approved a resolution authorizing an amendment to the contract for engineering services with Barton & Loguidice in connection with the development of White Pine Commerce Park authorizing asbestos monitoring assistance in the amount of $18,690. Motion was carried. WHITE PINE COMMERCE PARK DEMOLITION AND REMOVAL: AFFIRMATION OF THE DECLARATION OF EMERGENCY ACTION TO REMOVE PROPERTY Robert Petrovich stated this is an $18,690 increase in our authorization for services in connection with the demolition activities that are occurring along Burnet Road. He stated there has been some twists and turns and asbestos and to get to the end need to increase this amount. He stated he is comfortable putting this before the Board for authorization. Upon a motion by Janice Herzog, seconded by Fanny Villarreal, the OCIDA Board approved a resolution authorizing an amendment to the contract for engineering services with Barton & Loguidice in connection with the development of White Pine Commerce Park authorizing asbestos monitoring assistance in the amount of $18,690. Motion was carried. WHITE PINE COMMERCE PARK DEMOLITION AND REMOVAL: AFFIRMATION OF THE DECLARATION OF EMERGENCY ACTION TO REMOVE PROPERTY Jeff Davis stated he is going to read through the pertinent parts of the resolution. He stated the Agency currently owns several parcels of property comprising the White Pine Commerce Park and the property was acquired consistent with the GEIS done in 2013 and the 2021 Supplemental GEIS all in support of economic development for Onondaga County. He stated certain parcels within the park that were purchased included homes and other structures. He stated the purchase agreements by which the Agency took title of those were duly executed and delivered by the Agency pursuant to resolutions authorizing such execution delivery adopted between 2021 and 2023. He stated each subject purchase agreement required homeowners to vacate the improved parcels subject to several post possession life estate or fixture removal conditions and between 2021 and 2023 in connection with the Agency's acquisition of the parcels, homeowners vacated the improved parcels and removed various fixtures and possessions including but not limited to windows, exterior doors, interior doors, cabinets, plumbing, heating and cooling systems. He stated the Agency there after secured the structures that were vacated by the former owners and they became abandoned structures. He stated the windows and doors were boarded up and no trespassing signs posted. He stated it was the Agency’s intent as documented through the GEIS process to create a shovel ready site to stimulate economic growth and general prosperity for the people of the county. He stated it has been necessary from the beginning to remove the abandoned structures. He stated on November 8, 2022 the Agency commenced this process authorizing the procurement of a bid package and a demo and removal package for the Jeff Davis stated he is going to read through the pertinent parts of the resolution. He stated the Agency currently owns several parcels of property comprising the White Pine Commerce Park and the property was acquired consistent with the GEIS done in 2013 and the 2021 Supplemental GEIS all in support of economic development for Onondaga County. He stated certain parcels within the park that were purchased included homes and other structures. He stated the purchase agreements by which the Agency took title of those were duly executed and delivered by the Agency pursuant to resolutions authorizing such execution delivery adopted between 2021 and 2023. He stated each subject purchase agreement required homeowners to vacate the improved parcels subject to several post possession life estate or fixture removal conditions and between 2021 and 2023 in connection with the Agency's acquisition of the parcels, homeowners vacated the improved parcels and removed various fixtures and possessions including but not limited to windows, exterior doors, interior doors, cabinets, plumbing, heating and cooling systems. He stated the Agency there after secured the structures that were vacated by the former owners and they became abandoned structures. He stated the windows and doors were boarded up and no trespassing signs posted. He stated it was the Agency’s intent as documented through the GEIS process to create a shovel ready site to stimulate economic growth and general prosperity for the people of the county. He stated it has been necessary from the beginning to remove the abandoned structures. He stated on November 8, 2022 the Agency commenced this process authorizing the procurement of a bid package and a demo and removal package for the 86 abandoned structures and authorizing the use of the County Division of Purchase to manage any bidding for the work. He stated in May 2023 the Agency had over 35 parcels with abandoned structures and the Agency partnered with Habitat for Humanity to allow for the removal of remaining materials from several of the abandoned infrastructures that would support the mission for Habitat for Humanity. He stated on June 29, 2023 in conjunction with Barton & Loguidice, the Agency advertised for bid for the removal and demolition of the abandoned structures. He stated despite the Agency's best efforts to secure the abandoned structures, vandalism and a host of illegal activities, including theft, illicit drug use, underage drinking and trespassing has ensued. He stated on May 9, 2023, the Agency issued a press release advising the public to remain off the property, including in particular the abandoned structures following incidents of trespass, discharge of firearms and theft. He stated the press release resulted in four separate news articles concerning dangerous and criminal activity in or about the abandoned structures and advising the public to stay away from the park property. He stated on July 14 an application was submitted to the Agency by Micron New York Semiconductor Manufacturing detailing its plan and desire to invest over $100 billion in White Pine Commerce Park and create 1000s of jobs, stimulating significant economic growth for the county. He stated in relation to the Micron project there has been an increase of legitimate activity within the park by representatives of Micron performing due diligence activities and undertaking certain studies in connection with SEQRA, including various subsurface investigations, which I've defined as investigative work. He stated despite the press release and related news stories, reports of trespass theft and illegal activities in the park of increased creating a public safety concern for remaining residents within the park and in the center of the park as well as those trespassing into the abandoned structures in the areas of the investigative work. He stated on August 10, 2023, the Agency selected Gorick Construction Company to commence demo and removal of the abandoned structures. He stated in September the Agency owned 41 parcels with abandoned structures. He stated in late August and early September the County Department of Emergency Management issued demo permits for removal of the abandoned structures located on the 41 parcels. He stated on October 27, 2023, the County Sheriff's Office apprehended over 40 trespassers at vacant homes within the park. He stated the sheriff reported upon arrival the trespassers ran in different directions requiring Sheriff's office to use helicopter support to locate trespassers within the park. He stated the sheriff's reported to the Agency on October 30, 2023 juveniles are using internet social media threads to organize events at abandoned structures within the park. He stated despite the Agency's best efforts, the abandoned structures within the park are an attractive nuisance resulting in illegal activity in the park that threatens life, health and property for residents within 86 abandoned structures and authorizing the use of the County Division of Purchase to manage any bidding for the work. He stated in May 2023 the Agency had over 35 parcels with abandoned structures and the Agency partnered with Habitat for Humanity to allow for the removal of remaining materials from several of the abandoned infrastructures that would support the mission for Habitat for Humanity. He stated on June 29, 2023 in conjunction with Barton & Loguidice, the Agency advertised for bid for the removal and demolition of the abandoned structures. He stated despite the Agency's best efforts to secure the abandoned structures, vandalism and a host of illegal activities, including theft, illicit drug use, underage drinking and trespassing has ensued. He stated on May 9, 2023, the Agency issued a press release advising the public to remain off the property, including in particular the abandoned structures following incidents of trespass, discharge of firearms and theft. He stated the press release resulted in four separate news articles concerning dangerous and criminal activity in or about the abandoned structures and advising the public to stay away from the park property. He stated on July 14 an application was submitted to the Agency by Micron New York Semiconductor Manufacturing detailing its plan and desire to invest over $100 billion in White Pine Commerce Park and create 1000s of jobs, stimulating significant economic growth for the county. He stated in relation to the Micron project there has been an increase of legitimate activity within the park by representatives of Micron performing due diligence activities and undertaking certain studies in connection with SEQRA, including various subsurface investigations, which I've defined as investigative work. He stated despite the press release and related news stories, reports of trespass theft and illegal activities in the park of increased creating a public safety concern for remaining residents within the park and in the center of the park as well as those trespassing into the abandoned structures in the areas of the investigative work. He stated on August 10, 2023, the Agency selected Gorick Construction Company to commence demo and removal of the abandoned structures. He stated in September the Agency owned 41 parcels with abandoned structures. He stated in late August and early September the County Department of Emergency Management issued demo permits for removal of the abandoned structures located on the 41 parcels. He stated on October 27, 2023, the County Sheriff's Office apprehended over 40 trespassers at vacant homes within the park. He stated the sheriff reported upon arrival the trespassers ran in different directions requiring Sheriff's office to use helicopter support to locate trespassers within the park. He stated the sheriff's reported to the Agency on October 30, 2023 juveniles are using internet social media threads to organize events at abandoned structures within the park. He stated despite the Agency's best efforts, the abandoned structures within the park are an attractive nuisance resulting in illegal activity in the park that threatens life, health and property for residents within 97 and adjacent to the park. He stated there are two actions. He stated as part of the resolution consistent with the requirements of SEQRA, the Agency hereby affirms and ratifies a declaration of an emergency action under SEQRA to remove the abandoned structures for the protection of life, health and property and the Agency is directing the executive director of the Agency is hereby authorize on behalf of the Agency upon advice of agency counsel to take all necessary steps on a temporary basis to remove the abandoned structures to protect life, health and property consistent with the requirements of SEQRA. 97 and adjacent to the park. He stated there are two actions. He stated as part of the resolution consistent with the requirements of SEQRA, the Agency hereby affirms and ratifies a declaration of an emergency action under SEQRA to remove the abandoned structures for the protection of life, health and property and the Agency is directing the executive director of the Agency is hereby authorize on behalf of the Agency upon advice of agency counsel to take all necessary steps on a temporary basis to remove the abandoned structures to protect life, health and property consistent with the requirements of SEQRA. Robert Petrovich stated this pot has been on the stove for a while and on October 27 it boiled over. He stated we have been doing our best to try to secure and prohibit trespassing but it has come to a head with latest partying incident. He stated the contractors have also been suffering from theft and burglaries of generators, power tools and other equipment on the site. He stated people are getting caught in structures pulling materials out. He stated although we have a schedule to advance this project, by this action we want to accelerate that process and try to get it done as quickly as possible. He stated we do have people that are still living off of Burnett Road and ancillary to other locations on White Pine and life estates. He stated we certainly don't want to create or at least allow a condition that allows this to continue. Patrick Hogan asked if procedurally we have done everything as far as public safety aspects go. He stated he commends the Sheriff’s Department for their actions in regard to the last incident. Jeff Davis stated the October 27 incident was not the only incident that has happened out there but it is probably the largest. Robert Petrovich stated this pot has been on the stove for a while and on October 27 it boiled over. He stated we have been doing our best to try to secure and prohibit trespassing but it has come to a head with latest partying incident. He stated the contractors have also been suffering from theft and burglaries of generators, power tools and other equipment on the site. He stated people are getting caught in structures pulling materials out. He stated although we have a schedule to advance this project, by this action we want to accelerate that process and try to get it done as quickly as possible. He stated we do have people that are still living off of Burnett Road and ancillary to other locations on White Pine and life estates. He stated we certainly don't want to create or at least allow a condition that allows this to continue. Patrick Hogan asked if procedurally we have done everything as far as public safety aspects go. He stated he commends the Sheriff’s Department for their actions in regard to the last incident. Jeff Davis stated the October 27 incident was not the only incident that has happened out there but it is probably the largest. Robert Petrovich stated he is trying not to be draconian about it and the Sheriffs asked what we wanted to do and he told them give them a stern warning but apparently that is not effective. He stated the Sheriff’s Department called again and asked what to do and he said press charges. He stated at some point you have to take action and the latest incident was over the top and that is why we are doing this. Janice Herzog asked what advancing the schedule forward quicker will do. Robert Petrovich stated it eliminates the attractive nuisance. He stated all the structures are going to come down quicker and we are trying to accelerate that schedule to make everything wrap up quicker. He stated our goal is to be done by December 1. 108 Janice Herzog stated it makes the most sense to do it as quick as we can but in terms of our procedures do we already have the bids on who is doing the work. Robert Petrovich stated work is already happening and this resolution is proposing to accelerate this. He stated there are 1,400 acres and we have to keep the road open because there are still people living there. He stated it is not a simple situation. Jeff Davis stated this is affirming and ratifying the decision making process and affirming the fact that this is an emergency situation at this point. Robert Petrovich stated he is trying not to be draconian about it and the Sheriffs asked what we wanted to do and he told them give them a stern warning but apparently that is not effective. He stated the Sheriff’s Department called again and asked what to do and he said press charges. He stated at some point you have to take action and the latest incident was over the top and that is why we are doing this. Janice Herzog asked what advancing the schedule forward quicker will do. Robert Petrovich stated it eliminates the attractive nuisance. He stated all the structures are going to come down quicker and we are trying to accelerate that schedule to make everything wrap up quicker. He stated our goal is to be done by December 1. 108 Janice Herzog stated it makes the most sense to do it as quick as we can but in terms of our procedures do we already have the bids on who is doing the work. Robert Petrovich stated work is already happening and this resolution is proposing to accelerate this. He stated there are 1,400 acres and we have to keep the road open because there are still people living there. He stated it is not a simple situation. Jeff Davis stated this is affirming and ratifying the decision making process and affirming the fact that this is an emergency situation at this point. Jeff Davis stated there is other activity going on at the site and there cannot be people running through the site at night. He stated as the legitimate activities increase and the illegal activities increase at some point it is going to come to a head. He stated this is a process that was started back in December. Kevin Ryan asked if everything that is salvageable has been salvaged. Jeff Davis stated yes. Upon a motion by Janice Herzog, seconded by Kevin Ryan, the OCIDA Board approved a resolution affirming and ratifying the declaration of an emergency action to remove property to protect life, health and property in connection with the development of White Pine Commerce Park. Motion was carried. Jeff Davis stated there is other activity going on at the site and there cannot be people running through the site at night. He stated as the legitimate activities increase and the illegal activities increase at some point it is going to come to a head. He stated this is a process that was started back in December. Kevin Ryan asked if everything that is salvageable has been salvaged. Jeff Davis stated yes. Upon a motion by Janice Herzog, seconded by Kevin Ryan, the OCIDA Board approved a resolution affirming and ratifying the declaration of an emergency action to remove property to protect life, health and property in connection with the development of White Pine Commerce Park. Motion was carried. ADJOURN Upon a motion by Janice Herzog, seconded by Fanny Villarreal, the OCIDA Board adjourned the meeting at 9:03 am. Motion was carried. _________________________________ Nancy Lowery, Secretary 119 ADJOURN Upon a motion by Janice Herzog, seconded by Fanny Villarreal, the OCIDA Board adjourned the meeting at 9:03 am. Motion was carried. _________________________________ Nancy Lowery, Secretary 119 ONONDAGA COUNTY INDUSTRIAL DEVELOPMENT AGENCY 335 MONTGOMERY STREET, 2ND FLOOR, SYRACUSE, NY 13202 PHONE: 315.435.3770 • ECONOMICDEVELOPMENT@ONGOV.NET November 30, 2023 2023 Budget Current YTD Revenue / Expense / Income Current Period Current YTD Amount Change to Budget Operating/Non-Op Revenue 205,551 2,906,743 1,472,880 1,433,863 Administrative Expense 46,108 552,576 816,000 (263,424) Operating/Program Expense 24,252 665,317 656,880 8,437 Net Ordinary Income 135,192 1,688,849 - 1,688,849 Current Assets Current YTD Prior YTD Total Cash 6,549,886 4,191,077 Less Pass Through Received 463,103 - Available Cash 6,086,783 4,191,077 Receivables 230,722 149,691 Total 6,317,505 4,340,768 ONONDAGA COUNTY INDUSTRIAL DEVELOPMENT AGENCY 335 MONTGOMERY STREET, 2ND FLOOR, SYRACUSE, NY 13202 PHONE: 315.435.3770 • ECONOMICDEVELOPMENT@ONGOV.NET November 30, 2023 2023 Budget Current YTD Revenue / Expense / Income Current Period Current YTD Amount Change to Budget Operating/Non-Op Revenue 205,551 2,906,743 1,472,880 1,433,863 Administrative Expense 46,108 552,576 816,000 (263,424) Operating/Program Expense 24,252 665,317 656,880 8,437 Net Ordinary Income 135,192 1,688,849 - 1,688,849 Current Assets Current YTD Prior YTD Total Cash 6,549,886 4,191,077 Less Pass Through Received 463,103 - Available Cash 6,086,783 4,191,077 Receivables 230,722 149,691 Total 6,317,505 4,340,768 Onondaga County Industrial Development Agency Profit and Loss November 2023 TOTAL Income 500 Operating Revenue 2116 Fees 2116.1 Agency Fees 61,322.98 2116.3 WPCP Agency Fee 111,111.11 Total 2116 Fees 172,434.09 2410 Lease Income 2,448.60 Total 500 Operating Revenue 174,882.69 501 Non-Operating Revenue 2401 Interest Income 19,914.29 Total 501 Non-Operating Revenue 19,914.29 527 Nat Grid Matching Grant 10,754.00 534 Pilot & Pass Thru Revenue 528 Pass thru Income 2,910.00 528.003 OHB Redev LLC Funds Pass Thru 18,376.25 529 PILOT Income 25,179.12 Total 534 Pilot & Pass Thru Revenue 46,465.37 550 WPCP Pass Thru Revenue 970,097.59 Total Income $1,222,113.94 GROSS PROFIT $1,222,113.94 Expenses 6400 Operating Expense 6406 Other Professional Services 2,650.75 6407 Administrative Expense 46,107.53 6408 Meeting Expenses 363.94 6409 Conference Attendence 7,800.00 6409.1 Project Events 60.00 6410 Office Expense 1,421.95 6411 Memberships / Sponsorships 3,500.00 Total 6400 Operating Expense 61,904.17 6440 Legal Fees 6450 Barclay Damon 6460 IDA General Legal 4,203.75 Total 6450 Barclay Damon 4,203.75 Total 6440 Legal Fees 4,203.75 6500 Agency Program Expenses 6510 White Pine Commerce Park 6510.5 Insurance 4,251.42 Total 6510 White Pine Commerce Park 4,251.42 Total 6500 Agency Program Expenses 4,251.42 Onondaga County Industrial Development Agency Profit and Loss November 2023 TOTAL Income 500 Operating Revenue 2116 Fees 2116.1 Agency Fees 61,322.98 2116.3 WPCP Agency Fee 111,111.11 Total 2116 Fees 172,434.09 2410 Lease Income 2,448.60 Total 500 Operating Revenue 174,882.69 501 Non-Operating Revenue 2401 Interest Income 19,914.29 Total 501 Non-Operating Revenue 19,914.29 527 Nat Grid Matching Grant 10,754.00 534 Pilot & Pass Thru Revenue 528 Pass thru Income 2,910.00 528.003 OHB Redev LLC Funds Pass Thru 18,376.25 529 PILOT Income 25,179.12 Total 534 Pilot & Pass Thru Revenue 46,465.37 550 WPCP Pass Thru Revenue 970,097.59 Total Income $1,222,113.94 GROSS PROFIT $1,222,113.94 Expenses 6400 Operating Expense 6406 Other Professional Services 2,650.75 6407 Administrative Expense 46,107.53 6408 Meeting Expenses 363.94 6409 Conference Attendence 7,800.00 6409.1 Project Events 60.00 6410 Office Expense 1,421.95 6411 Memberships / Sponsorships 3,500.00 Total 6400 Operating Expense 61,904.17 6440 Legal Fees 6450 Barclay Damon 6460 IDA General Legal 4,203.75 Total 6450 Barclay Damon 4,203.75 Total 6440 Legal Fees 4,203.75 6500 Agency Program Expenses 6510 White Pine Commerce Park 6510.5 Insurance 4,251.42 Total 6510 White Pine Commerce Park 4,251.42 Total 6500 Agency Program Expenses 4,251.42 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 1/2 Onondaga County Industrial Development Agency Profit and Loss November 2023 TOTAL 6600 Non-Operating Expenses 6605 Pilot & Pass Thru Expenses 6605.1 Pass thru Expense 2,910.00 6605.2 PILOT Expense 27,496.73 6606 OHB Redev LLC Funds Pass Thru 18,376.25 Total 6605 Pilot & Pass Thru Expenses 48,782.98 Total 6600 Non-Operating Expenses 48,782.98 6610 WPCP Pass Thru Expenses 6610.1 Barclay Damon 177,777.78 6610.2 JMT 128,787.88 6610.6 Barton & Loguidice 50,059.00 6610.7 Gorick Construction 613,472.93 Total 6610 WPCP Pass Thru Expenses 970,097.59 Total Expenses $1,089,239.91 NET OPERATING INCOME $132,874.03 NET INCOME $132,874.03 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 1/2 Onondaga County Industrial Development Agency Profit and Loss November 2023 TOTAL 6600 Non-Operating Expenses 6605 Pilot & Pass Thru Expenses 6605.1 Pass thru Expense 2,910.00 6605.2 PILOT Expense 27,496.73 6606 OHB Redev LLC Funds Pass Thru 18,376.25 Total 6605 Pilot & Pass Thru Expenses 48,782.98 Total 6600 Non-Operating Expenses 48,782.98 6610 WPCP Pass Thru Expenses 6610.1 Barclay Damon 177,777.78 6610.2 JMT 128,787.88 6610.6 Barton & Loguidice 50,059.00 6610.7 Gorick Construction 613,472.93 Total 6610 WPCP Pass Thru Expenses 970,097.59 Total Expenses $1,089,239.91 NET OPERATING INCOME $132,874.03 NET INCOME $132,874.03 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 2/2 Onondaga County Industrial Development Agency Balance Sheet As of November 30, 2023 TOTAL ASSETS Current Assets Bank Accounts 200 Cash 0.00 200.1 Cash - M & T Checking 4,640,459.49 200.2 Cash - M & T Money Maker Savings 1,918,334.40 200.4 Destiny USA Restricted Cash -8,957.82 210 Petty Cash 50.00 Total 200 Cash 6,549,886.07 Total Bank Accounts $6,549,886.07 Accounts Receivable 380 Accounts Rec. 380.6 A/R Fees, Lease & PILOT 2,134,573.96 Total 380 Accounts Rec. 2,134,573.96 Total Accounts Receivable $2,134,573.96 Other Current Assets 480 Prepaid Expenses 480.4 Credit Balance on Card -3,400.00 Total 480 Prepaid Expenses -3,400.00 Total Other Current Assets $ -3,400.00 Total Current Assets $8,681,060.03 Fixed Assets 100 Land 101 White Pines Commerce Park 4,494,521.05 101.1 WPCP GEIS 101.101 CHA GEIS 1 267,452.05 101.102 CHA GEIS 2 219,439.36 101.104 GEIS Reg Plan Board Overview 19,797.74 Total 101.1 WPCP GEIS 506,689.15 101.2 WPCP Legal 69,774.25 101.3 Engineering Services 52,675.00 101.301 Temporary Access 4,055.44 101.4 Environmental/Demo Services 10,318.98 Total 101.3 Engineering Services 67,049.42 101.5 Land Acquisition Costs 101.501 Land Purchases 1,160,063.57 101.502 Closing Costs 3,168.14 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 2/2 Onondaga County Industrial Development Agency Balance Sheet As of November 30, 2023 TOTAL ASSETS Current Assets Bank Accounts 200 Cash 0.00 200.1 Cash - M & T Checking 4,640,459.49 200.2 Cash - M & T Money Maker Savings 1,918,334.40 200.4 Destiny USA Restricted Cash -8,957.82 210 Petty Cash 50.00 Total 200 Cash 6,549,886.07 Total Bank Accounts $6,549,886.07 Accounts Receivable 380 Accounts Rec. 380.6 A/R Fees, Lease & PILOT 2,134,573.96 Total 380 Accounts Rec. 2,134,573.96 Total Accounts Receivable $2,134,573.96 Other Current Assets 480 Prepaid Expenses 480.4 Credit Balance on Card -3,400.00 Total 480 Prepaid Expenses -3,400.00 Total Other Current Assets $ -3,400.00 Total Current Assets $8,681,060.03 Fixed Assets 100 Land 101 White Pines Commerce Park 4,494,521.05 101.1 WPCP GEIS 101.101 CHA GEIS 1 267,452.05 101.102 CHA GEIS 2 219,439.36 101.104 GEIS Reg Plan Board Overview 19,797.74 Total 101.1 WPCP GEIS 506,689.15 101.2 WPCP Legal 69,774.25 101.3 Engineering Services 52,675.00 101.301 Temporary Access 4,055.44 101.4 Environmental/Demo Services 10,318.98 Total 101.3 Engineering Services 67,049.42 101.5 Land Acquisition Costs 101.501 Land Purchases 1,160,063.57 101.502 Closing Costs 3,168.14 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 1/3 Onondaga County Industrial Development Agency Balance Sheet As of November 30, 2023 TOTAL Total 101.5 Land Acquisition Costs 1,163,231.71 101.6 WPCP Marketing 2,984.34 Total 101 White Pines Commerce Park 6,304,249.92 106 North Salina Properties 0.00 106.1 435 North Salina 17,083.55 106.3 435 North Salina Building 634,421.53 Total 106 North Salina Properties 651,505.08 107 800 Hiawatha 604,840.42 Total 100 Land 7,560,595.42 104 Machinery & Equipment 104.1 Office Furniture 1,429.00 104.2 Equipment 4,589.00 Total 104 Machinery & Equipment 6,018.00 211 A/D Office Furniture -4,124.00 213 A/D Buildings -113,870.00 250 Investment in Real Property 29,508,083.00 Total Fixed Assets $36,956,702.42 Other Assets 240 Blue Sky Redevelopment 1,641.76 Total Other Assets $1,641.76 TOTAL ASSETS $45,639,404.21 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 1/3 Onondaga County Industrial Development Agency Balance Sheet As of November 30, 2023 TOTAL Total 101.5 Land Acquisition Costs 1,163,231.71 101.6 WPCP Marketing 2,984.34 Total 101 White Pines Commerce Park 6,304,249.92 106 North Salina Properties 0.00 106.1 435 North Salina 17,083.55 106.3 435 North Salina Building 634,421.53 Total 106 North Salina Properties 651,505.08 107 800 Hiawatha 604,840.42 Total 100 Land 7,560,595.42 104 Machinery & Equipment 104.1 Office Furniture 1,429.00 104.2 Equipment 4,589.00 Total 104 Machinery & Equipment 6,018.00 211 A/D Office Furniture -4,124.00 213 A/D Buildings -113,870.00 250 Investment in Real Property 29,508,083.00 Total Fixed Assets $36,956,702.42 Other Assets 240 Blue Sky Redevelopment 1,641.76 Total Other Assets $1,641.76 TOTAL ASSETS $45,639,404.21 LIABILITIES AND EQUITY Liabilities Current Liabilities Accounts Payable 300 WPCP Pass Thru Payable 2,066,845.56 Total Accounts Payable $2,066,845.56 Other Current Liabilities 600 Accounts Payable 0.00 600.1 Due to Related Party - OED 552,575.63 600.102 Due to BD WPCP -0.34 600.204 OHB Redev LLC Funds 251,658.15 600.205 Exp Pay Prev Period 9,700.03 600.206 Mileage Reimbursement 0.34 600.208 BlueRock Energy Agreement Deposit 25,000.00 600.209 Syracuse Rail Overpayment 500.00 600.3 Onondaga County Loan 28,079,656.77 600.31 Accrued Interest - OC Note Payable 488,656.00 Total 600.3 Onondaga County Loan 28,568,312.77 LIABILITIES AND EQUITY Liabilities Current Liabilities Accounts Payable 300 WPCP Pass Thru Payable 2,066,845.56 Total Accounts Payable $2,066,845.56 Other Current Liabilities 600 Accounts Payable 0.00 600.1 Due to Related Party - OED 552,575.63 600.102 Due to BD WPCP -0.34 600.204 OHB Redev LLC Funds 251,658.15 600.205 Exp Pay Prev Period 9,700.03 600.206 Mileage Reimbursement 0.34 600.208 BlueRock Energy Agreement Deposit 25,000.00 600.209 Syracuse Rail Overpayment 500.00 600.3 Onondaga County Loan 28,079,656.77 600.31 Accrued Interest - OC Note Payable 488,656.00 Total 600.3 Onondaga County Loan 28,568,312.77 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 2/3 Onondaga County Industrial Development Agency Balance Sheet As of November 30, 2023 TOTAL Total 600 Accounts Payable 29,407,746.58 601 PILOT and Pass Thru Payable 602 Pass Thru Payable 32,471.00 603 PILOT Pass Thru -1,431.78 Total 601 PILOT and Pass Thru Payable 31,039.22 631 Due to Other Governments 631.1 Towns 631.15 Salina -0.81 Total 631.1 Towns -0.81 631.3 Schools 631.356 Syracuse -0.10 Total 631.3 Schools -0.10 631.4 Onondaga County -0.09 631.5 City of Syracuse -0.36 Total 631 Due to Other Governments -1.36 Total Other Current Liabilities $29,438,784.44 Total Current Liabilities $31,505,630.00 Total Liabilities $31,505,630.00 Equity 3900 Equity Unreserved 9,753,381.97 3901 Equity-Investment Fixed Assets 2,345,838.63 463 Reserve For Contracts 368,811.84 465 Equity - Unreserved 4,017.16 Net Income 1,661,724.61 Total Equity $14,133,774.21 TOTAL LIABILITIES AND EQUITY $45,639,404.21 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 2/3 Onondaga County Industrial Development Agency Balance Sheet As of November 30, 2023 TOTAL Total 600 Accounts Payable 29,407,746.58 601 PILOT and Pass Thru Payable 602 Pass Thru Payable 32,471.00 603 PILOT Pass Thru -1,431.78 Total 601 PILOT and Pass Thru Payable 31,039.22 631 Due to Other Governments 631.1 Towns 631.15 Salina -0.81 Total 631.1 Towns -0.81 631.3 Schools 631.356 Syracuse -0.10 Total 631.3 Schools -0.10 631.4 Onondaga County -0.09 631.5 City of Syracuse -0.36 Total 631 Due to Other Governments -1.36 Total Other Current Liabilities $29,438,784.44 Total Current Liabilities $31,505,630.00 Total Liabilities $31,505,630.00 Equity 3900 Equity Unreserved 9,753,381.97 3901 Equity-Investment Fixed Assets 2,345,838.63 463 Reserve For Contracts 368,811.84 465 Equity - Unreserved 4,017.16 Net Income 1,661,724.61 Total Equity $14,133,774.21 TOTAL LIABILITIES AND EQUITY $45,639,404.21 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 3/3 Accrual Basis Wednesday, December 6, 2023 12:48 PM GMT-05:00 3/3 ONONDAGA COUNTY INDUSTRIAL DEVELOPMENT AGENCY PAYMENT OF BILLS - SCHEDULE #488 December 14, 2023 ONONDAGA COUNTY INDUSTRIAL DEVELOPMENT AGENCY PAYMENT OF BILLS - SCHEDULE #488 December 14, 2023 GENERAL EXPENSES 1. UNITED STATES LIABILITY INSURANCE COMPANY* $ 349.00 Policy #XL1634729 2. BARCLAY DAMON LLP $ 177,777.78 October 2023 Legal Costs 3. JMT OF NEW YORK, INC. $ 128,787.88 October 2023 Engineering Costs 4. BARTON & LOGUIDICE $ 8,100.00 August 2023 Pre-Demolition Costs 5. GORICK CONSTRUCTION CO., INC. $ 148,437.50 Pre-Demolition Costs 6. ONONDAGA COUNTY $ 883.50 3rd Q 2023 Permit Reviews 7. NAFTZ $ 1,250.00 Annual Membership, Inv#1090 8. PARK STRATEGIES, LLC $ 7,500.00 Consulting Services, Inv#'s 16588758, 16588757, 16588958 9. BARTON & LOGUIDICE, D.P.C. $ 4,400.00 Brewerton Rd Phase I ESA, Inv#133728 10. LEN RAUCH $ 38.99 Meeting Reimbursement 11. BARTON & LOGUIDICE $ 5,527.86 Caughdenoy Business Park, Inv#138029 *Ratification of Check dated November 9, 2023 Schedule#487 page 2 12 BARTON & LOGUIDICE $ 31,303.13 Caughdenoy Business Park, Inv#138030 GENERAL EXPENSES 1. UNITED STATES LIABILITY INSURANCE COMPANY* $ 349.00 Policy #XL1634729 2. BARCLAY DAMON LLP $ 177,777.78 October 2023 Legal Costs 3. JMT OF NEW YORK, INC. $ 128,787.88 October 2023 Engineering Costs 4. BARTON & LOGUIDICE $ 8,100.00 August 2023 Pre-Demolition Costs 5. GORICK CONSTRUCTION CO., INC. $ 148,437.50 Pre-Demolition Costs 6. ONONDAGA COUNTY $ 883.50 3rd Q 2023 Permit Reviews 7. NAFTZ $ 1,250.00 Annual Membership, Inv#1090 8. PARK STRATEGIES, LLC $ 7,500.00 Consulting Services, Inv#'s 16588758, 16588757, 16588958 9. BARTON & LOGUIDICE, D.P.C. $ 4,400.00 Brewerton Rd Phase I ESA, Inv#133728 10. LEN RAUCH $ 38.99 Meeting Reimbursement 11. BARTON & LOGUIDICE $ 5,527.86 Caughdenoy Business Park, Inv#138029 *Ratification of Check dated November 9, 2023 Schedule#487 page 2 12 BARTON & LOGUIDICE $ 31,303.13 Caughdenoy Business Park, Inv#138030 13 BARCLAY DAMON LLP $ 75.00 Roth Steel, Inv#5262904 14 BARCLAY DAMON LLP $ 1,537.50 IDA Legal, Inv#5263730 15 ABC CREATIVE GROUP, LLC $ 14,000.00 Marketing/Public Relations, Inv#8030 TOTAL $ 529,968.14 13 BARCLAY DAMON LLP $ 75.00 Roth Steel, Inv#5262904 14 BARCLAY DAMON LLP $ 1,537.50 IDA Legal, Inv#5263730 15 ABC CREATIVE GROUP, LLC $ 14,000.00 Marketing/Public Relations, Inv#8030 TOTAL $ 529,968.14 ONONDAGA COUNTY INDUSTRIAL DEVELOPMENT AGENCY PAYMENT OF BILLS - SCHEDULE #488 December 14, 2023 PILOT Payments 1. ONONDAGA COUNTY* $ 1,406.83 Syracuse Rail 3rd Q PILOT Payment 2. TOWN OF ONONDAGA* $ 4.39 Syracuse Rail 3rd Q PILOT Payment 3. TOWN OF DEWITT* $ 21.56 Syracuse Rail 3rd Q PILOT Payment TOTAL $1,432.78 *Ratification of Checks dated November 16, 2023 1 21 22 23 24 25 26 27 ONONDAGA COUNTY INDUSTRIAL DEVELOPMENT AGENCY PAYMENT OF BILLS - SCHEDULE #488 December 14, 2023 PILOT Payments 1. ONONDAGA COUNTY* $ 1,406.83 Syracuse Rail 3rd Q PILOT Payment 2. TOWN OF ONONDAGA* $ 4.39 Syracuse Rail 3rd Q PILOT Payment 3. TOWN OF DEWITT* $ 21.56 Syracuse Rail 3rd Q PILOT Payment TOTAL $1,432.78 *Ratification of Checks dated November 16, 2023 1 21 22 23 24 25 26 27 MICRON SEMICONDUCTOR FABRICATION CLAY, NY MICRON SEMICONDUCTOR FABRICATION CLAY, NY FINAL SEQRA SCOPE OF WORK December 14, 2023 28 FINAL SEQRA SCOPE OF WORK December 14, 2023 28 CONTENTS 1 INTRODUCTION .................................................................................................................................. 1 1.1 PROPOSED PROJECT OVERVIEW AND DESCRIPTION........................................................... 1 1.1.1 Proposed Project Location ....................................................................................... 2 1.1.2 Project Background ................................................................................................... 2 1.1.3 Project Description ..................................................................................................... 5 1.1.3.1 Micron Campus.......................................................................................... 5 1.1.3.2 Off-Site Improvements ............................................................................... 7 1.1.3.3 Proposed Project Employment................................................................. 9 2 THE SCOPING PROCESS AND AGENCY COORDINATION ........................................................... 11 3 PURPOSE AND NEED ........................................................................................................................ 13 3.1 PURPOSE AND NEED .............................................................................................................. 13 3.2 PROJECT BACKGROUND ...................................................................................................... 13 4 PROJECT ALTERNATIVES .................................................................................................................. 18 4.1 INTRODUCTION ...................................................................................................................... 18 4.2 DISCUSSION OF ALTERNATIVE PROJECT LOCATIONS ......................................................... 18 4.2.1 Alternative Sites in New York State ......................................................................... 18 4.2.2 Alternative Sites and Design Options in Onondaga County .............................. 19 4.2.3 Other Alternatives Considered but Determined Not Feasible............................ 20 4.3 ALTERNATIVES TO BE CONSIDERED IN THE DEIS .................................................................. 20 4.3.1 No Action Alternative .............................................................................................. 20 4.3.2 The Proposed Project ............................................................................................... 20 4.3.3 The Proposed Project with No Access from US Route 11 .................................... 21 4.3.4 Alternative Internal Configurations of the Proposed Project .............................. 21 4.3.5 Reduced Scale Proposed Project .......................................................................... 21 5 ANALYSIS FRAMEWORK .................................................................................................................. 23 5.1 ORGANIZATION OF THE ENVIRONMENTAL IMPACT STATEMENT ....................................... 23 5.2 ANALYSIS YEARS ..................................................................................................................... 24 5.3 METHODOLOGIES FOR TECHNICAL ANALYSES ................................................................... 25 5.3.1 Technical Studies ...................................................................................................... 25 6 AGENCY AND PUBLIC COORDINATION ........................................................................................ 34 6.1 AGENCY COORDINATION ACTIVITIES ................................................................................. 34 APPENDIX A ............................................................................................................................................... 37 APPENDIX B: RESPONSE TO COMMENTS CONTENTS 1 INTRODUCTION .................................................................................................................................. 1 1.1 PROPOSED PROJECT OVERVIEW AND DESCRIPTION........................................................... 1 1.1.1 Proposed Project Location ....................................................................................... 2 1.1.2 Project Background ................................................................................................... 2 1.1.3 Project Description ..................................................................................................... 5 1.1.3.1 Micron Campus.......................................................................................... 5 1.1.3.2 Off-Site Improvements ............................................................................... 7 1.1.3.3 Proposed Project Employment................................................................. 9 2 THE SCOPING PROCESS AND AGENCY COORDINATION ........................................................... 11 3 PURPOSE AND NEED ........................................................................................................................ 13 3.1 PURPOSE AND NEED .............................................................................................................. 13 3.2 PROJECT BACKGROUND ...................................................................................................... 13 4 PROJECT ALTERNATIVES .................................................................................................................. 18 4.1 INTRODUCTION ...................................................................................................................... 18 4.2 DISCUSSION OF ALTERNATIVE PROJECT LOCATIONS ......................................................... 18 4.2.1 Alternative Sites in New York State ......................................................................... 18 4.2.2 Alternative Sites and Design Options in Onondaga County .............................. 19 4.2.3 Other Alternatives Considered but Determined Not Feasible............................ 20 4.3 ALTERNATIVES TO BE CONSIDERED IN THE DEIS .................................................................. 20 4.3.1 No Action Alternative .............................................................................................. 20 4.3.2 The Proposed Project ............................................................................................... 20 4.3.3 The Proposed Project with No Access from US Route 11 .................................... 21 4.3.4 Alternative Internal Configurations of the Proposed Project .............................. 21 4.3.5 Reduced Scale Proposed Project .......................................................................... 21 5 ANALYSIS FRAMEWORK .................................................................................................................. 23 5.1 ORGANIZATION OF THE ENVIRONMENTAL IMPACT STATEMENT ....................................... 23 5.2 ANALYSIS YEARS ..................................................................................................................... 24 5.3 METHODOLOGIES FOR TECHNICAL ANALYSES ................................................................... 25 5.3.1 Technical Studies ...................................................................................................... 25 6 AGENCY AND PUBLIC COORDINATION ........................................................................................ 34 6.1 AGENCY COORDINATION ACTIVITIES ................................................................................. 34 APPENDIX A ............................................................................................................................................... 37 APPENDIX B: RESPONSE TO COMMENTS 12/14/2023 i 29 12/14/2023 i 29 TABLES TABLE 1 SUMMARY OF ALTERNATIVES CONSIDERED OR TO BE CONSIDERED................................................. 22 TABLE 2 PRELIMINARY LIST OF SEQRA LEAD, INVOLVED, AND INTERESTED AGENCIES ................................... 35 TABLE 3 PRELIMINARY LIST OF FEDERAL AGENCIES .................................................................................... 36 TABLES TABLE 1 SUMMARY OF ALTERNATIVES CONSIDERED OR TO BE CONSIDERED................................................. 22 TABLE 2 PRELIMINARY LIST OF SEQRA LEAD, INVOLVED, AND INTERESTED AGENCIES ................................... 35 TABLE 3 PRELIMINARY LIST OF FEDERAL AGENCIES .................................................................................... 36 FIGURES FIGURE 1 VICINITY MAP............................................................................................................................ 3 FIGURE 2 LOCATION OF PROPOSED PROJECT ............................................................................................. 4 FIGURE 3 PROPOSED SITE PLAN FOR MICRON CAMPUS ............................................................................... 6 FIGURE 4 PROPOSED PROJECT AND OFF-SITE IMPROVEMENTS..................................................................... 10 FIGURES FIGURE 1 VICINITY MAP............................................................................................................................ 3 FIGURE 2 LOCATION OF PROPOSED PROJECT ............................................................................................. 4 FIGURE 3 PROPOSED SITE PLAN FOR MICRON CAMPUS ............................................................................... 6 FIGURE 4 PROPOSED PROJECT AND OFF-SITE IMPROVEMENTS..................................................................... 10 APPENDICES APPENDIX A: TRAFFIC COUNT LOCATIONS FIGURE A-1 TRAFFIC STUDY AREA .......................................................................................................... 38 FIGURE A-2 AUTOMATIC TRAFFIC RECORDER (ATR) COUNT LOCATIONS ......................................... 40 FIGURE A-3 TURNING MOVEMENT COUNT (TMC) COUNT LOCATIONS ............................................. 41 FIGURE A-4 VEHICLE CLASSIFICATION COUNT (VCC) COUNT LOCATIONS ...................................... 42 12/14/2023 ii 30 APPENDICES APPENDIX A: TRAFFIC COUNT LOCATIONS FIGURE A-1 TRAFFIC STUDY AREA .......................................................................................................... 38 FIGURE A-2 AUTOMATIC TRAFFIC RECORDER (ATR) COUNT LOCATIONS ......................................... 40 FIGURE A-3 TURNING MOVEMENT COUNT (TMC) COUNT LOCATIONS ............................................. 41 FIGURE A-4 VEHICLE CLASSIFICATION COUNT (VCC) COUNT LOCATIONS ...................................... 42 12/14/2023 ii 30 ABBREVIATIONS ADA ........................................................................................................... Americans with Disabilities Act CEQ ...................................................................................................... Council on Environmental Quality CFR................................................................................................................ Code of Federal Regulations CLCPA .................................................................. Climate Leadership and Community Protection Act DEIS ..............................................................................................Draft Environmental Impact Statement EIS .......................................................................................................... Environmental Impact Statement FHWA ....................................................................................................... Federal Highway Administration GEIS ........................................................................................ Generic Environmental Impact Statement GHG .................................................................................................................................. Greenhouse Gas LWRP .......................................................................................... Local Waterfront Revitalization Program MSAT ....................................................................................................................... Mobile Source Air Toxic NAAQS .......................................................................................National Ambient Air Quality Standards NEPA .................................................................................................... National Environmental Policy Act NOI ....................................................................................................................................... Notice of Intent NYSDEC .................................................. New York State Department of Environmental Conservation NYSDOT ........................................................................... New York State Department of Transportation OCDOT .....................................................................Onondaga County Department of Transportation OCDWEP ...................................... Onondaga County Department of Water Environment Protection OCIDA .................................................................. Onondaga County Industrial Development Agency OCWA .............................................................................................. Onondaga County Water Authority OPRHP ...................................... New York State Office of Parks, Recreation and Historic Preservation SEQRA ...................................................................... New York State Environmental Quality Review Act SGEIS .............................................................Supplemental Generic Environmental Impact Statement SHPO ...................................................................................................... State Historic Preservation Office SMTC ................................................................................Syracuse Metropolitan Transportation Council SPDES ................................................................................. State Pollutant Discharge Elimination System SWPPP ............................................................................................. Stormwater Pollution Prevention Plan TEM ..................................................................................................... NYSDOT’s The Environment Manual USACE ........................................................................................... United States Army Corps of Engineers U.S.C. ............................................................................................................................ United States Code USEPA .......................................................................... United States Environmental Protection Agency USFWS ............................................................................................ United States Fish and Wildlife Service WPCP .............................................................................................................. White Pine Commerce Park WWTP ............................................................................................................ Wastewater Treatment Plant ABBREVIATIONS ADA ........................................................................................................... Americans with Disabilities Act CEQ ...................................................................................................... Council on Environmental Quality CFR................................................................................................................ Code of Federal Regulations CLCPA .................................................................. Climate Leadership and Community Protection Act DEIS ..............................................................................................Draft Environmental Impact Statement EIS .......................................................................................................... Environmental Impact Statement FHWA ....................................................................................................... Federal Highway Administration GEIS ........................................................................................ Generic Environmental Impact Statement GHG .................................................................................................................................. Greenhouse Gas LWRP .......................................................................................... Local Waterfront Revitalization Program MSAT ....................................................................................................................... Mobile Source Air Toxic NAAQS .......................................................................................National Ambient Air Quality Standards NEPA .................................................................................................... National Environmental Policy Act NOI ....................................................................................................................................... Notice of Intent NYSDEC .................................................. New York State Department of Environmental Conservation NYSDOT ........................................................................... New York State Department of Transportation OCDOT .....................................................................Onondaga County Department of Transportation OCDWEP ...................................... Onondaga County Department of Water Environment Protection OCIDA .................................................................. Onondaga County Industrial Development Agency OCWA .............................................................................................. Onondaga County Water Authority OPRHP ...................................... New York State Office of Parks, Recreation and Historic Preservation SEQRA ...................................................................... New York State Environmental Quality Review Act SGEIS .............................................................Supplemental Generic Environmental Impact Statement SHPO ...................................................................................................... State Historic Preservation Office SMTC ................................................................................Syracuse Metropolitan Transportation Council SPDES ................................................................................. State Pollutant Discharge Elimination System SWPPP ............................................................................................. Stormwater Pollution Prevention Plan TEM ..................................................................................................... NYSDOT’s The Environment Manual USACE ........................................................................................... United States Army Corps of Engineers U.S.C. ............................................................................................................................ United States Code USEPA .......................................................................... United States Environmental Protection Agency USFWS ............................................................................................ United States Fish and Wildlife Service WPCP .............................................................................................................. White Pine Commerce Park WWTP ............................................................................................................ Wastewater Treatment Plant 12/14/2023 iii 31 This page is left blank intentionally. 12/14/2023 iv 32 12/14/2023 iii 31 This page is left blank intentionally. 12/14/2023 iv 32 1 Introduction Micron New York Semiconductor Manufacturing LLC (Micron), a Delaware limited liability company (LLC) and wholly owned subsidiary of Micron Technology, Inc., is proposing to construct a semiconductor manufacturing campus (the “Micron Campus”) in the Town of Clay, New York, at the White Pine Commerce Park (WPCP), an approximately 1,400-acre industrial park controlled by the Onondaga County Industrial Development Agency (OCIDA). The Micron Campus, together with ancillary development on nearby properties (described below), are referred to collectively as the “Proposed Project.” After receipt of an Application for Financial Assistance from Micron, OCIDA circulated a notice of intent to serve as State Environmental Quality Review Act (SEQRA) (6 NYCRR Part 617) (New York Environmental Conservation Law §§8-0101 et seq.) Lead Agency on July 28, 2023. No objections to that notice were received during the 30-day period commencing on that date. At its regular meeting of September 14, 2023, OCIDA issued a Positive Declaration, indicating the need for an Environmental Impact Statement (EIS), and scheduled a public scoping meeting held on October 11, 2023. 1 Introduction Micron New York Semiconductor Manufacturing LLC (Micron), a Delaware limited liability company (LLC) and wholly owned subsidiary of Micron Technology, Inc., is proposing to construct a semiconductor manufacturing campus (the “Micron Campus”) in the Town of Clay, New York, at the White Pine Commerce Park (WPCP), an approximately 1,400-acre industrial park controlled by the Onondaga County Industrial Development Agency (OCIDA). The Micron Campus, together with ancillary development on nearby properties (described below), are referred to collectively as the “Proposed Project.” After receipt of an Application for Financial Assistance from Micron, OCIDA circulated a notice of intent to serve as State Environmental Quality Review Act (SEQRA) (6 NYCRR Part 617) (New York Environmental Conservation Law §§8-0101 et seq.) Lead Agency on July 28, 2023. No objections to that notice were received during the 30-day period commencing on that date. At its regular meeting of September 14, 2023, OCIDA issued a Positive Declaration, indicating the need for an Environmental Impact Statement (EIS), and scheduled a public scoping meeting held on October 11, 2023. Micron, as the Project Sponsor, will prepare a draft Environmental Impact Statement (DEIS) pursuant to SEQRA. Since Micron is seeking federal funding under the “Creating Helpful Incentives to Produce Semiconductors and Science Act of 2022 (the “CHIPS Act”) and the Proposed Project will require certain federal permits and approvals that require federal environmental review, including, but not limited to, federal wetlands permits pursuant to Section 404 of the Clean Water Act, the SEQRA DEIS will also contain information to support the National Environmental Policy Act (NEPA) of 1969 (42 United States Code (U.S.C.) § 4321 et seq.) review. This document is the Final SEQRA Scope for the proposed DEIS. It was prepared pursuant to 6 NYCRR Part 617.8 and provides: (1) a brief description of the Proposed Project; (2) an identification of potentially significant adverse impacts from the SEQRA Environmental Assessment Form and through consultation with Federal, State, and local agencies; (3) the extent and quality of information needed to adequately address each impact; (4) an initial identification of mitigation measures; and (5) the reasonable alternatives to be considered. Micron, as the Project Sponsor, will prepare a draft Environmental Impact Statement (DEIS) pursuant to SEQRA. Since Micron is seeking federal funding under the “Creating Helpful Incentives to Produce Semiconductors and Science Act of 2022 (the “CHIPS Act”) and the Proposed Project will require certain federal permits and approvals that require federal environmental review, including, but not limited to, federal wetlands permits pursuant to Section 404 of the Clean Water Act, the SEQRA DEIS will also contain information to support the National Environmental Policy Act (NEPA) of 1969 (42 United States Code (U.S.C.) § 4321 et seq.) review. This document is the Final SEQRA Scope for the proposed DEIS. It was prepared pursuant to 6 NYCRR Part 617.8 and provides: (1) a brief description of the Proposed Project; (2) an identification of potentially significant adverse impacts from the SEQRA Environmental Assessment Form and through consultation with Federal, State, and local agencies; (3) the extent and quality of information needed to adequately address each impact; (4) an initial identification of mitigation measures; and (5) the reasonable alternatives to be considered. 1.1 PROPOSED PROJECT OVERVIEW AND DESCRIPTION Micron is a world leader in innovative memory solutions that transform how the world uses information. For over 40 years, the company has been instrumental to the world’s most significant technology advancements, delivering optimal memory and storage systems for a broad range of applications. Memory is at the leading edge of semiconductor manufacturing and fuels everything from feature-rich 5G smartphones to the AI-enabled cloud. Micron’s leadership in both 12/14/2023 1 33 DRAM and NAND technologies provides the market-based confidence to invest up to $100 billion to affirm the company’s industry-leading memory innovation and deliver differentiated products to its customers. 1.1 PROPOSED PROJECT OVERVIEW AND DESCRIPTION Micron is a world leader in innovative memory solutions that transform how the world uses information. For over 40 years, the company has been instrumental to the world’s most significant technology advancements, delivering optimal memory and storage systems for a broad range of applications. Memory is at the leading edge of semiconductor manufacturing and fuels everything from feature-rich 5G smartphones to the AI-enabled cloud. Micron’s leadership in both 12/14/2023 1 33 DRAM and NAND technologies provides the market-based confidence to invest up to $100 billion to affirm the company’s industry-leading memory innovation and deliver differentiated products to its customers. Micron’s proposed semiconductor manufacturing facility campus (“Micron Campus”) in the Town of Clay, Onondaga County, New York will be built-out over an approximate 20-year period, and will consist of the construction of four (4) Memory Fabrication facilities (Fabs). Micron expects that the Fabs will be built in sequence, with construction of each Fab starting as the preceding Fab is being fit-out with manufacturing equipment and operations begun (the DEIS will analyze two interim analysis years as well as a final year of completion). This process will result in continuous construction activities on the site over the approximate 20-year period, with a significant portion of that construction occurring inside previously-constructed Fab buildings. Micron intends to start construction of the Micron Campus in 2024 with Fabs 1 and 2 operational by 2032. Fabs 3 and 4 would be operational by 2041. Micron’s proposed semiconductor manufacturing facility campus (“Micron Campus”) in the Town of Clay, Onondaga County, New York will be built-out over an approximate 20-year period, and will consist of the construction of four (4) Memory Fabrication facilities (Fabs). Micron expects that the Fabs will be built in sequence, with construction of each Fab starting as the preceding Fab is being fit-out with manufacturing equipment and operations begun (the DEIS will analyze two interim analysis years as well as a final year of completion). This process will result in continuous construction activities on the site over the approximate 20-year period, with a significant portion of that construction occurring inside previously-constructed Fab buildings. Micron intends to start construction of the Micron Campus in 2024 with Fabs 1 and 2 operational by 2032. Fabs 3 and 4 would be operational by 2041. 1.1.1 Proposed Project Location The proposed Micron Campus is an approximately 1,400-acre assemblage of land located at the White Pine Commerce Park (WPCP) in the Town of Clay bordered by NYS Route 31 to the south, Caughdenoy Road to the west, a series of National Grid overhead power lines to the north (although the Micron Campus extends approximately 100 feet beyond the power lines), and the Town of Clay/Town of Cicero boundary line to the east. Most of the Micron Campus is contained within the Town of Clay, Onondaga County, New York and is accessible from I-81 via an interchange with NYS Route 31. Figure 1 identifies the broader vicinity within which the Micron Campus would be located. Figure 2 identifies the Micron Campus in relation to surrounding roadways. 1.1.1 Proposed Project Location The proposed Micron Campus is an approximately 1,400-acre assemblage of land located at the White Pine Commerce Park (WPCP) in the Town of Clay bordered by NYS Route 31 to the south, Caughdenoy Road to the west, a series of National Grid overhead power lines to the north (although the Micron Campus extends approximately 100 feet beyond the power lines), and the Town of Clay/Town of Cicero boundary line to the east. Most of the Micron Campus is contained within the Town of Clay, Onondaga County, New York and is accessible from I-81 via an interchange with NYS Route 31. Figure 1 identifies the broader vicinity within which the Micron Campus would be located. Figure 2 identifies the Micron Campus in relation to surrounding roadways. 1.1.2 Project Background OCIDA completed a Generic Environmental Impact Statement (GEIS) in 2013 and a Supplemental GEIS (SGEIS) in 2021 on potential development of WPCP with manufacturing use. See Section 3.2 for additional information on the project background and OCIDA’s efforts to prepare a shovel- ready site for manufacturing use, with a particular focus on the semiconductor industry. 12/14/2023 2 34 1.1.2 Project Background OCIDA completed a Generic Environmental Impact Statement (GEIS) in 2013 and a Supplemental GEIS (SGEIS) in 2021 on potential development of WPCP with manufacturing use. See Section 3.2 for additional information on the project background and OCIDA’s efforts to prepare a shovel- ready site for manufacturing use, with a particular focus on the semiconductor industry. 12/14/2023 2 34 FIGURE 1 VICINITY MAP 12/14/2023 3 35 FIGURE 1 VICINITY MAP 12/14/2023 3 35 FIGURE 2 LOCATION OF PROPOSED PROJECT 12/14/2023 4 36 FIGURE 2 LOCATION OF PROPOSED PROJECT 12/14/2023 4 36 1.1.3 Project Description 1.1.3.1 Micron Campus The Micron Campus would comprise approximately 1,400 acres, consisting of the enlarged WPCP parcel studied in the 2021 SGEIS along with additional contiguous acreage acquired or to be acquired by OCIDA or Micron. Each Fab is expected to cover approximately 1.2 million sf of land and contain approximately 600,000 sf of cleanroom space 1, 290,000 sf of cleanroom support space2, and 250,000 sf of administrative space. Each set of two Fabs will be supported by approximately 470,000 sf of central utility buildings3, 200,000 sf of warehouse space, and 200,000 sf of product testing space4 housed in separate buildings. The Micron Campus will also have ancillary on-site electrical substations, as well as facilities for water and wastewater treatment and storage, along with industrial gas storage. See Figure 3 for a preliminary site plan of the proposed Micron Campus. Two (2) additional properties will be developed with uses ancillary to the Micron Campus (see Figure 4): ▪ An approximately 30.2-acre parcel on the north side of Caughdenoy Road (Town of Clay tax parcel 042.-01-13.0, 9100 Caughdenoy Road) (the “Childcare Site”) on which Micron will construct an employee health care center and childcare center; and ▪ An approximately 1-acre parcel on the northwest side of the WPCP (048.-01-02.1) (“jack and bore site”) which will be used for utility line conveyance. 1.1.3 Project Description 1.1.3.1 Micron Campus The Micron Campus would comprise approximately 1,400 acres, consisting of the enlarged WPCP parcel studied in the 2021 SGEIS along with additional contiguous acreage acquired or to be acquired by OCIDA or Micron. Each Fab is expected to cover approximately 1.2 million sf of land and contain approximately 600,000 sf of cleanroom space 1, 290,000 sf of cleanroom support space2, and 250,000 sf of administrative space. Each set of two Fabs will be supported by approximately 470,000 sf of central utility buildings3, 200,000 sf of warehouse space, and 200,000 sf of product testing space4 housed in separate buildings. The Micron Campus will also have ancillary on-site electrical substations, as well as facilities for water and wastewater treatment and storage, along with industrial gas storage. See Figure 3 for a preliminary site plan of the proposed Micron Campus. Two (2) additional properties will be developed with uses ancillary to the Micron Campus (see Figure 4): ▪ An approximately 30.2-acre parcel on the north side of Caughdenoy Road (Town of Clay tax parcel 042.-01-13.0, 9100 Caughdenoy Road) (the “Childcare Site”) on which Micron will construct an employee health care center and childcare center; and ▪ An approximately 1-acre parcel on the northwest side of the WPCP (048.-01-02.1) (“jack and bore site”) which will be used for utility line conveyance. The Micron Campus, with four (4) Fabs and all ancillary support facilities, driveways, and parking; the jack and bore site; and the Childcare Site comprise the “Proposed Project.” The DEIS will include additional description of each element of the Proposed Project as well as a high-level description of key Micron systems to provide an understanding of Micron’s proposed use and management of water, chemicals, and energy serving the site (including provisions for renewable energy sources). The DEIS will also describe Micron’s generation and management of various waste streams and how best management practices will be implemented to limit energy consumption, water consumption, air pollutants, and generation of waste. The Micron Campus, with four (4) Fabs and all ancillary support facilities, driveways, and parking; the jack and bore site; and the Childcare Site comprise the “Proposed Project.” The DEIS will include additional description of each element of the Proposed Project as well as a high-level description of key Micron systems to provide an understanding of Micron’s proposed use and management of water, chemicals, and energy serving the site (including provisions for renewable energy sources). The DEIS will also describe Micron’s generation and management of various waste streams and how best management practices will be implemented to limit energy consumption, water consumption, air pollutants, and generation of waste. 1 Cleanroom: This part of the campus is where the thousands of advanced pieces of equipment are housed that are used to take raw silicon wafers and build the chips. It is called a cleanroom because there are strict requirements on particles in the air that can impact the functionality of the chips. The chips are built up in layers of metals and insulators, similar to how a building is constructed floor-by-floor. 2 Cleanroom support: This part of the campus includes functions such as workshops to refurbish parts, labs to complete incoming chemical tests, surface analysis of what is on the wafers, and analysis of cross-sections of the wafer to validate the structure of the chips meets requirements. 3 Central utility building: These buildings house the systems required for delivering the utilities necessary to produce the chips. These utilities include systems such as HVAC, electrical transmission equipment, water purification and recycling, and chemical/specialty gas delivery systems. 4 Product testing space: This space is used to house advanced equipment that takes finished wafers and performs electrical testing that validates the chips function to required specifications before the wafers are shipped out for assembly into products and further testing. 12/14/2023 5 37 1 Cleanroom: This part of the campus is where the thousands of advanced pieces of equipment are housed that are used to take raw silicon wafers and build the chips. It is called a cleanroom because there are strict requirements on particles in the air that can impact the functionality of the chips. The chips are built up in layers of metals and insulators, similar to how a building is constructed floor-by-floor. 2 Cleanroom support: This part of the campus includes functions such as workshops to refurbish parts, labs to complete incoming chemical tests, surface analysis of what is on the wafers, and analysis of cross-sections of the wafer to validate the structure of the chips meets requirements. 3 Central utility building: These buildings house the systems required for delivering the utilities necessary to produce the chips. These utilities include systems such as HVAC, electrical transmission equipment, water purification and recycling, and chemical/specialty gas delivery systems. 4 Product testing space: This space is used to house advanced equipment that takes finished wafers and performs electrical testing that validates the chips function to required specifications before the wafers are shipped out for assembly into products and further testing. 12/14/2023 5 37 FIGURE 3 PROPOSED SITE PLAN FOR MICRON CAMPUS 12/14/2023 6 38 FIGURE 3 PROPOSED SITE PLAN FOR MICRON CAMPUS 12/14/2023 6 38 1.1.3.2 Off-Site Improvements Off-site energy (natural gas and electricity), telecommunications, water, wastewater utility, and rail spur improvements also will be required and will be identified as “off-site improvements” necessary for the Proposed Project (see Figure 4). The DEIS will assess impacts of the Proposed Project and off-site improvements. National Grid will complete a separate Article 7 regulatory process before the New York Public Service Commission with regard to the electric transmission lines needed for the Proposed Project. The following off-site improvements have been identified: Energy ▪ Extension of a 16-inch diameter natural gas line from National Grid’s Gas Regulator Station (GRS) 147 at 4459 NYS Route 31 to the Micron Campus (approximately 3.15 miles) and construction of GRS 147A at the same address as the existing GRS; ▪ Construction of eight (two per Fab) underground electrical transmission duct bank connections from the existing National Grid sub-station west of Caughdenoy Road. Telecommunications ▪ Extension of existing fiber-optic lines located along NYS Route 31 to the Micron Campus and from the existing fiber-optic lines located along Caughdenoy Road. Water Supply 1.1.3.2 Off-Site Improvements Off-site energy (natural gas and electricity), telecommunications, water, wastewater utility, and rail spur improvements also will be required and will be identified as “off-site improvements” necessary for the Proposed Project (see Figure 4). The DEIS will assess impacts of the Proposed Project and off-site improvements. National Grid will complete a separate Article 7 regulatory process before the New York Public Service Commission with regard to the electric transmission lines needed for the Proposed Project. The following off-site improvements have been identified: Energy ▪ Extension of a 16-inch diameter natural gas line from National Grid’s Gas Regulator Station (GRS) 147 at 4459 NYS Route 31 to the Micron Campus (approximately 3.15 miles) and construction of GRS 147A at the same address as the existing GRS; ▪ Construction of eight (two per Fab) underground electrical transmission duct bank connections from the existing National Grid sub-station west of Caughdenoy Road. Telecommunications ▪ Extension of existing fiber-optic lines located along NYS Route 31 to the Micron Campus and from the existing fiber-optic lines located along Caughdenoy Road. Water Supply Onondaga County Water Authority (OCWA) has capacity within its water supply system to service Micron’s initial water demand for construction and operations of Fab 1 (approximately 11.5 million gallons per day (MGD)). A new Clear Water Pumping Station at OCWA’s Lake Ontario Water Treatment Plant (LOWTP) would be required. This new Clear Water Pumping Station will be designed to accommodate anticipated water demand for Micron’s Fab 2, Fab 3, and Fab 4. Potable water for initial construction would be provided to the Micron Campus through existing buried water mains located within the Caughdenoy Road and Burnet Road rights-of-way. Potable water for Fab 1 operations would be provided to the Micron Campus through construction of a new connection from OCWA’s existing Eastern Branch Transmission Main south of NYS Route 31 via a new service connection within a 99-foot-wide easement within the Micron Campus along Caughdenoy Road. To serve the anticipated future demand of approximately 48 MGD, OCWA would have to make the following water supply infrastructure improvements: ▪ Construction of a new Raw Water Tunnel and Raw Water Pumping Station at OCWA’s existing Burt Point property on Lake Ontario (City of Oswego); ▪ Construction of a new Raw Water Transmission Main from Burt Point to OCWA’s Lake Ontario Water Treatment Plant (LOWTP) using an easement that OCWA obtained for such purposes in the 1990s; Onondaga County Water Authority (OCWA) has capacity within its water supply system to service Micron’s initial water demand for construction and operations of Fab 1 (approximately 11.5 million gallons per day (MGD)). A new Clear Water Pumping Station at OCWA’s Lake Ontario Water Treatment Plant (LOWTP) would be required. This new Clear Water Pumping Station will be designed to accommodate anticipated water demand for Micron’s Fab 2, Fab 3, and Fab 4. Potable water for initial construction would be provided to the Micron Campus through existing buried water mains located within the Caughdenoy Road and Burnet Road rights-of-way. Potable water for Fab 1 operations would be provided to the Micron Campus through construction of a new connection from OCWA’s existing Eastern Branch Transmission Main south of NYS Route 31 via a new service connection within a 99-foot-wide easement within the Micron Campus along Caughdenoy Road. To serve the anticipated future demand of approximately 48 MGD, OCWA would have to make the following water supply infrastructure improvements: ▪ Construction of a new Raw Water Tunnel and Raw Water Pumping Station at OCWA’s existing Burt Point property on Lake Ontario (City of Oswego); ▪ Construction of a new Raw Water Transmission Main from Burt Point to OCWA’s Lake Ontario Water Treatment Plant (LOWTP) using an easement that OCWA obtained for such purposes in the 1990s; 12/14/2023 7 39 ▪ Modification to the LOWTP with addition of two (2) new filters, one (1) contact basin, and one (1) new clearwell as well as additional chemical storage space and residual handling facilities; ▪ Expansion of OCWA’s Clear Water Transmission Main from LOWTP to OCWA’s Terminal Campus with one (1) additional 54-inch diameter line parallel to the existing 54-inch diameter line; ▪ Construction of one (1) 15 million gallon water storage tank at OCWA’s Terminal Campus; ▪ Upgrading of existing pumps at OCWA’s Farrell Pumping Station at Terminal Campus and construction of a parallel pumping station; ▪ Expansion of OCWA’s Eastern Branch Transmission Main south of NYS Route 31 from one (1) 54-inch diameter water main with up to three (3) additional 54-inch diameter water mains depending on evaluations of Micron’s initial water re-use and reclamation performance; and ▪ Relocation of a portion of the existing OCWA Eastern Branch Transmission Line crossing the Micron Campus to allow for Micron Fab 3 and Fab 4 construction. Wastewater 12/14/2023 7 39 ▪ Modification to the LOWTP with addition of two (2) new filters, one (1) contact basin, and one (1) new clearwell as well as additional chemical storage space and residual handling facilities; ▪ Expansion of OCWA’s Clear Water Transmission Main from LOWTP to OCWA’s Terminal Campus with one (1) additional 54-inch diameter line parallel to the existing 54-inch diameter line; ▪ Construction of one (1) 15 million gallon water storage tank at OCWA’s Terminal Campus; ▪ Upgrading of existing pumps at OCWA’s Farrell Pumping Station at Terminal Campus and construction of a parallel pumping station; ▪ Expansion of OCWA’s Eastern Branch Transmission Main south of NYS Route 31 from one (1) 54-inch diameter water main with up to three (3) additional 54-inch diameter water mains depending on evaluations of Micron’s initial water re-use and reclamation performance; and ▪ Relocation of a portion of the existing OCWA Eastern Branch Transmission Line crossing the Micron Campus to allow for Micron Fab 3 and Fab 4 construction. Wastewater Onondaga County Department of Water Environment Protection (OCDWEP) will be able to convey sanitary wastewater from the Micron Campus during initial construction through a previously planned and separately studied extension of municipal sanitary wastewater force mains to a portion of the Oak Orchard Wastewater Treatment Plant (WWTP) service area that has not previously been served by municipal infrastructure. Operation of Micron’s Fabs 1-4 will require additional industrial wastewater infrastructure and improvements to the Oak Orchard WWTP in addition to planned industrial wastewater pre-treatment facilities that Micron will construct on the Micron Campus. The following OCDWEP infrastructure improvements are required prior to operation of Micron’s Fab 1: ▪ Construction of OCDWEP industrial wastewater service conveyance to the Oak Orchard wastewater treatment plant (WWTP) from a new industrial wastewater pumping station to be constructed on the Micron Campus. Conveyance infrastructure would comprise four (4) 30-inch force mains for industrial wastewater; and one (1) 36-inch force main for reclaimed water supply; and ▪ Expansion of the Oak Orchard WWTP to treat industrial wastewater (with pre-treatment required by Micron at the Micron Campus). Rail Spur Site Onondaga County Department of Water Environment Protection (OCDWEP) will be able to convey sanitary wastewater from the Micron Campus during initial construction through a previously planned and separately studied extension of municipal sanitary wastewater force mains to a portion of the Oak Orchard Wastewater Treatment Plant (WWTP) service area that has not previously been served by municipal infrastructure. Operation of Micron’s Fabs 1-4 will require additional industrial wastewater infrastructure and improvements to the Oak Orchard WWTP in addition to planned industrial wastewater pre-treatment facilities that Micron will construct on the Micron Campus. The following OCDWEP infrastructure improvements are required prior to operation of Micron’s Fab 1: ▪ Construction of OCDWEP industrial wastewater service conveyance to the Oak Orchard wastewater treatment plant (WWTP) from a new industrial wastewater pumping station to be constructed on the Micron Campus. Conveyance infrastructure would comprise four (4) 30-inch force mains for industrial wastewater; and one (1) 36-inch force main for reclaimed water supply; and ▪ Expansion of the Oak Orchard WWTP to treat industrial wastewater (with pre-treatment required by Micron at the Micron Campus). Rail Spur Site Micron has proposed to construct a rail spur on an approximately 37-acre area on the west side of Caughdenoy Road (including Town of Clay tax parcel 046.-02-03.2) (the “rail spur site”). The rail spur will be used to deliver construction aggregate to the Micron Campus to reduce construction vehicle impacts on the local community from construction of the Proposed Project, which will 12/14/2023 8 40 facilitate the avoidance, minimization and mitigation of traffic, air, climate change and community character impacts. The rail spur is a separate but related action that would require advanced construction to achieve the intended benefit of reduced construction vehicle impacts from the Proposed Project. Although it will be addressed separately under SEQRA so that it is in place at the commencement of groundbreaking in order to maximize mitigation measures for the Proposed Project, it will also be analyzed in the SEQRA DEIS. Micron has proposed to construct a rail spur on an approximately 37-acre area on the west side of Caughdenoy Road (including Town of Clay tax parcel 046.-02-03.2) (the “rail spur site”). The rail spur will be used to deliver construction aggregate to the Micron Campus to reduce construction vehicle impacts on the local community from construction of the Proposed Project, which will 12/14/2023 8 40 facilitate the avoidance, minimization and mitigation of traffic, air, climate change and community character impacts. The rail spur is a separate but related action that would require advanced construction to achieve the intended benefit of reduced construction vehicle impacts from the Proposed Project. Although it will be addressed separately under SEQRA so that it is in place at the commencement of groundbreaking in order to maximize mitigation measures for the Proposed Project, it will also be analyzed in the SEQRA DEIS. 1.1.3.3 Proposed Project Employment Micron will create approximately 9,000 high-paying jobs by 2045 to support the Micron Campus when operating at full capacity and about 40,000 community jobs over a 20-plus year period to include suppliers, contractors, and other supporting roles. Micron has begun efforts to attract a diverse and multi-talented workforce to Central New York. Using its existing labor models for high- volume fabs around the globe, Micron has estimated that 90% of its workers will be dedicated to manufacturing, and the remaining 10% will provide support services, including IT, security, quality, procurement, supply chain, smart manufacturing technology, finance, people, and legal services. 1.1.3.3 Proposed Project Employment Micron will create approximately 9,000 high-paying jobs by 2045 to support the Micron Campus when operating at full capacity and about 40,000 community jobs over a 20-plus year period to include suppliers, contractors, and other supporting roles. Micron has begun efforts to attract a diverse and multi-talented workforce to Central New York. Using its existing labor models for high- volume fabs around the globe, Micron has estimated that 90% of its workers will be dedicated to manufacturing, and the remaining 10% will provide support services, including IT, security, quality, procurement, supply chain, smart manufacturing technology, finance, people, and legal services. The bulk of manufacturing headcount will comprise three major job categories, each with a mix of specific jobs and skillsets. In the category of leadership (~10%), there are directors, managers, and supervisors. Typical qualifications for managers are a B.A. or B.S. degree or equivalent training and experience and five years of leadership experience. For supervisors, these are an A.A. or A.S. degree or Production Operations Management Certificate or equivalent training and experience. For directors, a B.A. or B.S. degree or equivalent training and experience, and eight years of leadership experience is required. In the category of Engineering & Professional (~44%), the bulk of needed roles are equipment engineers and process engineers. Engineering roles require a B.S. in Engineering or a B.S. in a relevant discipline, and Micron provides specific on-the-job training for the role’s function. In the category of Technicians (~36%), the bulk of needed roles are equipment technicians and process technicians. Technician roles require the same minimum qualifications, and Micron provides specific on-the-job training for the role’s function. The qualifications are an A.A or A.S. degree or completion of a Micron Apprenticeship Program or, other approved certification, or a combination of certifications under development with Micron community college partners or equivalent training and experience. The bulk of manufacturing headcount will comprise three major job categories, each with a mix of specific jobs and skillsets. In the category of leadership (~10%), there are directors, managers, and supervisors. Typical qualifications for managers are a B.A. or B.S. degree or equivalent training and experience and five years of leadership experience. For supervisors, these are an A.A. or A.S. degree or Production Operations Management Certificate or equivalent training and experience. For directors, a B.A. or B.S. degree or equivalent training and experience, and eight years of leadership experience is required. In the category of Engineering & Professional (~44%), the bulk of needed roles are equipment engineers and process engineers. Engineering roles require a B.S. in Engineering or a B.S. in a relevant discipline, and Micron provides specific on-the-job training for the role’s function. In the category of Technicians (~36%), the bulk of needed roles are equipment technicians and process technicians. Technician roles require the same minimum qualifications, and Micron provides specific on-the-job training for the role’s function. The qualifications are an A.A or A.S. degree or completion of a Micron Apprenticeship Program or, other approved certification, or a combination of certifications under development with Micron community college partners or equivalent training and experience. Micron will operate three (3) shifts over a 24-hour day. Day and night shifts will be utilized to sustain 24-hour manufacturing activities as well as a maintenance shift. 12/14/2023 9 41 Micron will operate three (3) shifts over a 24-hour day. Day and night shifts will be utilized to sustain 24-hour manufacturing activities as well as a maintenance shift. 12/14/2023 9 41 FIGURE 4 PROPOSED PROJECT AND OFF-SITE IMPROVEMENTS 12/14/2023 10 42 FIGURE 4 PROPOSED PROJECT AND OFF-SITE IMPROVEMENTS 12/14/2023 10 42 2 The Scoping Process and Agency Coordination Scoping provides an opportunity for the public to learn more about the Proposed Project and to provide valuable input as Micron and OCIDA prepare the SEQRA Draft EIS (DEIS). A SEQRA Positive Declaration and notice of public scoping meeting was published in the Environmental Notice Bulletin on September 20, 2023. Notice of the public scoping meeting was placed in The Post Standard (Syracuse.com) – a newspaper of general circulation serving the broader Clay, New York area on September 19, 2023. Project information and this final SEQRA Scope was also posted on OCIDA’s website (www.ongoved.com). OCIDA, as SEQRA Lead Agency, invited the public and agencies to be involved in the environmental review process. During the SEQRA scoping process, comments were encouraged on the draft purpose and need, potential alternatives, and environmental issues of concern. A list of the Federal, State, and local agencies with which OCIDA is coordinating is provided in Section 6. Public Comment Period and Community Meetings 2 The Scoping Process and Agency Coordination Scoping provides an opportunity for the public to learn more about the Proposed Project and to provide valuable input as Micron and OCIDA prepare the SEQRA Draft EIS (DEIS). A SEQRA Positive Declaration and notice of public scoping meeting was published in the Environmental Notice Bulletin on September 20, 2023. Notice of the public scoping meeting was placed in The Post Standard (Syracuse.com) – a newspaper of general circulation serving the broader Clay, New York area on September 19, 2023. Project information and this final SEQRA Scope was also posted on OCIDA’s website (www.ongoved.com). OCIDA, as SEQRA Lead Agency, invited the public and agencies to be involved in the environmental review process. During the SEQRA scoping process, comments were encouraged on the draft purpose and need, potential alternatives, and environmental issues of concern. A list of the Federal, State, and local agencies with which OCIDA is coordinating is provided in Section 6. Public Comment Period and Community Meetings ▪ The comment period for the scoping process was extended beyond the minimum required 30 days from September 20, 2023, to October 31, 2023. During this period, OCIDA held a public scoping meeting on October 11, 2023, at 6:30 PM to obtain input from the public. Everyone who registered or asked to speak was given the opportunity to submit a verbal comment. The scoping meeting provided simultaneous Spanish and American Sign Language interpretation. No additional language translation services or special needs assistance were requested. How Comments Were Received Comments were accepted during the scoping period via: ▪ Public comment at the public scoping meeting on October 11, 2023; ▪ E-mails to micron@ongov.net; and ▪ Mail to Attn: Micron Project, Office of Economic Development, Onondaga County, 335 Montgomery Street, 2nd Floor, Syracuse, NY 13202 All comments received, no matter their format, were considered equally. In total, 39 individuals, organizations, or agencies provided comments during the public comment period including written comment letters from the United States Fish & Wildlife Service and the New York State Department of Environmental Conservation. 12/14/2023 11 43 How Comments Were Used ▪ The comment period for the scoping process was extended beyond the minimum required 30 days from September 20, 2023, to October 31, 2023. During this period, OCIDA held a public scoping meeting on October 11, 2023, at 6:30 PM to obtain input from the public. Everyone who registered or asked to speak was given the opportunity to submit a verbal comment. The scoping meeting provided simultaneous Spanish and American Sign Language interpretation. No additional language translation services or special needs assistance were requested. How Comments Were Received Comments were accepted during the scoping period via: ▪ Public comment at the public scoping meeting on October 11, 2023; ▪ E-mails to micron@ongov.net; and ▪ Mail to Attn: Micron Project, Office of Economic Development, Onondaga County, 335 Montgomery Street, 2nd Floor, Syracuse, NY 13202 All comments received, no matter their format, were considered equally. In total, 39 individuals, organizations, or agencies provided comments during the public comment period including written comment letters from the United States Fish & Wildlife Service and the New York State Department of Environmental Conservation. 12/14/2023 11 43 How Comments Were Used After the end of the comment period on October 31, 2023, OCIDA, with assistance as needed from Micron, collected, reviewed, and summarized the comments received and prepared this final SEQRA Scope with attached Response to Comments found in Appendix B. The comments received during the scoping period were considered by OCIDA to define this final scope of the DEIS and to inform the related technical analyses and environmental resources to be evaluated. OCIDA has made the final SEQRA Scope available to all interested and involved agencies as well as on its website (www.ongoved.com/ocida) and to everyone that commented during the public comment period. This final SEQRA Scope will be used to prepare the DEIS. 12/14/2023 12 44 After the end of the comment period on October 31, 2023, OCIDA, with assistance as needed from Micron, collected, reviewed, and summarized the comments received and prepared this final SEQRA Scope with attached Response to Comments found in Appendix B. The comments received during the scoping period were considered by OCIDA to define this final scope of the DEIS and to inform the related technical analyses and environmental resources to be evaluated. OCIDA has made the final SEQRA Scope available to all interested and involved agencies as well as on its website (www.ongoved.com/ocida) and to everyone that commented during the public comment period. This final SEQRA Scope will be used to prepare the DEIS. 12/14/2023 12 44 3.1 PURPOSE AND NEED The purpose of the Proposed Project is to further the United States goal to expand domestic memory chip manufacturing capacity and restore U.S. leadership in semiconductor manufacturing as embodied in the “Creating Helpful Incentives to Produce Semiconductors and Science Act of 2022” (the “CHIPS Act”). For Micron, the purpose is to advance its leading-edge position in the development and manufacturing of DRAM memory chips. 3.1 PURPOSE AND NEED The purpose of the Proposed Project is to further the United States goal to expand domestic memory chip manufacturing capacity and restore U.S. leadership in semiconductor manufacturing as embodied in the “Creating Helpful Incentives to Produce Semiconductors and Science Act of 2022” (the “CHIPS Act”). For Micron, the purpose is to advance its leading-edge position in the development and manufacturing of DRAM memory chips. The purpose of the CHIPS Act and the need for the Proposed Project is to reduce U.S. reliance on foreign production of both leading edge and older generation microelectronics. Semiconductors were invented in America, and the U.S. semiconductor industry has historically dominated many parts of the international semiconductor supply chain, such as R&D, chip design and manufacturing. Yet the U.S. position within the semiconductor industry has been declining. According to the Semiconductor Industry Association, U.S. production of the world’s microchips has fallen from 37% in 1990 to 12% in 2020. The need for the Proposed Project is to reduce economic and national security risks by building domestic capacity, to establish a dynamic and collaborative network for semiconductor research and innovation centers, and to improve competitiveness and strengthen regional supply chain industries. Micron provides a unique and essential role in domestic production of leading-edge memory chips that are essential and high- volume components of the semiconductor industry. The purpose of the CHIPS Act and the need for the Proposed Project is to reduce U.S. reliance on foreign production of both leading edge and older generation microelectronics. Semiconductors were invented in America, and the U.S. semiconductor industry has historically dominated many parts of the international semiconductor supply chain, such as R&D, chip design and manufacturing. Yet the U.S. position within the semiconductor industry has been declining. According to the Semiconductor Industry Association, U.S. production of the world’s microchips has fallen from 37% in 1990 to 12% in 2020. The need for the Proposed Project is to reduce economic and national security risks by building domestic capacity, to establish a dynamic and collaborative network for semiconductor research and innovation centers, and to improve competitiveness and strengthen regional supply chain industries. Micron provides a unique and essential role in domestic production of leading-edge memory chips that are essential and high- volume components of the semiconductor industry. Micron’s investment in the Proposed Project will also advance the goals of the State of New York and OCIDA to enhance job growth in Central New York by promoting advanced manufacturing in the region. The Proposed Project is anticipated to generate nearly 50,000 jobs in Central New York over more than a 20-year period, including 9,000 good-paying Micron jobs directly generated by the Proposed Project and over 40,000 additional jobs with suppliers, contractors and other businesses supporting the proposed chip manufacturing facility. To this end, Micron and the State of New York have announced a historic $500 million investment in community and workforce development over a more than 20-year period. Micron will further invest $250 million in line with its commitment to the Green CHIPS Community Investment Fund. An additional $250 million is expected to be invested, with $100 million from New York, and $150 million from local, other state and national partners. This fund is intended to expand and train the workforce in the region, including providing support for disadvantaged populations. Micron’s investment in the Proposed Project will also advance the goals of the State of New York and OCIDA to enhance job growth in Central New York by promoting advanced manufacturing in the region. The Proposed Project is anticipated to generate nearly 50,000 jobs in Central New York over more than a 20-year period, including 9,000 good-paying Micron jobs directly generated by the Proposed Project and over 40,000 additional jobs with suppliers, contractors and other businesses supporting the proposed chip manufacturing facility. To this end, Micron and the State of New York have announced a historic $500 million investment in community and workforce development over a more than 20-year period. Micron will further invest $250 million in line with its commitment to the Green CHIPS Community Investment Fund. An additional $250 million is expected to be invested, with $100 million from New York, and $150 million from local, other state and national partners. This fund is intended to expand and train the workforce in the region, including providing support for disadvantaged populations. 3.2 PROJECT BACKGROUND Central New York as well as other regions of New York State have experienced a reduction in manufacturing jobs over several decades. In 1991, OCIDA and the City of Syracuse Chamber of 12/14/2023 13 45 Commerce commissioned an Industrial Park Feasibility Study to identify potential candidate sites for locating industrial businesses in Onondaga County (the “County”). The study identified two sites for large scale industrial uses, with the White Pine Commerce Park (WPCP) ultimately selected as the preferred site for purchase due to its proximity to National Grid’s Clay electric substation, highway access, and Industrial zoning designation. Between 1991 and 1999, the County purchased seven properties to form the original approximately 340-acre WPCP (previously referred to as Clay Business Park). 3.2 PROJECT BACKGROUND Central New York as well as other regions of New York State have experienced a reduction in manufacturing jobs over several decades. In 1991, OCIDA and the City of Syracuse Chamber of 12/14/2023 13 45 Commerce commissioned an Industrial Park Feasibility Study to identify potential candidate sites for locating industrial businesses in Onondaga County (the “County”). The study identified two sites for large scale industrial uses, with the White Pine Commerce Park (WPCP) ultimately selected as the preferred site for purchase due to its proximity to National Grid’s Clay electric substation, highway access, and Industrial zoning designation. Between 1991 and 1999, the County purchased seven properties to form the original approximately 340-acre WPCP (previously referred to as Clay Business Park). OCIDA’s intent in acquiring the lands, was further justified in 1998 with the advent of the SEMI-NY program (as discussed below), resulted in the accumulation of the original 340-acre footprint of the WPCP. The SEMI-NY program was a New York State initiative initiated in 1998 to attract the semiconductor industry to the state by identifying and advancing “qualified” sites that were consistent with conceptual semiconductor industry profiles. OCIDA’s objective was to further the County’s economic development agenda by providing a site that met the SEMI-NY criteria and could be presented as a qualified site for a semiconductor manufacturing facility under the SEMI- NY program. To support OCIDA’s efforts to obtain the SEMI-NY “qualified” site designation for its site, OCIDA prepared a SEQRA Generic Environmental Impact Statement (GEIS) to assess potential environmental and socio-economic impacts associated with full build-out of the 300-acres by a yet to be determined semiconductor company. OCIDA’s intent in acquiring the lands, was further justified in 1998 with the advent of the SEMI-NY program (as discussed below), resulted in the accumulation of the original 340-acre footprint of the WPCP. The SEMI-NY program was a New York State initiative initiated in 1998 to attract the semiconductor industry to the state by identifying and advancing “qualified” sites that were consistent with conceptual semiconductor industry profiles. OCIDA’s objective was to further the County’s economic development agenda by providing a site that met the SEMI-NY criteria and could be presented as a qualified site for a semiconductor manufacturing facility under the SEMI- NY program. To support OCIDA’s efforts to obtain the SEMI-NY “qualified” site designation for its site, OCIDA prepared a SEQRA Generic Environmental Impact Statement (GEIS) to assess potential environmental and socio-economic impacts associated with full build-out of the 300-acres by a yet to be determined semiconductor company. From 2017 to the present, OCIDA has made significant investments to advance and market the WPCP, with the semiconductor industry targeted as the site’s highest and best use. In the ensuing years following the initial creation and focused marketing of the WPCP, the semiconductor industry, for several commercial reasons, has transitioned toward the construction and use of a Fab complex, which typically consists of two to four fabrication facilities operating at a single site; a trend introduced in Asia and Europe and now replicated in the United States. The semiconductor industry of today focuses on economies of scale; the need to build fewer, larger Fabs; and the managerial and economic benefits regarding workforce and reducing operational downtimes during expansions. This has resulted in the need for 1000-acre sites. From 2017 to the present, OCIDA has made significant investments to advance and market the WPCP, with the semiconductor industry targeted as the site’s highest and best use. In the ensuing years following the initial creation and focused marketing of the WPCP, the semiconductor industry, for several commercial reasons, has transitioned toward the construction and use of a Fab complex, which typically consists of two to four fabrication facilities operating at a single site; a trend introduced in Asia and Europe and now replicated in the United States. The semiconductor industry of today focuses on economies of scale; the need to build fewer, larger Fabs; and the managerial and economic benefits regarding workforce and reducing operational downtimes during expansions. This has resulted in the need for 1000-acre sites. As a result, over the past six years, OCIDA decided to purchase adjacent land to enlarge the WPCP to accommodate this new industry model. The WPCP is now over 1,400 contiguous acres. This size makes it considerably larger than most available sites in New York. Considering other critical additional project needs beyond sheer size (e.g., proximity to a sufficient supply of electricity and water, wastewater treatment, and natural gas) further diminishes the number of available sites that can accommodate modern semiconductor manufacturing. Overlaying the acreage and infrastructure needs with access to multi-modal transportation and labor needs is often a point of failure for most other sites, which might otherwise meet the acreage need. Accordingly, sites that substantially meet Micron’s site selection criteria are not commonly available, which further supports Micron’s selection of the WPCP for the proposed Micron Campus. 12/14/2023 14 46 As a result, over the past six years, OCIDA decided to purchase adjacent land to enlarge the WPCP to accommodate this new industry model. The WPCP is now over 1,400 contiguous acres. This size makes it considerably larger than most available sites in New York. Considering other critical additional project needs beyond sheer size (e.g., proximity to a sufficient supply of electricity and water, wastewater treatment, and natural gas) further diminishes the number of available sites that can accommodate modern semiconductor manufacturing. Overlaying the acreage and infrastructure needs with access to multi-modal transportation and labor needs is often a point of failure for most other sites, which might otherwise meet the acreage need. Accordingly, sites that substantially meet Micron’s site selection criteria are not commonly available, which further supports Micron’s selection of the WPCP for the proposed Micron Campus. 12/14/2023 14 46 OCIDA utilized the development of a GEIS (2013) and the follow-up Supplemental Generic Environmental Impact Statement (SGEIS), completed in 2021, to evaluate potential locations throughout Onondaga County for development of a site suitable to attract semiconductor manufacturing. OCIDA, in 2013, and again in 2021, selected the WPCP as its preferred site to attract private industrial and commercial development because of its size, potential for industrial zoning, access to transportation, proximity of utilities, as well as a history of Town of Clay efforts to facilitate industrial development at the property. The 2013 GEIS considered several other potential sites in addition to WPCP: ▪ Radisson Corporate Park – 950 acres in the Town of Lysander; ▪ Hancock Air Park – 200 acres adjacent to the Syracuse Hancock Airport; ▪ Collamer Crossings Business Park – 200 acres in the Town of Dewitt located near NYS Route 298, I-90, I-481; and ▪ Syracuse Research Park – 99-acre site adjacent to Syracuse University. OCIDA utilized the development of a GEIS (2013) and the follow-up Supplemental Generic Environmental Impact Statement (SGEIS), completed in 2021, to evaluate potential locations throughout Onondaga County for development of a site suitable to attract semiconductor manufacturing. OCIDA, in 2013, and again in 2021, selected the WPCP as its preferred site to attract private industrial and commercial development because of its size, potential for industrial zoning, access to transportation, proximity of utilities, as well as a history of Town of Clay efforts to facilitate industrial development at the property. The 2013 GEIS considered several other potential sites in addition to WPCP: ▪ Radisson Corporate Park – 950 acres in the Town of Lysander; ▪ Hancock Air Park – 200 acres adjacent to the Syracuse Hancock Airport; ▪ Collamer Crossings Business Park – 200 acres in the Town of Dewitt located near NYS Route 298, I-90, I-481; and ▪ Syracuse Research Park – 99-acre site adjacent to Syracuse University. OCIDA deemed the Radisson Corporate Park as an unviable choice because it lacked sufficient room and it did not offer the location specific advantages such as the proximity to I-81 and I- 481/NY 481 that the WPCP did. Neither the Hancock Air Park nor the Collamer Crossing Business Park were deemed viable options because the available lots were small and could not accommodate large industrial uses. The Syracuse Research Park was available for light industrial use, but OCIDA concluded that it could not easily accommodate large-scale industrial uses. OCIDA deemed the Radisson Corporate Park as an unviable choice because it lacked sufficient room and it did not offer the location specific advantages such as the proximity to I-81 and I- 481/NY 481 that the WPCP did. Neither the Hancock Air Park nor the Collamer Crossing Business Park were deemed viable options because the available lots were small and could not accommodate large industrial uses. The Syracuse Research Park was available for light industrial use, but OCIDA concluded that it could not easily accommodate large-scale industrial uses. The 2013 GEIS evaluated three (3) different site layouts for the WPCP: 1) a layout that provided 1 million sf of development while avoiding all State-mapped wetlands; 2) a layout that provided 1.5 million sf of development that balanced approximately 4.2 acres of wetland impacts against the additional benefits from the larger size of development; and 3) a layout that provided over 2 million sf balanced against additional impacts to wetlands. OCIDA identified the third alternative as the “preferred alternative” in the 2013 GEIS based on the overall economic returns versus the degree of environmental impacts. The 2013 GEIS also included a 2012 engineering report evaluating three (3) options for extending sanitary sewer service to the WPCP: 1) use of Verplank Road north of NYS Route 31; 2) use of the NYS Route 31 right-of-way; and 3) use of the Metropolitan Water Board (now OCWA) right-of-way south of NYS Route 31. The 2012 engineering report built from a 2003 feasibility study, the Semi-NY Sewer Route Feasibility Study, which evaluated five (5) sanitary sewer line routing options. OCIDA selected the third option for extension of sanitary sewer service to the WPCP as the preferred alternative. The 2021 SGEIS revisited the question of whether the WPCP was the preferred alternative to attract industrial and commercial development to Onondaga County. The SGEIS compared WPCP to the 12/14/2023 15 47 The 2013 GEIS evaluated three (3) different site layouts for the WPCP: 1) a layout that provided 1 million sf of development while avoiding all State-mapped wetlands; 2) a layout that provided 1.5 million sf of development that balanced approximately 4.2 acres of wetland impacts against the additional benefits from the larger size of development; and 3) a layout that provided over 2 million sf balanced against additional impacts to wetlands. OCIDA identified the third alternative as the “preferred alternative” in the 2013 GEIS based on the overall economic returns versus the degree of environmental impacts. The 2013 GEIS also included a 2012 engineering report evaluating three (3) options for extending sanitary sewer service to the WPCP: 1) use of Verplank Road north of NYS Route 31; 2) use of the NYS Route 31 right-of-way; and 3) use of the Metropolitan Water Board (now OCWA) right-of-way south of NYS Route 31. The 2012 engineering report built from a 2003 feasibility study, the Semi-NY Sewer Route Feasibility Study, which evaluated five (5) sanitary sewer line routing options. OCIDA selected the third option for extension of sanitary sewer service to the WPCP as the preferred alternative. The 2021 SGEIS revisited the question of whether the WPCP was the preferred alternative to attract industrial and commercial development to Onondaga County. The SGEIS compared WPCP to the 12/14/2023 15 47 same alternative candidate sites that the 20132 GEIS assessed, again concluding that “[n]one of the previously considered alternative locations would be able to accommodate the large-scale industrial use that the [White Pine Commerce] Park is promoting due to size limitations and proximity to services and necessary infrastructure.” The 2021 SGEIS concluded that significant expansion of the WPCP was feasible and more likely to attract leading edge manufacturing, such as semiconductor manufacturing. The alternative locations considered in the 2021 SGEIS were rejected as much too small to accommodate semiconductor manufacturing. The 2021 SGEIS assessed the additional potential significant adverse impacts from a larger facility and the creation of a shovel-ready WPCP by increasing the size of the development parcel to approximately 1,250 acres (later expanded to the current approximately 1,400 acres). OCIDA indicated in the SEQRA Findings Statement that “consistent with social, economic and other essential considerations from among the reasonable alternatives available, the action is the one that avoids or minimizes adverse impacts to the maximum extent practicable, and that adverse impacts will be avoided or minimized to the maximum extent practicable by incorporating as conditions to the decision those mitigation measures that were identified as practicable.” same alternative candidate sites that the 20132 GEIS assessed, again concluding that “[n]one of the previously considered alternative locations would be able to accommodate the large-scale industrial use that the [White Pine Commerce] Park is promoting due to size limitations and proximity to services and necessary infrastructure.” The 2021 SGEIS concluded that significant expansion of the WPCP was feasible and more likely to attract leading edge manufacturing, such as semiconductor manufacturing. The alternative locations considered in the 2021 SGEIS were rejected as much too small to accommodate semiconductor manufacturing. The 2021 SGEIS assessed the additional potential significant adverse impacts from a larger facility and the creation of a shovel-ready WPCP by increasing the size of the development parcel to approximately 1,250 acres (later expanded to the current approximately 1,400 acres). OCIDA indicated in the SEQRA Findings Statement that “consistent with social, economic and other essential considerations from among the reasonable alternatives available, the action is the one that avoids or minimizes adverse impacts to the maximum extent practicable, and that adverse impacts will be avoided or minimized to the maximum extent practicable by incorporating as conditions to the decision those mitigation measures that were identified as practicable.” On August 9, 2022, President Biden signed into law the CHIPS Act making over $50 billion available “to strengthen American manufacturing, supply chains, and national security, and invest in research and development, science and technology, and the workforce of the future to keep the United States the leader in the industries of tomorrow, including nanotechnology, clean energy, quantum computing, and artificial intelligence.”5 On August 11, 2022, New York State Governor Kathy Hochul signed into law the Green CHIPS Act, which provides up to $10 billion in economic incentives for environmentally friendly semiconductor manufacturing and supply chain projects (Ch. 494, L. 2022). The Green CHIPS legislation was passed to align with the provisions of the Federal CHIPS Act for the purpose of attracting domestic semiconductor manufacturing and related activities to New York State. On August 9, 2022, President Biden signed into law the CHIPS Act making over $50 billion available “to strengthen American manufacturing, supply chains, and national security, and invest in research and development, science and technology, and the workforce of the future to keep the United States the leader in the industries of tomorrow, including nanotechnology, clean energy, quantum computing, and artificial intelligence.”5 On August 11, 2022, New York State Governor Kathy Hochul signed into law the Green CHIPS Act, which provides up to $10 billion in economic incentives for environmentally friendly semiconductor manufacturing and supply chain projects (Ch. 494, L. 2022). The Green CHIPS legislation was passed to align with the provisions of the Federal CHIPS Act for the purpose of attracting domestic semiconductor manufacturing and related activities to New York State. On October 4, 2022, Micron announced plans to invest up to $100 billion over the next 20-plus years to develop a new leading edge semiconductor manufacturing facility at what is now known as the WPCP in Clay, New York, with a first-tier investment of $20 billion planned by the end of this decade. Micron intends to apply for funding from both the CHIPS Act and the Green CHIPS Act to assist in the financing of the Proposed Project. Micron and Empire State Development (ESD), the umbrella organization of New York State’s two principal economic development public- benefit corporations, established a framework, known as the Community Investment Framework, outlining the shared investments to be made by Micron and the State of New York. This framework 5 FACT SHEET: CHIPS and Science Act will Lower Costs, Create Jobs, Strengthen Supply Chains, and Counter China, August 9, 2022, The White House. https://www.whitehouse.gov/briefing-room/statements-releases/2022/08/09/fact- sheet-chips-and-science-act-will-lower-costs-create-jobs-strengthen-supply-chains-and-counter-china/ 12/14/2023 16 48 will allow for the strengthening of the existing regional workforce and to create new growth and expansion of the workforce overall. On October 4, 2022, Micron announced plans to invest up to $100 billion over the next 20-plus years to develop a new leading edge semiconductor manufacturing facility at what is now known as the WPCP in Clay, New York, with a first-tier investment of $20 billion planned by the end of this decade. Micron intends to apply for funding from both the CHIPS Act and the Green CHIPS Act to assist in the financing of the Proposed Project. Micron and Empire State Development (ESD), the umbrella organization of New York State’s two principal economic development public- benefit corporations, established a framework, known as the Community Investment Framework, outlining the shared investments to be made by Micron and the State of New York. This framework 5 FACT SHEET: CHIPS and Science Act will Lower Costs, Create Jobs, Strengthen Supply Chains, and Counter China, August 9, 2022, The White House. https://www.whitehouse.gov/briefing-room/statements-releases/2022/08/09/fact- sheet-chips-and-science-act-will-lower-costs-create-jobs-strengthen-supply-chains-and-counter-china/ 12/14/2023 16 48 will allow for the strengthening of the existing regional workforce and to create new growth and expansion of the workforce overall. Micron’s Proposed Project is the long-anticipated fulfillment of OCIDA’s original goal to attract a state-of-the-art manufacturing facility to generate high-paying employment opportunities in Onondaga County. Micron’s investment also furthers recent United States and New York State policies and programs to incentivize domestic semiconductor manufacturing. 12/14/2023 17 49 Micron’s Proposed Project is the long-anticipated fulfillment of OCIDA’s original goal to attract a state-of-the-art manufacturing facility to generate high-paying employment opportunities in Onondaga County. Micron’s investment also furthers recent United States and New York State policies and programs to incentivize domestic semiconductor manufacturing. 12/14/2023 17 49 4.1 INTRODUCTION SEQRA requires the evaluation of alternatives to the Proposed Project, including either alternative sites or alternative designs, as well as a No Action Alternative. The evaluation of alternative site locations to be presented in the DEIS for the Proposed Project will be based upon the prior evaluation of alternative sites reflected in the earlier SEQRA analyses prepared by OCIDA as well as work completed by the New York State Economic Development Council (Project Rhino). See Table 1 for a summary of the various alternatives considered previously in the establishment of WPCP and those that will be carried into the DEIS for consideration. 4.1 INTRODUCTION SEQRA requires the evaluation of alternatives to the Proposed Project, including either alternative sites or alternative designs, as well as a No Action Alternative. The evaluation of alternative site locations to be presented in the DEIS for the Proposed Project will be based upon the prior evaluation of alternative sites reflected in the earlier SEQRA analyses prepared by OCIDA as well as work completed by the New York State Economic Development Council (Project Rhino). See Table 1 for a summary of the various alternatives considered previously in the establishment of WPCP and those that will be carried into the DEIS for consideration. 4.2 DISCUSSION OF ALTERNATIVE PROJECT LOCATIONS 4.2 DISCUSSION OF ALTERNATIVE PROJECT LOCATIONS 4.2.1 Alternative Sites in New York State The DEIS will include a discussion of project location needs for semiconductor manufacturing in general and Micron in particular. The DEIS will also discuss the process previously undertaken by New York State to identify candidate sites for semiconductor manufacturing over recent years. That process identified four (4) sites throughout New York State as “shovel ready” sites for semiconductor manufacturing: STAMP in Genesee County, WPCP in Onondaga County, Marcy Nanocenter in Oneida County, and Luther Forest Technology Campus in Saratoga County. The DEIS will discuss the three alternative shovel ready sites and detail why they are not suitable alternative locations for the Proposed Project. For example, since 2012, GlobalFoundries U.S., Inc. has operated a semiconductor manufacturing facility at the Luther Forest Technology Campus in Saratoga County. Marcy Nanocenter Parcel #1 was previously developed into a manufacturing facility for Wolfspeed. The remaining parcel at Marcy Nanocenter is only 438 acres, too small for the proposed project. Some development has already occurred at STAMP and the remaining available acreage at that site also is too small to accommodate the Proposed Project. 4.2.1 Alternative Sites in New York State The DEIS will include a discussion of project location needs for semiconductor manufacturing in general and Micron in particular. The DEIS will also discuss the process previously undertaken by New York State to identify candidate sites for semiconductor manufacturing over recent years. That process identified four (4) sites throughout New York State as “shovel ready” sites for semiconductor manufacturing: STAMP in Genesee County, WPCP in Onondaga County, Marcy Nanocenter in Oneida County, and Luther Forest Technology Campus in Saratoga County. The DEIS will discuss the three alternative shovel ready sites and detail why they are not suitable alternative locations for the Proposed Project. For example, since 2012, GlobalFoundries U.S., Inc. has operated a semiconductor manufacturing facility at the Luther Forest Technology Campus in Saratoga County. Marcy Nanocenter Parcel #1 was previously developed into a manufacturing facility for Wolfspeed. The remaining parcel at Marcy Nanocenter is only 438 acres, too small for the proposed project. Some development has already occurred at STAMP and the remaining available acreage at that site also is too small to accommodate the Proposed Project. In 2018 the New York State Economic Development Council (NYSEDC) prepared a “Competitive Site Location Benchmarking for Semiconductor Manufacturing” study (also known as “Project Rhino”). The purpose of the benchmarking study was to assess and compare four (4) sites in New York State, including WPCP, for their readiness to support semiconductor manufacturing; benchmark those four (4) sites against six (6) other sites located throughout the United States; and identify other industrial sectors that might be attracted to New York State to support semiconductor manufacturing. The study was based upon a hypothetical semiconductor manufacturing facility and evaluated each of the sites against a number of quality, cost, and economic incentive factors. 12/14/2023 18 50 In 2018 the New York State Economic Development Council (NYSEDC) prepared a “Competitive Site Location Benchmarking for Semiconductor Manufacturing” study (also known as “Project Rhino”). The purpose of the benchmarking study was to assess and compare four (4) sites in New York State, including WPCP, for their readiness to support semiconductor manufacturing; benchmark those four (4) sites against six (6) other sites located throughout the United States; and identify other industrial sectors that might be attracted to New York State to support semiconductor manufacturing. The study was based upon a hypothetical semiconductor manufacturing facility and evaluated each of the sites against a number of quality, cost, and economic incentive factors. 12/14/2023 18 50 The qualitative assessment evaluated the sites against five categories, each of which had several factors included: site quality and suitability; workforce and community alignment; utilities capacity, quality, and reliability; economic development and regulatory context; and incentive capacity and capability. WPCP ranked second nationally for access to utilities and readiness of those utilities to serve the site. It was noted that all four New York State sites ranked first through fourth for the degree to which tax and non-tax incentives have been made available from the State and local governments. Lastly, three of the New York sites, including WPCP, ranked in the top five for economic development and regulatory support. While all four New York State sites were among the most expensive in terms of construction costs, personnel, water and wastewater, and real estate and personal income taxes, the New York State sites had a competitive advantage on electricity and natural gas costs. On balance, the study concluded that New York State led all competitors in terms of the capacity, capability, and probability of delivering a meaningful incentives package. The DEIS will include a summary of the prior New York State site selection process and detail why alternative semiconductor locations in New York State cannot accommodate the Proposed Project. The qualitative assessment evaluated the sites against five categories, each of which had several factors included: site quality and suitability; workforce and community alignment; utilities capacity, quality, and reliability; economic development and regulatory context; and incentive capacity and capability. WPCP ranked second nationally for access to utilities and readiness of those utilities to serve the site. It was noted that all four New York State sites ranked first through fourth for the degree to which tax and non-tax incentives have been made available from the State and local governments. Lastly, three of the New York sites, including WPCP, ranked in the top five for economic development and regulatory support. While all four New York State sites were among the most expensive in terms of construction costs, personnel, water and wastewater, and real estate and personal income taxes, the New York State sites had a competitive advantage on electricity and natural gas costs. On balance, the study concluded that New York State led all competitors in terms of the capacity, capability, and probability of delivering a meaningful incentives package. The DEIS will include a summary of the prior New York State site selection process and detail why alternative semiconductor locations in New York State cannot accommodate the Proposed Project. 4.2.2 Alternative Sites and Design Options in Onondaga County As previously noted, as part of its effort to develop a “shovel-ready” industrial park in Onondaga County, OCIDA evaluated a number of potential locations throughout the county. OCIDA ultimately selected WPCP as its preferred site to attract private industrial and commercial development because of its size, potential for industrial zoning, access to transportation, proximity of utilities, as well as a history of Town of Clay efforts to facilitate industrial development at the property. 4.2.2 Alternative Sites and Design Options in Onondaga County As previously noted, as part of its effort to develop a “shovel-ready” industrial park in Onondaga County, OCIDA evaluated a number of potential locations throughout the county. OCIDA ultimately selected WPCP as its preferred site to attract private industrial and commercial development because of its size, potential for industrial zoning, access to transportation, proximity of utilities, as well as a history of Town of Clay efforts to facilitate industrial development at the property. The 2012 DGEIS prepared by OCIDA evaluated three (3) different site layouts for WPCP: 1) a layout that provided 1 million sf of development while avoiding all State-mapped wetlands; 2) a layout that provided 1.5 million sf of development that balanced approximately 4.2 acres of wetland impacts against the additional benefits from the larger size of development; and 3) a layout that provided over 2 million sf balanced against additional impacts to wetlands. OCIDA identified the third alternative as the “preferred alternative” in the 2012 DGEIS based on the overall economic returns versus the degree of environmental impacts. The DGEIS also included a 2012 engineering report evaluating three (3) options for extending sanitary sewer service to WPCP: 1) use of Verplank Road north of NYS Route 31; 2) use of the NYS Route 31 right-of-way; and 3) use of the Metropolitan Water Board (now OCWA) right-of-way south of NYS Route 31. The 2012 engineering report built from a 2003 feasibility study, the Semi-NY Sewer Route Feasibility Study, that evaluated five (5) sanitary sewer line routing options. OCIDA selected the third option for extension of sanitary sewer service to WPCP as the preferred alternative. 12/14/2023 19 51 The 2012 DGEIS prepared by OCIDA evaluated three (3) different site layouts for WPCP: 1) a layout that provided 1 million sf of development while avoiding all State-mapped wetlands; 2) a layout that provided 1.5 million sf of development that balanced approximately 4.2 acres of wetland impacts against the additional benefits from the larger size of development; and 3) a layout that provided over 2 million sf balanced against additional impacts to wetlands. OCIDA identified the third alternative as the “preferred alternative” in the 2012 DGEIS based on the overall economic returns versus the degree of environmental impacts. The DGEIS also included a 2012 engineering report evaluating three (3) options for extending sanitary sewer service to WPCP: 1) use of Verplank Road north of NYS Route 31; 2) use of the NYS Route 31 right-of-way; and 3) use of the Metropolitan Water Board (now OCWA) right-of-way south of NYS Route 31. The 2012 engineering report built from a 2003 feasibility study, the Semi-NY Sewer Route Feasibility Study, that evaluated five (5) sanitary sewer line routing options. OCIDA selected the third option for extension of sanitary sewer service to WPCP as the preferred alternative. 12/14/2023 19 51 The 2021 Final SGEIS prepared by OCIDA revisited the question of whether WPCP was the preferred alternative to attract industrial and commercial development to Onondaga County, and compared it to the same alternative candidate sites that were assessed in the 2012 DGEIS, concluding that “[n]one of the previously considered alternative locations would be able to accommodate the large-scale industrial use that the [White Pine Commerce] Park is promoting due to size limitations and proximity to services and necessary infrastructure.” The 2021 Final SGEIS further concluded that significant expansion of WPCP was feasible and more likely to attract leading edge manufacturing, such as semiconductor manufacturing. The 2021 SGEIS assessed the additional potential significant adverse impacts from a larger facility (up to 4 million sf of manufacturing space) and increase in size of the development parcel to approximately 1,250 acres. OCIDA indicated in the SEQRA Findings Statement that “consistent with social, economic and other essential considerations from among the reasonable alternatives available, the action is the one that avoids or minimizes adverse impacts to the maximum extent practicable, and that adverse impacts will be avoided or minimized to the maximum extent practicable by incorporating as conditions to the decision those mitigation measures that were identified as practicable.” The 2021 Final SGEIS prepared by OCIDA revisited the question of whether WPCP was the preferred alternative to attract industrial and commercial development to Onondaga County, and compared it to the same alternative candidate sites that were assessed in the 2012 DGEIS, concluding that “[n]one of the previously considered alternative locations would be able to accommodate the large-scale industrial use that the [White Pine Commerce] Park is promoting due to size limitations and proximity to services and necessary infrastructure.” The 2021 Final SGEIS further concluded that significant expansion of WPCP was feasible and more likely to attract leading edge manufacturing, such as semiconductor manufacturing. The 2021 SGEIS assessed the additional potential significant adverse impacts from a larger facility (up to 4 million sf of manufacturing space) and increase in size of the development parcel to approximately 1,250 acres. OCIDA indicated in the SEQRA Findings Statement that “consistent with social, economic and other essential considerations from among the reasonable alternatives available, the action is the one that avoids or minimizes adverse impacts to the maximum extent practicable, and that adverse impacts will be avoided or minimized to the maximum extent practicable by incorporating as conditions to the decision those mitigation measures that were identified as practicable.” The DEIS will include a summary of the prior Onondaga County site selection process, but will not include detailed impact assessment of any of the candidate sites included in that prior process. The DEIS will include a summary of the prior Onondaga County site selection process, but will not include detailed impact assessment of any of the candidate sites included in that prior process. 4.2.3 Other Alternatives Considered but Determined Not Feasible The DEIS will include a summary of other alternatives previously considered but determined not to be feasible, including an alternative that relies exclusively on alternative sources of energy (beyond use of renewable energy for purchased electricity). The DEIS will also summarize previous Onondaga County Water Authority studies evaluating potential alternative sources of water. 4.2.3 Other Alternatives Considered but Determined Not Feasible The DEIS will include a summary of other alternatives previously considered but determined not to be feasible, including an alternative that relies exclusively on alternative sources of energy (beyond use of renewable energy for purchased electricity). The DEIS will also summarize previous Onondaga County Water Authority studies evaluating potential alternative sources of water. 4.3 ALTERNATIVES TO BE CONSIDERED IN THE DEIS 4.3 ALTERNATIVES TO BE CONSIDERED IN THE DEIS 4.3.1 No Action Alternative Under the No Action Alternative, WPCP would delay OCIDA’s long-standing efforts to develop the WPCP, with a particular focus on development that will bring high-tech facilities and high paying jobs to Onondaga County. OCIDA’s 2021 Final SGEIS concluded that development of up to 4 million sf of manufacturing space would avoid, minimize, or mitigate adverse environmental impacts to the maximum extent practicable. The WPCP would therefore remain vacant land until such time as OCIDA identified another development proposal for the WPCP. 4.3.1 No Action Alternative Under the No Action Alternative, WPCP would delay OCIDA’s long-standing efforts to develop the WPCP, with a particular focus on development that will bring high-tech facilities and high paying jobs to Onondaga County. OCIDA’s 2021 Final SGEIS concluded that development of up to 4 million sf of manufacturing space would avoid, minimize, or mitigate adverse environmental impacts to the maximum extent practicable. The WPCP would therefore remain vacant land until such time as OCIDA identified another development proposal for the WPCP. 4.3.2 The Proposed Project Micron intends to build a semiconductor manufacturing facility campus (the “Micron Campus”) at the expanded WPCP, which will be built-out over an approximately 20-year period with four 12/14/2023 20 52 Fabs. It is expected that Fabs will be continuously fit-out and construction on the next Fab will be in sequence as the prior Fab finishes fit-out. The DEIS will analyze an interim analysis year of 2031 with Fab 1 in operation and Fab 2 under construction and anticipated completion of major off- site transportation improvements,6 2037 with Fab 1 and Fab 2 operating and construction of Fab 3 underway, as well as a final analysis year of 2041 with all four Fabs in operation with on-going fit- out of Fab 4). 4.3.2 The Proposed Project Micron intends to build a semiconductor manufacturing facility campus (the “Micron Campus”) at the expanded WPCP, which will be built-out over an approximately 20-year period with four 12/14/2023 20 52 Fabs. It is expected that Fabs will be continuously fit-out and construction on the next Fab will be in sequence as the prior Fab finishes fit-out. The DEIS will analyze an interim analysis year of 2031 with Fab 1 in operation and Fab 2 under construction and anticipated completion of major off- site transportation improvements,6 2037 with Fab 1 and Fab 2 operating and construction of Fab 3 underway, as well as a final analysis year of 2041 with all four Fabs in operation with on-going fit- out of Fab 4). 4.3.3 The Proposed Project with No Access from US Route 11 Micron intends to build a site access road from US Route 11 in the Town of Cicero to facilitate construction and operation access to the Proposed Project once construction of Fab 3 commences. The DEIS will analyze an alternative access scenario that eliminates this site access road from the Micron Campus to US Route 11. In this alternative, all access to the Micron Campus would be from NYS Route 31 and Caughdenoy Road. 4.3.3 The Proposed Project with No Access from US Route 11 Micron intends to build a site access road from US Route 11 in the Town of Cicero to facilitate construction and operation access to the Proposed Project once construction of Fab 3 commences. The DEIS will analyze an alternative access scenario that eliminates this site access road from the Micron Campus to US Route 11. In this alternative, all access to the Micron Campus would be from NYS Route 31 and Caughdenoy Road. 4.3.4 Alternative Internal Configurations of the Proposed Project Consistent with the requirements of the Clean Water Act (Section 404(b)(1)), which governs the filling of wetlands, Micron must demonstrate that the Proposed Project is the least environmentally damaging practicable alternative (“LEDPA”). In accordance with USEPA “Guidelines for Specification of Disposal Sites for Dredged or Fill Material (40 CFR Part 230), Micron has developed an alternative analysis to evaluate the reasonableness and practicableness of several on-site layout alternatives. The DEIS will consider these on-site layout alternatives. 4.3.4 Alternative Internal Configurations of the Proposed Project Consistent with the requirements of the Clean Water Act (Section 404(b)(1)), which governs the filling of wetlands, Micron must demonstrate that the Proposed Project is the least environmentally damaging practicable alternative (“LEDPA”). In accordance with USEPA “Guidelines for Specification of Disposal Sites for Dredged or Fill Material (40 CFR Part 230), Micron has developed an alternative analysis to evaluate the reasonableness and practicableness of several on-site layout alternatives. The DEIS will consider these on-site layout alternatives. 4.3.5 Reduced Scale Proposed Project The DEIS will consider an alternative development site plan reflecting a reduced scale of the Proposed Project, which would comprise only the first two Fabs, as described above. All of the same off-site improvements would be considered as part of the Reduced Scale Proposed Project and while the improvements would be scaled to the requirements of the smaller project, the areal extent of disturbance to construct those conveyances would be substantially similar to that required for the Proposed Project while only realizing half of the economic and social benefits from the Proposed Project. The purpose of this alternative is to assess significant adverse effects from a reduced scale project and compare such effects to the Proposed Project. 6 The 2031 interim year analysis will evaluate any traffic, air quality, noise, and construction impacts for what is projected to be a peak of operations and construction employment. For other areas of impact analysis, the 2037 analysis year representing completion of Fab 1 and Fab 2 will be used to reflect the larger amount of project completion at that time. 12/14/2023 21 53 4.3.5 Reduced Scale Proposed Project The DEIS will consider an alternative development site plan reflecting a reduced scale of the Proposed Project, which would comprise only the first two Fabs, as described above. All of the same off-site improvements would be considered as part of the Reduced Scale Proposed Project and while the improvements would be scaled to the requirements of the smaller project, the areal extent of disturbance to construct those conveyances would be substantially similar to that required for the Proposed Project while only realizing half of the economic and social benefits from the Proposed Project. The purpose of this alternative is to assess significant adverse effects from a reduced scale project and compare such effects to the Proposed Project. 6 The 2031 interim year analysis will evaluate any traffic, air quality, noise, and construction impacts for what is projected to be a peak of operations and construction employment. For other areas of impact analysis, the 2037 analysis year representing completion of Fab 1 and Fab 2 will be used to reflect the larger amount of project completion at that time. 12/14/2023 21 53 TABLE 1 SUMMARY OF ALTERNATIVES CONSIDERED OR TO BE CONSIDERED Alternatives Considered Status of Alternative Alternative Sites Considered in New York State STAMP in Genesee County Withdrawn from further consideration because some development has already occurred, and the remaining parcel is too small for the proposed project. Marcy Nanocenter in Oneida County Withdrawn from further consideration because the site was previously developed into a manufacturing facility for Wolfspeed. Luther Forest Technology Campus in Saratoga County Withdrawn from further consideration because, since 2012, GlobalFoundries has operated a semiconductor manufacturing facility on this site. TABLE 1 SUMMARY OF ALTERNATIVES CONSIDERED OR TO BE CONSIDERED Alternatives Considered Status of Alternative Alternative Sites Considered in New York State STAMP in Genesee County Withdrawn from further consideration because some development has already occurred, and the remaining parcel is too small for the proposed project. Marcy Nanocenter in Oneida County Withdrawn from further consideration because the site was previously developed into a manufacturing facility for Wolfspeed. Luther Forest Technology Campus in Saratoga County Withdrawn from further consideration because, since 2012, GlobalFoundries has operated a semiconductor manufacturing facility on this site. Previous Alternatives Considered in OCIDA 2013 Generic EIS (GEIS) for White Pine Commerce Park Radisson Corporate Park Withdrawn from further consideration because it lacked room and did not offer the location specific advantages such as proximity to Interstate 81. Hancock Air Park Withdrawn from further consideration because available lots were too Collamer Crossings Business Park small and could not accommodate large industrial uses. Syracuse Research Park Concept 1: 1 million square foot development – no wetland impacts Withdrawn from consideration because it could not easily accommodate Concept 2: 1.5 million square foot development – 4.2 acres of large-scale industrial uses. wetland impacts Concept 3: 2 million square foot development – additional wetlands impacts Previous Alternatives Considered in OCIDA 2013 Generic EIS (GEIS) for White Pine Commerce Park Radisson Corporate Park Withdrawn from further consideration because it lacked room and did not offer the location specific advantages such as proximity to Interstate 81. Hancock Air Park Withdrawn from further consideration because available lots were too Collamer Crossings Business Park small and could not accommodate large industrial uses. Syracuse Research Park Concept 1: 1 million square foot development – no wetland impacts Withdrawn from consideration because it could not easily accommodate Concept 2: 1.5 million square foot development – 4.2 acres of large-scale industrial uses. wetland impacts Concept 3: 2 million square foot development – additional wetlands impacts Previous Alternatives Considered in OCIDA 2021 Supplemental GEIS for White Pine Commerce Park Alternative 1: Retain site as open space Withdrawn from consideration because it could not easily accommodate large-scale industrial uses. Alternative 2: Same as Concept 3 in OCIDA’s 2013 GEIS Withdrawn from consideration because it could not easily accommodate Alternative 3: Comparable to Alternative 2 but at smaller large-scale industrial uses. scale Preferred Alternative: 4 million square feet development – OCIDA identified this alternative as the preferred alternative in the additional wetlands impacts Supplemental GEIS based on the overall economic returns versus the degree of environmental impacts. Previous Alternatives Considered in OCIDA 2021 Supplemental GEIS for White Pine Commerce Park Alternative 1: Retain site as open space Withdrawn from consideration because it could not easily accommodate large-scale industrial uses. Alternative 2: Same as Concept 3 in OCIDA’s 2013 GEIS Withdrawn from consideration because it could not easily accommodate Alternative 3: Comparable to Alternative 2 but at smaller large-scale industrial uses. scale Preferred Alternative: 4 million square feet development – OCIDA identified this alternative as the preferred alternative in the additional wetlands impacts Supplemental GEIS based on the overall economic returns versus the degree of environmental impacts. Other Alternatives Considered but Determined to be Not Feasible Alternative Energy Sources The DEIS will describe how Micron’s Proposed Project could not rely exclusively on alternative energy sources (beyond use of renewable energy for purchased electricity) before reliable energy sources are identified and developed. Alternatives to be Considered in the Draft EIS for the Micron Semiconductor Fabrication Project No Action Proposed Project (4 fabs) Proposed Project No Access from US Route 11 These alternatives will be considered in the DEIS for the Micron Proposed Project Alternative Internal Configurations* – Semiconductor Fabrication Project in Clay, NY. Options 2, 3, 4, 5, 6 and 7 Reduced Scale Proposed Project (2 fabs)** * Note: Proposed Project– Alternative Internal Configuration Option 1 is the Proposed Project (4 fabs). ** This alternative is similar to the Preferred Alternative: 4 million square feet development identified in the OCIDA 2021 SGEIS. 12/14/2023 22 54 Other Alternatives Considered but Determined to be Not Feasible Alternative Energy Sources The DEIS will describe how Micron’s Proposed Project could not rely exclusively on alternative energy sources (beyond use of renewable energy for purchased electricity) before reliable energy sources are identified and developed. Alternatives to be Considered in the Draft EIS for the Micron Semiconductor Fabrication Project No Action Proposed Project (4 fabs) Proposed Project No Access from US Route 11 These alternatives will be considered in the DEIS for the Micron Proposed Project Alternative Internal Configurations* – Semiconductor Fabrication Project in Clay, NY. Options 2, 3, 4, 5, 6 and 7 Reduced Scale Proposed Project (2 fabs)** * Note: Proposed Project– Alternative Internal Configuration Option 1 is the Proposed Project (4 fabs). ** This alternative is similar to the Preferred Alternative: 4 million square feet development identified in the OCIDA 2021 SGEIS. 12/14/2023 22 54 5 Analysis Framework This section outlines the analytical framework that will be used to complete the DEIS. It describes the reasoning behind the chosen analysis year(s) and study area(s) and outlines the methodology used to establish baseline conditions from which the environmental effects will be analyzed. 5 Analysis Framework This section outlines the analytical framework that will be used to complete the DEIS. It describes the reasoning behind the chosen analysis year(s) and study area(s) and outlines the methodology used to establish baseline conditions from which the environmental effects will be analyzed. 5.1 ORGANIZATION OF THE ENVIRONMENTAL IMPACT STATEMENT Preparation of the DEIS will conform to 6 NYCRR Part 617.9(b). The Proposed Project will be evaluated for potential significant adverse effects to the Project Site7 and applicable study areas for all relevant environmental technical categories in accordance with applicable SEQRA requirements. The DEIS will consider short-term (construction) and long-term (operational) effects (including direct and indirect effects) of the Proposed Project. Cumulative impacts will also be addressed, as applicable. The DEIS will identify proposed mitigation for any significant adverse environmental impacts. The DEIS shall include a list of all Involved and Interested Agencies to which copies of the DEIS and supporting material will be distributed. See Table 2, “Preliminary List of SEQRA Lead, Involved, and Interested Agencies,” and Table 3, “Preliminary List of Federal Agencies,” in Section 6. Consistent with those regulations, the DEIS technical chapters are proposed as shown below. Appendices of the DEIS will contain any detailed technical studies used to complete the DEIS. 5.1 ORGANIZATION OF THE ENVIRONMENTAL IMPACT STATEMENT Preparation of the DEIS will conform to 6 NYCRR Part 617.9(b). The Proposed Project will be evaluated for potential significant adverse effects to the Project Site7 and applicable study areas for all relevant environmental technical categories in accordance with applicable SEQRA requirements. The DEIS will consider short-term (construction) and long-term (operational) effects (including direct and indirect effects) of the Proposed Project. Cumulative impacts will also be addressed, as applicable. The DEIS will identify proposed mitigation for any significant adverse environmental impacts. The DEIS shall include a list of all Involved and Interested Agencies to which copies of the DEIS and supporting material will be distributed. See Table 2, “Preliminary List of SEQRA Lead, Involved, and Interested Agencies,” and Table 3, “Preliminary List of Federal Agencies,” in Section 6. Consistent with those regulations, the DEIS technical chapters are proposed as shown below. Appendices of the DEIS will contain any detailed technical studies used to complete the DEIS. ▪ Cover Sheet (see below) ▪ Table of Contents ▪ Executive Summary ▪ Chapter 1 – Purpose and Need ▪ Chapter 2 – Project Alternatives and Description of the Proposed Project ▪ Chapter 3 – Land Use, Zoning, and Public Policy ▪ Chapter 4 – Community Facilities, Open Space and Recreation ▪ Chapter 5 – Socioeconomic Conditions ▪ Chapter 6 – Environmental Justice ▪ Chapter 7 – Historic and Cultural Resources ▪ Chapter 8 – Visual Impacts and Community Character ▪ Chapter 9 – Geology, Soils, and Topography ▪ Chapter 10 – Water Resources ▪ Chapter 11 – Ecological Communities and Wildlife ▪ Chapter 12 – Solid Waste ▪ Chapter 13 – Hazardous Materials 7 References to the “Project Site” refer to any location where elements of the Proposed Project or off-site improvements will be constructed. 12/14/2023 23 55 ▪ Cover Sheet (see below) ▪ Table of Contents ▪ Executive Summary ▪ Chapter 1 – Purpose and Need ▪ Chapter 2 – Project Alternatives and Description of the Proposed Project ▪ Chapter 3 – Land Use, Zoning, and Public Policy ▪ Chapter 4 – Community Facilities, Open Space and Recreation ▪ Chapter 5 – Socioeconomic Conditions ▪ Chapter 6 – Environmental Justice ▪ Chapter 7 – Historic and Cultural Resources ▪ Chapter 8 – Visual Impacts and Community Character ▪ Chapter 9 – Geology, Soils, and Topography ▪ Chapter 10 – Water Resources ▪ Chapter 11 – Ecological Communities and Wildlife ▪ Chapter 12 – Solid Waste ▪ Chapter 13 – Hazardous Materials 7 References to the “Project Site” refer to any location where elements of the Proposed Project or off-site improvements will be constructed. 12/14/2023 23 55 ▪ Chapter 14 – Transportation ▪ Chapter 15 – Air Quality ▪ Chapter 16 – Greenhouse Gas Emissions and Climate Change ▪ Chapter 17 – Noise and Vibration ▪ Chapter 18 – Utilities and Infrastructure ▪ Chapter 19 – Use and Conservation of Energy ▪ Chapter 20 – Construction ▪ Chapter 21 – Permits ▪ Chapter 22 –Cumulative Impacts ▪ Chapter 23 – Unavoidable Adverse Impacts ▪ Chapter 24 – Growth Inducing Aspects ▪ Chapter 25 – Irreversible and Irretrievable Commitment of Resources ▪ Chapter 26 – Mitigation ▪ Appendices Consistent with 6 NYCRR Part 617.9(b)(3), the DEIS Cover Sheet shall: (i) identify the document as a DEIS; (ii) identify the name of the Proposed Project; (iii) identify the location of the Proposed Project; (iv) identify the name and address of the Lead Agency and the contact information of a person at the agency who can provide further information; (v) identify the names of individuals and organizations that prepared any portion of the DEIS; (vi) identify the date the DEIS was accepted as complete with respect to the Final Scope by the Lead Agency; and (vii) identify the date of the DEIS Public Hearing and the closing of the Public Comment Period. ▪ Chapter 14 – Transportation ▪ Chapter 15 – Air Quality ▪ Chapter 16 – Greenhouse Gas Emissions and Climate Change ▪ Chapter 17 – Noise and Vibration ▪ Chapter 18 – Utilities and Infrastructure ▪ Chapter 19 – Use and Conservation of Energy ▪ Chapter 20 – Construction ▪ Chapter 21 – Permits ▪ Chapter 22 –Cumulative Impacts ▪ Chapter 23 – Unavoidable Adverse Impacts ▪ Chapter 24 – Growth Inducing Aspects ▪ Chapter 25 – Irreversible and Irretrievable Commitment of Resources ▪ Chapter 26 – Mitigation ▪ Appendices Consistent with 6 NYCRR Part 617.9(b)(3), the DEIS Cover Sheet shall: (i) identify the document as a DEIS; (ii) identify the name of the Proposed Project; (iii) identify the location of the Proposed Project; (iv) identify the name and address of the Lead Agency and the contact information of a person at the agency who can provide further information; (v) identify the names of individuals and organizations that prepared any portion of the DEIS; (vi) identify the date the DEIS was accepted as complete with respect to the Final Scope by the Lead Agency; and (vii) identify the date of the DEIS Public Hearing and the closing of the Public Comment Period. 5.2 ANALYSIS YEARS The following analysis years (build years) will be included in the DEIS for the Proposed Project. Selection of analysis years is based on Micron's projected operations and construction employment and peak levels of activities: ▪ 2031 — Interim analysis year with Fab 1 in operation and Fab 2 under construction and anticipated completion of major off-site transportation improvements8; 8 The 2031 interim year analysis will evaluate any traffic, air quality, noise, and construction impacts for what is projected to be a peak of operations and construction employment. For other areas of impact analysis, the 2037 analysis year representing completion of Fab 1 and Fab 2 will be used to reflect the larger amount of project completion at that time. 12/14/2023 24 56 ▪ 2037 — Interim analysis year with Fab 1 and Fab 2 operating and construction of Fab 3 underway; and ▪ 2041 — All four Fabs in operation with on-going fit out of Fab 4. Specific study areas for technical evaluations will be established and described in each chapter as appropriate (i.e., traffic intersections for analysis). 5.2 ANALYSIS YEARS The following analysis years (build years) will be included in the DEIS for the Proposed Project. Selection of analysis years is based on Micron's projected operations and construction employment and peak levels of activities: ▪ 2031 — Interim analysis year with Fab 1 in operation and Fab 2 under construction and anticipated completion of major off-site transportation improvements8; 8 The 2031 interim year analysis will evaluate any traffic, air quality, noise, and construction impacts for what is projected to be a peak of operations and construction employment. For other areas of impact analysis, the 2037 analysis year representing completion of Fab 1 and Fab 2 will be used to reflect the larger amount of project completion at that time. 12/14/2023 24 56 ▪ 2037 — Interim analysis year with Fab 1 and Fab 2 operating and construction of Fab 3 underway; and ▪ 2041 — All four Fabs in operation with on-going fit out of Fab 4. Specific study areas for technical evaluations will be established and described in each chapter as appropriate (i.e., traffic intersections for analysis). 5.3 METHODOLOGIES FOR TECHNICAL ANALYSES 5.3 METHODOLOGIES FOR TECHNICAL ANALYSES 5.3.1 Technical Studies The environmental review will include site-specific evaluations and studies of the full range of technical areas needed to comply with SEQRA. The following bullets identify the key environmental topics that could result in potential adverse impacts that will be studied. If environmental analysis reveals any significant adverse impacts, the document will identify any reasonable measures to minimize or mitigate those impacts. To the extent applicable, prior studies completed by OCIDA as part of its generic environmental impact statements will be referenced in the site-specific assessments completed as part of the current environmental impact statement. 5.3.1 Technical Studies The environmental review will include site-specific evaluations and studies of the full range of technical areas needed to comply with SEQRA. The following bullets identify the key environmental topics that could result in potential adverse impacts that will be studied. If environmental analysis reveals any significant adverse impacts, the document will identify any reasonable measures to minimize or mitigate those impacts. To the extent applicable, prior studies completed by OCIDA as part of its generic environmental impact statements will be referenced in the site-specific assessments completed as part of the current environmental impact statement. ▪ LAND USE, ZONING, AND PUBLIC POLICY: This analysis will assess land use, zoning, and public policy, including relevant New York State policy related to Green CHIPS. Zoning compliance of the Proposed Project will be assessed where project elements are proposed. The study area for the land use assessment will be one mile from the Micron Campus as well as, where relevant, any other areas where off-site development is proposed to occur. Public policy assessments will cover the Town of Clay, Town of Cicero, and Onondaga County, as appropriate. This analysis will also identify reasonably foreseeable development projects (projects known or likely to be built within the time horizon of the Proposed Project in the study area) based on information obtained from the Town of Clay, Town of Cicero, and Onondaga County. Changes in land use and/or zoning that may result from the Proposed Project, either directly or indirectly, will be described and evaluated. Consistency with any applicable local or regional policies, including the SMTC 2050 Long Range Transportation Plan, Onondaga County Comprehensive Plan, Onondaga County Climate Action Plan, Town of Clay Comprehensive Plan (if available; draft anticipated in March 2024), Town of Clay Northern Land Use Study, Town of Clay Local Waterfront Revitalization Program (LWRP) (for proposed modifications to the Oak Orchard WWTP), Town of Cicero Comprehensive Plan (if available; draft anticipated in April 2024), and City of Oswego LWRP (for proposed improvements to water supply infrastructure) will be evaluated. ▪ COMMUNITY FACILITIES/OPEN SPACE AND RECREATION: The police, fire, emergency, and community service providers within the Town of Clay and the Town of Cicero, and school district(s) that serve the Proposed Project will be identified and the impacts to each service will be analyzed with potential mitigation identified where significant adverse impacts are identified. The relevant Town of Clay and Town of Cicero departments will be consulted regarding the ▪ LAND USE, ZONING, AND PUBLIC POLICY: This analysis will assess land use, zoning, and public policy, including relevant New York State policy related to Green CHIPS. Zoning compliance of the Proposed Project will be assessed where project elements are proposed. The study area for the land use assessment will be one mile from the Micron Campus as well as, where relevant, any other areas where off-site development is proposed to occur. Public policy assessments will cover the Town of Clay, Town of Cicero, and Onondaga County, as appropriate. This analysis will also identify reasonably foreseeable development projects (projects known or likely to be built within the time horizon of the Proposed Project in the study area) based on information obtained from the Town of Clay, Town of Cicero, and Onondaga County. Changes in land use and/or zoning that may result from the Proposed Project, either directly or indirectly, will be described and evaluated. Consistency with any applicable local or regional policies, including the SMTC 2050 Long Range Transportation Plan, Onondaga County Comprehensive Plan, Onondaga County Climate Action Plan, Town of Clay Comprehensive Plan (if available; draft anticipated in March 2024), Town of Clay Northern Land Use Study, Town of Clay Local Waterfront Revitalization Program (LWRP) (for proposed modifications to the Oak Orchard WWTP), Town of Cicero Comprehensive Plan (if available; draft anticipated in April 2024), and City of Oswego LWRP (for proposed improvements to water supply infrastructure) will be evaluated. ▪ COMMUNITY FACILITIES/OPEN SPACE AND RECREATION: The police, fire, emergency, and community service providers within the Town of Clay and the Town of Cicero, and school district(s) that serve the Proposed Project will be identified and the impacts to each service will be analyzed with potential mitigation identified where significant adverse impacts are identified. The relevant Town of Clay and Town of Cicero departments will be consulted regarding the 12/14/2023 25 57 existing staffing of emergency services; planned changes to staffing levels, service levels, equipment and/or facilities; and how those departments would respond to emergency situations at the site. The DEIS will assess potential impacts of the Proposed Project on staffing levels, service levels, equipment and/or facilities on- and off-site. The chapter will discuss separation distance between buildings, proposed fire access, and construction in accordance with applicable building and fire codes. The chapter will also describe and map existing parks and recreational resources on-site and within one mile of the Micron Campus, including walking paths and trails. Using information made available by the State/County/Town parks agencies, the assessment will include a discussion of planned changes to existing parks and recreational resources, and/or development of new parks and recreational resources anticipated to occur in the future without the Proposed Project. Potential direct and indirect impacts of the Proposed Project on parks and recreational facilities will be assessed. Operations of the Proposed Project may result in new residential populations that may generate additional school children. The DEIS will identify enrollment trends for the following school districts and will identify whether any of these school districts may require capacity enhancements: North Syracuse Central School District (CSD), Baldwinsville CSD, Liverpool CSD, Central Square CSD, and Phoenix CSD. ▪ SOCIOECONOMIC CONDITIONS: This analysis will examine the potential direct and indirect effects of the Proposed Project on population, housing, and economic activities within local and regional study areas. The local study area will be the Town of Clay, and the regional study area will include Onondaga County and surrounding counties in the Central New York region (the area from which most Micron employees would reside). The analysis will use a variety of data sources including the U.S. Census Bureau, New York State Department of Labor, Syracuse Metropolitan Transportation Council (SMTC), OCIDA, Empire State Development (ESD), and study area municipalities to present: existing demographic and workforce characteristics; changes that are expected to occur in the future independent of the Proposed Project; and the potential impacts of the Proposed Project. The impact assessment will consider changes in demographics and housing costs, property taxes, changes in labor supply and effects on existing businesses, and municipal costs generated by the Proposed Project. In addition to considering potential adverse effects, the analysis will describe anticipated social and economic benefits such as jobs, economic and workforce development opportunities, and municipal and state tax revenues. The DEIS will also describe Micron’s efforts to work with community leaders through the Community Engagement Committee (CEC) (an entity convened by the Governor’s Office, Micron, and local elected officials) to consider how project benefits can be distributed throughout the affected communities, including to communities of color or low-income communities. This is necessary to issue findings where agencies must balance social and economic considerations against environmental impacts that cannot be avoided or mitigated. ▪ ENVIRONMENTAL JUSTICE: The environmental justice study area will include all census block groups that are within or intersect a 10-mile radius of the Proposed Project as well as the area that 12/14/2023 25 57 existing staffing of emergency services; planned changes to staffing levels, service levels, equipment and/or facilities; and how those departments would respond to emergency situations at the site. The DEIS will assess potential impacts of the Proposed Project on staffing levels, service levels, equipment and/or facilities on- and off-site. The chapter will discuss separation distance between buildings, proposed fire access, and construction in accordance with applicable building and fire codes. The chapter will also describe and map existing parks and recreational resources on-site and within one mile of the Micron Campus, including walking paths and trails. Using information made available by the State/County/Town parks agencies, the assessment will include a discussion of planned changes to existing parks and recreational resources, and/or development of new parks and recreational resources anticipated to occur in the future without the Proposed Project. Potential direct and indirect impacts of the Proposed Project on parks and recreational facilities will be assessed. Operations of the Proposed Project may result in new residential populations that may generate additional school children. The DEIS will identify enrollment trends for the following school districts and will identify whether any of these school districts may require capacity enhancements: North Syracuse Central School District (CSD), Baldwinsville CSD, Liverpool CSD, Central Square CSD, and Phoenix CSD. ▪ SOCIOECONOMIC CONDITIONS: This analysis will examine the potential direct and indirect effects of the Proposed Project on population, housing, and economic activities within local and regional study areas. The local study area will be the Town of Clay, and the regional study area will include Onondaga County and surrounding counties in the Central New York region (the area from which most Micron employees would reside). The analysis will use a variety of data sources including the U.S. Census Bureau, New York State Department of Labor, Syracuse Metropolitan Transportation Council (SMTC), OCIDA, Empire State Development (ESD), and study area municipalities to present: existing demographic and workforce characteristics; changes that are expected to occur in the future independent of the Proposed Project; and the potential impacts of the Proposed Project. The impact assessment will consider changes in demographics and housing costs, property taxes, changes in labor supply and effects on existing businesses, and municipal costs generated by the Proposed Project. In addition to considering potential adverse effects, the analysis will describe anticipated social and economic benefits such as jobs, economic and workforce development opportunities, and municipal and state tax revenues. The DEIS will also describe Micron’s efforts to work with community leaders through the Community Engagement Committee (CEC) (an entity convened by the Governor’s Office, Micron, and local elected officials) to consider how project benefits can be distributed throughout the affected communities, including to communities of color or low-income communities. This is necessary to issue findings where agencies must balance social and economic considerations against environmental impacts that cannot be avoided or mitigated. ▪ ENVIRONMENTAL JUSTICE: The environmental justice study area will include all census block groups that are within or intersect a 10-mile radius of the Proposed Project as well as the area that 12/14/2023 26 58 could be affected by changes in traffic patterns resulting from the Proposed Project. The environmental justice study area also encompasses the areas that would be affected by the off-site improvements. Pursuant to the Laws of New York (2022) ECL § 8-0113(2)(b), this analysis will consider the direct or indirect impacts of the Proposed Project on any identified low- income, minority, or “disadvantaged communities” (as defined in ECL § 75-0101(5)), including whether the Proposed Project may cause or increase a disproportionate pollution burden on those communities. This analysis will also follow Executive Order 12898 on Environmental Justice, “Federal Actions to Address Environmental Justice in Minority Populations and Low- Income Populations,” Executive Order 14008, “Tackling the Climate Crisis at Home and Abroad,” and Executive Order 14096, “Revitalizing our Nation’s Commitment to Environmental Justice for All,” to determine whether the Proposed Project will result in any disproportionate and adverse impacts on minority or low-income populations (in anticipation of consistency with federal guidelines as part of federal NEPA review or permitting for the Proposed Project). This analysis will also describe the public outreach undertaken to inform and involve minority and low-income populations who may be affected by the Proposed Project. ▪ HISTORIC AND CULTURAL RESOURCES: This analysis will document the Proposed Project’s impact on historic and cultural resources consistent with Section 14.09 of the New York State Historic Preservation Act, and NYSDEC Commissioner Policy 42, “Contact, Cooperation, and Consultation with Indian Nations.” An Area of Potential Effects (APE) (study area) will be defined for potential direct effects covering any location where construction would occur as well as a ¼-mile study area for potential indirect effects where construction activities would result in permanent above-ground features that could have the potential to indirectly affect historic architectural resources. The New York State Office of Parks, Recreation, and Historic Preservation (OPRHP) Cultural Resources Information System (CRIS) will be consulted to identify if there are any known listed or eligible structures within the APE. Additionally, any previously unidentified historic resources in the APE will be identified and evaluated. The evaluation will assess the potential of the Proposed Project to affect historic and cultural resources in the APE including buried archaeological resources through consultation with the New York State Historic Preservation Office (SHPO). It is anticipated that Section 106 of the National Historic Preservation Act compliance would be completed by a Federal agency as part of federal permitting for the Proposed Project. ▪ VISUAL IMPACTS AND COMMUNITY CHARACTER: This analysis will evaluate the Proposed Project for potential visual and community character impacts within a five-mile radius of the Micron Campus and ¼-mile from the Childcare Site and rail spur site (which are included within the five-mile radius of the Micron Campus) and ¼-mile from above-ground structures associated with the off-site improvements. This section of the DEIS will detail the existing aesthetic characteristics of the WPCP and surrounding area through descriptive text and representative photographs including a description of prevalent landforms and vegetative cover. Potential changes in views of the Proposed Project and its surroundings will be evaluated through comparisons of post-development conditions to the existing conditions and to the established 12/14/2023 26 58 could be affected by changes in traffic patterns resulting from the Proposed Project. The environmental justice study area also encompasses the areas that would be affected by the off-site improvements. Pursuant to the Laws of New York (2022) ECL § 8-0113(2)(b), this analysis will consider the direct or indirect impacts of the Proposed Project on any identified low- income, minority, or “disadvantaged communities” (as defined in ECL § 75-0101(5)), including whether the Proposed Project may cause or increase a disproportionate pollution burden on those communities. This analysis will also follow Executive Order 12898 on Environmental Justice, “Federal Actions to Address Environmental Justice in Minority Populations and Low- Income Populations,” Executive Order 14008, “Tackling the Climate Crisis at Home and Abroad,” and Executive Order 14096, “Revitalizing our Nation’s Commitment to Environmental Justice for All,” to determine whether the Proposed Project will result in any disproportionate and adverse impacts on minority or low-income populations (in anticipation of consistency with federal guidelines as part of federal NEPA review or permitting for the Proposed Project). This analysis will also describe the public outreach undertaken to inform and involve minority and low-income populations who may be affected by the Proposed Project. ▪ HISTORIC AND CULTURAL RESOURCES: This analysis will document the Proposed Project’s impact on historic and cultural resources consistent with Section 14.09 of the New York State Historic Preservation Act, and NYSDEC Commissioner Policy 42, “Contact, Cooperation, and Consultation with Indian Nations.” An Area of Potential Effects (APE) (study area) will be defined for potential direct effects covering any location where construction would occur as well as a ¼-mile study area for potential indirect effects where construction activities would result in permanent above-ground features that could have the potential to indirectly affect historic architectural resources. The New York State Office of Parks, Recreation, and Historic Preservation (OPRHP) Cultural Resources Information System (CRIS) will be consulted to identify if there are any known listed or eligible structures within the APE. Additionally, any previously unidentified historic resources in the APE will be identified and evaluated. The evaluation will assess the potential of the Proposed Project to affect historic and cultural resources in the APE including buried archaeological resources through consultation with the New York State Historic Preservation Office (SHPO). It is anticipated that Section 106 of the National Historic Preservation Act compliance would be completed by a Federal agency as part of federal permitting for the Proposed Project. ▪ VISUAL IMPACTS AND COMMUNITY CHARACTER: This analysis will evaluate the Proposed Project for potential visual and community character impacts within a five-mile radius of the Micron Campus and ¼-mile from the Childcare Site and rail spur site (which are included within the five-mile radius of the Micron Campus) and ¼-mile from above-ground structures associated with the off-site improvements. This section of the DEIS will detail the existing aesthetic characteristics of the WPCP and surrounding area through descriptive text and representative photographs including a description of prevalent landforms and vegetative cover. Potential changes in views of the Proposed Project and its surroundings will be evaluated through comparisons of post-development conditions to the existing conditions and to the established 12/14/2023 27 59 aesthetic character of the surrounding area. The analysis will identify and describe significant views into the existing WPCP from a range of representative publicly accessible vantage points and aesthetic resources and the preservation of existing vegetative buffers. The visual and architectural character of the Proposed Project, with special attention to the site lighting and off-site visibility of buildings and structures will be assessed. Assessment of impacts shall be based on the NYSDEC Program Policy document “Assessing and Mitigating Visual and Aesthetic Impacts” last revised December 13, 2019. ▪ GEOLOGY, SOILS, AND TOPOGRAPHY: This analysis will identify the major geologic and soil conditions within areas where construction of the Proposed Project and off-site improvements would occur, focusing on suitability of the property for development and stormwater management purposes, as applicable. The analysis will use information readily available from the United States Department of Agriculture’s Natural Resources Conservation Service (e.g., soil survey) as well as the geotechnical investigation of the Micron Campus to complete this chapter. Any soils classified as prime agricultural soils will be identified. The assessment will also include a slope map and discussion of proposed modifications to site topography including categories of 0-10%, 10-15%, 15-25% and 25% or greater. A summary of the geotechnical investigation and cut and fill analysis for the Micron Campus will also be included. ▪ WATER RESOURCES: This analysis will address the potential impacts to water resources present on the Project Site or in any area impacted by off-site improvements, including groundwater, streams and wetlands. Groundwater levels will be described from geotechnical investigations. Wetlands will be delineated using the three-part standard outlined in the 1987 U.S. Army Corps of Engineers delineation manual, with the boundaries verified through the Jurisdictional Determination process. New York State regulated wetlands will also be delineated pursuant to the standards set forth at Article 24 of the Environmental Conversation Law and NYSDEC’s freshwater wetlands regulations set forth at 6 NYCRR Part 663. Any water resources will be characterized and any potential adverse impacts to them will be assessed and potential mitigation identified. The DEIS will include an assessment of wetland functions and services. A physical and chemical characterization of Youngs Creek will be presented in the DEIS based on site reconnaissance. The Proposed Project’s location with respect to any floodplain would also be documented. A Stormwater Pollution Prevention Plan (SWPPP) prepared pursuant to the NYSDEC Stormwater Management Design Manual will be prepared for the Proposed Project and included as an appendix to the DEIS. Potential impacts of stormwater generated by the Proposed Project on streams and wetlands will be described in the DEIS. While specific impacts and mitigation measures are not known at this time, impacts to streams and wetlands from the Proposed Project are likely. Stream and wetland mitigation could include on-site or off-site stream or wetland creation, restoration, or enhancements approved by USACE and NYSDEC. The wetland delineation report and draft conceptual compensatory mitigation plan will be included as an appendix to the DEIS. ▪ ECOLOGICAL COMMUNITIES AND WILDLIFE: This analysis will address the potential impacts to ecological communities (terrestrial and aquatic) and wildlife. The U.S. Fish & Wildlife Service 12/14/2023 27 59 aesthetic character of the surrounding area. The analysis will identify and describe significant views into the existing WPCP from a range of representative publicly accessible vantage points and aesthetic resources and the preservation of existing vegetative buffers. The visual and architectural character of the Proposed Project, with special attention to the site lighting and off-site visibility of buildings and structures will be assessed. Assessment of impacts shall be based on the NYSDEC Program Policy document “Assessing and Mitigating Visual and Aesthetic Impacts” last revised December 13, 2019. ▪ GEOLOGY, SOILS, AND TOPOGRAPHY: This analysis will identify the major geologic and soil conditions within areas where construction of the Proposed Project and off-site improvements would occur, focusing on suitability of the property for development and stormwater management purposes, as applicable. The analysis will use information readily available from the United States Department of Agriculture’s Natural Resources Conservation Service (e.g., soil survey) as well as the geotechnical investigation of the Micron Campus to complete this chapter. Any soils classified as prime agricultural soils will be identified. The assessment will also include a slope map and discussion of proposed modifications to site topography including categories of 0-10%, 10-15%, 15-25% and 25% or greater. A summary of the geotechnical investigation and cut and fill analysis for the Micron Campus will also be included. ▪ WATER RESOURCES: This analysis will address the potential impacts to water resources present on the Project Site or in any area impacted by off-site improvements, including groundwater, streams and wetlands. Groundwater levels will be described from geotechnical investigations. Wetlands will be delineated using the three-part standard outlined in the 1987 U.S. Army Corps of Engineers delineation manual, with the boundaries verified through the Jurisdictional Determination process. New York State regulated wetlands will also be delineated pursuant to the standards set forth at Article 24 of the Environmental Conversation Law and NYSDEC’s freshwater wetlands regulations set forth at 6 NYCRR Part 663. Any water resources will be characterized and any potential adverse impacts to them will be assessed and potential mitigation identified. The DEIS will include an assessment of wetland functions and services. A physical and chemical characterization of Youngs Creek will be presented in the DEIS based on site reconnaissance. The Proposed Project’s location with respect to any floodplain would also be documented. A Stormwater Pollution Prevention Plan (SWPPP) prepared pursuant to the NYSDEC Stormwater Management Design Manual will be prepared for the Proposed Project and included as an appendix to the DEIS. Potential impacts of stormwater generated by the Proposed Project on streams and wetlands will be described in the DEIS. While specific impacts and mitigation measures are not known at this time, impacts to streams and wetlands from the Proposed Project are likely. Stream and wetland mitigation could include on-site or off-site stream or wetland creation, restoration, or enhancements approved by USACE and NYSDEC. The wetland delineation report and draft conceptual compensatory mitigation plan will be included as an appendix to the DEIS. ▪ ECOLOGICAL COMMUNITIES AND WILDLIFE: This analysis will address the potential impacts to ecological communities (terrestrial and aquatic) and wildlife. The U.S. Fish & Wildlife Service 12/14/2023 28 60 (USFWS) Information, Planning, and Consultation System (IPaC) and New York State Natural Heritage Program database will be queried for any known or potential threatened or endangered species within the study area, which includes the Project Site as well as any areas where off-site improvements would be constructed. This will include an assessment for the presence of, and potential impacts to, threatened and endangered species for all linear utility construction projects, new infrastructure, and the expansion of existing infrastructure (e.g., Oak Orchard Wastewater Treatment Plant and the Lake Ontario water filtration plant). Consultation with NYSDEC and USFWS to develop protocol for assessing presence of habitat for any identified species and protocol for assessing potential impacts to any identified species will be undertaken. Summaries of field studies will be included as an appendix to the DEIS. The DEIS will include characterization of wildlife within the Project Site based on literature review and field observations collected seasonally, including winter and migration seasons. Field studies will identify existing plant species that are invasive, non-native, or both invasive and non- native. Field studies will also include characterization of aquatic wildlife (biology) within Youngs Creek. Potential impacts to wildlife that will be considered in the DEIS include, but are not limited to, habitat fragmentation, noise, lighting, pollution, human activity and traffic. The DEIS will include a commitment to prepare and implement an invasive species management plan as a condition of site plan approval. ▪ SOLID WASTE: This analysis will describe the proposed generation of solid waste by the Proposed Project and how that material will be handled, stored, and transported. This analysis will describe Micron’s proposed measures to reduce generation of solid waste through reuse or recycling. This analysis will describe Onondaga County’s Solid Waste Management Plan and how the Proposed Project would comply. The analysis will consider the capacity of the existing waste management network and the ability to accept increased volumes generated by the Proposed Project as well as the anticipated population growth in the study area. Approximate timing of expansion of waste or recycling facilities, if needed, will be discussed. ▪ HAZARDOUS MATERIALS: The assessment of hazardous materials will include Phase I environmental site assessments compatible with American Society for Testing and Materials (ASTM) standards (E1527-21) to identify potential areas of concern within areas where construction of the Proposed Project would occur. All pertinent environmental databases will be reviewed for each off-site improvement area and site inspections will be conducted where feasible. Phase II environmental sampling would be conducted as needed and to the extent practicable. Any warranted remedial approaches for addressing identified or potential contaminated materials would be described. The chapter will identify any hazardous materials (including any chemical or petroleum bulk or other storage) that would be used, stored, transported, or generated by the Proposed Project and measures to protect against releases to the environment and impacts to human health, including worker safety. Hazardous wastes as identified in 6 NYCRR Part 371.4 that the Proposed Project may generate will be described, including the type of hazardous waste anticipated to be generated, estimated volumes, storage methods, disposal options, and how the facility will comply with hazardous waste 12/14/2023 28 60 (USFWS) Information, Planning, and Consultation System (IPaC) and New York State Natural Heritage Program database will be queried for any known or potential threatened or endangered species within the study area, which includes the Project Site as well as any areas where off-site improvements would be constructed. This will include an assessment for the presence of, and potential impacts to, threatened and endangered species for all linear utility construction projects, new infrastructure, and the expansion of existing infrastructure (e.g., Oak Orchard Wastewater Treatment Plant and the Lake Ontario water filtration plant). Consultation with NYSDEC and USFWS to develop protocol for assessing presence of habitat for any identified species and protocol for assessing potential impacts to any identified species will be undertaken. Summaries of field studies will be included as an appendix to the DEIS. The DEIS will include characterization of wildlife within the Project Site based on literature review and field observations collected seasonally, including winter and migration seasons. Field studies will identify existing plant species that are invasive, non-native, or both invasive and non- native. Field studies will also include characterization of aquatic wildlife (biology) within Youngs Creek. Potential impacts to wildlife that will be considered in the DEIS include, but are not limited to, habitat fragmentation, noise, lighting, pollution, human activity and traffic. The DEIS will include a commitment to prepare and implement an invasive species management plan as a condition of site plan approval. ▪ SOLID WASTE: This analysis will describe the proposed generation of solid waste by the Proposed Project and how that material will be handled, stored, and transported. This analysis will describe Micron’s proposed measures to reduce generation of solid waste through reuse or recycling. This analysis will describe Onondaga County’s Solid Waste Management Plan and how the Proposed Project would comply. The analysis will consider the capacity of the existing waste management network and the ability to accept increased volumes generated by the Proposed Project as well as the anticipated population growth in the study area. Approximate timing of expansion of waste or recycling facilities, if needed, will be discussed. ▪ HAZARDOUS MATERIALS: The assessment of hazardous materials will include Phase I environmental site assessments compatible with American Society for Testing and Materials (ASTM) standards (E1527-21) to identify potential areas of concern within areas where construction of the Proposed Project would occur. All pertinent environmental databases will be reviewed for each off-site improvement area and site inspections will be conducted where feasible. Phase II environmental sampling would be conducted as needed and to the extent practicable. Any warranted remedial approaches for addressing identified or potential contaminated materials would be described. The chapter will identify any hazardous materials (including any chemical or petroleum bulk or other storage) that would be used, stored, transported, or generated by the Proposed Project and measures to protect against releases to the environment and impacts to human health, including worker safety. Hazardous wastes as identified in 6 NYCRR Part 371.4 that the Proposed Project may generate will be described, including the type of hazardous waste anticipated to be generated, estimated volumes, storage methods, disposal options, and how the facility will comply with hazardous waste 12/14/2023 29 61 regulations at 6 NYCRR Part 370-373. Potential mitigation measures to be considered include an evaluation of methods to reduce generation of hazardous waste. ▪ TRANSPORTATION: Construction and operation of the Proposed Project can be expected to generate a substantial number of new vehicular trips on the local and regional highway network including local roads and I-81 and NYS Route 481. The DEIS will describe the existing transportation network, project conditions in the future with and without the Proposed Project and will assess potential impacts associated with the Proposed Project, such as changes to intersection and roadway capacity and Levels of Service as well as access to existing and anticipated uses along key highway corridors serving the Project Site. In consultation with NYSDOT, New York State Thruway Authority, and Onondaga County Department of Transportation, automatic traffic recorder (ATR), turning movement counts (TMC), and vehicle classification counts (VCC) will be conducted. See Appendix A for additional information on the locations of proposed traffic data collection. Analysis will consider the effects of Proposed Project operations and construction, including during times when both operations and construction overlap. The DEIS will also describe the site driveways, internal circulation roadways, and parking facilities that will be part of the Proposed Project and designed to accommodate peak employee demand and on-going construction activity. The regional travel demand model developed by the Syracuse Metropolitan Transportation Council (SMTC), the designated Metropolitan Planning Organization (MPO) for the area serving the Project Site, will be used to identify existing and projected travel patterns on area roadways throughout the region. A sub-area section of SMTC’s model will be used to provide the analysis foundation for a Visum transportation planning model to assign routing through the regional study area. Micro-simulation modeling of roadways and intersections within the study area will be conducted with either Vissim or Synchro traffic analysis modeling tools to analyze potential impacts of the Proposed Project in coordination with NYSDOT. Additional evaluations of existing crash patterns related to addressing safety, signal functionality, signing and striping, roadway lighting, and ITS systems will be completed to propose future improvements designed to increase safety and service in the area. While specific impacts and mitigation measures are not known at this time, impacts to area roadways due to additional traffic (during construction and during operations) from the Proposed Project are likely. Traffic mitigation may include improvements to area roadways or construction of new roadways. The DEIS will identify any proposed traffic improvements and a timetable for their implementation. The Transportation assessment will also include an identification of, and assessment of potential impacts from the Proposed Project and off-site improvements to, transit systems operating within Onondaga County as well as the CSX freight rail operations using the railroad line adjacent to the Micron Campus. ▪ AIR QUALITY: This analysis will assess mobile source and stationary source air emissions from the Proposed Project, including air emissions from operation of the fabs as well as the increased vehicular traffic on the local and regional roads and highways. The mobile source air quality analyses will be performed in accordance with the procedures found in the NYSDOT The 12/14/2023 29 61 regulations at 6 NYCRR Part 370-373. Potential mitigation measures to be considered include an evaluation of methods to reduce generation of hazardous waste. ▪ TRANSPORTATION: Construction and operation of the Proposed Project can be expected to generate a substantial number of new vehicular trips on the local and regional highway network including local roads and I-81 and NYS Route 481. The DEIS will describe the existing transportation network, project conditions in the future with and without the Proposed Project and will assess potential impacts associated with the Proposed Project, such as changes to intersection and roadway capacity and Levels of Service as well as access to existing and anticipated uses along key highway corridors serving the Project Site. In consultation with NYSDOT, New York State Thruway Authority, and Onondaga County Department of Transportation, automatic traffic recorder (ATR), turning movement counts (TMC), and vehicle classification counts (VCC) will be conducted. See Appendix A for additional information on the locations of proposed traffic data collection. Analysis will consider the effects of Proposed Project operations and construction, including during times when both operations and construction overlap. The DEIS will also describe the site driveways, internal circulation roadways, and parking facilities that will be part of the Proposed Project and designed to accommodate peak employee demand and on-going construction activity. The regional travel demand model developed by the Syracuse Metropolitan Transportation Council (SMTC), the designated Metropolitan Planning Organization (MPO) for the area serving the Project Site, will be used to identify existing and projected travel patterns on area roadways throughout the region. A sub-area section of SMTC’s model will be used to provide the analysis foundation for a Visum transportation planning model to assign routing through the regional study area. Micro-simulation modeling of roadways and intersections within the study area will be conducted with either Vissim or Synchro traffic analysis modeling tools to analyze potential impacts of the Proposed Project in coordination with NYSDOT. Additional evaluations of existing crash patterns related to addressing safety, signal functionality, signing and striping, roadway lighting, and ITS systems will be completed to propose future improvements designed to increase safety and service in the area. While specific impacts and mitigation measures are not known at this time, impacts to area roadways due to additional traffic (during construction and during operations) from the Proposed Project are likely. Traffic mitigation may include improvements to area roadways or construction of new roadways. The DEIS will identify any proposed traffic improvements and a timetable for their implementation. The Transportation assessment will also include an identification of, and assessment of potential impacts from the Proposed Project and off-site improvements to, transit systems operating within Onondaga County as well as the CSX freight rail operations using the railroad line adjacent to the Micron Campus. ▪ AIR QUALITY: This analysis will assess mobile source and stationary source air emissions from the Proposed Project, including air emissions from operation of the fabs as well as the increased vehicular traffic on the local and regional roads and highways. The mobile source air quality analyses will be performed in accordance with the procedures found in the NYSDOT The 12/14/2023 30 62 Environmental Manual (TEM), the USEPA guidance on project-level analyses, and the FHWA’s current guidance on Mobile Source Air Toxic (MSAT) analysis. Potential air quality effects associated with construction activities will also be assessed. Overall, transportation conformity is not applicable to projects in Onondaga County. Consistent with the Clean Air Act and the Final Transportation Conformity Rule, the assessment will determine whether any regional or localized impacts to air quality (beneficial or detrimental) will result from the Proposed Project, including whether the Proposed Project would cause or contribute to any new violation of any National Ambient Air Quality Standards (NAAQS) in any area or increase the frequency or severity of any existing violation of any NAAQS in any area, or delay timely attainment of any NAAQS or any required interim emission reductions or other milestones in any area. The Proposed Project will require a stationary source air pollution control permit for the new manufacturing facilities. The air pollution control permit application will include evaluation of pollutants subject to NAAQS, New York air toxic control and ambient air requirements, and a Climate Leadership and Community Protection Act (CLCPA) greenhouse gas evaluation. The DEIS will summarize these detailed air quality modeling and impact assessment analyses that will be prepared to support the air pollution control permitting process and address potential impacts to human health from project related air emissions. ▪ GREENHOUSE GAS AND CLIMATE CHANGE: This analysis will estimate greenhouse gas (GHG) emissions from embodied carbon (carbon embodied in building materials) and construction activities and will describe anticipated facility design features that will minimize energy consumption and GHG emissions. This analysis will use the Motor Vehicle Emission Simulator (MOVES). Following the rule of reason (Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews), MOVES can be used for calculation of mobile source GHG emissions as inputs are available from use in the NAAQS related analysis. The GHG assessment will also follow applicable standards or guidance from the New York State CLCPA. ▪ NOISE AND VIBRATION: The Proposed Project will have the potential to increase noise levels based on construction activities and operation of the proposed facility. The increase in vehicular traffic is also likely to result increase in noise levels both on- and off-site. Noise standards as available from applicable local, state, and federal will be reviewed and used to establish impact thresholds and criteria. Traffic noise measurement and modeling methodology will use the NYSDOT TEM, Section 4.4.18, “Noise Analysis Policy and Procedures” (or “NYSDOT Noise Policy”) and will use FHWA Traffic Noise Model (TNM) 2.5 to perform the traffic noise analyses. The assessment of potential noise impacts will also be conducted following the NYSDEC guidance document, “Assessing and Mitigating Noise Impacts” (DEP-00-1, Revised February 2, 2001). ▪ UTILITIES AND INFRASTRUCTURE: As noted in the Proposed Project description, there are substantial off-site infrastructure improvements that will be required to support the Proposed Project. The DEIS will identify and describe these required improvements and assess if the Proposed Project, with improvements (and acknowledging any measures that Micron can take to reduce 12/14/2023 30 62 Environmental Manual (TEM), the USEPA guidance on project-level analyses, and the FHWA’s current guidance on Mobile Source Air Toxic (MSAT) analysis. Potential air quality effects associated with construction activities will also be assessed. Overall, transportation conformity is not applicable to projects in Onondaga County. Consistent with the Clean Air Act and the Final Transportation Conformity Rule, the assessment will determine whether any regional or localized impacts to air quality (beneficial or detrimental) will result from the Proposed Project, including whether the Proposed Project would cause or contribute to any new violation of any National Ambient Air Quality Standards (NAAQS) in any area or increase the frequency or severity of any existing violation of any NAAQS in any area, or delay timely attainment of any NAAQS or any required interim emission reductions or other milestones in any area. The Proposed Project will require a stationary source air pollution control permit for the new manufacturing facilities. The air pollution control permit application will include evaluation of pollutants subject to NAAQS, New York air toxic control and ambient air requirements, and a Climate Leadership and Community Protection Act (CLCPA) greenhouse gas evaluation. The DEIS will summarize these detailed air quality modeling and impact assessment analyses that will be prepared to support the air pollution control permitting process and address potential impacts to human health from project related air emissions. ▪ GREENHOUSE GAS AND CLIMATE CHANGE: This analysis will estimate greenhouse gas (GHG) emissions from embodied carbon (carbon embodied in building materials) and construction activities and will describe anticipated facility design features that will minimize energy consumption and GHG emissions. This analysis will use the Motor Vehicle Emission Simulator (MOVES). Following the rule of reason (Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews), MOVES can be used for calculation of mobile source GHG emissions as inputs are available from use in the NAAQS related analysis. The GHG assessment will also follow applicable standards or guidance from the New York State CLCPA. ▪ NOISE AND VIBRATION: The Proposed Project will have the potential to increase noise levels based on construction activities and operation of the proposed facility. The increase in vehicular traffic is also likely to result increase in noise levels both on- and off-site. Noise standards as available from applicable local, state, and federal will be reviewed and used to establish impact thresholds and criteria. Traffic noise measurement and modeling methodology will use the NYSDOT TEM, Section 4.4.18, “Noise Analysis Policy and Procedures” (or “NYSDOT Noise Policy”) and will use FHWA Traffic Noise Model (TNM) 2.5 to perform the traffic noise analyses. The assessment of potential noise impacts will also be conducted following the NYSDEC guidance document, “Assessing and Mitigating Noise Impacts” (DEP-00-1, Revised February 2, 2001). ▪ UTILITIES AND INFRASTRUCTURE: As noted in the Proposed Project description, there are substantial off-site infrastructure improvements that will be required to support the Proposed Project. The DEIS will identify and describe these required improvements and assess if the Proposed Project, with improvements (and acknowledging any measures that Micron can take to reduce 12/14/2023 31 63 consumption of energy or water or generation of wastewater), has the potential to adversely affect the larger community in terms of potential impacts to water from operational usage, as well as sanitary sewer and industrial wastewater discharges. The analysis will also note connections to energy (electrical and natural gas) and telecommunications infrastructure, and capacity of those systems, as applicable. ▪ USE AND CONSERVATION OF ENERGY: This analysis will describe the Proposed Project’s use and conservation of energy and measures that Micron intends to pursue to reduce energy consumption and use of renewable sources. ▪ CONSTRUCTION IMPACTS: This analysis will address impacts arising from the primary construction activities for the Proposed Project and off-site improvements, such as construction traffic on surrounding streets, noise and vibration, air quality (e.g., emissions from construction equipment), effects on adjacent historic structures, dewatering activities, and any hazardous materials that may be disturbed by construction activities. This assessment will also qualitatively discuss potential impacts associated with noise, air quality, water quality, and traffic impacts from construction of the Proposed Project. ▪ CUMULATIVE IMPACTS: The DEIS will consider any significant adverse impacts resulting from the incremental impact of the Proposed Project when added to other past, present, and reasonably foreseeable future actions. This chapter will identify the other projects or actions included in the assessment and summarize the cumulative impacts of the Proposed Project contained in each of the technical areas of evaluation. ▪ UNAVOIDABLE ADVERSE IMPACTS: This chapter will identify any impacts that are unavoidable and that cannot be reasonably mitigated. ▪ GROWTH INDUCING ASPECTS OF THE PROPOSED PROJECT: This chapter will focus on whether the Proposed Project will have the potential to induce new development within the surrounding area, including, but not limited to, White Pine South, an approximately 105-acre parcel south of the Micron Campus and NYS Route 31. As noted, one of the purposes of the Proposed Project will be to create both direct and indirect employment opportunities in Central New York. The DEIS will evaluate the environmental impacts that arise from such economic enhancements and new development. ▪ IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES: This chapter will include a discussion of any irreversible or irretrievable commitments of resources. ▪ MITIGATION: This chapter will summarize any mitigation measures required to avoid, minimize or mitigate identified significant adverse effects. Mitigation measures will be described in detail in the technical analyses. While specific impacts and mitigation measures are not known at this time, impacts to wetlands and area roadways due to additional traffic (during construction and during operations) from the Proposed Project are likely. Wetland mitigation could include on-site or off-site wetland enhancements approved by USACE and NYSDEC. Traffic mitigation could include physical enhancements to area roadways, railways, and/or 12/14/2023 31 63 consumption of energy or water or generation of wastewater), has the potential to adversely affect the larger community in terms of potential impacts to water from operational usage, as well as sanitary sewer and industrial wastewater discharges. The analysis will also note connections to energy (electrical and natural gas) and telecommunications infrastructure, and capacity of those systems, as applicable. ▪ USE AND CONSERVATION OF ENERGY: This analysis will describe the Proposed Project’s use and conservation of energy and measures that Micron intends to pursue to reduce energy consumption and use of renewable sources. ▪ CONSTRUCTION IMPACTS: This analysis will address impacts arising from the primary construction activities for the Proposed Project and off-site improvements, such as construction traffic on surrounding streets, noise and vibration, air quality (e.g., emissions from construction equipment), effects on adjacent historic structures, dewatering activities, and any hazardous materials that may be disturbed by construction activities. This assessment will also qualitatively discuss potential impacts associated with noise, air quality, water quality, and traffic impacts from construction of the Proposed Project. ▪ CUMULATIVE IMPACTS: The DEIS will consider any significant adverse impacts resulting from the incremental impact of the Proposed Project when added to other past, present, and reasonably foreseeable future actions. This chapter will identify the other projects or actions included in the assessment and summarize the cumulative impacts of the Proposed Project contained in each of the technical areas of evaluation. ▪ UNAVOIDABLE ADVERSE IMPACTS: This chapter will identify any impacts that are unavoidable and that cannot be reasonably mitigated. ▪ GROWTH INDUCING ASPECTS OF THE PROPOSED PROJECT: This chapter will focus on whether the Proposed Project will have the potential to induce new development within the surrounding area, including, but not limited to, White Pine South, an approximately 105-acre parcel south of the Micron Campus and NYS Route 31. As noted, one of the purposes of the Proposed Project will be to create both direct and indirect employment opportunities in Central New York. The DEIS will evaluate the environmental impacts that arise from such economic enhancements and new development. ▪ IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES: This chapter will include a discussion of any irreversible or irretrievable commitments of resources. ▪ MITIGATION: This chapter will summarize any mitigation measures required to avoid, minimize or mitigate identified significant adverse effects. Mitigation measures will be described in detail in the technical analyses. While specific impacts and mitigation measures are not known at this time, impacts to wetlands and area roadways due to additional traffic (during construction and during operations) from the Proposed Project are likely. Wetland mitigation could include on-site or off-site wetland enhancements approved by USACE and NYSDEC. Traffic mitigation could include physical enhancements to area roadways, railways, and/or 12/14/2023 32 64 signal timing changes approved by the Federal Highway Administration (FHWA), NYSDOT or Onondaga County. 12/14/2023 33 65 12/14/2023 32 64 signal timing changes approved by the Federal Highway Administration (FHWA), NYSDOT or Onondaga County. 12/14/2023 33 65 6 Agency and Public Coordination Agency and public coordination are an integral component at all stages of planning and project development, including in this SEQRA scoping process. 6 Agency and Public Coordination Agency and public coordination are an integral component at all stages of planning and project development, including in this SEQRA scoping process. 6.1 AGENCY COORDINATION ACTIVITIES The agency coordination process will include coordination with various Federal, State, and local agencies (see Table 2, “Preliminary List of SEQRA Lead, Involved, and Interested Agencies” and Table 3, “Preliminary List of Federal Agencies”). OCIDA, as the lead agency for the Proposed Project, has coordinated with Micron to identify Involved and Interested Agencies to be informed and involved throughout the environmental review. An “Involved Agency” means “an agency that has jurisdiction by law to fund, approve or directly undertake an action. If an agency will ultimately make a discretionary decision to fund, approve or undertake an action, then it is an ‘involved agency’ notwithstanding that it has not received an application for funding or approval at the time the SEQR process is commenced. The lead agency is also an ‘involved agency’” (6 NYCRR 617.2(t)). An “Interested Agency” means “an agency that lacks the jurisdiction to fund, approve or directly undertake an action but wishes to participate in the review process because of its specific expertise or concern about the proposed action. An ‘interested agency’ has the same ability to participate in the review process as a member of the public” (6 NYCRR 617.2(u)). 12/14/2023 34 66 TABLE 2 PRELIMINARY LIST OF SEQRA LEAD, INVOLVED, AND INTERESTED AGENCIES 6.1 AGENCY COORDINATION ACTIVITIES The agency coordination process will include coordination with various Federal, State, and local agencies (see Table 2, “Preliminary List of SEQRA Lead, Involved, and Interested Agencies” and Table 3, “Preliminary List of Federal Agencies”). OCIDA, as the lead agency for the Proposed Project, has coordinated with Micron to identify Involved and Interested Agencies to be informed and involved throughout the environmental review. An “Involved Agency” means “an agency that has jurisdiction by law to fund, approve or directly undertake an action. If an agency will ultimately make a discretionary decision to fund, approve or undertake an action, then it is an ‘involved agency’ notwithstanding that it has not received an application for funding or approval at the time the SEQR process is commenced. The lead agency is also an ‘involved agency’” (6 NYCRR 617.2(t)). An “Interested Agency” means “an agency that lacks the jurisdiction to fund, approve or directly undertake an action but wishes to participate in the review process because of its specific expertise or concern about the proposed action. An ‘interested agency’ has the same ability to participate in the review process as a member of the public” (6 NYCRR 617.2(u)). 12/14/2023 34 66 TABLE 2 PRELIMINARY LIST OF SEQRA LEAD, INVOLVED, AND INTERESTED AGENCIES Agency Potential Role Responsibilities Lead Agency Onondaga County Industrial Lead Agency SEQRA leadership and coordination, establishing final Development Agency (State entitlement of White Pine Industrial Park and coordination of environmental review lead) land development agreements. Sale of OCIDA property to Micron. Potential property condemnation pursuant to New York Eminent Domain Procedure Law. Involved and Interested Agencies New York State Department of Involved Agency Title V air quality permitting, wetlands jurisdictional Environmental Conservation determination and permitting, consultation related to threatened & endangered species, SWPPP permits for on-site and off-site land disturbance, modification to existing SPDES discharge for Oak Orchard WWTP, Section 401 water quality certification, hazardous petroleum and chemical bulk storage, and SPDES Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity. New York State Empire State Involved Agency Approval of Excelsior Jobs Program Green Chips Project Development Application. New York State Office of Parks, Involved Agency Consultation related to potential impact to historic and Recreation and Historic Preservation cultural resources. OPRHP serves as the New York SHPO. (OPRHP) New York State Department of Involved Agency Consultation in traffic impact evaluation and mitigation Transportation measures to address adverse transportation impacts on state routes and interstate highways. Potential property condemnation pursuant to New York Eminent Domain Procedure Law. Syracuse Metropolitan Transportation Interested Agency General consultation and approval actions to add to official Council (SMTC) regional transportation plans. Onondaga County Department of Interested Agency General consultation. Planning Onondaga County Dept. of Involved Agency Consultation in traffic impact evaluation and mitigation on Transportation (OCDOT) county routes. Potential property condemnation pursuant to New York Eminent Domain Procedure Law. Town of Clay Planning Board Involved Agency Site Plan/Subdivision (re-subdivision of multiple parcels) approvals including MS4/SWPPP approval. Town of Cicero Town Board Interested Agency Referral per General Municipal Law. Town of Cicero Planning Board Involved Agency Subdivision Approval. City of Syracuse Interested Agency General consultation. New York Power Authority Involved Agency Proving high-load factor energy allocation and ReCharge expansion energy allocation. New York State Energy Research Interested Agency Collaborating on Excelsior Jobs Program Green Chips Project Development Authority Application.. Onondaga County Department of Involved Agency Enlarging wastewater treatment capacity and extending Water Environment Protection sewer lines to the Micron Campus; Modification of OCDWEP’s SPDES Permit by NYSDEC; issuance of an Industrial Wastewater Discharge Permit from OCDWEP to Micron Campus. Onondaga County Water Authority Involved Agency Extending potable water lines to the Micron Campus. Agency Potential Role Responsibilities Lead Agency Onondaga County Industrial Lead Agency SEQRA leadership and coordination, establishing final Development Agency (State entitlement of White Pine Industrial Park and coordination of environmental review lead) land development agreements. Sale of OCIDA property to Micron. Potential property condemnation pursuant to New York Eminent Domain Procedure Law. Involved and Interested Agencies New York State Department of Involved Agency Title V air quality permitting, wetlands jurisdictional Environmental Conservation determination and permitting, consultation related to threatened & endangered species, SWPPP permits for on-site and off-site land disturbance, modification to existing SPDES discharge for Oak Orchard WWTP, Section 401 water quality certification, hazardous petroleum and chemical bulk storage, and SPDES Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity. New York State Empire State Involved Agency Approval of Excelsior Jobs Program Green Chips Project Development Application. New York State Office of Parks, Involved Agency Consultation related to potential impact to historic and Recreation and Historic Preservation cultural resources. OPRHP serves as the New York SHPO. (OPRHP) New York State Department of Involved Agency Consultation in traffic impact evaluation and mitigation Transportation measures to address adverse transportation impacts on state routes and interstate highways. Potential property condemnation pursuant to New York Eminent Domain Procedure Law. Syracuse Metropolitan Transportation Interested Agency General consultation and approval actions to add to official Council (SMTC) regional transportation plans. Onondaga County Department of Interested Agency General consultation. Planning Onondaga County Dept. of Involved Agency Consultation in traffic impact evaluation and mitigation on Transportation (OCDOT) county routes. Potential property condemnation pursuant to New York Eminent Domain Procedure Law. Town of Clay Planning Board Involved Agency Site Plan/Subdivision (re-subdivision of multiple parcels) approvals including MS4/SWPPP approval. Town of Cicero Town Board Interested Agency Referral per General Municipal Law. Town of Cicero Planning Board Involved Agency Subdivision Approval. City of Syracuse Interested Agency General consultation. New York Power Authority Involved Agency Proving high-load factor energy allocation and ReCharge expansion energy allocation. New York State Energy Research Interested Agency Collaborating on Excelsior Jobs Program Green Chips Project Development Authority Application.. Onondaga County Department of Involved Agency Enlarging wastewater treatment capacity and extending Water Environment Protection sewer lines to the Micron Campus; Modification of OCDWEP’s SPDES Permit by NYSDEC; issuance of an Industrial Wastewater Discharge Permit from OCDWEP to Micron Campus. Onondaga County Water Authority Involved Agency Extending potable water lines to the Micron Campus. 12/14/2023 35 67 12/14/2023 35 67 TABLE 3 PRELIMINARY LIST OF FEDERAL AGENCIES Federal Agencies US Dept. of Commerce Approval of CHIPS Act funding application. US Army Corps of Engineers (USACE) Issue 404 Wetlands permit. Federal Highway Administration Consultation on the need and design of alterations to the national highway system and the interstate highway system to mitigate identified adverse traffic impacts. U.S. Environmental Protection Agency NEPA advisory role (i.e., Environmental Justice) and consultation related to the issuance of federally-delegated Clean Air Act and Clean Water Act permits to be issued by New York State Department of Environmental Conservation. U.S. Department of Interior, Office of Environmental Policy and Consultation related to Section 4(f) of the U.S. Dept. of Compliance Transportation Act. U.S. Fish & Wildlife Service Consultation on federal Endangered Species Act compliance. TABLE 3 PRELIMINARY LIST OF FEDERAL AGENCIES Federal Agencies US Dept. of Commerce Approval of CHIPS Act funding application. US Army Corps of Engineers (USACE) Issue 404 Wetlands permit. Federal Highway Administration Consultation on the need and design of alterations to the national highway system and the interstate highway system to mitigate identified adverse traffic impacts. U.S. Environmental Protection Agency NEPA advisory role (i.e., Environmental Justice) and consultation related to the issuance of federally-delegated Clean Air Act and Clean Water Act permits to be issued by New York State Department of Environmental Conservation. U.S. Department of Interior, Office of Environmental Policy and Consultation related to Section 4(f) of the U.S. Dept. of Compliance Transportation Act. U.S. Fish & Wildlife Service Consultation on federal Endangered Species Act compliance. 12/14/2023 36 68 Appendix A TRAFFIC STUDY AREA It is expected that traffic due to the Proposed Project, which includes construction workers, Micron employees, and community jobs induced by the Proposed Project, will be distributed throughout Onondaga County and beyond. The DEIS will focus on the immediate area around the Proposed Project and will examine potentially impacted traffic areas through regional, highway, and local analyses. The regional analysis will focus on the broader transportation network links within a roughly 30-minute driving commute of the proposed Micron Campus because this is the area that is expected to experience the largest increases in traffic volume. Within this area, all major highways in the greater Syracuse area are represented, and it is expected that trips coming from a greater distance to the Micron Campus, including from the City of Syracuse would be captured along these major access roadways. Additionally, the area allows other major projects in the area, such as the modifications to Interstate 81 (I-81) to be considered in the analysis. The highway and local analyses will focus on the major highways, interstates, and intersections within a five-mile radius of the proposed Micron Campus. A 5-mile radius was chosen as this captures the locations most likely to be impacted by the Proposed Project. 12/14/2023 36 68 Appendix A TRAFFIC STUDY AREA It is expected that traffic due to the Proposed Project, which includes construction workers, Micron employees, and community jobs induced by the Proposed Project, will be distributed throughout Onondaga County and beyond. The DEIS will focus on the immediate area around the Proposed Project and will examine potentially impacted traffic areas through regional, highway, and local analyses. The regional analysis will focus on the broader transportation network links within a roughly 30-minute driving commute of the proposed Micron Campus because this is the area that is expected to experience the largest increases in traffic volume. Within this area, all major highways in the greater Syracuse area are represented, and it is expected that trips coming from a greater distance to the Micron Campus, including from the City of Syracuse would be captured along these major access roadways. Additionally, the area allows other major projects in the area, such as the modifications to Interstate 81 (I-81) to be considered in the analysis. The highway and local analyses will focus on the major highways, interstates, and intersections within a five-mile radius of the proposed Micron Campus. A 5-mile radius was chosen as this captures the locations most likely to be impacted by the Proposed Project. The analyzed highway area includes sections of New York State Route 481/Interstate 481 (NY 481/I- 481) and I-81. The analyzed local area will include 42 intersections along NY 31, United States Route 11 (US 11), Caughdenoy Road, Verplank Road, and other local streets. The study area extents of the regional, highway and local study areas described above are shown in Figure A-1. 12/14/2023 37 69 The analyzed highway area includes sections of New York State Route 481/Interstate 481 (NY 481/I- 481) and I-81. The analyzed local area will include 42 intersections along NY 31, United States Route 11 (US 11), Caughdenoy Road, Verplank Road, and other local streets. The study area extents of the regional, highway and local study areas described above are shown in Figure A-1. 12/14/2023 37 69 FIGURE A-1 TRAFFIC STUDY AREA 12/14/2023 38 70 FIGURE A-1 TRAFFIC STUDY AREA 12/14/2023 38 70 AUTOMATIC TRAFFIC RECORDER (ATR) COUNTS Continuous 24-hour, two-way Automatic Traffic Recorder (ATR) counts will be collected at 190 locations within the New York State Department of Transportation (NYSDOT) jurisdiction, collected at 65 locations within the Onondaga County Department of Transportation (OCDOT), and collected at 36 locations within the New York State Thruway Authority (NYSTA) jurisdiction, each for a total of 7 days. The ATR counts will be collected by a third-party vendor using traffic data collection cameras or pneumatic tubes. ATR volume data summaries will be summarized in 15- minute intervals by location. The proposed ATR count locations, for each jurisdiction, are shown in Figure A-2. AUTOMATIC TRAFFIC RECORDER (ATR) COUNTS Continuous 24-hour, two-way Automatic Traffic Recorder (ATR) counts will be collected at 190 locations within the New York State Department of Transportation (NYSDOT) jurisdiction, collected at 65 locations within the Onondaga County Department of Transportation (OCDOT), and collected at 36 locations within the New York State Thruway Authority (NYSTA) jurisdiction, each for a total of 7 days. The ATR counts will be collected by a third-party vendor using traffic data collection cameras or pneumatic tubes. ATR volume data summaries will be summarized in 15- minute intervals by location. The proposed ATR count locations, for each jurisdiction, are shown in Figure A-2. TURNING MOVEMENT COUNTS (TMC) Turning Movement Counts (TMCs) will be collected at 25 signalized and 7 unsignalized intersections within the NYSDOT jurisdiction and at 3 signalized and 6 unsignalized intersections within the OCDOT jurisdiction. A high-resolution video technology will be used to record vehicle classification TMC counts and crosswalk pedestrian volumes for two 5-hour time periods. The classified TMC counts will be compiled on two representative mid-weekdays (Tuesday, Wednesday, or Thursday) during the ATR count period nearest their location. The time periods chosen for reduction will be subject to the ATR results but is currently anticipated to be 5AM to 10AM and 3PM to 8PM. The number of conflicting pedestrians and bicyclists will be counted simultaneously with vehicle turning movement counts. Traffic recorded in the TMCs will be sorted into four classifications: Autos, Buses (including non-articulated buses, articulated buses and jitneys), Medium Trucks, and Heavy Trucks. The proposed TMC count locations are provided in Figure A-3. TURNING MOVEMENT COUNTS (TMC) Turning Movement Counts (TMCs) will be collected at 25 signalized and 7 unsignalized intersections within the NYSDOT jurisdiction and at 3 signalized and 6 unsignalized intersections within the OCDOT jurisdiction. A high-resolution video technology will be used to record vehicle classification TMC counts and crosswalk pedestrian volumes for two 5-hour time periods. The classified TMC counts will be compiled on two representative mid-weekdays (Tuesday, Wednesday, or Thursday) during the ATR count period nearest their location. The time periods chosen for reduction will be subject to the ATR results but is currently anticipated to be 5AM to 10AM and 3PM to 8PM. The number of conflicting pedestrians and bicyclists will be counted simultaneously with vehicle turning movement counts. Traffic recorded in the TMCs will be sorted into four classifications: Autos, Buses (including non-articulated buses, articulated buses and jitneys), Medium Trucks, and Heavy Trucks. The proposed TMC count locations are provided in Figure A-3. VEHICLE CLASSIFICATION COUNTS (VCC) 29 ATR locations have been identified within the NYSDOT jurisdiction and 4 ATR locations have been identified within the NYSTA jurisdiction for Vehicle Classification Counts (VCCs). VCC shall be collected to provide detailed vehicle classification data over a 24-hour period during one of the three representative mid- weekdays (Tuesday, Wednesday, or Thursday). The VCC volume data summary will be summarized by location in 15-minute intervals. Traffic recorded for the VCCs will be sorted into four vehicle classifications: Autos, Buses (which would include non-articulated buses, articulated buses and jitneys), Medium Trucks, and Heavy Trucks. The proposed VCC ATR count locations are provided in Figure A-4. 12/14/2023 39 71 VEHICLE CLASSIFICATION COUNTS (VCC) 29 ATR locations have been identified within the NYSDOT jurisdiction and 4 ATR locations have been identified within the NYSTA jurisdiction for Vehicle Classification Counts (VCCs). VCC shall be collected to provide detailed vehicle classification data over a 24-hour period during one of the three representative mid- weekdays (Tuesday, Wednesday, or Thursday). The VCC volume data summary will be summarized by location in 15-minute intervals. Traffic recorded for the VCCs will be sorted into four vehicle classifications: Autos, Buses (which would include non-articulated buses, articulated buses and jitneys), Medium Trucks, and Heavy Trucks. The proposed VCC ATR count locations are provided in Figure A-4. 12/14/2023 39 71 FIGURE A-2 AUTOMATIC TRAFFIC RECORDER LOCATIONS 12/14/2023 40 72 FIGURE A-2 AUTOMATIC TRAFFIC RECORDER LOCATIONS 12/14/2023 40 72 FIGURE A-3 TURNING MOVEMENT COUNT LOCATIONS 12/14/2023 41 73 FIGURE A-3 TURNING MOVEMENT COUNT LOCATIONS 12/14/2023 41 73 FIGURE A-4 VEHICLE CLASSIFICATION COUNT LOCATIONS 12/14/2023 42 74 FIGURE A-4 VEHICLE CLASSIFICATION COUNT LOCATIONS 12/14/2023 42 74 MICRON SEMICONDUCTOR FABRICATION CLAY, NY MICRON SEMICONDUCTOR FABRICATION CLAY, NY APPENDIX B: RESPONSE TO COMMENTS December 14, 2023 75 Contents A. Introduction ....................................................................................................... 3 B. Commenters on SEQRA Scope of Work................................................................. 4 AGENCY COMMENTS ......................................................................................................................... 4 ORAL TESTIMONY AT PUBLIC SCOPING MEETING ............................................................................ 4 WRITTEN PUBLIC COMMENTS.......................................................................................................... 4 C. Response to Agency Comments .............................................................................6 NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION (NYSDEC) ............................. 6 UNITED STATES FISH & WILDLIFE SERVICES (USFWS).......................................................................... 14 ONONDAGA COUNTY LEGISLATOR GARLAND .................................................................................... 16 TOWN OF CLAY .....................................................................................................................................17 APPENDIX B: RESPONSE TO COMMENTS December 14, 2023 75 Contents A. Introduction ....................................................................................................... 3 B. Commenters on SEQRA Scope of Work................................................................. 4 AGENCY COMMENTS ......................................................................................................................... 4 ORAL TESTIMONY AT PUBLIC SCOPING MEETING ............................................................................ 4 WRITTEN PUBLIC COMMENTS.......................................................................................................... 4 C. Response to Agency Comments .............................................................................6 NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION (NYSDEC) ............................. 6 UNITED STATES FISH & WILDLIFE SERVICES (USFWS).......................................................................... 14 ONONDAGA COUNTY LEGISLATOR GARLAND .................................................................................... 16 TOWN OF CLAY .....................................................................................................................................17 D. Response to Public Comments ............................................................................. 17 PURPOSE AND NEED.............................................................................................................................17 PROJECT ALTERNATIVES AND DESCRIPTION OF THE PROPOSED PROJECT ........................................ 18 LAND USE, ZONING, & PUBLIC POLICY ................................................................................................ 18 COMMUNITY FACILITIES, OPEN SPACE & RECREATION ....................................................................... 18 SOCIOECONOMIC CONDITIONS ........................................................................................................... 19 ENVIRONMENTAL JUSTICE................................................................................................................... 20 HISTORIC AND CULTURAL RESOURCES ............................................................................................... 21 VISUAL IMPACTS & COMMUNITY CHARACTER ..................................................................................... 21 GEOLOGY, SOILS, & TOPOGRAPHY ..................................................................................................... 21 WATER RESOURCES ............................................................................................................................. 22 ECOLOGICAL COMMUNITIES AND WILDLIFE........................................................................................ 23 SOLID WASTE ....................................................................................................................................... 23 HAZARDOUS MATERIALS & HAZARDOUS WASTE ............................................................................... 23 TRANSPORTATION............................................................................................................................... 24 AIR QUALITY......................................................................................................................................... 25 GREENHOUSE GAS EMISSIONS AND CLIMATE CHANGE...................................................................... 26 NOISE & VIBRATION ............................................................................................................................. 27 UTILITIES AND INFRASTRUCTURE ........................................................................................................ 27 ANTICIPATED USE & CONSERVATION OF ENERGY ............................................................................... 28 CONSTRUCTION ................................................................................................................................... 29 PERMITS ............................................................................................................................................... 30 CUMULATIVE IMPACTS ........................................................................................................................ 30 GROWTH INDUCING ASPECTS ............................................................................................................. 30 OTHER .................................................................................................................................................. 31 D. Response to Public Comments ............................................................................. 17 PURPOSE AND NEED.............................................................................................................................17 PROJECT ALTERNATIVES AND DESCRIPTION OF THE PROPOSED PROJECT ........................................ 18 LAND USE, ZONING, & PUBLIC POLICY ................................................................................................ 18 COMMUNITY FACILITIES, OPEN SPACE & RECREATION ....................................................................... 18 SOCIOECONOMIC CONDITIONS ........................................................................................................... 19 ENVIRONMENTAL JUSTICE................................................................................................................... 20 HISTORIC AND CULTURAL RESOURCES ............................................................................................... 21 VISUAL IMPACTS & COMMUNITY CHARACTER ..................................................................................... 21 GEOLOGY, SOILS, & TOPOGRAPHY ..................................................................................................... 21 WATER RESOURCES ............................................................................................................................. 22 ECOLOGICAL COMMUNITIES AND WILDLIFE........................................................................................ 23 SOLID WASTE ....................................................................................................................................... 23 HAZARDOUS MATERIALS & HAZARDOUS WASTE ............................................................................... 23 TRANSPORTATION............................................................................................................................... 24 AIR QUALITY......................................................................................................................................... 25 GREENHOUSE GAS EMISSIONS AND CLIMATE CHANGE...................................................................... 26 NOISE & VIBRATION ............................................................................................................................. 27 UTILITIES AND INFRASTRUCTURE ........................................................................................................ 27 ANTICIPATED USE & CONSERVATION OF ENERGY ............................................................................... 28 CONSTRUCTION ................................................................................................................................... 29 PERMITS ............................................................................................................................................... 30 CUMULATIVE IMPACTS ........................................................................................................................ 30 GROWTH INDUCING ASPECTS ............................................................................................................. 30 OTHER .................................................................................................................................................. 31 12/14/23 ii 76 A. Introduction Micron New York Semiconductor Manufacturing LLC (Micron), a Delaware limited liability company (LLC) and wholly owned subsidiary of Micron Technology, Inc., is proposing to construct a semiconductor manufacturing campus (the “Micron Campus”) in the Town of Clay, New York, at the White Pine Commerce Park (WPCP), an approximately 1,400-acre industrial park controlled by the Onondaga County Industrial Development Agency (OCIDA). The Micron Campus, together with ancillary development on nearby properties, are referred to collectively as the “Proposed Project.” Off-site energy (natural gas and electricity), telecommunications, water, and wastewater utility improvements also will be required and are referred to as “off-site improvements” necessary for the Proposed Project. Rail spur improvements adjacent to the site are also considered off-site improvements. 12/14/23 ii 76 A. Introduction Micron New York Semiconductor Manufacturing LLC (Micron), a Delaware limited liability company (LLC) and wholly owned subsidiary of Micron Technology, Inc., is proposing to construct a semiconductor manufacturing campus (the “Micron Campus”) in the Town of Clay, New York, at the White Pine Commerce Park (WPCP), an approximately 1,400-acre industrial park controlled by the Onondaga County Industrial Development Agency (OCIDA). The Micron Campus, together with ancillary development on nearby properties, are referred to collectively as the “Proposed Project.” Off-site energy (natural gas and electricity), telecommunications, water, and wastewater utility improvements also will be required and are referred to as “off-site improvements” necessary for the Proposed Project. Rail spur improvements adjacent to the site are also considered off-site improvements. After receipt of an Application for Financial Assistance from Micron, OCIDA circulated a notice of intent to serve as State Environmental Quality Review Act (SEQRA) (6 NYCRR Part 617) (New York Environmental Conservation Law §§8-0101 et seq.) Lead Agency on July 28, 2023. No objections to that notice were received during the 30-day period commencing on that date. At its regular meeting of September 14, 2023, OCIDA issued a Positive Declaration, indicating the need for an Environmental Impact Statement (EIS), and scheduled a public scoping meeting held on October 11, 2023. The Positive Declaration and notice of public scoping meeting was published in the Environmental Notice Bulletin on September 20, 2023. Notice of the public scoping meeting was placed in The Post Standard (Syracuse.com) – a newspaper of general circulation serving the broader Clay, New York area. Project information and a Draft SEQRA Scope were posted on OCIDA’s website (www.ongoved.com). This document is an addendum to the Final SEQRA Scope. It identifies comments received through a public scoping process that ran from September 20, 2023, through October 31, 2023, including an in- person scoping meeting on October 11, 2023, at North Syracuse Junior High School. Additional information on the Proposed Project and off-site improvements is contained in the Final SEQRA Scope. After receipt of an Application for Financial Assistance from Micron, OCIDA circulated a notice of intent to serve as State Environmental Quality Review Act (SEQRA) (6 NYCRR Part 617) (New York Environmental Conservation Law §§8-0101 et seq.) Lead Agency on July 28, 2023. No objections to that notice were received during the 30-day period commencing on that date. At its regular meeting of September 14, 2023, OCIDA issued a Positive Declaration, indicating the need for an Environmental Impact Statement (EIS), and scheduled a public scoping meeting held on October 11, 2023. The Positive Declaration and notice of public scoping meeting was published in the Environmental Notice Bulletin on September 20, 2023. Notice of the public scoping meeting was placed in The Post Standard (Syracuse.com) – a newspaper of general circulation serving the broader Clay, New York area. Project information and a Draft SEQRA Scope were posted on OCIDA’s website (www.ongoved.com). This document is an addendum to the Final SEQRA Scope. It identifies comments received through a public scoping process that ran from September 20, 2023, through October 31, 2023, including an in- person scoping meeting on October 11, 2023, at North Syracuse Junior High School. Additional information on the Proposed Project and off-site improvements is contained in the Final SEQRA Scope. 12/14/23 3 77 B. Commenters on SEQRA Scope of Work Individuals, elected officials, agencies, and organizations (“commenters”) were able to submit comments during the SEQRA scoping process in a variety of ways:  Oral testimony was received during a public scoping meeting on October 11, 2023; and  Written comments were received via mail and e-mail through October 31, 2023. The list below identifies all commenters who submitted comments during the comment period. In some instances, commenters used more than one method for submitting comments. All comment submittals (written and oral) were reviewed and substantive comments were allocated to comment categories. This document provides responses by comment category. When multiple commenters submitted similar comments, the similar comments were paraphrased and summarized in the respective comment categories, with effort taken to retain the substance and tone of the comments received. Each comment response includes a numbered cross-reference to the corresponding comment submittal(s). Attachment 1 is the full transcript of the public scoping meeting. Attachment 2 contains all written comments received during the public comment period. 12/14/23 3 77 B. Commenters on SEQRA Scope of Work Individuals, elected officials, agencies, and organizations (“commenters”) were able to submit comments during the SEQRA scoping process in a variety of ways:  Oral testimony was received during a public scoping meeting on October 11, 2023; and  Written comments were received via mail and e-mail through October 31, 2023. The list below identifies all commenters who submitted comments during the comment period. In some instances, commenters used more than one method for submitting comments. All comment submittals (written and oral) were reviewed and substantive comments were allocated to comment categories. This document provides responses by comment category. When multiple commenters submitted similar comments, the similar comments were paraphrased and summarized in the respective comment categories, with effort taken to retain the substance and tone of the comments received. Each comment response includes a numbered cross-reference to the corresponding comment submittal(s). Attachment 1 is the full transcript of the public scoping meeting. Attachment 2 contains all written comments received during the public comment period. AGENCY COMMENTS A. New York State Department of Environmental Conservation (NYSDEC) Region 7 B. United States Fish & Wildlife (USFWS) C. Onondaga County Legislator Charles Garland D. Town of Clay Supervisor Damien Ulatowski AGENCY COMMENTS A. New York State Department of Environmental Conservation (NYSDEC) Region 7 B. United States Fish & Wildlife (USFWS) C. Onondaga County Legislator Charles Garland D. Town of Clay Supervisor Damien Ulatowski ORAL TESTIMONY AT PUBLIC SCOPING MEETING 1. Frank Sciortino 2. Jay Riordan | Cicero Democratic Committee and candidate for Town Council 3. Donald Hughes | Sierra Club 4. John Przepiora | Greening USA, Inc. 5. Mary Scanlon 6. Diana Elliott 7. Jim Nistico 8. Denise Androvette | Sierra Club member 9. Debra DeSocio | Sierra Club member 10. Peter Wirth | Climate Change Awareness and Action 11. Brian Heffron ORAL TESTIMONY AT PUBLIC SCOPING MEETING 1. Frank Sciortino 2. Jay Riordan | Cicero Democratic Committee and candidate for Town Council 3. Donald Hughes | Sierra Club 4. John Przepiora | Greening USA, Inc. 5. Mary Scanlon 6. Diana Elliott 7. Jim Nistico 8. Denise Androvette | Sierra Club member 9. Debra DeSocio | Sierra Club member 10. Peter Wirth | Climate Change Awareness and Action 11. Brian Heffron WRITTEN PUBLIC COMMENTS 12. Frank Sciortino 12/14/23 4 78 13. Debra DeSocio | Central and Northern NY Sierra Club 14. Steve Erwin | Trucking Association of New York 15. Nathan Gunn 16. Minchin G Lewis 17. Audrey Fletcher 18. Paul Goldsman 19. Onondaga Audubon 20. Peter Wirth 21. Jill Shultz 22. Mary Lou Bender 23. Craig Polhamus 24. Richard Ellenbogen | Allied Converters, Inc. 25. Roger Caiazza 26. Michelle Fanelli 27. Brian Cocca 28. Center for Public Environmental Oversight 29. Sara Pieklik 30. CNY Sustainability Coalition 31. Sierra Club 32. Michael Wolfson 33. Frank Fowler 34. Jim Baker 35. Steve Strauss | Empire State Passengers Association1 1 Although this comment was received late, it was still considered by OCIDA and addressed in this Response to Comments. 12/14/23 5 79 C. Response to Agency Comments WRITTEN PUBLIC COMMENTS 12. Frank Sciortino 12/14/23 4 78 13. Debra DeSocio | Central and Northern NY Sierra Club 14. Steve Erwin | Trucking Association of New York 15. Nathan Gunn 16. Minchin G Lewis 17. Audrey Fletcher 18. Paul Goldsman 19. Onondaga Audubon 20. Peter Wirth 21. Jill Shultz 22. Mary Lou Bender 23. Craig Polhamus 24. Richard Ellenbogen | Allied Converters, Inc. 25. Roger Caiazza 26. Michelle Fanelli 27. Brian Cocca 28. Center for Public Environmental Oversight 29. Sara Pieklik 30. CNY Sustainability Coalition 31. Sierra Club 32. Michael Wolfson 33. Frank Fowler 34. Jim Baker 35. Steve Strauss | Empire State Passengers Association1 1 Although this comment was received late, it was still considered by OCIDA and addressed in this Response to Comments. 12/14/23 5 79 C. Response to Agency Comments New York State Department of Environmental Conservation (NYSDEC) NYSDEC Comment 1: The DEIS should include a separate chapter addressing stormwater management which should include an evaluation of stormwater runoff (industrial and construction) and water quality. This section should identify the current requirements of NYSDEC’ s State Pollutant Discharge Elimination System (SPDES) Permits, including the Construction General Permit (GP-0-20- 001) and Multi-Sector General Permit (GP-0-23-001), and also evaluate how these requirements will be met. Sufficient information should be developed to identify the approximate size and location of necessary stormwater management measures and outfalls during and after construction. Response: Although stormwater impacts and management will be evaluated in the DEIS, it will not be in a separate chapter but will be included in the water resources chapter as part of the assessment of the Proposed Project’s impact on surface waters. The Scope indicates that a Stormwater Pollution Prevention Plan (SWPPP) will be prepared for the Proposed Project and described in the DEIS (it will also be included as an appendix). New York State Department of Environmental Conservation (NYSDEC) NYSDEC Comment 1: The DEIS should include a separate chapter addressing stormwater management which should include an evaluation of stormwater runoff (industrial and construction) and water quality. This section should identify the current requirements of NYSDEC’ s State Pollutant Discharge Elimination System (SPDES) Permits, including the Construction General Permit (GP-0-20- 001) and Multi-Sector General Permit (GP-0-23-001), and also evaluate how these requirements will be met. Sufficient information should be developed to identify the approximate size and location of necessary stormwater management measures and outfalls during and after construction. Response: Although stormwater impacts and management will be evaluated in the DEIS, it will not be in a separate chapter but will be included in the water resources chapter as part of the assessment of the Proposed Project’s impact on surface waters. The Scope indicates that a Stormwater Pollution Prevention Plan (SWPPP) will be prepared for the Proposed Project and described in the DEIS (it will also be included as an appendix). NYSDEC Comment 2: Due to the scale of the project and the anticipated need to have large areas of soil exposed at any given time, the DEIS should evaluate the soil characteristics that may cause or contribute to erosion on site. A reference should be developed to identify any supporting information or reports that will be included as an appendix. The Stormwater Pollution Prevention Plan (SWPPP) needs to address hydraulic changes pre- and post-construction, and all changes to hydrology from filling in any wetlands, streams, and drainage ways on site. It is important to note that while NYSDEC’s Region 7 Division of Water and the Town of Clay will jointly evaluate the required SWPPP prepared by the Applicant, responsibility for the approval of the SWPPP lies with the Town of Clay as per the municipal separate stormwater sewer systems (MS4) General Permit (currently GP 0-15-003). Response: The SWPPP will be prepared pursuant to the New York State Stormwater Management Design Manual (SMDM) and included in Micron’s site plan application to the Town of Clay. Any soil characteristics that may cause or contribute to erosion will be identified in the SWPPP. Measures to protect against erosion during construction will also be identified in the SWPPP. NYSDEC Comment 2: Due to the scale of the project and the anticipated need to have large areas of soil exposed at any given time, the DEIS should evaluate the soil characteristics that may cause or contribute to erosion on site. A reference should be developed to identify any supporting information or reports that will be included as an appendix. The Stormwater Pollution Prevention Plan (SWPPP) needs to address hydraulic changes pre- and post-construction, and all changes to hydrology from filling in any wetlands, streams, and drainage ways on site. It is important to note that while NYSDEC’s Region 7 Division of Water and the Town of Clay will jointly evaluate the required SWPPP prepared by the Applicant, responsibility for the approval of the SWPPP lies with the Town of Clay as per the municipal separate stormwater sewer systems (MS4) General Permit (currently GP 0-15-003). Response: The SWPPP will be prepared pursuant to the New York State Stormwater Management Design Manual (SMDM) and included in Micron’s site plan application to the Town of Clay. Any soil characteristics that may cause or contribute to erosion will be identified in the SWPPP. Measures to protect against erosion during construction will also be identified in the SWPPP. NYSDEC Comment 3: Stormwater management should pay particular attention to Chapter 3 of the New York State Stormwater Management Design Manual (SMDM) and its focus on Stormwater Management Planning. The SMDM requires a specific planning process when addressing stormwater management on a project site and guides the planner through steps to maintain pre-development natural hydrologic conditions of the site by application of environmentally sound development principles, such as green infrastructure, as well as treatment and control of runoff discharges from the site. Response: Comment noted. 12/14/23 6 80 NYSDEC Comment 4: Identify additional potential development alternatives considering design and configuration changes to avoid or minimize potential impacts to wetlands, streams, and other sensitive natural resources. The area east of Burnett [sic] Road contains a large, forested wetland complex and portions of Youngs Creek; additional consideration should be given to avoiding development in this area. NYSDEC Comment 3: Stormwater management should pay particular attention to Chapter 3 of the New York State Stormwater Management Design Manual (SMDM) and its focus on Stormwater Management Planning. The SMDM requires a specific planning process when addressing stormwater management on a project site and guides the planner through steps to maintain pre-development natural hydrologic conditions of the site by application of environmentally sound development principles, such as green infrastructure, as well as treatment and control of runoff discharges from the site. Response: Comment noted. 12/14/23 6 80 NYSDEC Comment 4: Identify additional potential development alternatives considering design and configuration changes to avoid or minimize potential impacts to wetlands, streams, and other sensitive natural resources. The area east of Burnett [sic] Road contains a large, forested wetland complex and portions of Youngs Creek; additional consideration should be given to avoiding development in this area. Response: The Scope has been revised to indicate that the DEIS will consider two additional alternatives: 1) an alternative that evaluates the Proposed Project without access to and from US Route 11; and 2) an alternative that evaluates different internal configurations of Micron’s proposed Fabs to determine to what extent impacts to wetlands, streams, and other natural resources on the Micron Campus can be avoided or minimized. NYSDEC Comment 5: The DEIS should include a discussion of potential alternatives and mitigation that could reduce energy and fuel demands during construction and the long-term operation of the facility, including renewable energy sources. Response: The Scope has been revised to indicate that the DEIS will consider two additional alternatives: 1) an alternative that evaluates the Proposed Project without access to and from US Route 11; and 2) an alternative that evaluates different internal configurations of Micron’s proposed Fabs to determine to what extent impacts to wetlands, streams, and other natural resources on the Micron Campus can be avoided or minimized. NYSDEC Comment 5: The DEIS should include a discussion of potential alternatives and mitigation that could reduce energy and fuel demands during construction and the long-term operation of the facility, including renewable energy sources. Response: The Scope has been revised to indicate that the DEIS will include a summary of other alternatives previously considered but determined not to be feasible, including an alternative that relies exclusively on alternative sources of energy (beyond use of renewable energy for purchased electricity). The DEIS will also assess the proposed use and conservation of energy (including provisions for renewable energy sources). The DEIS will include an evaluation of energy impacts from construction and long-term operation of the facility, along with potential mitigation of those impacts. NYSDEC Comment 6: Natural resource impacts associated with off-site infrastructure improvements (linear utility construction projects, pump stations, water intake and associated improvements, wastewater plant) should be evaluated and described in the DEIS, including the presence of, and impacts to, wetlands, waterbodies, and threatened and endangered species for. Horizontal drilling should be discussed and considered. Response: The Scope has been revised to clarify that the DEIS will include an assessment of off-site improvements in each of the relevant subject areas, including natural resources. Proposed mitigation methods will be discussed. Response: The Scope has been revised to indicate that the DEIS will include a summary of other alternatives previously considered but determined not to be feasible, including an alternative that relies exclusively on alternative sources of energy (beyond use of renewable energy for purchased electricity). The DEIS will also assess the proposed use and conservation of energy (including provisions for renewable energy sources). The DEIS will include an evaluation of energy impacts from construction and long-term operation of the facility, along with potential mitigation of those impacts. NYSDEC Comment 6: Natural resource impacts associated with off-site infrastructure improvements (linear utility construction projects, pump stations, water intake and associated improvements, wastewater plant) should be evaluated and described in the DEIS, including the presence of, and impacts to, wetlands, waterbodies, and threatened and endangered species for. Horizontal drilling should be discussed and considered. Response: The Scope has been revised to clarify that the DEIS will include an assessment of off-site improvements in each of the relevant subject areas, including natural resources. Proposed mitigation methods will be discussed. NYSDEC Comment 7: The DEIS should include a table summarizing the amounts and types of wetlands, streams, and other waterbodies on the Proposed Project site, and those associated with the previous comment. The table should also quantify the impacts on these resources for phases 1 and 2, and the cumulative of both phases. Response: Comment noted. NYSDEC Comment 8: The DEIS should include a complete discussion on the avoidance and minimization of wetlands impacts, which are the first two analyses required prior to considering 12/14/23 7 81 wetland mitigation under implementing regulatory programs for Section 404 of the Clean Water Act and Article 24 of the New York State Environmental Conservation Law. Response: The Scope has been revised to indicate that the DEIS will consider an alternative that evaluates different internal configurations of Micron’s proposed Fabs to determine to what extent impacts to wetlands, streams, and other natural resources on the Micron Campus can be avoided or minimized. NYSDEC Comment 9: The DEIS should include and discuss wetland creation and restoration prior to consideration of enhancement. Please see attachment B, which discusses DEC wetland mitigation requirements. This information should be discussed in the DEIS. NYSDEC Comment 7: The DEIS should include a table summarizing the amounts and types of wetlands, streams, and other waterbodies on the Proposed Project site, and those associated with the previous comment. The table should also quantify the impacts on these resources for phases 1 and 2, and the cumulative of both phases. Response: Comment noted. NYSDEC Comment 8: The DEIS should include a complete discussion on the avoidance and minimization of wetlands impacts, which are the first two analyses required prior to considering 12/14/23 7 81 wetland mitigation under implementing regulatory programs for Section 404 of the Clean Water Act and Article 24 of the New York State Environmental Conservation Law. Response: The Scope has been revised to indicate that the DEIS will consider an alternative that evaluates different internal configurations of Micron’s proposed Fabs to determine to what extent impacts to wetlands, streams, and other natural resources on the Micron Campus can be avoided or minimized. NYSDEC Comment 9: The DEIS should include and discuss wetland creation and restoration prior to consideration of enhancement. Please see attachment B, which discusses DEC wetland mitigation requirements. This information should be discussed in the DEIS. Response: The Scope has been revised to note that creation and restoration of wetlands would be considered prior to consideration of enhancement. NYSDEC Comment 10: The DEIS should include the Proposed Project’s onsite wetland delineation and compensatory mitigation package being developed by Micron and its consultants. Response: The Scope has been revised to indicate that the wetland delineation report and draft conceptual compensatory mitigation plan will be included as an appendix to the DEIS. NYSDEC Comment 11: The DEIS should address and discuss stream mitigation that will be completed to offset impacts to waterbodies on the Proposed Project site. Response: The Scope has been revised to clarify that potential impacts (and any required mitigation) to streams will be assessed as part of the water resources assessment. NYSDEC Comment 12: The DEIS should include an assessment of the functions and benefits of all the streams and wetlands on the Proposed Project site. Response: The Scope has been revised to indicate that the DEIS will include an assessment of wetland functions and services. Response: The Scope has been revised to note that creation and restoration of wetlands would be considered prior to consideration of enhancement. NYSDEC Comment 10: The DEIS should include the Proposed Project’s onsite wetland delineation and compensatory mitigation package being developed by Micron and its consultants. Response: The Scope has been revised to indicate that the wetland delineation report and draft conceptual compensatory mitigation plan will be included as an appendix to the DEIS. NYSDEC Comment 11: The DEIS should address and discuss stream mitigation that will be completed to offset impacts to waterbodies on the Proposed Project site. Response: The Scope has been revised to clarify that potential impacts (and any required mitigation) to streams will be assessed as part of the water resources assessment. NYSDEC Comment 12: The DEIS should include an assessment of the functions and benefits of all the streams and wetlands on the Proposed Project site. Response: The Scope has been revised to indicate that the DEIS will include an assessment of wetland functions and services. NYSDEC Comment 13: The Acoustic Bat Survey Report and the Grassland Breeding Bird Survey Report, prepared for Micron New York by AKRF Inc. should be discussed and appended to the DEIS. The DEIS should reference Grass Land Bird Mitigation Requirements (attachment to comment letter) Response: The Scope has been revised to indicate that the field reports for work conducted in Spring 2023 on bat habitat and grassland birds will be included as appendices to the DEIS. NYSDEC Comment 14: The natural resource analysis of the Proposed Project should also include details on wildlife that likely use the site based on habitat types and any ancillary observations made by on-site natural resource consultants. The DEIS should discuss the impacts on the species associated with converting these habitats to an industrial site. 12/14/23 8 82 Response: The Scope indicates that the DEIS will include discussion of natural resources, including wildlife habitats, potential impacts and proposed mitigation. NYSDEC Comment 13: The Acoustic Bat Survey Report and the Grassland Breeding Bird Survey Report, prepared for Micron New York by AKRF Inc. should be discussed and appended to the DEIS. The DEIS should reference Grass Land Bird Mitigation Requirements (attachment to comment letter) Response: The Scope has been revised to indicate that the field reports for work conducted in Spring 2023 on bat habitat and grassland birds will be included as appendices to the DEIS. NYSDEC Comment 14: The natural resource analysis of the Proposed Project should also include details on wildlife that likely use the site based on habitat types and any ancillary observations made by on-site natural resource consultants. The DEIS should discuss the impacts on the species associated with converting these habitats to an industrial site. 12/14/23 8 82 Response: The Scope indicates that the DEIS will include discussion of natural resources, including wildlife habitats, potential impacts and proposed mitigation. NYSDEC Comment 15: The C-Class Youngs Creek (Water Index Number ONT-66-11-14), located east of Burnett [sic] Road, is continuously connected to the Oneida River (Water Index Number ONT-66- 11) with no known impassable barrier. The site plan OCIDA included with the draft scope shows portions of the Proposed Project filling Youngs Creek. The DEIS should include information on any portions of Youngs Creek being filled or “culverted” and discuss how water in the stream will be managed. Response: The Scope has been revised to note that field studies describing physical, biological, and chemical characteristics of Youngs Creek will be conducted as part of the DEIS. NYSDEC Comment 16: A biological survey of Youngs Creek on the Proposed Project site should be completed to assess fish species composition in this stream and detail the effects on these species associated with any impact on the stream. The analysis should consider upstream and downstream impacts, and evaluate upstream and downstream instream habitat enhancement projects to mitigate potential onsite impacts. Response: The Scope has been revised to include a requirement for field studies to characterize aquatic wildlife within Youngs Creek. NYSDEC Comment 15: The C-Class Youngs Creek (Water Index Number ONT-66-11-14), located east of Burnett [sic] Road, is continuously connected to the Oneida River (Water Index Number ONT-66- 11) with no known impassable barrier. The site plan OCIDA included with the draft scope shows portions of the Proposed Project filling Youngs Creek. The DEIS should include information on any portions of Youngs Creek being filled or “culverted” and discuss how water in the stream will be managed. Response: The Scope has been revised to note that field studies describing physical, biological, and chemical characteristics of Youngs Creek will be conducted as part of the DEIS. NYSDEC Comment 16: A biological survey of Youngs Creek on the Proposed Project site should be completed to assess fish species composition in this stream and detail the effects on these species associated with any impact on the stream. The analysis should consider upstream and downstream impacts, and evaluate upstream and downstream instream habitat enhancement projects to mitigate potential onsite impacts. Response: The Scope has been revised to include a requirement for field studies to characterize aquatic wildlife within Youngs Creek. NYSDEC Comment 17: The DEIS should include further details to identify how surface and subsurface water resources will be evaluated. It should address potential on-site and off-site flooding and impacts to surface and groundwater, and an evaluation of impacts on surface water volume, including streams, wetlands, and drainage ways, and groundwater elevations during and after construction. Impacts to groundwater levels, quantity, and quality from filling wetlands should be assessed, including a groundwater hydrologic and hydraulic analysis of the impacts of placing fill in watersheds contributing to the project area. Special consideration should be given to filling wetlands, drainage areas, Youngs Creek, and its tributaries, including unmapped streams, and evaluate how fill may affect the surface and subsurface water flow and drainage patterns in the area and surrounding properties. Consider factors such as increased surface runoff, potential water flow redirection, and impacts on nearby waterbodies or stormwater management systems. Portions of this information are also needed as part of the SWPPP review. Points for consideration in the hydrologic/hydraulic analysis were identified. NYSDEC Comment 17: The DEIS should include further details to identify how surface and subsurface water resources will be evaluated. It should address potential on-site and off-site flooding and impacts to surface and groundwater, and an evaluation of impacts on surface water volume, including streams, wetlands, and drainage ways, and groundwater elevations during and after construction. Impacts to groundwater levels, quantity, and quality from filling wetlands should be assessed, including a groundwater hydrologic and hydraulic analysis of the impacts of placing fill in watersheds contributing to the project area. Special consideration should be given to filling wetlands, drainage areas, Youngs Creek, and its tributaries, including unmapped streams, and evaluate how fill may affect the surface and subsurface water flow and drainage patterns in the area and surrounding properties. Consider factors such as increased surface runoff, potential water flow redirection, and impacts on nearby waterbodies or stormwater management systems. Portions of this information are also needed as part of the SWPPP review. Points for consideration in the hydrologic/hydraulic analysis were identified. Response: The Scope has been revised to clarify that the DEIS will identify both surface and subsurface water resources and impacts to those resources, including from construction, and potential mitigation of those impacts. See also Responses to NYSDEC Comments 1, 15, 16. NYSDEC Comment 18: The DEIS should discuss how drainage will be maintained and how potential flooding would be mitigated. 12/14/23 9 83 Response: The DEIS will include the requested discussion. NYSDEC Comment 19: NYSDEC supports documenting floodplains and recommends re-evaluating and updating floodplain mapping for any significant grade changes. Response: Comment noted. NYSDEC Comment 20: Dewatering of groundwater during construction should be discussed including best management practices that may be employed to avoid and mitigate impacts to the resource. Response: The DEIS will include the requested discussion. Response: The Scope has been revised to clarify that the DEIS will identify both surface and subsurface water resources and impacts to those resources, including from construction, and potential mitigation of those impacts. See also Responses to NYSDEC Comments 1, 15, 16. NYSDEC Comment 18: The DEIS should discuss how drainage will be maintained and how potential flooding would be mitigated. 12/14/23 9 83 Response: The DEIS will include the requested discussion. NYSDEC Comment 19: NYSDEC supports documenting floodplains and recommends re-evaluating and updating floodplain mapping for any significant grade changes. Response: Comment noted. NYSDEC Comment 20: Dewatering of groundwater during construction should be discussed including best management practices that may be employed to avoid and mitigate impacts to the resource. Response: The DEIS will include the requested discussion. NYSDEC Comment 21: Evaluate the impact potential population growth associated with this development will have on the management of solid waste and recyclables, as well as the anticipated amount of waste and recyclable material generated by Micron. Onondaga County law requires that waste generated within the County be disposed of at the Onondaga County Resource Recovery Waste to Energy Facility. Consider the existing waste management network's capacity, and ability to accept increased volumes associated with the Proposed Project, and the potential for population growth. If the evaluation includes an expansion of any waste or recycling facilities or the use of the Onondaga County landfill, approximate dates of the expansion(s) should be included that correspond with Micron's expected buildout. Response: The Scope has been revised to indicate that the DEIS will address issues of solid waste generation from the Proposed Project, as well as plans by Onondaga County to manage solid waste and recyclables as a result of economic development related to the Proposed Project. The Scope has been revised to provide additional detail on how the capacity of the existing waste management network would be affected by the Proposed Project. NYSDEC Comment 21: Evaluate the impact potential population growth associated with this development will have on the management of solid waste and recyclables, as well as the anticipated amount of waste and recyclable material generated by Micron. Onondaga County law requires that waste generated within the County be disposed of at the Onondaga County Resource Recovery Waste to Energy Facility. Consider the existing waste management network's capacity, and ability to accept increased volumes associated with the Proposed Project, and the potential for population growth. If the evaluation includes an expansion of any waste or recycling facilities or the use of the Onondaga County landfill, approximate dates of the expansion(s) should be included that correspond with Micron's expected buildout. Response: The Scope has been revised to indicate that the DEIS will address issues of solid waste generation from the Proposed Project, as well as plans by Onondaga County to manage solid waste and recyclables as a result of economic development related to the Proposed Project. The Scope has been revised to provide additional detail on how the capacity of the existing waste management network would be affected by the Proposed Project. NYSDEC Comment 22: The DEIS should include a discussion of hazardous waste, listed in 6 NYCRR Part 371.4, that the Proposed Project may generate, including type of hazardous waste anticipated to be generated, approximate volumes, storage methods, disposal options, and how the facility will operate following hazardous waste regulations found at 6 NYCRR Part 370-373. Response: The Scope has been revised to clarify that the DEIS will include a description of the generation, storage, and disposal of hazardous wastes identified in 6 NYCRR Part 371.4. NYSDEC Comment 23: Mitigation considerations for solid waste should include an evaluation of processing methods and chemicals used in the manufacturing process to determine if alternative methods could reduce the generation of hazardous waste. Response: See Responses to NYSDEC Comments 21 and 22. 12/14/23 10 84 NYSDEC Comment 22: The DEIS should include a discussion of hazardous waste, listed in 6 NYCRR Part 371.4, that the Proposed Project may generate, including type of hazardous waste anticipated to be generated, approximate volumes, storage methods, disposal options, and how the facility will operate following hazardous waste regulations found at 6 NYCRR Part 370-373. Response: The Scope has been revised to clarify that the DEIS will include a description of the generation, storage, and disposal of hazardous wastes identified in 6 NYCRR Part 371.4. NYSDEC Comment 23: Mitigation considerations for solid waste should include an evaluation of processing methods and chemicals used in the manufacturing process to determine if alternative methods could reduce the generation of hazardous waste. Response: See Responses to NYSDEC Comments 21 and 22. 12/14/23 10 84 NYSDEC Comment 24: The air quality modeling included in the DEIS should include an air quality impact evaluation or dispersion modeling analysis for a variety of emission sources including major sources, air toxic sources, and any sources that appear likely to contravene an applicable ambient air quality standard. NYSDEC developed the DAR-10 guidance document, NYSDEC Guidelines on Dispersion Modeling Procedures for Air Quality Impact Analysis. The applicant should submit a modeling protocol to DEC for approval prior to performing any dispersion modeling analyses. Response: The Scope notes that a stationary source air pollution control permit for the new manufacturing facilities will be required. The air pollution control permit application will include evaluation of pollutants subject to the National Ambient Air Quality Standards (NAAQS), New York air toxic control and ambient air requirements, and a Climate Leadership and Community Protection Act (CLCPA) greenhouse gas evaluation. The Scope indicates that the DEIS will summarize these detailed air quality modeling and impact assessment analyses that will be prepared to support the air pollution control permitting process. NYSDEC Comment 24: The air quality modeling included in the DEIS should include an air quality impact evaluation or dispersion modeling analysis for a variety of emission sources including major sources, air toxic sources, and any sources that appear likely to contravene an applicable ambient air quality standard. NYSDEC developed the DAR-10 guidance document, NYSDEC Guidelines on Dispersion Modeling Procedures for Air Quality Impact Analysis. The applicant should submit a modeling protocol to DEC for approval prior to performing any dispersion modeling analyses. Response: The Scope notes that a stationary source air pollution control permit for the new manufacturing facilities will be required. The air pollution control permit application will include evaluation of pollutants subject to the National Ambient Air Quality Standards (NAAQS), New York air toxic control and ambient air requirements, and a Climate Leadership and Community Protection Act (CLCPA) greenhouse gas evaluation. The Scope indicates that the DEIS will summarize these detailed air quality modeling and impact assessment analyses that will be prepared to support the air pollution control permitting process. NYSDEC Comment 25: If the impact assessment includes a private, pre-construction, on-site air quality monitoring network, the plan will need prior NYSDEC approval. Guidance for the establishment, maintenance, and reporting requirements of private air monitoring networks can be found in DAR-2, 6 NYCRR Part 231-12.3 and Appendix B to 40 CFR Part 58. Response: Comment noted. NYSDEC Comment 26: If one or more applicable requirements or proposed compliance certification sections require the use of a continuous emissions monitoring (CEM) system, the analysis should develop and include a continuous emissions monitoring plan. The analysis should include applicable RACT/BACT/LAER demonstrations, as well as appropriate Emission Reduction Credit (ERCs) demonstrations and analysis. Response: See Response to NYSDEC Comment 24. NYSDEC Comment 27: The analysis should include, as applicable, a Toxic Impact Assessment and Environmental Rating Demonstration pursuant to the requirements of 6 NYCRR Part 212. DEC developed DAR-1: Guidelines for the Evaluation and Control of Ambient Air Contaminants Under Part 212. Response: See Response to NYSDEC Comment 24. NYSDEC Comment 28: NYSDEC recommends that a copy of the Air Title V permit application and supporting information be appended to the DEIS to the extent it is available. Response: Information supporting the Air Title V permit application will be provided as an appendix to the DEIS. NYSDEC Comment 25: If the impact assessment includes a private, pre-construction, on-site air quality monitoring network, the plan will need prior NYSDEC approval. Guidance for the establishment, maintenance, and reporting requirements of private air monitoring networks can be found in DAR-2, 6 NYCRR Part 231-12.3 and Appendix B to 40 CFR Part 58. Response: Comment noted. NYSDEC Comment 26: If one or more applicable requirements or proposed compliance certification sections require the use of a continuous emissions monitoring (CEM) system, the analysis should develop and include a continuous emissions monitoring plan. The analysis should include applicable RACT/BACT/LAER demonstrations, as well as appropriate Emission Reduction Credit (ERCs) demonstrations and analysis. Response: See Response to NYSDEC Comment 24. NYSDEC Comment 27: The analysis should include, as applicable, a Toxic Impact Assessment and Environmental Rating Demonstration pursuant to the requirements of 6 NYCRR Part 212. DEC developed DAR-1: Guidelines for the Evaluation and Control of Ambient Air Contaminants Under Part 212. Response: See Response to NYSDEC Comment 24. NYSDEC Comment 28: NYSDEC recommends that a copy of the Air Title V permit application and supporting information be appended to the DEIS to the extent it is available. Response: Information supporting the Air Title V permit application will be provided as an appendix to the DEIS. 12/14/23 11 85 NYSDEC Comment 29: The Proposed Project is subject to the mandates of the Climate Leadership and Community Protection Act (CLCPA) and therefore requires an analysis pursuant to Section 7(2) of CLCPA. Please see DEC Program Policy DAR-21 for guidance on preparing the CLCPA analysis. Response: The DEIS will include an assessment of GHG emissions associated with the Proposed Project and will assess compliance with Section 7(2) of the CLCPA. NYSDEC Comment 30: NYSDEC recommends evaluating and quantifying GHG and co-pollutants of mobile emissions sources during construction and when the plant is in operation. Additionally, alternatives and mitigation that reduce GHG and co-pollutants from mobile emission sources must be considered. Response: The Scope indicates that the DEIS will assess the Proposed Project’s potential emission of GHGs and the measures proposed to avoid, minimize, and mitigate any impacts. 12/14/23 11 85 NYSDEC Comment 29: The Proposed Project is subject to the mandates of the Climate Leadership and Community Protection Act (CLCPA) and therefore requires an analysis pursuant to Section 7(2) of CLCPA. Please see DEC Program Policy DAR-21 for guidance on preparing the CLCPA analysis. Response: The DEIS will include an assessment of GHG emissions associated with the Proposed Project and will assess compliance with Section 7(2) of the CLCPA. NYSDEC Comment 30: NYSDEC recommends evaluating and quantifying GHG and co-pollutants of mobile emissions sources during construction and when the plant is in operation. Additionally, alternatives and mitigation that reduce GHG and co-pollutants from mobile emission sources must be considered. Response: The Scope indicates that the DEIS will assess the Proposed Project’s potential emission of GHGs and the measures proposed to avoid, minimize, and mitigate any impacts. NYSDEC Comment 31: Among other CLCPA requirements, the Proposed Project will result in an actual increase in greenhouse gas (GHG) emissions, including both direct and indirect GHG emissions. Therefore, the DEIS should include a discussion of the justification for the Proposed Project, along with the technical and economic feasibility of any alternatives or GHG mitigation measures to address the increase. Any such mitigation should take place at the New York facility or in the immediate area, rather than in other cities or out of state. NYSDEC offered examples of potential alternatives and mitigation measures. Response: The Scope indicates that the DEIS will include an assessment of GHG emissions associated with the Proposed Project and will assess compliance with Section 7(2) of the CLCPA. NYSDEC Comment 32: The discussion of natural resource impacts for constructing utility connections, such as clean water, wastewater, electric, gas, telecommunications, and roadway expansions should be referenced in the Utilities and Infrastructure section of the DEIS. Response: The Scope has been revised to clarify that the DEIS will include assessment of all off-site improvements (water, wastewater, electricity, natural gas, telecommunications) in each of the relevant subject areas, including natural resources. NYSDEC Comment 31: Among other CLCPA requirements, the Proposed Project will result in an actual increase in greenhouse gas (GHG) emissions, including both direct and indirect GHG emissions. Therefore, the DEIS should include a discussion of the justification for the Proposed Project, along with the technical and economic feasibility of any alternatives or GHG mitigation measures to address the increase. Any such mitigation should take place at the New York facility or in the immediate area, rather than in other cities or out of state. NYSDEC offered examples of potential alternatives and mitigation measures. Response: The Scope indicates that the DEIS will include an assessment of GHG emissions associated with the Proposed Project and will assess compliance with Section 7(2) of the CLCPA. NYSDEC Comment 32: The discussion of natural resource impacts for constructing utility connections, such as clean water, wastewater, electric, gas, telecommunications, and roadway expansions should be referenced in the Utilities and Infrastructure section of the DEIS. Response: The Scope has been revised to clarify that the DEIS will include assessment of all off-site improvements (water, wastewater, electricity, natural gas, telecommunications) in each of the relevant subject areas, including natural resources. NYSDEC Comment 33: NYSDEC recommends developing a phasing plan, which coincides with Micron’s incremental expansion, for the buildout and expansion of all utility upgrades required to meet the Proposed Project’s anticipated demands. The phasing plan should include sewer extensions, pumping systems, new clean water source(s) and distribution systems, wastewater plant upgrades, and gas and electricity distribution infrastructure. Response: The Scope indicates that the DEIS will describe the proposed phasing plan of off- site improvements required to meet the Proposed Project’s anticipated demand. 12/14/23 12 86 NYSDEC Comment 34: The DEIS should also provide adequate information to demonstrate that all utility upgrades will be constructed, operational, and sufficient to accept waste from or provide service to the Proposed Project. Please see Attachment D, which lists the typical details DEC reviews for a sewer extension and force main approvals. Response: See Response to NYSDEC Comment 33. NYSDEC Comment 35: Provide adequate details on the Proposed Project’s wastewater loading, flow, and discuss the on-site wastewater pretreatments. NYSDEC Comment 33: NYSDEC recommends developing a phasing plan, which coincides with Micron’s incremental expansion, for the buildout and expansion of all utility upgrades required to meet the Proposed Project’s anticipated demands. The phasing plan should include sewer extensions, pumping systems, new clean water source(s) and distribution systems, wastewater plant upgrades, and gas and electricity distribution infrastructure. Response: The Scope indicates that the DEIS will describe the proposed phasing plan of off- site improvements required to meet the Proposed Project’s anticipated demand. 12/14/23 12 86 NYSDEC Comment 34: The DEIS should also provide adequate information to demonstrate that all utility upgrades will be constructed, operational, and sufficient to accept waste from or provide service to the Proposed Project. Please see Attachment D, which lists the typical details DEC reviews for a sewer extension and force main approvals. Response: See Response to NYSDEC Comment 33. NYSDEC Comment 35: Provide adequate details on the Proposed Project’s wastewater loading, flow, and discuss the on-site wastewater pretreatments. Response: The Scope has been revised to indicate that the Project Description chapter of the DEIS will include additional description of Micron’s proposed use and management of water and chemicals (including on-site pretreatment) and Micron’s proposed generation and management of various waste streams and how best management practices will be implemented. NYSDEC Comment 36: The DEIS should provide details on the design specification of the new lake water intake structure and intake screening and assess potential fish impingement mortality and entrainment, and additional measures, including specific equipment, to avoid and minimize fish impingement and entrainment. Response: The DEIS will identify and describe required infrastructure improvements, including, to the extent known, information on the design, and potential impacts to environmental resources from construction of those improvements. NYSDEC Comment 37: The DEIS should consider and include details and a summary of water conservation and reuse practices to mitigate water demands. Response: The Scope has been revised to indicate that the Project Description chapter of the DEIS will include additional description of Micron’s proposed use and management of water and chemicals (including on-site pretreatment) and Micron’s proposed generation and management of various waste streams and how best management practices will be implemented. NYSDEC Comment 36: The DEIS should provide details on the design specification of the new lake water intake structure and intake screening and assess potential fish impingement mortality and entrainment, and additional measures, including specific equipment, to avoid and minimize fish impingement and entrainment. Response: The DEIS will identify and describe required infrastructure improvements, including, to the extent known, information on the design, and potential impacts to environmental resources from construction of those improvements. NYSDEC Comment 37: The DEIS should consider and include details and a summary of water conservation and reuse practices to mitigate water demands. Response: The Scope has been revised to indicate that the Project Description chapter of the DEIS will include additional description of Micron’s proposed use and management of water (including on-site pretreatment) and how best management practices will be implemented to conserve water usage. NYSDEC Comment 38: The DEIS should include a summary of any investigated and considered alternative water sources. Response: The Scope has been revised to indicate that the DEIS will describe any previous studies conducted by Onondaga County Water Authority on alternative sources of water. NYSDEC Comment 39: Water withdrawals within the Great Lakes Basin are subject to the requirement and provisions of the Great Lakes-St. Lawrence River Basin Water Resource Compact. The DEIS should discuss and address how the proposed water withdrawal and use is consistent with the Compact and all state, local, and federal laws. 12/14/23 13 87 Response: The Scope has been revised to indicate that the Project Description chapter of the DEIS will include additional description of Micron’s proposed use and management of water (including on-site pretreatment) and how best management practices will be implemented to conserve water usage. NYSDEC Comment 38: The DEIS should include a summary of any investigated and considered alternative water sources. Response: The Scope has been revised to indicate that the DEIS will describe any previous studies conducted by Onondaga County Water Authority on alternative sources of water. NYSDEC Comment 39: Water withdrawals within the Great Lakes Basin are subject to the requirement and provisions of the Great Lakes-St. Lawrence River Basin Water Resource Compact. The DEIS should discuss and address how the proposed water withdrawal and use is consistent with the Compact and all state, local, and federal laws. 12/14/23 13 87 Response: In accordance with NYSDEC rules and guidance there is an exception for public water supply systems from the Great Lakes-St. Lawrence River Basin Water Resources Compact as enacted in ECL Article 21 Title 10. The DEIS will include discussion regarding water withdrawal, including applicable permits and regulations. NYSDEC Comment 40: NYSDEC recommends renaming the DEIS chapter as “Use and Conservation of Energy.” Response: The Scope has been revised to indicate that the chapter will be named “Use and Conservation of Energy.” NYSDEC Comment 41: The DEIS should contain a description of energy sources to be used during both construction and operational phases of a project, including accurate estimates of demand or consumption. Discuss alternatives and mitigation that could reduce energy and fuel demands during construction and long-term operation. Response: The DEIS will assess the Proposed Project’s energy requirements and will include a discussion of the use of alternative energy sources and energy conservation. If significant adverse impacts with regard to energy resources are identified, mitigation of such impacts will be identified. Response: In accordance with NYSDEC rules and guidance there is an exception for public water supply systems from the Great Lakes-St. Lawrence River Basin Water Resources Compact as enacted in ECL Article 21 Title 10. The DEIS will include discussion regarding water withdrawal, including applicable permits and regulations. NYSDEC Comment 40: NYSDEC recommends renaming the DEIS chapter as “Use and Conservation of Energy.” Response: The Scope has been revised to indicate that the chapter will be named “Use and Conservation of Energy.” NYSDEC Comment 41: The DEIS should contain a description of energy sources to be used during both construction and operational phases of a project, including accurate estimates of demand or consumption. Discuss alternatives and mitigation that could reduce energy and fuel demands during construction and long-term operation. Response: The DEIS will assess the Proposed Project’s energy requirements and will include a discussion of the use of alternative energy sources and energy conservation. If significant adverse impacts with regard to energy resources are identified, mitigation of such impacts will be identified. NYSDEC Comment 42: The 2018 amendments to SEQR regulations require all New York State agencies to evaluate such GHG impacts in a new section specifically dedicated to climate change and its impacts. Proposed energy conservation measures that go beyond the minimum requirements of the State Energy Conservation Construction Code (9 NYCRR Parts 7810 through 7816) should be specifically identified, such as LEED or Energy Star. Please refer to Chapter 5, Section C, Item 44 on page 123 in the SEQR Handbook. The information and energy conservation measures discussed in this section may be applicable and cross-referenced to the Greenhouse Gas Emissions and Climate Change chapter. Response: Comment noted. NYSDEC Comment 42: The 2018 amendments to SEQR regulations require all New York State agencies to evaluate such GHG impacts in a new section specifically dedicated to climate change and its impacts. Proposed energy conservation measures that go beyond the minimum requirements of the State Energy Conservation Construction Code (9 NYCRR Parts 7810 through 7816) should be specifically identified, such as LEED or Energy Star. Please refer to Chapter 5, Section C, Item 44 on page 123 in the SEQR Handbook. The information and energy conservation measures discussed in this section may be applicable and cross-referenced to the Greenhouse Gas Emissions and Climate Change chapter. Response: Comment noted. United States Fish & Wildlife Services (USFWS) USFWS Comment 1: Section five of the Scope provides general topics and specific technical studies proposed to inform the DEIS. We note that while the list of resources includes wetlands, floodplains, and vegetated habitat, there is no mention of an analysis of the project’s effects on wildlife. The Scope should be amended to include literature review and field observations of wildlife using the site at all times of the year, including winter and migration seasons. Potential impacts to wildlife that should be considered in the DEIS include, but are not limited to, noise, lighting, pollution, human activity and traffic. Potential loss of habitat and fragmentation appear to be substantial and will negatively affect many species. This information should be included in the Scope and documented in the DEIS. Response: The Scope has been revised to divide the “Natural Resources” chapter into separate “Water Resources” and “Ecological Communities & Wildlife” chapters to 12/14/23 14 88 United States Fish & Wildlife Services (USFWS) USFWS Comment 1: Section five of the Scope provides general topics and specific technical studies proposed to inform the DEIS. We note that while the list of resources includes wetlands, floodplains, and vegetated habitat, there is no mention of an analysis of the project’s effects on wildlife. The Scope should be amended to include literature review and field observations of wildlife using the site at all times of the year, including winter and migration seasons. Potential impacts to wildlife that should be considered in the DEIS include, but are not limited to, noise, lighting, pollution, human activity and traffic. Potential loss of habitat and fragmentation appear to be substantial and will negatively affect many species. This information should be included in the Scope and documented in the DEIS. Response: The Scope has been revised to divide the “Natural Resources” chapter into separate “Water Resources” and “Ecological Communities & Wildlife” chapters to 12/14/23 14 88 provide clarity regarding how water resources (groundwater, streams, and wetlands) and habitat for wildlife will be assessed in the DEIS. The DEIS will assess potential impacts on wildlife, including where appropriate, literature review and field observations collected seasonally, including winter and migration seasons. This assessment will evaluate potential impacts associated with noise, lighting, pollution, human activity and traffic as well as from the potential loss of habitat and fragmentation. USFWS Comment 2: Regarding site vegetation, the Scope should include mapping of vegetation communities, surveys to document endemic plants and identification of rare species and communities as well as invasive plant species. Information should also be provided on the present and future threats of spreading invasive plants to and from the site. An invasive species management plan should be developed for the site in consultation with NYSDEC. provide clarity regarding how water resources (groundwater, streams, and wetlands) and habitat for wildlife will be assessed in the DEIS. The DEIS will assess potential impacts on wildlife, including where appropriate, literature review and field observations collected seasonally, including winter and migration seasons. This assessment will evaluate potential impacts associated with noise, lighting, pollution, human activity and traffic as well as from the potential loss of habitat and fragmentation. USFWS Comment 2: Regarding site vegetation, the Scope should include mapping of vegetation communities, surveys to document endemic plants and identification of rare species and communities as well as invasive plant species. Information should also be provided on the present and future threats of spreading invasive plants to and from the site. An invasive species management plan should be developed for the site in consultation with NYSDEC. Response: The Scope has been revised to enhance the description of how the DEIS will address ecological communities and potential impacts of the Proposed Project. The DEIS will include mapping of vegetation communities, surveys to document endemic plants and identification of rare species and communities as well as invasive plant species. The DEIS will also assess present and future threats of spreading invasive plants to and from the site. USFWS Comment 3: The information gathered using the Service’s Information, Planning and Consultation (IPaC) system should be included in the DEIS along with a description of studies completed thus far. For example, the Service and the Micron team, along with staff from the NYSDEC, have discussed studies of two endangered bat species believed to be using the site. Response: The Scope has been revised to enhance the description of how the DEIS will address ecological communities and potential impacts of the Proposed Project. The DEIS will include mapping of vegetation communities, surveys to document endemic plants and identification of rare species and communities as well as invasive plant species. The DEIS will also assess present and future threats of spreading invasive plants to and from the site. USFWS Comment 3: The information gathered using the Service’s Information, Planning and Consultation (IPaC) system should be included in the DEIS along with a description of studies completed thus far. For example, the Service and the Micron team, along with staff from the NYSDEC, have discussed studies of two endangered bat species believed to be using the site. Based on information in IPaC, the project is within the range of the federally listed endangered Indiana bat (Myotis sodalis) and the federally listed endangered northern long-eared bat (Myotis septentrionalis). Accordingly, Micron initiated acoustic surveys of these species at sample locations on the site. A summary of the survey results should be included in the DEIS. The documented call locations should be analyzed in regard to tree removal and habitat modification. This information should inform what the potential effects to these listed species may be and what, if any, measures could be implemented to mitigate adverse effects. The Service will continue to work with Micron and other partners in evaluating the project’s effects on federally listed species. Since federal agencies will be funding, permitting and/or approving aspects of the project, section 7 consultation under the ESA will be required. Response: The Scope has been revised to indicate that summaries of field studies will be included as an appendix to the DEIS. The Scope indicates that the USFWS IPaC system will be queried. Based on information in IPaC, the project is within the range of the federally listed endangered Indiana bat (Myotis sodalis) and the federally listed endangered northern long-eared bat (Myotis septentrionalis). Accordingly, Micron initiated acoustic surveys of these species at sample locations on the site. A summary of the survey results should be included in the DEIS. The documented call locations should be analyzed in regard to tree removal and habitat modification. This information should inform what the potential effects to these listed species may be and what, if any, measures could be implemented to mitigate adverse effects. The Service will continue to work with Micron and other partners in evaluating the project’s effects on federally listed species. Since federal agencies will be funding, permitting and/or approving aspects of the project, section 7 consultation under the ESA will be required. Response: The Scope has been revised to indicate that summaries of field studies will be included as an appendix to the DEIS. The Scope indicates that the USFWS IPaC system will be queried. USFWS Comment 4: The Scope indicates that wetlands will be identified and delineated in consultation with the US Army Corps of Engineers. We understand that most of that field work has been completed. However, the Scope does not indicate if or how wetland functions and services will be evaluated and reported. This information is important in understanding the habitat and social values (flood flow attenuation, sediment and nutrient retention, pollution abatement, etc.) these 12/14/23 15 89 areas provide. Documentation in the DEIS is also important to understand what is being potentially lost from the project and what mitigation is required of Micron to replace these functions and services. In line with section 404 of the Clean Water Act, the project design must avoid, minimize, and mitigate potential impacts to aquatic resources to the greatest extent practicable. This review approach should be added to the Scope. Response: The discussion of wetlands has been revised in the Scope to make clear that a discussion of wetland function and services will be included in the DEIS along with a discussion of Section 404 permitting factors. USFWS Comment 4: The Scope indicates that wetlands will be identified and delineated in consultation with the US Army Corps of Engineers. We understand that most of that field work has been completed. However, the Scope does not indicate if or how wetland functions and services will be evaluated and reported. This information is important in understanding the habitat and social values (flood flow attenuation, sediment and nutrient retention, pollution abatement, etc.) these 12/14/23 15 89 areas provide. Documentation in the DEIS is also important to understand what is being potentially lost from the project and what mitigation is required of Micron to replace these functions and services. In line with section 404 of the Clean Water Act, the project design must avoid, minimize, and mitigate potential impacts to aquatic resources to the greatest extent practicable. This review approach should be added to the Scope. Response: The discussion of wetlands has been revised in the Scope to make clear that a discussion of wetland function and services will be included in the DEIS along with a discussion of Section 404 permitting factors. USFWS Comment 5: Wetland mitigation is mentioned in the Scope as potentially occurring on and off site. While the extent of potential wetland impacts is not yet known, it appears to be a substantial amount based upon the extent of wetlands found on the 1400-acre site. Mitigation for unavoidable impacts should occur within the same watershed (as defined by the 8-digit hydrologic code) and be as close to the impacted wetlands as practicable. Micron has inquired about mitigation options including the purchase of credits at third party wetland mitigation banks or in-lieu fee sites. The Service does not support the complete purchase of available credits for the Micron project as that reduces the effectiveness of the mitigation program. Response: Comment noted. Onondaga County Legislator Garland Comment 1: “I want to be sure that our collective efforts ensure a pathway out of poverty for all of the residents I represent.” Response: Comment noted. Comment 2: Raised concerns about the potential for increased traffic on highways and roads in and around the project due to population growth and workforce commutes. USFWS Comment 5: Wetland mitigation is mentioned in the Scope as potentially occurring on and off site. While the extent of potential wetland impacts is not yet known, it appears to be a substantial amount based upon the extent of wetlands found on the 1400-acre site. Mitigation for unavoidable impacts should occur within the same watershed (as defined by the 8-digit hydrologic code) and be as close to the impacted wetlands as practicable. Micron has inquired about mitigation options including the purchase of credits at third party wetland mitigation banks or in-lieu fee sites. The Service does not support the complete purchase of available credits for the Micron project as that reduces the effectiveness of the mitigation program. Response: Comment noted. Onondaga County Legislator Garland Comment 1: “I want to be sure that our collective efforts ensure a pathway out of poverty for all of the residents I represent.” Response: Comment noted. Comment 2: Raised concerns about the potential for increased traffic on highways and roads in and around the project due to population growth and workforce commutes. Response: In coordination with the New York State Department of Transportation (NYSDOT), Onondaga County, the Town of Clay, and the Town of Cicero, and as indicated in the Scope, the DEIS will include an assessment of traffic conditions at the regional and local levels. Input from the Syracuse Metropolitan Transportation Council (SMTC) is also being provided. The Scope has been revised to include additional detail on how the traffic and transportation study area has been defined through consultation with NYSDOT and SMTC and in recognition of modifications to I-81. Comment 3: Raised safety concerns relative to increased traffic and questioned what improvements would be made. Response: See Response to Legislator Garland Comment 2. 12/14/23 16 90 Comment 4: Questioned the study area for traffic and whether additional areas to the south should be included. Response: See Response to Transportation Comments 1-2. Response: In coordination with the New York State Department of Transportation (NYSDOT), Onondaga County, the Town of Clay, and the Town of Cicero, and as indicated in the Scope, the DEIS will include an assessment of traffic conditions at the regional and local levels. Input from the Syracuse Metropolitan Transportation Council (SMTC) is also being provided. The Scope has been revised to include additional detail on how the traffic and transportation study area has been defined through consultation with NYSDOT and SMTC and in recognition of modifications to I-81. Comment 3: Raised safety concerns relative to increased traffic and questioned what improvements would be made. Response: See Response to Legislator Garland Comment 2. 12/14/23 16 90 Comment 4: Questioned the study area for traffic and whether additional areas to the south should be included. Response: See Response to Transportation Comments 1-2. Comment 5: “How is traffic going to be addressed as the scoping of the project goes further and further and brings not only Micron employees to our -- to our boundaries, but also those support industries that are so vital to that operation and will be instrumental in the growth of our community.” Response: See Response to Growth Inducing Impacts 2. Town of Clay Comment 1: The DEIS should include the reason or purpose for the chimneys or stacks (163 ± ft), and the emissions associates with those stacks. Response: The Scope indicates that the DEIS will include analysis of impacts associated with construction and operation of the facility, including visual impacts and air emissions impacts. Comment 2: Safeguards should be established for the discharges into the rivers, including testing, to confirm the discharges are safe and not contaminating the receiving waters. Response: Comment noted. Comment 3: Assurances should be made regarding the safe conveyance of wastewater from the facility to the Oak Orchard treatment plant. Response: Comment noted. Comment 4: The DEIS should address not only the traffic impacts to the Town from Micron employees but also those from the support industries. Response: The DEIS will include a full analysis of traffic impacts, including growth-inducing impacts. D. Response to Public Comments Comment 5: “How is traffic going to be addressed as the scoping of the project goes further and further and brings not only Micron employees to our -- to our boundaries, but also those support industries that are so vital to that operation and will be instrumental in the growth of our community.” Response: See Response to Growth Inducing Impacts 2. Town of Clay Comment 1: The DEIS should include the reason or purpose for the chimneys or stacks (163 ± ft), and the emissions associates with those stacks. Response: The Scope indicates that the DEIS will include analysis of impacts associated with construction and operation of the facility, including visual impacts and air emissions impacts. Comment 2: Safeguards should be established for the discharges into the rivers, including testing, to confirm the discharges are safe and not contaminating the receiving waters. Response: Comment noted. Comment 3: Assurances should be made regarding the safe conveyance of wastewater from the facility to the Oak Orchard treatment plant. Response: Comment noted. Comment 4: The DEIS should address not only the traffic impacts to the Town from Micron employees but also those from the support industries. Response: The DEIS will include a full analysis of traffic impacts, including growth-inducing impacts. D. Response to Public Comments Purpose and Need Comment 1: Many commenters expressed overall support of the Proposed Project and noted the many positive impacts, including economic impacts, it will have in the Town, County, region and State. (1, 14, 15 16, 17, 33, 34, 35) 12/14/23 17 91 Response: Comment noted. Project Alternatives and Description of the Proposed Project Comment 1: One commenter stated that “Micron, DEIS needs to greatly expand its range of alternatives.” (30) Response: See Responses to NYSDEC Comments 4-5. Comment 2: Comments asked why Micron needs to site the Proposed Project in Clay. (26) Response: See Response to NYSDEC Comment 4. The Scope indicates that the DEIS section on alternatives will detail the analyses previously performed for the proposed location of the Proposed Project and other locations in New York State and Onondaga County. Comment 3: Commenters suggest that the Draft Environmental Impact Statement should include an alternative to add a Combined Cycle generating plant on the Micron Property. (24, 25) Response: See Response to NYSDEC Comment 5. Comment 4: Comments requested a consideration of alternative energy sources, including the use of renewable energy. (3, 10, 13, 20, 21, 26, 29, 30, 31,) Response: See Response to NYSDEC Comment 5. Purpose and Need Comment 1: Many commenters expressed overall support of the Proposed Project and noted the many positive impacts, including economic impacts, it will have in the Town, County, region and State. (1, 14, 15 16, 17, 33, 34, 35) 12/14/23 17 91 Response: Comment noted. Project Alternatives and Description of the Proposed Project Comment 1: One commenter stated that “Micron, DEIS needs to greatly expand its range of alternatives.” (30) Response: See Responses to NYSDEC Comments 4-5. Comment 2: Comments asked why Micron needs to site the Proposed Project in Clay. (26) Response: See Response to NYSDEC Comment 4. The Scope indicates that the DEIS section on alternatives will detail the analyses previously performed for the proposed location of the Proposed Project and other locations in New York State and Onondaga County. Comment 3: Commenters suggest that the Draft Environmental Impact Statement should include an alternative to add a Combined Cycle generating plant on the Micron Property. (24, 25) Response: See Response to NYSDEC Comment 5. Comment 4: Comments requested a consideration of alternative energy sources, including the use of renewable energy. (3, 10, 13, 20, 21, 26, 29, 30, 31,) Response: See Response to NYSDEC Comment 5. Comment 5: “Careful attention must be paid to ensuring the energy at the plant will be fossil free.” (10) Response: As outlined in the Scope, the DEIS will assess the Proposed Project’s energy needs, including its potential use of fossil free energy. Land Use, Zoning, & Public Policy Comment 1: The Sierra Club and CNY Sustainability Coalition commented “Why isn’t the city of Syracuse explicitly included here? Seems to be a major omission.” (30, 31) Response: While changes to land use, zoning, and public policy within the City of Syracuse will be unlikely given the distance between the City of Syracuse and WPCP, the Scope indicates that the DEIS will address regional issues of economic activity and how that might affect land use within the surrounding area, including the City of Syracuse. See also response to Other Comment 11. Community Facilities, Open Space & Recreation Comment 1: A number of comments note that open space and the enjoyment of outdoor activities (e.g., birding) was important and should be preserved. Numerous studies have demonstrated the benefit to humans of having green spaces nearby. (19, 26, 29) 12/14/23 18 92 Comment 5: “Careful attention must be paid to ensuring the energy at the plant will be fossil free.” (10) Response: As outlined in the Scope, the DEIS will assess the Proposed Project’s energy needs, including its potential use of fossil free energy. Land Use, Zoning, & Public Policy Comment 1: The Sierra Club and CNY Sustainability Coalition commented “Why isn’t the city of Syracuse explicitly included here? Seems to be a major omission.” (30, 31) Response: While changes to land use, zoning, and public policy within the City of Syracuse will be unlikely given the distance between the City of Syracuse and WPCP, the Scope indicates that the DEIS will address regional issues of economic activity and how that might affect land use within the surrounding area, including the City of Syracuse. See also response to Other Comment 11. Community Facilities, Open Space & Recreation Comment 1: A number of comments note that open space and the enjoyment of outdoor activities (e.g., birding) was important and should be preserved. Numerous studies have demonstrated the benefit to humans of having green spaces nearby. (19, 26, 29) 12/14/23 18 92 Response: The Scope indicates that the DEIS will consider potential direct and indirect impacts of the Proposed Project on parks and recreational resources as well as open space. Comment 2: The Sierra Club and CNY Sustainability Coalition commented that “This section is poorly organized and deserves to be rewritten to define more clearly what are the parameters to be studied and analyzed relevant to police, fire and other emergency services; schools; parks and rec facilities. Absent from the community facilities most notably is the health care and hospital system.” (30, 31) Response: The Scope has been revised to provide greater clarity on the study areas that will be used for each of the technical areas of analysis, including for community facilities and services and parks and recreational resources. Because the technical areas are related to variable conditions, there will necessarily be a variety of study areas defined for each area. Note, however, that an assessment of impact on health care and the hospital system is not contemplated as it is beyond the scope of the environmental review of the Proposed Project. Response: The Scope indicates that the DEIS will consider potential direct and indirect impacts of the Proposed Project on parks and recreational resources as well as open space. Comment 2: The Sierra Club and CNY Sustainability Coalition commented that “This section is poorly organized and deserves to be rewritten to define more clearly what are the parameters to be studied and analyzed relevant to police, fire and other emergency services; schools; parks and rec facilities. Absent from the community facilities most notably is the health care and hospital system.” (30, 31) Response: The Scope has been revised to provide greater clarity on the study areas that will be used for each of the technical areas of analysis, including for community facilities and services and parks and recreational resources. Because the technical areas are related to variable conditions, there will necessarily be a variety of study areas defined for each area. Note, however, that an assessment of impact on health care and the hospital system is not contemplated as it is beyond the scope of the environmental review of the Proposed Project. Comment 3: “Onondaga County health care facilities, in particular our hospitals, were short-staffed even before the Coronavirus pandemic. Waiting times and bed shortages were unfortunately highlighted by Covid-19 cases and have continued. What improvements in the healthcare system are proposed to remedy these shortcomings in view of the expectation of potentially thousands of new residents to work at and/or serve the Micron plant.” (32) Response: See Response to Community Facilities, Open Space & Recreation Comment 2. Socioeconomic Conditions Comment 1: The public comments raised questions about the future workforce. (16, 26) Comment 3: “Onondaga County health care facilities, in particular our hospitals, were short-staffed even before the Coronavirus pandemic. Waiting times and bed shortages were unfortunately highlighted by Covid-19 cases and have continued. What improvements in the healthcare system are proposed to remedy these shortcomings in view of the expectation of potentially thousands of new residents to work at and/or serve the Micron plant.” (32) Response: See Response to Community Facilities, Open Space & Recreation Comment 2. Socioeconomic Conditions Comment 1: The public comments raised questions about the future workforce. (16, 26) Response: Micron has been engaged in an extensive discussion with the Community Engagement Committee (CEC) (an entity convened by the Governor’s Office, Micron, and local elected officials) on how the economic benefits of Micron’s Proposed Project will be experienced within the broader community, including, but not limited to, the City of Syracuse. Micron has been working with regional stakeholders to identify and enhance workforce development programs in anticipation of the thousands of jobs that the Proposed Project will generate. The draft Scope included estimates of projected Micron employment and the general qualifications required for different categories of jobs. The Scope has been revised to include a new sub-heading for this text: “Proposed Project Employment.” Comment 2: Some comments requested a discussion of the anticipated impacts on property taxes. (1, 3, 5, 26,) Response: SEQRA does not require consideration of purely economic impacts. Notwithstanding, the Scope indicates that the DEIS will consider changes in demographics and housing costs, changes in labor supply and effects on existing businesses, and municipal costs generated by the Proposed Project. As part of Response: Micron has been engaged in an extensive discussion with the Community Engagement Committee (CEC) (an entity convened by the Governor’s Office, Micron, and local elected officials) on how the economic benefits of Micron’s Proposed Project will be experienced within the broader community, including, but not limited to, the City of Syracuse. Micron has been working with regional stakeholders to identify and enhance workforce development programs in anticipation of the thousands of jobs that the Proposed Project will generate. The draft Scope included estimates of projected Micron employment and the general qualifications required for different categories of jobs. The Scope has been revised to include a new sub-heading for this text: “Proposed Project Employment.” Comment 2: Some comments requested a discussion of the anticipated impacts on property taxes. (1, 3, 5, 26,) Response: SEQRA does not require consideration of purely economic impacts. Notwithstanding, the Scope indicates that the DEIS will consider changes in demographics and housing costs, changes in labor supply and effects on existing businesses, and municipal costs generated by the Proposed Project. As part of 12/14/23 19 93 this, anticipated impacts to municipal tax levies (the amount of the municipal budget derived from property taxes) will be qualitatively discussed. Comment 3: How will the increase in this infrastructure expansion be covered financially? Will the local community be impacted financially due to the building of the pipeline to carry the water? How is the expense being covered? How much money will it take to pay for the whole building?” (26) Response: This comment is outside the scope of SEQRA. Notwithstanding, the Scope indicates that the DEIS will consider changes in demographics and housing costs, changes in labor supply and effects on existing businesses, and municipal costs generated by the Proposed Project. Comment 4: “What are the projected benefits for the local community? What does Micron have to offer the local community as they plan their environmental impact? How will the negative effects of this infrastructure affect me economically in the beginning and through to the future?” (26) 12/14/23 19 93 this, anticipated impacts to municipal tax levies (the amount of the municipal budget derived from property taxes) will be qualitatively discussed. Comment 3: How will the increase in this infrastructure expansion be covered financially? Will the local community be impacted financially due to the building of the pipeline to carry the water? How is the expense being covered? How much money will it take to pay for the whole building?” (26) Response: This comment is outside the scope of SEQRA. Notwithstanding, the Scope indicates that the DEIS will consider changes in demographics and housing costs, changes in labor supply and effects on existing businesses, and municipal costs generated by the Proposed Project. Comment 4: “What are the projected benefits for the local community? What does Micron have to offer the local community as they plan their environmental impact? How will the negative effects of this infrastructure affect me economically in the beginning and through to the future?” (26) Response: The Scope indicates that the DEIS will describe Micron’s projected benefits to the community as well as its efforts to work with community leaders through the CEC to consider how project benefits can be distributed throughout the affected communities, including to communities of color or low-income communities. Comment 5: The benefits and adverse impacts of socioeconomics need to be considered together and the DEIS should specify the analytical standards, tools and techniques employed. (32, 35) Response: The Scope indicates that potential adverse socioeconomic impacts will be assessed in the DEIS. Environmental Justice Comment 1: Comments raised concern that project-related traffic could potentially affect environmental justice areas and suggested that traffic data be collected from an expansive geographic, especially since the southwest side of the city which has been a concentration of historically disadvantaged populations. (16) Response: The Scope indicates that the DEIS will include analysis of potential impacts on environmental justice communities and disadvantaged communities. See Response to Transportation Comment 1. Response: The Scope indicates that the DEIS will describe Micron’s projected benefits to the community as well as its efforts to work with community leaders through the CEC to consider how project benefits can be distributed throughout the affected communities, including to communities of color or low-income communities. Comment 5: The benefits and adverse impacts of socioeconomics need to be considered together and the DEIS should specify the analytical standards, tools and techniques employed. (32, 35) Response: The Scope indicates that potential adverse socioeconomic impacts will be assessed in the DEIS. Environmental Justice Comment 1: Comments raised concern that project-related traffic could potentially affect environmental justice areas and suggested that traffic data be collected from an expansive geographic, especially since the southwest side of the city which has been a concentration of historically disadvantaged populations. (16) Response: The Scope indicates that the DEIS will include analysis of potential impacts on environmental justice communities and disadvantaged communities. See Response to Transportation Comment 1. Comment 2: “There is a draft permitting requirement that should be considered in the Technical Studies section of the DEIS. The New York State Department of Environmental Conservation (DEC) recently proposed a new policy that will require an analysis of impacts on disadvantaged communities (DACs) as part of most environmental permitting actions.” (25) Response: Comment noted. Micron will consider applicable guidance in the DEIS. 12/14/23 20 94 Historic and Cultural Resources Comment 1: One commenter noted the existence of properties located on Burnet Road and other parts of the White Pine site, some of which are eligible or potentially eligible for listing on the NY State Register of Historic Places and commented that these properties were supposed to be surveyed/assessed in conjunction with the NY State Historic Preservation Office. (18) One commenter suggested preservation of a house on the corner of Burnet and Route 31, and also preservation of a barn on the south side of Route 31. (34) Comment 2: “There is a draft permitting requirement that should be considered in the Technical Studies section of the DEIS. The New York State Department of Environmental Conservation (DEC) recently proposed a new policy that will require an analysis of impacts on disadvantaged communities (DACs) as part of most environmental permitting actions.” (25) Response: Comment noted. Micron will consider applicable guidance in the DEIS. 12/14/23 20 94 Historic and Cultural Resources Comment 1: One commenter noted the existence of properties located on Burnet Road and other parts of the White Pine site, some of which are eligible or potentially eligible for listing on the NY State Register of Historic Places and commented that these properties were supposed to be surveyed/assessed in conjunction with the NY State Historic Preservation Office. (18) One commenter suggested preservation of a house on the corner of Burnet and Route 31, and also preservation of a barn on the south side of Route 31. (34) Response: The properties located on Burnet Road were studied as part of the SGEIS for the WPCP prepared in 2021 to establish a shovel ready commerce park. Any demolition of those properties is not part of the Proposed Project and was completed earlier this year for public safety purposes. The Scope indicates that coordination with the New York State Historic Preservation Office (SHPO) would be required for any additional properties not previously evaluated. In coordination with SHPO, and as indicated in the Scope, the DEIS will identify potential eligible or listed historic resources at WPCP or the surrounding area. Visual Impacts & Community Character Comment 1: Commenters raised concerns about visual impacts, including impacts associated with lighting. (19, 22) Response: The Scope indicates that a visual impact assessment will be conducted consistent with NYSDEC Program Policy “Assessing and Mitigating Visual Impacts.” Comment 2: Concerns were raised about the Proposed Project’s impact on community character and quality of life. (4, 24) Response: The Scope indicates that potential impacts to community character will be addressed in the DEIS. Response: The properties located on Burnet Road were studied as part of the SGEIS for the WPCP prepared in 2021 to establish a shovel ready commerce park. Any demolition of those properties is not part of the Proposed Project and was completed earlier this year for public safety purposes. The Scope indicates that coordination with the New York State Historic Preservation Office (SHPO) would be required for any additional properties not previously evaluated. In coordination with SHPO, and as indicated in the Scope, the DEIS will identify potential eligible or listed historic resources at WPCP or the surrounding area. Visual Impacts & Community Character Comment 1: Commenters raised concerns about visual impacts, including impacts associated with lighting. (19, 22) Response: The Scope indicates that a visual impact assessment will be conducted consistent with NYSDEC Program Policy “Assessing and Mitigating Visual Impacts.” Comment 2: Concerns were raised about the Proposed Project’s impact on community character and quality of life. (4, 24) Response: The Scope indicates that potential impacts to community character will be addressed in the DEIS. Comment 3: The Sierra Club and CNY Sustainability Coalition commented that “This project has the potential to significantly alter the character of the community—not only the locale surrounding the immediate project location, but the wider Syracuse and Onondaga County as well as portions of Oswego County as population growth and housing development is induced.” (30, 31) Response: See Response to Visual Impacts & Community Character Comment 2. Geology, Soils, & Topography Comment 1: “Reference is made to ‘property survey’ as a data source but later the ‘geotechnical investigation’ is mentioned but not included in the sentence describing the analysis. Is this an oversight that should be corrected? Certainly the geotechnical survey will provide valuable information to confirm or modify the USGS soil survey data.” (30, 31) Response: The Scope has been revised to clarify the information to be used in the geology, soils, and topography DEIS chapter. 12/14/23 21 95 Water Resources Comment1: Public comments related to consumption of water, water infrastructure, wastewater, and water quality. (2, 3, 5, 17, 26, 27, 28, 30, 32 ) Comment 3: The Sierra Club and CNY Sustainability Coalition commented that “This project has the potential to significantly alter the character of the community—not only the locale surrounding the immediate project location, but the wider Syracuse and Onondaga County as well as portions of Oswego County as population growth and housing development is induced.” (30, 31) Response: See Response to Visual Impacts & Community Character Comment 2. Geology, Soils, & Topography Comment 1: “Reference is made to ‘property survey’ as a data source but later the ‘geotechnical investigation’ is mentioned but not included in the sentence describing the analysis. Is this an oversight that should be corrected? Certainly the geotechnical survey will provide valuable information to confirm or modify the USGS soil survey data.” (30, 31) Response: The Scope has been revised to clarify the information to be used in the geology, soils, and topography DEIS chapter. 12/14/23 21 95 Water Resources Comment1: Public comments related to consumption of water, water infrastructure, wastewater, and water quality. (2, 3, 5, 17, 26, 27, 28, 30, 32 ) Response: The Scope has been revised to indicate that the DEIS will include additional description of Micron’s proposed consumption of water and generation of wastewater and how those volumes will be minimized as well as managed and coordinated with County infrastructure. Comment 2: The DEIS must describe the types and amounts of pollutants that will be discharged into the water. (27) Response: See Response to Water Resources Comment 1. Comment 3: The DEIS should evaluate ways in which water consumption can be minimized including options for recycling. (3, 32) Response: See Response to Water Resources Comment 1. Comment 4: The volume of water and the contents of wastewater including, but not limited to known hazardous waste products/chemicals must be identified, including, the various expected contents of the water must be specified, including hazardous materials, even if the weights and the volumes are not known. (27, 28, 32) Response: See Response to Water Resources Comment 1. Comment 5: Questions were raised about the industrial wastewater, including how it will be treated and monitored. (5, 28, 30, 31) Response: See Response to Water Resources Comment 1. Comment 6: Concerns were raised about the massive use of water and potential impacts to water resources. (2, 3, 26, 30, 31, 32) Response: The Scope has been revised to indicate that the DEIS will include additional description of Micron’s proposed consumption of water and generation of wastewater and how those volumes will be minimized as well as managed and coordinated with County infrastructure. Comment 2: The DEIS must describe the types and amounts of pollutants that will be discharged into the water. (27) Response: See Response to Water Resources Comment 1. Comment 3: The DEIS should evaluate ways in which water consumption can be minimized including options for recycling. (3, 32) Response: See Response to Water Resources Comment 1. Comment 4: The volume of water and the contents of wastewater including, but not limited to known hazardous waste products/chemicals must be identified, including, the various expected contents of the water must be specified, including hazardous materials, even if the weights and the volumes are not known. (27, 28, 32) Response: See Response to Water Resources Comment 1. Comment 5: Questions were raised about the industrial wastewater, including how it will be treated and monitored. (5, 28, 30, 31) Response: See Response to Water Resources Comment 1. Comment 6: Concerns were raised about the massive use of water and potential impacts to water resources. (2, 3, 26, 30, 31, 32) Response: The Scope indicates that the DEIS will evaluate potential impacts to water resources. Comment 7: The public must be assured that the public water drinking supply will never be compromised to accommodate water use by the Micron plant. (32) Response: Comment noted. Comment 8: Questions were posed regarding safeguards and monitoring for wastewater leaving the Micron facility. (5, 27, 28, 30, 31) 12/14/23 22 96 Response: The Scope indicates that the DEIS will discuss applicable permitting, monitoring, and reporting obligations associated with wastewater. Ecological Communities and Wildlife Comment 1: Public comments raised concerns of the potentials impacts to wildlife and habitat on and around the site, specifically to birds, butterflies and other animals native to the site. (19, 21, 22, 23, 26, 28, 29, 30, 31) Response: The Scope indicates that potential adverse impacts to these natural resources will be addressed in the DEIS. Comment 2: Native plants should be considered as part of mitigation plans instead of typical ornamentals. (19) Response: The Scope indicates that the DEIS will consider use of native plants as mitigation where necessary and if appropriate. Response: The Scope indicates that the DEIS will evaluate potential impacts to water resources. Comment 7: The public must be assured that the public water drinking supply will never be compromised to accommodate water use by the Micron plant. (32) Response: Comment noted. Comment 8: Questions were posed regarding safeguards and monitoring for wastewater leaving the Micron facility. (5, 27, 28, 30, 31) 12/14/23 22 96 Response: The Scope indicates that the DEIS will discuss applicable permitting, monitoring, and reporting obligations associated with wastewater. Ecological Communities and Wildlife Comment 1: Public comments raised concerns of the potentials impacts to wildlife and habitat on and around the site, specifically to birds, butterflies and other animals native to the site. (19, 21, 22, 23, 26, 28, 29, 30, 31) Response: The Scope indicates that potential adverse impacts to these natural resources will be addressed in the DEIS. Comment 2: Native plants should be considered as part of mitigation plans instead of typical ornamentals. (19) Response: The Scope indicates that the DEIS will consider use of native plants as mitigation where necessary and if appropriate. Solid Waste Comment 1: Public comments submitted raised questions about solid waste and the amount of materials that would be used at the site, and what the process would be to dispose of the waste. (3, 26, 28, 32,) Response: The Scope indicates that the DEIS will evaluate solid waste generation from the Proposed Project, including proposed management, impacts to resources, as well as proposed mitigation strategies, including recycling to reduce waste stream volumes. Hazardous Materials & Hazardous Waste Comment 1: Public comments raised concerns about hazardous materials being transported to and from the site, along with how Micron plans to dispose of such materials. Comments mentioned the use of PFAS as it relates to the semiconductor industry more broadly. Comments requested more information about the use of PFAS and the potential effect on communities and the environment. Comments also expressed interest in further analysis as it relates to the materials that will be used at the site and how risks will be avoided or mitigated with respect to those materials. (3, 4, 9, 23, 26, 28, 32) Response: See Response to NYSDEC Comment 22. Comment 2: Comments requested that the DEIS identify any hazardous materials, including chemical or petroleum bulk storage that would be used towards transport or generated by the proposed project and measures to protect against releases to the environment. (4, 30, 31) Solid Waste Comment 1: Public comments submitted raised questions about solid waste and the amount of materials that would be used at the site, and what the process would be to dispose of the waste. (3, 26, 28, 32,) Response: The Scope indicates that the DEIS will evaluate solid waste generation from the Proposed Project, including proposed management, impacts to resources, as well as proposed mitigation strategies, including recycling to reduce waste stream volumes. Hazardous Materials & Hazardous Waste Comment 1: Public comments raised concerns about hazardous materials being transported to and from the site, along with how Micron plans to dispose of such materials. Comments mentioned the use of PFAS as it relates to the semiconductor industry more broadly. Comments requested more information about the use of PFAS and the potential effect on communities and the environment. Comments also expressed interest in further analysis as it relates to the materials that will be used at the site and how risks will be avoided or mitigated with respect to those materials. (3, 4, 9, 23, 26, 28, 32) Response: See Response to NYSDEC Comment 22. Comment 2: Comments requested that the DEIS identify any hazardous materials, including chemical or petroleum bulk storage that would be used towards transport or generated by the proposed project and measures to protect against releases to the environment. (4, 30, 31) 12/14/23 23 97 Response: See Response to NYSDEC Comment 22. The Scope has been revised to indicate that the Project Description in the DEIS must further illustrate Micron’s intended use, management, and conservation of water, chemicals, and energy. Transportation Comment 1: A commenter provided that “The importance of I-81 is recognized for its impact in the draft scoping document. The majority of the Micron Campus is contained within the Town of Clay, Onondaga County, New York and is accessible from I-81 from an interchange with NYS Route 31 (see Figure 1). OCIDA deemed the Radisson Corporate Park as an unviable choice because it lacked . . . specific advantages such as the proximity to Interstates 81 and 481. The draft scoping document notes that the lack of “access to multi-modal transportation” is often a point of failure for most other sites. Changes to I-81 should be evaluated for potential adverse impacts on the Micron Development." (16) 12/14/23 23 97 Response: See Response to NYSDEC Comment 22. The Scope has been revised to indicate that the Project Description in the DEIS must further illustrate Micron’s intended use, management, and conservation of water, chemicals, and energy. Transportation Comment 1: A commenter provided that “The importance of I-81 is recognized for its impact in the draft scoping document. The majority of the Micron Campus is contained within the Town of Clay, Onondaga County, New York and is accessible from I-81 from an interchange with NYS Route 31 (see Figure 1). OCIDA deemed the Radisson Corporate Park as an unviable choice because it lacked . . . specific advantages such as the proximity to Interstates 81 and 481. The draft scoping document notes that the lack of “access to multi-modal transportation” is often a point of failure for most other sites. Changes to I-81 should be evaluated for potential adverse impacts on the Micron Development." (16) Response: The Scope indicates that the DEIS, in coordination with the New York State Department of Transportation (NYSDOT), will evaluate regional and local traffic conditions. The assessment of potential future traffic conditions will include potential I-81 modifications. The Scope has been revised to include additional detail on how the traffic and transportation study area has been defined through consultation with NYSDOT and SMTC and in recognition of modifications to I-81. Comment 2: Several additional public comments raised concerns about the potential for increased traffic on highways and roads in and around the project due to population growth and workforce commutes. Many commenters are concerned about impact to residents and listed areas directly around the Project Site, while others raised concerns about the regional traffic impact. (1, 2, 5, 7, 14, 15, 16, 17, 22, 26, 32) Response: The Scope indicates that the DEIS, in coordination with the New York State Department of Transportation (NYSDOT), will evaluate regional and local traffic conditions. The assessment of potential future traffic conditions will include potential I-81 modifications. The Scope has been revised to include additional detail on how the traffic and transportation study area has been defined through consultation with NYSDOT and SMTC and in recognition of modifications to I-81. Comment 2: Several additional public comments raised concerns about the potential for increased traffic on highways and roads in and around the project due to population growth and workforce commutes. Many commenters are concerned about impact to residents and listed areas directly around the Project Site, while others raised concerns about the regional traffic impact. (1, 2, 5, 7, 14, 15, 16, 17, 22, 26, 32) Response: In coordination with NYSDOT, Onondaga County, the Town of Clay, and the Town of Cicero, and as indicated in the Scope, the DEIS will include an assessment of traffic conditions at the regional and local levels. Input from the Syracuse Metropolitan Transportation Council (SMTC) is also being provided. The Scope has been revised to include additional detail on how the traffic and transportation study area has been defined through consultation with NYSDOT and SMTC and in recognition of modifications to I-81. See also response to Legislator Garland Comment 2. Comment 3: Many commenters requested that the DEIS analyze and provide details for the proposed traffic improvements. As part of this, certain potential traffic improvements were proposed to help alleviate the traffic of the current roads that exist now. (2, 8) Response: The Scope indicates that the DEIS will identify proposed transportation improvements and provide a schedule for when the improvements would be required. Comment 4: Comments raised safety concerns and questions about what improvements would be made. Many commenters are concerned about impact to residents and listed areas directly around Response: In coordination with NYSDOT, Onondaga County, the Town of Clay, and the Town of Cicero, and as indicated in the Scope, the DEIS will include an assessment of traffic conditions at the regional and local levels. Input from the Syracuse Metropolitan Transportation Council (SMTC) is also being provided. The Scope has been revised to include additional detail on how the traffic and transportation study area has been defined through consultation with NYSDOT and SMTC and in recognition of modifications to I-81. See also response to Legislator Garland Comment 2. Comment 3: Many commenters requested that the DEIS analyze and provide details for the proposed traffic improvements. As part of this, certain potential traffic improvements were proposed to help alleviate the traffic of the current roads that exist now. (2, 8) Response: The Scope indicates that the DEIS will identify proposed transportation improvements and provide a schedule for when the improvements would be required. Comment 4: Comments raised safety concerns and questions about what improvements would be made. Many commenters are concerned about impact to residents and listed areas directly around 12/14/23 24 98 the Project Site, while others raised concerns about the regional traffic impact. (3, 5, 13, 15, 16, 17, 20, 28, 29, 30) Response: See Response to Transportation Comments 1-3. Comment 5: Traffic must be evaluated in the context of existing and proposed infrastructure. (16) Response: See Response to Transportation Comments 1-3. Comment 6: “Significant adverse impacts could result in the assessment of environmental impacts from traffic if Automatic Traffic Recorder (ATR) counts and Vehicle Classification Counts (VCC) data sites are not added to collect data from sites in the City of Syracuse.” (16) Response: See Response to Transportation Comments 1-2. Comment 7: A question was raised regarding the proposed number of entrances to the campus as well as the traffic flow and routes for delivery trucks. (2, 5) Response: Details of proposed access points and circulation routes for employee vehicles and delivery vehicles will be described in the DEIS. Comment 8: Certain comments questioned the study area for traffic and whether additional areas to the south should be included. “There [are] no traffic counters utilized on I-481 at the NY Route 92/5 exchange nor in the City of Syracuse.” (15, 16) 12/14/23 24 98 the Project Site, while others raised concerns about the regional traffic impact. (3, 5, 13, 15, 16, 17, 20, 28, 29, 30) Response: See Response to Transportation Comments 1-3. Comment 5: Traffic must be evaluated in the context of existing and proposed infrastructure. (16) Response: See Response to Transportation Comments 1-3. Comment 6: “Significant adverse impacts could result in the assessment of environmental impacts from traffic if Automatic Traffic Recorder (ATR) counts and Vehicle Classification Counts (VCC) data sites are not added to collect data from sites in the City of Syracuse.” (16) Response: See Response to Transportation Comments 1-2. Comment 7: A question was raised regarding the proposed number of entrances to the campus as well as the traffic flow and routes for delivery trucks. (2, 5) Response: Details of proposed access points and circulation routes for employee vehicles and delivery vehicles will be described in the DEIS. Comment 8: Certain comments questioned the study area for traffic and whether additional areas to the south should be included. “There [are] no traffic counters utilized on I-481 at the NY Route 92/5 exchange nor in the City of Syracuse.” (15, 16) Response: See Response to Transportation Comments 1-2. The Scope has been revised to include additional detail on how the traffic and transportation study area has been defined through consultation with NYSDOT and SMTC and in recognition of modifications to I-81. The interchange of I-481 and NY Route 92/5 is included in the regional study area. Comment 9: The Trucking Association of New York commented that “[w]hile the Micron project itself may not have a negative impact on our industry, the additional vehicle traffic will. Put that increased vehicular traffic on a poorly designed interstate, and the results will be disastrous for our industry.” As additional context, the Trucking Association of New York attached its October 2021 comments on the I-81 Viaduct Project DEIS. (14) Response: See Response to Transportation Comment 1. Air Quality Comment 1: Public comments mentioned air quality as it relates to operations at the Proposed Project Site along with the air quality implications due to increased traffic and potential hazardous material. These comments requested additional detail on proposed air emissions, including mobile source emissions, and requested that air quality impacts be evaluated in the context of the existing 12/14/23 25 99 Response: See Response to Transportation Comments 1-2. The Scope has been revised to include additional detail on how the traffic and transportation study area has been defined through consultation with NYSDOT and SMTC and in recognition of modifications to I-81. The interchange of I-481 and NY Route 92/5 is included in the regional study area. Comment 9: The Trucking Association of New York commented that “[w]hile the Micron project itself may not have a negative impact on our industry, the additional vehicle traffic will. Put that increased vehicular traffic on a poorly designed interstate, and the results will be disastrous for our industry.” As additional context, the Trucking Association of New York attached its October 2021 comments on the I-81 Viaduct Project DEIS. (14) Response: See Response to Transportation Comment 1. Air Quality Comment 1: Public comments mentioned air quality as it relates to operations at the Proposed Project Site along with the air quality implications due to increased traffic and potential hazardous material. These comments requested additional detail on proposed air emissions, including mobile source emissions, and requested that air quality impacts be evaluated in the context of the existing 12/14/23 25 99 and proposed infrastructure” and, “Air quality should be monitored at all the traffic locations.” (16, 17, 32, 36) Response: See Response to NYSDEC Comment 24. The Scope indicates that the DEIS will include assessment of mobile source and stationary source emissions from the Proposed Project. Mobile source emissions are primarily generated from additional vehicular traffic during both construction and operations. Stationary source emissions are generated from operation of the proposed Fabs. The Scope notes that a stationary source air pollution control permit for the new manufacturing facilities will be required. The air pollution control permit application will include evaluation of pollutants subject to the National Ambient Air Quality Standards (NAAQS), New York air toxic control and ambient air requirements, and a Climate Leadership and Community Protection Act (CLCPA) greenhouse gas evaluation. The Scope indicates that the DEIS will summarize these detailed air quality modeling and impact assessment analyses that will be prepared to support the air pollution control permitting process. and proposed infrastructure” and, “Air quality should be monitored at all the traffic locations.” (16, 17, 32, 36) Response: See Response to NYSDEC Comment 24. The Scope indicates that the DEIS will include assessment of mobile source and stationary source emissions from the Proposed Project. Mobile source emissions are primarily generated from additional vehicular traffic during both construction and operations. Stationary source emissions are generated from operation of the proposed Fabs. The Scope notes that a stationary source air pollution control permit for the new manufacturing facilities will be required. The air pollution control permit application will include evaluation of pollutants subject to the National Ambient Air Quality Standards (NAAQS), New York air toxic control and ambient air requirements, and a Climate Leadership and Community Protection Act (CLCPA) greenhouse gas evaluation. The Scope indicates that the DEIS will summarize these detailed air quality modeling and impact assessment analyses that will be prepared to support the air pollution control permitting process. Comment 2: The public must be informed now regarding the amounts and types of air pollutants released by current Micron industrial facilities and expected to be released/emitted by the proposed Clay plant. (32) Response: See Response to NYSDEC Comment 24. Comment 3: Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipment to respond safely to such releases. (28) Response: Comment Noted. Comment 4: Employees should be warned about the toxicity of gases used by the industry and trained to protect themselves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity.” (28) Response: Comment noted. Greenhouse Gas Emissions and Climate Change Comment 1: Public comments noted that the use of natural gas seems inconsistent with New York State’s Climate Leadership and Community Protection Act (CLPCA) greenhouse gas (GHG) reduction goals. (10, 20, 23) Response: See Responses to NYSDEC Comments 29-31. Comment 2: Members of the public provided comments about GHGs. (10, 20, 35) 12/14/23 26 100 Comment 2: The public must be informed now regarding the amounts and types of air pollutants released by current Micron industrial facilities and expected to be released/emitted by the proposed Clay plant. (32) Response: See Response to NYSDEC Comment 24. Comment 3: Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipment to respond safely to such releases. (28) Response: Comment Noted. Comment 4: Employees should be warned about the toxicity of gases used by the industry and trained to protect themselves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity.” (28) Response: Comment noted. Greenhouse Gas Emissions and Climate Change Comment 1: Public comments noted that the use of natural gas seems inconsistent with New York State’s Climate Leadership and Community Protection Act (CLPCA) greenhouse gas (GHG) reduction goals. (10, 20, 23) Response: See Responses to NYSDEC Comments 29-31. Comment 2: Members of the public provided comments about GHGs. (10, 20, 35) 12/14/23 26 100 Response: The Scope indicates that the DEIS will assess the Proposed Project’s potential emission of GHGs and the measures proposed to avoid, minimize and mitigate any impacts. Comment 3: “Semiconductors have a carbon problem. The public should be informed about the plan to prevent fluorocarbons from being introduced to our local air.” (9) Response: See Response to Greenhouse Gas and Climate Change Comments 1 and 2. Comment 4: “Interested to learn about the impact of embodied carbon as well as operational carbon in both the Micron plant and the associated growth.” (6) Response: See Response to Greenhouse Gas and Climate Change Comments 1 and 2. Comment 5: Methane is a much more potent greenhouse gas than CO2. (10) Response: Comment noted. Comment 6: “The current plans for powering the Micron facility in Clay, NY, while looking good on paper, will in fact increase emissions on energy used to supply the Micron facility... The reality is that Micron is going to be powered by Fossil Fuel Generation that is transmitted over long distances, very likely from out of state in Pennsylvania or Ohio that have generation carbon footprints far higher than those in NY State. As GHG emissions are not cognizant of political boundaries on a map, those emissions will end up affecting NY State residents.” (14) Response: Comment noted. Response: The Scope indicates that the DEIS will assess the Proposed Project’s potential emission of GHGs and the measures proposed to avoid, minimize and mitigate any impacts. Comment 3: “Semiconductors have a carbon problem. The public should be informed about the plan to prevent fluorocarbons from being introduced to our local air.” (9) Response: See Response to Greenhouse Gas and Climate Change Comments 1 and 2. Comment 4: “Interested to learn about the impact of embodied carbon as well as operational carbon in both the Micron plant and the associated growth.” (6) Response: See Response to Greenhouse Gas and Climate Change Comments 1 and 2. Comment 5: Methane is a much more potent greenhouse gas than CO2. (10) Response: Comment noted. Comment 6: “The current plans for powering the Micron facility in Clay, NY, while looking good on paper, will in fact increase emissions on energy used to supply the Micron facility... The reality is that Micron is going to be powered by Fossil Fuel Generation that is transmitted over long distances, very likely from out of state in Pennsylvania or Ohio that have generation carbon footprints far higher than those in NY State. As GHG emissions are not cognizant of political boundaries on a map, those emissions will end up affecting NY State residents.” (14) Response: Comment noted. Comment 7: “There are also possibilities for using the CO2 emissions of the generating facility for agricultural purposes, further reducing the carbon footprint of the plant.” (14) Response: Comment noted. Noise & Vibration Comment 1: Several public comments referred to concerns about noise & vibration from construction and operation, including noise from increased traffic. (8, 19, 29) Response: The Scope indicates that the DEIS will include assessment of noise and vibration generated by construction and operations of the Proposed Project, including from increased vehicular traffic. Utilities and Infrastructure Comment 1: One comment requests that the process for wastewater be described. Response: The Scope indicates that the DEIS will describe the manner in which wastewater will be treated. 12/14/23 27 101 Comment 2: There needs to be better definition of the assessment of potential impacts on infrastructure (water, stormwater, sanitary sewer, electrical and telecommunications) will be assessed. Response: The Scope indicates that the DEIS will include an assessment of potential adverse impacts on utilities and infrastructure due to demand associated with the Proposed Project. Comment 7: “There are also possibilities for using the CO2 emissions of the generating facility for agricultural purposes, further reducing the carbon footprint of the plant.” (14) Response: Comment noted. Noise & Vibration Comment 1: Several public comments referred to concerns about noise & vibration from construction and operation, including noise from increased traffic. (8, 19, 29) Response: The Scope indicates that the DEIS will include assessment of noise and vibration generated by construction and operations of the Proposed Project, including from increased vehicular traffic. Utilities and Infrastructure Comment 1: One comment requests that the process for wastewater be described. Response: The Scope indicates that the DEIS will describe the manner in which wastewater will be treated. 12/14/23 27 101 Comment 2: There needs to be better definition of the assessment of potential impacts on infrastructure (water, stormwater, sanitary sewer, electrical and telecommunications) will be assessed. Response: The Scope indicates that the DEIS will include an assessment of potential adverse impacts on utilities and infrastructure due to demand associated with the Proposed Project. Comment 3: The release of toxic contaminants through water pathways is one of the most serious threats of semiconductor productions. Releases of certain contaminants in wastewater could compromise the operations of the Oak Orchard Wastewater Treatment Plant, even undermining compliance with its discharge permit. Response: The Scope indicates that the DEIS will include an assessment of impacts from wastewater discharges from the Proposed Project. Comment 4: Industrial pre-treatment must be described in the DEIS and should include identification of identify ways to pre-treat hazardous chemicals, perhaps even reusing some, before comingling with other wastes. This is particularly important for PFAS, because in the future more PFAS compounds are likely to be subjected to enforceable environmental standards, many at very low concentrations.” (18) Response: The Scope indicates that the DEIS will include an assessment of impacts from wastewater discharges from the Proposed Project, and will include a description of industrial pretreatment at the Proposed Project. Comment 5: The DEIS needs to address parameters such as system capacity, level of service changes, fiscal implications for the community and impacts on water bodies. (16) Comment 3: The release of toxic contaminants through water pathways is one of the most serious threats of semiconductor productions. Releases of certain contaminants in wastewater could compromise the operations of the Oak Orchard Wastewater Treatment Plant, even undermining compliance with its discharge permit. Response: The Scope indicates that the DEIS will include an assessment of impacts from wastewater discharges from the Proposed Project. Comment 4: Industrial pre-treatment must be described in the DEIS and should include identification of identify ways to pre-treat hazardous chemicals, perhaps even reusing some, before comingling with other wastes. This is particularly important for PFAS, because in the future more PFAS compounds are likely to be subjected to enforceable environmental standards, many at very low concentrations.” (18) Response: The Scope indicates that the DEIS will include an assessment of impacts from wastewater discharges from the Proposed Project, and will include a description of industrial pretreatment at the Proposed Project. Comment 5: The DEIS needs to address parameters such as system capacity, level of service changes, fiscal implications for the community and impacts on water bodies. (16) Response: The Scope has been revised to indicate that the DEIS will include additional description of Micron’s proposed consumption of water and generation of wastewater and how those volumes will be managed and coordinated with County infrastructure. Comment 6: Impacts associated with the “natural gas main” that will be extended to the plant must be included in the DEIS. (30, 31) Response: The Scope has been revised to clarify that the DEIS will include assessment of all off-site improvements (water, wastewater, electricity, natural gas, telecommunications) in each of the relevant subject areas. Anticipated Use & Conservation of Energy Comment 1: “It is imperative to reduce emissions through clean energy usage initiatives and energy conservation projects.” (2,36) Response: Comment noted. 12/14/23 28 102 Comment 2: One comment questioned the impact of the Proposed Project on their energy bill and whether the Proposed Project will strain the grid and cause blackouts. (16) Response: The Scope has been revised to indicate that the DEIS will include additional description on Micron’s proposed use and conservation of energy (including provisions for renewable energy sources). Response: The Scope has been revised to indicate that the DEIS will include additional description of Micron’s proposed consumption of water and generation of wastewater and how those volumes will be managed and coordinated with County infrastructure. Comment 6: Impacts associated with the “natural gas main” that will be extended to the plant must be included in the DEIS. (30, 31) Response: The Scope has been revised to clarify that the DEIS will include assessment of all off-site improvements (water, wastewater, electricity, natural gas, telecommunications) in each of the relevant subject areas. Anticipated Use & Conservation of Energy Comment 1: “It is imperative to reduce emissions through clean energy usage initiatives and energy conservation projects.” (2,36) Response: Comment noted. 12/14/23 28 102 Comment 2: One comment questioned the impact of the Proposed Project on their energy bill and whether the Proposed Project will strain the grid and cause blackouts. (16) Response: The Scope has been revised to indicate that the DEIS will include additional description on Micron’s proposed use and conservation of energy (including provisions for renewable energy sources). Comment 3: Additional detail was requested on the anticipated energy needs of this project which were noted to be enormous. (20,23) Response: The DEIS will describe the Proposed Project’s energy needs. Comment 4: “Electrical consumption is anticipated to be 16 billion kilowatt-hours of electricity per year, when fully built. (Phase 2, Envir. Assessment Form, Part 1, Section K) To put this in perspective, this is equivalent to all of the electricity consumed by the states of New Hampshire and Vermont, combined. The entire state of New York used 143 billion kWh of energy in 2022. Micron will increase demand in NY by 11%.” (20,23) Response: Comment noted. Comment 5: Questions were raised regarding the type and source of energy to be used by the Proposed Project. (10, 11, 16, 22) Response: See Response to Anticipated Use and Conservation of Energy Comment 2. Comment 6: Commenters requested consideration of various sources of electricity, including those that are currently available, and whose which may become available as the plant is constructed. Response: See Response to NYSDEC Comment 5; Response to Anticipated Use and Conservation of Energy Comment 2. Comment 7: The DEIS must evaluate the ability of current power lines owned and operated by National Grid to deliver the required power. (30) Response: See Response to Anticipated Use and Conservation of Energy Comment 2. Comment 3: Additional detail was requested on the anticipated energy needs of this project which were noted to be enormous. (20,23) Response: The DEIS will describe the Proposed Project’s energy needs. Comment 4: “Electrical consumption is anticipated to be 16 billion kilowatt-hours of electricity per year, when fully built. (Phase 2, Envir. Assessment Form, Part 1, Section K) To put this in perspective, this is equivalent to all of the electricity consumed by the states of New Hampshire and Vermont, combined. The entire state of New York used 143 billion kWh of energy in 2022. Micron will increase demand in NY by 11%.” (20,23) Response: Comment noted. Comment 5: Questions were raised regarding the type and source of energy to be used by the Proposed Project. (10, 11, 16, 22) Response: See Response to Anticipated Use and Conservation of Energy Comment 2. Comment 6: Commenters requested consideration of various sources of electricity, including those that are currently available, and whose which may become available as the plant is constructed. Response: See Response to NYSDEC Comment 5; Response to Anticipated Use and Conservation of Energy Comment 2. Comment 7: The DEIS must evaluate the ability of current power lines owned and operated by National Grid to deliver the required power. (30) Response: See Response to Anticipated Use and Conservation of Energy Comment 2. Comment 8: One commenter questioned whether Micron stated its goal “to achieve 100% renewable energy for existing U.S. operations by the end of 2025” applies to the proposed facility. (10) Response: See Response to Anticipated Use and Conservation of Energy Comment 2. Construction Comment 1: Several public comments referred to concerns about construction, specifically the use of heavy duty equipment and expected constructed related vehicular trips. (1, 13, 24) 12/14/23 29 103 Response: The Scope indicates that the DEIS will include evaluation of traffic conditions and potential adverse impacts during the construction of the Proposed Project. Specific analysis of traffic and traffic-related air quality and noise during construction will be identified and assessed in the DEIS, including potential mitigation options to address any adverse impacts. Permits Comment 1: “The SEQRA review should list all anticipated permitting processes, with the anticipated schedule of public comment periods, and it should require public notification to interested parties of each permit application as it is submitted.” (18) Comment 8: One commenter questioned whether Micron stated its goal “to achieve 100% renewable energy for existing U.S. operations by the end of 2025” applies to the proposed facility. (10) Response: See Response to Anticipated Use and Conservation of Energy Comment 2. Construction Comment 1: Several public comments referred to concerns about construction, specifically the use of heavy duty equipment and expected constructed related vehicular trips. (1, 13, 24) 12/14/23 29 103 Response: The Scope indicates that the DEIS will include evaluation of traffic conditions and potential adverse impacts during the construction of the Proposed Project. Specific analysis of traffic and traffic-related air quality and noise during construction will be identified and assessed in the DEIS, including potential mitigation options to address any adverse impacts. Permits Comment 1: “The SEQRA review should list all anticipated permitting processes, with the anticipated schedule of public comment periods, and it should require public notification to interested parties of each permit application as it is submitted.” (18) Response: Section 6 of the Scope lists the Federal, State, and local agencies with which Micron would coordinate on the Proposed Project and a preliminary list of anticipated permits that would be required to construct and operate the Proposed Project. The status, and contents, of draft permit applications would be made available, as applicable, as appendices to the DEIS. When OCIDA releases the DEIS for public review, it will announce the schedule for public comment and notifications will be distributed in accordance with applicable rules and regulations. A forecasted date for the commencement of construction will be included in the DEIS. Cumulative Impacts Comment 1: “The use of the word ‘summarize’ to describe the scope of this Chapter is insufficient. This Chapter must assess indirect and cumulative impacts of the proposed project for each of the technical areas included in the DEIS. If these effects are included elsewhere it may be appropriate to summarize them here. Let’s be clear about exactly what is required to be included in the DEIS.” (20, 23) Response: Section 6 of the Scope lists the Federal, State, and local agencies with which Micron would coordinate on the Proposed Project and a preliminary list of anticipated permits that would be required to construct and operate the Proposed Project. The status, and contents, of draft permit applications would be made available, as applicable, as appendices to the DEIS. When OCIDA releases the DEIS for public review, it will announce the schedule for public comment and notifications will be distributed in accordance with applicable rules and regulations. A forecasted date for the commencement of construction will be included in the DEIS. Cumulative Impacts Comment 1: “The use of the word ‘summarize’ to describe the scope of this Chapter is insufficient. This Chapter must assess indirect and cumulative impacts of the proposed project for each of the technical areas included in the DEIS. If these effects are included elsewhere it may be appropriate to summarize them here. Let’s be clear about exactly what is required to be included in the DEIS.” (20, 23) Response: The Scope has been revised to indicate that the “Cumulative Impacts” chapter will consider any significant adverse impacts resulting from the incremental impact of the Proposed Project when added to other past, present, and reasonably foreseeable future actions. Each of the technical areas of the DEIS will address direct and indirect effects of the Proposed Project and off-site improvements. Growth Inducing Aspects Comment 1: Onondaga Audubon commented on Housing & Development that “the region outside of the project's direct footprint will be modified in order to support influx of as many as 100,000 new residents. Zoning maps have already been changed to increase the amount of land available to be developed for housing.” (21) Response: Comment noted. Comment 2: The DEIS should include an analysis of the potential for growth-induced changes in the community that this project will induce.” (32, 35) 12/14/23 30 104 Response: The Scope has been revised to indicate that the “Cumulative Impacts” chapter will consider any significant adverse impacts resulting from the incremental impact of the Proposed Project when added to other past, present, and reasonably foreseeable future actions. Each of the technical areas of the DEIS will address direct and indirect effects of the Proposed Project and off-site improvements. Growth Inducing Aspects Comment 1: Onondaga Audubon commented on Housing & Development that “the region outside of the project's direct footprint will be modified in order to support influx of as many as 100,000 new residents. Zoning maps have already been changed to increase the amount of land available to be developed for housing.” (21) Response: Comment noted. Comment 2: The DEIS should include an analysis of the potential for growth-induced changes in the community that this project will induce.” (32, 35) 12/14/23 30 104 Response: The Scope indicates that the DEIS will include an assessment of potential growth- inducing effects of the Proposed Project. This assessment will evaluate projected growth in traffic as a result of new residential development and any noise or air quality impacts associated with that increase in traffic. Comment 3: Commenters note that the Proposed Project will cause an increase in demand for new housing and questioned the necessary capacity as well as the potential environmental impacts. (19) Response: The Scope indicates that the DEIS will include an assessment of potential growth- inducing effects of the Proposed Project. This assessment will evaluate projected growth in traffic as a result of new residential development and any noise or air quality impacts associated with that increase in traffic. Comment 3: Commenters note that the Proposed Project will cause an increase in demand for new housing and questioned the necessary capacity as well as the potential environmental impacts. (19) Response: The location of any development of new housing within the Central New York region in response to any demand generated by Micron employment is unknown at this time and outside of Micron’s control. It is therefore beyond the scope of this environmental review. Notwithstanding, any such new development would be subject to local comprehensive planning policies and zoning laws and regulations and require separate approvals pursuant to those local laws, regulations, and policies. The Scope indicates that the DEIS will evaluate projected growth in traffic as a result of new residential development and any noise or air quality impacts associated with that increase in traffic. The Scope also indicates that the DEIS will evaluate potential indirect impacts to community facilities and services as a result of projected residential population growth (see above). Comment 4: “This is going to affect the housing market, are there any plans in order to ease this transition or combat this? (28) Response: See Response to Growth Inducing Comment 3. Comment 5: “With new jobs and housing comes increased traffic and therefore noise and air pollution. What impact will this have on residents’ health and how will it be mitigated?” (19, 27) Response: The location of any development of new housing within the Central New York region in response to any demand generated by Micron employment is unknown at this time and outside of Micron’s control. It is therefore beyond the scope of this environmental review. Notwithstanding, any such new development would be subject to local comprehensive planning policies and zoning laws and regulations and require separate approvals pursuant to those local laws, regulations, and policies. The Scope indicates that the DEIS will evaluate projected growth in traffic as a result of new residential development and any noise or air quality impacts associated with that increase in traffic. The Scope also indicates that the DEIS will evaluate potential indirect impacts to community facilities and services as a result of projected residential population growth (see above). Comment 4: “This is going to affect the housing market, are there any plans in order to ease this transition or combat this? (28) Response: See Response to Growth Inducing Comment 3. Comment 5: “With new jobs and housing comes increased traffic and therefore noise and air pollution. What impact will this have on residents’ health and how will it be mitigated?” (19, 27) Response: See Response to Growth Inducing Comment 2. Other Comment 1: Many commenters asserted that the NYSDOT’s environmental review of the I-81 project was inadequate and that similar mistakes should not be made for the Proposed Project. (14, 15, 16, 33) Response: Comment noted. The I-81 project is a separate and distinct project. Comment 2: “Onondaga County health care facilities, in particular our hospitals, were short-staffed even before the Coronavirus pandemic. Waiting times and bed shortages were unfortunately highlighted by Covid-19 cases and have continued. What improvements in the healthcare system are proposed to remedy these shortcomings in view of the expectation of potentially thousands of new residents to work at and/or serve the Micron plant.” (36) Response: An assessment of impact on health care and the hospital system is beyond the scope of the environmental review of the Proposed Project. 12/14/23 31 105 Comment 3: “Demand new housing have walkable community parks that exceed the WHO recommendation of green space per person, and demand current brownfield sites be the priority sites of new development.” (29, 31) Response: See Response to Growth Inducing Comment 2. Other Comment 1: Many commenters asserted that the NYSDOT’s environmental review of the I-81 project was inadequate and that similar mistakes should not be made for the Proposed Project. (14, 15, 16, 33) Response: Comment noted. The I-81 project is a separate and distinct project. Comment 2: “Onondaga County health care facilities, in particular our hospitals, were short-staffed even before the Coronavirus pandemic. Waiting times and bed shortages were unfortunately highlighted by Covid-19 cases and have continued. What improvements in the healthcare system are proposed to remedy these shortcomings in view of the expectation of potentially thousands of new residents to work at and/or serve the Micron plant.” (36) Response: An assessment of impact on health care and the hospital system is beyond the scope of the environmental review of the Proposed Project. 12/14/23 31 105 Comment 3: “Demand new housing have walkable community parks that exceed the WHO recommendation of green space per person, and demand current brownfield sites be the priority sites of new development.” (29, 31) Response: The specific development of new housing within the Central New York region in response to any demand generated by Micron employment is unknown at this time and outside of Micron’s control. The Scope indicates that impacts from induced demand will be considered in the DEIS. . Comment 4: “It just brought, and I sort of a thought to myself to make sure that the scope does consider and focus and put ample attention towards the rail line. I'm not sure if the current CSX line that is moving across 31 is a part of what would be an increase in that rail traffic because of -- if that movement happened with that grant and that played out in (unintelligible). But I just want to, you know, make sure that the scope looks at the rail lines and the impact of the rail service and of an increase in that surface as we move forward here in the future generation. Thank you.” (12) Response: The Scope has been revised to indicate that the DEIS will address the existing CSX rail line adjacent to WPCP and its potential use to support construction of the Proposed Project and reduce construction truck traffic. Potential air quality and noise impacts of additional rail traffic along the CSX rail line would also be considered in the DEIS. Comment 5: The use of rail was encouraged to mitigate transportation impacts. (35) Response: The specific development of new housing within the Central New York region in response to any demand generated by Micron employment is unknown at this time and outside of Micron’s control. The Scope indicates that impacts from induced demand will be considered in the DEIS. . Comment 4: “It just brought, and I sort of a thought to myself to make sure that the scope does consider and focus and put ample attention towards the rail line. I'm not sure if the current CSX line that is moving across 31 is a part of what would be an increase in that rail traffic because of -- if that movement happened with that grant and that played out in (unintelligible). But I just want to, you know, make sure that the scope looks at the rail lines and the impact of the rail service and of an increase in that surface as we move forward here in the future generation. Thank you.” (12) Response: The Scope has been revised to indicate that the DEIS will address the existing CSX rail line adjacent to WPCP and its potential use to support construction of the Proposed Project and reduce construction truck traffic. Potential air quality and noise impacts of additional rail traffic along the CSX rail line would also be considered in the DEIS. Comment 5: The use of rail was encouraged to mitigate transportation impacts. (35) Response: Comment noted. Comment 6: Several comments raised concerns about transit options in the area and how those options would be addressed for workers and commuters who will be working at the site. Commenters also encouraged prioritizing bike, and pedestrian access to the site. (29, 31, 32) Response: The Scope has been revised to indicate that the DEIS, in coordination with the Central New York Regional Transportation Authority (Centro), will identify potential adverse impacts to transit service caused by the Proposed Project and modifications and expansion to transit service that may be required to address those impact and address the need for such services caused by the Proposed Project. Comment 7: “The only mitigation measures mentioned in this section are improvements to roadways. It is imperative that the utilization of public transportation, including mass transit by bus and light rail, be considered.” (32) Response: See Response to Other Comment 6. Comment 8: It should be noted that the Community Grid Plan is subject to a court order requiring the need for additional diligence related to the Micron development among other factors.” (17) 12/14/23 32 106 Response: See Response to Other Comment 1. Response: Comment noted. Comment 6: Several comments raised concerns about transit options in the area and how those options would be addressed for workers and commuters who will be working at the site. Commenters also encouraged prioritizing bike, and pedestrian access to the site. (29, 31, 32) Response: The Scope has been revised to indicate that the DEIS, in coordination with the Central New York Regional Transportation Authority (Centro), will identify potential adverse impacts to transit service caused by the Proposed Project and modifications and expansion to transit service that may be required to address those impact and address the need for such services caused by the Proposed Project. Comment 7: “The only mitigation measures mentioned in this section are improvements to roadways. It is imperative that the utilization of public transportation, including mass transit by bus and light rail, be considered.” (32) Response: See Response to Other Comment 6. Comment 8: It should be noted that the Community Grid Plan is subject to a court order requiring the need for additional diligence related to the Micron development among other factors.” (17) 12/14/23 32 106 Response: See Response to Other Comment 1. Comment 9: Some comments questioned the use of the terminology “100 percent renewable energy.” (10, 11, 22) Response: Comment noted. Comment 10: News reports have indicated that Micron has not committed to the huge expense of building a second water supply system from Lake Ontario in order to serve its industrial needs. The taxpayers of Onondaga County should not pay for this water supply system. This new system amounts to a dedicated supply for the Clay Micron plant.” (36) Response: Comment noted. Comment 11: The City of Syracuse should be considered an interested agency. (31, 32) Response: The Scope has been revised to include the City of Syracuse as an interested agency. Comment 12: The DEIS should include a chapter for Wastewater and Stormwater. Response: See Response to NYSDEC Comment 1. Comment 13: A detailed assessment of the expected numbers of cancers and other pollutant-related illnesses based on air emissions, water discharge, and hazardous solid waste from the plant must be identified as part of the DEIS. (24) Response: The Scope has been revised to indicate that the DEIS will include an assessment of potential adverse health impacts associated with air emissions and the use and disposal of hazardous waste from the facility. Comment 14: “Micron is to be commended for committing itself to a large degree of sustainability, but what is actually achievable?” (3) Comment 9: Some comments questioned the use of the terminology “100 percent renewable energy.” (10, 11, 22) Response: Comment noted. Comment 10: News reports have indicated that Micron has not committed to the huge expense of building a second water supply system from Lake Ontario in order to serve its industrial needs. The taxpayers of Onondaga County should not pay for this water supply system. This new system amounts to a dedicated supply for the Clay Micron plant.” (36) Response: Comment noted. Comment 11: The City of Syracuse should be considered an interested agency. (31, 32) Response: The Scope has been revised to include the City of Syracuse as an interested agency. Comment 12: The DEIS should include a chapter for Wastewater and Stormwater. Response: See Response to NYSDEC Comment 1. Comment 13: A detailed assessment of the expected numbers of cancers and other pollutant-related illnesses based on air emissions, water discharge, and hazardous solid waste from the plant must be identified as part of the DEIS. (24) Response: The Scope has been revised to indicate that the DEIS will include an assessment of potential adverse health impacts associated with air emissions and the use and disposal of hazardous waste from the facility. Comment 14: “Micron is to be commended for committing itself to a large degree of sustainability, but what is actually achievable?” (3) Response: The Scope indicates that the DEIS will discuss sustainability measures that Micron intends to implement at its facility. 12/14/23 33 107 From: Audrey Fletcher Sent: Friday, October 20, 2023 8:36:29 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Micron Project: comments to Draft Scoping Document NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: Onondaga County Industrial Development Agency As a long-time resident of Syracuse, I have a few comments regarding the project’s EIS. First, it is thrilling that Micron is coming here. What an incredible opportunity for the region. I believe that Syracuse has been on a positive trajectory in recent years and Micron will strengthen that trajectory. But such an enormous project requires uncompromising commitment to monitor the impact it will have on the environment and on the community. The operation will use enormous amounts of water. What will be the long-term effect of such water demands? Is there a chance it could compromise this critical natural resource? Who will be responsible for maintaining the infrastructure? Response: The Scope indicates that the DEIS will discuss sustainability measures that Micron intends to implement at its facility. 12/14/23 33 107 From: Audrey Fletcher Sent: Friday, October 20, 2023 8:36:29 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Micron Project: comments to Draft Scoping Document NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: Onondaga County Industrial Development Agency As a long-time resident of Syracuse, I have a few comments regarding the project’s EIS. First, it is thrilling that Micron is coming here. What an incredible opportunity for the region. I believe that Syracuse has been on a positive trajectory in recent years and Micron will strengthen that trajectory. But such an enormous project requires uncompromising commitment to monitor the impact it will have on the environment and on the community. The operation will use enormous amounts of water. What will be the long-term effect of such water demands? Is there a chance it could compromise this critical natural resource? Who will be responsible for maintaining the infrastructure? Once the megafab is operational, there will be a huge demand for new housing. Do we have the capacity to build that much new housing? It will certainly be at the expense of farmland and forests. Would that be detrimental? 1 108 With new jobs and housing comes increased traffic and therefore noise and air pollution. What impact will this have on residents’ health and how will it be mitigated? Regarding traffic, I have real concern that eliminating I-81 through Syracuse would be a huge mistake. This route is heavily used now. Considering the potential for 9,000 new Micron jobs and 40,000 community jobs over 20 years, it makes no sense to eliminate a thru-route, especially one that connects to a potential source of workers. The viaduct should be rebuilt. It is fair and reasonable that residents of the region expect valid answers to these questions. Sincerely, Audrey Fletcher Audrey Fletcher Project & Resource Manager Once the megafab is operational, there will be a huge demand for new housing. Do we have the capacity to build that much new housing? It will certainly be at the expense of farmland and forests. Would that be detrimental? 1 108 With new jobs and housing comes increased traffic and therefore noise and air pollution. What impact will this have on residents’ health and how will it be mitigated? Regarding traffic, I have real concern that eliminating I-81 through Syracuse would be a huge mistake. This route is heavily used now. Considering the potential for 9,000 new Micron jobs and 40,000 community jobs over 20 years, it makes no sense to eliminate a thru-route, especially one that connects to a potential source of workers. The viaduct should be rebuilt. It is fair and reasonable that residents of the region expect valid answers to these questions. Sincerely, Audrey Fletcher Audrey Fletcher Project & Resource Manager 6756 Thompson Rd, Syracuse NY 13211 315-432-8905 p Precision Machining for Industry 2 109 110 111 112 113 114 115 116 From: Minchin G Lewis Sent: Friday, October 20, 2023 7:57:56 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: Minchin G Lewis Subject: Comments on the Draft Scoping Document for the Micron development NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: Onondaga County Industrial Development Agency ATTN: Micron Project I have attached a document with my comments regarding the draft scoping document for the Micron development. I hope they are helpful for this transformational project. Please let me know if there are questions or if any additional information is needed. Respectfully submitted, Minchin G Lewis, MPA, CGFM Adjunct Professor Maxwell School, Syracuse University 1 117 Department of Public Administration and International Affairs 6756 Thompson Rd, Syracuse NY 13211 315-432-8905 p Precision Machining for Industry 2 109 110 111 112 113 114 115 116 From: Minchin G Lewis Sent: Friday, October 20, 2023 7:57:56 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: Minchin G Lewis Subject: Comments on the Draft Scoping Document for the Micron development NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: Onondaga County Industrial Development Agency ATTN: Micron Project I have attached a document with my comments regarding the draft scoping document for the Micron development. I hope they are helpful for this transformational project. Please let me know if there are questions or if any additional information is needed. Respectfully submitted, Minchin G Lewis, MPA, CGFM Adjunct Professor Maxwell School, Syracuse University 1 117 Department of Public Administration and International Affairs 315 Maxwell Hall Syracuse New York 13244-1020 (315) 443-4000 FAX: (315) 443-9721 Cell: (315) 243-2530 2 118 To: Onondaga County Industrial Development Agency (OCIDA) From: Minchin G. Lewis Re: Comments on the Micron Draft Scoping Document Date: October 20, 2023 Introducfion: The Micron proposal has created more potenfial for the Central New York Community than we have seen in the past 50 years. These comments are designed to enhance the substanfial contribufion that Micron is making to this community and to both ensure that environmental impacts are mifigated and that the intended outcomes are maximized. Please note that I support the planned Micron development. These comments are being submifted to be considered in the preparafion of the final scope of the EIS and may inform the related technical analyses and environmental resources to be evaluated. They are limited in content to comments on the potenfial significant adverse impacts that should be addressed in the preparafion of the EIS. 315 Maxwell Hall Syracuse New York 13244-1020 (315) 443-4000 FAX: (315) 443-9721 Cell: (315) 243-2530 2 118 To: Onondaga County Industrial Development Agency (OCIDA) From: Minchin G. Lewis Re: Comments on the Micron Draft Scoping Document Date: October 20, 2023 Introducfion: The Micron proposal has created more potenfial for the Central New York Community than we have seen in the past 50 years. These comments are designed to enhance the substanfial contribufion that Micron is making to this community and to both ensure that environmental impacts are mifigated and that the intended outcomes are maximized. Please note that I support the planned Micron development. These comments are being submifted to be considered in the preparafion of the final scope of the EIS and may inform the related technical analyses and environmental resources to be evaluated. They are limited in content to comments on the potenfial significant adverse impacts that should be addressed in the preparafion of the EIS. Context: The Micron development is taking place at a fime when a plan proposed by the New York State Transportafion Department would change the traffic pafterns for over 100,000 daily travelers. NYS DOT’s I-81 Viaduct Project plan proposes to remove the porfion of I-81 through the city and replace it with a “Community Grid.” According to DOT’s plan, 60,000 vehicles would be diverted to what is now I-481. The remaining 40,000 vehicles would be diverted to city streets. The traffic, air quality, and social impacts for Micron must be evaluated in the context of the exisfing and proposed infrastructure. It should be noted that the Community Grid Plan is subject to a court order requiring the need for addifional diligence related to the Micron development1 among other factors. Comment 1: Significant adverse impacts could result in the assessment of environmental impacts from traffic if Automafic Traffic Recorder (ATR) counts and Vehicle Classificafion Counts (VCC) data sites are not added to collect data from sites in the City of Syracuse. Basis: 1. The NYS I-81 Viaduct Project would eliminate a porfion of I-81. If allowed to commence, the interstate roadway through the city would be replaced with a boulevard and series of city streets (the Community Grid). The elevated secfion of the roadway would be removed. This interstate highway currently is the direct link for traffic northbound on I-81 from areas south of Context: The Micron development is taking place at a fime when a plan proposed by the New York State Transportafion Department would change the traffic pafterns for over 100,000 daily travelers. NYS DOT’s I-81 Viaduct Project plan proposes to remove the porfion of I-81 through the city and replace it with a “Community Grid.” According to DOT’s plan, 60,000 vehicles would be diverted to what is now I-481. The remaining 40,000 vehicles would be diverted to city streets. The traffic, air quality, and social impacts for Micron must be evaluated in the context of the exisfing and proposed infrastructure. It should be noted that the Community Grid Plan is subject to a court order requiring the need for addifional diligence related to the Micron development1 among other factors. Comment 1: Significant adverse impacts could result in the assessment of environmental impacts from traffic if Automafic Traffic Recorder (ATR) counts and Vehicle Classificafion Counts (VCC) data sites are not added to collect data from sites in the City of Syracuse. Basis: 1. The NYS I-81 Viaduct Project would eliminate a porfion of I-81. If allowed to commence, the interstate roadway through the city would be replaced with a boulevard and series of city streets (the Community Grid). The elevated secfion of the roadway would be removed. This interstate highway currently is the direct link for traffic northbound on I-81 from areas south of 1 News summary of the court decision: “A judge on Tuesday (2/14/2023) ruled that the process of the Interstate 81 project in Syracuse can confinue but no demolifion can take place unfil further environmental impact studies are conducted to address some deficiencies outlined in a lawsuit filed last fall by the group Renew 81 For All. State Supreme Court Jusfice Gerard Neri ruled the state Department of Transportafion must now account for potenfial regional traffic and populafion changes that the $100 billion Micron project will make in the coming years.” Accessed at hftps://spectrumlocalnews.com/nys/central-ny/traffic/2023/02/14/judge--further-environmental- impact-studies-must-be-done-on-i-81-project on 10/20/2023 119 OCIDA Micron EIS: Draft Scoping Document Comments Page 2 Minchin G. Lewis October 20, 2023 the I-81/I-481 northern interchange (Interchange 29). Some of the traffic bound for Micron would be adversely affected by the changes proposed in the I-81 Viaduct Project. (See Footnote 1 below). 1 News summary of the court decision: “A judge on Tuesday (2/14/2023) ruled that the process of the Interstate 81 project in Syracuse can confinue but no demolifion can take place unfil further environmental impact studies are conducted to address some deficiencies outlined in a lawsuit filed last fall by the group Renew 81 For All. State Supreme Court Jusfice Gerard Neri ruled the state Department of Transportafion must now account for potenfial regional traffic and populafion changes that the $100 billion Micron project will make in the coming years.” Accessed at hftps://spectrumlocalnews.com/nys/central-ny/traffic/2023/02/14/judge--further-environmental- impact-studies-must-be-done-on-i-81-project on 10/20/2023 119 OCIDA Micron EIS: Draft Scoping Document Comments Page 2 Minchin G. Lewis October 20, 2023 the I-81/I-481 northern interchange (Interchange 29). Some of the traffic bound for Micron would be adversely affected by the changes proposed in the I-81 Viaduct Project. (See Footnote 1 below). 2. The importance of I-81 is recognized for its impact in the draft scoping document. The majority of the Micron Campus is contained within the Town of Clay, Onondaga County, New York and is accessible from I-81 from an interchange with NYS Route 31 (see Figure 1) OCIDA deemed the Radisson Corporate Park as an unviable choice because it lacked . . . specific advantages such as the proximity to Interstates 81 and 481. The draft scoping document notes that the lack of “access to mulfi-modal transportafion” is often a point of failure for most other sites. Changes to I-81 should be evaluated for potenfial adverse impacts on the Micron development. 2. The importance of I-81 is recognized for its impact in the draft scoping document. The majority of the Micron Campus is contained within the Town of Clay, Onondaga County, New York and is accessible from I-81 from an interchange with NYS Route 31 (see Figure 1) OCIDA deemed the Radisson Corporate Park as an unviable choice because it lacked . . . specific advantages such as the proximity to Interstates 81 and 481. The draft scoping document notes that the lack of “access to mulfi-modal transportafion” is often a point of failure for most other sites. Changes to I-81 should be evaluated for potenfial adverse impacts on the Micron development. 3. Traffic issues potenfially affect environmental jusfice. Micron will operate three (3) shifts over a 24-hour day. Day and night shifts will be ufilized to sustain 24-hour manufacturing acfivifies as well as a maintenance shift. (1.1.2) Current projecfions for addifional housing to accommodate the economic growth related to Micron call for 2,000 to 2,500 residenfial living units per year for the next two decades. Onondaga County’s plan2 suggests that much of that growth will take place in Syracuse, a “Strong Center” and the only “City Center” in the region. It is likely that many of Micron’s employees will reside in the city. Those living south of I-690 would potenfially be negafively affected by NYS DOT’s proposed Community Grid Plan. Traffic data should be collected from that geographic area to be used in projecfions, especially since the southwest side of the city has been a concentrafion of historically disadvantaged populafions. With well over 100,000 new residents projected, it is crifical that the infrastructure is designed to support the planned growth. 3. Traffic issues potenfially affect environmental jusfice. Micron will operate three (3) shifts over a 24-hour day. Day and night shifts will be ufilized to sustain 24-hour manufacturing acfivifies as well as a maintenance shift. (1.1.2) Current projecfions for addifional housing to accommodate the economic growth related to Micron call for 2,000 to 2,500 residenfial living units per year for the next two decades. Onondaga County’s plan2 suggests that much of that growth will take place in Syracuse, a “Strong Center” and the only “City Center” in the region. It is likely that many of Micron’s employees will reside in the city. Those living south of I-690 would potenfially be negafively affected by NYS DOT’s proposed Community Grid Plan. Traffic data should be collected from that geographic area to be used in projecfions, especially since the southwest side of the city has been a concentrafion of historically disadvantaged populafions. With well over 100,000 new residents projected, it is crifical that the infrastructure is designed to support the planned growth. 4. Considerafion has been given to many other strategic locafions. The aftached Appendix A maps show a selecfion of locafions for data collecfion. Data sites are in diverse communifies such as Fulton. Central Square, and the northside of Syracuse. Comparable data sites should be located in the City of Syracuse. 5. The scoping document shows concern for local roadways. A rail spur will be developed to supply construcfion materials and avoid impact on local roadways. (1.1.2). Many local roadways in the City of Syracuse will be affected by on-going Micron traffic. Conclusion: Based on the above factors, significant adverse impacts could result if the Draft EIS does not analyze data from impacted locafions. Specifically, ATR and VCC data collecfion should also take place at strategic locafions in the City of Syracuse south of the I-690 corridor. 1. Access to the Micron facility may come from those locafions. 2. Those locafions could have an impact on environmental jusfice by reducing convenient access to Southwest side of the city. 3. The Community Grid, if implemented to remove the I-81 Viaduct, will increase the negafive impacts for employees and suppliers accessing Micron from I-81 south of I-81/481 Interchange 29. 4. Air quality should be monitored at all the traffic locafions. 2 See “Plan Onondaga,” the County’s Comprehensive Plan, accessed at plan.ongov.net/the-plan/ on 10/19/2023. 4. Considerafion has been given to many other strategic locafions. The aftached Appendix A maps show a selecfion of locafions for data collecfion. Data sites are in diverse communifies such as Fulton. Central Square, and the northside of Syracuse. Comparable data sites should be located in the City of Syracuse. 5. The scoping document shows concern for local roadways. A rail spur will be developed to supply construcfion materials and avoid impact on local roadways. (1.1.2). Many local roadways in the City of Syracuse will be affected by on-going Micron traffic. Conclusion: Based on the above factors, significant adverse impacts could result if the Draft EIS does not analyze data from impacted locafions. Specifically, ATR and VCC data collecfion should also take place at strategic locafions in the City of Syracuse south of the I-690 corridor. 1. Access to the Micron facility may come from those locafions. 2. Those locafions could have an impact on environmental jusfice by reducing convenient access to Southwest side of the city. 3. The Community Grid, if implemented to remove the I-81 Viaduct, will increase the negafive impacts for employees and suppliers accessing Micron from I-81 south of I-81/481 Interchange 29. 4. Air quality should be monitored at all the traffic locafions. 2 See “Plan Onondaga,” the County’s Comprehensive Plan, accessed at plan.ongov.net/the-plan/ on 10/19/2023. 120 OCIDA Micron EIS: Draft Scoping Document Comments Page 3 Minchin G. Lewis October 20, 2023 5. The addifional sites would provide data to establish a baseline for future planning. Comment 2: Significant adverse impacts could result from relying on prior studies. 1. The draft scoping document suggests that “to the extent applicable, prior studies completed by OCIDA as part of its generic environmental impact statements will be referenced in the site- specific assessments completed as part of the current environmental impact statement.” 2. Many studies were conducted as part of the I-81 Viaduct project. A court found that those studies did not adequately address the environmental impacts of the proposed alternafive being evaluated by NYS DOT. (See Footnote 2) 3. To mifigate the possibility that adverse impacts could result from relying on prior studies, the Draft EIS should call for new traffic studies to be conducted by independent professional traffic engineering firms. The firms should have a nafional reputafion for independence. They should be charged with collecfing totally new data to replace most of the data cited in the I-81 Viaduct Project, data was collected prior to 2013. 120 OCIDA Micron EIS: Draft Scoping Document Comments Page 3 Minchin G. Lewis October 20, 2023 5. The addifional sites would provide data to establish a baseline for future planning. Comment 2: Significant adverse impacts could result from relying on prior studies. 1. The draft scoping document suggests that “to the extent applicable, prior studies completed by OCIDA as part of its generic environmental impact statements will be referenced in the site- specific assessments completed as part of the current environmental impact statement.” 2. Many studies were conducted as part of the I-81 Viaduct project. A court found that those studies did not adequately address the environmental impacts of the proposed alternafive being evaluated by NYS DOT. (See Footnote 2) 3. To mifigate the possibility that adverse impacts could result from relying on prior studies, the Draft EIS should call for new traffic studies to be conducted by independent professional traffic engineering firms. The firms should have a nafional reputafion for independence. They should be charged with collecfing totally new data to replace most of the data cited in the I-81 Viaduct Project, data was collected prior to 2013. 4. To ensure that the Micron project achieves the desired outcomes for all local residents, it is essenfial that OCIDA not rely on NYS DOT for mafters related to I-81, and conduct its own due diligence related to traffic. Submifted by: Minchin G. Lewis 205 Rigi Avenue Syracuse, NY 13206 Cell: 315-243-2530 Email: Mglewis@syr.edu 121 OCIDA Micron EIS: Draft Scoping Document Comments Page 4 Minchin G. Lewis October 20, 2023 4. To ensure that the Micron project achieves the desired outcomes for all local residents, it is essenfial that OCIDA not rely on NYS DOT for mafters related to I-81, and conduct its own due diligence related to traffic. Submifted by: Minchin G. Lewis 205 Rigi Avenue Syracuse, NY 13206 Cell: 315-243-2530 Email: Mglewis@syr.edu 121 OCIDA Micron EIS: Draft Scoping Document Comments Page 4 Minchin G. Lewis October 20, 2023 APPENDIX A: Automafic Traffic Recorder (ATR) Counts: ATR volume data summaries will be summarized in 15- minute intervals by locafion. 122 OCIDA Micron EIS: Draft Scoping Document Comments Page 5 Minchin G. Lewis October 20, 2023 Vehicle Classificafion Counts: The VCC volume data summary will be summarized by locafion in 15- minute intervals. Traffic recorded for the VCCs will be sorted into four vehicle classificafions: Autos, Buses (which would include non-arficulated buses, arficulated buses, and jitneys), Medium Trucks, and Heavy Trucks. 123 From: go Sent: Saturday, October 21, 2023 3:57:56 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: ATTN: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. October 20, 2023 Onondaga County Industrial Development Agency 335 Montgomery St Syracuse, N.Y. 13202 To Whom it May Concern: APPENDIX A: Automafic Traffic Recorder (ATR) Counts: ATR volume data summaries will be summarized in 15- minute intervals by locafion. 122 OCIDA Micron EIS: Draft Scoping Document Comments Page 5 Minchin G. Lewis October 20, 2023 Vehicle Classificafion Counts: The VCC volume data summary will be summarized by locafion in 15- minute intervals. Traffic recorded for the VCCs will be sorted into four vehicle classificafions: Autos, Buses (which would include non-arficulated buses, arficulated buses, and jitneys), Medium Trucks, and Heavy Trucks. 123 From: go Sent: Saturday, October 21, 2023 3:57:56 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: ATTN: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. October 20, 2023 Onondaga County Industrial Development Agency 335 Montgomery St Syracuse, N.Y. 13202 To Whom it May Concern: As Conservation Chair of Onondaga Audubon, I feel that I should send a comment regarding the Micron megafab site coming to Clay, New York. The consideration of the changes that this development brings with it is quite overwhelming and I am not sure if it is possible to mitigate for them. Open space is something that residents of upstate New York have taken for granted for many years. We enjoy it and the members of Onondaga Audubon enjoy outdoor activities, especially birding. It is obvious that the land use impacts of the Micron project will be significant. Within the 1400- acre project area, there will be a loss of 315 acres of forest, 430 acres of meadows/grasslands/brushlands, and 131 acres of wetland. Roads, buildings, and impervious surfaces will grow from 5 acres to 514. In addition to these changes, the region outside of the project's direct footprint will be modified in order to support influx of as many as 100,000 new residents. Zoning maps have already been changed to increase the amount of land available to be developed for housing. 1 124 As Conservation Chair of Onondaga Audubon, I feel that I should send a comment regarding the Micron megafab site coming to Clay, New York. The consideration of the changes that this development brings with it is quite overwhelming and I am not sure if it is possible to mitigate for them. Open space is something that residents of upstate New York have taken for granted for many years. We enjoy it and the members of Onondaga Audubon enjoy outdoor activities, especially birding. It is obvious that the land use impacts of the Micron project will be significant. Within the 1400- acre project area, there will be a loss of 315 acres of forest, 430 acres of meadows/grasslands/brushlands, and 131 acres of wetland. Roads, buildings, and impervious surfaces will grow from 5 acres to 514. In addition to these changes, the region outside of the project's direct footprint will be modified in order to support influx of as many as 100,000 new residents. Zoning maps have already been changed to increase the amount of land available to be developed for housing. 1 124 All of these things will diminish the amount of "wild" or unused land in our locale. Space like this is valuable to many people because it supports birds, wildlife and biodiversity. This is a huge loss to many. Does the economic gain that Micron will bring to Onondaga County cancel this loss? As a leader in technology, I would hope that the lighting used on the Micron campus will be aimed downward so as not to brighten the night sky. I would also hope that there will be some sort of mitigation for the loss of forest, meadow, and wetland that is simply unavoidable as the Micron site is developed. I have also learned about the plans for several housing developments along the Route 31 corridor with dining, shopping, and entertainment opportunities to be included. Along with this sort of mindful development, the landscaping needs to be done mindfully as well. The use of native plants and trees would help mitigate the loss of the many acres of native vegetation that had been present on the development site. Thank you for reading this. Sincerely, Maryanne Adams Conservation Chair Onondaga Audubon P.O. Box 620 Syracuse, NY 13202 2 125 From: Paul Goldsman Sent: Saturday, October 21, 2023 1:04:11 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Comments on the Draft Scoping Document for Micron project All of these things will diminish the amount of "wild" or unused land in our locale. Space like this is valuable to many people because it supports birds, wildlife and biodiversity. This is a huge loss to many. Does the economic gain that Micron will bring to Onondaga County cancel this loss? As a leader in technology, I would hope that the lighting used on the Micron campus will be aimed downward so as not to brighten the night sky. I would also hope that there will be some sort of mitigation for the loss of forest, meadow, and wetland that is simply unavoidable as the Micron site is developed. I have also learned about the plans for several housing developments along the Route 31 corridor with dining, shopping, and entertainment opportunities to be included. Along with this sort of mindful development, the landscaping needs to be done mindfully as well. The use of native plants and trees would help mitigate the loss of the many acres of native vegetation that had been present on the development site. Thank you for reading this. Sincerely, Maryanne Adams Conservation Chair Onondaga Audubon P.O. Box 620 Syracuse, NY 13202 2 125 From: Paul Goldsman Sent: Saturday, October 21, 2023 1:04:11 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Comments on the Draft Scoping Document for Micron project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Both the original generic SEQRA and the revised SEQRA documents note a number of historic properties located on Burnet Road and other parts of the White Pine site, some of which are eligible or potentially eligible for listing on the NY State Register of Historic Places. These properties were supposed to be surveyed/assessed in conjunction with the NY State Historic Preservation Office (SHPO, and possibly other state authorities). For example, in the "Full Environmental Assessment Form, Part 1 - Project and Setting," on p13, section E3e, it states: "Updated consultation with NYS SHPO will be conducted," and "Coordination with NYS SHPO will be conducted." (https://www.ongoved.com/assets/Uploads/files/projectfiles/Revised-SEQRA-EAF-Part-I.pdf) Nearly all of the properties owned by OCIDA along Burnet Road, and others elsewhere on the site are currently in various phases of demolition by OCIDA. I spoke with a representative from Micron at their public meeting on August 1. She said that the survey/study was due to be performed in the Fall. She was surprised to learn that demolitions were already in progress. Has the proposed survey/coordination with SHPO been completed? Was it completed before the demolitions began? Is the report available to the public? P Goldsman, Liverpool, NY NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Both the original generic SEQRA and the revised SEQRA documents note a number of historic properties located on Burnet Road and other parts of the White Pine site, some of which are eligible or potentially eligible for listing on the NY State Register of Historic Places. These properties were supposed to be surveyed/assessed in conjunction with the NY State Historic Preservation Office (SHPO, and possibly other state authorities). For example, in the "Full Environmental Assessment Form, Part 1 - Project and Setting," on p13, section E3e, it states: "Updated consultation with NYS SHPO will be conducted," and "Coordination with NYS SHPO will be conducted." (https://www.ongoved.com/assets/Uploads/files/projectfiles/Revised-SEQRA-EAF-Part-I.pdf) Nearly all of the properties owned by OCIDA along Burnet Road, and others elsewhere on the site are currently in various phases of demolition by OCIDA. I spoke with a representative from Micron at their public meeting on August 1. She said that the survey/study was due to be performed in the Fall. She was surprised to learn that demolitions were already in progress. Has the proposed survey/coordination with SHPO been completed? Was it completed before the demolitions began? Is the report available to the public? P Goldsman, Liverpool, NY 1 126 ________________________________________ From: Jill Shultz Sent: Wednesday, October 25, 2023 1:34:47 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Micron's huge campus will gobble up a lot of land, causing a range of environmental problems. I'd like to see them prevent as many of them as possible. One often overlooked mitigation is the use of native plants in landscaping instead of the typical ornamentals, which are usually nonnative and contribute almost nothing to our pollinators and wildlife. Ask for 80% native plants, especially in the shrub and tree layer -- ideally provided by our local native plant nurseries. Native plants are beautiful and once established, far hardier than their foreign counterparts, as well as easier to maintain, requiring less water, fertilizer, and mulch. And they'll attract birds and butterflies. 1 126 ________________________________________ From: Jill Shultz Sent: Wednesday, October 25, 2023 1:34:47 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Micron's huge campus will gobble up a lot of land, causing a range of environmental problems. I'd like to see them prevent as many of them as possible. One often overlooked mitigation is the use of native plants in landscaping instead of the typical ornamentals, which are usually nonnative and contribute almost nothing to our pollinators and wildlife. Ask for 80% native plants, especially in the shrub and tree layer -- ideally provided by our local native plant nurseries. Native plants are beautiful and once established, far hardier than their foreign counterparts, as well as easier to maintain, requiring less water, fertilizer, and mulch. And they'll attract birds and butterflies. Cities around the world are updating their building codes to require the installation of native plant landscaping to offset the environmental costs of buildings and hardscapes. This also makes the community so much more beautiful and inviting, a better place to live and work. I'd also like to see requirements for the installation of renewable energy projects. Our natural heritage belongs to all of us, not just corporations that want to consume it for their profits, and protecting it is vital to survival. Sincerely, Jill Shultz 1 127 ________________________________________ From: Peter Wirth Sent: Wednesday, October 25, 2023 3:26:52 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: ATTN: Micron Project. -you can send written comments to OCIDA at NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Questions for OCIDA regarding Micron Project Statements by our County Exec. and Micron officials the Micron project in Clay NY will use 100% renewable energy. I have the following questions. Cities around the world are updating their building codes to require the installation of native plant landscaping to offset the environmental costs of buildings and hardscapes. This also makes the community so much more beautiful and inviting, a better place to live and work. I'd also like to see requirements for the installation of renewable energy projects. Our natural heritage belongs to all of us, not just corporations that want to consume it for their profits, and protecting it is vital to survival. Sincerely, Jill Shultz 1 127 ________________________________________ From: Peter Wirth Sent: Wednesday, October 25, 2023 3:26:52 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: ATTN: Micron Project. -you can send written comments to OCIDA at NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Questions for OCIDA regarding Micron Project Statements by our County Exec. and Micron officials the Micron project in Clay NY will use 100% renewable energy. I have the following questions. 1. My understanding is the fab plants and all buildings on what is referred to as the campus will be heated & cooled by nonfossil fuel technologies ie. electric They will be heat pumps or a similar technology for heating. For cooling they will also use electric based appliances such as electric chillers. Is that correct? If not what sources of energy will be used for heating and cooling? 2. My understanding is that cooking facilities (cafeteria, kitchen for day care center etc.) in all the buildings will be electric and will not be gas based. Is that correct? Why would greenhouse gas based appliances be considered since the commitment is to 100% renewable energy ie. nonfossil fuel. 3. If hydrogen is used as an energy source will it be green hydrogen? 4. Re. solar will there be roof top solar installed and any additional solar farms on adjoining property? 5. If rooftop solar will be installed when will the new architectural drawings be finished as current drawings in the Syracuse Post Standard do not show rooftop solar. 6. Re. the breakout for the electrical usage will there be a breakout showing what percentage is coming from wind, solar etc. How will we know the electricity is sourced from renewable sources? 1. My understanding is the fab plants and all buildings on what is referred to as the campus will be heated & cooled by nonfossil fuel technologies ie. electric They will be heat pumps or a similar technology for heating. For cooling they will also use electric based appliances such as electric chillers. Is that correct? If not what sources of energy will be used for heating and cooling? 2. My understanding is that cooking facilities (cafeteria, kitchen for day care center etc.) in all the buildings will be electric and will not be gas based. Is that correct? Why would greenhouse gas based appliances be considered since the commitment is to 100% renewable energy ie. nonfossil fuel. 3. If hydrogen is used as an energy source will it be green hydrogen? 4. Re. solar will there be roof top solar installed and any additional solar farms on adjoining property? 5. If rooftop solar will be installed when will the new architectural drawings be finished as current drawings in the Syracuse Post Standard do not show rooftop solar. 6. Re. the breakout for the electrical usage will there be a breakout showing what percentage is coming from wind, solar etc. How will we know the electricity is sourced from renewable sources? 7. According to Micron documents National Grid is constructing a 16 inch high pressure gas line to the plant. What is the capacity of that gas-line? 1 128 8. Why are Micron officials using terminology "100% renewable energy" when referring to the plant when massive amounts of methane will be used at the plant? Methane is a much more potent greenhouse gas than CO2 Thank you for considering these questions. Looking forward to your reply Peter Wirth Vice President Climate Change Awareness and Action A local, CNY organization with 1,600 members 2 129 From: Mary Lou Bender Sent: Thursday, October 26, 2023 2:12:02 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. TO OCIDA & MICRON: 7. According to Micron documents National Grid is constructing a 16 inch high pressure gas line to the plant. What is the capacity of that gas-line? 1 128 8. Why are Micron officials using terminology "100% renewable energy" when referring to the plant when massive amounts of methane will be used at the plant? Methane is a much more potent greenhouse gas than CO2 Thank you for considering these questions. Looking forward to your reply Peter Wirth Vice President Climate Change Awareness and Action A local, CNY organization with 1,600 members 2 129 From: Mary Lou Bender Sent: Thursday, October 26, 2023 2:12:02 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. TO OCIDA & MICRON: I reside in an apartment complex called Tocco Villaggio located on Legionnaire Dr. which is approximately 1/2 mile away from Burnet Rd. There is a tree line to the north of Micron's site which esthetically enhances our view, and acts as a sound and visual buffer. At Tocco Villaggio, we are set back from Rt. 31 and enjoy the quiet quality of life. There is a pond on the property where geese & herons are protected and the soothing sounds of crickets or other creatures that inhabit the pond enhance our quiet and nature driven quality of life. We are very concerned that all the construction and Micron related heavy duty equipment & traffic will have a negative impact on the quality of our life. Also, we implore the tree line not be torn down, and in fact, several hundred more trees should be planted in the Micron complex. We are basically a rural community, and want to preserve our quality of life. My questions are what is OCIDA/Micron planning to do to preserve the trees and other environmental aspects and quality of life issues that greatly impact our rural community? Thank you for your consideration and the courtesy of a reply. Mary Lou Bender 5501 Legionnaire Dr. Apt. 311 Cicero, NY 13039 1 130 I reside in an apartment complex called Tocco Villaggio located on Legionnaire Dr. which is approximately 1/2 mile away from Burnet Rd. There is a tree line to the north of Micron's site which esthetically enhances our view, and acts as a sound and visual buffer. At Tocco Villaggio, we are set back from Rt. 31 and enjoy the quiet quality of life. There is a pond on the property where geese & herons are protected and the soothing sounds of crickets or other creatures that inhabit the pond enhance our quiet and nature driven quality of life. We are very concerned that all the construction and Micron related heavy duty equipment & traffic will have a negative impact on the quality of our life. Also, we implore the tree line not be torn down, and in fact, several hundred more trees should be planted in the Micron complex. We are basically a rural community, and want to preserve our quality of life. My questions are what is OCIDA/Micron planning to do to preserve the trees and other environmental aspects and quality of life issues that greatly impact our rural community? Thank you for your consideration and the courtesy of a reply. Mary Lou Bender 5501 Legionnaire Dr. Apt. 311 Cicero, NY 13039 1 130 From: Craig Polhamus Sent: Thursday, October 26, 2023 11:18:03 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: ATTN: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Dear Members of the Environmental Review Committee, As a licensed architect and a concerned citizen, I am writing to express my deep concerns about the proposed $100 billion expansion of Micron in Central New York. This expansion represents a significant step forward in our technological capabilities and economic growth. However, it also presents potential risks that must be thoroughly evaluated and mitigated to ensure the safety and well-being of our community and environment. History is replete with examples of disasters that have resulted from overlooked or underestimated risks. The sinking of the Titanic and the Hindenburg disaster serve as stark reminders of the devastating consequences that can occur when potential risks are not fully considered and addressed. These incidents were not inevitable accidents, but rather the result of a failure to adequately assess and mitigate known risks. From: Craig Polhamus Sent: Thursday, October 26, 2023 11:18:03 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: ATTN: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Dear Members of the Environmental Review Committee, As a licensed architect and a concerned citizen, I am writing to express my deep concerns about the proposed $100 billion expansion of Micron in Central New York. This expansion represents a significant step forward in our technological capabilities and economic growth. However, it also presents potential risks that must be thoroughly evaluated and mitigated to ensure the safety and well-being of our community and environment. History is replete with examples of disasters that have resulted from overlooked or underestimated risks. The sinking of the Titanic and the Hindenburg disaster serve as stark reminders of the devastating consequences that can occur when potential risks are not fully considered and addressed. These incidents were not inevitable accidents, but rather the result of a failure to adequately assess and mitigate known risks. Closer to home, we have seen the devastating impacts of industrial and environmental disasters. The pollution of Onondaga Lake by Allied Chemical, the Love Canal disaster, and the Split Rock explosion have all had profound impacts on our community and environment. These incidents have caused immeasurable harm to human health and the environment, and their effects are still being felt today. The semiconductor industry is not immune to these risks. The production process is complex and global in nature, subject to numerous risks including geopolitical tensions, earthquakes, extreme weather events, and supply chain disruptions. Moreover, the manufacturing process involves the use of hazardous materials that can pose significant risks to human health and the environment if not properly managed. As we consider Micron’s proposed expansion, it is crucial that we fully understand these risks and take all necessary steps to mitigate them. This includes conducting a comprehensive review of the facility’s architecture for best practices in containment, safety, and resiliency. We must ensure that all potential environmental impacts are thoroughly assessed and adequately addressed before proceeding. 1 131 Closer to home, we have seen the devastating impacts of industrial and environmental disasters. The pollution of Onondaga Lake by Allied Chemical, the Love Canal disaster, and the Split Rock explosion have all had profound impacts on our community and environment. These incidents have caused immeasurable harm to human health and the environment, and their effects are still being felt today. The semiconductor industry is not immune to these risks. The production process is complex and global in nature, subject to numerous risks including geopolitical tensions, earthquakes, extreme weather events, and supply chain disruptions. Moreover, the manufacturing process involves the use of hazardous materials that can pose significant risks to human health and the environment if not properly managed. As we consider Micron’s proposed expansion, it is crucial that we fully understand these risks and take all necessary steps to mitigate them. This includes conducting a comprehensive review of the facility’s architecture for best practices in containment, safety, and resiliency. We must ensure that all potential environmental impacts are thoroughly assessed and adequately addressed before proceeding. 1 131 I urge you to consider these cautionary tales from history as well as more from this list of industrial disasters as examples to keep in mind as we evaluate Micron’s proposed expansion. It is our responsibility to learn from these past mistakes and ensure that they are not repeated. We have an opportunity here to demonstrate that economic growth and environmental responsibility can coexist. By taking a proactive approach to risk management, we can ensure that this expansion proceeds in a manner that is safe, sustainable, and beneficial for all. Thank you for your attention to this matter. I trust that you will give these concerns the serious consideration they deserve. Sincerely, Craig Polhamus, AIA Registered Architect 219 Burnet Ave., Syracuse, NY 13203 Tel: (315) 475-8404 Email: craig@zausmerfrisch.com Please consider the environment before printing this message. This electronic mail transmission may contain confidential material and is intended only for the person or entity to which it is addressed. Any review, retransmission, dissemination or other use of or taking of any action by persons or entities other than the intended recipient is prohibited. If you are not the intended recipient, please delete the information from your system and contact the sender. 2 132 I urge you to consider these cautionary tales from history as well as more from this list of industrial disasters as examples to keep in mind as we evaluate Micron’s proposed expansion. It is our responsibility to learn from these past mistakes and ensure that they are not repeated. We have an opportunity here to demonstrate that economic growth and environmental responsibility can coexist. By taking a proactive approach to risk management, we can ensure that this expansion proceeds in a manner that is safe, sustainable, and beneficial for all. Thank you for your attention to this matter. I trust that you will give these concerns the serious consideration they deserve. Sincerely, Craig Polhamus, AIA Registered Architect 219 Burnet Ave., Syracuse, NY 13203 Tel: (315) 475-8404 Email: craig@zausmerfrisch.com Please consider the environment before printing this message. This electronic mail transmission may contain confidential material and is intended only for the person or entity to which it is addressed. Any review, retransmission, dissemination or other use of or taking of any action by persons or entities other than the intended recipient is prohibited. If you are not the intended recipient, please delete the information from your system and contact the sender. 2 132 ________________________________________ From: Richard Ellenbogen Sent: Friday, October 27, 2023 2:28:42 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: Richard Ellenbogen Subject: Ellenbogen Comments on the Micron Technologies Draft Scoping Plan 10-27-2023.pdf NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Onondaga County Industrial Development Agency ATTN: Micron Project 335 Montgomery Street, 2nd Floor Syracuse, New York 13202 Please see the attached comments regarding the Draft Scoping Plan for Micron Technologies. Thank you. Richard Ellenbogen President Allied Converters, Inc. 1 133 Ellenbogen Comments on the Micron Technologies Draft Scoping Plan I have some comments on potential significant adverse impacts that should be addressed on the Draft Scoping Document. I am a former Bell Labs Engineer that worked in their Power Systems Laboratory. My research has been used by the NY State Public Service Commission as the basis of a utility conference to address transmission line loss that resulted in significant energy savings in NY State. I was also the Keynote Speaker at the 2023 Business Council of NY State Renewable Energy Conference. Issues ________________________________________ From: Richard Ellenbogen Sent: Friday, October 27, 2023 2:28:42 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: Richard Ellenbogen Subject: Ellenbogen Comments on the Micron Technologies Draft Scoping Plan 10-27-2023.pdf NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Onondaga County Industrial Development Agency ATTN: Micron Project 335 Montgomery Street, 2nd Floor Syracuse, New York 13202 Please see the attached comments regarding the Draft Scoping Plan for Micron Technologies. Thank you. Richard Ellenbogen President Allied Converters, Inc. 1 133 Ellenbogen Comments on the Micron Technologies Draft Scoping Plan I have some comments on potential significant adverse impacts that should be addressed on the Draft Scoping Document. I am a former Bell Labs Engineer that worked in their Power Systems Laboratory. My research has been used by the NY State Public Service Commission as the basis of a utility conference to address transmission line loss that resulted in significant energy savings in NY State. I was also the Keynote Speaker at the 2023 Business Council of NY State Renewable Energy Conference. Issues The current plans for powering the Micron facility in Clay, NY, while looking good on paper, will in fact increase emissions on energy used to supply the Micron facility, raise Micron’s costs above what they could be, and are not achievable in any realistic time frame using renewable energy. Forcing Micron to purchase Renewable offsets may look good on paper but will do nothing for the environment. The reality is that NY State is going to have major difficulties just providing renewable energy for its existing electric load, let alone the predicted additional 16 Terawatt hours (TWh) of the Micron facility. To put that amount of energy in perspective, it is nearly as much as was produced by the 2 Gigawatt Indian Point Nuclear Plant in its last full year of operation. The New York Power Authority has said that it will provide 140 Megawatts of Hydroelectric Power to Micron, however that Hydropower does not exist, even at night. Any hydropower provided to Micron will force whoever is using it presently to switch to fossil fuel generation. It is an energy “shell game”. The current plans for powering the Micron facility in Clay, NY, while looking good on paper, will in fact increase emissions on energy used to supply the Micron facility, raise Micron’s costs above what they could be, and are not achievable in any realistic time frame using renewable energy. Forcing Micron to purchase Renewable offsets may look good on paper but will do nothing for the environment. The reality is that NY State is going to have major difficulties just providing renewable energy for its existing electric load, let alone the predicted additional 16 Terawatt hours (TWh) of the Micron facility. To put that amount of energy in perspective, it is nearly as much as was produced by the 2 Gigawatt Indian Point Nuclear Plant in its last full year of operation. The New York Power Authority has said that it will provide 140 Megawatts of Hydroelectric Power to Micron, however that Hydropower does not exist, even at night. Any hydropower provided to Micron will force whoever is using it presently to switch to fossil fuel generation. It is an energy “shell game”. The reality is that Micron is going to be powered by Fossil Fuel Generation that is transmitted over long distances, very likely from out of state in Pennsylvania or Ohio that have generation carbon footprints far higher than those in NY State. As GHG emissions are not cognizant of political boundaries on a map, those emissions will end up affecting NY State residents. Additionally, transmitting that much power over those long distances is going to greatly increase line losses. It will also increase the strain on the transmission system in Western and Central NY State, raising costs for that as well. Just a 3% line loss on that amount of energy will result in losses totaling close to 500 Gigawatt hours (GWh) annually. To put that in perspective, Cornell University uses 200 GWh annually to operate the entire University, so just the energy loss getting the power to Micron could operate Cornell for 2-1/2 years. Importing electric power to the Micron facility from off- site is a foolish concept and there are far better solutions. Instead of making Micron look “Green” on paper to satisfy some prescribed number in a document, Micron could be “Green” in reality with far lower holistic emissions and lower operating costs simultaneously. It would be better for the environment, better for the bottom line of Micron Technologies, and better for the economy of Central New York. Solutions The reality is that Micron is going to be powered by Fossil Fuel Generation that is transmitted over long distances, very likely from out of state in Pennsylvania or Ohio that have generation carbon footprints far higher than those in NY State. As GHG emissions are not cognizant of political boundaries on a map, those emissions will end up affecting NY State residents. Additionally, transmitting that much power over those long distances is going to greatly increase line losses. It will also increase the strain on the transmission system in Western and Central NY State, raising costs for that as well. Just a 3% line loss on that amount of energy will result in losses totaling close to 500 Gigawatt hours (GWh) annually. To put that in perspective, Cornell University uses 200 GWh annually to operate the entire University, so just the energy loss getting the power to Micron could operate Cornell for 2-1/2 years. Importing electric power to the Micron facility from off- site is a foolish concept and there are far better solutions. Instead of making Micron look “Green” on paper to satisfy some prescribed number in a document, Micron could be “Green” in reality with far lower holistic emissions and lower operating costs simultaneously. It would be better for the environment, better for the bottom line of Micron Technologies, and better for the economy of Central New York. Solutions To address these issues and the associated potential significant adverse impacts, the Draft Environmental Impact Statement should include an alternative to add a Combined Cycle generating plant on the Micron Property. By adding a 2 GW combined cycle plant on the Micron Property, it would save the 500 GWh of line loss annually. That is the annual output of a 500 Megawatt solar array that would cover approximately 1500 acres (2.35 square miles). As energy is fungible, eliminating those losses would make that wasted renewable energy available to help green the rest of the state. Further, 134 To address these issues and the associated potential significant adverse impacts, the Draft Environmental Impact Statement should include an alternative to add a Combined Cycle generating plant on the Micron Property. By adding a 2 GW combined cycle plant on the Micron Property, it would save the 500 GWh of line loss annually. That is the annual output of a 500 Megawatt solar array that would cover approximately 1500 acres (2.35 square miles). As energy is fungible, eliminating those losses would make that wasted renewable energy available to help green the rest of the state. Further, 134 by siting the Generating Center on the Micron site, the waste heat resulting from the generating process would be made available to Micron. As they have an enormous thermal load, they could make use of nearly the entire energy content of the combusted gas used to generate electricity. That sized facility is roughly twice the size of the recently built Crickett Valley Energy Center. In 2018, the cost of that facility was approximately $1.5 Billion. Adjusted for the recent bout of inflation, that could be $2 Billion today, making the total cost of a combined cycle facility for Micron approximately $4 Billion. However, Micron will recoup that money in energy savings and reduced costs, making the site even more attractive for development. As Micron will be expanding over time, the generating center would not need to be built at its full capacity initially. It could be expanded over time and if newer, more efficient technologies were developed, those could be incorporated as part of the later expansion of the energy center.. There are also possibilities for using the CO2 emissions of the generating facility for agricultural purposes, further reducing the carbon footprint of the plant. by siting the Generating Center on the Micron site, the waste heat resulting from the generating process would be made available to Micron. As they have an enormous thermal load, they could make use of nearly the entire energy content of the combusted gas used to generate electricity. That sized facility is roughly twice the size of the recently built Crickett Valley Energy Center. In 2018, the cost of that facility was approximately $1.5 Billion. Adjusted for the recent bout of inflation, that could be $2 Billion today, making the total cost of a combined cycle facility for Micron approximately $4 Billion. However, Micron will recoup that money in energy savings and reduced costs, making the site even more attractive for development. As Micron will be expanding over time, the generating center would not need to be built at its full capacity initially. It could be expanded over time and if newer, more efficient technologies were developed, those could be incorporated as part of the later expansion of the energy center.. There are also possibilities for using the CO2 emissions of the generating facility for agricultural purposes, further reducing the carbon footprint of the plant. Common sense solutions to energy issues have to be adopted if NY State is going to reduce its Carbon Footprint and remain a cost competitive state in which to do business. Blindly following an ideology that contradicts math and physics is not an intelligent way to create a sound environment for either business or the health of NY State residents. Richard Ellenbogen President Allied Converters, Inc New Rochelle, NY richard@alliedconverters.com 135 From: roger.caiazza@gmail.com On Behalf OfRoger Caiazza Sent: Sunday, October 29, 2023 7:51:03 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Comment on the Draft Scoping Document and Proposed Content of the Draft EIS. NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. My comments on the draft scoping document and proposed content of the Draft EIS.for the Micron New York Semiconductor Manufacturing Action are attached. -- Roger Caiazza 7679 Bay Cir Liverpool, NY 13090 Pragmatic Environmentalist of New York NYpragmaticenvironmentalist@gmail.com 315.529.6711 1 136 Common sense solutions to energy issues have to be adopted if NY State is going to reduce its Carbon Footprint and remain a cost competitive state in which to do business. Blindly following an ideology that contradicts math and physics is not an intelligent way to create a sound environment for either business or the health of NY State residents. Richard Ellenbogen President Allied Converters, Inc New Rochelle, NY richard@alliedconverters.com 135 From: roger.caiazza@gmail.com On Behalf OfRoger Caiazza Sent: Sunday, October 29, 2023 7:51:03 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Comment on the Draft Scoping Document and Proposed Content of the Draft EIS. NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. My comments on the draft scoping document and proposed content of the Draft EIS.for the Micron New York Semiconductor Manufacturing Action are attached. -- Roger Caiazza 7679 Bay Cir Liverpool, NY 13090 Pragmatic Environmentalist of New York NYpragmaticenvironmentalist@gmail.com 315.529.6711 1 136 Caiazza Comments on the Micron Technologies Draft Scoping Document I have some comments on potential significant adverse impacts that should be addressed in the Draft Scoping Document. I am a retired air quality meteorologist and live less than seven miles from the White Pine Commerce Park. I recognize the tremendous opportunity that this project affords this area and provide these comments in that context. I recommend that Section 5.3 – Methodologies for Technical Analyses include recent permitting requirements related to proposed disadvantaged community guidance. I suggest two co-generation alternatives be analyzed in the Draft Environmental Impact Study (DEIS). The associated benefits and adverse impacts of co-generation relative to the benefits and adverse impacts using electricity from the grid and natural gas only for thermal load requirements on-site should be considered in the environmental analyses. In the short-term because natural gas apparently is going to be used for process applications and heat, I believe a natural gas fired combined cycle combustion turbine(CCGT) should be included to support process applications and heat as well as provide electricity for the facility. In the long-term I believe that the facility should be designed so that a small modular nuclear reactor could be built to replace the CCGT when the technology is proven and available. Caiazza Comments on the Micron Technologies Draft Scoping Document I have some comments on potential significant adverse impacts that should be addressed in the Draft Scoping Document. I am a retired air quality meteorologist and live less than seven miles from the White Pine Commerce Park. I recognize the tremendous opportunity that this project affords this area and provide these comments in that context. I recommend that Section 5.3 – Methodologies for Technical Analyses include recent permitting requirements related to proposed disadvantaged community guidance. I suggest two co-generation alternatives be analyzed in the Draft Environmental Impact Study (DEIS). The associated benefits and adverse impacts of co-generation relative to the benefits and adverse impacts using electricity from the grid and natural gas only for thermal load requirements on-site should be considered in the environmental analyses. In the short-term because natural gas apparently is going to be used for process applications and heat, I believe a natural gas fired combined cycle combustion turbine(CCGT) should be included to support process applications and heat as well as provide electricity for the facility. In the long-term I believe that the facility should be designed so that a small modular nuclear reactor could be built to replace the CCGT when the technology is proven and available. Disadvantaged Community Requirements There is a draft permitting requirement that should be considered in the Technical Studies section of the DEIS. The New York State Department of Environmental Conservation (DEC) recently proposed a new policy that will require an analysis of impacts on disadvantaged communities (DACs) as part of most environmental permitting actions. The draft policy, DEP-23-1: Permitting and Disadvantaged Communities, was proposed by the Division of Environmental Permits on September 27, 2023. While this is a draft policy it will be in place by the time the DEIS is complete. My initial reading of this policy suggests that it is so comprehensive that it would not surprise me that, even though the facility is not in or adjacent to a disadvantaged community, that it still could be a consideration. Co-Generation Alternatives Section 4.3 Alternatives to be Analyzed in the DEIS should include options for co-generation. In brief, I believe there is a compelling argument that the proposed facility is so large that its energy use has ramifications not only to the facility but also New York State policy. Disadvantaged Community Requirements There is a draft permitting requirement that should be considered in the Technical Studies section of the DEIS. The New York State Department of Environmental Conservation (DEC) recently proposed a new policy that will require an analysis of impacts on disadvantaged communities (DACs) as part of most environmental permitting actions. The draft policy, DEP-23-1: Permitting and Disadvantaged Communities, was proposed by the Division of Environmental Permits on September 27, 2023. While this is a draft policy it will be in place by the time the DEIS is complete. My initial reading of this policy suggests that it is so comprehensive that it would not surprise me that, even though the facility is not in or adjacent to a disadvantaged community, that it still could be a consideration. Co-Generation Alternatives Section 4.3 Alternatives to be Analyzed in the DEIS should include options for co-generation. In brief, I believe there is a compelling argument that the proposed facility is so large that its energy use has ramifications not only to the facility but also New York State policy. On Page 18 in the discussion of project locations the rationale for this location was described: While all four New York State sites were among the most expensive in terms of construction costs, personnel, water and wastewater, and real estate and personal income taxes, the New York State sites had a competitive advantage on electricity and natural gas costs. On balance, the study concluded that New York State led all competitors in terms of the capacity, capability, and probability of delivering a meaningful incentives package. There may be a competitive advantage today for electricity and natural gas costs today but when the electric grid is transitioned to “zero-emissions” in the future electricity costs will increase dramatically. The likelihood of the complete buildout improves if energy costs are kept low and that would be best accomplished if Micron contains costs by on-site generation. Furthermore, I suspect, but do not know, 137 that natural gas will have to be used anyway for system processes and heating. If that is the case then this option is a pragmatic energy-efficient solution. On Page 18 in the discussion of project locations the rationale for this location was described: While all four New York State sites were among the most expensive in terms of construction costs, personnel, water and wastewater, and real estate and personal income taxes, the New York State sites had a competitive advantage on electricity and natural gas costs. On balance, the study concluded that New York State led all competitors in terms of the capacity, capability, and probability of delivering a meaningful incentives package. There may be a competitive advantage today for electricity and natural gas costs today but when the electric grid is transitioned to “zero-emissions” in the future electricity costs will increase dramatically. The likelihood of the complete buildout improves if energy costs are kept low and that would be best accomplished if Micron contains costs by on-site generation. Furthermore, I suspect, but do not know, 137 that natural gas will have to be used anyway for system processes and heating. If that is the case then this option is a pragmatic energy-efficient solution. According to the information provided so far, the amount of electric power required by Micron if everything is built will be equivalent to the electric power used by Vermont and New Hampshire. An article by James Hanley at the Empire Center that describes potential ramifications: Computer chip manufacturer Micron has revealed that by the 2040s its Onondaga County factories are going to be sucking up enough electricity to power New Hampshire and Vermont combined. Put another way, in a single year Micron will use enough energy to power the city of Buffalo for more than six years. All of it is supposed to come from renewable energy—but to date, despite offering Micron $6.3 billion in taxpayers’ money to move to New York, the state has no plan for providing that much renewable power. Micron predicts it will use over 16,000 gigawatt-hours of electricity annually. To get a sense of how much that is, a gigawatt-hour is roughly the amount of energy produced by a single large nuclear reactor in one hour. Micron’s expected demand is almost exactly what the two reactors at the Nine Mile Point nuclear plant produce each year. But since their factories will allegedly use 100 percent renewable energy, the big question is where it will come from. According to the information provided so far, the amount of electric power required by Micron if everything is built will be equivalent to the electric power used by Vermont and New Hampshire. An article by James Hanley at the Empire Center that describes potential ramifications: Computer chip manufacturer Micron has revealed that by the 2040s its Onondaga County factories are going to be sucking up enough electricity to power New Hampshire and Vermont combined. Put another way, in a single year Micron will use enough energy to power the city of Buffalo for more than six years. All of it is supposed to come from renewable energy—but to date, despite offering Micron $6.3 billion in taxpayers’ money to move to New York, the state has no plan for providing that much renewable power. Micron predicts it will use over 16,000 gigawatt-hours of electricity annually. To get a sense of how much that is, a gigawatt-hour is roughly the amount of energy produced by a single large nuclear reactor in one hour. Micron’s expected demand is almost exactly what the two reactors at the Nine Mile Point nuclear plant produce each year. But since their factories will allegedly use 100 percent renewable energy, the big question is where it will come from. Micron will need to draw 1.85 gigawatts of power from the grid continually, 24 hours a day, to power its operations. The New York Power Authority has offered Micron 140 megawatts (0.14 gigawatts) of hydropower. It may not have that much to spare, except at night when statewide electricity demand drops. But even if it can steadily provide Micron that much power, that’s just over 7 percent of the company’s needs. Micron has also signed a 178-megawatt (0.178 gigawatt) onshore wind power agreement. That will produce less than 467 gigawatt-hours annually, a mere three percent of Micron’s needs. Add those together, and 90 percent of Micron’s power demand remains to be determined. Even before Governor Hochul bribed Micron to come to New York, the state faced a 10 percent deficit in its energy supply by 2040, creating a risky future of probable blackouts due to insufficient power production. The danger is caused by the state’s climate policies. As consumers are mandated to buy electric cars, and households are forced to switch from natural gas to electric heat, electricity demand is expected to as much as double by midcentury. And 70 percent of that future electricity demand must be supplied by renewable energy. Micron will need to draw 1.85 gigawatts of power from the grid continually, 24 hours a day, to power its operations. The New York Power Authority has offered Micron 140 megawatts (0.14 gigawatts) of hydropower. It may not have that much to spare, except at night when statewide electricity demand drops. But even if it can steadily provide Micron that much power, that’s just over 7 percent of the company’s needs. Micron has also signed a 178-megawatt (0.178 gigawatt) onshore wind power agreement. That will produce less than 467 gigawatt-hours annually, a mere three percent of Micron’s needs. Add those together, and 90 percent of Micron’s power demand remains to be determined. Even before Governor Hochul bribed Micron to come to New York, the state faced a 10 percent deficit in its energy supply by 2040, creating a risky future of probable blackouts due to insufficient power production. The danger is caused by the state’s climate policies. As consumers are mandated to buy electric cars, and households are forced to switch from natural gas to electric heat, electricity demand is expected to as much as double by midcentury. And 70 percent of that future electricity demand must be supplied by renewable energy. Because hydropower output will not increase significantly, solar and wind power must increase from their current output of approximately 7,600 gigawatt-hours to as much as 185,000 138 gigawatt-hours by 2050. When Micron is added to the mix, the need will rise to almost 200,000 gigawatt-hours of wind and solar, a 2,600 percent increase from today. That’s a challenge New York simply has no real plan for achieving, because the state’s renewable and clean energy goals are based more on wishful thinking than hard-headed analysis about the technical challenges of radically restructuring the state’s power system. Richard Ellenbogen submitted relevant comments to the New York State Public Service Commission (PSC) “Order initiating a process regarding the zero-emissions target. Ellenbogen argued that natural gas-fired combined cycle power plants are a viable alternative during the transition. He makes a persuasive case that the huge electricity load of the proposed Micron chip fabrication plant should include a combined cycle co-generation plant that would provide both electricity and heat for the facility. Because hydropower output will not increase significantly, solar and wind power must increase from their current output of approximately 7,600 gigawatt-hours to as much as 185,000 138 gigawatt-hours by 2050. When Micron is added to the mix, the need will rise to almost 200,000 gigawatt-hours of wind and solar, a 2,600 percent increase from today. That’s a challenge New York simply has no real plan for achieving, because the state’s renewable and clean energy goals are based more on wishful thinking than hard-headed analysis about the technical challenges of radically restructuring the state’s power system. Richard Ellenbogen submitted relevant comments to the New York State Public Service Commission (PSC) “Order initiating a process regarding the zero-emissions target. Ellenbogen argued that natural gas-fired combined cycle power plants are a viable alternative during the transition. He makes a persuasive case that the huge electricity load of the proposed Micron chip fabrication plant should include a combined cycle co-generation plant that would provide both electricity and heat for the facility. He explains: With regard to Micron Technologies, one could be built on-site that would eliminate 500 GWh of line loss while also providing Micron easy access to high temperature thermal energy. The Energy on Demand aspect of the generating plants also eliminates the need for trillions of dollars of battery storage. It is not a perfect solution, but it is a far better solution than “ideal” solutions that can’t be executed because of the previously documented issues. He explains: With regard to Micron Technologies, one could be built on-site that would eliminate 500 GWh of line loss while also providing Micron easy access to high temperature thermal energy. The Energy on Demand aspect of the generating plants also eliminates the need for trillions of dollars of battery storage. It is not a perfect solution, but it is a far better solution than “ideal” solutions that can’t be executed because of the previously documented issues. I recommend that the DEIS include the option for a co-generation facility. If small modular nuclear reactors were a proven technology, then using that approach would provide long-term zero-emissions consistent with the Climate Leadership and Community Protection Act. Unfortunately, reality is that this technology is not available but neither is all the technology necessary for an electrical grid dependent upon wind, solar, energy storage, and a dispatchable emissions-free resource that the New York Independent System Operator, the Climate Act Integration Analysis, and the aforementioned PSC order all agree is necessary. Therefore, to ensure that this vitally important project has the affordable power it needs to come to fruition, natural gas co-generation is a logical option that should be included. The DEIS should consider phasing in sufficient co-generation to provide the on-site electricity and thermal load requirements as the facility expands. The DEIS should also assess an alternative with a project layout that could eventually enable deployment of a nuclear option. Personal Background I have extensive experience with air pollution permitting and regulatory analysis with over 40 years’ experience in the sector. The opinions expressed in these comments do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone. I recommend that the DEIS include the option for a co-generation facility. If small modular nuclear reactors were a proven technology, then using that approach would provide long-term zero-emissions consistent with the Climate Leadership and Community Protection Act. Unfortunately, reality is that this technology is not available but neither is all the technology necessary for an electrical grid dependent upon wind, solar, energy storage, and a dispatchable emissions-free resource that the New York Independent System Operator, the Climate Act Integration Analysis, and the aforementioned PSC order all agree is necessary. Therefore, to ensure that this vitally important project has the affordable power it needs to come to fruition, natural gas co-generation is a logical option that should be included. The DEIS should consider phasing in sufficient co-generation to provide the on-site electricity and thermal load requirements as the facility expands. The DEIS should also assess an alternative with a project layout that could eventually enable deployment of a nuclear option. Personal Background I have extensive experience with air pollution permitting and regulatory analysis with over 40 years’ experience in the sector. The opinions expressed in these comments do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone. Roger Caiazza Pragmatic Environmentalist of New York Blog NYpragmaticenvironmentalist@gmail.com Liverpool, NY 139 From: Michelle Fanelli Sent: Sunday, October 29, 2023 10:04:43 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: ATTN: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Roger Caiazza Pragmatic Environmentalist of New York Blog NYpragmaticenvironmentalist@gmail.com Liverpool, NY 139 From: Michelle Fanelli Sent: Sunday, October 29, 2023 10:04:43 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: ATTN: Micron Project NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. How will Micron drawing up to 48 million gallons of water daily, affect dairy farms? Other agriculture? How will the water use affect people in the region? How much water will be wasted during the manufacturing process? Is it possible to treat and reuse the treated water? What is the water used for? How will the daily use over time impact the water level of Lake Ontario? Will the cleaned waste water be returned to the lake? How will the local water levels be impacted by the water use? Are they gonna keep their promises on cleaning the water before letting it hit the environment? What if somewhere down the line this causes a shortage of water? Will there be air pollution that will impact the people? What will be done about gas wastes that could affect surrounding communities? How will green energy be used? How badly will the energy bills rise? Can solar panels be used? Or hydro electricity? What type of emissions would it emit? If there are emissions, will special carbon/particulate scrubbers be used? How will the process of creating the factory impact the air? Will the gas coming from this company be contained or just go out into the environment? How is this huge building going to affect the air and the environment around it? Why was the location near a marsh selected? What is the plan to limit the impact on the organisms near and in the marsh? Will the water use impact the drinking water? Is there a set list of contaminants that will be shared with the local community? Is Micron aware of the history of Onondaga lake as a Superfund site? How will Micron handle the disposal of toxic chemicals and waste? How will the waste water be treated? Can the process be described for the community? Will the local pipes be fixed/changed in order to support the projected changes to the water use? How do we know the returning wastewater has been thoroughly cleaned? How will the amount of water Micron uses affect the amount of water available to me and my family? Will Onondaga county be playing a role in water purification from the site? How is OCWA planning on handling the increase in water production? How will the increase in this infrastructure expansion be covered financially? How does the county/NYS plan on regulating the manufacturing site? How will the county ensure that the environmental use will be regulated in order to keep it from becoming a Superfund site (ex. Onondaga lake history) How long will the environmental impact be felt after the production site is up and running? Will local water sources be tested regularly to prevent water contamination? Where will the solid wastes go after they have been used/after the water How will Micron drawing up to 48 million gallons of water daily, affect dairy farms? Other agriculture? How will the water use affect people in the region? How much water will be wasted during the manufacturing process? Is it possible to treat and reuse the treated water? What is the water used for? How will the daily use over time impact the water level of Lake Ontario? Will the cleaned waste water be returned to the lake? How will the local water levels be impacted by the water use? Are they gonna keep their promises on cleaning the water before letting it hit the environment? What if somewhere down the line this causes a shortage of water? Will there be air pollution that will impact the people? What will be done about gas wastes that could affect surrounding communities? How will green energy be used? How badly will the energy bills rise? Can solar panels be used? Or hydro electricity? What type of emissions would it emit? If there are emissions, will special carbon/particulate scrubbers be used? How will the process of creating the factory impact the air? Will the gas coming from this company be contained or just go out into the environment? How is this huge building going to affect the air and the environment around it? Why was the location near a marsh selected? What is the plan to limit the impact on the organisms near and in the marsh? Will the water use impact the drinking water? Is there a set list of contaminants that will be shared with the local community? Is Micron aware of the history of Onondaga lake as a Superfund site? How will Micron handle the disposal of toxic chemicals and waste? How will the waste water be treated? Can the process be described for the community? Will the local pipes be fixed/changed in order to support the projected changes to the water use? How do we know the returning wastewater has been thoroughly cleaned? How will the amount of water Micron uses affect the amount of water available to me and my family? Will Onondaga county be playing a role in water purification from the site? How is OCWA planning on handling the increase in water production? How will the increase in this infrastructure expansion be covered financially? How does the county/NYS plan on regulating the manufacturing site? How will the county ensure that the environmental use will be regulated in order to keep it from becoming a Superfund site (ex. Onondaga lake history) How long will the environmental impact be felt after the production site is up and running? Will local water sources be tested regularly to prevent water contamination? Where will the solid wastes go after they have been used/after the water 1 140 has been cleaned? How will this effect wild life around and in the area, by ripping down the woods, grass land, and houses? Are they gonna be working through the Clay water purification center or making their own on-site? Or both? Why does Micron need to be built in Clay of all places? Will the local community be impacted financially due to the building of the pipeline to carry the water? How is the expense being covered? Why should the public have to pay for water bill if they already pay enough? Will there be a clean up plan if the site does become contaminated? Where would local members go while the site is cleaned? What species will be affected by this and will populations be monitored? What will be done for organisms living in this area (animals, humans, etc.)? Will water testing records be widely available to the public? Will this have a major impact on our wildlife? How will the endangered species be affected? Can windows have cling-ons or dots on them so birds can see them?Can lights be shut off at night because of the bird migration session? We have endangered bird species that come here for the winter season who are Snow Owls. Can native plants be used in landscaping and could they be a green roof? Can part of the swamp be perserved? If not can artificial marsh buoys be made and native plants used for landscaping? Will the community life around the project be affected? How many local jobs are projected? (to off set the environmental impact) What are the projected benefits for the local community? What does Micron have to offer the local community as they plan their environmental impact? This is going to affect the housing market, are there any plans in order to ease this transition or combat this? Will this massive strain on the electricity affect my electricity (more blackouts)? Will first responders need specialized training in order to handle any environmental toxic concerns? How will carbon emission levels be kept low? Will taxes be raised to pay for water? Will this extra use of water make water prices go up? How will the negative effects of this infrastructure affect me economically in the beginning and through to the future? Will internships be offered for local school students? If flooding would happen and major damage be done to the plant, how will this effect taxpayers? How will this effect the Traffic? What if this affects the flow of traffic so they have to take more land to make more roads? It's already getting bad because of this project and other companies. What will salary look like for the workers? How will the whole micron building effect homeowners around the site? How much money will it take to pay for the whole building? This is also gonna cause many economic concerns what are we going to do about that? Why should we have to be worried about paying more money for utilities, for the success and operation of a company? Will this have a major impact on out energy? Thank you for your time and consideration, Michelle Fanelli 1 140 has been cleaned? How will this effect wild life around and in the area, by ripping down the woods, grass land, and houses? Are they gonna be working through the Clay water purification center or making their own on-site? Or both? Why does Micron need to be built in Clay of all places? Will the local community be impacted financially due to the building of the pipeline to carry the water? How is the expense being covered? Why should the public have to pay for water bill if they already pay enough? Will there be a clean up plan if the site does become contaminated? Where would local members go while the site is cleaned? What species will be affected by this and will populations be monitored? What will be done for organisms living in this area (animals, humans, etc.)? Will water testing records be widely available to the public? Will this have a major impact on our wildlife? How will the endangered species be affected? Can windows have cling-ons or dots on them so birds can see them?Can lights be shut off at night because of the bird migration session? We have endangered bird species that come here for the winter season who are Snow Owls. Can native plants be used in landscaping and could they be a green roof? Can part of the swamp be perserved? If not can artificial marsh buoys be made and native plants used for landscaping? Will the community life around the project be affected? How many local jobs are projected? (to off set the environmental impact) What are the projected benefits for the local community? What does Micron have to offer the local community as they plan their environmental impact? This is going to affect the housing market, are there any plans in order to ease this transition or combat this? Will this massive strain on the electricity affect my electricity (more blackouts)? Will first responders need specialized training in order to handle any environmental toxic concerns? How will carbon emission levels be kept low? Will taxes be raised to pay for water? Will this extra use of water make water prices go up? How will the negative effects of this infrastructure affect me economically in the beginning and through to the future? Will internships be offered for local school students? If flooding would happen and major damage be done to the plant, how will this effect taxpayers? How will this effect the Traffic? What if this affects the flow of traffic so they have to take more land to make more roads? It's already getting bad because of this project and other companies. What will salary look like for the workers? How will the whole micron building effect homeowners around the site? How much money will it take to pay for the whole building? This is also gonna cause many economic concerns what are we going to do about that? Why should we have to be worried about paying more money for utilities, for the success and operation of a company? Will this have a major impact on out energy? Thank you for your time and consideration, Michelle Fanelli 2 141 From: Brian Cocca Sent: Monday, October 30, 2023 4:10:04 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Environmental concerns NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Hello, I'd like the following to be on the record as areas of concerns for the EIS, as well as general input for Micron on how they can help support the community. Thank you. We have heard a lot of the expected benefits of the proposed Micron chip plant; $100 billion invested in the community over 20 years- that’s on average $5 billion a year. To add some perspective to that number, that’s over 3 times the entire budget of the county this year ($1.5 billion) and more than 5 times the total budget of the City of Syracuse ($869 million). This is a very significant investment. 2 141 From: Brian Cocca Sent: Monday, October 30, 2023 4:10:04 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Environmental concerns NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Hello, I'd like the following to be on the record as areas of concerns for the EIS, as well as general input for Micron on how they can help support the community. Thank you. We have heard a lot of the expected benefits of the proposed Micron chip plant; $100 billion invested in the community over 20 years- that’s on average $5 billion a year. To add some perspective to that number, that’s over 3 times the entire budget of the county this year ($1.5 billion) and more than 5 times the total budget of the City of Syracuse ($869 million). This is a very significant investment. Primarily the benefits of these investments will manifest as new jobs and educational avenues to qualify for those jobs. Micron has been working strategically to ally itself with the organizations and communities that have traditionally been critical of such large industrial developments, by reaching out and giving opportunities (and promotional items) to many groups that are historically disenfranchised and often negatively impacted by these types of projects. This is good, even if it’s simply a stipulation of their federal subsidy. We hope those communities make some strong and wise demands. One group that seems to be left out of the strategic partnership conversation is the natural environment. We do not hear about a single environmental benefit, only impacts. When Micron asked the community how to invest $500 million toward community projects, their focus was squarely on housing units, education, and programs for their workers and nothing about making the community a healthier, more enjoyable place to be outside of the school-to-work-to-house triangle. The community investment can be summed up as “how do we create good workers and where can we put them?”. So far what we can expect from an environmental aspect is that they will simply comply with whatever regulators force them to do. Literally, the bare minimum. Primarily the benefits of these investments will manifest as new jobs and educational avenues to qualify for those jobs. Micron has been working strategically to ally itself with the organizations and communities that have traditionally been critical of such large industrial developments, by reaching out and giving opportunities (and promotional items) to many groups that are historically disenfranchised and often negatively impacted by these types of projects. This is good, even if it’s simply a stipulation of their federal subsidy. We hope those communities make some strong and wise demands. One group that seems to be left out of the strategic partnership conversation is the natural environment. We do not hear about a single environmental benefit, only impacts. When Micron asked the community how to invest $500 million toward community projects, their focus was squarely on housing units, education, and programs for their workers and nothing about making the community a healthier, more enjoyable place to be outside of the school-to-work-to-house triangle. The community investment can be summed up as “how do we create good workers and where can we put them?”. So far what we can expect from an environmental aspect is that they will simply comply with whatever regulators force them to do. Literally, the bare minimum. This is a big, sprawling project that will have lots of direct and indirect impacts. Impacts that we can anticipate as well unforeseeable impacts; here are some of my concerns: 1 142 -The 48 million gallons of water per day they intend to use and then, presumably, pump back into the wild in a form that’s not clean enough for them, yet (we hope) not so contaminated that it’s dangerous to nature…or at least clean enough that it is not illegal. - The clearing and development of thousands of acres of greenfield sites. The 1,200+ acres of what is billed as the White Pine Commerce Park (currently just wooded and agricultural land) for the main project, plus 5 times as many supply chain businesses (6,000 acres? that’s not clear), and the many various other greenfield sites in the county which will be cleared to add 12,000+ new housing units that are starting to spring up in advance of the facility. This is a big, sprawling project that will have lots of direct and indirect impacts. Impacts that we can anticipate as well unforeseeable impacts; here are some of my concerns: 1 142 -The 48 million gallons of water per day they intend to use and then, presumably, pump back into the wild in a form that’s not clean enough for them, yet (we hope) not so contaminated that it’s dangerous to nature…or at least clean enough that it is not illegal. - The clearing and development of thousands of acres of greenfield sites. The 1,200+ acres of what is billed as the White Pine Commerce Park (currently just wooded and agricultural land) for the main project, plus 5 times as many supply chain businesses (6,000 acres? that’s not clear), and the many various other greenfield sites in the county which will be cleared to add 12,000+ new housing units that are starting to spring up in advance of the facility. -Fewer places for humans to enjoy peace and quiet in the natural world. People who grew up in the area 40 years ago or more will likely remember having woods nearby where they would play. Those wild, open spaces have been steadily vanishing to make room for housing developments and commercial enterprises. We will never have those wild spaces back in our lifetime. Numerous studies have demonstrated the benefit to humans of having green spaces nearby, and the size and quality of those spaces matters too. Children are especially being deprived of quality outdoor spaces and it’s manifesting itself in many negative ways. -The further fragmentation and destruction of habitat for hundreds of species of plants and animals. As humans we tend not to think about green space as anyone’s home, however whenever we bulldoze, pave and build on an area we kill/evict all the plants and creatures that lived there and justify it by doing an Environmental Impact Study that tells us it’s an acceptable sacrifice. -Increased noise, light, air, and water pollution. We already live in a community where the drone of traffic can be heard from almost everywhere. We live in a place where seeing the stars at night is becoming harder and harder. And the air and water quality of our area are some of our greatest features- let’s not ruin these natural treasures any further in the name of earning dollars. -Fewer places for humans to enjoy peace and quiet in the natural world. People who grew up in the area 40 years ago or more will likely remember having woods nearby where they would play. Those wild, open spaces have been steadily vanishing to make room for housing developments and commercial enterprises. We will never have those wild spaces back in our lifetime. Numerous studies have demonstrated the benefit to humans of having green spaces nearby, and the size and quality of those spaces matters too. Children are especially being deprived of quality outdoor spaces and it’s manifesting itself in many negative ways. -The further fragmentation and destruction of habitat for hundreds of species of plants and animals. As humans we tend not to think about green space as anyone’s home, however whenever we bulldoze, pave and build on an area we kill/evict all the plants and creatures that lived there and justify it by doing an Environmental Impact Study that tells us it’s an acceptable sacrifice. -Increased noise, light, air, and water pollution. We already live in a community where the drone of traffic can be heard from almost everywhere. We live in a place where seeing the stars at night is becoming harder and harder. And the air and water quality of our area are some of our greatest features- let’s not ruin these natural treasures any further in the name of earning dollars. -Increased traffic and the dangers associated with increased traffic. With more traffic will inevitably come more accidents, injuries and death, not to mention the more mundane daily headache of more vehicles on the roads, more road construction and more delays and more noise. I challenge Micron and the people of Central New York to demand that Micron’s environmental impact not just be seen as an inevitable cost in the name of economic progress, and instead be seen as an opportunity to create a world-class model of how industry can not only lift people up economically, but also provide real improvement to the natural world we all depend on. Here are a few ideas; Donating enough money to the CNY Land Trust to create public green spaces that exceeds the footprint of their facilities and the support infrastructure. I would like to see 6,000+ acres preserved. Donate enough money to the Onondaga Earth Corps to exceed their annual funding needs. This organization helps teach young people about ecology and fits in with Micron’s STEM education mission goal. Demand that new housing have walkable community parks that exceed the WHO recommendation of green space per person, and demand current brownfield sites be the priority sites of new development. Completely utilize their rooftop space and parking areas for solar PV generation. Demand outdoor lighting be minimal and not face upward or outward if possible. -Increased traffic and the dangers associated with increased traffic. With more traffic will inevitably come more accidents, injuries and death, not to mention the more mundane daily headache of more vehicles on the roads, more road construction and more delays and more noise. I challenge Micron and the people of Central New York to demand that Micron’s environmental impact not just be seen as an inevitable cost in the name of economic progress, and instead be seen as an opportunity to create a world-class model of how industry can not only lift people up economically, but also provide real improvement to the natural world we all depend on. Here are a few ideas; Donating enough money to the CNY Land Trust to create public green spaces that exceeds the footprint of their facilities and the support infrastructure. I would like to see 6,000+ acres preserved. Donate enough money to the Onondaga Earth Corps to exceed their annual funding needs. This organization helps teach young people about ecology and fits in with Micron’s STEM education mission goal. Demand that new housing have walkable community parks that exceed the WHO recommendation of green space per person, and demand current brownfield sites be the priority sites of new development. Completely utilize their rooftop space and parking areas for solar PV generation. Demand outdoor lighting be minimal and not face upward or outward if possible. Create a transportation plan that prioritizes walkability, bicycling and mass transit over automobiles 2 143 From: Lenny Siegel Sent: Monday, October 30, 2023 9:46:17 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: CPEO Comments on the SEQRA Scope of Work for Micron Semiconductor Fabrication NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Please find attached our comments on the SEQRA Scope of Work for Micron Semiconductor Fabrication, as well as two reference documents. Lenny Siegel — Lenny Siegel Executive Director Center for Public Environmental Oversight A project of the Pacific Studies Center LSiegel@cpeo.org P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 http://www.cpeo.org Author: DISTURBING THE WAR: The Inside Story of the Movement to Get Stanford University out of Southeast Asia - 1965–1975 (See http://a3mreunion.org) 1 144 Create a transportation plan that prioritizes walkability, bicycling and mass transit over automobiles 2 143 From: Lenny Siegel Sent: Monday, October 30, 2023 9:46:17 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: CPEO Comments on the SEQRA Scope of Work for Micron Semiconductor Fabrication NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Please find attached our comments on the SEQRA Scope of Work for Micron Semiconductor Fabrication, as well as two reference documents. Lenny Siegel — Lenny Siegel Executive Director Center for Public Environmental Oversight A project of the Pacific Studies Center LSiegel@cpeo.org P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 http://www.cpeo.org Author: DISTURBING THE WAR: The Inside Story of the Movement to Get Stanford University out of Southeast Asia - 1965–1975 (See http://a3mreunion.org) 1 144 CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT A project of the Pacific Studies Center P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 (,,*$""---!%*&)!)+' TO: Micron Project, Office of Econom ic Developm ent, Onondaga County FROM: Lenny Siegel, Center for Public Environm ental Oversight DATE: October 30, 2023 SUBJECT: SEQRA Scope of Work for Micron Sem iconductor Fabrication Thank you for the opportunity to com m ent on the Septem ber 12, 2023 Draft SEQRA Scope of Work for Micron Sem iconductor Fabrication. I have been asked by residents of Onondoga County to offer m y com m ents. I have nearly five decades of experience m onitoring and influencing the worker health and environm ental im pacts of the sem iconductor industry, through the Pacific Studies Center, the Project on Health and Safety in Electronics, the Silicon Valley Toxics Coalition, and the Center for Public Environm ental Oversight, as well as m y service as Council Mem ber and Mayor of Mountain View, the birthplace of the com m ercial sem iconductor industry. CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT A project of the Pacific Studies Center P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 (,,*$""---!%*&)!)+' TO: Micron Project, Office of Econom ic Developm ent, Onondaga County FROM: Lenny Siegel, Center for Public Environm ental Oversight DATE: October 30, 2023 SUBJECT: SEQRA Scope of Work for Micron Sem iconductor Fabrication Thank you for the opportunity to com m ent on the Septem ber 12, 2023 Draft SEQRA Scope of Work for Micron Sem iconductor Fabrication. I have been asked by residents of Onondoga County to offer m y com m ents. I have nearly five decades of experience m onitoring and influencing the worker health and environm ental im pacts of the sem iconductor industry, through the Pacific Studies Center, the Project on Health and Safety in Electronics, the Silicon Valley Toxics Coalition, and the Center for Public Environm ental Oversight, as well as m y service as Council Mem ber and Mayor of Mountain View, the birthplace of the com m ercial sem iconductor industry. The sem iconductor industry produces rem arkable products that we all use. Unfortunately, its environm ental and workplace health record is less than rem arkable. The MEW Superfund Area here in Mountain View was the hom e of som e of the earliest successful integrated circuit m anufacturers. The wafer fabs are gone, but despite the scores (hundreds?) of m illions of dollars spent thus far on subsurface rem ediation, the contam ination—including the risk of public exposure—will rem ain for decades m ore, if not longer. The sam e is true at other Silicon Valley sites. The SEQRA process provides an opportunity to identify and m inim ize, in advance, the environm ental hazards of sem iconductor production. By doing so, it can lead to appropriate regulation, research on waste m anagem ent and pollution prevention, and investm ents in safer facilities. Sem iconductor production is essentially a series of chem ical processes that use a wide variety of hazardous substances. The industry explains, “While in the 1980s sem iconductor fabs used 145 " The sem iconductor industry produces rem arkable products that we all use. Unfortunately, its environm ental and workplace health record is less than rem arkable. The MEW Superfund Area here in Mountain View was the hom e of som e of the earliest successful integrated circuit m anufacturers. The wafer fabs are gone, but despite the scores (hundreds?) of m illions of dollars spent thus far on subsurface rem ediation, the contam ination—including the risk of public exposure—will rem ain for decades m ore, if not longer. The sam e is true at other Silicon Valley sites. The SEQRA process provides an opportunity to identify and m inim ize, in advance, the environm ental hazards of sem iconductor production. By doing so, it can lead to appropriate regulation, research on waste m anagem ent and pollution prevention, and investm ents in safer facilities. Sem iconductor production is essentially a series of chem ical processes that use a wide variety of hazardous substances. The industry explains, “While in the 1980s sem iconductor fabs used 145 " fewer than 20 elem ents, today they are using over 50% of the nonradioactive elem ents in the periodic table.”1 Those include toxic heavy m etals. The industry is a m ajor user of Per- and Polyfluorinated Substances (PFAS), also known as “Forever Chem icals” because they persist and bioaccum ulate in the environm ent and even hum an bloodstream s. As New York state agencies are well aware, these com pounds are toxic, even at extrem ely low exposure concentrations, through m ultiple pathways. But industry has becom e reliant on PFAS without first exam ining the hum an and environm ental risks. It explains, “Without PFAS, the ability to produce sem iconductors (and the facilities and equipm ent related to and supporting sem iconductor m anufacturing) would be put at risk.”2 Use and release of the industry’s hazardous building blocks are regulated by both state and federal statutes and regulations, but the public is generally unaware of the series of upcom ing perm it applications that Micron is expecting to m ake. The SEQRA review should list all anticipated perm itting processes, with the anticipated schedule of public com m ent periods, and it should require public notification to interested parties of each perm it application as it is subm itted. fewer than 20 elem ents, today they are using over 50% of the nonradioactive elem ents in the periodic table.”1 Those include toxic heavy m etals. The industry is a m ajor user of Per- and Polyfluorinated Substances (PFAS), also known as “Forever Chem icals” because they persist and bioaccum ulate in the environm ent and even hum an bloodstream s. As New York state agencies are well aware, these com pounds are toxic, even at extrem ely low exposure concentrations, through m ultiple pathways. But industry has becom e reliant on PFAS without first exam ining the hum an and environm ental risks. It explains, “Without PFAS, the ability to produce sem iconductors (and the facilities and equipm ent related to and supporting sem iconductor m anufacturing) would be put at risk.”2 Use and release of the industry’s hazardous building blocks are regulated by both state and federal statutes and regulations, but the public is generally unaware of the series of upcom ing perm it applications that Micron is expecting to m ake. The SEQRA review should list all anticipated perm itting processes, with the anticipated schedule of public com m ent periods, and it should require public notification to interested parties of each perm it application as it is subm itted. It should also identify hazardous substances, whether or not they currently have prom ulgated exposure standards. For exam ple, the industry reports, “Most PFAS are not regulated pollutants and therefore unless com pany specific provisions are in place, the wastewater from processes that use aqueous wet chem ical form ulations that contain PFAS would likely be discharged to the publicly owned treatm ent works without substantive rem oval of the PFAS.”3 Furtherm ore, potential workplace exposures should not be ignored because exposures are below the Occupational Exposure Level (OEL) or even a fraction of the OEL, as industry suggests.4 In m ost cases OELs, such as the Occupational Safety and Health Adm inistration’s (OSHA) Perm issible Exposure Lim its (PELs), are orders of m agnitude above what the science— including U.S. EPA studies—dictates. While the draft Scope of Work proposes m any useful Technical Chapters, there is room for m ore specificity. I focus on the use and release of hazardous substances. For Solid Wastes and Hazardous Materials, the Scope of Work states, “The chapter will identify any hazardous m aterials (including any chem ical or petroleum bulk storage) that would be used, stored, transported, or generated by the Proposed Project and m easures to protect It should also identify hazardous substances, whether or not they currently have prom ulgated exposure standards. For exam ple, the industry reports, “Most PFAS are not regulated pollutants and therefore unless com pany specific provisions are in place, the wastewater from processes that use aqueous wet chem ical form ulations that contain PFAS would likely be discharged to the publicly owned treatm ent works without substantive rem oval of the PFAS.”3 Furtherm ore, potential workplace exposures should not be ignored because exposures are below the Occupational Exposure Level (OEL) or even a fraction of the OEL, as industry suggests.4 In m ost cases OELs, such as the Occupational Safety and Health Adm inistration’s (OSHA) Perm issible Exposure Lim its (PELs), are orders of m agnitude above what the science— including U.S. EPA studies—dictates. While the draft Scope of Work proposes m any useful Technical Chapters, there is room for m ore specificity. I focus on the use and release of hazardous substances. For Solid Wastes and Hazardous Materials, the Scope of Work states, “The chapter will identify any hazardous m aterials (including any chem ical or petroleum bulk storage) that would be used, stored, transported, or generated by the Proposed Project and m easures to protect 1 “Background on Sem iconductor Manufacturing and PFAS,” Sem iconductor Association (SIA) PFAS Consortium , May 17, 2023, p. 54. The SIA PFAS Consortium is m ade up of chipm akers and their suppliers of equipm ent and m aterials. To sign up to receive their technical papers, go to https://www.sem iconductors.org/pfas/ . I am attaching this docum ent. 2 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 3. I am also attaching this docum ent. 3 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 3 4 “Background on Sem iconductor Manufacturing and PFAS,” SIA PFAS Consortium , May 17, 2023, p. 25. 146 # against releases to the environm ent. Any warranted rem edial approaches for addressing identified or potential contam inated m aterials would be described.” I suggest that the Review describe any perm itting required for the Treatm ent, Storage, and Disposal of hazardous m aterials and solid wastes, and that it list the storage requirem ents, such as double-walled tanks and piping, necessary to prevent environm ental releases. Furtherm ore, how will em ployees be educated about the risk from leaks and spills, as well as what to do when they occur? 1 “Background on Sem iconductor Manufacturing and PFAS,” Sem iconductor Association (SIA) PFAS Consortium , May 17, 2023, p. 54. The SIA PFAS Consortium is m ade up of chipm akers and their suppliers of equipm ent and m aterials. To sign up to receive their technical papers, go to https://www.sem iconductors.org/pfas/ . I am attaching this docum ent. 2 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 3. I am also attaching this docum ent. 3 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 3 4 “Background on Sem iconductor Manufacturing and PFAS,” SIA PFAS Consortium , May 17, 2023, p. 25. 146 # against releases to the environm ent. Any warranted rem edial approaches for addressing identified or potential contam inated m aterials would be described.” I suggest that the Review describe any perm itting required for the Treatm ent, Storage, and Disposal of hazardous m aterials and solid wastes, and that it list the storage requirem ents, such as double-walled tanks and piping, necessary to prevent environm ental releases. Furtherm ore, how will em ployees be educated about the risk from leaks and spills, as well as what to do when they occur? To what degree will disposal—including landfilling and incineration—create off-site hazards? Industry reports, “Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerized to be treated at an offsite licensed treatm ent and disposal facility, as a blended fuel by high tem perature incineration or reprocessing.”5 Perfluorinated com pounds are particularly difficult to destroy using incineration. Furtherm ore, even when perm itted by regulatory agencies, incineration m ay release products of incom plete com bustion into the atm osphere. For Air Quality, the Scope of Work barely m entions the potential em issions of highly toxic air contam inants. Historically the industry has used lethal gases such as arsine and phosphine, as well as toxic gases such as hydrogen chloride (the gaseous form of hydrochloric acid). Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipm ent to respond safely to such releases. Em ployees should be warned about the toxicity of gases used by the industry and trained to protect them selves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity. To what degree will disposal—including landfilling and incineration—create off-site hazards? Industry reports, “Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerized to be treated at an offsite licensed treatm ent and disposal facility, as a blended fuel by high tem perature incineration or reprocessing.”5 Perfluorinated com pounds are particularly difficult to destroy using incineration. Furtherm ore, even when perm itted by regulatory agencies, incineration m ay release products of incom plete com bustion into the atm osphere. For Air Quality, the Scope of Work barely m entions the potential em issions of highly toxic air contam inants. Historically the industry has used lethal gases such as arsine and phosphine, as well as toxic gases such as hydrogen chloride (the gaseous form of hydrochloric acid). Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipm ent to respond safely to such releases. Em ployees should be warned about the toxicity of gases used by the industry and trained to protect them selves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity. I am surprised and disappointed that no chapter is listed for Wastewater and Stormwater. The release of toxic contam inants through water pathways is one of the m ost serious threats of sem iconductor productions. Releases of certain contam inants in wastewater could com prom ise the operations of the Oak Orchard Wastewater Treatm ent Plant, even underm ining com pliance with its discharge perm it. The draft Scope of Work m entions industrial pre-treatm ent. Not only should that be described in an environm ental review chapter, but the review should identify ways to pre-treat hazardous chem icals, perhaps even reusing som e, before com ingling with other wastes. This is particularly im portant for PFAS, because in the future m ore PFAS com pounds are likely to be subjected to enforceable environm ental standards, m any at very low concentrations. In fact, given the vast num ber of PFAS used by the sem iconductor industry, the Review should identify m ethods for sam pling total organic fluorine, not just targeted com pounds. “At present, only a sm all percentage of PFAS com pounds within typical sem iconductor wastewater are detectable and quantifiable using conventional U.S. EPA analytical m ethods for PFAS-containing 5 “Background on Sem iconductor Manufacturing and PFAS,” SIA PFAS Consortium , May 17, 2023, p. 30. 147 $ I am surprised and disappointed that no chapter is listed for Wastewater and Stormwater. The release of toxic contam inants through water pathways is one of the m ost serious threats of sem iconductor productions. Releases of certain contam inants in wastewater could com prom ise the operations of the Oak Orchard Wastewater Treatm ent Plant, even underm ining com pliance with its discharge perm it. The draft Scope of Work m entions industrial pre-treatm ent. Not only should that be described in an environm ental review chapter, but the review should identify ways to pre-treat hazardous chem icals, perhaps even reusing som e, before com ingling with other wastes. This is particularly im portant for PFAS, because in the future m ore PFAS com pounds are likely to be subjected to enforceable environm ental standards, m any at very low concentrations. In fact, given the vast num ber of PFAS used by the sem iconductor industry, the Review should identify m ethods for sam pling total organic fluorine, not just targeted com pounds. “At present, only a sm all percentage of PFAS com pounds within typical sem iconductor wastewater are detectable and quantifiable using conventional U.S. EPA analytical m ethods for PFAS-containing 5 “Background on Sem iconductor Manufacturing and PFAS,” SIA PFAS Consortium , May 17, 2023, p. 30. 147 $ m aterials.”6 However, U.S. EPA has a draft m ethod (1621) for m easuring total organic fluorine.7 Furtherm ore, academ ic researchers are finding that failure to m easure total fluorine m isses discharges of significant quantities of PFAS pollutants. “[B]ecause m any studies of total organic fluorine have shown that total PFAS concentrations are at least 10 tim es higher than the sum of target PFASs. However, this does reinforce the idea that PFAS m onitoring should incorporate com plem entary target and nontarget analyses or otherwise include m easures of total organic fluorine to accurately assess PFAS abundance and potential environm ental im pacts.”8 Furtherm ore, there should be a chapter on Life-Cycle Environmental Impacts. What hazardous substances rem ain in the finished sem iconductor products, including packaging. At the end-of- life, are there m echanism s for preventing the environm ental release of sem iconductor hazardous substances? Industry’s PFAS Consortium reports, “At the end-of-life of the product containing the sem iconductor, or any parts replaced during the m anufacture of sem iconductors, would enter waste disposal stream s where any PFAS contained therein could enter the environm ent.”9 Are m anufacturers responsible for end-of-life pollution? m aterials.”6 However, U.S. EPA has a draft m ethod (1621) for m easuring total organic fluorine.7 Furtherm ore, academ ic researchers are finding that failure to m easure total fluorine m isses discharges of significant quantities of PFAS pollutants. “[B]ecause m any studies of total organic fluorine have shown that total PFAS concentrations are at least 10 tim es higher than the sum of target PFASs. However, this does reinforce the idea that PFAS m onitoring should incorporate com plem entary target and nontarget analyses or otherwise include m easures of total organic fluorine to accurately assess PFAS abundance and potential environm ental im pacts.”8 Furtherm ore, there should be a chapter on Life-Cycle Environmental Impacts. What hazardous substances rem ain in the finished sem iconductor products, including packaging. At the end-of- life, are there m echanism s for preventing the environm ental release of sem iconductor hazardous substances? Industry’s PFAS Consortium reports, “At the end-of-life of the product containing the sem iconductor, or any parts replaced during the m anufacture of sem iconductors, would enter waste disposal stream s where any PFAS contained therein could enter the environm ent.”9 Are m anufacturers responsible for end-of-life pollution? Finally, there are those who argue that a thorough environm ental review, as I have suggested, would unnecessarily delay the operation of new, advanced wafer fabrication plants. I find it hard to believe that docum enting potential hazardous substance and waste im pacts in advance would ham per the construction of a factory that is not expected to begin production until 2032. Micron—indeed, all sem iconductor m anufacturers—should already know what hazardous substances it uses and releases. Shouldn’t the public also know? The sem iconductor and com puter m anufacturing industry, such as IBM’s com plex in Endicott, New York, has a long history of causing pollution that threatens public health and the environm ent. An industry that claim s that PFAS—chem icals that are persistent, bioaccum ulative, and extrem ely toxic in low concentrations—are essential to its operations should be required to come clean about its environm ental and public health hazards. Finally, there are those who argue that a thorough environm ental review, as I have suggested, would unnecessarily delay the operation of new, advanced wafer fabrication plants. I find it hard to believe that docum enting potential hazardous substance and waste im pacts in advance would ham per the construction of a factory that is not expected to begin production until 2032. Micron—indeed, all sem iconductor m anufacturers—should already know what hazardous substances it uses and releases. Shouldn’t the public also know? The sem iconductor and com puter m anufacturing industry, such as IBM’s com plex in Endicott, New York, has a long history of causing pollution that threatens public health and the environm ent. An industry that claim s that PFAS—chem icals that are persistent, bioaccum ulative, and extrem ely toxic in low concentrations—are essential to its operations should be required to come clean about its environm ental and public health hazards. 6 “PFOS and PFOA Conversion to Short-Chain PFAS-Containing Materials Used in Sem iconductor Manufacturing,” SIA PFAS Consortium , June 5, 2023, p. 11. 7 Draft Method 1621: Screening Method for the Determ ination of Adsorbable Organic Fluorine (AOF) in Aqueous Matrices by Com bustion Ion Chrom atography (CIC), U.S. EPA, April 2022, https://www.epa.gov/system /files/docum ents/2022-04/draft-m ethod-1621-for-screening-aof- in-aqueous-m atrices-by-cic_0.pdf 8 Paige Jacob, Kristas Barzen-Hanson, and Dam ian Helbling, “Target and Nontarget Analysis of Per- and Polyfluoralkyl Substances in Wastewater from Electronics Fabrication Facilities,” Environmental Science & Technology, February 16, 2021, p. 2353. https://pubs.acs.org/doi/10.1021/acs.est.0c06690 9 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 90, 148 6 “PFOS and PFOA Conversion to Short-Chain PFAS-Containing Materials Used in Sem iconductor Manufacturing,” SIA PFAS Consortium , June 5, 2023, p. 11. 7 Draft Method 1621: Screening Method for the Determ ination of Adsorbable Organic Fluorine (AOF) in Aqueous Matrices by Com bustion Ion Chrom atography (CIC), U.S. EPA, April 2022, https://www.epa.gov/system /files/docum ents/2022-04/draft-m ethod-1621-for-screening-aof- in-aqueous-m atrices-by-cic_0.pdf 8 Paige Jacob, Kristas Barzen-Hanson, and Dam ian Helbling, “Target and Nontarget Analysis of Per- and Polyfluoralkyl Substances in Wastewater from Electronics Fabrication Facilities,” Environmental Science & Technology, February 16, 2021, p. 2353. https://pubs.acs.org/doi/10.1021/acs.est.0c06690 9 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 90, 148 Background on Semiconductor Manufacturing and PFAS Semiconductor PFAS Consortium May 17, 2023 Acknowledgments: The consortium would like to acknowledge the contributions of the Semiconductor PFAS Consortium for their efforts to compile this information. The consortium would also like to acknowledge the assistance provided by David Medeiros of Entegris, Edward Watkins and Thomas Dory of Fujifilm Electronic Materials, Brooke Tvermoes of IBM, Dawn Graunke and Patrick Gottsacker of Intel, David Speed of Global Foundries, Jim Snow of SCREEN Semiconductor Solutions, Sarah Wallace and Tim Yeakley of Texas Instruments Inc., Robert Hanley supporting TSMC, Laurie Beu of Laurie Beu Consulting, and Melissa Gresham of Melissa Gresham Consulting. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 1 149 Background on Semiconductor Manufacturing and PFAS Semiconductor PFAS Consortium May 17, 2023 Acknowledgments: The consortium would like to acknowledge the contributions of the Semiconductor PFAS Consortium for their efforts to compile this information. The consortium would also like to acknowledge the assistance provided by David Medeiros of Entegris, Edward Watkins and Thomas Dory of Fujifilm Electronic Materials, Brooke Tvermoes of IBM, Dawn Graunke and Patrick Gottsacker of Intel, David Speed of Global Foundries, Jim Snow of SCREEN Semiconductor Solutions, Sarah Wallace and Tim Yeakley of Texas Instruments Inc., Robert Hanley supporting TSMC, Laurie Beu of Laurie Beu Consulting, and Melissa Gresham of Melissa Gresham Consulting. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 1 149 This publication was developed by the Semiconductor PFAS Consortium. The contents do not necessarily reflect the uses, views or stated policies of individual consortium members. Also published in the Semiconductor PFAS Consortium white paper series: Case Study PFOS and PFOA Conversion to Short-Chain PFAS Used in Semiconductor Manufacturing Case Study PFAS-Containing Surfactants Used in Semiconductor Manufacturing Case Study PFAS-Containing Photo-Acid Generators Used in Semiconductor Manufacturing PFAS-Containing Fluorochemicals Used in Semiconductor Manufacturing Plasma-Enabled Etch White Paper and Deposition White Paper PFAS-Containing Heat Transfer Fluids Used in Semiconductor Manufacturing White Paper PFAS-Containing Materials Used in Semiconductor Assembly, Test and Substrate Processes White Paper PFAS-Containing Wet Chemistries Used in Semiconductor Manufacturing White Paper PFAS-Containing Lubricants Used in Semiconductor Manufacturing White Paper PFAS-Containing Articles Used in Semiconductor Manufacturing This publication was developed by the Semiconductor PFAS Consortium. The contents do not necessarily reflect the uses, views or stated policies of individual consortium members. Also published in the Semiconductor PFAS Consortium white paper series: Case Study PFOS and PFOA Conversion to Short-Chain PFAS Used in Semiconductor Manufacturing Case Study PFAS-Containing Surfactants Used in Semiconductor Manufacturing Case Study PFAS-Containing Photo-Acid Generators Used in Semiconductor Manufacturing PFAS-Containing Fluorochemicals Used in Semiconductor Manufacturing Plasma-Enabled Etch White Paper and Deposition White Paper PFAS-Containing Heat Transfer Fluids Used in Semiconductor Manufacturing White Paper PFAS-Containing Materials Used in Semiconductor Assembly, Test and Substrate Processes White Paper PFAS-Containing Wet Chemistries Used in Semiconductor Manufacturing White Paper PFAS-Containing Lubricants Used in Semiconductor Manufacturing White Paper PFAS-Containing Articles Used in Semiconductor Manufacturing About the Semiconductor PFAS Consortium The Semiconductor PFAS Consortium is an international group of semiconductor industry stakeholders formed to collect the technical data needed to formulate an industry approach to perfluoroalkyl and polyfluoroalkyl substances (PFAS). Consortium membership comprises semiconductor manufacturers and members of the supply chain including chemical, material and equipment suppliers. The consortium includes technical working groups, each focused on the: • Identification of PFAS uses, why they are used, and the viability of alternatives. • Application of the pollution prevention hierarchy to (where possible) reduce PFAS consumption or eliminate use, identify alternatives, and minimize and control emissions. • Development of socioeconomic impact analysis data. • Identification of research needs. This data will better inform public policy and legislation obd^oafkd qeb pbjf`lkar`qlo fkarpqov„p rpb lc PFAS and will focus R&D efforts. The Semiconductor PFAS Consortium is organized under the auspices of the Semiconductor Industry Association (SIA). For more information, see www.semiconductors.org. AGC Chemicals America Georg Fischer SCREEN Semiconductor Solutions Co., Ltd. Applied Materials Inc. GlobalFoundries Senju Metal Industry Co. Ltd. Arkema Henkel Shin-Etsu MicroSi ASML Hitachi High-Tech America Skywater BASF IBM Solvay Brewer Science Intel Corp. STMicroelectronics Central Glass Co. Ltd. JSR Sumitomo Chemical Co. Ltd. Chemours Lam Research Texas Instruments Inc. DuPont Linde Tokyo Electron Ltd. Edwards Micron Technology Tokyo Ohka Kogyo Co. Ltd. EMD Electronics Moses Lake Industries TSMC Entegris NXP Semiconductors Zeiss Fujifilm Electronic Materials Samsung Austin Semiconductor About the Semiconductor PFAS Consortium The Semiconductor PFAS Consortium is an international group of semiconductor industry stakeholders formed to collect the technical data needed to formulate an industry approach to perfluoroalkyl and polyfluoroalkyl substances (PFAS). Consortium membership comprises semiconductor manufacturers and members of the supply chain including chemical, material and equipment suppliers. The consortium includes technical working groups, each focused on the: • Identification of PFAS uses, why they are used, and the viability of alternatives. • Application of the pollution prevention hierarchy to (where possible) reduce PFAS consumption or eliminate use, identify alternatives, and minimize and control emissions. • Development of socioeconomic impact analysis data. • Identification of research needs. This data will better inform public policy and legislation obd^oafkd qeb pbjf`lkar`qlo fkarpqov„p rpb lc PFAS and will focus R&D efforts. The Semiconductor PFAS Consortium is organized under the auspices of the Semiconductor Industry Association (SIA). For more information, see www.semiconductors.org. AGC Chemicals America Georg Fischer SCREEN Semiconductor Solutions Co., Ltd. Applied Materials Inc. GlobalFoundries Senju Metal Industry Co. Ltd. Arkema Henkel Shin-Etsu MicroSi ASML Hitachi High-Tech America Skywater BASF IBM Solvay Brewer Science Intel Corp. STMicroelectronics Central Glass Co. Ltd. JSR Sumitomo Chemical Co. Ltd. Chemours Lam Research Texas Instruments Inc. DuPont Linde Tokyo Electron Ltd. Edwards Micron Technology Tokyo Ohka Kogyo Co. Ltd. EMD Electronics Moses Lake Industries TSMC Entegris NXP Semiconductors Zeiss Fujifilm Electronic Materials Samsung Austin Semiconductor Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 2 150 Table of Contents 1.0 Overview of the Semiconductor Industry ............................................................................................... 4 2.0 Introduction ............................................................................................................................................. 5 3.0 PFAS Definition...................................................................................................................................... 8 4.0 History of Semiconductor Industry Voluntary Actions on PFAS ........................................................... 8 5.0 Semiconductor Overview........................................................................................................................ 9 6.0 Supply-Chain Complexity .................................................................................................................... 10 7.0 Clean-Room Design .............................................................................................................................. 13 8.0 Tool Exhaust ......................................................................................................................................... 15 9.0 The Importance of Contamination Control ........................................................................................... 15 10.0 Properties of Fluorine and Organofluorine Compounds ..................................................................... 16 10.1 Perfluoroalkyl Acids ....................................................................................................................... 17 10.2 Surfactants....................................................................................................................................... 17 10.3 Fluorochemicals in Semiconductor Plasma-Enabled Etch and Deposition Processes .................... 18 11.0 Sustainability and the Semiconductor Technology Timeline ............................................................. 21 12.0 EHS Controls ...................................................................................................................................... 24 12.1 Occupational Exposure Control Strategy ........................................................................................ 24 12.2 SEMI Safety Guidelines for Tool Design ....................................................................................... 25 12.3 Safety Procedures and On-Site Industrial Hygiene Staff ................................................................ 26 12.4 Qualitative and Quantitative Chemical Risk Assessments ............................................................. 26 12.4.1 SEMATECH PFOS Industrial Hygiene Monitoring In and Around Track Tools ................... 26 12.4.2 NIOSH Research on PFAS ...................................................................................................... 27 12.4.3 Environmental Controls ........................................................................................................... 27 12.4.4 Wastewater Discharges and Treatment .................................................................................... 27 12.4.5 PFAS Waste Disposal and Destruction by Incineration .......................................................... 30 12.4.6 Air Emissions Control and Abatement .................................................................................... 30 13.0 R&D Needs ......................................................................................................................................... 32 13.0 Conclusions ......................................................................................................................................... 33 14.0 References ........................................................................................................................................... 35 Appendix A: Glossary of Acronyms and Terms ......................................................................................... 40 Appendix B: Semiconductor and Supply-Chain Complexity ..................................................................... 52 Appendix C: List of SEMI Safety Guidelines ............................................................................................ 60 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 2 150 Table of Contents 1.0 Overview of the Semiconductor Industry ............................................................................................... 4 2.0 Introduction ............................................................................................................................................. 5 3.0 PFAS Definition...................................................................................................................................... 8 4.0 History of Semiconductor Industry Voluntary Actions on PFAS ........................................................... 8 5.0 Semiconductor Overview........................................................................................................................ 9 6.0 Supply-Chain Complexity .................................................................................................................... 10 7.0 Clean-Room Design .............................................................................................................................. 13 8.0 Tool Exhaust ......................................................................................................................................... 15 9.0 The Importance of Contamination Control ........................................................................................... 15 10.0 Properties of Fluorine and Organofluorine Compounds ..................................................................... 16 10.1 Perfluoroalkyl Acids ....................................................................................................................... 17 10.2 Surfactants....................................................................................................................................... 17 10.3 Fluorochemicals in Semiconductor Plasma-Enabled Etch and Deposition Processes .................... 18 11.0 Sustainability and the Semiconductor Technology Timeline ............................................................. 21 12.0 EHS Controls ...................................................................................................................................... 24 12.1 Occupational Exposure Control Strategy ........................................................................................ 24 12.2 SEMI Safety Guidelines for Tool Design ....................................................................................... 25 12.3 Safety Procedures and On-Site Industrial Hygiene Staff ................................................................ 26 12.4 Qualitative and Quantitative Chemical Risk Assessments ............................................................. 26 12.4.1 SEMATECH PFOS Industrial Hygiene Monitoring In and Around Track Tools ................... 26 12.4.2 NIOSH Research on PFAS ...................................................................................................... 27 12.4.3 Environmental Controls ........................................................................................................... 27 12.4.4 Wastewater Discharges and Treatment .................................................................................... 27 12.4.5 PFAS Waste Disposal and Destruction by Incineration .......................................................... 30 12.4.6 Air Emissions Control and Abatement .................................................................................... 30 13.0 R&D Needs ......................................................................................................................................... 32 13.0 Conclusions ......................................................................................................................................... 33 14.0 References ........................................................................................................................................... 35 Appendix A: Glossary of Acronyms and Terms ......................................................................................... 40 Appendix B: Semiconductor and Supply-Chain Complexity ..................................................................... 52 Appendix C: List of SEMI Safety Guidelines ............................................................................................ 60 Executive Summary Semiconductors are essential components of electronic devices and are integral to modern society. A number of semiconductor manufacturing processes and applications use PFAS chemicals, a group of chemicals that contain two or more fluorine atoms bonded to a carbon or hydrocarbon backbone. The Semiconductor PFAS Consortium, which comprises semiconductor manufacturers and semiconductor equipment and chemical and material suppliers, has established seven working groups to: • Identify the principal applications of PFAS-containing materials in the industry. • Assess the application-specific performance requirements. • Determine the role of fluorocarbons in fulfilling performance requirements. By collecting this information, the consortium has determined where PFAS-containing materials are essential and where they are not. Technical areas of focus for the working groups are photolithography, wet chemistry, heat transfer fluids (HTFs), fluorocarbon uses in plasma etch and deposition, chip packaging, lubricants, and manufacturing equipment and its associated infrastructure (also known as Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 3 151 Executive Summary Semiconductors are essential components of electronic devices and are integral to modern society. A number of semiconductor manufacturing processes and applications use PFAS chemicals, a group of chemicals that contain two or more fluorine atoms bonded to a carbon or hydrocarbon backbone. The Semiconductor PFAS Consortium, which comprises semiconductor manufacturers and semiconductor equipment and chemical and material suppliers, has established seven working groups to: • Identify the principal applications of PFAS-containing materials in the industry. • Assess the application-specific performance requirements. • Determine the role of fluorocarbons in fulfilling performance requirements. By collecting this information, the consortium has determined where PFAS-containing materials are essential and where they are not. Technical areas of focus for the working groups are photolithography, wet chemistry, heat transfer fluids (HTFs), fluorocarbon uses in plasma etch and deposition, chip packaging, lubricants, and manufacturing equipment and its associated infrastructure (also known as Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 3 151 ^oqf`ibp‚*/ The working groups have prepared white papers and case studies presenting their findings, which are based on semiconductor manufacturer and supplier survey responses, literature and patent reviews, and expert input. The results of this work have shown that in a majority of cases, PFAS-containing materials provide properties integral to the semiconductor industry that are not found in known, non-PFAS alternatives. Eliminating PFAS-containing materials from this industry will require years of research and development (R&D) to identify, demonstrate, integrate and implement alternatives. Minimizing emissions may be a more feasible route for most applications. This white paper contains information that supplements and supports each of the working group„p work products, including a discussion of: ^oqf`ibp‚*/ The working groups have prepared white papers and case studies presenting their findings, which are based on semiconductor manufacturer and supplier survey responses, literature and patent reviews, and expert input. The results of this work have shown that in a majority of cases, PFAS-containing materials provide properties integral to the semiconductor industry that are not found in known, non-PFAS alternatives. Eliminating PFAS-containing materials from this industry will require years of research and development (R&D) to identify, demonstrate, integrate and implement alternatives. Minimizing emissions may be a more feasible route for most applications. This white paper contains information that supplements and supports each of the working group„p work products, including a discussion of: • Different regulatory bodfbp„ PFAS definitions, including the clkploqfrj„p abcfkfqflk- tef`e fp ^kv organic chemical with a perfluorinated methylene group (-CF2-) and/or perfluorinated methyl group (- CF3) moiety. • Actions that the industry has taken to eliminate and replace long-chain PFAS-containing materials with more environmentally benign substitutes. • The global supply chain associated with this industry, and the interconnected relationship between suppliers, manufacturers and end users. • The organization of modern advanced semiconductor manufacturing facilities. • A summary of fluorine and organofluorine properties that make them critical for some applications. • Human health and environmental controls. • The R&D necessary to find acceptable substitutes for PFAS-containing materials, and, where PFAS- containing materials are essential to this industry and substitutes are not possible, the development of environmental emissions-reduction technologies. • Different regulatory bodfbp„ PFAS definitions, including the clkploqfrj„p abcfkfqflk- tef`e fp ^kv organic chemical with a perfluorinated methylene group (-CF2-) and/or perfluorinated methyl group (- CF3) moiety. • Actions that the industry has taken to eliminate and replace long-chain PFAS-containing materials with more environmentally benign substitutes. • The global supply chain associated with this industry, and the interconnected relationship between suppliers, manufacturers and end users. • The organization of modern advanced semiconductor manufacturing facilities. • A summary of fluorine and organofluorine properties that make them critical for some applications. • Human health and environmental controls. • The R&D necessary to find acceptable substitutes for PFAS-containing materials, and, where PFAS- containing materials are essential to this industry and substitutes are not possible, the development of environmental emissions-reduction technologies. 1.0 Overview of the Semiconductor Industry Over the past three decades, the semiconductor industry has experienced rapid growth and delivered enormous global economic impact. Chip performance and cost improvements made possible the evolution from mainframes to PCs in the 1990s, the World Wide Web and online services in the 2000s, and the smartphone revolution in the 2010s. These chip-enabled innovations created significant economic benefits. For example, from 1995 to 2015, an estimated $3 trillion in global gross domestic product (GDP) was directly attributable to semiconductor innovation, along with an additional $11 trillion in indirect impact (SIA 2022). Semiconductors have become essential to our modern world, which is why long-term market demand remains strong. The impact of semiconductor availability to other industries was brought to the fore during the first two years of the COVID-19 pandemic, when COVID-19-induced reductions in chip manufacturing created bottlenecks in downstream manufacturing. Figure 1 shows global semiconductor sales growth from 2001 through 2021. Global semiconductor industry sales totaled $573.5 billion in 2022 (SIA 2022), the highest-ever annual total and an increase of 3.2% compared to the 2021 total of $555.9 billion. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 4 152 1.0 Overview of the Semiconductor Industry Over the past three decades, the semiconductor industry has experienced rapid growth and delivered enormous global economic impact. Chip performance and cost improvements made possible the evolution from mainframes to PCs in the 1990s, the World Wide Web and online services in the 2000s, and the smartphone revolution in the 2010s. These chip-enabled innovations created significant economic benefits. For example, from 1995 to 2015, an estimated $3 trillion in global gross domestic product (GDP) was directly attributable to semiconductor innovation, along with an additional $11 trillion in indirect impact (SIA 2022). Semiconductors have become essential to our modern world, which is why long-term market demand remains strong. The impact of semiconductor availability to other industries was brought to the fore during the first two years of the COVID-19 pandemic, when COVID-19-induced reductions in chip manufacturing created bottlenecks in downstream manufacturing. Figure 1 shows global semiconductor sales growth from 2001 through 2021. Global semiconductor industry sales totaled $573.5 billion in 2022 (SIA 2022), the highest-ever annual total and an increase of 3.2% compared to the 2021 total of $555.9 billion. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 4 152 Figure 1: 20 years of global semiconductor sales growth (2001-2021). Figure 1: 20 years of global semiconductor sales growth (2001-2021). 2.0 Introduction The semiconductor industry uses PFAS-containing materials in numerous critical applications. Because of human health and environmental factors associated with the persistence, bioaccumulation and toxicity of some fluorinated organic chemicals, legislative and regulatory efforts worldwide are seeking to categorize a majority of fluorinated organic chemicals under a single class termed PFAS, and initiate restrictions that could limit the use of PFAS-containing materials to only those considered essential to the function of society. Given the criticality of fluorinated organic chemicals to semiconductor manufacturing, the Semiconductor PFAS Consortium has developed six white papers that identify PFAS uses in semiconductor manufacturing and assess where use meets the definition of •essential‚ (Cousins, et al. 2019). To the extent that PFAS-containing formulations are essential to manufacturing semiconductors, the papers present the socioeconomic factors and data that support continued use, under exemptions with near-zero release. To the extent that nonfluorinated alternatives may be available that can satisfy application- specific performance requirements, the papers will identify the key steps necessary to develop, qualify and implement new materials into high-volume semiconductor manufacturing. They also outline potential avenues of R&D for new materials. Six white papers and three case studies prepared by the consortium collectively address the principal areas where semiconductor manufacturing uses fluorinated organic chemicals. The seven areas covered in these white papers and case studies are: 2.0 Introduction The semiconductor industry uses PFAS-containing materials in numerous critical applications. Because of human health and environmental factors associated with the persistence, bioaccumulation and toxicity of some fluorinated organic chemicals, legislative and regulatory efforts worldwide are seeking to categorize a majority of fluorinated organic chemicals under a single class termed PFAS, and initiate restrictions that could limit the use of PFAS-containing materials to only those considered essential to the function of society. Given the criticality of fluorinated organic chemicals to semiconductor manufacturing, the Semiconductor PFAS Consortium has developed six white papers that identify PFAS uses in semiconductor manufacturing and assess where use meets the definition of •essential‚ (Cousins, et al. 2019). To the extent that PFAS-containing formulations are essential to manufacturing semiconductors, the papers present the socioeconomic factors and data that support continued use, under exemptions with near-zero release. To the extent that nonfluorinated alternatives may be available that can satisfy application- specific performance requirements, the papers will identify the key steps necessary to develop, qualify and implement new materials into high-volume semiconductor manufacturing. They also outline potential avenues of R&D for new materials. Six white papers and three case studies prepared by the consortium collectively address the principal areas where semiconductor manufacturing uses fluorinated organic chemicals. The seven areas covered in these white papers and case studies are: • Photolithography. Photolithography is a patterning process that defines where to add or remove materials in each step of the fabrication of integrated circuits. Specialized fluorinated organic chemicals serve several important roles in performing photolithographic patterning processes (Ober, Kafer and Deng 2022). There are three supporting case studies on photoacid generators (PAGs), surfactants, and the history of perfluorooctyl sulfonate (PFOS) and perfluorooctyl acetate (PFOA) phaseouts. • Wet chemical processing. A number of different semiconductor manufacturing operations, including cleaning, etching, plating and planarization, employ aqueous- or solvent-based formulations. Some of these applications use fluorinated organic chemicals. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 5 153 • Photolithography. Photolithography is a patterning process that defines where to add or remove materials in each step of the fabrication of integrated circuits. Specialized fluorinated organic chemicals serve several important roles in performing photolithographic patterning processes (Ober, Kafer and Deng 2022). There are three supporting case studies on photoacid generators (PAGs), surfactants, and the history of perfluorooctyl sulfonate (PFOS) and perfluorooctyl acetate (PFOA) phaseouts. • Wet chemical processing. A number of different semiconductor manufacturing operations, including cleaning, etching, plating and planarization, employ aqueous- or solvent-based formulations. Some of these applications use fluorinated organic chemicals. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 5 153 • Fluorocarbon uses in plasma etch and deposition. Perfluorocarbons (PFCs) and hydrofluorocarbons (HFCs) are essential gases for directional etching and cleaning of silicon compounds. Silicon and silicon compounds are the fundamental semiconductor components; they provide the conductive properties of metal as well as operating as an insulator. Additionally, fluorinated organometallic compounds are essential for the deposition of metal-containing films. • HTFs. Many semiconductor manufacturing processes entail physical and chemical processes that require precisely controlled temperatures, and thus are highly reliant on HTFs. In both cooling and heating applications, fluorinated HTFs (F-HTFs) help ensure the ability to provide the precise temperature control required in specific manufacturing operations within the semiconductor fabrication process, and enable the testing of products to ensure the appropriate performance of semiconductor chips within finished electronic products. • Assembly, test and packaging materials. A semiconductor package encloses one or more semiconductor devices or integrated circuits, protecting the device from the environment. The package connects the semiconductor to the printed circuit board (PCB); dissipates heat; and provides protection from the surrounding environment, particularly from moisture, shock/vibration, dust, etc. • Semiconductor manufacturing and related equipment (SMRE) and infrastructure articles. Semiconductor manufacturing facilities and the manufacturing equipment and infrastructure within them contain a multitude of articles. An article is any object made from one or more substances and mixtures which during production is given a special shape, surface or design that determines its function to a greater degree than its chemical composition, whether on its own or in an assembly with other articles, substances and mixtures. PFAS-containing articles include those made of a fluoropolymer, articles coated or painted with a fluoropolymer, or other PFAS-containing materials (such as oligomers) and those made of non-PFAS polymers containing PFAS processing/machining aids or additives. Many semiconductor manufacturing applications require the use of PFAS- containing articles for safety, contamination control, resilience and other factors. • Pump fluids and lubricants. Semiconductor manufacturing relies on the extensive use of robotics, automation and vacuum systems to achieve nanometer-scale precision. The use of lubricants, many of which need to be fluorinated, is essential to the precision and reliability of these systems. Figure 2 is a broad overview of the scope of the Semiconductor PFAS Consortium„p analysis, showing both front- and back-end semiconductor processing, as well as facility support functions and device assembly, test and packaging operations. The scope of the operations considered by the Semiconductor PFAS Consortium starts with a bare silicon wafer entering a manufacturing facility and ends at the packaging of semiconductor devices. • Fluorocarbon uses in plasma etch and deposition. Perfluorocarbons (PFCs) and hydrofluorocarbons (HFCs) are essential gases for directional etching and cleaning of silicon compounds. Silicon and silicon compounds are the fundamental semiconductor components; they provide the conductive properties of metal as well as operating as an insulator. Additionally, fluorinated organometallic compounds are essential for the deposition of metal-containing films. • HTFs. Many semiconductor manufacturing processes entail physical and chemical processes that require precisely controlled temperatures, and thus are highly reliant on HTFs. In both cooling and heating applications, fluorinated HTFs (F-HTFs) help ensure the ability to provide the precise temperature control required in specific manufacturing operations within the semiconductor fabrication process, and enable the testing of products to ensure the appropriate performance of semiconductor chips within finished electronic products. • Assembly, test and packaging materials. A semiconductor package encloses one or more semiconductor devices or integrated circuits, protecting the device from the environment. The package connects the semiconductor to the printed circuit board (PCB); dissipates heat; and provides protection from the surrounding environment, particularly from moisture, shock/vibration, dust, etc. • Semiconductor manufacturing and related equipment (SMRE) and infrastructure articles. Semiconductor manufacturing facilities and the manufacturing equipment and infrastructure within them contain a multitude of articles. An article is any object made from one or more substances and mixtures which during production is given a special shape, surface or design that determines its function to a greater degree than its chemical composition, whether on its own or in an assembly with other articles, substances and mixtures. PFAS-containing articles include those made of a fluoropolymer, articles coated or painted with a fluoropolymer, or other PFAS-containing materials (such as oligomers) and those made of non-PFAS polymers containing PFAS processing/machining aids or additives. Many semiconductor manufacturing applications require the use of PFAS- containing articles for safety, contamination control, resilience and other factors. • Pump fluids and lubricants. Semiconductor manufacturing relies on the extensive use of robotics, automation and vacuum systems to achieve nanometer-scale precision. The use of lubricants, many of which need to be fluorinated, is essential to the precision and reliability of these systems. Figure 2 is a broad overview of the scope of the Semiconductor PFAS Consortium„p analysis, showing both front- and back-end semiconductor processing, as well as facility support functions and device assembly, test and packaging operations. The scope of the operations considered by the Semiconductor PFAS Consortium starts with a bare silicon wafer entering a manufacturing facility and ends at the packaging of semiconductor devices. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 6 154 Thousands of pieces of Exhaust Semiconductor Collec on & Abatement Manufacturing & Systems RelatedEquipment (SMRE), Facili es Front End of Line (FEOL) Fab Back End of Line (BEOL) Fab Back End Assembly, Assembly Test, Infrastructure, and Manufacturing Process Steps Manufacturing Process Steps & Packaging Opera ons General Manufacturing Equipment - as depicted below Oxida on / Diffusion Metal Di e Tes t Bump Chemical Photo- Wa fe r Gri nd & Mechanical Mount lithography Polish Wa fe r Sa w Cleans & Photo- Wafer Cl ea ns & Etch Di e Bond Metrology lithography Transport Me trol ogy Di e Wi re Underfill & Mold Etch Implant Enca ps ul a te Deposi on Pa cka ge Te s t Deposi on Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 6 154 Thousands of pieces of Exhaust Semiconductor Collec on & Abatement Manufacturing & Systems RelatedEquipment (SMRE), Facili es Front End of Line (FEOL) Fab Back End of Line (BEOL) Fab Back End Assembly, Assembly Test, Infrastructure, and Manufacturing Process Steps Manufacturing Process Steps & Packaging Opera ons General Manufacturing Equipment - as depicted below Oxida on / Diffusion Metal Di e Tes t Bump Chemical Photo- Wa fe r Gri nd & Mechanical Mount lithography Polish Wa fe r Sa w Cleans & Photo- Wafer Cl ea ns & Etch Di e Bond Metrology lithography Transport Me trol ogy Di e Wi re Underfill & Mold Etch Implant Enca ps ul a te Deposi on Pa cka ge Te s t Deposi on Ultrapure Water Bulk Chemical Wastewater Chemical & Waste Treatment & Delivery Distribu on Treatment & Collec on Treatment & Collec on Systems Systems Systems Systems Figure 2: General overview of semiconductor manufacturing process steps, operations and systems evaluated by Semiconductor PFAS Consortium working groups. groups 155 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 7 Ultrapure Water Bulk Chemical Wastewater Chemical & Waste Treatment & Delivery Distribu on Treatment & Collec on Treatment & Collec on Systems Systems Systems Systems Figure 2: General overview of semiconductor manufacturing process steps, operations and systems evaluated by Semiconductor PFAS Consortium working groups. groups 155 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 7 3.0 PFAS Definition The term PFAS gained use with a publication by Buck et al. (Buck, Franklin, et al. 2011) that presents a rational chemical nomenclature for describing fluorinated organic chemicals. Since then, many organizations have adopted the term PFAS, each applying somewhat different criteria to the definition, and affecting the span of compounds covered (OECD 2018); (OECD 2021); (US EPA 2021). Under the current Organization for Economic Co-Operation and Development (OECD) definition, the term PFAS includes virtually every compound that contains a -CF2- or -CF3 group (OECD 2021). The purpose of the white papers is to identify the use of all materials that could potentially meet a regulatory definition of PFAS; therefore, the consortium has defined the scope of materials to include all chemistries and materials that contain molecules with -CF2- and/or -CF3. As such, this definition closely aligns with the OECD definition. However, as noted by the OECD, the term PFAS is a broad, general, nonspecific term that does not indicate whether a compound is harmful or not, but communicates only that the compounds under this term share the same trait for having a fully fluorinated methyl or methylene carbon moiety (OECD 2021). In fact, the application of this definition lumps together gases, liquids and solids with vastly different properties, and that range in size from difluoromethane (CF2H2) to large, highly complex organic polymers and surfactants. 3.0 PFAS Definition The term PFAS gained use with a publication by Buck et al. (Buck, Franklin, et al. 2011) that presents a rational chemical nomenclature for describing fluorinated organic chemicals. Since then, many organizations have adopted the term PFAS, each applying somewhat different criteria to the definition, and affecting the span of compounds covered (OECD 2018); (OECD 2021); (US EPA 2021). Under the current Organization for Economic Co-Operation and Development (OECD) definition, the term PFAS includes virtually every compound that contains a -CF2- or -CF3 group (OECD 2021). The purpose of the white papers is to identify the use of all materials that could potentially meet a regulatory definition of PFAS; therefore, the consortium has defined the scope of materials to include all chemistries and materials that contain molecules with -CF2- and/or -CF3. As such, this definition closely aligns with the OECD definition. However, as noted by the OECD, the term PFAS is a broad, general, nonspecific term that does not indicate whether a compound is harmful or not, but communicates only that the compounds under this term share the same trait for having a fully fluorinated methyl or methylene carbon moiety (OECD 2021). In fact, the application of this definition lumps together gases, liquids and solids with vastly different properties, and that range in size from difluoromethane (CF2H2) to large, highly complex organic polymers and surfactants. 4.0 History of Semiconductor Industry Voluntary Actions on PFAS The semiconductor industry has been attuned to environmental concerns about the substances it uses, and quick to act proactively with voluntary elimination and reductions. For instance, when evidence of the persistence, bioaccumulation and toxicity of PFOS surfaced in the early 2000s, the World Semiconductor Council (WSC) initiated an international voluntary commitment in 2006 to phase out PFOS use worldwide, a goal that it achieved in 2011 (Council 2011). The WSC also committed to voluntarily phase out the use of PFOA by 2025. Companies began this phaseout in 2010 and, today, the majority of companies have eliminated PFOA. Similarly, in the face of global warming concerns, the U.S. Environmental Protection Agency (EPA) and Semiconductor Industry Association initiated a voluntary Perfluorocarbon Reduction Climate Partnership in 1996, which expanded into voluntary worldwide commitments that resulted in nearly a 50% reduction in the emissions of PFC gases between 1995 and 2010 (WSC 1999-2014), and which continues today. Our experience with these initiatives has taught consortium members valuable lessons regarding the obplro`b- bccloq ^ka qfjbifkb obnrfoba ql fkqolar`b ^iqbok^qfsb `ebjf`^ip fkql pljb lc qeb tloia„p jlpq complex technologies. The manufacture of semiconductor devices requires the use of manufacturing tools and processes that are highly integrated, with hundreds to thousands of interdependent steps that must be conducted at nanometer scale using materials that have complex relationships. Once a material has been engrained into a semiconductor manufacturing process, it can be excruciatingly difficult to find a viable alternative, prove that the alternative can be substituted without disrupting interdependencies, and then integrate the alternative into a high-volume manufacturing (HVM) process. This challenge makes it important to conduct collaborative R&D at the pre-competitive level, ideally with pooled resources like the Semiconductor Research Corp. (SRC), Interuniversity Microelectronics Center (IMEC), Industrial Technology Research Institute, the Semiconductor PFAS Consortium, and now-inactive SEMATECH. Industry-funded collaborative efforts have resulted in the publication of many dozens of PFAS-related research papers in peer-reviewed literature. 4.0 History of Semiconductor Industry Voluntary Actions on PFAS The semiconductor industry has been attuned to environmental concerns about the substances it uses, and quick to act proactively with voluntary elimination and reductions. For instance, when evidence of the persistence, bioaccumulation and toxicity of PFOS surfaced in the early 2000s, the World Semiconductor Council (WSC) initiated an international voluntary commitment in 2006 to phase out PFOS use worldwide, a goal that it achieved in 2011 (Council 2011). The WSC also committed to voluntarily phase out the use of PFOA by 2025. Companies began this phaseout in 2010 and, today, the majority of companies have eliminated PFOA. Similarly, in the face of global warming concerns, the U.S. Environmental Protection Agency (EPA) and Semiconductor Industry Association initiated a voluntary Perfluorocarbon Reduction Climate Partnership in 1996, which expanded into voluntary worldwide commitments that resulted in nearly a 50% reduction in the emissions of PFC gases between 1995 and 2010 (WSC 1999-2014), and which continues today. Our experience with these initiatives has taught consortium members valuable lessons regarding the obplro`b- bccloq ^ka qfjbifkb obnrfoba ql fkqolar`b ^iqbok^qfsb `ebjf`^ip fkql pljb lc qeb tloia„p jlpq complex technologies. The manufacture of semiconductor devices requires the use of manufacturing tools and processes that are highly integrated, with hundreds to thousands of interdependent steps that must be conducted at nanometer scale using materials that have complex relationships. Once a material has been engrained into a semiconductor manufacturing process, it can be excruciatingly difficult to find a viable alternative, prove that the alternative can be substituted without disrupting interdependencies, and then integrate the alternative into a high-volume manufacturing (HVM) process. This challenge makes it important to conduct collaborative R&D at the pre-competitive level, ideally with pooled resources like the Semiconductor Research Corp. (SRC), Interuniversity Microelectronics Center (IMEC), Industrial Technology Research Institute, the Semiconductor PFAS Consortium, and now-inactive SEMATECH. Industry-funded collaborative efforts have resulted in the publication of many dozens of PFAS-related research papers in peer-reviewed literature. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 8 156 No known alternatives bufpq clo j^kv lc qeb fkarpqov„p rpbp lc fluorocarbons. Given its carbon-fluorine chemistry, PFAS-containing materials offer a unique set of surface tension, stability and chemical compatibility that many semiconductor applications require. For example, despite years of extensive research, there have been no viable PFAS-free alternatives identified for the fluorocarbon gases used in plasma etch processes, fluorinated chemicals used in photolithography, or fluorinated chemicals used as refrigerants and HTFs. If an alternative is found, the process of qualifying and replacing critical materials in the semiconductor industry is a highly complex, multistep, multiyear, supply-chain stakeholder technical challenge. The possibility of regrettable substitution, in which a well-intentioned alternative is instituted and then later found to have undesirable characteristics, is an ever-present concern. The four perfluorocarbon sulfonic acids in wide use today • such as the acid anion in PAGs, for instance • were a widely endorsed solution to PFOS PAGs that were replaced just over 10 years ago, and yet now are the target of U.S. EPA and European Union (EU) regulatory actions. Similarly, some of the fluorinated refrigerants and HTFs in use today represent a fourth generation of replacements, where the intention of each generation has been to remedy the environmental, health and safety concerns of the previous generation. From this, it has become obvious that the selection of alternatives must be well-informed. The semiconductor industry will continue to focus on using PFAS chemistries safely and responsibly until it can find viable and proven alternatives. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 8 156 No known alternatives bufpq clo j^kv lc qeb fkarpqov„p rpbp lc fluorocarbons. Given its carbon-fluorine chemistry, PFAS-containing materials offer a unique set of surface tension, stability and chemical compatibility that many semiconductor applications require. For example, despite years of extensive research, there have been no viable PFAS-free alternatives identified for the fluorocarbon gases used in plasma etch processes, fluorinated chemicals used in photolithography, or fluorinated chemicals used as refrigerants and HTFs. If an alternative is found, the process of qualifying and replacing critical materials in the semiconductor industry is a highly complex, multistep, multiyear, supply-chain stakeholder technical challenge. The possibility of regrettable substitution, in which a well-intentioned alternative is instituted and then later found to have undesirable characteristics, is an ever-present concern. The four perfluorocarbon sulfonic acids in wide use today • such as the acid anion in PAGs, for instance • were a widely endorsed solution to PFOS PAGs that were replaced just over 10 years ago, and yet now are the target of U.S. EPA and European Union (EU) regulatory actions. Similarly, some of the fluorinated refrigerants and HTFs in use today represent a fourth generation of replacements, where the intention of each generation has been to remedy the environmental, health and safety concerns of the previous generation. From this, it has become obvious that the selection of alternatives must be well-informed. The semiconductor industry will continue to focus on using PFAS chemistries safely and responsibly until it can find viable and proven alternatives. 5.0 Semiconductor Overview Semiconductors power our world. In health care, they make robotic surgery, advanced imaging, pacemakers, continuous glucose monitoring and insulin pumps possible. Semiconductors enable safety systems in automobiles such as blind-spot detection, backup cameras, emergency braking systems, lane- change assistance and adaptive cruise control. Semiconductors are the brains and memory in computers, mobile phones and smartwatches. The first computer based on silicon-integrated circuits was the Apollo guidance computer that took humans to the moon. Those computers could perform 85,000 operations per second (Fishman 2019). In 1965, Gordon Moore postulated that the number of components on an integrated circuit would double every two years (Moore 1965); mobile phones in 2023 can perform 17 trillion operations per second (Wiggers 2022). In a span of 60 years, semiconductors have seen a 200 million times increase in computing power. Semiconductor chips are the most complicated mass-produced devices that humans have ever made, and the processes used to manufacture them are among the most complex and expensive in modern manufacturing. Chips are made on a silicon wafer, as shown in Figure 3, using complex photolithographic, deposition, plasma etching, cleaning and planarization processes. There are hundreds of required chemical formulations. For information on the increasing complexity of semiconductor devices, technology changes driving increased chemical usage and an overview of the manufacturing process, see Appendix B. 5.0 Semiconductor Overview Semiconductors power our world. In health care, they make robotic surgery, advanced imaging, pacemakers, continuous glucose monitoring and insulin pumps possible. Semiconductors enable safety systems in automobiles such as blind-spot detection, backup cameras, emergency braking systems, lane- change assistance and adaptive cruise control. Semiconductors are the brains and memory in computers, mobile phones and smartwatches. The first computer based on silicon-integrated circuits was the Apollo guidance computer that took humans to the moon. Those computers could perform 85,000 operations per second (Fishman 2019). In 1965, Gordon Moore postulated that the number of components on an integrated circuit would double every two years (Moore 1965); mobile phones in 2023 can perform 17 trillion operations per second (Wiggers 2022). In a span of 60 years, semiconductors have seen a 200 million times increase in computing power. Semiconductor chips are the most complicated mass-produced devices that humans have ever made, and the processes used to manufacture them are among the most complex and expensive in modern manufacturing. Chips are made on a silicon wafer, as shown in Figure 3, using complex photolithographic, deposition, plasma etching, cleaning and planarization processes. There are hundreds of required chemical formulations. For information on the increasing complexity of semiconductor devices, technology changes driving increased chemical usage and an overview of the manufacturing process, see Appendix B. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 9 157 Figure 3: The manufacturing process from wafer fab through packaged device (Source: Micron Technology Inc.). 6.0 .0 Supply-Chain Complexity Advances in the efficient and controlled use of materials are critical to improving semiconductor device performance. The manufacturing supply chain, a subset of the industry ecosystem, is global and highly integrated. It depends on a range of articles provided by specialized and supporting equipment suppliers as well as the specialty chemical suppliers shown in Figure 4. The SMRE used for semiconductor manufacturing is enormously complex ex, comprising thousands of components and subcomponents coming from many different supply-chain tiers, and equally many suppliers from start to finish. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 10 158 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 9 157 Figure 3: The manufacturing process from wafer fab through packaged device (Source: Micron Technology Inc.). 6.0 .0 Supply-Chain Complexity Advances in the efficient and controlled use of materials are critical to improving semiconductor device performance. The manufacturing supply chain, a subset of the industry ecosystem, is global and highly integrated. It depends on a range of articles provided by specialized and supporting equipment suppliers as well as the specialty chemical suppliers shown in Figure 4. The SMRE used for semiconductor manufacturing is enormously complex ex, comprising thousands of components and subcomponents coming from many different supply-chain tiers, and equally many suppliers from start to finish. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 10 158 Toray USHIO JEOL ASM Canon ASML Nikon Besi Nuflare SMIT Mycronic ULVAC Evatech EV Group Kokusai Tescan Tokyo Electron Li thography Camtek Screen Heidelberg Ebara SUSS MicroTec Rigaku Bruker SAMCO Zeiss Hitachi Vistec Lasertec Impl a nt Hesse Accretech Grohmann Shin-Etsu Merck / EMD JSR BASF TOK Linde Fujifilm Depos i on Henkel JX Nippon Entegris Fujimi Air Products Hitachi Chem KMG Chems Sumitomo Dry Etch / DuPont SEMES Avantor Gigalane Cl ea n Honeywell AP Systems Elec. Mat. Charm Engineering Amkor KOSES Quik-Pak Unitest Wet Etch / Cl ea n / CMP Nanonex SSP Applied Materials DI LAM Research Hermes-Epitek Ma son Tech Vecco Grand Plas c Axcelis NanYa Metrology Nissin Ion Kulick &Soffa Plasma Therm Keithley ASTI Thermo Fisher Naura As s embl y, Keysight Tech Hwatsing Accotest Tes t, & KLA COHU ASM Pacific Pa cka gi ng Teradyne ASM Pacific Micro Control Na onal Instruments Toray USHIO JEOL ASM Canon ASML Nikon Besi Nuflare SMIT Mycronic ULVAC Evatech EV Group Kokusai Tescan Tokyo Electron Li thography Camtek Screen Heidelberg Ebara SUSS MicroTec Rigaku Bruker SAMCO Zeiss Hitachi Vistec Lasertec Impl a nt Hesse Accretech Grohmann Shin-Etsu Merck / EMD JSR BASF TOK Linde Fujifilm Depos i on Henkel JX Nippon Entegris Fujimi Air Products Hitachi Chem KMG Chems Sumitomo Dry Etch / DuPont SEMES Avantor Gigalane Cl ea n Honeywell AP Systems Elec. Mat. Charm Engineering Amkor KOSES Quik-Pak Unitest Wet Etch / Cl ea n / CMP Nanonex SSP Applied Materials DI LAM Research Hermes-Epitek Ma son Tech Vecco Grand Plas c Axcelis NanYa Metrology Nissin Ion Kulick &Soffa Plasma Therm Keithley ASTI Thermo Fisher Naura As s embl y, Keysight Tech Hwatsing Accotest Tes t, & KLA COHU ASM Pacific Pa cka gi ng Teradyne ASM Pacific Micro Control Na onal Instruments SH Material Mitsui Hi-Tec Heraeus Note 1: Blue text represents presents examples example of direct semiconductor equipment suppliers. suppliers Tanaka Denshi Nippon Micro Note 2: Green text represents examples example of direct semiconductor material suppliers. suppliers Hitachi NGK Note 3: Fi^dp obmobpbkq qeb prmmifbop„ eb^anr^oqbop ^ka al klq obmobpbkq qeb dil_^i Ibiden Shinko extent of the suppliers„ suppliers operations. TOWA TESEC DISCO Note 4: The facility acility infrastructure supply chain is not represented in the figure above Advantest Fasford Tech but has its own unique and complex supply chain. Note 5: Connectors may not represent all supply pathways but rather are representative. SH Material Mitsui Hi-Tec Heraeus Note 1: Blue text represents presents examples example of direct semiconductor equipment suppliers. suppliers Tanaka Denshi Nippon Micro Note 2: Green text represents examples example of direct semiconductor material suppliers. suppliers Hitachi NGK Note 3: Fi^dp obmobpbkq qeb prmmifbop„ eb^anr^oqbop ^ka al klq obmobpbkq qeb dil_^i Ibiden Shinko extent of the suppliers„ suppliers operations. TOWA TESEC DISCO Note 4: The facility acility infrastructure supply chain is not represented in the figure above Advantest Fasford Tech but has its own unique and complex supply chain. Note 5: Connectors may not represent all supply pathways but rather are representative. Figure 4: The semiconductor global supply chain in 2019: example tier-11 SMRE and material suppliers (The Center for Security and Emerging Technology 2019). 2019) 159 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 11 Figure 4: The semiconductor global supply chain in 2019: example tier-11 SMRE and material suppliers (The Center for Security and Emerging Technology 2019). 2019) 159 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 11 SMRE itself is enormously complex, with a large, international supply chain. In a New York Times article, Dario Gil, a senior vice president at IBM, described the current leading-edge photolithography exposure tool, which uses extreme ultraviolet (EUV) light, as • ... definitely the most complicated machine humans have built‚ (Clark 2021). Figure 5 shows an EUV tool, manufactured by Dutch firm ASML, containing 100,000 parts and 2 km of cabling (Levi 2021). If any part is faulty, the machine will fail to produce chips that can be sold for commercial use. Specialized components of the machine are made in facilities in Germany, the U.S., the U.K. and Japan; it would not have been possible to build the tool were it not for international, cross-industry and supply-chain collaboration. SMRE such as the EUV tool incorporates many articles made from (or that contain) PFAS-containing materials because PFAS articles possess a unique set of characteristics required for certain semiconductor manufacturing processes, including inertness, purity, chemical and permeation resistance, a wide range of temperature stability, a low coefficient of friction, electrical properties, bacterial growth resistance, nonflammability, and a long service life (>25 years). SMRE itself is enormously complex, with a large, international supply chain. In a New York Times article, Dario Gil, a senior vice president at IBM, described the current leading-edge photolithography exposure tool, which uses extreme ultraviolet (EUV) light, as • ... definitely the most complicated machine humans have built‚ (Clark 2021). Figure 5 shows an EUV tool, manufactured by Dutch firm ASML, containing 100,000 parts and 2 km of cabling (Levi 2021). If any part is faulty, the machine will fail to produce chips that can be sold for commercial use. Specialized components of the machine are made in facilities in Germany, the U.S., the U.K. and Japan; it would not have been possible to build the tool were it not for international, cross-industry and supply-chain collaboration. SMRE such as the EUV tool incorporates many articles made from (or that contain) PFAS-containing materials because PFAS articles possess a unique set of characteristics required for certain semiconductor manufacturing processes, including inertness, purity, chemical and permeation resistance, a wide range of temperature stability, a low coefficient of friction, electrical properties, bacterial growth resistance, nonflammability, and a long service life (>25 years). Figure 5: ASML’s latest EUV lithography patterning machine (Source: ASML). Tier-1 (or direct) suppliers, in turn, have a supply chain of their own (tier-2 and tier-3 suppliers), with dependencies, for example, on components such as valves, tubing and machined parts for SMRE manufacturers or raw materials for chemical suppliers. Additionally, these subsuppliers have suppliers as well, leading to a supply chain much more complicated than depicted in Figure 4. The depth and complexity of the SMRE supply chain makes tracing the presence of PFAS-containing materials in individual components quite difficult. For more information on supply-chain complexity, see qeb Sbjf`lkar`qlo PFAS Clkploqfrj tefqb m^mbo- •PFAS-Containing Articles Used in Semiconductor Manufacturing/‚ The supply chain for semiconductor chemicals is also international; Figure 4 shows example tier-1 material suppliers in green text. Every gas or liquid that touches the wafer must have its impurities (substances that could negatively impact yield) controlled to levels less than a few parts per billion (ppb) and even to less than a few parts per trillion (ppt). One part per trillion is equivalent to 1 second in 32,000 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 12 160 Figure 5: ASML’s latest EUV lithography patterning machine (Source: ASML). Tier-1 (or direct) suppliers, in turn, have a supply chain of their own (tier-2 and tier-3 suppliers), with dependencies, for example, on components such as valves, tubing and machined parts for SMRE manufacturers or raw materials for chemical suppliers. Additionally, these subsuppliers have suppliers as well, leading to a supply chain much more complicated than depicted in Figure 4. The depth and complexity of the SMRE supply chain makes tracing the presence of PFAS-containing materials in individual components quite difficult. For more information on supply-chain complexity, see qeb Sbjf`lkar`qlo PFAS Clkploqfrj tefqb m^mbo- •PFAS-Containing Articles Used in Semiconductor Manufacturing/‚ The supply chain for semiconductor chemicals is also international; Figure 4 shows example tier-1 material suppliers in green text. Every gas or liquid that touches the wafer must have its impurities (substances that could negatively impact yield) controlled to levels less than a few parts per billion (ppb) and even to less than a few parts per trillion (ppt). One part per trillion is equivalent to 1 second in 32,000 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 12 160 years. The current technology node of 5 nm (an expression of the size of features fabricated into semiconductor devices) is tremendously difficult to make. Any impurity present, even if nanoscale in size, can result in malfunctioning devices. For additional information on supply-chain complexity, see Appendix B. years. The current technology node of 5 nm (an expression of the size of features fabricated into semiconductor devices) is tremendously difficult to make. Any impurity present, even if nanoscale in size, can result in malfunctioning devices. For additional information on supply-chain complexity, see Appendix B. 7.0 Clean-Room Design Teb c^_of`^qflk lc pbjf`lkar`qlop fp `lkar`qba fk pmb`f^ifwba _rfiafkdp hkltk ^p c^_p‚ qe^q rpb `ib^k rooms, and a hierarchy of design features that isolate workers and wafers from chemicals. Fabs comprise clean-room spaces that house manufacturing tools, and support spaces that house the many electrical, mechanical and chemical systems that contain manufacturing tools. The building can be divided between clean-room and support space in a number of alternative ways, such as _^v ^ka `e^pb‚ abpfdkp tebob qeb support space surrounds the clean-room space horizontally. However, most modern fabs employ a ballroom-type design where the clean-room space consists of one or more very large rooms that house hundreds of individual manufacturing tools, with the ancillary support systems provided from below (subfab) and above. A fab„p clean-room design approach protects manufacturing personnel and is also critical to semiconductor wafer product quality. Figure 6 illustrates a typical 300-mm ballroom fab consisting of an interstitial and fan deck; a clean room, where manufacturing operations are conducted; the subfab, which contains pumps and other ancillary equipment to support process tools; and the utility level, which contains chemical- and air-handling equipment, emission controls, and other infrastructures. 7.0 Clean-Room Design Teb c^_of`^qflk lc pbjf`lkar`qlop fp `lkar`qba fk pmb`f^ifwba _rfiafkdp hkltk ^p c^_p‚ qe^q rpb `ib^k rooms, and a hierarchy of design features that isolate workers and wafers from chemicals. Fabs comprise clean-room spaces that house manufacturing tools, and support spaces that house the many electrical, mechanical and chemical systems that contain manufacturing tools. The building can be divided between clean-room and support space in a number of alternative ways, such as _^v ^ka `e^pb‚ abpfdkp tebob qeb support space surrounds the clean-room space horizontally. However, most modern fabs employ a ballroom-type design where the clean-room space consists of one or more very large rooms that house hundreds of individual manufacturing tools, with the ancillary support systems provided from below (subfab) and above. A fab„p clean-room design approach protects manufacturing personnel and is also critical to semiconductor wafer product quality. Figure 6 illustrates a typical 300-mm ballroom fab consisting of an interstitial and fan deck; a clean room, where manufacturing operations are conducted; the subfab, which contains pumps and other ancillary equipment to support process tools; and the utility level, which contains chemical- and air-handling equipment, emission controls, and other infrastructures. 1. Interstitial and fan deck Houses systems to keep the cleanroom air particle-free and at right temperature and humidity. 2. Cleanroom level Factory where process tools take bare silicon wafers and create tens to hundreds of computer chips on the wafer. 3. Clean subfab level Contains thousands of pumps and other equipment to support the tools in the cleanroom. Pipes and ductwork carry gases, liquids, waste and exhaust. 4. Utility level Contains electrical panels, chillers and compressor systems along with the large utility pipes and ductwork. 1. Interstitial and fan deck Houses systems to keep the cleanroom air particle-free and at right temperature and humidity. 2. Cleanroom level Factory where process tools take bare silicon wafers and create tens to hundreds of computer chips on the wafer. 3. Clean subfab level Contains thousands of pumps and other equipment to support the tools in the cleanroom. Pipes and ductwork carry gases, liquids, waste and exhaust. 4. Utility level Contains electrical panels, chillers and compressor systems along with the large utility pipes and ductwork. Figure 6: Example semiconductor manufacturing facility layout (CPS an Exyte Group Company 2019). On the interstitial and fan deck level, clean-room airflow recirculates vertically downward through filters mounted in the clean-room ceiling to the clean-room floor, where the air exits and returns through a plenum system, where it mixes with conditioned fresh air from outside the building before being recirculated back through the clean room. Fabs typically employ high-efficiency particulate air (HEPA)- or ultra-low particulate air (ULPA)-rated filters. ULPA filters are rated to remove 99.999% of particles i^odbo qe^k 231 kj )1/23 •j* ^ka molsfab ^k bu`bmqflk^i ibsbi lc m^oqf`ib objls^i/ Vboqf`^iiv altkt^oa Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 13 161 Figure 6: Example semiconductor manufacturing facility layout (CPS an Exyte Group Company 2019). On the interstitial and fan deck level, clean-room airflow recirculates vertically downward through filters mounted in the clean-room ceiling to the clean-room floor, where the air exits and returns through a plenum system, where it mixes with conditioned fresh air from outside the building before being recirculated back through the clean room. Fabs typically employ high-efficiency particulate air (HEPA)- or ultra-low particulate air (ULPA)-rated filters. ULPA filters are rated to remove 99.999% of particles i^odbo qe^k 231 kj )1/23 •j* ^ka molsfab ^k bu`bmqflk^i ibsbi lc m^oqf`ib objls^i/ Vboqf`^iiv altkt^oa Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 13 161 laminar airflow carries the freshest air past the typical personal breathing zone (PBZ) of fab workers, past the manufacturing tools, and then down and out through the return plenums located in or at the floor level. In a typical 300-mm wafer manufacturing fab, the entire volume of air in the clean room is replaced every four to seven minutes, and the entire volume of air in the clean room is recirculated through ULPA filters at a rate of once every 30 seconds to one minute. This extensive level of air circulation and replacement provides an exceptional level of cleanliness. The fabrication of an integrated circuit on a silicon wafer occurs in the clean room and involves a sequence of hundreds of additive, subtractive, photolithographic and cleaning steps that entail shuttling wafers between specialized manufacturing tools. Boxes of wafers or front-opening unified pods (FOUPs) transport wafers through an automated material handling system (AMHS) (see Figure 7), which uses thousands of autonomous vehicles to carry FOUPs containing as many as 25 wafers to the required process step (Intel 2020). Manufacturing tools, engineers and operators are located in the clean room. Virtually every tool has its own exhaust system, which maintains the tool enclosure under negative pressure relative to the clean room, thus preventing worker exposure to chemicals. Great care is taken to avoid any contact of wafers with workers, in order to prevent contamination. The subfab contains thousands of pumps and other equipment to support tools, as well as laterals to convey gases, liquids, waste and exhaust to and from production tools. The utility level, typically housed on the bottom level (but also in separate rooms on the side of the building or in separate structures) provides services that include ultra-pure water (UPW), bulk high-purity gases such as nitrogen and argon, exhaust gas handling and disposal ducts, electrical panels, chillers, and compressor systems. There are compressed gas cabinets and bulk chemical distribution systems located in separate rooms segregated by hazard class. Much of the supporting infrastructure is made up of fluoropolymers and other PFAS-containing articles used for their functional characteristics. Fabs are capital-intensive facilities, costing billions of dollars to construct. A state-of-the-art fab of standard capacity requires roughly between $5 billion (for an advanced analog fab) and $20 billion (for advanced logic and memory fabs) of capital expenditure (including land, buildings and equipment). The primary threats to safe and continuous fab operations include fires/explosions, fluid leakage and critical service interruptions (FM Global 2019). Many semiconductor manufacturers limit the amount of combustible material that can be present in a tool to 1 pound per square foot of tool to reduce flammable loading; so does Factory Mutual (FM), a major insurer of the industry (FM Global 2019). Fluoropolymers exhibit a high resistance to combustion (FM 4910 compliance; American Society of Testing and Materials [ASTM] E84 25/50 rating), a property that is critical to minimize factory damage from smoke and other risks, and to meet combustible material limits. laminar airflow carries the freshest air past the typical personal breathing zone (PBZ) of fab workers, past the manufacturing tools, and then down and out through the return plenums located in or at the floor level. In a typical 300-mm wafer manufacturing fab, the entire volume of air in the clean room is replaced every four to seven minutes, and the entire volume of air in the clean room is recirculated through ULPA filters at a rate of once every 30 seconds to one minute. This extensive level of air circulation and replacement provides an exceptional level of cleanliness. The fabrication of an integrated circuit on a silicon wafer occurs in the clean room and involves a sequence of hundreds of additive, subtractive, photolithographic and cleaning steps that entail shuttling wafers between specialized manufacturing tools. Boxes of wafers or front-opening unified pods (FOUPs) transport wafers through an automated material handling system (AMHS) (see Figure 7), which uses thousands of autonomous vehicles to carry FOUPs containing as many as 25 wafers to the required process step (Intel 2020). Manufacturing tools, engineers and operators are located in the clean room. Virtually every tool has its own exhaust system, which maintains the tool enclosure under negative pressure relative to the clean room, thus preventing worker exposure to chemicals. Great care is taken to avoid any contact of wafers with workers, in order to prevent contamination. The subfab contains thousands of pumps and other equipment to support tools, as well as laterals to convey gases, liquids, waste and exhaust to and from production tools. The utility level, typically housed on the bottom level (but also in separate rooms on the side of the building or in separate structures) provides services that include ultra-pure water (UPW), bulk high-purity gases such as nitrogen and argon, exhaust gas handling and disposal ducts, electrical panels, chillers, and compressor systems. There are compressed gas cabinets and bulk chemical distribution systems located in separate rooms segregated by hazard class. Much of the supporting infrastructure is made up of fluoropolymers and other PFAS-containing articles used for their functional characteristics. Fabs are capital-intensive facilities, costing billions of dollars to construct. A state-of-the-art fab of standard capacity requires roughly between $5 billion (for an advanced analog fab) and $20 billion (for advanced logic and memory fabs) of capital expenditure (including land, buildings and equipment). The primary threats to safe and continuous fab operations include fires/explosions, fluid leakage and critical service interruptions (FM Global 2019). Many semiconductor manufacturers limit the amount of combustible material that can be present in a tool to 1 pound per square foot of tool to reduce flammable loading; so does Factory Mutual (FM), a major insurer of the industry (FM Global 2019). Fluoropolymers exhibit a high resistance to combustion (FM 4910 compliance; American Society of Testing and Materials [ASTM] E84 25/50 rating), a property that is critical to minimize factory damage from smoke and other risks, and to meet combustible material limits. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 14 162 Figure 7: Inside a wafer fab, a worker walks down a row lined with process tools. Wafers are loaded into each tool via FOUPs. An AMHS carries FOUPs throughout the fab to the appropriate tool for processing. 8.0 .0 Tool Exhaust Chemical processes are designed to isolate chemicals from workers. These processes are conducted in tools equipped with process exhaust that route to either an abatement system or to general exhaust, as „p processing chambers. appropriate to the nature and quantity of the chemicals used within the tool„p Tool exhaust systems are typically balanced to maintain processing chambers at a negative pressure relative to the rest of the tool, with the tool itself typically maintained at negative pressure relative to the clean room. Collectively, these measures assure the capture of chemicals used in tool-specific process chambers directly at their source so that they do not migrate elsewhere within the tool or clean room. For additional information about fabrication and assembly, test and packaging facility exhausts and abatement, see the Environmental Controls section. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 14 162 Figure 7: Inside a wafer fab, a worker walks down a row lined with process tools. Wafers are loaded into each tool via FOUPs. An AMHS carries FOUPs throughout the fab to the appropriate tool for processing. 8.0 .0 Tool Exhaust Chemical processes are designed to isolate chemicals from workers. These processes are conducted in tools equipped with process exhaust that route to either an abatement system or to general exhaust, as „p processing chambers. appropriate to the nature and quantity of the chemicals used within the tool„p Tool exhaust systems are typically balanced to maintain processing chambers at a negative pressure relative to the rest of the tool, with the tool itself typically maintained at negative pressure relative to the clean room. Collectively, these measures assure the capture of chemicals used in tool-specific process chambers directly at their source so that they do not migrate elsewhere within the tool or clean room. For additional information about fabrication and assembly, test and packaging facility exhausts and abatement, see the Environmental Controls section. 9.0 .0 The Importance of Contamination Control Smaller device features and increasingly more complex 3D structures require strict contamination controls to achieve acceptable wafer production yields. Contamination control is an essential aspect of semiconductor manufacturing. Trace amounts of contamination in the form of particles, impurities or other unwanted materials can lead to yield or reliability issues in semiconductor devices. Sources of contamination may be the fab manufacturing environment or workers; process chemicals and gases; the UPW used to rinse wafers; or the packaging and delivery of chemicals, gases and UPW. Manufacturers implement stringent protocols to mitigate sources of potential defectivity. At the highest level, such protocols include precise control over the quantity of airborne particles in the clean room through careful control of the airflow, proper filtration of the ambient air, and the appropriate isolation of fab workers through proper gowning and hygiene procedures. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 15 163 9.0 .0 The Importance of Contamination Control Smaller device features and increasingly more complex 3D structures require strict contamination controls to achieve acceptable wafer production yields. Contamination control is an essential aspect of semiconductor manufacturing. Trace amounts of contamination in the form of particles, impurities or other unwanted materials can lead to yield or reliability issues in semiconductor devices. Sources of contamination may be the fab manufacturing environment or workers; process chemicals and gases; the UPW used to rinse wafers; or the packaging and delivery of chemicals, gases and UPW. Manufacturers implement stringent protocols to mitigate sources of potential defectivity. At the highest level, such protocols include precise control over the quantity of airborne particles in the clean room through careful control of the airflow, proper filtration of the ambient air, and the appropriate isolation of fab workers through proper gowning and hygiene procedures. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 15 163 Wafers used in manufacturing are enclosed in highly engineered containers as they are processed in fabs. Carefully maintaining tooling prevents the introduction of particles. It is important to hold materials such as specialty gases, wet chemistries, solid precursors, solid metal targets and UPW to exacting specifications of purity and deliver them to process equipment in a pristine manner. PFAS-containing materials, in particular fluoropolymers, play a critical role in affording the level of cleanliness required for high-yielding, high-reliability semiconductor devices, as they are often the only materials that possess the unique combination of chemical inertness, heat resistance, lack of particle shedding or metal leaching, processability, and other attributes required to meet rigorous requirements. Tla^v„p jlpq ^as^k`ba qb`eklildfbp ^ob j^ab tfqe EUV lithography, capable of feature sizes in the single nanometer scale and gate lengths of ~10 nm or less. Thus, defectivity in the tens- to single- nanometer domain can be detrimental to device yields, performance and reliability. In order to enable manufacturing at these dimensions, cleanliness afforded by fluoropolymer plastics and other PFAS- containing articles used for piping, tanks, seals and coated valves is often essential. Wafers used in manufacturing are enclosed in highly engineered containers as they are processed in fabs. Carefully maintaining tooling prevents the introduction of particles. It is important to hold materials such as specialty gases, wet chemistries, solid precursors, solid metal targets and UPW to exacting specifications of purity and deliver them to process equipment in a pristine manner. PFAS-containing materials, in particular fluoropolymers, play a critical role in affording the level of cleanliness required for high-yielding, high-reliability semiconductor devices, as they are often the only materials that possess the unique combination of chemical inertness, heat resistance, lack of particle shedding or metal leaching, processability, and other attributes required to meet rigorous requirements. Tla^v„p jlpq ^as^k`ba qb`eklildfbp ^ob j^ab tfqe EUV lithography, capable of feature sizes in the single nanometer scale and gate lengths of ~10 nm or less. Thus, defectivity in the tens- to single- nanometer domain can be detrimental to device yields, performance and reliability. In order to enable manufacturing at these dimensions, cleanliness afforded by fluoropolymer plastics and other PFAS- containing articles used for piping, tanks, seals and coated valves is often essential. 10.0 Properties of Fluorine and Organofluorine Compounds Fluorine is the most electronegative element in the periodic table, with a dense, closely held electron cloud (Lemal 2004). When bonded with carbon, fluorine„s high electronegativity (3.98 vs. 2.55), relatively small size and three lone sp3 nonbonding electron pairs result in the carbon-fluorine bond having the highest bond strength known to organic chemistry )O„H^d^k 3119*. The high electronegativity differential polarizes the C-F bond and creates a Coulombic attraction between carbon and fluorine that `lkqof_rqbp ql qeb _lka pqobkdqe lc qeb `ls^ibkq CèF _lka (Liang, Neumann and Ritter 2013). The dense bib`qolk `ilra ^olrka qeb F ^ipl ebimp pefbia ^ka pqobkdqebk qeb phbibq^i CèC _lkap fk cirlol`^o_lk `e^fkp (Lemal 2004). Compared to the C-H bond, the C-F bond is stronger (13 kcal/mole higher) and longer (1.35 Å vs. 1.09 Å), with a larger dipole moment (1.85 D vs. 0.3 D) that is opposite in direction to that of the C-H group (Biswas and Singh 2020). The combination of high C-F bond strength and shielded C-C bonds make fluorocarbons much less flammable relative to hydrocarbons, while also resistant to degradation by oxidants, reductants, acids and bases, photolysis, and microbial and multicellular metabolic processes (Kovalchuk, et al. 2014); (Krafft and Riess 2015). Because of the strength of the C-F bond and the small size of F, it is possible to substitute fluorine for hydrogen in virtually any kind of organic molecule (Lemal 2004). Consequently, most fluorinated commercial organic chemicals are created by replacing one or more of the hydrogens in a hydrocarbon molecule with fluorine atoms. For instance, when fully fluorinated, methane (CH4) becomes carbon tetrafluoride (CF4); methane sulfonic acid (CH3SO3H) becomes triflic acid (CF3SO3H); and octanoic acid (CH3(CH2)6COOH) becomes perfluorooctanoic acid (CF3(CF2)6COOH), also known as PFOA. Much of what we understand about fluorocarbons comes from comparisons to the corresponding hydrocarbon analog. Individual C-F bonds are highly polar, yet perfluorocarbon molecules have low polarizability and are among the most nonpolar solvents known (Kirsch 2013). The seeming contradiction between the high polarity of individual C-F bonds and the low polarity of overall perfluorocarbon molecules is a consequence of the individual local dipole moments canceling one another, which renders a perfluorocarbon molecule nonpolar overall (Kirsch 2013). As a result of the low molecular polarizability, the van der Waals-type intermolecular attractions between perfluorocarbons and between perfluorocarbons and other organic molecules are weak (Kirsch 2013). Weak attraction between 10.0 Properties of Fluorine and Organofluorine Compounds Fluorine is the most electronegative element in the periodic table, with a dense, closely held electron cloud (Lemal 2004). When bonded with carbon, fluorine„s high electronegativity (3.98 vs. 2.55), relatively small size and three lone sp3 nonbonding electron pairs result in the carbon-fluorine bond having the highest bond strength known to organic chemistry )O„H^d^k 3119*. The high electronegativity differential polarizes the C-F bond and creates a Coulombic attraction between carbon and fluorine that `lkqof_rqbp ql qeb _lka pqobkdqe lc qeb `ls^ibkq CèF _lka (Liang, Neumann and Ritter 2013). The dense bib`qolk `ilra ^olrka qeb F ^ipl ebimp pefbia ^ka pqobkdqebk qeb phbibq^i CèC _lkap fk cirlol`^o_lk `e^fkp (Lemal 2004). Compared to the C-H bond, the C-F bond is stronger (13 kcal/mole higher) and longer (1.35 Å vs. 1.09 Å), with a larger dipole moment (1.85 D vs. 0.3 D) that is opposite in direction to that of the C-H group (Biswas and Singh 2020). The combination of high C-F bond strength and shielded C-C bonds make fluorocarbons much less flammable relative to hydrocarbons, while also resistant to degradation by oxidants, reductants, acids and bases, photolysis, and microbial and multicellular metabolic processes (Kovalchuk, et al. 2014); (Krafft and Riess 2015). Because of the strength of the C-F bond and the small size of F, it is possible to substitute fluorine for hydrogen in virtually any kind of organic molecule (Lemal 2004). Consequently, most fluorinated commercial organic chemicals are created by replacing one or more of the hydrogens in a hydrocarbon molecule with fluorine atoms. For instance, when fully fluorinated, methane (CH4) becomes carbon tetrafluoride (CF4); methane sulfonic acid (CH3SO3H) becomes triflic acid (CF3SO3H); and octanoic acid (CH3(CH2)6COOH) becomes perfluorooctanoic acid (CF3(CF2)6COOH), also known as PFOA. Much of what we understand about fluorocarbons comes from comparisons to the corresponding hydrocarbon analog. Individual C-F bonds are highly polar, yet perfluorocarbon molecules have low polarizability and are among the most nonpolar solvents known (Kirsch 2013). The seeming contradiction between the high polarity of individual C-F bonds and the low polarity of overall perfluorocarbon molecules is a consequence of the individual local dipole moments canceling one another, which renders a perfluorocarbon molecule nonpolar overall (Kirsch 2013). As a result of the low molecular polarizability, the van der Waals-type intermolecular attractions between perfluorocarbons and between perfluorocarbons and other organic molecules are weak (Kirsch 2013). Weak attraction between Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 16 164 perfluorocarbons of the same type makes them volatile (Krafft and Riess 2015). Perfluorocarbons tend to be lipophobic, ^ka _b`^rpb CèF _lkap ^ob ^ipl mllo evaoldbk _lka ^``bmqlop- mbocirlol`^o_lkp ^ipl qbka to be hydrophobic (Han, et al. 2021); (Krafft and Riess 2009). The strength of the intermolecular forces between two molecules of the same type governs physical properties such as melting and boiling points, vapor pressure, enthalpy of vaporization, and viscosity (Krafft and Riess 2015). Because of the weak intermolecular attraction between perfluorinated molecules, neutral perfluorocarbons have low melting and boiling points, high vapor pressures, low enthalpies of vaporization, and relatively low viscosities (Krafft and Riess 2009). Carbon tetrafluoride (CF4, molecular weight [MW] 88) has a much lower boiling point (•128°C) than n-hexane (MW 86, boiling point [BP] = 69°C), with both compounds having nearly the same molecular mass (Kirsch 2013). On the other hand, ionic perfluorocarbons such as perfluoroalkyl carboxylates and perfluoroalkyl sulfonates are well- solvated in water, and have low volatility. The larger size of fluorine compared to hydrogen (with a 23% larger van der Waals radius) make perfluorocarbons bulkier and impose steric requirements that make fluorocarbon chains more rigid than hydrocarbon chains (Krafft and Riess 2015). Given their bulkiness and repulsive fluorine-fluorine interaction, longer fluorocarbon chains tend to adopt a helical geometry, which differs from the planar structure and behavior of the corresponding hydrocarbons (Krafft and Riess 2009). More specifically, the helical geometry is caused by the interaction of the back lobe of an sp3 C-F bond orbital with the front lobe of a C-F orbital on a neighboring carbon. Consequently, the anti-dihedral angle of F-C-C-F is a local maximum with global minima approximately ±5 degrees from the anti-conformation (Watkins and Jorgenson 2001). The larger effective surface area of fluorocarbon chains contributes to the hydrophobicity of perfluorocarbon relative to hydrocarbon chains (Krafft and Riess 2015). For instance, the free energy change associated with the transfer of a -CF2- group from bulk water to the air-water interface is about twice that of a CH2 group (Krafft and Riess 2009). This strongly promotes the partitioning of a fluorocarbon to an air-water interface. In partially fluorinated compounds where a combination of C-F and C-H bonds occur within the same molecule, the local dipole moments may not cancel, with the result that these molecules may have an appreciable overall dipole moment (Kirsch 2013). Partially fluorinated organics often have much higher heat of vaporization and much higher dielectric constants than perfluorocarbons (Kirsch 2013). 10.1 Perfluoroalkyl Acids Two of the most commercially important types of fluorinated organic molecules are the homologous series of perfluoroalkyl carboxylic acids (PFCAs, CF3(CF2)nCOOH) and the homologous series of perfluoroalkyl sulfonic acids (PFSAs, CF3(CF2)nSO3H). Collectively, they are known as perfluoroalkyl acids. The electron-withdrawing characteristics of perfluoroalkyl tails stabilize the anion of the acid head group, rendering PFSAs and PFCAs as strong acids with a very low acid dissociation constant (pKa). Perfluoroalkyl acids are much stronger than their corresponding hydrocarbon analogs and are sometimes referred to as •super acids.‚ There is relatively little increase in acidity with an increase in perfluoroalkyl chain length. For example, the first -CF2- group adjacent to the sulfonic acid moiety is responsible for most of the acid strength (Olah, et al. 2009). The smallest perfluorosulfonic acid, CF3SO3H, is one of the strongest known monoprotic organic acids and has extreme thermal stability, with resistance to both oxidative and reductive cleavage (Howells and McCown 1977). 10.2 Surfactants Fluorocarbon surfactants reduce the surface tension of water to much lower values (~15 to 20 dyne/cm) than hydrocarbon surfactants (~30 dyne/cm) because the fluorocarbon groups are bulkier, with a higher Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 16 164 perfluorocarbons of the same type makes them volatile (Krafft and Riess 2015). Perfluorocarbons tend to be lipophobic, ^ka _b`^rpb CèF _lkap ^ob ^ipl mllo evaoldbk _lka ^``bmqlop- mbocirlol`^o_lkp ^ipl qbka to be hydrophobic (Han, et al. 2021); (Krafft and Riess 2009). The strength of the intermolecular forces between two molecules of the same type governs physical properties such as melting and boiling points, vapor pressure, enthalpy of vaporization, and viscosity (Krafft and Riess 2015). Because of the weak intermolecular attraction between perfluorinated molecules, neutral perfluorocarbons have low melting and boiling points, high vapor pressures, low enthalpies of vaporization, and relatively low viscosities (Krafft and Riess 2009). Carbon tetrafluoride (CF4, molecular weight [MW] 88) has a much lower boiling point (•128°C) than n-hexane (MW 86, boiling point [BP] = 69°C), with both compounds having nearly the same molecular mass (Kirsch 2013). On the other hand, ionic perfluorocarbons such as perfluoroalkyl carboxylates and perfluoroalkyl sulfonates are well- solvated in water, and have low volatility. The larger size of fluorine compared to hydrogen (with a 23% larger van der Waals radius) make perfluorocarbons bulkier and impose steric requirements that make fluorocarbon chains more rigid than hydrocarbon chains (Krafft and Riess 2015). Given their bulkiness and repulsive fluorine-fluorine interaction, longer fluorocarbon chains tend to adopt a helical geometry, which differs from the planar structure and behavior of the corresponding hydrocarbons (Krafft and Riess 2009). More specifically, the helical geometry is caused by the interaction of the back lobe of an sp3 C-F bond orbital with the front lobe of a C-F orbital on a neighboring carbon. Consequently, the anti-dihedral angle of F-C-C-F is a local maximum with global minima approximately ±5 degrees from the anti-conformation (Watkins and Jorgenson 2001). The larger effective surface area of fluorocarbon chains contributes to the hydrophobicity of perfluorocarbon relative to hydrocarbon chains (Krafft and Riess 2015). For instance, the free energy change associated with the transfer of a -CF2- group from bulk water to the air-water interface is about twice that of a CH2 group (Krafft and Riess 2009). This strongly promotes the partitioning of a fluorocarbon to an air-water interface. In partially fluorinated compounds where a combination of C-F and C-H bonds occur within the same molecule, the local dipole moments may not cancel, with the result that these molecules may have an appreciable overall dipole moment (Kirsch 2013). Partially fluorinated organics often have much higher heat of vaporization and much higher dielectric constants than perfluorocarbons (Kirsch 2013). 10.1 Perfluoroalkyl Acids Two of the most commercially important types of fluorinated organic molecules are the homologous series of perfluoroalkyl carboxylic acids (PFCAs, CF3(CF2)nCOOH) and the homologous series of perfluoroalkyl sulfonic acids (PFSAs, CF3(CF2)nSO3H). Collectively, they are known as perfluoroalkyl acids. The electron-withdrawing characteristics of perfluoroalkyl tails stabilize the anion of the acid head group, rendering PFSAs and PFCAs as strong acids with a very low acid dissociation constant (pKa). Perfluoroalkyl acids are much stronger than their corresponding hydrocarbon analogs and are sometimes referred to as •super acids.‚ There is relatively little increase in acidity with an increase in perfluoroalkyl chain length. For example, the first -CF2- group adjacent to the sulfonic acid moiety is responsible for most of the acid strength (Olah, et al. 2009). The smallest perfluorosulfonic acid, CF3SO3H, is one of the strongest known monoprotic organic acids and has extreme thermal stability, with resistance to both oxidative and reductive cleavage (Howells and McCown 1977). 10.2 Surfactants Fluorocarbon surfactants reduce the surface tension of water to much lower values (~15 to 20 dyne/cm) than hydrocarbon surfactants (~30 dyne/cm) because the fluorocarbon groups are bulkier, with a higher Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 17 165 molecular surface area, and have stronger hydrophobicity (Krafft and Riess 2015). The cross-sectional area of a fluorocarbon (27 Å2 to 32 Å2) is much larger than the corresponding hydrocarbon (18 Å2 to 21 Å2), and a significant contributor to its high surface activity (Kovalchuk, et al. 2014). Since the fluorocarbon tail is both oleophobic and hydrophobic, it is surface-active in hydrocarbons as well as water. Surfactant head groups include those that are anionic (sulfonates and carboxylates, phosphates), cationic (quaternary ammonium), nonionic (polyethylene glycols, acrylamide oligomers) and amphoteric (betaines) (Buck, Murphy and Pabon 2012). Given the electron-withdrawing characteristics of the fluorocarbon tail, perfluoroalkyl acids have low pKa, and thus are fully ionized even under very acidic conditions. This can be especially important in wet etch and clean formulations that need to preserve the polar head group, even in the presence of strong mineral acids like hydrofluoric acid (HF HF). The critical micellar concentration (CMC) of a surfactant in water is the concentration at which it aggregates into micellar structures that have a hydrophobic interior and a hydrophilic exterior, and above which no further decrease in surface tension occurs. The CMC of fluorocarbon surfactants are typically equivalent to those of hydrocarbon surfactants, with 50% longer chains (Mukerjee 1994). In water, high hydrophobicity causes fluorinated surfactants to partition to interfaces where they can lower air-liquid, water-oil and air-solid interfacial tensions. The free energy of adsorption for the transfer of each CF2 group from bulk water to the air-water interface is roughly twice as large as for a CH2 group vs. •2.6 kJ/mole) (Krafft and Riess 2015). (•5.1 kJ/mole vs 10 Fluorochemicals in Semiconductor Plasma-Enabled Etch and Deposition Processes 10.3 Fluorinated chemistries used in semiconductor plasma (dry) etch and chamber cleaning include HFCs/PFCs, nitrogen trifluoride (NF NF3) and sulfur hexafluoride (SF SF6). Thin-film deposition and plasma chamber cleaning can be gases (predominantly), liquid or solid (organometallic precursors). Table 1 lists some examples of substances used in these semiconductor manufacturing processes. Table 1: Example PFC, HFC and organometallic precursors used in plasma-enabled etch, clean and deposition processes. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 17 165 molecular surface area, and have stronger hydrophobicity (Krafft and Riess 2015). The cross-sectional area of a fluorocarbon (27 Å2 to 32 Å2) is much larger than the corresponding hydrocarbon (18 Å2 to 21 Å2), and a significant contributor to its high surface activity (Kovalchuk, et al. 2014). Since the fluorocarbon tail is both oleophobic and hydrophobic, it is surface-active in hydrocarbons as well as water. Surfactant head groups include those that are anionic (sulfonates and carboxylates, phosphates), cationic (quaternary ammonium), nonionic (polyethylene glycols, acrylamide oligomers) and amphoteric (betaines) (Buck, Murphy and Pabon 2012). Given the electron-withdrawing characteristics of the fluorocarbon tail, perfluoroalkyl acids have low pKa, and thus are fully ionized even under very acidic conditions. This can be especially important in wet etch and clean formulations that need to preserve the polar head group, even in the presence of strong mineral acids like hydrofluoric acid (HF HF). The critical micellar concentration (CMC) of a surfactant in water is the concentration at which it aggregates into micellar structures that have a hydrophobic interior and a hydrophilic exterior, and above which no further decrease in surface tension occurs. The CMC of fluorocarbon surfactants are typically equivalent to those of hydrocarbon surfactants, with 50% longer chains (Mukerjee 1994). In water, high hydrophobicity causes fluorinated surfactants to partition to interfaces where they can lower air-liquid, water-oil and air-solid interfacial tensions. The free energy of adsorption for the transfer of each CF2 group from bulk water to the air-water interface is roughly twice as large as for a CH2 group vs. •2.6 kJ/mole) (Krafft and Riess 2015). (•5.1 kJ/mole vs 10 Fluorochemicals in Semiconductor Plasma-Enabled Etch and Deposition Processes 10.3 Fluorinated chemistries used in semiconductor plasma (dry) etch and chamber cleaning include HFCs/PFCs, nitrogen trifluoride (NF NF3) and sulfur hexafluoride (SF SF6). Thin-film deposition and plasma chamber cleaning can be gases (predominantly), liquid or solid (organometallic precursors). Table 1 lists some examples of substances used in these semiconductor manufacturing processes. Table 1: Example PFC, HFC and organometallic precursors used in plasma-enabled etch, clean and deposition processes. Chemical Classification Name Structure Trifluoromethane (CHF3)/ HFC gas as HFC-2323 Difluoromethane (CH2F2)/ HFC gas HFC-32 32 Tetrafluoromethane (CF4)/ PFC gas as PFC-14 14 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 18 166 Hexafluoroethane (C2F6)/ PFC gas PFC-116 Octafluoropropane (C3F8)/ PFC gas PFC-218 Octafluorocyclobutane PFC gas (C4F8)/freon-C-318 Chemical Classification Name Structure Trifluoromethane (CHF3)/ HFC gas as HFC-2323 Difluoromethane (CH2F2)/ HFC gas HFC-32 32 Tetrafluoromethane (CF4)/ PFC gas as PFC-14 14 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 18 166 Hexafluoroethane (C2F6)/ PFC gas PFC-116 Octafluoropropane (C3F8)/ PFC gas PFC-218 Octafluorocyclobutane PFC gas (C4F8)/freon-C-318 Organometallic tfac (1,1,1-trifluoro-2,4- precursor ligands pentane-dionate) hfac (1,1,1,5,5,5-hexafluoro- Organometallic 2,4-pentane-dionate) precursor ligands HFC and PFC gases are used in plasma etch tools as a safe source of fluorine, carbon and hydrogen for the precise and selective etching of silicon and other materials to form the often-geometrically complex features of a semiconductor device. Another process using HFC and PFC gases and a plasma source • commonly known as ^ chamber clean‚ • involves the controlled removal of residual films from the interior of chemical vapor deposition (CVD) tools, while minimizing damage to the process chamber. Since the 1980s, semiconductor manufacturers have used PFC gases such as C2F6 and CF4 as fluorine generation sources for CVD chamber cleans because they are nonflammable, less corrosive and less toxic than many other options. Concerns arose, however, about the high global warming potential (GWP) and long atmospheric lifetimes of fluorinated greenhouse gases (GHGs) (for example, C2F6 has a GWP100 of 12,400 and an atmospheric lifetime of 10,000 years; the GWP100 of CF4 is 7,380, with an atmospheric lifetime of 50,000 years). In response to the GWP of PFC emissions, the industry undertook extensive voluntary actions to eliminate the use of PFCs where possible and to reduce emissions. NF3 remote plasma clean (RPS) has replaced fluorocarbon chamber clean processes in 300-mm tools; however, the increased use se of NF3 has resulted in the generation of large quantities of HF and F2, which require the installation of additional air abatements and wastewater treatments to prevent their release to the environment. When disassociated in a plasma, CF4 produces CF3 radical, electron and fluorine atoms, as indicated by Equation 1. The fluorine reacts with solid silicon, as indicated in Equation 2, to produce the volatile tetrafluorosilicon species, which is evacuated from the plasma etch chamber. Organometallic tfac (1,1,1-trifluoro-2,4- precursor ligands pentane-dionate) hfac (1,1,1,5,5,5-hexafluoro- Organometallic 2,4-pentane-dionate) precursor ligands HFC and PFC gases are used in plasma etch tools as a safe source of fluorine, carbon and hydrogen for the precise and selective etching of silicon and other materials to form the often-geometrically complex features of a semiconductor device. Another process using HFC and PFC gases and a plasma source • commonly known as ^ chamber clean‚ • involves the controlled removal of residual films from the interior of chemical vapor deposition (CVD) tools, while minimizing damage to the process chamber. Since the 1980s, semiconductor manufacturers have used PFC gases such as C2F6 and CF4 as fluorine generation sources for CVD chamber cleans because they are nonflammable, less corrosive and less toxic than many other options. Concerns arose, however, about the high global warming potential (GWP) and long atmospheric lifetimes of fluorinated greenhouse gases (GHGs) (for example, C2F6 has a GWP100 of 12,400 and an atmospheric lifetime of 10,000 years; the GWP100 of CF4 is 7,380, with an atmospheric lifetime of 50,000 years). In response to the GWP of PFC emissions, the industry undertook extensive voluntary actions to eliminate the use of PFCs where possible and to reduce emissions. NF3 remote plasma clean (RPS) has replaced fluorocarbon chamber clean processes in 300-mm tools; however, the increased use se of NF3 has resulted in the generation of large quantities of HF and F2, which require the installation of additional air abatements and wastewater treatments to prevent their release to the environment. When disassociated in a plasma, CF4 produces CF3 radical, electron and fluorine atoms, as indicated by Equation 1. The fluorine reacts with solid silicon, as indicated in Equation 2, to produce the volatile tetrafluorosilicon species, which is evacuated from the plasma etch chamber. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 19 167 CF4 + e- => CF3* + F* + e- (1) 4F* + Si(s) => SiF4(g) (2) The use of plasma etch in the semiconductor industry enables the directional (anisotropic) etching of materials, and therefore overcomes qeb isotropic‚ k^qrob lc qeb bq`efkd fk ^ `lksbkqflk^i ^nrblrp bq`efkd solution like hydrofluoric acid. An aqueous etchant removes material (etches) at a uniform rate in all directions (isotropic), resulting in an undercut of the film that requires etching. In contrast, the plasma etch process operates vertically downward (anisotropically), without undercutting the film that requires etching (see Figure 8). Iq„p common to need specific mixtures of PFC and/or HFC gases in order to selectively etch one material, and/or to form a protective polymer coating on the sidewall of the feature being etched that helps maintain the precise, uniform geometries of etched features. In this manner, the equilibrium between etching and deposition reactions provides a way to modulate the etching action. For instance, the addition of H, CxFyHz, serves to control silicon dioxide (SiO2) and silicon nitride (SiN) uniformity and SiO2/SiN selectivity. Similarly, the use of CHF3 helps prevent the lateral etching of aluminum sidewalls. Employing different PFC gases and/or a combination of gases makes highly precise and selective etching at the nanometer scale possible. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 19 167 CF4 + e- => CF3* + F* + e- (1) 4F* + Si(s) => SiF4(g) (2) The use of plasma etch in the semiconductor industry enables the directional (anisotropic) etching of materials, and therefore overcomes qeb isotropic‚ k^qrob lc qeb bq`efkd fk ^ `lksbkqflk^i ^nrblrp bq`efkd solution like hydrofluoric acid. An aqueous etchant removes material (etches) at a uniform rate in all directions (isotropic), resulting in an undercut of the film that requires etching. In contrast, the plasma etch process operates vertically downward (anisotropically), without undercutting the film that requires etching (see Figure 8). Iq„p common to need specific mixtures of PFC and/or HFC gases in order to selectively etch one material, and/or to form a protective polymer coating on the sidewall of the feature being etched that helps maintain the precise, uniform geometries of etched features. In this manner, the equilibrium between etching and deposition reactions provides a way to modulate the etching action. For instance, the addition of H, CxFyHz, serves to control silicon dioxide (SiO2) and silicon nitride (SiN) uniformity and SiO2/SiN selectivity. Similarly, the use of CHF3 helps prevent the lateral etching of aluminum sidewalls. Employing different PFC gases and/or a combination of gases makes highly precise and selective etching at the nanometer scale possible. Figure 8: An anisotropic etch. In certain limited situations, it is possible to use fluorine gas (F2) with additive gases as the gas phase reactant for plasma etching; however, this involves replacing a nontoxic PFC gas with highly hazardous F2. The use of F2 requires significant human health and safety controls. F2 has limited applications in plasma etching because it represents an acute life/safety trade-off relative to currently used PFC and HFC Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 20 168 gases. Exhaust abatement technologies effectively destroy residual PFC and HFC gases from plasma etch and chamber clean processes. Figure 8: An anisotropic etch. In certain limited situations, it is possible to use fluorine gas (F2) with additive gases as the gas phase reactant for plasma etching; however, this involves replacing a nontoxic PFC gas with highly hazardous F2. The use of F2 requires significant human health and safety controls. F2 has limited applications in plasma etching because it represents an acute life/safety trade-off relative to currently used PFC and HFC Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 20 168 gases. Exhaust abatement technologies effectively destroy residual PFC and HFC gases from plasma etch and chamber clean processes. 11.0 Sustainability and the Semiconductor Technology Timeline As the complexity of semiconductor technology increased, the semiconductor industry realized the need for cooperation and pre-competitive R&D. Device makers, SMRE and material suppliers, academia, consortia and national labs came together to develop the first National Technology Roadmap for Semiconductors (NTRS) in 1992, an effort that continued with the International Technology Roadmap for Semiconductors (ITRS); the International Roadmap for Devices and Systems (IRDS) in 2017 and 2023, respectively; and the 2023 SRC Microelectronic and Advanced Packaging Technologies Roadmap. The SRC roadmap defines a 15-vb^o qfjbifkb lc qb`eklildv obnrfobjbkqp ql `lkqfkrb lk qeb m^qe lc Mllob„p law, as well as highlighting priority environmental, health and safety (EHS) research needs. In 1994, the NTRS pq^qba- •Teb roadmap is analogous to paved roads of proven technology, unimproved roads of ^iqbok^qfsb qb`eklildfbp- cllqm^qep qlt^oa kbt qb`eklildfbp- ^ka fkkls^qfsb qo^fip vbq ql _b _i^wba/‚ The semiconductor technology timeline consists of four distinct phases: 11.0 Sustainability and the Semiconductor Technology Timeline As the complexity of semiconductor technology increased, the semiconductor industry realized the need for cooperation and pre-competitive R&D. Device makers, SMRE and material suppliers, academia, consortia and national labs came together to develop the first National Technology Roadmap for Semiconductors (NTRS) in 1992, an effort that continued with the International Technology Roadmap for Semiconductors (ITRS); the International Roadmap for Devices and Systems (IRDS) in 2017 and 2023, respectively; and the 2023 SRC Microelectronic and Advanced Packaging Technologies Roadmap. The SRC roadmap defines a 15-vb^o qfjbifkb lc qb`eklildv obnrfobjbkqp ql `lkqfkrb lk qeb m^qe lc Mllob„p law, as well as highlighting priority environmental, health and safety (EHS) research needs. In 1994, the NTRS pq^qba- •Teb roadmap is analogous to paved roads of proven technology, unimproved roads of ^iqbok^qfsb qb`eklildfbp- cllqm^qep qlt^oa kbt qb`eklildfbp- ^ka fkkls^qfsb qo^fip vbq ql _b _i^wba/‚ The semiconductor technology timeline consists of four distinct phases: • Research. Fundamental research at universities and government labs occurs as much as 15 years before manufacturing ramp. Research addresses fundamental barriers to the extension of existing technologies, following multiple paths. Much research never makes it to subsequent phases. • Development. Development entails the evaluation of a pared-down number of alternative technologies, with a focus on proof of concept. Device makers, tool suppliers, chemical suppliers and consortia conduct research and develop prototype materials, processes and equipment, with an understanding of the application requirements. • Integration. Semiconductor manufacturers focus on the integration and qualification of fab processes, chemicals, tools, test protocols, and the verification of the physical and electrical design of new products, with a focus on developing functional, reliable and high-yielding products. • Ramp to HVM. This phase is the implementation of next-generation tools, chemicals and processes throughout a fab. EHS is an essential element of the technology roadmap (see Figure 9), addressed through various means at each phase of the timeline. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 21 169 • Research. Fundamental research at universities and government labs occurs as much as 15 years before manufacturing ramp. Research addresses fundamental barriers to the extension of existing technologies, following multiple paths. Much research never makes it to subsequent phases. • Development. Development entails the evaluation of a pared-down number of alternative technologies, with a focus on proof of concept. Device makers, tool suppliers, chemical suppliers and consortia conduct research and develop prototype materials, processes and equipment, with an understanding of the application requirements. • Integration. Semiconductor manufacturers focus on the integration and qualification of fab processes, chemicals, tools, test protocols, and the verification of the physical and electrical design of new products, with a focus on developing functional, reliable and high-yielding products. • Ramp to HVM. This phase is the implementation of next-generation tools, chemicals and processes throughout a fab. EHS is an essential element of the technology roadmap (see Figure 9), addressed through various means at each phase of the timeline. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 21 169 Engagement through consortia, Ability to Effect Change Early engagement through and tool and universities and government chemical suppliers Last chance to effect labs technology change Technology frozen, major changes require significant effort and substantial cost External Research Development Integration Manufacturing Ramp Engagement through consortia, Ability to Effect Change Early engagement through and tool and universities and government chemical suppliers Last chance to effect labs technology change Technology frozen, major changes require significant effort and substantial cost External Research Development Integration Manufacturing Ramp 10+ 4 2.5 0 Research Commercialization Phases Demonstration Ramp to HVM YEARS to High Volume Manufacturing Figure 9: EHS engagement model. Teb fkarpqov„p ^_fifqv ql ^mmiv a pollution prevention hierarchy both quickly and cost-effectively (Figure 10) tracks with the technology timeline. It is easiest to address sustainability issues during the R&D phases, when an EHS assessment enables the identification of issues early enough to be resolved before transfer to HVM. It is possible to avoid materials of concern or to replace them with less hazardous substances at the research stage, although the majority of new materials evaluated in research do not progress to development because they do not meet the performance requirements. It is important to evaluate basic physical-chemical properties and some aspects of environmental fate during research. But it is rare to pursue extensive EHS studies until materials are demonstrated because such studies take years to complete, and the material may never be commercialized. The impetus to address sustainability is most effective if driven from the funding side of the R&D equation. 10+ 4 2.5 0 Research Commercialization Phases Demonstration Ramp to HVM YEARS to High Volume Manufacturing Figure 9: EHS engagement model. Teb fkarpqov„p ^_fifqv ql ^mmiv a pollution prevention hierarchy both quickly and cost-effectively (Figure 10) tracks with the technology timeline. It is easiest to address sustainability issues during the R&D phases, when an EHS assessment enables the identification of issues early enough to be resolved before transfer to HVM. It is possible to avoid materials of concern or to replace them with less hazardous substances at the research stage, although the majority of new materials evaluated in research do not progress to development because they do not meet the performance requirements. It is important to evaluate basic physical-chemical properties and some aspects of environmental fate during research. But it is rare to pursue extensive EHS studies until materials are demonstrated because such studies take years to complete, and the material may never be commercialized. The impetus to address sustainability is most effective if driven from the funding side of the R&D equation. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 22 170 Figure 10: Implementation of a pollution prevention hierarchy. The development and integration phases entail efforts to optimize processes and reduce chemical and resource consumption. Many semiconductor processes are transformative; for example, in plasma- enhanced CVD, a plasma reaction deposits input gas as solid thin films (see Figure 11); other processes use thermal energy to generate reaction products. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 22 170 Figure 10: Implementation of a pollution prevention hierarchy. The development and integration phases entail efforts to optimize processes and reduce chemical and resource consumption. Many semiconductor processes are transformative; for example, in plasma- enhanced CVD, a plasma reaction deposits input gas as solid thin films (see Figure 11); other processes use thermal energy to generate reaction products. Inputs Conversion/Consumption Conversion/Consumption Outputs Reaction/Byproduct Reaction/ByproductFormation Formation Figure 11: The emissions characterization process involves the evaluation of inputs, outputs, and conversion or reaction byproducts. Emissions characterization and mass-balance models provide an understanding of process efficiency and enable process optimization to minimize chemical consumption and increase utilization efficiency; moreover, you can identify process byproducts and assess and address EHS risks. Assessing emissions to determine whether they can be recycled or reclaimed often occurs at the integration stage. The progression of new technologies in the development cycle reduces the options for addressing EHS issues because SMRE, chemicals, processes and controls are set at HVM ramp. Changes at HVM are time-consuming and costly; thus, disposal and abatement are the primary solutions available once a technology has reached HVM. Major barriers exist to implementing alternatives after HVM ramp. It is important to evaluate and demonstrate that any alternative has equivalent process performance, requiring research and invention Inputs Conversion/Consumption Conversion/Consumption Outputs Reaction/Byproduct Reaction/ByproductFormation Formation Figure 11: The emissions characterization process involves the evaluation of inputs, outputs, and conversion or reaction byproducts. Emissions characterization and mass-balance models provide an understanding of process efficiency and enable process optimization to minimize chemical consumption and increase utilization efficiency; moreover, you can identify process byproducts and assess and address EHS risks. Assessing emissions to determine whether they can be recycled or reclaimed often occurs at the integration stage. The progression of new technologies in the development cycle reduces the options for addressing EHS issues because SMRE, chemicals, processes and controls are set at HVM ramp. Changes at HVM are time-consuming and costly; thus, disposal and abatement are the primary solutions available once a technology has reached HVM. Major barriers exist to implementing alternatives after HVM ramp. It is important to evaluate and demonstrate that any alternative has equivalent process performance, requiring research and invention Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 23 171 that may not be successful. To prevent regrettable substitutions, any evaluation of alternatives includes emissions and byproducts characterization to understand what is potentially emitted, and in what concentrations; it is also imperative to consider the EHS characteristics of alternatives and reaction byproducts. After selecting an alternative, environmental fate and toxicity data is often not available and testing may take several years. If an alternative provides equivalent process performance but is more hazardous to workers, risk assessments will identify the controls necessary to protect workers. Alternative materials must also be evaluated from an environmental perspective. A proven alternative requires the requalification of processes, an effort that can take six months to several years; moreover, customers of semiconductor products used in applications that require extended lifetimes and reliability (such as automotive and defense) are reluctant to allow process changes and, if a process change is allowed, require product requalifications that can take an additional five to eight years (PFAS Consortium 2023). In summary, the timeline to identify and implement PFAS alternatives is: Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 23 171 that may not be successful. To prevent regrettable substitutions, any evaluation of alternatives includes emissions and byproducts characterization to understand what is potentially emitted, and in what concentrations; it is also imperative to consider the EHS characteristics of alternatives and reaction byproducts. After selecting an alternative, environmental fate and toxicity data is often not available and testing may take several years. If an alternative provides equivalent process performance but is more hazardous to workers, risk assessments will identify the controls necessary to protect workers. Alternative materials must also be evaluated from an environmental perspective. A proven alternative requires the requalification of processes, an effort that can take six months to several years; moreover, customers of semiconductor products used in applications that require extended lifetimes and reliability (such as automotive and defense) are reluctant to allow process changes and, if a process change is allowed, require product requalifications that can take an additional five to eight years (PFAS Consortium 2023). In summary, the timeline to identify and implement PFAS alternatives is: • Three to four years. If an existing non-PFAS alternative is available, does not require infrastructure alterations, and demonstrates adequate performance for a specific application, then it typically takes three to four years to conduct the trial testing and implement the alternative into HVM. • Three to 10-plus years. In some applications, an existing non-PFAS alternative may be viable, but requires tooling and/or process changes before its successful introduction into HVM. In these cases, it may take between three and 10-plus years to introduce changes to the SMRE and/or processes, perform qualification testing, and implement the non-PFAS alternative into HVM. • Five to 25-plus years – successful invention required. For some applications, it may not be possible to demonstrate that an available non-PFAS alternative can fulfill the application-specific performance requirements. In those cases, it may be necessary to invent and synthesize new chemicals, and/or develop alternative approaches to fabricating a device structure that provides the necessary electrical and computational performance. Invention is an open-ended endeavor, with no guarantee of success. • No alternative achievable. In some cases, a non-PFAS alternative may not be capable of providing the required chemical function. • Three to four years. If an existing non-PFAS alternative is available, does not require infrastructure alterations, and demonstrates adequate performance for a specific application, then it typically takes three to four years to conduct the trial testing and implement the alternative into HVM. • Three to 10-plus years. In some applications, an existing non-PFAS alternative may be viable, but requires tooling and/or process changes before its successful introduction into HVM. In these cases, it may take between three and 10-plus years to introduce changes to the SMRE and/or processes, perform qualification testing, and implement the non-PFAS alternative into HVM. • Five to 25-plus years – successful invention required. For some applications, it may not be possible to demonstrate that an available non-PFAS alternative can fulfill the application-specific performance requirements. In those cases, it may be necessary to invent and synthesize new chemicals, and/or develop alternative approaches to fabricating a device structure that provides the necessary electrical and computational performance. Invention is an open-ended endeavor, with no guarantee of success. • No alternative achievable. In some cases, a non-PFAS alternative may not be capable of providing the required chemical function. 12.0 EHS Controls 12.1 Occupational Exposure Control Strategy The design and operation of fabs to stringent building codes and EHS clean-room standards, in combination with strict EHS controls managed by on-site industrial hygienists and engineers, greatly minimizes the opportunity for workers to be exposed to chemicals, including PFAS-containing materials. There are several fundamental features of a semiconductor clean room and fab environment that protect employees: • The isolation of chemicals from the manufacturing floor space by locating chemical supply, air- handling and other ancillary systems outside of manufacturing areas, either by using support spaces located below the clean room (subfab and utility levels), outside the clean-room space (bay and chase-type design), or in specifically designed bulk chemical storage and dispensing areas. • The provision of 10-plus air changes per hour (1 cfm/ft2 of outside air to the space, with a typical minimum of total recirculated air of 20 cfm/ft2), whereby fab air recirculates through high-efficiency filters with a time constant on the order of seconds, replaced entirely with fresh outdoor air in a time constant on the order of minutes. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 24 172 12.0 EHS Controls 12.1 Occupational Exposure Control Strategy The design and operation of fabs to stringent building codes and EHS clean-room standards, in combination with strict EHS controls managed by on-site industrial hygienists and engineers, greatly minimizes the opportunity for workers to be exposed to chemicals, including PFAS-containing materials. There are several fundamental features of a semiconductor clean room and fab environment that protect employees: • The isolation of chemicals from the manufacturing floor space by locating chemical supply, air- handling and other ancillary systems outside of manufacturing areas, either by using support spaces located below the clean room (subfab and utility levels), outside the clean-room space (bay and chase-type design), or in specifically designed bulk chemical storage and dispensing areas. • The provision of 10-plus air changes per hour (1 cfm/ft2 of outside air to the space, with a typical minimum of total recirculated air of 20 cfm/ft2), whereby fab air recirculates through high-efficiency filters with a time constant on the order of seconds, replaced entirely with fresh outdoor air in a time constant on the order of minutes. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 24 172 • Robotic process automation provides a high level of automation, including enclosed process tools and robotics, that inherently isolates workers from chemicals. Throughout the manufacturing process, manufacturing tools shuttle wafers in enclosed FOUPs. Robots typically transfer wafers from the FOUP into the interior of a tool, where they are processed and further handled robotically. • The use of manufacturing tools built to Semiconductor Equipment and Materials Institute (SEMI) safety guidelines and certified to maintain chemical concentrations below defined occupational exposure threshold levels during normal operation and maintenance procedures and in the event of a tool failure. • Where there is a potential risk of exposure to chemicals, qualified EHS staff design any manual work tasks to minimize contact with chemicals and select personal protective equipment (PPE) for workers that are suitable for the task. Employees who work with chemicals will have extensive chemical safety training, with annual refreshers. 12.2 SEMI Safety Guidelines for Tool Design Most semiconductor manufacturers have a company requirement to purchase semiconductor manufacturing tools designed and certified to comply with SEMI safety guidelines; for a complete list of these safety guidelines, see Appendix C. SEMI safety guidelines cover many aspects of manufacturing tool standardization and design conventions that have an enabled a fungible supply of immensely complex and specialized manufacturing tools for installation in fabs across the world. In particular, the SEMI S2 safety guideline addresses design and performance standards for assuring the isolation or protection of clean-room workers from the chemicals used in semiconductor manufacturing tools. The SEMI S2 safety guideline distinguishes between the concentration of a chemical in the general ambient air surrounding a semiconductor manufacturing toli ^ka qeb `lk`bkqo^qflk tfqefk ^ •tlopq-`^pb‚ PBZ. The SEMI S2 safety guideline also differentiates between three states of tool operation: • Robotic process automation provides a high level of automation, including enclosed process tools and robotics, that inherently isolates workers from chemicals. Throughout the manufacturing process, manufacturing tools shuttle wafers in enclosed FOUPs. Robots typically transfer wafers from the FOUP into the interior of a tool, where they are processed and further handled robotically. • The use of manufacturing tools built to Semiconductor Equipment and Materials Institute (SEMI) safety guidelines and certified to maintain chemical concentrations below defined occupational exposure threshold levels during normal operation and maintenance procedures and in the event of a tool failure. • Where there is a potential risk of exposure to chemicals, qualified EHS staff design any manual work tasks to minimize contact with chemicals and select personal protective equipment (PPE) for workers that are suitable for the task. Employees who work with chemicals will have extensive chemical safety training, with annual refreshers. 12.2 SEMI Safety Guidelines for Tool Design Most semiconductor manufacturers have a company requirement to purchase semiconductor manufacturing tools designed and certified to comply with SEMI safety guidelines; for a complete list of these safety guidelines, see Appendix C. SEMI safety guidelines cover many aspects of manufacturing tool standardization and design conventions that have an enabled a fungible supply of immensely complex and specialized manufacturing tools for installation in fabs across the world. In particular, the SEMI S2 safety guideline addresses design and performance standards for assuring the isolation or protection of clean-room workers from the chemicals used in semiconductor manufacturing tools. The SEMI S2 safety guideline distinguishes between the concentration of a chemical in the general ambient air surrounding a semiconductor manufacturing toli ^ka qeb `lk`bkqo^qflk tfqefk ^ •tlopq-`^pb‚ PBZ. The SEMI S2 safety guideline also differentiates between three states of tool operation: • SEMI S2, 23.5.1 states that there should be no chemical emissions to the workplace environment during normal equipment operation. Measurements that show the air concentration to be less than 1% of the occupational exposure limit (OEL) in the worst-case PBZ demonstrate conformance to this requirement. • SEMI S2, 23.5.2 states that chemical emissions during maintenance activities should be minimized. Measurements that show a concentration in the anticipated worst-case PBZ during maintenance activities as less than 25% of the OEL demonstrate conformance to this requirement. • SEMI S2, 25.5.3 states that chemical emissions during equipment failure should be minimized. Measurements that show a concentration in the anticipated worst-case PBZ during a realistic worst- case system failure as less than 25% of the OEL demonstrate conformance to this requirement. A third-party engineering company typically demonstrates conformance with SEMI safety guidelines on new models of manufacturing tools. Performance testing of chemical isolation relative to OEL entails the direct measurement of a chemical of concern under operating conditions, or by using a tracer test with a benign tracer gas. At present, there are no U.S. Occupational Safety and Health Administration, U.S. EPA or other published regulatory standards that address vapor-phase PFAS-containing materials. The third-party engineering company documents their evaluations (which typically also include process hazard evaluations) in a comprehensive, several-hundred-page report. Since these reports contain extensive detail on the design and operating characteristics of highly proprietary manufacturing tools, the test reports are usually classified as confidential business information (CBI). The tool supplier only shares the test reports with direct customers under the protection of nondisclosure agreements. • SEMI S2, 23.5.1 states that there should be no chemical emissions to the workplace environment during normal equipment operation. Measurements that show the air concentration to be less than 1% of the occupational exposure limit (OEL) in the worst-case PBZ demonstrate conformance to this requirement. • SEMI S2, 23.5.2 states that chemical emissions during maintenance activities should be minimized. Measurements that show a concentration in the anticipated worst-case PBZ during maintenance activities as less than 25% of the OEL demonstrate conformance to this requirement. • SEMI S2, 25.5.3 states that chemical emissions during equipment failure should be minimized. Measurements that show a concentration in the anticipated worst-case PBZ during a realistic worst- case system failure as less than 25% of the OEL demonstrate conformance to this requirement. A third-party engineering company typically demonstrates conformance with SEMI safety guidelines on new models of manufacturing tools. Performance testing of chemical isolation relative to OEL entails the direct measurement of a chemical of concern under operating conditions, or by using a tracer test with a benign tracer gas. At present, there are no U.S. Occupational Safety and Health Administration, U.S. EPA or other published regulatory standards that address vapor-phase PFAS-containing materials. The third-party engineering company documents their evaluations (which typically also include process hazard evaluations) in a comprehensive, several-hundred-page report. Since these reports contain extensive detail on the design and operating characteristics of highly proprietary manufacturing tools, the test reports are usually classified as confidential business information (CBI). The tool supplier only shares the test reports with direct customers under the protection of nondisclosure agreements. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 25 173 Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 25 173 12.3 Safety Procedures and On-Site Industrial Hygiene Staff Semiconductor fabs have on-site industrial hygienists, safety specialists and environmental engineers who review and approve chemicals before their purchase and ensure the existence of process-specific safety procedures. In addition, EHS professionals develop and provide chemical and safety training, and review and approve all new tool and chemical infrastructure installations before startup. When a manual task includes a potential risk of exposure to chemicals, EHS staff reviews those work tasks and designs work procedures to minimize contact with chemicals. Where appropriate, employees wear PPE selected for the task by qualified EHS staff. Employees who work with chemicals will have extensive chemical safety and PPE training, with annual refreshers. The availability of on-site EHS staff gives workers an ongoing opportunity for consultation with qualified experts. 12.4 Qualitative and Quantitative Chemical Risk Assessments During a typical chemical review process, industrial hygienists perform qualitative and quantitative risk assessments. A qualitative hazard identification or risk assessment can help risk managers set priorities and make policy decisions to allocate resources to sampling. Many factors influence the decision to conduct a qualitative versus a quantitative risk assessment. In the case of PFAS use in the semiconductor industry, the very small quantities within chemical mixtures located in highly controlled equipment with locally exhausted ventilation essentially make exposure to PFAS by inhalation virtually nonexistent. 12.4.1 SEMATECH PFOS Industrial Hygiene Monitoring in and Around Track Tools The results of PFOS measurements conducted during industrial hygiene sampling in a semiconductor fab by SEMATECH in 2005 provide the best-known available validation of the high level of protection against PFAS exposure provided by fab manufacturing tool design and operation. The use of PFOS has long since been eliminated from semiconductor fabs. But in 2005, SEMATECH„p study assured that there were appropriately protective designs and procedures in place to protect workers from exposure during the evaluation and implementation period of PFOS alternatives. The SEMATECH study involved the collection of a total of nine air samples from within and around photolithography track tools that were known to be using PFOS-containing photoresists at the time of collection. Industrial hygienists collected the samples over a five-day period between May 21 and May 25, 2005, using established industrial hygiene sampling protocols and available analytical methods (Kaiser, et al. 2005); (Reagen, et al. 2004). The results of all samples were less than the method detection limits, which ranged from <160 ng/m3 to <800 ng/m3 in air, as listed in Table 2. The range in detection limits is attributable to the location-specific sample volumes, which varied with the duration of the sample collection (Reagen, et al. 2004). At the time, the OEL recommended by a PFOS formulator was 100,000 ng/m3. The SEMATECH report also summarized the results of industrial hygiene samples collected from at least nine fabs across four semiconductor manufacturing companies. PFOS measurements were all below the method detection limits and were therefore two to three orders of magnitude (100 to 1,000 times) below the OEL of 100,000 ng/m3 recommended by the PFOS supplier at the time. 12.3 Safety Procedures and On-Site Industrial Hygiene Staff Semiconductor fabs have on-site industrial hygienists, safety specialists and environmental engineers who review and approve chemicals before their purchase and ensure the existence of process-specific safety procedures. In addition, EHS professionals develop and provide chemical and safety training, and review and approve all new tool and chemical infrastructure installations before startup. When a manual task includes a potential risk of exposure to chemicals, EHS staff reviews those work tasks and designs work procedures to minimize contact with chemicals. Where appropriate, employees wear PPE selected for the task by qualified EHS staff. Employees who work with chemicals will have extensive chemical safety and PPE training, with annual refreshers. The availability of on-site EHS staff gives workers an ongoing opportunity for consultation with qualified experts. 12.4 Qualitative and Quantitative Chemical Risk Assessments During a typical chemical review process, industrial hygienists perform qualitative and quantitative risk assessments. A qualitative hazard identification or risk assessment can help risk managers set priorities and make policy decisions to allocate resources to sampling. Many factors influence the decision to conduct a qualitative versus a quantitative risk assessment. In the case of PFAS use in the semiconductor industry, the very small quantities within chemical mixtures located in highly controlled equipment with locally exhausted ventilation essentially make exposure to PFAS by inhalation virtually nonexistent. 12.4.1 SEMATECH PFOS Industrial Hygiene Monitoring in and Around Track Tools The results of PFOS measurements conducted during industrial hygiene sampling in a semiconductor fab by SEMATECH in 2005 provide the best-known available validation of the high level of protection against PFAS exposure provided by fab manufacturing tool design and operation. The use of PFOS has long since been eliminated from semiconductor fabs. But in 2005, SEMATECH„p study assured that there were appropriately protective designs and procedures in place to protect workers from exposure during the evaluation and implementation period of PFOS alternatives. The SEMATECH study involved the collection of a total of nine air samples from within and around photolithography track tools that were known to be using PFOS-containing photoresists at the time of collection. Industrial hygienists collected the samples over a five-day period between May 21 and May 25, 2005, using established industrial hygiene sampling protocols and available analytical methods (Kaiser, et al. 2005); (Reagen, et al. 2004). The results of all samples were less than the method detection limits, which ranged from <160 ng/m3 to <800 ng/m3 in air, as listed in Table 2. The range in detection limits is attributable to the location-specific sample volumes, which varied with the duration of the sample collection (Reagen, et al. 2004). At the time, the OEL recommended by a PFOS formulator was 100,000 ng/m3. The SEMATECH report also summarized the results of industrial hygiene samples collected from at least nine fabs across four semiconductor manufacturing companies. PFOS measurements were all below the method detection limits and were therefore two to three orders of magnitude (100 to 1,000 times) below the OEL of 100,000 ng/m3 recommended by the PFOS supplier at the time. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 26 174 Table 2: PFOS concentrations measured in air by SEMATECH in 2005. The American Conference for Governmental Industrial Hygienists (ACGIH) has established threshold limit values (TLVs) for three PFAS chemicals in air: perfluoroisobutylene (a short-term exposure limit of 0.01 ppm), perfluorobutyl ethylene (a 100-ppm time-weighted average) and ammonium perfluorooctanoate • a salt of PFOA (a 0.01-mg/m3 time-weighted average). 12.4.2 NIOSH Research on PFAS The industry is monitoring the development of scientific and regulatory information on the potential occupational toxicity of fluorinated organic compounds. The National Institute for Occupational Safety and Health (NIOSH) reports that their future research will continue building industry knowledge about potential exposure routes and advance practices to reduce the prevalence of PFAS exposure. The industry welcomes these developments. 12.4.3 Environmental Controls The industry has an extensive track record on implementing strict controls on environmental releases including wastewater treatment, air emissions abatement technologies and waste management. The semiconductor industry is actively working to assess, test and implement process controls where they may be needed to reduce PFAS releases to the extent that they may occur. The industry is also sponsoring an extensive amount of university research on PFAS alternatives, emissions abatement, wastewater treatment and waste destruction, as summarized in the following sections. 12.4.4 Wastewater Discharges and Treatment Semiconductor fabs typically have complex wastewater drain systems that carry process-specific wastewater through pre-treatment, equalization and neutralization steps before merging into a combined facility effluent. Segregated wastewater drain and treatment systems include those for certain metals, fluoride, certain acids and chemical-mechanical planarization (CMP) processes, but vary according to the fab design and applicability of local and federal pre-treatment requirements. Typical pre-treatment requirements for the semiconductor industry include the removal of fluoride, ammonia, copper and other plating metals; solids and dissolved solids removal; and pH adjustments. To the extent that PFAS-containing materials are present in fab wastewater systems, the fate of PFAS- containing materials depends on their particular type, and the type of treatment processes used on PFAS- Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 26 174 Table 2: PFOS concentrations measured in air by SEMATECH in 2005. The American Conference for Governmental Industrial Hygienists (ACGIH) has established threshold limit values (TLVs) for three PFAS chemicals in air: perfluoroisobutylene (a short-term exposure limit of 0.01 ppm), perfluorobutyl ethylene (a 100-ppm time-weighted average) and ammonium perfluorooctanoate • a salt of PFOA (a 0.01-mg/m3 time-weighted average). 12.4.2 NIOSH Research on PFAS The industry is monitoring the development of scientific and regulatory information on the potential occupational toxicity of fluorinated organic compounds. The National Institute for Occupational Safety and Health (NIOSH) reports that their future research will continue building industry knowledge about potential exposure routes and advance practices to reduce the prevalence of PFAS exposure. The industry welcomes these developments. 12.4.3 Environmental Controls The industry has an extensive track record on implementing strict controls on environmental releases including wastewater treatment, air emissions abatement technologies and waste management. The semiconductor industry is actively working to assess, test and implement process controls where they may be needed to reduce PFAS releases to the extent that they may occur. The industry is also sponsoring an extensive amount of university research on PFAS alternatives, emissions abatement, wastewater treatment and waste destruction, as summarized in the following sections. 12.4.4 Wastewater Discharges and Treatment Semiconductor fabs typically have complex wastewater drain systems that carry process-specific wastewater through pre-treatment, equalization and neutralization steps before merging into a combined facility effluent. Segregated wastewater drain and treatment systems include those for certain metals, fluoride, certain acids and chemical-mechanical planarization (CMP) processes, but vary according to the fab design and applicability of local and federal pre-treatment requirements. Typical pre-treatment requirements for the semiconductor industry include the removal of fluoride, ammonia, copper and other plating metals; solids and dissolved solids removal; and pH adjustments. To the extent that PFAS-containing materials are present in fab wastewater systems, the fate of PFAS- containing materials depends on their particular type, and the type of treatment processes used on PFAS- Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 27 175 containing wastewater. PFAS-containing materials have been detected in the wastewater of typical fabs (Jacob, Barzen-Hanson and Helbling 2021). If it is necessary to remove PFAS-containing materials from a fab„p „p wastewater, they should ideally be intercepted and/or treated close to their source, where flows are typically lower and concentrations higher. Typical fab effluents can be on the order of 12,000 m3/day to 23,000 m3/day, and removing low concentrations of PFAS-containing materials from a final effluent discharge point that operates at a high flow will be very expensive and, in some cases, infeasible. It is not likely that the conventional precipitation-coagulation-clarification treatment processes typically used to remove dissolved metals and fluoride from on-site fab wastewater systems would exert a high removal efficiency for soluble PFAS-containing materials. The partitioning of some PFAS-containing materials to waste solids may be possible and could represent a relevant vector for PFAS migration in treatment processes. Similarly, it is unlikely that microfiltration processes can remove significant amounts of soluble PFAS- containing materials. Nanofiltration (NF) and reverse osmosis (RO) membranes could potentially remove a significant fraction of long-chain PFAS and lesser amounts of short-chain PFAS into membrane concentrate streams (Boo, et al. 2018); (Jin, Peydayesh and Mezzenga 2021); (Tow, et al. 2021). There are two types of treatment process technologies for removing PFAS-containing materials: technologies that remove or separate PFAS constituents from wastewater, and technologies that destroy the PFAS-containing material. A treatment process such as granular activated carbon (GAC), for instance, can remove PFAS-containing materials from wastewater, but following the completion of the sorption cycle, the used GAC itself becomes waste. Table 3 summarizes the principal separation and destruction technologies currently in use or under development for treating PFAS-containing wastewater. The principal, commercially available technologies applicable to the removal of PFAS-containing materials from wastewater are adsorption onto GAC, anion exchange (AIX) and membrane filtration (Crone, et al. 2019). The capacity of GAC to remove a given PFAS-containing material is typically expressed in terms of the milligrams of PFAS per kilogram of GAC and varies considerably depending on the particular type of PFAS-containing material. AIX can be an effective way to remove anionic PFAS-containing materials from water. AIX typically has a higher sorption capacity than GAC, and some similar (but not quite as strong) constraints regarding a preference for longer- over shorter-chain PFAS-containing materials, as well as a preference for sulfonic acid vs. carboxylate groups (Franke, et al. 2021). High-pressure membrane techniques like RO and NF (as illustrated in Figure 12) can be an effective way to separate PFAS-containing materials from an aqueous waste stream and concentrate it for further treatment (Lee, Speth and Nadagouda 2022); (Liu and Strathmann 2021); (Liu, et al. 2022). RO, in particular, can serve as a near-absolute barrier to most typical PFAS-containing materials Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 27 175 containing wastewater. PFAS-containing materials have been detected in the wastewater of typical fabs (Jacob, Barzen-Hanson and Helbling 2021). If it is necessary to remove PFAS-containing materials from a fab„p „p wastewater, they should ideally be intercepted and/or treated close to their source, where flows are typically lower and concentrations higher. Typical fab effluents can be on the order of 12,000 m3/day to 23,000 m3/day, and removing low concentrations of PFAS-containing materials from a final effluent discharge point that operates at a high flow will be very expensive and, in some cases, infeasible. It is not likely that the conventional precipitation-coagulation-clarification treatment processes typically used to remove dissolved metals and fluoride from on-site fab wastewater systems would exert a high removal efficiency for soluble PFAS-containing materials. The partitioning of some PFAS-containing materials to waste solids may be possible and could represent a relevant vector for PFAS migration in treatment processes. Similarly, it is unlikely that microfiltration processes can remove significant amounts of soluble PFAS- containing materials. Nanofiltration (NF) and reverse osmosis (RO) membranes could potentially remove a significant fraction of long-chain PFAS and lesser amounts of short-chain PFAS into membrane concentrate streams (Boo, et al. 2018); (Jin, Peydayesh and Mezzenga 2021); (Tow, et al. 2021). There are two types of treatment process technologies for removing PFAS-containing materials: technologies that remove or separate PFAS constituents from wastewater, and technologies that destroy the PFAS-containing material. A treatment process such as granular activated carbon (GAC), for instance, can remove PFAS-containing materials from wastewater, but following the completion of the sorption cycle, the used GAC itself becomes waste. Table 3 summarizes the principal separation and destruction technologies currently in use or under development for treating PFAS-containing wastewater. The principal, commercially available technologies applicable to the removal of PFAS-containing materials from wastewater are adsorption onto GAC, anion exchange (AIX) and membrane filtration (Crone, et al. 2019). The capacity of GAC to remove a given PFAS-containing material is typically expressed in terms of the milligrams of PFAS per kilogram of GAC and varies considerably depending on the particular type of PFAS-containing material. AIX can be an effective way to remove anionic PFAS-containing materials from water. AIX typically has a higher sorption capacity than GAC, and some similar (but not quite as strong) constraints regarding a preference for longer- over shorter-chain PFAS-containing materials, as well as a preference for sulfonic acid vs. carboxylate groups (Franke, et al. 2021). High-pressure membrane techniques like RO and NF (as illustrated in Figure 12) can be an effective way to separate PFAS-containing materials from an aqueous waste stream and concentrate it for further treatment (Lee, Speth and Nadagouda 2022); (Liu and Strathmann 2021); (Liu, et al. 2022). RO, in particular, can serve as a near-absolute barrier to most typical PFAS-containing materials Figure 12: A two wo-stage nanofiltration system (Franke, et al. 2021). Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 28 176 The semiconductor industry is funding university research to study a number of different types of PFAS treatment technologies. The right-hand column in Table 3 lists universities that are either receiving funding from the SRC or companies that are SRC members. In general, the state of technology for PFAS wastewater treatment is immature, with significant improvements needed to increase the number and types of PFAS-containing materials that can be removed cost-effectively from wastewater. Existing separation and destruction methods are generally best suited to the removal of longer-chain perfluoroalkyl acids, with more difficulty removing shorter-chain and/or neutral PFAS-containing materials (Murray, et al. 2021); (Liu and Strathmann 2021); (Liu, et al. 2022). There are numerous methods to destroy PFAS-containing materials under evaluation, with new technologies and refinements of existing technologies reported in literature virtually every day. The bottom half of Table 3 lists several of the most promising PFAS destruction technologies under development. Generally, reduction, plasma and electrochemical methods appear to be more effective than oxidation methods, which face thermodynamic barriers (Vecitis, et al. 2008); (Bentel, et al. 2020). Alkaline hydrolysis and supercritical water oxidation (SCWO) are high-temperature, high-pressure processes that aim to mineralize PFAS-containing materials and show promising results. Table 3: Summary of PFAS wastewater treatment methods. Figure 12: A two wo-stage nanofiltration system (Franke, et al. 2021). Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 28 176 The semiconductor industry is funding university research to study a number of different types of PFAS treatment technologies. The right-hand column in Table 3 lists universities that are either receiving funding from the SRC or companies that are SRC members. In general, the state of technology for PFAS wastewater treatment is immature, with significant improvements needed to increase the number and types of PFAS-containing materials that can be removed cost-effectively from wastewater. Existing separation and destruction methods are generally best suited to the removal of longer-chain perfluoroalkyl acids, with more difficulty removing shorter-chain and/or neutral PFAS-containing materials (Murray, et al. 2021); (Liu and Strathmann 2021); (Liu, et al. 2022). There are numerous methods to destroy PFAS-containing materials under evaluation, with new technologies and refinements of existing technologies reported in literature virtually every day. The bottom half of Table 3 lists several of the most promising PFAS destruction technologies under development. Generally, reduction, plasma and electrochemical methods appear to be more effective than oxidation methods, which face thermodynamic barriers (Vecitis, et al. 2008); (Bentel, et al. 2020). Alkaline hydrolysis and supercritical water oxidation (SCWO) are high-temperature, high-pressure processes that aim to mineralize PFAS-containing materials and show promising results. Table 3: Summary of PFAS wastewater treatment methods. When evaluating PFAS destruction technologies, it is important to measure the extent of mineralization (conversion to carbon dioxide plus fluoride ion or hydrogen fluoride gas) and the extent to which potentially harmful byproducts are generated. Often, the removal efficiencies reported for targeted parent compounds are much higher than the overall defluorination (Wang, et al. 2022). Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 29 177 When evaluating PFAS destruction technologies, it is important to measure the extent of mineralization (conversion to carbon dioxide plus fluoride ion or hydrogen fluoride gas) and the extent to which potentially harmful byproducts are generated. Often, the removal efficiencies reported for targeted parent compounds are much higher than the overall defluorination (Wang, et al. 2022). Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 29 177 12.4.5 PFAS Waste Disposal and Destruction by Incineration PFAS-containing materials are present in some semiconductor manufacturing solvent wastes. Residual photoresists and anti-reflective coatings, for instance, are largely captured directly at the photolithography tool dispensing step and shipped for off-site disposal. Organic waste (including PFAS organic liquids) is typically segregated, collected, and containerized for off-site treatment, and disposed of as a blended fuel through high-temperature incineration or reprocessing. Often regulated because of its flammability (rather than the presence of PFAS-containing materials), liquid organic waste that cannot be treated on-site is collected and shipped off-site to a licensed treatment and disposal facility. These facilities will either reclaim solvent constituents, manage the solvent for energy recovery as fuel for cement kilns, or incinerate the hazardous waste. There are currently no published PFAS-specific regulations or regulatory guidance governing the design, operation or monitoring of commercial waste incinerators used to destroy PFAS waste. The U.S. EPA has indicated that it is working to establish such guidance in late 2023. A number of technical papers describe laboratory or simulation studies that address the temperature at which certain PFAS-containing materials decompose, and some of the fluorinated decomposition products that form, but these papers generally lack specific information regarding the temperature, residence time, and other process and design variables directly applicable to commercial incineration (Wang, et al. 2022); (U.S. EPA 2020). Based on calculated bond energies, for instance, the most difficult fluorinated organic compound to decompose is CF4, which requires temperatures over 1,400°C for effective destruction (Tsang, Burgess Jr. and Babushok 1998). A typical commercial hazardous waste incinerator in the U.S. is a rotary kiln with a primary combustion chamber that has solid retention times of 0.5 to 1.5 hours and gas residence times around 2 seconds, with kiln flame temperatures from 650°C to 1,650°C (U.S. EPA 2020). The rotary kiln is typically followed by an afterburner that operates at a temperature between 1,100°C and 1,370°C, with a gas phase residence time of 1 to 3 seconds (U.S. EPA 2020). In some cases, hazardous waste is burned in cement kilns, where temperatures may rise above 1,650°C with gas phase residence times on the order of 4 to 16 seconds, depending on the design (U.S. EPA 2020). In addition to operating at high temperatures and having long gas phase residence times, cement kilns have the additional advantage of providing a caustic environment for halogen reaction and acid neutralization (U.S. EPA 2020). Based on the high temperatures and long gas phase residence times reported for the kiln-type incinerators commonly used to destroy hazardous waste, PFAS destruction or removal efficiency (DRE) should be very good. 12.4.6 Air Emissions Control and Abatement Fab exhaust systems are designed to remove chemical vapors or gases and heat from manufacturing tool exhausts. PFCs and HFCs are essential for plasma etching, plasma cleaning and other low-volume applications, as their uses balance the process requirement for high chemical and ion reactivity with the need for safe and effective manufacturing. The chemistries used in photolithography have a relatively low vapor pressure, and the industry does not ^kqf`fm^qb bjfppflkp colj melqlifqeldo^mev/ Teb fkarpqov„p `ljjfqjbkq ql obar`b GHGs has successfully reduced PFC and HFC emissions through a combination of process optimization, substitution and abatement. Point-of-use (POU) technologies on many tools using PFCs and HFCs have reduced the potential exposure risk to employees, as well as reducing GHG emissions. 12.4.5 PFAS Waste Disposal and Destruction by Incineration PFAS-containing materials are present in some semiconductor manufacturing solvent wastes. Residual photoresists and anti-reflective coatings, for instance, are largely captured directly at the photolithography tool dispensing step and shipped for off-site disposal. Organic waste (including PFAS organic liquids) is typically segregated, collected, and containerized for off-site treatment, and disposed of as a blended fuel through high-temperature incineration or reprocessing. Often regulated because of its flammability (rather than the presence of PFAS-containing materials), liquid organic waste that cannot be treated on-site is collected and shipped off-site to a licensed treatment and disposal facility. These facilities will either reclaim solvent constituents, manage the solvent for energy recovery as fuel for cement kilns, or incinerate the hazardous waste. There are currently no published PFAS-specific regulations or regulatory guidance governing the design, operation or monitoring of commercial waste incinerators used to destroy PFAS waste. The U.S. EPA has indicated that it is working to establish such guidance in late 2023. A number of technical papers describe laboratory or simulation studies that address the temperature at which certain PFAS-containing materials decompose, and some of the fluorinated decomposition products that form, but these papers generally lack specific information regarding the temperature, residence time, and other process and design variables directly applicable to commercial incineration (Wang, et al. 2022); (U.S. EPA 2020). Based on calculated bond energies, for instance, the most difficult fluorinated organic compound to decompose is CF4, which requires temperatures over 1,400°C for effective destruction (Tsang, Burgess Jr. and Babushok 1998). A typical commercial hazardous waste incinerator in the U.S. is a rotary kiln with a primary combustion chamber that has solid retention times of 0.5 to 1.5 hours and gas residence times around 2 seconds, with kiln flame temperatures from 650°C to 1,650°C (U.S. EPA 2020). The rotary kiln is typically followed by an afterburner that operates at a temperature between 1,100°C and 1,370°C, with a gas phase residence time of 1 to 3 seconds (U.S. EPA 2020). In some cases, hazardous waste is burned in cement kilns, where temperatures may rise above 1,650°C with gas phase residence times on the order of 4 to 16 seconds, depending on the design (U.S. EPA 2020). In addition to operating at high temperatures and having long gas phase residence times, cement kilns have the additional advantage of providing a caustic environment for halogen reaction and acid neutralization (U.S. EPA 2020). Based on the high temperatures and long gas phase residence times reported for the kiln-type incinerators commonly used to destroy hazardous waste, PFAS destruction or removal efficiency (DRE) should be very good. 12.4.6 Air Emissions Control and Abatement Fab exhaust systems are designed to remove chemical vapors or gases and heat from manufacturing tool exhausts. PFCs and HFCs are essential for plasma etching, plasma cleaning and other low-volume applications, as their uses balance the process requirement for high chemical and ion reactivity with the need for safe and effective manufacturing. The chemistries used in photolithography have a relatively low vapor pressure, and the industry does not ^kqf`fm^qb bjfppflkp colj melqlifqeldo^mev/ Teb fkarpqov„p `ljjfqjbkq ql obar`b GHGs has successfully reduced PFC and HFC emissions through a combination of process optimization, substitution and abatement. Point-of-use (POU) technologies on many tools using PFCs and HFCs have reduced the potential exposure risk to employees, as well as reducing GHG emissions. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 30 178 The F-HTFs used in chillers and test equipment are contained with intent to minimize release during use. Before any maintenance activities, qualified workers drain F-HTFs contained in equipment into collection containers that are managed for direct use or reclamation at the F-HTF supplier. If any of the F-HTF fluid requires management as waste, certified waste management facilities destroy the fluid by incineration. There are four general categories of exhaust systems (Li, et al. 2021); (Sherer 2018): • General exhaust is a centralized exhaust system consisting of air from exhausted enclosures, typically uncontaminated with hazardous or toxic chemicals and heat exhaust. General exhaust does not require abatement. • Acid and alkali (corrosive) exhaust, the highest-volume exhaust stream, is primarily generated from the use or generation of acid or alkali gases within etch, deposition and cleaning processes. Chlorine, fluorine, fluorinated GHG and hydrides are components of acid exhaust. Alkali exhaust is usually segregated from acid exhaust in order to prevent the clogging and formation of submicron particles, and to treat the exhaust more effectively. Acid and alkali exhaust treatments often occur in centralized pH-controlled packed-bed wet scrubbers. • Organic exhaust is primarily generated from the use or generation of volatile organic compounds (VOCs) within photolithography and organic cleaning processes. • Organic solvent exhaust typically has a high volume and a low concentration, which often leads to a concentrated exhaust stream before treatment with centralized thermal, catalytic or plasma oxidizers. Certain SMRE requires the installation of POU abatement devices to remove contaminants before their discharge to centralized exhaust systems. POU abatement devices prevent the clogging of exhaust lines and thus increase process uptimes; they also prevent fires, explosions and corrosion, and protect workers and the environment. The main components of any exhaust collection and distribution system consist of ductwork, fans, pumps and possibly treatment technologies. The materials used to construct exhaust systems in fab and assembly test manufacturing facilities must be chemically resistant, in order to prevent corrosion and release of the exhaust. Ethylene chlorotrifluoroethylene (ECTFE)- or polytetrafluoroethylene (PTFE)-lined stainless- steel ductwork helps ensure safe conditions within fab and assembly, test and packaging operations, especially in high-heat, chemically corrosive or chemically unstable environments. POU abatement systems have evolved over time to meet safety, environmental and risk-reduction targets. They facilitate effective and safe treatment for pyrophoric, toxic, flammable and corrosive gases. Researchers, suppliers and semiconductor manufacturers have undertaken extensive efforts to develop and improve fluorinated GHG abatement technologies over the last 30 years (see Figure 13). Abatement technologies including combustion with a wet scrubber, electrical heating with a wet scrubber, chemisorption/adsorber and plasma have been shown to remove PFCs and other fluorinated GHGs from process exhaust (Beu 2019). Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 30 178 The F-HTFs used in chillers and test equipment are contained with intent to minimize release during use. Before any maintenance activities, qualified workers drain F-HTFs contained in equipment into collection containers that are managed for direct use or reclamation at the F-HTF supplier. If any of the F-HTF fluid requires management as waste, certified waste management facilities destroy the fluid by incineration. There are four general categories of exhaust systems (Li, et al. 2021); (Sherer 2018): • General exhaust is a centralized exhaust system consisting of air from exhausted enclosures, typically uncontaminated with hazardous or toxic chemicals and heat exhaust. General exhaust does not require abatement. • Acid and alkali (corrosive) exhaust, the highest-volume exhaust stream, is primarily generated from the use or generation of acid or alkali gases within etch, deposition and cleaning processes. Chlorine, fluorine, fluorinated GHG and hydrides are components of acid exhaust. Alkali exhaust is usually segregated from acid exhaust in order to prevent the clogging and formation of submicron particles, and to treat the exhaust more effectively. Acid and alkali exhaust treatments often occur in centralized pH-controlled packed-bed wet scrubbers. • Organic exhaust is primarily generated from the use or generation of volatile organic compounds (VOCs) within photolithography and organic cleaning processes. • Organic solvent exhaust typically has a high volume and a low concentration, which often leads to a concentrated exhaust stream before treatment with centralized thermal, catalytic or plasma oxidizers. Certain SMRE requires the installation of POU abatement devices to remove contaminants before their discharge to centralized exhaust systems. POU abatement devices prevent the clogging of exhaust lines and thus increase process uptimes; they also prevent fires, explosions and corrosion, and protect workers and the environment. The main components of any exhaust collection and distribution system consist of ductwork, fans, pumps and possibly treatment technologies. The materials used to construct exhaust systems in fab and assembly test manufacturing facilities must be chemically resistant, in order to prevent corrosion and release of the exhaust. Ethylene chlorotrifluoroethylene (ECTFE)- or polytetrafluoroethylene (PTFE)-lined stainless- steel ductwork helps ensure safe conditions within fab and assembly, test and packaging operations, especially in high-heat, chemically corrosive or chemically unstable environments. POU abatement systems have evolved over time to meet safety, environmental and risk-reduction targets. They facilitate effective and safe treatment for pyrophoric, toxic, flammable and corrosive gases. Researchers, suppliers and semiconductor manufacturers have undertaken extensive efforts to develop and improve fluorinated GHG abatement technologies over the last 30 years (see Figure 13). Abatement technologies including combustion with a wet scrubber, electrical heating with a wet scrubber, chemisorption/adsorber and plasma have been shown to remove PFCs and other fluorinated GHGs from process exhaust (Beu 2019). Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 31 179 Figure 13 13: Semiconductor industry fluorinated GHG abatement development timeline. For additional information about fluorinated GHG abatement, see the Semiconductor PFAS Consortium white paper, •PFAS-Containing Fluorochemicals Used in Semiconductor Manufacturing Plasma-Enabled Etch and Deposition.‚ Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 31 179 Figure 13 13: Semiconductor industry fluorinated GHG abatement development timeline. For additional information about fluorinated GHG abatement, see the Semiconductor PFAS Consortium white paper, •PFAS-Containing Fluorochemicals Used in Semiconductor Manufacturing Plasma-Enabled Etch and Deposition.‚ 13 R&D Needs 13.0 The fluorinated organic molecule possesses numerous attributes that provide unique functionality across a wide spectrum of applications. In many situations, it is not just one particular attribute (like low surface tension) that makes a fluorinated organic chemical effective for an application, but the combination of several attributes that enable fluorinated organics to satisfy multiple, overlapping performance requirements. For many PFAS-containing materials, there is an absence of basic validated physicochemical data, which makes it virtually impossible to determine their toxicity and environmental fate and transport. Given their potential persistence, bioaccumulation and toxicity, regulators and policymakers both in the U.S. and globally are taking actions to mitigate the potential impacts of these chemicals. A growing number of jurisdictions are addressing or proposing the categorization of PFAS as an entire class. To maintain industry growth and avoid regrettable substitutions, it is imperative to: 13 R&D Needs 13.0 The fluorinated organic molecule possesses numerous attributes that provide unique functionality across a wide spectrum of applications. In many situations, it is not just one particular attribute (like low surface tension) that makes a fluorinated organic chemical effective for an application, but the combination of several attributes that enable fluorinated organics to satisfy multiple, overlapping performance requirements. For many PFAS-containing materials, there is an absence of basic validated physicochemical data, which makes it virtually impossible to determine their toxicity and environmental fate and transport. Given their potential persistence, bioaccumulation and toxicity, regulators and policymakers both in the U.S. and globally are taking actions to mitigate the potential impacts of these chemicals. A growing number of jurisdictions are addressing or proposing the categorization of PFAS as an entire class. To maintain industry growth and avoid regrettable substitutions, it is imperative to: • Fund and conduct research to understand basic physicochemical data to better model the potential environmental and human health risks associated with these chemistries, and to identify alternative chemistries where possible that are more environmentally preferable. • Develop recycling, treatment and abatement technologies to prevent environmental releases for uses with no known alternatives at this time. Further, given the multiple properties that PFAS-containing materials instill, it is more likely that there will be a combination of application-specific solutions rather than a universal replacement. It is recommended that the semiconductor industry, academicians, national labs and suppliers collaborate on semiconductor PFAS-focused R&D efforts to: • Advance the development of analytical methods to measure and control PFAS-containing materials in the work environment, wastewater and air emissions streams. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 32 180 • Fund and conduct research to understand basic physicochemical data to better model the potential environmental and human health risks associated with these chemistries, and to identify alternative chemistries where possible that are more environmentally preferable. • Develop recycling, treatment and abatement technologies to prevent environmental releases for uses with no known alternatives at this time. Further, given the multiple properties that PFAS-containing materials instill, it is more likely that there will be a combination of application-specific solutions rather than a universal replacement. It is recommended that the semiconductor industry, academicians, national labs and suppliers collaborate on semiconductor PFAS-focused R&D efforts to: • Advance the development of analytical methods to measure and control PFAS-containing materials in the work environment, wastewater and air emissions streams. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 32 180 • Develop a higher level of knowledge regarding the environmental behavior and toxicity of PFAS- containing materials, their potential degradation products, and potential alternatives, using the data to: o Develop and validate predictive toxicology, environmental fate and behavior tools for PFAS- containing materials and potential PFAS alternatives for use in semiconductor manufacturing. o Improve knowledge of the factors that cause PFAS-containing materials to be toxic, which will aid the development and identification of potentially more benign substitutes. • Quantify and improve technology that minimizes potential environmental releases. • Quantify and validate the efficacy of workplace exposure controls. • Optimize processes to reduce or reuse materials where possible in support of a circular economy. • Develop, design, test and validate PFAS destruction technologies. • Identify opportunities for process enhancements that reduce the total use of fluorinated gases. • Develop HFC and PFC abatement options for POU or house (end-of-pipe) abatement of exhaust emissions that can achieve higher DREs while minimizing the generation of other regulated emissions. • Promote development of additional reuse and recycling options for PFAS-containing liquid waste streams. • Evaluate options to facilitate the recovery and reuse of articles containing PFAS. • Evaluate alternative plasma etch/wafer clean gases and processes that are effective, safe and have a lower GWP than fluorinated gases. • Develop low-temperature, high-efficiency processes and look for materials that can work at lower temperatures (bottom-up processes such as directed self-assembly) to help facilitate the transition away from F-HTFs. • Identify and characterize process performance and EHS characteristics of more benign nonfluorinated alternatives such as: o PFAS-free anions in PAGs capable of making strong acids. o PFAS-free anti-reflective coatings. o PFAS-free immersion barriers. o PFAS-free surfactants. o PFAS-free lubricants. o PFAS-free HTFs with a lower GWP used in chillers to control wafer temperatures during manufacturing processes or device testing. o PFAS-free ligands for metal-organic CVD precursors. • Identify and evaluate: o Fluoropolymer alternatives for use in SMRE and facilities infrastructures. o The potential of additive processing techniques. o Non-PFAS semiconductor assembly, test and packaging materials that can perform at sustained high temperatures, low temperatures, wide thermal excursions and under large thermomechanical loads. • Develop a higher level of knowledge regarding the environmental behavior and toxicity of PFAS- containing materials, their potential degradation products, and potential alternatives, using the data to: o Develop and validate predictive toxicology, environmental fate and behavior tools for PFAS- containing materials and potential PFAS alternatives for use in semiconductor manufacturing. o Improve knowledge of the factors that cause PFAS-containing materials to be toxic, which will aid the development and identification of potentially more benign substitutes. • Quantify and improve technology that minimizes potential environmental releases. • Quantify and validate the efficacy of workplace exposure controls. • Optimize processes to reduce or reuse materials where possible in support of a circular economy. • Develop, design, test and validate PFAS destruction technologies. • Identify opportunities for process enhancements that reduce the total use of fluorinated gases. • Develop HFC and PFC abatement options for POU or house (end-of-pipe) abatement of exhaust emissions that can achieve higher DREs while minimizing the generation of other regulated emissions. • Promote development of additional reuse and recycling options for PFAS-containing liquid waste streams. • Evaluate options to facilitate the recovery and reuse of articles containing PFAS. • Evaluate alternative plasma etch/wafer clean gases and processes that are effective, safe and have a lower GWP than fluorinated gases. • Develop low-temperature, high-efficiency processes and look for materials that can work at lower temperatures (bottom-up processes such as directed self-assembly) to help facilitate the transition away from F-HTFs. • Identify and characterize process performance and EHS characteristics of more benign nonfluorinated alternatives such as: o PFAS-free anions in PAGs capable of making strong acids. o PFAS-free anti-reflective coatings. o PFAS-free immersion barriers. o PFAS-free surfactants. o PFAS-free lubricants. o PFAS-free HTFs with a lower GWP used in chillers to control wafer temperatures during manufacturing processes or device testing. o PFAS-free ligands for metal-organic CVD precursors. • Identify and evaluate: o Fluoropolymer alternatives for use in SMRE and facilities infrastructures. o The potential of additive processing techniques. o Non-PFAS semiconductor assembly, test and packaging materials that can perform at sustained high temperatures, low temperatures, wide thermal excursions and under large thermomechanical loads. 13.0 Conclusions PFAS chemicals contain two or more fluorine atoms bonded to a carbon or hydrocarbon backbone. Their carbon-fluorine bonds and structure give them unique physical and chemical properties, such as repelling both water and oils, remaining stable over a wide temperature range, and having low coefficients of friction, making them useful in many industrial and consumer applications, including semiconductor manufacturing. However, many of these same properties make PFAS-containing materials resistant to decomposition when released to the bksfolkjbkq- tef`e e^p iba qebj ql _b `^iiba clobsbo `ebjf`^ip/‚ Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 33 181 13.0 Conclusions PFAS chemicals contain two or more fluorine atoms bonded to a carbon or hydrocarbon backbone. Their carbon-fluorine bonds and structure give them unique physical and chemical properties, such as repelling both water and oils, remaining stable over a wide temperature range, and having low coefficients of friction, making them useful in many industrial and consumer applications, including semiconductor manufacturing. However, many of these same properties make PFAS-containing materials resistant to decomposition when released to the bksfolkjbkq- tef`e e^p iba qebj ql _b `^iiba clobsbo `ebjf`^ip/‚ Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 33 181 Semiconductors are essential components of electronic devices and are integral to modern society. According to the World Economic Forum, semiconductor-enabled technologies such as digital technologies can reduce GHG emissions by 15% • almost one-third of the 50% reduction required by 2039 (World Economic Forum 2019). Manufacturers and suppliers have identified seven areas where PFAS chemistry supports advanced semiconductor manufacturing: photolithography, wet chemistry, HFC and PFC gases, HTFs, chip packaging, fabrication tools and associated fixtures, and lubricants. Modern semiconductor manufacturing fabs consist of thousands of tools, and each of these perform a specific process operation to construct and assemble a chip wafer. Fabs have strict requirements to maintain clean-room environments to capture and remove contaminants such as dust, and to control humidity and chemistry. In many applications, PFAS-containing materials are the only chemicals known to provide the required physical and chemical properties for advanced semiconductor manufacturing. The industry has strict controls to minimize working exposure to chemicals, including PFAS-containing materials used in the chip manufacturing process. Some materials are sent off-site for treatment, such as incineration, or disposed of in regulated solid waste disposal facilities. Fabs also have wastewater pre- treatment or treatment systems before discharge. The semiconductor industry continues actively identifying, testing and implementing improved process controls that minimize releases to the environment, including PFAS-containing materials. The industry is also researching prospective PFAS substitutes, which is expensive and time-consuming. The identification and validation of alternatives is a lengthy process that entails identifying potential substitutes, evaluating their potential human and environmental risks, conducting laboratory and pilot tests, designing and retooling equipment, conducting verification tests, and finally implementing a substitution. The semiconductor industry recognizes the need for and is undertaking additional R&D to: Semiconductors are essential components of electronic devices and are integral to modern society. According to the World Economic Forum, semiconductor-enabled technologies such as digital technologies can reduce GHG emissions by 15% • almost one-third of the 50% reduction required by 2039 (World Economic Forum 2019). Manufacturers and suppliers have identified seven areas where PFAS chemistry supports advanced semiconductor manufacturing: photolithography, wet chemistry, HFC and PFC gases, HTFs, chip packaging, fabrication tools and associated fixtures, and lubricants. Modern semiconductor manufacturing fabs consist of thousands of tools, and each of these perform a specific process operation to construct and assemble a chip wafer. Fabs have strict requirements to maintain clean-room environments to capture and remove contaminants such as dust, and to control humidity and chemistry. In many applications, PFAS-containing materials are the only chemicals known to provide the required physical and chemical properties for advanced semiconductor manufacturing. The industry has strict controls to minimize working exposure to chemicals, including PFAS-containing materials used in the chip manufacturing process. Some materials are sent off-site for treatment, such as incineration, or disposed of in regulated solid waste disposal facilities. Fabs also have wastewater pre- treatment or treatment systems before discharge. The semiconductor industry continues actively identifying, testing and implementing improved process controls that minimize releases to the environment, including PFAS-containing materials. The industry is also researching prospective PFAS substitutes, which is expensive and time-consuming. The identification and validation of alternatives is a lengthy process that entails identifying potential substitutes, evaluating their potential human and environmental risks, conducting laboratory and pilot tests, designing and retooling equipment, conducting verification tests, and finally implementing a substitution. The semiconductor industry recognizes the need for and is undertaking additional R&D to: • Characterize the human health and environmental risks associated with PFAS-containing materials used in the industry. • Develop analytical methods to characterize PFAS-containing materials. • Evaluate PFAS releases to air and/or water. • Identify, test and implement substitutes to either eliminate PFAS-containing materials, or substitute PFAS-containing materials with those having lower human health or environmental risks. • Evaluate and test abatement technologies to capture or destroy PFAS-containing materials before their release to the environment. Based on the clkploqfrj„p cfkafkdp ^ka ^p al`rjbkqba fk b^`e lc qeb ^``ljm^kvfkd tefqb m^mbop- rkqfi the industry can identify, test and qualify suitable substitutes, PFAS-containing materials are essential to semiconductor manufacturing operations and equipment. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 34 182 • Characterize the human health and environmental risks associated with PFAS-containing materials used in the industry. • Develop analytical methods to characterize PFAS-containing materials. • Evaluate PFAS releases to air and/or water. • Identify, test and implement substitutes to either eliminate PFAS-containing materials, or substitute PFAS-containing materials with those having lower human health or environmental risks. • Evaluate and test abatement technologies to capture or destroy PFAS-containing materials before their release to the environment. Based on the clkploqfrj„p cfkafkdp ^ka ^p al`rjbkqba fk b^`e lc qeb ^``ljm^kvfkd tefqb m^mbop- rkqfi the industry can identify, test and qualify suitable substitutes, PFAS-containing materials are essential to semiconductor manufacturing operations and equipment. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 34 182 14.0 References Alam, Syed, Timothy Chu, Shrikant Lohokare, Shungo Saito, and McKinley Baker. 2020. Globality and Complexity of the Semiconductor Ecosystem. https://www.accenture.com/_acnmedia/PDF- 119/Accenture-Globality-Semiconductor-Industry.pdf. Bentel, Michael J, Yaochun Yu, Lihua Xu, Hyuna Kwon, Zhong Li, Bryan M Wong, Yujie Men, and Jinyong Liu. 2020. "Degradation of Perfluoroalkyl Ether Carboxylic Acids with Hydrated Electrons: Structure•Reactivity Relationships and Environmental Implications." Environmental Science and Technology 2489-2499. Beu, L. 2019. 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Park, J. Cheng, B.T. Mader, and M.R. Hoffman. 2008. "Kinetics and mechanism of the sonolytic conversion of the aqueous perfluorinated surfactants, perfluorooctanoate (PFOA), and perfluorooctane sulfonate (PFOS) into inorganic products. ." The Journal of Physical Chemistry A 4261-4270. Wang, J., Z. Lin, X. He, M. Song, P. Westerhoff, K. Doudrick, and D. Hanigan. 2022. "Critical Review of Thermal Decomposition of Per-and Polyfluoroalkyl Substances: Mechanisms and Implications for Thermal Treatment Processes." Environmental Science and Technology 5355-5370. Watkins, Edward K., and William L. Jorgenson. 2001. ") Perfluoroalkanes: Conformational Analysis and Liquid-State Properties from AB Initio and Monte Carlo Calculations." Journal of Physical Chemistry A 4118-4125. Wiggers, Kyle. 2022. Apple unveils the A16 Bionic, its most powerful mobile chip yet. https://techcrunch.com/2022/09/07/apple-unveils-new-mobile-chips-including-the-a16-bionic/. World Economic Forum. 2019. https://www.weforum.org/agenda/2019/01/why-digitalization-is-the-key-to- exponential-climate-action/. WSC, World Semiconductor Council. 1999-2014. http://www.semiconductorcouncil.org/issuesactivities/environment-safety-and-health/. US EPA, United States Environmental Protection Agency. 2021. PFAS Strategic Roadmap: EPA's Commitment to Action 2021-2024. US EPA. Vecitis, C.D., H. Park, J. Cheng, B.T. Mader, and M.R. Hoffman. 2008. "Kinetics and mechanism of the sonolytic conversion of the aqueous perfluorinated surfactants, perfluorooctanoate (PFOA), and perfluorooctane sulfonate (PFOS) into inorganic products. ." The Journal of Physical Chemistry A 4261-4270. Wang, J., Z. Lin, X. He, M. Song, P. Westerhoff, K. Doudrick, and D. Hanigan. 2022. "Critical Review of Thermal Decomposition of Per-and Polyfluoroalkyl Substances: Mechanisms and Implications for Thermal Treatment Processes." Environmental Science and Technology 5355-5370. Watkins, Edward K., and William L. Jorgenson. 2001. ") Perfluoroalkanes: Conformational Analysis and Liquid-State Properties from AB Initio and Monte Carlo Calculations." Journal of Physical Chemistry A 4118-4125. Wiggers, Kyle. 2022. Apple unveils the A16 Bionic, its most powerful mobile chip yet. https://techcrunch.com/2022/09/07/apple-unveils-new-mobile-chips-including-the-a16-bionic/. World Economic Forum. 2019. https://www.weforum.org/agenda/2019/01/why-digitalization-is-the-key-to- exponential-climate-action/. WSC, World Semiconductor Council. 1999-2014. http://www.semiconductorcouncil.org/issuesactivities/environment-safety-and-health/. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 39 187 Appendix A: Glossary of Acronyms and Terms Terms Definition 3D three dimensional 5G/6G Fifth- and sixth-generation cellular technology for wireless internet connections and communications. ABT manufacturing equipment abatement ACGIH American Conference of Governmental Industrial Hygienists AI artificial intelligence AIX anion exchange ALD atomic layer deposition Aluminum etch An aqueous mixture that includes phosphoric acid, nitric acid and acetic acid. AMHS automated material handling system ANSI American National Standards Institute Anti-EBO anti-epoxy bleedout Antireflective coatings Top- or bottom-surface coatings used to reduce light reflection at surface interfaces to better control line width in photolithography. APM A mixture of ammonium hydroxide (28 wt %), hydrogen peroxide (30 wt %) and water, also known as SC1. Aqueous-based A mixture in which water is the solvent. ARC anti-reflective coating ArF argon fluoride Article(s) An object or objects made from one or more substances and mixtures given a special shape, surface or design during production that determines its function to a greater degree than its chemical composition, whether on its own or in an assembly with other articles, substances and mixtures. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 39 187 Appendix A: Glossary of Acronyms and Terms Terms Definition 3D three dimensional 5G/6G Fifth- and sixth-generation cellular technology for wireless internet connections and communications. ABT manufacturing equipment abatement ACGIH American Conference of Governmental Industrial Hygienists AI artificial intelligence AIX anion exchange ALD atomic layer deposition Aluminum etch An aqueous mixture that includes phosphoric acid, nitric acid and acetic acid. AMHS automated material handling system ANSI American National Standards Institute Anti-EBO anti-epoxy bleedout Antireflective coatings Top- or bottom-surface coatings used to reduce light reflection at surface interfaces to better control line width in photolithography. APM A mixture of ammonium hydroxide (28 wt %), hydrogen peroxide (30 wt %) and water, also known as SC1. Aqueous-based A mixture in which water is the solvent. ARC anti-reflective coating ArF argon fluoride Article(s) An object or objects made from one or more substances and mixtures given a special shape, surface or design during production that determines its function to a greater degree than its chemical composition, whether on its own or in an assembly with other articles, substances and mixtures. Also, materials used in the construction of semiconductor processing equipment, support equipment, facilities equipment, and other purchased or produced items containing PFAS. Assembly, test and The processing steps necessary to test and attach individual semiconductor packaging devices into chip packages that can then be used in electronic devices. ASTM American Society for Testing and Materials ATP assembly, test and packaging ATPS assembly, test, packaging and substrate AWN acid waste neutralization Back end of line Processing to create the interconnect wiring for a device. BARC bottom anti-reflective coating Barrier layers Film between the silicide and metallization layers in an interconnect. BCD bulk chemical delivery BEOL back end of line Bespoke parts Parts or articles that are made to order or custom fabricated. BGA ball grid array Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 40 188 Also, materials used in the construction of semiconductor processing equipment, support equipment, facilities equipment, and other purchased or produced items containing PFAS. Assembly, test and The processing steps necessary to test and attach individual semiconductor packaging devices into chip packages that can then be used in electronic devices. ASTM American Society for Testing and Materials ATP assembly, test and packaging ATPS assembly, test, packaging and substrate AWN acid waste neutralization Back end of line Processing to create the interconnect wiring for a device. BARC bottom anti-reflective coating Barrier layers Film between the silicide and metallization layers in an interconnect. BCD bulk chemical delivery BEOL back end of line Bespoke parts Parts or articles that are made to order or custom fabricated. BGA ball grid array Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 40 188 Terms Definition BHF buffered hydrofluoric acid etch Bioaccumulation A gradual accumulation of substances or chemicals in an organism. BMS/QA business management system/quality assurance BOE buffered oxide etch BOM bill of materials BP boiling point Buffered oxide etch An aqueous mixture of hydrofluoric acid and ammonium fluoride. C4 Perfluorinated and polyfluorinated alkyl substances with a chain length of four carbons. C4 can sometimes refer to controlled collapse chip connect, the steps in semiconductor manufacturing between front-end fab manufacturing and assembly test and packaging steps. CAGR compound annual growth rate CARs chemically amplified resists CBI confidential business information C-C backbone All organic compounds are made up of carbon-carbon bonds, creating a carbon skeleton or backbone in the compounds. CD-SEM critical dimension-scanning electron microscope C-F bond carbon-fluorine bond CFCs chlorofluorocarbons Chalcogen Any element in group 16 of the periodic table such as oxygen, polonium, sulfur, selenium or tellurium; the latter three are typical chalcogens in a dichalcogenide. Chamber clean A process in chemical vapor deposition that removes deposition residues from chamber walls and other interior surfaces. Chemical mechanical Abrasive and corrosive chemical slurry (commonly a colloid) used to remove planarization slurries material and even out irregular topography, making the wafer flat or planar. Chemical mechanical A process that smooths and polishes the surface of a wafer to extreme levels of polishing precision, used during multiple steps of wafer manufacturing. Chemical vapor Microfabrication processes used to deposit thin films of materials in various deposition forms, including monocrystalline, polycrystalline, amorphous and epitaxial. Chip The common name for an integrated circuit. Clean room An engineered space that maintains a very low concentration of airborne particulates. CMC critical micellar concentration CMP chemical-mechanical planarization CMR carcinogenic, mutagenic and toxic for reproduction substances CNT carbon nanotube C-O Bond carbon-oxygen bond Coax The abbreviated term for a coaxial cable. Component An identifiable part that a manufacturer of SMRE or facilities equipment has purchased to produce a more complex assembly. CTE coefficient of thermal expansion Terms Definition BHF buffered hydrofluoric acid etch Bioaccumulation A gradual accumulation of substances or chemicals in an organism. BMS/QA business management system/quality assurance BOE buffered oxide etch BOM bill of materials BP boiling point Buffered oxide etch An aqueous mixture of hydrofluoric acid and ammonium fluoride. C4 Perfluorinated and polyfluorinated alkyl substances with a chain length of four carbons. C4 can sometimes refer to controlled collapse chip connect, the steps in semiconductor manufacturing between front-end fab manufacturing and assembly test and packaging steps. CAGR compound annual growth rate CARs chemically amplified resists CBI confidential business information C-C backbone All organic compounds are made up of carbon-carbon bonds, creating a carbon skeleton or backbone in the compounds. CD-SEM critical dimension-scanning electron microscope C-F bond carbon-fluorine bond CFCs chlorofluorocarbons Chalcogen Any element in group 16 of the periodic table such as oxygen, polonium, sulfur, selenium or tellurium; the latter three are typical chalcogens in a dichalcogenide. Chamber clean A process in chemical vapor deposition that removes deposition residues from chamber walls and other interior surfaces. Chemical mechanical Abrasive and corrosive chemical slurry (commonly a colloid) used to remove planarization slurries material and even out irregular topography, making the wafer flat or planar. Chemical mechanical A process that smooths and polishes the surface of a wafer to extreme levels of polishing precision, used during multiple steps of wafer manufacturing. Chemical vapor Microfabrication processes used to deposit thin films of materials in various deposition forms, including monocrystalline, polycrystalline, amorphous and epitaxial. Chip The common name for an integrated circuit. Clean room An engineered space that maintains a very low concentration of airborne particulates. CMC critical micellar concentration CMP chemical-mechanical planarization CMR carcinogenic, mutagenic and toxic for reproduction substances CNT carbon nanotube C-O Bond carbon-oxygen bond Coax The abbreviated term for a coaxial cable. Component An identifiable part that a manufacturer of SMRE or facilities equipment has purchased to produce a more complex assembly. CTE coefficient of thermal expansion Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 41 189 Terms Definition CVD chemical vapor deposition CZ The Czochralski crystal growth process (for making silicon ingot that silicon wafers are then cut from). D4, D5, D6 ring Cyclosiloxanes containing four, five and six silicon atoms in the ring, respectively. Deep ultraviolet The wavelength of light (249 nm and 193 nm) used to produce fine features on semiconductor devices. Dense feature bias A critical dimension swing resulting from a shifted resist depth of focus caused by a change in thickness of a lithography film stack as it coats over various pitches, critical dimensions and aspect ratios of substrate topography. DEP deposition equipment Deposition A semiconductor manufacturing step where thin films of materials are added in various forms to the surface of a wafer. DETCH dry etch equipment Device An electronic component that relies on the electronic properties of a semiconductor material (primarily silicon, germanium and gallium arsenide, as well as organic semiconductors) for its function. Dichalcogenides Any chalcogenide (a compound that contains a chalcogen and a more electropositive element) that contains two chalcogen atoms per molecule. Die A single instance of a particular end device produced simultaneously on a wafer; a wafer comprises hundreds of die, and a single die may contain millions of integrated circuits. Die-attach adhesives Adhesive used to mount or bond die to a support structure using an epoxy- based adhesive. Die overcoat Protective polymer coating applied to a bare die surface for small form packages. Die passivation The application of a PFAS anti-stiction material as a microcoating of micro- electromechanical system structures so that they become passive (less readily affected by the environment, while also reducing the surface work of adhesion to improve the surface energy properties necessary for actuation). Dilute HF(DHF) An aqueous mixture containing 0.1% to 0.5% hydrofluoric acid in water. Drop-in replacement An alternative substance that that performs in a functionally equivalent way and does not require the modification of existing manufacturing equipment. Dry etch The removal of a masked pattern of semiconductor material by exposing the material to a bombardment of ions (usually a plasma of reactive gases such as fluorocarbons or oxygen). Dry vacuum pump A vacuum pump system that does not use a liquid sealing system, and is oil- system and water-free. DSC die-side components DUV deep ultraviolet E-beam Electron-beam processing, also called electron irradiation. EBI electron irradiation EC European Commission ECD electrochemical deposition ECHA European Chemicals Agency Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 41 189 Terms Definition CVD chemical vapor deposition CZ The Czochralski crystal growth process (for making silicon ingot that silicon wafers are then cut from). D4, D5, D6 ring Cyclosiloxanes containing four, five and six silicon atoms in the ring, respectively. Deep ultraviolet The wavelength of light (249 nm and 193 nm) used to produce fine features on semiconductor devices. Dense feature bias A critical dimension swing resulting from a shifted resist depth of focus caused by a change in thickness of a lithography film stack as it coats over various pitches, critical dimensions and aspect ratios of substrate topography. DEP deposition equipment Deposition A semiconductor manufacturing step where thin films of materials are added in various forms to the surface of a wafer. DETCH dry etch equipment Device An electronic component that relies on the electronic properties of a semiconductor material (primarily silicon, germanium and gallium arsenide, as well as organic semiconductors) for its function. Dichalcogenides Any chalcogenide (a compound that contains a chalcogen and a more electropositive element) that contains two chalcogen atoms per molecule. Die A single instance of a particular end device produced simultaneously on a wafer; a wafer comprises hundreds of die, and a single die may contain millions of integrated circuits. Die-attach adhesives Adhesive used to mount or bond die to a support structure using an epoxy- based adhesive. Die overcoat Protective polymer coating applied to a bare die surface for small form packages. Die passivation The application of a PFAS anti-stiction material as a microcoating of micro- electromechanical system structures so that they become passive (less readily affected by the environment, while also reducing the surface work of adhesion to improve the surface energy properties necessary for actuation). Dilute HF(DHF) An aqueous mixture containing 0.1% to 0.5% hydrofluoric acid in water. Drop-in replacement An alternative substance that that performs in a functionally equivalent way and does not require the modification of existing manufacturing equipment. Dry etch The removal of a masked pattern of semiconductor material by exposing the material to a bombardment of ions (usually a plasma of reactive gases such as fluorocarbons or oxygen). Dry vacuum pump A vacuum pump system that does not use a liquid sealing system, and is oil- system and water-free. DSC die-side components DUV deep ultraviolet E-beam Electron-beam processing, also called electron irradiation. EBI electron irradiation EC European Commission ECD electrochemical deposition ECHA European Chemicals Agency Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 42 190 Terms Definition ECTFE ethylene chlorotrifluoroethylene EEA European Economic Area EEE electrical and electronic equipment EFEM equipment front-end modules EHS environmental, health and safety Electronegativity The tendency of an atom such as fluorine to attract electrons in a molecule. Electronic mold Cured resin used to protect semiconductor components from moisture and compounds mechanical damage, and to serve as a mechanical structure. Embedded barrier layers A component of top-coat-free photoresists used for immersion lithography that (photolithography) contains an oligomeric or low-molecular-weight PFAS. Encapsulant A processing step in which a semiconductor chip is encased with a certain material to protect it from the external environment. Environmental fate and How chemicals released to the environment move in response to wind, rain transport and human activities. EoL end of life EPDM ethylene propylene diene monomer Equipment See SMRE. ESIA European Semiconductor Industry Association Etching The removal of unnecessary materials from a wafer„p surface during the photolithography process so that only the design pattern remains. ETFE ethylene tetrafluoroethylene EU European Union EUV extreme ultraviolet Extreme ultraviolet The wavelength of light (13.5 nm) used to pattern the finest features required on foundation layers of advanced semiconductor devices. Exposure latitude The extent to which a light-sensitive material can be under- or overexposed and still achieve an acceptable result. Fab The abbreviated term for fabrication plant or fabricator, where semiconductors are manufactured on wafers (typically silicon wafers). Facilities infrastructure Systems within a factory that support manufacturing operations; for example, the storage, supply and disposal of gaseous and liquid chemicals, ultrapure water production, and exhaust abatement. Far back end of the line Processing that occurs after the fabrication of a semiconductor device in preparation for subsequent packaging. FBEOL far back end of the line FC flip chip FCBGA flip-chip ball grid array FCCSP flip-chip chip-scale package FCLGA flip-chip land grid array FEOL front end of line FEP fluorinated ethylene propylene FFU HEPA fan filter unit high-efficiency particulate air Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 42 190 Terms Definition ECTFE ethylene chlorotrifluoroethylene EEA European Economic Area EEE electrical and electronic equipment EFEM equipment front-end modules EHS environmental, health and safety Electronegativity The tendency of an atom such as fluorine to attract electrons in a molecule. Electronic mold Cured resin used to protect semiconductor components from moisture and compounds mechanical damage, and to serve as a mechanical structure. Embedded barrier layers A component of top-coat-free photoresists used for immersion lithography that (photolithography) contains an oligomeric or low-molecular-weight PFAS. Encapsulant A processing step in which a semiconductor chip is encased with a certain material to protect it from the external environment. Environmental fate and How chemicals released to the environment move in response to wind, rain transport and human activities. EoL end of life EPDM ethylene propylene diene monomer Equipment See SMRE. ESIA European Semiconductor Industry Association Etching The removal of unnecessary materials from a wafer„p surface during the photolithography process so that only the design pattern remains. ETFE ethylene tetrafluoroethylene EU European Union EUV extreme ultraviolet Extreme ultraviolet The wavelength of light (13.5 nm) used to pattern the finest features required on foundation layers of advanced semiconductor devices. Exposure latitude The extent to which a light-sensitive material can be under- or overexposed and still achieve an acceptable result. Fab The abbreviated term for fabrication plant or fabricator, where semiconductors are manufactured on wafers (typically silicon wafers). Facilities infrastructure Systems within a factory that support manufacturing operations; for example, the storage, supply and disposal of gaseous and liquid chemicals, ultrapure water production, and exhaust abatement. Far back end of the line Processing that occurs after the fabrication of a semiconductor device in preparation for subsequent packaging. FBEOL far back end of the line FC flip chip FCBGA flip-chip ball grid array FCCSP flip-chip chip-scale package FCLGA flip-chip land grid array FEOL front end of line FEP fluorinated ethylene propylene FFU HEPA fan filter unit high-efficiency particulate air Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 43 191 Terms Definition F-gas Fluorinated gases, particularly those that are perfluorocarbons and hydrofluorocarbons and may be considered PFAS-containing materials. F-HTF fluorinated heat transfer fluid Final resolution The smallest mask feature size that a photoresist can pattern. FinFET A multigate metal-oxide semiconductor field-effect transistor. FKM The American Society of Testing and Materials„ name for fluoroelastomers or fluoro rubber material. Fluorine A chemical element with the chemical symbol F and atomic number 9. Fluorine gas/F2 A diatomic gas consisting of two fluorine atoms covalently bonded. FFKM The American Society of Testing and Materials„ name for perfluoro elastomers or perfluoro rubber material, which typically contains higher levels of fluorinated materials compared to FKM. Fluoroelastomer Fluorocarbon-based synthetic rubbers; part of the fluoropolymers family. Fluoropolymer A distinct subset of fluorinated high-molecular weight polymers with fluorine atoms directly attached to their carbon-only backbone. FM Factory Mutual Focus window A range of focus values for which a photoresist simultaneously meets linewidth, wall angle, absence of residues and top retention criteria. FOSB front opening shipping box FPD flat panel display Front end of line The steps of semiconductor fabrication, from a blank wafer to a completed wafer that has not yet been separated into individual chips. FOUP front opening unified pods f-TTF fluorinated-tetrathiafulvalene GAC granular activated carbon GaN gallium nitride Gas cluster ion beam A technology for nano-scale modification of surfaces. The process can smooth a wide variety of surface material types to within an angstrom of roughness without subsurface damage, and is also used to chemically alter surfaces through infusion or deposition. Gasket Flat, circular seals (often manufactured with flexible materials, but sometimes designed with harder materials) that sit between two flat surfaces designed to prevent leakage. GDP gross domestic product GHG greenhouse gas GHS globally harmonized system GWP global warming potential H2O water H2O2 hydrogen peroxide H2SO4 sulfuric acid H3PO4 phosphoric acid HAR high aspect ratio Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 43 191 Terms Definition F-gas Fluorinated gases, particularly those that are perfluorocarbons and hydrofluorocarbons and may be considered PFAS-containing materials. F-HTF fluorinated heat transfer fluid Final resolution The smallest mask feature size that a photoresist can pattern. FinFET A multigate metal-oxide semiconductor field-effect transistor. FKM The American Society of Testing and Materials„ name for fluoroelastomers or fluoro rubber material. Fluorine A chemical element with the chemical symbol F and atomic number 9. Fluorine gas/F2 A diatomic gas consisting of two fluorine atoms covalently bonded. FFKM The American Society of Testing and Materials„ name for perfluoro elastomers or perfluoro rubber material, which typically contains higher levels of fluorinated materials compared to FKM. Fluoroelastomer Fluorocarbon-based synthetic rubbers; part of the fluoropolymers family. Fluoropolymer A distinct subset of fluorinated high-molecular weight polymers with fluorine atoms directly attached to their carbon-only backbone. FM Factory Mutual Focus window A range of focus values for which a photoresist simultaneously meets linewidth, wall angle, absence of residues and top retention criteria. FOSB front opening shipping box FPD flat panel display Front end of line The steps of semiconductor fabrication, from a blank wafer to a completed wafer that has not yet been separated into individual chips. FOUP front opening unified pods f-TTF fluorinated-tetrathiafulvalene GAC granular activated carbon GaN gallium nitride Gas cluster ion beam A technology for nano-scale modification of surfaces. The process can smooth a wide variety of surface material types to within an angstrom of roughness without subsurface damage, and is also used to chemically alter surfaces through infusion or deposition. Gasket Flat, circular seals (often manufactured with flexible materials, but sometimes designed with harder materials) that sit between two flat surfaces designed to prevent leakage. GDP gross domestic product GHG greenhouse gas GHS globally harmonized system GWP global warming potential H2O water H2O2 hydrogen peroxide H2SO4 sulfuric acid H3PO4 phosphoric acid HAR high aspect ratio Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 44 192 Terms Definition HCl hydrochloric acid HDI high-density interconnect HDPE high-density polyethylene HEPA high-efficiency particulate air HF hydrofluoric acid or hydrogen fluoride gas HFC hydrofluorocarbon HFFR halogen-free flame retardants HFPO-DA hexafluoropropylene oxide-dimer acid High aspect ratio Very tall and narrow device features such as dynamic random access memory capacitor cells; the higher the aspect ratio of a feature, the more challenging it is to create. HNBR hydrogenated nitrile butadiene rubber HNO3 nitric acid HPDE high-density polyethylene HPM A mixture of hydrochloric acid and hydrogen peroxide, also known as SC2. HTF heat transfer fluid HUPW high ultra-pure water HV high voltage HVM high-volume manufacturing IC integrated circuit IEEE Institute of Electrical and Electronics Engineers IH industrial hygiene IHS integrated heat spreader IMEC Interuniversity Microelectronics Centre Immersion topcoat A thin film, containing PFAS, applied over the photoresist to prevent the leaching of resist components into the water of the immersion tool, and likewise, to prevent water from permeating into the resist. IMP implant equipment Implantation A low-temperature process by which the ions of one element are accelerated into a solid target, thereby changing the physical, chemical or electrical properties of the target. Integrated circuit Also known as a chip, microchip or semiconductor device; a set of electronic circuits on one small flat piece of semiconductor material, usually silicon, with large numbers of integrated, miniaturized transistors and other electronic components. Ion implantation A low-temperature process in which a beam of ions is created from a source material and implanted (or injected) into the surface of a patterned wafer substrate. IP intellectual property IPA isopropyl alcohol IRDS International Roadmap for Devices and Systems Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 44 192 Terms Definition HCl hydrochloric acid HDI high-density interconnect HDPE high-density polyethylene HEPA high-efficiency particulate air HF hydrofluoric acid or hydrogen fluoride gas HFC hydrofluorocarbon HFFR halogen-free flame retardants HFPO-DA hexafluoropropylene oxide-dimer acid High aspect ratio Very tall and narrow device features such as dynamic random access memory capacitor cells; the higher the aspect ratio of a feature, the more challenging it is to create. HNBR hydrogenated nitrile butadiene rubber HNO3 nitric acid HPDE high-density polyethylene HPM A mixture of hydrochloric acid and hydrogen peroxide, also known as SC2. HTF heat transfer fluid HUPW high ultra-pure water HV high voltage HVM high-volume manufacturing IC integrated circuit IEEE Institute of Electrical and Electronics Engineers IH industrial hygiene IHS integrated heat spreader IMEC Interuniversity Microelectronics Centre Immersion topcoat A thin film, containing PFAS, applied over the photoresist to prevent the leaching of resist components into the water of the immersion tool, and likewise, to prevent water from permeating into the resist. IMP implant equipment Implantation A low-temperature process by which the ions of one element are accelerated into a solid target, thereby changing the physical, chemical or electrical properties of the target. Integrated circuit Also known as a chip, microchip or semiconductor device; a set of electronic circuits on one small flat piece of semiconductor material, usually silicon, with large numbers of integrated, miniaturized transistors and other electronic components. Ion implantation A low-temperature process in which a beam of ions is created from a source material and implanted (or injected) into the surface of a patterned wafer substrate. IP intellectual property IPA isopropyl alcohol IRDS International Roadmap for Devices and Systems Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 45 193 Terms Definition ISO International Organization for Standardization ITRI Industrial Technology Research Institute ITRS International Technology Roadmap for Semiconductors KOH potassium hydroxide KrF krypton fluoride LAN local area network Land-side components The bottom side of a controlled collapse chip connection (C4) package, on which the package is mounted to a printed circuit board. Laser release layers A thermoset polymer-based layer that enables the stress-free debonding of glass-carrier wafers using ultraviolet laser irradiation. LGA land-grid array LITH lithography equipment Lithography/litho Abbreviated terms for photolithography. L-PFC liquid perfluorocarbon LSC land-side components MAC multiple-alkylated cyclopentane Mask/mask set See photomask. MEMS micro-electromechanical systems MET metrology equipment Metrology Measuring the various dimensions or physical or chemical characteristics of a semiconductor integrated circuit on a wafer. Micro-electromechanical The technology of microscopic devices incorporating both electronic and system devices moving parts. Micron A unit of length equal to one-millionth of a meter. Mold releases Materials applied to molds (for example, of plastic parts) to create a nonstick barrier. Mold release sprays An aerosol that forms a layer or barrier between the mold and casting agent that facilitates demolding. Moore„s law Gloalk Mllob„p mofk`fmib qe^q qhe number of transistors incorporated in a chip will approximately double every 24 months. MTBC mean time between cleans MW molecular weight NAND A type of flash memory that is nonvolatile, and does not require any power to keep data in it. Nanometer A unit of length equal to one-billionth (short scale) of a meter. NaOH sodium hydroxide NBR nitrile butadiene rubber NEC National Electrical Code NF nanofiltration NH4OH ammonium hydroxide NIOSH National Institute for Occupational Safety and Health Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 45 193 Terms Definition ISO International Organization for Standardization ITRI Industrial Technology Research Institute ITRS International Technology Roadmap for Semiconductors KOH potassium hydroxide KrF krypton fluoride LAN local area network Land-side components The bottom side of a controlled collapse chip connection (C4) package, on which the package is mounted to a printed circuit board. Laser release layers A thermoset polymer-based layer that enables the stress-free debonding of glass-carrier wafers using ultraviolet laser irradiation. LGA land-grid array LITH lithography equipment Lithography/litho Abbreviated terms for photolithography. L-PFC liquid perfluorocarbon LSC land-side components MAC multiple-alkylated cyclopentane Mask/mask set See photomask. MEMS micro-electromechanical systems MET metrology equipment Metrology Measuring the various dimensions or physical or chemical characteristics of a semiconductor integrated circuit on a wafer. Micro-electromechanical The technology of microscopic devices incorporating both electronic and system devices moving parts. Micron A unit of length equal to one-millionth of a meter. Mold releases Materials applied to molds (for example, of plastic parts) to create a nonstick barrier. Mold release sprays An aerosol that forms a layer or barrier between the mold and casting agent that facilitates demolding. Moore„s law Gloalk Mllob„p mofk`fmib qe^q qhe number of transistors incorporated in a chip will approximately double every 24 months. MTBC mean time between cleans MW molecular weight NAND A type of flash memory that is nonvolatile, and does not require any power to keep data in it. Nanometer A unit of length equal to one-billionth (short scale) of a meter. NaOH sodium hydroxide NBR nitrile butadiene rubber NEC National Electrical Code NF nanofiltration NH4OH ammonium hydroxide NIOSH National Institute for Occupational Safety and Health Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 46 194 Terms Definition nm nanometer Node Each new generation process designated by its minimum feature size in nanometers or its transistor gate length. NTRS National Technology Roadmap for Semiconductors O2 oxygen O3 ozone OECD Organization for Economic Co-Operation and Development OEM original equipment manufacturer OEL occupational exposure limit Oleophobic A substance that repels oil or organics. Optical proximity A photolithography enhancement technique used to compensate for image correction distortion caused by light diffraction or process effects. Organic-based Chemicals or formulations where the principle constituents are carbon- containing molecules. O-ring A donut-shaped gasket that helps seal joins between separate parts and prevents the leakage of fluids and gases. Outgassing The release of a gas that was dissolved, trapped, frozen or absorbed in a material. Package Metal, plastic, glass or ceramic casing containing one or more discrete semiconductor devices or integrated circuits. PAGs photoacid generators PAO polyalphaolfins PAS polyalkyl substances PBGA plastic ball grid array PBT persistent bioaccumulative toxins PBZ personal breathing zone PC personal computer PCB printed circuit board PCD planar chemical delivery PCTFE polychlorotrifluoroethylene PDMS polydimethylsiloxane fluids PE polyethylene PECVD plasma-enhanced chemical vapor deposition PEEK polyether ether ketone Pellicle A thin, transparent membrane used to prevent the deposition of unwanted particles on a photomask. Perfluorocarbon gases Gases used in plasma etching, gas deposition and chamber cleaning. PERR post-etch residue remover PFA perfluoroalkoxy copolymer PFA-CF perfluoroalkoxy-carbon fiber-reinforced composite PFAS perfluoroalkyl and polyfluoroalkyl substances Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 46 194 Terms Definition nm nanometer Node Each new generation process designated by its minimum feature size in nanometers or its transistor gate length. NTRS National Technology Roadmap for Semiconductors O2 oxygen O3 ozone OECD Organization for Economic Co-Operation and Development OEM original equipment manufacturer OEL occupational exposure limit Oleophobic A substance that repels oil or organics. Optical proximity A photolithography enhancement technique used to compensate for image correction distortion caused by light diffraction or process effects. Organic-based Chemicals or formulations where the principle constituents are carbon- containing molecules. O-ring A donut-shaped gasket that helps seal joins between separate parts and prevents the leakage of fluids and gases. Outgassing The release of a gas that was dissolved, trapped, frozen or absorbed in a material. Package Metal, plastic, glass or ceramic casing containing one or more discrete semiconductor devices or integrated circuits. PAGs photoacid generators PAO polyalphaolfins PAS polyalkyl substances PBGA plastic ball grid array PBT persistent bioaccumulative toxins PBZ personal breathing zone PC personal computer PCB printed circuit board PCD planar chemical delivery PCTFE polychlorotrifluoroethylene PDMS polydimethylsiloxane fluids PE polyethylene PECVD plasma-enhanced chemical vapor deposition PEEK polyether ether ketone Pellicle A thin, transparent membrane used to prevent the deposition of unwanted particles on a photomask. Perfluorocarbon gases Gases used in plasma etching, gas deposition and chamber cleaning. PERR post-etch residue remover PFA perfluoroalkoxy copolymer PFA-CF perfluoroalkoxy-carbon fiber-reinforced composite PFAS perfluoroalkyl and polyfluoroalkyl substances Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 47 195 Terms Definition PFC perfluorocarbons PFEPE polyfluoroethyl propyl ether PFOA perfluorooctanoic acid PFOS perfluorooctane sulfonic acid PFPE perfluoropolyether PFSA perfluorosulfonic acid PGA pin grid array Photoacid generator Molecules that generate a strong acid upon the absorption of light used in chemically amplified resists. Photolithography Techniques that use light to produce minutely patterned thin films of suitable materials over a substrate, such as a silicon wafer, to protect selected areas of it during subsequent etching, deposition or implantation operations. Typically, ultraviolet light is used to transfer a geometric design from an optical mask to a light-sensitive chemical (a photoresist) coated on the substrate. The photoresist either breaks down or hardens where it is exposed to light. Removing the softer parts of the coating with appropriate solvents then creates the patterned film. Photomask A glass substrate with a pattern of transparent and opaque regions used to selectively expose the photoresist used in the photolithography process. Photoresists A light-sensitive material used in photolithography to form a patterned coating on a surface. Pin grid array A means of connecting a semiconductor package to a circuit board using metal pins. Piranha etch A mixture of sulfuric acid and hydrogen peroxide used to clean organic residues off of substrates. Plasma cleaning The use of a plasma gas to remove particles, residues and films from a wafer surface before or after adjacent processes. Plasma dry etch The removal of a masked pattern of semiconductor material by exposing the material to a bombardment of ions (usually a plasma of reactive gases such as fluorocarbons or oxygen). Polymer A substance or material consisting of very large molecules called macromolecules, composed of many repeating subunits. POU point-of-use abatement PP polypropylene ppb parts per billion PPE personal protective equipment ppm parts per million ppt parts per trillion Pre-clean See season. PTFE polytetrafluoroethylene Pulse dampeners A device in a pumping system that reduces pulsation during a pump cycle. Pump fluids and Chemicals that prevent the generation of particles and offgassing (in a lubricants vacuum), while ensuring the smooth and precise functionality of fabrication and processing equipment. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 47 195 Terms Definition PFC perfluorocarbons PFEPE polyfluoroethyl propyl ether PFOA perfluorooctanoic acid PFOS perfluorooctane sulfonic acid PFPE perfluoropolyether PFSA perfluorosulfonic acid PGA pin grid array Photoacid generator Molecules that generate a strong acid upon the absorption of light used in chemically amplified resists. Photolithography Techniques that use light to produce minutely patterned thin films of suitable materials over a substrate, such as a silicon wafer, to protect selected areas of it during subsequent etching, deposition or implantation operations. Typically, ultraviolet light is used to transfer a geometric design from an optical mask to a light-sensitive chemical (a photoresist) coated on the substrate. The photoresist either breaks down or hardens where it is exposed to light. Removing the softer parts of the coating with appropriate solvents then creates the patterned film. Photomask A glass substrate with a pattern of transparent and opaque regions used to selectively expose the photoresist used in the photolithography process. Photoresists A light-sensitive material used in photolithography to form a patterned coating on a surface. Pin grid array A means of connecting a semiconductor package to a circuit board using metal pins. Piranha etch A mixture of sulfuric acid and hydrogen peroxide used to clean organic residues off of substrates. Plasma cleaning The use of a plasma gas to remove particles, residues and films from a wafer surface before or after adjacent processes. Plasma dry etch The removal of a masked pattern of semiconductor material by exposing the material to a bombardment of ions (usually a plasma of reactive gases such as fluorocarbons or oxygen). Polymer A substance or material consisting of very large molecules called macromolecules, composed of many repeating subunits. POU point-of-use abatement PP polypropylene ppb parts per billion PPE personal protective equipment ppm parts per million ppt parts per trillion Pre-clean See season. PTFE polytetrafluoroethylene Pulse dampeners A device in a pumping system that reduces pulsation during a pump cycle. Pump fluids and Chemicals that prevent the generation of particles and offgassing (in a lubricants vacuum), while ensuring the smooth and precise functionality of fabrication and processing equipment. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 48 196 Terms Definition PVC polyvinylchloride PVD physical vapor deposition PVDF polyvinylidene fluoride QFN quad-flat no-lead package QFP quad-flat pack R&D research and development REACH Registration, Evaluation, Authorization and Restriction of Chemicals Registration, Evaluation, European Union Regulation 1907/2006. Authorization and Restriction of Chemicals RF radio frequency RFO restrictive flow orifice RO reverse osmosis Standard Clean 1/SC1 A mixture of ammonium hydroxide (28 wt %), hydrogen peroxide (30 wt %) and water, also known as APM. Standard Clean 2/SC2 A mixture of hydrochloric acid and hydrogen peroxide, also known as HPM. SDS safety data sheet Season A step in dry-etch processing that conditions the tool chamber with plasma gases to reduce chamber wall contamination or defects to production wafers. SEM scanning electron microscope SEMI Semiconductor Equipment and Materials International Semiconductor A global industry trade association for the semiconductor and electronics Equipment and Materials supply chain. International SFE semiconductor facility equipment Si3N4 silicon nitride SIA Semiconductor Industry Association SiARC silicon anti-reflective coating SiC silicon carbide Siloxanes A functional group in organosilicon chemistry with the Si-O-Si linkage. SiO2 silicon oxide SMD surface-mount device SMIF standard mechanical interface SMRE semiconductor manufacturing and related equipment SMT surface modification treatment SOIC small-outline integrated circuit SOP small-outline package Spin-on barriers Layers applied by spin casting that separate lithographic elements from each other; for example, spin-on topcoats in immersion lithography that separate photoresists and the immersion liquid. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 48 196 Terms Definition PVC polyvinylchloride PVD physical vapor deposition PVDF polyvinylidene fluoride QFN quad-flat no-lead package QFP quad-flat pack R&D research and development REACH Registration, Evaluation, Authorization and Restriction of Chemicals Registration, Evaluation, European Union Regulation 1907/2006. Authorization and Restriction of Chemicals RF radio frequency RFO restrictive flow orifice RO reverse osmosis Standard Clean 1/SC1 A mixture of ammonium hydroxide (28 wt %), hydrogen peroxide (30 wt %) and water, also known as APM. Standard Clean 2/SC2 A mixture of hydrochloric acid and hydrogen peroxide, also known as HPM. SDS safety data sheet Season A step in dry-etch processing that conditions the tool chamber with plasma gases to reduce chamber wall contamination or defects to production wafers. SEM scanning electron microscope SEMI Semiconductor Equipment and Materials International Semiconductor A global industry trade association for the semiconductor and electronics Equipment and Materials supply chain. International SFE semiconductor facility equipment Si3N4 silicon nitride SIA Semiconductor Industry Association SiARC silicon anti-reflective coating SiC silicon carbide Siloxanes A functional group in organosilicon chemistry with the Si-O-Si linkage. SiO2 silicon oxide SMD surface-mount device SMIF standard mechanical interface SMRE semiconductor manufacturing and related equipment SMT surface modification treatment SOIC small-outline integrated circuit SOP small-outline package Spin-on barriers Layers applied by spin casting that separate lithographic elements from each other; for example, spin-on topcoats in immersion lithography that separate photoresists and the immersion liquid. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 49 197 Terms Definition Spin-on low-K dielectrics A j^qbof^i tfqe ^ pj^ii obi^qfsb afbib`qof` `lkpq^kq )Ž- h^mm^* obi^qfsb ql pfif`lk dioxide that is deposited on the surface of a wafer spinning on a rotating vacuum chuck. Sputtering Microscopic particles of a solid material ejected from its surface after the material is itself bombarded by energetic particles of a plasma or gas. SRC Semiconductor Research Corp. SS stainless steel Substrate (packaging) Supporting material upon which or within which the elements of a semiconductor device are fabricated or attached. Surfactants Chemical compounds that decrease the surface tension or interfacial tension between two liquids, a liquid and a gas, or a liquid and a solid. SUS steel uses stainless SVHC substance of very high concern TAG thermal acid generator TARC top anti-reflective coating TCU temperature control unit/thermal control unit Temporary A process to offer temporary mechanical support for thin or to-be-thinned bonding/debonding wafers in the advanced packaging and heterogeneous assembly of semiconductors. TFE tetrafluoroethylene Thermal test method A variety of techniques in which a property of a sample is continuously measured as the sample is programmed through a pre-determined temperature profile. Thickener A formulation component that increases the viscosity of the formulation. TIM thermal interface materials TLV threshold limit values TMAH tetramethylammonium hydroxide TOC total organic carbon Tool Another term for SMRE, often used to describe semiconductor manufacturing and related equipment. Top retention A lack of film thickness from the photoresist top. Transistor A semiconductor device used to amplify or switch electrical signals and power. TSV through-silicon via TTF thermal test fluids UHP ultra-high purity ULPA ultra-low particulate air Underfills An electrically insulating adhesive used to provide a stronger mechanical connection, provide a heat bridge, or prevent solder joint stress caused by differential heating of the chip and the rest of the system. UPW ultra-pure water USA United States of America U.S. EPA United States Environmental Protection Agency Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 49 197 Terms Definition Spin-on low-K dielectrics A j^qbof^i tfqe ^ pj^ii obi^qfsb afbib`qof` `lkpq^kq )Ž- h^mm^* obi^qfsb ql pfif`lk dioxide that is deposited on the surface of a wafer spinning on a rotating vacuum chuck. Sputtering Microscopic particles of a solid material ejected from its surface after the material is itself bombarded by energetic particles of a plasma or gas. SRC Semiconductor Research Corp. SS stainless steel Substrate (packaging) Supporting material upon which or within which the elements of a semiconductor device are fabricated or attached. Surfactants Chemical compounds that decrease the surface tension or interfacial tension between two liquids, a liquid and a gas, or a liquid and a solid. SUS steel uses stainless SVHC substance of very high concern TAG thermal acid generator TARC top anti-reflective coating TCU temperature control unit/thermal control unit Temporary A process to offer temporary mechanical support for thin or to-be-thinned bonding/debonding wafers in the advanced packaging and heterogeneous assembly of semiconductors. TFE tetrafluoroethylene Thermal test method A variety of techniques in which a property of a sample is continuously measured as the sample is programmed through a pre-determined temperature profile. Thickener A formulation component that increases the viscosity of the formulation. TIM thermal interface materials TLV threshold limit values TMAH tetramethylammonium hydroxide TOC total organic carbon Tool Another term for SMRE, often used to describe semiconductor manufacturing and related equipment. Top retention A lack of film thickness from the photoresist top. Transistor A semiconductor device used to amplify or switch electrical signals and power. TSV through-silicon via TTF thermal test fluids UHP ultra-high purity ULPA ultra-low particulate air Underfills An electrically insulating adhesive used to provide a stronger mechanical connection, provide a heat bridge, or prevent solder joint stress caused by differential heating of the chip and the rest of the system. UPW ultra-pure water USA United States of America U.S. EPA United States Environmental Protection Agency Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 50 198 Terms Definition USD United States dollar UV ultraviolet VAC vacuum equipment Vacuum dry etching The removal a masked pattern of semiconductor material by exposing the material to a bombardment of ions (usually a plasma of reactive gases such as fluorocarbons). Vacuum pump system A pump and its associated appurtenances, such as tubing, piping and seals used to draw a vacuum. van der Waals radius A measure of the size of an atom that is not chemically (ionically or covalently) bound. VF2 vinylidene fluoride VMB valve manifold box VMQ vinyl methyl silicone VOC volatile organic compound vPvB very persistent very bioaccumulative VTM vacuum transfer module Wafer A thin, round slice of a semiconductor (usually crystalline silicon) used for the fabrication of integrated circuits. Wall angle The angle formed by a photoresist sidewall and a substrate. WCLN wet cleaning WEEE waste electrical and electronic equipment Wet chemistry Liquid substances used in processes such as wet etching, cleaning, chemical- mechanical planarization, surface modification treatments and other liquid applications in chip manufacturing. WETCH wet etch equipment WLP wafer-level packaging WSC World Semiconductor Council WSTS World Semiconductor Trade Statistics WTE waste to energy Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 50 198 Terms Definition USD United States dollar UV ultraviolet VAC vacuum equipment Vacuum dry etching The removal a masked pattern of semiconductor material by exposing the material to a bombardment of ions (usually a plasma of reactive gases such as fluorocarbons). Vacuum pump system A pump and its associated appurtenances, such as tubing, piping and seals used to draw a vacuum. van der Waals radius A measure of the size of an atom that is not chemically (ionically or covalently) bound. VF2 vinylidene fluoride VMB valve manifold box VMQ vinyl methyl silicone VOC volatile organic compound vPvB very persistent very bioaccumulative VTM vacuum transfer module Wafer A thin, round slice of a semiconductor (usually crystalline silicon) used for the fabrication of integrated circuits. Wall angle The angle formed by a photoresist sidewall and a substrate. WCLN wet cleaning WEEE waste electrical and electronic equipment Wet chemistry Liquid substances used in processes such as wet etching, cleaning, chemical- mechanical planarization, surface modification treatments and other liquid applications in chip manufacturing. WETCH wet etch equipment WLP wafer-level packaging WSC World Semiconductor Council WSTS World Semiconductor Trade Statistics WTE waste to energy Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 51 199 Appendix B: Semiconductor and Supply-Chain Complexity Semiconductor devices, also known as chips, are the foundation of all modern electronics. In 1965, Gordon Moore hypothesized a doubling every two years of components on an integrated circuit (see Figure B-1). As the number of transistors on devices has increased, the capability that they deliver has likewise increased, and the cost per transistor has decreased. Semiconductors are faster, smaller, less expensive, more energy efficient and more important than ever. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 51 199 Appendix B: Semiconductor and Supply-Chain Complexity Semiconductor devices, also known as chips, are the foundation of all modern electronics. In 1965, Gordon Moore hypothesized a doubling every two years of components on an integrated circuit (see Figure B-1). As the number of transistors on devices has increased, the capability that they deliver has likewise increased, and the cost per transistor has decreased. Semiconductors are faster, smaller, less expensive, more energy efficient and more important than ever. Figure B-1: Moore’s law – a semi-log plot of transistor counts for microprocessors against dates of introduction, nearly doubling every two years (Roser and Ritchie 2020). In 1972, the Intel 4004 microprocessor contained 2,250 transistors and was manufactured using critical dimensions (transistor gate width) on the order of 10 µm (or 10,000 nm)/ Cljm^ob qe^q ql Ammib„p M3 Max processor, launched in January 2023, which contains 67 billion transistors manufactured using critical dimensions on the order of 5 nm (Shankland 2023). That corresponds to >29 million times more transistors per chip, built using critical dimensions that are >2,000 times smaller, and just a dozen water molecules wide. If you applied this same boost in performance to automobiles, a car that got 20 mpg in 1972 would be able to go to the moon 2,500 times on a single gallon of gas in 2023. The efficient and controlled use of materials has been an important component in achieving these advances. Increased computing power attributed to improved semiconductors has enabled advances in communications (mobile phones and smartwatches), computing, medical devices and health care (portable ultrasounds, magnetic resonance imaging, robotic surgery and telemedicine), military systems, Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 52 200 Figure B-1: Moore’s law – a semi-log plot of transistor counts for microprocessors against dates of introduction, nearly doubling every two years (Roser and Ritchie 2020). In 1972, the Intel 4004 microprocessor contained 2,250 transistors and was manufactured using critical dimensions (transistor gate width) on the order of 10 µm (or 10,000 nm)/ Cljm^ob qe^q ql Ammib„p M3 Max processor, launched in January 2023, which contains 67 billion transistors manufactured using critical dimensions on the order of 5 nm (Shankland 2023). That corresponds to >29 million times more transistors per chip, built using critical dimensions that are >2,000 times smaller, and just a dozen water molecules wide. If you applied this same boost in performance to automobiles, a car that got 20 mpg in 1972 would be able to go to the moon 2,500 times on a single gallon of gas in 2023. The efficient and controlled use of materials has been an important component in achieving these advances. Increased computing power attributed to improved semiconductors has enabled advances in communications (mobile phones and smartwatches), computing, medical devices and health care (portable ultrasounds, magnetic resonance imaging, robotic surgery and telemedicine), military systems, Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 52 200 transportation (advanced driver assistance systems, electric vehicles), clean energy, enhanced and advanced safety applications (anti-lock and auto-braking technology), GPS, and many other applications that impact all facets of society. See Figure B-2. These advances would not have been possible without proportionally immense innovations in semiconductor manufacturing. Successive device generations have required increasingly complex chip designs and a continuous downscaling in feature size. The number of processing steps used to manufacture each semiconductor device has also grown dramatically, necessitating increasingly high yields in each step (>99.999%) to achieve cost efficiency (De Backer, et al. 2018). Achieving features at nanoscale requires rigorous control and great precision in manufacturing; however, without a consistently reproducible means to achieve such high yields, pbjf`lkar`qlo j^krc^`qrofkd tlria klq _b mlppf_ib ^q qeb p`^ib obnrfoba clo qla^v„p computerized world. transportation (advanced driver assistance systems, electric vehicles), clean energy, enhanced and advanced safety applications (anti-lock and auto-braking technology), GPS, and many other applications that impact all facets of society. See Figure B-2. These advances would not have been possible without proportionally immense innovations in semiconductor manufacturing. Successive device generations have required increasingly complex chip designs and a continuous downscaling in feature size. The number of processing steps used to manufacture each semiconductor device has also grown dramatically, necessitating increasingly high yields in each step (>99.999%) to achieve cost efficiency (De Backer, et al. 2018). Achieving features at nanoscale requires rigorous control and great precision in manufacturing; however, without a consistently reproducible means to achieve such high yields, pbjf`lkar`qlo j^krc^`qrofkd tlria klq _b mlppf_ib ^q qeb p`^ib obnrfoba clo qla^v„p computerized world. Figure B-2: Semiconductors enable technologies from aerospace and automotive to artificial intelligence, consumer products, medical, and robotics applications. The supply chain required to support the semiconductor industry is dispersed and complex. In their 2021 report, the Center for Security and Emerging Technology (Alam, et al. 2020) statea qe^q •The half-trillion- alii^o pbjf`lkar`qlo prmmiv `e^fk fp lkb lc qeb tloia„p jlpq `ljmibu/ Teb molar`qflk lc ^ pfkdib computer chip often requires more than 1,000 steps passing through international borders 70 or more times before reaching an end customer.‚ The semiconductor industry ecosystem involves several different layers of companies, each serving distinct roles from enablement software and intellectual property (IP), to chip designers, to the raw materials, tooling and facilities infrastructure needed in manufacturing facilities, to manufacturers where chips are built, to packaging houses that test and package chips for use in a wide range of applications. The Proprietary Nature of Semiconductor Chemicals Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 53 201 Figure B-2: Semiconductors enable technologies from aerospace and automotive to artificial intelligence, consumer products, medical, and robotics applications. The supply chain required to support the semiconductor industry is dispersed and complex. In their 2021 report, the Center for Security and Emerging Technology (Alam, et al. 2020) statea qe^q •The half-trillion- alii^o pbjf`lkar`qlo prmmiv `e^fk fp lkb lc qeb tloia„p jlpq `ljmibu/ Teb molar`qflk lc ^ pfkdib computer chip often requires more than 1,000 steps passing through international borders 70 or more times before reaching an end customer.‚ The semiconductor industry ecosystem involves several different layers of companies, each serving distinct roles from enablement software and intellectual property (IP), to chip designers, to the raw materials, tooling and facilities infrastructure needed in manufacturing facilities, to manufacturers where chips are built, to packaging houses that test and package chips for use in a wide range of applications. The Proprietary Nature of Semiconductor Chemicals Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 53 201 Suppliers invest considerable time, money and resources to develop proprietary chemicals that meet the exacting requirements to manufacture at nanometer dimensions. They need to protect their investment. Many semiconductor materials are complex chemical formulations. Given that a specific chemical identit ity is highly guarded IP, suppliers usually require a signed nondisclosure agreement before sharing this information with their customers (semiconductor device manufacturers). Releasing information about proprietary chemicals to the public would give competitors an unfair advantage and could cause substantial harm to a company„s competitive market position. In addition, when companies submit CBI to the U.S. EPA, they certify that they have gone through reasonable measures or internal controls to protect that information as confidential. If companies were to provide proprietary chemical information to the public, the claim of CBI with the U.S. EPA would also be at risk. Device Technology Must Evolve to Meet the Demands of an Increasingly Complex World Teb fkarpqov e^p j^fkq^fkba qeb Mllob„p law trajectory by continually shrinking minimum feature sizes; this has required continuous evolution in designs, chemicals and tools. Along the way, the complexity and number of materials used in chip manufacturing has grown tremendously. While in the 1980s semiconductor fabs used fewer than 20 elements, today they are using over 50% of the nonradioactive elements in the periodic table (Figure B-3). As an example, to maintain sufficient conductivity of ever-finer metal structures, the metal used for highly conductive in in-chip wiring has moved from aluminum and tungsten to copper, and is further migrating to cobalt (at present) and possibly ruthenium. Thesese new metals not only require new precursors and processes but the development of new barrier layers and liners to help them maintain their integrity and prevent their migration to other parts of the chip structure. Suppliers invest considerable time, money and resources to develop proprietary chemicals that meet the exacting requirements to manufacture at nanometer dimensions. They need to protect their investment. Many semiconductor materials are complex chemical formulations. Given that a specific chemical identit ity is highly guarded IP, suppliers usually require a signed nondisclosure agreement before sharing this information with their customers (semiconductor device manufacturers). Releasing information about proprietary chemicals to the public would give competitors an unfair advantage and could cause substantial harm to a company„s competitive market position. In addition, when companies submit CBI to the U.S. EPA, they certify that they have gone through reasonable measures or internal controls to protect that information as confidential. If companies were to provide proprietary chemical information to the public, the claim of CBI with the U.S. EPA would also be at risk. Device Technology Must Evolve to Meet the Demands of an Increasingly Complex World Teb fkarpqov e^p j^fkq^fkba qeb Mllob„p law trajectory by continually shrinking minimum feature sizes; this has required continuous evolution in designs, chemicals and tools. Along the way, the complexity and number of materials used in chip manufacturing has grown tremendously. While in the 1980s semiconductor fabs used fewer than 20 elements, today they are using over 50% of the nonradioactive elements in the periodic table (Figure B-3). As an example, to maintain sufficient conductivity of ever-finer metal structures, the metal used for highly conductive in in-chip wiring has moved from aluminum and tungsten to copper, and is further migrating to cobalt (at present) and possibly ruthenium. Thesese new metals not only require new precursors and processes but the development of new barrier layers and liners to help them maintain their integrity and prevent their migration to other parts of the chip structure. Figure B-3: Advanced semiconductor manufacturing now uses over 50% of the nonradioactive elements in the periodic table. The portfolio of a major materials vendor offers existing precursors containing 28 elements, with another 22 under development. The Belgian research organization IMEC has predicted that qeb afjbkpflk^i p`^ifkd rkaboivfkd Mllob„p law will continue through 2036 for logic devices. See Figure B-4. Maintaining and improving the performance of photolithography processes is key to staying on this roadmap as critical feature sizes shrink down to 12 nm, or about 50 silicon atoms. At these ranges, the demands on photoresist and other imaging chemicals and processes become extreme, with the need to control line widths to a single monomer unit in a lithographic polymer. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 54 202 Figure B-3: Advanced semiconductor manufacturing now uses over 50% of the nonradioactive elements in the periodic table. The portfolio of a major materials vendor offers existing precursors containing 28 elements, with another 22 under development. The Belgian research organization IMEC has predicted that qeb afjbkpflk^i p`^ifkd rkaboivfkd Mllob„p law will continue through 2036 for logic devices. See Figure B-4. Maintaining and improving the performance of photolithography processes is key to staying on this roadmap as critical feature sizes shrink down to 12 nm, or about 50 silicon atoms. At these ranges, the demands on photoresist and other imaging chemicals and processes become extreme, with the need to control line widths to a single monomer unit in a lithographic polymer. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 54 202 Figure B-4: IMEC’s vision of the future logic roadmap, with dimensional scaling predicted to continue through 2036 (IMEC 2023). Beginning with the A5 logic node, transistors will begin moving into the third dimension. This is the start of a development that will ultimately see the advent of 3D logic circuits. Logic chips will thus follow the trajectory already blazed by 3D not-and (NAND) nonvolatile memory chips, which have overcome the limitations of two-dimensional NAND designs by stacking hundreds of memory cells on top of each other. The dynamic random access memory (DRAM) sli^qfib jbjlov `efmp qe^q `lkpqfqrqb ^ `ljmrqbo„p working memory are on the verge of following this path, with all major memory makers working on 3D DRAM designs to replace the 2D versions, which are increasingly hard to make as feature sizes shrink. See Figure B-5. Figure B-5: A 3D NAND complementary metal-oxide semiconductor under-array design with 232 memory cell layers in two stacks (Micron Technology Inc. 2022). Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 55 203 Figure B-4: IMEC’s vision of the future logic roadmap, with dimensional scaling predicted to continue through 2036 (IMEC 2023). Beginning with the A5 logic node, transistors will begin moving into the third dimension. This is the start of a development that will ultimately see the advent of 3D logic circuits. Logic chips will thus follow the trajectory already blazed by 3D not-and (NAND) nonvolatile memory chips, which have overcome the limitations of two-dimensional NAND designs by stacking hundreds of memory cells on top of each other. The dynamic random access memory (DRAM) sli^qfib jbjlov `efmp qe^q `lkpqfqrqb ^ `ljmrqbo„p working memory are on the verge of following this path, with all major memory makers working on 3D DRAM designs to replace the 2D versions, which are increasingly hard to make as feature sizes shrink. See Figure B-5. Figure B-5: A 3D NAND complementary metal-oxide semiconductor under-array design with 232 memory cell layers in two stacks (Micron Technology Inc. 2022). Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 55 203 Stacked 3D structures demand highly advanced dry-etch processes. While highly performing photolithography remains a key prerequisite, high-aspect-ratio etch steps are highly demanding: they have become some of the most critical processes and can only be carried out with advanced PFAS-type etch gases. All of these developments will rely on evolving existing materials and processes to a higher level of performance. At present, for the most advanced chips, the number of photolithography layers used to successively build circuits has exceeded 70 (see Figure B-6), many of which are highly interconnected: a seemingly small change in one layer can impact the yield of a process three or four steps further down. Integrating these successive patterning steps is highly complex. There is therefore little to no room for compromise in accepting substitutions of photolithography materials with even slightly inferior alternatives. Stacked 3D structures demand highly advanced dry-etch processes. While highly performing photolithography remains a key prerequisite, high-aspect-ratio etch steps are highly demanding: they have become some of the most critical processes and can only be carried out with advanced PFAS-type etch gases. All of these developments will rely on evolving existing materials and processes to a higher level of performance. At present, for the most advanced chips, the number of photolithography layers used to successively build circuits has exceeded 70 (see Figure B-6), many of which are highly interconnected: a seemingly small change in one layer can impact the yield of a process three or four steps further down. Integrating these successive patterning steps is highly complex. There is therefore little to no room for compromise in accepting substitutions of photolithography materials with even slightly inferior alternatives. Figure B-6: Layer numbers for advanced logic device nodes by exposure technology. A highly beneficial side effect of shrinking feature sizes is the higher energy efficiency of advanced node chips. This is visible to consumers through improved battery life of the latest-model smartphone, but it is ^ipl `ofqf`^i fk qbojp lc lsbo^ii tloia bkbodv rpb/ Wb ^ob lk qo^`h ql rpb ^_lrq 36& lc qeb tloia„p electricity production for computing by 2025, with demand rising further thereafter • clearly an unsustainable development. There have been calls for computing efficiency improvements by 1,000 or even 1 million times (see Figure B-7). Figure B-7: The SRC’s Decadal Plan has identified five “seismic shifts” that will define the future of semiconductors and information/communications technology (SRC 2022). No. 5 calls for a millionfold improvement in computing efficiency. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 56 204 Figure B-6: Layer numbers for advanced logic device nodes by exposure technology. A highly beneficial side effect of shrinking feature sizes is the higher energy efficiency of advanced node chips. This is visible to consumers through improved battery life of the latest-model smartphone, but it is ^ipl `ofqf`^i fk qbojp lc lsbo^ii tloia bkbodv rpb/ Wb ^ob lk qo^`h ql rpb ^_lrq 36& lc qeb tloia„p electricity production for computing by 2025, with demand rising further thereafter • clearly an unsustainable development. There have been calls for computing efficiency improvements by 1,000 or even 1 million times (see Figure B-7). Figure B-7: The SRC’s Decadal Plan has identified five “seismic shifts” that will define the future of semiconductors and information/communications technology (SRC 2022). No. 5 calls for a millionfold improvement in computing efficiency. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 56 204 As the world transitions to an information-based society, computational demands will skyrocket. Intel has estimated that the implementation of the metaverse vision will require a thousandfold increase in available computing power (Gartenberg 2021). The computing requirements of advanced artificial intelligence (AI) models will serve as another example. The rate of increase in computational demands for qeb qo^fkfkd lc ^as^k`ba AI jlabip pr`e ^p Glldib„p DbbmFlia AI lo OmbkAI„p Ce^qGPT e^sb exceeded qeb _bkbcfqp molsfaba _v Mllob„p law by a factor of over 100 (Figure B-8). These high demands on computing power are already beginning to slow down the development of advanced AI. The computing power and energy efficiency necessary to enable continued AI development will require new chip designs, most likely neuromorphic designs modeled after the human brain. While it is yet uncertain what these new chip designs will be and what new materials they will require, it is certain that their manufacturing processes will build as much as possible on existing photolithographic processes and materials. As the world transitions to an information-based society, computational demands will skyrocket. Intel has estimated that the implementation of the metaverse vision will require a thousandfold increase in available computing power (Gartenberg 2021). The computing requirements of advanced artificial intelligence (AI) models will serve as another example. The rate of increase in computational demands for qeb qo^fkfkd lc ^as^k`ba AI jlabip pr`e ^p Glldib„p DbbmFlia AI lo OmbkAI„p Ce^qGPT e^sb exceeded qeb _bkbcfqp molsfaba _v Mllob„p law by a factor of over 100 (Figure B-8). These high demands on computing power are already beginning to slow down the development of advanced AI. The computing power and energy efficiency necessary to enable continued AI development will require new chip designs, most likely neuromorphic designs modeled after the human brain. While it is yet uncertain what these new chip designs will be and what new materials they will require, it is certain that their manufacturing processes will build as much as possible on existing photolithographic processes and materials. Figure B-8: Exploding computational requirements for the training of advanced AI models (Binus University Faculty of Engineering 2022). Overview of Semiconductor Manufacturing Semiconductor device fabrication is the process used to create integrated circuits, which are an essential component of electronic devices. OECD emissions scenario documents provide an overview of the semiconductor manufacturing process (OECD 2015); (OECD 2004). The fabrication process (see Figure Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 57 205 B-9) begins with a wafer of semiconductor material (typically silicon) varying in size from 150 mm to 300 mm in diameter. In the fab, a sequence of photographic and chemical processing steps gradually create electronic circuits on the wafer substrate. These electrical circuits are made one layer at a time through the combination of depositing a layer on the surface of the wafer and using a patterning process to then remove designated parts of the layer and leave behind a specific shape. For more information on the use of PFAS chemicals and articles in semiconductor manufacturing, see the Semiconductor PFAS Consortium white papers. These are the basic steps that occur in a fab: Figure B-8: Exploding computational requirements for the training of advanced AI models (Binus University Faculty of Engineering 2022). Overview of Semiconductor Manufacturing Semiconductor device fabrication is the process used to create integrated circuits, which are an essential component of electronic devices. OECD emissions scenario documents provide an overview of the semiconductor manufacturing process (OECD 2015); (OECD 2004). The fabrication process (see Figure Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 57 205 B-9) begins with a wafer of semiconductor material (typically silicon) varying in size from 150 mm to 300 mm in diameter. In the fab, a sequence of photographic and chemical processing steps gradually create electronic circuits on the wafer substrate. These electrical circuits are made one layer at a time through the combination of depositing a layer on the surface of the wafer and using a patterning process to then remove designated parts of the layer and leave behind a specific shape. For more information on the use of PFAS chemicals and articles in semiconductor manufacturing, see the Semiconductor PFAS Consortium white papers. These are the basic steps that occur in a fab: • Oxidation, usually performed at 800°C to 1,200°C in a tube furnace, is a batch process that diffuses O2 or water H2O vapor into a silicon wafer to form an SiO2 layer that protects the wafer surface during subsequent steps. • Photolithography, also known as lithography, is a process that transfers the specific device pattern onto the wafer. It can create extremely small patterns, down to a few tens of nanometers in size, with precise control of the shape, size and placement of the images it produces. These patterns are used to create the tens of billions of transistors and connecting wiring on a modern microprocessor. o In a typical processing scheme, a photoresist polymer formulation is applied to a spinning wafer and then subjected to a pre-exposure bake to drive off the solvent, rendering a solid film. The coated wafer substrate is then exposed through a patterned photomask, with actinic radiation from a light source of specified wavelength. Reflectivity of a semiconductor material during light exposure can be problematic; a layer of anti-reflective coating helps absorb light and reduce reflections during exposure. An anti-reflective coating applied after the photoresist is known as a top anti-reflective coating (TARC) agent and an anti-reflective coating applied before the photoresist is known as a bottom anti-reflective coating (BARC) layer. • After exposure, the coated wafer substrate undergoes a development process in which the previously exposed regions are selectively dissolved and removed from the photoresist film. This leaves the wafer surface with a patterned coating of photoresist, where in selected regions the resist material is completely removed, and in the remaining areas the photoresist forms a protective coating. The open areas of the substrate may then undergo additive processes like physical vapor deposition, CVD, diffusion, ion implant or plating, or subtractive processes like a plasma etch. In doping/diffusion, atoms with one less electron than silicon (such as boron) or one more electron than silicon (such as phosphorus) are introduced into the area exposed by the etch process in order to alter the electrical character (conductivity) of the silicon. In thin-film deposition, a type of which is known as CVD (OECD 2015), adding thin layers or films to the wafer surface can change its electrical properties or serve as masks. Etching chemically removes specific areas of a deposited film in order to expose an underlying material or deposit another material. Etching may be performed in a wet process using solutions of acids, bases or oxidizers, or in a dry process using various gases in a plasma. After the etch or deposition process, the residual photoresist and anti-reflective coating are removed from the wafer surface. This final step, known as photoresist strip, occurs in a way that completely and uniformly removes the residual photoresist, without adversely impacting the surfaces of the materials comprising the underlying wafer substrate. • Semiconductor devices are highly susceptible to various kinds of contamination such as particles, metal ions, chemicals, bacteria and airborne molecular contaminants; thus, surface preparation in etching and cleaning tools is a necessary step at multiple points in the manufacturing flow to remove contaminants and ensure high yields. Following completion of the •front end,‚ the individual devices are interconnected using a series of alternating metal depositions and dielectric films, with their respective patterning. • CMP uses chemical and physical forces to remove excess material from the wafer„p surface, creating a perfectly flat surface for the next layer of circuit features. • Oxidation, usually performed at 800°C to 1,200°C in a tube furnace, is a batch process that diffuses O2 or water H2O vapor into a silicon wafer to form an SiO2 layer that protects the wafer surface during subsequent steps. • Photolithography, also known as lithography, is a process that transfers the specific device pattern onto the wafer. It can create extremely small patterns, down to a few tens of nanometers in size, with precise control of the shape, size and placement of the images it produces. These patterns are used to create the tens of billions of transistors and connecting wiring on a modern microprocessor. o In a typical processing scheme, a photoresist polymer formulation is applied to a spinning wafer and then subjected to a pre-exposure bake to drive off the solvent, rendering a solid film. The coated wafer substrate is then exposed through a patterned photomask, with actinic radiation from a light source of specified wavelength. Reflectivity of a semiconductor material during light exposure can be problematic; a layer of anti-reflective coating helps absorb light and reduce reflections during exposure. An anti-reflective coating applied after the photoresist is known as a top anti-reflective coating (TARC) agent and an anti-reflective coating applied before the photoresist is known as a bottom anti-reflective coating (BARC) layer. • After exposure, the coated wafer substrate undergoes a development process in which the previously exposed regions are selectively dissolved and removed from the photoresist film. This leaves the wafer surface with a patterned coating of photoresist, where in selected regions the resist material is completely removed, and in the remaining areas the photoresist forms a protective coating. The open areas of the substrate may then undergo additive processes like physical vapor deposition, CVD, diffusion, ion implant or plating, or subtractive processes like a plasma etch. In doping/diffusion, atoms with one less electron than silicon (such as boron) or one more electron than silicon (such as phosphorus) are introduced into the area exposed by the etch process in order to alter the electrical character (conductivity) of the silicon. In thin-film deposition, a type of which is known as CVD (OECD 2015), adding thin layers or films to the wafer surface can change its electrical properties or serve as masks. Etching chemically removes specific areas of a deposited film in order to expose an underlying material or deposit another material. Etching may be performed in a wet process using solutions of acids, bases or oxidizers, or in a dry process using various gases in a plasma. After the etch or deposition process, the residual photoresist and anti-reflective coating are removed from the wafer surface. This final step, known as photoresist strip, occurs in a way that completely and uniformly removes the residual photoresist, without adversely impacting the surfaces of the materials comprising the underlying wafer substrate. • Semiconductor devices are highly susceptible to various kinds of contamination such as particles, metal ions, chemicals, bacteria and airborne molecular contaminants; thus, surface preparation in etching and cleaning tools is a necessary step at multiple points in the manufacturing flow to remove contaminants and ensure high yields. Following completion of the •front end,‚ the individual devices are interconnected using a series of alternating metal depositions and dielectric films, with their respective patterning. • CMP uses chemical and physical forces to remove excess material from the wafer„p surface, creating a perfectly flat surface for the next layer of circuit features. Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 58 206 • After the last metal is patterned, the depositing of a final insulating layer known as passivation protects the circuit from damage and contamination. Etching openings in this film allow access to the top metal layer with electrical probes and subsequent wire bonds. Passivation may occur in the wafer fab or at an assembly and packaging facility. Figure B-9: Overall process flow diagram – semiconductor manufacturing (OECD 2010). After passivation, wafers are shipped to assembly, test and packaging facilities. At this stage, a probe of each chip on the wafer identifies defects, and then a diamond-embedded saw blade slices the wafer into individual die. Packaging functional die then facilitates electrical connections; dissipates heat; and protects the die from external factors such as humidity, chemicals, impact and vibration. The packaged integrated circuit is then shipped to customers for incorporation into their products. PFAS-containing articles are found in many SMRE used to perform the processes described here and in the manufacturing facility infrastructure. For examples of PFAS-containing articles, see the Semiconductor PFAS Consortium white paper- •PFAS-Containing Articles Used in Semiconductor Manufacturing/‚ Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 58 206 • After the last metal is patterned, the depositing of a final insulating layer known as passivation protects the circuit from damage and contamination. Etching openings in this film allow access to the top metal layer with electrical probes and subsequent wire bonds. Passivation may occur in the wafer fab or at an assembly and packaging facility. Figure B-9: Overall process flow diagram – semiconductor manufacturing (OECD 2010). After passivation, wafers are shipped to assembly, test and packaging facilities. At this stage, a probe of each chip on the wafer identifies defects, and then a diamond-embedded saw blade slices the wafer into individual die. Packaging functional die then facilitates electrical connections; dissipates heat; and protects the die from external factors such as humidity, chemicals, impact and vibration. The packaged integrated circuit is then shipped to customers for incorporation into their products. PFAS-containing articles are found in many SMRE used to perform the processes described here and in the manufacturing facility infrastructure. For examples of PFAS-containing articles, see the Semiconductor PFAS Consortium white paper- •PFAS-Containing Articles Used in Semiconductor Manufacturing/‚ Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 59 207 Appendix C: List of SEMI Safety Guidelines • SEMI AUX005 • Comparison Matrix Between SEMI S2-93A and S2-0200 • SEMI S1 • Safety Guideline for Equipment Safety Labels • SEMI S2 • Environmental, Health and Safety Guideline for Semiconductor Manufacturing Equipment • SEMI S3 • Safety Guideline for Process Liquid Heating Systems • SEMI S4 • Safety Guideline for the Segregation/Separation of Gas Cylinders Contained in Cabinets • SEMI S5 • Safety Guideline for Sizing and Identifying Flow Limiting Devices for Gases • SEMI S6 • Environmental, Health and Safety Guideline for Exhaust Ventilation of Semiconductor Manufacturing Equipment • SEMI S7 • Safety Guideline for Evaluating Personnel and Evaluating Company Qualifications • SEMI S8 • Safety Guideline for Ergonomics Engineering of Semiconductor Manufacturing Equipment • SEMI S10 • Safety Guideline for Risk Assessment and Risk Evaluation Process • SEMI S12 • Environmental, Health and Safety Guideline for Manufacturing Equipment Decontamination • SEMI S13 • Environmental, Health and Safety Guideline for Documents Provided to the Equipment User for Use With Manufacturing Equipment • SEMI S14 • Safety Guideline for Fire Risk Assessment and Mitigation for Semiconductor Manufacturing Equipment • SEMI S16 • Guide for Semiconductor Manufacturing Equipment Design for Reduction of Environmental Impact at End of Life • SEMI S17 • Safety Guideline for Unmanned Transport Vehicle (UTV) Systems • SEMI S18 • Environmental, Health and Safety Guideline for Flammable Silicon Compounds • SEMI S19 • Safety Guideline for Training of Manufacturing Equipment Installation, Maintenance and Service Personnel • SEMI S21 • Safety Guideline for Worker Protection • SEMI S22 • Safety Guideline for the Electrical Design of Semiconductor Manufacturing Equipment • SEMI S23 • Guide for Conservation of Energy, Utilities and Materials Used by Semiconductor Manufacturing Equipment • SEMI S24 • Safety Guideline for Multi-Employer Work Areas • SEMI S25 • Safety Guideline for Hydrogen Peroxide Storage and Handling Systems • SEMI S26 • Environmental, Health and Safety Guideline for FPD Manufacturing System • SEMI S27 • Safety Guideline for the Contents of Environmental, Safety and Health Evaluation Reports • SEMI S28 • Safety Guideline for Robots and Load Ports Intended for Use in Semiconductor Manufacturing Equipment • SEMI S29 • Guide for Fluorinated Greenhouse Gas (F-GHG) Emission Characterization and Reduction • SEMI S30 • Safety Guideline for Use of Energetic Materials in Semiconductor R&D and Manufacturing Processes Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 59 207 Appendix C: List of SEMI Safety Guidelines • SEMI AUX005 • Comparison Matrix Between SEMI S2-93A and S2-0200 • SEMI S1 • Safety Guideline for Equipment Safety Labels • SEMI S2 • Environmental, Health and Safety Guideline for Semiconductor Manufacturing Equipment • SEMI S3 • Safety Guideline for Process Liquid Heating Systems • SEMI S4 • Safety Guideline for the Segregation/Separation of Gas Cylinders Contained in Cabinets • SEMI S5 • Safety Guideline for Sizing and Identifying Flow Limiting Devices for Gases • SEMI S6 • Environmental, Health and Safety Guideline for Exhaust Ventilation of Semiconductor Manufacturing Equipment • SEMI S7 • Safety Guideline for Evaluating Personnel and Evaluating Company Qualifications • SEMI S8 • Safety Guideline for Ergonomics Engineering of Semiconductor Manufacturing Equipment • SEMI S10 • Safety Guideline for Risk Assessment and Risk Evaluation Process • SEMI S12 • Environmental, Health and Safety Guideline for Manufacturing Equipment Decontamination • SEMI S13 • Environmental, Health and Safety Guideline for Documents Provided to the Equipment User for Use With Manufacturing Equipment • SEMI S14 • Safety Guideline for Fire Risk Assessment and Mitigation for Semiconductor Manufacturing Equipment • SEMI S16 • Guide for Semiconductor Manufacturing Equipment Design for Reduction of Environmental Impact at End of Life • SEMI S17 • Safety Guideline for Unmanned Transport Vehicle (UTV) Systems • SEMI S18 • Environmental, Health and Safety Guideline for Flammable Silicon Compounds • SEMI S19 • Safety Guideline for Training of Manufacturing Equipment Installation, Maintenance and Service Personnel • SEMI S21 • Safety Guideline for Worker Protection • SEMI S22 • Safety Guideline for the Electrical Design of Semiconductor Manufacturing Equipment • SEMI S23 • Guide for Conservation of Energy, Utilities and Materials Used by Semiconductor Manufacturing Equipment • SEMI S24 • Safety Guideline for Multi-Employer Work Areas • SEMI S25 • Safety Guideline for Hydrogen Peroxide Storage and Handling Systems • SEMI S26 • Environmental, Health and Safety Guideline for FPD Manufacturing System • SEMI S27 • Safety Guideline for the Contents of Environmental, Safety and Health Evaluation Reports • SEMI S28 • Safety Guideline for Robots and Load Ports Intended for Use in Semiconductor Manufacturing Equipment • SEMI S29 • Guide for Fluorinated Greenhouse Gas (F-GHG) Emission Characterization and Reduction • SEMI S30 • Safety Guideline for Use of Energetic Materials in Semiconductor R&D and Manufacturing Processes Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 60 208 SIA PFAS Consortium The Impact of a Potential PFAS Restriction on the Semiconductor Sector Report No. 2022-0737 Rev. 0 Project No. REG4720-001 Rev. 0 Description Final Report Prepared by Emily Tyrwhitt Jones Controlled by Maitheya Riva, Liz Kimber Approved by Chris Robertson Date 13th April 2023 RINA Tech UK Limited | 1 Springfield Drive, Leatherhead, Surrey, KT22 7AJ AJ, United Kingdom | P. +44 0 1372 367350 | UKinfo@rina.org | www.rina.org Company No. 07419599 Registered in England and Wales All rights, including translation, reserved. No part of this document may be disclosed to any third party without written consent of RINA Tech UK Limited 209 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Note on report approval The persons identified above have signed off each stage of this report in accordance with RINA’s Business management system and quality assurance procedure. Disclaimer Copyright © 2023 the Semiconductor Industry Association (SIA). All rights reserved. 60 208 SIA PFAS Consortium The Impact of a Potential PFAS Restriction on the Semiconductor Sector Report No. 2022-0737 Rev. 0 Project No. REG4720-001 Rev. 0 Description Final Report Prepared by Emily Tyrwhitt Jones Controlled by Maitheya Riva, Liz Kimber Approved by Chris Robertson Date 13th April 2023 RINA Tech UK Limited | 1 Springfield Drive, Leatherhead, Surrey, KT22 7AJ AJ, United Kingdom | P. +44 0 1372 367350 | UKinfo@rina.org | www.rina.org Company No. 07419599 Registered in England and Wales All rights, including translation, reserved. No part of this document may be disclosed to any third party without written consent of RINA Tech UK Limited 209 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Note on report approval The persons identified above have signed off each stage of this report in accordance with RINA’s Business management system and quality assurance procedure. Disclaimer Whilst great care has been taken in the compilation of this report, use of the information contained herein is entirely at the risk of the client or recipient. It does not constitute legal advice and should not be relied upon as such. To the extent permitted by law, RINA Tech UK Limited (“RINA”) accepts no responsibility or liability for loss or damage arising out of acting upon or refraining from action as a result of any material in this publication. Issue and Revision Record Rev. Description Prepared by Controlled by Approved by Date 0 Final report Emily Tyrwhitt Jones Maitheya Riva, Liz Kimber Chris Robertson 13/04/2023 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 2 210 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Whilst great care has been taken in the compilation of this report, use of the information contained herein is entirely at the risk of the client or recipient. It does not constitute legal advice and should not be relied upon as such. To the extent permitted by law, RINA Tech UK Limited (“RINA”) accepts no responsibility or liability for loss or damage arising out of acting upon or refraining from action as a result of any material in this publication. Issue and Revision Record Rev. Description Prepared by Controlled by Approved by Date 0 Final report Emily Tyrwhitt Jones Maitheya Riva, Liz Kimber Chris Robertson 13/04/2023 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 2 210 The Impact of a Potential PFAS Restriction on the Semiconductor Sector EXECUTIVE SUMMARY RINA Tech UK Limited (RINA) were engaged by the Semiconductor per- and polyfluoroalkyl substances (PFAS) Consortium to gather information from members, to establish an evidence base, to inform the semiconductor sector in support of their respective information gathering activities, when considering the potential impact of PFAS restriction. This report comprises an assimilation of this evidence. ---- The Semiconductor PFAS Consortium represents 69% of worldwide semiconductor manufacturing capital expenditure as well as 70% of global sales of semiconductor equipment in 2021. Its members represented over $400 billion dollars in revenue and directly provide over 500,000 jobs worldwide. The Semiconductor PFAS Consortium is organized under the auspices of the Semiconductor Industry Association (SIA). For more information, see www.semiconductors.org. EXECUTIVE SUMMARY RINA Tech UK Limited (RINA) were engaged by the Semiconductor per- and polyfluoroalkyl substances (PFAS) Consortium to gather information from members, to establish an evidence base, to inform the semiconductor sector in support of their respective information gathering activities, when considering the potential impact of PFAS restriction. This report comprises an assimilation of this evidence. ---- The Semiconductor PFAS Consortium represents 69% of worldwide semiconductor manufacturing capital expenditure as well as 70% of global sales of semiconductor equipment in 2021. Its members represented over $400 billion dollars in revenue and directly provide over 500,000 jobs worldwide. The Semiconductor PFAS Consortium is organized under the auspices of the Semiconductor Industry Association (SIA). For more information, see www.semiconductors.org. Semiconductor devices (also known as “chips”, or “integrated circuits”) are essential components of electronic devices. Semiconductor devices are extremely complex to manufacture, with leading devices requiring more than 2,000 process steps, hundreds of production materials, and approximately 26 weeks to manufacture and test. This requires the utilisation of process chemicals, manufacturing equipment, and manufacturing facility infrastructure which may contain PFAS. PFAS provide specific and unique capabilities within semiconductor process chemistries, semiconductor manufacturing equipment and facilities, as well as the electronic products they drive. Without PFAS, the ability to produce semiconductors (and the facilities and equipment related to and supporting semiconductor manufacturing) would be put at risk. Considering that the semiconductor industry was estimated as having global sales of $574 billion USD in 2022, the withdrawal of PFAS will have severe economic impacts. These impacts are significantly larger, if the consequential effects of chip supply and the societal impact of loss of device functionality are also considered. Semiconductor devices (also known as “chips”, or “integrated circuits”) are essential components of electronic devices. Semiconductor devices are extremely complex to manufacture, with leading devices requiring more than 2,000 process steps, hundreds of production materials, and approximately 26 weeks to manufacture and test. This requires the utilisation of process chemicals, manufacturing equipment, and manufacturing facility infrastructure which may contain PFAS. PFAS provide specific and unique capabilities within semiconductor process chemistries, semiconductor manufacturing equipment and facilities, as well as the electronic products they drive. Without PFAS, the ability to produce semiconductors (and the facilities and equipment related to and supporting semiconductor manufacturing) would be put at risk. Considering that the semiconductor industry was estimated as having global sales of $574 billion USD in 2022, the withdrawal of PFAS will have severe economic impacts. These impacts are significantly larger, if the consequential effects of chip supply and the societal impact of loss of device functionality are also considered. The semiconductor industry has a history of proactively adopting voluntary elimination and reduction strategies, as a result of new information on the environmental concerns of the substances it uses. An example of best industry practice is the substitution of perfluorooctanesulfonic acid (PFOS) in the early 2000's that was found to be persistent, bioaccumulative, and toxic. The World Semiconductor Council (WSC) initiated an international voluntary commitment to phase out PFOS uses worldwide and announced the elimination of PFOS in 2011. 1 The following are the key challenges the Semiconductor PFAS Consortium members have highlighted, due to their deep understanding of the effort required in terms of resources, challenges, and timeline, are necessary to introduce alternative chemicals into some of the world's most complex technology: • Semiconductor manufacturing is highly integrated, uses thousands of process steps, and occurs at the nanometre scale. • Some materials are unique and have such specific technical requirements that it is extremely challenging to find a viable alternative. No known alternatives exist for many of the industry’s uses of fluorocarbon-containing materials and in many instances a successful invention of an alternative substance needs to occur before subsequent steps of qualification can be undertaken. The semiconductor industry has a history of proactively adopting voluntary elimination and reduction strategies, as a result of new information on the environmental concerns of the substances it uses. An example of best industry practice is the substitution of perfluorooctanesulfonic acid (PFOS) in the early 2000's that was found to be persistent, bioaccumulative, and toxic. The World Semiconductor Council (WSC) initiated an international voluntary commitment to phase out PFOS uses worldwide and announced the elimination of PFOS in 2011. 1 The following are the key challenges the Semiconductor PFAS Consortium members have highlighted, due to their deep understanding of the effort required in terms of resources, challenges, and timeline, are necessary to introduce alternative chemicals into some of the world's most complex technology: • Semiconductor manufacturing is highly integrated, uses thousands of process steps, and occurs at the nanometre scale. • Some materials are unique and have such specific technical requirements that it is extremely challenging to find a viable alternative. No known alternatives exist for many of the industry’s uses of fluorocarbon-containing materials and in many instances a successful invention of an alternative substance needs to occur before subsequent steps of qualification can be undertaken. • The organisation of collaborative research and industry alignment is sometimes needed when making significant changes. For instance, the industry’s voluntary commitments to a PFOS phase- ______ 1 WSC-May-06-Charter-Amendment-SIGNED.pdf (semiconductorcouncil.org) © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 3 211 The Impact of a Potential PFAS Restriction on the Semiconductor Sector out and perfluorocarbon (PFC) emission reduction were only effective due to the alignment and efforts of the industry as a whole. • The timeline needed to develop, qualify, and implement alternatives falls into the following four broad categories: - 3 to 4 years: If an existing non-PFAS alternative is available, does not require infrastructure alterations, and can be demonstrated to provide adequate performance for a specific application, then it typically takes 3 to 4 years to conduct the necessary manufacturing trials and implement the successful alternative into high volume manufacturing (HVM). • The organisation of collaborative research and industry alignment is sometimes needed when making significant changes. For instance, the industry’s voluntary commitments to a PFOS phase- ______ 1 WSC-May-06-Charter-Amendment-SIGNED.pdf (semiconductorcouncil.org) © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 3 211 The Impact of a Potential PFAS Restriction on the Semiconductor Sector out and perfluorocarbon (PFC) emission reduction were only effective due to the alignment and efforts of the industry as a whole. • The timeline needed to develop, qualify, and implement alternatives falls into the following four broad categories: - 3 to 4 years: If an existing non-PFAS alternative is available, does not require infrastructure alterations, and can be demonstrated to provide adequate performance for a specific application, then it typically takes 3 to 4 years to conduct the necessary manufacturing trials and implement the successful alternative into high volume manufacturing (HVM). - From 3 to more than 10 years: In some applications, an existing non-PFAS alternative may be viable but requires tooling and/or process or facility changes before it can be successfully introduced into high volume manufacturing. In these cases, it may take from 3 to more than 10 years to introduce changes to the semiconductor manufacturing and related equipment (SMRE) and/or processes, and then perform qualification testing, and implement the non-PFAS alternative into HVM. - From 5 to more than 25 years and successful invention is required: For some applications, it is not currently possible to demonstrate that a non-PFAS alternative can fulfil the application- specific performance requirements. In these cases, it may be necessary to invent and synthesise new chemicals, and/or develop alternative approaches to device fabrication that provides the necessary electrical and computational performance. Invention is an open-ended endeavour without a fixed timeline or guarantee of success. - From 3 to more than 10 years: In some applications, an existing non-PFAS alternative may be viable but requires tooling and/or process or facility changes before it can be successfully introduced into high volume manufacturing. In these cases, it may take from 3 to more than 10 years to introduce changes to the semiconductor manufacturing and related equipment (SMRE) and/or processes, and then perform qualification testing, and implement the non-PFAS alternative into HVM. - From 5 to more than 25 years and successful invention is required: For some applications, it is not currently possible to demonstrate that a non-PFAS alternative can fulfil the application- specific performance requirements. In these cases, it may be necessary to invent and synthesise new chemicals, and/or develop alternative approaches to device fabrication that provides the necessary electrical and computational performance. Invention is an open-ended endeavour without a fixed timeline or guarantee of success. - No alternative is achievable: In some cases, it may ultimately be found that a non-PFAS alternative is not capable of providing the required chemical function. If a non-PFAS alternative chemical cannot be invented, then the integrated circuit device structure may need to be abandoned in favour of an alternative device structure that may or may not provide equivalent performance. In some cases, the fundamental laws of chemistry and physics prevent the use of PFAS-free alternatives. • This is only an overview and potential alternatives must be evaluated on a case-by-case basis considering technical, regulatory, as well as economic aspects. By its nature, the invention of an alternative has no clearly defined timeline, and, for some applications, there may be no known alternative. When the alternative is not viable, the process will loop back to invention, research and development steps to find a different chemistry or technology that does not have the same issues. • Stringent qualification also has to take place with semiconductor customers to ensure that the semiconductor product guarantees the same function as the semiconductor product did previously. • Qualification and replacement of critical materials is a highly complex, multi-step, multi-year, challenge which impacts multiple parts of the semiconductor supply chain. - No alternative is achievable: In some cases, it may ultimately be found that a non-PFAS alternative is not capable of providing the required chemical function. If a non-PFAS alternative chemical cannot be invented, then the integrated circuit device structure may need to be abandoned in favour of an alternative device structure that may or may not provide equivalent performance. In some cases, the fundamental laws of chemistry and physics prevent the use of PFAS-free alternatives. • This is only an overview and potential alternatives must be evaluated on a case-by-case basis considering technical, regulatory, as well as economic aspects. By its nature, the invention of an alternative has no clearly defined timeline, and, for some applications, there may be no known alternative. When the alternative is not viable, the process will loop back to invention, research and development steps to find a different chemistry or technology that does not have the same issues. • Stringent qualification also has to take place with semiconductor customers to ensure that the semiconductor product guarantees the same function as the semiconductor product did previously. • Qualification and replacement of critical materials is a highly complex, multi-step, multi-year, challenge which impacts multiple parts of the semiconductor supply chain. • The possibility of regrettable substitution is an ever-present concern. The selection of alternatives must be well informed and consider current and potential future concerns. • If alternatives decrease production yield even by very small percentages, significant increases are required in semiconductor manufacturing facility size, resulting in correspondingly increased chemical, water, and energy consumption, as well as waste generation. • A decrease in the performance of PFAS-free alternatives would increase the consumption of parts and waste generation for some uses. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 4 212 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 0-1 provides a general overview of the semiconductor manufacturing process steps, operations, and systems evaluated by the Semiconductor PFAS Consortium and is based on the best and current knowledge of consortium members. • The possibility of regrettable substitution is an ever-present concern. The selection of alternatives must be well informed and consider current and potential future concerns. • If alternatives decrease production yield even by very small percentages, significant increases are required in semiconductor manufacturing facility size, resulting in correspondingly increased chemical, water, and energy consumption, as well as waste generation. • A decrease in the performance of PFAS-free alternatives would increase the consumption of parts and waste generation for some uses. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 4 212 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 0-1 provides a general overview of the semiconductor manufacturing process steps, operations, and systems evaluated by the Semiconductor PFAS Consortium and is based on the best and current knowledge of consortium members. Figure 0-1 General overview of the semiconductor manufacturing process steps, operations, and systems evaluated by the Semiconductor PFAS Consortium. The following highlights key uses and challenges in each of the application groupings which are critical to the semiconductor industry: • Photolithography is a critical semiconductor manufacturing function, providing cutting-edge semiconductor transistor device dimensions from 2 to 180 nanometres in width with tolerances below these dimensions. For context the diameter of a human hair is about 100,000 nm. PFAS- containing materials within photolithography enable nanometre-scale semiconductor dimensions. Photolithography materials containing PFAS are a critical component used within photoacid generators in chemically amplified resists and bottom antireflective coatings, top antireflective coatings, surfactants, barrier layers, photo-imageable polybenzoxazoles and polyimides for dielectric and buffer coat applications, and photoresist applications. Figure 0-1 General overview of the semiconductor manufacturing process steps, operations, and systems evaluated by the Semiconductor PFAS Consortium. The following highlights key uses and challenges in each of the application groupings which are critical to the semiconductor industry: • Photolithography is a critical semiconductor manufacturing function, providing cutting-edge semiconductor transistor device dimensions from 2 to 180 nanometres in width with tolerances below these dimensions. For context the diameter of a human hair is about 100,000 nm. PFAS- containing materials within photolithography enable nanometre-scale semiconductor dimensions. Photolithography materials containing PFAS are a critical component used within photoacid generators in chemically amplified resists and bottom antireflective coatings, top antireflective coatings, surfactants, barrier layers, photo-imageable polybenzoxazoles and polyimides for dielectric and buffer coat applications, and photoresist applications. After more than 25 years of development, whilst some PFAS-free material substitutions may be possible, PFAS-free materials have not been shown to be successful or effective in the vast majority of photolithography applications. Possible PFAS-free alternatives would require total reinvention for many applications. The process of identifying and implementing alternatives involves academic research, material supplier research and development (validation) and scale-up, followed by device manufacturer efforts toward demonstration (verification), integration and implementation, and scale- up to HVM. Although each PFAS use has its own challenges and timelines for development, most lithography uses are expected to take from 15 to more than 20 years to develop and qualify a PFAS-free alternative, with the exception of PAGs which are expected to take more than 25 years. A detailed explanation of photolithography applications and the use of PFAS materials is found in Section 4. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 5 213 The Impact of a Potential PFAS Restriction on the Semiconductor Sector After more than 25 years of development, whilst some PFAS-free material substitutions may be possible, PFAS-free materials have not been shown to be successful or effective in the vast majority of photolithography applications. Possible PFAS-free alternatives would require total reinvention for many applications. The process of identifying and implementing alternatives involves academic research, material supplier research and development (validation) and scale-up, followed by device manufacturer efforts toward demonstration (verification), integration and implementation, and scale- up to HVM. Although each PFAS use has its own challenges and timelines for development, most lithography uses are expected to take from 15 to more than 20 years to develop and qualify a PFAS-free alternative, with the exception of PAGs which are expected to take more than 25 years. A detailed explanation of photolithography applications and the use of PFAS materials is found in Section 4. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 5 213 The Impact of a Potential PFAS Restriction on the Semiconductor Sector • Wet chemistries are applied within semiconductor manufacturing for cleaning, stripping, wet etching, chemical mechanical planarization, metal plating, and to facilitate other processes. The use of PFAS in some wet chemistries is necessary to achieve the nanometre-sized transistor dimensions. Most wet chemistry applications do not contain PFAS; however, there are some applications that rely on PFAS materials for specific performance requirements. Examples of these applications include but are not limited to; post-plasma photoresist strip, high aspect ratio collapse mitigation, selective film inhibition, wetting of low surface energy substrates, and specific parts cleaning. Wet chemistry alternatives are highly application specific and depend on the technology and application for which they are used. What may be a suitable alternative for one application, will not necessarily be a suitable alternative for another. The timeline for implementing alternatives is estimated from 3 to 15 or more years after an alternative is found to be suitable. A detailed explanation of wet chemistry applications and the use of PFAS materials is found in Section 5. • Wet chemistries are applied within semiconductor manufacturing for cleaning, stripping, wet etching, chemical mechanical planarization, metal plating, and to facilitate other processes. The use of PFAS in some wet chemistries is necessary to achieve the nanometre-sized transistor dimensions. Most wet chemistry applications do not contain PFAS; however, there are some applications that rely on PFAS materials for specific performance requirements. Examples of these applications include but are not limited to; post-plasma photoresist strip, high aspect ratio collapse mitigation, selective film inhibition, wetting of low surface energy substrates, and specific parts cleaning. Wet chemistry alternatives are highly application specific and depend on the technology and application for which they are used. What may be a suitable alternative for one application, will not necessarily be a suitable alternative for another. The timeline for implementing alternatives is estimated from 3 to 15 or more years after an alternative is found to be suitable. A detailed explanation of wet chemistry applications and the use of PFAS materials is found in Section 5. • Fluorocarbon uses in plasma (or “dry”) etch / wafer clean, and deposition. Silicon and its compounds are the fundamental components of silicon-based semiconductors; they provide the conductive properties of metal as well as being an insulator. Cutting edge semiconductor technology exists because of the unique properties of fluorocarbon gases which enable extremely high process yields at nanometre width scales. Perfluorocarbons and hydrofluorocarbons 2 are essential for directional etching and cleaning of silicon compounds. • Fluorocarbon uses in plasma (or “dry”) etch / wafer clean, and deposition. Silicon and its compounds are the fundamental components of silicon-based semiconductors; they provide the conductive properties of metal as well as being an insulator. Cutting edge semiconductor technology exists because of the unique properties of fluorocarbon gases which enable extremely high process yields at nanometre width scales. Perfluorocarbons and hydrofluorocarbons 2 are essential for directional etching and cleaning of silicon compounds. In the plasma etch/wafer clean application, there are no known viable substitutes for fluorocarbon chemistries due to the basic chemistry and physics of etching silicon and its compounds which are critical for forming semiconductor devices. While some non-PFAS alternatives have been identified for specific applications – for instance, the use of nitrogen trifluoride in chamber cleans – the alternatives may produce PFAS-containing emission by-products if carbon- containing films are present and may not be suitable for all applications. In some cases, alternatives, such as fluorine gas, may present additional worker and environmental safety concerns. The semiconductor industry has reduced the use of PFAS-containing chamber clean gases over a period of more than 30 years, due to concerns regarding greenhouse gases. While no fluorine-free alternatives have been identified that meet manufacturing needs, the air emissions of PFCs and HFCs have been significantly reduced through industry level best practice initiatives. Alternatives would require a fundamental reinvention of semiconductor devices to replace silicon as well as the process of fabricating semiconductors. A detailed explanation of fluorocarbon gas applications and the use of PFAS materials is found in Section 6. In the plasma etch/wafer clean application, there are no known viable substitutes for fluorocarbon chemistries due to the basic chemistry and physics of etching silicon and its compounds which are critical for forming semiconductor devices. While some non-PFAS alternatives have been identified for specific applications – for instance, the use of nitrogen trifluoride in chamber cleans – the alternatives may produce PFAS-containing emission by-products if carbon- containing films are present and may not be suitable for all applications. In some cases, alternatives, such as fluorine gas, may present additional worker and environmental safety concerns. The semiconductor industry has reduced the use of PFAS-containing chamber clean gases over a period of more than 30 years, due to concerns regarding greenhouse gases. While no fluorine-free alternatives have been identified that meet manufacturing needs, the air emissions of PFCs and HFCs have been significantly reduced through industry level best practice initiatives. Alternatives would require a fundamental reinvention of semiconductor devices to replace silicon as well as the process of fabricating semiconductors. A detailed explanation of fluorocarbon gas applications and the use of PFAS materials is found in Section 6. • Fluorinated heat transfer fluids in use include refrigerants and liquid fluorinated heat transfer fluids (F-HTF) to meet operational temperature requirements in the manufacturing processes and device test applications. Semiconductor devices are tested under a range of conditions to ensure device integrity. Burn-in, thermal shock, and device reliability testing use F-HTFs to ensure that semiconductors can be used within the customers’ requirements – including but not limited to aerospace and medical device requirements. F-HTFs provide the unique 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. PFAS-free alternatives to F-HTF, such as glycol/water, require the complete re-design of SMRE in the limited number of applications where these can be used. For the remaining cases suitable ______ 2 Such as octafluorocyclopentene, octafluoro-2-butene, hexafluoro-1,3-butadiene, octafluoropropane, hexafluoroethane and carbon tetrafluoride. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 6 • Fluorinated heat transfer fluids in use include refrigerants and liquid fluorinated heat transfer fluids (F-HTF) to meet operational temperature requirements in the manufacturing processes and device test applications. Semiconductor devices are tested under a range of conditions to ensure device integrity. Burn-in, thermal shock, and device reliability testing use F-HTFs to ensure that semiconductors can be used within the customers’ requirements – including but not limited to aerospace and medical device requirements. F-HTFs provide the unique 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. PFAS-free alternatives to F-HTF, such as glycol/water, require the complete re-design of SMRE in the limited number of applications where these can be used. For the remaining cases suitable ______ 2 Such as octafluorocyclopentene, octafluoro-2-butene, hexafluoro-1,3-butadiene, octafluoropropane, hexafluoroethane and carbon tetrafluoride. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 6 214 The Impact of a Potential PFAS Restriction on the Semiconductor Sector alternative materials have not been invented yet which offer the required technical performance. Key attributes include high boiling points, low pour points, low kinematic viscosity (fluidity) at working temperatures and lower operating temperatures, electrical non-conductivity, compatible with all materials of construction, suitable toxicity/flammability ratings and the prevention of contamination. This unique combination of properties is what enables every manufacturing step to be virtually perfect, with yields well above 99%, which is essential due to the thousands of process steps involved in semiconductor manufacturing. 214 The Impact of a Potential PFAS Restriction on the Semiconductor Sector alternative materials have not been invented yet which offer the required technical performance. Key attributes include high boiling points, low pour points, low kinematic viscosity (fluidity) at working temperatures and lower operating temperatures, electrical non-conductivity, compatible with all materials of construction, suitable toxicity/flammability ratings and the prevention of contamination. This unique combination of properties is what enables every manufacturing step to be virtually perfect, with yields well above 99%, which is essential due to the thousands of process steps involved in semiconductor manufacturing. In the limited number of instances where alternatives are available, from 8 to more than 14 years is required to implement needed equipment redesign and infrastructure installation. A similar timeline is also required for the substitution of refrigerants within process equipment chillers. Where there are currently no alternatives, an alternative would need to be invented and then an additional 5 to more than 15 years would be required to implement (although this could be significantly longer depending on the number of affected cooling systems at a single manufacturing facility). For PFAS- free thermal test methods, once an alternative has been invented from 8 to more than 14 years would be required to implement (although this could be significantly longer if a new method is required). A detailed explanation of the uses of fluorinated heat transfer and thermal test fluids is found in Section 7. In the limited number of instances where alternatives are available, from 8 to more than 14 years is required to implement needed equipment redesign and infrastructure installation. A similar timeline is also required for the substitution of refrigerants within process equipment chillers. Where there are currently no alternatives, an alternative would need to be invented and then an additional 5 to more than 15 years would be required to implement (although this could be significantly longer depending on the number of affected cooling systems at a single manufacturing facility). For PFAS- free thermal test methods, once an alternative has been invented from 8 to more than 14 years would be required to implement (although this could be significantly longer if a new method is required). A detailed explanation of the uses of fluorinated heat transfer and thermal test fluids is found in Section 7. • Semiconductor assembly, test, and packaging are processes that occur after the semiconductor devices are built on the silicon wafer. A semiconductor package encloses one or more semiconductor devices (also known as die or integrated circuits), protecting the device from the environment. Assembly, test, and packaging processes include the processes of die test, wafer grind, wafer mount, wafer saw, die bond, die wire, underfill, mold, encapsulate, and final semiconductor packaging and device test. Assembly, test, and packaging also has the key function of preparing the semiconductor package so that it can connect to customers' products. • Semiconductor assembly, test, and packaging are processes that occur after the semiconductor devices are built on the silicon wafer. A semiconductor package encloses one or more semiconductor devices (also known as die or integrated circuits), protecting the device from the environment. Assembly, test, and packaging processes include the processes of die test, wafer grind, wafer mount, wafer saw, die bond, die wire, underfill, mold, encapsulate, and final semiconductor packaging and device test. Assembly, test, and packaging also has the key function of preparing the semiconductor package so that it can connect to customers' products. As packaging becomes more and more complex due to decreased semiconductor size, increased processing speed, and/or increased packaging complexity, the combination of properties necessary are frequently only found in the fluorinated hydrocarbon family. PFAS materials are used to ensure hermetic sealing against moisture, provide environmental and mechanical isolation and stability, to reduce stress on solder joints increasing device durability, and other product reliability purposes. PFAS are used in some packaging fluxes, surfactants, adhesives and encapsulants and as anti- stiction agents inside specialty microelectromechanical system (MEMS) packages. While more simple uses like packaging fluxes are expected to take more than 5 years to qualify an alternative, the vast majority of package related uses of adhesives have sought alternatives for 18 years without success and alternatives are expected to take 20 years or more to identify and implement. As packaging becomes more and more complex due to decreased semiconductor size, increased processing speed, and/or increased packaging complexity, the combination of properties necessary are frequently only found in the fluorinated hydrocarbon family. PFAS materials are used to ensure hermetic sealing against moisture, provide environmental and mechanical isolation and stability, to reduce stress on solder joints increasing device durability, and other product reliability purposes. PFAS are used in some packaging fluxes, surfactants, adhesives and encapsulants and as anti- stiction agents inside specialty microelectromechanical system (MEMS) packages. While more simple uses like packaging fluxes are expected to take more than 5 years to qualify an alternative, the vast majority of package related uses of adhesives have sought alternatives for 18 years without success and alternatives are expected to take 20 years or more to identify and implement. Changes to assembly package materials due to their interactions with both the silicon die and the end customer product require additional customer product change notification, product requalification and approval, which require additional time to the timeframes listed above. Customer requalification activities are required to start at least 1-2 years prior to change, with some applications requiring 6+ years. A detailed explanation of semiconductor assembly, test, and packaging applications and the use of PFAS materials is found in Section 8. • Pump Fluids & Lubricants use PFAS such as polyfluorinated polyether oils (PFPE), or polytetrafluoroethylene (PTFE) micropowders which are critical for use in semiconductor manufacturing. Although non-PFAS lubricants such as silicone oil exist, they are unable to meet critical performance requirements such as inertness when used in harsh conditions, low off-gassing and particle generation which is important due to the cleanliness requirements during manufacturing. In addition to this they have a higher likelihood for increased failure rates and human health and safety impacts. As such it is expected that more than 10 years would be required to substitute PFAS lubricants in Changes to assembly package materials due to their interactions with both the silicon die and the end customer product require additional customer product change notification, product requalification and approval, which require additional time to the timeframes listed above. Customer requalification activities are required to start at least 1-2 years prior to change, with some applications requiring 6+ years. A detailed explanation of semiconductor assembly, test, and packaging applications and the use of PFAS materials is found in Section 8. • Pump Fluids & Lubricants use PFAS such as polyfluorinated polyether oils (PFPE), or polytetrafluoroethylene (PTFE) micropowders which are critical for use in semiconductor manufacturing. Although non-PFAS lubricants such as silicone oil exist, they are unable to meet critical performance requirements such as inertness when used in harsh conditions, low off-gassing and particle generation which is important due to the cleanliness requirements during manufacturing. In addition to this they have a higher likelihood for increased failure rates and human health and safety impacts. As such it is expected that more than 10 years would be required to substitute PFAS lubricants in © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 7 215 The Impact of a Potential PFAS Restriction on the Semiconductor Sector general applications and more than 25 years for lubricants used in photolithography due to the need for ultraviolet (UV) stability. A detailed explanation of semiconductor uses of PFAS-containing lubricants is found in Section 9. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 7 215 The Impact of a Potential PFAS Restriction on the Semiconductor Sector general applications and more than 25 years for lubricants used in photolithography due to the need for ultraviolet (UV) stability. A detailed explanation of semiconductor uses of PFAS-containing lubricants is found in Section 9. • Articles PFAS-containing articles are critical to the manufacture of semiconductor devices. SMRE and facility support equipment use millions of articles to enable the technical requirements of clean, and safe manufacturing. Fluoropolymers are a subclass of PFAS that possess a unique set of characteristics that are required for many of the critical articles, including inertness, purity, low flammability, temperature stability, resistance to chemical permeation, low coefficient of friction, optical properties, mechanical properties, contamination control, electrical properties, processability, resistance to bacterial growth, and long service life (>25 years). SMRE and facility support equipment are exposed to environments that include corrosive, high temperature, flammable and toxic materials and therefore, the use of fluoropolymers is often required by safety and insurance guidelines. To maintain the cleanroom and assembly test purity requirements, fluoropolymers are also needed to prevent particle generation, which is detrimental to semiconductor production yield. • Articles PFAS-containing articles are critical to the manufacture of semiconductor devices. SMRE and facility support equipment use millions of articles to enable the technical requirements of clean, and safe manufacturing. Fluoropolymers are a subclass of PFAS that possess a unique set of characteristics that are required for many of the critical articles, including inertness, purity, low flammability, temperature stability, resistance to chemical permeation, low coefficient of friction, optical properties, mechanical properties, contamination control, electrical properties, processability, resistance to bacterial growth, and long service life (>25 years). SMRE and facility support equipment are exposed to environments that include corrosive, high temperature, flammable and toxic materials and therefore, the use of fluoropolymers is often required by safety and insurance guidelines. To maintain the cleanroom and assembly test purity requirements, fluoropolymers are also needed to prevent particle generation, which is detrimental to semiconductor production yield. Possible PFAS-free alternatives would require total reinvention for many applications. Depending on the material and its application, more than 15 years are needed to implement a suitable alternative. Additionally, the semiconductor industry’s supply chain is both specific and complex as well as generic and multi-layered, depending on the article or equipment supplied. Substitutions require an industry effort to drive change throughout the supply chain. A detailed explanation of semiconductor PFAS-containing articles is found in Section 10. More detailed technical information can be found in the respective white papers and case study reports written by the Semiconductor PFAS Consortium (listed in Table 1-2). Possible PFAS-free alternatives would require total reinvention for many applications. Depending on the material and its application, more than 15 years are needed to implement a suitable alternative. Additionally, the semiconductor industry’s supply chain is both specific and complex as well as generic and multi-layered, depending on the article or equipment supplied. Substitutions require an industry effort to drive change throughout the supply chain. A detailed explanation of semiconductor PFAS-containing articles is found in Section 10. More detailed technical information can be found in the respective white papers and case study reports written by the Semiconductor PFAS Consortium (listed in Table 1-2). It is worthwhile noting that the timelines outlined above have a significant degree of uncertainty. For many of the substances there are no alternative theoretical material chemistries to use as a basis for invention and a whole new area of chemistry and/or technology will be required. There are also concerns that a change process as large as designing out all PFAS has never taken place and the timelines are based on the time to undertake a single change. As highlighted above, there may be interactions between multiple stages in processing which will need to be explored. There will also be limitations on how many suitably knowledgeable people are available given the magnitude and complexity of the task at hand. As such, the timelines could easily be much longer than those estimated. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 8 216 The Impact of a Potential PFAS Restriction on the Semiconductor Sector It is worthwhile noting that the timelines outlined above have a significant degree of uncertainty. For many of the substances there are no alternative theoretical material chemistries to use as a basis for invention and a whole new area of chemistry and/or technology will be required. There are also concerns that a change process as large as designing out all PFAS has never taken place and the timelines are based on the time to undertake a single change. As highlighted above, there may be interactions between multiple stages in processing which will need to be explored. There will also be limitations on how many suitably knowledgeable people are available given the magnitude and complexity of the task at hand. As such, the timelines could easily be much longer than those estimated. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 8 216 The Impact of a Potential PFAS Restriction on the Semiconductor Sector TABLE OF CONTENTS Page EXECUTIVE SUMMARY 3 1 INTRODUCTION 14 1.1 Reporting Methodology 15 1.1.1 Terminology used within the report 16 2 SEMICONDUCTOR TECHNOLOGY 17 2.1 Importance of Semiconductors to Society 18 2.2 Semiconductor Manufacture and Supply Chain 20 2.3 Importance of Innovation 21 2.4 Importance of Yield 25 2.5 Essential Use 26 TABLE OF CONTENTS Page EXECUTIVE SUMMARY 3 1 INTRODUCTION 14 1.1 Reporting Methodology 15 1.1.1 Terminology used within the report 16 2 SEMICONDUCTOR TECHNOLOGY 17 2.1 Importance of Semiconductors to Society 18 2.2 Semiconductor Manufacture and Supply Chain 20 2.3 Importance of Innovation 21 2.4 Importance of Yield 25 2.5 Essential Use 26 3 PFAS SUBSTITUTION OPPORTUNITIES AND CHALLENGES 26 3.1 PFAS substance identification 26 3.2 Timeframes for substitution 27 3.3 Incentives for PFAS substitution 29 3.4 Challenges to substitution 30 3.4.1 Regrettable Substitution 30 4 PHOTOLITHOGRAPHY USES 32 4.1 Photoacid Generators (PAG) 37 4.2 Top antireflective coatings (TARCs) 39 4.3 Immersion Barriers 39 4.4 Surfactants 40 4.5 Dielectric Polymers: polyimides (PI) and polybenzoxazoles (PBO) 40 4.6 Environmental Considerations in Photolithography 41 3 PFAS SUBSTITUTION OPPORTUNITIES AND CHALLENGES 26 3.1 PFAS substance identification 26 3.2 Timeframes for substitution 27 3.3 Incentives for PFAS substitution 29 3.4 Challenges to substitution 30 3.4.1 Regrettable Substitution 30 4 PHOTOLITHOGRAPHY USES 32 4.1 Photoacid Generators (PAG) 37 4.2 Top antireflective coatings (TARCs) 39 4.3 Immersion Barriers 39 4.4 Surfactants 40 4.5 Dielectric Polymers: polyimides (PI) and polybenzoxazoles (PBO) 40 4.6 Environmental Considerations in Photolithography 41 5 WET CHEMISTRY USES 43 5.1 Wet Chemical Processing 44 5.2 Surfactants 46 5.2.1 Wet Clean applications 47 5.2.2 Wet Chemical Etching 48 5.2.3 Chemical mechanical planarization (CMP) and Post CMP Cleans 48 5.2.4 Metal Plating 48 5.3 Environmental Considerations in Wet Chemistries 52 6 FLUOROCARBON USES IN PLASMA ETCH/WAFER CLEAN AND DEPOSITION 53 6.1 Dry Etching 53 6.2 Plasma Cleaning 54 6.3 Chemical Vapour Deposition/Atomic Layer Deposition of Organometallics 54 6.4 Other critical uses of PFCs and HFCs 55 5 WET CHEMISTRY USES 43 5.1 Wet Chemical Processing 44 5.2 Surfactants 46 5.2.1 Wet Clean applications 47 5.2.2 Wet Chemical Etching 48 5.2.3 Chemical mechanical planarization (CMP) and Post CMP Cleans 48 5.2.4 Metal Plating 48 5.3 Environmental Considerations in Wet Chemistries 52 6 FLUOROCARBON USES IN PLASMA ETCH/WAFER CLEAN AND DEPOSITION 53 6.1 Dry Etching 53 6.2 Plasma Cleaning 54 6.3 Chemical Vapour Deposition/Atomic Layer Deposition of Organometallics 54 6.4 Other critical uses of PFCs and HFCs 55 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 9 217 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 6.5 Environmental Considerations in PFCs and HFCs 57 7 HEAT TRANSFER FLUID USES 58 7.1 Alternatives 65 7.1.1 Alternatives to Liquid HTF 65 7.1.2 Alternatives to Refrigerants 66 7.2 Environmental Considerations for use of F-HTFs 66 8 ASSEMBLY, TEST, PACKAGING AND SUBSTRATE MATERIALS USES 67 8.1 Impact of change 73 8.2 Environmental considerations for PFAS packaging materials 76 9 PUMP FLUIDS & LUBRICANTS USES 77 9.1 Challenges with non-PFAS lubricants 77 9.2 Environmental Considerations in Lubricants 80 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 9 217 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 6.5 Environmental Considerations in PFCs and HFCs 57 7 HEAT TRANSFER FLUID USES 58 7.1 Alternatives 65 7.1.1 Alternatives to Liquid HTF 65 7.1.2 Alternatives to Refrigerants 66 7.2 Environmental Considerations for use of F-HTFs 66 8 ASSEMBLY, TEST, PACKAGING AND SUBSTRATE MATERIALS USES 67 8.1 Impact of change 73 8.2 Environmental considerations for PFAS packaging materials 76 9 PUMP FLUIDS & LUBRICANTS USES 77 9.1 Challenges with non-PFAS lubricants 77 9.2 Environmental Considerations in Lubricants 80 10 ARTICLE USES 82 10.1 Required Characteristics 83 10.2 Alternatives 86 10.2.1 Examples of unsuccessful PFAS-free article trials 87 10.3 Environmental Considerations for Articles 88 11 ENVIRONMENTAL IMPACT, END OF LIFE AND WASTE CONSIDERATIONS 89 11.1 Air Emissions Control and Abatement 89 11.2 Wastewater Treatment 90 11.3 Waste Disposal 90 11.4 Environmental Impacts of Non-PFAS Use 90 12 SUMMARY OF FINDINGS 92 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 10 218 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 10 ARTICLE USES 82 10.1 Required Characteristics 83 10.2 Alternatives 86 10.2.1 Examples of unsuccessful PFAS-free article trials 87 10.3 Environmental Considerations for Articles 88 11 ENVIRONMENTAL IMPACT, END OF LIFE AND WASTE CONSIDERATIONS 89 11.1 Air Emissions Control and Abatement 89 11.2 Wastewater Treatment 90 11.3 Waste Disposal 90 11.4 Environmental Impacts of Non-PFAS Use 90 12 SUMMARY OF FINDINGS 92 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 10 218 The Impact of a Potential PFAS Restriction on the Semiconductor Sector LIST OF TABLES Table 1-1 PFAS Semiconductor PFAS Consortium members business breakdown. 14 Table 1-2 Semiconductor PFAS Consortium papers. 15 Table 4-1 Key photolithography PFAS uses and technical criteria. 33 Table 4-2 PFAS use in photolithography according to exposure technology. 34 Table 4-3 Photolithography potential PFAS replacement viability and timeline uses and technical criteria. 35 Table 4-4 Comparison of the performance of PAGs versus alternatives. 38 Table 4-5 Results of SIA 2021 sales survey and an example release mass balance. 42 Table 5-1 Examples of etches and cleaning operations utilising PFAS. 50 Table 6-1 Examples of the manufacturing processes using PFC and HFC gases. 55 Table 7-1 Examples of HTFs utilising PFAS. 62 Table 8-1 Examples of the packaging products utilising PFAS. 74 Table 9-1 Examples of the products utilising PFAS lubricants. 78 Table 10-1 Examples of articles utilising PFAS where no alternatives have been identified to date. 85 LIST OF TABLES Table 1-1 PFAS Semiconductor PFAS Consortium members business breakdown. 14 Table 1-2 Semiconductor PFAS Consortium papers. 15 Table 4-1 Key photolithography PFAS uses and technical criteria. 33 Table 4-2 PFAS use in photolithography according to exposure technology. 34 Table 4-3 Photolithography potential PFAS replacement viability and timeline uses and technical criteria. 35 Table 4-4 Comparison of the performance of PAGs versus alternatives. 38 Table 4-5 Results of SIA 2021 sales survey and an example release mass balance. 42 Table 5-1 Examples of etches and cleaning operations utilising PFAS. 50 Table 6-1 Examples of the manufacturing processes using PFC and HFC gases. 55 Table 7-1 Examples of HTFs utilising PFAS. 62 Table 8-1 Examples of the packaging products utilising PFAS. 74 Table 9-1 Examples of the products utilising PFAS lubricants. 78 Table 10-1 Examples of articles utilising PFAS where no alternatives have been identified to date. 85 LIST OF FIGURES Figure 0-1 General overview of the semiconductor manufacturing process steps, operations, and systems evaluated by the Semiconductor PFAS Consortium. 5 Figure 2-1 Global semiconductor demand by end-market, in USD. 17 Figure 2-2 Illustrative (non-comprehensive) companies involved in different stages of the value chain. 18 Figure 2-3 Technologies enabled by semiconductors. 19 Figure 2-4 Schematic of semiconductor supply chain. 20 Figure 2-5 Sample of semiconductor products: exponential decrease in critical dimensions over time (and associated lithographic wavelengths). 22 Figure 2-6 Comparison of various biological assemblies and technological device. 23 Figure 2-7 Semiconductor R&D expenditure as a percentage of sales. 24 Figure 2-8 Moore’s Law- exponential technological advancement through time. 25 Figure 3-1 Illustrative timeline for qualification of a single alternative. 28 Figure 5-1 Conventional simple wet etch application. 44 Figure 5-2 3D NAND flash memory manufacturing process and wet lateral etching. Each layer is on the order of 25-40 nm thick, and 4,000 nm deep. 45 Figure 5-3 Diagram illustrating the capillary forces exerted by a wetting fluid on the walls of the material holding the fluid. 46 Figure 5-4 Image of line collapse that has been caused by capillary forces. 46 Figure 8-1 An example package, with many other configurations possible. 68 Figure 8-2 An example MEMS package. 68 Figure 8-3 Timeline for the semiconductor packaging showing the complexity of packaging increasing over time. 69 Figure 8-4 Status of the Advanced Packaging Industry including multiple types of packaging and materials. 70 Figure 10-1 ASML Latest Extreme Ultraviolet Photolithography Exposure Tool. 83 LIST OF FIGURES Figure 0-1 General overview of the semiconductor manufacturing process steps, operations, and systems evaluated by the Semiconductor PFAS Consortium. 5 Figure 2-1 Global semiconductor demand by end-market, in USD. 17 Figure 2-2 Illustrative (non-comprehensive) companies involved in different stages of the value chain. 18 Figure 2-3 Technologies enabled by semiconductors. 19 Figure 2-4 Schematic of semiconductor supply chain. 20 Figure 2-5 Sample of semiconductor products: exponential decrease in critical dimensions over time (and associated lithographic wavelengths). 22 Figure 2-6 Comparison of various biological assemblies and technological device. 23 Figure 2-7 Semiconductor R&D expenditure as a percentage of sales. 24 Figure 2-8 Moore’s Law- exponential technological advancement through time. 25 Figure 3-1 Illustrative timeline for qualification of a single alternative. 28 Figure 5-1 Conventional simple wet etch application. 44 Figure 5-2 3D NAND flash memory manufacturing process and wet lateral etching. Each layer is on the order of 25-40 nm thick, and 4,000 nm deep. 45 Figure 5-3 Diagram illustrating the capillary forces exerted by a wetting fluid on the walls of the material holding the fluid. 46 Figure 5-4 Image of line collapse that has been caused by capillary forces. 46 Figure 8-1 An example package, with many other configurations possible. 68 Figure 8-2 An example MEMS package. 68 Figure 8-3 Timeline for the semiconductor packaging showing the complexity of packaging increasing over time. 69 Figure 8-4 Status of the Advanced Packaging Industry including multiple types of packaging and materials. 70 Figure 10-1 ASML Latest Extreme Ultraviolet Photolithography Exposure Tool. 83 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 11 219 The Impact of a Potential PFAS Restriction on the Semiconductor Sector © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 11 219 The Impact of a Potential PFAS Restriction on the Semiconductor Sector ABBREVIATIONS AND ACRONYMS ARC Antireflective coating PCB Printed circuit board ATPS Assembly, testing, and packaging PCTFE Polychlorotrifluoroethylene BARC Bottom Antireflective Coating BHF Buffered hydrofluoric acid etch PDMS Polydimethylsiloxane fluids BOE Buffered oxide etch PFA Perfluoroalkoxy alkanes C4 Per and polyfluorinated alkyl substances PFAS Per- and polyfluoroalkyl compounds or with a chain length of 4 carbons or less. substances CARs Chemically Amplified Resists PFC Perfluorocarbons CFCs Chlorofluorocarbons PFEPE Poly fluoro ethyl propyl ether grease CMP Chemical Mechanical Planarization PFOA Perfluorooctanoic acid and its salts (a chemical family of substances) CN5 Pentacyanocyclopentadiene PFOS Perfluoro octane sulfonic acid and its salts (a chemical family of substances) CTE Coefficient of thermal expansion PFPE Polyfluorinated polyether oils CZ Czochralski crystal growth process (for PI Polyimides and their precursors making silicon ingot that silicon wafers are then cut from) D4, D5, D6 cyclosiloxanes containing 4, 5 and 6 POU Point of use emission abatement system - ring silicon atoms in the ring respectively. E-beam Electron-beam processing, also called PTFE Polytetrafluoroethylene electron irradiation EG/DI Ethylene glycol and deionised water PVDF Polyvinylidene fluoride ETFE Ethyl tetrafluoroethylene R&D Research and development EU European Union RINA RINA Tech UK Limited EUV Extreme Ultraviolet, a type of SDS Safety Data Sheet photoactivation for photoacid generators Fab / Fabs Fabrication (facility(ies)) SEMI Global industry trade association for electronics manufacturing and design FEP Fluorinated ethylene propylene SIA Semiconductor Industry Association FFKM American standard (ASTM) short form SiARC Silicon anti-reflective coating name for perfluoro elastomers or perfluoro rubber material. Also called Kalrez™. F-HTF Liquid fluorinated heat transfer fluids SiC Silicon Carbide FKM American standard (ASTM) short form SMRE Semiconductor manufacturing and name for Fluoroelastomers or fluoro related equipment rubber material. Also called Viton™. HDPE High density polyethylene SVHC Substance of Very High Concern HFC Hydrofluorocarbon TARC Top Anti reflective coating HFE Hydrofluoroethers TIM Thermal interface materials HFO Hydrofluoroolefins UPW Ultra-pure water HTF Heat transfer fluid US / United States of America USA ABBREVIATIONS AND ACRONYMS ARC Antireflective coating PCB Printed circuit board ATPS Assembly, testing, and packaging PCTFE Polychlorotrifluoroethylene BARC Bottom Antireflective Coating BHF Buffered hydrofluoric acid etch PDMS Polydimethylsiloxane fluids BOE Buffered oxide etch PFA Perfluoroalkoxy alkanes C4 Per and polyfluorinated alkyl substances PFAS Per- and polyfluoroalkyl compounds or with a chain length of 4 carbons or less. substances CARs Chemically Amplified Resists PFC Perfluorocarbons CFCs Chlorofluorocarbons PFEPE Poly fluoro ethyl propyl ether grease CMP Chemical Mechanical Planarization PFOA Perfluorooctanoic acid and its salts (a chemical family of substances) CN5 Pentacyanocyclopentadiene PFOS Perfluoro octane sulfonic acid and its salts (a chemical family of substances) CTE Coefficient of thermal expansion PFPE Polyfluorinated polyether oils CZ Czochralski crystal growth process (for PI Polyimides and their precursors making silicon ingot that silicon wafers are then cut from) D4, D5, D6 cyclosiloxanes containing 4, 5 and 6 POU Point of use emission abatement system - ring silicon atoms in the ring respectively. E-beam Electron-beam processing, also called PTFE Polytetrafluoroethylene electron irradiation EG/DI Ethylene glycol and deionised water PVDF Polyvinylidene fluoride ETFE Ethyl tetrafluoroethylene R&D Research and development EU European Union RINA RINA Tech UK Limited EUV Extreme Ultraviolet, a type of SDS Safety Data Sheet photoactivation for photoacid generators Fab / Fabs Fabrication (facility(ies)) SEMI Global industry trade association for electronics manufacturing and design FEP Fluorinated ethylene propylene SIA Semiconductor Industry Association FFKM American standard (ASTM) short form SiARC Silicon anti-reflective coating name for perfluoro elastomers or perfluoro rubber material. Also called Kalrez™. F-HTF Liquid fluorinated heat transfer fluids SiC Silicon Carbide FKM American standard (ASTM) short form SMRE Semiconductor manufacturing and name for Fluoroelastomers or fluoro related equipment rubber material. Also called Viton™. HDPE High density polyethylene SVHC Substance of Very High Concern HFC Hydrofluorocarbon TARC Top Anti reflective coating HFE Hydrofluoroethers TIM Thermal interface materials HFO Hydrofluoroolefins UPW Ultra-pure water HTF Heat transfer fluid US / United States of America USA © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 12 220 The Impact of a Potential PFAS Restriction on the Semiconductor Sector HVM High Volume Manufacturing US EPA United States Environmental Protection Agency IPA Isopropyl alcohol USD United States Dollar MEMS Microelectromechanical systems / UV Ultra-violet micromachines PAG / Photoacid generators WSC World Semiconductor Council PAGs PBO Polybenzoxazoles and their precursors WSTS World Semiconductor Trade Statistics © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 13 221 The Impact of a Potential PFAS Restriction on the Semiconductor Sector © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 12 220 The Impact of a Potential PFAS Restriction on the Semiconductor Sector HVM High Volume Manufacturing US EPA United States Environmental Protection Agency IPA Isopropyl alcohol USD United States Dollar MEMS Microelectromechanical systems / UV Ultra-violet micromachines PAG / Photoacid generators WSC World Semiconductor Council PAGs PBO Polybenzoxazoles and their precursors WSTS World Semiconductor Trade Statistics © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 13 221 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 1 INTRODUCTION RINA Tech UK Limited (RINA) was requested by the Semiconductor PFAS Consortium to gather information from members to provide evidence for the semiconductor sector to support information gathering considering the potentials impact of PFAS restriction. The Semiconductor PFAS Consortium comprises thirty-nine Member Companies representing 69% of worldwide semiconductor manufacturing capital expenditures, as well as 70% of global sales of semiconductor equipment in 2021. Semiconductor device and equipment manufacturing operations performed by Semiconductor PFAS Consortium members represented over $400 billion dollars in revenue and directly provide over 500,000 jobs worldwide. The Semiconductor PFAS Consortium was formed to collect the technical data needed to better inform public policy and legislation, including the: • Identification of critical uses of PFAS, • Application of the pollution prevention hierarchy to, where possible: reduce PFAS consumption or eliminate use, identify alternatives, and minimise and control emissions, • Identification of research needs, and • Development of socioeconomic impact assessments. Table 1-1 PFAS Semiconductor PFAS Consortium members business breakdown. 1 INTRODUCTION RINA Tech UK Limited (RINA) was requested by the Semiconductor PFAS Consortium to gather information from members to provide evidence for the semiconductor sector to support information gathering considering the potentials impact of PFAS restriction. The Semiconductor PFAS Consortium comprises thirty-nine Member Companies representing 69% of worldwide semiconductor manufacturing capital expenditures, as well as 70% of global sales of semiconductor equipment in 2021. Semiconductor device and equipment manufacturing operations performed by Semiconductor PFAS Consortium members represented over $400 billion dollars in revenue and directly provide over 500,000 jobs worldwide. The Semiconductor PFAS Consortium was formed to collect the technical data needed to better inform public policy and legislation, including the: • Identification of critical uses of PFAS, • Application of the pollution prevention hierarchy to, where possible: reduce PFAS consumption or eliminate use, identify alternatives, and minimise and control emissions, • Identification of research needs, and • Development of socioeconomic impact assessments. Table 1-1 PFAS Semiconductor PFAS Consortium members business breakdown. % of market Number of represented in Type of Business Description Member Semiconductor Companies PFAS Consortium Semiconductor device design and manufacturing firms with operations in Europe, Asia, and North America. Companies include fab, assembly, test, and 69% of worldwide Semiconductor packaging operations for individual device capital Device 10 manufacturers as well as foundries. expenditures in Manufacturers Semiconductor devices include logic and memory 2021 chips, microelectromechanical (MEMs) and image sensor devices. Specialised semiconductor manufacturing equipment manufacturers and suppliers with 70% of global Semiconductor operations in Europe, Asia, and North America. sales of Manufacturing Companies include manufacturing equipment for 8 semiconductor Equipment fab, assembly, and device packaging as well as equipment in Suppliers facility support and emissions control equipment. 2021 % of market Number of represented in Type of Business Description Member Semiconductor Companies PFAS Consortium Semiconductor device design and manufacturing firms with operations in Europe, Asia, and North America. Companies include fab, assembly, test, and 69% of worldwide Semiconductor packaging operations for individual device capital Device 10 manufacturers as well as foundries. expenditures in Manufacturers Semiconductor devices include logic and memory 2021 chips, microelectromechanical (MEMs) and image sensor devices. Specialised semiconductor manufacturing equipment manufacturers and suppliers with 70% of global Semiconductor operations in Europe, Asia, and North America. sales of Manufacturing Companies include manufacturing equipment for 8 semiconductor Equipment fab, assembly, and device packaging as well as equipment in Suppliers facility support and emissions control equipment. 2021 Manufacturers and suppliers of specialised semiconductor process chemicals and formulations Chemical / as well as semiconductor material suppliers. 21 Varies Material Suppliers Chemical / Material suppliers provide: Raw materials, fab chemicals and formulations, device packaging materials, and facility materials. 3 ______ 3 These materials include, but are not limited to photoresists, chemical mechanical planarization slurries, deposition and etching gases, wet clean formulations, chip package substrates, packaging encapsulant and die attach materials, as well as specialised materials for ultrapure water systems and emissions control and abatement. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 14 222 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Manufacturers and suppliers of specialised semiconductor process chemicals and formulations Chemical / as well as semiconductor material suppliers. 21 Varies Material Suppliers Chemical / Material suppliers provide: Raw materials, fab chemicals and formulations, device packaging materials, and facility materials. 3 ______ 3 These materials include, but are not limited to photoresists, chemical mechanical planarization slurries, deposition and etching gases, wet clean formulations, chip package substrates, packaging encapsulant and die attach materials, as well as specialised materials for ultrapure water systems and emissions control and abatement. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 14 222 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 1.1 Reporting Methodology PFAS are used in chemical formulations, components of manufacturing process tools, facilities infrastructure and packaging used to make the semiconductor devices that are integral to our modern world. Given the widespread uses of PFAS in Semiconductor PFAS Consortium members applications, this report has grouped PFAS uses into similar groups to aid in the understanding of this complex picture. The following groupings of use have been used in this report: • Photolithography - A crucial phase in the process of manufacturing semiconductors, of transferring a component or circuit pattern by applying a photoresist and exposure. • Wet Chemistry - Liquid substances used in processes such as wet etching, cleaning, chemical mechanical planarization, surface modification treatment, and other liquid applications in chip manufacturing. • Fluorocarbon uses in plasma etch and deposition - Gases used in plasma etching and chamber cleaning, and metalorganics used in deposition. • Heat Transfer Fluids - Coolants used in the manufacture of semiconductors, during the testing of devices, and in equipment such as chillers. • Assembly, Test, Packaging, and substrate material uses - Materials used to test and attach individual semiconductor devices into chip packages. 1.1 Reporting Methodology PFAS are used in chemical formulations, components of manufacturing process tools, facilities infrastructure and packaging used to make the semiconductor devices that are integral to our modern world. Given the widespread uses of PFAS in Semiconductor PFAS Consortium members applications, this report has grouped PFAS uses into similar groups to aid in the understanding of this complex picture. The following groupings of use have been used in this report: • Photolithography - A crucial phase in the process of manufacturing semiconductors, of transferring a component or circuit pattern by applying a photoresist and exposure. • Wet Chemistry - Liquid substances used in processes such as wet etching, cleaning, chemical mechanical planarization, surface modification treatment, and other liquid applications in chip manufacturing. • Fluorocarbon uses in plasma etch and deposition - Gases used in plasma etching and chamber cleaning, and metalorganics used in deposition. • Heat Transfer Fluids - Coolants used in the manufacture of semiconductors, during the testing of devices, and in equipment such as chillers. • Assembly, Test, Packaging, and substrate material uses - Materials used to test and attach individual semiconductor devices into chip packages. • Pump Fluids & Lubricants - To provide smooth and precise functionality of fabrication and processing equipment while preventing the generation of particles and outgassing (under vacuum). • Articles - Physical materials used in the construction of semiconductor processing equipment, support equipment, facilities equipment, and infrastructure, and other purchased or produced items containing PFAS. Examples include components within a billion-dollar extreme ultra-violet (EUV) semiconductor lithography machine, plasma tool O-rings, ultra-pure water systems and piping, and environmental control systems such as lined ductwork and wet scrubbers. These PFAS articles are used during semiconductor manufacturing and also in forms which may be present in certain final products. This report outlines key PFAS uses which are indicative of the technical challenges faced by each use. In addition to this report, the Semiconductor PFAS Consortium has written seven white papers (listed in Table 1-2) and three case study reports to collectively address the principal areas in which fluorinated organic chemicals are used in semiconductor manufacturing, which has been utilised in writing this report. Table 1-2 Semiconductor PFAS Consortium papers. • Pump Fluids & Lubricants - To provide smooth and precise functionality of fabrication and processing equipment while preventing the generation of particles and outgassing (under vacuum). • Articles - Physical materials used in the construction of semiconductor processing equipment, support equipment, facilities equipment, and infrastructure, and other purchased or produced items containing PFAS. Examples include components within a billion-dollar extreme ultra-violet (EUV) semiconductor lithography machine, plasma tool O-rings, ultra-pure water systems and piping, and environmental control systems such as lined ductwork and wet scrubbers. These PFAS articles are used during semiconductor manufacturing and also in forms which may be present in certain final products. This report outlines key PFAS uses which are indicative of the technical challenges faced by each use. In addition to this report, the Semiconductor PFAS Consortium has written seven white papers (listed in Table 1-2) and three case study reports to collectively address the principal areas in which fluorinated organic chemicals are used in semiconductor manufacturing, which has been utilised in writing this report. Table 1-2 Semiconductor PFAS Consortium papers. Paper Type Paper Title Whitepaper Background on Semiconductor Manufacturing and PFAS Case Study PFOS and PFOA conversion to short chain PFAS used in the Semiconductor Manufacturing Case Study PFAS-Containing Photo-Acid Generators used in Semiconductor Manufacturing Case Study PFAS-Containing Surfactants used in Semiconductor Manufacturing Whitepaper PFAS-Containing Wet Chemistries used in Semiconductor Manufacturing PFAS-containing Fluorochemicals used in Semiconductor Manufacturing Plasma-enabled Etch Whitepaper and Deposition © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 15 223 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Paper Type Paper Title Whitepaper Background on Semiconductor Manufacturing and PFAS Case Study PFOS and PFOA conversion to short chain PFAS used in the Semiconductor Manufacturing Case Study PFAS-Containing Photo-Acid Generators used in Semiconductor Manufacturing Case Study PFAS-Containing Surfactants used in Semiconductor Manufacturing Whitepaper PFAS-Containing Wet Chemistries used in Semiconductor Manufacturing PFAS-containing Fluorochemicals used in Semiconductor Manufacturing Plasma-enabled Etch Whitepaper and Deposition © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 15 223 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Paper Type Paper Title PFAS-Containing Heat Transfer Fluids (HTF) PFAS-containing Heat Transfer Fluids used in Whitepaper Semiconductor Manufacturing PFAS-Containing Materials used in Semiconductor Manufacturing Assembly Test Packaging Whitepaper and Substrate processes Whitepaper PFAS-Containing Lubricants used in Semiconductor Manufacturing Whitepaper PFAS-Containing Articles used in Semiconductor Manufacturing The information shared by the Semiconductor PFAS Consortium membership in this report provides a snapshot at the point of the information being gathered. RINA devised a questionnaire which was circulated by the Semiconductor PFAS Consortium to its members. The responses from the questionnaire were collated and analysed for common themes, to give a representation of the whole membership. It is understood that many Semiconductor PFAS Consortium members are still developing their strategies and responses to PFAS concerns, and as such have not been able to answer all of the questions asked at this time. It is to be expected, therefore, that views may change or develop with time as more work is done, evidence is discovered, and as requirements emerge. Paper Type Paper Title PFAS-Containing Heat Transfer Fluids (HTF) PFAS-containing Heat Transfer Fluids used in Whitepaper Semiconductor Manufacturing PFAS-Containing Materials used in Semiconductor Manufacturing Assembly Test Packaging Whitepaper and Substrate processes Whitepaper PFAS-Containing Lubricants used in Semiconductor Manufacturing Whitepaper PFAS-Containing Articles used in Semiconductor Manufacturing The information shared by the Semiconductor PFAS Consortium membership in this report provides a snapshot at the point of the information being gathered. RINA devised a questionnaire which was circulated by the Semiconductor PFAS Consortium to its members. The responses from the questionnaire were collated and analysed for common themes, to give a representation of the whole membership. It is understood that many Semiconductor PFAS Consortium members are still developing their strategies and responses to PFAS concerns, and as such have not been able to answer all of the questions asked at this time. It is to be expected, therefore, that views may change or develop with time as more work is done, evidence is discovered, and as requirements emerge. 1.1.1 Terminology used within the report Where the term ‘No known alternative’ is used within this report it is meant that there is no known alternative chemistry or technology within the semiconductor industry and its supply chain that could be investigated as a replacement for this use at this time. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 16 224 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 1.1.1 Terminology used within the report Where the term ‘No known alternative’ is used within this report it is meant that there is no known alternative chemistry or technology within the semiconductor industry and its supply chain that could be investigated as a replacement for this use at this time. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 16 224 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 2 SEMICONDUCTOR TECHNOLOGY The overall global semiconductor market was valued at $440 billion in 2020 and increased to $555.9 billion in 2021, an increase of over 26.2% according to data from the World Semiconductor Trade Statistics (WSTS) 2021. In February 2023, the Semiconductor Industry Association (SIA) reported global semiconductor industry sales totalled $574 billion in 2022, the highest-ever annual total and an increase of 3.32% compared to the 2021 total of $555.9 billion. Figure 2-1 Global semiconductor demand by end-market, in USD. 4 Based on information from SIA 5 and shown in Figure 2-1, the semiconductor industry serves a number of end-use markets, and the information and communication technology sectors typically account for a majority of global sales at two-thirds. However, from 2021 to 2022, the automotive, industrial, and consumer electronics markets’ share of sales revenue grew, indicative of demand trends demonstrated by end market growth projections. The semiconductor value chain is highly complex, as indicated in Figure 2-2, requiring the co-operation of many different companies to support the end use equipment consumers are familiar with. 2 SEMICONDUCTOR TECHNOLOGY The overall global semiconductor market was valued at $440 billion in 2020 and increased to $555.9 billion in 2021, an increase of over 26.2% according to data from the World Semiconductor Trade Statistics (WSTS) 2021. In February 2023, the Semiconductor Industry Association (SIA) reported global semiconductor industry sales totalled $574 billion in 2022, the highest-ever annual total and an increase of 3.32% compared to the 2021 total of $555.9 billion. Figure 2-1 Global semiconductor demand by end-market, in USD. 4 Based on information from SIA 5 and shown in Figure 2-1, the semiconductor industry serves a number of end-use markets, and the information and communication technology sectors typically account for a majority of global sales at two-thirds. However, from 2021 to 2022, the automotive, industrial, and consumer electronics markets’ share of sales revenue grew, indicative of demand trends demonstrated by end market growth projections. The semiconductor value chain is highly complex, as indicated in Figure 2-2, requiring the co-operation of many different companies to support the end use equipment consumers are familiar with. ______ 4 Omdia (Q3 2022) McKinsey 5 upply Chain Deep Dive Assessment, U.S. Department of Energy Response to Executive Order 14017, Semiconductor Sup “America’s Supply chains” February 24, 2022. https://www.energy.gov/sites/default/files/2022- 02/Semiconductor%20Supply%20Chain%20Report%20-%20Final.pdf © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 17 225 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-2 Illustrative (non-comprehensive) companies involved in different stages of the value chain. 6 ______ 4 Omdia (Q3 2022) McKinsey 5 upply Chain Deep Dive Assessment, U.S. Department of Energy Response to Executive Order 14017, Semiconductor Sup “America’s Supply chains” February 24, 2022. https://www.energy.gov/sites/default/files/2022- 02/Semiconductor%20Supply%20Chain%20Report%20-%20Final.pdf © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 17 225 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-2 Illustrative (non-comprehensive) companies involved in different stages of the value chain. 6 2.1 Importance of Semiconductors to Society Semiconductor devices are central to the digital economy and an enabling technology for a number of key applications as shown in Figure 2-3. 7 Semiconductors are at the centre of technological advancements that can make a significant contribution to society. Due to their complexity and key role in technological development, semiconductors have been defined as one of the most complex devices ever created by humans. For example, innovative uses of semiconductor technology have the potential to make significant contributions towards solutions to global climate change. According to the World Economic Forum, semiconductor-enabled technologies, such as digital technologies, can reduce greenhouse gas emissions by 15% - almost one-third of the 50% reduction required by 2030. 8 2.1 Importance of Semiconductors to Society Semiconductor devices are central to the digital economy and an enabling technology for a number of key applications as shown in Figure 2-3. 7 Semiconductors are at the centre of technological advancements that can make a significant contribution to society. Due to their complexity and key role in technological development, semiconductors have been defined as one of the most complex devices ever created by humans. For example, innovative uses of semiconductor technology have the potential to make significant contributions towards solutions to global climate change. According to the World Economic Forum, semiconductor-enabled technologies, such as digital technologies, can reduce greenhouse gas emissions by 15% - almost one-third of the 50% reduction required by 2030. 8 ______ 6 Source: The Semiconductor Ecosystem: Complex, Global, and Specialized - Altman Solon, EDA - Electronic Design Automation, IP - Intellectual Property, OSAT - Outsourced Semiconductor Assembly & Test, ATMP - Assembly, Test, Markup & Packaging, EMS - Electronic Manufacturing Services, PCB - Printed Circuit Board, OEM - Original Equipment Manufacturer 7 Sourced from Alex Capri, “Semiconductors at the Heart of the U.S.-China Tech War: How a New Era of Techno Nationalism is Shaking Up Semiconductor Value Chains,” Hinrich Foundation, January 2020, p. 13. 8 https://www.weforum.org/agenda/2019/01/why-digitalization-is is-the-key-to to-exponential-climate-action/ © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 18 226 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-3 Technologies enabled by semiconductors. ______ 6 Source: The Semiconductor Ecosystem: Complex, Global, and Specialized - Altman Solon, EDA - Electronic Design Automation, IP - Intellectual Property, OSAT - Outsourced Semiconductor Assembly & Test, ATMP - Assembly, Test, Markup & Packaging, EMS - Electronic Manufacturing Services, PCB - Printed Circuit Board, OEM - Original Equipment Manufacturer 7 Sourced from Alex Capri, “Semiconductors at the Heart of the U.S.-China Tech War: How a New Era of Techno Nationalism is Shaking Up Semiconductor Value Chains,” Hinrich Foundation, January 2020, p. 13. 8 https://www.weforum.org/agenda/2019/01/why-digitalization-is is-the-key-to to-exponential-climate-action/ © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 18 226 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-3 Technologies enabled by semiconductors. Within the past several years, industry has witnessed disruptions in the supply of chips, causing shortages across multiple economic sectors and potentially serious societal consequences. Many sectors, including automotive, energy, communication, and health, as well as strategic sectors such as defence, security, and space are under threat by such supply disruptions. Any further disruptions due to PFAS restrictions will likely make the situation more severe. The current supply chain disruptions have revealed structural vulnerabilities of the value chains. The global semiconductor shortage has exposed dependency on supply from a limited number of companies and geographies, and its vulnerability to third country export restrictions and other disruptions in the present geopolitical context. Building new facilities to manufacture the latest semiconductor devices technologies requires a considerable upfront investment of at least €15 billion and several years to achieve production-readiness with adequate yields. The expenditures to design such chips can range from €0.5 billion to well over €1.0 billion. Research and development (R&D) intensity in the sector is high with more than a 15% investment percentage with respect to sales. 9 It is estimated that in 2021 the capital expenditure invested was close to $150 billion and was expected to rise to above $150 billion in 2022. 10 This trend will only continue as demand for electronics and connectivity grows. In the automotive space, new vehicles increasingly rely on semiconductor devices for fuel efficiency, safety, and other features. The expected growth in electric cars will only further this reliance. In the long term, as semiconductor devices play an even bigger role in an ever-expanding array of products, global demand for semiconductor devices will continue to rise. In addition to this the semiconductor industry is growing substantially, with the following calculated by the World Semiconductor Trade Statistics (WSTS)10: Within the past several years, industry has witnessed disruptions in the supply of chips, causing shortages across multiple economic sectors and potentially serious societal consequences. Many sectors, including automotive, energy, communication, and health, as well as strategic sectors such as defence, security, and space are under threat by such supply disruptions. Any further disruptions due to PFAS restrictions will likely make the situation more severe. The current supply chain disruptions have revealed structural vulnerabilities of the value chains. The global semiconductor shortage has exposed dependency on supply from a limited number of companies and geographies, and its vulnerability to third country export restrictions and other disruptions in the present geopolitical context. Building new facilities to manufacture the latest semiconductor devices technologies requires a considerable upfront investment of at least €15 billion and several years to achieve production-readiness with adequate yields. The expenditures to design such chips can range from €0.5 billion to well over €1.0 billion. Research and development (R&D) intensity in the sector is high with more than a 15% investment percentage with respect to sales. 9 It is estimated that in 2021 the capital expenditure invested was close to $150 billion and was expected to rise to above $150 billion in 2022. 10 This trend will only continue as demand for electronics and connectivity grows. In the automotive space, new vehicles increasingly rely on semiconductor devices for fuel efficiency, safety, and other features. The expected growth in electric cars will only further this reliance. In the long term, as semiconductor devices play an even bigger role in an ever-expanding array of products, global demand for semiconductor devices will continue to rise. In addition to this the semiconductor industry is growing substantially, with the following calculated by the World Semiconductor Trade Statistics (WSTS)10: ______ 9 A Chip Act for Europe, ”Brussels, 8.2.2022 COM(2022) 45 final. https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX:52022DC0045 10 WSTS Semiconductor Market Forecast Fall 2022 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 19 227 The Impact of a Potential PFAS Restriction on the Semiconductor Sector • Worldwide sales have a yearly growth of 12%. 11 • The American market is supposed to grow 17.0%. • The European market is supposed to grow 12.6%. • The Japanese market is supposed to grow 10.0%. • The Asia Pacific market is supposed to decline 2.0%. ______ 9 A Chip Act for Europe, ”Brussels, 8.2.2022 COM(2022) 45 final. https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX:52022DC0045 10 WSTS Semiconductor Market Forecast Fall 2022 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 19 227 The Impact of a Potential PFAS Restriction on the Semiconductor Sector • Worldwide sales have a yearly growth of 12%. 11 • The American market is supposed to grow 17.0%. • The European market is supposed to grow 12.6%. • The Japanese market is supposed to grow 10.0%. • The Asia Pacific market is supposed to decline 2.0%. 2.2 Semiconductor Manufacture and Supply Chain Semiconductor devices are extremely complex to manufacture, with leading devices requiring more than 2,000 process steps, hundreds of production materials, and approximately 26 weeks to manufacture and test. 12 A simplified diagram of the supply chain is outlined in Figure 2-4. The materials used for the manufacture of semiconductors have been specially formulated and engineered to meet the exacting standards of the industry which continue to be more and more demanding as the technology evolves. Each step in the process requires extremely high purity, exacting process control and high yields for the overall production to be viable. Figure 2-4 Schematic of semiconductor supply chain. 13 The supply chain for semiconductors starts with a range of unique materials, chemicals and sophisticated equipment and services provided by special vendors to meet the unique needs of this sector. The semiconductor supply chain has a global footprint and relies upon key technology holders across the globe. The full supply chain uses components and materials supplied by many tiers of suppliers and sub-suppliers, and those components and materials will typically pass multiple borders before final distribution. If this complex supply chain is broken due to a restriction being placed on the use of PFAS, the effects will be felt globally. 2.2 Semiconductor Manufacture and Supply Chain Semiconductor devices are extremely complex to manufacture, with leading devices requiring more than 2,000 process steps, hundreds of production materials, and approximately 26 weeks to manufacture and test. 12 A simplified diagram of the supply chain is outlined in Figure 2-4. The materials used for the manufacture of semiconductors have been specially formulated and engineered to meet the exacting standards of the industry which continue to be more and more demanding as the technology evolves. Each step in the process requires extremely high purity, exacting process control and high yields for the overall production to be viable. Figure 2-4 Schematic of semiconductor supply chain. 13 The supply chain for semiconductors starts with a range of unique materials, chemicals and sophisticated equipment and services provided by special vendors to meet the unique needs of this sector. The semiconductor supply chain has a global footprint and relies upon key technology holders across the globe. The full supply chain uses components and materials supplied by many tiers of suppliers and sub-suppliers, and those components and materials will typically pass multiple borders before final distribution. If this complex supply chain is broken due to a restriction being placed on the use of PFAS, the effects will be felt globally. The processes and equipment used are enormously complex. A simplified step by step workflow of the semiconductor manufacturing process indicating where PFAS are used is shown in Figure 0-1, which ______ 11 Based on 2016-2021 global data. 12 According to Consortium members. 13 A Chip Act for Europe, ”Brussels, 8.2.2022 COM(2022) 45 final. https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX:52022DC0045 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 20 228 The Impact of a Potential PFAS Restriction on the Semiconductor Sector describes the use of PFAS in the semiconductor product manufacturing process and associated waste streams. The processes and equipment used are enormously complex. A simplified step by step workflow of the semiconductor manufacturing process indicating where PFAS are used is shown in Figure 0-1, which ______ 11 Based on 2016-2021 global data. 12 According to Consortium members. 13 A Chip Act for Europe, ”Brussels, 8.2.2022 COM(2022) 45 final. https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX:52022DC0045 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 20 228 The Impact of a Potential PFAS Restriction on the Semiconductor Sector describes the use of PFAS in the semiconductor product manufacturing process and associated waste streams. 2.3 Importance of Innovation In the past 50 years, semiconductor performance has increased from 10 thousand floating point operations per second, or FLOPs 14, to more than 400 quadrillion FLOPs for the fastest super computers. 15 The need for semiconductor enabled technology to be faster and more powerful comes from the developing and evolving need for digitisation. The demand for faster and more powerful devices is anticipated to continue, requiring the semiconductor industry to invest in next generation innovations. Further miniaturisation continues, towards smaller node 16 dimensions in the mainstream process technologies along the lines of Moore’s law 17, while more energy-efficient solutions are in high demand to ensure that the ever-growing processing footprint remains sustainable. According to the International Roadmap for devices and systems 2022 update 18, by 2037 a 0.5 nm equivalent node size on semiconductors will be necessary. Since the 1970's semiconductor speed and performance has grown exponentially due to these innovations, as outlined by Figure 2-5. 2.3 Importance of Innovation In the past 50 years, semiconductor performance has increased from 10 thousand floating point operations per second, or FLOPs 14, to more than 400 quadrillion FLOPs for the fastest super computers. 15 The need for semiconductor enabled technology to be faster and more powerful comes from the developing and evolving need for digitisation. The demand for faster and more powerful devices is anticipated to continue, requiring the semiconductor industry to invest in next generation innovations. Further miniaturisation continues, towards smaller node 16 dimensions in the mainstream process technologies along the lines of Moore’s law 17, while more energy-efficient solutions are in high demand to ensure that the ever-growing processing footprint remains sustainable. According to the International Roadmap for devices and systems 2022 update 18, by 2037 a 0.5 nm equivalent node size on semiconductors will be necessary. Since the 1970's semiconductor speed and performance has grown exponentially due to these innovations, as outlined by Figure 2-5. ______ 14 FLOP is a measure of computer performance representing the number of floating point operations performed by a computer in a second. 15 TOP500 Supercomputer Database. 16 Typically refers to the technology node, a term used to describe the size of the features in the finished product. Quoted in terms of nanometres "EG B7G=;G ;QDE:;QD7C; G;<;GH IE >7B< I>; :?HI7D9; 8;IL;;D ?:;DI?97B <;7IJG;H%Q 17 Moore’s law is an observation based on historical trend in the semiconductors industry, which shows the density of transistors on an integrated circuit doubles approximately every two years. 18 International Roadmap for Devices and Systems, 2022 Update, More Moore, IEEE, https://irds.ieee.org/editions/2022 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 21 229 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-5 Sample of semiconductor products: exponential decrease in critical dimensions over time (and associated lithographic wavelengths). 19 ______ 14 FLOP is a measure of computer performance representing the number of floating point operations performed by a computer in a second. 15 TOP500 Supercomputer Database. 16 Typically refers to the technology node, a term used to describe the size of the features in the finished product. Quoted in terms of nanometres "EG B7G=;G ;QDE:;QD7C; G;<;GH IE >7B< I>; :?HI7D9; 8;IL;;D ?:;DI?97B <;7IJG;H%Q 17 Moore’s law is an observation based on historical trend in the semiconductors industry, which shows the density of transistors on an integrated circuit doubles approximately every two years. 18 International Roadmap for Devices and Systems, 2022 Update, More Moore, IEEE, https://irds.ieee.org/editions/2022 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 21 229 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-5 Sample of semiconductor products: exponential decrease in critical dimensions over time (and associated lithographic wavelengths). 19 For context the diameter of a human hair is 100,000 nm with Figure 2-6 showing semiconductor node sizes compared to biological references, which explains why the extreme miniaturisation of si semiconductors poses so many technical challenges. Many PFAS are intrinsically linked into the technological advances which have allowed the current node sizes to be achieved. Node sizes, and the wavelengths used to create them, are not necessarily replaced by smaller nodes, rather devices can have multiple node sizes or rely on legacy node size technologies. As such, all of the above-mentioned wavelengths are still in use today with the most advanced (i.e., most capable, and most expensive) lithographic technology being used for the most critical layers, and older, less costly technologies for the less demanding ones. Any changes to each of these layers can influence the next, causing a reduction in yield or even catastrophic process failure. ______ 19 File:Comparison semiconductor process nodes.svg - Wikimedia Commons © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 22 230 The Impact of a Potential PFAS Restriction on the Semiconductor Sector For context the diameter of a human hair is 100,000 nm with Figure 2-6 showing semiconductor node sizes compared to biological references, which explains why the extreme miniaturisation of si semiconductors poses so many technical challenges. Many PFAS are intrinsically linked into the technological advances which have allowed the current node sizes to be achieved. Node sizes, and the wavelengths used to create them, are not necessarily replaced by smaller nodes, rather devices can have multiple node sizes or rely on legacy node size technologies. As such, all of the above-mentioned wavelengths are still in use today with the most advanced (i.e., most capable, and most expensive) lithographic technology being used for the most critical layers, and older, less costly technologies for the less demanding ones. Any changes to each of these layers can influence the next, causing a reduction in yield or even catastrophic process failure. ______ 19 File:Comparison semiconductor process nodes.svg - Wikimedia Commons © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 22 230 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-6 Comparison of various biological assemblies and technological device. 20 Products containing semiconductors are essential technologies in everyday life and form the backbone of the technical strategic value chain with strategic objectives in multiple jurisdictions, including Europe via the European Green Deal and digital autonomy. 21 To renew its pledge to innovation, the European Union is committed to its strategic goal to reach at least 20% of world production in value of cutting- edge, innovative, and sustainable semiconductors by 2030, as set out in the Digital Decade Policy Programme. 22 Innovation fuels continuous advances in microelectronics technologies, which is why semiconductor companies spend so much on research and development expenditure as outlined in Figure 2-7 and is necessary to make the advances in technology. It is only as a result of the high-level innovation that the objectives of the US CHIPs act 23 and the EU Digital Decade Policy are possible. Figure 2-6 Comparison of various biological assemblies and technological device. 20 Products containing semiconductors are essential technologies in everyday life and form the backbone of the technical strategic value chain with strategic objectives in multiple jurisdictions, including Europe via the European Green Deal and digital autonomy. 21 To renew its pledge to innovation, the European Union is committed to its strategic goal to reach at least 20% of world production in value of cutting- edge, innovative, and sustainable semiconductors by 2030, as set out in the Digital Decade Policy Programme. 22 Innovation fuels continuous advances in microelectronics technologies, which is why semiconductor companies spend so much on research and development expenditure as outlined in Figure 2-7 and is necessary to make the advances in technology. It is only as a result of the high-level innovation that the objectives of the US CHIPs act 23 and the EU Digital Decade Policy are possible. ______ 20 Modification E< ,J?BB7JC; 27JC?;G$ 2>?B?F 3ED7D$ 1.-$ 'GIJG /7D +?@7OAELHA?$ /;GEC; 67BA;G$ 0?9>7;B )7K?: /ED;H$ 5MB;G Heal, Mariana Ruiz, Science Primer (National Center for Biotechnology Information), Liquid_2003, Arne Nordmann & The Tango! Desktop Project, CC BY-SA 2.5 via Wikimedia Commons 21 https://www.semi.org/en/blogs/semi-news/fluorinated-chemicals-are-essential-to-semiconductor-manufacturing-and- innovation 22 https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/europe-fit-digital-age/europes-digital-decade-digital- targets-2030_en 23 A Chip Act for Europe, ”Brussels, 8.2.2022 COM(2022) 45 final. https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX:52022DC0045 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 23 231 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-7 Semiconductor R&D expenditure as a percentage of sales. ______ 20 Modification E< ,J?BB7JC; 27JC?;G$ 2>?B?F 3ED7D$ 1.-$ 'GIJG /7D +?@7OAELHA?$ /;GEC; 67BA;G$ 0?9>7;B )7K?: /ED;H$ 5MB;G Heal, Mariana Ruiz, Science Primer (National Center for Biotechnology Information), Liquid_2003, Arne Nordmann & The Tango! Desktop Project, CC BY-SA 2.5 via Wikimedia Commons 21 https://www.semi.org/en/blogs/semi-news/fluorinated-chemicals-are-essential-to-semiconductor-manufacturing-and- innovation 22 https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/europe-fit-digital-age/europes-digital-decade-digital- targets-2030_en 23 A Chip Act for Europe, ”Brussels, 8.2.2022 COM(2022) 45 final. https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX:52022DC0045 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 23 231 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-7 Semiconductor R&D expenditure as a percentage of sales. Innovation fuels continuous advances in microelectronics technologies, which is necessary to make the advances in technology which are required to underpin the objectives of the US CHIPs act 24 and the EU Digital Decade Policy. 25 Moore’s law describes the trend whereby the number of transistors on a microchip doubles every two years shown in Figure 2-8. This advancement is important for other aspects of technological progress in computing such as processing speed or the cost of computing. ______ 24 A Chip Act for Europe, ”Brussels, 8.2.2022 COM(2022) 45 final. https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX:52022DC0045 25 Europe’s Digital Decade: digital targets for 2030 (europa.eu) © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 24 232 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-8 Moore’s Law- exponential technological advancement through time. Innovation fuels continuous advances in microelectronics technologies, which is necessary to make the advances in technology which are required to underpin the objectives of the US CHIPs act 24 and the EU Digital Decade Policy. 25 Moore’s law describes the trend whereby the number of transistors on a microchip doubles every two years shown in Figure 2-8. This advancement is important for other aspects of technological progress in computing such as processing speed or the cost of computing. ______ 24 A Chip Act for Europe, ”Brussels, 8.2.2022 COM(2022) 45 final. https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX:52022DC0045 25 Europe’s Digital Decade: digital targets for 2030 (europa.eu) © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 24 232 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 2-8 Moore’s Law- exponential technological advancement through time. The continuing validity of Moore’s law for technology could be disrupted by the loss of PFAS which is a key enabling technology to make ever smaller transistors, through the ability to have extremely high purity, high quality, highly directed manufacturing. This is based on the PFAS applications explained in this report. The impact on the global economy derived from denying access to state-of-the-art semiconductor technology would be significant, because PFAS provide multiple, critical functions which are crucial to production. In many instances, PFAS are the only substances known currently to offer the necessary technical performance in semiconductor production. If manufacturers are no longer able to invest in innovations relying on PFAS, a further consequential impact would be significant disruption to the technology roadmap 26 as manufacturers attempt to develop the next materials and equipment, which would be a lengthy and demanding process with no certainty of success. These impacts pose an enormous competitive disadvantage for semiconductor producers based in jurisdictions where there are PFAS restrictions compared to their non-affected competitors. The continuing validity of Moore’s law for technology could be disrupted by the loss of PFAS which is a key enabling technology to make ever smaller transistors, through the ability to have extremely high purity, high quality, highly directed manufacturing. This is based on the PFAS applications explained in this report. The impact on the global economy derived from denying access to state-of-the-art semiconductor technology would be significant, because PFAS provide multiple, critical functions which are crucial to production. In many instances, PFAS are the only substances known currently to offer the necessary technical performance in semiconductor production. If manufacturers are no longer able to invest in innovations relying on PFAS, a further consequential impact would be significant disruption to the technology roadmap 26 as manufacturers attempt to develop the next materials and equipment, which would be a lengthy and demanding process with no certainty of success. These impacts pose an enormous competitive disadvantage for semiconductor producers based in jurisdictions where there are PFAS restrictions compared to their non-affected competitors. 2.4 Importance of Yield Production yield is the single most important factor for semiconductor manufacturing as not only does it influence the cost, but also the output per unit of input resources, waste generation, environmental and financial sustainability. During the manufacture of semiconductors yield loss is caused for example by defects, faults, process variations and contamination. Examples of contamination and mechanisms ______ 26 The direction of research and timelines of semiconductor development in the future. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 25 233 The Impact of a Potential PFAS Restriction on the Semiconductor Sector responsible for yield loss include airborne molecular contamination by the environment or by the tools, process-induced defects, process variations resulting in attributes such as different layer thickness, and many others. The complexity and sensitivity of semiconductor manufacture and the occurrence of defects have a huge impact on the ability to produce designs, with each individual step needing to meet process control limits set in order to achieve wafer level yields of greater than 90% 27 and in lithography well above 99%. 2.4 Importance of Yield Production yield is the single most important factor for semiconductor manufacturing as not only does it influence the cost, but also the output per unit of input resources, waste generation, environmental and financial sustainability. During the manufacture of semiconductors yield loss is caused for example by defects, faults, process variations and contamination. Examples of contamination and mechanisms ______ 26 The direction of research and timelines of semiconductor development in the future. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 25 233 The Impact of a Potential PFAS Restriction on the Semiconductor Sector responsible for yield loss include airborne molecular contamination by the environment or by the tools, process-induced defects, process variations resulting in attributes such as different layer thickness, and many others. The complexity and sensitivity of semiconductor manufacture and the occurrence of defects have a huge impact on the ability to produce designs, with each individual step needing to meet process control limits set in order to achieve wafer level yields of greater than 90% 27 and in lithography well above 99%. Many PFAS are intrinsically linked to achieving the highly demanding yields, either by contributing to the cleanliness of the system or accuracy of the processing, and so they enable the manufacturing of current semiconductor devices. It is important to keep in mind that the factors which affect yield can rarely be attributed to a single process parameter, which is why multiple variables have to be considered concurrently, as outlined in multiple papers. 28, 29 Considering the widespread uses of PFAS, this too will pose a significant challenge due to the concurrent need to identify possible PFAS-free alternatives. Many PFAS are intrinsically linked to achieving the highly demanding yields, either by contributing to the cleanliness of the system or accuracy of the processing, and so they enable the manufacturing of current semiconductor devices. It is important to keep in mind that the factors which affect yield can rarely be attributed to a single process parameter, which is why multiple variables have to be considered concurrently, as outlined in multiple papers. 28, 29 Considering the widespread uses of PFAS, this too will pose a significant challenge due to the concurrent need to identify possible PFAS-free alternatives. 2.5 Essential Use The Chemicals Strategy for Sustainability Towards a Toxic-Free Environment 30 proposes the development of a widespread essential use concept to apply across chemicals legislation. The Chemicals Strategy 31 programme has not yet published its definition of ‘Essential Use’ but will develop criteria for essentiality. At this point it is known that the definition will be based on the criteria that there are no alternatives and that the use of the substance is necessary for health, safety or is critical for the functioning of society. As is outlined in the respective sections of this report, PFAS substances in most applications do not have a known viable alternative and are key enablers of semiconductors. Semiconductors themselves are essential to the functioning of society and also essential for health as they are embedded in medical devices, power stations, satellite, and every home. 2.5 Essential Use The Chemicals Strategy for Sustainability Towards a Toxic-Free Environment 30 proposes the development of a widespread essential use concept to apply across chemicals legislation. The Chemicals Strategy 31 programme has not yet published its definition of ‘Essential Use’ but will develop criteria for essentiality. At this point it is known that the definition will be based on the criteria that there are no alternatives and that the use of the substance is necessary for health, safety or is critical for the functioning of society. As is outlined in the respective sections of this report, PFAS substances in most applications do not have a known viable alternative and are key enablers of semiconductors. Semiconductors themselves are essential to the functioning of society and also essential for health as they are embedded in medical devices, power stations, satellite, and every home. 3 PFAS SUBSTITUTION OPPORTUNITIES AND CHALLENGES 3 PFAS SUBSTITUTION OPPORTUNITIES AND CHALLENGES 3.1 PFAS substance identification Many PFAS used in mixtures have not been classified as hazardous per the Globally Harmonised System for classification and labelling. In addition, they have not been listed as Substances of Very High Concern (SVHC) or included on the Candidate List of SVHC for Authorisation. Therefore, many PFAS are not shown on safety data sheets even though the substance is present. In addition to this, chemical supplier companies invest significant time, money, and resources into developing proprietary chemicals to meet the exacting requirements to manufacture semiconductors at nanometre dimensions. In some instances, the use of PFAS is considered to be the intellectual property ______ 27 Enhancing the Production Yield of Semiconductors | Infosys, 2022. 28 Data Science in Semiconductor Process Yield | by Brian Mattis | Towards Data Science 29 Taking the next leap forward in semiconductor yield improvement | McKinsey, April 2018. 30 https://ec.europa.eu/environment/pdf/chemicals/2020/10/Strategy.pdf 31 https://eur-lex.europa.eu/resource.html?uri=cellar:f815479a-0f01-11eb-bc0701aa75ed71a1.0003.02/DOC_1&format=PDF © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 26 3.1 PFAS substance identification Many PFAS used in mixtures have not been classified as hazardous per the Globally Harmonised System for classification and labelling. In addition, they have not been listed as Substances of Very High Concern (SVHC) or included on the Candidate List of SVHC for Authorisation. Therefore, many PFAS are not shown on safety data sheets even though the substance is present. In addition to this, chemical supplier companies invest significant time, money, and resources into developing proprietary chemicals to meet the exacting requirements to manufacture semiconductors at nanometre dimensions. In some instances, the use of PFAS is considered to be the intellectual property ______ 27 Enhancing the Production Yield of Semiconductors | Infosys, 2022. 28 Data Science in Semiconductor Process Yield | by Brian Mattis | Towards Data Science 29 Taking the next leap forward in semiconductor yield improvement | McKinsey, April 2018. 30 https://ec.europa.eu/environment/pdf/chemicals/2020/10/Strategy.pdf 31 https://eur-lex.europa.eu/resource.html?uri=cellar:f815479a-0f01-11eb-bc0701aa75ed71a1.0003.02/DOC_1&format=PDF © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 26 234 The Impact of a Potential PFAS Restriction on the Semiconductor Sector of the chemical supplier, so the identification of the specific substance is not communicated to customers as companies need to ensure that their investment is protected. Releasing information about certain chemicals to the public would give competitors an unfair advantage and is likely to cause substantial harm to the company’s competitive market position. Moreover, when PFAS are used as articles or articles in complex objects, the parts suppliers are currently under no regulatory obligation to highlight the presence of PFAS. As a result of these various factors the discovery of PFAS uses in this sector is extremely challenging. 234 The Impact of a Potential PFAS Restriction on the Semiconductor Sector of the chemical supplier, so the identification of the specific substance is not communicated to customers as companies need to ensure that their investment is protected. Releasing information about certain chemicals to the public would give competitors an unfair advantage and is likely to cause substantial harm to the company’s competitive market position. Moreover, when PFAS are used as articles or articles in complex objects, the parts suppliers are currently under no regulatory obligation to highlight the presence of PFAS. As a result of these various factors the discovery of PFAS uses in this sector is extremely challenging. 3.2 Timeframes for substitution Due to the unique attributes of organofluorine chemistry, and the highly specialised function that PFAS provide in numerous semiconductor manufacturing applications, it is not known if PFAS-free alternatives will be viable for all applications. In any case, the timelines to qualify and implement alternatives are lengthy for the semiconductor industry as the following stages need to be undertaken: 1. The first stage in substitution is reviewing all potential alternatives currently marketed, to determine if they offer suitable performance. Sources can vary between commercial off the shelf products, and specialised alternatives developed specifically for the semiconductor sector, with the determining factor of whether they can be taken forward based on the technical needs of the application. 2. For many applications, investment in fundamental research and development is needed to identify a PFAS free alternative, as there is not one currently marketed which is suitable for the semiconductor’s industry needs. This can start from fundamental external research undertaken by universities or research laboratories. 3.2 Timeframes for substitution Due to the unique attributes of organofluorine chemistry, and the highly specialised function that PFAS provide in numerous semiconductor manufacturing applications, it is not known if PFAS-free alternatives will be viable for all applications. In any case, the timelines to qualify and implement alternatives are lengthy for the semiconductor industry as the following stages need to be undertaken: 1. The first stage in substitution is reviewing all potential alternatives currently marketed, to determine if they offer suitable performance. Sources can vary between commercial off the shelf products, and specialised alternatives developed specifically for the semiconductor sector, with the determining factor of whether they can be taken forward based on the technical needs of the application. 2. For many applications, investment in fundamental research and development is needed to identify a PFAS free alternative, as there is not one currently marketed which is suitable for the semiconductor’s industry needs. This can start from fundamental external research undertaken by universities or research laboratories. 3. Once a possible alternative is identified this needs to be researched and developed by the material supply chain and then the semiconductor/semiconductor equipment manufacturer to assess the impact on the product, such that it offers the necessary technical performance through the following: a. Integration, b. Demonstration including re-qualification to standards or safety evaluations, c. Ramp to HVM, This can involve significant timeframes as it potentially includes the development, installation, and integration of new equipment and/or new facility installations that manage environmental controls. Additionally, there are checkpoints along the development process to assess the viability of the alternative and the functionality of the material to manufacturing and product requirements. d. Impact on the market. The concurrent processes of semiconductor design and PFAS material alternative identification and qualification can cause additional delay in overall time to market as well as additional qualification resources to both semiconductor manufacturers and customers. 3. Once a possible alternative is identified this needs to be researched and developed by the material supply chain and then the semiconductor/semiconductor equipment manufacturer to assess the impact on the product, such that it offers the necessary technical performance through the following: a. Integration, b. Demonstration including re-qualification to standards or safety evaluations, c. Ramp to HVM, This can involve significant timeframes as it potentially includes the development, installation, and integration of new equipment and/or new facility installations that manage environmental controls. Additionally, there are checkpoints along the development process to assess the viability of the alternative and the functionality of the material to manufacturing and product requirements. d. Impact on the market. The concurrent processes of semiconductor design and PFAS material alternative identification and qualification can cause additional delay in overall time to market as well as additional qualification resources to both semiconductor manufacturers and customers. Components and substances used in semiconductor equipment often require bespoke parts to be developed and qualified, with solutions potentially only being suitable alternatives for certain applications and therefore not being a one-for-all replacement. Therefore, the redesign and testing requirements for each use often is very significant and needs to be undertaken by each company due to differences in process. It is anticipated that significant innovation loops will take place between the semiconductor manufacturers and suppliers in feasibility testing of new © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 27 235 The Impact of a Potential PFAS Restriction on the Semiconductor Sector innovations for PFAS replacement chemicals, to discover the appropriate technology platform for PFAS replacement for the numerous uses within the industry. Components and substances used in semiconductor equipment often require bespoke parts to be developed and qualified, with solutions potentially only being suitable alternatives for certain applications and therefore not being a one-for-all replacement. Therefore, the redesign and testing requirements for each use often is very significant and needs to be undertaken by each company due to differences in process. It is anticipated that significant innovation loops will take place between the semiconductor manufacturers and suppliers in feasibility testing of new © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 27 235 The Impact of a Potential PFAS Restriction on the Semiconductor Sector innovations for PFAS replacement chemicals, to discover the appropriate technology platform for PFAS replacement for the numerous uses within the industry. 4. Suitable time to complete su supplier change management, including changes to part numbers/drawings/technical and safety information, consumption of stock parts throughout multiple levels in the supply chain. The impact on production yield of a small change can be very significant, therefore the change control process within the semiconductor industry is strictly followed. 5. Assessment of unintended consequences, such as an alternative causing damage or an increase in defects present (Impact to production), which leads to increased safety risk (Impact to people). When the alternative is not viable, the process has to loop back to earlier steps to find a different chemistry or technology that does not have the same issues. 6. Additionally, stringent qualification also has to take place with semiconductor customers to ensure that the semiconductor product guarantees the same function as semiconductor product did previously. Figure 3-1 Illustrative timeline for qualification of a single alternative. Of course, this is only an overview and potential alternatives must be evaluated on a case-by by-case basis, considering technical, regulatory as well as economic aspects. By its nature, the invention of an alternative has no estimated timeline as it can vary significantly, and for some applications there may be no known alternative. 4. Suitable time to complete su supplier change management, including changes to part numbers/drawings/technical and safety information, consumption of stock parts throughout multiple levels in the supply chain. The impact on production yield of a small change can be very significant, therefore the change control process within the semiconductor industry is strictly followed. 5. Assessment of unintended consequences, such as an alternative causing damage or an increase in defects present (Impact to production), which leads to increased safety risk (Impact to people). When the alternative is not viable, the process has to loop back to earlier steps to find a different chemistry or technology that does not have the same issues. 6. Additionally, stringent qualification also has to take place with semiconductor customers to ensure that the semiconductor product guarantees the same function as semiconductor product did previously. Figure 3-1 Illustrative timeline for qualification of a single alternative. Of course, this is only an overview and potential alternatives must be evaluated on a case-by by-case basis, considering technical, regulatory as well as economic aspects. By its nature, the invention of an alternative has no estimated timeline as it can vary significantly, and for some applications there may be no known alternative. Aspects such as the following further increase the uncertainty of the timelines: Technical • The alternative may not be a drop-in replacement and alternative design changes need to be made, solution may not be backward compatible to designs of equipment which are already in service. • The technical requirements at each stage must be met, and may require multiple iterations of testing and development, as indicated by the red arrows in Figure 3-1. • The solution may not address the long-term reliability of the alternative, which may only introduce additional design needs or technical limitations once the alternative has been used for a considerable length of time. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 28 236 The Impact of a Potential PFAS Restriction on the Semiconductor Sector • The solution may need to be qualified by a certified body which can add additional time. Supplier factors • Difficulties in identifying a new supplier and their qualification can add considerable additional time to envisaged timeline in Figure 3-1. • The alternative substance needs to be available in sufficient quantities to meet demand. Aspects such as the following further increase the uncertainty of the timelines: Technical • The alternative may not be a drop-in replacement and alternative design changes need to be made, solution may not be backward compatible to designs of equipment which are already in service. • The technical requirements at each stage must be met, and may require multiple iterations of testing and development, as indicated by the red arrows in Figure 3-1. • The solution may not address the long-term reliability of the alternative, which may only introduce additional design needs or technical limitations once the alternative has been used for a considerable length of time. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 28 236 The Impact of a Potential PFAS Restriction on the Semiconductor Sector • The solution may need to be qualified by a certified body which can add additional time. Supplier factors • Difficulties in identifying a new supplier and their qualification can add considerable additional time to envisaged timeline in Figure 3-1. • The alternative substance needs to be available in sufficient quantities to meet demand. The supply chain for semiconductors can be narrow and varied, and highly, highly specialised. An impact to any one of these unique supply chain elements can have dramatic impacts to downstream customers. For instance, only a handful of chemical suppliers have the research and materials capability to support the critical lithographic materials needed for the entire semiconductor industry. Delays in testing • Unavailability of testing labs due to the expected increase in the demand for testing of other applications/alternatives, or delays in receiving test material from supplier or prototypes for testing. Environmental • PFAS articles are exposed to hazardous substances during use which might contaminate the proposed alternatives differently, and thus impact recyclability. Therefore, alternative waste manage streams would need to be identified. Additional information about the semiconductor industry’s environmental impact, end of life and waste considerations can be found in Section 11 of this report. • Technical resources Significant additional specialised highly educated technical resources will be required in the innovation and commercialisation of PFAS replacement materials. As such there may be additional time required to recruit and train additional people. The supply chain for semiconductors can be narrow and varied, and highly, highly specialised. An impact to any one of these unique supply chain elements can have dramatic impacts to downstream customers. For instance, only a handful of chemical suppliers have the research and materials capability to support the critical lithographic materials needed for the entire semiconductor industry. Delays in testing • Unavailability of testing labs due to the expected increase in the demand for testing of other applications/alternatives, or delays in receiving test material from supplier or prototypes for testing. Environmental • PFAS articles are exposed to hazardous substances during use which might contaminate the proposed alternatives differently, and thus impact recyclability. Therefore, alternative waste manage streams would need to be identified. Additional information about the semiconductor industry’s environmental impact, end of life and waste considerations can be found in Section 11 of this report. • Technical resources Significant additional specialised highly educated technical resources will be required in the innovation and commercialisation of PFAS replacement materials. As such there may be additional time required to recruit and train additional people. The timeframes for qualification of alternatives outlined in this report are wherever possible extrapolated from other qualifications, such as for PFOS and perfluorooctanoic acid (PFOA). Substitutions like these are only single changes and not a full re-engineering of the product, which is unprecedented, as discussed further in Section 3.4.1. Where previous substitutions are not applicable, timelines have been estimated on engineering judgement based on the information to the best of the Semiconductor PFAS Consortium’s knowledge at the time of publication of this report. However, many of the timelines have a degree of uncertainty due to the number of steps still left to be undertaken and the possibility of unforeseen challenges yet to be identified. In addition to these impacts, chemical, material and equipment suppliers would be significantly disrupted if PFAS were no longer able to be used because so many applications in semiconductor production are reliant on these substances. This would represent a critical and continual innovation challenge to industry. The timeframes for qualification of alternatives outlined in this report are wherever possible extrapolated from other qualifications, such as for PFOS and perfluorooctanoic acid (PFOA). Substitutions like these are only single changes and not a full re-engineering of the product, which is unprecedented, as discussed further in Section 3.4.1. Where previous substitutions are not applicable, timelines have been estimated on engineering judgement based on the information to the best of the Semiconductor PFAS Consortium’s knowledge at the time of publication of this report. However, many of the timelines have a degree of uncertainty due to the number of steps still left to be undertaken and the possibility of unforeseen challenges yet to be identified. In addition to these impacts, chemical, material and equipment suppliers would be significantly disrupted if PFAS were no longer able to be used because so many applications in semiconductor production are reliant on these substances. This would represent a critical and continual innovation challenge to industry. 3.3 Incentives for PFAS substitution The semiconductor industry is a global leader in promoting environmental sustainability in the design, manufacture, and use of its products, as well as the health and safety of its operations and impacts on workers in semiconductor fabrication facilities (fabs). Semiconductor industry companies recognise the importance of substituting PFAS where possible and where it does not create worker or community safety concerns. Despite this, there are still significant technical challenges to be overcome for a large number of PFAS uses in semiconductor applications due to the critical functionality they provide to the industry. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 29 237 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 3.3 Incentives for PFAS substitution The semiconductor industry is a global leader in promoting environmental sustainability in the design, manufacture, and use of its products, as well as the health and safety of its operations and impacts on workers in semiconductor fabrication facilities (fabs). Semiconductor industry companies recognise the importance of substituting PFAS where possible and where it does not create worker or community safety concerns. Despite this, there are still significant technical challenges to be overcome for a large number of PFAS uses in semiconductor applications due to the critical functionality they provide to the industry. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 29 237 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 3.4 Challenges to substitution Capabilities in the fluorochemical and semiconductor industries have evolved synergistically since 1971 with fluorocarbons being a key enabling technology to node size development in all aspects of semiconductor manufacturing. Finding another chemistry and technology which can match and exceed the PFAS application will require for many applications, investment in fundamental research and development to identify a PFAS free alternative. In broad terms, PFAS offer a unique set of technical characteristics, which include exceptional heat and chemical resistance, high electrical insulation resistance, high purity, low-outgassing and low coefficient of friction. One of the characteristic <;7IJG;H E< I>; (P+ 8ED: ?H ?IH HIG;D=I> 9ECF7G;: L?I> I>; (P( bond, due to the intrinsic electron-withdrawing power (electronegativity) of the fluorine atom. This intrinsic attribute is the basis of many of the technical benefits of fluorinated materials in semiconductor processing, but this also leads to its chemical stability and environmental persistence. Fluorination brings unique physiochemical properties and consequent qualitative improvements that are the enabler of semiconductor, performance and manufacture, advancements. These unique properties make substituting PFAS a challenge. 3.4 Challenges to substitution Capabilities in the fluorochemical and semiconductor industries have evolved synergistically since 1971 with fluorocarbons being a key enabling technology to node size development in all aspects of semiconductor manufacturing. Finding another chemistry and technology which can match and exceed the PFAS application will require for many applications, investment in fundamental research and development to identify a PFAS free alternative. In broad terms, PFAS offer a unique set of technical characteristics, which include exceptional heat and chemical resistance, high electrical insulation resistance, high purity, low-outgassing and low coefficient of friction. One of the characteristic <;7IJG;H E< I>; (P+ 8ED: ?H ?IH HIG;D=I> 9ECF7G;: L?I> I>; (P( bond, due to the intrinsic electron-withdrawing power (electronegativity) of the fluorine atom. This intrinsic attribute is the basis of many of the technical benefits of fluorinated materials in semiconductor processing, but this also leads to its chemical stability and environmental persistence. Fluorination brings unique physiochemical properties and consequent qualitative improvements that are the enabler of semiconductor, performance and manufacture, advancements. These unique properties make substituting PFAS a challenge. PFAS is used in gaseous, liquid, and solid forms, and is used in many different applications, which need to work together to form a coherent production process. Some of the uses, such as cleaning fluids and lubricants, have dependencies on one another, and finding alternatives for cleaning fluids can only be started once all PFAS containing lubricants are substituted. Removing PFAS from earlier process steps can result in deterioration of performance which makes the later steps in the process impossible due to excessive defect rates, such as moving to a silicone-based alternative resulting in excessive defects. This complexity and interdependency are discussed in Section 2.2. Elimination or substitution of a whole class of chemicals, like PFAS, is unprecedented and will add a significant amount of time to identify and implement each alternative due to the following: PFAS is used in gaseous, liquid, and solid forms, and is used in many different applications, which need to work together to form a coherent production process. Some of the uses, such as cleaning fluids and lubricants, have dependencies on one another, and finding alternatives for cleaning fluids can only be started once all PFAS containing lubricants are substituted. Removing PFAS from earlier process steps can result in deterioration of performance which makes the later steps in the process impossible due to excessive defect rates, such as moving to a silicone-based alternative resulting in excessive defects. This complexity and interdependency are discussed in Section 2.2. Elimination or substitution of a whole class of chemicals, like PFAS, is unprecedented and will add a significant amount of time to identify and implement each alternative due to the following: • Each alternative must first show suitable performance in its technical parameters or the combination of its technical parameters but will also need to be tested to ensure that there are no negative impacts to all other substitutions as well. Parameters such as yield, and production performance need to be maintained. This could require changes in the design of the devices, as well as changes in the manufacturing process to accommodate the properties of alternate materials – thus triggering the need for rigorous testing to ensure it does not have a detrimental impact on the function and performance of the device. Due to the number of changing parameters which need to be investigated this poses a significant challenge. • Availability of skilled engineers and leadership within the market has already been highlighted as limited, moreover, owing to the complexity of the products this shortage has an even higher impact. This limits the ability of manufacturers to implement all of the solutions at any one time and would result in the decrease or halt of research and development activities (R&D). It is important to note that those engineers will be diverted from their normal function of R&D for new innovations and products, production optimisation, and quality improvement activities. • Each alternative must first show suitable performance in its technical parameters or the combination of its technical parameters but will also need to be tested to ensure that there are no negative impacts to all other substitutions as well. Parameters such as yield, and production performance need to be maintained. This could require changes in the design of the devices, as well as changes in the manufacturing process to accommodate the properties of alternate materials – thus triggering the need for rigorous testing to ensure it does not have a detrimental impact on the function and performance of the device. Due to the number of changing parameters which need to be investigated this poses a significant challenge. • Availability of skilled engineers and leadership within the market has already been highlighted as limited, moreover, owing to the complexity of the products this shortage has an even higher impact. This limits the ability of manufacturers to implement all of the solutions at any one time and would result in the decrease or halt of research and development activities (R&D). It is important to note that those engineers will be diverted from their normal function of R&D for new innovations and products, production optimisation, and quality improvement activities. 3.4.1 Regrettable Substitution For a PFAS alternative to be successful, it must not only pass through all the qualification timeline stages successfully and provide effective performance for the application, but it must also be a sustainable alternative that can be used without impact to human health or the environment. When deciding whether to restrict a substance it is always important to consider whether safer alternatives exist. Where alternatives are identified which are more harmful than, or no better than, the © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 30 238 The Impact of a Potential PFAS Restriction on the Semiconductor Sector substances currently in use, these substances should not be considered as a potential alternative and should not be taken forward (e.g., for development) in the Semiconductor PFAS Consortium’s opinion. 3.4.1 Regrettable Substitution For a PFAS alternative to be successful, it must not only pass through all the qualification timeline stages successfully and provide effective performance for the application, but it must also be a sustainable alternative that can be used without impact to human health or the environment. When deciding whether to restrict a substance it is always important to consider whether safer alternatives exist. Where alternatives are identified which are more harmful than, or no better than, the © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 30 238 The Impact of a Potential PFAS Restriction on the Semiconductor Sector substances currently in use, these substances should not be considered as a potential alternative and should not be taken forward (e.g., for development) in the Semiconductor PFAS Consortium’s opinion. Potential alternatives can be relatively new substances and/or substances made in smaller quantities where much less research has been carried out regarding their health and environmental hazards, as compared to current substances in use that have been thoroughly studied. Alternatives and their hazards are not always known, and for many of these instances it is not unreasonable to assume that they are likely to present similar concerns to PFAS. This is based on the understanding that their desired characteristics and therefore environmental controls and concerns would be of similar nature to the ones implemented for the use of PFAS. Informed substitution is therefore crucial. If the replacement is not carefully considered for its own potentially deleterious effects, regrettable substitution can easily occur. A sufficiently long transition time is crucial to ensure proper research into alternatives. Indications of these timeframes are given in each of the sections below which consider the various stages where PFAS are used. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 31 239 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Potential alternatives can be relatively new substances and/or substances made in smaller quantities where much less research has been carried out regarding their health and environmental hazards, as compared to current substances in use that have been thoroughly studied. Alternatives and their hazards are not always known, and for many of these instances it is not unreasonable to assume that they are likely to present similar concerns to PFAS. This is based on the understanding that their desired characteristics and therefore environmental controls and concerns would be of similar nature to the ones implemented for the use of PFAS. Informed substitution is therefore crucial. If the replacement is not carefully considered for its own potentially deleterious effects, regrettable substitution can easily occur. A sufficiently long transition time is crucial to ensure proper research into alternatives. Indications of these timeframes are given in each of the sections below which consider the various stages where PFAS are used. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 31 239 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 4 PHOTOLITHOGRAPHY USES Summary: PFAS has been an enabling technology in the development of ever smaller and more advanced semiconductors over the last 30 years through cutting edge lithographic developments. • Photoacid generators (PAGs) are key components of the Chemically Amplified Resists (CARs) that are used in advanced lithography. They generate strong acids on exposure to UV light, and the chemistry requires sulfonium and iodonium-acid salts with fluorinated anions. The strong electronegativity of the fluorine atom creates a super acids capable of causing the solubility change of the photoresist. All successfully demonstrated PAGs are fluorinated, some down to one CF2 unit, and there are no universally applicable viable fluorine free alternatives for a vast array of lithographic materials. Current photoacid generators have been in development for 25 years, and alternatives are expected to take from 15 to more than 20 years to reach production. For an alternative to be successful it would have to show acidity comparable to perfluoro sulfonic acids, show similar lack of side reactions, lack volatility, and show minimum diffusivity for high resolution patterns. 4 PHOTOLITHOGRAPHY USES Summary: PFAS has been an enabling technology in the development of ever smaller and more advanced semiconductors over the last 30 years through cutting edge lithographic developments. • Photoacid generators (PAGs) are key components of the Chemically Amplified Resists (CARs) that are used in advanced lithography. They generate strong acids on exposure to UV light, and the chemistry requires sulfonium and iodonium-acid salts with fluorinated anions. The strong electronegativity of the fluorine atom creates a super acids capable of causing the solubility change of the photoresist. All successfully demonstrated PAGs are fluorinated, some down to one CF2 unit, and there are no universally applicable viable fluorine free alternatives for a vast array of lithographic materials. Current photoacid generators have been in development for 25 years, and alternatives are expected to take from 15 to more than 20 years to reach production. For an alternative to be successful it would have to show acidity comparable to perfluoro sulfonic acids, show similar lack of side reactions, lack volatility, and show minimum diffusivity for high resolution patterns. • Top antireflective coatings (TARCs) require a very low refractive index, low surface energy and excellent barrier properties, which are provided in fluorinated acrylate / methacrylate / styrene-based copolymers. The requirements differ between “193 nm” and “193 nm immersion” lithography, but no currently, viable alternative materials exist for either application. Fluorine free systems have resulted in patterning failure in immersion processes. • Top antireflective coatings (TARCs) require a very low refractive index, low surface energy and excellent barrier properties, which are provided in fluorinated acrylate / methacrylate / styrene-based copolymers. The requirements differ between “193 nm” and “193 nm immersion” lithography, but no currently, viable alternative materials exist for either application. Fluorine free systems have resulted in patterning failure in immersion processes. • PFAS Surfactants have unique properties, such as very low surface tension and a combination of hydrophobic and oleophobic behaviour, that have been utilised in various types of photolithographic materials. Applications include photoresists (248nm, 193nm, immersion, thick film, etc.), BARCs, TARCs, colour resists for image sensing, and rinse solutions. The surfactants are used to improve film quality, alter surface interaction, wetting characteristics, and component mixing, all of which helps to minimise various defectivities in the lithographic process and thus increase lithographic impacted yield. It may be possible to find non-PFAS alternatives for less advanced applications using current known potential alternatives, such as siloxane-based surfactants. However, for most advanced applications, siloxane (or other) alternatives cannot duplicate performance characteristics that PFAS surfactants offer and would lead to compromised performance. • PFAS Surfactants have unique properties, such as very low surface tension and a combination of hydrophobic and oleophobic behaviour, that have been utilised in various types of photolithographic materials. Applications include photoresists (248nm, 193nm, immersion, thick film, etc.), BARCs, TARCs, colour resists for image sensing, and rinse solutions. The surfactants are used to improve film quality, alter surface interaction, wetting characteristics, and component mixing, all of which helps to minimise various defectivities in the lithographic process and thus increase lithographic impacted yield. It may be possible to find non-PFAS alternatives for less advanced applications using current known potential alternatives, such as siloxane-based surfactants. However, for most advanced applications, siloxane (or other) alternatives cannot duplicate performance characteristics that PFAS surfactants offer and would lead to compromised performance. • Immersion top coatings require very low surface energy (resulting in very high water contact angles), excellent barrier properties and a lack of intermixing with the photoresist, which are provided in fluorinated acrylate / methacrylate / styrene-based copolymers. The requirements differ between “193 nm” and “193 nm immersion” lithography, but currently, no viable alternative materials exist for either application and there are not even any concepts for PFAS replacement for this application. Fluorine free systems have resulted in patterning failure in immersion processes. • Current PFAS materials were designed, developed, and optimised as dedicated substances to satisfy many functions and performance needs in lithographic imaging products. Thus, replacement with a new non-PFAS material will likely require multiple solutions depending on the application, which has a significant impact on the estimated timelines. • The consumption of PFAS for photolithography is quite low with very small releases when compared to global releases. 32 ______ 32 When compared to 470 Tons of PFAS surfactants in fire foams as described in the European Chemicals Agency reports. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 32 • Immersion top coatings require very low surface energy (resulting in very high water contact angles), excellent barrier properties and a lack of intermixing with the photoresist, which are provided in fluorinated acrylate / methacrylate / styrene-based copolymers. The requirements differ between “193 nm” and “193 nm immersion” lithography, but currently, no viable alternative materials exist for either application and there are not even any concepts for PFAS replacement for this application. Fluorine free systems have resulted in patterning failure in immersion processes. • Current PFAS materials were designed, developed, and optimised as dedicated substances to satisfy many functions and performance needs in lithographic imaging products. Thus, replacement with a new non-PFAS material will likely require multiple solutions depending on the application, which has a significant impact on the estimated timelines. • The consumption of PFAS for photolithography is quite low with very small releases when compared to global releases. 32 ______ 32 When compared to 470 Tons of PFAS surfactants in fire foams as described in the European Chemicals Agency reports. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 32 240 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Photolithography is a patterning process in which a photosensitive film, called a photoresist, is selectively exposed to light to provide a pattern to an underlying substrate, with the chemistry of photoresists and role of PFAS different for different wavelengths. Photolithography is a critical process step in the mass production of a semiconductor, with the most advanced devices requiring over 70 photolithographic steps in their production. On average a minimum of 10 years is required to take a new product to market, from concept through development and deployment. This is assuming alternatives are known and commercially available. Although the total amount of PFAS used in photolithography is small when compared to global consumption and releases of PFAS32, the addition of small quantities of fluorinated materials enables patterning capabilities that are otherwise not possible to achieve, this leads to superior device performance. In comparison to the 836,787 tonnes of 2020 EU PFAS brought new to market, 33 the semiconductor industry uses less than 2.3 tonnes per year of PFAS in photolithography in the European Economic Area. The following uses of PFAS in photolithography have been listed, with a short description of their technical criteria: 240 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Photolithography is a patterning process in which a photosensitive film, called a photoresist, is selectively exposed to light to provide a pattern to an underlying substrate, with the chemistry of photoresists and role of PFAS different for different wavelengths. Photolithography is a critical process step in the mass production of a semiconductor, with the most advanced devices requiring over 70 photolithographic steps in their production. On average a minimum of 10 years is required to take a new product to market, from concept through development and deployment. This is assuming alternatives are known and commercially available. Although the total amount of PFAS used in photolithography is small when compared to global consumption and releases of PFAS32, the addition of small quantities of fluorinated materials enables patterning capabilities that are otherwise not possible to achieve, this leads to superior device performance. In comparison to the 836,787 tonnes of 2020 EU PFAS brought new to market, 33 the semiconductor industry uses less than 2.3 tonnes per year of PFAS in photolithography in the European Economic Area. The following uses of PFAS in photolithography have been listed, with a short description of their technical criteria: 1. Component of surfactants, 2. Component of photoacid generators (PAGs) in chemically amplified resists (CARs) and bottom anti-reflective coatings (BARCs), 3. As low refractive index materials in top antireflective coatings (TARCs), which are used to control thin film interference effects in photoresist layers as substrates are not perfectly flat and otherwise this will detrimentally affect the photoresist imaging fidelity, 4. As barrier layers in immersion lithography, 5. Photo-imageable polybenzoxazoles and polyimides for dielectric and buffer coat applications, and 6. Photoresist applications. The various types of photolithographic materials and their applications have recently been reviewed in the 2022 Ober paper 34, with a key summary of PFAS uses outlined in Table 4-1. Table 4-1 Key photolithography PFAS uses and technical criteria. 1. Component of surfactants, 2. Component of photoacid generators (PAGs) in chemically amplified resists (CARs) and bottom anti-reflective coatings (BARCs), 3. As low refractive index materials in top antireflective coatings (TARCs), which are used to control thin film interference effects in photoresist layers as substrates are not perfectly flat and otherwise this will detrimentally affect the photoresist imaging fidelity, 4. As barrier layers in immersion lithography, 5. Photo-imageable polybenzoxazoles and polyimides for dielectric and buffer coat applications, and 6. Photoresist applications. The various types of photolithographic materials and their applications have recently been reviewed in the 2022 Ober paper 34, with a key summary of PFAS uses outlined in Table 4-1. Table 4-1 Key photolithography PFAS uses and technical criteria. PFAS use Function Types of compounds used PFAS provide area Longer chain PFAS (C6-C8) and Improved coating Photoresists telomer alcohols pending form uniformity. Post develop Low surface tension, and BARCs – polymer backbones. Now mostly rinses: prevention of control of contact angle. Surfactants replaced by C4 pendant chains. pattern collapse. Rinses: C4 surfactants. ______ 33 ANNEX XV RESTRICTION REPORT, Proposal for a restriction, Per- and polyfluoroalkyl substances (PFAS) by European Chemicals Agency 2023, Annex XV reporting format 040615 (europa.eu) 34 Christopher K. Ober, Florian Käfer, and Jingyuan Deng, “Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing,” Journal of Micro/Nanopatterning, Materials, and Metrology, Vol. 21, Issue 1, 010901 (March 2022). https://doi.org/10.1117/1.JMM.21.1.010901 PFAS use Function Types of compounds used PFAS provide area Longer chain PFAS (C6-C8) and Improved coating Photoresists telomer alcohols pending form uniformity. Post develop Low surface tension, and BARCs – polymer backbones. Now mostly rinses: prevention of control of contact angle. Surfactants replaced by C4 pendant chains. pattern collapse. Rinses: C4 surfactants. ______ 33 ANNEX XV RESTRICTION REPORT, Proposal for a restriction, Per- and polyfluoroalkyl substances (PFAS) by European Chemicals Agency 2023, Annex XV reporting format 040615 (europa.eu) 34 Christopher K. Ober, Florian Käfer, and Jingyuan Deng, “Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing,” Journal of Micro/Nanopatterning, Materials, and Metrology, Vol. 21, Issue 1, 010901 (March 2022). https://doi.org/10.1117/1.JMM.21.1.010901 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 33 241 The Impact of a Potential PFAS Restriction on the Semiconductor Sector © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 33 241 The Impact of a Potential PFAS Restriction on the Semiconductor Sector PFAS use Function Types of compounds used PFAS provide area PFAS component of PAGs Perfluoroalkylsulfonates C4 or Precursor for the generates strong acids Photoresists lower and C4 or lower substituted photoacid catalyst that do not show side and BARCs – superacid anions such as C1. For needed for CARs and reactions that interfere PAGs some advanced resists, these are BARCs. with the chemical bound to polymers. amplification process. Increases absorbance, Photoresists – Control pattern profile in improves the dissolution C1 PFAS polymer. polymers EUV. properties, increases resolution. High fluorine content is Control of thin film needed to achieve the low Fluorinated water and developer TARCs interference effects in refractive index needed to soluble polymers. resists. effectively suppress film interference effects. PFAS use Function Types of compounds used PFAS provide area PFAS component of PAGs Perfluoroalkylsulfonates C4 or Precursor for the generates strong acids Photoresists lower and C4 or lower substituted photoacid catalyst that do not show side and BARCs – superacid anions such as C1. For needed for CARs and reactions that interfere PAGs some advanced resists, these are BARCs. with the chemical bound to polymers. amplification process. Increases absorbance, Photoresists – Control pattern profile in improves the dissolution C1 PFAS polymer. polymers EUV. properties, increases resolution. High fluorine content is Control of thin film needed to achieve the low Fluorinated water and developer TARCs interference effects in refractive index needed to soluble polymers. resists. effectively suppress film interference effects. Spin-on barriers: Water insoluble Barriers that are soluble in Protection of the resist and developer soluble polymers casting solvents, insoluble from immersion liquid and with fluorinated side chains. in water but soluble in of the exposure tool from developer, and that show contamination. Embedded barriers: oligomeric or no intermixing with Immersion low molecular weight polymeric photoresists. barriers Prevent water film pulling highly fluorinated compounds. and resist component Hydrophobicity and control leaching in immersion Fluoroalcohol methacrylate of contact angle, inert topcoats. polymers with high water contact under 193nm radiation, angles (in the order of >90o). and transparency. Provide electrical, C1 PFAS groups attached thermal, and mechanical to the polymer backbone Dielectric protection for the provide solubility in Water-insoluble C1 PFAS Polymers semiconductor device. environmentally friendly polymers. (PBO/PI) Also protects the device casting solvents and components from the enable aqueous impact of moisture. development. Spin-on barriers: Water insoluble Barriers that are soluble in Protection of the resist and developer soluble polymers casting solvents, insoluble from immersion liquid and with fluorinated side chains. in water but soluble in of the exposure tool from developer, and that show contamination. Embedded barriers: oligomeric or no intermixing with Immersion low molecular weight polymeric photoresists. barriers Prevent water film pulling highly fluorinated compounds. and resist component Hydrophobicity and control leaching in immersion Fluoroalcohol methacrylate of contact angle, inert topcoats. polymers with high water contact under 193nm radiation, angles (in the order of >90o). and transparency. Provide electrical, C1 PFAS groups attached thermal, and mechanical to the polymer backbone Dielectric protection for the provide solubility in Water-insoluble C1 PFAS Polymers semiconductor device. environmentally friendly polymers. (PBO/PI) Also protects the device casting solvents and components from the enable aqueous impact of moisture. development. Owing to the changing technological challenges as the wavelength of exposure decreases, different PFAS uses are required depending on the technology used. Table 4-2 aims to outline this differing need at a high level. Table 4-2 PFAS use in photolithography according to exposure technology. Wavelength PFAS use Technical requirement (nm) • Mostly surfactants 365 nm and • Some PAGs in niche photoresists Surface levelling, resolution enhancement. larger • Photoimageable polybenzoxazoles • Polyimide • Surfactants 365nm resists were insufficiently transparent so 248 nm • Photoimageable polybenzoxazoles alternative CAR resists were developed requiring and polyimide PAG. • PAG © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 34 242 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Owing to the changing technological challenges as the wavelength of exposure decreases, different PFAS uses are required depending on the technology used. Table 4-2 aims to outline this differing need at a high level. Table 4-2 PFAS use in photolithography according to exposure technology. Wavelength PFAS use Technical requirement (nm) • Mostly surfactants 365 nm and • Some PAGs in niche photoresists Surface levelling, resolution enhancement. larger • Photoimageable polybenzoxazoles • Polyimide • Surfactants 365nm resists were insufficiently transparent so 248 nm • Photoimageable polybenzoxazoles alternative CAR resists were developed requiring and polyimide PAG. • PAG © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 34 242 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Wavelength PFAS use Technical requirement (nm) • Surfactants • Photoimageable polybenzoxazoles 248 nm resists were insufficiently transparent, 193 nm and polyimide requiring a new chemistry for 193 nm resists that only • A limited number of PAGs works with PAGs that make very strong acids. • Immersion barriers 13.5 nm Low acid diffusivity in photoresists and underlayers. • Surfactants (EUV • PAGs (frequently polymer bound) Increases absorbance, improves the dissolution resists) properties, increases resolution. Material changes for lithographic materials are not easy nor quickly achieved, with PAGs in chemically amplified resists having been under development for at least 25 years. Current PFAS materials were designed, developed, and optimised as dedicated substances to satisfy many functions and performance needs in lithographic imaging products. Thus, replacement with a new non-PFAS material will likely require multiple solutions depending on the application. Wavelength PFAS use Technical requirement (nm) • Surfactants • Photoimageable polybenzoxazoles 248 nm resists were insufficiently transparent, 193 nm and polyimide requiring a new chemistry for 193 nm resists that only • A limited number of PAGs works with PAGs that make very strong acids. • Immersion barriers 13.5 nm Low acid diffusivity in photoresists and underlayers. • Surfactants (EUV • PAGs (frequently polymer bound) Increases absorbance, improves the dissolution resists) properties, increases resolution. Material changes for lithographic materials are not easy nor quickly achieved, with PAGs in chemically amplified resists having been under development for at least 25 years. Current PFAS materials were designed, developed, and optimised as dedicated substances to satisfy many functions and performance needs in lithographic imaging products. Thus, replacement with a new non-PFAS material will likely require multiple solutions depending on the application. Each new material must satisfy multiple performance characteristics that may be impacted by the change, as outlined in Table 4-3. As a result, each new non-PFAS replacement product containing the new non-PFAS material(s) must be optimised to satisfy multiple performance characteristics, while not detrimentally impacting others to fully meet all customer requirements. Table 4-3 Photolithography potential PFAS replacement viability and timeline uses and technical criteria. Timeline to Concern of PFAS use area Criticality for manufacture develop alternative Commercial CARs and BARCs: replacement silicon-based materials exist. Replacement maybe surfactants developed For applications At high levels, possible in many for some applications; that do not have silicon surfactants applications, but there will not suitable for all existing may cause etch be exceptions due to applications. commercial defects. replacement replacements, capability/functionality. invention is required. Surfactants Active area of Rinses: non-PFAS Still need to research; time to aqueous surfactants – demonstrate Critical for advanced prototype 1-2 active area of research. equivalent lithography. years. performance. Each new material must satisfy multiple performance characteristics that may be impacted by the change, as outlined in Table 4-3. As a result, each new non-PFAS replacement product containing the new non-PFAS material(s) must be optimised to satisfy multiple performance characteristics, while not detrimentally impacting others to fully meet all customer requirements. Table 4-3 Photolithography potential PFAS replacement viability and timeline uses and technical criteria. Timeline to Concern of PFAS use area Criticality for manufacture develop alternative Commercial CARs and BARCs: replacement silicon-based materials exist. Replacement maybe surfactants developed For applications At high levels, possible in many for some applications; that do not have silicon surfactants applications, but there will not suitable for all existing may cause etch be exceptions due to applications. commercial defects. replacement replacements, capability/functionality. invention is required. Surfactants Active area of Rinses: non-PFAS Still need to research; time to aqueous surfactants – demonstrate Critical for advanced prototype 1-2 active area of research. equivalent lithography. years. performance. Total development time for surfactants up to 15 years after invention. PFAS free alternatives PFAS free PAG A PFAS free PAG Critical: currently most PAGs in do not show suitable 5+ years of of equivalent CARs for any node use CARs and performance. BARCs invention, performance has PFAS. PAGS and all estimated never been production of chips below © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 35 243 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Total development time for surfactants up to 15 years after invention. PFAS free alternatives PFAS free PAG A PFAS free PAG Critical: currently most PAGs in do not show suitable 5+ years of of equivalent CARs for any node use CARs and performance. BARCs invention, performance has PFAS. PAGS and all estimated never been production of chips below © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 35 243 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Timeline to Concern of PFAS use area Criticality for manufacture develop alternative timeline to developed so this 40 nm node is impossible implement from may not be without PFAS CARs. 15 to more than technically possible See Table 4-4 for more 20 years after for all applications information. invention. or wave-lengths. Any substitution will likely have to be limited to certain applications only. Currently only possible to replace for 248nm resists or those exposed at larger wavelength. Substitution with Substitution with lower chain PFAS: lower chain Replacement with requires significant PFAS: 10+ shorter chain, lower work to be years to re- molecular weight PFAS undertaken and qualify and fails due to volatility and resources would assess impact diffusivity. have to be diverted on subsequent from developments process steps. in innovation. Refractive index of Current implant processes 1.3 -1.4 needed to use TARC as an effective Originally salts of PFOA be effective. For way of reflectivity and or PFOS were used but New research ease of use and defectivity control. replaced ~ 2004 with needed. defect control, it is Alternatives are more other PFAS that show advantageous to complex and require lower bioavailability and spin TARCs on additional processing. bioaccumulation. using water as the solvent. Concepts for Some concepts for replacements exist but PFAS-Free TARCs are unproven and need Timeline for unavoidably lead to TARCs to offer suitable invention 5+ significant loss of performance in terms of years and wafer throughput, thickness, uniformity, development another 8+ e.g., dyed TARCs 35 coat quality, surface years. have a 20-30% energy, edge bead, wafer throughput roughness, gap-fill, and loss. aging at various temperatures. Total Silicon anti-reflective development coating materials are time from 11 to under evaluation. more than 13 years after Timeline to Concern of PFAS use area Criticality for manufacture develop alternative timeline to developed so this 40 nm node is impossible implement from may not be without PFAS CARs. 15 to more than technically possible See Table 4-4 for more 20 years after for all applications information. invention. or wave-lengths. Any substitution will likely have to be limited to certain applications only. Currently only possible to replace for 248nm resists or those exposed at larger wavelength. Substitution with Substitution with lower chain PFAS: lower chain Replacement with requires significant PFAS: 10+ shorter chain, lower work to be years to re- molecular weight PFAS undertaken and qualify and fails due to volatility and resources would assess impact diffusivity. have to be diverted on subsequent from developments process steps. in innovation. Refractive index of Current implant processes 1.3 -1.4 needed to use TARC as an effective Originally salts of PFOA be effective. For way of reflectivity and or PFOS were used but New research ease of use and defectivity control. replaced ~ 2004 with needed. defect control, it is Alternatives are more other PFAS that show advantageous to complex and require lower bioavailability and spin TARCs on additional processing. bioaccumulation. using water as the solvent. Concepts for Some concepts for replacements exist but PFAS-Free TARCs are unproven and need Timeline for unavoidably lead to TARCs to offer suitable invention 5+ significant loss of performance in terms of years and wafer throughput, thickness, uniformity, development another 8+ e.g., dyed TARCs 35 coat quality, surface years. have a 20-30% energy, edge bead, wafer throughput roughness, gap-fill, and loss. aging at various temperatures. Total Silicon anti-reflective development coating materials are time from 11 to under evaluation. more than 13 years after ______ 35 Ralph R. Dammel and Robert A. Norwood, “Light-absorbing antireflective coatings with improved performance due to refractive index optimization,” US patent 6,274,295 B1 (2001) and, Wu-Song Huang, William H. Heath, Ranee Kwong, Wenjie Li, Kaushal Patel, Pushkara Rao Varanasi, "New 193-nm top antireflective coatings for superior swing reduction," Proc. SPIE 6153, Advances in Resist Technology and Processing XXIII, 61530S (29 March 2006); doi: 10.1117/12.656641 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 36 244 The Impact of a Potential PFAS Restriction on the Semiconductor Sector ______ 35 Ralph R. Dammel and Robert A. Norwood, “Light-absorbing antireflective coatings with improved performance due to refractive index optimization,” US patent 6,274,295 B1 (2001) and, Wu-Song Huang, William H. Heath, Ranee Kwong, Wenjie Li, Kaushal Patel, Pushkara Rao Varanasi, "New 193-nm top antireflective coatings for superior swing reduction," Proc. SPIE 6153, Advances in Resist Technology and Processing XXIII, 61530S (29 March 2006); doi: 10.1117/12.656641 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 36 244 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Timeline to Concern of PFAS use area Criticality for manufacture develop alternative invention for TARCs. There currently is no known concept for a non-PFAS material that Current can combine all the assessment is necessary properties. that replacement Production of chips Properties include Critical – no known requires below the 40 nm Immersion soluble in casting alternatives to PFAS, no invention, but no node is not barriers solvents and developer, concepts for concept possible without but insoluble in water, replacements. currently exists immersion barriers. no intermixing with for photoresists, very high- replacement. water contact angles (>90o) to prevent watermark defects. Dielectric PFAS free alternatives New research PFAS free Critical for advanced Polymers either don’t show needed to alternatives semiconductor packaging. (PBO/PI) suitable performance or develop soluble currently require require the use of highly PFAS free the use of highly toxic casting solvents. polymers. toxic casting solvents. Total Lack of PFAS in development the backbone can time of 15+ result in resolution years after and aqueous invention for development PBO/PI. issues. Timeline to Concern of PFAS use area Criticality for manufacture develop alternative invention for TARCs. There currently is no known concept for a non-PFAS material that Current can combine all the assessment is necessary properties. that replacement Production of chips Properties include Critical – no known requires below the 40 nm Immersion soluble in casting alternatives to PFAS, no invention, but no node is not barriers solvents and developer, concepts for concept possible without but insoluble in water, replacements. currently exists immersion barriers. no intermixing with for photoresists, very high- replacement. water contact angles (>90o) to prevent watermark defects. Dielectric PFAS free alternatives New research PFAS free Critical for advanced Polymers either don’t show needed to alternatives semiconductor packaging. (PBO/PI) suitable performance or develop soluble currently require require the use of highly PFAS free the use of highly toxic casting solvents. polymers. toxic casting solvents. Total Lack of PFAS in development the backbone can time of 15+ result in resolution years after and aqueous invention for development PBO/PI. issues. 4.1 Photoacid Generators (PAG) Photoacid generators (PAG), are photoactivated acid compounds which, when irradiated with high energy light (deep ultraviolet or EUV), undergo photodissociation generating extremely strong, non- reactive and stable acids. Currently there are somewhere between 100 and 150 PAGs used in CARs worldwide. They are used in relatively small quantities overall. 36 The individual use of a PAG is dependent upon the overall parameters that must be met in the CAR – the chemical, physical and imaging/print quality characteristics. Because of this, there is no single PAG that is suitable for use in all CAR applications. PAG precursors need to be sufficiently soluble in good casting solvents. The acids need to be sufficiently strong to cause the solubility change, non-absorbing at key wavelengths to avoid pattern disruption, have a low volatility to not evaporate from the resist films and not undergo side reactions which would destroy the acid catalyst. 37 In addition to this, with smaller node sizes the right amount of diffusivity is also required. However, when investigating alternatives, the following properties also need to be investigated; final resolution, exposure latitude, focus window, wall angle, top retention, or isolated to dense feature bias. These parameters result in different optical proximity correction requirements and 4.1 Photoacid Generators (PAG) Photoacid generators (PAG), are photoactivated acid compounds which, when irradiated with high energy light (deep ultraviolet or EUV), undergo photodissociation generating extremely strong, non- reactive and stable acids. Currently there are somewhere between 100 and 150 PAGs used in CARs worldwide. They are used in relatively small quantities overall. 36 The individual use of a PAG is dependent upon the overall parameters that must be met in the CAR – the chemical, physical and imaging/print quality characteristics. Because of this, there is no single PAG that is suitable for use in all CAR applications. PAG precursors need to be sufficiently soluble in good casting solvents. The acids need to be sufficiently strong to cause the solubility change, non-absorbing at key wavelengths to avoid pattern disruption, have a low volatility to not evaporate from the resist films and not undergo side reactions which would destroy the acid catalyst. 37 In addition to this, with smaller node sizes the right amount of diffusivity is also required. However, when investigating alternatives, the following properties also need to be investigated; final resolution, exposure latitude, focus window, wall angle, top retention, or isolated to dense feature bias. These parameters result in different optical proximity correction requirements and ______ 36 As outlined in Table 4-5 Organic Polymers of which PAGs are a portion thereof has a consumption figure of 9,276 kg/year globally for 2021. 37 Something that standard strong acids such as hydrogen chloride or bromide would readily do. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 37 245 The Impact of a Potential PFAS Restriction on the Semiconductor Sector hence in the need to procure a new mask set for the resist. Finally, the wafers patterned with new resist have to be tested for performance in subsequent process steps. This process is sufficiently demanding that most chip manufacturers have special integration teams assigned to it and this often takes 3 years or more. ______ 36 As outlined in Table 4-5 Organic Polymers of which PAGs are a portion thereof has a consumption figure of 9,276 kg/year globally for 2021. 37 Something that standard strong acids such as hydrogen chloride or bromide would readily do. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 37 245 The Impact of a Potential PFAS Restriction on the Semiconductor Sector hence in the need to procure a new mask set for the resist. Finally, the wafers patterned with new resist have to be tested for performance in subsequent process steps. This process is sufficiently demanding that most chip manufacturers have special integration teams assigned to it and this often takes 3 years or more. Non-PFAS PAGs generally lack the acidity to perform in current platforms and this prevents the required reactions from progressing. Potential alternatives such as pentacyanocyclopentadiene (CN5) were investigated, 38 however, it was found to have strong absorption at 248nm preventing it being used at that wavelength. Its use in 193nm was found to have half of the processing speed of PFAS alternatives, and toxicological testing in rats found the presence of cyanide. Nitro-substituted thiophene was also investigated by the same team but also found to have an inferior standard of performance. There are initial indications that bis-sulfonyldiazomethanes might be suitable in 248nm but not at 193nm due to the weaker acids generated, however this needs to be fully investigated. Non-PFAS PAGs generally lack the acidity to perform in current platforms and this prevents the required reactions from progressing. Potential alternatives such as pentacyanocyclopentadiene (CN5) were investigated, 38 however, it was found to have strong absorption at 248nm preventing it being used at that wavelength. Its use in 193nm was found to have half of the processing speed of PFAS alternatives, and toxicological testing in rats found the presence of cyanide. Nitro-substituted thiophene was also investigated by the same team but also found to have an inferior standard of performance. There are initial indications that bis-sulfonyldiazomethanes might be suitable in 248nm but not at 193nm due to the weaker acids generated, however this needs to be fully investigated. Amongst known substitutes, IBM have developed non-PFAS PAGs (CN5 and thiophene sulphonate), which has highlighted the difficulty of developing formulations that meet all performance criteria simultaneously, as shown in Table 4-4. As such, non-PFAS PAGs are for a narrow range of use applications only, as no known non-PFAS PAG/photoacid exhibits the same level of performance for all criteria. While a candidate chemistry might show good acid strength, it will have lower photospeed39 because of lower acid diffusivity, and at the same time the acid anion might be transparent for a single wavelength only. PFAS PAGs, on the other hand, present simultaneously good to excellent performance for all listed performance criteria with the notable exception of environmental persistence. Amongst known substitutes, IBM have developed non-PFAS PAGs (CN5 and thiophene sulphonate), which has highlighted the difficulty of developing formulations that meet all performance criteria simultaneously, as shown in Table 4-4. As such, non-PFAS PAGs are for a narrow range of use applications only, as no known non-PFAS PAG/photoacid exhibits the same level of performance for all criteria. While a candidate chemistry might show good acid strength, it will have lower photospeed39 because of lower acid diffusivity, and at the same time the acid anion might be transparent for a single wavelength only. PFAS PAGs, on the other hand, present simultaneously good to excellent performance for all listed performance criteria with the notable exception of environmental persistence. Table 4-4 Comparison of the performance of PAGs versus alternatives. PFAS CN5 non-PFAS Thiophene sulfonate Performance criterion PAGs/photoacids PAG/photoacid PAG/photoacid Photospeed 39 Excellent Poor Good Acid strength Excellent Excellent Good 40 Diffusivity Good to excellent Lower than PFAS acids High to too High Line width roughness Line width roughness much Pattern quality/ Line Good higher than commercial higher than commercial width roughness resists resists Transparency at all Excellent Not transparent at 248nm Not transparent at 248nm exposure wavelengths Solubility of PAGs in Good Good Poor to moderate casting solvent Lack of side reactions Excellent Excellent Excellent High process temperature None Yes None requirement Table 4-4 Comparison of the performance of PAGs versus alternatives. PFAS CN5 non-PFAS Thiophene sulfonate Performance criterion PAGs/photoacids PAG/photoacid PAG/photoacid Photospeed 39 Excellent Poor Good Acid strength Excellent Excellent Good 40 Diffusivity Good to excellent Lower than PFAS acids High to too High Line width roughness Line width roughness much Pattern quality/ Line Good higher than commercial higher than commercial width roughness resists resists Transparency at all Excellent Not transparent at 248nm Not transparent at 248nm exposure wavelengths Solubility of PAGs in Good Good Poor to moderate casting solvent Lack of side reactions Excellent Excellent Excellent High process temperature None Yes None requirement ______ 38 Martin Glodde, Sen Liu, and Pushkara Rao Varanasi, “Fluorine-free photoacid generators for 193 nm lithography based on non-sulfonate organic superacids,” J. Photopol. Sci. Technol. 23 (2), 173-184 (2010) and Sen Liu, Martin Glodde, and Pushkara Rao Varanasi, “Design, Synthesis and Characterization of Fluorine-free PAGs for 193nm Lithography,” Advances in Resist Materials and Processing Technology XXVII, Proc. of SPIE Vol. 7639, 76390D (25 March 2010); doi: 10.1117/12.846600 39 Photospeed is a composite of acid strength, acid diffusivity, and PAG quantum yield. 40 Low diffusivity requires polymer-bound photoacids. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 38 246 The Impact of a Potential PFAS Restriction on the Semiconductor Sector ______ 38 Martin Glodde, Sen Liu, and Pushkara Rao Varanasi, “Fluorine-free photoacid generators for 193 nm lithography based on non-sulfonate organic superacids,” J. Photopol. Sci. Technol. 23 (2), 173-184 (2010) and Sen Liu, Martin Glodde, and Pushkara Rao Varanasi, “Design, Synthesis and Characterization of Fluorine-free PAGs for 193nm Lithography,” Advances in Resist Materials and Processing Technology XXVII, Proc. of SPIE Vol. 7639, 76390D (25 March 2010); doi: 10.1117/12.846600 39 Photospeed is a composite of acid strength, acid diffusivity, and PAG quantum yield. 40 Low diffusivity requires polymer-bound photoacids. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 38 246 The Impact of a Potential PFAS Restriction on the Semiconductor Sector PFAS CN5 non-PFAS Thiophene sulfonate Performance criterion PAGs/photoacids PAG/photoacid PAG/photoacid Uniformity of PAG Good Good Good distribution Toxicity Moderate to high High 41 Moderate Environmental Assumed to be Assumed to be Highly persistent persistence biodegradable biodegradable PFAS CN5 non-PFAS Thiophene sulfonate Performance criterion PAGs/photoacids PAG/photoacid PAG/photoacid Uniformity of PAG Good Good Good distribution Toxicity Moderate to high High 41 Moderate Environmental Assumed to be Assumed to be Highly persistent persistence biodegradable biodegradable So far, the only non-PFAS alternatives for 193 nm applications or lower are not technically viable due to their potential for a prohibitively high decrease in yield (estimated by a Semiconductor PFAS Consortium member to be 1-2%), and lower performance. If alternatives decrease yield even by very small percentages at a fab production site, this results in significant increases in extremely high-cost waste generation. The current feature sizes would not be able to be achieved as a significant invention still has to be undertaken, moreover it is not certain if suitable materials can be developed for all applications. As such all manufacturing of these devices have to rely on PFAS until wavelength- specific, alternative superacids have been developed. This significantly increases the amount of invention and development that needs to be done as all of the above-mentioned steps would need to be completed for each alternative analysed. So far, the only non-PFAS alternatives for 193 nm applications or lower are not technically viable due to their potential for a prohibitively high decrease in yield (estimated by a Semiconductor PFAS Consortium member to be 1-2%), and lower performance. If alternatives decrease yield even by very small percentages at a fab production site, this results in significant increases in extremely high-cost waste generation. The current feature sizes would not be able to be achieved as a significant invention still has to be undertaken, moreover it is not certain if suitable materials can be developed for all applications. As such all manufacturing of these devices have to rely on PFAS until wavelength- specific, alternative superacids have been developed. This significantly increases the amount of invention and development that needs to be done as all of the above-mentioned steps would need to be completed for each alternative analysed. Additionally, even if performance criteria can be met, the replacement of PFAS PAGs by non-PFAS alternatives with fundamentally different acidity and diffusion profiles are likely to result in even larger differences in photoresist behaviour, which means that the above-mentioned task of resist re- qualification and integration is even more demanding. This would be in addition to the requirements for product development, customisation, product scale-up, commercialisation, customer product evaluation (with potential product optimisation/evaluation loops between suppliers and customers), and final qualification at the customer site. Additionally, even if performance criteria can be met, the replacement of PFAS PAGs by non-PFAS alternatives with fundamentally different acidity and diffusion profiles are likely to result in even larger differences in photoresist behaviour, which means that the above-mentioned task of resist re- qualification and integration is even more demanding. This would be in addition to the requirements for product development, customisation, product scale-up, commercialisation, customer product evaluation (with potential product optimisation/evaluation loops between suppliers and customers), and final qualification at the customer site. 4.2 Top antireflective coatings (TARCs) Top antireflective coatings (TARCs) previously used PFOS and PFOA. Activities to replace these began in 2004 to use other fluorinated polymers that show lower bioavailability and bioaccumulation. This replacement has been completed and it is believed that no PFOA/PFAS-based TARCs are on the market. This substitution activity highlights challenges in identifying and qualifying alternatives as it took manufactures between 4-15 years depending on their use of PFOS and PFOA. As a result of this change, a number of unintended consequences also occurred; the developer use increased by 25%, the cycle time increased ~25% and in some cases of previous PFOS use the yield significantly dropped, all of which have negative environmental and production cost impacts. 4.2 Top antireflective coatings (TARCs) Top antireflective coatings (TARCs) previously used PFOS and PFOA. Activities to replace these began in 2004 to use other fluorinated polymers that show lower bioavailability and bioaccumulation. This replacement has been completed and it is believed that no PFOA/PFAS-based TARCs are on the market. This substitution activity highlights challenges in identifying and qualifying alternatives as it took manufactures between 4-15 years depending on their use of PFOS and PFOA. As a result of this change, a number of unintended consequences also occurred; the developer use increased by 25%, the cycle time increased ~25% and in some cases of previous PFOS use the yield significantly dropped, all of which have negative environmental and production cost impacts. 4.3 Immersion Barriers Immersion barriers include spin-on barriers and embedded barriers. Spin-on barriers are coated on the resist from an alcohol solvent, whereas embedded barriers as part of the photoresist solution are initially homogeneously distributed in the resist but migrate to the resist surface through phase separation. Both types are removed during the development step of production and are a key part of the immersion lithography process. Chip manufacture at and below the 40 nm node is not currently possible without them. ______ 41 Cyanide ion is found in rat stomachs when fed CN5. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 39 247 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 4.3 Immersion Barriers Immersion barriers include spin-on barriers and embedded barriers. Spin-on barriers are coated on the resist from an alcohol solvent, whereas embedded barriers as part of the photoresist solution are initially homogeneously distributed in the resist but migrate to the resist surface through phase separation. Both types are removed during the development step of production and are a key part of the immersion lithography process. Chip manufacture at and below the 40 nm node is not currently possible without them. ______ 41 Cyanide ion is found in rat stomachs when fed CN5. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 39 247 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Although PFAS-free silicon-based barriers are available, they are not developer-soluble, are not stable under 193 nm exposure and could lead to SiO2 deposits on the lens element. If deposits occur, the entire production tool would need to be shipped back to the manufacturer for repairs, causing it to be out of commission for 6 months or more. No other potential alternative has yet been identified offering suitable technical performance, as such the replacement of PFAS in immersion barriers is currently considered technically not possible at this time. Although PFAS-free silicon-based barriers are available, they are not developer-soluble, are not stable under 193 nm exposure and could lead to SiO2 deposits on the lens element. If deposits occur, the entire production tool would need to be shipped back to the manufacturer for repairs, causing it to be out of commission for 6 months or more. No other potential alternative has yet been identified offering suitable technical performance, as such the replacement of PFAS in immersion barriers is currently considered technically not possible at this time. 4.4 Surfactants Another fundamental application of PFAS compounds in photolithography is the use of PFAS surfactants. Surfactants in general are “surface-active agents” that consist of a hydrophobic segment and a hydrophilic unit. Surfactants can be used in a variety of coating applications for improving film quality and component mixing, and changing surface interaction, and wetting characteristics. One specific performance advantage of fluorinated surfactants is that the surface activity is much higher than equivalent hydrocarbon or silicone surfactants as indicated by the requirement for less surfactant material in a formulation to achieve its critical micelle concentration. Fluorinated non-ionic surfactants have been used in a wide range of lithographic processes due to their very low surface energy, thermal- and mechanical stability, and low refractive index and they can be used to improve photoresist deposition and eliminate defects during photoresist coating. 4.4 Surfactants Another fundamental application of PFAS compounds in photolithography is the use of PFAS surfactants. Surfactants in general are “surface-active agents” that consist of a hydrophobic segment and a hydrophilic unit. Surfactants can be used in a variety of coating applications for improving film quality and component mixing, and changing surface interaction, and wetting characteristics. One specific performance advantage of fluorinated surfactants is that the surface activity is much higher than equivalent hydrocarbon or silicone surfactants as indicated by the requirement for less surfactant material in a formulation to achieve its critical micelle concentration. Fluorinated non-ionic surfactants have been used in a wide range of lithographic processes due to their very low surface energy, thermal- and mechanical stability, and low refractive index and they can be used to improve photoresist deposition and eliminate defects during photoresist coating. The majority of non-PFAS alternatives contain silicon, which can lead to potential compatibility and defectivity issues as outlined in Section 4.3. Polyalkylene glycol based and alcohol ethoxylate based surfactants were also screened in bottom anti-reflective coatings but were not able to show suitable performance. Replacements are most likely to be less problematic for older, less advanced technologies (i.e., i-line photoresists 42), but for advanced lithographic photoresist technologies, direct replacement of PFAS surfactant with non-PFAS options is more challenging and requires invention. There is the concern that PFAS-free surfactants will lead to shorter shelf-life stability due to the comparative strength of the carbon-fluorine bond not being able to be matched, which would impact the supply chain logistics 40otentiallly result in an increase in extremely high-cost wasted products. The majority of non-PFAS alternatives contain silicon, which can lead to potential compatibility and defectivity issues as outlined in Section 4.3. Polyalkylene glycol based and alcohol ethoxylate based surfactants were also screened in bottom anti-reflective coatings but were not able to show suitable performance. Replacements are most likely to be less problematic for older, less advanced technologies (i.e., i-line photoresists 42), but for advanced lithographic photoresist technologies, direct replacement of PFAS surfactant with non-PFAS options is more challenging and requires invention. There is the concern that PFAS-free surfactants will lead to shorter shelf-life stability due to the comparative strength of the carbon-fluorine bond not being able to be matched, which would impact the supply chain logistics 40otentiallly result in an increase in extremely high-cost wasted products. 4.5 Dielectric Polymers: polyimides (PI) and polybenzoxazoles (PBO) The development of next-generation semiconductor products has become reliant upon advanced semiconductor packaging technologies. These advanced packaging technologies have enabled the modular integration of several small chiplets 43 designed to meet specific functions within a larger completed package, like on-chip memory, accelerators, controllers, and chip-to-chip interconnections. Advanced semiconductor manufacturing technologies have new performance requirements, such as the need to control heat generation within the new stacked configurations, as well as the need to maintain electric integrity through control of electrical leakage and mechanical integrity during thermal cycling in operation. These materials are non-fugitive and stay with the device for its service life. The cured material is insoluble in either aqueous or organic media and is sandwiched between inorganic layers. These materials must therefore have sufficient thermal, mechanical, and electrical properties to survive the harsh environments in which the devices made with them are used, as predicted by highly accelerated stress testing. The new performance requirements of advanced semiconductor packages have been met through the development and implementation of novel photo-imageable dielectric materials. These dielectric 4.5 Dielectric Polymers: polyimides (PI) and polybenzoxazoles (PBO) The development of next-generation semiconductor products has become reliant upon advanced semiconductor packaging technologies. These advanced packaging technologies have enabled the modular integration of several small chiplets 43 designed to meet specific functions within a larger completed package, like on-chip memory, accelerators, controllers, and chip-to-chip interconnections. Advanced semiconductor manufacturing technologies have new performance requirements, such as the need to control heat generation within the new stacked configurations, as well as the need to maintain electric integrity through control of electrical leakage and mechanical integrity during thermal cycling in operation. These materials are non-fugitive and stay with the device for its service life. The cured material is insoluble in either aqueous or organic media and is sandwiched between inorganic layers. These materials must therefore have sufficient thermal, mechanical, and electrical properties to survive the harsh environments in which the devices made with them are used, as predicted by highly accelerated stress testing. The new performance requirements of advanced semiconductor packages have been met through the development and implementation of novel photo-imageable dielectric materials. These dielectric ______ 42 A general purpose, multi-wavelength resist designed to cover a wide range of film thicknesses, 1–10 µm, with a single coat process. 43 Chiplets are small, modular chips which are part of a processing module that makes up a larger integrated circuit. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 40 248 The Impact of a Potential PFAS Restriction on the Semiconductor Sector ______ 42 A general purpose, multi-wavelength resist designed to cover a wide range of film thicknesses, 1–10 µm, with a single coat process. 43 Chiplets are small, modular chips which are part of a processing module that makes up a larger integrated circuit. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 40 248 The Impact of a Potential PFAS Restriction on the Semiconductor Sector materials are virtually exclusively selected from two families of polymers: polyimides and polybenzoxazoles. These polymeric materials protect the semiconductor device by effectively preventing electrical leakage, thermal stress, and corrosion of the underlying semiconductor circuitry. The PI and PBO materials are required to be photo-imageable to meet the required high-resolution requirements for chiplet interconnects through the use of PFAS ingredients typically found in photolithographic chemistries such as surfactants, photoacid generators and polymers. PI and PBO materials used in advanced packaging applications typically employ C1 PFAS groups attached directly to the polymer backbone to impart solubility, transparency, and moisture resistance in the dielectric film as well as clean development of patterns in aqueous processing. The essential properties enabled by the use of the C1 PFAS in the polymer are: materials are virtually exclusively selected from two families of polymers: polyimides and polybenzoxazoles. These polymeric materials protect the semiconductor device by effectively preventing electrical leakage, thermal stress, and corrosion of the underlying semiconductor circuitry. The PI and PBO materials are required to be photo-imageable to meet the required high-resolution requirements for chiplet interconnects through the use of PFAS ingredients typically found in photolithographic chemistries such as surfactants, photoacid generators and polymers. PI and PBO materials used in advanced packaging applications typically employ C1 PFAS groups attached directly to the polymer backbone to impart solubility, transparency, and moisture resistance in the dielectric film as well as clean development of patterns in aqueous processing. The essential properties enabled by the use of the C1 PFAS in the polymer are: • Optical transparency • Higher resolution of solvent developable polyimides • Thermal stability • Good mechanical properties (e.g., elongation • Low moisture absorption at break) • Lower cure temperature • Improved electrical properties • Cleaner development • Solubility in environment, health & safety friendly solvents elimination the need for • Aqueous development of PBO materials more toxic solvents Currently no PFAS-free materials are known to be viable as photo-imageable dielectric materials for use in advanced semiconductor manufacturing processes. Photo-imageable dielectric materials can be deposited through either a spin-on process, or as a dry film. Wastes generated from spin on application is similar to that from a photoresist, where waste photo- imageable dielectric chemistry and solvent based developer is collected within a bulk waste solvent collection system and managed as hazardous waste through thermal destruction at an incinerator or within a cement kiln. Aqueous based developer waste is collected in a separate, aqueous waste stream, neutralised, and filtered/separated prior to release to the aqueous waste stream. • Optical transparency • Higher resolution of solvent developable polyimides • Thermal stability • Good mechanical properties (e.g., elongation • Low moisture absorption at break) • Lower cure temperature • Improved electrical properties • Cleaner development • Solubility in environment, health & safety friendly solvents elimination the need for • Aqueous development of PBO materials more toxic solvents Currently no PFAS-free materials are known to be viable as photo-imageable dielectric materials for use in advanced semiconductor manufacturing processes. Photo-imageable dielectric materials can be deposited through either a spin-on process, or as a dry film. Wastes generated from spin on application is similar to that from a photoresist, where waste photo- imageable dielectric chemistry and solvent based developer is collected within a bulk waste solvent collection system and managed as hazardous waste through thermal destruction at an incinerator or within a cement kiln. Aqueous based developer waste is collected in a separate, aqueous waste stream, neutralised, and filtered/separated prior to release to the aqueous waste stream. With the demands of the industry for improvements in lithography and packaging, the replacement of C1 PFAS moieties on the polymer backbone with currently known alternatives would significantly compromise the performance required for these applications. Moving away from PFAS in photoresist applications, is likely to require a change in the entire photolithographic process. Photoresists are not interchangeable; they are designed to work with a specific photolithography method and are needed for the life of that manufacturing facility which is dedicated to the particular device technology (generation) being manufactured. Qualifying an alternative as a drop-in photoresist replacement part way through the life of a facility would not be possible in many cases and would need assessing for each facility individually. With the demands of the industry for improvements in lithography and packaging, the replacement of C1 PFAS moieties on the polymer backbone with currently known alternatives would significantly compromise the performance required for these applications. Moving away from PFAS in photoresist applications, is likely to require a change in the entire photolithographic process. Photoresists are not interchangeable; they are designed to work with a specific photolithography method and are needed for the life of that manufacturing facility which is dedicated to the particular device technology (generation) being manufactured. Qualifying an alternative as a drop-in photoresist replacement part way through the life of a facility would not be possible in many cases and would need assessing for each facility individually. 4.6 Environmental Considerations in Photolithography Worldwide, a total of 33,745 kg of PFAS are used by semiconductor manufacturers in photolithography annually based on SIA’s members survey of 2021 sales capturing well over 90% of the materials market, as shown in Table 4-5. TARCs are the largest single product type, accounting for over 50% of total PFAS use in photolithography. The total PFAS use for photolithography in Europe is estimated to be 2,248 kg annually, or about 6.7% of the worldwide semiconductor use. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 41 249 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 4.6 Environmental Considerations in Photolithography Worldwide, a total of 33,745 kg of PFAS are used by semiconductor manufacturers in photolithography annually based on SIA’s members survey of 2021 sales capturing well over 90% of the materials market, as shown in Table 4-5. TARCs are the largest single product type, accounting for over 50% of total PFAS use in photolithography. The total PFAS use for photolithography in Europe is estimated to be 2,248 kg annually, or about 6.7% of the worldwide semiconductor use. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 41 249 The Impact of a Potential PFAS Restriction on the Semiconductor Sector The total worldwide PFAS discharges from photolithography range between 1,282 to 17,433 kg/year (of which the EU is estimated at 6.7%, or 86 to 1,168 kg/year), depending on the amount of spin bowl waste collection. SIA estimates from previous surveys that about 50-60% of TARC users collect and properly dispose of the waste so the emissions ar are expected to be on the lower end of this scale. With full TARC spin bowl waste collection, the estimated amount discharged to wastewater in the European Union is 56 kg per year. Table 4-5 Results of SIA 2021 sales survey and an example release mass balance. 44 The following assumptions were used in the calculation: • During spin on processes, 95% of the dispensed material was left in the spin bowl as waste, whereas 5% remained as a coating on the wafer. • For aqueous development, 100% of the TARC and immersion topcoat material was removed in development and discharged to wastewater. • For photoresists, an average of 50% of the coating is dissolved in aqueous developers and discharged to wastewater, and the other 50% would remain on the wafer and be removed in subsequent strip operations. The total worldwide PFAS discharges from photolithography range between 1,282 to 17,433 kg/year (of which the EU is estimated at 6.7%, or 86 to 1,168 kg/year), depending on the amount of spin bowl waste collection. SIA estimates from previous surveys that about 50-60% of TARC users collect and properly dispose of the waste so the emissions ar are expected to be on the lower end of this scale. With full TARC spin bowl waste collection, the estimated amount discharged to wastewater in the European Union is 56 kg per year. Table 4-5 Results of SIA 2021 sales survey and an example release mass balance. 44 The following assumptions were used in the calculation: • During spin on processes, 95% of the dispensed material was left in the spin bowl as waste, whereas 5% remained as a coating on the wafer. • For aqueous development, 100% of the TARC and immersion topcoat material was removed in development and discharged to wastewater. • For photoresists, an average of 50% of the coating is dissolved in aqueous developers and discharged to wastewater, and the other 50% would remain on the wafer and be removed in subsequent strip operations. ______ 44 For this table, the presented acronyms and their meaning are as follows: Litho (photolithography), Aq (aqueous), Org (organic), Poly (polymer), Solv (solvent), Dev (developer), PB/PI (polybenzoxazole / polyimide), wt (wet), efl (effluent), env (environment), WW (wastewater), w/o (without), and y or yr (year). © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 42 250 The Impact of a Potential PFAS Restriction on the Semiconductor Sector ______ 44 For this table, the presented acronyms and their meaning are as follows: Litho (photolithography), Aq (aqueous), Org (organic), Poly (polymer), Solv (solvent), Dev (developer), PB/PI (polybenzoxazole / polyimide), wt (wet), efl (effluent), env (environment), WW (wastewater), w/o (without), and y or yr (year). © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 42 250 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 5 WET CHEMISTRY USES Summary: Wet chemical processing is the terminology used to describe several different semiconductor fabrication processes that involve dispensing a liquid chemical mixture to clean, etch, dry, planarize, or electroplate. The composition of wet chemical process formulations varies greatly depending on the application-specific performance requirements. Different companies and even different fabs within the same company do not all manufacture the same products, and therefore there are important inter- and intra-company differences in the wet chemical processing formulations and technologies in which they are employed. It follows that the need for a PFAS component in a wet chemical formulation depends on the application-specific performance requirements that, in turn, depend on the specific wafer processing technology being manufactured. The timeline needed to develop, qualify, and implement alternatives falls into the following four broad categories: • 3 to 4 years: If an existing non-PFAS alternative is available and can be demonstrated to provide adequate performance for a specific application. • 3 to 15+ years: In some applications where an existing non-PFAS alternative may be viable but requires tooling and/or process changes before it can be successfully introduced into high volume manufacturing (HVM). 5 WET CHEMISTRY USES Summary: Wet chemical processing is the terminology used to describe several different semiconductor fabrication processes that involve dispensing a liquid chemical mixture to clean, etch, dry, planarize, or electroplate. The composition of wet chemical process formulations varies greatly depending on the application-specific performance requirements. Different companies and even different fabs within the same company do not all manufacture the same products, and therefore there are important inter- and intra-company differences in the wet chemical processing formulations and technologies in which they are employed. It follows that the need for a PFAS component in a wet chemical formulation depends on the application-specific performance requirements that, in turn, depend on the specific wafer processing technology being manufactured. The timeline needed to develop, qualify, and implement alternatives falls into the following four broad categories: • 3 to 4 years: If an existing non-PFAS alternative is available and can be demonstrated to provide adequate performance for a specific application. • 3 to 15+ years: In some applications where an existing non-PFAS alternative may be viable but requires tooling and/or process changes before it can be successfully introduced into high volume manufacturing (HVM). • Successful invention required (from 5 to more than 12 years): For some applications it may not be possible to demonstrate that an available non-PFAS alternative can fulfil the application specific performance requirements. In these cases, it may be necessary to invent and synthesise new chemicals, and/or develop alternative approaches to fabricating a device structure that provides the necessary electrical and computational performance. Invention is an open-ended endeavour with no guarantee of success. • No alternative achievable: In some cases, it may ultimately be found that a non-PFAS alternative is not capable of providing the required chemical function. If a non-PFAS alternative chemical cannot be invented, then the integrated circuit device structure may need to be abandoned in favour of an alternative device structure that may or may not provide equivalent performance. • Successful invention required (from 5 to more than 12 years): For some applications it may not be possible to demonstrate that an available non-PFAS alternative can fulfil the application specific performance requirements. In these cases, it may be necessary to invent and synthesise new chemicals, and/or develop alternative approaches to fabricating a device structure that provides the necessary electrical and computational performance. Invention is an open-ended endeavour with no guarantee of success. • No alternative achievable: In some cases, it may ultimately be found that a non-PFAS alternative is not capable of providing the required chemical function. If a non-PFAS alternative chemical cannot be invented, then the integrated circuit device structure may need to be abandoned in favour of an alternative device structure that may or may not provide equivalent performance. Fluorinated organic chemicals have several unique physicochemical properties that, in some applications, are essential to the successful performance of the process. However, there is no general a priori means to determine whether a non-PFAS alternative will be capable of working for a particular application. Instead, the evaluation of potential alternatives must begin with experimental trials using available non-PFAS candidates as guided by chemical theory and experience. The timeline as outlined in the Executive Summary and Wet Chemicals uses Summary. The majority of wet chemical formulations do not utilise a PFAS additive. Where PFAS are used in wet chemical processing they are typically shorter chain PFAS (4-perfluorocarbon or less). Many of the shorter chain PFAS have been implemented relatively recently as alternatives to the longer chain homologues like PFOS and PFOA that they replaced. For instance, one device maker spent 8 years replacing the PFOS (8-perfluorocarbons) in a buffered hydrofluoric acid (BHF) formulation with a 4- perfluorocarbon alternative by working with several chemical suppliers. In contrast to the technical challenge in substituting from a long chain to a shorter chain PFAS homologue, it can be anticipated that substitution from a short chain PFAS to an entirely PFAS-free alternative represents a significantly more difficult technical challenge. Fluorinated organic chemicals have several unique physicochemical properties that, in some applications, are essential to the successful performance of the process. However, there is no general a priori means to determine whether a non-PFAS alternative will be capable of working for a particular application. Instead, the evaluation of potential alternatives must begin with experimental trials using available non-PFAS candidates as guided by chemical theory and experience. The timeline as outlined in the Executive Summary and Wet Chemicals uses Summary. The majority of wet chemical formulations do not utilise a PFAS additive. Where PFAS are used in wet chemical processing they are typically shorter chain PFAS (4-perfluorocarbon or less). Many of the shorter chain PFAS have been implemented relatively recently as alternatives to the longer chain homologues like PFOS and PFOA that they replaced. For instance, one device maker spent 8 years replacing the PFOS (8-perfluorocarbons) in a buffered hydrofluoric acid (BHF) formulation with a 4- perfluorocarbon alternative by working with several chemical suppliers. In contrast to the technical challenge in substituting from a long chain to a shorter chain PFAS homologue, it can be anticipated that substitution from a short chain PFAS to an entirely PFAS-free alternative represents a significantly more difficult technical challenge. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 43 251 The Impact of a Potential PFAS Restriction on the Semiconductor Sector The move to shorter chain PFAS, despite there being evidence that they have lower bioaccumulation factors 45, is now seen as a regrettable substitution and highlights the need for comprehensive cross discipline evaluations of the alternatives that are offered as replacements for currently used PFAS. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 43 251 The Impact of a Potential PFAS Restriction on the Semiconductor Sector The move to shorter chain PFAS, despite there being evidence that they have lower bioaccumulation factors 45, is now seen as a regrettable substitution and highlights the need for comprehensive cross discipline evaluations of the alternatives that are offered as replacements for currently used PFAS. 5.1 Wet Chemical Processing Wet chemical processing encompasses several different semiconductor fabrication processes including wet chemical etching, planarization, electroplating, and also wafer cleaning, rinsing, and drying. Although these involve very different wafer processing operations, with different objectives, the common factor is that they involve contacting a wafer with a liquid chemical mixture. Wet chemical etching and cleaning operations are typically conducted in specialised “wets” SMRE or tools that bring a liquid chemical mixture into contact with wafers either by dispensing it onto a spinning wafer or by immersing one or more wafers into a tank for “batch processing wets tools”. 5.1 Wet Chemical Processing Wet chemical processing encompasses several different semiconductor fabrication processes including wet chemical etching, planarization, electroplating, and also wafer cleaning, rinsing, and drying. Although these involve very different wafer processing operations, with different objectives, the common factor is that they involve contacting a wafer with a liquid chemical mixture. Wet chemical etching and cleaning operations are typically conducted in specialised “wets” SMRE or tools that bring a liquid chemical mixture into contact with wafers either by dispensing it onto a spinning wafer or by immersing one or more wafers into a tank for “batch processing wets tools”. In most wet etch, chemical mechanical planarization (CMP), electroplating operations, and in many wafer cleaning operations, the areas of the wafer that are operated on by a wet chemical processing step are isolated to very specific regions of the wafer defined by a photolithography “masking” operation. In assessing the complexity and challenge of conducting a wet chemical process, therefore, it is essential to consider the dimensions and geometric complexity of the integrated circuit features that are being fabricated. Although semiconductors are typically fabricated from crystalline silicon “wafers” that are generally either 200 mm or 300 mm in diameter, and in the order of 0. 0.8 mm thick; the individual integrated circuit device structures often have critical dimensions that typically measure in nanometres and thus are often at the molecular scale. It is the dimensions and materials complexity of the device features, not the wafer as a whole, that presents the challenge in wet chemical processing. In most wet etch, chemical mechanical planarization (CMP), electroplating operations, and in many wafer cleaning operations, the areas of the wafer that are operated on by a wet chemical processing step are isolated to very specific regions of the wafer defined by a photolithography “masking” operation. In assessing the complexity and challenge of conducting a wet chemical process, therefore, it is essential to consider the dimensions and geometric complexity of the integrated circuit features that are being fabricated. Although semiconductors are typically fabricated from crystalline silicon “wafers” that are generally either 200 mm or 300 mm in diameter, and in the order of 0. 0.8 mm thick; the individual integrated circuit device structures often have critical dimensions that typically measure in nanometres and thus are often at the molecular scale. It is the dimensions and materials complexity of the device features, not the wafer as a whole, that presents the challenge in wet chemical processing. Figure 5-1, for instance, illustrates schematically a typical wet chemical etching operation where a patterned photoresist is used to delineate the region of the wafer substrate that the etchant operates on. The etchant must transport into, react with, and transport reaction products out of the region that is masked by the photoresist layer, and must “stop” at, and not remove material from the underlying substrate. The difficulty of the wet etch application generally increases with the need to etch features that are very narrow and deep (high aspect ratio). The difficulty of an etch operation also depends on the number and type of materials that are exposed to the etchant, and the relative removal rate for each material. Figure 5-1 Conventional simple wet etch application. ______ 45 Burkhard, L.P., 2021. Evaluation of published bioconcentration factor (BCF) and bioaccumulation factor (BAF) data for per‐ and polyfluoroalkyl substances across aquatic species. Environmental toxicology and chemistry, 40(6), pp.1530-1543. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 44 252 Figure 5-1, for instance, illustrates schematically a typical wet chemical etching operation where a patterned photoresist is used to delineate the region of the wafer substrate that the etchant operates on. The etchant must transport into, react with, and transport reaction products out of the region that is masked by the photoresist layer, and must “stop” at, and not remove material from the underlying substrate. The difficulty of the wet etch application generally increases with the need to etch features that are very narrow and deep (high aspect ratio). The difficulty of an etch operation also depends on the number and type of materials that are exposed to the etchant, and the relative removal rate for each material. Figure 5-1 Conventional simple wet etch application. ______ 45 Burkhard, L.P., 2021. Evaluation of published bioconcentration factor (BCF) and bioaccumulation factor (BAF) data for per‐ and polyfluoroalkyl substances across aquatic species. Environmental toxicology and chemistry, 40(6), pp.1530-1543. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 44 252 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 5-2 ilillustrates the geometry of a current generation memory cell, where the etchant needs to penetrate between “nano sheets” that may be only tens of nanometres wide, and down into a channel that can be thousands of nanometres deep. The aspect ratio of the region into which etchant must transport, and etchant products must be removed, is more than 100 which introduces highly demanding technical requirements. Figure 5-2 3D NAND flash memory manufacturing process and wet lateral etching. Each layer is on the order of 25-40 nm thick, and 4,000 nm deep. 46 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 5-2 ilillustrates the geometry of a current generation memory cell, where the etchant needs to penetrate between “nano sheets” that may be only tens of nanometres wide, and down into a channel that can be thousands of nanometres deep. The aspect ratio of the region into which etchant must transport, and etchant products must be removed, is more than 100 which introduces highly demanding technical requirements. Figure 5-2 3D NAND flash memory manufacturing process and wet lateral etching. Each layer is on the order of 25-40 nm thick, and 4,000 nm deep. 46 The rinsing and drying of a modern wafer is also challenging due to the narrow dimensions causing immense capillary forces to be generated by the liquid on the walls of the structure, as illustrated in Figure 5-3 and can result in “pattern collapse” as illustrated in Figure 5-4. The phenomenon of pattern collapse requires the use of specialty fluids, these are used to either reduce the surface tension of the fluid that enters a channel or change the surface properties of the channel walls. Fluorinated surfactants and fluorinated surface modification chemicals, which are capable of lower surface forces than other known materials are often required to solve pattern collapse issues. With the increasing geometric complexity and narrow dimensions associated with advance integrated circuit fabrication, there will be continuing, if not increasing need to employ specialty fluorinated liquids in these applications. ______ 46 Lee, H.I., Kim, H.S., Tikue, E.T., Kang, S.K., Zhang, H., Park, J.W., Yang, S. and Lee, P.S., (2021). Green Manufacturing of Silyl-Phosphate for Use in 3D NAND Flash Memory Fabrication. ACS Sustainable Chemistry & Engineering, 9(14), pp.4948- 4956. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 45 The rinsing and drying of a modern wafer is also challenging due to the narrow dimensions causing immense capillary forces to be generated by the liquid on the walls of the structure, as illustrated in Figure 5-3 and can result in “pattern collapse” as illustrated in Figure 5-4. The phenomenon of pattern collapse requires the use of specialty fluids, these are used to either reduce the surface tension of the fluid that enters a channel or change the surface properties of the channel walls. Fluorinated surfactants and fluorinated surface modification chemicals, which are capable of lower surface forces than other known materials are often required to solve pattern collapse issues. With the increasing geometric complexity and narrow dimensions associated with advance integrated circuit fabrication, there will be continuing, if not increasing need to employ specialty fluorinated liquids in these applications. ______ 46 Lee, H.I., Kim, H.S., Tikue, E.T., Kang, S.K., Zhang, H., Park, J.W., Yang, S. and Lee, P.S., (2021). Green Manufacturing of Silyl-Phosphate for Use in 3D NAND Flash Memory Fabrication. ACS Sustainable Chemistry & Engineering, 9(14), pp.4948- 4956. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 45 253 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 5-3 Diagram illustrating the capillary forces exerted by a wetting fluid on the walls of the material holding the fluid. 47 Figure 5-4 Image of line collapse that has been caused by capillary forces. 48 253 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 5-3 Diagram illustrating the capillary forces exerted by a wetting fluid on the walls of the material holding the fluid. 47 Figure 5-4 Image of line collapse that has been caused by capillary forces. 48 5.2 Surfactants Wet chemical formulations vary greatly depending on the particular application. Surfactants are commonly needed in wet chemical formulations, and in some applications, a fluorinated surfactant is used because of the superior performance they provide as described below. However, in addition to use as surfactants, other types of PFAS are also employed as surface modifying agents and solvents. Additional detail regarding these uses is provided in the Wet Chemical Processing White Paper, as outlined in Table 1-2. In general, surfactants are often added to semiconductor chemical formulations to achieve the necessary process performance which include: • The ability to reduce surface tension at low concentrations and to allow for the penetration of aqueous solutions into narrow, high aspect ratio features with hydrophobic sidewalls, ______ 47 https://www.tel.com/product/cellesta.html 48 Image provided by Bassett (2019) TEL. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 46 254 The Impact of a Potential PFAS Restriction on the Semiconductor Sector • Stability in strong mineral acids and bases, 5.2 Surfactants Wet chemical formulations vary greatly depending on the particular application. Surfactants are commonly needed in wet chemical formulations, and in some applications, a fluorinated surfactant is used because of the superior performance they provide as described below. However, in addition to use as surfactants, other types of PFAS are also employed as surface modifying agents and solvents. Additional detail regarding these uses is provided in the Wet Chemical Processing White Paper, as outlined in Table 1-2. In general, surfactants are often added to semiconductor chemical formulations to achieve the necessary process performance which include: • The ability to reduce surface tension at low concentrations and to allow for the penetration of aqueous solutions into narrow, high aspect ratio features with hydrophobic sidewalls, ______ 47 https://www.tel.com/product/cellesta.html 48 Image provided by Bassett (2019) TEL. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 46 254 The Impact of a Potential PFAS Restriction on the Semiconductor Sector • Stability in strong mineral acids and bases, • Rapid adsorption at solid/liquid interface to provide improved wetting which improves etch rate uniformity of films, • Adsorb to a surface to prevent the deposition of metals that are introduced into the solution during an etching process, • Adsorb to a surface to suppress etching of one material while another material is preferentially removed. For instance, in the removal of SiO2 from the surface of a Si substrate, a surfactant is employed to selectively adsorb to the Si surface and suppress its etching while the SiO2 is removed, • Ease of rinsability from surfaces, and • Low foaming to mitigate the formation of air bubbles that can form and cause failure of the etching of contact holes. The selection of a particular surfactant for one of these applications varies depending on the application specific requirements. Important factors that can drive a requirement for a fluorinated surfactant include the following: • If the surfactant must resist decomposition under chemically reactive conditions, including acidic, basic, oxidising, or reducing conditions, then organofluorine (a PFAS substance) surfactants may be required. Fluorocarbons have the strongest bonds known in organic chemistry. • Rapid adsorption at solid/liquid interface to provide improved wetting which improves etch rate uniformity of films, • Adsorb to a surface to prevent the deposition of metals that are introduced into the solution during an etching process, • Adsorb to a surface to suppress etching of one material while another material is preferentially removed. For instance, in the removal of SiO2 from the surface of a Si substrate, a surfactant is employed to selectively adsorb to the Si surface and suppress its etching while the SiO2 is removed, • Ease of rinsability from surfaces, and • Low foaming to mitigate the formation of air bubbles that can form and cause failure of the etching of contact holes. The selection of a particular surfactant for one of these applications varies depending on the application specific requirements. Important factors that can drive a requirement for a fluorinated surfactant include the following: • If the surfactant must resist decomposition under chemically reactive conditions, including acidic, basic, oxidising, or reducing conditions, then organofluorine (a PFAS substance) surfactants may be required. Fluorocarbons have the strongest bonds known in organic chemistry. • If the mixture must achieve very low surface tensions or contact angle, then a fluorinated surfactant may be required. Fluorinated surfactants can achieve lower aqueous surface tensions (15 – 20 dyne/cm) than hydrocarbon (~ 30 dyne/cm) and other known materials including fluorosilicates. This is due to a combination of low polarizability, high molecular surface area, and conformation of the perfluorocarbon tail groups. • If the surfactant must retain its surface activity at very low pH, then a fluorosurfactant may be required. Fluoroalkyl acid surfactants, for instance, typically have near zero pKa 49 values and therefore their headgroup remains ionized and hydrophilic even if the pH approaches zero. • If the surfactant must be surface active in a non-aqueous media, then a fluorinated surfactant may be required. Surfactants with perfluorinated tail groups are oleophobic as well as hydrophobic. In many applications, several if not all of these factors together are essential to the performance of a fluorosurfactant. • If the mixture must achieve very low surface tensions or contact angle, then a fluorinated surfactant may be required. Fluorinated surfactants can achieve lower aqueous surface tensions (15 – 20 dyne/cm) than hydrocarbon (~ 30 dyne/cm) and other known materials including fluorosilicates. This is due to a combination of low polarizability, high molecular surface area, and conformation of the perfluorocarbon tail groups. • If the surfactant must retain its surface activity at very low pH, then a fluorosurfactant may be required. Fluoroalkyl acid surfactants, for instance, typically have near zero pKa 49 values and therefore their headgroup remains ionized and hydrophilic even if the pH approaches zero. • If the surfactant must be surface active in a non-aqueous media, then a fluorinated surfactant may be required. Surfactants with perfluorinated tail groups are oleophobic as well as hydrophobic. In many applications, several if not all of these factors together are essential to the performance of a fluorosurfactant. 5.2.1 Wet Clean applications Wet cleaning occurs after virtually every wafer processing step, to remove residue and restore the substrate surface to a pristine state before proceeding to the next wafer fabrication step. Aqueous clean processes such as those known as standard clean 1 (SC1 =H2O2 and NH4OH) and standard clean 2 (HCl and H2O2) are typically simple inorganic formulations that generally do not contain surfactants or other additives. Organic solvent etch and clean formulations are used in some applications due to their unique solvency properties, and/or surface activity. Among the physicochemical attributes that are important in certain ______ 49 pKa, or acid dissociation constant, is a measure of the strength of an acid. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 47 255 The Impact of a Potential PFAS Restriction on the Semiconductor Sector applications are specified melting and boiling points, viscosity, surface activity and polarizability, solvency, hydrophobicity, and dielectric properties. 5.2.1 Wet Clean applications Wet cleaning occurs after virtually every wafer processing step, to remove residue and restore the substrate surface to a pristine state before proceeding to the next wafer fabrication step. Aqueous clean processes such as those known as standard clean 1 (SC1 =H2O2 and NH4OH) and standard clean 2 (HCl and H2O2) are typically simple inorganic formulations that generally do not contain surfactants or other additives. Organic solvent etch and clean formulations are used in some applications due to their unique solvency properties, and/or surface activity. Among the physicochemical attributes that are important in certain ______ 49 pKa, or acid dissociation constant, is a measure of the strength of an acid. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 47 255 The Impact of a Potential PFAS Restriction on the Semiconductor Sector applications are specified melting and boiling points, viscosity, surface activity and polarizability, solvency, hydrophobicity, and dielectric properties. Multiple stage wet cleans use both aqueous and organic based cleaners and may be critical to ensuring the nanometre level device critical features and high aspect ratios. Each cleaning regime is specific to the product being cleaned, technology, type of chip and its end function. Multiple stage wet cleans use both aqueous and organic based cleaners and may be critical to ensuring the nanometre level device critical features and high aspect ratios. Each cleaning regime is specific to the product being cleaned, technology, type of chip and its end function. 5.2.2 Wet Chemical Etching Wet chemical etch processes are used to selectively remove one material in the presence of others, often in the presence of extreme geometric complexity. Each etching operation must be highly uniform across a wafer, from wafer to wafer, from run to run, and regardless of variations in feature sizes and pattern densities. A variety of different aqueous etchant formulations are used in wet chemical processing. Commonly used aqueous etchants include BHF, the generically named “metal etchant” that typically consists of a mixture of phosphoric and other acids and aqueous tetramethylammonium hydroxide. BHF, for instance, is used to wet etch or clean a variety of different wafer substrate materials including silicon, polysilicon, silicon oxide, silicon nitride, aluminium, copper, and photoresists. The challenge in conducting these operations varies greatly depending on the juxtaposition of materials and the geometric complexity of the feature being etched. In one common application of BHF, silicon oxide is selectively removed from a silicon surface. Another common application involves the etching/cleaning of contact holes, which vary significantly in their critical dimension and aspect ratio depending on the particular application. 5.2.2 Wet Chemical Etching Wet chemical etch processes are used to selectively remove one material in the presence of others, often in the presence of extreme geometric complexity. Each etching operation must be highly uniform across a wafer, from wafer to wafer, from run to run, and regardless of variations in feature sizes and pattern densities. A variety of different aqueous etchant formulations are used in wet chemical processing. Commonly used aqueous etchants include BHF, the generically named “metal etchant” that typically consists of a mixture of phosphoric and other acids and aqueous tetramethylammonium hydroxide. BHF, for instance, is used to wet etch or clean a variety of different wafer substrate materials including silicon, polysilicon, silicon oxide, silicon nitride, aluminium, copper, and photoresists. The challenge in conducting these operations varies greatly depending on the juxtaposition of materials and the geometric complexity of the feature being etched. In one common application of BHF, silicon oxide is selectively removed from a silicon surface. Another common application involves the etching/cleaning of contact holes, which vary significantly in their critical dimension and aspect ratio depending on the particular application. PFAS-free BHF formulations are known to work for some BHF applications, but not all as fluorinated surfactants are still required where the following requirements are needed: very low pKa as needed to maintain a charged headgroup for surfactant properties at a low pH, very low surface tensions, or resiliency in highly aggressive chemical solutions. As such, depending on the number of technical challenges yet to be overcome and the need for systems level qualifications, the exact timeframe for qualification is very uncertain. PFAS-free BHF formulations are known to work for some BHF applications, but not all as fluorinated surfactants are still required where the following requirements are needed: very low pKa as needed to maintain a charged headgroup for surfactant properties at a low pH, very low surface tensions, or resiliency in highly aggressive chemical solutions. As such, depending on the number of technical challenges yet to be overcome and the need for systems level qualifications, the exact timeframe for qualification is very uncertain. 5.2.3 Chemical mechanical planarization (CMP) and Post CMP Cleans CMP utilises water-based slurries typically comprised of mixtures of abrasive particles with chemical components such as acids, bases, oxidisers, chelating agents, metal passivating agents, surfactants, and other selectivity control agents to remove a wide range of film types (SiO2, SiN, W, Cu, etc.). Surfactants are routinely used in the formulation of CMP slurries and post-CMP cleaning solutions, and in some applications the surfactant may be a PFAS. Typically, the surfactants serve to disperse the particles, improve slurry stability, control the wettability of films and polishing pads, and reduce corrosion of some films. Although only used in very specialised instances, fluorosurfactants can be found in the formulation of certain types of CMP slurries for targeted performance improvements, including the enablement of selective film inhibition and the wetting of low surface energy substrates. 5.2.3 Chemical mechanical planarization (CMP) and Post CMP Cleans CMP utilises water-based slurries typically comprised of mixtures of abrasive particles with chemical components such as acids, bases, oxidisers, chelating agents, metal passivating agents, surfactants, and other selectivity control agents to remove a wide range of film types (SiO2, SiN, W, Cu, etc.). Surfactants are routinely used in the formulation of CMP slurries and post-CMP cleaning solutions, and in some applications the surfactant may be a PFAS. Typically, the surfactants serve to disperse the particles, improve slurry stability, control the wettability of films and polishing pads, and reduce corrosion of some films. Although only used in very specialised instances, fluorosurfactants can be found in the formulation of certain types of CMP slurries for targeted performance improvements, including the enablement of selective film inhibition and the wetting of low surface energy substrates. 5.2.4 Metal Plating A variety of electrolytic and electroless plating operations are used in semiconductor wafer manufacturing (fab) and post fab packaging operations. Plating solutions commonly contain surface- active components, that in some formulations may contain PFAS to: • Lower surface tension to: © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 48 256 The Impact of a Potential PFAS Restriction on the Semiconductor Sector - Improve wetting and access of the plating bath solution to geometric features with high aspect ratios, - Mitigate the inclusion of hydrogen gas that is generated at electrodes, into the metal deposit, - Reduce bubble size and mitigate acid mist formation. • Provide a surface-active material as a co-reactant to form a deposition conjugate with the plating metal. 5.2.4 Metal Plating A variety of electrolytic and electroless plating operations are used in semiconductor wafer manufacturing (fab) and post fab packaging operations. Plating solutions commonly contain surface- active components, that in some formulations may contain PFAS to: • Lower surface tension to: © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 48 256 The Impact of a Potential PFAS Restriction on the Semiconductor Sector - Improve wetting and access of the plating bath solution to geometric features with high aspect ratios, - Mitigate the inclusion of hydrogen gas that is generated at electrodes, into the metal deposit, - Reduce bubble size and mitigate acid mist formation. • Provide a surface-active material as a co-reactant to form a deposition conjugate with the plating metal. In addition to conventional plating operations, electroless plating of Cu is conducted in trench/via fill operations, and sometimes requires a surfactant to prevent interference from the hydrogen that is generated as a by-product. In these applications, a surfactant may need to be fluorinated in order to achieve the particular surface tension and wettability requirements, and/or for resiliency to the oxidation and reduction reactions. Table 5-1 provides an overview of the PFAS uses in wet chem applications, all of which require from 3 to more than 15 years to develop a PFAS-free alternative depending on whether qualification and implementation of existing alternatives, or invention of new materials and processes is required. In addition to conventional plating operations, electroless plating of Cu is conducted in trench/via fill operations, and sometimes requires a surfactant to prevent interference from the hydrogen that is generated as a by-product. In these applications, a surfactant may need to be fluorinated in order to achieve the particular surface tension and wettability requirements, and/or for resiliency to the oxidation and reduction reactions. Table 5-1 provides an overview of the PFAS uses in wet chem applications, all of which require from 3 to more than 15 years to develop a PFAS-free alternative depending on whether qualification and implementation of existing alternatives, or invention of new materials and processes is required. Historically, there were many more wet chemical uses of PFAS, but the majority of uses have already been substituted, in some cases to a shorter chain PFAS, with a limited number remaining. One such example, is the historical use of PFOS and PFOA as surfactants, which were substituted with shorter chain perfluoroalkyl sulfonic and/or perfluoroalkyl carboxylic acids. This change was the result of substantial effort over a period of up to 16 years for this application. Substitutions have impact across the supply chain. For example, one chemical manufacturer changed the design of over 20 products by incorporating alternatives. Those products were then, in turn, qualified and used by a hundred different customers. Some PFC gases are also used for cleaning, and these are discussed in Section 6. The semiconductor industry expects PFAS-free alternatives to be much more difficult to find than the transition from PFOA or PFOS to shorter chain PFAS substances. This is because in many cases there are no known chemical alternatives that are capable of providing equivalent chemical functionality and performance to fluorinated organic chemicals. In some applications, a non-PFAS chemical may be viable, whereas in other applications currently known alternatives may not be able to provide the necessary performance requirements and therefore may be essential. Historically, there were many more wet chemical uses of PFAS, but the majority of uses have already been substituted, in some cases to a shorter chain PFAS, with a limited number remaining. One such example, is the historical use of PFOS and PFOA as surfactants, which were substituted with shorter chain perfluoroalkyl sulfonic and/or perfluoroalkyl carboxylic acids. This change was the result of substantial effort over a period of up to 16 years for this application. Substitutions have impact across the supply chain. For example, one chemical manufacturer changed the design of over 20 products by incorporating alternatives. Those products were then, in turn, qualified and used by a hundred different customers. Some PFC gases are also used for cleaning, and these are discussed in Section 6. The semiconductor industry expects PFAS-free alternatives to be much more difficult to find than the transition from PFOA or PFOS to shorter chain PFAS substances. This is because in many cases there are no known chemical alternatives that are capable of providing equivalent chemical functionality and performance to fluorinated organic chemicals. In some applications, a non-PFAS chemical may be viable, whereas in other applications currently known alternatives may not be able to provide the necessary performance requirements and therefore may be essential. In some situations, it is likely that entirely new molecules may need to be synthesised and evaluated. To prevent regrettable substitution, the timeline must include evaluations of the chemical behaviour and toxicity of the proposed alternatives, including characterisation of the controls necessary to prevent impact to human health and the environment. Owing to these considerations, a specific timeline cannot be predicted. However, once the invention of a viable alternative has been accomplished, the demonstration, qualification, and transfer to HVM may take more than 15 years. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 49 257 The Impact of a Potential PFAS Restriction on the Semiconductor Sector In some situations, it is likely that entirely new molecules may need to be synthesised and evaluated. To prevent regrettable substitution, the timeline must include evaluations of the chemical behaviour and toxicity of the proposed alternatives, including characterisation of the controls necessary to prevent impact to human health and the environment. Owing to these considerations, a specific timeline cannot be predicted. However, once the invention of a viable alternative has been accomplished, the demonstration, qualification, and transfer to HVM may take more than 15 years. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 49 257 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Table 5-1 Examples of etches and cleaning operations utilising PFAS. Criticality for semiconductor devices PFAS use area Role of PFAS additives "*)$%+).*& #(,%+)#,'-% manufacture Aqueous a) The surface-active agent must resist etch/clean decomposition under chemically reactive conditions. a) Facilitate entry of the wet etchant into, and reaction formulations b) Fluorinated surfactants can achieve lower products out of, a capillary space by reducing the aqueous surface tensions (15 – 20 mN/m) than PFAS additives are critical for some, but surface tension of the fluid and the contact angle with hydrocarbons (~ 30 mN/m) and other known not all wet etch applications. The the solid. materials including fluorosilicates. requirement for a PFAS additive depends on b) Adsorb to a surface to prevent the deposition of c) Fluoroalkyl acid surfactants have uniquely low the physical dimensions and aspect ratio of Organic based metals that are introduced into the solution during an pKa values that enable them to remain ionized and the device feature being etched, and the etch etching process. hydrophilic even if the pH approaches zero. particular set of materials exposed to the formulations c) Mitigate the formation of air bubbles. d) Surfactants with perfluorinated tail groups are etchant during etching. d) Adsorb to a surface to suppress etching of one oleophobic as well as hydrophobic, and therefore material while another material is preferentially removed. are surface active in organic solvents as well as aqueous etchants. a) The surface-active agents must rapidly adsorb to Surfactants and surface-active materials are critical the substrate during polishing and rapidly desorb components of CMP slurries and post-CMP cleaning with water rinse. solutions. These components must: PFAS additives are critical for some, but b) they must be non-foaming to prevent foaming. a) Disperse the particles. not all CMP applications. The requirement c) In situations where a very low surface tension is Chemical b) Provide slurry stability. for a PFAS depends on the materials required, only PFAS surfactants can lower surface Mechanical c) Control the wettability of films and polishing pads; and properties of the exposed surfaces that need tension of aqueous solutions to values below ~ 20 Planarization d) Reduce corrosion of some films. Fluorosurfactants protection, surface tension reduction (mN/m) rapidly. are critical to achieving CMP performance requirements requirements, and aggressiveness of the d) In chemically aggressive CMP formulations a in certain situations. In particular, they are used where CMP formulation. PFAS surface active agent may be necessary to necessary to enable selective film inhibition and the prevent degradation by reactive oxygen species wetting of low surface energy substrates. produced in oxidising systems. Table 5-1 Examples of etches and cleaning operations utilising PFAS. Criticality for semiconductor devices PFAS use area Role of PFAS additives "*)$%+).*& #(,%+)#,'-% manufacture Aqueous a) The surface-active agent must resist etch/clean decomposition under chemically reactive conditions. a) Facilitate entry of the wet etchant into, and reaction formulations b) Fluorinated surfactants can achieve lower products out of, a capillary space by reducing the aqueous surface tensions (15 – 20 mN/m) than PFAS additives are critical for some, but surface tension of the fluid and the contact angle with hydrocarbons (~ 30 mN/m) and other known not all wet etch applications. The the solid. materials including fluorosilicates. requirement for a PFAS additive depends on b) Adsorb to a surface to prevent the deposition of c) Fluoroalkyl acid surfactants have uniquely low the physical dimensions and aspect ratio of Organic based metals that are introduced into the solution during an pKa values that enable them to remain ionized and the device feature being etched, and the etch etching process. hydrophilic even if the pH approaches zero. particular set of materials exposed to the formulations c) Mitigate the formation of air bubbles. d) Surfactants with perfluorinated tail groups are etchant during etching. d) Adsorb to a surface to suppress etching of one oleophobic as well as hydrophobic, and therefore material while another material is preferentially removed. are surface active in organic solvents as well as aqueous etchants. a) The surface-active agents must rapidly adsorb to Surfactants and surface-active materials are critical the substrate during polishing and rapidly desorb components of CMP slurries and post-CMP cleaning with water rinse. solutions. These components must: PFAS additives are critical for some, but b) they must be non-foaming to prevent foaming. a) Disperse the particles. not all CMP applications. The requirement c) In situations where a very low surface tension is Chemical b) Provide slurry stability. for a PFAS depends on the materials required, only PFAS surfactants can lower surface Mechanical c) Control the wettability of films and polishing pads; and properties of the exposed surfaces that need tension of aqueous solutions to values below ~ 20 Planarization d) Reduce corrosion of some films. Fluorosurfactants protection, surface tension reduction (mN/m) rapidly. are critical to achieving CMP performance requirements requirements, and aggressiveness of the d) In chemically aggressive CMP formulations a in certain situations. In particular, they are used where CMP formulation. PFAS surface active agent may be necessary to necessary to enable selective film inhibition and the prevent degradation by reactive oxygen species wetting of low surface energy substrates. produced in oxidising systems. © RINA Tech UK Ltd 258 Report No. 2022-0737 Rev. 0 Page 50 The Impact of a Potential PFAS Restriction on the Semiconductor Sector © RINA Tech UK Ltd 258 Report No. 2022-0737 Rev. 0 Page 50 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Criticality for semiconductor devices PFAS use area Role of PFAS additives "*)$%+).*& #(,%+)#,'-% manufacture The ability of a solvent to dissolve and solubilise a Organic solvents are required for some wafer clean/strip material from the surface of a wafer or part depends formulations and also some cleaning operations that are PFAS containing solvent mixtures are on their respective chemical characteristics, as often Organic solvent conducted on parts outside of the fab cleanrooms. In critical for some, but not all solvent clean represented by the Hansen Solubility parameters based clean some applications these mixtures are comprised of applications. The requirement for a PFAS (dispersion, polar, and H-bonding intermolecular formulations fluorinated organic solvents and/or fluorinated organic depends on the materials properties of the forces). In some cases, therefore, a fluorinated alternatives in order to provide the necessary solvency substance that needs removal. component is necessary to remove fluorinated and fluid handling characteristics. materials from a surface. PFAS are used in a number of different formulations that are used to mitigate pattern collapse issues, including surfactants, surface modification treatment materials, The ability of a non-PFAS alternative to serve Some PFAS containing formulations displacement fluids, and organic solvents. Historically effectively as a means of pattern collapse mitigation used to mitigate pattern collapse may be associated with photoresist, pattern collapse is now a depends on the particular application. Several essential. Development of new solutions for Pattern collapse critical and evolving challenge in the etching and drying different approaches that are in use, or being the evolving pattern collapse issue may be mitigation of narrow dimensioned, high aspect ratio device features pursued, as means of mitigating pattern collapse able to avoid the use of fluorinated organics like nanosheets and 3DNAND structures. Pattern issues that are evolving with increasing use depending on the application specific collapse occurs when the capillary forces created by molecular dimension device structures. performance requirements. liquid menisci formed between high aspect ratio features exceed the structural strength of the material forming the walls of the capillary space. a) The surface-active agent must resist decomposition under chemically reactive conditions Plating and electroless plating utilise surfactants and particularly at plating electrodes; surface-active materials to: b) Fluorinated surfactants can achieve lower PFAS containing plating mixtures are a) Reduce surface tension to improve wetting and aqueous surface tensions (15 – 20 mN/m) than critical for some, but not all plating access of the plating bath solution to geometric features hydrocarbons (~ 30 mN/m) and other known applications. The requirement for a PFAS Plating and with high aspect ratios. materials including fluorosilicates; is application specific and therefore depends electroplating b) Mitigate the inclusion of hydrogen gas that is c) Fluoroalkyl acid surfactants have uniquely low on the materials properties of substance generated at electrodes, into the metal deposit. pKa values that enable them to remain ionized and being plated, as well as the dimensions and c) Mitigate bubble and/or mist formation. hydrophilic even if the pH of the plating solution aspect ratio of the features being plated. d) Function as a co-reactant to form a deposition approaches zero. conjugate with the plating metal. d) Ability to function as a co-reactant depends on the materials present in the plating operation. Criticality for semiconductor devices PFAS use area Role of PFAS additives "*)$%+).*& #(,%+)#,'-% manufacture The ability of a solvent to dissolve and solubilise a Organic solvents are required for some wafer clean/strip material from the surface of a wafer or part depends formulations and also some cleaning operations that are PFAS containing solvent mixtures are on their respective chemical characteristics, as often Organic solvent conducted on parts outside of the fab cleanrooms. In critical for some, but not all solvent clean represented by the Hansen Solubility parameters based clean some applications these mixtures are comprised of applications. The requirement for a PFAS (dispersion, polar, and H-bonding intermolecular formulations fluorinated organic solvents and/or fluorinated organic depends on the materials properties of the forces). In some cases, therefore, a fluorinated alternatives in order to provide the necessary solvency substance that needs removal. component is necessary to remove fluorinated and fluid handling characteristics. materials from a surface. PFAS are used in a number of different formulations that are used to mitigate pattern collapse issues, including surfactants, surface modification treatment materials, The ability of a non-PFAS alternative to serve Some PFAS containing formulations displacement fluids, and organic solvents. Historically effectively as a means of pattern collapse mitigation used to mitigate pattern collapse may be associated with photoresist, pattern collapse is now a depends on the particular application. Several essential. Development of new solutions for Pattern collapse critical and evolving challenge in the etching and drying different approaches that are in use, or being the evolving pattern collapse issue may be mitigation of narrow dimensioned, high aspect ratio device features pursued, as means of mitigating pattern collapse able to avoid the use of fluorinated organics like nanosheets and 3DNAND structures. Pattern issues that are evolving with increasing use depending on the application specific collapse occurs when the capillary forces created by molecular dimension device structures. performance requirements. liquid menisci formed between high aspect ratio features exceed the structural strength of the material forming the walls of the capillary space. a) The surface-active agent must resist decomposition under chemically reactive conditions Plating and electroless plating utilise surfactants and particularly at plating electrodes; surface-active materials to: b) Fluorinated surfactants can achieve lower PFAS containing plating mixtures are a) Reduce surface tension to improve wetting and aqueous surface tensions (15 – 20 mN/m) than critical for some, but not all plating access of the plating bath solution to geometric features hydrocarbons (~ 30 mN/m) and other known applications. The requirement for a PFAS Plating and with high aspect ratios. materials including fluorosilicates; is application specific and therefore depends electroplating b) Mitigate the inclusion of hydrogen gas that is c) Fluoroalkyl acid surfactants have uniquely low on the materials properties of substance generated at electrodes, into the metal deposit. pKa values that enable them to remain ionized and being plated, as well as the dimensions and c) Mitigate bubble and/or mist formation. hydrophilic even if the pH of the plating solution aspect ratio of the features being plated. d) Function as a co-reactant to form a deposition approaches zero. conjugate with the plating metal. d) Ability to function as a co-reactant depends on the materials present in the plating operation. © RINA Tech UK Ltd 259 Report No. 2022-0737 Rev. 0 Page 51 The Impact of a Potential PFAS Restriction on the Semiconductor Sector © RINA Tech UK Ltd 259 Report No. 2022-0737 Rev. 0 Page 51 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 5.3 Environmental Considerations in Wet Chemistries Semiconductor facilities generate organic and aqueous waste streams which are treated in accordance with local and federal waste and wastewater regulations. Organic waste is typically collected and disposed of as a blended fuel by high temperature incineration or reprocessing. Historically, the majority of aqueous chemicals employed in fab manufacturing processes are discharged to an industrial wastewater drain system that conveys wastewater for treatment of specific regulated pollutants in accordance with local and federal regulations, and subsequently discharged to a publicly owned treatment works or surface water. Most PFAS are not regulated pollutants and therefore unless company specific provisions are in place, the wastewater from processes that use aqueous wet chemical formulations that contain PFAS would likely be discharged to the publicly owned treatment works without substantive removal of the PFAS. The industry is actively researching PFAS wastewater releases and treatment technologies. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 52 260 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 5.3 Environmental Considerations in Wet Chemistries Semiconductor facilities generate organic and aqueous waste streams which are treated in accordance with local and federal waste and wastewater regulations. Organic waste is typically collected and disposed of as a blended fuel by high temperature incineration or reprocessing. Historically, the majority of aqueous chemicals employed in fab manufacturing processes are discharged to an industrial wastewater drain system that conveys wastewater for treatment of specific regulated pollutants in accordance with local and federal regulations, and subsequently discharged to a publicly owned treatment works or surface water. Most PFAS are not regulated pollutants and therefore unless company specific provisions are in place, the wastewater from processes that use aqueous wet chemical formulations that contain PFAS would likely be discharged to the publicly owned treatment works without substantive removal of the PFAS. The industry is actively researching PFAS wastewater releases and treatment technologies. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 52 260 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 6 FLUOROCARBON USES IN PLASMA ETCH/WAFER CLEAN AND DEPOSITION Summary: Perfluorocarbons (PFCs) and hydrofluorocarbons (HFCs) are essential for semiconductor manufacturing and are used in thin film deposition, plasma etch/wafer clean, and chamber cleaning processes, but are already subject to separate greenhouse gas regulations. The semiconductor industry has a demonstrable history of engineering solutions to reduce both the consumption and emission of HFC/PFC gases in response to environmental concerns. The industry can employ this substantial knowledge base to further improve the performance of abatement systems if exemptions are granted. PFAS alternatives either do not exist at present, or if they do, they create PFAS by-products if a carbon containing film is present. The intrinsic properties of silicon wafers have informed the use of fluorocarbons. Invention is needed to find alternatives because silica compounds (SiO2, SiN, etc.) are the foundation of semiconductor device structures and tuneable silicon layers require a specific and tuneable ratio of carbon and fluorine to etch. For chamber cleaning, fluorine ions and radicals are necessary; non-PFAS alternatives are either potent greenhouse gases or extremely reactive and toxic and PFAS by-products are created if residual carbon is present. 6 FLUOROCARBON USES IN PLASMA ETCH/WAFER CLEAN AND DEPOSITION Summary: Perfluorocarbons (PFCs) and hydrofluorocarbons (HFCs) are essential for semiconductor manufacturing and are used in thin film deposition, plasma etch/wafer clean, and chamber cleaning processes, but are already subject to separate greenhouse gas regulations. The semiconductor industry has a demonstrable history of engineering solutions to reduce both the consumption and emission of HFC/PFC gases in response to environmental concerns. The industry can employ this substantial knowledge base to further improve the performance of abatement systems if exemptions are granted. PFAS alternatives either do not exist at present, or if they do, they create PFAS by-products if a carbon containing film is present. The intrinsic properties of silicon wafers have informed the use of fluorocarbons. Invention is needed to find alternatives because silica compounds (SiO2, SiN, etc.) are the foundation of semiconductor device structures and tuneable silicon layers require a specific and tuneable ratio of carbon and fluorine to etch. For chamber cleaning, fluorine ions and radicals are necessary; non-PFAS alternatives are either potent greenhouse gases or extremely reactive and toxic and PFAS by-products are created if residual carbon is present. A fundamental re-design of semiconductors and the equipment, processes, and chemicals to make them would be needed if HFCs and PFCs are no longer available for plasma etch and chamber cleaning processes. As such the following timelines are estimated (at a minimum) to implement alternatives after a feasible invention is identified: • Dry etching more than 15 years to qualify each specific etch type and additional implementation time if alternatives are found. • Chamber cleans more than 10 years for each specific type. Perfluorocarbons (PFCs) and hydrofluorocarbons (HFCs) are critical process gases used within semiconductor manufacturing and have played a critical role in the evolution of semiconductor device technology to its current level of development. PFCs and HFCs are used in dry etching and other process operations due to their chemical stability and as their reactivity in plasma. Table 6-1 below summarises these operations, the current substances used, the status of alternative and the timescale to develop them. Plasmas and other specialised semiconductor process operations can convert stable gases into radicals and ions without the need for reactive gases to be stored and transported within semiconductor manufacturing facilities. A fundamental re-design of semiconductors and the equipment, processes, and chemicals to make them would be needed if HFCs and PFCs are no longer available for plasma etch and chamber cleaning processes. As such the following timelines are estimated (at a minimum) to implement alternatives after a feasible invention is identified: • Dry etching more than 15 years to qualify each specific etch type and additional implementation time if alternatives are found. • Chamber cleans more than 10 years for each specific type. Perfluorocarbons (PFCs) and hydrofluorocarbons (HFCs) are critical process gases used within semiconductor manufacturing and have played a critical role in the evolution of semiconductor device technology to its current level of development. PFCs and HFCs are used in dry etching and other process operations due to their chemical stability and as their reactivity in plasma. Table 6-1 below summarises these operations, the current substances used, the status of alternative and the timescale to develop them. Plasmas and other specialised semiconductor process operations can convert stable gases into radicals and ions without the need for reactive gases to be stored and transported within semiconductor manufacturing facilities. As many of these PFCs and HFCs are greenhouse gases, which are currently subject to separate regulation, the semiconductor industry has worked for over 30 years (and continues to work) to develop best practices to minimise PFC and HFC emissions. However, alternatives to PFCs/HFCs have not yet been found and the search is proving especially challenging for the etching of the insulator in the semiconductor device structure. As many of these PFCs and HFCs are greenhouse gases, which are currently subject to separate regulation, the semiconductor industry has worked for over 30 years (and continues to work) to develop best practices to minimise PFC and HFC emissions. However, alternatives to PFCs/HFCs have not yet been found and the search is proving especially challenging for the etching of the insulator in the semiconductor device structure. 6.1 Dry Etching While wet etches and cleans are used to indiscriminately remove metal, insulators, polymers, or defects; plasma or “dry etching” is used to remove or chemically change very specific elements on the surface of the wafer. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 53 261 The Impact of a Potential PFAS Restriction on the Semiconductor Sector In the manufacture of recent logic semiconductor devices, there are more than 100 distinct plasma etching process steps. Many of these process steps use PFAS gases. Some etching processes use PFAS as primary gas(es), whist others use PFAS as an additive. Each of these process steps has a different purpose and different requirements to be achieved, therefore many different combinations of PFAS are used. Plasma etching is directional, making it possible to target the specific, microscopic features needed to be removed or chemically changed. The desired combination of anisotropic/isotropic etching and protective layer formation can be obtained by using plasma of PFAS gas(es) or a gas mixture containing PFAS gas(es). These etching processes are indispensable steps in the production of semiconductor devices. 6.1 Dry Etching While wet etches and cleans are used to indiscriminately remove metal, insulators, polymers, or defects; plasma or “dry etching” is used to remove or chemically change very specific elements on the surface of the wafer. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 53 261 The Impact of a Potential PFAS Restriction on the Semiconductor Sector In the manufacture of recent logic semiconductor devices, there are more than 100 distinct plasma etching process steps. Many of these process steps use PFAS gases. Some etching processes use PFAS as primary gas(es), whist others use PFAS as an additive. Each of these process steps has a different purpose and different requirements to be achieved, therefore many different combinations of PFAS are used. Plasma etching is directional, making it possible to target the specific, microscopic features needed to be removed or chemically changed. The desired combination of anisotropic/isotropic etching and protective layer formation can be obtained by using plasma of PFAS gas(es) or a gas mixture containing PFAS gas(es). These etching processes are indispensable steps in the production of semiconductor devices. In the semiconductor industry today, very high aspect ratios are required to enable increasingly demanding device densities. This means that plasma processes must be able to etch out smaller and smaller gaps. Especially where etching the insulator of the semiconductor device structure, it is important to have the interaction between C/CHF/CF deposition and F etching, when controlling the dissociation ratio of PFAS molecular radicals by plasma. By using directional etching of F while protecting any material that is not intended to be etched or otherwise altered during the etching process, using a deposited layer consisting of C and F, it is possible to etch the intended shape. The physical and chemical reactions on the wafer are dependent on the type of gases, the flow rate of gases, the chamber pressure, the power, and other highly controlled and highly specialised chemical, and chamber conditions. Changing any one of these parameters can change the overall profile of the device structure being formed by the plasma etch process. The gases used for a specific etch must be selective for the material to be removed or changed. For instance, gases such as CF4 alone will etch both silicon and silicon dioxide, so CF4 needs to be combined with other gases (like hydrogen) so that it etches only the silicon dioxide. In the semiconductor industry today, very high aspect ratios are required to enable increasingly demanding device densities. This means that plasma processes must be able to etch out smaller and smaller gaps. Especially where etching the insulator of the semiconductor device structure, it is important to have the interaction between C/CHF/CF deposition and F etching, when controlling the dissociation ratio of PFAS molecular radicals by plasma. By using directional etching of F while protecting any material that is not intended to be etched or otherwise altered during the etching process, using a deposited layer consisting of C and F, it is possible to etch the intended shape. The physical and chemical reactions on the wafer are dependent on the type of gases, the flow rate of gases, the chamber pressure, the power, and other highly controlled and highly specialised chemical, and chamber conditions. Changing any one of these parameters can change the overall profile of the device structure being formed by the plasma etch process. The gases used for a specific etch must be selective for the material to be removed or changed. For instance, gases such as CF4 alone will etch both silicon and silicon dioxide, so CF4 needs to be combined with other gases (like hydrogen) so that it etches only the silicon dioxide. 6.2 Plasma Cleaning Even with the highly controlled, selective use of PFCs and HFCs, some by-product deposition or dielectric layers previously deposited may occur on the sidewall of semiconductor equipment chambers. This deposition in both plasma etching and chemical vapour deposition chambers, if not cleaned periodically, can result in contamination of the wafer and the ultimate scrapping of functional semiconductors. Periodic PFC cleaning and conditioning of chambers is used to optimise product yield. PFCs and HFCs are used due to their relative stability in storage and gas transfer as well as their ion reactivity in plasma. The gases used to clean internal equipment surfaces must be reactive enough to clean the chamber, but not so reactive as to damage it. Common PFAS gases used for plasma cleaning and conditioning include, but are not limited to: C2F6, C3F8, CF4, and C4F8. In the early 2000’s and the implementation of 300mm wafer size and associated tool development, NF3 chamber cleans were implemented for much of the 300mm semiconductor industry, replacing C2F6 and other PFC cleans. 6.2 Plasma Cleaning Even with the highly controlled, selective use of PFCs and HFCs, some by-product deposition or dielectric layers previously deposited may occur on the sidewall of semiconductor equipment chambers. This deposition in both plasma etching and chemical vapour deposition chambers, if not cleaned periodically, can result in contamination of the wafer and the ultimate scrapping of functional semiconductors. Periodic PFC cleaning and conditioning of chambers is used to optimise product yield. PFCs and HFCs are used due to their relative stability in storage and gas transfer as well as their ion reactivity in plasma. The gases used to clean internal equipment surfaces must be reactive enough to clean the chamber, but not so reactive as to damage it. Common PFAS gases used for plasma cleaning and conditioning include, but are not limited to: C2F6, C3F8, CF4, and C4F8. In the early 2000’s and the implementation of 300mm wafer size and associated tool development, NF3 chamber cleans were implemented for much of the 300mm semiconductor industry, replacing C2F6 and other PFC cleans. 6.3 Chemical Vapour Deposition/Atomic Layer Deposition of Organometallics Deposition of many metal-containing films (including, but not limited to oxides, nitrides, and pure metals) required for current and future semiconductor process nodes relies on organometallic precursors containing polyfluorinated compounds as ligands. This is especially prevalent in late transition metal deposition precursors. The presence of fluorine in the molecules serves several important roles. First, the presence of fluorine atoms in organometallic compounds reduces the intermolecular dispersion force © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 54 262 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 6.3 Chemical Vapour Deposition/Atomic Layer Deposition of Organometallics Deposition of many metal-containing films (including, but not limited to oxides, nitrides, and pure metals) required for current and future semiconductor process nodes relies on organometallic precursors containing polyfluorinated compounds as ligands. This is especially prevalent in late transition metal deposition precursors. The presence of fluorine in the molecules serves several important roles. First, the presence of fluorine atoms in organometallic compounds reduces the intermolecular dispersion force © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 54 262 The Impact of a Potential PFAS Restriction on the Semiconductor Sector and thereby increases the volatility (lowers boiling temperature) significantly, allowing the precursor to reach the chamber where it will react to form films containing the metal of interest. The presence of fluorine in these ligands also influences the stability and reactivity of these materials. Fluorine containing ligands have a strong impact on the electron density at the metal centre and can stabilise a molecule sufficiently to allow easy transport to the chamber while leaving the molecule reactive enough to interact with other co-reactants resulting in the film of interest. and thereby increases the volatility (lowers boiling temperature) significantly, allowing the precursor to reach the chamber where it will react to form films containing the metal of interest. The presence of fluorine in these ligands also influences the stability and reactivity of these materials. Fluorine containing ligands have a strong impact on the electron density at the metal centre and can stabilise a molecule sufficiently to allow easy transport to the chamber while leaving the molecule reactive enough to interact with other co-reactants resulting in the film of interest. 6.4 Other critical uses of PFCs and HFCs Gas-cluster ion beam is a technology used for nano-scale modification of semiconductor surfaces through infusion or deposition. This technology is used to develop the necessary electrical properties of the wafer through surface modification. Current stability gases used in gas-cluster ion beam include, but are not limited to, CF4 and CF3. Assembly, test, and packaging steps connect the semiconductor die to the semiconductor package. These steps include bonding, cleaning, and preparing the package to ensure electrical connectivity. Future advanced assembly, test, and packaging operations (including such processes as through silicon via and wafer stacking) are currently in the invention and research and development phase. PFC and HFC gases, such as but not limited to CF4, are used, and may be used in next generation assembly, test, and packaging operations. 6.4 Other critical uses of PFCs and HFCs Gas-cluster ion beam is a technology used for nano-scale modification of semiconductor surfaces through infusion or deposition. This technology is used to develop the necessary electrical properties of the wafer through surface modification. Current stability gases used in gas-cluster ion beam include, but are not limited to, CF4 and CF3. Assembly, test, and packaging steps connect the semiconductor die to the semiconductor package. These steps include bonding, cleaning, and preparing the package to ensure electrical connectivity. Future advanced assembly, test, and packaging operations (including such processes as through silicon via and wafer stacking) are currently in the invention and research and development phase. PFC and HFC gases, such as but not limited to CF4, are used, and may be used in next generation assembly, test, and packaging operations. Table 6-1 Examples of the manufacturing processes using PFC and HFC gases. Processing need/ Example substances Alternative or replacement status Timeline to develop function CHF3; HFC-23; There are no viable substitutes for Trifluoromethane; CH2F2; fluorocarbon chemistries at CH3F present. These chemistries provide CH2FCF3; HFC-134a; both thermodynamically favourable 1,1,1,2-tetrafluoroethane reactions for patterning silicon and its dielectrics and selectivity to C5F8; PFC-1418; 15+ years for each carbon-based masking materials. Octafluorocyclopentene specific etch type Attempts to separate these (for example: oxide C4F8; PFC-318; components (e.g., using etch, nitride etch, Dry etch Octafluoro-2-butene hydrocarbons and separate silicon etch, C4F6; Hexafluoro-1,3- fluorine sources) introduce hardmask etch, etc.) butadiene additional safety concerns and with additional likely form PFC by-products. time to implement C3F8; PFC-218; each solution Octafluoropropane Alternative molecules containing C and F which do not fit into the PFAS definition may have CF4; PFC-14; Carbon complicating factors such as high tetrafluoride global warming potentials and low destruction/removal efficiencies. NF3 has been implemented as an 10+ years for each C2F6; PFC-116; C4F8; Chamber cleans alternative due to its high utilisation specific cleaning Hexafluoroethane (for deposition and efficiency but can create CFx by- type etch chambers) C3F8; PFC-218; products when there is residual carbon. 10+ years 50 Octafluoropropane Table 6-1 Examples of the manufacturing processes using PFC and HFC gases. Processing need/ Example substances Alternative or replacement status Timeline to develop function CHF3; HFC-23; There are no viable substitutes for Trifluoromethane; CH2F2; fluorocarbon chemistries at CH3F present. These chemistries provide CH2FCF3; HFC-134a; both thermodynamically favourable 1,1,1,2-tetrafluoroethane reactions for patterning silicon and its dielectrics and selectivity to C5F8; PFC-1418; 15+ years for each carbon-based masking materials. Octafluorocyclopentene specific etch type Attempts to separate these (for example: oxide C4F8; PFC-318; components (e.g., using etch, nitride etch, Dry etch Octafluoro-2-butene hydrocarbons and separate silicon etch, C4F6; Hexafluoro-1,3- fluorine sources) introduce hardmask etch, etc.) butadiene additional safety concerns and with additional likely form PFC by-products. time to implement C3F8; PFC-218; each solution Octafluoropropane Alternative molecules containing C and F which do not fit into the PFAS definition may have CF4; PFC-14; Carbon complicating factors such as high tetrafluoride global warming potentials and low destruction/removal efficiencies. NF3 has been implemented as an 10+ years for each C2F6; PFC-116; C4F8; Chamber cleans alternative due to its high utilisation specific cleaning Hexafluoroethane (for deposition and efficiency but can create CFx by- type etch chambers) C3F8; PFC-218; products when there is residual carbon. 10+ years 50 Octafluoropropane ______ 50 The alternative would require redesign of tools, existing semiconductor equipment and manufacturing processes which is why such a development timeframe is needed. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 55 263 The Impact of a Potential PFAS Restriction on the Semiconductor Sector ______ 50 The alternative would require redesign of tools, existing semiconductor equipment and manufacturing processes which is why such a development timeframe is needed. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 55 263 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Processing need/ Example substances Alternative or replacement status Timeline to develop function CF4; PFC-14; Carbon 10+ years50 tetrafluoride CF4; PFC-14; Carbon The process needs exactly the Pre- tetrafluoride same gas combinations and mix 5 years clean/seasoning C4F6; Hexafluoro-1,3- ratio to the etching step following butadiene the process. Replacements investigated, but not viable. Assembly test and CF4; PFC-14; Carbon Other replacements may be 10+ years packaging tetrafluoride possible but need further investigation. CF4; PFC-14; Carbon tetrafluoride Replacement may be possible with Gas cluster ion NF3, SF6, O2, Ar, further 10+ years beam CHF3; HFC-23; investigation needed. Trifluoromethane The presence of fluorine in these ligands also influences the stability Metal HFAC and reactivity of these materials. Indeterminate Organometallic Evaluations in progress but do not precursors Metal TFAC meet required process Others performance; further investigation is needed. Self-assembled This is in the research stage. Lack monolayer and Polyfluorinated of access to these molecules will Indeterminate small molecule hydrocarbons limit innovation. inhibitors 51 Processing need/ Example substances Alternative or replacement status Timeline to develop function CF4; PFC-14; Carbon 10+ years50 tetrafluoride CF4; PFC-14; Carbon The process needs exactly the Pre- tetrafluoride same gas combinations and mix 5 years clean/seasoning C4F6; Hexafluoro-1,3- ratio to the etching step following butadiene the process. Replacements investigated, but not viable. Assembly test and CF4; PFC-14; Carbon Other replacements may be 10+ years packaging tetrafluoride possible but need further investigation. CF4; PFC-14; Carbon tetrafluoride Replacement may be possible with Gas cluster ion NF3, SF6, O2, Ar, further 10+ years beam CHF3; HFC-23; investigation needed. Trifluoromethane The presence of fluorine in these ligands also influences the stability Metal HFAC and reactivity of these materials. Indeterminate Organometallic Evaluations in progress but do not precursors Metal TFAC meet required process Others performance; further investigation is needed. Self-assembled This is in the research stage. Lack monolayer and Polyfluorinated of access to these molecules will Indeterminate small molecule hydrocarbons limit innovation. inhibitors 51 PFC and HFC gases have been used in the semiconductor industry for decades following many years of intensive development to optimise processes. These gases are and have been a critical component for manufacturing semiconductors due to their relative chemical stability during storage and transfer and relative chemical reactivity during plasma ion generation. PFC and HFC emission reductions have been a committed goal of the semiconductor industry for over 30 years. 52 PFC and HFC emission reductions have been achieved through the development of industry best practices 53 such as: chemical recipe optimisation, chemical replacements, point of use abatement, and lower emitting remote plasma cleans. Semiconductor manufacturing was one of the first industries to establish global voluntary reduction targets for these PFCs when in 1999 the WSC agreed to reduce absolute PFC emissions by at least 10% by the end of 2010 having as a baseline the 1995 emissions. By 2010, emissions were reduced 32% below the baseline, surpassing the 10% reduction target. The WSC again committed to a voluntary PFC agreement in 2010 with a time horizon up to 2020 and reports on progress publicly in the WSC annual joint statement. However, during these 30 years of investigation, PFC and HFC gases have been used in the semiconductor industry for decades following many years of intensive development to optimise processes. These gases are and have been a critical component for manufacturing semiconductors due to their relative chemical stability during storage and transfer and relative chemical reactivity during plasma ion generation. PFC and HFC emission reductions have been a committed goal of the semiconductor industry for over 30 years. 52 PFC and HFC emission reductions have been achieved through the development of industry best practices 53 such as: chemical recipe optimisation, chemical replacements, point of use abatement, and lower emitting remote plasma cleans. Semiconductor manufacturing was one of the first industries to establish global voluntary reduction targets for these PFCs when in 1999 the WSC agreed to reduce absolute PFC emissions by at least 10% by the end of 2010 having as a baseline the 1995 emissions. By 2010, emissions were reduced 32% below the baseline, surpassing the 10% reduction target. The WSC again committed to a voluntary PFC agreement in 2010 with a time horizon up to 2020 and reports on progress publicly in the WSC annual joint statement. However, during these 30 years of investigation, ______ 51 This is not discussed previously as it is in the research phase. 52 World Semiconductor Council (WSC) Joint Statement, April 1999, http://www.semiconductorcouncil.org/wp- content/uploads/2016/04/PFC-Reduction.pdf 53 World Semiconductor Council (WSC) PFC Best Practices Guidance, September 2012, http://www.semiconductorcouncil.org/wp- content/uploads/2016/07/Final_WSC_Best_Practice_Guidance_26_Sept_2012.pdf © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 56 264 The Impact of a Potential PFAS Restriction on the Semiconductor Sector the industry has not identified safe and effective alternatives for all PFC and HFC gas uses. Given this, it is believed the elimination of HFCs and PFCs would require a fundamental re-design of semiconductors to a non-silicon base material as well as redesign of the processes and equipment used to make them. Replacing silicon with another material will not necessarily result in elimination of the need for HFCs and PFCs. ______ 51 This is not discussed previously as it is in the research phase. 52 World Semiconductor Council (WSC) Joint Statement, April 1999, http://www.semiconductorcouncil.org/wp- content/uploads/2016/04/PFC-Reduction.pdf 53 World Semiconductor Council (WSC) PFC Best Practices Guidance, September 2012, http://www.semiconductorcouncil.org/wp- content/uploads/2016/07/Final_WSC_Best_Practice_Guidance_26_Sept_2012.pdf © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 56 264 The Impact of a Potential PFAS Restriction on the Semiconductor Sector the industry has not identified safe and effective alternatives for all PFC and HFC gas uses. Given this, it is believed the elimination of HFCs and PFCs would require a fundamental re-design of semiconductors to a non-silicon base material as well as redesign of the processes and equipment used to make them. Replacing silicon with another material will not necessarily result in elimination of the need for HFCs and PFCs. While the use of C2F6 in chamber cleaning has been replaced in many applications with NF3, the semiconductor industry operates a variety of fabs with tools that may not always have the capability to upgrade to an alternative gas. It is important to note that this transition to NF3 was the result of over 15 years of development which was initiated in 1997 and now has become the industry standard whenever possible. The cost implications of such a transition are high with the costs per chamber ranging from ~$60K to $400K and a semiconductor manufacturing fab containing hundreds of chambers for thin film (etch and deposition) processes. Even with this transition, PFAS by-products are still produced when carbon containing precursors are used in the dielectric deposition and emitted due to the reaction and recombination of fluorine with carbon and hydrogen to create PFC and HFC by-products. Owing to the resilient nature of many chamber residues, highly reactive fluorine (the most electronegative atom) is required for chamber cleaning which is why alternatives still rely on the inclusion of fluorine. As such, although this does resolve in some ways the reliance on PFAS substances, it still involves PFAS if the end-to-end system is considered. While the use of C2F6 in chamber cleaning has been replaced in many applications with NF3, the semiconductor industry operates a variety of fabs with tools that may not always have the capability to upgrade to an alternative gas. It is important to note that this transition to NF3 was the result of over 15 years of development which was initiated in 1997 and now has become the industry standard whenever possible. The cost implications of such a transition are high with the costs per chamber ranging from ~$60K to $400K and a semiconductor manufacturing fab containing hundreds of chambers for thin film (etch and deposition) processes. Even with this transition, PFAS by-products are still produced when carbon containing precursors are used in the dielectric deposition and emitted due to the reaction and recombination of fluorine with carbon and hydrogen to create PFC and HFC by-products. Owing to the resilient nature of many chamber residues, highly reactive fluorine (the most electronegative atom) is required for chamber cleaning which is why alternatives still rely on the inclusion of fluorine. As such, although this does resolve in some ways the reliance on PFAS substances, it still involves PFAS if the end-to-end system is considered. 6.5 Environmental Considerations in PFCs and HFCs As discussed above, the use of PFCs and HFCs is essential for plasma etching, plasma cleaning, and other low volume critical applications, their uses balance the process need for high chemical and ion reactivity with the need for safe and effective manufacturing. The industry’s commitment to reduce greenhouse gas emissions has successfully reduced PFCs and HFCs emissions through a combination of process optimisation, substitution, and abatement. Implementation has required companies to invest time and funds to identify and research prospective changes to HFC/PFC chemicals, to design, test and implement process and equipment modifications, and to identify, test and design increasingly effective abatement systems. Although this process has proven effective at mitigating the impact of emissions, it has not proven effective in eliminating PFCs and HFCs from the manufacturing process. 6.5 Environmental Considerations in PFCs and HFCs As discussed above, the use of PFCs and HFCs is essential for plasma etching, plasma cleaning, and other low volume critical applications, their uses balance the process need for high chemical and ion reactivity with the need for safe and effective manufacturing. The industry’s commitment to reduce greenhouse gas emissions has successfully reduced PFCs and HFCs emissions through a combination of process optimisation, substitution, and abatement. Implementation has required companies to invest time and funds to identify and research prospective changes to HFC/PFC chemicals, to design, test and implement process and equipment modifications, and to identify, test and design increasingly effective abatement systems. Although this process has proven effective at mitigating the impact of emissions, it has not proven effective in eliminating PFCs and HFCs from the manufacturing process. The adoption of point of use (POU) technologies on many tools using PFCs and HFCs has reduced the potential hazard exposure risk to employees and has reduced greenhouse gas emissions. With the implementation of WSC PFC best practices in new fabs – including remote plasma clean and POU abatement- many facilities have needed to expand other treatment systems, such as wastewater, fluoride, and exhaust to meet the required standards for wastewater and air toxics. Some POU technologies use fuel-burning processes to abate PFCs and HFCs, creating additional nitrogen oxides, carbon monoxide, and other air pollutants from combustion in exchange for a reduction in PFCs and HFCs. Process and abatement alternatives often require a full safety, health, and environmental impact review to understand additional implications to employee and community safety and health. Viable alternatives often require coordinated efforts between material suppliers, equipment suppliers, device manufacturers, and environmental safety and health professionals to determine the overall environmental impact of even a small change. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 57 265 The adoption of point of use (POU) technologies on many tools using PFCs and HFCs has reduced the potential hazard exposure risk to employees and has reduced greenhouse gas emissions. With the implementation of WSC PFC best practices in new fabs – including remote plasma clean and POU abatement- many facilities have needed to expand other treatment systems, such as wastewater, fluoride, and exhaust to meet the required standards for wastewater and air toxics. Some POU technologies use fuel-burning processes to abate PFCs and HFCs, creating additional nitrogen oxides, carbon monoxide, and other air pollutants from combustion in exchange for a reduction in PFCs and HFCs. Process and abatement alternatives often require a full safety, health, and environmental impact review to understand additional implications to employee and community safety and health. Viable alternatives often require coordinated efforts between material suppliers, equipment suppliers, device manufacturers, and environmental safety and health professionals to determine the overall environmental impact of even a small change. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 57 265 The Impact of a Potential PFAS Restriction on the Semiconductor Sector The Impact of a Potential PFAS Restriction on the Semiconductor Sector 7 HEAT TRANSFER FLUID USES Summary: Two types of fluorinated heat transfer fluids are used in semiconductor manufacturing processes and semiconductor device test applications: liquid fluorinated heat transfer fluids (F-HTFs) and fluorinated refrigerants. These two types of fluorinated heat transfer fluids are used in tandem within corresponding heat transfer fluid (HTF) loops and refrigerant cycles to meet operational temperature requirements in semiconductor manufacturing processes like dry etch or thin film deposition and semiconductor device test applications, of which dry etch is the predominant and most complex use with stringent manufacturing process requirements. To date, non-PFAS alternatives have not been identified. For F-HTFs the performance characteristics require the material to be electrically non-conductive, to be compatible with all materials of construction including sensitive electrical components, suitable toxicity/flammability, and to not cause catastrophic process contamination issues. Fluorinated refrigerants work in tandem with F-HTFs and must remain in a gaseous or liquid form to remain pumpable and useful for temperature control. 7 HEAT TRANSFER FLUID USES Summary: Two types of fluorinated heat transfer fluids are used in semiconductor manufacturing processes and semiconductor device test applications: liquid fluorinated heat transfer fluids (F-HTFs) and fluorinated refrigerants. These two types of fluorinated heat transfer fluids are used in tandem within corresponding heat transfer fluid (HTF) loops and refrigerant cycles to meet operational temperature requirements in semiconductor manufacturing processes like dry etch or thin film deposition and semiconductor device test applications, of which dry etch is the predominant and most complex use with stringent manufacturing process requirements. To date, non-PFAS alternatives have not been identified. For F-HTFs the performance characteristics require the material to be electrically non-conductive, to be compatible with all materials of construction including sensitive electrical components, suitable toxicity/flammability, and to not cause catastrophic process contamination issues. Fluorinated refrigerants work in tandem with F-HTFs and must remain in a gaseous or liquid form to remain pumpable and useful for temperature control. As such, suitable, non-PFAS-containing substitutes for the majority of uses would need to be invented and those invented may not enable ready plug-and-play substitution. When a plug-and-play substitute is not available it would drive a complete redesign of manufacturing and support equipment. New equipment designs may also require invention, may drive additional space and/or facilities that could result in a reduction of available manufacturing space and/or expense, that could impact global 9ECF;I?I?K;D;HH%Q • For the small percentage of applications in which glycol / water alternatives can be substituted and refrigerants within process equipment chillers from 8 to more than 14 years are required to substitute PFAS in HTF for semiconductor manufacturing processes. • Where no alternatives have been invented for the remainder of semiconductor manufacturing processes such as dry etch applications (70 – 100% of cases), there is an unquantifiable time to invent an alternative, followed by from 5 to more than 15 years required. • Invention of a PFAS-free thermal test fluid hasn’t started and time to do this cannot be quantified. Once invented, it will take from 8 to more than 14 years to implement and if the thermal test equipment needs redesign to accommodate the new method longer. As such, suitable, non-PFAS-containing substitutes for the majority of uses would need to be invented and those invented may not enable ready plug-and-play substitution. When a plug-and-play substitute is not available it would drive a complete redesign of manufacturing and support equipment. New equipment designs may also require invention, may drive additional space and/or facilities that could result in a reduction of available manufacturing space and/or expense, that could impact global 9ECF;I?I?K;D;HH%Q • For the small percentage of applications in which glycol / water alternatives can be substituted and refrigerants within process equipment chillers from 8 to more than 14 years are required to substitute PFAS in HTF for semiconductor manufacturing processes. • Where no alternatives have been invented for the remainder of semiconductor manufacturing processes such as dry etch applications (70 – 100% of cases), there is an unquantifiable time to invent an alternative, followed by from 5 to more than 15 years required. • Invention of a PFAS-free thermal test fluid hasn’t started and time to do this cannot be quantified. Once invented, it will take from 8 to more than 14 years to implement and if the thermal test equipment needs redesign to accommodate the new method longer. Most F-HTF uses involve closed but not hermetically sealed systems where fluorinated long-life seals and optimised equipment minimis; ;K7FEG7I?K; BEHH;H :JG?D= DEGC7B EF;G7I?ED% Q 4C7BB 7CEJDIH E< emissions are expected from HTF loops during maintenance tasks such as changeout of parts that require replacement, from filling and draining, as well as from any leaks that may occur upon failure of the couplers, seals or gaskets used within the loop systems. Waste is typically collected during operation and end of equipment life for recovery and reuse or thermal destruction. Heat transfer fluids can be differentiated into two categories based upon their manner of absorption or extraction of heat from the substances to be cooled or heated: • Fluorinated heat transfer fluids (F-HTFs) are used within closed loop systems between specialised semiconductor manufacturing process modules and process equipment temperature control systems that require either heating or cooling to achieve temperature control across a very broad temperature range (-80oC to +125oC) within very tightly controlled setpoints. 54 HTFs remain ______ 54 Reference: Tuma, P., & Tousignant, L. (2002). Reducing Emissions of PFC Heat Transfer Fluids. https://multimedia.3m.com/mws/media/122381O/reducing-emissions-of-pfc-heat-transfer-fluids.pdf Most F-HTF uses involve closed but not hermetically sealed systems where fluorinated long-life seals and optimised equipment minimis; ;K7FEG7I?K; BEHH;H :JG?D= DEGC7B EF;G7I?ED% Q 4C7BB 7CEJDIH E< emissions are expected from HTF loops during maintenance tasks such as changeout of parts that require replacement, from filling and draining, as well as from any leaks that may occur upon failure of the couplers, seals or gaskets used within the loop systems. Waste is typically collected during operation and end of equipment life for recovery and reuse or thermal destruction. Heat transfer fluids can be differentiated into two categories based upon their manner of absorption or extraction of heat from the substances to be cooled or heated: • Fluorinated heat transfer fluids (F-HTFs) are used within closed loop systems between specialised semiconductor manufacturing process modules and process equipment temperature control systems that require either heating or cooling to achieve temperature control across a very broad temperature range (-80oC to +125oC) within very tightly controlled setpoints. 54 HTFs remain ______ 54 Reference: Tuma, P., & Tousignant, L. (2002). Reducing Emissions of PFC Heat Transfer Fluids. https://multimedia.3m.com/mws/media/122381O/reducing-emissions-of-pfc-heat-transfer-fluids.pdf © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 58 266 The Impact of a Potential PFAS Restriction on the Semiconductor Sector in liquid phase in most cases and cool or heat by exchanging heat through use of simple heat exchangers that are part of the closed loop system. Classes of F-HTFs include: - Perfluoropolyethers (PFPEs) - Hydrofluoroolefins (HFOs) - Perfluorocarbons (PFCs) - Fluorinated Ketones - Hydrofluorocarbons (HFCs) - Other Fluorinated Liquids - Hydrofluoroethers (HFEs) © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 58 266 The Impact of a Potential PFAS Restriction on the Semiconductor Sector in liquid phase in most cases and cool or heat by exchanging heat through use of simple heat exchangers that are part of the closed loop system. Classes of F-HTFs include: - Perfluoropolyethers (PFPEs) - Hydrofluoroolefins (HFOs) - Perfluorocarbons (PFCs) - Fluorinated Ketones - Hydrofluorocarbons (HFCs) - Other Fluorinated Liquids - Hydrofluoroethers (HFEs) • Fluorinated refrigerants are used in the refrigeration cycle of process equipment chillers and temperature control units to provide a heat sink often well below ambient temperatures (as low as – 80oC). In most cases refrigerants undergo a repeated phase transition from a liquid to a gas and back again with the use of evaporators and condensers integrated into a hermetically sealed cooling loop. 55 Classes of fluorinated refrigerants currently in use within the process equipment chillers used and temperature control units, in support of semiconductor manufacturing include: - PFCs - Fluorinated Ketones - HFCs - Other Fluorinated Liquids - HFOs Heat transfer fluids (F-HTFs) fulfil a number of different uses including 56: • Manufacturing processes where temperature setpoints must be maintained ranging from -60oC to 125oC and material must remain pumpable across this entire range. For most applications, only one stable temperature set point is required but this must be held within tight tolerances, such as +/- 0.1oC for dry etch, with corresponding cooling capacities of up to several kilowatts. • Fluorinated refrigerants are used in the refrigeration cycle of process equipment chillers and temperature control units to provide a heat sink often well below ambient temperatures (as low as – 80oC). In most cases refrigerants undergo a repeated phase transition from a liquid to a gas and back again with the use of evaporators and condensers integrated into a hermetically sealed cooling loop. 55 Classes of fluorinated refrigerants currently in use within the process equipment chillers used and temperature control units, in support of semiconductor manufacturing include: - PFCs - Fluorinated Ketones - HFCs - Other Fluorinated Liquids - HFOs Heat transfer fluids (F-HTFs) fulfil a number of different uses including 56: • Manufacturing processes where temperature setpoints must be maintained ranging from -60oC to 125oC and material must remain pumpable across this entire range. For most applications, only one stable temperature set point is required but this must be held within tight tolerances, such as +/- 0.1oC for dry etch, with corresponding cooling capacities of up to several kilowatts. • Performance and thermal testing at various stages of the semiconductor devices development, to ensure device integrity and to test their ability to effectively operate within the finished electronic end products. Including: - Burn-in testing: Burn-in is a part of the end of line test done after package assembly. The part is placed in a socket and an electrical signal is applied to stress and heat up the part. The test is designed to find infancy failures, which are screened out and scrapped. - Thermal shock testing: Also known as hermetic seal testing. Parts are shocked at a cold or high temperature to simulate use conditions or shipping, or to accelerate failures that enable better understanding of the longevity of a part in expected use conditions. - Device reliability testing: Parts are cycled from low temperature to high temperature to simulate their use in the field, over tens to thousands of cycles. The HTF is required for this to take place in a temperature-controlled environment. Reliability testing is used to certify products for the lifetime use condition of multiple years, through a test protocol that can be achieved over a timeline of a few of weeks or months. • Performance and thermal testing at various stages of the semiconductor devices development, to ensure device integrity and to test their ability to effectively operate within the finished electronic end products. Including: - Burn-in testing: Burn-in is a part of the end of line test done after package assembly. The part is placed in a socket and an electrical signal is applied to stress and heat up the part. The test is designed to find infancy failures, which are screened out and scrapped. - Thermal shock testing: Also known as hermetic seal testing. Parts are shocked at a cold or high temperature to simulate use conditions or shipping, or to accelerate failures that enable better understanding of the longevity of a part in expected use conditions. - Device reliability testing: Parts are cycled from low temperature to high temperature to simulate their use in the field, over tens to thousands of cycles. The HTF is required for this to take place in a temperature-controlled environment. Reliability testing is used to certify products for the lifetime use condition of multiple years, through a test protocol that can be achieved over a timeline of a few of weeks or months. To support the complex requirements of semiconductor manufacturing, specific combinations of physical and chemical properties are required to be met simultaneously from the HTFs. The need to ______ 55 ANSI/ASHRAE Standard 34-2019, Designation and Safety Classification of Refrigerants. 56 https://www.epa.gov/sites/default/files/2016-02/documents/pfc_heat_tranfer_fluid_emission.pdf page 2 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 59 267 The Impact of a Potential PFAS Restriction on the Semiconductor Sector To support the complex requirements of semiconductor manufacturing, specific combinations of physical and chemical properties are required to be met simultaneously from the HTFs. The need to ______ 55 ANSI/ASHRAE Standard 34-2019, Designation and Safety Classification of Refrigerants. 56 https://www.epa.gov/sites/default/files/2016-02/documents/pfc_heat_tranfer_fluid_emission.pdf page 2 © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 59 267 The Impact of a Potential PFAS Restriction on the Semiconductor Sector meet all requirements at once often requires selection of fluorinated heat transfer fluids, as similar capabilities are not found in non-PFAS alternative fluids. For example and as outlined in Table 7-1 below, certain dry etch processes, which require cooling of an electrostatic chuck very near an active plasma, will need an HTF that possesses a high boiling point, high thermal conductivity, and high resistivity in order to maintain the proper functioning of the wafer chuck, as well as the stability of the plasma. Similarly, an HTF that is used in semiconductor test applications, requires the following: a high boiling point, a low pour-point, low kinematic viscosity at low temperature and high specific heat to enable the test operational temperature range. The following provides information on specific HTF applications. Heat Transfer Fluid (F-HTFs) in Process Equipment Chillers: Temperature control for many semiconductor manufacturing steps is achieved through use of individual process equipment chillers which are roughly the size of a small home appliance and are part of the support equipment packages connected to each piece of semiconductor manufacturing equipment in a fab. Process equipment chillers pump HTF through the plumbing loops embedded in the process chambers to either remove or add heat to the system. meet all requirements at once often requires selection of fluorinated heat transfer fluids, as similar capabilities are not found in non-PFAS alternative fluids. For example and as outlined in Table 7-1 below, certain dry etch processes, which require cooling of an electrostatic chuck very near an active plasma, will need an HTF that possesses a high boiling point, high thermal conductivity, and high resistivity in order to maintain the proper functioning of the wafer chuck, as well as the stability of the plasma. Similarly, an HTF that is used in semiconductor test applications, requires the following: a high boiling point, a low pour-point, low kinematic viscosity at low temperature and high specific heat to enable the test operational temperature range. The following provides information on specific HTF applications. Heat Transfer Fluid (F-HTFs) in Process Equipment Chillers: Temperature control for many semiconductor manufacturing steps is achieved through use of individual process equipment chillers which are roughly the size of a small home appliance and are part of the support equipment packages connected to each piece of semiconductor manufacturing equipment in a fab. Process equipment chillers pump HTF through the plumbing loops embedded in the process chambers to either remove or add heat to the system. A semiconductor manufacturing facility may have well in excess of 1000 process equipment chillers all using PFAS F-HTF 57 which is circulated through the wafer mounts during the process. Through the years of development of semiconductor technology, it was necessary to replace water-based lower boiling point non-F-HTFs with higher boiling point F-HTFs. F-HTFs are capable of achieving all required performance requirements whilst avoiding the generation of imperfections that negatively impact the yield of the semiconductor manufacturing process. They also enable the determination of the appropriate functionality of the semiconductor devices within the conditions expected to be encountered within the end use applications. Part of the drive to convert to F-HTFs was their stability, inertness, reduced flammability risk, lower impact to manufacturing tooling and reduced requirement to replace materials during normal operation. A semiconductor manufacturing facility may have well in excess of 1000 process equipment chillers all using PFAS F-HTF 57 which is circulated through the wafer mounts during the process. Through the years of development of semiconductor technology, it was necessary to replace water-based lower boiling point non-F-HTFs with higher boiling point F-HTFs. F-HTFs are capable of achieving all required performance requirements whilst avoiding the generation of imperfections that negatively impact the yield of the semiconductor manufacturing process. They also enable the determination of the appropriate functionality of the semiconductor devices within the conditions expected to be encountered within the end use applications. Part of the drive to convert to F-HTFs was their stability, inertness, reduced flammability risk, lower impact to manufacturing tooling and reduced requirement to replace materials during normal operation. Dry etch manufacturing equipment: To meet precise temperature requirements within the manufacturing chamber, any alternative would need to avoid interfering with equipment performance or the manufacturing process, while maximising the lifetime of the manufacturing equipment. The process equipment side of the HTF loop usually has mechanical joints for maintenance of process equipment and formation of flammable vapour is possible under fault conditions. The electrical equipment and wiring within the process equipment may need to satisfy electrical design requirement for hazardous (classified) locations, such as NFPA 70. 58 Due to this the development of future non-PFAS utilising systems will likely require significant redesign timelines for development and implementation as outlined in Section 6.1. Testing applications of semiconductor devices: Precision manufacturing processes necessitate the frequent use of test instrumentation to ensure that these processes are performing as required, and that the final semiconductor devices perform correctly and remain reliable across a range of environmental conditions. In some test applications it is necessary to electrically test a completed semiconductor device over varying conditions to assure that it can perform as required under different temperature conditions. Dry etch manufacturing equipment: To meet precise temperature requirements within the manufacturing chamber, any alternative would need to avoid interfering with equipment performance or the manufacturing process, while maximising the lifetime of the manufacturing equipment. The process equipment side of the HTF loop usually has mechanical joints for maintenance of process equipment and formation of flammable vapour is possible under fault conditions. The electrical equipment and wiring within the process equipment may need to satisfy electrical design requirement for hazardous (classified) locations, such as NFPA 70. 58 Due to this the development of future non-PFAS utilising systems will likely require significant redesign timelines for development and implementation as outlined in Section 6.1. Testing applications of semiconductor devices: Precision manufacturing processes necessitate the frequent use of test instrumentation to ensure that these processes are performing as required, and that the final semiconductor devices perform correctly and remain reliable across a range of environmental conditions. In some test applications it is necessary to electrically test a completed semiconductor device over varying conditions to assure that it can perform as required under different temperature conditions. ______ 57 Taken from EPA publication “Uses and emissions of liquid pfc heat transfer fluids from the electronics sector” available at Uses and Air Emissions of Liquid PFC Heat Transfer Fluids from the Electronics Sector | US EPA (1/11/2022) 58 The US national electrical code, which is the benchmark for safe electrical design, installation, and inspection to protect people and property from electrical hazards. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 60 268 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Certain types of semiconductor device test applications also employ temperature stressing to assure that the different materials of construction are mechanically compatible. ______ 57 Taken from EPA publication “Uses and emissions of liquid pfc heat transfer fluids from the electronics sector” available at Uses and Air Emissions of Liquid PFC Heat Transfer Fluids from the Electronics Sector | US EPA (1/11/2022) 58 The US national electrical code, which is the benchmark for safe electrical design, installation, and inspection to protect people and property from electrical hazards. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 60 268 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Certain types of semiconductor device test applications also employ temperature stressing to assure that the different materials of construction are mechanically compatible. Refrigerants within process equipment chillers: Process equipment chillers currently make use of fluorinated refrigerants within their compressor systems to act as a heat sink and as heat-transfer agents between the manufacturing process and the facility chiller system. Operation of process equipment at the operational temperature set points requires complementary capabilities between the F-HTF in the HTF loop and the refrigerant in the refrigerant cycle. The most critical performance requirement of the refrigerant is to enable the lowest operational setpoint, while avoiding a catastrophic phase shift to solid form (the refrigerant must remain in a gaseous or liquid form to remain pumpable and useful for temperature control). Other performance requirements which need to be optimised include the energy efficiency of the chiller, size of the equipment, and avoiding introducing new safety and worker exposure risks. It is important to note that no HTF remains in the finished semiconductor device. In any case HTFs42 have the benefits of being odourless, non-flammable, non-explosive, evaporate cleanly and exhibit very low toxicity based on current understanding, which results in easier safe usage and storage. Due to the demanding environments HTF operates in, only specifically tailored fluorinated compounds are able to offer the required performance in many of the applications and there are very few manufacturers of HTFs for semiconductor industry applications. Refrigerants within process equipment chillers: Process equipment chillers currently make use of fluorinated refrigerants within their compressor systems to act as a heat sink and as heat-transfer agents between the manufacturing process and the facility chiller system. Operation of process equipment at the operational temperature set points requires complementary capabilities between the F-HTF in the HTF loop and the refrigerant in the refrigerant cycle. The most critical performance requirement of the refrigerant is to enable the lowest operational setpoint, while avoiding a catastrophic phase shift to solid form (the refrigerant must remain in a gaseous or liquid form to remain pumpable and useful for temperature control). Other performance requirements which need to be optimised include the energy efficiency of the chiller, size of the equipment, and avoiding introducing new safety and worker exposure risks. It is important to note that no HTF remains in the finished semiconductor device. In any case HTFs42 have the benefits of being odourless, non-flammable, non-explosive, evaporate cleanly and exhibit very low toxicity based on current understanding, which results in easier safe usage and storage. Due to the demanding environments HTF operates in, only specifically tailored fluorinated compounds are able to offer the required performance in many of the applications and there are very few manufacturers of HTFs for semiconductor industry applications. The following tables shows examples of both types of PFAS HTFs. This table does not exhaustively describe the whole Semiconductor industry as it is limited to information provided by the Semiconductor PFAS consortium members. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 61 269 The Impact of a Potential PFAS Restriction on the Semiconductor Sector The following tables shows examples of both types of PFAS HTFs. This table does not exhaustively describe the whole Semiconductor industry as it is limited to information provided by the Semiconductor PFAS consortium members. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 61 269 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Table 7-1 Examples of HTFs utilising PFAS. Status of PFAS use area Typical PFAS Used Role of PFAS Timeline to develop Concer).*& #(,%+)#,'-% alternatives 3-ethoxy- 1,1,1,2,3,4,4,5,5,6,6,6dodeca- Suitable viscosity at lowest operating fluoro-2-(trifluoromethyl)-hexane, temperature, low dielectric constant Invention/Fundamental Perfluoroalkanes, perfluoroethers In certain F-HTF in process that supports direct cooling of Research – 2-5+ years, and tertiary perfluoroamines, 59 applications equipment energised equipment by immersion, Demonstration – 2 years, Perfluorotributylamine, EG/DI Materials compatibility and chillers (except low vapour pressure, thermally Integration – 2 years, Hydrofluoroolefins 60 such as combinations potential corrosion over time. high energy dry stable, low toxicity, non-flammable, HVM – 2-5 years. ethoxytridecafluoroheptene are being etching) no affinity for hydrocarbon-based Total from 8 to more than isomers: (Z)-1,1,1,4,4,4- investigated. compounds, metal, and plastic 14 years. Hexafluoro-2butene, compatibility. Mixtures of perfluoro- FEBM;I>;GHQ"2+2*H# 61 Dielectric property change Research – unknown, Suitable viscosity (up to -80oC), low may affect plasma conditions, Demonstration – 2+ years; if dielectric constants that support which can require extensive unsuccessful, return to direct cooling of energised process development for each invention/fundamental equipment by immersion, high application, followed by research, F-HTF in high volume resistance, thermally stable adjustment of process Ethoxy-nonafluorobutane Invention is Integration – 2+ years; if energy dry etch for operational temperature range (- conditions. CH2FCF3; HFC-134a; 1,1,1,2- needed for unsuccessful, equipment manufacturing 50oC to +80oC) for long periods, Possible design change of tetrafluoroethane alternative. change may be required equipment chemical inertness, low vapour electrode assembly, the chiller (additional 1 year + repeat pressure, low toxicity, non- and other critical parts of the integration), flammability, no affinity for process chamber may be HVM – 2-5 years. hydrocarbon-based compounds, required. For example, a high Total: Invention from 5 to metal, and plastic compatibility. flammability alternative would more than 15 years. require any equipment used in Table 7-1 Examples of HTFs utilising PFAS. Status of PFAS use area Typical PFAS Used Role of PFAS Timeline to develop Concer).*& #(,%+)#,'-% alternatives 3-ethoxy- 1,1,1,2,3,4,4,5,5,6,6,6dodeca- Suitable viscosity at lowest operating fluoro-2-(trifluoromethyl)-hexane, temperature, low dielectric constant Invention/Fundamental Perfluoroalkanes, perfluoroethers In certain F-HTF in process that supports direct cooling of Research – 2-5+ years, and tertiary perfluoroamines, 59 applications equipment energised equipment by immersion, Demonstration – 2 years, Perfluorotributylamine, EG/DI Materials compatibility and chillers (except low vapour pressure, thermally Integration – 2 years, Hydrofluoroolefins 60 such as combinations potential corrosion over time. high energy dry stable, low toxicity, non-flammable, HVM – 2-5 years. ethoxytridecafluoroheptene are being etching) no affinity for hydrocarbon-based Total from 8 to more than isomers: (Z)-1,1,1,4,4,4- investigated. compounds, metal, and plastic 14 years. Hexafluoro-2butene, compatibility. Mixtures of perfluoro- FEBM;I>;GHQ"2+2*H# 61 Dielectric property change Research – unknown, Suitable viscosity (up to -80oC), low may affect plasma conditions, Demonstration – 2+ years; if dielectric constants that support which can require extensive unsuccessful, return to direct cooling of energised process development for each invention/fundamental equipment by immersion, high application, followed by research, F-HTF in high volume resistance, thermally stable adjustment of process Ethoxy-nonafluorobutane Invention is Integration – 2+ years; if energy dry etch for operational temperature range (- conditions. CH2FCF3; HFC-134a; 1,1,1,2- needed for unsuccessful, equipment manufacturing 50oC to +80oC) for long periods, Possible design change of tetrafluoroethane alternative. change may be required equipment chemical inertness, low vapour electrode assembly, the chiller (additional 1 year + repeat pressure, low toxicity, non- and other critical parts of the integration), flammability, no affinity for process chamber may be HVM – 2-5 years. hydrocarbon-based compounds, required. For example, a high Total: Invention from 5 to metal, and plastic compatibility. flammability alternative would more than 15 years. require any equipment used in ______ 59 Including 3M™ Novec™ 7XXX series Engineered Fluid range and 3M™ Fluorinert™ Electronic Liquid FC-3283/ FC-40/ FC-43/ FC-70/ FC-770/ FC-7000/ FC-7100/ FC-7200/ FC-7300/ FC-7700 60 Sold as Chemours OpteonTM SF10. 61 Including Solvay™ Galden™ range of HTF, including HT 80/ HT-110/ HT-135/ HT-170/ HT-200/ HT-270/ D02-TS, Solvay™ Fomblin™ 14/6 25/6, 16/6. © RINA Tech UK Ltd 270 Report No. 2022-0737 Rev. 0 Page 62 The Impact of a Potential PFAS Restriction on the Semiconductor Sector ______ 59 Including 3M™ Novec™ 7XXX series Engineered Fluid range and 3M™ Fluorinert™ Electronic Liquid FC-3283/ FC-40/ FC-43/ FC-70/ FC-770/ FC-7000/ FC-7100/ FC-7200/ FC-7300/ FC-7700 60 Sold as Chemours OpteonTM SF10. 61 Including Solvay™ Galden™ range of HTF, including HT 80/ HT-110/ HT-135/ HT-170/ HT-200/ HT-270/ D02-TS, Solvay™ Fomblin™ 14/6 25/6, 16/6. © RINA Tech UK Ltd 270 Report No. 2022-0737 Rev. 0 Page 62 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Status of PFAS use area Typical PFAS Used Role of PFAS Timeline to develop Concer).*& #(,%+)#,'-% alternatives its proximity to meet specialised safety standards such as Class 1 division 2 under NFPA 70. Suitable viscosity (up to -40oC), low Possible design change of dielectric constants that support tester head assembly, chiller direct cooling of energised Invention/Fundamental and other critical parts of the equipment by immersion, high Perfluoroamine, 62 Research – 2-5+ years, process equipment may be Testing volume resistance and its long-term Perfluorotributylamine, 63 Invention is Demonstration – 2 years, required. For example, a high applications of stability, thermally stable for the PFPE based testing fluids needed for Integration – 2 years, flammability alternative would semiconductor entire operational temperature range designed for specific test alternative. HVM – 2-5 years. require any equipment used in devices (-40oC to +120oC), low toxicity, non- conditions 64 Total: from 8 to more than its proximity to meet flammability, chemical inertness, low 14 years. specialised safety standards vapour pressure, no affinity for such as Class 1 division 2 hydrocarbon-based compounds, under NFPA 70. metal, and plastic compatibility. CO2 refrigerant chiller doesn’t C2HF5; HFC-125; satisfy cooling capacity, as Invention/Fundamental Pentafluoroethane 65, operational temperature is CO2, NH3 Research – 2.5+ years, Refrigerants CH2FCF3; HFC-134°; 1,1,1,2- Refrigeration capability that can cool very close to the triple point. C3H8, and Demonstration – 2 years, within process tetrafluoroethane, the HTF by heat exchange to lower Therefore, a fluctuation of Feasibility Integration – 2 years, equipment C3H3F5; HFC 245fa; than -50oC with a cooling capacity of pressure control can result in studies of N2 HVM – 2-5 years. chillers Pentafluoropropane, at least 7kW. vapor-solid phase transition chillers required. Total: from 8 to more than R407C (refrigeration failure). 14 years. NH3 is flammable and toxic, which requires containment Status of PFAS use area Typical PFAS Used Role of PFAS Timeline to develop Concer).*& #(,%+)#,'-% alternatives its proximity to meet specialised safety standards such as Class 1 division 2 under NFPA 70. Suitable viscosity (up to -40oC), low Possible design change of dielectric constants that support tester head assembly, chiller direct cooling of energised Invention/Fundamental and other critical parts of the equipment by immersion, high Perfluoroamine, 62 Research – 2-5+ years, process equipment may be Testing volume resistance and its long-term Perfluorotributylamine, 63 Invention is Demonstration – 2 years, required. For example, a high applications of stability, thermally stable for the PFPE based testing fluids needed for Integration – 2 years, flammability alternative would semiconductor entire operational temperature range designed for specific test alternative. HVM – 2-5 years. require any equipment used in devices (-40oC to +120oC), low toxicity, non- conditions 64 Total: from 8 to more than its proximity to meet flammability, chemical inertness, low 14 years. specialised safety standards vapour pressure, no affinity for such as Class 1 division 2 hydrocarbon-based compounds, under NFPA 70. metal, and plastic compatibility. CO2 refrigerant chiller doesn’t C2HF5; HFC-125; satisfy cooling capacity, as Invention/Fundamental Pentafluoroethane 65, operational temperature is CO2, NH3 Research – 2.5+ years, Refrigerants CH2FCF3; HFC-134°; 1,1,1,2- Refrigeration capability that can cool very close to the triple point. C3H8, and Demonstration – 2 years, within process tetrafluoroethane, the HTF by heat exchange to lower Therefore, a fluctuation of Feasibility Integration – 2 years, equipment C3H3F5; HFC 245fa; than -50oC with a cooling capacity of pressure control can result in studies of N2 HVM – 2-5 years. chillers Pentafluoropropane, at least 7kW. vapor-solid phase transition chillers required. Total: from 8 to more than R407C (refrigeration failure). 14 years. NH3 is flammable and toxic, which requires containment ______ 62 Such as 3M™ Fluorinert™ Electronic Liquid FC-3283. 63 Such as 3M™ Fluorinert™ Electronic Liquid FC-43. 64 Including , Galden® D02-TS, D02, D03, D05, 3M™ Novec™ 7500/7100 Engineered Fluid and Solvay Galden® PFPE HT-135. 65 Such as Chemours FE-25™, Fike Ecaro-25®. © RINA Tech UK Ltd 271 Report No. 2022-0737 Rev. 0 Page 63 The Impact of a Potential PFAS Restriction on the Semiconductor Sector ______ 62 Such as 3M™ Fluorinert™ Electronic Liquid FC-3283. 63 Such as 3M™ Fluorinert™ Electronic Liquid FC-43. 64 Including , Galden® D02-TS, D02, D03, D05, 3M™ Novec™ 7500/7100 Engineered Fluid and Solvay Galden® PFPE HT-135. 65 Such as Chemours FE-25™, Fike Ecaro-25®. © RINA Tech UK Ltd 271 Report No. 2022-0737 Rev. 0 Page 63 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Status of PFAS use area Typical PFAS Used Role of PFAS Timeline to develop Concer).*& #(,%+)#,'-% alternatives and exhaust abatement, so cannot be located near the production facility. It also is less efficient at temperatures below -30oC. C3H8 is flammable and inefficient at very low temperatures and again cannot be used near the production facility. Status of PFAS use area Typical PFAS Used Role of PFAS Timeline to develop Concer).*& #(,%+)#,'-% alternatives and exhaust abatement, so cannot be located near the production facility. It also is less efficient at temperatures below -30oC. C3H8 is flammable and inefficient at very low temperatures and again cannot be used near the production facility. © RINA Tech UK Ltd 272 Report No. 2022-0737 Rev. 0 Page 64 The Impact of a Potential PFAS Restriction on the Semiconductor Sector © RINA Tech UK Ltd 272 Report No. 2022-0737 Rev. 0 Page 64 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 7.1 Alternatives To date, no non-PFAS alternatives have been identified which can be used in dry etch and semiconductor test applications, due to the required performance characteristics of electrical non- conductivity, compatibility with all materials of construction (including sensitive electrical components), non-flammability, all within the operational range that is required for the manufacture and test of semiconductor products. 7.1 Alternatives To date, no non-PFAS alternatives have been identified which can be used in dry etch and semiconductor test applications, due to the required performance characteristics of electrical non- conductivity, compatibility with all materials of construction (including sensitive electrical components), non-flammability, all within the operational range that is required for the manufacture and test of semiconductor products. 7.1.1 Alternatives to Liquid HTF The most promising available non-fluorinated HTFs that have been considered for use in semiconductor manufacturing operations include synthetic hydrocarbon oils, silicone based HTFs and glycol ether and deionised water (EG/DI) combinations. Synthetic Hydrocarbon Oils Synthetic hydrocarbon oils have kinematic viscosity values that are much higher than the F-HTFs that are currently in use. This leads to an inability to maintain tight temperature tolerances at the upper operational temperature limit currently required. Residues of these HTFs can cause contamination of the fab environment, leading to a decreased process yield. Flashpoints are also much lower and have the potential to drive significant changes to equipment chiller designs owing to safety requirements. 7.1.1 Alternatives to Liquid HTF The most promising available non-fluorinated HTFs that have been considered for use in semiconductor manufacturing operations include synthetic hydrocarbon oils, silicone based HTFs and glycol ether and deionised water (EG/DI) combinations. Synthetic Hydrocarbon Oils Synthetic hydrocarbon oils have kinematic viscosity values that are much higher than the F-HTFs that are currently in use. This leads to an inability to maintain tight temperature tolerances at the upper operational temperature limit currently required. Residues of these HTFs can cause contamination of the fab environment, leading to a decreased process yield. Flashpoints are also much lower and have the potential to drive significant changes to equipment chiller designs owing to safety requirements. Silicone-based HTFs Silicone-based heat transfer fluids are inert and have many unique properties like extreme stability against thermal oxidation, low freezing points, wide operating temperatures, good dielectric strength, favourable environmental properties, and low toxicity. Whilst silicone-based fluids have many advantageous properties for use as an alternative HTF, they are non-viable for use in semiconductor manufacturing processes such as dry etch. This is due to their ability to cause catastrophic contamination issues when they vaporise or to result in residual deposits on surfaces which in turn contaminate the very sensitive processes associated with the semiconductor manufacture. 66 This issue has already been reported in other industries, which have needed to scrap parts that have become contaminated with silicone oil residues. 67 These accidental transfers, in the order of a few drops of fluid, are most likely to occur during the performance of certain maintenance activities like the changeout of replaceable parts connected to the chiller loop. If silicone oils were used to replace the current F-HTFs in dry etch applications, these accidental transfers could result in the need for extensive cleaning and significant downtime in order to complete chamber rebuilds and replace contaminated parts. Silicone-based HTFs Silicone-based heat transfer fluids are inert and have many unique properties like extreme stability against thermal oxidation, low freezing points, wide operating temperatures, good dielectric strength, favourable environmental properties, and low toxicity. Whilst silicone-based fluids have many advantageous properties for use as an alternative HTF, they are non-viable for use in semiconductor manufacturing processes such as dry etch. This is due to their ability to cause catastrophic contamination issues when they vaporise or to result in residual deposits on surfaces which in turn contaminate the very sensitive processes associated with the semiconductor manufacture. 66 This issue has already been reported in other industries, which have needed to scrap parts that have become contaminated with silicone oil residues. 67 These accidental transfers, in the order of a few drops of fluid, are most likely to occur during the performance of certain maintenance activities like the changeout of replaceable parts connected to the chiller loop. If silicone oils were used to replace the current F-HTFs in dry etch applications, these accidental transfers could result in the need for extensive cleaning and significant downtime in order to complete chamber rebuilds and replace contaminated parts. Ethylene Glycol and Deionised Water (EG/DI) Combinations Mixtures of EG/DI are commonly used as HTFs within semiconductor applications. However, where F- HTFs are currently in use, they have been selected because EG/DI is not able to meet boiling point and pour point requirements to support the operational temperature ranges. In addition, EG/DI mixtures have been observed to exhibit a reduction in resistivity during use; this makes the control of the etch and deposition processes increasingly difficult. This can lead to a catastrophic interaction with the plasma or an electrical short circuit due to contact with the wafer chuck. Residues of EG/DI HTFs within the process chamber can cause contamination of the fab environment, leading to decreases in die yield. Use of these HTFs also requires special design considerations to avoid aggressive corrosion of the sensitive semiconductor manufacturing equipment. ______ 66 https://www.rdworldonline.com/please-help-us-determine-the-source-of-the-silicone-contamination/ 67 The Removal of Silicone Contaminants from Spacecraft Hardware, 2002, https://apps.dtic.mil/sti/pdfs/ADA410311.pdf © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 65 Ethylene Glycol and Deionised Water (EG/DI) Combinations Mixtures of EG/DI are commonly used as HTFs within semiconductor applications. However, where F- HTFs are currently in use, they have been selected because EG/DI is not able to meet boiling point and pour point requirements to support the operational temperature ranges. In addition, EG/DI mixtures have been observed to exhibit a reduction in resistivity during use; this makes the control of the etch and deposition processes increasingly difficult. This can lead to a catastrophic interaction with the plasma or an electrical short circuit due to contact with the wafer chuck. Residues of EG/DI HTFs within the process chamber can cause contamination of the fab environment, leading to decreases in die yield. Use of these HTFs also requires special design considerations to avoid aggressive corrosion of the sensitive semiconductor manufacturing equipment. ______ 66 https://www.rdworldonline.com/please-help-us-determine-the-source-of-the-silicone-contamination/ 67 The Removal of Silicone Contaminants from Spacecraft Hardware, 2002, https://apps.dtic.mil/sti/pdfs/ADA410311.pdf © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 65 273 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Additional information on alternatives to liquid HTF can be found in the ‘PFAS-Containing Heat Transfer Fluids (HTF) used in Semiconductor Manufacturing Whitepaper’ outlined in Table 1-2. 273 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Additional information on alternatives to liquid HTF can be found in the ‘PFAS-Containing Heat Transfer Fluids (HTF) used in Semiconductor Manufacturing Whitepaper’ outlined in Table 1-2. 7.1.2 Alternatives to Refrigerants Process equipment chillers currently make use of fluorinated refrigerants within their compressor systems to act as a heat sink and as heat-transfer agents between the manufacturing process and the facility chiller system. Currently available non-fluorinated refrigerants include carbon dioxide and ammonia which have the following concerns: • Limited operational ranges that do not meet the required operational temperature for dry etch and semiconductor test applications (–60oC). • Less energy efficient compared to PFAS refrigerants, and in order to provide a similar level of cooling, more chilling capacity would need to be installed, requiring significantly more space and higher energy consumption. • Ammonia based refrigerant chillers are required by ANSI/ASHRAE Standard 34 safety classification rating of B2L to be installed in a separate building with ammonia monitoring and other controls, such as a pressure relief valve and associated abatement. Additional information on alternatives to liquid HTF can be found in the ‘PFAS-Containing Heat Transfer Fluids (HTF) used in Semiconductor Manufacturing Whitepaper’ outlined in Table 1-2. 7.1.2 Alternatives to Refrigerants Process equipment chillers currently make use of fluorinated refrigerants within their compressor systems to act as a heat sink and as heat-transfer agents between the manufacturing process and the facility chiller system. Currently available non-fluorinated refrigerants include carbon dioxide and ammonia which have the following concerns: • Limited operational ranges that do not meet the required operational temperature for dry etch and semiconductor test applications (–60oC). • Less energy efficient compared to PFAS refrigerants, and in order to provide a similar level of cooling, more chilling capacity would need to be installed, requiring significantly more space and higher energy consumption. • Ammonia based refrigerant chillers are required by ANSI/ASHRAE Standard 34 safety classification rating of B2L to be installed in a separate building with ammonia monitoring and other controls, such as a pressure relief valve and associated abatement. Additional information on alternatives to liquid HTF can be found in the ‘PFAS-Containing Heat Transfer Fluids (HTF) used in Semiconductor Manufacturing Whitepaper’ outlined in Table 1-2. 7.2 Environmental Considerations for use of F-HTFs F-HTF is bought by the semiconductor manufacturer when they install and commission the equipment and requires periodic replenishment. As designed, the F-HTFs used within the chiller and test equipment are contained with intent to minimise release during use and are accessed and maintained only by trained and/or certified technicians. Prior to the initiation of maintenance activities, the HTF contents of the chiller and associated equipment is drained into collection containers that are managed either for direct reuse, or for reclaim. If any HTF fluid is required to be managed as a waste, the fluid is incinerated at appropriately certified waste management facilities. 7.2 Environmental Considerations for use of F-HTFs F-HTF is bought by the semiconductor manufacturer when they install and commission the equipment and requires periodic replenishment. As designed, the F-HTFs used within the chiller and test equipment are contained with intent to minimise release during use and are accessed and maintained only by trained and/or certified technicians. Prior to the initiation of maintenance activities, the HTF contents of the chiller and associated equipment is drained into collection containers that are managed either for direct reuse, or for reclaim. If any HTF fluid is required to be managed as a waste, the fluid is incinerated at appropriately certified waste management facilities. Small amounts of emissions are expected from HTF loops during normal operation of the chillers and heat exchangers, with the exact amount dependent on the process operating temperature. Emissions are also possible during maintenance tasks such as changeout of parts that require replacement, from filling and draining, as well as from any leaks that may occur upon failure of the couplings, seals or gaskets used within the loop systems. Due to the relatively high vapour pressure of the HTFs that are used in semiconductor manufacturing and testing applications, the HTF that escapes containment is released to the air. Overall, the industrial emissions of F-HTF are actively minimised to reduce greenhouse gas emissions and reduce manufacturing costs. Data from the US EPA on emissions across the electronics manufacturing industry from 2014-2021 shows that more than 70% of reporting facilities claimed less than 1 tonne per year of emissions, which is equivalent to less than 2 kilograms of F-HTF per year per piece of equipment (assuming 500 individual closed-loop systems per facility). © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 66 274 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Small amounts of emissions are expected from HTF loops during normal operation of the chillers and heat exchangers, with the exact amount dependent on the process operating temperature. Emissions are also possible during maintenance tasks such as changeout of parts that require replacement, from filling and draining, as well as from any leaks that may occur upon failure of the couplings, seals or gaskets used within the loop systems. Due to the relatively high vapour pressure of the HTFs that are used in semiconductor manufacturing and testing applications, the HTF that escapes containment is released to the air. Overall, the industrial emissions of F-HTF are actively minimised to reduce greenhouse gas emissions and reduce manufacturing costs. Data from the US EPA on emissions across the electronics manufacturing industry from 2014-2021 shows that more than 70% of reporting facilities claimed less than 1 tonne per year of emissions, which is equivalent to less than 2 kilograms of F-HTF per year per piece of equipment (assuming 500 individual closed-loop systems per facility). © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 66 274 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 8 ASSEMBLY, TEST, PACKAGING AND SUBSTRATE MATERIALS USES Summary: As packaging becomes more and more complex due to decreasing semiconductor device size, increased processing speed, and/or increased packaging complexity, the combination of material properties required to meeting these challenges are often only found in the fluorinated hydrocarbon family. Changes to assembly packaging materials range in their complexity, but unlike other uses due to their interface with both the silicon die and the end customer product, additional customer product change notification/ requalification processes need to be followed (minimum average product requalification is 1-2 years, with some applications such as aerospace, military, or automotive requiring 6+ years). The following timelines are estimated to find or implement PFAS free alternatives: • Packaging fluxes more than 5 years, to find and implement alternatives. • Surfactants from 10 to more than 18 years, to find and implement alternatives, with many suppliers being single source which may cause suppliers to exit the market. • For a few older die attach adhesive applications alternatives can be expected in the very near future (1+ year). However, for most adhesives and encapsulants it is expected to take from 10 to more than 13 years to find and implement alternatives. 8 ASSEMBLY, TEST, PACKAGING AND SUBSTRATE MATERIALS USES Summary: As packaging becomes more and more complex due to decreasing semiconductor device size, increased processing speed, and/or increased packaging complexity, the combination of material properties required to meeting these challenges are often only found in the fluorinated hydrocarbon family. Changes to assembly packaging materials range in their complexity, but unlike other uses due to their interface with both the silicon die and the end customer product, additional customer product change notification/ requalification processes need to be followed (minimum average product requalification is 1-2 years, with some applications such as aerospace, military, or automotive requiring 6+ years). The following timelines are estimated to find or implement PFAS free alternatives: • Packaging fluxes more than 5 years, to find and implement alternatives. • Surfactants from 10 to more than 18 years, to find and implement alternatives, with many suppliers being single source which may cause suppliers to exit the market. • For a few older die attach adhesive applications alternatives can be expected in the very near future (1+ year). However, for most adhesives and encapsulants it is expected to take from 10 to more than 13 years to find and implement alternatives. • However, for the vast majority of package related uses of adhesives, in MEMS and Thermal Interface Materials System (TIMS), die overcoats, encapsulants and underfills, die passivation and substrate polymer there are no viable alternatives to the PFAS being used. For some of these technologies, alternatives have been sought for 18 years without success. For these uses it is likely that alternatives will take more than 20 years to find viable alternative chemistries or technologies and 6 years to implement. There should be no release of PFAS during normal use of consumer or other end products, for those that include PFAS containing semiconductors. The concentrations of PFAS in assembly, testing, and packaging (ATPS) chemistries are low (parts per billion range) and any releases are anticipated to be minimal and only at the end of the product’s useful life, during electronics recycling or disposal. Some of the electronic reclamation processes are thermal and may cause a break-down of PFAS, but this would require further investigation. • However, for the vast majority of package related uses of adhesives, in MEMS and Thermal Interface Materials System (TIMS), die overcoats, encapsulants and underfills, die passivation and substrate polymer there are no viable alternatives to the PFAS being used. For some of these technologies, alternatives have been sought for 18 years without success. For these uses it is likely that alternatives will take more than 20 years to find viable alternative chemistries or technologies and 6 years to implement. There should be no release of PFAS during normal use of consumer or other end products, for those that include PFAS containing semiconductors. The concentrations of PFAS in assembly, testing, and packaging (ATPS) chemistries are low (parts per billion range) and any releases are anticipated to be minimal and only at the end of the product’s useful life, during electronics recycling or disposal. Some of the electronic reclamation processes are thermal and may cause a break-down of PFAS, but this would require further investigation. A semiconductor package encloses one or more semiconductor devices or integrated circuits protecting the device from the environment. The package connects the semiconductor to the printed circuit board (PCB), dissipates heat and provides protection from the surrounding environment particularly from moisture, shock/vibration, dust, etc. Semiconductor packaging is the process of assembling integrated circuits into final products, individual integrated circuit components are fabricated from semiconductor wafers, and these are then diced into integrated circuit die and tested. Assembled packages go through multiple package types, to form three dimensional integrated circuits. Older technologies still use subsequent thermal and chemical steps to produce, therefore thermal and chemical stability in the assembled package are important. Semiconductor packaging technology evolves quickly and there are lots of different technology levels on the market at any one time, including dual in-line packaged assembly like wire bond ball-grid assembly and flip-chip technologies as illustrated schematically in Figure 8-1 and Figure 8-2. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 67 275 A semiconductor package encloses one or more semiconductor devices or integrated circuits protecting the device from the environment. The package connects the semiconductor to the printed circuit board (PCB), dissipates heat and provides protection from the surrounding environment particularly from moisture, shock/vibration, dust, etc. Semiconductor packaging is the process of assembling integrated circuits into final products, individual integrated circuit components are fabricated from semiconductor wafers, and these are then diced into integrated circuit die and tested. Assembled packages go through multiple package types, to form three dimensional integrated circuits. Older technologies still use subsequent thermal and chemical steps to produce, therefore thermal and chemical stability in the assembled package are important. Semiconductor packaging technology evolves quickly and there are lots of different technology levels on the market at any one time, including dual in-line packaged assembly like wire bond ball-grid assembly and flip-chip technologies as illustrated schematically in Figure 8-1 and Figure 8-2. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 67 275 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 8-1 An example package, with many other configurations possible. Figure 8-2 An example MEMS package. Packaging has developed over time, as outlined in Figure 8-3 and Figure 8-4, with all of these packaging types still supported by current manufacturing practices. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 68 276 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 8-3 Timeline for the semiconductor packaging showing the complexity of packaging increasing over time. © RINA Tech UK Ltd 277 Report No. 2022-0737 Rev. 0 Page 69 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 8-4 Status of the Advanced Packaging Industry including multiple types of packaging and materials. The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 8-1 An example package, with many other configurations possible. Figure 8-2 An example MEMS package. Packaging has developed over time, as outlined in Figure 8-3 and Figure 8-4, with all of these packaging types still supported by current manufacturing practices. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 68 276 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 8-3 Timeline for the semiconductor packaging showing the complexity of packaging increasing over time. © RINA Tech UK Ltd 277 Report No. 2022-0737 Rev. 0 Page 69 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Figure 8-4 Status of the Advanced Packaging Industry including multiple types of packaging and materials. © RINA Tech UK Ltd 278 Report No. 2022-0737 Rev. 0 Page 70 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Assembly, Test, Packaging, and Substrate use PFAS in many applications, across multiple process steps, including: • Substrate polymers, including core, build-up, or dielectric materials. These enable high speed signalling between components of a module or an assembly. This is turn enables specific functions within a larger completed package to be met, like on-chip memory, accelerators, controllers, and chip-to-chip interconnections. PFAS provide low dielectric constants, high thermostability, chemical inertness (to acids, bases, and solvents), and low moisture absorption, low electric permittivity / dielectric loss, low water absorption, and low coefficient of thermal expansion (CTE) 68. These materials are required to be photo-imageable to meet the required high-resolution requirements for chip-to-chip interconnects, PFAS properties typically found in photolithographic chemistries are used and further discussed in Section 4. © RINA Tech UK Ltd 278 Report No. 2022-0737 Rev. 0 Page 70 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Assembly, Test, Packaging, and Substrate use PFAS in many applications, across multiple process steps, including: • Substrate polymers, including core, build-up, or dielectric materials. These enable high speed signalling between components of a module or an assembly. This is turn enables specific functions within a larger completed package to be met, like on-chip memory, accelerators, controllers, and chip-to-chip interconnections. PFAS provide low dielectric constants, high thermostability, chemical inertness (to acids, bases, and solvents), and low moisture absorption, low electric permittivity / dielectric loss, low water absorption, and low coefficient of thermal expansion (CTE) 68. These materials are required to be photo-imageable to meet the required high-resolution requirements for chip-to-chip interconnects, PFAS properties typically found in photolithographic chemistries are used and further discussed in Section 4. Core dielectrics currently use fully-imidized polyimide and polybenzoxazoles which have to have a pendant PFAS group on the polyimide backbone to be soluble in organic coating solvents. Without the presence of PFAS groups on the polyimide backbone, advances in semiconductor packaging technology will be delayed by decades or never materialise. • Assembly materials – coatings - Die overcoat / adhesive to provide hermetic sealing for moisture sensitive applications and chemical resistance. - Die attach adhesives to attach silicon die to packaging substrates or leadframes, while helping to mitigate stress on the die and encapsulant. PFTE/PFAS in the epoxy anti- bleed out agent in die attach glue is important to control the amount of epoxy (adhesive) bleed beyond the peripherals of the die mounted to the frame/substrate. • Encapsulants (hermetic or molding) to provide environmental and mechanical isolation via the following properties: heat conductivity due to a low CTE across a wide temperature range without a glass transition temperature. Electrically insulated, and hydrophobic to avoid void related failures. 69 Core dielectrics currently use fully-imidized polyimide and polybenzoxazoles which have to have a pendant PFAS group on the polyimide backbone to be soluble in organic coating solvents. Without the presence of PFAS groups on the polyimide backbone, advances in semiconductor packaging technology will be delayed by decades or never materialise. • Assembly materials – coatings - Die overcoat / adhesive to provide hermetic sealing for moisture sensitive applications and chemical resistance. - Die attach adhesives to attach silicon die to packaging substrates or leadframes, while helping to mitigate stress on the die and encapsulant. PFTE/PFAS in the epoxy anti- bleed out agent in die attach glue is important to control the amount of epoxy (adhesive) bleed beyond the peripherals of the die mounted to the frame/substrate. • Encapsulants (hermetic or molding) to provide environmental and mechanical isolation via the following properties: heat conductivity due to a low CTE across a wide temperature range without a glass transition temperature. Electrically insulated, and hydrophobic to avoid void related failures. 69 • Underfills to reduce stress on solder joints and increase the durability and longevity of the assembled package compared to an assembled package without underfill. Underfills must have high mechanical strength, low CTE and generally contain ~50% silica materials with the remainder being polymeric materials such as vinylidene fluoride-propylene hexafluoride copolymer and tetrafluoroethylene-propylene copolymer. The polymer must have high viscosity to ensure homogeneity and low volatility to minimise void formation. Surfactants utilising PFAS are also used to ensure compatibility of the additive with the resin system as well as helping to control resin bleed out. • Surfactants used in defoaming or foam promotion, thin films and spin coating applications require surfactants to adjust the surface energy of the solution the surfactant is added to. They are also used in temporary bonding / mechanical debonding processes. Surfactants can play many rolls within a formulation, such as lowering surface tension, behave as wetting agents, foaming agents, • Underfills to reduce stress on solder joints and increase the durability and longevity of the assembled package compared to an assembled package without underfill. Underfills must have high mechanical strength, low CTE and generally contain ~50% silica materials with the remainder being polymeric materials such as vinylidene fluoride-propylene hexafluoride copolymer and tetrafluoroethylene-propylene copolymer. The polymer must have high viscosity to ensure homogeneity and low volatility to minimise void formation. Surfactants utilising PFAS are also used to ensure compatibility of the additive with the resin system as well as helping to control resin bleed out. • Surfactants used in defoaming or foam promotion, thin films and spin coating applications require surfactants to adjust the surface energy of the solution the surfactant is added to. They are also used in temporary bonding / mechanical debonding processes. Surfactants can play many rolls within a formulation, such as lowering surface tension, behave as wetting agents, foaming agents, ______ 68 These properties are referred to in patents from the University of Electronic Science and Technology of China (CN107474312B), Jiangxi Tieno Technology Co Ltd (CN106604536B, Intel (US 11, 348,897 B2), and Taiwan Semiconductor Manufacturing Company Ltd (TSMC) (US 10,261,248 B2). 69 A common failure mechanism for encapsulants is void creation caused when water absorbed by the encapsulant expands during heating caused by operation of the semiconductor, as demonstrated by: Thompson, Dane & Tentzeris, Manos & Papapolymerou, John. (2007). Experimental Analysis of the Water Absorption Effects on RF/mm-Wave Active/Passive Circuits Packaged in Multilayer Organic Substrates. Advanced Packaging, IEEE Transactions on. 30. 551 - 557. 10.1109/TADVP.2007.898637. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 71 279 The Impact of a Potential PFAS Restriction on the Semiconductor Sector ______ 68 These properties are referred to in patents from the University of Electronic Science and Technology of China (CN107474312B), Jiangxi Tieno Technology Co Ltd (CN106604536B, Intel (US 11, 348,897 B2), and Taiwan Semiconductor Manufacturing Company Ltd (TSMC) (US 10,261,248 B2). 69 A common failure mechanism for encapsulants is void creation caused when water absorbed by the encapsulant expands during heating caused by operation of the semiconductor, as demonstrated by: Thompson, Dane & Tentzeris, Manos & Papapolymerou, John. (2007). Experimental Analysis of the Water Absorption Effects on RF/mm-Wave Active/Passive Circuits Packaged in Multilayer Organic Substrates. Advanced Packaging, IEEE Transactions on. 30. 551 - 557. 10.1109/TADVP.2007.898637. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 71 279 The Impact of a Potential PFAS Restriction on the Semiconductor Sector defoaming agents, or dispersants. Surfactants can be used to improve the coat quality of solution processed films. Surfactants can also be added to cleaning solutions including resist strippers and temporary adhesive cleans to improve the cleaning efficiency. • Temporary bonding / mechanical debonding: an adhesive/release layer pair or single layer material (with appropriate bond strength) providing support to the wafer which is mechanically de- bonded after processing. The release layers for mechanical release typically have very low surface tension. Fluorinated polymers are one class of polymers which fit this description. After debonding the surfaces are cleaned, the cleaner may include a surfactant in its formulation. • Laser release layers: either as a film or mold release sprays use PFAS such as PTFE or ETFE. These provide UV light sensitivity, thermal stability, aid in photoacid generation efficiency and the removal of the adhesive from the wafer or other piece cleanly. • Thermal interface material (TIM) act as a heat conduit between the package (silicon die) and a heat spreader. Good coverage, consistency, and longevity of the material are necessary to withstand high temperatures and multiple thermal cycles. • Packaging of microelectromechanical systems (MEMs) for surface energy modification of MEMS for anti-stiction purposes. • Packaging adhesives (either thermal or UV curable) to improve adhesion between dielectrics and low roughness copper without having to resort to roughening surfaces which introduces low insertion loss. Types of adhesive include paste, film, or wafer. • Packaging fluxes to assist with connecting the die to substrate, with different types of flux used depending on the joining technology in use. With PFAS used as a surfactant in ultra-low residue flux 70 and thermocompression bonding flip chip copper pillar joining, using a specialist copper pillar flip chip flux, but not ball—attach processes or pin attach processes where alternatives to PFAS are routinely used. PFAS-containing surfactants provide heat resistant, void solder resistance 71 and have wetting properties that control spread ensuring package reliability and yield. • Memory component packaging may use PFAS processing steps listed in the manufacture of some products. Additionally, PFAS may be present in manufacturing equipment. • Die passivation as part of the back end of line bumping process 72 in that the photo imageable dielectric is used both to help pattern the bumps and remain on the die to protect the interlayer dielectric (underlying electronics within a die). As technology is moving to faster signal processing the use of PFAS components is expected to grow, as no other manufacturable material currently exists with the same electrical properties for dielectric constant and insertion loss. defoaming agents, or dispersants. Surfactants can be used to improve the coat quality of solution processed films. Surfactants can also be added to cleaning solutions including resist strippers and temporary adhesive cleans to improve the cleaning efficiency. • Temporary bonding / mechanical debonding: an adhesive/release layer pair or single layer material (with appropriate bond strength) providing support to the wafer which is mechanically de- bonded after processing. The release layers for mechanical release typically have very low surface tension. Fluorinated polymers are one class of polymers which fit this description. After debonding the surfaces are cleaned, the cleaner may include a surfactant in its formulation. • Laser release layers: either as a film or mold release sprays use PFAS such as PTFE or ETFE. These provide UV light sensitivity, thermal stability, aid in photoacid generation efficiency and the removal of the adhesive from the wafer or other piece cleanly. • Thermal interface material (TIM) act as a heat conduit between the package (silicon die) and a heat spreader. Good coverage, consistency, and longevity of the material are necessary to withstand high temperatures and multiple thermal cycles. • Packaging of microelectromechanical systems (MEMs) for surface energy modification of MEMS for anti-stiction purposes. • Packaging adhesives (either thermal or UV curable) to improve adhesion between dielectrics and low roughness copper without having to resort to roughening surfaces which introduces low insertion loss. Types of adhesive include paste, film, or wafer. • Packaging fluxes to assist with connecting the die to substrate, with different types of flux used depending on the joining technology in use. With PFAS used as a surfactant in ultra-low residue flux 70 and thermocompression bonding flip chip copper pillar joining, using a specialist copper pillar flip chip flux, but not ball—attach processes or pin attach processes where alternatives to PFAS are routinely used. PFAS-containing surfactants provide heat resistant, void solder resistance 71 and have wetting properties that control spread ensuring package reliability and yield. • Memory component packaging may use PFAS processing steps listed in the manufacture of some products. Additionally, PFAS may be present in manufacturing equipment. • Die passivation as part of the back end of line bumping process 72 in that the photo imageable dielectric is used both to help pattern the bumps and remain on the die to protect the interlayer dielectric (underlying electronics within a die). As technology is moving to faster signal processing the use of PFAS components is expected to grow, as no other manufacturable material currently exists with the same electrical properties for dielectric constant and insertion loss. Specifically, as the signalling frequency increases the conductor length becomes even more critical; higher losses require lower insertion loss materials. This is mainly because PCB conductor lengths are long and signal loss increases with longer travel distances. Fluorinated components offer best in class electrical properties for dielectric constant and insertion loss. It may also be the case that in certain packaging applications, where high speed signalling is needed on the core or on package architectures such as package on package or interposers where the material used is a glass reinforced epoxy matrix, PFAS containing components may be needed to mitigate the risk of signal loss. ______ 70 As discussed by various patents including KR100985004B1 and IBM’s DE2137329A1. 71 As discussed in Arakawa Chemical Industries Ltd Patent CN101090797B. 72 Solder bumps deposited on chips pads situated on the top side of a silicon wafer during the final wafer processing step. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 72 280 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Specifically, as the signalling frequency increases the conductor length becomes even more critical; higher losses require lower insertion loss materials. This is mainly because PCB conductor lengths are long and signal loss increases with longer travel distances. Fluorinated components offer best in class electrical properties for dielectric constant and insertion loss. It may also be the case that in certain packaging applications, where high speed signalling is needed on the core or on package architectures such as package on package or interposers where the material used is a glass reinforced epoxy matrix, PFAS containing components may be needed to mitigate the risk of signal loss. ______ 70 As discussed by various patents including KR100985004B1 and IBM’s DE2137329A1. 71 As discussed in Arakawa Chemical Industries Ltd Patent CN101090797B. 72 Solder bumps deposited on chips pads situated on the top side of a silicon wafer during the final wafer processing step. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 72 280 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 8.1 Impact of change Packaging materials have interactions with both the silicon die and the end customer product, so if substances are changed the following additional steps would be required: 1. Alternative process will require notification of change for each product for each customer. As the assembly process is the interaction between the fab and the end product, it is possible that there could be dies and passivation materials from multiple fabs or multiple motherboards and second level interconnect materials. This creates extensive complexity as a change in one assembly material could require testing across multiple silicon die vendors or multiple second level interconnect vendors/customers. Typical notifications require at least one year prior to any change, due to the contractual requirements and the necessity of the end customer to determine impacts within their processes and/or products, but certain market segments such as aerospace, military, and automotive could require longer change notification or more extensive testing. 2. In some applications, PFAS substances allow for reduced consumption of material (as in coating on a silicon wafer or other substrates). However, if increased volumes of material are needed this will increase cost/wafer and possibly increase waste. 3. In some applications, PFAS substances improve film coating uniformity when coated on a silicon wafer (or other substrates). If the alternative is not able to achieve the same level of uniformity, the process tolerance might suffer. Increased sample volumes may be required during testing or new processes may need to be developed. Ultimately this could lead to loss of yield and scrap. 4. New analytical methods may need to be developed to analyse the presence of alternatives. This will add cost and time to product development. It is also possible that new tooling or methodology developments, will also need to be added. Table 8-1 indicates the status of alternatives for identified packaging uses and estimated timelines for the development of the alternatives. 8.1 Impact of change Packaging materials have interactions with both the silicon die and the end customer product, so if substances are changed the following additional steps would be required: 1. Alternative process will require notification of change for each product for each customer. As the assembly process is the interaction between the fab and the end product, it is possible that there could be dies and passivation materials from multiple fabs or multiple motherboards and second level interconnect materials. This creates extensive complexity as a change in one assembly material could require testing across multiple silicon die vendors or multiple second level interconnect vendors/customers. Typical notifications require at least one year prior to any change, due to the contractual requirements and the necessity of the end customer to determine impacts within their processes and/or products, but certain market segments such as aerospace, military, and automotive could require longer change notification or more extensive testing. 2. In some applications, PFAS substances allow for reduced consumption of material (as in coating on a silicon wafer or other substrates). However, if increased volumes of material are needed this will increase cost/wafer and possibly increase waste. 3. In some applications, PFAS substances improve film coating uniformity when coated on a silicon wafer (or other substrates). If the alternative is not able to achieve the same level of uniformity, the process tolerance might suffer. Increased sample volumes may be required during testing or new processes may need to be developed. Ultimately this could lead to loss of yield and scrap. 4. New analytical methods may need to be developed to analyse the presence of alternatives. This will add cost and time to product development. It is also possible that new tooling or methodology developments, will also need to be added. Table 8-1 indicates the status of alternatives for identified packaging uses and estimated timelines for the development of the alternatives. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 73 281 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Table 8-1 Examples of the packaging products utilising PFAS. Substance Function Quantity Status of alternative Concern of alternative Timeline to develop © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 73 281 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Table 8-1 Examples of the packaging products utilising PFAS. Substance Function Quantity Status of alternative Concern of alternative Timeline to develop Replacement known & viable for some Main polymer Lower dielectric characteristics, low Coefficient formulations but not all. 10+ years depending substrate and of thermal expansion, low electric permittivity / PTFE (including versions FEP, Alternatives are not available in cases dielectric loss, and low water absorption. on chosen build up >0.1% PFA, AF, and PTFE 30 where one or more of the functional quality replacement dielectric Quality, reliability, form, fit, function in some characteristics is not met such as adhesion, technology material material changes. Hazards from alternatives. dielectric constant, ability to process. Replacement known & viable for some Main polymer Lower dielectric characteristics, low Coefficient formulations but not all. 10+ years depending substrate and of thermal expansion, low electric permittivity / PTFE (including versions FEP, Alternatives are not available in cases dielectric loss, and low water absorption. on chosen build up >0.1% PFA, AF, and PTFE 30 where one or more of the functional quality replacement dielectric Quality, reliability, form, fit, function in some characteristics is not met such as adhesion, technology material material changes. Hazards from alternatives. dielectric constant, ability to process. Tear resistance, high tensile strength + incorporation of highly thermally conductive fillers such as carbon nano tubes, metals, Fluorinated-ethylene propylene TIMs <0.1% No viable alternatives have been identified. 10+ years ceramics into different resin systems may require unique compatibility that only fluorinated-ethylene propylene has. Tear resistance, high tensile strength + incorporation of highly thermally conductive fillers such as carbon nano tubes, metals, Fluorinated-ethylene propylene TIMs <0.1% No viable alternatives have been identified. 10+ years ceramics into different resin systems may require unique compatibility that only fluorinated-ethylene propylene has. Replacement marketed by flux manufactures in 2020 which needs to be Quality, reliability, thermal stability, wetting. evaluated by manufacturers. Perfluoroalkyl Alcohols, Fluorine Some flux alternatives are halogenated and so Additive fluxes <0.1% After two years of research one candidate 4-5+ years Resins have other hazards which could prove to be flux is now being tested by a chip packaging regrettable substitutions. company, to see if it will perform adequately and has a sufficiently low failure rate. Replacement marketed by flux manufactures in 2020 which needs to be Quality, reliability, thermal stability, wetting. evaluated by manufacturers. Perfluoroalkyl Alcohols, Fluorine Some flux alternatives are halogenated and so Additive fluxes <0.1% After two years of research one candidate 4-5+ years Resins have other hazards which could prove to be flux is now being tested by a chip packaging regrettable substitutions. company, to see if it will perform adequately and has a sufficiently low failure rate. Difficulties finding a surfactant with low surface None as it is a energy performance. Replacement known & viable for some 10-13+ years Fluorinated Pressure Sensitive Additive in processing aid and not For one alternative: inadequate chemical formulations but not all, with more depending on Adhesives adhesive included in the final resistance, thermal stability. For the other information outlined below this table. technical challenges. product alternative there are the same concerns as well as inadequate photoactive properties. Difficulties finding a surfactant with low surface None as it is a energy performance. Replacement known & viable for some 10-13+ years Fluorinated Pressure Sensitive Additive in processing aid and not For one alternative: inadequate chemical formulations but not all, with more depending on Adhesives adhesive included in the final resistance, thermal stability. For the other information outlined below this table. technical challenges. product alternative there are the same concerns as well as inadequate photoactive properties. )?; EK;G9E7IQ& ;D97FHJB7DI Unknown No known viable alternative. 15+ years © RINA Tech UK Ltd 282 Report No. 2022-0737 Rev. 0 Page 74 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Substance Function Quantity Status of alternative Concern of alternative Timeline to develop )?; EK;G9E7IQ& ;D97FHJB7DI Unknown No known viable alternative. 15+ years © RINA Tech UK Ltd 282 Report No. 2022-0737 Rev. 0 Page 74 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Substance Function Quantity Status of alternative Concern of alternative Timeline to develop PFHxA as per relevant dossier Anti-stiction presented to ECHA by the purposes and <0.1%. <1kg/year of After >18 years of work, and >$30M, it was European Semiconductor surface energy PFAS in products sold No known alternative determined that non-PFAS alternatives do not 20+ years Industry Association 6th modification in globally. exist that meet the performance requirements September 2021 or MEMS 73 device F;G;GHQ PFHxA as per relevant dossier Anti-stiction presented to ECHA by the purposes and <0.1%. <1kg/year of After >18 years of work, and >$30M, it was European Semiconductor surface energy PFAS in products sold No known alternative determined that non-PFAS alternatives do not 20+ years Industry Association 6th modification in globally. exist that meet the performance requirements September 2021 or MEMS 73 device F;G;GHQ <0.1%. <1kg/year of PFAS in products sold After >18 years of work, and >$30M, it was globally. determined that non-PFAS alternatives do not Adhesive (UV curable Surface energy exist that meet the performance requirements: adhesives, die attach adhesives) modification in In final component No known alternative 10+ years low dielectric constant; low dielectric loss; high containing PTFE adhesives PFTE is estimated to adhesion too low roughness Cu pre and post range between 0.01 % stress testing 74 and 1.4 % <0.1%. <1kg/year of PFAS in products sold After >18 years of work, and >$30M, it was globally. determined that non-PFAS alternatives do not Adhesive (UV curable Surface energy exist that meet the performance requirements: adhesives, die attach adhesives) modification in In final component No known alternative 10+ years low dielectric constant; low dielectric loss; high containing PTFE adhesives PFTE is estimated to adhesion too low roughness Cu pre and post range between 0.01 % stress testing 74 and 1.4 % Die attach None as it is a PTFE/ Polyvinylidene fluoride 8+ years to develop – 7:>;H?K;Q7D: processing aid and not Testing ongoing. Viable alternative available Time will be required to roll out the alternative (PVDF)/ tooling and fixturing 1 year remaining to Epoxy Anti included in the final for all formulations technology to all tooling and fixturing uses. adhesive. implement Bleed Out agent product Die attach None as it is a PTFE/ Polyvinylidene fluoride 8+ years to develop – 7:>;H?K;Q7D: processing aid and not Testing ongoing. Viable alternative available Time will be required to roll out the alternative (PVDF)/ tooling and fixturing 1 year remaining to Epoxy Anti included in the final for all formulations technology to all tooling and fixturing uses. adhesive. implement Bleed Out agent product In final component the Non-PFAS alternatives do not exist that meet Trifluoroacetic anhydride in PFAS substance is the performance requirements (Thermal and polyimide, polybenzoxazole, and Die passivation No known alternative 10+ years estimated to be <500 chemical stability, photo imageable, dielectric, other epoxy-based passivation ppm good wetting) Replacement may be possible & plan in Surfactant / defoaming agent Unknown Quality, reliability, form, fit, function. 4+ years place to evaluate In final component the Non-PFAS alternatives do not exist that meet Trifluoroacetic anhydride in PFAS substance is the performance requirements (Thermal and polyimide, polybenzoxazole, and Die passivation No known alternative 10+ years estimated to be <500 chemical stability, photo imageable, dielectric, other epoxy-based passivation ppm good wetting) Replacement may be possible & plan in Surfactant / defoaming agent Unknown Quality, reliability, form, fit, function. 4+ years place to evaluate Additive in defoaming agent- Replacement possible, to start the detailed Underfill 0.01% Quality, reliability, form, fit, function. 4+ years PFTE evaluation this year ______ 73 MEMs are made up of components between 1 and 100 micrometres in size and usually are made up of a central processor and several components that interact with the surroundings like microsensors. MEMS chips are often packaged together with an application-specific integrated circuit chip stacked together inside the plastic package, so that one package has the sensor and the circuitry, saving space and cost. 74 A highly accelerated method of electronic component reliability testing using temperature and humidity as the environmental parameters. © RINA Tech UK Ltd 283 Report No. 2022-0737 Rev. 0 Page 75 Additive in defoaming agent- Replacement possible, to start the detailed Underfill 0.01% Quality, reliability, form, fit, function. 4+ years PFTE evaluation this year ______ 73 MEMs are made up of components between 1 and 100 micrometres in size and usually are made up of a central processor and several components that interact with the surroundings like microsensors. MEMS chips are often packaged together with an application-specific integrated circuit chip stacked together inside the plastic package, so that one package has the sensor and the circuitry, saving space and cost. 74 A highly accelerated method of electronic component reliability testing using temperature and humidity as the environmental parameters. © RINA Tech UK Ltd 283 Report No. 2022-0737 Rev. 0 Page 75 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Supply chains for some of the specialty chemicals that are of concern, such as low surface energy surfactants, are currently limited to typically just a few, or a single-source supplier, or the end-user actually makes these chemicals themselves. It is expected that once restrictions are in place that suppliers may stop making the intermediates necessary and/or the end product, or they may increase the cost to cover these more limited/restricted materials. For example, Semiconductor PFAS Consortium members purchase a commonly used surfactant, where over the past 10 years the demand from other industries has diminished such that the semi-conductor industry is now the sole user of this surfactant. Research and development efforts to replace the surfactant were not successful. The Impact of a Potential PFAS Restriction on the Semiconductor Sector Supply chains for some of the specialty chemicals that are of concern, such as low surface energy surfactants, are currently limited to typically just a few, or a single-source supplier, or the end-user actually makes these chemicals themselves. It is expected that once restrictions are in place that suppliers may stop making the intermediates necessary and/or the end product, or they may increase the cost to cover these more limited/restricted materials. For example, Semiconductor PFAS Consortium members purchase a commonly used surfactant, where over the past 10 years the demand from other industries has diminished such that the semi-conductor industry is now the sole user of this surfactant. Research and development efforts to replace the surfactant were not successful. PTFE is an additive in some die attach adhesives to provide for added specificity in the polymerisation to perform the function of limiting the area of the flow of the adhesive or bleed control. These PTFE “Antibleed agents” control the amount of epoxy bleed beyond the peripherals of the die mounted to the leadframe/substrate. This is important to prevent spread of the epoxy to adjacent critical areas such as wirebond pads which will lead to product failures such as wire non-stick on pad, spread on die top resulting in prevention of mold compound adhesion and subsequent void and delamination on the package. The PTFE also promotes flatness of the die and uniform adhesive thickness. For some specific die attach adhesive applications in packaging, alternatives have been under investigation since 2014 and some appear to work and appear to be viable. For this specific application, the alternative is expected to be used in production in the near future (1 year +). PTFE is an additive in some die attach adhesives to provide for added specificity in the polymerisation to perform the function of limiting the area of the flow of the adhesive or bleed control. These PTFE “Antibleed agents” control the amount of epoxy bleed beyond the peripherals of the die mounted to the leadframe/substrate. This is important to prevent spread of the epoxy to adjacent critical areas such as wirebond pads which will lead to product failures such as wire non-stick on pad, spread on die top resulting in prevention of mold compound adhesion and subsequent void and delamination on the package. The PTFE also promotes flatness of the die and uniform adhesive thickness. For some specific die attach adhesive applications in packaging, alternatives have been under investigation since 2014 and some appear to work and appear to be viable. For this specific application, the alternative is expected to be used in production in the near future (1 year +). 8.2 Environmental considerations for PFAS packaging materials There is no foreseeable release of PFAS substances during normal use of consumable products or other end products. Moreover, the concentrations of PFAS in ATPS chemistries are low (parts per billion range) and any release is expected to minimal and only at the end of the product’s useful life. This release would occur only during electronics recycling or disposal. Some of the electronic reclamation processes are thermal and may cause a break-down of PFAS, but this would require further investigation. There has not been a large-scale investigation in the waste streams across the assembly / test / packaging / substrate supply chain for the broad definition of PFAS that we are using within this paper. As most PFAS materials have not been regulated, there have not been the same tracking of PFAS molecules through manufacturing use to finished semiconductor products as there have been for other regulated or traced ATPS compounds. Further investigation and research in this area will be needed. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 76 284 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 8.2 Environmental considerations for PFAS packaging materials There is no foreseeable release of PFAS substances during normal use of consumable products or other end products. Moreover, the concentrations of PFAS in ATPS chemistries are low (parts per billion range) and any release is expected to minimal and only at the end of the product’s useful life. This release would occur only during electronics recycling or disposal. Some of the electronic reclamation processes are thermal and may cause a break-down of PFAS, but this would require further investigation. There has not been a large-scale investigation in the waste streams across the assembly / test / packaging / substrate supply chain for the broad definition of PFAS that we are using within this paper. As most PFAS materials have not been regulated, there have not been the same tracking of PFAS molecules through manufacturing use to finished semiconductor products as there have been for other regulated or traced ATPS compounds. Further investigation and research in this area will be needed. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 76 284 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 9 PUMP FLUIDS & LUBRICANTS USES Summary: PFAS lubricants are critical for use in semiconductor manufacturing, and currently no viable alternatives are known to exist for many critical applications. As such it is expected that more than 10 years would be required to substitute PFAS lubricants in general applications and more than 25 years for lubricants used in photolithography. Potential silicone-based alternatives have a high likelihood of being unsuitable substitutions due to the high likelihood for increased failure rates and inability to meet critical performance requirements, like inertness when used in harsh conditions and low off-gassing and particle generation when used in manufacturing areas and processes where maintaining the highest standards of cleanliness is of paramount importance. Also, a switch to a relatively more reactive alternative is likely to result in: • Mechanical system and seal failures that affect human health and safety within the workplace, and environmental releases of toxic/dangerous chemicals from the manufacturing process. • Additional energy consumption of the machinery they are used in would be required due to their decreased performance. • Reduction in the lifetime of such lubricants so increased raw material and processing energy would be required to manufacture additional quantities of lubricants when compared to PFAS lubricant use. 9 PUMP FLUIDS & LUBRICANTS USES Summary: PFAS lubricants are critical for use in semiconductor manufacturing, and currently no viable alternatives are known to exist for many critical applications. As such it is expected that more than 10 years would be required to substitute PFAS lubricants in general applications and more than 25 years for lubricants used in photolithography. Potential silicone-based alternatives have a high likelihood of being unsuitable substitutions due to the high likelihood for increased failure rates and inability to meet critical performance requirements, like inertness when used in harsh conditions and low off-gassing and particle generation when used in manufacturing areas and processes where maintaining the highest standards of cleanliness is of paramount importance. Also, a switch to a relatively more reactive alternative is likely to result in: • Mechanical system and seal failures that affect human health and safety within the workplace, and environmental releases of toxic/dangerous chemicals from the manufacturing process. • Additional energy consumption of the machinery they are used in would be required due to their decreased performance. • Reduction in the lifetime of such lubricants so increased raw material and processing energy would be required to manufacture additional quantities of lubricants when compared to PFAS lubricant use. Overall volume of PFAS lubricants used within the semiconductor manufacturing industry is small, with expected minimal impact to human health and safety, and minimal exposure to the environment through reuse, recycling, and proper waste management. Any substitution effort would require significant resourcing over an extended and indeterminate amount of time, at significant expense that could impact the local (i.e., EU, US, and US States) semiconductor industry’s global competitiveness. Some substitutions would require extensive redesign and retrofit of semiconductor manufacturing equipment to an extent that would be cost-prohibitive for semiconductor manufacturers. Overall volume of PFAS lubricants used within the semiconductor manufacturing industry is small, with expected minimal impact to human health and safety, and minimal exposure to the environment through reuse, recycling, and proper waste management. Any substitution effort would require significant resourcing over an extended and indeterminate amount of time, at significant expense that could impact the local (i.e., EU, US, and US States) semiconductor industry’s global competitiveness. Some substitutions would require extensive redesign and retrofit of semiconductor manufacturing equipment to an extent that would be cost-prohibitive for semiconductor manufacturers. Solid and liquid lubricants are used to reduce friction and wear between surfaces and as a sealant to prevent the ingress of foreign materials into the lubrication clearance zone. Semiconductor manufacturing requires high-performance lubricants, many of which are PFAS-based, to prevent the creation of particles within cleanrooms and the extreme physical environments present in the manufacturing environments, as well as remaining inert, non-off gassing, and UV stable. PFAS lubricants are critical for use in semiconductor manufacturing, and currently no viable alternatives are known to exist, alternatives such as silicon-based lubricants do not offer the necessary technical performance. In many cases the lubricants are exposed to demanding environments for over 10 years, so long term reliability is key. The overall volume of PFAS lubricants used within the semiconductor manufacturing industry is small and no lubricant will ever be on the semiconductor chip. As such the expected environmental exposure is minimal due to lubricant reuse, recycling, and proper waste management. Solid and liquid lubricants are used to reduce friction and wear between surfaces and as a sealant to prevent the ingress of foreign materials into the lubrication clearance zone. Semiconductor manufacturing requires high-performance lubricants, many of which are PFAS-based, to prevent the creation of particles within cleanrooms and the extreme physical environments present in the manufacturing environments, as well as remaining inert, non-off gassing, and UV stable. PFAS lubricants are critical for use in semiconductor manufacturing, and currently no viable alternatives are known to exist, alternatives such as silicon-based lubricants do not offer the necessary technical performance. In many cases the lubricants are exposed to demanding environments for over 10 years, so long term reliability is key. The overall volume of PFAS lubricants used within the semiconductor manufacturing industry is small and no lubricant will ever be on the semiconductor chip. As such the expected environmental exposure is minimal due to lubricant reuse, recycling, and proper waste management. 9.1 Challenges with non-PFAS lubricants It is important to keep in mind that PFPEs were introduced in semiconductor applications mainly because of safety reasons due to their stability and non-flammability. Any alternative would need to offer these same technical attributes, so as not to decrease the overall safety of these systems potentially causing safety incidents/explosions, injuries, and damage to manufacturing facilities. Specifically, non- PFAS lubricants generate more heat as the lubricant breaks down, which results in lost productivity via © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 77 285 The Impact of a Potential PFAS Restriction on the Semiconductor Sector indirect routes of increased wear and loss of precision leading to increased defect rates. This has direct implications including reduced productivity and costs through machine downtime for maintenance, cleaning and relubrication activities and replacement of parts. 9.1 Challenges with non-PFAS lubricants It is important to keep in mind that PFPEs were introduced in semiconductor applications mainly because of safety reasons due to their stability and non-flammability. Any alternative would need to offer these same technical attributes, so as not to decrease the overall safety of these systems potentially causing safety incidents/explosions, injuries, and damage to manufacturing facilities. Specifically, non- PFAS lubricants generate more heat as the lubricant breaks down, which results in lost productivity via © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 77 285 The Impact of a Potential PFAS Restriction on the Semiconductor Sector indirect routes of increased wear and loss of precision leading to increased defect rates. This has direct implications including reduced productivity and costs through machine downtime for maintenance, cleaning and relubrication activities and replacement of parts. The production of semiconductors is undertaken in cleanrooms that are thousands of times cleaner than those used for manufacturing of medical devices. Due to this need and the high dimensional tolerances required, all moving mechanisms within manufacturing cleanrooms and within the semiconductor manufacturing equipment itself must be lubricated. Lubricants also ensure that maintenance intervals are minimised, and the lifetime of moving parts is extended to the maximum possible. PFAS-based lubricants also have negligible evaporation loss which plays an important role in applications such as vacuum applications. Other PFAS-free alternative cannot offer such very low outgassing performance, which would lead to contamination of the semiconductor wafer during production processes and therefore a decrease in yield. In addition, the more an alternative outgasses, the shorter the lifetime of the grease due to its degradation and the increased heat generation and energy consumption. The biggest issue is the potential for generation of particles / contaminants. Any friction arising from insufficient lubrication causes particle generation, and this results in a reduced yield. Each stage in the process must be virtually perfect with yields above 99%, because there may be hundreds of process steps used to manufacture each advanced semiconductor device. Without those very high yields, semiconductor manufacturing would fail to produce functional and economically viable products. The production of semiconductors is undertaken in cleanrooms that are thousands of times cleaner than those used for manufacturing of medical devices. Due to this need and the high dimensional tolerances required, all moving mechanisms within manufacturing cleanrooms and within the semiconductor manufacturing equipment itself must be lubricated. Lubricants also ensure that maintenance intervals are minimised, and the lifetime of moving parts is extended to the maximum possible. PFAS-based lubricants also have negligible evaporation loss which plays an important role in applications such as vacuum applications. Other PFAS-free alternative cannot offer such very low outgassing performance, which would lead to contamination of the semiconductor wafer during production processes and therefore a decrease in yield. In addition, the more an alternative outgasses, the shorter the lifetime of the grease due to its degradation and the increased heat generation and energy consumption. The biggest issue is the potential for generation of particles / contaminants. Any friction arising from insufficient lubrication causes particle generation, and this results in a reduced yield. Each stage in the process must be virtually perfect with yields above 99%, because there may be hundreds of process steps used to manufacture each advanced semiconductor device. Without those very high yields, semiconductor manufacturing would fail to produce functional and economically viable products. Increased mechanical failures of moving parts, resulting in an increased need for maintenance and shorter lifetimes of semiconductor manufacturing equipment, and a need to update semiconductor manufacturing equipment designs to incorporate additional redundancy and allow access to removable parts. This is due to the fact that all known non-PFAS-containing alternatives would provide lesser performance than the PFAS-containing lubricants currently in use. The following table provides an overview of PFAS-containing lubricants used in semiconductor manufacturing and support equipment, all of which would require more than 10 to more than 25 years to develop a PFAS free alternative that meets all technical performance requirements. Increased mechanical failures of moving parts, resulting in an increased need for maintenance and shorter lifetimes of semiconductor manufacturing equipment, and a need to update semiconductor manufacturing equipment designs to incorporate additional redundancy and allow access to removable parts. This is due to the fact that all known non-PFAS-containing alternatives would provide lesser performance than the PFAS-containing lubricants currently in use. The following table provides an overview of PFAS-containing lubricants used in semiconductor manufacturing and support equipment, all of which would require more than 10 to more than 25 years to develop a PFAS free alternative that meets all technical performance requirements. Table 9-1 Examples of the products utilising PFAS lubricants. Substance Function Status of alternative Concern of alternative Very low outgassing properties, and No known substitute, no outgassing of hydrocarbon Currently, no non-PFAS- as all available compounds. Provides a viscous, based oils and greases substitutes are hydrodynamic film that is sufficient are known to be viable for associated with lesser to support the load and separate ball use in dry vacuum pump performance, including from the raceway in bearing applications. outgassing, chemical applications, enabling high inertness, and thermal PFPE Oil PFPE is the sole option stability endurance performance. 75 Any lubricant used within the dry vacuum to be used for the base characteristics. pump system may mix with the oil of ferromagnetic fluid Where PFPE greases chemically reactive, oxidative used in the ferromagnetic are used the process materials and/or corrosive fluid sealed rotation components are feedthrough. considered ‘lubricated process materials. UV stability for photolithography applications. 15 years surface smoothness, chemical resistance, will gain the necessary thermal resistance. safety approvals. In wire insulation, O-rings, valve seal, abatement Chemical resistance, FKM, FFKM and seals, sealing tape: elasticity, chemical inertness, heat resistance, and >15 years PTFE resistance properties against power, dampness, non-flammability. temperature, heat, UV, and corrosion. In chemical storage and transportation (tanks, pumps, pipes, seal, gaskets etc), ultra-pure water PVDF, PTFE, Chemical resistance and systems including pumps and filters provides >15 years PFA cleanliness. purity via low particle shed, surface smoothness, and is chemically resistant. In exhaust abatement / scrubber: chemical Chemical resistance and PTFE >15 years inertness, non-flammable. heat resistance. In Chemical dispense arm/nozzle assembly, wafer spin chuck, wafer splash guard, reclaim tank, IPA tank, solvent supply/measuring tank, chemical mixing tank, air/liquid separation box PTFE/PFA/PCT chemical mixing box wafer handling and effector Reduced durability and 5-15+ years FE, ETFE, PFA- coatings, valves, control, switching, regulating component lifetimes depending CF, monitoring systems low pressure chamber, robot resulting in a significant on the PTFE/PFA/PVD hand, lifters piping, automated material handling increase in waste. application F systems wafer carriers, UPW & Chemical Filters/housings; Purity via low particle shed, surface smoothness, chemical resistance, thermal resistance, resistance to permeation of chemical resistance and gasses. In potentiometer shims provides smooth motion. In potentiometer resistive inks: presumed to provide long term wear. Information should be In SMD tantalum capacitors provides a special sought from PTFE Unknown mechanical/chemical barrier on the magnesium potentiometer and electrode. In liquid dielectric capacitors as capacitor manufacturers. dielectric films and electrolyte constituents provides long term chemical stability. Table 10-1 Examples of articles utilising PFAS where no alternatives have been identified to date. Timeline to Substance Function Concern of alternative 82 develop Information should be In Lithium batteries: provide a thermal and sought from lithium electrochemical stability as a barrier. battery manufacturers; Excellent electrochemical stability, good expected concerns PVDF Unknown wettability with electrolyte and acceptable binding include chemical ability between active materials and current resistance, heat collectors. resistance, and non- flammability. Chemical resistance, In bearings: provide lubricity, chemical PTFE heat resistance, and Unknown resistance, thermal resistance. cleanliness. Wet cleans and etch processing equipment such Whether they can be as tubing and fittings, Purity via low particle shed, maintained and if they PFAs or PTFE >15 years surface smoothness, chemical resistance, will gain the necessary thermal resistance. safety approvals. In wire insulation, O-rings, valve seal, abatement Chemical resistance, FKM, FFKM and seals, sealing tape: elasticity, chemical inertness, heat resistance, and >15 years PTFE resistance properties against power, dampness, non-flammability. temperature, heat, UV, and corrosion. In chemical storage and transportation (tanks, pumps, pipes, seal, gaskets etc), ultra-pure water PVDF, PTFE, Chemical resistance and systems including pumps and filters provides >15 years PFA cleanliness. purity via low particle shed, surface smoothness, and is chemically resistant. In exhaust abatement / scrubber: chemical Chemical resistance and PTFE >15 years inertness, non-flammable. heat resistance. In Chemical dispense arm/nozzle assembly, wafer spin chuck, wafer splash guard, reclaim tank, IPA tank, solvent supply/measuring tank, chemical mixing tank, air/liquid separation box PTFE/PFA/PCT chemical mixing box wafer handling and effector Reduced durability and 5-15+ years FE, ETFE, PFA- coatings, valves, control, switching, regulating component lifetimes depending CF, monitoring systems low pressure chamber, robot resulting in a significant on the PTFE/PFA/PVD hand, lifters piping, automated material handling increase in waste. application F systems wafer carriers, UPW & Chemical Filters/housings; Purity via low particle shed, surface smoothness, chemical resistance, thermal resistance, resistance to permeation of chemical resistance and gasses. In potentiometer shims provides smooth motion. In potentiometer resistive inks: presumed to provide long term wear. Information should be In SMD tantalum capacitors provides a special sought from PTFE Unknown mechanical/chemical barrier on the magnesium potentiometer and electrode. In liquid dielectric capacitors as capacitor manufacturers. dielectric films and electrolyte constituents provides long term chemical stability. ______ 82 Properties where it may be difficult to find an equivalent alternative, or factors that will increase development times, or possible consequences of an alternative. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 85 293 The Impact of a Potential PFAS Restriction on the Semiconductor Sector If the technical characteristics of a proposed alternative do not strongly align with the PFAS substance it is intended to replace, the requalification time is anticipated to be much longer; moreover, the replacement may fail entirely. ______ 82 Properties where it may be difficult to find an equivalent alternative, or factors that will increase development times, or possible consequences of an alternative. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 85 293 The Impact of a Potential PFAS Restriction on the Semiconductor Sector If the technical characteristics of a proposed alternative do not strongly align with the PFAS substance it is intended to replace, the requalification time is anticipated to be much longer; moreover, the replacement may fail entirely. 10.2 Alternatives The specific application of the article informs the necessary technical requirements, which in turn inform the viability of potential alternatives. The following are key themes relating to technical performance that alternatives need to meet: • Cleanliness: Alternative materials must offer the same level of cleanliness with specifications such as SEMI F57 83 outlining requirements. For example, ultra-pure water (UPW) systems need to operate to demanding specifications which include metals <0.05ppb, low ion contaminants (>19 Mohm/cm resistivity), total organic carbon <1.0 ppb, dissolved oxygen of <5 ppb, low particulate matter with no particles greater in size than 0.2 microns, and <10 particles/ml of particles greater than 10 nm diameter. The historic move from PVC to PVDF to meet these criteria took 47 years to fully complete (1948-1995). • High chemical resistance as otherwise this could lead to chemical leakage, chemical damage to equipment and in operating conditions pose safety concerns for workers. For example, replacing PFA and FFKM seals would require a redesign of the tool which would either need to include a seal, where this would be exposed to the plasma, or would need to shield the seal from plasma exposure. 10.2 Alternatives The specific application of the article informs the necessary technical requirements, which in turn inform the viability of potential alternatives. The following are key themes relating to technical performance that alternatives need to meet: • Cleanliness: Alternative materials must offer the same level of cleanliness with specifications such as SEMI F57 83 outlining requirements. For example, ultra-pure water (UPW) systems need to operate to demanding specifications which include metals <0.05ppb, low ion contaminants (>19 Mohm/cm resistivity), total organic carbon <1.0 ppb, dissolved oxygen of <5 ppb, low particulate matter with no particles greater in size than 0.2 microns, and <10 particles/ml of particles greater than 10 nm diameter. The historic move from PVC to PVDF to meet these criteria took 47 years to fully complete (1948-1995). • High chemical resistance as otherwise this could lead to chemical leakage, chemical damage to equipment and in operating conditions pose safety concerns for workers. For example, replacing PFA and FFKM seals would require a redesign of the tool which would either need to include a seal, where this would be exposed to the plasma, or would need to shield the seal from plasma exposure. • Heat resistance as otherwise this could lead to piping components melting or deforming, resulting in chemical leakage and fire, e.g., silicon rubber replacing PTFE gaskets in turbo pumps could result in failure due to decreased heat resistance. Replacing with PFAS-free alternatives is often incredibly challenging as often potential alternatives require more frequent replacement. For example, data collected by Consortium members has highlighted that the degradation of O-rings consisting of PFAS- free alternatives is higher than the currently used PFAS material. The use of such alternatives would result in increased waste generation, equipment downtime, and maintenance worker exposure to potential hazards. There is also the environmental concern related to any failures of the materials in service, resulting in a higher likelihood of negative environmental impacts and worker exposure due to unplanned releases of process chemicals. • Heat resistance as otherwise this could lead to piping components melting or deforming, resulting in chemical leakage and fire, e.g., silicon rubber replacing PTFE gaskets in turbo pumps could result in failure due to decreased heat resistance. Replacing with PFAS-free alternatives is often incredibly challenging as often potential alternatives require more frequent replacement. For example, data collected by Consortium members has highlighted that the degradation of O-rings consisting of PFAS- free alternatives is higher than the currently used PFAS material. The use of such alternatives would result in increased waste generation, equipment downtime, and maintenance worker exposure to potential hazards. There is also the environmental concern related to any failures of the materials in service, resulting in a higher likelihood of negative environmental impacts and worker exposure due to unplanned releases of process chemicals. In order for PFAS-free alternatives to be incorporated in semiconductor equipment, and especially fabs, it is important that the initial qualification is undertaken by the many layers of the supply chain. Although there may be PFAS-free alternatives advertised, until they have been evaluated in semiconductor applications described in this report, they cannot be determined to be viable alternatives. Extensive test data would be required to understand the impacts of material changes on the safe use, degradation potential and useful life of any articles. Without the development timescales outlined in Table 10-1, there is a greater probability of an alternative material failing whilst in use, which could have serious health and safety implications. Alternatively, if the replacement part is for a key piece of equipment in the device manufacturing process, it could impede the availability of many thousand end-use devices (chips) per day. ______ 83 F05700 - SEMI F57 - Specification for High Purity Polymer Materials an – semi.org © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 86 294 The Impact of a Potential PFAS Restriction on the Semiconductor Sector In order for PFAS-free alternatives to be incorporated in semiconductor equipment, and especially fabs, it is important that the initial qualification is undertaken by the many layers of the supply chain. Although there may be PFAS-free alternatives advertised, until they have been evaluated in semiconductor applications described in this report, they cannot be determined to be viable alternatives. Extensive test data would be required to understand the impacts of material changes on the safe use, degradation potential and useful life of any articles. Without the development timescales outlined in Table 10-1, there is a greater probability of an alternative material failing whilst in use, which could have serious health and safety implications. Alternatively, if the replacement part is for a key piece of equipment in the device manufacturing process, it could impede the availability of many thousand end-use devices (chips) per day. ______ 83 F05700 - SEMI F57 - Specification for High Purity Polymer Materials an – semi.org © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 86 294 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 10.2.1 Examples of unsuccessful PFAS-free article trials The following are some examples of PFAS-free alternatives that have been researched and evaluated but do not offer suitable performance in the applications in which they were assessed, grouped by the failure type. Decreased Cleanliness • Sulfuric acid container made from high-density polyethylene (HDPE) leached particles over time, resulting in wasted chemical and product failure. PFA/PTFE lined containers eliminated the leached particle issue. • IPA container made from HDPE leached high molecular weight organics into IPA causing a process issue and contaminating the tubing and process chamber. • Polyvinylchloride (PVC) has been shown to shed particles, so is not suitable for use in SMRE. 84 • One of the major properties of fluoropolymers is their low outgassing, which contribute to the clean environment required during photolithography. Without PFAS materials impurities are deposited on mirrors used during the processing of semiconductors. Only fluor- and silicon-based materials are able to meet the critical requirements necessary for these applications. 85 Increased Failure/Safety Concerns • PVC filter housing for the dilution of copper water increased failures by a factor of 2.5. Changed to PFA and zero failure rate was achieved with removal of the risk of chemical spill and safety concerns for the workers. 10.2.1 Examples of unsuccessful PFAS-free article trials The following are some examples of PFAS-free alternatives that have been researched and evaluated but do not offer suitable performance in the applications in which they were assessed, grouped by the failure type. Decreased Cleanliness • Sulfuric acid container made from high-density polyethylene (HDPE) leached particles over time, resulting in wasted chemical and product failure. PFA/PTFE lined containers eliminated the leached particle issue. • IPA container made from HDPE leached high molecular weight organics into IPA causing a process issue and contaminating the tubing and process chamber. • Polyvinylchloride (PVC) has been shown to shed particles, so is not suitable for use in SMRE. 84 • One of the major properties of fluoropolymers is their low outgassing, which contribute to the clean environment required during photolithography. Without PFAS materials impurities are deposited on mirrors used during the processing of semiconductors. Only fluor- and silicon-based materials are able to meet the critical requirements necessary for these applications. 85 Increased Failure/Safety Concerns • PVC filter housing for the dilution of copper water increased failures by a factor of 2.5. Changed to PFA and zero failure rate was achieved with removal of the risk of chemical spill and safety concerns for the workers. • Stainless steel was used for level indicator of ammonia waste transmitters, but this had a high corrosion rate, resulting in the overflow of the tank due to failure of the component. The part was substituted by a PFAS, and the failure rate was greatly reduced. • The design of piping system to deliver organic amines was trialled however PFA was the only material that showed compatibility with organic amines and achieved zero failure rate. • HDPE was investigated as a possible replacement for PTFE in tanks, tubing, and containers, however after 6 months it was found to start decomposing in 70% nitric acid, which leads to chemical leakage and an increased replacement rate. • Pulse dampeners using nitrile or EPDM (ethylene propylene diene monomer) elastomers failed because of chemical breaching the diaphragm. By using fluoropolymers, i.e., PTFE, PVDF or PFA in the diaphragm the failure rate has been zero, eliminating both a contamination and failure mechanism. • Stainless steel was used for level indicator of ammonia waste transmitters, but this had a high corrosion rate, resulting in the overflow of the tank due to failure of the component. The part was substituted by a PFAS, and the failure rate was greatly reduced. • The design of piping system to deliver organic amines was trialled however PFA was the only material that showed compatibility with organic amines and achieved zero failure rate. • HDPE was investigated as a possible replacement for PTFE in tanks, tubing, and containers, however after 6 months it was found to start decomposing in 70% nitric acid, which leads to chemical leakage and an increased replacement rate. • Pulse dampeners using nitrile or EPDM (ethylene propylene diene monomer) elastomers failed because of chemical breaching the diaphragm. By using fluoropolymers, i.e., PTFE, PVDF or PFA in the diaphragm the failure rate has been zero, eliminating both a contamination and failure mechanism. • Non-PFAS elastomers have been used as O-rings and seals, by mistake, within mechanical and chemical/gas delivery systems. In some cases, these seals failed almost immediately and caused leaks due to their incompatibility with the gases and chemistries running through the lines. This has resulted in the requirement to disassemble the system and replace the O-rings, result in >10 days of lost production time to replace and requalify the system. ______ 84 Burkhart, Marty, Martin Bittner, Casey Williamson, and Andrea Ulrich, “A Scientific Look at Lab Quality Deionized Water Piping Materials”, Ultrapure Water, Nov 2003, p 36-41. 85 Based on information on outgassing complied by NASA in relation to O-rings and gaskets. Outgassing Data for Selecting Spacecraft Materials Online | Outgassing (nasa.gov) © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 87 295 The Impact of a Potential PFAS Restriction on the Semiconductor Sector • Non-PFAS elastomers have been used as O-rings and seals, by mistake, within mechanical and chemical/gas delivery systems. In some cases, these seals failed almost immediately and caused leaks due to their incompatibility with the gases and chemistries running through the lines. This has resulted in the requirement to disassemble the system and replace the O-rings, result in >10 days of lost production time to replace and requalify the system. ______ 84 Burkhart, Marty, Martin Bittner, Casey Williamson, and Andrea Ulrich, “A Scientific Look at Lab Quality Deionized Water Piping Materials”, Ultrapure Water, Nov 2003, p 36-41. 85 Based on information on outgassing complied by NASA in relation to O-rings and gaskets. Outgassing Data for Selecting Spacecraft Materials Online | Outgassing (nasa.gov) © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 87 295 The Impact of a Potential PFAS Restriction on the Semiconductor Sector Each of the above examples indicate that replacement can increase product safety risk and, more importantly, a risk to workers and the manufacturing facility. As such each use meets a safety need in production. For example, if the alternative non-PFAS substance used is combustible or does not have the appropriate heat resistance it will result in an unacceptable fire risk. Each of the above examples indicate that replacement can increase product safety risk and, more importantly, a risk to workers and the manufacturing facility. As such each use meets a safety need in production. For example, if the alternative non-PFAS substance used is combustible or does not have the appropriate heat resistance it will result in an unacceptable fire risk. 10.3 Environmental Considerations for Articles Potential environmental impacts associated with articles occur primarily during the manufacture of raw materials, which is upstream of the semiconductor devices manufacture. There are also environmental impacts associated with the end of life of articles. Articles are reused and recycled when possible. In some instances, articles are contaminated during use with hazardous chemicals and, therefore, require management according to specific regulatory obligations. The industry will continue to act responsibly by taking advantage of circular economy opportunities as they arise. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 88 296 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 10.3 Environmental Considerations for Articles Potential environmental impacts associated with articles occur primarily during the manufacture of raw materials, which is upstream of the semiconductor devices manufacture. There are also environmental impacts associated with the end of life of articles. Articles are reused and recycled when possible. In some instances, articles are contaminated during use with hazardous chemicals and, therefore, require management according to specific regulatory obligations. The industry will continue to act responsibly by taking advantage of circular economy opportunities as they arise. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 88 296 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 11 ENVIRONMENTAL IMPACT, END OF LIFE AND WASTE CONSIDERATIONS The semiconductor industry works to understand the environmental impact of its manufacturing process and employs wherever possible appropriate engineering controls, abatement, and treatment systems to minimise emissions. In addition, the semiconductor industry undertakes process optimisation to reduce the amount of waste generated and disposed of at a regulated waste disposal facility. The semiconductor industry has implemented where possible control and treatment technologies to reduce emissions and discharges of chemicals, including PFAS, used in semiconductor manufacturing processes. Typical environmental releases include emissions to air and water and disposal of hazardous or non-hazardous waste. Some PFAS-containing materials are sent off-site for treatment, such as incineration, or disposal in regulated solid waste disposal facilities. Semiconductor manufacturing facilities also have on-site abatement systems for air emissions and wastewater pre- treatment or treatment systems prior to discharging wastewater. The semiconductor industry continues to actively identify, test, and implement wherever possible improved process controls that reduce PFAS releases to the environment. 11 ENVIRONMENTAL IMPACT, END OF LIFE AND WASTE CONSIDERATIONS The semiconductor industry works to understand the environmental impact of its manufacturing process and employs wherever possible appropriate engineering controls, abatement, and treatment systems to minimise emissions. In addition, the semiconductor industry undertakes process optimisation to reduce the amount of waste generated and disposed of at a regulated waste disposal facility. The semiconductor industry has implemented where possible control and treatment technologies to reduce emissions and discharges of chemicals, including PFAS, used in semiconductor manufacturing processes. Typical environmental releases include emissions to air and water and disposal of hazardous or non-hazardous waste. Some PFAS-containing materials are sent off-site for treatment, such as incineration, or disposal in regulated solid waste disposal facilities. Semiconductor manufacturing facilities also have on-site abatement systems for air emissions and wastewater pre- treatment or treatment systems prior to discharging wastewater. The semiconductor industry continues to actively identify, test, and implement wherever possible improved process controls that reduce PFAS releases to the environment. 11.1 Air Emissions Control and Abatement Manufacturing facility exhaust systems are designed to remove chemical vapours or gases and heat from equipment. The use of PFCs and HFCs is essential for plasma etching, plasma cleaning, and other low volume but critical applications, as their uses balance the process need for high chemical and ion reactivity with the need for safe and effective manufacturing. The chemistries used in photolithography have relatively low vapour pressure and as outlined in Section 4.6 the quantities of emissions from photolithography are extremely small. The semiconductor industry has a history of commitment to reducing greenhouse gases and has successfully reduced PFCs and HFCs emissions through a combination of process optimisation, substitution, and abatement. The use of POU technologies on many tools using PFCs and HFCs has reduced the potential hazard of exposure to employees and has reduced greenhouse gas emissions. With the implementation of WSC PFC best practices in new fabs - including remote plasma clean and POU abatement- many facilities have needed to expand other treatment systems, such as wastewater, fluoride, and exhaust to meet the required standards for wastewater and air toxics. 11.1 Air Emissions Control and Abatement Manufacturing facility exhaust systems are designed to remove chemical vapours or gases and heat from equipment. The use of PFCs and HFCs is essential for plasma etching, plasma cleaning, and other low volume but critical applications, as their uses balance the process need for high chemical and ion reactivity with the need for safe and effective manufacturing. The chemistries used in photolithography have relatively low vapour pressure and as outlined in Section 4.6 the quantities of emissions from photolithography are extremely small. The semiconductor industry has a history of commitment to reducing greenhouse gases and has successfully reduced PFCs and HFCs emissions through a combination of process optimisation, substitution, and abatement. The use of POU technologies on many tools using PFCs and HFCs has reduced the potential hazard of exposure to employees and has reduced greenhouse gas emissions. With the implementation of WSC PFC best practices in new fabs - including remote plasma clean and POU abatement- many facilities have needed to expand other treatment systems, such as wastewater, fluoride, and exhaust to meet the required standards for wastewater and air toxics. Some POU technologies use fuel-burning processes to abate PFCs and HFCs, creating additional nitrogen oxides, carbon monoxide, and other air pollutants from combustion in exchange for a reduction in PFCs and HFCs. It is therefore especially important that process and abatement alternatives undertake a full safety, health, and environmental impact review to understand additional implications to employee and community safety and health. In addition, tool PFCs and HFCs, F-HTF are also a potential small source of PFAS emissions to air. The F-HTFs used within chillers and test equipment are contained with intent to minimise release during use. Prior to any maintenance activities, F-HTF in the equipment is drained into collection containers that are typically managed for direct use or reclaim at the location of the F-HTF supplier. If any of the F-HTF fluid is required to be managed as waste, the fluid is typically managed for destruction by incineration or thermal destruction by certified waste management facilities. However, during this activity it is possible that small quantities of the F-HTF can be released into the air. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 89 297 Some POU technologies use fuel-burning processes to abate PFCs and HFCs, creating additional nitrogen oxides, carbon monoxide, and other air pollutants from combustion in exchange for a reduction in PFCs and HFCs. It is therefore especially important that process and abatement alternatives undertake a full safety, health, and environmental impact review to understand additional implications to employee and community safety and health. In addition, tool PFCs and HFCs, F-HTF are also a potential small source of PFAS emissions to air. The F-HTFs used within chillers and test equipment are contained with intent to minimise release during use. Prior to any maintenance activities, F-HTF in the equipment is drained into collection containers that are typically managed for direct use or reclaim at the location of the F-HTF supplier. If any of the F-HTF fluid is required to be managed as waste, the fluid is typically managed for destruction by incineration or thermal destruction by certified waste management facilities. However, during this activity it is possible that small quantities of the F-HTF can be released into the air. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 89 297 The Impact of a Potential PFAS Restriction on the Semiconductor Sector The Impact of a Potential PFAS Restriction on the Semiconductor Sector 11.2 Wastewater Treatment Semiconductor manufacturing facilities generate organic and aqueous waste streams which are treated in accordance with local and federal waste and wastewater regulations. Historically, the majority of aqueous chemicals employed in fab manufacturing processes are discharged to an industrial wastewater drain system that conveys wastewater for treatment of specific regulated pollutants in accordance with local and federal regulations, and subsequently discharged to a publicly owned treatment works or surface water. Most PFAS are not regulated pollutants and therefore unless company specific provisions are in place, the wastewater from processes that use aqueous wet chemical formulations that contain PFAS would likely be discharged to the publicly owned treatment works without substantive removal of the PFAS. The industry is actively researching PFAS wastewater releases and treatment technologies. 11.2 Wastewater Treatment Semiconductor manufacturing facilities generate organic and aqueous waste streams which are treated in accordance with local and federal waste and wastewater regulations. Historically, the majority of aqueous chemicals employed in fab manufacturing processes are discharged to an industrial wastewater drain system that conveys wastewater for treatment of specific regulated pollutants in accordance with local and federal regulations, and subsequently discharged to a publicly owned treatment works or surface water. Most PFAS are not regulated pollutants and therefore unless company specific provisions are in place, the wastewater from processes that use aqueous wet chemical formulations that contain PFAS would likely be discharged to the publicly owned treatment works without substantive removal of the PFAS. The industry is actively researching PFAS wastewater releases and treatment technologies. Conventional precipitation-coagulation-clarification treatment processes that are typically used to remove dissolved metals and fluoride from semiconductor wastewater would not be expected to exert a high removal efficiency for soluble PFAS. However, partitioning of some PFAS to the biological waste solids can be anticipated, and may represent a significant opportunity for PFAS migration in the treatment processes. In general, the state of technology for PFAS wastewater treatment is immature, with significant improvements needed to increase the number and types of PFAS that can be cost effectively removed from wastewater. Conventional precipitation-coagulation-clarification treatment processes that are typically used to remove dissolved metals and fluoride from semiconductor wastewater would not be expected to exert a high removal efficiency for soluble PFAS. However, partitioning of some PFAS to the biological waste solids can be anticipated, and may represent a significant opportunity for PFAS migration in the treatment processes. In general, the state of technology for PFAS wastewater treatment is immature, with significant improvements needed to increase the number and types of PFAS that can be cost effectively removed from wastewater. 11.3 Waste Disposal Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerised to be treated at an offsite licensed treatment and disposal facility, as a blended fuel by high temperature incineration or reprocessing. Liquid PFAS lubricants are only used in closed systems and do not need to be replenished as often as other lubricants as they are designed to be long-lasting. As such the potential exposures for most lubricants are limited to product damage, or at end-of-life. For lubricants requiring replenishment, during oil change, the liquids are pumped via a closed system into a collection container with negligible emissions. Typically, liquid PFAS lubricant wastes are collected and sent for recycling so are not expected to enter waste disposal streams. For articles and packaging, there should be minimal or no release of PFAS during normal use of the end product containing semiconductors. At the end-of-life of the product containing the semiconductor, or any parts replaced during the manufacture of semiconductors, would enter waste disposal streams where any PFAS contained therein could enter the environment. Articles are reused and recycled when possible. In some instances, articles replaced during the manufacture of semiconductors are contaminated with hazardous chemicals and, therefore, require management according to specific regulatory obligations so would not enter general waste disposal streams. 11.3 Waste Disposal Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerised to be treated at an offsite licensed treatment and disposal facility, as a blended fuel by high temperature incineration or reprocessing. Liquid PFAS lubricants are only used in closed systems and do not need to be replenished as often as other lubricants as they are designed to be long-lasting. As such the potential exposures for most lubricants are limited to product damage, or at end-of-life. For lubricants requiring replenishment, during oil change, the liquids are pumped via a closed system into a collection container with negligible emissions. Typically, liquid PFAS lubricant wastes are collected and sent for recycling so are not expected to enter waste disposal streams. For articles and packaging, there should be minimal or no release of PFAS during normal use of the end product containing semiconductors. At the end-of-life of the product containing the semiconductor, or any parts replaced during the manufacture of semiconductors, would enter waste disposal streams where any PFAS contained therein could enter the environment. Articles are reused and recycled when possible. In some instances, articles replaced during the manufacture of semiconductors are contaminated with hazardous chemicals and, therefore, require management according to specific regulatory obligations so would not enter general waste disposal streams. 11.4 Environmental Impacts of Non-PFAS Use It is worthwhile noting that if PFAS-based materials are substituted, there are some broad potential adverse environmental implications which are as outlined: • If alternatives decrease yield even by very small percentages significant increases are required in semiconductor manufacturing facility size resulting in correspondingly increased chemical, water, and energy consumption, as well as waste generation. • Decrease in PFAS-free alternative performance would increase the consumption of parts and waste generation for some uses. For example, some PFAS-free articles have an increased risk of © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 90 298 The Impact of a Potential PFAS Restriction on the Semiconductor Sector release to air and water due to early article failure, increasing the number of leaks and the consumption of articles, as they need replacing more often. This loss of process integrity also results in process safety concerns due to loss of containment. 11.4 Environmental Impacts of Non-PFAS Use It is worthwhile noting that if PFAS-based materials are substituted, there are some broad potential adverse environmental implications which are as outlined: • If alternatives decrease yield even by very small percentages significant increases are required in semiconductor manufacturing facility size resulting in correspondingly increased chemical, water, and energy consumption, as well as waste generation. • Decrease in PFAS-free alternative performance would increase the consumption of parts and waste generation for some uses. For example, some PFAS-free articles have an increased risk of © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 90 298 The Impact of a Potential PFAS Restriction on the Semiconductor Sector release to air and water due to early article failure, increasing the number of leaks and the consumption of articles, as they need replacing more often. This loss of process integrity also results in process safety concerns due to loss of containment. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 91 299 The Impact of a Potential PFAS Restriction on the Semiconductor Sector © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 91 299 The Impact of a Potential PFAS Restriction on the Semiconductor Sector 12 SUMMARY OF FINDINGS RINA has undertaken a process of data collection and analysis based on a survey of Semiconductor PFAS Consortium members and subsequent discussion and technical feedback. The evidence provided can be summarised as follows. PFAS are used in chemical formulations, components of manufacturing process tools, facilities infrastructure, and packaging used to make the semiconductor devices that are integral to the modern world. The current semiconductor state of the art is critically reliant on the use of PFAS chemistry owing to the particular properties that these substances provide to enable the extremely demanding performance requirements of semiconductor devices to be realised. Given their unique properties, it is going to be extremely difficult, if not impossible in some instances, to find viable alternatives without stepping back decades in technological advancement. There are also environmental impacts with not using PFAS, such as the potential for decrease in yield and therefore and increase in chemical, water, energy consumption and waste generation. In addition, there is the potential for the decrease in performance of some PFAS-free articles to result in increased waste. 12 SUMMARY OF FINDINGS RINA has undertaken a process of data collection and analysis based on a survey of Semiconductor PFAS Consortium members and subsequent discussion and technical feedback. The evidence provided can be summarised as follows. PFAS are used in chemical formulations, components of manufacturing process tools, facilities infrastructure, and packaging used to make the semiconductor devices that are integral to the modern world. The current semiconductor state of the art is critically reliant on the use of PFAS chemistry owing to the particular properties that these substances provide to enable the extremely demanding performance requirements of semiconductor devices to be realised. Given their unique properties, it is going to be extremely difficult, if not impossible in some instances, to find viable alternatives without stepping back decades in technological advancement. There are also environmental impacts with not using PFAS, such as the potential for decrease in yield and therefore and increase in chemical, water, energy consumption and waste generation. In addition, there is the potential for the decrease in performance of some PFAS-free articles to result in increased waste. The following highlights key uses of PFAS and the estimated time to identify PFAS-free alternatives in each area. More detailed technical information can be found in the respective white papers and case study reports written by the Semiconductor PFAS Consortium (listed in Table 1-2). • Photolithography – PFAS has been an enabling technology in the development of ever smaller semiconductors through cutting edge lithographic developments. PFAS are used in multiple processing steps including photoacid generators (PAG), antireflective coatings (TARCS), surfactants, and barrier layers. For each use type, there are significant technical challenges, many of which will require a new technological development to enable any alternatives to even be potentially viable. All successfully demonstrated PAGs are fluorinated and there are no universally applicable viable fluorine free alternatives for a vast array of lithographic materials. Current PAGs have been in development for 25 years, and alternatives are expected to take from 15 to more than 20 years to reach production. TARCs previously used PFOS and PFOA, which industry moved away from to shorter chain PFAS when regulators identified them as a safer alternative. A high fluorine content is needed to achieve the low refractive index required for TARCs to work, so an alternative solution needs to be identified, after which qualification activities can start. The following highlights key uses of PFAS and the estimated time to identify PFAS-free alternatives in each area. More detailed technical information can be found in the respective white papers and case study reports written by the Semiconductor PFAS Consortium (listed in Table 1-2). • Photolithography – PFAS has been an enabling technology in the development of ever smaller semiconductors through cutting edge lithographic developments. PFAS are used in multiple processing steps including photoacid generators (PAG), antireflective coatings (TARCS), surfactants, and barrier layers. For each use type, there are significant technical challenges, many of which will require a new technological development to enable any alternatives to even be potentially viable. All successfully demonstrated PAGs are fluorinated and there are no universally applicable viable fluorine free alternatives for a vast array of lithographic materials. Current PAGs have been in development for 25 years, and alternatives are expected to take from 15 to more than 20 years to reach production. TARCs previously used PFOS and PFOA, which industry moved away from to shorter chain PFAS when regulators identified them as a safer alternative. A high fluorine content is needed to achieve the low refractive index required for TARCs to work, so an alternative solution needs to be identified, after which qualification activities can start. There is a similar need for the invention of new materials offering the necessary technical parameters for immersion barriers and dielectric materials. It may be possible to find non-PFAS alternatives for less advanced surfactant applications using current known potential alternatives, however, for most advanced applications, a new material would need to be invented to meet the necessary technical requirements. Although each PFAS use has its own challenges and timelines for development, most uses are expected to take between from 10 to more than 13 years to develop and qualify a PFAS-free alternative, with the exception of PAG’s. Alternative solutions will not only have to offer highly demanding technical performance for their intended use, but also not affect subsequent processing steps. A further complicating consideration is that a one-for-one replacement in many of the PFAS uses is not deemed to be technically viable due to the changing technological challenges as the node size decreases. As such, qualification © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 92 300 The Impact of a Potential PFAS Restriction on the Semiconductor Sector There is a similar need for the invention of new materials offering the necessary technical parameters for immersion barriers and dielectric materials. It may be possible to find non-PFAS alternatives for less advanced surfactant applications using current known potential alternatives, however, for most advanced applications, a new material would need to be invented to meet the necessary technical requirements. Although each PFAS use has its own challenges and timelines for development, most uses are expected to take between from 10 to more than 13 years to develop and qualify a PFAS-free alternative, with the exception of PAG’s. Alternative solutions will not only have to offer highly demanding technical performance for their intended use, but also not affect subsequent processing steps. A further complicating consideration is that a one-for-one replacement in many of the PFAS uses is not deemed to be technically viable due to the changing technological challenges as the node size decreases. As such, qualification © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 92 300 The Impact of a Potential PFAS Restriction on the Semiconductor Sector activities are likely to be limited to certain node sizes, with particular challenges at the smaller node sizes. • Wet Chemistry – There are application-specific performance requirements, which may be product or company specific and essential applications which are not universally used by all manufacturers, fabs or products. PFAS are used in several types of formulations of photodevelopers, and etchants, at different steps in the semiconductor manufacturing process. The timeline needed to develop, qualify, and implement alternatives falls into the following four broad categories: - 3 to 4 years: If an existing non-PFAS alternative is available and can be demonstrated to provide adequate performance for a specific application. - 3 to more than 15 years: In some applications where existing non-PFAS alternative may be viable but requires tooling and/or process changes before it can be successfully introduced into HVM. - Successful invention required (from 5 to more than 25 years): where the invention of new chemicals, and/or development of alternative approaches to manufacturing the device are required, with no guarantee of success. activities are likely to be limited to certain node sizes, with particular challenges at the smaller node sizes. • Wet Chemistry – There are application-specific performance requirements, which may be product or company specific and essential applications which are not universally used by all manufacturers, fabs or products. PFAS are used in several types of formulations of photodevelopers, and etchants, at different steps in the semiconductor manufacturing process. The timeline needed to develop, qualify, and implement alternatives falls into the following four broad categories: - 3 to 4 years: If an existing non-PFAS alternative is available and can be demonstrated to provide adequate performance for a specific application. - 3 to more than 15 years: In some applications where existing non-PFAS alternative may be viable but requires tooling and/or process changes before it can be successfully introduced into HVM. - Successful invention required (from 5 to more than 25 years): where the invention of new chemicals, and/or development of alternative approaches to manufacturing the device are required, with no guarantee of success. - No alternative achievable: In some cases, it may ultimately be found that a non-PFAS alternative is not capable of providing the required chemical function and therefore an alternative semiconductor device structure would be required. • Fluorocarbon uses in plasma (or “dry”) etch / wafer clean and deposition– PFC and HFC are used in plasma (or dry) etch/wafer clean, deposition chamber clean, and organometallic precursors and cannot be substituted as extreme cleanliness is necessary to anisotropically etch features without damage. PFC and HFC emission reductions have been a committed goal of the semiconductor industry for over 30 years. However, cutting-edge semiconductor technology only exists because of the unique properties of these gases to perform specifically as intended in this environment. Fundamental changes in semiconductor materials, device design and manufacturing processes are required for alternatives to be feasible. For the vast majority of uses 10-15 years after invention of new semiconductor materials, designs and processes would be required to substitute for each specific type of PFC and HFC use. - No alternative achievable: In some cases, it may ultimately be found that a non-PFAS alternative is not capable of providing the required chemical function and therefore an alternative semiconductor device structure would be required. • Fluorocarbon uses in plasma (or “dry”) etch / wafer clean and deposition– PFC and HFC are used in plasma (or dry) etch/wafer clean, deposition chamber clean, and organometallic precursors and cannot be substituted as extreme cleanliness is necessary to anisotropically etch features without damage. PFC and HFC emission reductions have been a committed goal of the semiconductor industry for over 30 years. However, cutting-edge semiconductor technology only exists because of the unique properties of these gases to perform specifically as intended in this environment. Fundamental changes in semiconductor materials, device design and manufacturing processes are required for alternatives to be feasible. For the vast majority of uses 10-15 years after invention of new semiconductor materials, designs and processes would be required to substitute for each specific type of PFC and HFC use. • Heat Transfer Fluids (HTF) - Fluorinated HTFs are used as liquid fluorinated heat transfer fluids (F-HTFs) and fluorinated refrigerants which are used in tandem within HTF loops and refrigerant cycles to meet operational temperature requirements in semiconductor manufacturing processes like dry etch, thin film deposition and semiconductor device test applications. Similarly performing non-PFAS do not exist for most heat-transfer applications, due to differing working temperature ranges, viscosity, and dielectric properties. There are some PFAS-free HTF, such as glycol / water alternatives which can be used in a limited number of applications. However, it would require from 8 to more than 14 years to substitute due to the need for equipment redesigns to ensure the ongoing safety of equipment making use of the HTF. A similar timeline from 8 to more than 14 years is also required for the substitution of refrigerants within process equipment chillers. For over 70% of applications there is no currently viable alternative, so an alternative would need to be invented, after which from 5 to more than 15 years would be required to implement this and ramp up to HVM. • Heat Transfer Fluids (HTF) - Fluorinated HTFs are used as liquid fluorinated heat transfer fluids (F-HTFs) and fluorinated refrigerants which are used in tandem within HTF loops and refrigerant cycles to meet operational temperature requirements in semiconductor manufacturing processes like dry etch, thin film deposition and semiconductor device test applications. Similarly performing non-PFAS do not exist for most heat-transfer applications, due to differing working temperature ranges, viscosity, and dielectric properties. There are some PFAS-free HTF, such as glycol / water alternatives which can be used in a limited number of applications. However, it would require from 8 to more than 14 years to substitute due to the need for equipment redesigns to ensure the ongoing safety of equipment making use of the HTF. A similar timeline from 8 to more than 14 years is also required for the substitution of refrigerants within process equipment chillers. For over 70% of applications there is no currently viable alternative, so an alternative would need to be invented, after which from 5 to more than 15 years would be required to implement this and ramp up to HVM. There are very few companies which manufacture thermal test fluids, which are manufactured to extremely high specifications. Invention of a PFAS-free thermal test method has not started and the time to do this cannot be quantified. However once invented, it will take from 8 to more than 14 years to implement, or considerably longer if the thermal test equipment needs redesign to accommodate the new method. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 93 301 The Impact of a Potential PFAS Restriction on the Semiconductor Sector There are very few companies which manufacture thermal test fluids, which are manufactured to extremely high specifications. Invention of a PFAS-free thermal test method has not started and the time to do this cannot be quantified. However once invented, it will take from 8 to more than 14 years to implement, or considerably longer if the thermal test equipment needs redesign to accommodate the new method. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 93 301 The Impact of a Potential PFAS Restriction on the Semiconductor Sector • Assembly, Test, & Packaging Materials - As packaging becomes more and more complex due to decreased size, increased processing speed, and/or increased packaging complexity, the combination of properties required are often only found in the fluorinated hydrocarbon family. Changes to assembly package materials range in their complexity, but unlike other uses, due to their interactions with both the silicon die and the end customer product, additional customer product change notification/approval steps are required (average 1-2 years, with some applications requiring 6+ years). The following timelines are estimated to implement PFAS free alternatives: Packaging fluxes 5+ years, surfactants 18+ years, with many suppliers being single source which may cause suppliers to exit the market, encapsulants 13+ years, and adhesives and certain MEMS anti- stiction agents 20+ years as alternatives have been sought for 18 years without success. It is important to keep in mind that the use of PFAS underpins fast signal processing requirements, so the need for PFAS components is expected to grow to limit signal losses; so additional PFAS uses are expected to be required to enable key technology developments within the semiconductor industry. • Assembly, Test, & Packaging Materials - As packaging becomes more and more complex due to decreased size, increased processing speed, and/or increased packaging complexity, the combination of properties required are often only found in the fluorinated hydrocarbon family. Changes to assembly package materials range in their complexity, but unlike other uses, due to their interactions with both the silicon die and the end customer product, additional customer product change notification/approval steps are required (average 1-2 years, with some applications requiring 6+ years). The following timelines are estimated to implement PFAS free alternatives: Packaging fluxes 5+ years, surfactants 18+ years, with many suppliers being single source which may cause suppliers to exit the market, encapsulants 13+ years, and adhesives and certain MEMS anti- stiction agents 20+ years as alternatives have been sought for 18 years without success. It is important to keep in mind that the use of PFAS underpins fast signal processing requirements, so the need for PFAS components is expected to grow to limit signal losses; so additional PFAS uses are expected to be required to enable key technology developments within the semiconductor industry. • Pump Fluids & Lubricants - PFAS lubricants are critical for use in semiconductor manufacturing, and currently no viable alternatives are known to exist. As such it is expected that more than 10 years would be required to substitute PFAS lubricants in general applications and more than 25 years for lubricants used in photolithography. Potential silicon-based alternatives have a high likelihood for increased failure rates and an inability to meet critical performance requirements, like inertness when used in harsh conditions and low off-gassing and particle generation when used in clean manufacturing environments. A more reactive lubricant is also likely to result in system and seal failures, ultimately resulting in health and environmental impacts as a result of, increased energy consumption of the machinery, and the more frequent replacement of the lubricant. • Articles - Very many individual component parts in semiconductor manufacturing equipment are dependent on these substances to provide the compatible, inert, clean, temperature tolerant environment needed for the fluids used in the equipment. Fluoropolymer articles are key in supporting billion-dollar EUV semiconductor lithography machinery, plasma chambers, ultra-pure water system piping, and the multitude of electronic equipment and tools that support a manufacturing facility. • Pump Fluids & Lubricants - PFAS lubricants are critical for use in semiconductor manufacturing, and currently no viable alternatives are known to exist. As such it is expected that more than 10 years would be required to substitute PFAS lubricants in general applications and more than 25 years for lubricants used in photolithography. Potential silicon-based alternatives have a high likelihood for increased failure rates and an inability to meet critical performance requirements, like inertness when used in harsh conditions and low off-gassing and particle generation when used in clean manufacturing environments. A more reactive lubricant is also likely to result in system and seal failures, ultimately resulting in health and environmental impacts as a result of, increased energy consumption of the machinery, and the more frequent replacement of the lubricant. • Articles - Very many individual component parts in semiconductor manufacturing equipment are dependent on these substances to provide the compatible, inert, clean, temperature tolerant environment needed for the fluids used in the equipment. Fluoropolymer articles are key in supporting billion-dollar EUV semiconductor lithography machinery, plasma chambers, ultra-pure water system piping, and the multitude of electronic equipment and tools that support a manufacturing facility. Alternatives typically take more than 15 years to substitute, and it is not guaranteed that a non- PFAS alternative will be able to offer all the salient properties of PFAS. It is worthwhile noting that the timelines outlined above have a significant degree of uncertainty. For many of the substances there are no alternative theoretical material chemistries to use as a basis for invention and a whole new area of chemistry and/or technology will be required. There are also concerns that a change process as large as designing out all PFAS has never taken place and the timelines are based on the time to undertake a single change. As highlighted above, there may be interactions between multiple stages in processing which will need to be explored. There will also be limitations on how many suitably knowledgeable people are available given the magnitude and complexity of the task at hand. As such, the timelines could easily be much longer than those estimated. Alternatives typically take more than 15 years to substitute, and it is not guaranteed that a non- PFAS alternative will be able to offer all the salient properties of PFAS. It is worthwhile noting that the timelines outlined above have a significant degree of uncertainty. For many of the substances there are no alternative theoretical material chemistries to use as a basis for invention and a whole new area of chemistry and/or technology will be required. There are also concerns that a change process as large as designing out all PFAS has never taken place and the timelines are based on the time to undertake a single change. As highlighted above, there may be interactions between multiple stages in processing which will need to be explored. There will also be limitations on how many suitably knowledgeable people are available given the magnitude and complexity of the task at hand. As such, the timelines could easily be much longer than those estimated. The semiconductor industry has, where possible, implemented control and treatment technologies to reduce emissions and discharges of chemicals, including PFAS, used in semiconductor manufacturing processes. Typical environmental releases include emissions to air and water and disposal of hazardous or non-hazardous waste. Some PFAS-containing materials are sent off-site for treatment, such as incineration, or disposal in regulated solid waste disposal facilities. Semiconductor manufacturing facilities also have on-site abatement systems for air emissions and wastewater pre- treatment or treatment systems prior to discharging wastewater. In addition, the semiconductor industry undertakes process optimisation to reduce the amount of waste generated and disposed of at a regulated waste disposal facility. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 94 302 RINA Tech UK Limited | 1 Springfield Drive, Leatherhead, Surrey, KT22 7AJ, United Kingdom | P. +44 0 1372 367350 | Company No. 07419599 UKinfo@rina.org | www.rina.org The semiconductor industry has, where possible, implemented control and treatment technologies to reduce emissions and discharges of chemicals, including PFAS, used in semiconductor manufacturing processes. Typical environmental releases include emissions to air and water and disposal of hazardous or non-hazardous waste. Some PFAS-containing materials are sent off-site for treatment, such as incineration, or disposal in regulated solid waste disposal facilities. Semiconductor manufacturing facilities also have on-site abatement systems for air emissions and wastewater pre- treatment or treatment systems prior to discharging wastewater. In addition, the semiconductor industry undertakes process optimisation to reduce the amount of waste generated and disposed of at a regulated waste disposal facility. © RINA Tech UK Ltd Report No. 2022-0737 Rev. 0 Page 94 302 RINA Tech UK Limited | 1 Springfield Drive, Leatherhead, Surrey, KT22 7AJ, United Kingdom | P. +44 0 1372 367350 | Company No. 07419599 UKinfo@rina.org | www.rina.org 303 From: John Przepiora Sent: Tuesday, October 31, 2023 5:26:16 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: t.worrell@ujtfs.org ; 'Barry Lentz' ; 'C Biesemeyer' ; 'Chris Straile' ; David Coburn ; David Sonnenfeld ; dbdesigninteriors@verizon.net ; Diana Elliott ; 'Dick Kornbluth' ; 'Don Hughes' ; 'Greg Michel' ; MovingPeopleCNY@gmail.com ; 'Owen Kerney' ; 'Peter Arsenault' ; 'Peter Wirth' ; rhaleyarch@gmail.com ; 'Scott Kushner' ; 'Yvonne Chu' ; 'Zac Bellinger' ; ZoeckleJ@upstate.edu Subject: Micron DEIS Scoping Comments NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: OCIDA 303 From: John Przepiora Sent: Tuesday, October 31, 2023 5:26:16 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: t.worrell@ujtfs.org ; 'Barry Lentz' ; 'C Biesemeyer' ; 'Chris Straile' ; David Coburn ; David Sonnenfeld ; dbdesigninteriors@verizon.net ; Diana Elliott ; 'Dick Kornbluth' ; 'Don Hughes' ; 'Greg Michel' ; MovingPeopleCNY@gmail.com ; 'Owen Kerney' ; 'Peter Arsenault' ; 'Peter Wirth' ; rhaleyarch@gmail.com ; 'Scott Kushner' ; 'Yvonne Chu' ; 'Zac Bellinger' ; ZoeckleJ@upstate.edu Subject: Micron DEIS Scoping Comments NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: OCIDA On behalf of the following individuals and myself working together as the CNY Sustainability Coalition, and who have signed the attached memorandum on behalf of our respective organizations, I am submitting the attached comments and supporting 4 attachments (A1-A4) pursuant to the public comment period for the Micron project SEQRA DEIS scoping. Please do not hesitate to contact me if you have any questions. Thank you for the opportunity to comment on this important document and for allowing an extension of time for filing this. Donald Hughes Conservation Chair, Sierra Club Central & Northern NY Group 1 304 Syracuse, NY dhughes171@gmail.com Peter Wirth Vice President, Climate Change Action and Awareness Fayetteville, NY pwirth2@verizon.net John Przepiora Vice President, GreeningUSA, Inc. Syracuse, NY info@greeningusa.org Dick Kornbluth Climate Justice Committee CNY Solidarity Coalition Onondaga County, NY cnysolidarity@gmail.com Tylah Worrell Exec. Director, Urban Jobs Task Force of Syracuse Syracuse, NY t.worrell@ujtfs.org Thank you again. We look forward to working with you as this project moves forward. 2 305 John Przepiora Vice-President & Director GreeningUSA, Inc. (315) 382-3829 On behalf of the following individuals and myself working together as the CNY Sustainability Coalition, and who have signed the attached memorandum on behalf of our respective organizations, I am submitting the attached comments and supporting 4 attachments (A1-A4) pursuant to the public comment period for the Micron project SEQRA DEIS scoping. Please do not hesitate to contact me if you have any questions. Thank you for the opportunity to comment on this important document and for allowing an extension of time for filing this. Donald Hughes Conservation Chair, Sierra Club Central & Northern NY Group 1 304 Syracuse, NY dhughes171@gmail.com Peter Wirth Vice President, Climate Change Action and Awareness Fayetteville, NY pwirth2@verizon.net John Przepiora Vice President, GreeningUSA, Inc. Syracuse, NY info@greeningusa.org Dick Kornbluth Climate Justice Committee CNY Solidarity Coalition Onondaga County, NY cnysolidarity@gmail.com Tylah Worrell Exec. Director, Urban Jobs Task Force of Syracuse Syracuse, NY t.worrell@ujtfs.org Thank you again. We look forward to working with you as this project moves forward. 2 305 John Przepiora Vice-President & Director GreeningUSA, Inc. (315) 382-3829 …Advocating for sustainable communities to the benefit of local economies and environments. 3 306 ‭To: Onondaga County Industrial Development Agency (OCIDA)‬ ‭ rom: The undersigned individuals and representatives of environmental and sustainability‬ F ‭organizations of Central New York, aka, “CNY Sustainability Coalition”‬ ‭ E: Comments on the‬‭DRAFT SEQRA SCOPE OF WORK (‬‭draft‬‭Scoping Document or draft‬ R ‭scope‬‭),‬‭dated‬‭September 12, 2023‬‭for the proposed‬‭MICRON SEMICONDUCTOR‬ ‭FABRICATION plant in‬‭Clay, NY.‬ ‭----------------------------------------------------------------------------------------------------------------‬ ‭ he SEQR Handbook, 4th Edition, dated 2020, states: “A written scope of issues developed‬ T ‭through a public scoping process benefits the lead agency and the sponsor by providing explicit‬ ‭guidance as to what criteria will be used to determine whether a submitted draft EIS is adequate.‬ ‭The written scope provides a means of ensuring that significant topics have not been missed and‬ ‭that the level of analysis in the EIS satisfies standards established during the scoping process.”‬ …Advocating for sustainable communities to the benefit of local economies and environments. 3 306 ‭To: Onondaga County Industrial Development Agency (OCIDA)‬ ‭ rom: The undersigned individuals and representatives of environmental and sustainability‬ F ‭organizations of Central New York, aka, “CNY Sustainability Coalition”‬ ‭ E: Comments on the‬‭DRAFT SEQRA SCOPE OF WORK (‬‭draft‬‭Scoping Document or draft‬ R ‭scope‬‭),‬‭dated‬‭September 12, 2023‬‭for the proposed‬‭MICRON SEMICONDUCTOR‬ ‭FABRICATION plant in‬‭Clay, NY.‬ ‭----------------------------------------------------------------------------------------------------------------‬ ‭ he SEQR Handbook, 4th Edition, dated 2020, states: “A written scope of issues developed‬ T ‭through a public scoping process benefits the lead agency and the sponsor by providing explicit‬ ‭guidance as to what criteria will be used to determine whether a submitted draft EIS is adequate.‬ ‭The written scope provides a means of ensuring that significant topics have not been missed and‬ ‭that the level of analysis in the EIS satisfies standards established during the scoping process.”‬ ‭ hile the draft Scoping Document offers a reasonable approach to defining significant‬ W ‭environmental impacts in certain areas, we believe it is inadequate in other areas, especially‬ ‭ith respect to chemicals and energy usage. We offer the following comments:"‬ ‭4.3 ALTERNATIVES TO BE ANALYZED IN THE DEIS‬ ‭ he SEQR Handbook stipulates (p 100) the scoping process should “Define reasonable‬ T ‭alternatives for avoiding specific impacts which must be included in the EIS, either as individual‬ ‭scenarios or a range of alternatives.”‬ ‭Two “build” alternatives are presented in the draft scope:‬ 1‭ )‬ ‭Full construction and operation of four fabs over an approximately 20-year period‬ ‭2)‬ ‭Reduced Scale: construction and operation of two fabs over a shorter period.‬ ‭ hile the draft Scoping Document offers a reasonable approach to defining significant‬ W ‭environmental impacts in certain areas, we believe it is inadequate in other areas, especially‬ ‭ith respect to chemicals and energy usage. We offer the following comments:"‬ ‭4.3 ALTERNATIVES TO BE ANALYZED IN THE DEIS‬ ‭ he SEQR Handbook stipulates (p 100) the scoping process should “Define reasonable‬ T ‭alternatives for avoiding specific impacts which must be included in the EIS, either as individual‬ ‭scenarios or a range of alternatives.”‬ ‭Two “build” alternatives are presented in the draft scope:‬ 1‭ )‬ ‭Full construction and operation of four fabs over an approximately 20-year period‬ ‭2)‬ ‭Reduced Scale: construction and operation of two fabs over a shorter period.‬ ‭ his analysis is too limited. It does not address a proper range of alternatives. For example, the‬ T ‭impacts on Greenhouse Gas Emissions and Climate Change will vary tremendously depending‬ ‭on the amount of renewable energy that Micron is able to procure. Micron has expressed a desire‬ ‭to achieve 100% renewable energy for electricity, but that may be unrealistic for the construction‬ ‭timeframes that are envisioned. Micron’s electricity demands are projected to be very large (7.15‬ ‭billion kWh/year for Phase 1; 16.17 billion kWh/year for Phase 2), so it would be far more‬ ‭realistic to evaluate a range of alternatives which take into account the time needed to construct a‬ ‭supply of renewable energy sources (wind, solar, and hydropower). The evaluation must assess‬ ‭the feasibility of achieving 100% of electricity from renewable sources for each Phase of the‬ ‭project.‬ I‭ t has been estimated (Plumley, pers. communication) that it would take 1200 3MW wind‬ ‭turbines to generate the power needed for Phase 2.‬ I‭ t would also be useful to consider alternatives with different phasing such as construction of a‬ ‭single fab followed by a reassessment of impacts prior to construction of a second fab. In a‬ ‭1‬‭|‬‭Page‬ 307 ‭ his analysis is too limited. It does not address a proper range of alternatives. For example, the‬ T ‭impacts on Greenhouse Gas Emissions and Climate Change will vary tremendously depending‬ ‭on the amount of renewable energy that Micron is able to procure. Micron has expressed a desire‬ ‭to achieve 100% renewable energy for electricity, but that may be unrealistic for the construction‬ ‭timeframes that are envisioned. Micron’s electricity demands are projected to be very large (7.15‬ ‭billion kWh/year for Phase 1; 16.17 billion kWh/year for Phase 2), so it would be far more‬ ‭realistic to evaluate a range of alternatives which take into account the time needed to construct a‬ ‭supply of renewable energy sources (wind, solar, and hydropower). The evaluation must assess‬ ‭the feasibility of achieving 100% of electricity from renewable sources for each Phase of the‬ ‭project.‬ I‭ t has been estimated (Plumley, pers. communication) that it would take 1200 3MW wind‬ ‭turbines to generate the power needed for Phase 2.‬ I‭ t would also be useful to consider alternatives with different phasing such as construction of a‬ ‭single fab followed by a reassessment of impacts prior to construction of a second fab. In a‬ ‭1‬‭|‬‭Page‬ 307 ‭ ulti-phase approach, lengthening the time frame may be an appropriate way to manage the‬ m ‭community impacts while allowing for the potential for technological changes that may affect‬ ‭chip fabrication or building and/or transportation improvements which may reduce impacts. A‬ ‭long term approach may allow the community to adjust to the growth and assimilate it with less‬ ‭adversity.‬ 5‭ ANALYSIS FRAMEWORK‬ ‭Preparation of the DEIS must conform to 6 NYCRR Part 617.9(b). The DEC’s SEQR Handbook‬ ‭asserts that “An Environmental Impact Statement (EIS) is a document that impartially analyzes‬ ‭the full range of potential significant adverse environmental impacts of a proposed action and‬ ‭how those impacts can be avoided or minimized.”‬ ‭ ection 5.1 of the draft scope states: “The Proposed Project will be evaluated for potential‬ S ‭significant adverse effects to the Project Site and‬‭applicable study areas‬‭for all relevant‬ ‭environmental technical categories in accordance with applicable SEQRA requirements.”‬ ‭ ulti-phase approach, lengthening the time frame may be an appropriate way to manage the‬ m ‭community impacts while allowing for the potential for technological changes that may affect‬ ‭chip fabrication or building and/or transportation improvements which may reduce impacts. A‬ ‭long term approach may allow the community to adjust to the growth and assimilate it with less‬ ‭adversity.‬ 5‭ ANALYSIS FRAMEWORK‬ ‭Preparation of the DEIS must conform to 6 NYCRR Part 617.9(b). The DEC’s SEQR Handbook‬ ‭asserts that “An Environmental Impact Statement (EIS) is a document that impartially analyzes‬ ‭the full range of potential significant adverse environmental impacts of a proposed action and‬ ‭how those impacts can be avoided or minimized.”‬ ‭ ection 5.1 of the draft scope states: “The Proposed Project will be evaluated for potential‬ S ‭significant adverse effects to the Project Site and‬‭applicable study areas‬‭for all relevant‬ ‭environmental technical categories in accordance with applicable SEQRA requirements.”‬ ‭‘Applicable study areas’ is a vague phrase which needs to be better defined specifically in an‬ o‭ verarching, comprehensive manner. Answers to questions are directly related to the question‬ ‭asked; asking the wrong question leads to wrong answers. We recognize that each of the‬ ‭sub-sections in 5.3.1 may define study area specific to the particular analysis and that may be‬ ‭appropriate, however, we believe that the final scope document should include a stand alone‬ ‭section devoted to defining the study area clearly in order to convey the breadth with which the‬ ‭impacts of this project will be manifest and establish the full areal extent of the analytical‬ ‭framework.‬ ‭‘Applicable study areas’ is a vague phrase which needs to be better defined specifically in an‬ o‭ verarching, comprehensive manner. Answers to questions are directly related to the question‬ ‭asked; asking the wrong question leads to wrong answers. We recognize that each of the‬ ‭sub-sections in 5.3.1 may define study area specific to the particular analysis and that may be‬ ‭appropriate, however, we believe that the final scope document should include a stand alone‬ ‭section devoted to defining the study area clearly in order to convey the breadth with which the‬ ‭impacts of this project will be manifest and establish the full areal extent of the analytical‬ ‭framework.‬ ‭ his project requires an ecosystem approach that considers the regional impacts on the‬ T ‭environment, the economy and society. The impacts must be determined and assessed for their‬ ‭equitable distribution and for their adverse impacts that are detrimental to the region’s short and‬ ‭long term sustainability. This is not a typical project. It is enormous in scale, unprecedented for‬ ‭the region and with potential for egregious environmental impacts. It has been suggested by‬ ‭Onondaga county officials that the Onondaga County population may increase by 25% or‬ ‭125,000 over the full build-out period (estimates of regional growth are unknown to this‬ ‭reviewer). The scale of the environmental review process, and the expertise required to carry it‬ ‭out, must rival the project’s enormity.‬ ‭ CIDA must assure that the final scope for each of the technical sections of the DEIS is‬ O ‭specified with rigor, that the appropriate and necessary expertise is utilized in the writing of each‬ ‭scope item, that the study areas are broad enough and that each analysis is based on not only the‬ ‭current standards, but also reasonably presumed standards that will be in force throughout the‬ ‭build out and operational period of the proposed project.‬ ‭ his project requires an ecosystem approach that considers the regional impacts on the‬ T ‭environment, the economy and society. The impacts must be determined and assessed for their‬ ‭equitable distribution and for their adverse impacts that are detrimental to the region’s short and‬ ‭long term sustainability. This is not a typical project. It is enormous in scale, unprecedented for‬ ‭the region and with potential for egregious environmental impacts. It has been suggested by‬ ‭Onondaga county officials that the Onondaga County population may increase by 25% or‬ ‭125,000 over the full build-out period (estimates of regional growth are unknown to this‬ ‭reviewer). The scale of the environmental review process, and the expertise required to carry it‬ ‭out, must rival the project’s enormity.‬ ‭ CIDA must assure that the final scope for each of the technical sections of the DEIS is‬ O ‭specified with rigor, that the appropriate and necessary expertise is utilized in the writing of each‬ ‭scope item, that the study areas are broad enough and that each analysis is based on not only the‬ ‭current standards, but also reasonably presumed standards that will be in force throughout the‬ ‭build out and operational period of the proposed project.‬ ‭ inally, The SEQR Handbook requires the following in the scoping of the identified reasonably‬ F ‭expected impacts:‬ ‭•‬ ‭Describe the extent and quality of information needed;‬ ‭•‬ ‭List available sources of information;‬ ‭•‬ ‭Specify study methods or models to be used to generate new information, including‬ ‭criteria or assumptions underlying any models, and define nature and presentation of the data to‬ ‭be generated by those studies and models.‬ ‭2‬‭|‬‭Page‬ 308 I‭ n many of the areas included in section 5.3 the standards for information and methods appear to‬ ‭be inadequate. The scoping document must require high standards be applied to the analysis and‬ ‭specify information and methods to be utilized. To do less shortchanges the community and can‬ ‭lead to disastrous and unanticipated consequences.‬ ‭ he biggest challenge presented by this project is the enormity of it; in order to fulfill the dreams‬ T ‭which this project offers in a just, equitable, economically and environmentally sustainable‬ ‭manner, the review process must be equally enormous, impartial and thorough.‬ ‭5.3‬‭METHODOLOGIES FOR TECHNICAL ANALYSES‬ ‭Comments on specific sections are listed below.‬ ‭ inally, The SEQR Handbook requires the following in the scoping of the identified reasonably‬ F ‭expected impacts:‬ ‭•‬ ‭Describe the extent and quality of information needed;‬ ‭•‬ ‭List available sources of information;‬ ‭•‬ ‭Specify study methods or models to be used to generate new information, including‬ ‭criteria or assumptions underlying any models, and define nature and presentation of the data to‬ ‭be generated by those studies and models.‬ ‭2‬‭|‬‭Page‬ 308 I‭ n many of the areas included in section 5.3 the standards for information and methods appear to‬ ‭be inadequate. The scoping document must require high standards be applied to the analysis and‬ ‭specify information and methods to be utilized. To do less shortchanges the community and can‬ ‭lead to disastrous and unanticipated consequences.‬ ‭ he biggest challenge presented by this project is the enormity of it; in order to fulfill the dreams‬ T ‭which this project offers in a just, equitable, economically and environmentally sustainable‬ ‭manner, the review process must be equally enormous, impartial and thorough.‬ ‭5.3‬‭METHODOLOGIES FOR TECHNICAL ANALYSES‬ ‭Comments on specific sections are listed below.‬ ‭ any of the methodologies outlined in Chapter 5, Analysis Framework, are very‬ M ‭comprehensive and appropriate for a project of this size. We fully support the inclusion of‬ ‭each of these categories. However, we have noted certain areas where the level of detail‬ ‭and intent seems inadequate as follows.‬ ‭5.3.1 TECHNICAL STUDIES‬ ‭●‬ ‭LAND USE, ZONING, AND PUBLIC POLICY‬ ‭ OMMENT: Why isn’t the city of Syracuse explicitly included here? Seems to be a‬ C ‭major omission.‬ ‭●‬ ‭COMMUNITY FACILITIES/OPEN SPACE AND RECREATION‬ ‭ OMMENT: Here is an assessment of impacts on community emergency services, fire‬ C ‭safety requirements included in building code and site access requirements of the‬ ‭emergency service providers.‬ ‭ umped in is assessment of growth impacts on educational facilities and parks and‬ L ‭recreational facilities. The study area seems ill defined and critical to this analysis. Some‬ ‭reference to Towns of Clay and Cicero seems to limit the study area to these two towns;‬ ‭is that what is intended? If so, it is probably too narrow an area particularly when the‬ ‭cumulative and indirect impacts are considered.‬ ‭ any of the methodologies outlined in Chapter 5, Analysis Framework, are very‬ M ‭comprehensive and appropriate for a project of this size. We fully support the inclusion of‬ ‭each of these categories. However, we have noted certain areas where the level of detail‬ ‭and intent seems inadequate as follows.‬ ‭5.3.1 TECHNICAL STUDIES‬ ‭●‬ ‭LAND USE, ZONING, AND PUBLIC POLICY‬ ‭ OMMENT: Why isn’t the city of Syracuse explicitly included here? Seems to be a‬ C ‭major omission.‬ ‭●‬ ‭COMMUNITY FACILITIES/OPEN SPACE AND RECREATION‬ ‭ OMMENT: Here is an assessment of impacts on community emergency services, fire‬ C ‭safety requirements included in building code and site access requirements of the‬ ‭emergency service providers.‬ ‭ umped in is assessment of growth impacts on educational facilities and parks and‬ L ‭recreational facilities. The study area seems ill defined and critical to this analysis. Some‬ ‭reference to Towns of Clay and Cicero seems to limit the study area to these two towns;‬ ‭is that what is intended? If so, it is probably too narrow an area particularly when the‬ ‭cumulative and indirect impacts are considered.‬ ‭ his section is poorly organized and deserves to be rewritten to define more clearly what‬ T ‭are the parameters to be studied and analyzed relevant to police, fire and other emergency‬ ‭services; schools; parks and rec facilities. Absent from the community facilities most‬ ‭notably is the health care and hospital system.‬ ‭●‬ ‭SOCIO-ECONOMIC CONDITIONS‬ ‭ OMMENT: The study area is defined better here and seems appropriate. It is necessary‬ C ‭to assess the way benefits and adverse impacts are distributed. There is no specified time‬ ‭horizon for this analysis and little specificity regarding the analytical standards, tools and‬ ‭techniques that will be employed. If OCIDA is ill equipped to specify generally accepted‬ ‭standards for such an analysis it is incumbent tha OCIDA obtain the expertise required to‬ ‭specify how this must be done.‬ ‭3‬‭|‬‭Page‬ 309 ‭●‬ ‭VISUAL IMPACTS AND COMMUNITY CHARACTER‬ ‭ his section is poorly organized and deserves to be rewritten to define more clearly what‬ T ‭are the parameters to be studied and analyzed relevant to police, fire and other emergency‬ ‭services; schools; parks and rec facilities. Absent from the community facilities most‬ ‭notably is the health care and hospital system.‬ ‭●‬ ‭SOCIO-ECONOMIC CONDITIONS‬ ‭ OMMENT: The study area is defined better here and seems appropriate. It is necessary‬ C ‭to assess the way benefits and adverse impacts are distributed. There is no specified time‬ ‭horizon for this analysis and little specificity regarding the analytical standards, tools and‬ ‭techniques that will be employed. If OCIDA is ill equipped to specify generally accepted‬ ‭standards for such an analysis it is incumbent tha OCIDA obtain the expertise required to‬ ‭specify how this must be done.‬ ‭3‬‭|‬‭Page‬ 309 ‭●‬ ‭VISUAL IMPACTS AND COMMUNITY CHARACTER‬ ‭ OMMENT: This project has the potential to significantly alter the character of the‬ C ‭community—not only the locale surrounding the immediate project location, but the‬ ‭wider Syracuse and Onondaga County as well as portions of Oswego County as‬ ‭population growth and housing development is induced. The DEIS should include an‬ ‭analysis of the potential for growth-induced changes in the community that this project‬ ‭will induce.‬ ‭●‬ ‭GEOLOGY, SOILS, AND TOPOGRAPHY‬ ‭ OMMENT: Reference is made to ‘property survey’ as a data source but later the‬ C ‭‘geotechnical investigation’ is mentioned but not included in the sentence describing the‬ ‭analysis. Is this an oversight that should be corrected? Certainly the geotechnical survey‬ ‭will provide valuable information to confirm or modify the USGS soil survey data.‬ ‭●‬ ‭NATURAL RESOURCES‬ ‭ OMMENT: This seems to prioritize wildlife and overlook the categorization of existing‬ C ‭vegetation. Is that what is intended? The EAF mentioned the undertaking of detailed field‬ ‭studies of land coverage and natural resource conditions on or near the Micron Campus.‬ ‭Will a detailed land cover field study be done? It should be included.‬ ‭ OMMENT: This project has the potential to significantly alter the character of the‬ C ‭community—not only the locale surrounding the immediate project location, but the‬ ‭wider Syracuse and Onondaga County as well as portions of Oswego County as‬ ‭population growth and housing development is induced. The DEIS should include an‬ ‭analysis of the potential for growth-induced changes in the community that this project‬ ‭will induce.‬ ‭●‬ ‭GEOLOGY, SOILS, AND TOPOGRAPHY‬ ‭ OMMENT: Reference is made to ‘property survey’ as a data source but later the‬ C ‭‘geotechnical investigation’ is mentioned but not included in the sentence describing the‬ ‭analysis. Is this an oversight that should be corrected? Certainly the geotechnical survey‬ ‭will provide valuable information to confirm or modify the USGS soil survey data.‬ ‭●‬ ‭NATURAL RESOURCES‬ ‭ OMMENT: This seems to prioritize wildlife and overlook the categorization of existing‬ C ‭vegetation. Is that what is intended? The EAF mentioned the undertaking of detailed field‬ ‭studies of land coverage and natural resource conditions on or near the Micron Campus.‬ ‭Will a detailed land cover field study be done? It should be included.‬ ‭ ittle detail is included about the hydrology and wetlands evaluations that will be‬ L ‭necessary. Standards, tools and analytical techniques required to be employed must be‬ ‭specified. If OCIDA lacks the expertise to properly specify this analysis they must obtain‬ ‭that expertise from involved agencies or consultants that can properly specify the scope‬ ‭and requirements of this work.‬ ‭●‬ ‭SOLID WASTE & HAZARDOUS MATERIALS‬ “‭ This analysis will describe the proposed generation of solid waste by the Proposed‬ ‭Project and how that material will be handled, stored, and transported. This analysis will‬ ‭describe Micron’s proposed measures to reduce generation of solid waste through reuse‬ ‭or recycling.”‬ ‭ ittle detail is included about the hydrology and wetlands evaluations that will be‬ L ‭necessary. Standards, tools and analytical techniques required to be employed must be‬ ‭specified. If OCIDA lacks the expertise to properly specify this analysis they must obtain‬ ‭that expertise from involved agencies or consultants that can properly specify the scope‬ ‭and requirements of this work.‬ ‭●‬ ‭SOLID WASTE & HAZARDOUS MATERIALS‬ “‭ This analysis will describe the proposed generation of solid waste by the Proposed‬ ‭Project and how that material will be handled, stored, and transported. This analysis will‬ ‭describe Micron’s proposed measures to reduce generation of solid waste through reuse‬ ‭or recycling.”‬ ‭ OMMENT: It is appropriate for Micron to identify the quantities and types of solid‬ C ‭waste that are likely to be generated at their facilities. The applicant estimates the‬ ‭generation of 45,000 tons per year of solid waste, which represents an additional 15% of‬ ‭waste generated in Onondaga County. All solid waste in Onondaga County is burned in‬ ‭an incinerator. What impacts will the solid wastes disposed of through the OCRRA‬ ‭system have on air quality? The fiscal implications for the OCRRA must also be‬ ‭assessed. The indirect, long term and cumulative impacts of the use and disposal of both‬ ‭solid and hazardous waste materials must be included in the analysis.‬ ‭ he applicant is proposing to take measures to reduce the generation of solid waste. What‬ T ‭is under consideration?‬ ‭Strangely, the same level of investigation is not described for hazardous wastes, which‬ ‭constitute a far greater threat to employees, the community, and the environment.‬ ‭4‬‭|‬‭Page‬ 310 ‭ OMMENT: It is appropriate for Micron to identify the quantities and types of solid‬ C ‭waste that are likely to be generated at their facilities. The applicant estimates the‬ ‭generation of 45,000 tons per year of solid waste, which represents an additional 15% of‬ ‭waste generated in Onondaga County. All solid waste in Onondaga County is burned in‬ ‭an incinerator. What impacts will the solid wastes disposed of through the OCRRA‬ ‭system have on air quality? The fiscal implications for the OCRRA must also be‬ ‭assessed. The indirect, long term and cumulative impacts of the use and disposal of both‬ ‭solid and hazardous waste materials must be included in the analysis.‬ ‭ he applicant is proposing to take measures to reduce the generation of solid waste. What‬ T ‭is under consideration?‬ ‭Strangely, the same level of investigation is not described for hazardous wastes, which‬ ‭constitute a far greater threat to employees, the community, and the environment.‬ ‭4‬‭|‬‭Page‬ 310 ‭ he text reads that the DEIS “will identify any hazardous materials (including any‬ T ‭chemical or petroleum bulk storage) that would be used, stored, transported, or generated‬ ‭by the Proposed Project and measures to protect against releases to the environment.”‬ I‭ t is imperative that the DEIS identify ways to reduce and eliminate the generation of‬ ‭hazardous waste through reuse and recycling. Hazardous waste is best eliminated by‬ ‭using non-hazardous substances in the fabrication process. In the event that hazardous‬ ‭substances must be used in the fabrication process, methods to completely contain those‬ ‭substances, and/or ultimately destroy them, must be considered.‬ ‭Of particular concern are perfluorinated alkyl substances (PFAS), otherwise known as‬ “‭ forever” chemicals because of their long lifetimes in the environment and in organisms.‬ ‭These chemicals are of great concern due to their high levels of toxicity. The‬ ‭semiconductor industry uses PFAS extensively (Forbes magazine, Oct. 5 , 2023;‬ ‭https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-mean‬ ‭s-more-forever-chemicals/?sh=2d10b08c7821‬‭P‬‭) The DEIS must address the use of these‬ ‭chemicals and alternative chemicals that could be used as substitutes.‬ ‭ he text reads that the DEIS “will identify any hazardous materials (including any‬ T ‭chemical or petroleum bulk storage) that would be used, stored, transported, or generated‬ ‭by the Proposed Project and measures to protect against releases to the environment.”‬ I‭ t is imperative that the DEIS identify ways to reduce and eliminate the generation of‬ ‭hazardous waste through reuse and recycling. Hazardous waste is best eliminated by‬ ‭using non-hazardous substances in the fabrication process. In the event that hazardous‬ ‭substances must be used in the fabrication process, methods to completely contain those‬ ‭substances, and/or ultimately destroy them, must be considered.‬ ‭Of particular concern are perfluorinated alkyl substances (PFAS), otherwise known as‬ “‭ forever” chemicals because of their long lifetimes in the environment and in organisms.‬ ‭These chemicals are of great concern due to their high levels of toxicity. The‬ ‭semiconductor industry uses PFAS extensively (Forbes magazine, Oct. 5 , 2023;‬ ‭https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-mean‬ ‭s-more-forever-chemicals/?sh=2d10b08c7821‬‭P‬‭) The DEIS must address the use of these‬ ‭chemicals and alternative chemicals that could be used as substitutes.‬ ‭ he attached memorandum from Lenny Siegel, Center for Public Environmental‬ T ‭Oversight, provides additional details regarding the problems posed by PFAS and other‬ ‭hazardous chemicals. The authors of a recent paper on use of PFAS in the semiconductor‬ ‭industry note that: “ the strength of the C─F bond creates materials with unique and‬ ‭technologically useful properties in semiconductor processing. That same bond strength‬ ‭also results in‬‭strong resistance toward physical,‬‭chemical, and biological degradation‬‭.‬ ‭Due to this strong resistance to degradation, PFAS compounds in general‬‭are extremely‬ ‭stable in the environment.‬‭In addition, such compounds‬‭have been found to be‬ ‭bioaccumulative. Extensive literature exists describing the detection of a number of PFAS‬ ‭compounds in drinking water.” (emphasis added) The authors also note “there is a strong‬ ‭societal interest in eliminating their use, and “essential use” is a stopgap situation in‬ ‭which replacements are actively sought.”‬ ‭https://www.spiedigitallibrary.org/journals/journal-of-micro-nanopatterning-materials-an‬ ‭d-metrology/volume-21/issue-01/010901/Review-of-essential-use-of-fluorochemicals-in-‬ ‭lithographic-patterning-and/10.1117/1.JMM.21.1.010901.full?SSO=1‬ ‭ he attached memorandum from Lenny Siegel, Center for Public Environmental‬ T ‭Oversight, provides additional details regarding the problems posed by PFAS and other‬ ‭hazardous chemicals. The authors of a recent paper on use of PFAS in the semiconductor‬ ‭industry note that: “ the strength of the C─F bond creates materials with unique and‬ ‭technologically useful properties in semiconductor processing. That same bond strength‬ ‭also results in‬‭strong resistance toward physical,‬‭chemical, and biological degradation‬‭.‬ ‭Due to this strong resistance to degradation, PFAS compounds in general‬‭are extremely‬ ‭stable in the environment.‬‭In addition, such compounds‬‭have been found to be‬ ‭bioaccumulative. Extensive literature exists describing the detection of a number of PFAS‬ ‭compounds in drinking water.” (emphasis added) The authors also note “there is a strong‬ ‭societal interest in eliminating their use, and “essential use” is a stopgap situation in‬ ‭which replacements are actively sought.”‬ ‭https://www.spiedigitallibrary.org/journals/journal-of-micro-nanopatterning-materials-an‬ ‭d-metrology/volume-21/issue-01/010901/Review-of-essential-use-of-fluorochemicals-in-‬ ‭lithographic-patterning-and/10.1117/1.JMM.21.1.010901.full?SSO=1‬ ‭ nhesa (formerly Chemical Watch) is an industry trade organization that provides‬ E ‭regulatory guidance to industry. They note that: “‬‭The‬‭use of PFAS is a major focus for‬ ‭regulatory authorities worldwide right now. In Europe, the REACH restriction proposal‬ ‭aims to place limits on all uses of more than 10,000 per- and polyfluoroalkyl substances.‬ ‭Meanwhile, in the US, restrictions are high on the agenda in several states.‬ I‭ n late September 2023 the European Parliament voted overwhelmingly in support of a‬ ‭parliamentary report backing the first revision of the Urban Wastewater Treatment‬ ‭Directive (UWWTD) in 30 years. The revision proposal would introduce new limit‬ ‭values and treatment requirements for‬‭micropollutants‬‭in wastewater, including per- and‬ ‭polyfluoroalkyl substances (‬‭PFASs)‬‭and microplastics.‬ ‭5‬‭|‬‭Page‬ 311 ‭ nhesa (formerly Chemical Watch) is an industry trade organization that provides‬ E ‭regulatory guidance to industry. They note that: “‬‭The‬‭use of PFAS is a major focus for‬ ‭regulatory authorities worldwide right now. In Europe, the REACH restriction proposal‬ ‭aims to place limits on all uses of more than 10,000 per- and polyfluoroalkyl substances.‬ ‭Meanwhile, in the US, restrictions are high on the agenda in several states.‬ I‭ n late September 2023 the European Parliament voted overwhelmingly in support of a‬ ‭parliamentary report backing the first revision of the Urban Wastewater Treatment‬ ‭Directive (UWWTD) in 30 years. The revision proposal would introduce new limit‬ ‭values and treatment requirements for‬‭micropollutants‬‭in wastewater, including per- and‬ ‭polyfluoroalkyl substances (‬‭PFASs)‬‭and microplastics.‬ ‭5‬‭|‬‭Page‬ 311 ‭ he hazardous materials component is a significant component of the EIS. It deserves its‬ T ‭own chapter. As written, there is no reference to worker safety; but of course OSHA rules‬ ‭apply as well as other laws when the use, storage and transport of Hazardous Materials‬ ‭(HazMat) is considered. The DEIS should be required to include information about this‬ ‭issue as 9,000 workers will potentially interact with these materials, and the community‬ ‭in general is potentially being put at risk. HazMat emergency response and potential risks‬ ‭to the community must also be fully considered and described. The DEIS must include a‬ ‭full disclosure of HazMat risks related to the manufacture of chips including supply‬ ‭chain, transport, storage, security, air quality, spill/release response and disposal. Cradle‬ ‭to grave analysis must be provided to decision makers being asked to permit this‬ ‭endeavor, as well as community members who are being asked to assume these risks.‬ ‭Additionally, we believe alternative production processes should be evaluated to‬ ‭determine whether the objective production can be realized without the utilization of‬ ‭hazardous materials.‬ ‭●‬ ‭TRANSPORTATION:‬ ‭ he hazardous materials component is a significant component of the EIS. It deserves its‬ T ‭own chapter. As written, there is no reference to worker safety; but of course OSHA rules‬ ‭apply as well as other laws when the use, storage and transport of Hazardous Materials‬ ‭(HazMat) is considered. The DEIS should be required to include information about this‬ ‭issue as 9,000 workers will potentially interact with these materials, and the community‬ ‭in general is potentially being put at risk. HazMat emergency response and potential risks‬ ‭to the community must also be fully considered and described. The DEIS must include a‬ ‭full disclosure of HazMat risks related to the manufacture of chips including supply‬ ‭chain, transport, storage, security, air quality, spill/release response and disposal. Cradle‬ ‭to grave analysis must be provided to decision makers being asked to permit this‬ ‭endeavor, as well as community members who are being asked to assume these risks.‬ ‭Additionally, we believe alternative production processes should be evaluated to‬ ‭determine whether the objective production can be realized without the utilization of‬ ‭hazardous materials.‬ ‭●‬ ‭TRANSPORTATION:‬ ‭ he only mitigation measures mentioned in this section are improvements to roadways. It‬ T ‭is imperative that the utilization of public transportation, including mass transit by bus‬ ‭and light rail, be considered.‬ ‭●‬ ‭UTILITIES & INFRASTRUCTURE:‬ ‭ OMMENT: The potential impacts on infrastructure (water, stormwater, sanitary sewer,‬ C ‭electrical and telecommunications) will be assessed. The scope of this assessment is ill‬ ‭defined here and needs to be specified in greater detail. The DEIS needs to address‬ ‭parameters such as system capacity, level of service changes, fiscal implications for the‬ ‭community and impacts on water bodies.‬ ‭ he city of Syracuse should be considered an interested agency for this (as well as other‬ T ‭aspects of this project) as it relies on a connection to the OCWA for a portion of its water‬ ‭supply needs.‬ I‭ t is noted elsewhere in project documents that a 16” natural gas main will be extended to‬ ‭the plant, yet it isn’t mentioned in this section; Shouldn’t impacts associated with the‬ ‭area’s gas supply and the construction of this line be included here?‬ ‭●‬ ‭USE AND CONSUMPTION OF ENERGY‬ ‭ he only mitigation measures mentioned in this section are improvements to roadways. It‬ T ‭is imperative that the utilization of public transportation, including mass transit by bus‬ ‭and light rail, be considered.‬ ‭●‬ ‭UTILITIES & INFRASTRUCTURE:‬ ‭ OMMENT: The potential impacts on infrastructure (water, stormwater, sanitary sewer,‬ C ‭electrical and telecommunications) will be assessed. The scope of this assessment is ill‬ ‭defined here and needs to be specified in greater detail. The DEIS needs to address‬ ‭parameters such as system capacity, level of service changes, fiscal implications for the‬ ‭community and impacts on water bodies.‬ ‭ he city of Syracuse should be considered an interested agency for this (as well as other‬ T ‭aspects of this project) as it relies on a connection to the OCWA for a portion of its water‬ ‭supply needs.‬ I‭ t is noted elsewhere in project documents that a 16” natural gas main will be extended to‬ ‭the plant, yet it isn’t mentioned in this section; Shouldn’t impacts associated with the‬ ‭area’s gas supply and the construction of this line be included here?‬ ‭●‬ ‭USE AND CONSUMPTION OF ENERGY‬ ‭ he Scoping Document simply states: “This analysis will describe the Proposed Project’s‬ T ‭use and consumption of energy and measures that Micron intends to pursue to reduce‬ ‭energy consumption and use of renewable sources.”‬ ‭ OMMENT: The anticipated energy needs of this project are enormous. Much greater‬ C ‭detail is warranted, as discussed below. Local as well as regional and statewide impacts‬ ‭must be considered. Further, this section is related to other sections such as‬ ‭transportation, air quality, and climate change.‬ ‭6‬‭|‬‭Page‬ 312 ‭ he Scoping Document simply states: “This analysis will describe the Proposed Project’s‬ T ‭use and consumption of energy and measures that Micron intends to pursue to reduce‬ ‭energy consumption and use of renewable sources.”‬ ‭ OMMENT: The anticipated energy needs of this project are enormous. Much greater‬ C ‭detail is warranted, as discussed below. Local as well as regional and statewide impacts‬ ‭must be considered. Further, this section is related to other sections such as‬ ‭transportation, air quality, and climate change.‬ ‭6‬‭|‬‭Page‬ 312 ‭ lectricity:‬ ‭Electrical consumption is anticipated to be 16 billion kilowatt-hours of‬ E ‭electricity per year, when fully built. (Phase 2, Envir. Assessment Form, Part 1, Section‬ ‭K) To put this in perspective, this is equivalent to all of the electricity consumed by the‬ ‭states of New Hampshire and Vermont, combined. The entire state of New York used 143‬ ‭billion kWh of energy in 2022. Micron will increase demand in NY by 11%. The Scoping‬ ‭Document clearly needs to provide greater details about:‬ ‭●‬ ‭How will the EIS consider the various sources of electricity which are currently‬ ‭available, and which may become available as the plant is constructed?‬ ‭●‬ ‭The EIS must evaluate the ability of current power lines owned and operated by‬ ‭National Grid to deliver the required power.‬ ‭●‬ ‭Micron has stated its goal “to achieve 100% renewable energy for existing U.S.‬ ‭operations by the end of 2025.” (Micron sustainability progress summary 2023:‬ ‭Message from Sanjay Mehrotra President and CEO, Micron Technology) Does‬ ‭Micron plan to achieve this goal for the proposed facility in Clay?‬ ‭●‬ ‭The Scoping Document should state that the EIS will examine:‬ ‭○‬ ‭power purchase agreements with suppliers of solar power, wind power and‬ ‭hydropower.‬ ‭○‬ ‭on-site production of electricity from solar and/or wind generation‬ ‭ lectricity:‬ ‭Electrical consumption is anticipated to be 16 billion kilowatt-hours of‬ E ‭electricity per year, when fully built. (Phase 2, Envir. Assessment Form, Part 1, Section‬ ‭K) To put this in perspective, this is equivalent to all of the electricity consumed by the‬ ‭states of New Hampshire and Vermont, combined. The entire state of New York used 143‬ ‭billion kWh of energy in 2022. Micron will increase demand in NY by 11%. The Scoping‬ ‭Document clearly needs to provide greater details about:‬ ‭●‬ ‭How will the EIS consider the various sources of electricity which are currently‬ ‭available, and which may become available as the plant is constructed?‬ ‭●‬ ‭The EIS must evaluate the ability of current power lines owned and operated by‬ ‭National Grid to deliver the required power.‬ ‭●‬ ‭Micron has stated its goal “to achieve 100% renewable energy for existing U.S.‬ ‭operations by the end of 2025.” (Micron sustainability progress summary 2023:‬ ‭Message from Sanjay Mehrotra President and CEO, Micron Technology) Does‬ ‭Micron plan to achieve this goal for the proposed facility in Clay?‬ ‭●‬ ‭The Scoping Document should state that the EIS will examine:‬ ‭○‬ ‭power purchase agreements with suppliers of solar power, wind power and‬ ‭hydropower.‬ ‭○‬ ‭on-site production of electricity from solar and/or wind generation‬ ‭ atural Gas:‬‭National Grid is proposing to build approximately‬‭2.5 miles of 124-psig,12"‬ N ‭natural gas distribution main to the new Micron facility. (Exhibit G, Micron Term Sheet,‬ ‭signed Sept. 22, 2022). The DEIS needs to address these topics:‬ ‭●‬ ‭How much natural gas will the facility need, and for what purpose?‬ ‭●‬ ‭The use of natural gas seems inconsistent with New York state’s CLCPA, which‬ ‭calls for a‬‭40% reduction of greenhouse gas (GHG)‬‭emissions 2030, and then an‬ ‭85% reduction of GHG (below 1990 levels) by 2050. Combustion of natural gas‬ ‭releases CO‬‭2‬ ‭which is the primary driver of climate‬‭change.‬ ‭●‬ ‭The use of natural gas also seems incompatible with‬‭Micron’s global target to‬ ‭achieve a 42% reduction in GHG emissions from operations (“scope 1”) by 2030‬ ‭and net-zero emissions from operations and purchased energy (“scope 1 & 2") by‬ ‭2050, supporting the objectives of the Paris Agreement. (Source:‬‭Micron website:‬ ‭https://www.micron.com/ny/fact-sheet‬‭)‬ ‭ atural Gas:‬‭National Grid is proposing to build approximately‬‭2.5 miles of 124-psig,12"‬ N ‭natural gas distribution main to the new Micron facility. (Exhibit G, Micron Term Sheet,‬ ‭signed Sept. 22, 2022). The DEIS needs to address these topics:‬ ‭●‬ ‭How much natural gas will the facility need, and for what purpose?‬ ‭●‬ ‭The use of natural gas seems inconsistent with New York state’s CLCPA, which‬ ‭calls for a‬‭40% reduction of greenhouse gas (GHG)‬‭emissions 2030, and then an‬ ‭85% reduction of GHG (below 1990 levels) by 2050. Combustion of natural gas‬ ‭releases CO‬‭2‬ ‭which is the primary driver of climate‬‭change.‬ ‭●‬ ‭The use of natural gas also seems incompatible with‬‭Micron’s global target to‬ ‭achieve a 42% reduction in GHG emissions from operations (“scope 1”) by 2030‬ ‭and net-zero emissions from operations and purchased energy (“scope 1 & 2") by‬ ‭2050, supporting the objectives of the Paris Agreement. (Source:‬‭Micron website:‬ ‭https://www.micron.com/ny/fact-sheet‬‭)‬ ‭ elated energy usage:‬‭The use of energy for construction,‬‭facility operations and the‬ R ‭ancillary increases in energy consumption related to transportation needs the project will‬ ‭generate should also be investigated. It may not be unreasonable to consider the increase‬ ‭in energy consumption from the induced community growth which this project will‬ ‭generate as described in the chapters on indirect and cumulative impacts and the growth‬ ‭inducing aspects of the project.‬ ‭●‬ ‭INDIRECT AND CUMULATIVE IMPACTS:‬ ‭ OMMENT: The use of the word ‘summarize’ to describe the scope of this Chapter is‬ C ‭insufficient. This Chapter must assess indirect and cumulative impacts of the proposed‬ ‭project for each of the technical areas included in the DEIS. If these effects are included‬ ‭elsewhere it may be appropriate to summarize them here. Let’s be clear about exactly‬ ‭what is required to be included in the DEIS‬ ‭7‬‭|‬‭Page‬ 313 ‭●‬ ‭GROWTH INDUCING ASPECTS OF THE PROPOSED PROJECT:‬ ‭ elated energy usage:‬‭The use of energy for construction,‬‭facility operations and the‬ R ‭ancillary increases in energy consumption related to transportation needs the project will‬ ‭generate should also be investigated. It may not be unreasonable to consider the increase‬ ‭in energy consumption from the induced community growth which this project will‬ ‭generate as described in the chapters on indirect and cumulative impacts and the growth‬ ‭inducing aspects of the project.‬ ‭●‬ ‭INDIRECT AND CUMULATIVE IMPACTS:‬ ‭ OMMENT: The use of the word ‘summarize’ to describe the scope of this Chapter is‬ C ‭insufficient. This Chapter must assess indirect and cumulative impacts of the proposed‬ ‭project for each of the technical areas included in the DEIS. If these effects are included‬ ‭elsewhere it may be appropriate to summarize them here. Let’s be clear about exactly‬ ‭what is required to be included in the DEIS‬ ‭7‬‭|‬‭Page‬ 313 ‭●‬ ‭GROWTH INDUCING ASPECTS OF THE PROPOSED PROJECT:‬ ‭ OMMENT: This section relates to perhaps the most significant aspects of this project.‬ C ‭While jobs and employment and economic growth will be created, the population growth‬ ‭of the region has the potential to produce significant adverse environmental and‬ ‭economic impacts as well which must be considered. While this section overlaps with‬ ‭other sections of the proposed DEIS scope, it is important to not forget that there will be‬ ‭significant impacts on the community. Such effects as rising housing costs could‬ ‭disproportionately impact the impoverished and increase the potential for a rise in‬ ‭homelessness. The DEIS must not overlook this and other issues relating to population‬ ‭growth of Syracuse, Onondaga County and the surrounding area.‬ ‭●‬ ‭IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES‬ ‭ OMMENT: Aside from building materials and energy, resources consumed in the‬ C ‭manufacturing process, as well as the land devoted to this project, the water consumed‬ ‭and the changes to water and air quality (eg., compounds such as “forever chemicals”‬ ‭which could be discharged into water bodies and the air) should be included in this‬ ‭analysis. The community should, and must know, the sustainability aspects of this‬ ‭venture as it decides to permit its development.‬ ‭ OMMENT: This section relates to perhaps the most significant aspects of this project.‬ C ‭While jobs and employment and economic growth will be created, the population growth‬ ‭of the region has the potential to produce significant adverse environmental and‬ ‭economic impacts as well which must be considered. While this section overlaps with‬ ‭other sections of the proposed DEIS scope, it is important to not forget that there will be‬ ‭significant impacts on the community. Such effects as rising housing costs could‬ ‭disproportionately impact the impoverished and increase the potential for a rise in‬ ‭homelessness. The DEIS must not overlook this and other issues relating to population‬ ‭growth of Syracuse, Onondaga County and the surrounding area.‬ ‭●‬ ‭IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES‬ ‭ OMMENT: Aside from building materials and energy, resources consumed in the‬ C ‭manufacturing process, as well as the land devoted to this project, the water consumed‬ ‭and the changes to water and air quality (eg., compounds such as “forever chemicals”‬ ‭which could be discharged into water bodies and the air) should be included in this‬ ‭analysis. The community should, and must know, the sustainability aspects of this‬ ‭venture as it decides to permit its development.‬ ‭●‬ ‭MITIGATION:‬ ‭The SEQR Handbook suggests, “ Specify possible measures for mitigating potential‬ ‭impacts that must be discussed in the EIS, to the extent that they can be identified at the‬ ‭time of scoping.”‬ ‭In addition to those listed in this draft scope, others that should be listed are:‬ ‭●‬ ‭Public transportation (various options such as fixed route bus, demand activated‬ ‭bus service, light rail),‬ ‭●‬ ‭Building design features such as those proscribed in LEED building standards that‬ ‭reduce energy consumption, or production of renewable energy (geothermal or‬ ‭other water-source heat pumps) or‬ ‭●‬ ‭Mitigate habitat loss with green roofs or parking area reductions via public‬ ‭transportation options for employees‬ ‭●‬ ‭Alternative production processes that can minimize use of hazardous materials,‬ ‭energy use, etc.‬ ‭Respectfully submitted by the following, on behalf of their respective organizations.‬ ‭ onald Hughes‬ D ‭Conservation Chair, Sierra Club Central & Northern NY Group‬ ‭Syracuse, NY‬ ‭dhughes171@gmail.com‬ ‭ eter Wirth‬ P ‭Vice President, Climate Change Action and Awareness‬ ‭Fayetteville, NY‬ ‭pwirth2@verizon.net‬ ‭8‬‭|‬‭Page‬ 314 ‭●‬ ‭MITIGATION:‬ ‭The SEQR Handbook suggests, “ Specify possible measures for mitigating potential‬ ‭impacts that must be discussed in the EIS, to the extent that they can be identified at the‬ ‭time of scoping.”‬ ‭In addition to those listed in this draft scope, others that should be listed are:‬ ‭●‬ ‭Public transportation (various options such as fixed route bus, demand activated‬ ‭bus service, light rail),‬ ‭●‬ ‭Building design features such as those proscribed in LEED building standards that‬ ‭reduce energy consumption, or production of renewable energy (geothermal or‬ ‭other water-source heat pumps) or‬ ‭●‬ ‭Mitigate habitat loss with green roofs or parking area reductions via public‬ ‭transportation options for employees‬ ‭●‬ ‭Alternative production processes that can minimize use of hazardous materials,‬ ‭energy use, etc.‬ ‭Respectfully submitted by the following, on behalf of their respective organizations.‬ ‭ onald Hughes‬ D ‭Conservation Chair, Sierra Club Central & Northern NY Group‬ ‭Syracuse, NY‬ ‭dhughes171@gmail.com‬ ‭ eter Wirth‬ P ‭Vice President, Climate Change Action and Awareness‬ ‭Fayetteville, NY‬ ‭pwirth2@verizon.net‬ ‭8‬‭|‬‭Page‬ 314 J‭ ohn Przepiora‬ ‭Vice President, GreeningUSA, Inc.‬ ‭Syracuse, NY‬ ‭info@greeningusa.org‬ ‭ ick Kornbluth‬ D ‭Climate Justice Committee‬ ‭CNY Solidarity Coalition‬ ‭Onondaga County, NY‬ ‭cnysolidarity@gmail.com‬ ‭ ylah Worrell‬ T ‭Exec. Director,‬ ‭Urban Jobs Task Force of Syracuse‬ ‭Syracuse, NY‬ ‭t.worrell@ujtfs.org‬ ‭LIST OF ATTACHMENTS‬ ‭1.‬ ‭Forbes magazine, Oct. 5 , 2023;‬ ‭https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-mean‬ ‭s-more-forever-chemicals/?sh=2d10b08c7821‬‭P‬ ‭2.‬ ‭Memorandum from Lenny Siegel, Center for Public Environmental Oversight‬ ‭3.‬ ‭Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng. “Review of‬ ‭essential use of fluorochemicals in lithographic patterning and semiconductor‬ ‭processing,”‬‭Journal of Micro/Nanopatterning, Materials, and Metrology, Vol.‬ ‭21, Issue 1‬‭, 010901 (March 2022).‬ ‭https://doi.org/10.1117/1.JMM.21.1.010901‬ ‭4.‬ ‭Micron sustainability progress summary 2023: Message from Sanjay Mehrotra President‬ ‭and CEO, Micron Technology‬ ‭9‬‭|‬‭Page‬ 315 More Domestic Chip-Making Means More ‘Forever Chemicals’ by Amy Feldman, Forbes Staff, October 5, 2033 https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-means-more-forever-chemicals/?sh=2d10b08c7821 J‭ ohn Przepiora‬ ‭Vice President, GreeningUSA, Inc.‬ ‭Syracuse, NY‬ ‭info@greeningusa.org‬ ‭ ick Kornbluth‬ D ‭Climate Justice Committee‬ ‭CNY Solidarity Coalition‬ ‭Onondaga County, NY‬ ‭cnysolidarity@gmail.com‬ ‭ ylah Worrell‬ T ‭Exec. Director,‬ ‭Urban Jobs Task Force of Syracuse‬ ‭Syracuse, NY‬ ‭t.worrell@ujtfs.org‬ ‭LIST OF ATTACHMENTS‬ ‭1.‬ ‭Forbes magazine, Oct. 5 , 2023;‬ ‭https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-mean‬ ‭s-more-forever-chemicals/?sh=2d10b08c7821‬‭P‬ ‭2.‬ ‭Memorandum from Lenny Siegel, Center for Public Environmental Oversight‬ ‭3.‬ ‭Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng. “Review of‬ ‭essential use of fluorochemicals in lithographic patterning and semiconductor‬ ‭processing,”‬‭Journal of Micro/Nanopatterning, Materials, and Metrology, Vol.‬ ‭21, Issue 1‬‭, 010901 (March 2022).‬ ‭https://doi.org/10.1117/1.JMM.21.1.010901‬ ‭4.‬ ‭Micron sustainability progress summary 2023: Message from Sanjay Mehrotra President‬ ‭and CEO, Micron Technology‬ ‭9‬‭|‬‭Page‬ 315 More Domestic Chip-Making Means More ‘Forever Chemicals’ by Amy Feldman, Forbes Staff, October 5, 2033 https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-means-more-forever-chemicals/?sh=2d10b08c7821 Mark Newman, CEO of Chemours, the only American PFA manufacturer, says the company is ramping up production to meet the demands of reshored semiconductor fabrication. “I brought some show-and-tell,” Mark Newman, CEO of chemical maker Chemours, told Forbes during a recent interview in a midtown Manhattan conference room. He pulled a valve assembly out of a bag. The innocuous piece of plastic, he explained, is made of fluoropolymer known as PFA — a type of controversial “forever chemical” and an essential tool in the production of semiconductors. 1|Page 316 “You cannot make chips without a whole PFA infrastructure,” he said. “We estimate that in a modern-day fab, there’s a half-kilo of PFA in every square foot. So in a 400,000- to 600,000- square-foot fab, that’s 200 to 300 metric tons of this stuff.” It’s not just valves, of course, but all types of pipes, tubes and pumps in semiconductor equipment. Fluoropolymers are particularly key for filtering out small particles from fluids during chip production. Few factories need to be as clean as chip fabs, where particles as tiny as human skin cells can contaminate production. Chemours’ PFA is in much of that equipment and material, providing a big, and largely unseen, part of a semiconductor fab’s processes. Mark Newman, CEO of Chemours, the only American PFA manufacturer, says the company is ramping up production to meet the demands of reshored semiconductor fabrication. “I brought some show-and-tell,” Mark Newman, CEO of chemical maker Chemours, told Forbes during a recent interview in a midtown Manhattan conference room. He pulled a valve assembly out of a bag. The innocuous piece of plastic, he explained, is made of fluoropolymer known as PFA — a type of controversial “forever chemical” and an essential tool in the production of semiconductors. 1|Page 316 “You cannot make chips without a whole PFA infrastructure,” he said. “We estimate that in a modern-day fab, there’s a half-kilo of PFA in every square foot. So in a 400,000- to 600,000- square-foot fab, that’s 200 to 300 metric tons of this stuff.” It’s not just valves, of course, but all types of pipes, tubes and pumps in semiconductor equipment. Fluoropolymers are particularly key for filtering out small particles from fluids during chip production. Few factories need to be as clean as chip fabs, where particles as tiny as human skin cells can contaminate production. Chemours’ PFA is in much of that equipment and material, providing a big, and largely unseen, part of a semiconductor fab’s processes. Wilmington, Delaware-based Chemours, a spinout of DuPont, is the only U.S. manufacturer of PFA. For Chemours, advanced materials including fluoropolymers represent roughly one- quarter of its total $6.3 billion (latest 12-months revenue) business, with refrigerants and titanium dioxide, used in paints and aerospace coatings, making up the bulk of the rest. Within that, semiconductors are part of its performance-solutions segment, which accounted for $493 million in sales for 2022, up 53% from $322 million in 2020. On its website, Chemours says flat-out that “without PFA, domestic semiconductor manufacturing would not be possible.” Last year, President Biden signed into law the CHIPS Act, which provides $52 billion in funding to spur domestic semiconductor manufacturing with a goal of improving national security by decreasing reliance on nations like China for critical technology. Chips are essential not just for our phones and computers, but also for medical devices and fighter jets. “Geopolitics has been defined by oil over the last 50 years,” Intel CEO Pat Gelsinger said at an MIT event earlier this year. “Technology supply chains are more important for a digital future than oil for the next 50 years.” But our insatiable desire for electronic devices and American policymakers’ push for more domestic manufacturing of semiconductors relies on the industry’s access to large amounts of “forever chemicals.” Wilmington, Delaware-based Chemours, a spinout of DuPont, is the only U.S. manufacturer of PFA. For Chemours, advanced materials including fluoropolymers represent roughly one- quarter of its total $6.3 billion (latest 12-months revenue) business, with refrigerants and titanium dioxide, used in paints and aerospace coatings, making up the bulk of the rest. Within that, semiconductors are part of its performance-solutions segment, which accounted for $493 million in sales for 2022, up 53% from $322 million in 2020. On its website, Chemours says flat-out that “without PFA, domestic semiconductor manufacturing would not be possible.” Last year, President Biden signed into law the CHIPS Act, which provides $52 billion in funding to spur domestic semiconductor manufacturing with a goal of improving national security by decreasing reliance on nations like China for critical technology. Chips are essential not just for our phones and computers, but also for medical devices and fighter jets. “Geopolitics has been defined by oil over the last 50 years,” Intel CEO Pat Gelsinger said at an MIT event earlier this year. “Technology supply chains are more important for a digital future than oil for the next 50 years.” But our insatiable desire for electronic devices and American policymakers’ push for more domestic manufacturing of semiconductors relies on the industry’s access to large amounts of “forever chemicals.” 2|Page 317 Ongoing Litigation Forever chemicals, or PFAS, comprise thousands of synthetic chemicals. They’re long-lasting and resistant to heat, corrosion and moisture, making them popular for a variety of products that include nonstick pans, stain-resistant upholstery, firefighting foam — and semiconductor production. Studies, however, have linked PFAS to a variety of diseases, including cancers and reduced immune system response, as well as to contaminated groundwater, air and soil that can lead to a host of health problems. PFAS are an enormous category. Fluoropolymers, like those that Chemours manufactures for industrial uses, are just one class. Litigation over their impact is ongoing. In June, Chemours, along with DuPont and another spinoff, Corteva, reached a $1.2 billion settlement with public water systems. Meanwhile, legislators and regulators have been cracking down on the chemicals’ use, particularly in consumer products such as clothing, furniture and textiles, where they can be more easily replaced. Minneapolis-based 3M, which in 2018 agreed to pay $850 million for damaging drinking water and natural resources in the Twin Cities area, announced that it would cease production of PFAS by the end of 2025. 2|Page 317 Ongoing Litigation Forever chemicals, or PFAS, comprise thousands of synthetic chemicals. They’re long-lasting and resistant to heat, corrosion and moisture, making them popular for a variety of products that include nonstick pans, stain-resistant upholstery, firefighting foam — and semiconductor production. Studies, however, have linked PFAS to a variety of diseases, including cancers and reduced immune system response, as well as to contaminated groundwater, air and soil that can lead to a host of health problems. PFAS are an enormous category. Fluoropolymers, like those that Chemours manufactures for industrial uses, are just one class. Litigation over their impact is ongoing. In June, Chemours, along with DuPont and another spinoff, Corteva, reached a $1.2 billion settlement with public water systems. Meanwhile, legislators and regulators have been cracking down on the chemicals’ use, particularly in consumer products such as clothing, furniture and textiles, where they can be more easily replaced. Minneapolis-based 3M, which in 2018 agreed to pay $850 million for damaging drinking water and natural resources in the Twin Cities area, announced that it would cease production of PFAS by the end of 2025. The semiconductor industry has pushed back against regulations here and in Europe, where regulators had proposed a ban on PFAS. When the U.S. Environmental Protection Agency asked for comments on tightened oversight on PFAS earlier this year by revoking certain low- volume exemptions, the microelectronics trade group SEMI called it “catastrophic” for domestic chip manufacturing. In a letter to the EPA, it said that such a rule “would significantly hamper the domestic semiconductor industry despite express goals of the Administration to the contrary and to the detriment of the U.S. economy.” Doubling Down In this landscape, Chemours’ Newman is doubling down. In a wide-ranging interview with Forbes during a trip to New York for Climate Week, Newman said that the $4 billion 3|Page 318 (market cap) company was expanding production of fluoropolymers, driven by the critical need for the chemicals in semiconductors and electric vehicles. Further, he said, such production could be done safely with investments that his company is making. It has, for example, invested more than $100 million in emissions control technology at its Fayetteville, North Carolina plant. The semiconductor industry has pushed back against regulations here and in Europe, where regulators had proposed a ban on PFAS. When the U.S. Environmental Protection Agency asked for comments on tightened oversight on PFAS earlier this year by revoking certain low- volume exemptions, the microelectronics trade group SEMI called it “catastrophic” for domestic chip manufacturing. In a letter to the EPA, it said that such a rule “would significantly hamper the domestic semiconductor industry despite express goals of the Administration to the contrary and to the detriment of the U.S. economy.” Doubling Down In this landscape, Chemours’ Newman is doubling down. In a wide-ranging interview with Forbes during a trip to New York for Climate Week, Newman said that the $4 billion 3|Page 318 (market cap) company was expanding production of fluoropolymers, driven by the critical need for the chemicals in semiconductors and electric vehicles. Further, he said, such production could be done safely with investments that his company is making. It has, for example, invested more than $100 million in emissions control technology at its Fayetteville, North Carolina plant. “We’re currently sold out and working to expand capacity here in the United States,” Newman said. Chemours plans to enlarge its West Virginia production facility, he said. Located just across the river from Ohio, the factory is well positioned to supply Intel’s giant chip fab near Columbus, now under construction. “Imagine making something for the semiconductor industry in what people think of as coal country,” Newman said. All told, the company is investing up to $1 billion in fluoropolymers, including those for use in semiconductors. The combination of reshoring and PFAS is “a very complicated discussion,” said Zhanyun Wang, a scientist and PFAS researcher with EMPA-Swiss Federal Laboratories for Materials Testing and Research. “There’s a lot of resistance from the industry because, of course, if we want to do the change, it costs.” That’s especially problematic if the United States and the European Union impose regulations and other parts of the world do not. However, he said, such regulations could be designed to spur new innovations. “The semiconductor industry has a lot of R&D power,” he said. “We’re currently sold out and working to expand capacity here in the United States,” Newman said. Chemours plans to enlarge its West Virginia production facility, he said. Located just across the river from Ohio, the factory is well positioned to supply Intel’s giant chip fab near Columbus, now under construction. “Imagine making something for the semiconductor industry in what people think of as coal country,” Newman said. All told, the company is investing up to $1 billion in fluoropolymers, including those for use in semiconductors. The combination of reshoring and PFAS is “a very complicated discussion,” said Zhanyun Wang, a scientist and PFAS researcher with EMPA-Swiss Federal Laboratories for Materials Testing and Research. “There’s a lot of resistance from the industry because, of course, if we want to do the change, it costs.” That’s especially problematic if the United States and the European Union impose regulations and other parts of the world do not. However, he said, such regulations could be designed to spur new innovations. “The semiconductor industry has a lot of R&D power,” he said. In July 2015, when industrial giant DuPont spun off its performance chemicals division and named it Chemours for “chemistry” plus the “Nemours” part of DuPont’s full name, the new company was saddled with debt and potentially toxic assets. “I think investors were worried if we were going to be solvent,” then-CEO Mark Vergnano told Fortune in 2016. “Were we going to make it through this or not?” Vergnano proceeded to pull off a dramatic turnaround by slashing costs, selling off non-essential businesses and gaining market share for its refrigerants business. 4|Page 319 Big Expense Newman, who had been the company’s chief financial officer during those years and is one of the country’s top Black executives, became CEO in 2021. The company’s revenue ballooned to a peak of $6.8 billion in 2022, driven by strong pricing. Its advanced performance materials business, which includes the Teflon lineup of fluorine chemicals, gained price increases of 18% and reached total sales of $1.6 billion as it focused on high-tech markets including advanced electronics and clean energy. In July 2015, when industrial giant DuPont spun off its performance chemicals division and named it Chemours for “chemistry” plus the “Nemours” part of DuPont’s full name, the new company was saddled with debt and potentially toxic assets. “I think investors were worried if we were going to be solvent,” then-CEO Mark Vergnano told Fortune in 2016. “Were we going to make it through this or not?” Vergnano proceeded to pull off a dramatic turnaround by slashing costs, selling off non-essential businesses and gaining market share for its refrigerants business. 4|Page 319 Big Expense Newman, who had been the company’s chief financial officer during those years and is one of the country’s top Black executives, became CEO in 2021. The company’s revenue ballooned to a peak of $6.8 billion in 2022, driven by strong pricing. Its advanced performance materials business, which includes the Teflon lineup of fluorine chemicals, gained price increases of 18% and reached total sales of $1.6 billion as it focused on high-tech markets including advanced electronics and clean energy. The semiconductor industry “didn’t want to use fluoropolymers, not because they were concerned about them, but because fluoropolymers are expensive,” said Gerardo Familiar, president of Chemours’ Advanced Performance Materials division, which includes fluorine chemicals. But alternatives have been scarce because of fluoropolymers’ resistance to corrosion and ability to work at high temperatures and to last for a long time. He said that fluoropolymers like PFA are “substances of low concern,” and that they should be considered differently than PFAS. “Those materials last a very, very, very long time, but they make your manufacturing very, very, very safe for the people who are there because you don’t have an issue with corrosion,” he said. The conundrum, he said, is how to manufacture them responsibly and what to do with the materials at the end of their life. The semiconductor industry “didn’t want to use fluoropolymers, not because they were concerned about them, but because fluoropolymers are expensive,” said Gerardo Familiar, president of Chemours’ Advanced Performance Materials division, which includes fluorine chemicals. But alternatives have been scarce because of fluoropolymers’ resistance to corrosion and ability to work at high temperatures and to last for a long time. He said that fluoropolymers like PFA are “substances of low concern,” and that they should be considered differently than PFAS. “Those materials last a very, very, very long time, but they make your manufacturing very, very, very safe for the people who are there because you don’t have an issue with corrosion,” he said. The conundrum, he said, is how to manufacture them responsibly and what to do with the materials at the end of their life. Some smaller companies are working on replacing PFAS in electronics manufacturing. Danvers, Massachusetts-based Transene, a privately held business founded in 1965, partnered with Toxics Use Reduction Institute (TURI) researchers at University of Massachusetts Lowell to develop alternatives for its etching solutions used in the semiconductor industry. The vast majority of customers have made the switch, and others are working through their qualification process. “You keep hearing from the industry, ‘We need 10 or 15 years to make a change,’” said Greg Morose, research professor at UMass Lowell and research manager at TURI, who worked with Transene. “We basically did the research in 18 months, which is really rapid.” 5|Page 320 Phasing Out PFAS But that’s just one small company, and one use of PFAS within a semiconductor fab. David Zamarin, founder of venture-backed DetraPel, which works on sustainable coatings for food packaging and textiles, said he received inquiries from semiconductor and electronics manufacturers, but that the cost and time didn’t make it economically viable. In the electronics industry, even companies that have set goals of getting rid of PFAS are moving slowly. Apple, for example, has promised to “thoughtfully phase out PFAS in a way that does not result in regrettable substitutions.” Some smaller companies are working on replacing PFAS in electronics manufacturing. Danvers, Massachusetts-based Transene, a privately held business founded in 1965, partnered with Toxics Use Reduction Institute (TURI) researchers at University of Massachusetts Lowell to develop alternatives for its etching solutions used in the semiconductor industry. The vast majority of customers have made the switch, and others are working through their qualification process. “You keep hearing from the industry, ‘We need 10 or 15 years to make a change,’” said Greg Morose, research professor at UMass Lowell and research manager at TURI, who worked with Transene. “We basically did the research in 18 months, which is really rapid.” 5|Page 320 Phasing Out PFAS But that’s just one small company, and one use of PFAS within a semiconductor fab. David Zamarin, founder of venture-backed DetraPel, which works on sustainable coatings for food packaging and textiles, said he received inquiries from semiconductor and electronics manufacturers, but that the cost and time didn’t make it economically viable. In the electronics industry, even companies that have set goals of getting rid of PFAS are moving slowly. Apple, for example, has promised to “thoughtfully phase out PFAS in a way that does not result in regrettable substitutions.” Newman said that fluorine chemicals can be made responsibly. Chemours has committed to eliminating at least 99% of PFAS air and water emissions from its manufacturing processes by 2030. Chemours is also working on sustainable technologies, he said, such as renewable membranes for green hydrogen production marketed under the Nafion brand name and low- global-warming refrigerants for heating and cooling buildings. “We felt because of our legacy we needed to lean into this mantra of being a different kind of chemistry company and showcasing the fact that we could be a leader in emissions reduction,” Newman said. “Our chemistry really enables a lot of the future economy.” 6|Page 321 Newman said that fluorine chemicals can be made responsibly. Chemours has committed to eliminating at least 99% of PFAS air and water emissions from its manufacturing processes by 2030. Chemours is also working on sustainable technologies, he said, such as renewable membranes for green hydrogen production marketed under the Nafion brand name and low- global-warming refrigerants for heating and cooling buildings. “We felt because of our legacy we needed to lean into this mantra of being a different kind of chemistry company and showcasing the fact that we could be a leader in emissions reduction,” Newman said. “Our chemistry really enables a lot of the future economy.” 6|Page 321 CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT A project of the Pacific Studies Center P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 http://www.cpeo.org TO: Micron Project, Office of Economic Development, Onondaga County FROM: Lenny Siegel, Center for Public Environmental Oversight DATE: October 30, 2023 SUBJECT: SEQRA Scope of Work for Micron Semiconductor Fabrication Thank you for the opportunity to comment on the September 12, 2023 Draft SEQRA Scope of Work for Micron Semiconductor Fabrication. I have been asked by residents of Onondoga County to offer my comments. I have nearly five decades of experience monitoring and influencing the worker health and environmental impacts of the semiconductor industry, through the Pacific Studies Center, the Project on Health and Safety in Electronics, the Silicon Valley Toxics Coalition, and the Center for Public Environmental Oversight, as well as my service as Council Member and Mayor of Mountain View, the birthplace of the commercial semiconductor industry. CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT A project of the Pacific Studies Center P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 http://www.cpeo.org TO: Micron Project, Office of Economic Development, Onondaga County FROM: Lenny Siegel, Center for Public Environmental Oversight DATE: October 30, 2023 SUBJECT: SEQRA Scope of Work for Micron Semiconductor Fabrication Thank you for the opportunity to comment on the September 12, 2023 Draft SEQRA Scope of Work for Micron Semiconductor Fabrication. I have been asked by residents of Onondoga County to offer my comments. I have nearly five decades of experience monitoring and influencing the worker health and environmental impacts of the semiconductor industry, through the Pacific Studies Center, the Project on Health and Safety in Electronics, the Silicon Valley Toxics Coalition, and the Center for Public Environmental Oversight, as well as my service as Council Member and Mayor of Mountain View, the birthplace of the commercial semiconductor industry. The semiconductor industry produces remarkable products that we all use. Unfortunately, its environmental and workplace health record is less than remarkable. The MEW Superfund Area here in Mountain View was the home of some of the earliest successful integrated circuit manufacturers. The wafer fabs are gone, but despite the scores (hundreds?) of millions of dollars spent thus far on subsurface remediation, the contamination—including the risk of public exposure—will remain for decades more, if not longer. The same is true at other Silicon Valley sites. The SEQRA process provides an opportunity to identify and minimize, in advance, the environmental hazards of semiconductor production. By doing so, it can lead to appropriate regulation, research on waste management and pollution prevention, and investments in safer facilities. Semiconductor production is essentially a series of chemical processes that use a wide variety of hazardous substances. The industry explains, “While in the 1980s semiconductor fabs used 322 2 The semiconductor industry produces remarkable products that we all use. Unfortunately, its environmental and workplace health record is less than remarkable. The MEW Superfund Area here in Mountain View was the home of some of the earliest successful integrated circuit manufacturers. The wafer fabs are gone, but despite the scores (hundreds?) of millions of dollars spent thus far on subsurface remediation, the contamination—including the risk of public exposure—will remain for decades more, if not longer. The same is true at other Silicon Valley sites. The SEQRA process provides an opportunity to identify and minimize, in advance, the environmental hazards of semiconductor production. By doing so, it can lead to appropriate regulation, research on waste management and pollution prevention, and investments in safer facilities. Semiconductor production is essentially a series of chemical processes that use a wide variety of hazardous substances. The industry explains, “While in the 1980s semiconductor fabs used 322 2 fewer than 20 elements, today they are using over 50% of the nonradioactive elements in the periodic table.”1 Those include toxic heavy metals. The industry is a major user of Per- and Polyfluorinated Substances (PFAS), also known as “Forever Chemicals” because they persist and bioaccumulate in the environment and even human bloodstreams. As New York state agencies are well aware, these compounds are toxic, even at extremely low exposure concentrations, through multiple pathways. But industry has become reliant on PFAS without first examining the human and environmental risks. It explains, “Without PFAS, the ability to produce semiconductors (and the facilities and equipment related to and supporting semiconductor manufacturing) would be put at risk.”2 Use and release of the industry’s hazardous building blocks are regulated by both state and federal statutes and regulations, but the public is generally unaware of the series of upcoming permit applications that Micron is expecting to make. The SEQRA review should list all anticipated permitting processes, with the anticipated schedule of public comment periods, and it should require public notification to interested parties of each permit application as it is submitted. fewer than 20 elements, today they are using over 50% of the nonradioactive elements in the periodic table.”1 Those include toxic heavy metals. The industry is a major user of Per- and Polyfluorinated Substances (PFAS), also known as “Forever Chemicals” because they persist and bioaccumulate in the environment and even human bloodstreams. As New York state agencies are well aware, these compounds are toxic, even at extremely low exposure concentrations, through multiple pathways. But industry has become reliant on PFAS without first examining the human and environmental risks. It explains, “Without PFAS, the ability to produce semiconductors (and the facilities and equipment related to and supporting semiconductor manufacturing) would be put at risk.”2 Use and release of the industry’s hazardous building blocks are regulated by both state and federal statutes and regulations, but the public is generally unaware of the series of upcoming permit applications that Micron is expecting to make. The SEQRA review should list all anticipated permitting processes, with the anticipated schedule of public comment periods, and it should require public notification to interested parties of each permit application as it is submitted. It should also identify hazardous substances, whether or not they currently have promulgated exposure standards. For example, the industry reports, “Most PFAS are not regulated pollutants and therefore unless company specific provisions are in place, the wastewater from processes that use aqueous wet chemical formulations that contain PFAS would likely be discharged to the publicly owned treatment works without substantive removal of the PFAS.”3 Furthermore, potential workplace exposures should not be ignored because exposures are below the Occupational Exposure Level (OEL) or even a fraction of the OEL, as industry suggests.4 In most cases OELs, such as the Occupational Safety and Health Administration’s (OSHA) Permissible Exposure Limits (PELs), are orders of magnitude above what the science— including U.S. EPA studies—dictates. While the draft Scope of Work proposes many useful Technical Chapters, there is room for more specificity. I focus on the use and release of hazardous substances. For Solid Wastes and Hazardous Materials, the Scope of Work states, “The chapter will identify any hazardous materials (including any chemical or petroleum bulk storage) that would be used, stored, transported, or generated by the Proposed Project and measures to protect It should also identify hazardous substances, whether or not they currently have promulgated exposure standards. For example, the industry reports, “Most PFAS are not regulated pollutants and therefore unless company specific provisions are in place, the wastewater from processes that use aqueous wet chemical formulations that contain PFAS would likely be discharged to the publicly owned treatment works without substantive removal of the PFAS.”3 Furthermore, potential workplace exposures should not be ignored because exposures are below the Occupational Exposure Level (OEL) or even a fraction of the OEL, as industry suggests.4 In most cases OELs, such as the Occupational Safety and Health Administration’s (OSHA) Permissible Exposure Limits (PELs), are orders of magnitude above what the science— including U.S. EPA studies—dictates. While the draft Scope of Work proposes many useful Technical Chapters, there is room for more specificity. I focus on the use and release of hazardous substances. For Solid Wastes and Hazardous Materials, the Scope of Work states, “The chapter will identify any hazardous materials (including any chemical or petroleum bulk storage) that would be used, stored, transported, or generated by the Proposed Project and measures to protect 1 “Background on Semiconductor Manufacturing and PFAS,” Semiconductor Association (SIA) PFAS Consortium, May 17, 2023, p. 54. The SIA PFAS Consortium is made up of chipmakers and their suppliers of equipment and materials. To sign up to receive their technical papers, go to https://www.semiconductors.org/pfas/ . I am attaching this document. 2 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 3. I am also attaching this document. 3 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 3 4 “Background on Semiconductor Manufacturing and PFAS,” SIA PFAS Consortium, May 17, 2023, p. 25. 323 3 against releases to the environment. Any warranted remedial approaches for addressing identified or potential contaminated materials would be described.” I suggest that the Review describe any permitting required for the Treatment, Storage, and Disposal of hazardous materials and solid wastes, and that it list the storage requirements, such as double-walled tanks and piping, necessary to prevent environmental releases. Furthermore, how will employees be educated about the risk from leaks and spills, as well as what to do when they occur? 1 “Background on Semiconductor Manufacturing and PFAS,” Semiconductor Association (SIA) PFAS Consortium, May 17, 2023, p. 54. The SIA PFAS Consortium is made up of chipmakers and their suppliers of equipment and materials. To sign up to receive their technical papers, go to https://www.semiconductors.org/pfas/ . I am attaching this document. 2 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 3. I am also attaching this document. 3 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 3 4 “Background on Semiconductor Manufacturing and PFAS,” SIA PFAS Consortium, May 17, 2023, p. 25. 323 3 against releases to the environment. Any warranted remedial approaches for addressing identified or potential contaminated materials would be described.” I suggest that the Review describe any permitting required for the Treatment, Storage, and Disposal of hazardous materials and solid wastes, and that it list the storage requirements, such as double-walled tanks and piping, necessary to prevent environmental releases. Furthermore, how will employees be educated about the risk from leaks and spills, as well as what to do when they occur? To what degree will disposal—including landfilling and incineration—create off-site hazards? Industry reports, “Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerized to be treated at an offsite licensed treatment and disposal facility, as a blended fuel by high temperature incineration or reprocessing.”5 Perfluorinated compounds are particularly difficult to destroy using incineration. Furthermore, even when permitted by regulatory agencies, incineration may release products of incomplete combustion into the atmosphere. For Air Quality, the Scope of Work barely mentions the potential emissions of highly toxic air contaminants. Historically the industry has used lethal gases such as arsine and phosphine, as well as toxic gases such as hydrogen chloride (the gaseous form of hydrochloric acid). Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipment to respond safely to such releases. Employees should be warned about the toxicity of gases used by the industry and trained to protect themselves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity. To what degree will disposal—including landfilling and incineration—create off-site hazards? Industry reports, “Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerized to be treated at an offsite licensed treatment and disposal facility, as a blended fuel by high temperature incineration or reprocessing.”5 Perfluorinated compounds are particularly difficult to destroy using incineration. Furthermore, even when permitted by regulatory agencies, incineration may release products of incomplete combustion into the atmosphere. For Air Quality, the Scope of Work barely mentions the potential emissions of highly toxic air contaminants. Historically the industry has used lethal gases such as arsine and phosphine, as well as toxic gases such as hydrogen chloride (the gaseous form of hydrochloric acid). Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipment to respond safely to such releases. Employees should be warned about the toxicity of gases used by the industry and trained to protect themselves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity. I am surprised and disappointed that no chapter is listed for Wastewater and Stormwater. The release of toxic contaminants through water pathways is one of the most serious threats of semiconductor productions. Releases of certain contaminants in wastewater could compromise the operations of the Oak Orchard Wastewater Treatment Plant, even undermining compliance with its discharge permit. The draft Scope of Work mentions industrial pre-treatment. Not only should that be described in an environmental review chapter, but the review should identify ways to pre-treat hazardous chemicals, perhaps even reusing some, before comingling with other wastes. This is particularly important for PFAS, because in the future more PFAS compounds are likely to be subjected to enforceable environmental standards, many at very low concentrations. In fact, given the vast number of PFAS used by the semiconductor industry, the Review should identify methods for sampling total organic fluorine, not just targeted compounds. “At present, only a small percentage of PFAS compounds within typical semiconductor wastewater are detectable and quantifiable using conventional U.S. EPA analytical methods for PFAS-containing 5 “Background on Semiconductor Manufacturing and PFAS,” SIA PFAS Consortium, May 17, 2023, p. 30. 324 4 I am surprised and disappointed that no chapter is listed for Wastewater and Stormwater. The release of toxic contaminants through water pathways is one of the most serious threats of semiconductor productions. Releases of certain contaminants in wastewater could compromise the operations of the Oak Orchard Wastewater Treatment Plant, even undermining compliance with its discharge permit. The draft Scope of Work mentions industrial pre-treatment. Not only should that be described in an environmental review chapter, but the review should identify ways to pre-treat hazardous chemicals, perhaps even reusing some, before comingling with other wastes. This is particularly important for PFAS, because in the future more PFAS compounds are likely to be subjected to enforceable environmental standards, many at very low concentrations. In fact, given the vast number of PFAS used by the semiconductor industry, the Review should identify methods for sampling total organic fluorine, not just targeted compounds. “At present, only a small percentage of PFAS compounds within typical semiconductor wastewater are detectable and quantifiable using conventional U.S. EPA analytical methods for PFAS-containing 5 “Background on Semiconductor Manufacturing and PFAS,” SIA PFAS Consortium, May 17, 2023, p. 30. 324 4 materials.”6 However, U.S. EPA has a draft method (1621) for measuring total organic fluorine.7 Furthermore, academic researchers are finding that failure to measure total fluorine misses discharges of significant quantities of PFAS pollutants. “[B]ecause many studies of total organic fluorine have shown that total PFAS concentrations are at least 10 times higher than the sum of target PFASs. However, this does reinforce the idea that PFAS monitoring should incorporate complementary target and nontarget analyses or otherwise include measures of total organic fluorine to accurately assess PFAS abundance and potential environmental impacts.”8 Furthermore, there should be a chapter on Life-Cycle Environmental Impacts. What hazardous substances remain in the finished semiconductor products, including packaging. At the end-of- life, are there mechanisms for preventing the environmental release of semiconductor hazardous substances? Industry’s PFAS Consortium reports, “At the end-of-life of the product containing the semiconductor, or any parts replaced during the manufacture of semiconductors, would enter waste disposal streams where any PFAS contained therein could enter the environment.”9 Are manufacturers responsible for end-of-life pollution? materials.”6 However, U.S. EPA has a draft method (1621) for measuring total organic fluorine.7 Furthermore, academic researchers are finding that failure to measure total fluorine misses discharges of significant quantities of PFAS pollutants. “[B]ecause many studies of total organic fluorine have shown that total PFAS concentrations are at least 10 times higher than the sum of target PFASs. However, this does reinforce the idea that PFAS monitoring should incorporate complementary target and nontarget analyses or otherwise include measures of total organic fluorine to accurately assess PFAS abundance and potential environmental impacts.”8 Furthermore, there should be a chapter on Life-Cycle Environmental Impacts. What hazardous substances remain in the finished semiconductor products, including packaging. At the end-of- life, are there mechanisms for preventing the environmental release of semiconductor hazardous substances? Industry’s PFAS Consortium reports, “At the end-of-life of the product containing the semiconductor, or any parts replaced during the manufacture of semiconductors, would enter waste disposal streams where any PFAS contained therein could enter the environment.”9 Are manufacturers responsible for end-of-life pollution? Finally, there are those who argue that a thorough environmental review, as I have suggested, would unnecessarily delay the operation of new, advanced wafer fabrication plants. I find it hard to believe that documenting potential hazardous substance and waste impacts in advance would hamper the construction of a factory that is not expected to begin production until 2032. Micron—indeed, all semiconductor manufacturers—should already know what hazardous substances it uses and releases. Shouldn’t the public also know? The semiconductor and computer manufacturing industry, such as IBM’s complex in Endicott, New York, has a long history of causing pollution that threatens public health and the environment. An industry that claims that PFAS—chemicals that are persistent, bioaccumulative, and extremely toxic in low concentrations—are essential to its operations should be required to come clean about its environmental and public health hazards. Finally, there are those who argue that a thorough environmental review, as I have suggested, would unnecessarily delay the operation of new, advanced wafer fabrication plants. I find it hard to believe that documenting potential hazardous substance and waste impacts in advance would hamper the construction of a factory that is not expected to begin production until 2032. Micron—indeed, all semiconductor manufacturers—should already know what hazardous substances it uses and releases. Shouldn’t the public also know? The semiconductor and computer manufacturing industry, such as IBM’s complex in Endicott, New York, has a long history of causing pollution that threatens public health and the environment. An industry that claims that PFAS—chemicals that are persistent, bioaccumulative, and extremely toxic in low concentrations—are essential to its operations should be required to come clean about its environmental and public health hazards. 6 “PFOS and PFOA Conversion to Short-Chain PFAS-Containing Materials Used in Semiconductor Manufacturing,” SIA PFAS Consortium, June 5, 2023, p. 11. 7 Draft Method 1621: Screening Method for the Determination of Adsorbable Organic Fluorine (AOF) in Aqueous Matrices by Combustion Ion Chromatography (CIC), U.S. EPA, April 2022, https://www.epa.gov/system/files/documents/2022-04/draft-method-1621-for-screening-aof- in-aqueous-matrices-by-cic_0.pdf 8 Paige Jacob, Kristas Barzen-Hanson, and Damian Helbling, “Target and Nontarget Analysis of Per- and Polyfluoralkyl Substances in Wastewater from Electronics Fabrication Facilities,” Environmental Science & Technology, February 16, 2021, p. 2353. https://pubs.acs.org/doi/10.1021/acs.est.0c06690 9 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 90, 325 6 “PFOS and PFOA Conversion to Short-Chain PFAS-Containing Materials Used in Semiconductor Manufacturing,” SIA PFAS Consortium, June 5, 2023, p. 11. 7 Draft Method 1621: Screening Method for the Determination of Adsorbable Organic Fluorine (AOF) in Aqueous Matrices by Combustion Ion Chromatography (CIC), U.S. EPA, April 2022, https://www.epa.gov/system/files/documents/2022-04/draft-method-1621-for-screening-aof- in-aqueous-matrices-by-cic_0.pdf 8 Paige Jacob, Kristas Barzen-Hanson, and Damian Helbling, “Target and Nontarget Analysis of Per- and Polyfluoralkyl Substances in Wastewater from Electronics Fabrication Facilities,” Environmental Science & Technology, February 16, 2021, p. 2353. https://pubs.acs.org/doi/10.1021/acs.est.0c06690 9 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 90, 325 REVIEW Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng Cornell University, Department of Material Science and Engineering, Ithaca, New York, United States REVIEW Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng Cornell University, Department of Material Science and Engineering, Ithaca, New York, United States Abstract. We identify and describe categories of fluorochemicals used to produce advanced semiconductors within the lithographic patterning manufacturing processes. Topics discussed include the per- and polyfluoroalkyl substance (PFAS) materials used and their necessary attrib- utes for successful semiconductor manufacturing, consisting of photoacid generators, fluorinated polyimides, poly(benzoxazole)s, antireflection coatings, topcoats, and embedded barrier layers, fluorinated surfactants, and materials for nanoimprint lithography. In particular, an explanation is given of the particular function that these PFAS materials contribute. It is noted that in almost all cases fluorine-free alternatives are very unlikely to provide the essential properties present in PFAS systems. Nonfluorinated alternative compounds are discussed where available. Finally, a summary table is provided listing the families of materials discussed, the critical purpose served, what the PFAS compound provides, and the prospects for alternatives. © The Authors. Published by SPIE under a Creative Commons Attribution 4.0 International License. Distribution or repro- duction of this work in whole or in part requires full attribution of the original publication, including its DOI. [DOI: 10.1117/1.JMM.21.1.010901] Keywords: fluorochemicals; per- and polyfluoroalkyl substance; photolithography; semicon- ductor processing. Paper 22003V received Jan. 21, 2022; accepted for publication Mar. 3, 2022; published online Mar. 31, 2022. Abstract. We identify and describe categories of fluorochemicals used to produce advanced semiconductors within the lithographic patterning manufacturing processes. Topics discussed include the per- and polyfluoroalkyl substance (PFAS) materials used and their necessary attrib- utes for successful semiconductor manufacturing, consisting of photoacid generators, fluorinated polyimides, poly(benzoxazole)s, antireflection coatings, topcoats, and embedded barrier layers, fluorinated surfactants, and materials for nanoimprint lithography. In particular, an explanation is given of the particular function that these PFAS materials contribute. It is noted that in almost all cases fluorine-free alternatives are very unlikely to provide the essential properties present in PFAS systems. Nonfluorinated alternative compounds are discussed where available. Finally, a summary table is provided listing the families of materials discussed, the critical purpose served, what the PFAS compound provides, and the prospects for alternatives. © The Authors. Published by SPIE under a Creative Commons Attribution 4.0 International License. Distribution or repro- duction of this work in whole or in part requires full attribution of the original publication, including its DOI. [DOI: 10.1117/1.JMM.21.1.010901] Keywords: fluorochemicals; per- and polyfluoroalkyl substance; photolithography; semicon- ductor processing. Paper 22003V received Jan. 21, 2022; accepted for publication Mar. 3, 2022; published online Mar. 31, 2022. 1 Introduction The use of fluorochemicals in lithography and semiconductor patterning plays a critical role in the success of semiconductor technology. The addition of small quantities of fluorinated mate- rials enables patterning capabilities that are otherwise not possible to achieve, and this leads to superior device performance. The compact size of the fluorine atom and its strong electron- withdrawing characteristics make it stand out in the periodic table and gives fluorocarbon mate- rials unique properties, unmatched by other chemical compounds. Fluorochemicals have found use in semiconductor processing for good technical reasons. 1 Introduction The use of fluorochemicals in lithography and semiconductor patterning plays a critical role in the success of semiconductor technology. The addition of small quantities of fluorinated mate- rials enables patterning capabilities that are otherwise not possible to achieve, and this leads to superior device performance. The compact size of the fluorine atom and its strong electron- withdrawing characteristics make it stand out in the periodic table and gives fluorocarbon mate- rials unique properties, unmatched by other chemical compounds. Fluorochemicals have found use in semiconductor processing for good technical reasons. 1. The presence of fluorine near acidic groups can convert them from an acid to a superacid, an essential characteristic for photoacid generators (PAGs) needed in advanced photoresists. 2. Fluorocarbon materials have low surface energy characteristics and act as superior barrier layers (including water repellence), which provide useful properties in photoresists and in antireflection coatings used in immersion lithography while also providing excellent release properties because they do not adhere strongly to other materials. 3. Fluorinated materials have unique solubility characteristics and can prevent intermixing between layers in a complex system such as an antireflection coating. Fluorinated materi- als are both hydrophobic and oleophobic and thus have reduced or no miscibility with essentially all fluorine-free classes of polymers. 4. Fluoropolymers have a low refractive index compared with any material except air and provide useful optical properties in photoresists and antireflection coatings. 5. They possess low dielectric constant and are especially good electrical insulators, an important feature when polyimides are patterned and retained in the final device. 1. The presence of fluorine near acidic groups can convert them from an acid to a superacid, an essential characteristic for photoacid generators (PAGs) needed in advanced photoresists. 2. Fluorocarbon materials have low surface energy characteristics and act as superior barrier layers (including water repellence), which provide useful properties in photoresists and in antireflection coatings used in immersion lithography while also providing excellent release properties because they do not adhere strongly to other materials. 3. Fluorinated materials have unique solubility characteristics and can prevent intermixing between layers in a complex system such as an antireflection coating. Fluorinated materi- als are both hydrophobic and oleophobic and thus have reduced or no miscibility with essentially all fluorine-free classes of polymers. 4. Fluoropolymers have a low refractive index compared with any material except air and provide useful optical properties in photoresists and antireflection coatings. 5. They possess low dielectric constant and are especially good electrical insulators, an important feature when polyimides are patterned and retained in the final device. *Address all correspondence to Christopher K. Ober, c.ober@cornell.edu J. Micro/Nanopattern. Mater. Metrol. 010901-1 Jan–Mar 2022 • Vol. 21(1) 326 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . *Address all correspondence to Christopher K. Ober, c.ober@cornell.edu J. Micro/Nanopattern. Mater. Metrol. 010901-1 Jan–Mar 2022 • Vol. 21(1) 326 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . This document provides a systematic overview of the photolithography process and key fluorinated materials involved, provides insight into performance requirements, and describes why fluorinated chemicals help achieve needed characteristics. Photolithography, a critical process step in the production of a semiconductor, uses a photo- resist to transfer a pattern. The primary component of a photoresist is a photopolymer whose solubility will be changed upon exposure to short wavelength radiation. In addition, the photo- resist contains a deposition solvent and several small-molecule compounds. The desired solu- bility change must be great enough that a developer (a solvent that removes the unwanted region of a resist pattern) does not swell the remaining photoresist. The development process must be able to discriminate between exposed and unexposed regions as small as a few nanometers in size. The unremoved photoresist must protect the underlying substrate from the next process steps in semiconductor manufacturing. Each stage in the process must be virtually perfect with yields well above 99%, because there may be hundreds of process steps used to manufacture each advanced semiconductor device. Without those very high yields, semiconductor manufac- turing would fail. The basic lithography process used globally today for advanced semiconductor manufactur- ing and the foreseeable future employs chemically amplified photoresists. Chemical amplifica- tion was a key invention needed to overcome the challenge of limited light sources but was also found to provide superior patterning performance. In such resist systems a photopolymer that contains acid cleavable protecting groups is combined with a photoactive compound, such as a PAG. In its native state, the photoresist polymer with protecting groups is soluble in organic solvents. Upon exposure to UV radiation, the PAG releases acid. Frequently, a subsequent post- exposure bake (PEB) step leads to the acid-catalyzed removal of protecting groups, thereby transforming the hydrophobic photopolymer into one that is soluble in an aqueous base devel- oper. The single photon of light needed to release one acidic proton is “amplified” by the more efficient acid-catalyzed deprotection process. By transforming the solubility of the photoresist, a high contrast patterning process needed in semiconductor manufacturing becomes possible. The combination of photoresist polymer and PAG to make the photoresist system is an essential part of this process and fluorination in the PAG provides the high acidity necessary for chemical amplification to work and will be described subsequently. The lithographic process is a complex series of steps requiring, at times, several complex properties in a single material or other cases combination of different materials used in the same process step. An example of the latter can be represented by the use of an antireflective coating in combination with a photoresist. An antireflection coating (ARC) is important to prevent light reflected from the semiconductor substrate, which would otherwise alter the very precise molecular scale patterns required for today’s semiconductor devices. An ARC does this by min- imizing the refractive index difference across each interface of all layers in the system. As an example, a top ARC (TARC) is a layer that sits on top of the already complex photoresist. It must not intermix with the photoresist, and it can also serve as a protective layer for this complex, multilayer lithographic system. Finally, it must be easily removed. Only a fluorinated material has a significantly lower refractive index and fluorination also provides these additional proper- ties. More details for ARCs will be discussed below. Additional uses of fluorochemicals in photolithography processes are also discussed in this paper. It is worth noting that while there are many types of fluorochemicals, our survey of the technical literature reveals that there are several specific examples of fluorocompounds that are currently in use by the semiconductor industry in the lithography process including (1) perfluor- oalkyl acid compounds (C4 or less), used in PAGs; (2) hexafluoroisopropanol, fluorotelomers, and fluoroacrylate side-chain units may be used in photoresists to incorporate specific function- alities including barrier properties and low surface energy; (3) hexafluoropropyl units are used in sub-units of some classes of polyimides for thermal stability and low dielectric constant; (4) spe- cialized per- and polyfluoroalkyl substances (PFAS) are used in ARCs; (5) PFAS are also include surfactants (used as coating leveling agents) to improve coating uniformity in a number of prod- ucts used in lithographic processes. A key feature of the addition of a fluorinated component is that its addition provides a necessary additional characteristic to the material while minimally compromising its other critical properties. Examples of these materials and uses are tabulated in This document provides a systematic overview of the photolithography process and key fluorinated materials involved, provides insight into performance requirements, and describes why fluorinated chemicals help achieve needed characteristics. Photolithography, a critical process step in the production of a semiconductor, uses a photo- resist to transfer a pattern. The primary component of a photoresist is a photopolymer whose solubility will be changed upon exposure to short wavelength radiation. In addition, the photo- resist contains a deposition solvent and several small-molecule compounds. The desired solu- bility change must be great enough that a developer (a solvent that removes the unwanted region of a resist pattern) does not swell the remaining photoresist. The development process must be able to discriminate between exposed and unexposed regions as small as a few nanometers in size. The unremoved photoresist must protect the underlying substrate from the next process steps in semiconductor manufacturing. Each stage in the process must be virtually perfect with yields well above 99%, because there may be hundreds of process steps used to manufacture each advanced semiconductor device. Without those very high yields, semiconductor manufac- turing would fail. The basic lithography process used globally today for advanced semiconductor manufactur- ing and the foreseeable future employs chemically amplified photoresists. Chemical amplifica- tion was a key invention needed to overcome the challenge of limited light sources but was also found to provide superior patterning performance. In such resist systems a photopolymer that contains acid cleavable protecting groups is combined with a photoactive compound, such as a PAG. In its native state, the photoresist polymer with protecting groups is soluble in organic solvents. Upon exposure to UV radiation, the PAG releases acid. Frequently, a subsequent post- exposure bake (PEB) step leads to the acid-catalyzed removal of protecting groups, thereby transforming the hydrophobic photopolymer into one that is soluble in an aqueous base devel- oper. The single photon of light needed to release one acidic proton is “amplified” by the more efficient acid-catalyzed deprotection process. By transforming the solubility of the photoresist, a high contrast patterning process needed in semiconductor manufacturing becomes possible. The combination of photoresist polymer and PAG to make the photoresist system is an essential part of this process and fluorination in the PAG provides the high acidity necessary for chemical amplification to work and will be described subsequently. The lithographic process is a complex series of steps requiring, at times, several complex properties in a single material or other cases combination of different materials used in the same process step. An example of the latter can be represented by the use of an antireflective coating in combination with a photoresist. An antireflection coating (ARC) is important to prevent light reflected from the semiconductor substrate, which would otherwise alter the very precise molecular scale patterns required for today’s semiconductor devices. An ARC does this by min- imizing the refractive index difference across each interface of all layers in the system. As an example, a top ARC (TARC) is a layer that sits on top of the already complex photoresist. It must not intermix with the photoresist, and it can also serve as a protective layer for this complex, multilayer lithographic system. Finally, it must be easily removed. Only a fluorinated material has a significantly lower refractive index and fluorination also provides these additional proper- ties. More details for ARCs will be discussed below. Additional uses of fluorochemicals in photolithography processes are also discussed in this paper. It is worth noting that while there are many types of fluorochemicals, our survey of the technical literature reveals that there are several specific examples of fluorocompounds that are currently in use by the semiconductor industry in the lithography process including (1) perfluor- oalkyl acid compounds (C4 or less), used in PAGs; (2) hexafluoroisopropanol, fluorotelomers, and fluoroacrylate side-chain units may be used in photoresists to incorporate specific function- alities including barrier properties and low surface energy; (3) hexafluoropropyl units are used in sub-units of some classes of polyimides for thermal stability and low dielectric constant; (4) spe- cialized per- and polyfluoroalkyl substances (PFAS) are used in ARCs; (5) PFAS are also include surfactants (used as coating leveling agents) to improve coating uniformity in a number of prod- ucts used in lithographic processes. A key feature of the addition of a fluorinated component is that its addition provides a necessary additional characteristic to the material while minimally compromising its other critical properties. Examples of these materials and uses are tabulated in J. Micro/Nanopattern. Mater. Metrol. 010901-2 Jan–Mar 2022 • Vol. 21(1) 327 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-2 Jan–Mar 2022 • Vol. 21(1) 327 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . the Appendix. This paper discusses current PFAS use in the field of photolithography, explains why certain materials are used, reviews in part the current understanding of PFAS degradation during processing, and where possible, identifies alternative materials. One of the special features of the C─F bond is its strength compared with the C─C bond due to the electron-withdrawing power of the fluorine atom. This attribute is the basis of many of the technical benefits of fluorinated materials in semiconductor processing but leads to its chemical stability and environmental persistence. Fluorination brings specific improvement in perfor- mance, and its targeted incorporation can minimize the quantities of material needed to achieve that performance. Such aspects are discussed in the context of PAGs. Thus, despite the remark- able performance improvement in many aspects of the lithographic process provided by fluo- rochemicals (PFAS) that makes possible the semiconductor revolution with its benefit to society, the large and growing environmental and societal concerns surrounding PFAS may counterbal- ance the positive technological benefits of these materials. The reader is referred to a discussion of such PFAS concerns in a well-written review article, but photolithography chemicals are largely glossed over.1 Going forward, due to environmental and regulatory concerns, perfor- mance equivalent alternatives for many of these applications still need to be identified and this will be a major research challenge. This paper presents a detailed discussion of the different types of PFAS used in advanced lithographic patterning and semiconductor manufacturing paying specific attention to the unique physical-chemical attributes of these chemistries that make them essential for semiconductor manufacturing. Specifically, we break the PFAS used in semiconductor manufacturing into six main categories of fluorochemicals used in photolithography and semiconductor patterning. For each category, we discuss the critical function served by the fluorochemicals and why the spe- cific fluorocompounds are used, based on the unique properties provided by the chemical. However, it is worth noting that there are required processes in the semiconductor manufactory using per-fluorinated compounds such as etch gases for metal etching, wet cleaning chemicals to clean and condition substrate, and other minor processes that are not covered further in this paper. Based on concerns regarding the high persistence, bioaccumulation potential, and potential toxicity of PFAS studied to date, it has been suggested that the use of PFAS be limited to essen- tial uses only. We discuss whether viable alternatives exist for each of these applications and the character- istics that must be achieved to find an alternative compound where none currently exists. Finally, we apply the essential use concept described by Cousins et al.2 to show that these compounds should be considered essential for certain processes in semiconductor manufacturing (i.e., photo- lithography and patterning) because they provide for vital functions and are currently without established alternatives. The prior paper did an excellent job of discussing different aspects of PFAS use. In this paper, we focus our discussion of essential use as “necessary for highly impor- tant purposes in semiconductor manufacturing for which alternatives are not yet established.” We describe the many uses and unique properties of PFAS chemicals, which in our opinion justifies their current use as essential in microelectronics manufacturing and for which alterna- tives have not yet been adequately identified. This paper is not intended to be an extensive listing of every example of fluorochemical used in photolithography but does attempt to explain strat- egies and classes of material used in the manufacturing of semiconductors. the Appendix. This paper discusses current PFAS use in the field of photolithography, explains why certain materials are used, reviews in part the current understanding of PFAS degradation during processing, and where possible, identifies alternative materials. One of the special features of the C─F bond is its strength compared with the C─C bond due to the electron-withdrawing power of the fluorine atom. This attribute is the basis of many of the technical benefits of fluorinated materials in semiconductor processing but leads to its chemical stability and environmental persistence. Fluorination brings specific improvement in perfor- mance, and its targeted incorporation can minimize the quantities of material needed to achieve that performance. Such aspects are discussed in the context of PAGs. Thus, despite the remark- able performance improvement in many aspects of the lithographic process provided by fluo- rochemicals (PFAS) that makes possible the semiconductor revolution with its benefit to society, the large and growing environmental and societal concerns surrounding PFAS may counterbal- ance the positive technological benefits of these materials. The reader is referred to a discussion of such PFAS concerns in a well-written review article, but photolithography chemicals are largely glossed over.1 Going forward, due to environmental and regulatory concerns, perfor- mance equivalent alternatives for many of these applications still need to be identified and this will be a major research challenge. This paper presents a detailed discussion of the different types of PFAS used in advanced lithographic patterning and semiconductor manufacturing paying specific attention to the unique physical-chemical attributes of these chemistries that make them essential for semiconductor manufacturing. Specifically, we break the PFAS used in semiconductor manufacturing into six main categories of fluorochemicals used in photolithography and semiconductor patterning. For each category, we discuss the critical function served by the fluorochemicals and why the spe- cific fluorocompounds are used, based on the unique properties provided by the chemical. However, it is worth noting that there are required processes in the semiconductor manufactory using per-fluorinated compounds such as etch gases for metal etching, wet cleaning chemicals to clean and condition substrate, and other minor processes that are not covered further in this paper. Based on concerns regarding the high persistence, bioaccumulation potential, and potential toxicity of PFAS studied to date, it has been suggested that the use of PFAS be limited to essen- tial uses only. We discuss whether viable alternatives exist for each of these applications and the character- istics that must be achieved to find an alternative compound where none currently exists. Finally, we apply the essential use concept described by Cousins et al.2 to show that these compounds should be considered essential for certain processes in semiconductor manufacturing (i.e., photo- lithography and patterning) because they provide for vital functions and are currently without established alternatives. The prior paper did an excellent job of discussing different aspects of PFAS use. In this paper, we focus our discussion of essential use as “necessary for highly impor- tant purposes in semiconductor manufacturing for which alternatives are not yet established.” We describe the many uses and unique properties of PFAS chemicals, which in our opinion justifies their current use as essential in microelectronics manufacturing and for which alterna- tives have not yet been adequately identified. This paper is not intended to be an extensive listing of every example of fluorochemical used in photolithography but does attempt to explain strat- egies and classes of material used in the manufacturing of semiconductors. 2 Photoacid Generators PAGs are photoactive compounds that generate acids upon exposure to high-energy light [deep ultraviolet (DUV) or extreme ultraviolet (EUV)]. These photoactive compounds were originally used for applications in photopolymerization in the early 1960s.3 After the introduction of chemically amplified resists (CARs) in the 1980s, they have been used in semiconductor manu- facturing as key components in advanced photoresists. It is important to understand that the process of chemical amplification requires a very strong acid in the PAG to function well. PAGs are now highly evolved with over 40 years of in-depth research and development for photoresist applications. A positive tone resist polymer after deprotection, for example, contains 2 Photoacid Generators PAGs are photoactive compounds that generate acids upon exposure to high-energy light [deep ultraviolet (DUV) or extreme ultraviolet (EUV)]. These photoactive compounds were originally used for applications in photopolymerization in the early 1960s.3 After the introduction of chemically amplified resists (CARs) in the 1980s, they have been used in semiconductor manu- facturing as key components in advanced photoresists. It is important to understand that the process of chemical amplification requires a very strong acid in the PAG to function well. PAGs are now highly evolved with over 40 years of in-depth research and development for photoresist applications. A positive tone resist polymer after deprotection, for example, contains J. Micro/Nanopattern. Mater. Metrol. 010901-3 Jan–Mar 2022 • Vol. 21(1) 328 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-3 Jan–Mar 2022 • Vol. 21(1) 328 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . weak acid groups that will act to buffer (weaken) the acidity of the deprotection process. Without the presence of the strong fluorosulfonic (or stronger) acid, the catalyzed deprotection process will be less efficient or may not even occur. Sulfonate anions without fluorination have repeat- edly been shown to be inadequate for use ineffective 193 nm chemically amplified photoresists and this is well known in the photoresist community. The unique characteristics of fluorine (noted below), which lead to very strong proton donation by fluorinated sulfonic acids, are essen- tial in CARs. This intrinsic benefit of fluorinated acids makes it extremely difficult to eliminate the use of fluorinated acids whilst retaining the key performance characteristics of CARs needed for advanced photolithography in microelectronics manufacturing. Other attributes of a PAG that depend less on the acid and more on the chromophore include quantum yield at the wavelength of use, the sensitivity of the overall resist formulation (e.g., 15 to 60 mJ∕cm2 ), miscibility in the resist matrix, thermal and hydrolytic stability and shelf life of the photoresist, solubility in aque- ous base developer for positive tone develop or organic solvent for negative tone development followed by removal in the resist strip operation. In general, PAGs are divided into two catego- ries: either ionic or covalent (nonionic) structures. As the name suggests, ionic PAGs consist of two portions: a cation and an anion. In addition, covalent PAGs are uncharged, nonpolar com- pounds that are constructed of covalent bonds but are generally less sensitive and therefore less effective than ionic PAGs. The availability of both ionic and covalent PAGs offers process flex- ibility. In some cases, the presence of ionic groups may lead to storage instability of the photo- resist mixture or the inhomogeneous distribution of photoactive compounds in the photoresist, thus making a nonionic PAG necessary. However, most photoresist compositions that are used in semiconductor manufacturing employ ionic PAGs because of their greater sensitivity. Examples of PAGs are shown in Figs. 1 (ionic) and (covalent). In either case, a fluorinated sulfonic acid would be used to make an effective PAG. The photoefficiency difference between ionic and covalent PAGs, which leads to higher quantum yields in the ionic PAG is controlled by the cation.4 The low diffusivity and high strength of the acid resulting from the photolysis of the cation are controlled by the resulting accompa- nying fluorosulfonate anion. These anions are used in virtually all current commercial photo- resists. Limited diffusivity is important to achieving high-resolution patterns because excess diffusion of the PAG has been shown to limit the resolution of the images produced in a CAR. While aromatic sulfonic esters are shown in some nonionic PAGs described in Fig. 2, the strength of the resulting sulfonic acid after photolysis is not as high as the ionic PAGs with fluorinated sulfonate anions. weak acid groups that will act to buffer (weaken) the acidity of the deprotection process. Without the presence of the strong fluorosulfonic (or stronger) acid, the catalyzed deprotection process will be less efficient or may not even occur. Sulfonate anions without fluorination have repeat- edly been shown to be inadequate for use ineffective 193 nm chemically amplified photoresists and this is well known in the photoresist community. The unique characteristics of fluorine (noted below), which lead to very strong proton donation by fluorinated sulfonic acids, are essen- tial in CARs. This intrinsic benefit of fluorinated acids makes it extremely difficult to eliminate the use of fluorinated acids whilst retaining the key performance characteristics of CARs needed for advanced photolithography in microelectronics manufacturing. Other attributes of a PAG that depend less on the acid and more on the chromophore include quantum yield at the wavelength of use, the sensitivity of the overall resist formulation (e.g., 15 to 60 mJ∕cm2 ), miscibility in the resist matrix, thermal and hydrolytic stability and shelf life of the photoresist, solubility in aque- ous base developer for positive tone develop or organic solvent for negative tone development followed by removal in the resist strip operation. In general, PAGs are divided into two catego- ries: either ionic or covalent (nonionic) structures. As the name suggests, ionic PAGs consist of two portions: a cation and an anion. In addition, covalent PAGs are uncharged, nonpolar com- pounds that are constructed of covalent bonds but are generally less sensitive and therefore less effective than ionic PAGs. The availability of both ionic and covalent PAGs offers process flex- ibility. In some cases, the presence of ionic groups may lead to storage instability of the photo- resist mixture or the inhomogeneous distribution of photoactive compounds in the photoresist, thus making a nonionic PAG necessary. However, most photoresist compositions that are used in semiconductor manufacturing employ ionic PAGs because of their greater sensitivity. Examples of PAGs are shown in Figs. 1 (ionic) and (covalent). In either case, a fluorinated sulfonic acid would be used to make an effective PAG. The photoefficiency difference between ionic and covalent PAGs, which leads to higher quantum yields in the ionic PAG is controlled by the cation.4 The low diffusivity and high strength of the acid resulting from the photolysis of the cation are controlled by the resulting accompa- nying fluorosulfonate anion. These anions are used in virtually all current commercial photo- resists. Limited diffusivity is important to achieving high-resolution patterns because excess diffusion of the PAG has been shown to limit the resolution of the images produced in a CAR. While aromatic sulfonic esters are shown in some nonionic PAGs described in Fig. 2, the strength of the resulting sulfonic acid after photolysis is not as high as the ionic PAGs with fluorinated sulfonate anions. O O S O O O F S F F F F O S F F S F O F F FO 1 4 O O S O O O F S F F F F O S F F S F O F F FO 1 4 O F O O S F F O S I O F F S O N Br F O O 2 5 O F O O S F F O S I O F F S O N Br F O O 2 5 F F F F F F I O O O S F S S O F O F FO F FO F 6 3 Fig. 1 Representative ionic PAGs: 1,2,3,4 Sulfonium PAG and 5,6 Iodonium PAG. F F F F F F I O O O S F S S O F O F FO F FO F 6 3 Fig. 1 Representative ionic PAGs: 1,2,3,4 Sulfonium PAG and 5,6 Iodonium PAG. J. Micro/Nanopattern. Mater. Metrol. 010901-4 Jan–Mar 2022 • Vol. 21(1) 329 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-4 Jan–Mar 2022 • Vol. 21(1) 329 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . O O O O O O O F F F F S S N S F O O O O O F F F F O 7 8 9 Fig. 2 Representative nonionic covalent PAGs. O O O O O O O F F F F S S N S F O O O O O F F F F O 7 8 9 Fig. 2 Representative nonionic covalent PAGs. Covalent PAGs do not suffer from the sorts of phase separation, low miscibility, and dark loss (the dissolution of unexposed photoresist) issues that may occur in ionic PAG-containing resist formulations, but the quantum yield of photoacid generation is generally lower for covalent PAGs so this and other factors drive the ultimate choice of PAG.5 In order to increase the acidity of the photoacid, perfluorinated methylene units may be placed next to the sulfonate group in both ionic and covalent PAGs. The polarization present in the C─F bond due to the electron- withdrawing character of fluorine stabilizes the acid anion and makes the acid stronger. A sulfonic acid such as methane sulfonic acid has a pK a of −2 (already a strong acid) but trifluor- omethyl sulfonic acid (triflic acid) has a pK a of −14. Any induction effect is significantly smaller after two or three CF2 units, so the relative benefit of fluorination is significantly reduced as the neighboring CF2 units are further away from the acid group. The original choice of longer sequence perfluorinated sulfonates (six or more) has not been explained in patents or the liter- ature but was likely due to the effectiveness of the resulting PAG, the reduced diffusivity because it is a larger molecule, its availability, and the lack of volatility in this material. For example, the volatility of the small triflate anion limits its use in a production photoresist PAG because the resulting concentration gradients in such photoresist films harm performance. However, shorter CF2 segments (1 or 2) next to the anion and connected to other units of higher mass have been shown to make effective PAGs (see Sec. 2.3).6 Finally, the diffusivity of the PAG will affect pattern resolution (less diffusion enhances resolution) and can be addressed by the use of a higher molar mass PAG/acid and even covalent attachment of the PAG to the photoresist polymer itself (see Sec. 2.4). Although actively used in some applications, triflic acid is not always a useful component in a PAG since it may have significant deficiencies when used in a very high-resolution CAR system; it is volatile and may evaporate during the PEB step leading to composition gradients that are detrimental to image resolution and it readily diffuses during annealing, which may, in turn, lead to pattern degradation from deprotection chemistry occurring in unexposed areas, effectively reducing image contrast and disrupting pattern formation. Covalent PAGs do not suffer from the sorts of phase separation, low miscibility, and dark loss (the dissolution of unexposed photoresist) issues that may occur in ionic PAG-containing resist formulations, but the quantum yield of photoacid generation is generally lower for covalent PAGs so this and other factors drive the ultimate choice of PAG.5 In order to increase the acidity of the photoacid, perfluorinated methylene units may be placed next to the sulfonate group in both ionic and covalent PAGs. The polarization present in the C─F bond due to the electron- withdrawing character of fluorine stabilizes the acid anion and makes the acid stronger. A sulfonic acid such as methane sulfonic acid has a pK a of −2 (already a strong acid) but trifluor- omethyl sulfonic acid (triflic acid) has a pK a of −14. Any induction effect is significantly smaller after two or three CF2 units, so the relative benefit of fluorination is significantly reduced as the neighboring CF2 units are further away from the acid group. The original choice of longer sequence perfluorinated sulfonates (six or more) has not been explained in patents or the liter- ature but was likely due to the effectiveness of the resulting PAG, the reduced diffusivity because it is a larger molecule, its availability, and the lack of volatility in this material. For example, the volatility of the small triflate anion limits its use in a production photoresist PAG because the resulting concentration gradients in such photoresist films harm performance. However, shorter CF2 segments (1 or 2) next to the anion and connected to other units of higher mass have been shown to make effective PAGs (see Sec. 2.3).6 Finally, the diffusivity of the PAG will affect pattern resolution (less diffusion enhances resolution) and can be addressed by the use of a higher molar mass PAG/acid and even covalent attachment of the PAG to the photoresist polymer itself (see Sec. 2.4). Although actively used in some applications, triflic acid is not always a useful component in a PAG since it may have significant deficiencies when used in a very high-resolution CAR system; it is volatile and may evaporate during the PEB step leading to composition gradients that are detrimental to image resolution and it readily diffuses during annealing, which may, in turn, lead to pattern degradation from deprotection chemistry occurring in unexposed areas, effectively reducing image contrast and disrupting pattern formation. 2.1 Ionic PAGs and Their Photochemistry Most ionic PAGs used in lithography are onium salt derivatives. Such ionic compounds consist of an onium moiety as the cation and sulfonate groups as the anion.4 Upon exposure, photolysis occurs and photoacid is formed. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. Returning to Fig. 1, ionic PAGs are generally composed of either diaryliodonium or triarylsulfonium photoactive units to form a salt with an appropriate anion. Triarylsulfonium PAGs usually have longer shelf life compared with diaryliodonium salt. However, a diaryliodonium salt has higher absorptivity in particular for next-generation 13.5-nm wavelength EUV photons. The mechanism of photolysis of diaryliodonium salt4 and triarylsul- fonium salts7,8 has been studied extensively. Reported photolysis mechanisms for diaryliodo- nium salt and triarylsulfonium salts are shown in Figs. 3 and 4, respectively. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. In Fig. 3, the energy required to cleave the aromatic C (sp2 ) and iodine bond is somewhat higher compared with the energy required to promote bond cleavage between the aromatic C (sp2 ) and sulfur bond (Fig. 4). 2.1 Ionic PAGs and Their Photochemistry Most ionic PAGs used in lithography are onium salt derivatives. Such ionic compounds consist of an onium moiety as the cation and sulfonate groups as the anion.4 Upon exposure, photolysis occurs and photoacid is formed. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. Returning to Fig. 1, ionic PAGs are generally composed of either diaryliodonium or triarylsulfonium photoactive units to form a salt with an appropriate anion. Triarylsulfonium PAGs usually have longer shelf life compared with diaryliodonium salt. However, a diaryliodonium salt has higher absorptivity in particular for next-generation 13.5-nm wavelength EUV photons. The mechanism of photolysis of diaryliodonium salt4 and triarylsul- fonium salts7,8 has been studied extensively. Reported photolysis mechanisms for diaryliodo- nium salt and triarylsulfonium salts are shown in Figs. 3 and 4, respectively. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. In Fig. 3, the energy required to cleave the aromatic C (sp2 ) and iodine bond is somewhat higher compared with the energy required to promote bond cleavage between the aromatic C (sp2 ) and sulfur bond (Fig. 4). J. Micro/Nanopattern. Mater. Metrol. 010901-5 Jan–Mar 2022 • Vol. 21(1) 330 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 3 Proposed photolysis mechanism for diaryliodonium salt under DUV exposure. Reproduced from Ref. 8. S O3S(CF2)3CF3 hv hv S S hv S 1% J. Micro/Nanopattern. Mater. Metrol. 010901-5 Jan–Mar 2022 • Vol. 21(1) 330 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 3 Proposed photolysis mechanism for diaryliodonium salt under DUV exposure. Reproduced from Ref. 8. S O3S(CF2)3CF3 hv hv S S hv S 1% 3% 20% 7% S 1% Primary photoproducts 2% Secondary photoproducts S Polymer 1% In-cage products Cage-escape products Fig. 4 Proposed photolysis mechanism for triarylsulfonium salt in solid poly(methyl methacrylate) matrix exposed to 266-nm irradiation (2631 mJ · cm−2 ). Reproduced from Ref. 9. 3% 20% 7% S 1% Primary photoproducts 2% Secondary photoproducts S Polymer 1% In-cage products Cage-escape products Fig. 4 Proposed photolysis mechanism for triarylsulfonium salt in solid poly(methyl methacrylate) matrix exposed to 266-nm irradiation (2631 mJ · cm−2 ). Reproduced from Ref. 9. Generally, the sulfonium PAG family is more widely used than iodonium PAGs considering its greater sensitivity and longer shelf life when used in either DUV or EUV lithography. Reference 8 reports solution results for exposure of the triphenylsulfonium cation. More recent results of solid-state polymer matrix results are shown in Fig. 4.9 Solid-state studies at 193, 248, and 266 nm exposures reveal additional products including in all cases, two previously unre- ported Triphenyl sulfonium photoproducts, triphenylene, and dibenzothiophene. Generally, the sulfonium PAG family is more widely used than iodonium PAGs considering its greater sensitivity and longer shelf life when used in either DUV or EUV lithography. Reference 8 reports solution results for exposure of the triphenylsulfonium cation. More recent results of solid-state polymer matrix results are shown in Fig. 4.9 Solid-state studies at 193, 248, and 266 nm exposures reveal additional products including in all cases, two previously unre- ported Triphenyl sulfonium photoproducts, triphenylene, and dibenzothiophene. 2.2 Nonionic Covalent PAGs and Their Photochemistry Although ionic PAGs have higher sensitivity in lithographic applications, they may be less solu- ble and more prone to phase separation in photoresist formulations. It is worth recalling that the PAG is needed to generate acid in the exposed regions to deprotect the photoresist and thereby change its solubility. Uniform distribution of a PAG is an essential attribute to excellent perfor- mance in a photoresist. Detrimental interaction between ionic structures in a photoresist and an ionic PAG may also occur in future resist materials.10 To overcome such issues, covalent PAGs J. Micro/Nanopattern. Mater. Metrol. 010901-6 Jan–Mar 2022 • Vol. 21(1) 331 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use 2.2 Nonionic Covalent PAGs and Their Photochemistry Although ionic PAGs have higher sensitivity in lithographic applications, they may be less solu- ble and more prone to phase separation in photoresist formulations. It is worth recalling that the PAG is needed to generate acid in the exposed regions to deprotect the photoresist and thereby change its solubility. Uniform distribution of a PAG is an essential attribute to excellent perfor- mance in a photoresist. Detrimental interaction between ionic structures in a photoresist and an ionic PAG may also occur in future resist materials.10 To overcome such issues, covalent PAGs J. Micro/Nanopattern. Mater. Metrol. 010901-6 Jan–Mar 2022 • Vol. 21(1) 331 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Pathway A 2 (2) H2O Ar + H2SO3 Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Pathway A 2 (2) H2O Ar + H2SO3 O O O Ar Irradiation Ar Ar S S + S O O O O O O H2O / O2 O Ar + S OH HO O Photoacid generation Pathway B O O O Ar Irradiation Ar Ar S S + S O O O O O O H2O / O2 O Ar + S OH HO O Photoacid generation Pathway B O O O Ar Ar Ar Irradiation + S S S OH O O O O O Photoacid generation Fig. 5 Photoacid generation mechanism for arylsulfonate esters. O O O Ar Ar Ar Irradiation + S S S OH O O O O O Photoacid generation Fig. 5 Photoacid generation mechanism for arylsulfonate esters. O N O S R O Iminosulfonates Irradiation O O O S R HO S R O O O O N O S R Photoacid generation O O Imidosulfonates Fig. 6 Photoacid generation mechanism for iminosulfonates and imidosulfonates. O N O S R O Iminosulfonates Irradiation O O O S R HO S R O O O O N O S R Photoacid generation O O Imidosulfonates Fig. 6 Photoacid generation mechanism for iminosulfonates and imidosulfonates. may be attractive alternatives.4 In general, covalent PAGs are derivatives of arylsulfonates,11 iminosulfonates,12 and imidosulfonates.13 Arylsulfonate esters can be easily synthesized from phenol and sulfonyl chlorides. A similar effort to create fluorinated sulfonate ester-containing covalent PAGs has not taken place because such PAGs have not been as effective in photoresist applications. The photoacid generation mechanism is proposed based on the nonfries photolytic ArO─S bond cleavage (pathway A) or pseudofries rearrangement (pathway B), which is more likely to occur for electron-rich aryl sulfonates as shown in Fig. 5.14,15 It is worth noting that in pathway A, in the presence of oxygen and water, stronger sulfonic acid is generated. In the absence of oxygen, weaker sulfurous acid is produced. Iminosulfonates and imidosulfonates have similar chemical structures with the N─O bond undergoing homolytic cleavage upon irradiation to generate sulfonyloxy radicals, which subsequently capture hydro- gens from nearby molecules to afford the corresponding sulfonic acid as shown in Fig. 6. may be attractive alternatives.4 In general, covalent PAGs are derivatives of arylsulfonates,11 iminosulfonates,12 and imidosulfonates.13 Arylsulfonate esters can be easily synthesized from phenol and sulfonyl chlorides. A similar effort to create fluorinated sulfonate ester-containing covalent PAGs has not taken place because such PAGs have not been as effective in photoresist applications. The photoacid generation mechanism is proposed based on the nonfries photolytic ArO─S bond cleavage (pathway A) or pseudofries rearrangement (pathway B), which is more likely to occur for electron-rich aryl sulfonates as shown in Fig. 5.14,15 It is worth noting that in pathway A, in the presence of oxygen and water, stronger sulfonic acid is generated. In the absence of oxygen, weaker sulfurous acid is produced. Iminosulfonates and imidosulfonates have similar chemical structures with the N─O bond undergoing homolytic cleavage upon irradiation to generate sulfonyloxy radicals, which subsequently capture hydro- gens from nearby molecules to afford the corresponding sulfonic acid as shown in Fig. 6. 2.3 Alternatives to Current PAGs PAGs other than iodonium and sulfonium units as well as those that do not contain traditional PFAS have also been studied for use in photolithography. To be used successfully in a CAR photoresist, the resulting acid must be as acidic as a perfluorosulfonic acid, lack volatility so that it does not evaporate during the PEB step, and in the next generation photoresists possess minimum diffusivity (to enable high-resolution pattern formation). The PAG-resist combination should have a sensitivity in the range between 10 and 75 mJ∕cm2 under exposure conditions i.e., the source wavelength and tool-specific settings. Some new photoresists attach the PAG directly to the photopolymer chain to both limit diffusion and deal with issues of stochastic variations that may be present in photoresists consisting of mixtures of polymer and photoactive molecules. Nontraditional PFAS Covalent PAGs: Nitrobenzyl esters have found some application in DUVL and may be extendable to EUV lithography.10 Such molecules can generate photoacid 2.3 Alternatives to Current PAGs PAGs other than iodonium and sulfonium units as well as those that do not contain traditional PFAS have also been studied for use in photolithography. To be used successfully in a CAR photoresist, the resulting acid must be as acidic as a perfluorosulfonic acid, lack volatility so that it does not evaporate during the PEB step, and in the next generation photoresists possess minimum diffusivity (to enable high-resolution pattern formation). The PAG-resist combination should have a sensitivity in the range between 10 and 75 mJ∕cm2 under exposure conditions i.e., the source wavelength and tool-specific settings. Some new photoresists attach the PAG directly to the photopolymer chain to both limit diffusion and deal with issues of stochastic variations that may be present in photoresists consisting of mixtures of polymer and photoactive molecules. Nontraditional PFAS Covalent PAGs: Nitrobenzyl esters have found some application in DUVL and may be extendable to EUV lithography.10 Such molecules can generate photoacid J. Micro/Nanopattern. Mater. Metrol. 010901-7 Jan–Mar 2022 • Vol. 21(1) 332 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 7 Chemical structure for non-PFAS covalent PAGs: (a) nitrobenzyl ester and (b) terarylene backbone-based PAG. J. Micro/Nanopattern. Mater. Metrol. 010901-7 Jan–Mar 2022 • Vol. 21(1) 332 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 7 Chemical structure for non-PFAS covalent PAGs: (a) nitrobenzyl ester and (b) terarylene backbone-based PAG. upon irradiation through o-nitrobenzyl rearrangement to generate nitrobenzaldehyde and a sulfonic acid such as triflic acid shown in Fig. 7. The chemical structure is shown in Fig. 7(a). The terarylene skeleton-based self-contained PAG is another potential candidate for some applications. The photoacid generation is triggered by the 6π-electro-cyclization reaction of photochromic triangular terarylenes.16 The chemical structure is shown in Fig. 7(b). Similarly, a triflate ester is used in the reported structure to release triflic acid upon exposure. While these and other structures can be used to demonstrate PAG concepts, they are unlikely to be as useful in new high-resolution photoresist systems because they use triflate groups. Alternative acids may be used to make more suitable PAGs from the moieties in Fig. 7. Should a useful PAG be produced from these types of photoactive structures the resulting sulfonic acid will need to be less volatile and less mobile in the polymer film? A higher molar mass, much less volatile, lower diffusivity anion might work well with these mate- rials in a functioning photoresist system. Nontraditional PFAS Ionic PAGs: Ionic PAGs derived from 2-phenoxytetrafluoroethane sulfonate were introduced by Ober and coworkers in 2007.17 This PAG was tested under e-beam and EUV radiation and showed high sensitivity, resolution, and acceptably low line edge deviations. The use of such a fluorosulfonic acid has the advantage that it limits fluorine content yet produces a very strong acid with both limited volatility and diffusivity by placing a CF2 group next to the acid group. Such an approach (discussed more below) can be used to minimize fluorine incorporation while placing this structure where it is most valuable. Its chemical structure is shown in Fig. 8(a). This PAG was tested for its envi- ronmental degradation and its effect on bacterial populations when first reported and found to be benign under the rules of that time. The good lithographic results suggest that shorter fluorinated segments (two or possibly one CF2 unit adjacent to the sulfonic acid) may make useful ionic PAGs. It should be noted that the building blocks for sulfonic acids with one CF2 are the subject of experimental studies. The pentacyanocyclopentadienide PAG is another potential ionic PAG candidate in some applica- tions. Its lithographic performance was demonstrated by Varanasi and coworkers in 2010, and it stands out for the amount of publicity it received.18 The chemical structure is shown in Fig. 8(b). While announced in 2010 as part of IBM’s efforts to reduce Perfluorooctanoic acid (PFOA) in its manufacturing process, to the best of our knowledge, this PAG was not commercialized. upon irradiation through o-nitrobenzyl rearrangement to generate nitrobenzaldehyde and a sulfonic acid such as triflic acid shown in Fig. 7. The chemical structure is shown in Fig. 7(a). The terarylene skeleton-based self-contained PAG is another potential candidate for some applications. The photoacid generation is triggered by the 6π-electro-cyclization reaction of photochromic triangular terarylenes.16 The chemical structure is shown in Fig. 7(b). Similarly, a triflate ester is used in the reported structure to release triflic acid upon exposure. While these and other structures can be used to demonstrate PAG concepts, they are unlikely to be as useful in new high-resolution photoresist systems because they use triflate groups. Alternative acids may be used to make more suitable PAGs from the moieties in Fig. 7. Should a useful PAG be produced from these types of photoactive structures the resulting sulfonic acid will need to be less volatile and less mobile in the polymer film? A higher molar mass, much less volatile, lower diffusivity anion might work well with these mate- rials in a functioning photoresist system. Nontraditional PFAS Ionic PAGs: Ionic PAGs derived from 2-phenoxytetrafluoroethane sulfonate were introduced by Ober and coworkers in 2007.17 This PAG was tested under e-beam and EUV radiation and showed high sensitivity, resolution, and acceptably low line edge deviations. The use of such a fluorosulfonic acid has the advantage that it limits fluorine content yet produces a very strong acid with both limited volatility and diffusivity by placing a CF2 group next to the acid group. Such an approach (discussed more below) can be used to minimize fluorine incorporation while placing this structure where it is most valuable. Its chemical structure is shown in Fig. 8(a). This PAG was tested for its envi- ronmental degradation and its effect on bacterial populations when first reported and found to be benign under the rules of that time. The good lithographic results suggest that shorter fluorinated segments (two or possibly one CF2 unit adjacent to the sulfonic acid) may make useful ionic PAGs. It should be noted that the building blocks for sulfonic acids with one CF2 are the subject of experimental studies. The pentacyanocyclopentadienide PAG is another potential ionic PAG candidate in some applica- tions. Its lithographic performance was demonstrated by Varanasi and coworkers in 2010, and it stands out for the amount of publicity it received.18 The chemical structure is shown in Fig. 8(b). While announced in 2010 as part of IBM’s efforts to reduce Perfluorooctanoic acid (PFOA) in its manufacturing process, to the best of our knowledge, this PAG was not commercialized. Fig. 8 Chemical structure of untraditional ionic PAGs: (a) 2-phenoxytetrafluoroethane sulfonate PAG and (b) pentacyanocyclopentadienide PAGs. J. Micro/Nanopattern. Mater. Metrol. 010901-8 Jan–Mar 2022 • Vol. 21(1) 333 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 8 Chemical structure of untraditional ionic PAGs: (a) 2-phenoxytetrafluoroethane sulfonate PAG and (b) pentacyanocyclopentadienide PAGs. J. Micro/Nanopattern. Mater. Metrol. 010901-8 Jan–Mar 2022 • Vol. 21(1) 333 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . O CF2CF2OCF2CF2SO3- F F AcO F F F F F AcO F SO3- O S O O O O O O F O F F F F AcO OAc F F F OH HO Lactone PAG Sugar sweet PAG OH HO O F F HO O F SO3- OH F O O O O Deactylated linear sweet PAG-K F F O F O O F O CF2CF2OCF2CF2SO3- O CF2CF2OCF2CF2SO3- F F AcO F F F F F AcO F SO3- O S O O O O O O F O F F F F AcO OAc F F F OH HO Lactone PAG Sugar sweet PAG OH HO O F F HO O F SO3- OH F O O O O Deactylated linear sweet PAG-K F F O F O O F O CF2CF2OCF2CF2SO3- Methoxy sugar B sweet PAG Lithocholic acid PAG Methoxy sugar B sweet PAG Lithocholic acid PAG HO F F HO F SO3- F O O O F F F O CF2CF2OCF2CF2SO3- HO OH F Hydroxy sugar B sweet PAG Dihydrocholesterol PAG Fig. 9 Chemical structures for natural products-based PAGs. HO F F HO F SO3- F O O O F F F O CF2CF2OCF2CF2SO3- HO OH F Hydroxy sugar B sweet PAG Dihydrocholesterol PAG Fig. 9 Chemical structures for natural products-based PAGs. Finally, PAGs based on glucose or other natural products have been explored. These PAGs were demonstrated to be functional materials for some high-resolution photoresist applications ena- bling sub-100nm features using ArF laser and e-beam lithography. Moreover, these PAGs showed successful microbial degradation to smaller molecular units under aerobic conditions. The chemical structures are shown in Fig. 9. Such studies revealed the successful biodegradation of these PFAS units to smaller oxidized components as well as low bacterial cytotoxicity19,20 of the photoactive sulfonium subunit. In general, the anionic units underwent biodegradation using sludge from a local municipal waste- water treatment plant. The sugar or cholesterol groups appeared to degrade easily leaving only a short, fluorinated acid residue. An advantage of these structures is that the residues retain polar functional groups and are therefore more hydrophilic than PFOS/PFAS units. This makes them less likely to accumulate in fatty tissues, but further studies are needed to identify any bioac- cumulation characteristics. The photoactive cation unit but not the fluorinated anion was gen- erally found to be cytotoxic to the bacteria. Importantly, the short, fluorinated segment enabled the formation of a high-performance PAG that could be subjected to successful biological degradation. More recently, patents have appeared that describe a number of related chemical structures, the goal of which is intended to deliver strong PAG performance and minimize the size of the fluorinated unit in the fluorosulfonic acid or eliminate it entirely. These patents claim excellent lithographic performance.21 These and other patents describe PAGs with shorter fluorinated segments,22 some of which are designed to fall into small molecular pieces.23 To assess their viability as alternative PAGs their performance characteristics (sensitivity, acid strength, and diffusivity) and environmental characteristics (fluorine content, degradation products, and toxicity) will need to be assessed. Finally, PAGs based on glucose or other natural products have been explored. These PAGs were demonstrated to be functional materials for some high-resolution photoresist applications ena- bling sub-100nm features using ArF laser and e-beam lithography. Moreover, these PAGs showed successful microbial degradation to smaller molecular units under aerobic conditions. The chemical structures are shown in Fig. 9. Such studies revealed the successful biodegradation of these PFAS units to smaller oxidized components as well as low bacterial cytotoxicity19,20 of the photoactive sulfonium subunit. In general, the anionic units underwent biodegradation using sludge from a local municipal waste- water treatment plant. The sugar or cholesterol groups appeared to degrade easily leaving only a short, fluorinated acid residue. An advantage of these structures is that the residues retain polar functional groups and are therefore more hydrophilic than PFOS/PFAS units. This makes them less likely to accumulate in fatty tissues, but further studies are needed to identify any bioac- cumulation characteristics. The photoactive cation unit but not the fluorinated anion was gen- erally found to be cytotoxic to the bacteria. Importantly, the short, fluorinated segment enabled the formation of a high-performance PAG that could be subjected to successful biological degradation. More recently, patents have appeared that describe a number of related chemical structures, the goal of which is intended to deliver strong PAG performance and minimize the size of the fluorinated unit in the fluorosulfonic acid or eliminate it entirely. These patents claim excellent lithographic performance.21 These and other patents describe PAGs with shorter fluorinated segments,22 some of which are designed to fall into small molecular pieces.23 To assess their viability as alternative PAGs their performance characteristics (sensitivity, acid strength, and diffusivity) and environmental characteristics (fluorine content, degradation products, and toxicity) will need to be assessed. 2.4 Polymer-Bound PAGs One approach to increasing the resolution to photolithography is to employ PAG that is incor- porated into the photoresist polymer structure.24 It has the advantage of making the distribution more uniform and at the same time limits the diffusivity of the sulfonate anion since it is bound to the photoresist polymer. Resolution is set in part by the diffusivity of the PAG in the photoresist formulation, which is associated with the size of the molecule. The smaller the anion, the farther the photogenerated proton can diffuse in a given time. If the PAG acid diffuses too broadly then deprotection of the photoresist takes place in unwanted regions and makes the pattern larger, less precise, and “blurry.” These pattern irregularities are characterized in terms of line edge roughness, line width roughness, and critical dimension uniformity. Examples of bound-PAG structures have been reported and two are described below shown in Fig. 10. 2.4 Polymer-Bound PAGs One approach to increasing the resolution to photolithography is to employ PAG that is incor- porated into the photoresist polymer structure.24 It has the advantage of making the distribution more uniform and at the same time limits the diffusivity of the sulfonate anion since it is bound to the photoresist polymer. Resolution is set in part by the diffusivity of the PAG in the photoresist formulation, which is associated with the size of the molecule. The smaller the anion, the farther the photogenerated proton can diffuse in a given time. If the PAG acid diffuses too broadly then deprotection of the photoresist takes place in unwanted regions and makes the pattern larger, less precise, and “blurry.” These pattern irregularities are characterized in terms of line edge roughness, line width roughness, and critical dimension uniformity. Examples of bound-PAG structures have been reported and two are described below shown in Fig. 10. J. Micro/Nanopattern. Mater. Metrol. 010901-9 Jan–Mar 2022 • Vol. 21(1) 334 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 10 Examples of polymer-bound PAGs. (a) Single CF2 unit next to sulfonate21 and (b) single CF2 unit next to sulfonate in a structure that falls apart on exposure; groups (R1, and R2) not specified groups while R3 is a linking group.20 J. Micro/Nanopattern. Mater. Metrol. 010901-9 Jan–Mar 2022 • Vol. 21(1) 334 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 10 Examples of polymer-bound PAGs. (a) Single CF2 unit next to sulfonate21 and (b) single CF2 unit next to sulfonate in a structure that falls apart on exposure; groups (R1, and R2) not specified groups while R3 is a linking group.20 This strategy also lowers concerns about “stochastics,” i.e., the chemical heterogeneity of a photoresist mixture at the dimensions of the pattern are thought to also contribute to the limit of resolution of today’s most advanced lithographic processes. Upon exposure, the fluorosulfonate group becomes protonated, catalyzes deprotection of the rest of the photoresist chain, but the strongly acidic proton cannot diffuse broadly because it remains near the anion bound to the polymer chain and thereby forms higher resolution patterns. By attaching the same number of PAG units to each polymer chain, then the PAG is uniformly distributed throughout the photo- resist film. This strategy is being seriously considered for future generations of photoresists, particularly for use in EUV lithography.25 These examples share several common features, including the attachment of the anion to the polymer backbone. Since many CAR photoresists are based on (meth) acrylates, examples reported for 193 nm (DUV) resists [shown in Figs. 10(a) and 10(b)] possess a sulfonate anion and an adjacent CF2 unit, which then is connected to the methacrylate monomer through an ester linkage. While it has not been established if one or two CF2 units are needed to produce sufficiently strong anion, this example demonstrates one approach and good prospects for polymer-bound PAGs. This strategy also lowers concerns about “stochastics,” i.e., the chemical heterogeneity of a photoresist mixture at the dimensions of the pattern are thought to also contribute to the limit of resolution of today’s most advanced lithographic processes. Upon exposure, the fluorosulfonate group becomes protonated, catalyzes deprotection of the rest of the photoresist chain, but the strongly acidic proton cannot diffuse broadly because it remains near the anion bound to the polymer chain and thereby forms higher resolution patterns. By attaching the same number of PAG units to each polymer chain, then the PAG is uniformly distributed throughout the photo- resist film. This strategy is being seriously considered for future generations of photoresists, particularly for use in EUV lithography.25 These examples share several common features, including the attachment of the anion to the polymer backbone. Since many CAR photoresists are based on (meth) acrylates, examples reported for 193 nm (DUV) resists [shown in Figs. 10(a) and 10(b)] possess a sulfonate anion and an adjacent CF2 unit, which then is connected to the methacrylate monomer through an ester linkage. While it has not been established if one or two CF2 units are needed to produce sufficiently strong anion, this example demonstrates one approach and good prospects for polymer-bound PAGs. 3 Fluorinated Polyimides In an increasing number of applications, the photopatterned polymer is not removed but is retained as part of the device, even though the lithographic requirements are not as stringent as the high-resolution photoresist systems discussed above. Their use ranges from semiconduc- tor packaging to lithographic insulation patterns for integrated circuits. Under these circumstan- ces a completely different photopolymer must be used and have properties of very high thermal stability, strong mechanical properties (high Young’s modulus, good fracture toughness), low dielectric constant (be an insulator), and moisture resistance.26 In this highly demanding application only a few polymers can provide this complex set of properties and, among them, polyimides have been found to provide the best trade-off between processing and performance. Polyimides themselves bring many of these necessary attributes but the intro- duction of fluorinated groups is used to incorporate a chemical function capable of withstand- ing high process temperature, making the final material more moisture resistant and providing a lower dielectric constant than otherwise possible without compromise to other necessary properties. The technical literature reveals that polyimides are used in a number of processes and appli- cations in photolithography.27 Polyimides are a family of polymers characterized by high thermal 3 Fluorinated Polyimides In an increasing number of applications, the photopatterned polymer is not removed but is retained as part of the device, even though the lithographic requirements are not as stringent as the high-resolution photoresist systems discussed above. Their use ranges from semiconduc- tor packaging to lithographic insulation patterns for integrated circuits. Under these circumstan- ces a completely different photopolymer must be used and have properties of very high thermal stability, strong mechanical properties (high Young’s modulus, good fracture toughness), low dielectric constant (be an insulator), and moisture resistance.26 In this highly demanding application only a few polymers can provide this complex set of properties and, among them, polyimides have been found to provide the best trade-off between processing and performance. Polyimides themselves bring many of these necessary attributes but the intro- duction of fluorinated groups is used to incorporate a chemical function capable of withstand- ing high process temperature, making the final material more moisture resistant and providing a lower dielectric constant than otherwise possible without compromise to other necessary properties. The technical literature reveals that polyimides are used in a number of processes and appli- cations in photolithography.27 Polyimides are a family of polymers characterized by high thermal J. Micro/Nanopattern. Mater. Metrol. 010901-10 Jan–Mar 2022 • Vol. 21(1) 335 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-10 Jan–Mar 2022 • Vol. 21(1) 335 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . stability, excellent thin film mechanical properties, good adhesion properties, and a low dielectric constant and dissipation factor. In particular, rigid functional groups such as phenylene- and less polar functional groups provide low dielectric constant (Δk) and good mechanical toughness (resistance to tearing). Polyimides are unique as a family of polymers because they have among the highest glass transition (softening) temperatures known in a polymer (>200°C) and they are thermally stable because the polymer chain consists of interconnected aromatic rings. These properties make polyimides able to withstand the high-temperature processing used in semicon- ductor manufacturing. Like all polymers, they can be etched with the right etchants and therefore patterned, they are amorphous and transparent so they can be used to guide light and they have a lower dielectric constant than many other components in a device so they can be insulators, but unlike other polymers they come with the ability to withstand very high-temperature processing without physical softening and deformation. They often remain in the semiconductor device, unlike most other photolithographic layers. Photopatternable polyimides are generally made from a poly(amic acid) precursor such as one made from oxydianiline (ODA) (Y═O) and a dianhydride (such as pyromellitic dianhy- dride), which can be spin coated onto a substrate (see Fig. 11). However, photocrosslinkable acrylate (or similar) groups are incorporated in the soluble pol- y(amic acid). A photoradical initiator is used to crosslink the acrylate groups and the pattern is developed in this negative tone system. Then a high-temperature bake step is used to transform the poly(amic acid) to the polyimide (with loss of the acrylate groups) to form its final high thermal stability, patterned and insoluble polyimide form. Any component in the final polyimide must withstand this high-temperature bake step. Among the applications of polyimides in microelectronics processing, they find use as thick film photoresist, sacrificial layers, and structural layers. It is notable that the structure of a fluo- rinated unit, when incorporated into the polyimide, largely employs the identical hexafluoroi- sopropyl unit regardless of the application.28–30 Hence, in the most common examples, the polyimides consist of tetracarboxylic acid anhydride derivatives and aromatic diamines, as shown in Fig. 11. The polyimide polymer itself has a softening temperature too high for melt processing, but this group of polymers offers processing through its poly(amide) intermediate. The intermediate is soluble, can be coated in a thin or thick film, and after patterning is converted to the polyimide through the heating step making it an ideal material for integration with semi- conductor manufacturing. The soluble intermediate can be made into a polymer that is directly photo-patternable as shown in the poly(amide) in Fig. 11. The acrylate modified poly(amide) is photo-crosslinked upon exposure to UV radiation in the presence of a photoradical generator and then a pattern is formed. After development, the patterned polymer is subsequently transformed to the final polyimide by thermal processing. It is known in the art that the insertion of the fluorinated hexafluoroisopropyl functional group into the backbone provides a combination of better solubility in processing solvents, lower dielectric constant (more insulating), and pro- vides higher thermal and thermooxidative stability compared with other alternate chemical functions.31 stability, excellent thin film mechanical properties, good adhesion properties, and a low dielectric constant and dissipation factor. In particular, rigid functional groups such as phenylene- and less polar functional groups provide low dielectric constant (Δk) and good mechanical toughness (resistance to tearing). Polyimides are unique as a family of polymers because they have among the highest glass transition (softening) temperatures known in a polymer (>200°C) and they are thermally stable because the polymer chain consists of interconnected aromatic rings. These properties make polyimides able to withstand the high-temperature processing used in semicon- ductor manufacturing. Like all polymers, they can be etched with the right etchants and therefore patterned, they are amorphous and transparent so they can be used to guide light and they have a lower dielectric constant than many other components in a device so they can be insulators, but unlike other polymers they come with the ability to withstand very high-temperature processing without physical softening and deformation. They often remain in the semiconductor device, unlike most other photolithographic layers. Photopatternable polyimides are generally made from a poly(amic acid) precursor such as one made from oxydianiline (ODA) (Y═O) and a dianhydride (such as pyromellitic dianhy- dride), which can be spin coated onto a substrate (see Fig. 11). However, photocrosslinkable acrylate (or similar) groups are incorporated in the soluble pol- y(amic acid). A photoradical initiator is used to crosslink the acrylate groups and the pattern is developed in this negative tone system. Then a high-temperature bake step is used to transform the poly(amic acid) to the polyimide (with loss of the acrylate groups) to form its final high thermal stability, patterned and insoluble polyimide form. Any component in the final polyimide must withstand this high-temperature bake step. Among the applications of polyimides in microelectronics processing, they find use as thick film photoresist, sacrificial layers, and structural layers. It is notable that the structure of a fluo- rinated unit, when incorporated into the polyimide, largely employs the identical hexafluoroi- sopropyl unit regardless of the application.28–30 Hence, in the most common examples, the polyimides consist of tetracarboxylic acid anhydride derivatives and aromatic diamines, as shown in Fig. 11. The polyimide polymer itself has a softening temperature too high for melt processing, but this group of polymers offers processing through its poly(amide) intermediate. The intermediate is soluble, can be coated in a thin or thick film, and after patterning is converted to the polyimide through the heating step making it an ideal material for integration with semi- conductor manufacturing. The soluble intermediate can be made into a polymer that is directly photo-patternable as shown in the poly(amide) in Fig. 11. The acrylate modified poly(amide) is photo-crosslinked upon exposure to UV radiation in the presence of a photoradical generator and then a pattern is formed. After development, the patterned polymer is subsequently transformed to the final polyimide by thermal processing. It is known in the art that the insertion of the fluorinated hexafluoroisopropyl functional group into the backbone provides a combination of better solubility in processing solvents, lower dielectric constant (more insulating), and pro- vides higher thermal and thermooxidative stability compared with other alternate chemical functions.31 Fig. 11 Synthesis and structure of polyimides for photolithographic processes. J. Micro/Nanopattern. Mater. Metrol. 010901-11 Jan–Mar 2022 • Vol. 21(1) 336 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 11 Synthesis and structure of polyimides for photolithographic processes. J. Micro/Nanopattern. Mater. Metrol. 010901-11 Jan–Mar 2022 • Vol. 21(1) 336 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . It must be noted that similar insulator properties have been claimed for the targeted optimi- zation of a polyimide chemical structure without the presence of fluorinated residues such as CF3 - and others, which has been successfully demonstrated in at least one scientific study.32 Araki et al.32 recently described the synthesis of a novel low dielectric constant (Δk) and low dissipation factor (Δf) polyimides suitable for insulator of redistribution layers used as an inter- poser layer in wafer-level packaging. However, this polyimide replaces the thermally stable aromatic structure with a silicone segment (chemically identical to bathtub caulk) to achieve the insulating properties. While this new polyimide has good dielectric properties, unmentioned in the report is the fact it undoubtedly has poor mechanical properties, thermal stability and introduces a softening temperature well below materials used in this semiconductor manufac- turing application. To demonstrate equivalence to the fluorinated polyimides, it would be nec- essary to evaluate these new polymers in a series of comparative studies. It is likely that the lower glass transition temperature and the higher associated thermal expansion changes of the silicone- based system would lead to mechanical stresses that severely limit its use outside of simple packaging applications. No literature was found on the in-process or environmental degradation of these fluorinated polyimides. It must be noted that similar insulator properties have been claimed for the targeted optimi- zation of a polyimide chemical structure without the presence of fluorinated residues such as CF3 - and others, which has been successfully demonstrated in at least one scientific study.32 Araki et al.32 recently described the synthesis of a novel low dielectric constant (Δk) and low dissipation factor (Δf) polyimides suitable for insulator of redistribution layers used as an inter- poser layer in wafer-level packaging. However, this polyimide replaces the thermally stable aromatic structure with a silicone segment (chemically identical to bathtub caulk) to achieve the insulating properties. While this new polyimide has good dielectric properties, unmentioned in the report is the fact it undoubtedly has poor mechanical properties, thermal stability and introduces a softening temperature well below materials used in this semiconductor manufac- turing application. To demonstrate equivalence to the fluorinated polyimides, it would be nec- essary to evaluate these new polymers in a series of comparative studies. It is likely that the lower glass transition temperature and the higher associated thermal expansion changes of the silicone- based system would lead to mechanical stresses that severely limit its use outside of simple packaging applications. No literature was found on the in-process or environmental degradation of these fluorinated polyimides. 4 Fluorinated Polybenzoxazoles Building on the properties described for fluorinated polyimides, the industry has requested materials with similar properties, which could be patterned using the more generally acceptable aqueous tetramethylammonium hydroxide based developers. One way to achieve this end was to replace the polyamic acid derivative precursors with polyhydroxyamide precursors to polybenzoxazole, which could, after patterning and cyclization, yield a polybenzoxazole (Fig. 12). The phenolic group allows for development by aqueous base, whereas use of classical diazonaphthoquinone (DNQ) photoactive units to modify the base solubility as in positive-tone photoresists allows for the needed selective patterning (Fig. 13).4 Alternatively, other protective groups such as acid-labile ethers and a PAG can also be used, as are common in advanced positive tone photoresists. These materials provide properties similar to polyimides, including thermal stability, tensile strength, and transparency as polyimides while also allowing easier processing. The incorporation of a hexafluoroisopropylidene containing monomer again confers the needed properties of transparency in 365 nm applications, good moisture resistance, thermal stability, reduced darkening after cure, and the correct solubility in aqueous development. Other additives are used to further control base solubility.33–36 The DNQ PAC may either be added to the formulation or incorporated into the polymer backbone as shown below. 4 Fluorinated Polybenzoxazoles Building on the properties described for fluorinated polyimides, the industry has requested materials with similar properties, which could be patterned using the more generally acceptable aqueous tetramethylammonium hydroxide based developers. One way to achieve this end was to replace the polyamic acid derivative precursors with polyhydroxyamide precursors to polybenzoxazole, which could, after patterning and cyclization, yield a polybenzoxazole (Fig. 12). The phenolic group allows for development by aqueous base, whereas use of classical diazonaphthoquinone (DNQ) photoactive units to modify the base solubility as in positive-tone photoresists allows for the needed selective patterning (Fig. 13).4 Alternatively, other protective groups such as acid-labile ethers and a PAG can also be used, as are common in advanced positive tone photoresists. These materials provide properties similar to polyimides, including thermal stability, tensile strength, and transparency as polyimides while also allowing easier processing. The incorporation of a hexafluoroisopropylidene containing monomer again confers the needed properties of transparency in 365 nm applications, good moisture resistance, thermal stability, reduced darkening after cure, and the correct solubility in aqueous development. Other additives are used to further control base solubility.33–36 The DNQ PAC may either be added to the formulation or incorporated into the polymer backbone as shown below. Base polymer HO OH X COHN NHCO Y Oxazole ring Precursor polymer CABC n heat O O X Y -H2O N N n After postbake (Polybenzoxazole) Fig. 12 Figure showing ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. Base polymer HO OH X COHN NHCO Y Oxazole ring Precursor polymer CABC n heat O O X Y -H2O N N n After postbake (Polybenzoxazole) Fig. 12 Figure showing ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. J. Micro/Nanopattern. Mater. Metrol. 010901-12 Jan–Mar 2022 • Vol. 21(1) 337 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 13 Ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. J. Micro/Nanopattern. Mater. Metrol. 010901-12 Jan–Mar 2022 • Vol. 21(1) 337 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 13 Ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. 5 Antireflection Coatings and Topcoats The purpose of an antireflection coating (ARC) is to prevent reflection of the imaging radiation from interface layers that produce unwanted exposure effects including standing waves. An important attribute of an ARC is to tune the refractive index difference across each interface, and reflection from the many interfaces between layers is suppressed. A difference in refractive index is essential in preventing unwanted reflection of imaging radiation, which otherwise has a detrimental effect on pattern exposures. Fluorinated materials are important because they have a lower refractive index than virtually any other material category. For example, the refractive index of poly(trifluoroethyl methacrylate) is 1.418 compared with a polymer chemically similar to photoresist materials, poly(2-methoxy styrene) with its refractive index of 1.585, a significant and critical difference for an antireflection coating. Ideally a TARC, e.g., should have an RI value of ∼1.3 and even with fluorinated materials, a good TARC refractive index is currently between 1.4 and 1.45. In addition to their optical properties, ARCs must not intermix with the photoresist as the different layers are deposited, and fluorination helps make that possible. Important requirements for ARCs also include ease of etching, their adhesion to a substrate, and precise thickness deposition.37–39 Bottom ARCs (BARCs) are also used to form a level surface for a photoresist. Processing of ARC and topcoat materials depend very much on where they sit in the lithographic stack (on top or on the bottom) and a combination of etch, rinse and/or devel- opment steps are used in processing. This paper does not detail these differences. TARC materi- als require first and foremost controlled and reduced refractive index (RI), good mechanical properties for film formation as well as excellent etch characteristics (faster etching than the photoresist). The low RI properties and immiscibility (by being both nonpolar and oleophobic) with the photoresist are mainly achieved by the incorporation of short, fluorinated groups such as CF3 - and C2 F4 - units in the TARC, although longer fluorinated segments have been used. An example of a generic chemical structure of an ARC is shown in Fig. 14 in which a base soluble fluoropolymer is displayed.40 It is also possible to achieve immiscibility between ARC and resist using cyclic perfluori- nated ether units in the ARC41 Finally, fluorinated surfactants have also been used to improve ARC coating quality, and more is discussed about such surfactants below. There are two possible geometries that work to limit reflection: TARC and BARC antireflection coating materials. The name specifies wherein the multilayer stack the ARC is located. Figure 15 shows the arrange- ment of the silicon substrate, the photoresist, and a TARC.42 The radiation path is different in the air, the TARC, and the photoresist since each has a different refractive index. By using a low RI TARC (due to its fluorination) and by finding the 5 Antireflection Coatings and Topcoats The purpose of an antireflection coating (ARC) is to prevent reflection of the imaging radiation from interface layers that produce unwanted exposure effects including standing waves. An important attribute of an ARC is to tune the refractive index difference across each interface, and reflection from the many interfaces between layers is suppressed. A difference in refractive index is essential in preventing unwanted reflection of imaging radiation, which otherwise has a detrimental effect on pattern exposures. Fluorinated materials are important because they have a lower refractive index than virtually any other material category. For example, the refractive index of poly(trifluoroethyl methacrylate) is 1.418 compared with a polymer chemically similar to photoresist materials, poly(2-methoxy styrene) with its refractive index of 1.585, a significant and critical difference for an antireflection coating. Ideally a TARC, e.g., should have an RI value of ∼1.3 and even with fluorinated materials, a good TARC refractive index is currently between 1.4 and 1.45. In addition to their optical properties, ARCs must not intermix with the photoresist as the different layers are deposited, and fluorination helps make that possible. Important requirements for ARCs also include ease of etching, their adhesion to a substrate, and precise thickness deposition.37–39 Bottom ARCs (BARCs) are also used to form a level surface for a photoresist. Processing of ARC and topcoat materials depend very much on where they sit in the lithographic stack (on top or on the bottom) and a combination of etch, rinse and/or devel- opment steps are used in processing. This paper does not detail these differences. TARC materi- als require first and foremost controlled and reduced refractive index (RI), good mechanical properties for film formation as well as excellent etch characteristics (faster etching than the photoresist). The low RI properties and immiscibility (by being both nonpolar and oleophobic) with the photoresist are mainly achieved by the incorporation of short, fluorinated groups such as CF3 - and C2 F4 - units in the TARC, although longer fluorinated segments have been used. An example of a generic chemical structure of an ARC is shown in Fig. 14 in which a base soluble fluoropolymer is displayed.40 It is also possible to achieve immiscibility between ARC and resist using cyclic perfluori- nated ether units in the ARC41 Finally, fluorinated surfactants have also been used to improve ARC coating quality, and more is discussed about such surfactants below. There are two possible geometries that work to limit reflection: TARC and BARC antireflection coating materials. The name specifies wherein the multilayer stack the ARC is located. Figure 15 shows the arrange- ment of the silicon substrate, the photoresist, and a TARC.42 The radiation path is different in the air, the TARC, and the photoresist since each has a different refractive index. By using a low RI TARC (due to its fluorination) and by finding the Fig. 14 Composition of a commercial ARC; n ¼ m.40 J. Micro/Nanopattern. Mater. Metrol. 010901-13 Jan–Mar 2022 • Vol. 21(1) 338 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 15 Light path of top coat/antireflective coating and resist film stack.43 optimal TARC film thickness reflection can be minimized.44–47 Both the phase match and inten- sity match conditions must be satisfied. This follows Airy’s original 19th-century derivation. If both conditions are met perfectly, the reflection amplitude is zero and all light is coupled into the film. This added ARC layer of lower RI results in a superior pattern with higher resolution. Fig. 14 Composition of a commercial ARC; n ¼ m.40 J. Micro/Nanopattern. Mater. Metrol. 010901-13 Jan–Mar 2022 • Vol. 21(1) 338 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 15 Light path of top coat/antireflective coating and resist film stack.43 optimal TARC film thickness reflection can be minimized.44–47 Both the phase match and inten- sity match conditions must be satisfied. This follows Airy’s original 19th-century derivation. If both conditions are met perfectly, the reflection amplitude is zero and all light is coupled into the film. This added ARC layer of lower RI results in a superior pattern with higher resolution. 5.1 Bottom Antireflective Coatings Some fluorine-containing acrylate and methacrylate-based copolymers may be used as compo- nents in BARC antireflection coating materials (as shown in Fig. 16). BARC materials used for 193-nm lithography include copolymers of acrylates/methacry- lates/alicyclic units as well as bis(benzocyclobutene) and fluorinated arylene ethers.31 Besides the use of acrylate-based copolymers, it has been reported that perfluoroalkyl silanes (shown in Fig. 13) and poly(ethoxy siloxanes) (not shown) are used as BARC materials. In all these materials the fluorinated component aids in preventing intermixing between the antireflec- tion coating and the photoresist. If mixing were to occur then the performance of the ARC (top or bottom) and the photoresist will be greatly diminished, because the thin photoresist layers will no longer be optically uniform. It should also be noted that fluorine “free” alternative BARCs are known, and they similarly must prevent mixing between ARC layers and photoresists without fluorination. Material suppliers have shown fast etching BARCs for 193-nm lithography. Such materials were targeted for first and second reflectivity minima thickness, are immiscible with photoresists (by being crosslinked), and are not affected by base developers, see Fig. 17. However, these materials were introduced before the advent of 193-nm immersion lithog- raphy. In addition, disposal of hydrophilic ARCs is complicated when ARC and resist disposal cannot be disposed of via the same waste system. 5.1 Bottom Antireflective Coatings Some fluorine-containing acrylate and methacrylate-based copolymers may be used as compo- nents in BARC antireflection coating materials (as shown in Fig. 16). BARC materials used for 193-nm lithography include copolymers of acrylates/methacry- lates/alicyclic units as well as bis(benzocyclobutene) and fluorinated arylene ethers.31 Besides the use of acrylate-based copolymers, it has been reported that perfluoroalkyl silanes (shown in Fig. 13) and poly(ethoxy siloxanes) (not shown) are used as BARC materials. In all these materials the fluorinated component aids in preventing intermixing between the antireflec- tion coating and the photoresist. If mixing were to occur then the performance of the ARC (top or bottom) and the photoresist will be greatly diminished, because the thin photoresist layers will no longer be optically uniform. It should also be noted that fluorine “free” alternative BARCs are known, and they similarly must prevent mixing between ARC layers and photoresists without fluorination. Material suppliers have shown fast etching BARCs for 193-nm lithography. Such materials were targeted for first and second reflectivity minima thickness, are immiscible with photoresists (by being crosslinked), and are not affected by base developers, see Fig. 17. However, these materials were introduced before the advent of 193-nm immersion lithog- raphy. In addition, disposal of hydrophilic ARCs is complicated when ARC and resist disposal cannot be disposed of via the same waste system. (a) F F F F CF3 O O n CF3 F F F F (b) n n O O O Si (CF2)5CF3 O O CF3 HO CF3 CF3 CF3 OH (a) F F F F CF3 O O n CF3 F F F F (b) n n O O O Si (CF2)5CF3 O O CF3 HO CF3 CF3 CF3 OH Fig. 16 (a) Fluorinated arylene ethers and (b) acrylate/methacrylate perfluoroalkyl silane-based BARC and TARC materials. J. Micro/Nanopattern. Mater. Metrol. 010901-14 Jan–Mar 2022 • Vol. 21(1) 339 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 17 Representative BARC material.52 Fig. 16 (a) Fluorinated arylene ethers and (b) acrylate/methacrylate perfluoroalkyl silane-based BARC and TARC materials. J. Micro/Nanopattern. Mater. Metrol. 010901-14 Jan–Mar 2022 • Vol. 21(1) 339 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 17 Representative BARC material.52 5.2 Top Antireflective Coatings Antireflective coatings may also be placed on top of a photoresist stack to reduce optical issues. The comments related to BARCs above about refractive index and miscibility are relevant to TARC materials as well. Issues of wetting and interactions with water arise when 193-nm immer- sion lithography is used. In this variation of high-resolution lithography, a droplet of water is placed between the photoresist stack surface and the stepper (exposure) lens. As the wafer is patterned, the water film must not wet the wafer surface, or else the patterning process will fail since the rapid movement of the stepper would rapidly lead to the breakdown of the immersion layer. A very hydrophobic, nonwetting surface makes the immersion process work well and prevents leaching of the photoactive component. For immersion lithography, control of substrate reflectivity is critical and for this reason immersion, BARCs are favored over TARC when using this process. Similar chemical strategies have been used to make fluorinated TARCs and topcoats (below), where fluorinated acrylate- and methacrylate-based copolymers are used, but they are optimized for different property sets.48 Jung et al.49 showed a TARC material based on these components, which are easily developable but possess a relatively low refractive index of 1.55. Furthermore, by increasing the fluorine content of the TARC material, a high dissolution rate and receding contact angles >70 deg could be achieved. 5.2 Top Antireflective Coatings Antireflective coatings may also be placed on top of a photoresist stack to reduce optical issues. The comments related to BARCs above about refractive index and miscibility are relevant to TARC materials as well. Issues of wetting and interactions with water arise when 193-nm immer- sion lithography is used. In this variation of high-resolution lithography, a droplet of water is placed between the photoresist stack surface and the stepper (exposure) lens. As the wafer is patterned, the water film must not wet the wafer surface, or else the patterning process will fail since the rapid movement of the stepper would rapidly lead to the breakdown of the immersion layer. A very hydrophobic, nonwetting surface makes the immersion process work well and prevents leaching of the photoactive component. For immersion lithography, control of substrate reflectivity is critical and for this reason immersion, BARCs are favored over TARC when using this process. Similar chemical strategies have been used to make fluorinated TARCs and topcoats (below), where fluorinated acrylate- and methacrylate-based copolymers are used, but they are optimized for different property sets.48 Jung et al.49 showed a TARC material based on these components, which are easily developable but possess a relatively low refractive index of 1.55. Furthermore, by increasing the fluorine content of the TARC material, a high dissolution rate and receding contact angles >70 deg could be achieved. 5.3 Topcoats Sanders wrote an extensive review of resist systems for 193-nm immersion lithography and dis- cussed the need for topcoats.41 These are materials used as the upper layer in the resist stack that was optimized for the purpose of preventing immersion liquid (water) from leaching photoactive materials from the photoresist during the patterning process and for base development. In that report, he describes several compositions that work well as topcoats. These include perfluoro ethers as well as polymers with hexafluoroisopropanol units and those with short-chain perfluor- oalkyl units. All approaches reported function well as barrier materials. In addition to immersion topcoats, which are directly coated on the resist, material suppliers have also developed highly functionalized fluorinated amphiphilic molecular structures, which provide the same properties as a topcoat. The advantage of this approach is that the material, known as an embedded barrier layer (EBL), is formulated directly in the resist, and no separate topcoat coating step is required. Such photoresists are known as topcoat-free resists.50 Such EBL materials may have similar fluorinated components as those found in fluorinated topcoats and fluorinated ARCs, but their application and processing are different. Other approaches to low RI materials include the incorporation of air pockets using silica nanoparticles. However, this approach did not gain industry acceptance, because it was not pos- sible to implement with the necessary process reliability and reproducibility. In addition, dyed TARCs (limited by the availability of appropriate chromophores) have been developed that reduce the need for fluorination using anomalous dispersion optical effects but do not eliminate the need for fluorinated components for performance reasons discussed above. Finally, the only molecular unit that comes close to fluorochemicals in low surface energy are silicones, but they have the disadvantage that they have low softening temperatures and are very 5.3 Topcoats Sanders wrote an extensive review of resist systems for 193-nm immersion lithography and dis- cussed the need for topcoats.41 These are materials used as the upper layer in the resist stack that was optimized for the purpose of preventing immersion liquid (water) from leaching photoactive materials from the photoresist during the patterning process and for base development. In that report, he describes several compositions that work well as topcoats. These include perfluoro ethers as well as polymers with hexafluoroisopropanol units and those with short-chain perfluor- oalkyl units. All approaches reported function well as barrier materials. In addition to immersion topcoats, which are directly coated on the resist, material suppliers have also developed highly functionalized fluorinated amphiphilic molecular structures, which provide the same properties as a topcoat. The advantage of this approach is that the material, known as an embedded barrier layer (EBL), is formulated directly in the resist, and no separate topcoat coating step is required. Such photoresists are known as topcoat-free resists.50 Such EBL materials may have similar fluorinated components as those found in fluorinated topcoats and fluorinated ARCs, but their application and processing are different. Other approaches to low RI materials include the incorporation of air pockets using silica nanoparticles. However, this approach did not gain industry acceptance, because it was not pos- sible to implement with the necessary process reliability and reproducibility. In addition, dyed TARCs (limited by the availability of appropriate chromophores) have been developed that reduce the need for fluorination using anomalous dispersion optical effects but do not eliminate the need for fluorinated components for performance reasons discussed above. Finally, the only molecular unit that comes close to fluorochemicals in low surface energy are silicones, but they have the disadvantage that they have low softening temperatures and are very J. Micro/Nanopattern. Mater. Metrol. 010901-15 Jan–Mar 2022 • Vol. 21(1) 340 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . oxygen plasma etch-resistant. Where ARCs need to be removed using such etch methods, alter- native structures with silicones do not provide needed properties. J. Micro/Nanopattern. Mater. Metrol. 010901-15 Jan–Mar 2022 • Vol. 21(1) 340 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . oxygen plasma etch-resistant. Where ARCs need to be removed using such etch methods, alter- native structures with silicones do not provide needed properties. 6 Fluorinated Surfactants and Surface Leveling Agents Surfactants in general are “surface-active agents” that consists of a hydrophobic segment and a hydrophilic unit. Surfactants can be used in a variety of coating applications for improving film quality, changing surface interaction,51 and wetting characteristics, and component mixing. The hydrophobic portion of a surfactant can consist of such moieties as hydrocarbon, silicone, or perfluorocarbon segments while the hydrophilic portion of a surfactant can be charged or neutral. Specific performance advantage of fluorinated surfactants is that the surface activity is much higher than equivalent hydrocarbon or silicone surfactants as indicated by the requirement for less surfactant material in a formulation to achieve its critical micelle concentration. Fluorinated surfactants may be used in several applications in photoresist processing. For example, they can be used to improve photoresist deposition and eliminate defects during photo- resist coating. Fluorinated surfactants have been used to improve the development process of an exposed photoresist. They are used to improve the uniformity of an ARC coating process and are especially effective when fluorinated ARCs are involved. Thick film photoresists benefit from surfactants in the formulation to achieve good coating uniformity. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality to reduce layer contamination and increase process yield) and the surface activity of fluorocarbon surfactants makes them readily useable with other ARCs and photoresist materials. Fluorinated nonionic surfactants have been used in a wide range of lithographic processes due to their very low surface energy, thermal-and mechanical stability, and low refractive index. Nanoimprint lithography (below) is making use of fluorinated surfactants to reduce defects caused by the removal of the template in the patterning process.53,54 Lin et al.55 demonstrated the use of methyl perfluorooctanoate to significantly reduce defects of printed patterns. Another example was shown by Zelsmann et al.56 applying perfluorooctyl-triethoxysilane and perfluoro- octyl-trimethoxysilane. Besides use in nanoimprint lithography, fluorosurfactant-assisted photo- lithography was demonstrated by Sakanoue et al. using commercial polymeric fluorosurfactants, such as Surflon S-386, S-651 (AGC) and Novec FC-4432 (3M).57 It should be noted that, due to the unique properties of fluorinated surfactants, examples of nonfluorinated surfactants with equivalent characteristics to those of fluorinated surfactants are limited and have been used in few resist formulations. 6 Fluorinated Surfactants and Surface Leveling Agents Surfactants in general are “surface-active agents” that consists of a hydrophobic segment and a hydrophilic unit. Surfactants can be used in a variety of coating applications for improving film quality, changing surface interaction,51 and wetting characteristics, and component mixing. The hydrophobic portion of a surfactant can consist of such moieties as hydrocarbon, silicone, or perfluorocarbon segments while the hydrophilic portion of a surfactant can be charged or neutral. Specific performance advantage of fluorinated surfactants is that the surface activity is much higher than equivalent hydrocarbon or silicone surfactants as indicated by the requirement for less surfactant material in a formulation to achieve its critical micelle concentration. Fluorinated surfactants may be used in several applications in photoresist processing. For example, they can be used to improve photoresist deposition and eliminate defects during photo- resist coating. Fluorinated surfactants have been used to improve the development process of an exposed photoresist. They are used to improve the uniformity of an ARC coating process and are especially effective when fluorinated ARCs are involved. Thick film photoresists benefit from surfactants in the formulation to achieve good coating uniformity. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality to reduce layer contamination and increase process yield) and the surface activity of fluorocarbon surfactants makes them readily useable with other ARCs and photoresist materials. Fluorinated nonionic surfactants have been used in a wide range of lithographic processes due to their very low surface energy, thermal-and mechanical stability, and low refractive index. Nanoimprint lithography (below) is making use of fluorinated surfactants to reduce defects caused by the removal of the template in the patterning process.53,54 Lin et al.55 demonstrated the use of methyl perfluorooctanoate to significantly reduce defects of printed patterns. Another example was shown by Zelsmann et al.56 applying perfluorooctyl-triethoxysilane and perfluoro- octyl-trimethoxysilane. Besides use in nanoimprint lithography, fluorosurfactant-assisted photo- lithography was demonstrated by Sakanoue et al. using commercial polymeric fluorosurfactants, such as Surflon S-386, S-651 (AGC) and Novec FC-4432 (3M).57 It should be noted that, due to the unique properties of fluorinated surfactants, examples of nonfluorinated surfactants with equivalent characteristics to those of fluorinated surfactants are limited and have been used in few resist formulations. 7 Nanoimprint Lithography While nanoimprint lithography is not today a mainstream patterning technology, it has the poten- tial to be introduced soon for specific patterning applications. A mold with nm-scale features is used to imprint polymer or a photopolymerizable monomer mixture to form the pattern in the transparent mold.58,59 In the former case, many polymers have been explored for nanoimprinting but a mold release agent such as a poly(perfluoroether) is usually added to the surface of the mold. In the latter case, fluorochemical units such as those used in BARCs and ARCs including perfluoralkyl segments or hexafluoroisopropanol groups have been used.60 In all cases, removal of the polymer from the mold is an important step in the production of the pattern and for this reason, fluoropolymers are frequently used. It is worth being aware of this approach to high- resolution pattern formation because some early attempts at process development depend on the use of fluorinated photoresists. The fluoropolymer has, in addition to excellent release proper- ties, the advantage that air, which can be trapped in the process, is easily dissolved in the fluo- ropolymer thereby eliminating trapped bubbles and does not seem to affect pattern formation. Therefore, fluoropolymers are often preferred in this process. This technology area is new enough that little or no reported work has been carried out on the environmental fate of such materials. Alternate materials for this process include silicones that can be used for their mold release properties.61 This area is attracting strong interest and demonstrates that nonfluorinated materials 7 Nanoimprint Lithography While nanoimprint lithography is not today a mainstream patterning technology, it has the poten- tial to be introduced soon for specific patterning applications. A mold with nm-scale features is used to imprint polymer or a photopolymerizable monomer mixture to form the pattern in the transparent mold.58,59 In the former case, many polymers have been explored for nanoimprinting but a mold release agent such as a poly(perfluoroether) is usually added to the surface of the mold. In the latter case, fluorochemical units such as those used in BARCs and ARCs including perfluoralkyl segments or hexafluoroisopropanol groups have been used.60 In all cases, removal of the polymer from the mold is an important step in the production of the pattern and for this reason, fluoropolymers are frequently used. It is worth being aware of this approach to high- resolution pattern formation because some early attempts at process development depend on the use of fluorinated photoresists. The fluoropolymer has, in addition to excellent release proper- ties, the advantage that air, which can be trapped in the process, is easily dissolved in the fluo- ropolymer thereby eliminating trapped bubbles and does not seem to affect pattern formation. Therefore, fluoropolymers are often preferred in this process. This technology area is new enough that little or no reported work has been carried out on the environmental fate of such materials. Alternate materials for this process include silicones that can be used for their mold release properties.61 This area is attracting strong interest and demonstrates that nonfluorinated materials J. Micro/Nanopattern. Mater. Metrol. 010901-16 Jan–Mar 2022 • Vol. 21(1) 341 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . perform well, but at this time it has not been established if silicone materials are superior in performance. Etch characteristics and wear properties are of course different between fluoropol- ymers and silicones. J. Micro/Nanopattern. Mater. Metrol. 010901-16 Jan–Mar 2022 • Vol. 21(1) 341 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . perform well, but at this time it has not been established if silicone materials are superior in performance. Etch characteristics and wear properties are of course different between fluoropol- ymers and silicones. 8 PFOS/PFAS Remediation As noted above, the strength of the C─F bond creates materials with unique and technologically useful properties in semiconductor processing. That same bond strength also results in strong re- sistance toward physical, chemical, and biological degradation. Due to this strong resistance to degradation, PFAS compounds in general are extremely stable in the environment. In addition, such compounds have been found to be bioaccumulative.62 Extensive literature exists describing the detection of a number of PFAS compounds in drinking water.63 Postuse PFAS waste treatment methods including advanced oxidation processes,64 reductive decomposition processes (aqueous electrons, hydrated electrons, etc.), and incineration have been developed for mitigation purposes.59 Among these methods, advanced oxidation processes do not show high efficacy for PFAS degradation due to the high electronegativity of the fluorine atoms. More work will need to be done to assess the relevance to the kinds of fluorinated materials discussed in this paper. Recent actions by the EPA include interim recommendations for addressing groundwater contaminated with PFOA and PFOS, published method 533 for detection of PFAS compounds in drinking water, an updated list of 172 PFAS chemicals subject to toxics release inventory reporting, a proposal to regulate PFOA and PFOS in drinking water and significant new use rule for certain PFAS in manufactured products.65 Significant data gaps presently exist in dealing with PFAS and PFOS materials. The EPA is also leading a national effort to under- stand PFAS and reduce PFAS risks to the public through the implementation of its PFAS action plan and through active engagement and partnership with other government agencies and constituencies.66 8 PFOS/PFAS Remediation As noted above, the strength of the C─F bond creates materials with unique and technologically useful properties in semiconductor processing. That same bond strength also results in strong re- sistance toward physical, chemical, and biological degradation. Due to this strong resistance to degradation, PFAS compounds in general are extremely stable in the environment. In addition, such compounds have been found to be bioaccumulative.62 Extensive literature exists describing the detection of a number of PFAS compounds in drinking water.63 Postuse PFAS waste treatment methods including advanced oxidation processes,64 reductive decomposition processes (aqueous electrons, hydrated electrons, etc.), and incineration have been developed for mitigation purposes.59 Among these methods, advanced oxidation processes do not show high efficacy for PFAS degradation due to the high electronegativity of the fluorine atoms. More work will need to be done to assess the relevance to the kinds of fluorinated materials discussed in this paper. Recent actions by the EPA include interim recommendations for addressing groundwater contaminated with PFOA and PFOS, published method 533 for detection of PFAS compounds in drinking water, an updated list of 172 PFAS chemicals subject to toxics release inventory reporting, a proposal to regulate PFOA and PFOS in drinking water and significant new use rule for certain PFAS in manufactured products.65 Significant data gaps presently exist in dealing with PFAS and PFOS materials. The EPA is also leading a national effort to under- stand PFAS and reduce PFAS risks to the public through the implementation of its PFAS action plan and through active engagement and partnership with other government agencies and constituencies.66 9 Summary Fluorinated materials play a useful and often essential role in many aspects of semiconductor processing. In our review of the technical literature, we have examined six major applications of fluorochemicals in photolithography and semiconductor processing and identified an emerging technology, nanoimprint lithography, see Table 1. These fluorochemicals are employed as com- ponents of PAGs, as components of photoresists, as elements of high-temperature polymers, and as ingredients in ARCs, BARCs, and as topcoats, frequently satisfying the “essential use” cri- terion. However, there is a strong societal interest in eliminating their use, and “essential use” is a stopgap situation in which replacements are actively sought. The “essential use” concept expects that PFAS uses considered essential today should be continually reviewed for potential removal or replacement by new technologies and be targeted by innovation toward alternatives. The con- cept does not support long-term and large-scale remediation technologies to justify the ongoing use of PFAS chemicals. Thus, the challenges going forward are to find a means to replace PFAS components that achieve or surpass today’s current performance characteristics in the following current and pos- sible future lithography systems. 9 Summary Fluorinated materials play a useful and often essential role in many aspects of semiconductor processing. In our review of the technical literature, we have examined six major applications of fluorochemicals in photolithography and semiconductor processing and identified an emerging technology, nanoimprint lithography, see Table 1. These fluorochemicals are employed as com- ponents of PAGs, as components of photoresists, as elements of high-temperature polymers, and as ingredients in ARCs, BARCs, and as topcoats, frequently satisfying the “essential use” cri- terion. However, there is a strong societal interest in eliminating their use, and “essential use” is a stopgap situation in which replacements are actively sought. The “essential use” concept expects that PFAS uses considered essential today should be continually reviewed for potential removal or replacement by new technologies and be targeted by innovation toward alternatives. The con- cept does not support long-term and large-scale remediation technologies to justify the ongoing use of PFAS chemicals. Thus, the challenges going forward are to find a means to replace PFAS components that achieve or surpass today’s current performance characteristics in the following current and pos- sible future lithography systems. 1. The use of fluorination in PAGs is to enhance the acidity (make pK a ≪ 1) of the acid produced in the region of exposure of a photoresist. The formation of acid to induce a solubility change is the critical step in today’s chemically amplified photoresists, the workhorse family of photoresists that enable the production of the vast majority of semi- conductors. The presence of a fluorinated unit adjacent to the sulfonic acid gives the acid its ability to efficiently release a proton that reacts with the resist polymer to create a solubility switch. Subsequent development forms a pattern in the photoresist. Today there is no effective alternative to a fluorinated sulfonic acid and this situation applies to chemi- cally amplified photoresists across all wavelengths of lithography from 248 nm to EUV. Efforts to reduce the amount of fluorination in a PAG molecule have been demonstrated, but a survey of the current literature has not shown that complete elimination of 1. The use of fluorination in PAGs is to enhance the acidity (make pK a ≪ 1) of the acid produced in the region of exposure of a photoresist. The formation of acid to induce a solubility change is the critical step in today’s chemically amplified photoresists, the workhorse family of photoresists that enable the production of the vast majority of semi- conductors. The presence of a fluorinated unit adjacent to the sulfonic acid gives the acid its ability to efficiently release a proton that reacts with the resist polymer to create a solubility switch. Subsequent development forms a pattern in the photoresist. Today there is no effective alternative to a fluorinated sulfonic acid and this situation applies to chemi- cally amplified photoresists across all wavelengths of lithography from 248 nm to EUV. Efforts to reduce the amount of fluorination in a PAG molecule have been demonstrated, but a survey of the current literature has not shown that complete elimination of J. Micro/Nanopattern. Mater. Metrol. 010901-17 Jan–Mar 2022 • Vol. 21(1) 342 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-17 Jan–Mar 2022 • Vol. 21(1) 342 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . fluorination has produced a successful alternative. However, it is very likely that fluorine- free alternatives, which perform equally well and can easily take the place of the fluo- rinated compounds used today, will be more widely used, and developed in the coming years. Fluorinated polyimides use the presence of a fluorinated unit to improve the dielec- tric constant of the material and make it a better insulator while retaining excellent thermal stability. This combination of characteristics has not been effectively achieved by alter- nate means. 2. Other materials like poly(benzoxazole)s also receive an important performance boost from the incorporation of a fluorinated unit. 3. Antireflection coatings (ARC, BARC, and TARC) and other coatings such as topcoats or EBL use fluorinated components to limit the miscibility of this added layer with a photo- resist or other organic layer in the semiconductor manufacturing process. As surface layers, they also provide barrier properties and when used as a topcoat act to protect the photoresist from interactions with the immersion fluid (currently water) used in 193-nm lithography. However, while these features can in part be replicated by other systems the necessary combination of properties (immiscibility, surface wetting properties, barrier properties, low refractive index) has not been successfully achieved. 4. Fluorinated surfactants provide a specific performance advantage since their surface energy is much lower than hydrocarbon or silicone surfactants resulting in the need for less surfactant material in formulations. Additionally, properties including very low sur- face energy, thermal and mechanical stability, and low refractive index provide benefits to coating and etching processes. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality), and the surface activity of fluorocarbon surfactants makes them readily useable with ARCs and photoresist materials. 5. Nanoimprint lithography may become an important technology for some specialized forms of nanopatterning, and there is interest in the use of fluoromaterials in nanoimprint lithography. Current studies have not yet fully demonstrated that fluorine-free alternatives are successful in producing fine-featured patterns in a production capable system. fluorination has produced a successful alternative. However, it is very likely that fluorine- free alternatives, which perform equally well and can easily take the place of the fluo- rinated compounds used today, will be more widely used, and developed in the coming years. Fluorinated polyimides use the presence of a fluorinated unit to improve the dielec- tric constant of the material and make it a better insulator while retaining excellent thermal stability. This combination of characteristics has not been effectively achieved by alter- nate means. 2. Other materials like poly(benzoxazole)s also receive an important performance boost from the incorporation of a fluorinated unit. 3. Antireflection coatings (ARC, BARC, and TARC) and other coatings such as topcoats or EBL use fluorinated components to limit the miscibility of this added layer with a photo- resist or other organic layer in the semiconductor manufacturing process. As surface layers, they also provide barrier properties and when used as a topcoat act to protect the photoresist from interactions with the immersion fluid (currently water) used in 193-nm lithography. However, while these features can in part be replicated by other systems the necessary combination of properties (immiscibility, surface wetting properties, barrier properties, low refractive index) has not been successfully achieved. 4. Fluorinated surfactants provide a specific performance advantage since their surface energy is much lower than hydrocarbon or silicone surfactants resulting in the need for less surfactant material in formulations. Additionally, properties including very low sur- face energy, thermal and mechanical stability, and low refractive index provide benefits to coating and etching processes. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality), and the surface activity of fluorocarbon surfactants makes them readily useable with ARCs and photoresist materials. 5. Nanoimprint lithography may become an important technology for some specialized forms of nanopatterning, and there is interest in the use of fluoromaterials in nanoimprint lithography. Current studies have not yet fully demonstrated that fluorine-free alternatives are successful in producing fine-featured patterns in a production capable system. Appendix Table 1 summarizes the function of the fluorinated compounds required for the main lithographic processes. In addition, non-fluorinated alternatives and their current feasibility are shown. Table 1 Purpose, properties of fluorocompounds for lithographic patterning and semiconductor processing. Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative Appendix Table 1 summarizes the function of the fluorinated compounds required for the main lithographic processes. In addition, non-fluorinated alternatives and their current feasibility are shown. Table 1 Purpose, properties of fluorocompounds for lithographic patterning and semiconductor processing. Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative PAGs Generation of strong Fluorinated All successfully Not yet acid upon exposure to sulfonium- and demonstrated demonstrated in UV light, when iodonium-acid salts/ alternatives have completely fluorine- fluorination acid strong fluorinated segments free materials groups. Control of electronegativity of —some down to one location and F atom—creates CF2 unit distribution of superacid material generated acids, capable of mixing especially in high- with photoresist resolution applications Antireflection Low refractive index, Largely fluorinated Fluorine-free ARC requirements coatings (top and low surface energy, units in acrylate/ alternatives known. different in 193- and bottom versions and good barrier methacrylate/ But necessary 193-nm immersion have different properties styrene-based properties not yet lithography— requirements) copolymers, very low broadly fluorine-free refractive index, and demonstrated in 193 systems not fully excellent barrier immersion demonstrated properties PAGs Generation of strong Fluorinated All successfully Not yet acid upon exposure to sulfonium- and demonstrated demonstrated in UV light, when iodonium-acid salts/ alternatives have completely fluorine- fluorination acid strong fluorinated segments free materials groups. Control of electronegativity of —some down to one location and F atom—creates CF2 unit distribution of superacid material generated acids, capable of mixing especially in high- with photoresist resolution applications Antireflection Low refractive index, Largely fluorinated Fluorine-free ARC requirements coatings (top and low surface energy, units in acrylate/ alternatives known. different in 193- and bottom versions and good barrier methacrylate/ But necessary 193-nm immersion have different properties styrene-based properties not yet lithography— requirements) copolymers, very low broadly fluorine-free refractive index, and demonstrated in 193 systems not fully excellent barrier immersion demonstrated properties J. Micro/Nanopattern. Mater. Metrol. 010901-18 Jan–Mar 2022 • Vol. 21(1) 343 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Table 1 (Continued). Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative J. Micro/Nanopattern. Mater. Metrol. 010901-18 Jan–Mar 2022 • Vol. 21(1) 343 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Table 1 (Continued). Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative Topcoat Provides barrier layer Largely fluorinated Lacking satisfactory Not yet (for 193-nm for 193-nm immersion acrylate/ options demonstrated in immersion photoresists applied on methacrylate/ fluorine-free photoresist) top of photoresist and styrene-based materials prevents leaching of copolymers, excellent photoactive barrier properties with components. Protects fluorinated the photoresist from components contact with immersion liquid (water) EBL (for 193-nm Forms a protective Largely acrylate/ Lacking satisfactory Not yet immersion surface layer for 193- methacrylate/ options demonstrated in photoresist) nm immersion styrene-based fluorine-free photoresists and copolymers, excellent materials prevents leaching of barrier properties with photoactive fluorinated components. components Incorporated as part of photoresist and segregates to film surface during the coating process. Protects the photoresist from contact with immersion liquid (water) Polyimides Required stress buffer Tetracarboxylic acid Novel polyimides— Not yet (photopatternable) coat between chip and anhydride derivatives suitable fluorine-free demonstrated in package to prevent and aromatic alternatives have not fluorine-free premature device diamines/solubility in demonstrated equal materials failure; especially good organic solvents, low performance electrical insulating dielectric constants, characteristics and high thermal and thermooxidative stability; requires negative tone solvent to develop Polybenzoxazoles Stress buffer coat to Low dielectric Novel Not yet (photopatternable) prevent premature constants, and high polybenzoxazoles— demonstrated in device failure; high- thermal and suitable fluorine-free fluorine-free temperature stability thermooxidative alternatives have not materials and good insulating stability; processed demonstrated equal characteristics using positive resist performance developer Nanoimprint Excellent release Fluoropolymers/low Silicone-based Potentially good but Lithography characteristics; low surface adherence release agents not yet established fluoropolymers surface energy and fluoromonomers reported to dissolve trapped air making them ideal for filling the micromolds of nanoimprint lithography Nonionic Improve coat quality in Nonionic fluorinated For a number of Not yet fluorinated thin lithographic films segments with water- applications, demonstrated in surfactants (e.g., photoresists and soluble units alternatives have not fluorine-free BARCs); compatibility demonstrated equal materials with photoresists and performance TARC/BARC structures; high efficiency of fluorinated surfactants requires very little additive and enables better performance Topcoat Provides barrier layer Largely fluorinated Lacking satisfactory Not yet (for 193-nm for 193-nm immersion acrylate/ options demonstrated in immersion photoresists applied on methacrylate/ fluorine-free photoresist) top of photoresist and styrene-based materials prevents leaching of copolymers, excellent photoactive barrier properties with components. Protects fluorinated the photoresist from components contact with immersion liquid (water) EBL (for 193-nm Forms a protective Largely acrylate/ Lacking satisfactory Not yet immersion surface layer for 193- methacrylate/ options demonstrated in photoresist) nm immersion styrene-based fluorine-free photoresists and copolymers, excellent materials prevents leaching of barrier properties with photoactive fluorinated components. components Incorporated as part of photoresist and segregates to film surface during the coating process. Protects the photoresist from contact with immersion liquid (water) Polyimides Required stress buffer Tetracarboxylic acid Novel polyimides— Not yet (photopatternable) coat between chip and anhydride derivatives suitable fluorine-free demonstrated in package to prevent and aromatic alternatives have not fluorine-free premature device diamines/solubility in demonstrated equal materials failure; especially good organic solvents, low performance electrical insulating dielectric constants, characteristics and high thermal and thermooxidative stability; requires negative tone solvent to develop Polybenzoxazoles Stress buffer coat to Low dielectric Novel Not yet (photopatternable) prevent premature constants, and high polybenzoxazoles— demonstrated in device failure; high- thermal and suitable fluorine-free fluorine-free temperature stability thermooxidative alternatives have not materials and good insulating stability; processed demonstrated equal characteristics using positive resist performance developer Nanoimprint Excellent release Fluoropolymers/low Silicone-based Potentially good but Lithography characteristics; low surface adherence release agents not yet established fluoropolymers surface energy and fluoromonomers reported to dissolve trapped air making them ideal for filling the micromolds of nanoimprint lithography Nonionic Improve coat quality in Nonionic fluorinated For a number of Not yet fluorinated thin lithographic films segments with water- applications, demonstrated in surfactants (e.g., photoresists and soluble units alternatives have not fluorine-free BARCs); compatibility demonstrated equal materials with photoresists and performance TARC/BARC structures; high efficiency of fluorinated surfactants requires very little additive and enables better performance J. Micro/Nanopattern. Mater. Metrol. 010901-19 Jan–Mar 2022 • Vol. 21(1) 344 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Acknowledgments The authors gratefully acknowledge the Semiconductor PAG Consortium for financial support in the preparation of this manuscript. In particular, we thank Brook Tvermoes (IBM) for very helpful input in the preparation of this manuscript. Each author contributed significantly to the writing of this manuscript. The basis of this manuscript was a report commissioned by the Semiconductor PAG Consortium. J. Micro/Nanopattern. Mater. 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Metrol. 010901-21 Jan–Mar 2022 • Vol. 21(1) 346 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . 46. D. Sanders et al., “High contact angle fluorosulfonamide-based materials for immersion lithography,” Proc. SPIE 7639, 763925 (2010). 47. M. Khojasteh et al., “Building an immersion topcoat from the ground up: materials perspec- tive,” Proc. SPIE 6519, 651907 (2007). 48. D. P. Sanders, R. Sooriyakumaran, and R. A. DiPietro, “Hexafluoroalcohol-functionalized methacrylate monomers for lithographic/nanopatterning materials,” in Material Matters, K. Patel, Ed., IBM Almaden Research Center, San Jose, California (2011). 49. Q. Lin et al., “Resolution enhanced top antireflective coating materials for ArF immersion lithography [6153-74],” Proc. SPIE, 61531Z (2006). 50. D. Wang et al., “Novel embedded barrier layer materials for ArF non-topcoat immersion applications,” Proc. SPIE 7140, 71402I (2008). 51. J. Kaitz et al., “High contact angle embedded barrier layer materials for next-generation 193 immersion lithography,” Proc. SPIE 11612, 116120U (2021). 52. C. Neef et al., “New BARC materials for the 65-nm node in 193-nm lithography,” Proc. SPIE 5376, 684–688 (2004). 53. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” J. Micro/Nanolithogr., MEMS, MOEMS 12, 031114 (2013). 54. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” Proc. SPIE 7970, 79700T (2011). 55. M. Lin et al., “Role of surfactants in adhesion reduction for step and flash imprint lithog- raphy,” J. Micro/Nanolithogr., MEMS, MOEMS 7, 033005 (2008). 56. M. Zelsmann et al., “Degradation and surfactant-aided regeneration of fluorinated anti- sticking mold treatments in UV nanoimprint lithography,” Microelectron. Eng. 87, 1029–1032 (2010). 57. T. Sakanoue et al., “Fluorosurfactant-assisted photolithography for patterning of perfluor- opolymers and solution- processed organic semiconductors for printed displays,” Appl. Phys. Express 7, 101602 (2014). 58. S. Ito et al., “Investigation of fluorinated (Meth)Acrylate monomers and macromonomers suitable for a hydroxy- containing acrylate monomer in UV nanoimprinting,” Langmuir 30, 7127–7133 (2014). 59. K. Honda et al., “Room-temperature nanoimprint lithography for crystalline poly(fluor- oalkyl acrylate) thin films,” Soft Matter 6, 870–875 (2010). 60. M. Zelsmann et al., “Double-anchoring fluorinated molecules for antiadhesion mold treat- ment in UV nanoimprint lithography,” J. Vac. Sci. Technol., B: Microelectron. Nanometer Struct.–Process. Meas., Phenom. 27, 2873–2876 (2009). 61. L. J. Guo, “Nanoimprint lithography: methods and material requirements,” Adv. Mater. 19, 495–513 (2007). 62. K. H. Kucharzyk et al., “Novel treatment technologies for PFAS compounds: a critical review,” J. Environ. Manage. 204, 757–764 (2017). 63. Z. R. Hopkins et al., “Recently detected drinking water contaminants: GenX and other per- and polyfluoroalkyl ether acids,” J. AWWA 110, 13–28 (2018). 64. H. F. Schröder and R. J. W. Meesters, “Stability of fluorinated surfactants in advanced oxi- dation processes— a follow up of degradation products using flow injection– mass spec- trometry, liquid chromatography–mass spectrometry and liquid chromatography–multiple stage mass spectrometry,” J. Chromatogr. A 1082, 110–119 (2005). 65. A. J. R. Gillespie, “US EPA’s science-based approach to understanding and managing envi- ronmental risk from PFAS,” 2020, https://www.epa.gov/sites/production/files/2020-09/ documents/epa_pfas_rd_overview_complete_2020_0 9_25.pdf 66. A. Hanf, “Research on per- and polyfluoroalkyl substances (PFAS),” 2021, https://www.epa .gov/chemical-research/research-and-polyfluoroalkyl-substances-pfas 46. D. Sanders et al., “High contact angle fluorosulfonamide-based materials for immersion lithography,” Proc. SPIE 7639, 763925 (2010). 47. M. Khojasteh et al., “Building an immersion topcoat from the ground up: materials perspec- tive,” Proc. SPIE 6519, 651907 (2007). 48. D. P. Sanders, R. Sooriyakumaran, and R. A. DiPietro, “Hexafluoroalcohol-functionalized methacrylate monomers for lithographic/nanopatterning materials,” in Material Matters, K. Patel, Ed., IBM Almaden Research Center, San Jose, California (2011). 49. Q. Lin et al., “Resolution enhanced top antireflective coating materials for ArF immersion lithography [6153-74],” Proc. SPIE, 61531Z (2006). 50. D. Wang et al., “Novel embedded barrier layer materials for ArF non-topcoat immersion applications,” Proc. SPIE 7140, 71402I (2008). 51. J. Kaitz et al., “High contact angle embedded barrier layer materials for next-generation 193 immersion lithography,” Proc. SPIE 11612, 116120U (2021). 52. C. Neef et al., “New BARC materials for the 65-nm node in 193-nm lithography,” Proc. SPIE 5376, 684–688 (2004). 53. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” J. Micro/Nanolithogr., MEMS, MOEMS 12, 031114 (2013). 54. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” Proc. SPIE 7970, 79700T (2011). 55. M. Lin et al., “Role of surfactants in adhesion reduction for step and flash imprint lithog- raphy,” J. Micro/Nanolithogr., MEMS, MOEMS 7, 033005 (2008). 56. M. Zelsmann et al., “Degradation and surfactant-aided regeneration of fluorinated anti- sticking mold treatments in UV nanoimprint lithography,” Microelectron. Eng. 87, 1029–1032 (2010). 57. T. Sakanoue et al., “Fluorosurfactant-assisted photolithography for patterning of perfluor- opolymers and solution- processed organic semiconductors for printed displays,” Appl. Phys. Express 7, 101602 (2014). 58. S. Ito et al., “Investigation of fluorinated (Meth)Acrylate monomers and macromonomers suitable for a hydroxy- containing acrylate monomer in UV nanoimprinting,” Langmuir 30, 7127–7133 (2014). 59. K. Honda et al., “Room-temperature nanoimprint lithography for crystalline poly(fluor- oalkyl acrylate) thin films,” Soft Matter 6, 870–875 (2010). 60. M. Zelsmann et al., “Double-anchoring fluorinated molecules for antiadhesion mold treat- ment in UV nanoimprint lithography,” J. Vac. Sci. Technol., B: Microelectron. Nanometer Struct.–Process. Meas., Phenom. 27, 2873–2876 (2009). 61. L. J. Guo, “Nanoimprint lithography: methods and material requirements,” Adv. Mater. 19, 495–513 (2007). 62. K. H. Kucharzyk et al., “Novel treatment technologies for PFAS compounds: a critical review,” J. Environ. Manage. 204, 757–764 (2017). 63. Z. R. Hopkins et al., “Recently detected drinking water contaminants: GenX and other per- and polyfluoroalkyl ether acids,” J. AWWA 110, 13–28 (2018). 64. H. F. Schröder and R. J. W. Meesters, “Stability of fluorinated surfactants in advanced oxi- dation processes— a follow up of degradation products using flow injection– mass spec- trometry, liquid chromatography–mass spectrometry and liquid chromatography–multiple stage mass spectrometry,” J. Chromatogr. A 1082, 110–119 (2005). 65. A. J. R. Gillespie, “US EPA’s science-based approach to understanding and managing envi- ronmental risk from PFAS,” 2020, https://www.epa.gov/sites/production/files/2020-09/ documents/epa_pfas_rd_overview_complete_2020_0 9_25.pdf 66. A. Hanf, “Research on per- and polyfluoroalkyl substances (PFAS),” 2021, https://www.epa .gov/chemical-research/research-and-polyfluoroalkyl-substances-pfas Christopher K. Ober is the Francis Bard professor of materials engineering at Cornell University. He has pioneered new materials for photolithography and studies the biology- materials interface. He received his BSc degree in honors chemistry (Co-op) from the University of Waterloo, Ontario, Canada, in 1978 and his MS and PhD degrees in polymer sci- ence and engineering from the University of Massachusetts (Amherst) in 1982. From 1982 to J. Micro/Nanopattern. Mater. Metrol. 010901-22 Jan–Mar 2022 • Vol. 21(1) 347 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Christopher K. Ober is the Francis Bard professor of materials engineering at Cornell University. He has pioneered new materials for photolithography and studies the biology- materials interface. He received his BSc degree in honors chemistry (Co-op) from the University of Waterloo, Ontario, Canada, in 1978 and his MS and PhD degrees in polymer sci- ence and engineering from the University of Massachusetts (Amherst) in 1982. From 1982 to J. Micro/Nanopattern. Mater. Metrol. 010901-22 Jan–Mar 2022 • Vol. 21(1) 347 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . 1986, he was a senior member of the research staff at the Xerox Research Centre of Canada, where he worked on marking materials. He joined Cornell University in the Department of Materials Science and Engineering in 1986. Recently, he served as interim dean of the College of Engineering. Currently, he is a director of the Cornell Nanoscale Facility. From 2014 to 2021, he served on the executive committee (its governing group) of The International Union of Pure and Applied Chemistry (IUPAC). He is a fellow of the ACS (2009), APS (2014), and AAAS (2014). He is a SPIE Senior Member (2018). He received his ACS Award in applied polymer science in 2006, the Gutenberg Research Award in 2009, the Society of Polymer Science Japan (SPSJ) International Prize in 2013, and the Japan Photopolymer Science and Technology Outstanding Achievement Award in 2015. 1986, he was a senior member of the research staff at the Xerox Research Centre of Canada, where he worked on marking materials. He joined Cornell University in the Department of Materials Science and Engineering in 1986. Recently, he served as interim dean of the College of Engineering. Currently, he is a director of the Cornell Nanoscale Facility. From 2014 to 2021, he served on the executive committee (its governing group) of The International Union of Pure and Applied Chemistry (IUPAC). He is a fellow of the ACS (2009), APS (2014), and AAAS (2014). He is a SPIE Senior Member (2018). He received his ACS Award in applied polymer science in 2006, the Gutenberg Research Award in 2009, the Society of Polymer Science Japan (SPSJ) International Prize in 2013, and the Japan Photopolymer Science and Technology Outstanding Achievement Award in 2015. Florian Käfer received his PhD from the University of Bayreuth, Germany, in 2019. Throughout his PhD thesis he focused on the synthesis of new thermoresponsive polymers and their applications. Since 2018, he is a postdoctoral fellow in the Department of Materials Science and Engineering at Cornell University, supervised by professor Christopher Ober. Thereby, he is focused on the synthesis of polymer-grafted nanoparticles as well as the design and synthesis of sequence-controlled small molecules as future photoresist materials for extreme ultraviolet (EUV) photolithography. Jingyuan Deng graduated from Nagoya University in 2016 with a BEng in applied chemistry and the University of Tokyo in 2018 with an MEng in chemistry and biotechnology. He is cur- rently pursuing his PhD in materials chemistry under the supervision of professor Christopher Ober at Cornell University. His current research focuses on the development of novel photoresist materials for EUV lithography. Florian Käfer received his PhD from the University of Bayreuth, Germany, in 2019. Throughout his PhD thesis he focused on the synthesis of new thermoresponsive polymers and their applications. Since 2018, he is a postdoctoral fellow in the Department of Materials Science and Engineering at Cornell University, supervised by professor Christopher Ober. Thereby, he is focused on the synthesis of polymer-grafted nanoparticles as well as the design and synthesis of sequence-controlled small molecules as future photoresist materials for extreme ultraviolet (EUV) photolithography. Jingyuan Deng graduated from Nagoya University in 2016 with a BEng in applied chemistry and the University of Tokyo in 2018 with an MEng in chemistry and biotechnology. He is cur- rently pursuing his PhD in materials chemistry under the supervision of professor Christopher Ober at Cornell University. His current research focuses on the development of novel photoresist materials for EUV lithography. J. Micro/Nanopattern. Mater. Metrol. 010901-23 Jan–Mar 2022 • Vol. 21(1) 348 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use 349 350 351 From: Balduzzi, Kevin M (DEC) Sent: Tuesday, October 31, 2023 6:59:34 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: Berkman, Thomas S (DEC) ; Glance, Dereth B (DEC) ; Petronis, Katharine J (DEC) ; Sheen, Margaret A (DEC) ; Whitehead, Daniel T (DEC) ; Sheeley, Scott E (DEC) Subject: NYSDEC Micron White Pine Draft Scope Response NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Good afternoon Director Petrovitch Attached are DEC’s comments on the Draft Scope for the Micron Semiconductor Fabrication Draft Environmental Impact Statement. Thank you. Kevin M. Balduzzi Regional Permit Administrator, Division of Environmental Permits New York State Department of Environmental Conservation, Region 7 J. Micro/Nanopattern. Mater. Metrol. 010901-23 Jan–Mar 2022 • Vol. 21(1) 348 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use 349 350 351 From: Balduzzi, Kevin M (DEC) Sent: Tuesday, October 31, 2023 6:59:34 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: Berkman, Thomas S (DEC) ; Glance, Dereth B (DEC) ; Petronis, Katharine J (DEC) ; Sheen, Margaret A (DEC) ; Whitehead, Daniel T (DEC) ; Sheeley, Scott E (DEC) Subject: NYSDEC Micron White Pine Draft Scope Response NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Good afternoon Director Petrovitch Attached are DEC’s comments on the Draft Scope for the Micron Semiconductor Fabrication Draft Environmental Impact Statement. Thank you. Kevin M. Balduzzi Regional Permit Administrator, Division of Environmental Permits New York State Department of Environmental Conservation, Region 7 5786 Widewaters Parkway, Syracuse, NY 13214-1867 1 352 P: (315) 426-7493 | F: (315) 426-7425 | kevin.balduzzi@dec.ny.gov www.dec.ny.gov | | | 2 353 October 31, 2023 Robert Petrovitch-Director Onondaga County Industrial Development Agency 335 Montgomery Street, 2nd floor Syracuse, NY 13202 RE: SEQR Draft EIS Scoping Comments-Micron Semiconductor Fabrication White Pine Industrial Park, Town of Clay, Onondaga County DEC ID 7-3124-00575 Dear Mr. Petrovitch: The New York State Department of Environmental Conservation (DEC) reviewed the “Draft SEQRA Scope of Work” and Full Environmental Assessment Form (EAF) documents, received on September 25, 2023, associated with the State Environmental Quality Review (SEQR) for the proposed Micron Semiconductor Fabrication project (Proposed Project) proposed at the White Pine Industrial Park in the Town of Clay. Based on current information, DEC’s expected jurisdiction(s) under the Environmental Conservation Law (ECL) are listed in Attachment A. Please note that DEC may identify additional jurisdictions as information becomes available. 5786 Widewaters Parkway, Syracuse, NY 13214-1867 1 352 P: (315) 426-7493 | F: (315) 426-7425 | kevin.balduzzi@dec.ny.gov www.dec.ny.gov | | | 2 353 October 31, 2023 Robert Petrovitch-Director Onondaga County Industrial Development Agency 335 Montgomery Street, 2nd floor Syracuse, NY 13202 RE: SEQR Draft EIS Scoping Comments-Micron Semiconductor Fabrication White Pine Industrial Park, Town of Clay, Onondaga County DEC ID 7-3124-00575 Dear Mr. Petrovitch: The New York State Department of Environmental Conservation (DEC) reviewed the “Draft SEQRA Scope of Work” and Full Environmental Assessment Form (EAF) documents, received on September 25, 2023, associated with the State Environmental Quality Review (SEQR) for the proposed Micron Semiconductor Fabrication project (Proposed Project) proposed at the White Pine Industrial Park in the Town of Clay. Based on current information, DEC’s expected jurisdiction(s) under the Environmental Conservation Law (ECL) are listed in Attachment A. Please note that DEC may identify additional jurisdictions as information becomes available. DEC offers the following comments on the draft scope for consideration in the preparation of the final scope for the Draft Environmental Impact Statement (DEIS). General Comments 1. Section 5.3.1 outlines technical studies to be performed for the DEIS. Both the “Geology, Soils, and Topography” and “Utilities & Infrastructure” sections briefly address stormwater, but do not include a specific heading for stormwater management. A separate chapter should be included for an evaluation of stormwater runoff (industrial and construction) and water quality. This section should identify the current requirements of DEC’s State Pollutant Discharge Elimination System (SPDES) Permits, including the Construction General Permit (GP-0-20-001) and Multi-Sector General Permit (GP-0-23-001). The DEIS should evaluate how these requirements will be met. Sufficient information should be developed to identify the approximate size and location of necessary stormwater management measures and outfalls during and after construction. In addition, due to the scale of the project and the anticipated need to have large areas of soil exposed at any given time, the DEIS should evaluate the soil characteristics that may cause or contribute to erosion on site. A reference should be developed to identify any supporting information or reports that will be included as an DEC offers the following comments on the draft scope for consideration in the preparation of the final scope for the Draft Environmental Impact Statement (DEIS). General Comments 1. Section 5.3.1 outlines technical studies to be performed for the DEIS. Both the “Geology, Soils, and Topography” and “Utilities & Infrastructure” sections briefly address stormwater, but do not include a specific heading for stormwater management. A separate chapter should be included for an evaluation of stormwater runoff (industrial and construction) and water quality. This section should identify the current requirements of DEC’s State Pollutant Discharge Elimination System (SPDES) Permits, including the Construction General Permit (GP-0-20-001) and Multi-Sector General Permit (GP-0-23-001). The DEIS should evaluate how these requirements will be met. Sufficient information should be developed to identify the approximate size and location of necessary stormwater management measures and outfalls during and after construction. In addition, due to the scale of the project and the anticipated need to have large areas of soil exposed at any given time, the DEIS should evaluate the soil characteristics that may cause or contribute to erosion on site. A reference should be developed to identify any supporting information or reports that will be included as an 354 appendix. The Stormwater Pollution Prevention Plan (SWPPP) needs to address hydraulic changes pre- and post-construction, and all changes to hydrology from filling in any wetlands, streams, and drainageways on site. It is important to note that while DEC’s Region 7 Division of Water and the Town of Clay will jointly evaluate the required SWPPP prepared by the Applicant, responsibility for the approval of the SWPPP lies with the Town of Clay as per the municipal separate stormwater sewer systems (MS4) General Permit (currently GP 0-15-003). When considering an overall approach to stormwater management at the Micron site, the DEIS should pay particular attention to Chapter 3 of the New York State Stormwater Management Design Manual (SMDM). This chapter focuses on Stormwater Management Planning. The SMDM requires a specific planning process when addressing stormwater management on a project site and guides the planner through steps to maintain pre-development natural hydrologic conditions of the site by application of environmentally sound development principles, such as green infrastructure, as well as treatment and control of runoff discharges from the site. Chapter 2 Project Alternatives and Description of the Proposed Project 354 appendix. The Stormwater Pollution Prevention Plan (SWPPP) needs to address hydraulic changes pre- and post-construction, and all changes to hydrology from filling in any wetlands, streams, and drainageways on site. It is important to note that while DEC’s Region 7 Division of Water and the Town of Clay will jointly evaluate the required SWPPP prepared by the Applicant, responsibility for the approval of the SWPPP lies with the Town of Clay as per the municipal separate stormwater sewer systems (MS4) General Permit (currently GP 0-15-003). When considering an overall approach to stormwater management at the Micron site, the DEIS should pay particular attention to Chapter 3 of the New York State Stormwater Management Design Manual (SMDM). This chapter focuses on Stormwater Management Planning. The SMDM requires a specific planning process when addressing stormwater management on a project site and guides the planner through steps to maintain pre-development natural hydrologic conditions of the site by application of environmentally sound development principles, such as green infrastructure, as well as treatment and control of runoff discharges from the site. Chapter 2 Project Alternatives and Description of the Proposed Project 2. The scoping documents only consider two development alternatives: build and reduced-scale. DEC recommends identifying additional potential development alternatives considering design and configuration changes to avoid or minimize potential impacts to wetlands, streams, and other sensitive natural resources. The area east of Burnett Road contains a large, forested wetland complex and portions of Youngs Creek; additional consideration should be given to avoiding development in this area. 3. Please include a discussion of potential alternatives and mitigation that could reduce energy and fuel demands during construction and the long-term operation of the facility, including renewable energy sources. Chapter 10 Natural Resources In addition to the details in Section 5.3.1 Technical Studies-Natural Resources, DEC believe the following items should be evaluated: 2. The scoping documents only consider two development alternatives: build and reduced-scale. DEC recommends identifying additional potential development alternatives considering design and configuration changes to avoid or minimize potential impacts to wetlands, streams, and other sensitive natural resources. The area east of Burnett Road contains a large, forested wetland complex and portions of Youngs Creek; additional consideration should be given to avoiding development in this area. 3. Please include a discussion of potential alternatives and mitigation that could reduce energy and fuel demands during construction and the long-term operation of the facility, including renewable energy sources. Chapter 10 Natural Resources In addition to the details in Section 5.3.1 Technical Studies-Natural Resources, DEC believe the following items should be evaluated: 4. The Utilities & Infrastructures narrative states that substantial off-site infrastructure improvements are required to support the Proposed Project. To the extent they can be included, natural resource impacts associated with these projects should be evaluated and described in the DEIS. The DEIS should also assess the presence of, and impacts to, wetlands, waterbodies, and threatened and endangered species for all linear utility construction projects, new infrastructure such as pump stations, and the expansion of existing infrastructure such as the Oak Orchard Wastewater Treatment Plant and the Lake Ontario water filtration plant. For linear pipeline construction projects, DEC recommends 2 355 considering and discussing horizontal directional drilling (HDD) pipelines under streams and wetlands to the greatest extent practicable. 5. The DEIS should include a table summarizing the amounts and types of wetlands, streams, and other waterbodies on the Proposed Project site, and those associated with the previous comment. The table should also quantify the impacts on these resources for phases 1 and 2, and the cumulative of both phases. 4. The Utilities & Infrastructures narrative states that substantial off-site infrastructure improvements are required to support the Proposed Project. To the extent they can be included, natural resource impacts associated with these projects should be evaluated and described in the DEIS. The DEIS should also assess the presence of, and impacts to, wetlands, waterbodies, and threatened and endangered species for all linear utility construction projects, new infrastructure such as pump stations, and the expansion of existing infrastructure such as the Oak Orchard Wastewater Treatment Plant and the Lake Ontario water filtration plant. For linear pipeline construction projects, DEC recommends 2 355 considering and discussing horizontal directional drilling (HDD) pipelines under streams and wetlands to the greatest extent practicable. 5. The DEIS should include a table summarizing the amounts and types of wetlands, streams, and other waterbodies on the Proposed Project site, and those associated with the previous comment. The table should also quantify the impacts on these resources for phases 1 and 2, and the cumulative of both phases. 6. The natural resource section states that potential adverse wetlands impacts will be assessed, and potential mitigation identified. The DEIS should also include a complete discussion on the avoidance and minimization of wetlands impacts, which are the first two analyses required prior to considering wetland mitigation under implementing regulatory programs for Section 404 of the Clean Water Act and Article 24 of the New York State Environmental Conservation Law. 7. The on-site and off-site wetland mitigation is described as “enhancement” in this section. The DEIS should include and discuss wetland creation and restoration prior to consideration of enhancement. Please see attachment B, which discusses DEC wetland mitigation requirements. This information should be discussed in the DEIS. 8. To the extent it is available, the DEIS should include the Proposed Project’s onsite wetland delineation and compensatory mitigation package being developed by Micron and its consultants. 9. The DEIS should address and discuss stream mitigation that will be completed to offset impacts to waterbodies on the Proposed Project site. 10. The DEIS should include an assessment of the functions and benefits of all the streams and wetlands on the Proposed Project site. 6. The natural resource section states that potential adverse wetlands impacts will be assessed, and potential mitigation identified. The DEIS should also include a complete discussion on the avoidance and minimization of wetlands impacts, which are the first two analyses required prior to considering wetland mitigation under implementing regulatory programs for Section 404 of the Clean Water Act and Article 24 of the New York State Environmental Conservation Law. 7. The on-site and off-site wetland mitigation is described as “enhancement” in this section. The DEIS should include and discuss wetland creation and restoration prior to consideration of enhancement. Please see attachment B, which discusses DEC wetland mitigation requirements. This information should be discussed in the DEIS. 8. To the extent it is available, the DEIS should include the Proposed Project’s onsite wetland delineation and compensatory mitigation package being developed by Micron and its consultants. 9. The DEIS should address and discuss stream mitigation that will be completed to offset impacts to waterbodies on the Proposed Project site. 10. The DEIS should include an assessment of the functions and benefits of all the streams and wetlands on the Proposed Project site. 11. The Acoustic Bat Survey Report and the Grassland Breeding Bird Survey Report, prepared for Micron New York by AKRF Inc., should be discussed and appended to the DEIS. Additionally, DEC's "Grass Land Bird Mitigation Requirements" is included as attachment C to this document, and the DEIS should reference these requirements in the mitigation discussion for grassland bird habitat impacts. 12. The natural resource analysis of the Proposed Project should also include details on wildlife that likely use the site based on habitat types and any ancillary observations made by on-site natural resource consultants. Additionally, the DEIS should discuss the impacts on the species associated with converting these habitats to an industrial site. 13. The C-Class Youngs Creek (Water Index Number ONT-66-11-14), located east of Burnett Road, is continuously connected to the Oneida River (Water Index Number ONT-66-11). with no known impassable barrier The site plan OCIDA included with the draft scope show portions of the Proposed Project filling 3 356 11. The Acoustic Bat Survey Report and the Grassland Breeding Bird Survey Report, prepared for Micron New York by AKRF Inc., should be discussed and appended to the DEIS. Additionally, DEC's "Grass Land Bird Mitigation Requirements" is included as attachment C to this document, and the DEIS should reference these requirements in the mitigation discussion for grassland bird habitat impacts. 12. The natural resource analysis of the Proposed Project should also include details on wildlife that likely use the site based on habitat types and any ancillary observations made by on-site natural resource consultants. Additionally, the DEIS should discuss the impacts on the species associated with converting these habitats to an industrial site. 13. The C-Class Youngs Creek (Water Index Number ONT-66-11-14), located east of Burnett Road, is continuously connected to the Oneida River (Water Index Number ONT-66-11). with no known impassable barrier The site plan OCIDA included with the draft scope show portions of the Proposed Project filling 3 356 Youngs Creek. The DEIS should include information on any portions of Youngs Creek being filled or “culverted” and discuss how water in the stream will be managed. In addition, a biological survey of the stream on the Proposed Project site should be completed to assess fish species composition in this stream. The DEIS should also detail the effects on these species associated with any impact on the stream from the Proposed Project. This analysis should consider upstream and downstream impacts, as well. The DEIS should evaluate upstream and downstream instream habitat enhancement projects to mitigate potential onsite impacts. Youngs Creek. The DEIS should include information on any portions of Youngs Creek being filled or “culverted” and discuss how water in the stream will be managed. In addition, a biological survey of the stream on the Proposed Project site should be completed to assess fish species composition in this stream. The DEIS should also detail the effects on these species associated with any impact on the stream from the Proposed Project. This analysis should consider upstream and downstream impacts, as well. The DEIS should evaluate upstream and downstream instream habitat enhancement projects to mitigate potential onsite impacts. 14. The DEIS should include further details to identify how surface and subsurface water resources will be evaluated. The DEIS should address potential on-site and off-site flooding and impacts to surface and groundwater. This section should include an evaluation of impacts on surface water volume, including streams, wetlands, and drainageways, and groundwater elevations during and after construction. Additionally, it should detail impacts on groundwater levels, quantity, and quality from filling any wetlands on site. The analysis should include a groundwater hydrologic and hydraulic analysis of the impacts of placing fill in watersheds contributing to the project area. Special consideration should be given to filling wetlands, drainage areas, Youngs Creek, and its tributaries, including unmapped streams, and evaluate how fill may affect the surface and subsurface water flow and drainage patterns in the area and surrounding properties. The DEIS should also consider factors such as increased surface runoff, potential water flow redirection, and impacts on nearby waterbodies or stormwater management systems. Portions of this information are also needed as part of the SWPPP review. In the hydrologic/hydraulic analysis, please consider: a. Pre- and post-construction design points (i.e., receiving waterbodies). b. Wetland cover types. c. Pre- and post-construction ordinary water levels in streams and wetlands. d. Hydraulic modeling to simulate the effects of cut and fill on water flow, flood levels, and drainage patterns. The modeling should include all the surrounding areas that will be affected by this development. 14. The DEIS should include further details to identify how surface and subsurface water resources will be evaluated. The DEIS should address potential on-site and off-site flooding and impacts to surface and groundwater. This section should include an evaluation of impacts on surface water volume, including streams, wetlands, and drainageways, and groundwater elevations during and after construction. Additionally, it should detail impacts on groundwater levels, quantity, and quality from filling any wetlands on site. The analysis should include a groundwater hydrologic and hydraulic analysis of the impacts of placing fill in watersheds contributing to the project area. Special consideration should be given to filling wetlands, drainage areas, Youngs Creek, and its tributaries, including unmapped streams, and evaluate how fill may affect the surface and subsurface water flow and drainage patterns in the area and surrounding properties. The DEIS should also consider factors such as increased surface runoff, potential water flow redirection, and impacts on nearby waterbodies or stormwater management systems. Portions of this information are also needed as part of the SWPPP review. In the hydrologic/hydraulic analysis, please consider: a. Pre- and post-construction design points (i.e., receiving waterbodies). b. Wetland cover types. c. Pre- and post-construction ordinary water levels in streams and wetlands. d. Hydraulic modeling to simulate the effects of cut and fill on water flow, flood levels, and drainage patterns. The modeling should include all the surrounding areas that will be affected by this development. 15. The DEIS should discuss how drainage will be maintained and how potential flooding would be mitigated. 16. DEC supports documenting floodplains and recommends re-evaluating and updating floodplain mapping for any significant grade changes. 17. Dewatering of groundwater during construction should be discussed including best management practices that may be employed to avoid and mitigate impacts to the resource. Chapter 11 Solid & Hazardous Waste 18. The DEIS should evaluate the impact potential population growth associated with this development will have on the management of solid waste and recyclables, 4 357 15. The DEIS should discuss how drainage will be maintained and how potential flooding would be mitigated. 16. DEC supports documenting floodplains and recommends re-evaluating and updating floodplain mapping for any significant grade changes. 17. Dewatering of groundwater during construction should be discussed including best management practices that may be employed to avoid and mitigate impacts to the resource. Chapter 11 Solid & Hazardous Waste 18. The DEIS should evaluate the impact potential population growth associated with this development will have on the management of solid waste and recyclables, 4 357 as well as the anticipated amount of waste and recyclable material generated by Micron. Onondaga County law requires that waste generated within the County be disposed of at the Onondaga County Resource Recovery Waste to Energy Facility. This evaluation should consider the existing waste management network's capacity, its ability to accept increased volumes associated with the Proposed Project, and the potential for population growth. If the evaluation includes an expansion of any waste or recycling facilities or the use of the Onondaga County landfill, approximate dates of the expansion(s) should be included that correspond with Micron's expected buildout. 19. The DEIS should include a discussion of hazardous waste, listed in 6 NYCRR Part 371.4, that the Proposed Project may generate. Details should include the type of hazardous waste anticipated to be generated, approximate volumes, storage methods, disposal options, and how the facility will operate following hazardous waste regulations found at 6 NYCRR Part 370-373. 20. Mitigation considerations for solid waste should include an evaluation of processing methods and chemicals used in the manufacturing process to determine if alternative methods could reduce the generation of hazardous waste. Chapter 13 Air Quality as well as the anticipated amount of waste and recyclable material generated by Micron. Onondaga County law requires that waste generated within the County be disposed of at the Onondaga County Resource Recovery Waste to Energy Facility. This evaluation should consider the existing waste management network's capacity, its ability to accept increased volumes associated with the Proposed Project, and the potential for population growth. If the evaluation includes an expansion of any waste or recycling facilities or the use of the Onondaga County landfill, approximate dates of the expansion(s) should be included that correspond with Micron's expected buildout. 19. The DEIS should include a discussion of hazardous waste, listed in 6 NYCRR Part 371.4, that the Proposed Project may generate. Details should include the type of hazardous waste anticipated to be generated, approximate volumes, storage methods, disposal options, and how the facility will operate following hazardous waste regulations found at 6 NYCRR Part 370-373. 20. Mitigation considerations for solid waste should include an evaluation of processing methods and chemicals used in the manufacturing process to determine if alternative methods could reduce the generation of hazardous waste. Chapter 13 Air Quality 21. DEC offers the following regarding comments the air quality modeling and impact assessment that will be prepared to support the air pollution control permit: a. The air quality modeling included in the DEIS should include an air quality impact evaluation or dispersion modeling analysis for a variety of emission sources including major sources, air toxic sources, and any sources that appear likely to contravene an applicable ambient air quality standard. DEC developed the DAR-10 guidance document, NYSDEC Guidelines on Dispersion Modeling Procedures for Air Quality Impact Analysis, found at https://www.dec.ny.gov/docs/air_pdf/dar10.pdf, which details the recommended procedures for conducting ambient air quality impact analyses. The applicant should submit a modeling protocol to DEC for approval prior to performing any dispersion modeling analyses. b. If the impact assessment includes a private, pre-construction, on-site air quality monitoring network, the plan will need prior DEC approval. Guidance for the establishment, maintenance, and reporting requirements of private air monitoring networks can be found in DAR-2, 6 NYCRR Part 231-12.3 and Appendix B to 40 CFR Part 58. c. If one or more applicable requirements or proposed compliance certification sections require the use of a continuous emissions monitoring (CEM) system, the analysis should develop and include a continuous emissions monitoring plan. d. The analysis should include applicable RACT/BACT/LAER demonstrations, as well as Appropriate Emission Reduction Credit (ERCs) demonstrations and analysis 21. DEC offers the following regarding comments the air quality modeling and impact assessment that will be prepared to support the air pollution control permit: a. The air quality modeling included in the DEIS should include an air quality impact evaluation or dispersion modeling analysis for a variety of emission sources including major sources, air toxic sources, and any sources that appear likely to contravene an applicable ambient air quality standard. DEC developed the DAR-10 guidance document, NYSDEC Guidelines on Dispersion Modeling Procedures for Air Quality Impact Analysis, found at https://www.dec.ny.gov/docs/air_pdf/dar10.pdf, which details the recommended procedures for conducting ambient air quality impact analyses. The applicant should submit a modeling protocol to DEC for approval prior to performing any dispersion modeling analyses. b. If the impact assessment includes a private, pre-construction, on-site air quality monitoring network, the plan will need prior DEC approval. Guidance for the establishment, maintenance, and reporting requirements of private air monitoring networks can be found in DAR-2, 6 NYCRR Part 231-12.3 and Appendix B to 40 CFR Part 58. c. If one or more applicable requirements or proposed compliance certification sections require the use of a continuous emissions monitoring (CEM) system, the analysis should develop and include a continuous emissions monitoring plan. d. The analysis should include applicable RACT/BACT/LAER demonstrations, as well as Appropriate Emission Reduction Credit (ERCs) demonstrations and analysis 5 358 e. The analysis should include, as applicable, a Toxic Impact Assessment and Environmental Rating Demonstration pursuant to the requirements of 6 NYCRR Part 212. DEC developed DAR-1: Guidelines for the Evaluation and Control of Ambient Air Contaminants Under Part 212 found at https://www.dec.ny.gov/docs/air_pdf/dar1proposed.pdf for reference. 22. DEC recommends that a copy of the Air Title V permit application and supporting information be appended to the DEIS to the extent it is available. Chapter 14 Greenhouse Gas and Climate Change 23. The Proposed Project is subject to the mandates of the Climate Leadership and Community Protection Act (CLCPA) and therefore requires an analysis pursuant to Section 7(2) of CLCPA. Please see DEC Program Policy DAR-21 for guidance on preparing the CLCPA analysis. DAR-21: https://www.dec.ny.gov/docs/air_pdf/dar21.pdf. 24. DEC recommends evaluating and quantifying GHG and co-pollutants of mobile emissions sources during construction and when the plant is in operation. Additionally, alternatives and mitigation that reduce GHG and co-pollutants from mobile emission sources must be considered. 5 358 e. The analysis should include, as applicable, a Toxic Impact Assessment and Environmental Rating Demonstration pursuant to the requirements of 6 NYCRR Part 212. DEC developed DAR-1: Guidelines for the Evaluation and Control of Ambient Air Contaminants Under Part 212 found at https://www.dec.ny.gov/docs/air_pdf/dar1proposed.pdf for reference. 22. DEC recommends that a copy of the Air Title V permit application and supporting information be appended to the DEIS to the extent it is available. Chapter 14 Greenhouse Gas and Climate Change 23. The Proposed Project is subject to the mandates of the Climate Leadership and Community Protection Act (CLCPA) and therefore requires an analysis pursuant to Section 7(2) of CLCPA. Please see DEC Program Policy DAR-21 for guidance on preparing the CLCPA analysis. DAR-21: https://www.dec.ny.gov/docs/air_pdf/dar21.pdf. 24. DEC recommends evaluating and quantifying GHG and co-pollutants of mobile emissions sources during construction and when the plant is in operation. Additionally, alternatives and mitigation that reduce GHG and co-pollutants from mobile emission sources must be considered. 25. Among other CLCPA requirements, the Proposed Project will result in an actual increase in greenhouse gas (GHG) emissions, including both direct and indirect GHG emissions. Therefore, the DEIS should include a discussion of the justification for the Proposed Project, along with the technical and economic feasibility of any alternatives or GHG mitigation measures to address the increase. Any such mitigation should take place at the New York facility or in the immediate area, rather than in other cities or out of state. DEC offers the following details and illustrative examples regarding potential alternatives and mitigation the DEIS could consider: a. Given the large site footprint, the facility should explore geothermal heating and cooling. Further details about the plant’s operating profiles (MW) and the annual heating/cooling loads (MWh) would help determine the balance of heating and cooling and how much of the thermal process loads could be efficiently supported by a ground loop heat exchanger (geothermal). This would require information about the size of the manufacturing plant, including its thermal load profiles, peak loads, and annual loads. b. Installation of solar arrays to provide power directly to the facility and minimize energy demands for facility operation. c. Assessment of mobile source emissions consistent with guidance from the New York State Department of Transportation (NYSDOT). d. Use of electric powered alternatives wherever fossil fuels are typically utilized. e. Discuss of the use of bus or light rail connecting residences in the Syracuse metropolitan area. 25. Among other CLCPA requirements, the Proposed Project will result in an actual increase in greenhouse gas (GHG) emissions, including both direct and indirect GHG emissions. Therefore, the DEIS should include a discussion of the justification for the Proposed Project, along with the technical and economic feasibility of any alternatives or GHG mitigation measures to address the increase. Any such mitigation should take place at the New York facility or in the immediate area, rather than in other cities or out of state. DEC offers the following details and illustrative examples regarding potential alternatives and mitigation the DEIS could consider: a. Given the large site footprint, the facility should explore geothermal heating and cooling. Further details about the plant’s operating profiles (MW) and the annual heating/cooling loads (MWh) would help determine the balance of heating and cooling and how much of the thermal process loads could be efficiently supported by a ground loop heat exchanger (geothermal). This would require information about the size of the manufacturing plant, including its thermal load profiles, peak loads, and annual loads. b. Installation of solar arrays to provide power directly to the facility and minimize energy demands for facility operation. c. Assessment of mobile source emissions consistent with guidance from the New York State Department of Transportation (NYSDOT). d. Use of electric powered alternatives wherever fossil fuels are typically utilized. e. Discuss of the use of bus or light rail connecting residences in the Syracuse metropolitan area. 6 359 Chapter 16 Utilities and Infrastructure 26. DEC’s comment 4 noted the DEIS should include a discussion of discuss natural resource impacts for constructing utility connections, such as clean water, wastewater, electric, gas, telecommunications, and roadway expansions. The information in the Natural Resource chapter relevant to the Utilities and Infrastructure should also be referenced in this section of the DEIS. 27. DEC recommends developing a phasing plan, which coincides with Micron’s incremental expansion, for the buildout and expansion of all utility upgrades required to meet the Proposed Project’s anticipated demands. The phasing plan should include sewer extensions, pumping systems, new clean water source(s) and distribution systems, wastewater plant upgrades, and gas and electricity distribution infrastructure. 28. The DEIS should also provide adequate information to demonstrate that all utility upgrades will be constructed, operational, and sufficient to accept waste from or provide service to the Proposed Project. Please see Attachment D, which lists the typical details DEC reviews for a sewer extension and force main approvals. 6 359 Chapter 16 Utilities and Infrastructure 26. DEC’s comment 4 noted the DEIS should include a discussion of discuss natural resource impacts for constructing utility connections, such as clean water, wastewater, electric, gas, telecommunications, and roadway expansions. The information in the Natural Resource chapter relevant to the Utilities and Infrastructure should also be referenced in this section of the DEIS. 27. DEC recommends developing a phasing plan, which coincides with Micron’s incremental expansion, for the buildout and expansion of all utility upgrades required to meet the Proposed Project’s anticipated demands. The phasing plan should include sewer extensions, pumping systems, new clean water source(s) and distribution systems, wastewater plant upgrades, and gas and electricity distribution infrastructure. 28. The DEIS should also provide adequate information to demonstrate that all utility upgrades will be constructed, operational, and sufficient to accept waste from or provide service to the Proposed Project. Please see Attachment D, which lists the typical details DEC reviews for a sewer extension and force main approvals. 29. The DEIS should provide adequate details on the Proposed Project’s wastewater loading, flow, and discuss the on-site wastewater pretreatments. 30. As stated in the section 1.1.2 Project Description Water Supply, the Proposed Project has an anticipated total future demand of approximately 48 million gallons per day (MGD). Withdrawals of this scale have the potential to impact fisheries resources through impingement and entrainment. The DEIS should provide details on the design specification of the new lake water intake structure and intake screening and assess potential fish impingement mortality and entrainment. Any additional measures to avoid and minimize fish impingement and entrainment should also be discussed (e.g., variable speed pumps, water reuse/conservation, etc.). 31. The DEIS should consider and include details and a summary of water conservation and reuse practices to mitigate water demands. 32. The DEIS should include a summary of any investigated and considered alternative water sources. 29. The DEIS should provide adequate details on the Proposed Project’s wastewater loading, flow, and discuss the on-site wastewater pretreatments. 30. As stated in the section 1.1.2 Project Description Water Supply, the Proposed Project has an anticipated total future demand of approximately 48 million gallons per day (MGD). Withdrawals of this scale have the potential to impact fisheries resources through impingement and entrainment. The DEIS should provide details on the design specification of the new lake water intake structure and intake screening and assess potential fish impingement mortality and entrainment. Any additional measures to avoid and minimize fish impingement and entrainment should also be discussed (e.g., variable speed pumps, water reuse/conservation, etc.). 31. The DEIS should consider and include details and a summary of water conservation and reuse practices to mitigate water demands. 32. The DEIS should include a summary of any investigated and considered alternative water sources. 33. Water withdrawals within the Great Lakes Basin are subject to the requirements and provisions of the Great Lakes-St. Lawrence River Basin Water Resource Compact, found at the link below. The DEIS should discuss and address how the proposed water withdrawal and use is consistent with the Compact and all state, local, and federal laws. https://www.glslcompactcouncil.org/media/nmzfv5jq/great_lakes- st_lawrence_river_basin_water_resources_compact.pdf 7 360 Chapter 17-Use and Consumption of Energy 34. DEC recommends renaming this chapter as “Use and Conservation of Energy.” 33. Water withdrawals within the Great Lakes Basin are subject to the requirements and provisions of the Great Lakes-St. Lawrence River Basin Water Resource Compact, found at the link below. The DEIS should discuss and address how the proposed water withdrawal and use is consistent with the Compact and all state, local, and federal laws. https://www.glslcompactcouncil.org/media/nmzfv5jq/great_lakes- st_lawrence_river_basin_water_resources_compact.pdf 7 360 Chapter 17-Use and Consumption of Energy 34. DEC recommends renaming this chapter as “Use and Conservation of Energy.” 35. The DEIS should contain a description of energy sources to be used during both construction and operational phases of a project. Anticipated levels of demand or consumption should be quantified or estimated as accurately as possible given available information. In addition, the DEIS should discuss alternatives and mitigation that could reduce energy and fuel demands during construction and long-term operation. The 2018 amendments to SEQR regulations require all New York State agencies to evaluate such GHG impacts in a new section specifically dedicated to climate change and its impacts. Proposed energy conservation measures that go beyond the minimum requirements of the State Energy Conservation Construction Code (9 NYCRR Parts 7810 through 7816) should be specifically identified, such as LEED or Energy Star. Please refer to Chapter 5, Section C, Item 44 on page 123 in DEC’s SEQR Handbook, found at https://www.dec.ny.gov/docs/permits_ej_operations_pdf/seqrhandbook.pdf. The information and energy conservation measures discussed in this section may be applicable and cross-referenced to the Greenhouse Gas Emissions and Climate Change chapter. 35. The DEIS should contain a description of energy sources to be used during both construction and operational phases of a project. Anticipated levels of demand or consumption should be quantified or estimated as accurately as possible given available information. In addition, the DEIS should discuss alternatives and mitigation that could reduce energy and fuel demands during construction and long-term operation. The 2018 amendments to SEQR regulations require all New York State agencies to evaluate such GHG impacts in a new section specifically dedicated to climate change and its impacts. Proposed energy conservation measures that go beyond the minimum requirements of the State Energy Conservation Construction Code (9 NYCRR Parts 7810 through 7816) should be specifically identified, such as LEED or Energy Star. Please refer to Chapter 5, Section C, Item 44 on page 123 in DEC’s SEQR Handbook, found at https://www.dec.ny.gov/docs/permits_ej_operations_pdf/seqrhandbook.pdf. The information and energy conservation measures discussed in this section may be applicable and cross-referenced to the Greenhouse Gas Emissions and Climate Change chapter. Thank you for the opportunity to provide written comments on the DEIS for the Micron project. DEC hopes that OCIDA will find the information helpful in the preparation of the DEIS for this Proposed Project. If you have any questions on the information provided in this letter, you may call me at 315-426-7493, or email me at kevin.balduzzi@dec.ny.gov Sincerely, Digitally signed by Kevin M. Balduzzi Date: 2023.10.31 14:49:35 -04'00' Kevin M. Balduzzi Regional Permit Administrator Division of Environmental Permits Cc Thomas Berkman, DEC Deputy Commissioner and General Counsel Katharine Petronis, DEC Deputy Commissioner Dereth Glance, DEC Regional Director, Region 7 Daniel Whitehead, DEC Division of Environmental Permit, Director Margaret Sheen, DEC Regional Attorney, Region 7 Scott Sheeley, DEC Chief Permit Administrator Att. Attachment A- NYSDEC’s Jurisdictions Associated with Micron-White Pine Development. Attachment B- Proposed Project Wetland Mitigation Requirements Attachment C- Grassland Bird Mitigation Requirements Attachment D- Proposed Project Wastewater Sewer Extension Information 8 Thank you for the opportunity to provide written comments on the DEIS for the Micron project. DEC hopes that OCIDA will find the information helpful in the preparation of the DEIS for this Proposed Project. If you have any questions on the information provided in this letter, you may call me at 315-426-7493, or email me at kevin.balduzzi@dec.ny.gov Sincerely, Digitally signed by Kevin M. Balduzzi Date: 2023.10.31 14:49:35 -04'00' Kevin M. Balduzzi Regional Permit Administrator Division of Environmental Permits Cc Thomas Berkman, DEC Deputy Commissioner and General Counsel Katharine Petronis, DEC Deputy Commissioner Dereth Glance, DEC Regional Director, Region 7 Daniel Whitehead, DEC Division of Environmental Permit, Director Margaret Sheen, DEC Regional Attorney, Region 7 Scott Sheeley, DEC Chief Permit Administrator Att. Attachment A- NYSDEC’s Jurisdictions Associated with Micron-White Pine Development. Attachment B- Proposed Project Wetland Mitigation Requirements Attachment C- Grassland Bird Mitigation Requirements Attachment D- Proposed Project Wastewater Sewer Extension Information 8 361 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2020, DEC ID 7-3124-00575, Attachment A Attachment A NYSDEC’s Jurisdictions Associated with Micron-White Pine Development • Water Quality Certifications (401 certifications), Section 401 of the Clean Water Act, U.S. Public Law 95-217, and 33 USC 1341 (see section 608.9[c] of this Title) (implemented by 6 NYCRR Part 608): for projects which impact federally regulated waters of the US require Federal approval under Section 404 of the Clean Water Act. • Use and Protection of Water, ECL article 15, title 5 (implemented by 6 NYCRR Part 608) • State Pollutant Discharge Elimination System (SPDES), ECL article 17 titles 7 and 8, (implemented by 6 NYCRR Part 750), General Permit for Stormwater Discharges from Construction Activities (GP-0-20-001) and Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity (GP-0-23- 001). • Air Pollution Control, ECL article 19, (implemented by 6 NYCRR Parts 201 and 231): including construction and operation of a new emission source or a modification to an existing emission source of air contamination, and construction of indirect sources of air contamination. • Endangered and Threatened Species of Fish and Wildlife; Species of Special Concern; Incidental Take Permits, ECL article 11, (implemented by 6 NYCRR Part 182) for the take of state-listed, endangered bird species occupied habitat. • Water withdrawals, ECL article 15, title 15 (implemented by 6 NYCRR Parts 601 and 602). • Freshwater Wetlands, ECL article 24, (implemented by 6 NYCRR Parts 662- 663). • Solid Waste Management, ECL article 27 title 7, (implemented by 6 NYCRR Part 360). • Industrial Hazardous Waste Management, ECL article 27 title 9, (implemented by 6 NYCRR Part 373). 361 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2020, DEC ID 7-3124-00575, Attachment A Attachment A NYSDEC’s Jurisdictions Associated with Micron-White Pine Development • Water Quality Certifications (401 certifications), Section 401 of the Clean Water Act, U.S. Public Law 95-217, and 33 USC 1341 (see section 608.9[c] of this Title) (implemented by 6 NYCRR Part 608): for projects which impact federally regulated waters of the US require Federal approval under Section 404 of the Clean Water Act. • Use and Protection of Water, ECL article 15, title 5 (implemented by 6 NYCRR Part 608) • State Pollutant Discharge Elimination System (SPDES), ECL article 17 titles 7 and 8, (implemented by 6 NYCRR Part 750), General Permit for Stormwater Discharges from Construction Activities (GP-0-20-001) and Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity (GP-0-23- 001). • Air Pollution Control, ECL article 19, (implemented by 6 NYCRR Parts 201 and 231): including construction and operation of a new emission source or a modification to an existing emission source of air contamination, and construction of indirect sources of air contamination. • Endangered and Threatened Species of Fish and Wildlife; Species of Special Concern; Incidental Take Permits, ECL article 11, (implemented by 6 NYCRR Part 182) for the take of state-listed, endangered bird species occupied habitat. • Water withdrawals, ECL article 15, title 15 (implemented by 6 NYCRR Parts 601 and 602). • Freshwater Wetlands, ECL article 24, (implemented by 6 NYCRR Parts 662- 663). • Solid Waste Management, ECL article 27 title 7, (implemented by 6 NYCRR Part 360). • Industrial Hazardous Waste Management, ECL article 27 title 9, (implemented by 6 NYCRR Part 373). 1 362 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment B Attachment B Proposed Project Wetland Mitigation Requirements 1 362 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment B Attachment B Proposed Project Wetland Mitigation Requirements Mitigation proposals should be based on plans containing clear and specific details, short and long-term goals and measurable performance criteria. Wetland design must provide for persistence of the wetlands over time with the capacity to successfully adapt to changing conditions. The plan must include but is not limited to: • Acreage of proposed mitigation at the DEC-accepted, replacement ratios which may vary dependent on wetland cover types and lost functions and values. • Location of mitigation site(s), including such information as site descriptions, topography, and proximity to DEC mapped Freshwater Wetlands. Mitigation sites should be located as close as possible to the impacted wetlands. Explore all possible locations within the Hydrologic Unit Code (HUC) 12 watershed areas first. After exhausting all potential mitigation sites near the impacted areas, the search may be expanded beyond the HUC 12. • Analysis of lost functions and values (ECL § 24-0105) and how mitigation plans will compensate for these losses. • A plan to create wetland hydrology at the mitigation site for each cover type, including water source, water budget and monitoring plan. • The mitigation plan must provide for a proportional replacement for all cover types lost; forested, shrub/scrub, emergent marsh open water wetland and wet meadow with native wetland herbaceous and woody plant species • A Planting Plan consisting of a site plan showing the locations of plantings/seedings, the source of plant materials, a species list, and performance criteria used to measure success. The Monitoring Plan must include a description of annual monitoring, the duration of which is dependent on the cover type must be described. For example, forested wetlands must be monitored for successful replacement for a minimum of 10 years. Corrective actions, including re-planting, to achieve sustainable hydrology and control of invasive species must be taken promptly until the mitigation goals are met. Annual monitoring reports will include observed percent coverage of the planned vegetation cover type, hydroperiod, percent coverage of invasive species, and an analysis of any deficiencies, along with corrective actions to achieve the goals of the mitigation plan. Mitigation proposals should be based on plans containing clear and specific details, short and long-term goals and measurable performance criteria. Wetland design must provide for persistence of the wetlands over time with the capacity to successfully adapt to changing conditions. The plan must include but is not limited to: • Acreage of proposed mitigation at the DEC-accepted, replacement ratios which may vary dependent on wetland cover types and lost functions and values. • Location of mitigation site(s), including such information as site descriptions, topography, and proximity to DEC mapped Freshwater Wetlands. Mitigation sites should be located as close as possible to the impacted wetlands. Explore all possible locations within the Hydrologic Unit Code (HUC) 12 watershed areas first. After exhausting all potential mitigation sites near the impacted areas, the search may be expanded beyond the HUC 12. • Analysis of lost functions and values (ECL § 24-0105) and how mitigation plans will compensate for these losses. • A plan to create wetland hydrology at the mitigation site for each cover type, including water source, water budget and monitoring plan. • The mitigation plan must provide for a proportional replacement for all cover types lost; forested, shrub/scrub, emergent marsh open water wetland and wet meadow with native wetland herbaceous and woody plant species • A Planting Plan consisting of a site plan showing the locations of plantings/seedings, the source of plant materials, a species list, and performance criteria used to measure success. The Monitoring Plan must include a description of annual monitoring, the duration of which is dependent on the cover type must be described. For example, forested wetlands must be monitored for successful replacement for a minimum of 10 years. Corrective actions, including re-planting, to achieve sustainable hydrology and control of invasive species must be taken promptly until the mitigation goals are met. Annual monitoring reports will include observed percent coverage of the planned vegetation cover type, hydroperiod, percent coverage of invasive species, and an analysis of any deficiencies, along with corrective actions to achieve the goals of the mitigation plan. 1 363 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment C Attachment C Grassland Bird Mitigation Requirements 1 363 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment C Attachment C Grassland Bird Mitigation Requirements The primary threat to grassland bird species in New York is habitat loss. As a result, the best mitigation method is habitat creation, habitat enhancement, and habitat management. Field size is a significant predictor of use by listed grassland birds. For this reason, acceptable habitat mitigation should include fields of similar size to those taken, with all fields used for mitigation being at least 25 acres in size. A large field of 100 acres or more is generally preferred over several fields meeting the minimum size criteria. The benefits of mitigation are quantified based on the total acreage proposed for mitigation, the conservation plan proposed for those acres, and the length of time that the conservation plan will be implemented. Although parcels may include wetlands, wetland acres are not credited for grassland or species mitigation as they are already protected through Article 24 or their own mitigation process. Mitigation actions must be either completed before initiation of construction of the project in the occupied habitat or an implementation agreement must be in place that demonstrates Micron has fully funded the proposed mitigation plan, and all entities responsible for its implementation sign off that they can ensure the work is implemented. Approvable mitigation strategies must demonstrate that they will accomplish a net conservation benefit to the species impacted, such that the affected species is better off after the completion of the project than if the Micron development had not been implemented. Baseline mitigation ratios are 3:1 for impacts to breeding habitat and 1:1 for wintering habitat, based on the assumption that habitat mitigation will employ management practices that will result in better habitat than the habitat being taken. Ratios may be reduced if the applicant can demonstrate that their proposed management will demonstrably improve the status of the impacted species. Factors that can potentially decrease the ratio of breeding habitat required for mitigation include the following: 1. At least one proposed mitigation area is a larger contiguous grassland than the largest field taken by the project. 2. At least one mitigation parcel is greater than 100 acres of contiguous habitat. 3. The proposed mitigation areas are immediately adjacent to other protected grassland habitats that are at least 25 acres in size. 4. Proposed mitigation will result in the removal of known threats from parcels of known occupied habitat of the species being taken similar in size to those taken (>25 acres). 5. Proposed mitigation lands are within recognized important landscapes for grassland birds (e.g., Grassland Focus Area, Important Bird Area, Raptor Concentration Area). The primary threat to grassland bird species in New York is habitat loss. As a result, the best mitigation method is habitat creation, habitat enhancement, and habitat management. Field size is a significant predictor of use by listed grassland birds. For this reason, acceptable habitat mitigation should include fields of similar size to those taken, with all fields used for mitigation being at least 25 acres in size. A large field of 100 acres or more is generally preferred over several fields meeting the minimum size criteria. The benefits of mitigation are quantified based on the total acreage proposed for mitigation, the conservation plan proposed for those acres, and the length of time that the conservation plan will be implemented. Although parcels may include wetlands, wetland acres are not credited for grassland or species mitigation as they are already protected through Article 24 or their own mitigation process. Mitigation actions must be either completed before initiation of construction of the project in the occupied habitat or an implementation agreement must be in place that demonstrates Micron has fully funded the proposed mitigation plan, and all entities responsible for its implementation sign off that they can ensure the work is implemented. Approvable mitigation strategies must demonstrate that they will accomplish a net conservation benefit to the species impacted, such that the affected species is better off after the completion of the project than if the Micron development had not been implemented. Baseline mitigation ratios are 3:1 for impacts to breeding habitat and 1:1 for wintering habitat, based on the assumption that habitat mitigation will employ management practices that will result in better habitat than the habitat being taken. Ratios may be reduced if the applicant can demonstrate that their proposed management will demonstrably improve the status of the impacted species. Factors that can potentially decrease the ratio of breeding habitat required for mitigation include the following: 1. At least one proposed mitigation area is a larger contiguous grassland than the largest field taken by the project. 2. At least one mitigation parcel is greater than 100 acres of contiguous habitat. 3. The proposed mitigation areas are immediately adjacent to other protected grassland habitats that are at least 25 acres in size. 4. Proposed mitigation will result in the removal of known threats from parcels of known occupied habitat of the species being taken similar in size to those taken (>25 acres). 5. Proposed mitigation lands are within recognized important landscapes for grassland birds (e.g., Grassland Focus Area, Important Bird Area, Raptor Concentration Area). 1 364 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment C 6. The proposed mitigation area can be protected and managed for a period of time that extends beyond the 30-year life of the facility (e.g., 40 years, 50 years, or in perpetuity). 2 365 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment D Attachment D Proposed Project Wastewater Sewer Extension Information 1 364 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment C 6. The proposed mitigation area can be protected and managed for a period of time that extends beyond the 30-year life of the facility (e.g., 40 years, 50 years, or in perpetuity). 2 365 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment D Attachment D Proposed Project Wastewater Sewer Extension Information Please provide the following information regarding the proposed facilities’ wastewater sewer extension: 1. Conveyances • Confirmation from Onondaga County that its facility can accept the expected additional flows and organic loadings from the extension. • Location of the proposed sewer extension. • Expected hydraulic flows (gpd) and organic loadings (lb/d) in the proposed flow. • Design plans and specifications stamped and signed by a Professional Engineer licensed in the State of New York. Design plans must include plan and profile views of the proposed extension. These must be submitted in hardcopy. • Plan indicating the downstream routing of the sewer to the Oak Orchard WWTP detailing all sewer diameters, theoretical capacities and actual capacities during peak flows. • Design plans indicating lots served, property lines, existing and proposed streets (if applicable), storm drainage, existing and proposed utilities and easements, direction of flow, contour lines, placement of manholes, rim and invert elevations for pipes and type of pipe selected, and special construction (i.e. drop manholes, crossing of waterways). • Design capacity and how this capacity was determined. • Detailed drawings and specifications for manholes, pipe bedding and construction, leakage testing, deflection testing, notes indicating sewer and waterline separation distances. 2. Pump stations • Type of pump station (wet well/dry well); package or built-in-place; number and type of pumps chosen (submersible or suction lift). • Maximum flow expected and how this was calculated. • Provide pump curves and head calculations. • Accessibility of pump station for maintenance and protections for personnel, including ventilation. • Provisions which consider buoyance of the station and its structures. • Chemical storage and pumps (if applicable). • Detail of bar rack (if applicable). • Corrosion prevention considerations. • Location of all valves and control systems. • Provisions for alarm systems and emergency operation. • Bypass plan (if applicable). Please provide the following information regarding the proposed facilities’ wastewater sewer extension: 1. Conveyances • Confirmation from Onondaga County that its facility can accept the expected additional flows and organic loadings from the extension. • Location of the proposed sewer extension. • Expected hydraulic flows (gpd) and organic loadings (lb/d) in the proposed flow. • Design plans and specifications stamped and signed by a Professional Engineer licensed in the State of New York. Design plans must include plan and profile views of the proposed extension. These must be submitted in hardcopy. • Plan indicating the downstream routing of the sewer to the Oak Orchard WWTP detailing all sewer diameters, theoretical capacities and actual capacities during peak flows. • Design plans indicating lots served, property lines, existing and proposed streets (if applicable), storm drainage, existing and proposed utilities and easements, direction of flow, contour lines, placement of manholes, rim and invert elevations for pipes and type of pipe selected, and special construction (i.e. drop manholes, crossing of waterways). • Design capacity and how this capacity was determined. • Detailed drawings and specifications for manholes, pipe bedding and construction, leakage testing, deflection testing, notes indicating sewer and waterline separation distances. 2. Pump stations • Type of pump station (wet well/dry well); package or built-in-place; number and type of pumps chosen (submersible or suction lift). • Maximum flow expected and how this was calculated. • Provide pump curves and head calculations. • Accessibility of pump station for maintenance and protections for personnel, including ventilation. • Provisions which consider buoyance of the station and its structures. • Chemical storage and pumps (if applicable). • Detail of bar rack (if applicable). • Corrosion prevention considerations. • Location of all valves and control systems. • Provisions for alarm systems and emergency operation. • Bypass plan (if applicable). 1 366 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment D • Design plans (with requirements as noted above). • Design specifications covering all equipment and appurtenances, construction procedures, testing of piping and equipment • Design plans and specifications stamped and signed by a Professional Engineer licensed in the State of New York. Design plans must include plan and profile views of the proposed extension. These must be submitted in hardcopy. 2 367 From: Don Hughes Sent: Wednesday, November 1, 2023 3:03:40 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Fwd: Micron DEIS Scoping Comments NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: Onondaga County Industrial Development Agency ATTN: Micron Project 335 Montgomery Street, 2nd Floor Syracuse, New York 13202 From: Donald Hughes, Conservation Chair, Central & Northern New York Sierra Club Group 1 366 DEC SEQR Draft Scope Response-Micron Semiconductor Fabrications Clay, NY 10/31/2023, DEC ID 7-3124-00575, Attachment D • Design plans (with requirements as noted above). • Design specifications covering all equipment and appurtenances, construction procedures, testing of piping and equipment • Design plans and specifications stamped and signed by a Professional Engineer licensed in the State of New York. Design plans must include plan and profile views of the proposed extension. These must be submitted in hardcopy. 2 367 From: Don Hughes Sent: Wednesday, November 1, 2023 3:03:40 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Fwd: Micron DEIS Scoping Comments NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: Onondaga County Industrial Development Agency ATTN: Micron Project 335 Montgomery Street, 2nd Floor Syracuse, New York 13202 From: Donald Hughes, Conservation Chair, Central & Northern New York Sierra Club Group Re: Draft Scoping Document for the proposed Micron Semiconductor Fabrication facility in Clay, NY I wish to submit, on behalf of the approximately 3000 members of Sierra Club who reside in our territory, the attached comments. You should have received the same documents from John Przepiora earlier today. Would you kindly confirm receipt of these comments with four supporting attachments? thank you, DH Donald J. Hughes, P.E., Ph.D. dhughes171@gmail.com 315.214.4060 ============================= Hughes Environmental Consulting 1 368 Re: Draft Scoping Document for the proposed Micron Semiconductor Fabrication facility in Clay, NY I wish to submit, on behalf of the approximately 3000 members of Sierra Club who reside in our territory, the attached comments. You should have received the same documents from John Przepiora earlier today. Would you kindly confirm receipt of these comments with four supporting attachments? thank you, DH Donald J. Hughes, P.E., Ph.D. dhughes171@gmail.com 315.214.4060 ============================= Hughes Environmental Consulting 1 368 157 Strong Ave, Syracuse, NY 13210 ============================= "dans les champs de l'observation, le hasard ne favorise que les esprits préparés" ("In the field of observation, chance favors only the prepared mind") Louis Pasteur, French chemist and microbiologist (1822 -1895) To: OCIDA On behalf of the following individuals and myself working together as the CNY Sustainability Coalition, and who have signed the attached memorandum on behalf of our respective organizations, I am submitting the attached comments and supporting 4 attachments (A1-A4) pursuant to the public comment period for the Micron project SEQRA DEIS scoping. Please do not hesitate to contact me if you have any questions. Thank you for the opportunity to comment on this important document and for allowing an extension of time for filing this. Donald Hughes Conservation Chair, Sierra Club Central & Northern NY Group Syracuse, NY dhughes171@gmail.com Peter Wirth Vice President, Climate Change Action and Awareness Fayetteville, NY pwirth2@verizon.net John Przepiora Vice President, GreeningUSA, Inc. Syracuse, NY info@greeningusa.org Dick Kornbluth 2 369 Climate Justice Committee CNY Solidarity Coalition Onondaga County, NY cnysolidarity@gmail.com Tylah Worrell Exec. Director, Urban Jobs Task Force of Syracuse Syracuse, NY t.worrell@ujtfs.org 157 Strong Ave, Syracuse, NY 13210 ============================= "dans les champs de l'observation, le hasard ne favorise que les esprits préparés" ("In the field of observation, chance favors only the prepared mind") Louis Pasteur, French chemist and microbiologist (1822 -1895) To: OCIDA On behalf of the following individuals and myself working together as the CNY Sustainability Coalition, and who have signed the attached memorandum on behalf of our respective organizations, I am submitting the attached comments and supporting 4 attachments (A1-A4) pursuant to the public comment period for the Micron project SEQRA DEIS scoping. Please do not hesitate to contact me if you have any questions. Thank you for the opportunity to comment on this important document and for allowing an extension of time for filing this. Donald Hughes Conservation Chair, Sierra Club Central & Northern NY Group Syracuse, NY dhughes171@gmail.com Peter Wirth Vice President, Climate Change Action and Awareness Fayetteville, NY pwirth2@verizon.net John Przepiora Vice President, GreeningUSA, Inc. Syracuse, NY info@greeningusa.org Dick Kornbluth 2 369 Climate Justice Committee CNY Solidarity Coalition Onondaga County, NY cnysolidarity@gmail.com Tylah Worrell Exec. Director, Urban Jobs Task Force of Syracuse Syracuse, NY t.worrell@ujtfs.org Thank you again. We look forward to working with you as this project moves forward. John Przepiora Vice-President & Director GreeningUSA, Inc. (315) 382-3829 …Advocating for sustainable communities to the benefit of local economies and environments. 3 370 Ma5 H`a`VSYS 5 JK AS`VTaa]' /fZ >V[f[a`' VSfWV -+-+' efSfWe5 o: id[ffW` eUabW aX [eegWe VWhW^abWV fZdagYZ S bgT^[U eUab[`Y bdaUWee TW`WX[fe fZW ^WSV SYW`Uk S`V fZW eba`ead Tk bdah[V[`Y Wjb^[U[f Yg[VS`UW Se fa iZSf Ud[fWd[S i[^^ TW geWV fa VWfWd_[`W iZWfZWd S egT_[ffWV VdSXf >BL [e SVWcgSfW) MZW id[ffW` eUabW bdah[VWe S _WS`e aX W`egd[`Y fZSf e[Y`[X[US`f fab[Ue ZShW `af TWW` _[eeWV S`V fZSf fZW ^WhW^ aX S`S^ke[e [` fZW >BL eSf[eX[We efS`VSdVe WefST^[eZWV Vgd[`Y fZW eUab[`Y bdaUWee)p Thank you again. We look forward to working with you as this project moves forward. John Przepiora Vice-President & Director GreeningUSA, Inc. 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Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng. “Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing,”Journal of Micro/Nanopatterning, Materials, and Metrology, Vol. 21, Issue 1, 010901 (March 2022). https://doi.org/10.1117/1.JMM.21.1.010901 /) F[Uda` egefS[`ST[^[fk bdaYdWee eg__Sdk -+-.5 FWeeSYW Xda_ LS`\Sk FWZdafdS IdWe[VW`f S`V <>H' F[Uda` MWUZ`a^aYk 9 | Page 379 More Domestic Chip-Making Means More ‘Forever Chemicals’ by Amy Feldman, Forbes Staff, October 5, 2033 https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-means-more-forever-chemicals/?sh=2d10b08c7821 Mark Newman, CEO of Chemours, the only American PFA manufacturer, says the company is ramping up production to meet the demands of reshored semiconductor fabrication. =[U] Dad`T^gfZ <^[_SfW Cgef[UW jWU) =[dWUfad' NdTS` CaTe MSe] ?adUW aX LkdSUgeW LkdSUgeW' GQ f)iaddW^^9g\fXe)adY EBLM H? :MM:GML ,) ?adTWe _SYSl[`W' HUf) 0 ' -+-.6 Zffbe5**iii)XadTWe)Ua_*e[fWe*S_kXW^V_S`*-+-.*,+*+0*_adW(Va_Wef[U(UZ[b(_S][`Y(_WS` e(_adW(XadWhWd(UZW_[US^e*8eZ7-V,+T+3U23-,I -) FW_adS`Vg_ Xda_ EW``k L[WYW^' `h[da`_W`fS^ HhWde[YZf 3. Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng. “Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing,”Journal of Micro/Nanopatterning, Materials, and Metrology, Vol. 21, Issue 1, 010901 (March 2022). https://doi.org/10.1117/1.JMM.21.1.010901 /) F[Uda` egefS[`ST[^[fk bdaYdWee eg__Sdk -+-.5 FWeeSYW Xda_ LS`\Sk FWZdafdS IdWe[VW`f S`V <>H' F[Uda` MWUZ`a^aYk 9 | Page 379 More Domestic Chip-Making Means More ‘Forever Chemicals’ by Amy Feldman, Forbes Staff, October 5, 2033 https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-means-more-forever-chemicals/?sh=2d10b08c7821 Mark Newman, CEO of Chemours, the only American PFA manufacturer, says the company is ramping up production to meet the demands of reshored semiconductor fabrication. “I brought some show-and-tell,” Mark Newman, CEO of chemical maker Chemours, told Forbes during a recent interview in a midtown Manhattan conference room. He pulled a valve assembly out of a bag. The innocuous piece of plastic, he explained, is made of fluoropolymer known as PFA — a type of controversial “forever chemical” and an essential tool in the production of semiconductors. 1|Page 380 “You cannot make chips without a whole PFA infrastructure,” he said. “We estimate that in a modern-day fab, there’s a half-kilo of PFA in every square foot. So in a 400,000- to 600,000- square-foot fab, that’s 200 to 300 metric tons of this stuff.” It’s not just valves, of course, but all types of pipes, tubes and pumps in semiconductor equipment. Fluoropolymers are particularly key for filtering out small particles from fluids during chip production. Few factories need to be as clean as chip fabs, where particles as tiny as human skin cells can contaminate production. Chemours’ PFA is in much of that equipment and material, providing a big, and largely unseen, part of a semiconductor fab’s processes. “I brought some show-and-tell,” Mark Newman, CEO of chemical maker Chemours, told Forbes during a recent interview in a midtown Manhattan conference room. He pulled a valve assembly out of a bag. The innocuous piece of plastic, he explained, is made of fluoropolymer known as PFA — a type of controversial “forever chemical” and an essential tool in the production of semiconductors. 1|Page 380 “You cannot make chips without a whole PFA infrastructure,” he said. “We estimate that in a modern-day fab, there’s a half-kilo of PFA in every square foot. So in a 400,000- to 600,000- square-foot fab, that’s 200 to 300 metric tons of this stuff.” It’s not just valves, of course, but all types of pipes, tubes and pumps in semiconductor equipment. Fluoropolymers are particularly key for filtering out small particles from fluids during chip production. Few factories need to be as clean as chip fabs, where particles as tiny as human skin cells can contaminate production. Chemours’ PFA is in much of that equipment and material, providing a big, and largely unseen, part of a semiconductor fab’s processes. Wilmington, Delaware-based Chemours, a spinout of DuPont, is the only U.S. manufacturer of PFA. For Chemours, advanced materials including fluoropolymers represent roughly one- quarter of its total $6.3 billion (latest 12-months revenue) business, with refrigerants and titanium dioxide, used in paints and aerospace coatings, making up the bulk of the rest. Within that, semiconductors are part of its performance-solutions segment, which accounted for $493 million in sales for 2022, up 53% from $322 million in 2020. On its website, Chemours says flat-out that “without PFA, domestic semiconductor manufacturing would not be possible.” Last year, President Biden signed into law the CHIPS Act, which provides $52 billion in funding to spur domestic semiconductor manufacturing with a goal of improving national security by decreasing reliance on nations like China for critical technology. Chips are essential not just for our phones and computers, but also for medical devices and fighter jets. “Geopolitics has been defined by oil over the last 50 years,” Intel CEO Pat Gelsinger said at an MIT event earlier this year. “Technology supply chains are more important for a digital future than oil for the next 50 years.” But our insatiable desire for electronic devices and American policymakers’ push for more domestic manufacturing of semiconductors relies on the industry’s access to large amounts of “forever chemicals.” Wilmington, Delaware-based Chemours, a spinout of DuPont, is the only U.S. manufacturer of PFA. For Chemours, advanced materials including fluoropolymers represent roughly one- quarter of its total $6.3 billion (latest 12-months revenue) business, with refrigerants and titanium dioxide, used in paints and aerospace coatings, making up the bulk of the rest. Within that, semiconductors are part of its performance-solutions segment, which accounted for $493 million in sales for 2022, up 53% from $322 million in 2020. On its website, Chemours says flat-out that “without PFA, domestic semiconductor manufacturing would not be possible.” Last year, President Biden signed into law the CHIPS Act, which provides $52 billion in funding to spur domestic semiconductor manufacturing with a goal of improving national security by decreasing reliance on nations like China for critical technology. Chips are essential not just for our phones and computers, but also for medical devices and fighter jets. “Geopolitics has been defined by oil over the last 50 years,” Intel CEO Pat Gelsinger said at an MIT event earlier this year. “Technology supply chains are more important for a digital future than oil for the next 50 years.” But our insatiable desire for electronic devices and American policymakers’ push for more domestic manufacturing of semiconductors relies on the industry’s access to large amounts of “forever chemicals.” 2|Page 381 Ongoing Litigation Forever chemicals, or PFAS, comprise thousands of synthetic chemicals. They’re long-lasting and resistant to heat, corrosion and moisture, making them popular for a variety of products that include nonstick pans, stain-resistant upholstery, firefighting foam — and semiconductor production. Studies, however, have linked PFAS to a variety of diseases, including cancers and reduced immune system response, as well as to contaminated groundwater, air and soil that can lead to a host of health problems. PFAS are an enormous category. Fluoropolymers, like those that Chemours manufactures for industrial uses, are just one class. Litigation over their impact is ongoing. In June, Chemours, along with DuPont and another spinoff, Corteva, reached a $1.2 billion settlement with public water systems. Meanwhile, legislators and regulators have been cracking down on the chemicals’ use, particularly in consumer products such as clothing, furniture and textiles, where they can be more easily replaced. Minneapolis-based 3M, which in 2018 agreed to pay $850 million for damaging drinking water and natural resources in the Twin Cities area, announced that it would cease production of PFAS by the end of 2025. 2|Page 381 Ongoing Litigation Forever chemicals, or PFAS, comprise thousands of synthetic chemicals. They’re long-lasting and resistant to heat, corrosion and moisture, making them popular for a variety of products that include nonstick pans, stain-resistant upholstery, firefighting foam — and semiconductor production. Studies, however, have linked PFAS to a variety of diseases, including cancers and reduced immune system response, as well as to contaminated groundwater, air and soil that can lead to a host of health problems. PFAS are an enormous category. Fluoropolymers, like those that Chemours manufactures for industrial uses, are just one class. Litigation over their impact is ongoing. In June, Chemours, along with DuPont and another spinoff, Corteva, reached a $1.2 billion settlement with public water systems. Meanwhile, legislators and regulators have been cracking down on the chemicals’ use, particularly in consumer products such as clothing, furniture and textiles, where they can be more easily replaced. Minneapolis-based 3M, which in 2018 agreed to pay $850 million for damaging drinking water and natural resources in the Twin Cities area, announced that it would cease production of PFAS by the end of 2025. The semiconductor industry has pushed back against regulations here and in Europe, where regulators had proposed a ban on PFAS. When the U.S. Environmental Protection Agency asked for comments on tightened oversight on PFAS earlier this year by revoking certain low- volume exemptions, the microelectronics trade group SEMI called it “catastrophic” for domestic chip manufacturing. In a letter to the EPA, it said that such a rule “would significantly hamper the domestic semiconductor industry despite express goals of the Administration to the contrary and to the detriment of the U.S. economy.” Doubling Down In this landscape, Chemours’ Newman is doubling down. In a wide-ranging interview with Forbes during a trip to New York for Climate Week, Newman said that the $4 billion 3|Page 382 (market cap) company was expanding production of fluoropolymers, driven by the critical need for the chemicals in semiconductors and electric vehicles. Further, he said, such production could be done safely with investments that his company is making. It has, for example, invested more than $100 million in emissions control technology at its Fayetteville, North Carolina plant. The semiconductor industry has pushed back against regulations here and in Europe, where regulators had proposed a ban on PFAS. When the U.S. Environmental Protection Agency asked for comments on tightened oversight on PFAS earlier this year by revoking certain low- volume exemptions, the microelectronics trade group SEMI called it “catastrophic” for domestic chip manufacturing. In a letter to the EPA, it said that such a rule “would significantly hamper the domestic semiconductor industry despite express goals of the Administration to the contrary and to the detriment of the U.S. economy.” Doubling Down In this landscape, Chemours’ Newman is doubling down. In a wide-ranging interview with Forbes during a trip to New York for Climate Week, Newman said that the $4 billion 3|Page 382 (market cap) company was expanding production of fluoropolymers, driven by the critical need for the chemicals in semiconductors and electric vehicles. Further, he said, such production could be done safely with investments that his company is making. It has, for example, invested more than $100 million in emissions control technology at its Fayetteville, North Carolina plant. “We’re currently sold out and working to expand capacity here in the United States,” Newman said. Chemours plans to enlarge its West Virginia production facility, he said. Located just across the river from Ohio, the factory is well positioned to supply Intel’s giant chip fab near Columbus, now under construction. “Imagine making something for the semiconductor industry in what people think of as coal country,” Newman said. All told, the company is investing up to $1 billion in fluoropolymers, including those for use in semiconductors. The combination of reshoring and PFAS is “a very complicated discussion,” said Zhanyun Wang, a scientist and PFAS researcher with EMPA-Swiss Federal Laboratories for Materials Testing and Research. “There’s a lot of resistance from the industry because, of course, if we want to do the change, it costs.” That’s especially problematic if the United States and the European Union impose regulations and other parts of the world do not. However, he said, such regulations could be designed to spur new innovations. “The semiconductor industry has a lot of R&D power,” he said. “We’re currently sold out and working to expand capacity here in the United States,” Newman said. Chemours plans to enlarge its West Virginia production facility, he said. Located just across the river from Ohio, the factory is well positioned to supply Intel’s giant chip fab near Columbus, now under construction. “Imagine making something for the semiconductor industry in what people think of as coal country,” Newman said. All told, the company is investing up to $1 billion in fluoropolymers, including those for use in semiconductors. The combination of reshoring and PFAS is “a very complicated discussion,” said Zhanyun Wang, a scientist and PFAS researcher with EMPA-Swiss Federal Laboratories for Materials Testing and Research. “There’s a lot of resistance from the industry because, of course, if we want to do the change, it costs.” That’s especially problematic if the United States and the European Union impose regulations and other parts of the world do not. However, he said, such regulations could be designed to spur new innovations. “The semiconductor industry has a lot of R&D power,” he said. In July 2015, when industrial giant DuPont spun off its performance chemicals division and named it Chemours for “chemistry” plus the “Nemours” part of DuPont’s full name, the new company was saddled with debt and potentially toxic assets. “I think investors were worried if we were going to be solvent,” then-CEO Mark Vergnano told Fortune in 2016. “Were we going to make it through this or not?” Vergnano proceeded to pull off a dramatic turnaround by slashing costs, selling off non-essential businesses and gaining market share for its refrigerants business. 4|Page 383 Big Expense Newman, who had been the company’s chief financial officer during those years and is one of the country’s top Black executives, became CEO in 2021. The company’s revenue ballooned to a peak of $6.8 billion in 2022, driven by strong pricing. Its advanced performance materials business, which includes the Teflon lineup of fluorine chemicals, gained price increases of 18% and reached total sales of $1.6 billion as it focused on high-tech markets including advanced electronics and clean energy. In July 2015, when industrial giant DuPont spun off its performance chemicals division and named it Chemours for “chemistry” plus the “Nemours” part of DuPont’s full name, the new company was saddled with debt and potentially toxic assets. “I think investors were worried if we were going to be solvent,” then-CEO Mark Vergnano told Fortune in 2016. “Were we going to make it through this or not?” Vergnano proceeded to pull off a dramatic turnaround by slashing costs, selling off non-essential businesses and gaining market share for its refrigerants business. 4|Page 383 Big Expense Newman, who had been the company’s chief financial officer during those years and is one of the country’s top Black executives, became CEO in 2021. The company’s revenue ballooned to a peak of $6.8 billion in 2022, driven by strong pricing. Its advanced performance materials business, which includes the Teflon lineup of fluorine chemicals, gained price increases of 18% and reached total sales of $1.6 billion as it focused on high-tech markets including advanced electronics and clean energy. The semiconductor industry “didn’t want to use fluoropolymers, not because they were concerned about them, but because fluoropolymers are expensive,” said Gerardo Familiar, president of Chemours’ Advanced Performance Materials division, which includes fluorine chemicals. But alternatives have been scarce because of fluoropolymers’ resistance to corrosion and ability to work at high temperatures and to last for a long time. He said that fluoropolymers like PFA are “substances of low concern,” and that they should be considered differently than PFAS. “Those materials last a very, very, very long time, but they make your manufacturing very, very, very safe for the people who are there because you don’t have an issue with corrosion,” he said. The conundrum, he said, is how to manufacture them responsibly and what to do with the materials at the end of their life. The semiconductor industry “didn’t want to use fluoropolymers, not because they were concerned about them, but because fluoropolymers are expensive,” said Gerardo Familiar, president of Chemours’ Advanced Performance Materials division, which includes fluorine chemicals. But alternatives have been scarce because of fluoropolymers’ resistance to corrosion and ability to work at high temperatures and to last for a long time. He said that fluoropolymers like PFA are “substances of low concern,” and that they should be considered differently than PFAS. “Those materials last a very, very, very long time, but they make your manufacturing very, very, very safe for the people who are there because you don’t have an issue with corrosion,” he said. The conundrum, he said, is how to manufacture them responsibly and what to do with the materials at the end of their life. Some smaller companies are working on replacing PFAS in electronics manufacturing. Danvers, Massachusetts-based Transene, a privately held business founded in 1965, partnered with Toxics Use Reduction Institute (TURI) researchers at University of Massachusetts Lowell to develop alternatives for its etching solutions used in the semiconductor industry. The vast majority of customers have made the switch, and others are working through their qualification process. “You keep hearing from the industry, ‘We need 10 or 15 years to make a change,’” said Greg Morose, research professor at UMass Lowell and research manager at TURI, who worked with Transene. “We basically did the research in 18 months, which is really rapid.” 5|Page 384 Phasing Out PFAS But that’s just one small company, and one use of PFAS within a semiconductor fab. David Zamarin, founder of venture-backed DetraPel, which works on sustainable coatings for food packaging and textiles, said he received inquiries from semiconductor and electronics manufacturers, but that the cost and time didn’t make it economically viable. In the electronics industry, even companies that have set goals of getting rid of PFAS are moving slowly. Apple, for example, has promised to “thoughtfully phase out PFAS in a way that does not result in regrettable substitutions.” Some smaller companies are working on replacing PFAS in electronics manufacturing. Danvers, Massachusetts-based Transene, a privately held business founded in 1965, partnered with Toxics Use Reduction Institute (TURI) researchers at University of Massachusetts Lowell to develop alternatives for its etching solutions used in the semiconductor industry. The vast majority of customers have made the switch, and others are working through their qualification process. “You keep hearing from the industry, ‘We need 10 or 15 years to make a change,’” said Greg Morose, research professor at UMass Lowell and research manager at TURI, who worked with Transene. “We basically did the research in 18 months, which is really rapid.” 5|Page 384 Phasing Out PFAS But that’s just one small company, and one use of PFAS within a semiconductor fab. David Zamarin, founder of venture-backed DetraPel, which works on sustainable coatings for food packaging and textiles, said he received inquiries from semiconductor and electronics manufacturers, but that the cost and time didn’t make it economically viable. In the electronics industry, even companies that have set goals of getting rid of PFAS are moving slowly. Apple, for example, has promised to “thoughtfully phase out PFAS in a way that does not result in regrettable substitutions.” Newman said that fluorine chemicals can be made responsibly. Chemours has committed to eliminating at least 99% of PFAS air and water emissions from its manufacturing processes by 2030. Chemours is also working on sustainable technologies, he said, such as renewable membranes for green hydrogen production marketed under the Nafion brand name and low- global-warming refrigerants for heating and cooling buildings. “We felt because of our legacy we needed to lean into this mantra of being a different kind of chemistry company and showcasing the fact that we could be a leader in emissions reduction,” Newman said. “Our chemistry really enables a lot of the future economy.” 6|Page 385 Newman said that fluorine chemicals can be made responsibly. Chemours has committed to eliminating at least 99% of PFAS air and water emissions from its manufacturing processes by 2030. Chemours is also working on sustainable technologies, he said, such as renewable membranes for green hydrogen production marketed under the Nafion brand name and low- global-warming refrigerants for heating and cooling buildings. “We felt because of our legacy we needed to lean into this mantra of being a different kind of chemistry company and showcasing the fact that we could be a leader in emissions reduction,” Newman said. “Our chemistry really enables a lot of the future economy.” 6|Page 385 CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT A project of the Pacific Studies Center P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 (,,*$""---!%*&)!)+' TO: Micron Project, Office of Econom ic Developm ent, Onondaga County FROM: Lenny Siegel, Center for Public Environm ental Oversight DATE: October 30, 2023 SUBJECT: SEQRA Scope of Work for Micron Sem iconductor Fabrication Thank you for the opportunity to com m ent on the Septem ber 12, 2023 Draft SEQRA Scope of Work for Micron Sem iconductor Fabrication. I have been asked by residents of Onondoga County to offer m y com m ents. I have nearly five decades of experience m onitoring and influencing the worker health and environm ental im pacts of the sem iconductor industry, through the Pacific Studies Center, the Project on Health and Safety in Electronics, the Silicon Valley Toxics Coalition, and the Center for Public Environm ental Oversight, as well as m y service as Council Mem ber and Mayor of Mountain View, the birthplace of the com m ercial sem iconductor industry. CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT A project of the Pacific Studies Center P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 (,,*$""---!%*&)!)+' TO: Micron Project, Office of Econom ic Developm ent, Onondaga County FROM: Lenny Siegel, Center for Public Environm ental Oversight DATE: October 30, 2023 SUBJECT: SEQRA Scope of Work for Micron Sem iconductor Fabrication Thank you for the opportunity to com m ent on the Septem ber 12, 2023 Draft SEQRA Scope of Work for Micron Sem iconductor Fabrication. I have been asked by residents of Onondoga County to offer m y com m ents. I have nearly five decades of experience m onitoring and influencing the worker health and environm ental im pacts of the sem iconductor industry, through the Pacific Studies Center, the Project on Health and Safety in Electronics, the Silicon Valley Toxics Coalition, and the Center for Public Environm ental Oversight, as well as m y service as Council Mem ber and Mayor of Mountain View, the birthplace of the com m ercial sem iconductor industry. The sem iconductor industry produces rem arkable products that we all use. Unfortunately, its environm ental and workplace health record is less than rem arkable. The MEW Superfund Area here in Mountain View was the hom e of som e of the earliest successful integrated circuit m anufacturers. The wafer fabs are gone, but despite the scores (hundreds?) of m illions of dollars spent thus far on subsurface rem ediation, the contam ination—including the risk of public exposure—will rem ain for decades m ore, if not longer. The sam e is true at other Silicon Valley sites. The SEQRA process provides an opportunity to identify and m inim ize, in advance, the environm ental hazards of sem iconductor production. By doing so, it can lead to appropriate regulation, research on waste m anagem ent and pollution prevention, and investm ents in safer facilities. Sem iconductor production is essentially a series of chem ical processes that use a wide variety of hazardous substances. The industry explains, “While in the 1980s sem iconductor fabs used 386 " The sem iconductor industry produces rem arkable products that we all use. Unfortunately, its environm ental and workplace health record is less than rem arkable. The MEW Superfund Area here in Mountain View was the hom e of som e of the earliest successful integrated circuit m anufacturers. The wafer fabs are gone, but despite the scores (hundreds?) of m illions of dollars spent thus far on subsurface rem ediation, the contam ination—including the risk of public exposure—will rem ain for decades m ore, if not longer. The sam e is true at other Silicon Valley sites. The SEQRA process provides an opportunity to identify and m inim ize, in advance, the environm ental hazards of sem iconductor production. By doing so, it can lead to appropriate regulation, research on waste m anagem ent and pollution prevention, and investm ents in safer facilities. Sem iconductor production is essentially a series of chem ical processes that use a wide variety of hazardous substances. The industry explains, “While in the 1980s sem iconductor fabs used 386 " fewer than 20 elem ents, today they are using over 50% of the nonradioactive elem ents in the periodic table.”1 Those include toxic heavy m etals. The industry is a m ajor user of Per- and Polyfluorinated Substances (PFAS), also known as “Forever Chem icals” because they persist and bioaccum ulate in the environm ent and even hum an bloodstream s. As New York state agencies are well aware, these com pounds are toxic, even at extrem ely low exposure concentrations, through m ultiple pathways. But industry has becom e reliant on PFAS without first exam ining the hum an and environm ental risks. It explains, “Without PFAS, the ability to produce sem iconductors (and the facilities and equipm ent related to and supporting sem iconductor m anufacturing) would be put at risk.”2 Use and release of the industry’s hazardous building blocks are regulated by both state and federal statutes and regulations, but the public is generally unaware of the series of upcom ing perm it applications that Micron is expecting to m ake. The SEQRA review should list all anticipated perm itting processes, with the anticipated schedule of public com m ent periods, and it should require public notification to interested parties of each perm it application as it is subm itted. fewer than 20 elem ents, today they are using over 50% of the nonradioactive elem ents in the periodic table.”1 Those include toxic heavy m etals. The industry is a m ajor user of Per- and Polyfluorinated Substances (PFAS), also known as “Forever Chem icals” because they persist and bioaccum ulate in the environm ent and even hum an bloodstream s. As New York state agencies are well aware, these com pounds are toxic, even at extrem ely low exposure concentrations, through m ultiple pathways. But industry has becom e reliant on PFAS without first exam ining the hum an and environm ental risks. It explains, “Without PFAS, the ability to produce sem iconductors (and the facilities and equipm ent related to and supporting sem iconductor m anufacturing) would be put at risk.”2 Use and release of the industry’s hazardous building blocks are regulated by both state and federal statutes and regulations, but the public is generally unaware of the series of upcom ing perm it applications that Micron is expecting to m ake. The SEQRA review should list all anticipated perm itting processes, with the anticipated schedule of public com m ent periods, and it should require public notification to interested parties of each perm it application as it is subm itted. It should also identify hazardous substances, whether or not they currently have prom ulgated exposure standards. For exam ple, the industry reports, “Most PFAS are not regulated pollutants and therefore unless com pany specific provisions are in place, the wastewater from processes that use aqueous wet chem ical form ulations that contain PFAS would likely be discharged to the publicly owned treatm ent works without substantive rem oval of the PFAS.”3 Furtherm ore, potential workplace exposures should not be ignored because exposures are below the Occupational Exposure Level (OEL) or even a fraction of the OEL, as industry suggests.4 In m ost cases OELs, such as the Occupational Safety and Health Adm inistration’s (OSHA) Perm issible Exposure Lim its (PELs), are orders of m agnitude above what the science— including U.S. EPA studies—dictates. While the draft Scope of Work proposes m any useful Technical Chapters, there is room for m ore specificity. I focus on the use and release of hazardous substances. For Solid Wastes and Hazardous Materials, the Scope of Work states, “The chapter will identify any hazardous m aterials (including any chem ical or petroleum bulk storage) that would be used, stored, transported, or generated by the Proposed Project and m easures to protect It should also identify hazardous substances, whether or not they currently have prom ulgated exposure standards. For exam ple, the industry reports, “Most PFAS are not regulated pollutants and therefore unless com pany specific provisions are in place, the wastewater from processes that use aqueous wet chem ical form ulations that contain PFAS would likely be discharged to the publicly owned treatm ent works without substantive rem oval of the PFAS.”3 Furtherm ore, potential workplace exposures should not be ignored because exposures are below the Occupational Exposure Level (OEL) or even a fraction of the OEL, as industry suggests.4 In m ost cases OELs, such as the Occupational Safety and Health Adm inistration’s (OSHA) Perm issible Exposure Lim its (PELs), are orders of m agnitude above what the science— including U.S. EPA studies—dictates. While the draft Scope of Work proposes m any useful Technical Chapters, there is room for m ore specificity. I focus on the use and release of hazardous substances. For Solid Wastes and Hazardous Materials, the Scope of Work states, “The chapter will identify any hazardous m aterials (including any chem ical or petroleum bulk storage) that would be used, stored, transported, or generated by the Proposed Project and m easures to protect 1 “Background on Sem iconductor Manufacturing and PFAS,” Sem iconductor Association (SIA) PFAS Consortium , May 17, 2023, p. 54. The SIA PFAS Consortium is m ade up of chipm akers and their suppliers of equipm ent and m aterials. To sign up to receive their technical papers, go to https://www.sem iconductors.org/pfas/ . I am attaching this docum ent. 2 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 3. I am also attaching this docum ent. 3 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 3 4 “Background on Sem iconductor Manufacturing and PFAS,” SIA PFAS Consortium , May 17, 2023, p. 25. 387 # against releases to the environm ent. Any warranted rem edial approaches for addressing identified or potential contam inated m aterials would be described.” I suggest that the Review describe any perm itting required for the Treatm ent, Storage, and Disposal of hazardous m aterials and solid wastes, and that it list the storage requirem ents, such as double-walled tanks and piping, necessary to prevent environm ental releases. Furtherm ore, how will em ployees be educated about the risk from leaks and spills, as well as what to do when they occur? 1 “Background on Sem iconductor Manufacturing and PFAS,” Sem iconductor Association (SIA) PFAS Consortium , May 17, 2023, p. 54. The SIA PFAS Consortium is m ade up of chipm akers and their suppliers of equipm ent and m aterials. To sign up to receive their technical papers, go to https://www.sem iconductors.org/pfas/ . I am attaching this docum ent. 2 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 3. I am also attaching this docum ent. 3 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 3 4 “Background on Sem iconductor Manufacturing and PFAS,” SIA PFAS Consortium , May 17, 2023, p. 25. 387 # against releases to the environm ent. Any warranted rem edial approaches for addressing identified or potential contam inated m aterials would be described.” I suggest that the Review describe any perm itting required for the Treatm ent, Storage, and Disposal of hazardous m aterials and solid wastes, and that it list the storage requirem ents, such as double-walled tanks and piping, necessary to prevent environm ental releases. Furtherm ore, how will em ployees be educated about the risk from leaks and spills, as well as what to do when they occur? To what degree will disposal—including landfilling and incineration—create off-site hazards? Industry reports, “Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerized to be treated at an offsite licensed treatm ent and disposal facility, as a blended fuel by high tem perature incineration or reprocessing.”5 Perfluorinated com pounds are particularly difficult to destroy using incineration. Furtherm ore, even when perm itted by regulatory agencies, incineration m ay release products of incom plete com bustion into the atm osphere. For Air Quality, the Scope of Work barely m entions the potential em issions of highly toxic air contam inants. Historically the industry has used lethal gases such as arsine and phosphine, as well as toxic gases such as hydrogen chloride (the gaseous form of hydrochloric acid). Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipm ent to respond safely to such releases. Em ployees should be warned about the toxicity of gases used by the industry and trained to protect them selves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity. To what degree will disposal—including landfilling and incineration—create off-site hazards? Industry reports, “Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerized to be treated at an offsite licensed treatm ent and disposal facility, as a blended fuel by high tem perature incineration or reprocessing.”5 Perfluorinated com pounds are particularly difficult to destroy using incineration. Furtherm ore, even when perm itted by regulatory agencies, incineration m ay release products of incom plete com bustion into the atm osphere. For Air Quality, the Scope of Work barely m entions the potential em issions of highly toxic air contam inants. Historically the industry has used lethal gases such as arsine and phosphine, as well as toxic gases such as hydrogen chloride (the gaseous form of hydrochloric acid). Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipm ent to respond safely to such releases. Em ployees should be warned about the toxicity of gases used by the industry and trained to protect them selves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity. I am surprised and disappointed that no chapter is listed for Wastewater and Stormwater. The release of toxic contam inants through water pathways is one of the m ost serious threats of sem iconductor productions. Releases of certain contam inants in wastewater could com prom ise the operations of the Oak Orchard Wastewater Treatm ent Plant, even underm ining com pliance with its discharge perm it. The draft Scope of Work m entions industrial pre-treatm ent. Not only should that be described in an environm ental review chapter, but the review should identify ways to pre-treat hazardous chem icals, perhaps even reusing som e, before com ingling with other wastes. This is particularly im portant for PFAS, because in the future m ore PFAS com pounds are likely to be subjected to enforceable environm ental standards, m any at very low concentrations. In fact, given the vast num ber of PFAS used by the sem iconductor industry, the Review should identify m ethods for sam pling total organic fluorine, not just targeted com pounds. “At present, only a sm all percentage of PFAS com pounds within typical sem iconductor wastewater are detectable and quantifiable using conventional U.S. EPA analytical m ethods for PFAS-containing 5 “Background on Sem iconductor Manufacturing and PFAS,” SIA PFAS Consortium , May 17, 2023, p. 30. 388 $ I am surprised and disappointed that no chapter is listed for Wastewater and Stormwater. The release of toxic contam inants through water pathways is one of the m ost serious threats of sem iconductor productions. Releases of certain contam inants in wastewater could com prom ise the operations of the Oak Orchard Wastewater Treatm ent Plant, even underm ining com pliance with its discharge perm it. The draft Scope of Work m entions industrial pre-treatm ent. Not only should that be described in an environm ental review chapter, but the review should identify ways to pre-treat hazardous chem icals, perhaps even reusing som e, before com ingling with other wastes. This is particularly im portant for PFAS, because in the future m ore PFAS com pounds are likely to be subjected to enforceable environm ental standards, m any at very low concentrations. In fact, given the vast num ber of PFAS used by the sem iconductor industry, the Review should identify m ethods for sam pling total organic fluorine, not just targeted com pounds. “At present, only a sm all percentage of PFAS com pounds within typical sem iconductor wastewater are detectable and quantifiable using conventional U.S. EPA analytical m ethods for PFAS-containing 5 “Background on Sem iconductor Manufacturing and PFAS,” SIA PFAS Consortium , May 17, 2023, p. 30. 388 $ m aterials.”6 However, U.S. EPA has a draft m ethod (1621) for m easuring total organic fluorine.7 Furtherm ore, academ ic researchers are finding that failure to m easure total fluorine m isses discharges of significant quantities of PFAS pollutants. “[B]ecause m any studies of total organic fluorine have shown that total PFAS concentrations are at least 10 tim es higher than the sum of target PFASs. However, this does reinforce the idea that PFAS m onitoring should incorporate com plem entary target and nontarget analyses or otherwise include m easures of total organic fluorine to accurately assess PFAS abundance and potential environm ental im pacts.”8 Furtherm ore, there should be a chapter on Life-Cycle Environmental Impacts. What hazardous substances rem ain in the finished sem iconductor products, including packaging. At the end-of- life, are there m echanism s for preventing the environm ental release of sem iconductor hazardous substances? Industry’s PFAS Consortium reports, “At the end-of-life of the product containing the sem iconductor, or any parts replaced during the m anufacture of sem iconductors, would enter waste disposal stream s where any PFAS contained therein could enter the environm ent.”9 Are m anufacturers responsible for end-of-life pollution? m aterials.”6 However, U.S. EPA has a draft m ethod (1621) for m easuring total organic fluorine.7 Furtherm ore, academ ic researchers are finding that failure to m easure total fluorine m isses discharges of significant quantities of PFAS pollutants. “[B]ecause m any studies of total organic fluorine have shown that total PFAS concentrations are at least 10 tim es higher than the sum of target PFASs. However, this does reinforce the idea that PFAS m onitoring should incorporate com plem entary target and nontarget analyses or otherwise include m easures of total organic fluorine to accurately assess PFAS abundance and potential environm ental im pacts.”8 Furtherm ore, there should be a chapter on Life-Cycle Environmental Impacts. What hazardous substances rem ain in the finished sem iconductor products, including packaging. At the end-of- life, are there m echanism s for preventing the environm ental release of sem iconductor hazardous substances? Industry’s PFAS Consortium reports, “At the end-of-life of the product containing the sem iconductor, or any parts replaced during the m anufacture of sem iconductors, would enter waste disposal stream s where any PFAS contained therein could enter the environm ent.”9 Are m anufacturers responsible for end-of-life pollution? Finally, there are those who argue that a thorough environm ental review, as I have suggested, would unnecessarily delay the operation of new, advanced wafer fabrication plants. I find it hard to believe that docum enting potential hazardous substance and waste im pacts in advance would ham per the construction of a factory that is not expected to begin production until 2032. Micron—indeed, all sem iconductor m anufacturers—should already know what hazardous substances it uses and releases. Shouldn’t the public also know? The sem iconductor and com puter m anufacturing industry, such as IBM’s com plex in Endicott, New York, has a long history of causing pollution that threatens public health and the environm ent. An industry that claim s that PFAS—chem icals that are persistent, bioaccum ulative, and extrem ely toxic in low concentrations—are essential to its operations should be required to come clean about its environm ental and public health hazards. Finally, there are those who argue that a thorough environm ental review, as I have suggested, would unnecessarily delay the operation of new, advanced wafer fabrication plants. I find it hard to believe that docum enting potential hazardous substance and waste im pacts in advance would ham per the construction of a factory that is not expected to begin production until 2032. Micron—indeed, all sem iconductor m anufacturers—should already know what hazardous substances it uses and releases. Shouldn’t the public also know? The sem iconductor and com puter m anufacturing industry, such as IBM’s com plex in Endicott, New York, has a long history of causing pollution that threatens public health and the environm ent. An industry that claim s that PFAS—chem icals that are persistent, bioaccum ulative, and extrem ely toxic in low concentrations—are essential to its operations should be required to come clean about its environm ental and public health hazards. 6 “PFOS and PFOA Conversion to Short-Chain PFAS-Containing Materials Used in Sem iconductor Manufacturing,” SIA PFAS Consortium , June 5, 2023, p. 11. 7 Draft Method 1621: Screening Method for the Determ ination of Adsorbable Organic Fluorine (AOF) in Aqueous Matrices by Com bustion Ion Chrom atography (CIC), U.S. EPA, April 2022, https://www.epa.gov/system /files/docum ents/2022-04/draft-m ethod-1621-for-screening-aof- in-aqueous-m atrices-by-cic_0.pdf 8 Paige Jacob, Kristas Barzen-Hanson, and Dam ian Helbling, “Target and Nontarget Analysis of Per- and Polyfluoralkyl Substances in Wastewater from Electronics Fabrication Facilities,” Environmental Science & Technology, February 16, 2021, p. 2353. https://pubs.acs.org/doi/10.1021/acs.est.0c06690 9 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 90, 389 6 “PFOS and PFOA Conversion to Short-Chain PFAS-Containing Materials Used in Sem iconductor Manufacturing,” SIA PFAS Consortium , June 5, 2023, p. 11. 7 Draft Method 1621: Screening Method for the Determ ination of Adsorbable Organic Fluorine (AOF) in Aqueous Matrices by Com bustion Ion Chrom atography (CIC), U.S. EPA, April 2022, https://www.epa.gov/system /files/docum ents/2022-04/draft-m ethod-1621-for-screening-aof- in-aqueous-m atrices-by-cic_0.pdf 8 Paige Jacob, Kristas Barzen-Hanson, and Dam ian Helbling, “Target and Nontarget Analysis of Per- and Polyfluoralkyl Substances in Wastewater from Electronics Fabrication Facilities,” Environmental Science & Technology, February 16, 2021, p. 2353. https://pubs.acs.org/doi/10.1021/acs.est.0c06690 9 “The Im pact of a Potential PFAS Restriction on the Sem iconductor Sector,” SIA PFAS Consortium , April 13, 2023, p. 90, 389 REVIEW Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng Cornell University, Department of Material Science and Engineering, Ithaca, New York, United States REVIEW Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng Cornell University, Department of Material Science and Engineering, Ithaca, New York, United States Abstract. We identify and describe categories of fluorochemicals used to produce advanced semiconductors within the lithographic patterning manufacturing processes. Topics discussed include the per- and polyfluoroalkyl substance (PFAS) materials used and their necessary attrib- utes for successful semiconductor manufacturing, consisting of photoacid generators, fluorinated polyimides, poly(benzoxazole)s, antireflection coatings, topcoats, and embedded barrier layers, fluorinated surfactants, and materials for nanoimprint lithography. In particular, an explanation is given of the particular function that these PFAS materials contribute. It is noted that in almost all cases fluorine-free alternatives are very unlikely to provide the essential properties present in PFAS systems. Nonfluorinated alternative compounds are discussed where available. Finally, a summary table is provided listing the families of materials discussed, the critical purpose served, what the PFAS compound provides, and the prospects for alternatives. © The Authors. Published by SPIE under a Creative Commons Attribution 4.0 International License. Distribution or repro- duction of this work in whole or in part requires full attribution of the original publication, including its DOI. [DOI: 10.1117/1.JMM.21.1.010901] Keywords: fluorochemicals; per- and polyfluoroalkyl substance; photolithography; semicon- ductor processing. Paper 22003V received Jan. 21, 2022; accepted for publication Mar. 3, 2022; published online Mar. 31, 2022. Abstract. We identify and describe categories of fluorochemicals used to produce advanced semiconductors within the lithographic patterning manufacturing processes. Topics discussed include the per- and polyfluoroalkyl substance (PFAS) materials used and their necessary attrib- utes for successful semiconductor manufacturing, consisting of photoacid generators, fluorinated polyimides, poly(benzoxazole)s, antireflection coatings, topcoats, and embedded barrier layers, fluorinated surfactants, and materials for nanoimprint lithography. In particular, an explanation is given of the particular function that these PFAS materials contribute. It is noted that in almost all cases fluorine-free alternatives are very unlikely to provide the essential properties present in PFAS systems. Nonfluorinated alternative compounds are discussed where available. Finally, a summary table is provided listing the families of materials discussed, the critical purpose served, what the PFAS compound provides, and the prospects for alternatives. © The Authors. Published by SPIE under a Creative Commons Attribution 4.0 International License. Distribution or repro- duction of this work in whole or in part requires full attribution of the original publication, including its DOI. [DOI: 10.1117/1.JMM.21.1.010901] Keywords: fluorochemicals; per- and polyfluoroalkyl substance; photolithography; semicon- ductor processing. Paper 22003V received Jan. 21, 2022; accepted for publication Mar. 3, 2022; published online Mar. 31, 2022. 1 Introduction The use of fluorochemicals in lithography and semiconductor patterning plays a critical role in the success of semiconductor technology. The addition of small quantities of fluorinated mate- rials enables patterning capabilities that are otherwise not possible to achieve, and this leads to superior device performance. The compact size of the fluorine atom and its strong electron- withdrawing characteristics make it stand out in the periodic table and gives fluorocarbon mate- rials unique properties, unmatched by other chemical compounds. Fluorochemicals have found use in semiconductor processing for good technical reasons. 1. The presence of fluorine near acidic groups can convert them from an acid to a superacid, an essential characteristic for photoacid generators (PAGs) needed in advanced photoresists. 2. Fluorocarbon materials have low surface energy characteristics and act as superior barrier layers (including water repellence), which provide useful properties in photoresists and in antireflection coatings used in immersion lithography while also providing excellent release properties because they do not adhere strongly to other materials. 3. Fluorinated materials have unique solubility characteristics and can prevent intermixing between layers in a complex system such as an antireflection coating. Fluorinated materi- als are both hydrophobic and oleophobic and thus have reduced or no miscibility with essentially all fluorine-free classes of polymers. 4. Fluoropolymers have a low refractive index compared with any material except air and provide useful optical properties in photoresists and antireflection coatings. 5. They possess low dielectric constant and are especially good electrical insulators, an important feature when polyimides are patterned and retained in the final device. 1 Introduction The use of fluorochemicals in lithography and semiconductor patterning plays a critical role in the success of semiconductor technology. The addition of small quantities of fluorinated mate- rials enables patterning capabilities that are otherwise not possible to achieve, and this leads to superior device performance. The compact size of the fluorine atom and its strong electron- withdrawing characteristics make it stand out in the periodic table and gives fluorocarbon mate- rials unique properties, unmatched by other chemical compounds. Fluorochemicals have found use in semiconductor processing for good technical reasons. 1. The presence of fluorine near acidic groups can convert them from an acid to a superacid, an essential characteristic for photoacid generators (PAGs) needed in advanced photoresists. 2. Fluorocarbon materials have low surface energy characteristics and act as superior barrier layers (including water repellence), which provide useful properties in photoresists and in antireflection coatings used in immersion lithography while also providing excellent release properties because they do not adhere strongly to other materials. 3. Fluorinated materials have unique solubility characteristics and can prevent intermixing between layers in a complex system such as an antireflection coating. Fluorinated materi- als are both hydrophobic and oleophobic and thus have reduced or no miscibility with essentially all fluorine-free classes of polymers. 4. Fluoropolymers have a low refractive index compared with any material except air and provide useful optical properties in photoresists and antireflection coatings. 5. They possess low dielectric constant and are especially good electrical insulators, an important feature when polyimides are patterned and retained in the final device. *Address all correspondence to Christopher K. Ober, c.ober@cornell.edu J. Micro/Nanopattern. Mater. Metrol. 010901-1 Jan–Mar 2022 • Vol. 21(1) 390 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . *Address all correspondence to Christopher K. Ober, c.ober@cornell.edu J. Micro/Nanopattern. Mater. Metrol. 010901-1 Jan–Mar 2022 • Vol. 21(1) 390 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . This document provides a systematic overview of the photolithography process and key fluorinated materials involved, provides insight into performance requirements, and describes why fluorinated chemicals help achieve needed characteristics. Photolithography, a critical process step in the production of a semiconductor, uses a photo- resist to transfer a pattern. The primary component of a photoresist is a photopolymer whose solubility will be changed upon exposure to short wavelength radiation. In addition, the photo- resist contains a deposition solvent and several small-molecule compounds. The desired solu- bility change must be great enough that a developer (a solvent that removes the unwanted region of a resist pattern) does not swell the remaining photoresist. The development process must be able to discriminate between exposed and unexposed regions as small as a few nanometers in size. The unremoved photoresist must protect the underlying substrate from the next process steps in semiconductor manufacturing. Each stage in the process must be virtually perfect with yields well above 99%, because there may be hundreds of process steps used to manufacture each advanced semiconductor device. Without those very high yields, semiconductor manufac- turing would fail. The basic lithography process used globally today for advanced semiconductor manufactur- ing and the foreseeable future employs chemically amplified photoresists. Chemical amplifica- tion was a key invention needed to overcome the challenge of limited light sources but was also found to provide superior patterning performance. In such resist systems a photopolymer that contains acid cleavable protecting groups is combined with a photoactive compound, such as a PAG. In its native state, the photoresist polymer with protecting groups is soluble in organic solvents. Upon exposure to UV radiation, the PAG releases acid. Frequently, a subsequent post- exposure bake (PEB) step leads to the acid-catalyzed removal of protecting groups, thereby transforming the hydrophobic photopolymer into one that is soluble in an aqueous base devel- oper. The single photon of light needed to release one acidic proton is “amplified” by the more efficient acid-catalyzed deprotection process. By transforming the solubility of the photoresist, a high contrast patterning process needed in semiconductor manufacturing becomes possible. The combination of photoresist polymer and PAG to make the photoresist system is an essential part of this process and fluorination in the PAG provides the high acidity necessary for chemical amplification to work and will be described subsequently. The lithographic process is a complex series of steps requiring, at times, several complex properties in a single material or other cases combination of different materials used in the same process step. An example of the latter can be represented by the use of an antireflective coating in combination with a photoresist. An antireflection coating (ARC) is important to prevent light reflected from the semiconductor substrate, which would otherwise alter the very precise molecular scale patterns required for today’s semiconductor devices. An ARC does this by min- imizing the refractive index difference across each interface of all layers in the system. As an example, a top ARC (TARC) is a layer that sits on top of the already complex photoresist. It must not intermix with the photoresist, and it can also serve as a protective layer for this complex, multilayer lithographic system. Finally, it must be easily removed. Only a fluorinated material has a significantly lower refractive index and fluorination also provides these additional proper- ties. More details for ARCs will be discussed below. Additional uses of fluorochemicals in photolithography processes are also discussed in this paper. It is worth noting that while there are many types of fluorochemicals, our survey of the technical literature reveals that there are several specific examples of fluorocompounds that are currently in use by the semiconductor industry in the lithography process including (1) perfluor- oalkyl acid compounds (C4 or less), used in PAGs; (2) hexafluoroisopropanol, fluorotelomers, and fluoroacrylate side-chain units may be used in photoresists to incorporate specific function- alities including barrier properties and low surface energy; (3) hexafluoropropyl units are used in sub-units of some classes of polyimides for thermal stability and low dielectric constant; (4) spe- cialized per- and polyfluoroalkyl substances (PFAS) are used in ARCs; (5) PFAS are also include surfactants (used as coating leveling agents) to improve coating uniformity in a number of prod- ucts used in lithographic processes. A key feature of the addition of a fluorinated component is that its addition provides a necessary additional characteristic to the material while minimally compromising its other critical properties. Examples of these materials and uses are tabulated in This document provides a systematic overview of the photolithography process and key fluorinated materials involved, provides insight into performance requirements, and describes why fluorinated chemicals help achieve needed characteristics. Photolithography, a critical process step in the production of a semiconductor, uses a photo- resist to transfer a pattern. The primary component of a photoresist is a photopolymer whose solubility will be changed upon exposure to short wavelength radiation. In addition, the photo- resist contains a deposition solvent and several small-molecule compounds. The desired solu- bility change must be great enough that a developer (a solvent that removes the unwanted region of a resist pattern) does not swell the remaining photoresist. The development process must be able to discriminate between exposed and unexposed regions as small as a few nanometers in size. The unremoved photoresist must protect the underlying substrate from the next process steps in semiconductor manufacturing. Each stage in the process must be virtually perfect with yields well above 99%, because there may be hundreds of process steps used to manufacture each advanced semiconductor device. Without those very high yields, semiconductor manufac- turing would fail. The basic lithography process used globally today for advanced semiconductor manufactur- ing and the foreseeable future employs chemically amplified photoresists. Chemical amplifica- tion was a key invention needed to overcome the challenge of limited light sources but was also found to provide superior patterning performance. In such resist systems a photopolymer that contains acid cleavable protecting groups is combined with a photoactive compound, such as a PAG. In its native state, the photoresist polymer with protecting groups is soluble in organic solvents. Upon exposure to UV radiation, the PAG releases acid. Frequently, a subsequent post- exposure bake (PEB) step leads to the acid-catalyzed removal of protecting groups, thereby transforming the hydrophobic photopolymer into one that is soluble in an aqueous base devel- oper. The single photon of light needed to release one acidic proton is “amplified” by the more efficient acid-catalyzed deprotection process. By transforming the solubility of the photoresist, a high contrast patterning process needed in semiconductor manufacturing becomes possible. The combination of photoresist polymer and PAG to make the photoresist system is an essential part of this process and fluorination in the PAG provides the high acidity necessary for chemical amplification to work and will be described subsequently. The lithographic process is a complex series of steps requiring, at times, several complex properties in a single material or other cases combination of different materials used in the same process step. An example of the latter can be represented by the use of an antireflective coating in combination with a photoresist. An antireflection coating (ARC) is important to prevent light reflected from the semiconductor substrate, which would otherwise alter the very precise molecular scale patterns required for today’s semiconductor devices. An ARC does this by min- imizing the refractive index difference across each interface of all layers in the system. As an example, a top ARC (TARC) is a layer that sits on top of the already complex photoresist. It must not intermix with the photoresist, and it can also serve as a protective layer for this complex, multilayer lithographic system. Finally, it must be easily removed. Only a fluorinated material has a significantly lower refractive index and fluorination also provides these additional proper- ties. More details for ARCs will be discussed below. Additional uses of fluorochemicals in photolithography processes are also discussed in this paper. It is worth noting that while there are many types of fluorochemicals, our survey of the technical literature reveals that there are several specific examples of fluorocompounds that are currently in use by the semiconductor industry in the lithography process including (1) perfluor- oalkyl acid compounds (C4 or less), used in PAGs; (2) hexafluoroisopropanol, fluorotelomers, and fluoroacrylate side-chain units may be used in photoresists to incorporate specific function- alities including barrier properties and low surface energy; (3) hexafluoropropyl units are used in sub-units of some classes of polyimides for thermal stability and low dielectric constant; (4) spe- cialized per- and polyfluoroalkyl substances (PFAS) are used in ARCs; (5) PFAS are also include surfactants (used as coating leveling agents) to improve coating uniformity in a number of prod- ucts used in lithographic processes. A key feature of the addition of a fluorinated component is that its addition provides a necessary additional characteristic to the material while minimally compromising its other critical properties. Examples of these materials and uses are tabulated in J. Micro/Nanopattern. Mater. Metrol. 010901-2 Jan–Mar 2022 • Vol. 21(1) 391 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-2 Jan–Mar 2022 • Vol. 21(1) 391 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . the Appendix. This paper discusses current PFAS use in the field of photolithography, explains why certain materials are used, reviews in part the current understanding of PFAS degradation during processing, and where possible, identifies alternative materials. One of the special features of the C!F bond is its strength compared with the C!C bond due to the electron-withdrawing power of the fluorine atom. This attribute is the basis of many of the technical benefits of fluorinated materials in semiconductor processing but leads to its chemical stability and environmental persistence. Fluorination brings specific improvement in perfor- mance, and its targeted incorporation can minimize the quantities of material needed to achieve that performance. Such aspects are discussed in the context of PAGs. Thus, despite the remark- able performance improvement in many aspects of the lithographic process provided by fluo- rochemicals (PFAS) that makes possible the semiconductor revolution with its benefit to society, the large and growing environmental and societal concerns surrounding PFAS may counterbal- ance the positive technological benefits of these materials. The reader is referred to a discussion of such PFAS concerns in a well-written review article, but photolithography chemicals are largely glossed over.1 Going forward, due to environmental and regulatory concerns, perfor- mance equivalent alternatives for many of these applications still need to be identified and this will be a major research challenge. This paper presents a detailed discussion of the different types of PFAS used in advanced lithographic patterning and semiconductor manufacturing paying specific attention to the unique physical-chemical attributes of these chemistries that make them essential for semiconductor manufacturing. Specifically, we break the PFAS used in semiconductor manufacturing into six main categories of fluorochemicals used in photolithography and semiconductor patterning. For each category, we discuss the critical function served by the fluorochemicals and why the spe- cific fluorocompounds are used, based on the unique properties provided by the chemical. However, it is worth noting that there are required processes in the semiconductor manufactory using per-fluorinated compounds such as etch gases for metal etching, wet cleaning chemicals to clean and condition substrate, and other minor processes that are not covered further in this paper. Based on concerns regarding the high persistence, bioaccumulation potential, and potential toxicity of PFAS studied to date, it has been suggested that the use of PFAS be limited to essen- tial uses only. We discuss whether viable alternatives exist for each of these applications and the character- istics that must be achieved to find an alternative compound where none currently exists. Finally, we apply the essential use concept described by Cousins et al.2 to show that these compounds should be considered essential for certain processes in semiconductor manufacturing (i.e., photo- lithography and patterning) because they provide for vital functions and are currently without established alternatives. The prior paper did an excellent job of discussing different aspects of PFAS use. In this paper, we focus our discussion of essential use as “necessary for highly impor- tant purposes in semiconductor manufacturing for which alternatives are not yet established.” We describe the many uses and unique properties of PFAS chemicals, which in our opinion justifies their current use as essential in microelectronics manufacturing and for which alterna- tives have not yet been adequately identified. This paper is not intended to be an extensive listing of every example of fluorochemical used in photolithography but does attempt to explain strat- egies and classes of material used in the manufacturing of semiconductors. the Appendix. This paper discusses current PFAS use in the field of photolithography, explains why certain materials are used, reviews in part the current understanding of PFAS degradation during processing, and where possible, identifies alternative materials. One of the special features of the C!F bond is its strength compared with the C!C bond due to the electron-withdrawing power of the fluorine atom. This attribute is the basis of many of the technical benefits of fluorinated materials in semiconductor processing but leads to its chemical stability and environmental persistence. Fluorination brings specific improvement in perfor- mance, and its targeted incorporation can minimize the quantities of material needed to achieve that performance. Such aspects are discussed in the context of PAGs. Thus, despite the remark- able performance improvement in many aspects of the lithographic process provided by fluo- rochemicals (PFAS) that makes possible the semiconductor revolution with its benefit to society, the large and growing environmental and societal concerns surrounding PFAS may counterbal- ance the positive technological benefits of these materials. The reader is referred to a discussion of such PFAS concerns in a well-written review article, but photolithography chemicals are largely glossed over.1 Going forward, due to environmental and regulatory concerns, perfor- mance equivalent alternatives for many of these applications still need to be identified and this will be a major research challenge. This paper presents a detailed discussion of the different types of PFAS used in advanced lithographic patterning and semiconductor manufacturing paying specific attention to the unique physical-chemical attributes of these chemistries that make them essential for semiconductor manufacturing. Specifically, we break the PFAS used in semiconductor manufacturing into six main categories of fluorochemicals used in photolithography and semiconductor patterning. For each category, we discuss the critical function served by the fluorochemicals and why the spe- cific fluorocompounds are used, based on the unique properties provided by the chemical. However, it is worth noting that there are required processes in the semiconductor manufactory using per-fluorinated compounds such as etch gases for metal etching, wet cleaning chemicals to clean and condition substrate, and other minor processes that are not covered further in this paper. Based on concerns regarding the high persistence, bioaccumulation potential, and potential toxicity of PFAS studied to date, it has been suggested that the use of PFAS be limited to essen- tial uses only. We discuss whether viable alternatives exist for each of these applications and the character- istics that must be achieved to find an alternative compound where none currently exists. Finally, we apply the essential use concept described by Cousins et al.2 to show that these compounds should be considered essential for certain processes in semiconductor manufacturing (i.e., photo- lithography and patterning) because they provide for vital functions and are currently without established alternatives. The prior paper did an excellent job of discussing different aspects of PFAS use. In this paper, we focus our discussion of essential use as “necessary for highly impor- tant purposes in semiconductor manufacturing for which alternatives are not yet established.” We describe the many uses and unique properties of PFAS chemicals, which in our opinion justifies their current use as essential in microelectronics manufacturing and for which alterna- tives have not yet been adequately identified. This paper is not intended to be an extensive listing of every example of fluorochemical used in photolithography but does attempt to explain strat- egies and classes of material used in the manufacturing of semiconductors. 2 Photoacid Generators PAGs are photoactive compounds that generate acids upon exposure to high-energy light [deep ultraviolet (DUV) or extreme ultraviolet (EUV)]. These photoactive compounds were originally used for applications in photopolymerization in the early 1960s.3 After the introduction of chemically amplified resists (CARs) in the 1980s, they have been used in semiconductor manu- facturing as key components in advanced photoresists. It is important to understand that the process of chemical amplification requires a very strong acid in the PAG to function well. PAGs are now highly evolved with over 40 years of in-depth research and development for photoresist applications. A positive tone resist polymer after deprotection, for example, contains J. Micro/Nanopattern. Mater. Metrol. 010901-3 Jan–Mar 2022 • Vol. 21(1) 392 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use 2 Photoacid Generators PAGs are photoactive compounds that generate acids upon exposure to high-energy light [deep ultraviolet (DUV) or extreme ultraviolet (EUV)]. These photoactive compounds were originally used for applications in photopolymerization in the early 1960s.3 After the introduction of chemically amplified resists (CARs) in the 1980s, they have been used in semiconductor manu- facturing as key components in advanced photoresists. It is important to understand that the process of chemical amplification requires a very strong acid in the PAG to function well. PAGs are now highly evolved with over 40 years of in-depth research and development for photoresist applications. A positive tone resist polymer after deprotection, for example, contains J. Micro/Nanopattern. Mater. Metrol. 010901-3 Jan–Mar 2022 • Vol. 21(1) 392 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . weak acid groups that will act to buffer (weaken) the acidity of the deprotection process. Without the presence of the strong fluorosulfonic (or stronger) acid, the catalyzed deprotection process will be less efficient or may not even occur. Sulfonate anions without fluorination have repeat- edly been shown to be inadequate for use ineffective 193 nm chemically amplified photoresists and this is well known in the photoresist community. The unique characteristics of fluorine (noted below), which lead to very strong proton donation by fluorinated sulfonic acids, are essen- tial in CARs. This intrinsic benefit of fluorinated acids makes it extremely difficult to eliminate the use of fluorinated acids whilst retaining the key performance characteristics of CARs needed for advanced photolithography in microelectronics manufacturing. Other attributes of a PAG that depend less on the acid and more on the chromophore include quantum yield at the wavelength of use, the sensitivity of the overall resist formulation (e.g., 15 to 60 mJ!cm2 ), miscibility in the resist matrix, thermal and hydrolytic stability and shelf life of the photoresist, solubility in aque- ous base developer for positive tone develop or organic solvent for negative tone development followed by removal in the resist strip operation. In general, PAGs are divided into two catego- ries: either ionic or covalent (nonionic) structures. As the name suggests, ionic PAGs consist of two portions: a cation and an anion. In addition, covalent PAGs are uncharged, nonpolar com- pounds that are constructed of covalent bonds but are generally less sensitive and therefore less effective than ionic PAGs. The availability of both ionic and covalent PAGs offers process flex- ibility. In some cases, the presence of ionic groups may lead to storage instability of the photo- resist mixture or the inhomogeneous distribution of photoactive compounds in the photoresist, thus making a nonionic PAG necessary. However, most photoresist compositions that are used in semiconductor manufacturing employ ionic PAGs because of their greater sensitivity. Examples of PAGs are shown in Figs. 1 (ionic) and (covalent). In either case, a fluorinated sulfonic acid would be used to make an effective PAG. The photoefficiency difference between ionic and covalent PAGs, which leads to higher quantum yields in the ionic PAG is controlled by the cation.4 The low diffusivity and high strength of the acid resulting from the photolysis of the cation are controlled by the resulting accompa- nying fluorosulfonate anion. These anions are used in virtually all current commercial photo- resists. Limited diffusivity is important to achieving high-resolution patterns because excess diffusion of the PAG has been shown to limit the resolution of the images produced in a CAR. While aromatic sulfonic esters are shown in some nonionic PAGs described in Fig. 2, the strength of the resulting sulfonic acid after photolysis is not as high as the ionic PAGs with fluorinated sulfonate anions. Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . weak acid groups that will act to buffer (weaken) the acidity of the deprotection process. Without the presence of the strong fluorosulfonic (or stronger) acid, the catalyzed deprotection process will be less efficient or may not even occur. Sulfonate anions without fluorination have repeat- edly been shown to be inadequate for use ineffective 193 nm chemically amplified photoresists and this is well known in the photoresist community. The unique characteristics of fluorine (noted below), which lead to very strong proton donation by fluorinated sulfonic acids, are essen- tial in CARs. This intrinsic benefit of fluorinated acids makes it extremely difficult to eliminate the use of fluorinated acids whilst retaining the key performance characteristics of CARs needed for advanced photolithography in microelectronics manufacturing. Other attributes of a PAG that depend less on the acid and more on the chromophore include quantum yield at the wavelength of use, the sensitivity of the overall resist formulation (e.g., 15 to 60 mJ!cm2 ), miscibility in the resist matrix, thermal and hydrolytic stability and shelf life of the photoresist, solubility in aque- ous base developer for positive tone develop or organic solvent for negative tone development followed by removal in the resist strip operation. In general, PAGs are divided into two catego- ries: either ionic or covalent (nonionic) structures. As the name suggests, ionic PAGs consist of two portions: a cation and an anion. In addition, covalent PAGs are uncharged, nonpolar com- pounds that are constructed of covalent bonds but are generally less sensitive and therefore less effective than ionic PAGs. The availability of both ionic and covalent PAGs offers process flex- ibility. In some cases, the presence of ionic groups may lead to storage instability of the photo- resist mixture or the inhomogeneous distribution of photoactive compounds in the photoresist, thus making a nonionic PAG necessary. However, most photoresist compositions that are used in semiconductor manufacturing employ ionic PAGs because of their greater sensitivity. Examples of PAGs are shown in Figs. 1 (ionic) and (covalent). In either case, a fluorinated sulfonic acid would be used to make an effective PAG. The photoefficiency difference between ionic and covalent PAGs, which leads to higher quantum yields in the ionic PAG is controlled by the cation.4 The low diffusivity and high strength of the acid resulting from the photolysis of the cation are controlled by the resulting accompa- nying fluorosulfonate anion. These anions are used in virtually all current commercial photo- resists. Limited diffusivity is important to achieving high-resolution patterns because excess diffusion of the PAG has been shown to limit the resolution of the images produced in a CAR. While aromatic sulfonic esters are shown in some nonionic PAGs described in Fig. 2, the strength of the resulting sulfonic acid after photolysis is not as high as the ionic PAGs with fluorinated sulfonate anions. O O S O O O F S F F F F O S F F S F O F F FO 1 4 O O S O O O F S F F F F O S F F S F O F F FO 1 4 O F O O S F F O S I F F S O O Br N F O O 2 5 O F O O S F F O S I F F S O O Br N F O O 2 5 F F F F F F I O O O S F S S O F O F FO F FO F 6 3 Fig. 1 Representative ionic PAGs: 1,2,3,4 Sulfonium PAG and 5,6 Iodonium PAG. J. Micro/Nanopattern. Mater. Metrol. 010901-4 Jan–Mar 2022 • Vol. 21(1) 393 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use F F F F F F I O O O S F S S O F O F FO F FO F 6 3 Fig. 1 Representative ionic PAGs: 1,2,3,4 Sulfonium PAG and 5,6 Iodonium PAG. J. Micro/Nanopattern. Mater. Metrol. 010901-4 Jan–Mar 2022 • Vol. 21(1) 393 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . O O O O O O O F F F F S S N S F O O O O O F F F F O 7 8 9 Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . O O O O O O O F F F F S S N S F O O O O O F F F F O 7 8 9 Fig. 2 Representative nonionic covalent PAGs. Covalent PAGs do not suffer from the sorts of phase separation, low miscibility, and dark loss (the dissolution of unexposed photoresist) issues that may occur in ionic PAG-containing resist formulations, but the quantum yield of photoacid generation is generally lower for covalent PAGs so this and other factors drive the ultimate choice of PAG.5 In order to increase the acidity of the photoacid, perfluorinated methylene units may be placed next to the sulfonate group in both ionic and covalent PAGs. The polarization present in the C!F bond due to the electron- withdrawing character of fluorine stabilizes the acid anion and makes the acid stronger. A sulfonic acid such as methane sulfonic acid has a pK a of $2 (already a strong acid) but trifluor- omethyl sulfonic acid (triflic acid) has a pK a of $14. Any induction effect is significantly smaller after two or three CF2 units, so the relative benefit of fluorination is significantly reduced as the neighboring CF2 units are further away from the acid group. The original choice of longer sequence perfluorinated sulfonates (six or more) has not been explained in patents or the liter- ature but was likely due to the effectiveness of the resulting PAG, the reduced diffusivity because it is a larger molecule, its availability, and the lack of volatility in this material. For example, the volatility of the small triflate anion limits its use in a production photoresist PAG because the resulting concentration gradients in such photoresist films harm performance. However, shorter CF2 segments (1 or 2) next to the anion and connected to other units of higher mass have been shown to make effective PAGs (see Sec. 2.3).6 Finally, the diffusivity of the PAG will affect pattern resolution (less diffusion enhances resolution) and can be addressed by the use of a higher molar mass PAG/acid and even covalent attachment of the PAG to the photoresist polymer itself (see Sec. 2.4). Although actively used in some applications, triflic acid is not always a useful component in a PAG since it may have significant deficiencies when used in a very high-resolution CAR system; it is volatile and may evaporate during the PEB step leading to composition gradients that are detrimental to image resolution and it readily diffuses during annealing, which may, in turn, lead to pattern degradation from deprotection chemistry occurring in unexposed areas, effectively reducing image contrast and disrupting pattern formation. Fig. 2 Representative nonionic covalent PAGs. Covalent PAGs do not suffer from the sorts of phase separation, low miscibility, and dark loss (the dissolution of unexposed photoresist) issues that may occur in ionic PAG-containing resist formulations, but the quantum yield of photoacid generation is generally lower for covalent PAGs so this and other factors drive the ultimate choice of PAG.5 In order to increase the acidity of the photoacid, perfluorinated methylene units may be placed next to the sulfonate group in both ionic and covalent PAGs. The polarization present in the C!F bond due to the electron- withdrawing character of fluorine stabilizes the acid anion and makes the acid stronger. A sulfonic acid such as methane sulfonic acid has a pK a of $2 (already a strong acid) but trifluor- omethyl sulfonic acid (triflic acid) has a pK a of $14. Any induction effect is significantly smaller after two or three CF2 units, so the relative benefit of fluorination is significantly reduced as the neighboring CF2 units are further away from the acid group. The original choice of longer sequence perfluorinated sulfonates (six or more) has not been explained in patents or the liter- ature but was likely due to the effectiveness of the resulting PAG, the reduced diffusivity because it is a larger molecule, its availability, and the lack of volatility in this material. For example, the volatility of the small triflate anion limits its use in a production photoresist PAG because the resulting concentration gradients in such photoresist films harm performance. However, shorter CF2 segments (1 or 2) next to the anion and connected to other units of higher mass have been shown to make effective PAGs (see Sec. 2.3).6 Finally, the diffusivity of the PAG will affect pattern resolution (less diffusion enhances resolution) and can be addressed by the use of a higher molar mass PAG/acid and even covalent attachment of the PAG to the photoresist polymer itself (see Sec. 2.4). Although actively used in some applications, triflic acid is not always a useful component in a PAG since it may have significant deficiencies when used in a very high-resolution CAR system; it is volatile and may evaporate during the PEB step leading to composition gradients that are detrimental to image resolution and it readily diffuses during annealing, which may, in turn, lead to pattern degradation from deprotection chemistry occurring in unexposed areas, effectively reducing image contrast and disrupting pattern formation. 2.1 Ionic PAGs and Their Photochemistry Most ionic PAGs used in lithography are onium salt derivatives. Such ionic compounds consist of an onium moiety as the cation and sulfonate groups as the anion.4 Upon exposure, photolysis occurs and photoacid is formed. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. Returning to Fig. 1, ionic PAGs are generally composed of either diaryliodonium or triarylsulfonium photoactive units to form a salt with an appropriate anion. Triarylsulfonium PAGs usually have longer shelf life compared with diaryliodonium salt. However, a diaryliodonium salt has higher absorptivity in particular for next-generation 13.5-nm wavelength EUV photons. The mechanism of photolysis of diaryliodonium salt4 and triarylsul- fonium salts7,8 has been studied extensively. Reported photolysis mechanisms for diaryliodo- nium salt and triarylsulfonium salts are shown in Figs. 3 and 4, respectively. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. In Fig. 3, the energy required to cleave the aromatic C (sp2 ) and iodine bond is somewhat higher compared with the energy required to promote bond cleavage between the aromatic C (sp2 ) and sulfur bond (Fig. 4). 2.1 Ionic PAGs and Their Photochemistry Most ionic PAGs used in lithography are onium salt derivatives. Such ionic compounds consist of an onium moiety as the cation and sulfonate groups as the anion.4 Upon exposure, photolysis occurs and photoacid is formed. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. Returning to Fig. 1, ionic PAGs are generally composed of either diaryliodonium or triarylsulfonium photoactive units to form a salt with an appropriate anion. Triarylsulfonium PAGs usually have longer shelf life compared with diaryliodonium salt. However, a diaryliodonium salt has higher absorptivity in particular for next-generation 13.5-nm wavelength EUV photons. The mechanism of photolysis of diaryliodonium salt4 and triarylsul- fonium salts7,8 has been studied extensively. Reported photolysis mechanisms for diaryliodo- nium salt and triarylsulfonium salts are shown in Figs. 3 and 4, respectively. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. In Fig. 3, the energy required to cleave the aromatic C (sp2 ) and iodine bond is somewhat higher compared with the energy required to promote bond cleavage between the aromatic C (sp2 ) and sulfur bond (Fig. 4). J. Micro/Nanopattern. Mater. Metrol. 010901-5 Jan–Mar 2022 • Vol. 21(1) 394 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 3 Proposed photolysis mechanism for diaryliodonium salt under DUV exposure. Reproduced from Ref. 8. S O3S(CF2)3CF3 hv hv S S hv S 1% J. Micro/Nanopattern. Mater. Metrol. 010901-5 Jan–Mar 2022 • Vol. 21(1) 394 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 3 Proposed photolysis mechanism for diaryliodonium salt under DUV exposure. Reproduced from Ref. 8. S O3S(CF2)3CF3 hv hv S S hv S 1% 3% 20% 7% S 1% Primary photoproducts 2% Secondary photoproducts S Polymer 1% In-cage products Cage-escape products Fig. 4 Proposed photolysis mechanism for triarylsulfonium salt in solid poly(methyl methacrylate) matrix exposed to 266-nm irradiation (2631 mJ · cm$2 ). Reproduced from Ref. 9. 3% 20% 7% S 1% Primary photoproducts 2% Secondary photoproducts S Polymer 1% In-cage products Cage-escape products Fig. 4 Proposed photolysis mechanism for triarylsulfonium salt in solid poly(methyl methacrylate) matrix exposed to 266-nm irradiation (2631 mJ · cm$2 ). Reproduced from Ref. 9. Generally, the sulfonium PAG family is more widely used than iodonium PAGs considering its greater sensitivity and longer shelf life when used in either DUV or EUV lithography. Reference 8 reports solution results for exposure of the triphenylsulfonium cation. More recent results of solid-state polymer matrix results are shown in Fig. 4.9 Solid-state studies at 193, 248, and 266 nm exposures reveal additional products including in all cases, two previously unre- ported Triphenyl sulfonium photoproducts, triphenylene, and dibenzothiophene. Generally, the sulfonium PAG family is more widely used than iodonium PAGs considering its greater sensitivity and longer shelf life when used in either DUV or EUV lithography. Reference 8 reports solution results for exposure of the triphenylsulfonium cation. More recent results of solid-state polymer matrix results are shown in Fig. 4.9 Solid-state studies at 193, 248, and 266 nm exposures reveal additional products including in all cases, two previously unre- ported Triphenyl sulfonium photoproducts, triphenylene, and dibenzothiophene. 2.2 Nonionic Covalent PAGs and Their Photochemistry Although ionic PAGs have higher sensitivity in lithographic applications, they may be less solu- ble and more prone to phase separation in photoresist formulations. It is worth recalling that the PAG is needed to generate acid in the exposed regions to deprotect the photoresist and thereby change its solubility. Uniform distribution of a PAG is an essential attribute to excellent perfor- mance in a photoresist. Detrimental interaction between ionic structures in a photoresist and an ionic PAG may also occur in future resist materials.10 To overcome such issues, covalent PAGs J. Micro/Nanopattern. Mater. Metrol. 010901-6 Jan–Mar 2022 • Vol. 21(1) 395 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . 2.2 Nonionic Covalent PAGs and Their Photochemistry Although ionic PAGs have higher sensitivity in lithographic applications, they may be less solu- ble and more prone to phase separation in photoresist formulations. It is worth recalling that the PAG is needed to generate acid in the exposed regions to deprotect the photoresist and thereby change its solubility. Uniform distribution of a PAG is an essential attribute to excellent perfor- mance in a photoresist. Detrimental interaction between ionic structures in a photoresist and an ionic PAG may also occur in future resist materials.10 To overcome such issues, covalent PAGs J. Micro/Nanopattern. Mater. Metrol. 010901-6 Jan–Mar 2022 • Vol. 21(1) 395 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Pathway A 2 (2) H2O Ar + H2SO3 Pathway A 2 (2) H2O Ar + H2SO3 O O O Ar Irradiation Ar Ar S S + S O O O O O O H2O / O2 O Ar + S OH HO O Photoacid generation Pathway B O O O Ar Irradiation Ar Ar S S + S O O O O O O H2O / O2 O Ar + S OH HO O Photoacid generation Pathway B O O O Ar Ar Ar Irradiation + S S S O OH O O O O Photoacid generation Fig. 5 Photoacid generation mechanism for arylsulfonate esters. O O O Ar Ar Ar Irradiation + S S S O OH O O O O Photoacid generation Fig. 5 Photoacid generation mechanism for arylsulfonate esters. O N O S R O Iminosulfonates Irradiation O O O S R HO S R O O O O N O S R Photoacid generation O O Imidosulfonates Fig. 6 Photoacid generation mechanism for iminosulfonates and imidosulfonates. O N O S R O Iminosulfonates Irradiation O O O S R HO S R O O O O N O S R Photoacid generation O O Imidosulfonates Fig. 6 Photoacid generation mechanism for iminosulfonates and imidosulfonates. may be attractive alternatives.4 In general, covalent PAGs are derivatives of arylsulfonates,11 iminosulfonates,12 and imidosulfonates.13 Arylsulfonate esters can be easily synthesized from phenol and sulfonyl chlorides. A similar effort to create fluorinated sulfonate ester-containing covalent PAGs has not taken place because such PAGs have not been as effective in photoresist applications. The photoacid generation mechanism is proposed based on the nonfries photolytic ArO!S bond cleavage (pathway A) or pseudofries rearrangement (pathway B), which is more likely to occur for electron-rich aryl sulfonates as shown in Fig. 5.14,15 It is worth noting that in pathway A, in the presence of oxygen and water, stronger sulfonic acid is generated. In the absence of oxygen, weaker sulfurous acid is produced. Iminosulfonates and imidosulfonates have similar chemical structures with the N!O bond undergoing homolytic cleavage upon irradiation to generate sulfonyloxy radicals, which subsequently capture hydro- gens from nearby molecules to afford the corresponding sulfonic acid as shown in Fig. 6. may be attractive alternatives.4 In general, covalent PAGs are derivatives of arylsulfonates,11 iminosulfonates,12 and imidosulfonates.13 Arylsulfonate esters can be easily synthesized from phenol and sulfonyl chlorides. A similar effort to create fluorinated sulfonate ester-containing covalent PAGs has not taken place because such PAGs have not been as effective in photoresist applications. The photoacid generation mechanism is proposed based on the nonfries photolytic ArO!S bond cleavage (pathway A) or pseudofries rearrangement (pathway B), which is more likely to occur for electron-rich aryl sulfonates as shown in Fig. 5.14,15 It is worth noting that in pathway A, in the presence of oxygen and water, stronger sulfonic acid is generated. In the absence of oxygen, weaker sulfurous acid is produced. Iminosulfonates and imidosulfonates have similar chemical structures with the N!O bond undergoing homolytic cleavage upon irradiation to generate sulfonyloxy radicals, which subsequently capture hydro- gens from nearby molecules to afford the corresponding sulfonic acid as shown in Fig. 6. 2.3 Alternatives to Current PAGs PAGs other than iodonium and sulfonium units as well as those that do not contain traditional PFAS have also been studied for use in photolithography. To be used successfully in a CAR photoresist, the resulting acid must be as acidic as a perfluorosulfonic acid, lack volatility so that it does not evaporate during the PEB step, and in the next generation photoresists possess minimum diffusivity (to enable high-resolution pattern formation). The PAG-resist combination should have a sensitivity in the range between 10 and 75 mJ!cm2 under exposure conditions i.e., the source wavelength and tool-specific settings. Some new photoresists attach the PAG directly to the photopolymer chain to both limit diffusion and deal with issues of stochastic variations that may be present in photoresists consisting of mixtures of polymer and photoactive molecules. Nontraditional PFAS Covalent PAGs: Nitrobenzyl esters have found some application in DUVL and may be extendable to EUV lithography.10 Such molecules can generate photoacid 2.3 Alternatives to Current PAGs PAGs other than iodonium and sulfonium units as well as those that do not contain traditional PFAS have also been studied for use in photolithography. To be used successfully in a CAR photoresist, the resulting acid must be as acidic as a perfluorosulfonic acid, lack volatility so that it does not evaporate during the PEB step, and in the next generation photoresists possess minimum diffusivity (to enable high-resolution pattern formation). The PAG-resist combination should have a sensitivity in the range between 10 and 75 mJ!cm2 under exposure conditions i.e., the source wavelength and tool-specific settings. Some new photoresists attach the PAG directly to the photopolymer chain to both limit diffusion and deal with issues of stochastic variations that may be present in photoresists consisting of mixtures of polymer and photoactive molecules. Nontraditional PFAS Covalent PAGs: Nitrobenzyl esters have found some application in DUVL and may be extendable to EUV lithography.10 Such molecules can generate photoacid J. Micro/Nanopattern. Mater. Metrol. 010901-7 Jan–Mar 2022 • Vol. 21(1) 396 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 7 Chemical structure for non-PFAS covalent PAGs: (a) nitrobenzyl ester and (b) terarylene backbone-based PAG. J. Micro/Nanopattern. Mater. Metrol. 010901-7 Jan–Mar 2022 • Vol. 21(1) 396 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 7 Chemical structure for non-PFAS covalent PAGs: (a) nitrobenzyl ester and (b) terarylene backbone-based PAG. upon irradiation through o-nitrobenzyl rearrangement to generate nitrobenzaldehyde and a sulfonic acid such as triflic acid shown in Fig. 7. The chemical structure is shown in Fig. 7(a). The terarylene skeleton-based self-contained PAG is another potential candidate for some applications. The photoacid generation is triggered by the 6!-electro-cyclization reaction of photochromic triangular terarylenes.16 The chemical structure is shown in Fig. 7(b). Similarly, a triflate ester is used in the reported structure to release triflic acid upon exposure. While these and other structures can be used to demonstrate PAG concepts, they are unlikely to be as useful in new high-resolution photoresist systems because they use triflate groups. Alternative acids may be used to make more suitable PAGs from the moieties in Fig. 7. Should a useful PAG be produced from these types of photoactive structures the resulting sulfonic acid will need to be less volatile and less mobile in the polymer film? A higher molar mass, much less volatile, lower diffusivity anion might work well with these mate- rials in a functioning photoresist system. Nontraditional PFAS Ionic PAGs: Ionic PAGs derived from 2-phenoxytetrafluoroethane sulfonate were introduced by Ober and coworkers in 2007.17 This PAG was tested under e-beam and EUV radiation and showed high sensitivity, resolution, and acceptably low line edge deviations. The use of such a fluorosulfonic acid has the advantage that it limits fluorine content yet produces a very strong acid with both limited volatility and diffusivity by placing a CF2 group next to the acid group. Such an approach (discussed more below) can be used to minimize fluorine incorporation while placing this structure where it is most valuable. Its chemical structure is shown in Fig. 8(a). This PAG was tested for its envi- ronmental degradation and its effect on bacterial populations when first reported and found to be benign under the rules of that time. The good lithographic results suggest that shorter fluorinated segments (two or possibly one CF2 unit adjacent to the sulfonic acid) may make useful ionic PAGs. It should be noted that the building blocks for sulfonic acids with one CF2 are the subject of experimental studies. The pentacyanocyclopentadienide PAG is another potential ionic PAG candidate in some applica- tions. Its lithographic performance was demonstrated by Varanasi and coworkers in 2010, and it stands out for the amount of publicity it received.18 The chemical structure is shown in Fig. 8(b). While announced in 2010 as part of IBM’s efforts to reduce Perfluorooctanoic acid (PFOA) in its manufacturing process, to the best of our knowledge, this PAG was not commercialized. upon irradiation through o-nitrobenzyl rearrangement to generate nitrobenzaldehyde and a sulfonic acid such as triflic acid shown in Fig. 7. The chemical structure is shown in Fig. 7(a). The terarylene skeleton-based self-contained PAG is another potential candidate for some applications. The photoacid generation is triggered by the 6!-electro-cyclization reaction of photochromic triangular terarylenes.16 The chemical structure is shown in Fig. 7(b). Similarly, a triflate ester is used in the reported structure to release triflic acid upon exposure. While these and other structures can be used to demonstrate PAG concepts, they are unlikely to be as useful in new high-resolution photoresist systems because they use triflate groups. Alternative acids may be used to make more suitable PAGs from the moieties in Fig. 7. Should a useful PAG be produced from these types of photoactive structures the resulting sulfonic acid will need to be less volatile and less mobile in the polymer film? A higher molar mass, much less volatile, lower diffusivity anion might work well with these mate- rials in a functioning photoresist system. Nontraditional PFAS Ionic PAGs: Ionic PAGs derived from 2-phenoxytetrafluoroethane sulfonate were introduced by Ober and coworkers in 2007.17 This PAG was tested under e-beam and EUV radiation and showed high sensitivity, resolution, and acceptably low line edge deviations. The use of such a fluorosulfonic acid has the advantage that it limits fluorine content yet produces a very strong acid with both limited volatility and diffusivity by placing a CF2 group next to the acid group. Such an approach (discussed more below) can be used to minimize fluorine incorporation while placing this structure where it is most valuable. Its chemical structure is shown in Fig. 8(a). This PAG was tested for its envi- ronmental degradation and its effect on bacterial populations when first reported and found to be benign under the rules of that time. The good lithographic results suggest that shorter fluorinated segments (two or possibly one CF2 unit adjacent to the sulfonic acid) may make useful ionic PAGs. It should be noted that the building blocks for sulfonic acids with one CF2 are the subject of experimental studies. The pentacyanocyclopentadienide PAG is another potential ionic PAG candidate in some applica- tions. Its lithographic performance was demonstrated by Varanasi and coworkers in 2010, and it stands out for the amount of publicity it received.18 The chemical structure is shown in Fig. 8(b). While announced in 2010 as part of IBM’s efforts to reduce Perfluorooctanoic acid (PFOA) in its manufacturing process, to the best of our knowledge, this PAG was not commercialized. Fig. 8 Chemical structure of untraditional ionic PAGs: (a) 2-phenoxytetrafluoroethane sulfonate PAG and (b) pentacyanocyclopentadienide PAGs. J. Micro/Nanopattern. Mater. Metrol. 010901-8 Jan–Mar 2022 • Vol. 21(1) 397 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 8 Chemical structure of untraditional ionic PAGs: (a) 2-phenoxytetrafluoroethane sulfonate PAG and (b) pentacyanocyclopentadienide PAGs. J. Micro/Nanopattern. Mater. Metrol. 010901-8 Jan–Mar 2022 • Vol. 21(1) 397 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . O CF2CF2OCF2CF2SO3- F F AcO F F F F AcO F F SO3- O S O O O O O O F O F F F F AcO OAc F F F OH HO Lactone PAG Sugar sweet PAG OH HO O F F HO O F SO3- OH F O O O O F F F O Deactylated linear sweet PAG-K O O F O CF2CF2OCF2CF2SO3- O CF2CF2OCF2CF2SO3- F F AcO F F F F AcO F F SO3- O S O O O O O O F O F F F F AcO OAc F F F OH HO Lactone PAG Sugar sweet PAG OH HO O F F HO O F SO3- OH F O O O O F F F O Deactylated linear sweet PAG-K O O F O CF2CF2OCF2CF2SO3- Methoxy sugar B sweet PAG Lithocholic acid PAG Methoxy sugar B sweet PAG Lithocholic acid PAG HO F F HO F SO3- F O O O F F F O CF2CF2OCF2CF2SO3- HO OH F Hydroxy sugar B sweet PAG Dihydrocholesterol PAG Fig. 9 Chemical structures for natural products-based PAGs. HO F F HO F SO3- F O O O F F F O CF2CF2OCF2CF2SO3- HO OH F Hydroxy sugar B sweet PAG Dihydrocholesterol PAG Fig. 9 Chemical structures for natural products-based PAGs. Finally, PAGs based on glucose or other natural products have been explored. These PAGs were demonstrated to be functional materials for some high-resolution photoresist applications ena- bling sub-100nm features using ArF laser and e-beam lithography. Moreover, these PAGs showed successful microbial degradation to smaller molecular units under aerobic conditions. The chemical structures are shown in Fig. 9. Such studies revealed the successful biodegradation of these PFAS units to smaller oxidized components as well as low bacterial cytotoxicity19,20 of the photoactive sulfonium subunit. In general, the anionic units underwent biodegradation using sludge from a local municipal waste- water treatment plant. The sugar or cholesterol groups appeared to degrade easily leaving only a short, fluorinated acid residue. An advantage of these structures is that the residues retain polar functional groups and are therefore more hydrophilic than PFOS/PFAS units. This makes them less likely to accumulate in fatty tissues, but further studies are needed to identify any bioac- cumulation characteristics. The photoactive cation unit but not the fluorinated anion was gen- erally found to be cytotoxic to the bacteria. Importantly, the short, fluorinated segment enabled the formation of a high-performance PAG that could be subjected to successful biological degradation. More recently, patents have appeared that describe a number of related chemical structures, the goal of which is intended to deliver strong PAG performance and minimize the size of the fluorinated unit in the fluorosulfonic acid or eliminate it entirely. These patents claim excellent lithographic performance.21 These and other patents describe PAGs with shorter fluorinated segments,22 some of which are designed to fall into small molecular pieces.23 To assess their viability as alternative PAGs their performance characteristics (sensitivity, acid strength, and diffusivity) and environmental characteristics (fluorine content, degradation products, and toxicity) will need to be assessed. Finally, PAGs based on glucose or other natural products have been explored. These PAGs were demonstrated to be functional materials for some high-resolution photoresist applications ena- bling sub-100nm features using ArF laser and e-beam lithography. Moreover, these PAGs showed successful microbial degradation to smaller molecular units under aerobic conditions. The chemical structures are shown in Fig. 9. Such studies revealed the successful biodegradation of these PFAS units to smaller oxidized components as well as low bacterial cytotoxicity19,20 of the photoactive sulfonium subunit. In general, the anionic units underwent biodegradation using sludge from a local municipal waste- water treatment plant. The sugar or cholesterol groups appeared to degrade easily leaving only a short, fluorinated acid residue. An advantage of these structures is that the residues retain polar functional groups and are therefore more hydrophilic than PFOS/PFAS units. This makes them less likely to accumulate in fatty tissues, but further studies are needed to identify any bioac- cumulation characteristics. The photoactive cation unit but not the fluorinated anion was gen- erally found to be cytotoxic to the bacteria. Importantly, the short, fluorinated segment enabled the formation of a high-performance PAG that could be subjected to successful biological degradation. More recently, patents have appeared that describe a number of related chemical structures, the goal of which is intended to deliver strong PAG performance and minimize the size of the fluorinated unit in the fluorosulfonic acid or eliminate it entirely. These patents claim excellent lithographic performance.21 These and other patents describe PAGs with shorter fluorinated segments,22 some of which are designed to fall into small molecular pieces.23 To assess their viability as alternative PAGs their performance characteristics (sensitivity, acid strength, and diffusivity) and environmental characteristics (fluorine content, degradation products, and toxicity) will need to be assessed. 2.4 Polymer-Bound PAGs One approach to increasing the resolution to photolithography is to employ PAG that is incor- porated into the photoresist polymer structure.24 It has the advantage of making the distribution more uniform and at the same time limits the diffusivity of the sulfonate anion since it is bound to the photoresist polymer. Resolution is set in part by the diffusivity of the PAG in the photoresist formulation, which is associated with the size of the molecule. The smaller the anion, the farther the photogenerated proton can diffuse in a given time. If the PAG acid diffuses too broadly then deprotection of the photoresist takes place in unwanted regions and makes the pattern larger, less precise, and “blurry.” These pattern irregularities are characterized in terms of line edge roughness, line width roughness, and critical dimension uniformity. Examples of bound-PAG structures have been reported and two are described below shown in Fig. 10. 2.4 Polymer-Bound PAGs One approach to increasing the resolution to photolithography is to employ PAG that is incor- porated into the photoresist polymer structure.24 It has the advantage of making the distribution more uniform and at the same time limits the diffusivity of the sulfonate anion since it is bound to the photoresist polymer. Resolution is set in part by the diffusivity of the PAG in the photoresist formulation, which is associated with the size of the molecule. The smaller the anion, the farther the photogenerated proton can diffuse in a given time. If the PAG acid diffuses too broadly then deprotection of the photoresist takes place in unwanted regions and makes the pattern larger, less precise, and “blurry.” These pattern irregularities are characterized in terms of line edge roughness, line width roughness, and critical dimension uniformity. Examples of bound-PAG structures have been reported and two are described below shown in Fig. 10. J. Micro/Nanopattern. Mater. Metrol. 010901-9 Jan–Mar 2022 • Vol. 21(1) 398 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 10 Examples of polymer-bound PAGs. (a) Single CF2 unit next to sulfonate21 and (b) single CF2 unit next to sulfonate in a structure that falls apart on exposure; groups (R1, and R2) not specified groups while R3 is a linking group.20 J. Micro/Nanopattern. Mater. Metrol. 010901-9 Jan–Mar 2022 • Vol. 21(1) 398 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 10 Examples of polymer-bound PAGs. (a) Single CF2 unit next to sulfonate21 and (b) single CF2 unit next to sulfonate in a structure that falls apart on exposure; groups (R1, and R2) not specified groups while R3 is a linking group.20 This strategy also lowers concerns about “stochastics,” i.e., the chemical heterogeneity of a photoresist mixture at the dimensions of the pattern are thought to also contribute to the limit of resolution of today’s most advanced lithographic processes. Upon exposure, the fluorosulfonate group becomes protonated, catalyzes deprotection of the rest of the photoresist chain, but the strongly acidic proton cannot diffuse broadly because it remains near the anion bound to the polymer chain and thereby forms higher resolution patterns. By attaching the same number of PAG units to each polymer chain, then the PAG is uniformly distributed throughout the photo- resist film. This strategy is being seriously considered for future generations of photoresists, particularly for use in EUV lithography.25 These examples share several common features, including the attachment of the anion to the polymer backbone. Since many CAR photoresists are based on (meth) acrylates, examples reported for 193 nm (DUV) resists [shown in Figs. 10(a) and 10(b)] possess a sulfonate anion and an adjacent CF2 unit, which then is connected to the methacrylate monomer through an ester linkage. While it has not been established if one or two CF2 units are needed to produce sufficiently strong anion, this example demonstrates one approach and good prospects for polymer-bound PAGs. This strategy also lowers concerns about “stochastics,” i.e., the chemical heterogeneity of a photoresist mixture at the dimensions of the pattern are thought to also contribute to the limit of resolution of today’s most advanced lithographic processes. Upon exposure, the fluorosulfonate group becomes protonated, catalyzes deprotection of the rest of the photoresist chain, but the strongly acidic proton cannot diffuse broadly because it remains near the anion bound to the polymer chain and thereby forms higher resolution patterns. By attaching the same number of PAG units to each polymer chain, then the PAG is uniformly distributed throughout the photo- resist film. This strategy is being seriously considered for future generations of photoresists, particularly for use in EUV lithography.25 These examples share several common features, including the attachment of the anion to the polymer backbone. Since many CAR photoresists are based on (meth) acrylates, examples reported for 193 nm (DUV) resists [shown in Figs. 10(a) and 10(b)] possess a sulfonate anion and an adjacent CF2 unit, which then is connected to the methacrylate monomer through an ester linkage. While it has not been established if one or two CF2 units are needed to produce sufficiently strong anion, this example demonstrates one approach and good prospects for polymer-bound PAGs. 3 Fluorinated Polyimides In an increasing number of applications, the photopatterned polymer is not removed but is retained as part of the device, even though the lithographic requirements are not as stringent as the high-resolution photoresist systems discussed above. Their use ranges from semiconduc- tor packaging to lithographic insulation patterns for integrated circuits. Under these circumstan- ces a completely different photopolymer must be used and have properties of very high thermal stability, strong mechanical properties (high Young’s modulus, good fracture toughness), low dielectric constant (be an insulator), and moisture resistance.26 In this highly demanding application only a few polymers can provide this complex set of properties and, among them, polyimides have been found to provide the best trade-off between processing and performance. Polyimides themselves bring many of these necessary attributes but the intro- duction of fluorinated groups is used to incorporate a chemical function capable of withstand- ing high process temperature, making the final material more moisture resistant and providing a lower dielectric constant than otherwise possible without compromise to other necessary properties. The technical literature reveals that polyimides are used in a number of processes and appli- cations in photolithography.27 Polyimides are a family of polymers characterized by high thermal 3 Fluorinated Polyimides In an increasing number of applications, the photopatterned polymer is not removed but is retained as part of the device, even though the lithographic requirements are not as stringent as the high-resolution photoresist systems discussed above. Their use ranges from semiconduc- tor packaging to lithographic insulation patterns for integrated circuits. Under these circumstan- ces a completely different photopolymer must be used and have properties of very high thermal stability, strong mechanical properties (high Young’s modulus, good fracture toughness), low dielectric constant (be an insulator), and moisture resistance.26 In this highly demanding application only a few polymers can provide this complex set of properties and, among them, polyimides have been found to provide the best trade-off between processing and performance. Polyimides themselves bring many of these necessary attributes but the intro- duction of fluorinated groups is used to incorporate a chemical function capable of withstand- ing high process temperature, making the final material more moisture resistant and providing a lower dielectric constant than otherwise possible without compromise to other necessary properties. The technical literature reveals that polyimides are used in a number of processes and appli- cations in photolithography.27 Polyimides are a family of polymers characterized by high thermal J. Micro/Nanopattern. Mater. Metrol. 010901-10 Jan–Mar 2022 • Vol. 21(1) 399 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-10 Jan–Mar 2022 • Vol. 21(1) 399 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . stability, excellent thin film mechanical properties, good adhesion properties, and a low dielectric constant and dissipation factor. In particular, rigid functional groups such as phenylene- and less polar functional groups provide low dielectric constant (!k) and good mechanical toughness (resistance to tearing). Polyimides are unique as a family of polymers because they have among the highest glass transition (softening) temperatures known in a polymer (>200°C) and they are thermally stable because the polymer chain consists of interconnected aromatic rings. These properties make polyimides able to withstand the high-temperature processing used in semicon- ductor manufacturing. Like all polymers, they can be etched with the right etchants and therefore patterned, they are amorphous and transparent so they can be used to guide light and they have a lower dielectric constant than many other components in a device so they can be insulators, but unlike other polymers they come with the ability to withstand very high-temperature processing without physical softening and deformation. They often remain in the semiconductor device, unlike most other photolithographic layers. Photopatternable polyimides are generally made from a poly(amic acid) precursor such as one made from oxydianiline (ODA) (Y"O) and a dianhydride (such as pyromellitic dianhy- dride), which can be spin coated onto a substrate (see Fig. 11). However, photocrosslinkable acrylate (or similar) groups are incorporated in the soluble pol- y(amic acid). A photoradical initiator is used to crosslink the acrylate groups and the pattern is developed in this negative tone system. Then a high-temperature bake step is used to transform the poly(amic acid) to the polyimide (with loss of the acrylate groups) to form its final high thermal stability, patterned and insoluble polyimide form. Any component in the final polyimide must withstand this high-temperature bake step. Among the applications of polyimides in microelectronics processing, they find use as thick film photoresist, sacrificial layers, and structural layers. It is notable that the structure of a fluo- rinated unit, when incorporated into the polyimide, largely employs the identical hexafluoroi- sopropyl unit regardless of the application.28–30 Hence, in the most common examples, the polyimides consist of tetracarboxylic acid anhydride derivatives and aromatic diamines, as shown in Fig. 11. The polyimide polymer itself has a softening temperature too high for melt processing, but this group of polymers offers processing through its poly(amide) intermediate. The intermediate is soluble, can be coated in a thin or thick film, and after patterning is converted to the polyimide through the heating step making it an ideal material for integration with semi- conductor manufacturing. The soluble intermediate can be made into a polymer that is directly photo-patternable as shown in the poly(amide) in Fig. 11. The acrylate modified poly(amide) is photo-crosslinked upon exposure to UV radiation in the presence of a photoradical generator and then a pattern is formed. After development, the patterned polymer is subsequently transformed to the final polyimide by thermal processing. It is known in the art that the insertion of the fluorinated hexafluoroisopropyl functional group into the backbone provides a combination of better solubility in processing solvents, lower dielectric constant (more insulating), and pro- vides higher thermal and thermooxidative stability compared with other alternate chemical functions.31 stability, excellent thin film mechanical properties, good adhesion properties, and a low dielectric constant and dissipation factor. In particular, rigid functional groups such as phenylene- and less polar functional groups provide low dielectric constant (!k) and good mechanical toughness (resistance to tearing). Polyimides are unique as a family of polymers because they have among the highest glass transition (softening) temperatures known in a polymer (>200°C) and they are thermally stable because the polymer chain consists of interconnected aromatic rings. These properties make polyimides able to withstand the high-temperature processing used in semicon- ductor manufacturing. Like all polymers, they can be etched with the right etchants and therefore patterned, they are amorphous and transparent so they can be used to guide light and they have a lower dielectric constant than many other components in a device so they can be insulators, but unlike other polymers they come with the ability to withstand very high-temperature processing without physical softening and deformation. They often remain in the semiconductor device, unlike most other photolithographic layers. Photopatternable polyimides are generally made from a poly(amic acid) precursor such as one made from oxydianiline (ODA) (Y"O) and a dianhydride (such as pyromellitic dianhy- dride), which can be spin coated onto a substrate (see Fig. 11). However, photocrosslinkable acrylate (or similar) groups are incorporated in the soluble pol- y(amic acid). A photoradical initiator is used to crosslink the acrylate groups and the pattern is developed in this negative tone system. Then a high-temperature bake step is used to transform the poly(amic acid) to the polyimide (with loss of the acrylate groups) to form its final high thermal stability, patterned and insoluble polyimide form. Any component in the final polyimide must withstand this high-temperature bake step. Among the applications of polyimides in microelectronics processing, they find use as thick film photoresist, sacrificial layers, and structural layers. It is notable that the structure of a fluo- rinated unit, when incorporated into the polyimide, largely employs the identical hexafluoroi- sopropyl unit regardless of the application.28–30 Hence, in the most common examples, the polyimides consist of tetracarboxylic acid anhydride derivatives and aromatic diamines, as shown in Fig. 11. The polyimide polymer itself has a softening temperature too high for melt processing, but this group of polymers offers processing through its poly(amide) intermediate. The intermediate is soluble, can be coated in a thin or thick film, and after patterning is converted to the polyimide through the heating step making it an ideal material for integration with semi- conductor manufacturing. The soluble intermediate can be made into a polymer that is directly photo-patternable as shown in the poly(amide) in Fig. 11. The acrylate modified poly(amide) is photo-crosslinked upon exposure to UV radiation in the presence of a photoradical generator and then a pattern is formed. After development, the patterned polymer is subsequently transformed to the final polyimide by thermal processing. It is known in the art that the insertion of the fluorinated hexafluoroisopropyl functional group into the backbone provides a combination of better solubility in processing solvents, lower dielectric constant (more insulating), and pro- vides higher thermal and thermooxidative stability compared with other alternate chemical functions.31 Fig. 11 Synthesis and structure of polyimides for photolithographic processes. J. Micro/Nanopattern. Mater. Metrol. 010901-11 Jan–Mar 2022 • Vol. 21(1) 400 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 11 Synthesis and structure of polyimides for photolithographic processes. J. Micro/Nanopattern. Mater. Metrol. 010901-11 Jan–Mar 2022 • Vol. 21(1) 400 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . It must be noted that similar insulator properties have been claimed for the targeted optimi- zation of a polyimide chemical structure without the presence of fluorinated residues such as CF3 - and others, which has been successfully demonstrated in at least one scientific study.32 Araki et al.32 recently described the synthesis of a novel low dielectric constant (!k) and low dissipation factor (!f) polyimides suitable for insulator of redistribution layers used as an inter- poser layer in wafer-level packaging. However, this polyimide replaces the thermally stable aromatic structure with a silicone segment (chemically identical to bathtub caulk) to achieve the insulating properties. While this new polyimide has good dielectric properties, unmentioned in the report is the fact it undoubtedly has poor mechanical properties, thermal stability and introduces a softening temperature well below materials used in this semiconductor manufac- turing application. To demonstrate equivalence to the fluorinated polyimides, it would be nec- essary to evaluate these new polymers in a series of comparative studies. It is likely that the lower glass transition temperature and the higher associated thermal expansion changes of the silicone- based system would lead to mechanical stresses that severely limit its use outside of simple packaging applications. No literature was found on the in-process or environmental degradation of these fluorinated polyimides. It must be noted that similar insulator properties have been claimed for the targeted optimi- zation of a polyimide chemical structure without the presence of fluorinated residues such as CF3 - and others, which has been successfully demonstrated in at least one scientific study.32 Araki et al.32 recently described the synthesis of a novel low dielectric constant (!k) and low dissipation factor (!f) polyimides suitable for insulator of redistribution layers used as an inter- poser layer in wafer-level packaging. However, this polyimide replaces the thermally stable aromatic structure with a silicone segment (chemically identical to bathtub caulk) to achieve the insulating properties. While this new polyimide has good dielectric properties, unmentioned in the report is the fact it undoubtedly has poor mechanical properties, thermal stability and introduces a softening temperature well below materials used in this semiconductor manufac- turing application. To demonstrate equivalence to the fluorinated polyimides, it would be nec- essary to evaluate these new polymers in a series of comparative studies. It is likely that the lower glass transition temperature and the higher associated thermal expansion changes of the silicone- based system would lead to mechanical stresses that severely limit its use outside of simple packaging applications. No literature was found on the in-process or environmental degradation of these fluorinated polyimides. 4 Fluorinated Polybenzoxazoles Building on the properties described for fluorinated polyimides, the industry has requested materials with similar properties, which could be patterned using the more generally acceptable aqueous tetramethylammonium hydroxide based developers. One way to achieve this end was to replace the polyamic acid derivative precursors with polyhydroxyamide precursors to polybenzoxazole, which could, after patterning and cyclization, yield a polybenzoxazole (Fig. 12). The phenolic group allows for development by aqueous base, whereas use of classical diazonaphthoquinone (DNQ) photoactive units to modify the base solubility as in positive-tone photoresists allows for the needed selective patterning (Fig. 13).4 Alternatively, other protective groups such as acid-labile ethers and a PAG can also be used, as are common in advanced positive tone photoresists. These materials provide properties similar to polyimides, including thermal stability, tensile strength, and transparency as polyimides while also allowing easier processing. The incorporation of a hexafluoroisopropylidene containing monomer again confers the needed properties of transparency in 365 nm applications, good moisture resistance, thermal stability, reduced darkening after cure, and the correct solubility in aqueous development. Other additives are used to further control base solubility.33–36 The DNQ PAC may either be added to the formulation or incorporated into the polymer backbone as shown below. 4 Fluorinated Polybenzoxazoles Building on the properties described for fluorinated polyimides, the industry has requested materials with similar properties, which could be patterned using the more generally acceptable aqueous tetramethylammonium hydroxide based developers. One way to achieve this end was to replace the polyamic acid derivative precursors with polyhydroxyamide precursors to polybenzoxazole, which could, after patterning and cyclization, yield a polybenzoxazole (Fig. 12). The phenolic group allows for development by aqueous base, whereas use of classical diazonaphthoquinone (DNQ) photoactive units to modify the base solubility as in positive-tone photoresists allows for the needed selective patterning (Fig. 13).4 Alternatively, other protective groups such as acid-labile ethers and a PAG can also be used, as are common in advanced positive tone photoresists. These materials provide properties similar to polyimides, including thermal stability, tensile strength, and transparency as polyimides while also allowing easier processing. The incorporation of a hexafluoroisopropylidene containing monomer again confers the needed properties of transparency in 365 nm applications, good moisture resistance, thermal stability, reduced darkening after cure, and the correct solubility in aqueous development. Other additives are used to further control base solubility.33–36 The DNQ PAC may either be added to the formulation or incorporated into the polymer backbone as shown below. Base polymer HO OH X COHN NHCO Y Oxazole ring Precursor polymer CABC n heat O O X Y -H2O N N n After postbake (Polybenzoxazole) Fig. 12 Figure showing ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. Base polymer HO OH X COHN NHCO Y Oxazole ring Precursor polymer CABC n heat O O X Y -H2O N N n After postbake (Polybenzoxazole) Fig. 12 Figure showing ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. J. Micro/Nanopattern. Mater. Metrol. 010901-12 Jan–Mar 2022 • Vol. 21(1) 401 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 13 Ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. J. Micro/Nanopattern. Mater. Metrol. 010901-12 Jan–Mar 2022 • Vol. 21(1) 401 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 13 Ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. 5 Antireflection Coatings and Topcoats The purpose of an antireflection coating (ARC) is to prevent reflection of the imaging radiation from interface layers that produce unwanted exposure effects including standing waves. An important attribute of an ARC is to tune the refractive index difference across each interface, and reflection from the many interfaces between layers is suppressed. A difference in refractive index is essential in preventing unwanted reflection of imaging radiation, which otherwise has a detrimental effect on pattern exposures. Fluorinated materials are important because they have a lower refractive index than virtually any other material category. For example, the refractive index of poly(trifluoroethyl methacrylate) is 1.418 compared with a polymer chemically similar to photoresist materials, poly(2-methoxy styrene) with its refractive index of 1.585, a significant and critical difference for an antireflection coating. Ideally a TARC, e.g., should have an RI value of "1.3 and even with fluorinated materials, a good TARC refractive index is currently between 1.4 and 1.45. In addition to their optical properties, ARCs must not intermix with the photoresist as the different layers are deposited, and fluorination helps make that possible. Important requirements for ARCs also include ease of etching, their adhesion to a substrate, and precise thickness deposition.37–39 Bottom ARCs (BARCs) are also used to form a level surface for a photoresist. Processing of ARC and topcoat materials depend very much on where they sit in the lithographic stack (on top or on the bottom) and a combination of etch, rinse and/or devel- opment steps are used in processing. This paper does not detail these differences. TARC materi- als require first and foremost controlled and reduced refractive index (RI), good mechanical properties for film formation as well as excellent etch characteristics (faster etching than the photoresist). The low RI properties and immiscibility (by being both nonpolar and oleophobic) with the photoresist are mainly achieved by the incorporation of short, fluorinated groups such as CF3 - and C2 F4 - units in the TARC, although longer fluorinated segments have been used. An example of a generic chemical structure of an ARC is shown in Fig. 14 in which a base soluble fluoropolymer is displayed.40 It is also possible to achieve immiscibility between ARC and resist using cyclic perfluori- nated ether units in the ARC41 Finally, fluorinated surfactants have also been used to improve ARC coating quality, and more is discussed about such surfactants below. There are two possible geometries that work to limit reflection: TARC and BARC antireflection coating materials. The name specifies wherein the multilayer stack the ARC is located. Figure 15 shows the arrange- ment of the silicon substrate, the photoresist, and a TARC.42 The radiation path is different in the air, the TARC, and the photoresist since each has a different refractive index. By using a low RI TARC (due to its fluorination) and by finding the 5 Antireflection Coatings and Topcoats The purpose of an antireflection coating (ARC) is to prevent reflection of the imaging radiation from interface layers that produce unwanted exposure effects including standing waves. An important attribute of an ARC is to tune the refractive index difference across each interface, and reflection from the many interfaces between layers is suppressed. A difference in refractive index is essential in preventing unwanted reflection of imaging radiation, which otherwise has a detrimental effect on pattern exposures. Fluorinated materials are important because they have a lower refractive index than virtually any other material category. For example, the refractive index of poly(trifluoroethyl methacrylate) is 1.418 compared with a polymer chemically similar to photoresist materials, poly(2-methoxy styrene) with its refractive index of 1.585, a significant and critical difference for an antireflection coating. Ideally a TARC, e.g., should have an RI value of "1.3 and even with fluorinated materials, a good TARC refractive index is currently between 1.4 and 1.45. In addition to their optical properties, ARCs must not intermix with the photoresist as the different layers are deposited, and fluorination helps make that possible. Important requirements for ARCs also include ease of etching, their adhesion to a substrate, and precise thickness deposition.37–39 Bottom ARCs (BARCs) are also used to form a level surface for a photoresist. Processing of ARC and topcoat materials depend very much on where they sit in the lithographic stack (on top or on the bottom) and a combination of etch, rinse and/or devel- opment steps are used in processing. This paper does not detail these differences. TARC materi- als require first and foremost controlled and reduced refractive index (RI), good mechanical properties for film formation as well as excellent etch characteristics (faster etching than the photoresist). The low RI properties and immiscibility (by being both nonpolar and oleophobic) with the photoresist are mainly achieved by the incorporation of short, fluorinated groups such as CF3 - and C2 F4 - units in the TARC, although longer fluorinated segments have been used. An example of a generic chemical structure of an ARC is shown in Fig. 14 in which a base soluble fluoropolymer is displayed.40 It is also possible to achieve immiscibility between ARC and resist using cyclic perfluori- nated ether units in the ARC41 Finally, fluorinated surfactants have also been used to improve ARC coating quality, and more is discussed about such surfactants below. There are two possible geometries that work to limit reflection: TARC and BARC antireflection coating materials. The name specifies wherein the multilayer stack the ARC is located. Figure 15 shows the arrange- ment of the silicon substrate, the photoresist, and a TARC.42 The radiation path is different in the air, the TARC, and the photoresist since each has a different refractive index. By using a low RI TARC (due to its fluorination) and by finding the Fig. 14 Composition of a commercial ARC; n ¼ m.40 J. Micro/Nanopattern. Mater. Metrol. 010901-13 Jan–Mar 2022 • Vol. 21(1) 402 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 15 Light path of top coat/antireflective coating and resist film stack.43 optimal TARC film thickness reflection can be minimized.44–47 Both the phase match and inten- sity match conditions must be satisfied. This follows Airy’s original 19th-century derivation. If both conditions are met perfectly, the reflection amplitude is zero and all light is coupled into the film. This added ARC layer of lower RI results in a superior pattern with higher resolution. Fig. 14 Composition of a commercial ARC; n ¼ m.40 J. Micro/Nanopattern. Mater. Metrol. 010901-13 Jan–Mar 2022 • Vol. 21(1) 402 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 15 Light path of top coat/antireflective coating and resist film stack.43 optimal TARC film thickness reflection can be minimized.44–47 Both the phase match and inten- sity match conditions must be satisfied. This follows Airy’s original 19th-century derivation. If both conditions are met perfectly, the reflection amplitude is zero and all light is coupled into the film. This added ARC layer of lower RI results in a superior pattern with higher resolution. 5.1 Bottom Antireflective Coatings Some fluorine-containing acrylate and methacrylate-based copolymers may be used as compo- nents in BARC antireflection coating materials (as shown in Fig. 16). BARC materials used for 193-nm lithography include copolymers of acrylates/methacry- lates/alicyclic units as well as bis(benzocyclobutene) and fluorinated arylene ethers.31 Besides the use of acrylate-based copolymers, it has been reported that perfluoroalkyl silanes (shown in Fig. 13) and poly(ethoxy siloxanes) (not shown) are used as BARC materials. In all these materials the fluorinated component aids in preventing intermixing between the antireflec- tion coating and the photoresist. If mixing were to occur then the performance of the ARC (top or bottom) and the photoresist will be greatly diminished, because the thin photoresist layers will no longer be optically uniform. It should also be noted that fluorine “free” alternative BARCs are known, and they similarly must prevent mixing between ARC layers and photoresists without fluorination. Material suppliers have shown fast etching BARCs for 193-nm lithography. Such materials were targeted for first and second reflectivity minima thickness, are immiscible with photoresists (by being crosslinked), and are not affected by base developers, see Fig. 17. However, these materials were introduced before the advent of 193-nm immersion lithog- raphy. In addition, disposal of hydrophilic ARCs is complicated when ARC and resist disposal cannot be disposed of via the same waste system. 5.1 Bottom Antireflective Coatings Some fluorine-containing acrylate and methacrylate-based copolymers may be used as compo- nents in BARC antireflection coating materials (as shown in Fig. 16). BARC materials used for 193-nm lithography include copolymers of acrylates/methacry- lates/alicyclic units as well as bis(benzocyclobutene) and fluorinated arylene ethers.31 Besides the use of acrylate-based copolymers, it has been reported that perfluoroalkyl silanes (shown in Fig. 13) and poly(ethoxy siloxanes) (not shown) are used as BARC materials. In all these materials the fluorinated component aids in preventing intermixing between the antireflec- tion coating and the photoresist. If mixing were to occur then the performance of the ARC (top or bottom) and the photoresist will be greatly diminished, because the thin photoresist layers will no longer be optically uniform. It should also be noted that fluorine “free” alternative BARCs are known, and they similarly must prevent mixing between ARC layers and photoresists without fluorination. Material suppliers have shown fast etching BARCs for 193-nm lithography. Such materials were targeted for first and second reflectivity minima thickness, are immiscible with photoresists (by being crosslinked), and are not affected by base developers, see Fig. 17. However, these materials were introduced before the advent of 193-nm immersion lithog- raphy. In addition, disposal of hydrophilic ARCs is complicated when ARC and resist disposal cannot be disposed of via the same waste system. (a) F F F F CF3 O O n CF3 F F F F (a) F F F F CF3 O O n CF3 F F F F (b) n n O O O Si (CF2)5CF3 O O CF3 HO CF3 CF3 CF3 OH Fig. 16 (a) Fluorinated arylene ethers and (b) acrylate/methacrylate perfluoroalkyl silane-based BARC and TARC materials. J. Micro/Nanopattern. Mater. Metrol. 010901-14 Jan–Mar 2022 • Vol. 21(1) 403 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use (b) n n O O O Si (CF2)5CF3 O O CF3 HO CF3 CF3 CF3 OH Fig. 16 (a) Fluorinated arylene ethers and (b) acrylate/methacrylate perfluoroalkyl silane-based BARC and TARC materials. J. Micro/Nanopattern. Mater. Metrol. 010901-14 Jan–Mar 2022 • Vol. 21(1) 403 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 17 Representative BARC material.52 Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 17 Representative BARC material.52 5.2 Top Antireflective Coatings Antireflective coatings may also be placed on top of a photoresist stack to reduce optical issues. The comments related to BARCs above about refractive index and miscibility are relevant to TARC materials as well. Issues of wetting and interactions with water arise when 193-nm immer- sion lithography is used. In this variation of high-resolution lithography, a droplet of water is placed between the photoresist stack surface and the stepper (exposure) lens. As the wafer is patterned, the water film must not wet the wafer surface, or else the patterning process will fail since the rapid movement of the stepper would rapidly lead to the breakdown of the immersion layer. A very hydrophobic, nonwetting surface makes the immersion process work well and prevents leaching of the photoactive component. For immersion lithography, control of substrate reflectivity is critical and for this reason immersion, BARCs are favored over TARC when using this process. Similar chemical strategies have been used to make fluorinated TARCs and topcoats (below), where fluorinated acrylate- and methacrylate-based copolymers are used, but they are optimized for different property sets.48 Jung et al.49 showed a TARC material based on these components, which are easily developable but possess a relatively low refractive index of 1.55. Furthermore, by increasing the fluorine content of the TARC material, a high dissolution rate and receding contact angles >70 deg could be achieved. 5.2 Top Antireflective Coatings Antireflective coatings may also be placed on top of a photoresist stack to reduce optical issues. The comments related to BARCs above about refractive index and miscibility are relevant to TARC materials as well. Issues of wetting and interactions with water arise when 193-nm immer- sion lithography is used. In this variation of high-resolution lithography, a droplet of water is placed between the photoresist stack surface and the stepper (exposure) lens. As the wafer is patterned, the water film must not wet the wafer surface, or else the patterning process will fail since the rapid movement of the stepper would rapidly lead to the breakdown of the immersion layer. A very hydrophobic, nonwetting surface makes the immersion process work well and prevents leaching of the photoactive component. For immersion lithography, control of substrate reflectivity is critical and for this reason immersion, BARCs are favored over TARC when using this process. Similar chemical strategies have been used to make fluorinated TARCs and topcoats (below), where fluorinated acrylate- and methacrylate-based copolymers are used, but they are optimized for different property sets.48 Jung et al.49 showed a TARC material based on these components, which are easily developable but possess a relatively low refractive index of 1.55. Furthermore, by increasing the fluorine content of the TARC material, a high dissolution rate and receding contact angles >70 deg could be achieved. 5.3 Topcoats Sanders wrote an extensive review of resist systems for 193-nm immersion lithography and dis- cussed the need for topcoats.41 These are materials used as the upper layer in the resist stack that was optimized for the purpose of preventing immersion liquid (water) from leaching photoactive materials from the photoresist during the patterning process and for base development. In that report, he describes several compositions that work well as topcoats. These include perfluoro ethers as well as polymers with hexafluoroisopropanol units and those with short-chain perfluor- oalkyl units. All approaches reported function well as barrier materials. In addition to immersion topcoats, which are directly coated on the resist, material suppliers have also developed highly functionalized fluorinated amphiphilic molecular structures, which provide the same properties as a topcoat. The advantage of this approach is that the material, known as an embedded barrier layer (EBL), is formulated directly in the resist, and no separate topcoat coating step is required. Such photoresists are known as topcoat-free resists.50 Such EBL materials may have similar fluorinated components as those found in fluorinated topcoats and fluorinated ARCs, but their application and processing are different. Other approaches to low RI materials include the incorporation of air pockets using silica nanoparticles. However, this approach did not gain industry acceptance, because it was not pos- sible to implement with the necessary process reliability and reproducibility. In addition, dyed TARCs (limited by the availability of appropriate chromophores) have been developed that reduce the need for fluorination using anomalous dispersion optical effects but do not eliminate the need for fluorinated components for performance reasons discussed above. Finally, the only molecular unit that comes close to fluorochemicals in low surface energy are silicones, but they have the disadvantage that they have low softening temperatures and are very 5.3 Topcoats Sanders wrote an extensive review of resist systems for 193-nm immersion lithography and dis- cussed the need for topcoats.41 These are materials used as the upper layer in the resist stack that was optimized for the purpose of preventing immersion liquid (water) from leaching photoactive materials from the photoresist during the patterning process and for base development. In that report, he describes several compositions that work well as topcoats. These include perfluoro ethers as well as polymers with hexafluoroisopropanol units and those with short-chain perfluor- oalkyl units. All approaches reported function well as barrier materials. In addition to immersion topcoats, which are directly coated on the resist, material suppliers have also developed highly functionalized fluorinated amphiphilic molecular structures, which provide the same properties as a topcoat. The advantage of this approach is that the material, known as an embedded barrier layer (EBL), is formulated directly in the resist, and no separate topcoat coating step is required. Such photoresists are known as topcoat-free resists.50 Such EBL materials may have similar fluorinated components as those found in fluorinated topcoats and fluorinated ARCs, but their application and processing are different. Other approaches to low RI materials include the incorporation of air pockets using silica nanoparticles. However, this approach did not gain industry acceptance, because it was not pos- sible to implement with the necessary process reliability and reproducibility. In addition, dyed TARCs (limited by the availability of appropriate chromophores) have been developed that reduce the need for fluorination using anomalous dispersion optical effects but do not eliminate the need for fluorinated components for performance reasons discussed above. Finally, the only molecular unit that comes close to fluorochemicals in low surface energy are silicones, but they have the disadvantage that they have low softening temperatures and are very J. Micro/Nanopattern. Mater. Metrol. 010901-15 Jan–Mar 2022 • Vol. 21(1) 404 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . oxygen plasma etch-resistant. Where ARCs need to be removed using such etch methods, alter- native structures with silicones do not provide needed properties. J. Micro/Nanopattern. Mater. Metrol. 010901-15 Jan–Mar 2022 • Vol. 21(1) 404 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . oxygen plasma etch-resistant. Where ARCs need to be removed using such etch methods, alter- native structures with silicones do not provide needed properties. 6 Fluorinated Surfactants and Surface Leveling Agents Surfactants in general are “surface-active agents” that consists of a hydrophobic segment and a hydrophilic unit. Surfactants can be used in a variety of coating applications for improving film quality, changing surface interaction,51 and wetting characteristics, and component mixing. The hydrophobic portion of a surfactant can consist of such moieties as hydrocarbon, silicone, or perfluorocarbon segments while the hydrophilic portion of a surfactant can be charged or neutral. Specific performance advantage of fluorinated surfactants is that the surface activity is much higher than equivalent hydrocarbon or silicone surfactants as indicated by the requirement for less surfactant material in a formulation to achieve its critical micelle concentration. Fluorinated surfactants may be used in several applications in photoresist processing. For example, they can be used to improve photoresist deposition and eliminate defects during photo- resist coating. Fluorinated surfactants have been used to improve the development process of an exposed photoresist. They are used to improve the uniformity of an ARC coating process and are especially effective when fluorinated ARCs are involved. Thick film photoresists benefit from surfactants in the formulation to achieve good coating uniformity. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality to reduce layer contamination and increase process yield) and the surface activity of fluorocarbon surfactants makes them readily useable with other ARCs and photoresist materials. Fluorinated nonionic surfactants have been used in a wide range of lithographic processes due to their very low surface energy, thermal-and mechanical stability, and low refractive index. Nanoimprint lithography (below) is making use of fluorinated surfactants to reduce defects caused by the removal of the template in the patterning process.53,54 Lin et al.55 demonstrated the use of methyl perfluorooctanoate to significantly reduce defects of printed patterns. Another example was shown by Zelsmann et al.56 applying perfluorooctyl-triethoxysilane and perfluoro- octyl-trimethoxysilane. Besides use in nanoimprint lithography, fluorosurfactant-assisted photo- lithography was demonstrated by Sakanoue et al. using commercial polymeric fluorosurfactants, such as Surflon S-386, S-651 (AGC) and Novec FC-4432 (3M).57 It should be noted that, due to the unique properties of fluorinated surfactants, examples of nonfluorinated surfactants with equivalent characteristics to those of fluorinated surfactants are limited and have been used in few resist formulations. 6 Fluorinated Surfactants and Surface Leveling Agents Surfactants in general are “surface-active agents” that consists of a hydrophobic segment and a hydrophilic unit. Surfactants can be used in a variety of coating applications for improving film quality, changing surface interaction,51 and wetting characteristics, and component mixing. The hydrophobic portion of a surfactant can consist of such moieties as hydrocarbon, silicone, or perfluorocarbon segments while the hydrophilic portion of a surfactant can be charged or neutral. Specific performance advantage of fluorinated surfactants is that the surface activity is much higher than equivalent hydrocarbon or silicone surfactants as indicated by the requirement for less surfactant material in a formulation to achieve its critical micelle concentration. Fluorinated surfactants may be used in several applications in photoresist processing. For example, they can be used to improve photoresist deposition and eliminate defects during photo- resist coating. Fluorinated surfactants have been used to improve the development process of an exposed photoresist. They are used to improve the uniformity of an ARC coating process and are especially effective when fluorinated ARCs are involved. Thick film photoresists benefit from surfactants in the formulation to achieve good coating uniformity. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality to reduce layer contamination and increase process yield) and the surface activity of fluorocarbon surfactants makes them readily useable with other ARCs and photoresist materials. Fluorinated nonionic surfactants have been used in a wide range of lithographic processes due to their very low surface energy, thermal-and mechanical stability, and low refractive index. Nanoimprint lithography (below) is making use of fluorinated surfactants to reduce defects caused by the removal of the template in the patterning process.53,54 Lin et al.55 demonstrated the use of methyl perfluorooctanoate to significantly reduce defects of printed patterns. Another example was shown by Zelsmann et al.56 applying perfluorooctyl-triethoxysilane and perfluoro- octyl-trimethoxysilane. Besides use in nanoimprint lithography, fluorosurfactant-assisted photo- lithography was demonstrated by Sakanoue et al. using commercial polymeric fluorosurfactants, such as Surflon S-386, S-651 (AGC) and Novec FC-4432 (3M).57 It should be noted that, due to the unique properties of fluorinated surfactants, examples of nonfluorinated surfactants with equivalent characteristics to those of fluorinated surfactants are limited and have been used in few resist formulations. 7 Nanoimprint Lithography While nanoimprint lithography is not today a mainstream patterning technology, it has the poten- tial to be introduced soon for specific patterning applications. A mold with nm-scale features is used to imprint polymer or a photopolymerizable monomer mixture to form the pattern in the transparent mold.58,59 In the former case, many polymers have been explored for nanoimprinting but a mold release agent such as a poly(perfluoroether) is usually added to the surface of the mold. In the latter case, fluorochemical units such as those used in BARCs and ARCs including perfluoralkyl segments or hexafluoroisopropanol groups have been used.60 In all cases, removal of the polymer from the mold is an important step in the production of the pattern and for this reason, fluoropolymers are frequently used. It is worth being aware of this approach to high- resolution pattern formation because some early attempts at process development depend on the use of fluorinated photoresists. The fluoropolymer has, in addition to excellent release proper- ties, the advantage that air, which can be trapped in the process, is easily dissolved in the fluo- ropolymer thereby eliminating trapped bubbles and does not seem to affect pattern formation. Therefore, fluoropolymers are often preferred in this process. This technology area is new enough that little or no reported work has been carried out on the environmental fate of such materials. Alternate materials for this process include silicones that can be used for their mold release properties.61 This area is attracting strong interest and demonstrates that nonfluorinated materials 7 Nanoimprint Lithography While nanoimprint lithography is not today a mainstream patterning technology, it has the poten- tial to be introduced soon for specific patterning applications. A mold with nm-scale features is used to imprint polymer or a photopolymerizable monomer mixture to form the pattern in the transparent mold.58,59 In the former case, many polymers have been explored for nanoimprinting but a mold release agent such as a poly(perfluoroether) is usually added to the surface of the mold. In the latter case, fluorochemical units such as those used in BARCs and ARCs including perfluoralkyl segments or hexafluoroisopropanol groups have been used.60 In all cases, removal of the polymer from the mold is an important step in the production of the pattern and for this reason, fluoropolymers are frequently used. It is worth being aware of this approach to high- resolution pattern formation because some early attempts at process development depend on the use of fluorinated photoresists. The fluoropolymer has, in addition to excellent release proper- ties, the advantage that air, which can be trapped in the process, is easily dissolved in the fluo- ropolymer thereby eliminating trapped bubbles and does not seem to affect pattern formation. Therefore, fluoropolymers are often preferred in this process. This technology area is new enough that little or no reported work has been carried out on the environmental fate of such materials. Alternate materials for this process include silicones that can be used for their mold release properties.61 This area is attracting strong interest and demonstrates that nonfluorinated materials J. Micro/Nanopattern. Mater. Metrol. 010901-16 Jan–Mar 2022 • Vol. 21(1) 405 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . perform well, but at this time it has not been established if silicone materials are superior in performance. Etch characteristics and wear properties are of course different between fluoropol- ymers and silicones. J. Micro/Nanopattern. Mater. Metrol. 010901-16 Jan–Mar 2022 • Vol. 21(1) 405 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . perform well, but at this time it has not been established if silicone materials are superior in performance. Etch characteristics and wear properties are of course different between fluoropol- ymers and silicones. 8 PFOS/PFAS Remediation As noted above, the strength of the C!F bond creates materials with unique and technologically useful properties in semiconductor processing. That same bond strength also results in strong re- sistance toward physical, chemical, and biological degradation. Due to this strong resistance to degradation, PFAS compounds in general are extremely stable in the environment. In addition, such compounds have been found to be bioaccumulative.62 Extensive literature exists describing the detection of a number of PFAS compounds in drinking water.63 Postuse PFAS waste treatment methods including advanced oxidation processes,64 reductive decomposition processes (aqueous electrons, hydrated electrons, etc.), and incineration have been developed for mitigation purposes.59 Among these methods, advanced oxidation processes do not show high efficacy for PFAS degradation due to the high electronegativity of the fluorine atoms. More work will need to be done to assess the relevance to the kinds of fluorinated materials discussed in this paper. Recent actions by the EPA include interim recommendations for addressing groundwater contaminated with PFOA and PFOS, published method 533 for detection of PFAS compounds in drinking water, an updated list of 172 PFAS chemicals subject to toxics release inventory reporting, a proposal to regulate PFOA and PFOS in drinking water and significant new use rule for certain PFAS in manufactured products.65 Significant data gaps presently exist in dealing with PFAS and PFOS materials. The EPA is also leading a national effort to under- stand PFAS and reduce PFAS risks to the public through the implementation of its PFAS action plan and through active engagement and partnership with other government agencies and constituencies.66 8 PFOS/PFAS Remediation As noted above, the strength of the C!F bond creates materials with unique and technologically useful properties in semiconductor processing. That same bond strength also results in strong re- sistance toward physical, chemical, and biological degradation. Due to this strong resistance to degradation, PFAS compounds in general are extremely stable in the environment. In addition, such compounds have been found to be bioaccumulative.62 Extensive literature exists describing the detection of a number of PFAS compounds in drinking water.63 Postuse PFAS waste treatment methods including advanced oxidation processes,64 reductive decomposition processes (aqueous electrons, hydrated electrons, etc.), and incineration have been developed for mitigation purposes.59 Among these methods, advanced oxidation processes do not show high efficacy for PFAS degradation due to the high electronegativity of the fluorine atoms. More work will need to be done to assess the relevance to the kinds of fluorinated materials discussed in this paper. Recent actions by the EPA include interim recommendations for addressing groundwater contaminated with PFOA and PFOS, published method 533 for detection of PFAS compounds in drinking water, an updated list of 172 PFAS chemicals subject to toxics release inventory reporting, a proposal to regulate PFOA and PFOS in drinking water and significant new use rule for certain PFAS in manufactured products.65 Significant data gaps presently exist in dealing with PFAS and PFOS materials. The EPA is also leading a national effort to under- stand PFAS and reduce PFAS risks to the public through the implementation of its PFAS action plan and through active engagement and partnership with other government agencies and constituencies.66 9 Summary Fluorinated materials play a useful and often essential role in many aspects of semiconductor processing. In our review of the technical literature, we have examined six major applications of fluorochemicals in photolithography and semiconductor processing and identified an emerging technology, nanoimprint lithography, see Table 1. These fluorochemicals are employed as com- ponents of PAGs, as components of photoresists, as elements of high-temperature polymers, and as ingredients in ARCs, BARCs, and as topcoats, frequently satisfying the “essential use” cri- terion. However, there is a strong societal interest in eliminating their use, and “essential use” is a stopgap situation in which replacements are actively sought. The “essential use” concept expects that PFAS uses considered essential today should be continually reviewed for potential removal or replacement by new technologies and be targeted by innovation toward alternatives. The con- cept does not support long-term and large-scale remediation technologies to justify the ongoing use of PFAS chemicals. Thus, the challenges going forward are to find a means to replace PFAS components that achieve or surpass today’s current performance characteristics in the following current and pos- sible future lithography systems. 9 Summary Fluorinated materials play a useful and often essential role in many aspects of semiconductor processing. In our review of the technical literature, we have examined six major applications of fluorochemicals in photolithography and semiconductor processing and identified an emerging technology, nanoimprint lithography, see Table 1. These fluorochemicals are employed as com- ponents of PAGs, as components of photoresists, as elements of high-temperature polymers, and as ingredients in ARCs, BARCs, and as topcoats, frequently satisfying the “essential use” cri- terion. However, there is a strong societal interest in eliminating their use, and “essential use” is a stopgap situation in which replacements are actively sought. The “essential use” concept expects that PFAS uses considered essential today should be continually reviewed for potential removal or replacement by new technologies and be targeted by innovation toward alternatives. The con- cept does not support long-term and large-scale remediation technologies to justify the ongoing use of PFAS chemicals. Thus, the challenges going forward are to find a means to replace PFAS components that achieve or surpass today’s current performance characteristics in the following current and pos- sible future lithography systems. 1. The use of fluorination in PAGs is to enhance the acidity (make pK a # 1) of the acid produced in the region of exposure of a photoresist. The formation of acid to induce a solubility change is the critical step in today’s chemically amplified photoresists, the workhorse family of photoresists that enable the production of the vast majority of semi- conductors. The presence of a fluorinated unit adjacent to the sulfonic acid gives the acid its ability to efficiently release a proton that reacts with the resist polymer to create a solubility switch. Subsequent development forms a pattern in the photoresist. Today there is no effective alternative to a fluorinated sulfonic acid and this situation applies to chemi- cally amplified photoresists across all wavelengths of lithography from 248 nm to EUV. Efforts to reduce the amount of fluorination in a PAG molecule have been demonstrated, but a survey of the current literature has not shown that complete elimination of 1. The use of fluorination in PAGs is to enhance the acidity (make pK a # 1) of the acid produced in the region of exposure of a photoresist. The formation of acid to induce a solubility change is the critical step in today’s chemically amplified photoresists, the workhorse family of photoresists that enable the production of the vast majority of semi- conductors. The presence of a fluorinated unit adjacent to the sulfonic acid gives the acid its ability to efficiently release a proton that reacts with the resist polymer to create a solubility switch. Subsequent development forms a pattern in the photoresist. Today there is no effective alternative to a fluorinated sulfonic acid and this situation applies to chemi- cally amplified photoresists across all wavelengths of lithography from 248 nm to EUV. Efforts to reduce the amount of fluorination in a PAG molecule have been demonstrated, but a survey of the current literature has not shown that complete elimination of J. Micro/Nanopattern. Mater. Metrol. 010901-17 Jan–Mar 2022 • Vol. 21(1) 406 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-17 Jan–Mar 2022 • Vol. 21(1) 406 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . fluorination has produced a successful alternative. However, it is very likely that fluorine- free alternatives, which perform equally well and can easily take the place of the fluo- rinated compounds used today, will be more widely used, and developed in the coming years. Fluorinated polyimides use the presence of a fluorinated unit to improve the dielec- tric constant of the material and make it a better insulator while retaining excellent thermal stability. This combination of characteristics has not been effectively achieved by alter- nate means. 2. Other materials like poly(benzoxazole)s also receive an important performance boost from the incorporation of a fluorinated unit. 3. Antireflection coatings (ARC, BARC, and TARC) and other coatings such as topcoats or EBL use fluorinated components to limit the miscibility of this added layer with a photo- resist or other organic layer in the semiconductor manufacturing process. As surface layers, they also provide barrier properties and when used as a topcoat act to protect the photoresist from interactions with the immersion fluid (currently water) used in 193-nm lithography. However, while these features can in part be replicated by other systems the necessary combination of properties (immiscibility, surface wetting properties, barrier properties, low refractive index) has not been successfully achieved. 4. Fluorinated surfactants provide a specific performance advantage since their surface energy is much lower than hydrocarbon or silicone surfactants resulting in the need for less surfactant material in formulations. Additionally, properties including very low sur- face energy, thermal and mechanical stability, and low refractive index provide benefits to coating and etching processes. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality), and the surface activity of fluorocarbon surfactants makes them readily useable with ARCs and photoresist materials. 5. Nanoimprint lithography may become an important technology for some specialized forms of nanopatterning, and there is interest in the use of fluoromaterials in nanoimprint lithography. Current studies have not yet fully demonstrated that fluorine-free alternatives are successful in producing fine-featured patterns in a production capable system. fluorination has produced a successful alternative. However, it is very likely that fluorine- free alternatives, which perform equally well and can easily take the place of the fluo- rinated compounds used today, will be more widely used, and developed in the coming years. Fluorinated polyimides use the presence of a fluorinated unit to improve the dielec- tric constant of the material and make it a better insulator while retaining excellent thermal stability. This combination of characteristics has not been effectively achieved by alter- nate means. 2. Other materials like poly(benzoxazole)s also receive an important performance boost from the incorporation of a fluorinated unit. 3. Antireflection coatings (ARC, BARC, and TARC) and other coatings such as topcoats or EBL use fluorinated components to limit the miscibility of this added layer with a photo- resist or other organic layer in the semiconductor manufacturing process. As surface layers, they also provide barrier properties and when used as a topcoat act to protect the photoresist from interactions with the immersion fluid (currently water) used in 193-nm lithography. However, while these features can in part be replicated by other systems the necessary combination of properties (immiscibility, surface wetting properties, barrier properties, low refractive index) has not been successfully achieved. 4. Fluorinated surfactants provide a specific performance advantage since their surface energy is much lower than hydrocarbon or silicone surfactants resulting in the need for less surfactant material in formulations. Additionally, properties including very low sur- face energy, thermal and mechanical stability, and low refractive index provide benefits to coating and etching processes. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality), and the surface activity of fluorocarbon surfactants makes them readily useable with ARCs and photoresist materials. 5. Nanoimprint lithography may become an important technology for some specialized forms of nanopatterning, and there is interest in the use of fluoromaterials in nanoimprint lithography. Current studies have not yet fully demonstrated that fluorine-free alternatives are successful in producing fine-featured patterns in a production capable system. Appendix Table 1 summarizes the function of the fluorinated compounds required for the main lithographic processes. In addition, non-fluorinated alternatives and their current feasibility are shown. Table 1 Purpose, properties of fluorocompounds for lithographic patterning and semiconductor processing. Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative Appendix Table 1 summarizes the function of the fluorinated compounds required for the main lithographic processes. In addition, non-fluorinated alternatives and their current feasibility are shown. Table 1 Purpose, properties of fluorocompounds for lithographic patterning and semiconductor processing. Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative PAGs Generation of strong Fluorinated All successfully Not yet acid upon exposure to sulfonium- and demonstrated demonstrated in UV light, when iodonium-acid salts/ alternatives have completely fluorine- fluorination acid strong fluorinated segments free materials groups. Control of electronegativity of —some down to one location and F atom—creates CF2 unit distribution of superacid material generated acids, capable of mixing especially in high- with photoresist resolution applications Antireflection Low refractive index, Largely fluorinated Fluorine-free ARC requirements coatings (top and low surface energy, units in acrylate/ alternatives known. different in 193- and bottom versions and good barrier methacrylate/ But necessary 193-nm immersion have different properties styrene-based properties not yet lithography— requirements) copolymers, very low broadly fluorine-free refractive index, and demonstrated in 193 systems not fully excellent barrier immersion demonstrated properties PAGs Generation of strong Fluorinated All successfully Not yet acid upon exposure to sulfonium- and demonstrated demonstrated in UV light, when iodonium-acid salts/ alternatives have completely fluorine- fluorination acid strong fluorinated segments free materials groups. Control of electronegativity of —some down to one location and F atom—creates CF2 unit distribution of superacid material generated acids, capable of mixing especially in high- with photoresist resolution applications Antireflection Low refractive index, Largely fluorinated Fluorine-free ARC requirements coatings (top and low surface energy, units in acrylate/ alternatives known. different in 193- and bottom versions and good barrier methacrylate/ But necessary 193-nm immersion have different properties styrene-based properties not yet lithography— requirements) copolymers, very low broadly fluorine-free refractive index, and demonstrated in 193 systems not fully excellent barrier immersion demonstrated properties J. Micro/Nanopattern. Mater. Metrol. 010901-18 Jan–Mar 2022 • Vol. 21(1) 407 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Table 1 (Continued). Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative J. Micro/Nanopattern. Mater. Metrol. 010901-18 Jan–Mar 2022 • Vol. 21(1) 407 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Table 1 (Continued). Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative Topcoat Provides barrier layer Largely fluorinated Lacking satisfactory Not yet (for 193-nm for 193-nm immersion acrylate/ options demonstrated in immersion photoresists applied on methacrylate/ fluorine-free photoresist) top of photoresist and styrene-based materials prevents leaching of copolymers, excellent photoactive barrier properties with components. Protects fluorinated the photoresist from components contact with immersion liquid (water) EBL (for 193-nm Forms a protective Largely acrylate/ Lacking satisfactory Not yet immersion surface layer for 193- methacrylate/ options demonstrated in photoresist) nm immersion styrene-based fluorine-free photoresists and copolymers, excellent materials prevents leaching of barrier properties with photoactive fluorinated components. components Incorporated as part of photoresist and segregates to film surface during the coating process. Protects the photoresist from contact with immersion liquid (water) Polyimides Required stress buffer Tetracarboxylic acid Novel polyimides— Not yet (photopatternable) coat between chip and anhydride derivatives suitable fluorine-free demonstrated in package to prevent and aromatic alternatives have not fluorine-free premature device diamines/solubility in demonstrated equal materials failure; especially good organic solvents, low performance electrical insulating dielectric constants, characteristics and high thermal and thermooxidative stability; requires negative tone solvent to develop Polybenzoxazoles Stress buffer coat to Low dielectric Novel Not yet (photopatternable) prevent premature constants, and high polybenzoxazoles— demonstrated in device failure; high- thermal and suitable fluorine-free fluorine-free temperature stability thermooxidative alternatives have not materials and good insulating stability; processed demonstrated equal characteristics using positive resist performance developer Nanoimprint Excellent release Fluoropolymers/low Silicone-based Potentially good but Lithography characteristics; low surface adherence release agents not yet established fluoropolymers surface energy and fluoromonomers reported to dissolve trapped air making them ideal for filling the micromolds of nanoimprint lithography Nonionic Improve coat quality in Nonionic fluorinated For a number of Not yet fluorinated thin lithographic films segments with water- applications, demonstrated in surfactants (e.g., photoresists and soluble units alternatives have not fluorine-free BARCs); compatibility demonstrated equal materials with photoresists and performance TARC/BARC structures; high efficiency of fluorinated surfactants requires very little additive and enables better performance Topcoat Provides barrier layer Largely fluorinated Lacking satisfactory Not yet (for 193-nm for 193-nm immersion acrylate/ options demonstrated in immersion photoresists applied on methacrylate/ fluorine-free photoresist) top of photoresist and styrene-based materials prevents leaching of copolymers, excellent photoactive barrier properties with components. Protects fluorinated the photoresist from components contact with immersion liquid (water) EBL (for 193-nm Forms a protective Largely acrylate/ Lacking satisfactory Not yet immersion surface layer for 193- methacrylate/ options demonstrated in photoresist) nm immersion styrene-based fluorine-free photoresists and copolymers, excellent materials prevents leaching of barrier properties with photoactive fluorinated components. components Incorporated as part of photoresist and segregates to film surface during the coating process. Protects the photoresist from contact with immersion liquid (water) Polyimides Required stress buffer Tetracarboxylic acid Novel polyimides— Not yet (photopatternable) coat between chip and anhydride derivatives suitable fluorine-free demonstrated in package to prevent and aromatic alternatives have not fluorine-free premature device diamines/solubility in demonstrated equal materials failure; especially good organic solvents, low performance electrical insulating dielectric constants, characteristics and high thermal and thermooxidative stability; requires negative tone solvent to develop Polybenzoxazoles Stress buffer coat to Low dielectric Novel Not yet (photopatternable) prevent premature constants, and high polybenzoxazoles— demonstrated in device failure; high- thermal and suitable fluorine-free fluorine-free temperature stability thermooxidative alternatives have not materials and good insulating stability; processed demonstrated equal characteristics using positive resist performance developer Nanoimprint Excellent release Fluoropolymers/low Silicone-based Potentially good but Lithography characteristics; low surface adherence release agents not yet established fluoropolymers surface energy and fluoromonomers reported to dissolve trapped air making them ideal for filling the micromolds of nanoimprint lithography Nonionic Improve coat quality in Nonionic fluorinated For a number of Not yet fluorinated thin lithographic films segments with water- applications, demonstrated in surfactants (e.g., photoresists and soluble units alternatives have not fluorine-free BARCs); compatibility demonstrated equal materials with photoresists and performance TARC/BARC structures; high efficiency of fluorinated surfactants requires very little additive and enables better performance J. Micro/Nanopattern. Mater. Metrol. 010901-19 Jan–Mar 2022 • Vol. 21(1) 408 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Acknowledgments The authors gratefully acknowledge the Semiconductor PAG Consortium for financial support in the preparation of this manuscript. In particular, we thank Brook Tvermoes (IBM) for very helpful input in the preparation of this manuscript. Each author contributed significantly to the writing of this manuscript. The basis of this manuscript was a report commissioned by the Semiconductor PAG Consortium. J. Micro/Nanopattern. Mater. 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Hanf, “Research on per- and polyfluoroalkyl substances (PFAS),” 2021, https://www.epa .gov/chemical-research/research-and-polyfluoroalkyl-substances-pfas 46. D. Sanders et al., “High contact angle fluorosulfonamide-based materials for immersion lithography,” Proc. SPIE 7639, 763925 (2010). 47. M. Khojasteh et al., “Building an immersion topcoat from the ground up: materials perspec- tive,” Proc. SPIE 6519, 651907 (2007). 48. D. P. Sanders, R. Sooriyakumaran, and R. A. DiPietro, “Hexafluoroalcohol-functionalized methacrylate monomers for lithographic/nanopatterning materials,” in Material Matters, K. Patel, Ed., IBM Almaden Research Center, San Jose, California (2011). 49. Q. Lin et al., “Resolution enhanced top antireflective coating materials for ArF immersion lithography [6153-74],” Proc. SPIE, 61531Z (2006). 50. D. Wang et al., “Novel embedded barrier layer materials for ArF non-topcoat immersion applications,” Proc. SPIE 7140, 71402I (2008). 51. J. Kaitz et al., “High contact angle embedded barrier layer materials for next-generation 193 immersion lithography,” Proc. SPIE 11612, 116120U (2021). 52. C. Neef et al., “New BARC materials for the 65-nm node in 193-nm lithography,” Proc. SPIE 5376, 684–688 (2004). 53. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” J. Micro/Nanolithogr., MEMS, MOEMS 12, 031114 (2013). 54. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” Proc. SPIE 7970, 79700T (2011). 55. M. Lin et al., “Role of surfactants in adhesion reduction for step and flash imprint lithog- raphy,” J. Micro/Nanolithogr., MEMS, MOEMS 7, 033005 (2008). 56. M. Zelsmann et al., “Degradation and surfactant-aided regeneration of fluorinated anti- sticking mold treatments in UV nanoimprint lithography,” Microelectron. Eng. 87, 1029–1032 (2010). 57. T. Sakanoue et al., “Fluorosurfactant-assisted photolithography for patterning of perfluor- opolymers and solution- processed organic semiconductors for printed displays,” Appl. Phys. Express 7, 101602 (2014). 58. S. Ito et al., “Investigation of fluorinated (Meth)Acrylate monomers and macromonomers suitable for a hydroxy- containing acrylate monomer in UV nanoimprinting,” Langmuir 30, 7127–7133 (2014). 59. K. Honda et al., “Room-temperature nanoimprint lithography for crystalline poly(fluor- oalkyl acrylate) thin films,” Soft Matter 6, 870–875 (2010). 60. M. Zelsmann et al., “Double-anchoring fluorinated molecules for antiadhesion mold treat- ment in UV nanoimprint lithography,” J. Vac. Sci. Technol., B: Microelectron. Nanometer Struct.–Process. Meas., Phenom. 27, 2873–2876 (2009). 61. L. J. Guo, “Nanoimprint lithography: methods and material requirements,” Adv. Mater. 19, 495–513 (2007). 62. K. H. Kucharzyk et al., “Novel treatment technologies for PFAS compounds: a critical review,” J. Environ. Manage. 204, 757–764 (2017). 63. Z. R. Hopkins et al., “Recently detected drinking water contaminants: GenX and other per- and polyfluoroalkyl ether acids,” J. AWWA 110, 13–28 (2018). 64. H. F. Schröder and R. J. W. Meesters, “Stability of fluorinated surfactants in advanced oxi- dation processes— a follow up of degradation products using flow injection– mass spec- trometry, liquid chromatography–mass spectrometry and liquid chromatography–multiple stage mass spectrometry,” J. Chromatogr. A 1082, 110–119 (2005). 65. A. J. R. Gillespie, “US EPA’s science-based approach to understanding and managing envi- ronmental risk from PFAS,” 2020, https://www.epa.gov/sites/production/files/2020-09/ documents/epa_pfas_rd_overview_complete_2020_0 9_25.pdf 66. A. Hanf, “Research on per- and polyfluoroalkyl substances (PFAS),” 2021, https://www.epa .gov/chemical-research/research-and-polyfluoroalkyl-substances-pfas Christopher K. Ober is the Francis Bard professor of materials engineering at Cornell University. He has pioneered new materials for photolithography and studies the biology- materials interface. He received his BSc degree in honors chemistry (Co-op) from the University of Waterloo, Ontario, Canada, in 1978 and his MS and PhD degrees in polymer sci- ence and engineering from the University of Massachusetts (Amherst) in 1982. From 1982 to J. Micro/Nanopattern. Mater. Metrol. 010901-22 Jan–Mar 2022 • Vol. 21(1) 411 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Christopher K. Ober is the Francis Bard professor of materials engineering at Cornell University. He has pioneered new materials for photolithography and studies the biology- materials interface. He received his BSc degree in honors chemistry (Co-op) from the University of Waterloo, Ontario, Canada, in 1978 and his MS and PhD degrees in polymer sci- ence and engineering from the University of Massachusetts (Amherst) in 1982. From 1982 to J. Micro/Nanopattern. Mater. Metrol. 010901-22 Jan–Mar 2022 • Vol. 21(1) 411 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . 1986, he was a senior member of the research staff at the Xerox Research Centre of Canada, where he worked on marking materials. He joined Cornell University in the Department of Materials Science and Engineering in 1986. Recently, he served as interim dean of the College of Engineering. Currently, he is a director of the Cornell Nanoscale Facility. From 2014 to 2021, he served on the executive committee (its governing group) of The International Union of Pure and Applied Chemistry (IUPAC). He is a fellow of the ACS (2009), APS (2014), and AAAS (2014). He is a SPIE Senior Member (2018). He received his ACS Award in applied polymer science in 2006, the Gutenberg Research Award in 2009, the Society of Polymer Science Japan (SPSJ) International Prize in 2013, and the Japan Photopolymer Science and Technology Outstanding Achievement Award in 2015. 1986, he was a senior member of the research staff at the Xerox Research Centre of Canada, where he worked on marking materials. He joined Cornell University in the Department of Materials Science and Engineering in 1986. Recently, he served as interim dean of the College of Engineering. Currently, he is a director of the Cornell Nanoscale Facility. From 2014 to 2021, he served on the executive committee (its governing group) of The International Union of Pure and Applied Chemistry (IUPAC). He is a fellow of the ACS (2009), APS (2014), and AAAS (2014). He is a SPIE Senior Member (2018). He received his ACS Award in applied polymer science in 2006, the Gutenberg Research Award in 2009, the Society of Polymer Science Japan (SPSJ) International Prize in 2013, and the Japan Photopolymer Science and Technology Outstanding Achievement Award in 2015. Florian Käfer received his PhD from the University of Bayreuth, Germany, in 2019. Throughout his PhD thesis he focused on the synthesis of new thermoresponsive polymers and their applications. Since 2018, he is a postdoctoral fellow in the Department of Materials Science and Engineering at Cornell University, supervised by professor Christopher Ober. Thereby, he is focused on the synthesis of polymer-grafted nanoparticles as well as the design and synthesis of sequence-controlled small molecules as future photoresist materials for extreme ultraviolet (EUV) photolithography. Jingyuan Deng graduated from Nagoya University in 2016 with a BEng in applied chemistry and the University of Tokyo in 2018 with an MEng in chemistry and biotechnology. He is cur- rently pursuing his PhD in materials chemistry under the supervision of professor Christopher Ober at Cornell University. His current research focuses on the development of novel photoresist materials for EUV lithography. Florian Käfer received his PhD from the University of Bayreuth, Germany, in 2019. Throughout his PhD thesis he focused on the synthesis of new thermoresponsive polymers and their applications. Since 2018, he is a postdoctoral fellow in the Department of Materials Science and Engineering at Cornell University, supervised by professor Christopher Ober. Thereby, he is focused on the synthesis of polymer-grafted nanoparticles as well as the design and synthesis of sequence-controlled small molecules as future photoresist materials for extreme ultraviolet (EUV) photolithography. Jingyuan Deng graduated from Nagoya University in 2016 with a BEng in applied chemistry and the University of Tokyo in 2018 with an MEng in chemistry and biotechnology. He is cur- rently pursuing his PhD in materials chemistry under the supervision of professor Christopher Ober at Cornell University. His current research focuses on the development of novel photoresist materials for EUV lithography. J. Micro/Nanopattern. Mater. Metrol. 010901-23 Jan–Mar 2022 • Vol. 21(1) 412 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use 413 414 415 Volcko, Mary E. From: ED-Micron Sent: Tuesday, October 31, 2023 10:54 PM To: outreach@micronnewyork.com; Volcko, Mary E. Subject: FW: Micron DEIS Scoping Comments Attachments: Micron DEIS Scoping Comments by greeningusa et al_dba cny sustainability coalition.pdf; A.1 More Domestic Chip-Perfluoro cmpds-Forbes_Oct2023.pdf; A.2 CPEO Comments Micron SEQRA Scoping.pdf; A.3 Review of Essential use of fluorochemicals.pdf; A.4 Micron 2023 Sustainability Report,pp1-4.pdf Importance: High !-- Similar name as someone you've contacted. No employee in your company has ever replied to this person. Mark as Safe | Report Malicious or Mark Safe (click once) | Powered by Mimecast J. Micro/Nanopattern. Mater. Metrol. 010901-23 Jan–Mar 2022 • Vol. 21(1) 412 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use 413 414 415 Volcko, Mary E. From: ED-Micron Sent: Tuesday, October 31, 2023 10:54 PM To: outreach@micronnewyork.com; Volcko, Mary E. Subject: FW: Micron DEIS Scoping Comments Attachments: Micron DEIS Scoping Comments by greeningusa et al_dba cny sustainability coalition.pdf; A.1 More Domestic Chip-Perfluoro cmpds-Forbes_Oct2023.pdf; A.2 CPEO Comments Micron SEQRA Scoping.pdf; A.3 Review of Essential use of fluorochemicals.pdf; A.4 Micron 2023 Sustainability Report,pp1-4.pdf Importance: High !-- Similar name as someone you've contacted. No employee in your company has ever replied to this person. Mark as Safe | Report Malicious or Mark Safe (click once) | Powered by Mimecast From: Don Hughes Sent: Wednesday, November 1, 2023 3:03:40 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Fwd: Micron DEIS Scoping Comments NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: Onondaga County Industrial Development Agency ATTN: Micron Project 335 Montgomery Street, 2nd Floor Syracuse, New York 13202 From: Donald Hughes, Conservation Chair, Central & Northern New York Sierra Club Group Re: Draft Scoping Document for the proposed Micron Semiconductor Fabrication facility in Clay, NY I wish to submit, on behalf of the approximately 3000 members of Sierra Club who reside in our territory, the attached comments. You should have received the same documents from John Przepiora earlier today. Would you kindly confirm receipt of these comments with four supporting attachments? thank you, DH Donald J. Hughes, P.E., Ph.D. dhughes171@gmail.com 315.214.4060 ============================= Hughes Environmental Consulting 1 416 From: Don Hughes Sent: Wednesday, November 1, 2023 3:03:40 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Fwd: Micron DEIS Scoping Comments NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To: Onondaga County Industrial Development Agency ATTN: Micron Project 335 Montgomery Street, 2nd Floor Syracuse, New York 13202 From: Donald Hughes, Conservation Chair, Central & Northern New York Sierra Club Group Re: Draft Scoping Document for the proposed Micron Semiconductor Fabrication facility in Clay, NY I wish to submit, on behalf of the approximately 3000 members of Sierra Club who reside in our territory, the attached comments. You should have received the same documents from John Przepiora earlier today. Would you kindly confirm receipt of these comments with four supporting attachments? thank you, DH Donald J. Hughes, P.E., Ph.D. dhughes171@gmail.com 315.214.4060 ============================= Hughes Environmental Consulting 1 416 157 Strong Ave, Syracuse, NY 13210 ============================= "dans les champs de l'observation, le hasard ne favorise que les esprits préparés" ("In the field of observation, chance favors only the prepared mind") Louis Pasteur, French chemist and microbiologist (1822 -1895) To: OCIDA On behalf of the following individuals and myself working together as the CNY Sustainability Coalition, and who have signed the attached memorandum on behalf of our respective organizations, I am submitting the attached comments and supporting 4 attachments (A1-A4) pursuant to the public comment period for the Micron project SEQRA DEIS scoping. Please do not hesitate to contact me if you have any questions. Thank you for the opportunity to comment on this important document and for allowing an extension of time for filing this. Donald Hughes Conservation Chair, Sierra Club Central & Northern NY Group Syracuse, NY dhughes171@gmail.com Peter Wirth Vice President, Climate Change Action and Awareness Fayetteville, NY pwirth2@verizon.net John Przepiora Vice President, GreeningUSA, Inc. Syracuse, NY info@greeningusa.org Dick Kornbluth 2 417 Climate Justice Committee CNY Solidarity Coalition Onondaga County, NY cnysolidarity@gmail.com Tylah Worrell Exec. Director, Urban Jobs Task Force of Syracuse Syracuse, NY t.worrell@ujtfs.org 157 Strong Ave, Syracuse, NY 13210 ============================= "dans les champs de l'observation, le hasard ne favorise que les esprits préparés" ("In the field of observation, chance favors only the prepared mind") Louis Pasteur, French chemist and microbiologist (1822 -1895) To: OCIDA On behalf of the following individuals and myself working together as the CNY Sustainability Coalition, and who have signed the attached memorandum on behalf of our respective organizations, I am submitting the attached comments and supporting 4 attachments (A1-A4) pursuant to the public comment period for the Micron project SEQRA DEIS scoping. Please do not hesitate to contact me if you have any questions. Thank you for the opportunity to comment on this important document and for allowing an extension of time for filing this. Donald Hughes Conservation Chair, Sierra Club Central & Northern NY Group Syracuse, NY dhughes171@gmail.com Peter Wirth Vice President, Climate Change Action and Awareness Fayetteville, NY pwirth2@verizon.net John Przepiora Vice President, GreeningUSA, Inc. Syracuse, NY info@greeningusa.org Dick Kornbluth 2 417 Climate Justice Committee CNY Solidarity Coalition Onondaga County, NY cnysolidarity@gmail.com Tylah Worrell Exec. Director, Urban Jobs Task Force of Syracuse Syracuse, NY t.worrell@ujtfs.org Thank you again. We look forward to working with you as this project moves forward. John Przepiora Vice-President & Director GreeningUSA, Inc. (315) 382-3829 …Advocating for sustainable communities to the benefit of local economies and environments. 3 418 ‭To: Onondaga County Industrial Development Agency (OCIDA)‬ ‭ rom: The undersigned individuals and representatives of environmental and sustainability‬ F ‭organizations of Central New York, aka, “CNY Sustainability Coalition”‬ ‭ E: Comments on the‬‭DRAFT SEQRA SCOPE OF WORK (‬‭draft‬‭Scoping Document or draft‬ R ‭scope‬‭),‬‭dated‬‭September 12, 2023‬‭for the proposed‬‭MICRON SEMICONDUCTOR‬ ‭FABRICATION plant in‬‭Clay, NY.‬ ‭----------------------------------------------------------------------------------------------------------------‬ ‭ he SEQR Handbook, 4th Edition, dated 2020, states: “A written scope of issues developed‬ T ‭through a public scoping process benefits the lead agency and the sponsor by providing explicit‬ ‭guidance as to what criteria will be used to determine whether a submitted draft EIS is adequate.‬ ‭The written scope provides a means of ensuring that significant topics have not been missed and‬ ‭that the level of analysis in the EIS satisfies standards established during the scoping process.”‬ Thank you again. We look forward to working with you as this project moves forward. John Przepiora Vice-President & Director GreeningUSA, Inc. (315) 382-3829 …Advocating for sustainable communities to the benefit of local economies and environments. 3 418 ‭To: Onondaga County Industrial Development Agency (OCIDA)‬ ‭ rom: The undersigned individuals and representatives of environmental and sustainability‬ F ‭organizations of Central New York, aka, “CNY Sustainability Coalition”‬ ‭ E: Comments on the‬‭DRAFT SEQRA SCOPE OF WORK (‬‭draft‬‭Scoping Document or draft‬ R ‭scope‬‭),‬‭dated‬‭September 12, 2023‬‭for the proposed‬‭MICRON SEMICONDUCTOR‬ ‭FABRICATION plant in‬‭Clay, NY.‬ ‭----------------------------------------------------------------------------------------------------------------‬ ‭ he SEQR Handbook, 4th Edition, dated 2020, states: “A written scope of issues developed‬ T ‭through a public scoping process benefits the lead agency and the sponsor by providing explicit‬ ‭guidance as to what criteria will be used to determine whether a submitted draft EIS is adequate.‬ ‭The written scope provides a means of ensuring that significant topics have not been missed and‬ ‭that the level of analysis in the EIS satisfies standards established during the scoping process.”‬ ‭ hile the draft Scoping Document offers a reasonable approach to defining significant‬ W ‭environmental impacts in certain areas, we believe it is inadequate in other areas, especially‬ ‭ith respect to chemicals and energy usage. We offer the following comments:"‬ ‭4.3 ALTERNATIVES TO BE ANALYZED IN THE DEIS‬ ‭ he SEQR Handbook stipulates (p 100) the scoping process should “Define reasonable‬ T ‭alternatives for avoiding specific impacts which must be included in the EIS, either as individual‬ ‭scenarios or a range of alternatives.”‬ ‭Two “build” alternatives are presented in the draft scope:‬ 1‭ )‬ ‭Full construction and operation of four fabs over an approximately 20-year period‬ ‭2)‬ ‭Reduced Scale: construction and operation of two fabs over a shorter period.‬ ‭ hile the draft Scoping Document offers a reasonable approach to defining significant‬ W ‭environmental impacts in certain areas, we believe it is inadequate in other areas, especially‬ ‭ith respect to chemicals and energy usage. We offer the following comments:"‬ ‭4.3 ALTERNATIVES TO BE ANALYZED IN THE DEIS‬ ‭ he SEQR Handbook stipulates (p 100) the scoping process should “Define reasonable‬ T ‭alternatives for avoiding specific impacts which must be included in the EIS, either as individual‬ ‭scenarios or a range of alternatives.”‬ ‭Two “build” alternatives are presented in the draft scope:‬ 1‭ )‬ ‭Full construction and operation of four fabs over an approximately 20-year period‬ ‭2)‬ ‭Reduced Scale: construction and operation of two fabs over a shorter period.‬ ‭ his analysis is too limited. It does not address a proper range of alternatives. For example, the‬ T ‭impacts on Greenhouse Gas Emissions and Climate Change will vary tremendously depending‬ ‭on the amount of renewable energy that Micron is able to procure. Micron has expressed a desire‬ ‭to achieve 100% renewable energy for electricity, but that may be unrealistic for the construction‬ ‭timeframes that are envisioned. Micron’s electricity demands are projected to be very large (7.15‬ ‭billion kWh/year for Phase 1; 16.17 billion kWh/year for Phase 2), so it would be far more‬ ‭realistic to evaluate a range of alternatives which take into account the time needed to construct a‬ ‭supply of renewable energy sources (wind, solar, and hydropower). The evaluation must assess‬ ‭the feasibility of achieving 100% of electricity from renewable sources for each Phase of the‬ ‭project.‬ I‭ t has been estimated (Plumley, pers. communication) that it would take 1200 3MW wind‬ ‭turbines to generate the power needed for Phase 2.‬ I‭ t would also be useful to consider alternatives with different phasing such as construction of a‬ ‭single fab followed by a reassessment of impacts prior to construction of a second fab. In a‬ ‭1‬‭|‬‭Page‬ 419 ‭ his analysis is too limited. It does not address a proper range of alternatives. For example, the‬ T ‭impacts on Greenhouse Gas Emissions and Climate Change will vary tremendously depending‬ ‭on the amount of renewable energy that Micron is able to procure. Micron has expressed a desire‬ ‭to achieve 100% renewable energy for electricity, but that may be unrealistic for the construction‬ ‭timeframes that are envisioned. Micron’s electricity demands are projected to be very large (7.15‬ ‭billion kWh/year for Phase 1; 16.17 billion kWh/year for Phase 2), so it would be far more‬ ‭realistic to evaluate a range of alternatives which take into account the time needed to construct a‬ ‭supply of renewable energy sources (wind, solar, and hydropower). The evaluation must assess‬ ‭the feasibility of achieving 100% of electricity from renewable sources for each Phase of the‬ ‭project.‬ I‭ t has been estimated (Plumley, pers. communication) that it would take 1200 3MW wind‬ ‭turbines to generate the power needed for Phase 2.‬ I‭ t would also be useful to consider alternatives with different phasing such as construction of a‬ ‭single fab followed by a reassessment of impacts prior to construction of a second fab. In a‬ ‭1‬‭|‬‭Page‬ 419 ‭ ulti-phase approach, lengthening the time frame may be an appropriate way to manage the‬ m ‭community impacts while allowing for the potential for technological changes that may affect‬ ‭chip fabrication or building and/or transportation improvements which may reduce impacts. A‬ ‭long term approach may allow the community to adjust to the growth and assimilate it with less‬ ‭adversity.‬ 5‭ ANALYSIS FRAMEWORK‬ ‭Preparation of the DEIS must conform to 6 NYCRR Part 617.9(b). The DEC’s SEQR Handbook‬ ‭asserts that “An Environmental Impact Statement (EIS) is a document that impartially analyzes‬ ‭the full range of potential significant adverse environmental impacts of a proposed action and‬ ‭how those impacts can be avoided or minimized.”‬ ‭ ection 5.1 of the draft scope states: “The Proposed Project will be evaluated for potential‬ S ‭significant adverse effects to the Project Site and‬‭applicable study areas‬‭for all relevant‬ ‭environmental technical categories in accordance with applicable SEQRA requirements.”‬ ‭ ulti-phase approach, lengthening the time frame may be an appropriate way to manage the‬ m ‭community impacts while allowing for the potential for technological changes that may affect‬ ‭chip fabrication or building and/or transportation improvements which may reduce impacts. A‬ ‭long term approach may allow the community to adjust to the growth and assimilate it with less‬ ‭adversity.‬ 5‭ ANALYSIS FRAMEWORK‬ ‭Preparation of the DEIS must conform to 6 NYCRR Part 617.9(b). The DEC’s SEQR Handbook‬ ‭asserts that “An Environmental Impact Statement (EIS) is a document that impartially analyzes‬ ‭the full range of potential significant adverse environmental impacts of a proposed action and‬ ‭how those impacts can be avoided or minimized.”‬ ‭ ection 5.1 of the draft scope states: “The Proposed Project will be evaluated for potential‬ S ‭significant adverse effects to the Project Site and‬‭applicable study areas‬‭for all relevant‬ ‭environmental technical categories in accordance with applicable SEQRA requirements.”‬ ‭‘Applicable study areas’ is a vague phrase which needs to be better defined specifically in an‬ o‭ verarching, comprehensive manner. Answers to questions are directly related to the question‬ ‭asked; asking the wrong question leads to wrong answers. We recognize that each of the‬ ‭sub-sections in 5.3.1 may define study area specific to the particular analysis and that may be‬ ‭appropriate, however, we believe that the final scope document should include a stand alone‬ ‭section devoted to defining the study area clearly in order to convey the breadth with which the‬ ‭impacts of this project will be manifest and establish the full areal extent of the analytical‬ ‭framework.‬ ‭‘Applicable study areas’ is a vague phrase which needs to be better defined specifically in an‬ o‭ verarching, comprehensive manner. Answers to questions are directly related to the question‬ ‭asked; asking the wrong question leads to wrong answers. We recognize that each of the‬ ‭sub-sections in 5.3.1 may define study area specific to the particular analysis and that may be‬ ‭appropriate, however, we believe that the final scope document should include a stand alone‬ ‭section devoted to defining the study area clearly in order to convey the breadth with which the‬ ‭impacts of this project will be manifest and establish the full areal extent of the analytical‬ ‭framework.‬ ‭ his project requires an ecosystem approach that considers the regional impacts on the‬ T ‭environment, the economy and society. The impacts must be determined and assessed for their‬ ‭equitable distribution and for their adverse impacts that are detrimental to the region’s short and‬ ‭long term sustainability. This is not a typical project. It is enormous in scale, unprecedented for‬ ‭the region and with potential for egregious environmental impacts. It has been suggested by‬ ‭Onondaga county officials that the Onondaga County population may increase by 25% or‬ ‭125,000 over the full build-out period (estimates of regional growth are unknown to this‬ ‭reviewer). The scale of the environmental review process, and the expertise required to carry it‬ ‭out, must rival the project’s enormity.‬ ‭ CIDA must assure that the final scope for each of the technical sections of the DEIS is‬ O ‭specified with rigor, that the appropriate and necessary expertise is utilized in the writing of each‬ ‭scope item, that the study areas are broad enough and that each analysis is based on not only the‬ ‭current standards, but also reasonably presumed standards that will be in force throughout the‬ ‭build out and operational period of the proposed project.‬ ‭ his project requires an ecosystem approach that considers the regional impacts on the‬ T ‭environment, the economy and society. The impacts must be determined and assessed for their‬ ‭equitable distribution and for their adverse impacts that are detrimental to the region’s short and‬ ‭long term sustainability. This is not a typical project. It is enormous in scale, unprecedented for‬ ‭the region and with potential for egregious environmental impacts. It has been suggested by‬ ‭Onondaga county officials that the Onondaga County population may increase by 25% or‬ ‭125,000 over the full build-out period (estimates of regional growth are unknown to this‬ ‭reviewer). The scale of the environmental review process, and the expertise required to carry it‬ ‭out, must rival the project’s enormity.‬ ‭ CIDA must assure that the final scope for each of the technical sections of the DEIS is‬ O ‭specified with rigor, that the appropriate and necessary expertise is utilized in the writing of each‬ ‭scope item, that the study areas are broad enough and that each analysis is based on not only the‬ ‭current standards, but also reasonably presumed standards that will be in force throughout the‬ ‭build out and operational period of the proposed project.‬ ‭ inally, The SEQR Handbook requires the following in the scoping of the identified reasonably‬ F ‭expected impacts:‬ ‭•‬ ‭Describe the extent and quality of information needed;‬ ‭•‬ ‭List available sources of information;‬ ‭•‬ ‭Specify study methods or models to be used to generate new information, including‬ ‭criteria or assumptions underlying any models, and define nature and presentation of the data to‬ ‭be generated by those studies and models.‬ ‭2‬‭|‬‭Page‬ 420 I‭ n many of the areas included in section 5.3 the standards for information and methods appear to‬ ‭be inadequate. The scoping document must require high standards be applied to the analysis and‬ ‭specify information and methods to be utilized. To do less shortchanges the community and can‬ ‭lead to disastrous and unanticipated consequences.‬ ‭ he biggest challenge presented by this project is the enormity of it; in order to fulfill the dreams‬ T ‭which this project offers in a just, equitable, economically and environmentally sustainable‬ ‭manner, the review process must be equally enormous, impartial and thorough.‬ ‭5.3‬‭METHODOLOGIES FOR TECHNICAL ANALYSES‬ ‭Comments on specific sections are listed below.‬ ‭ inally, The SEQR Handbook requires the following in the scoping of the identified reasonably‬ F ‭expected impacts:‬ ‭•‬ ‭Describe the extent and quality of information needed;‬ ‭•‬ ‭List available sources of information;‬ ‭•‬ ‭Specify study methods or models to be used to generate new information, including‬ ‭criteria or assumptions underlying any models, and define nature and presentation of the data to‬ ‭be generated by those studies and models.‬ ‭2‬‭|‬‭Page‬ 420 I‭ n many of the areas included in section 5.3 the standards for information and methods appear to‬ ‭be inadequate. The scoping document must require high standards be applied to the analysis and‬ ‭specify information and methods to be utilized. To do less shortchanges the community and can‬ ‭lead to disastrous and unanticipated consequences.‬ ‭ he biggest challenge presented by this project is the enormity of it; in order to fulfill the dreams‬ T ‭which this project offers in a just, equitable, economically and environmentally sustainable‬ ‭manner, the review process must be equally enormous, impartial and thorough.‬ ‭5.3‬‭METHODOLOGIES FOR TECHNICAL ANALYSES‬ ‭Comments on specific sections are listed below.‬ ‭ any of the methodologies outlined in Chapter 5, Analysis Framework, are very‬ M ‭comprehensive and appropriate for a project of this size. We fully support the inclusion of‬ ‭each of these categories. However, we have noted certain areas where the level of detail‬ ‭and intent seems inadequate as follows.‬ ‭5.3.1 TECHNICAL STUDIES‬ ‭●‬ ‭LAND USE, ZONING, AND PUBLIC POLICY‬ ‭ OMMENT: Why isn’t the city of Syracuse explicitly included here? Seems to be a‬ C ‭major omission.‬ ‭●‬ ‭COMMUNITY FACILITIES/OPEN SPACE AND RECREATION‬ ‭ OMMENT: Here is an assessment of impacts on community emergency services, fire‬ C ‭safety requirements included in building code and site access requirements of the‬ ‭emergency service providers.‬ ‭ umped in is assessment of growth impacts on educational facilities and parks and‬ L ‭recreational facilities. The study area seems ill defined and critical to this analysis. Some‬ ‭reference to Towns of Clay and Cicero seems to limit the study area to these two towns;‬ ‭is that what is intended? If so, it is probably too narrow an area particularly when the‬ ‭cumulative and indirect impacts are considered.‬ ‭ any of the methodologies outlined in Chapter 5, Analysis Framework, are very‬ M ‭comprehensive and appropriate for a project of this size. We fully support the inclusion of‬ ‭each of these categories. However, we have noted certain areas where the level of detail‬ ‭and intent seems inadequate as follows.‬ ‭5.3.1 TECHNICAL STUDIES‬ ‭●‬ ‭LAND USE, ZONING, AND PUBLIC POLICY‬ ‭ OMMENT: Why isn’t the city of Syracuse explicitly included here? Seems to be a‬ C ‭major omission.‬ ‭●‬ ‭COMMUNITY FACILITIES/OPEN SPACE AND RECREATION‬ ‭ OMMENT: Here is an assessment of impacts on community emergency services, fire‬ C ‭safety requirements included in building code and site access requirements of the‬ ‭emergency service providers.‬ ‭ umped in is assessment of growth impacts on educational facilities and parks and‬ L ‭recreational facilities. The study area seems ill defined and critical to this analysis. Some‬ ‭reference to Towns of Clay and Cicero seems to limit the study area to these two towns;‬ ‭is that what is intended? If so, it is probably too narrow an area particularly when the‬ ‭cumulative and indirect impacts are considered.‬ ‭ his section is poorly organized and deserves to be rewritten to define more clearly what‬ T ‭are the parameters to be studied and analyzed relevant to police, fire and other emergency‬ ‭services; schools; parks and rec facilities. Absent from the community facilities most‬ ‭notably is the health care and hospital system.‬ ‭●‬ ‭SOCIO-ECONOMIC CONDITIONS‬ ‭ OMMENT: The study area is defined better here and seems appropriate. It is necessary‬ C ‭to assess the way benefits and adverse impacts are distributed. There is no specified time‬ ‭horizon for this analysis and little specificity regarding the analytical standards, tools and‬ ‭techniques that will be employed. If OCIDA is ill equipped to specify generally accepted‬ ‭standards for such an analysis it is incumbent tha OCIDA obtain the expertise required to‬ ‭specify how this must be done.‬ ‭3‬‭|‬‭Page‬ 421 ‭●‬ ‭VISUAL IMPACTS AND COMMUNITY CHARACTER‬ ‭ his section is poorly organized and deserves to be rewritten to define more clearly what‬ T ‭are the parameters to be studied and analyzed relevant to police, fire and other emergency‬ ‭services; schools; parks and rec facilities. Absent from the community facilities most‬ ‭notably is the health care and hospital system.‬ ‭●‬ ‭SOCIO-ECONOMIC CONDITIONS‬ ‭ OMMENT: The study area is defined better here and seems appropriate. It is necessary‬ C ‭to assess the way benefits and adverse impacts are distributed. There is no specified time‬ ‭horizon for this analysis and little specificity regarding the analytical standards, tools and‬ ‭techniques that will be employed. If OCIDA is ill equipped to specify generally accepted‬ ‭standards for such an analysis it is incumbent tha OCIDA obtain the expertise required to‬ ‭specify how this must be done.‬ ‭3‬‭|‬‭Page‬ 421 ‭●‬ ‭VISUAL IMPACTS AND COMMUNITY CHARACTER‬ ‭ OMMENT: This project has the potential to significantly alter the character of the‬ C ‭community—not only the locale surrounding the immediate project location, but the‬ ‭wider Syracuse and Onondaga County as well as portions of Oswego County as‬ ‭population growth and housing development is induced. The DEIS should include an‬ ‭analysis of the potential for growth-induced changes in the community that this project‬ ‭will induce.‬ ‭●‬ ‭GEOLOGY, SOILS, AND TOPOGRAPHY‬ ‭ OMMENT: Reference is made to ‘property survey’ as a data source but later the‬ C ‭‘geotechnical investigation’ is mentioned but not included in the sentence describing the‬ ‭analysis. Is this an oversight that should be corrected? Certainly the geotechnical survey‬ ‭will provide valuable information to confirm or modify the USGS soil survey data.‬ ‭●‬ ‭NATURAL RESOURCES‬ ‭ OMMENT: This seems to prioritize wildlife and overlook the categorization of existing‬ C ‭vegetation. Is that what is intended? The EAF mentioned the undertaking of detailed field‬ ‭studies of land coverage and natural resource conditions on or near the Micron Campus.‬ ‭Will a detailed land cover field study be done? It should be included.‬ ‭ OMMENT: This project has the potential to significantly alter the character of the‬ C ‭community—not only the locale surrounding the immediate project location, but the‬ ‭wider Syracuse and Onondaga County as well as portions of Oswego County as‬ ‭population growth and housing development is induced. The DEIS should include an‬ ‭analysis of the potential for growth-induced changes in the community that this project‬ ‭will induce.‬ ‭●‬ ‭GEOLOGY, SOILS, AND TOPOGRAPHY‬ ‭ OMMENT: Reference is made to ‘property survey’ as a data source but later the‬ C ‭‘geotechnical investigation’ is mentioned but not included in the sentence describing the‬ ‭analysis. Is this an oversight that should be corrected? Certainly the geotechnical survey‬ ‭will provide valuable information to confirm or modify the USGS soil survey data.‬ ‭●‬ ‭NATURAL RESOURCES‬ ‭ OMMENT: This seems to prioritize wildlife and overlook the categorization of existing‬ C ‭vegetation. Is that what is intended? The EAF mentioned the undertaking of detailed field‬ ‭studies of land coverage and natural resource conditions on or near the Micron Campus.‬ ‭Will a detailed land cover field study be done? It should be included.‬ ‭ ittle detail is included about the hydrology and wetlands evaluations that will be‬ L ‭necessary. Standards, tools and analytical techniques required to be employed must be‬ ‭specified. If OCIDA lacks the expertise to properly specify this analysis they must obtain‬ ‭that expertise from involved agencies or consultants that can properly specify the scope‬ ‭and requirements of this work.‬ ‭●‬ ‭SOLID WASTE & HAZARDOUS MATERIALS‬ “‭ This analysis will describe the proposed generation of solid waste by the Proposed‬ ‭Project and how that material will be handled, stored, and transported. This analysis will‬ ‭describe Micron’s proposed measures to reduce generation of solid waste through reuse‬ ‭or recycling.”‬ ‭ ittle detail is included about the hydrology and wetlands evaluations that will be‬ L ‭necessary. Standards, tools and analytical techniques required to be employed must be‬ ‭specified. If OCIDA lacks the expertise to properly specify this analysis they must obtain‬ ‭that expertise from involved agencies or consultants that can properly specify the scope‬ ‭and requirements of this work.‬ ‭●‬ ‭SOLID WASTE & HAZARDOUS MATERIALS‬ “‭ This analysis will describe the proposed generation of solid waste by the Proposed‬ ‭Project and how that material will be handled, stored, and transported. This analysis will‬ ‭describe Micron’s proposed measures to reduce generation of solid waste through reuse‬ ‭or recycling.”‬ ‭ OMMENT: It is appropriate for Micron to identify the quantities and types of solid‬ C ‭waste that are likely to be generated at their facilities. The applicant estimates the‬ ‭generation of 45,000 tons per year of solid waste, which represents an additional 15% of‬ ‭waste generated in Onondaga County. All solid waste in Onondaga County is burned in‬ ‭an incinerator. What impacts will the solid wastes disposed of through the OCRRA‬ ‭system have on air quality? The fiscal implications for the OCRRA must also be‬ ‭assessed. The indirect, long term and cumulative impacts of the use and disposal of both‬ ‭solid and hazardous waste materials must be included in the analysis.‬ ‭ he applicant is proposing to take measures to reduce the generation of solid waste. What‬ T ‭is under consideration?‬ ‭Strangely, the same level of investigation is not described for hazardous wastes, which‬ ‭constitute a far greater threat to employees, the community, and the environment.‬ ‭4‬‭|‬‭Page‬ 422 ‭ OMMENT: It is appropriate for Micron to identify the quantities and types of solid‬ C ‭waste that are likely to be generated at their facilities. The applicant estimates the‬ ‭generation of 45,000 tons per year of solid waste, which represents an additional 15% of‬ ‭waste generated in Onondaga County. All solid waste in Onondaga County is burned in‬ ‭an incinerator. What impacts will the solid wastes disposed of through the OCRRA‬ ‭system have on air quality? The fiscal implications for the OCRRA must also be‬ ‭assessed. The indirect, long term and cumulative impacts of the use and disposal of both‬ ‭solid and hazardous waste materials must be included in the analysis.‬ ‭ he applicant is proposing to take measures to reduce the generation of solid waste. What‬ T ‭is under consideration?‬ ‭Strangely, the same level of investigation is not described for hazardous wastes, which‬ ‭constitute a far greater threat to employees, the community, and the environment.‬ ‭4‬‭|‬‭Page‬ 422 ‭ he text reads that the DEIS “will identify any hazardous materials (including any‬ T ‭chemical or petroleum bulk storage) that would be used, stored, transported, or generated‬ ‭by the Proposed Project and measures to protect against releases to the environment.”‬ I‭ t is imperative that the DEIS identify ways to reduce and eliminate the generation of‬ ‭hazardous waste through reuse and recycling. Hazardous waste is best eliminated by‬ ‭using non-hazardous substances in the fabrication process. In the event that hazardous‬ ‭substances must be used in the fabrication process, methods to completely contain those‬ ‭substances, and/or ultimately destroy them, must be considered.‬ ‭Of particular concern are perfluorinated alkyl substances (PFAS), otherwise known as‬ “‭ forever” chemicals because of their long lifetimes in the environment and in organisms.‬ ‭These chemicals are of great concern due to their high levels of toxicity. The‬ ‭semiconductor industry uses PFAS extensively (Forbes magazine, Oct. 5 , 2023;‬ ‭https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-mean‬ ‭s-more-forever-chemicals/?sh=2d10b08c7821‬‭P‬‭) The DEIS must address the use of these‬ ‭chemicals and alternative chemicals that could be used as substitutes.‬ ‭ he text reads that the DEIS “will identify any hazardous materials (including any‬ T ‭chemical or petroleum bulk storage) that would be used, stored, transported, or generated‬ ‭by the Proposed Project and measures to protect against releases to the environment.”‬ I‭ t is imperative that the DEIS identify ways to reduce and eliminate the generation of‬ ‭hazardous waste through reuse and recycling. Hazardous waste is best eliminated by‬ ‭using non-hazardous substances in the fabrication process. In the event that hazardous‬ ‭substances must be used in the fabrication process, methods to completely contain those‬ ‭substances, and/or ultimately destroy them, must be considered.‬ ‭Of particular concern are perfluorinated alkyl substances (PFAS), otherwise known as‬ “‭ forever” chemicals because of their long lifetimes in the environment and in organisms.‬ ‭These chemicals are of great concern due to their high levels of toxicity. The‬ ‭semiconductor industry uses PFAS extensively (Forbes magazine, Oct. 5 , 2023;‬ ‭https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-mean‬ ‭s-more-forever-chemicals/?sh=2d10b08c7821‬‭P‬‭) The DEIS must address the use of these‬ ‭chemicals and alternative chemicals that could be used as substitutes.‬ ‭ he attached memorandum from Lenny Siegel, Center for Public Environmental‬ T ‭Oversight, provides additional details regarding the problems posed by PFAS and other‬ ‭hazardous chemicals. The authors of a recent paper on use of PFAS in the semiconductor‬ ‭industry note that: “ the strength of the C─F bond creates materials with unique and‬ ‭technologically useful properties in semiconductor processing. That same bond strength‬ ‭also results in‬‭strong resistance toward physical,‬‭chemical, and biological degradation‬‭.‬ ‭Due to this strong resistance to degradation, PFAS compounds in general‬‭are extremely‬ ‭stable in the environment.‬‭In addition, such compounds‬‭have been found to be‬ ‭bioaccumulative. Extensive literature exists describing the detection of a number of PFAS‬ ‭compounds in drinking water.” (emphasis added) The authors also note “there is a strong‬ ‭societal interest in eliminating their use, and “essential use” is a stopgap situation in‬ ‭which replacements are actively sought.”‬ ‭https://www.spiedigitallibrary.org/journals/journal-of-micro-nanopatterning-materials-an‬ ‭d-metrology/volume-21/issue-01/010901/Review-of-essential-use-of-fluorochemicals-in-‬ ‭lithographic-patterning-and/10.1117/1.JMM.21.1.010901.full?SSO=1‬ ‭ he attached memorandum from Lenny Siegel, Center for Public Environmental‬ T ‭Oversight, provides additional details regarding the problems posed by PFAS and other‬ ‭hazardous chemicals. The authors of a recent paper on use of PFAS in the semiconductor‬ ‭industry note that: “ the strength of the C─F bond creates materials with unique and‬ ‭technologically useful properties in semiconductor processing. That same bond strength‬ ‭also results in‬‭strong resistance toward physical,‬‭chemical, and biological degradation‬‭.‬ ‭Due to this strong resistance to degradation, PFAS compounds in general‬‭are extremely‬ ‭stable in the environment.‬‭In addition, such compounds‬‭have been found to be‬ ‭bioaccumulative. Extensive literature exists describing the detection of a number of PFAS‬ ‭compounds in drinking water.” (emphasis added) The authors also note “there is a strong‬ ‭societal interest in eliminating their use, and “essential use” is a stopgap situation in‬ ‭which replacements are actively sought.”‬ ‭https://www.spiedigitallibrary.org/journals/journal-of-micro-nanopatterning-materials-an‬ ‭d-metrology/volume-21/issue-01/010901/Review-of-essential-use-of-fluorochemicals-in-‬ ‭lithographic-patterning-and/10.1117/1.JMM.21.1.010901.full?SSO=1‬ ‭ nhesa (formerly Chemical Watch) is an industry trade organization that provides‬ E ‭regulatory guidance to industry. They note that: “‬‭The‬‭use of PFAS is a major focus for‬ ‭regulatory authorities worldwide right now. In Europe, the REACH restriction proposal‬ ‭aims to place limits on all uses of more than 10,000 per- and polyfluoroalkyl substances.‬ ‭Meanwhile, in the US, restrictions are high on the agenda in several states.‬ I‭ n late September 2023 the European Parliament voted overwhelmingly in support of a‬ ‭parliamentary report backing the first revision of the Urban Wastewater Treatment‬ ‭Directive (UWWTD) in 30 years. The revision proposal would introduce new limit‬ ‭values and treatment requirements for‬‭micropollutants‬‭in wastewater, including per- and‬ ‭polyfluoroalkyl substances (‬‭PFASs)‬‭and microplastics.‬ ‭5‬‭|‬‭Page‬ 423 ‭ nhesa (formerly Chemical Watch) is an industry trade organization that provides‬ E ‭regulatory guidance to industry. They note that: “‬‭The‬‭use of PFAS is a major focus for‬ ‭regulatory authorities worldwide right now. In Europe, the REACH restriction proposal‬ ‭aims to place limits on all uses of more than 10,000 per- and polyfluoroalkyl substances.‬ ‭Meanwhile, in the US, restrictions are high on the agenda in several states.‬ I‭ n late September 2023 the European Parliament voted overwhelmingly in support of a‬ ‭parliamentary report backing the first revision of the Urban Wastewater Treatment‬ ‭Directive (UWWTD) in 30 years. The revision proposal would introduce new limit‬ ‭values and treatment requirements for‬‭micropollutants‬‭in wastewater, including per- and‬ ‭polyfluoroalkyl substances (‬‭PFASs)‬‭and microplastics.‬ ‭5‬‭|‬‭Page‬ 423 ‭ he hazardous materials component is a significant component of the EIS. It deserves its‬ T ‭own chapter. As written, there is no reference to worker safety; but of course OSHA rules‬ ‭apply as well as other laws when the use, storage and transport of Hazardous Materials‬ ‭(HazMat) is considered. The DEIS should be required to include information about this‬ ‭issue as 9,000 workers will potentially interact with these materials, and the community‬ ‭in general is potentially being put at risk. HazMat emergency response and potential risks‬ ‭to the community must also be fully considered and described. The DEIS must include a‬ ‭full disclosure of HazMat risks related to the manufacture of chips including supply‬ ‭chain, transport, storage, security, air quality, spill/release response and disposal. Cradle‬ ‭to grave analysis must be provided to decision makers being asked to permit this‬ ‭endeavor, as well as community members who are being asked to assume these risks.‬ ‭Additionally, we believe alternative production processes should be evaluated to‬ ‭determine whether the objective production can be realized without the utilization of‬ ‭hazardous materials.‬ ‭●‬ ‭TRANSPORTATION:‬ ‭ he hazardous materials component is a significant component of the EIS. It deserves its‬ T ‭own chapter. As written, there is no reference to worker safety; but of course OSHA rules‬ ‭apply as well as other laws when the use, storage and transport of Hazardous Materials‬ ‭(HazMat) is considered. The DEIS should be required to include information about this‬ ‭issue as 9,000 workers will potentially interact with these materials, and the community‬ ‭in general is potentially being put at risk. HazMat emergency response and potential risks‬ ‭to the community must also be fully considered and described. The DEIS must include a‬ ‭full disclosure of HazMat risks related to the manufacture of chips including supply‬ ‭chain, transport, storage, security, air quality, spill/release response and disposal. Cradle‬ ‭to grave analysis must be provided to decision makers being asked to permit this‬ ‭endeavor, as well as community members who are being asked to assume these risks.‬ ‭Additionally, we believe alternative production processes should be evaluated to‬ ‭determine whether the objective production can be realized without the utilization of‬ ‭hazardous materials.‬ ‭●‬ ‭TRANSPORTATION:‬ ‭ he only mitigation measures mentioned in this section are improvements to roadways. It‬ T ‭is imperative that the utilization of public transportation, including mass transit by bus‬ ‭and light rail, be considered.‬ ‭●‬ ‭UTILITIES & INFRASTRUCTURE:‬ ‭ OMMENT: The potential impacts on infrastructure (water, stormwater, sanitary sewer,‬ C ‭electrical and telecommunications) will be assessed. The scope of this assessment is ill‬ ‭defined here and needs to be specified in greater detail. The DEIS needs to address‬ ‭parameters such as system capacity, level of service changes, fiscal implications for the‬ ‭community and impacts on water bodies.‬ ‭ he city of Syracuse should be considered an interested agency for this (as well as other‬ T ‭aspects of this project) as it relies on a connection to the OCWA for a portion of its water‬ ‭supply needs.‬ I‭ t is noted elsewhere in project documents that a 16” natural gas main will be extended to‬ ‭the plant, yet it isn’t mentioned in this section; Shouldn’t impacts associated with the‬ ‭area’s gas supply and the construction of this line be included here?‬ ‭●‬ ‭USE AND CONSUMPTION OF ENERGY‬ ‭ he only mitigation measures mentioned in this section are improvements to roadways. It‬ T ‭is imperative that the utilization of public transportation, including mass transit by bus‬ ‭and light rail, be considered.‬ ‭●‬ ‭UTILITIES & INFRASTRUCTURE:‬ ‭ OMMENT: The potential impacts on infrastructure (water, stormwater, sanitary sewer,‬ C ‭electrical and telecommunications) will be assessed. The scope of this assessment is ill‬ ‭defined here and needs to be specified in greater detail. The DEIS needs to address‬ ‭parameters such as system capacity, level of service changes, fiscal implications for the‬ ‭community and impacts on water bodies.‬ ‭ he city of Syracuse should be considered an interested agency for this (as well as other‬ T ‭aspects of this project) as it relies on a connection to the OCWA for a portion of its water‬ ‭supply needs.‬ I‭ t is noted elsewhere in project documents that a 16” natural gas main will be extended to‬ ‭the plant, yet it isn’t mentioned in this section; Shouldn’t impacts associated with the‬ ‭area’s gas supply and the construction of this line be included here?‬ ‭●‬ ‭USE AND CONSUMPTION OF ENERGY‬ ‭ he Scoping Document simply states: “This analysis will describe the Proposed Project’s‬ T ‭use and consumption of energy and measures that Micron intends to pursue to reduce‬ ‭energy consumption and use of renewable sources.”‬ ‭ OMMENT: The anticipated energy needs of this project are enormous. Much greater‬ C ‭detail is warranted, as discussed below. Local as well as regional and statewide impacts‬ ‭must be considered. Further, this section is related to other sections such as‬ ‭transportation, air quality, and climate change.‬ ‭6‬‭|‬‭Page‬ 424 ‭ he Scoping Document simply states: “This analysis will describe the Proposed Project’s‬ T ‭use and consumption of energy and measures that Micron intends to pursue to reduce‬ ‭energy consumption and use of renewable sources.”‬ ‭ OMMENT: The anticipated energy needs of this project are enormous. Much greater‬ C ‭detail is warranted, as discussed below. Local as well as regional and statewide impacts‬ ‭must be considered. Further, this section is related to other sections such as‬ ‭transportation, air quality, and climate change.‬ ‭6‬‭|‬‭Page‬ 424 ‭ lectricity:‬ ‭Electrical consumption is anticipated to be 16 billion kilowatt-hours of‬ E ‭electricity per year, when fully built. (Phase 2, Envir. Assessment Form, Part 1, Section‬ ‭K) To put this in perspective, this is equivalent to all of the electricity consumed by the‬ ‭states of New Hampshire and Vermont, combined. The entire state of New York used 143‬ ‭billion kWh of energy in 2022. Micron will increase demand in NY by 11%. The Scoping‬ ‭Document clearly needs to provide greater details about:‬ ‭●‬ ‭How will the EIS consider the various sources of electricity which are currently‬ ‭available, and which may become available as the plant is constructed?‬ ‭●‬ ‭The EIS must evaluate the ability of current power lines owned and operated by‬ ‭National Grid to deliver the required power.‬ ‭●‬ ‭Micron has stated its goal “to achieve 100% renewable energy for existing U.S.‬ ‭operations by the end of 2025.” (Micron sustainability progress summary 2023:‬ ‭Message from Sanjay Mehrotra President and CEO, Micron Technology) Does‬ ‭Micron plan to achieve this goal for the proposed facility in Clay?‬ ‭●‬ ‭The Scoping Document should state that the EIS will examine:‬ ‭○‬ ‭power purchase agreements with suppliers of solar power, wind power and‬ ‭hydropower.‬ ‭○‬ ‭on-site production of electricity from solar and/or wind generation‬ ‭ lectricity:‬ ‭Electrical consumption is anticipated to be 16 billion kilowatt-hours of‬ E ‭electricity per year, when fully built. (Phase 2, Envir. Assessment Form, Part 1, Section‬ ‭K) To put this in perspective, this is equivalent to all of the electricity consumed by the‬ ‭states of New Hampshire and Vermont, combined. The entire state of New York used 143‬ ‭billion kWh of energy in 2022. Micron will increase demand in NY by 11%. The Scoping‬ ‭Document clearly needs to provide greater details about:‬ ‭●‬ ‭How will the EIS consider the various sources of electricity which are currently‬ ‭available, and which may become available as the plant is constructed?‬ ‭●‬ ‭The EIS must evaluate the ability of current power lines owned and operated by‬ ‭National Grid to deliver the required power.‬ ‭●‬ ‭Micron has stated its goal “to achieve 100% renewable energy for existing U.S.‬ ‭operations by the end of 2025.” (Micron sustainability progress summary 2023:‬ ‭Message from Sanjay Mehrotra President and CEO, Micron Technology) Does‬ ‭Micron plan to achieve this goal for the proposed facility in Clay?‬ ‭●‬ ‭The Scoping Document should state that the EIS will examine:‬ ‭○‬ ‭power purchase agreements with suppliers of solar power, wind power and‬ ‭hydropower.‬ ‭○‬ ‭on-site production of electricity from solar and/or wind generation‬ ‭ atural Gas:‬‭National Grid is proposing to build approximately‬‭2.5 miles of 124-psig,12"‬ N ‭natural gas distribution main to the new Micron facility. (Exhibit G, Micron Term Sheet,‬ ‭signed Sept. 22, 2022). The DEIS needs to address these topics:‬ ‭●‬ ‭How much natural gas will the facility need, and for what purpose?‬ ‭●‬ ‭The use of natural gas seems inconsistent with New York state’s CLCPA, which‬ ‭calls for a‬‭40% reduction of greenhouse gas (GHG)‬‭emissions 2030, and then an‬ ‭85% reduction of GHG (below 1990 levels) by 2050. Combustion of natural gas‬ ‭releases CO‬‭2‬ ‭which is the primary driver of climate‬‭change.‬ ‭●‬ ‭The use of natural gas also seems incompatible with‬‭Micron’s global target to‬ ‭achieve a 42% reduction in GHG emissions from operations (“scope 1”) by 2030‬ ‭and net-zero emissions from operations and purchased energy (“scope 1 & 2") by‬ ‭2050, supporting the objectives of the Paris Agreement. (Source:‬‭Micron website:‬ ‭https://www.micron.com/ny/fact-sheet‬‭)‬ ‭ atural Gas:‬‭National Grid is proposing to build approximately‬‭2.5 miles of 124-psig,12"‬ N ‭natural gas distribution main to the new Micron facility. (Exhibit G, Micron Term Sheet,‬ ‭signed Sept. 22, 2022). The DEIS needs to address these topics:‬ ‭●‬ ‭How much natural gas will the facility need, and for what purpose?‬ ‭●‬ ‭The use of natural gas seems inconsistent with New York state’s CLCPA, which‬ ‭calls for a‬‭40% reduction of greenhouse gas (GHG)‬‭emissions 2030, and then an‬ ‭85% reduction of GHG (below 1990 levels) by 2050. Combustion of natural gas‬ ‭releases CO‬‭2‬ ‭which is the primary driver of climate‬‭change.‬ ‭●‬ ‭The use of natural gas also seems incompatible with‬‭Micron’s global target to‬ ‭achieve a 42% reduction in GHG emissions from operations (“scope 1”) by 2030‬ ‭and net-zero emissions from operations and purchased energy (“scope 1 & 2") by‬ ‭2050, supporting the objectives of the Paris Agreement. (Source:‬‭Micron website:‬ ‭https://www.micron.com/ny/fact-sheet‬‭)‬ ‭ elated energy usage:‬‭The use of energy for construction,‬‭facility operations and the‬ R ‭ancillary increases in energy consumption related to transportation needs the project will‬ ‭generate should also be investigated. It may not be unreasonable to consider the increase‬ ‭in energy consumption from the induced community growth which this project will‬ ‭generate as described in the chapters on indirect and cumulative impacts and the growth‬ ‭inducing aspects of the project.‬ ‭●‬ ‭INDIRECT AND CUMULATIVE IMPACTS:‬ ‭ OMMENT: The use of the word ‘summarize’ to describe the scope of this Chapter is‬ C ‭insufficient. This Chapter must assess indirect and cumulative impacts of the proposed‬ ‭project for each of the technical areas included in the DEIS. If these effects are included‬ ‭elsewhere it may be appropriate to summarize them here. Let’s be clear about exactly‬ ‭what is required to be included in the DEIS‬ ‭7‬‭|‬‭Page‬ 425 ‭●‬ ‭GROWTH INDUCING ASPECTS OF THE PROPOSED PROJECT:‬ ‭ elated energy usage:‬‭The use of energy for construction,‬‭facility operations and the‬ R ‭ancillary increases in energy consumption related to transportation needs the project will‬ ‭generate should also be investigated. It may not be unreasonable to consider the increase‬ ‭in energy consumption from the induced community growth which this project will‬ ‭generate as described in the chapters on indirect and cumulative impacts and the growth‬ ‭inducing aspects of the project.‬ ‭●‬ ‭INDIRECT AND CUMULATIVE IMPACTS:‬ ‭ OMMENT: The use of the word ‘summarize’ to describe the scope of this Chapter is‬ C ‭insufficient. This Chapter must assess indirect and cumulative impacts of the proposed‬ ‭project for each of the technical areas included in the DEIS. If these effects are included‬ ‭elsewhere it may be appropriate to summarize them here. Let’s be clear about exactly‬ ‭what is required to be included in the DEIS‬ ‭7‬‭|‬‭Page‬ 425 ‭●‬ ‭GROWTH INDUCING ASPECTS OF THE PROPOSED PROJECT:‬ ‭ OMMENT: This section relates to perhaps the most significant aspects of this project.‬ C ‭While jobs and employment and economic growth will be created, the population growth‬ ‭of the region has the potential to produce significant adverse environmental and‬ ‭economic impacts as well which must be considered. While this section overlaps with‬ ‭other sections of the proposed DEIS scope, it is important to not forget that there will be‬ ‭significant impacts on the community. Such effects as rising housing costs could‬ ‭disproportionately impact the impoverished and increase the potential for a rise in‬ ‭homelessness. The DEIS must not overlook this and other issues relating to population‬ ‭growth of Syracuse, Onondaga County and the surrounding area.‬ ‭●‬ ‭IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES‬ ‭ OMMENT: Aside from building materials and energy, resources consumed in the‬ C ‭manufacturing process, as well as the land devoted to this project, the water consumed‬ ‭and the changes to water and air quality (eg., compounds such as “forever chemicals”‬ ‭which could be discharged into water bodies and the air) should be included in this‬ ‭analysis. The community should, and must know, the sustainability aspects of this‬ ‭venture as it decides to permit its development.‬ ‭ OMMENT: This section relates to perhaps the most significant aspects of this project.‬ C ‭While jobs and employment and economic growth will be created, the population growth‬ ‭of the region has the potential to produce significant adverse environmental and‬ ‭economic impacts as well which must be considered. While this section overlaps with‬ ‭other sections of the proposed DEIS scope, it is important to not forget that there will be‬ ‭significant impacts on the community. Such effects as rising housing costs could‬ ‭disproportionately impact the impoverished and increase the potential for a rise in‬ ‭homelessness. The DEIS must not overlook this and other issues relating to population‬ ‭growth of Syracuse, Onondaga County and the surrounding area.‬ ‭●‬ ‭IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES‬ ‭ OMMENT: Aside from building materials and energy, resources consumed in the‬ C ‭manufacturing process, as well as the land devoted to this project, the water consumed‬ ‭and the changes to water and air quality (eg., compounds such as “forever chemicals”‬ ‭which could be discharged into water bodies and the air) should be included in this‬ ‭analysis. The community should, and must know, the sustainability aspects of this‬ ‭venture as it decides to permit its development.‬ ‭●‬ ‭MITIGATION:‬ ‭The SEQR Handbook suggests, “ Specify possible measures for mitigating potential‬ ‭impacts that must be discussed in the EIS, to the extent that they can be identified at the‬ ‭time of scoping.”‬ ‭In addition to those listed in this draft scope, others that should be listed are:‬ ‭●‬ ‭Public transportation (various options such as fixed route bus, demand activated‬ ‭bus service, light rail),‬ ‭●‬ ‭Building design features such as those proscribed in LEED building standards that‬ ‭reduce energy consumption, or production of renewable energy (geothermal or‬ ‭other water-source heat pumps) or‬ ‭●‬ ‭Mitigate habitat loss with green roofs or parking area reductions via public‬ ‭transportation options for employees‬ ‭●‬ ‭Alternative production processes that can minimize use of hazardous materials,‬ ‭energy use, etc.‬ ‭Respectfully submitted by the following, on behalf of their respective organizations.‬ ‭ onald Hughes‬ D ‭Conservation Chair, Sierra Club Central & Northern NY Group‬ ‭Syracuse, NY‬ ‭dhughes171@gmail.com‬ ‭ eter Wirth‬ P ‭Vice President, Climate Change Action and Awareness‬ ‭Fayetteville, NY‬ ‭pwirth2@verizon.net‬ ‭8‬‭|‬‭Page‬ 426 ‭●‬ ‭MITIGATION:‬ ‭The SEQR Handbook suggests, “ Specify possible measures for mitigating potential‬ ‭impacts that must be discussed in the EIS, to the extent that they can be identified at the‬ ‭time of scoping.”‬ ‭In addition to those listed in this draft scope, others that should be listed are:‬ ‭●‬ ‭Public transportation (various options such as fixed route bus, demand activated‬ ‭bus service, light rail),‬ ‭●‬ ‭Building design features such as those proscribed in LEED building standards that‬ ‭reduce energy consumption, or production of renewable energy (geothermal or‬ ‭other water-source heat pumps) or‬ ‭●‬ ‭Mitigate habitat loss with green roofs or parking area reductions via public‬ ‭transportation options for employees‬ ‭●‬ ‭Alternative production processes that can minimize use of hazardous materials,‬ ‭energy use, etc.‬ ‭Respectfully submitted by the following, on behalf of their respective organizations.‬ ‭ onald Hughes‬ D ‭Conservation Chair, Sierra Club Central & Northern NY Group‬ ‭Syracuse, NY‬ ‭dhughes171@gmail.com‬ ‭ eter Wirth‬ P ‭Vice President, Climate Change Action and Awareness‬ ‭Fayetteville, NY‬ ‭pwirth2@verizon.net‬ ‭8‬‭|‬‭Page‬ 426 J‭ ohn Przepiora‬ ‭Vice President, GreeningUSA, Inc.‬ ‭Syracuse, NY‬ ‭info@greeningusa.org‬ ‭ ick Kornbluth‬ D ‭Climate Justice Committee‬ ‭CNY Solidarity Coalition‬ ‭Onondaga County, NY‬ ‭cnysolidarity@gmail.com‬ ‭ ylah Worrell‬ T ‭Exec. Director,‬ ‭Urban Jobs Task Force of Syracuse‬ ‭Syracuse, NY‬ ‭t.worrell@ujtfs.org‬ ‭LIST OF ATTACHMENTS‬ ‭1.‬ ‭Forbes magazine, Oct. 5 , 2023;‬ ‭https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-mean‬ ‭s-more-forever-chemicals/?sh=2d10b08c7821‬‭P‬ ‭2.‬ ‭Memorandum from Lenny Siegel, Center for Public Environmental Oversight‬ ‭3.‬ ‭Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng. “Review of‬ ‭essential use of fluorochemicals in lithographic patterning and semiconductor‬ ‭processing,”‬‭Journal of Micro/Nanopatterning, Materials, and Metrology, Vol.‬ ‭21, Issue 1‬‭, 010901 (March 2022).‬ ‭https://doi.org/10.1117/1.JMM.21.1.010901‬ ‭4.‬ ‭Micron sustainability progress summary 2023: Message from Sanjay Mehrotra President‬ ‭and CEO, Micron Technology‬ ‭9‬‭|‬‭Page‬ 427 More Domestic Chip-Making Means More ‘Forever Chemicals’ by Amy Feldman, Forbes Staff, October 5, 2033 https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-means-more-forever-chemicals/?sh=2d10b08c7821 J‭ ohn Przepiora‬ ‭Vice President, GreeningUSA, Inc.‬ ‭Syracuse, NY‬ ‭info@greeningusa.org‬ ‭ ick Kornbluth‬ D ‭Climate Justice Committee‬ ‭CNY Solidarity Coalition‬ ‭Onondaga County, NY‬ ‭cnysolidarity@gmail.com‬ ‭ ylah Worrell‬ T ‭Exec. Director,‬ ‭Urban Jobs Task Force of Syracuse‬ ‭Syracuse, NY‬ ‭t.worrell@ujtfs.org‬ ‭LIST OF ATTACHMENTS‬ ‭1.‬ ‭Forbes magazine, Oct. 5 , 2023;‬ ‭https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-mean‬ ‭s-more-forever-chemicals/?sh=2d10b08c7821‬‭P‬ ‭2.‬ ‭Memorandum from Lenny Siegel, Center for Public Environmental Oversight‬ ‭3.‬ ‭Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng. “Review of‬ ‭essential use of fluorochemicals in lithographic patterning and semiconductor‬ ‭processing,”‬‭Journal of Micro/Nanopatterning, Materials, and Metrology, Vol.‬ ‭21, Issue 1‬‭, 010901 (March 2022).‬ ‭https://doi.org/10.1117/1.JMM.21.1.010901‬ ‭4.‬ ‭Micron sustainability progress summary 2023: Message from Sanjay Mehrotra President‬ ‭and CEO, Micron Technology‬ ‭9‬‭|‬‭Page‬ 427 More Domestic Chip-Making Means More ‘Forever Chemicals’ by Amy Feldman, Forbes Staff, October 5, 2033 https://www.forbes.com/sites/amyfeldman/2023/10/05/more-domestic-chip-making-means-more-forever-chemicals/?sh=2d10b08c7821 Mark Newman, CEO of Chemours, the only American PFA manufacturer, says the company is ramping up production to meet the demands of reshored semiconductor fabrication. “I brought some show-and-tell,” Mark Newman, CEO of chemical maker Chemours, told Forbes during a recent interview in a midtown Manhattan conference room. He pulled a valve assembly out of a bag. The innocuous piece of plastic, he explained, is made of fluoropolymer known as PFA — a type of controversial “forever chemical” and an essential tool in the production of semiconductors. 1|Page 428 “You cannot make chips without a whole PFA infrastructure,” he said. “We estimate that in a modern-day fab, there’s a half-kilo of PFA in every square foot. So in a 400,000- to 600,000- square-foot fab, that’s 200 to 300 metric tons of this stuff.” It’s not just valves, of course, but all types of pipes, tubes and pumps in semiconductor equipment. Fluoropolymers are particularly key for filtering out small particles from fluids during chip production. Few factories need to be as clean as chip fabs, where particles as tiny as human skin cells can contaminate production. Chemours’ PFA is in much of that equipment and material, providing a big, and largely unseen, part of a semiconductor fab’s processes. Mark Newman, CEO of Chemours, the only American PFA manufacturer, says the company is ramping up production to meet the demands of reshored semiconductor fabrication. “I brought some show-and-tell,” Mark Newman, CEO of chemical maker Chemours, told Forbes during a recent interview in a midtown Manhattan conference room. He pulled a valve assembly out of a bag. The innocuous piece of plastic, he explained, is made of fluoropolymer known as PFA — a type of controversial “forever chemical” and an essential tool in the production of semiconductors. 1|Page 428 “You cannot make chips without a whole PFA infrastructure,” he said. “We estimate that in a modern-day fab, there’s a half-kilo of PFA in every square foot. So in a 400,000- to 600,000- square-foot fab, that’s 200 to 300 metric tons of this stuff.” It’s not just valves, of course, but all types of pipes, tubes and pumps in semiconductor equipment. Fluoropolymers are particularly key for filtering out small particles from fluids during chip production. Few factories need to be as clean as chip fabs, where particles as tiny as human skin cells can contaminate production. Chemours’ PFA is in much of that equipment and material, providing a big, and largely unseen, part of a semiconductor fab’s processes. Wilmington, Delaware-based Chemours, a spinout of DuPont, is the only U.S. manufacturer of PFA. For Chemours, advanced materials including fluoropolymers represent roughly one- quarter of its total $6.3 billion (latest 12-months revenue) business, with refrigerants and titanium dioxide, used in paints and aerospace coatings, making up the bulk of the rest. Within that, semiconductors are part of its performance-solutions segment, which accounted for $493 million in sales for 2022, up 53% from $322 million in 2020. On its website, Chemours says flat-out that “without PFA, domestic semiconductor manufacturing would not be possible.” Last year, President Biden signed into law the CHIPS Act, which provides $52 billion in funding to spur domestic semiconductor manufacturing with a goal of improving national security by decreasing reliance on nations like China for critical technology. Chips are essential not just for our phones and computers, but also for medical devices and fighter jets. “Geopolitics has been defined by oil over the last 50 years,” Intel CEO Pat Gelsinger said at an MIT event earlier this year. “Technology supply chains are more important for a digital future than oil for the next 50 years.” But our insatiable desire for electronic devices and American policymakers’ push for more domestic manufacturing of semiconductors relies on the industry’s access to large amounts of “forever chemicals.” Wilmington, Delaware-based Chemours, a spinout of DuPont, is the only U.S. manufacturer of PFA. For Chemours, advanced materials including fluoropolymers represent roughly one- quarter of its total $6.3 billion (latest 12-months revenue) business, with refrigerants and titanium dioxide, used in paints and aerospace coatings, making up the bulk of the rest. Within that, semiconductors are part of its performance-solutions segment, which accounted for $493 million in sales for 2022, up 53% from $322 million in 2020. On its website, Chemours says flat-out that “without PFA, domestic semiconductor manufacturing would not be possible.” Last year, President Biden signed into law the CHIPS Act, which provides $52 billion in funding to spur domestic semiconductor manufacturing with a goal of improving national security by decreasing reliance on nations like China for critical technology. Chips are essential not just for our phones and computers, but also for medical devices and fighter jets. “Geopolitics has been defined by oil over the last 50 years,” Intel CEO Pat Gelsinger said at an MIT event earlier this year. “Technology supply chains are more important for a digital future than oil for the next 50 years.” But our insatiable desire for electronic devices and American policymakers’ push for more domestic manufacturing of semiconductors relies on the industry’s access to large amounts of “forever chemicals.” 2|Page 429 Ongoing Litigation Forever chemicals, or PFAS, comprise thousands of synthetic chemicals. They’re long-lasting and resistant to heat, corrosion and moisture, making them popular for a variety of products that include nonstick pans, stain-resistant upholstery, firefighting foam — and semiconductor production. Studies, however, have linked PFAS to a variety of diseases, including cancers and reduced immune system response, as well as to contaminated groundwater, air and soil that can lead to a host of health problems. PFAS are an enormous category. Fluoropolymers, like those that Chemours manufactures for industrial uses, are just one class. Litigation over their impact is ongoing. In June, Chemours, along with DuPont and another spinoff, Corteva, reached a $1.2 billion settlement with public water systems. Meanwhile, legislators and regulators have been cracking down on the chemicals’ use, particularly in consumer products such as clothing, furniture and textiles, where they can be more easily replaced. Minneapolis-based 3M, which in 2018 agreed to pay $850 million for damaging drinking water and natural resources in the Twin Cities area, announced that it would cease production of PFAS by the end of 2025. 2|Page 429 Ongoing Litigation Forever chemicals, or PFAS, comprise thousands of synthetic chemicals. They’re long-lasting and resistant to heat, corrosion and moisture, making them popular for a variety of products that include nonstick pans, stain-resistant upholstery, firefighting foam — and semiconductor production. Studies, however, have linked PFAS to a variety of diseases, including cancers and reduced immune system response, as well as to contaminated groundwater, air and soil that can lead to a host of health problems. PFAS are an enormous category. Fluoropolymers, like those that Chemours manufactures for industrial uses, are just one class. Litigation over their impact is ongoing. In June, Chemours, along with DuPont and another spinoff, Corteva, reached a $1.2 billion settlement with public water systems. Meanwhile, legislators and regulators have been cracking down on the chemicals’ use, particularly in consumer products such as clothing, furniture and textiles, where they can be more easily replaced. Minneapolis-based 3M, which in 2018 agreed to pay $850 million for damaging drinking water and natural resources in the Twin Cities area, announced that it would cease production of PFAS by the end of 2025. The semiconductor industry has pushed back against regulations here and in Europe, where regulators had proposed a ban on PFAS. When the U.S. Environmental Protection Agency asked for comments on tightened oversight on PFAS earlier this year by revoking certain low- volume exemptions, the microelectronics trade group SEMI called it “catastrophic” for domestic chip manufacturing. In a letter to the EPA, it said that such a rule “would significantly hamper the domestic semiconductor industry despite express goals of the Administration to the contrary and to the detriment of the U.S. economy.” Doubling Down In this landscape, Chemours’ Newman is doubling down. In a wide-ranging interview with Forbes during a trip to New York for Climate Week, Newman said that the $4 billion 3|Page 430 (market cap) company was expanding production of fluoropolymers, driven by the critical need for the chemicals in semiconductors and electric vehicles. Further, he said, such production could be done safely with investments that his company is making. It has, for example, invested more than $100 million in emissions control technology at its Fayetteville, North Carolina plant. The semiconductor industry has pushed back against regulations here and in Europe, where regulators had proposed a ban on PFAS. When the U.S. Environmental Protection Agency asked for comments on tightened oversight on PFAS earlier this year by revoking certain low- volume exemptions, the microelectronics trade group SEMI called it “catastrophic” for domestic chip manufacturing. In a letter to the EPA, it said that such a rule “would significantly hamper the domestic semiconductor industry despite express goals of the Administration to the contrary and to the detriment of the U.S. economy.” Doubling Down In this landscape, Chemours’ Newman is doubling down. In a wide-ranging interview with Forbes during a trip to New York for Climate Week, Newman said that the $4 billion 3|Page 430 (market cap) company was expanding production of fluoropolymers, driven by the critical need for the chemicals in semiconductors and electric vehicles. Further, he said, such production could be done safely with investments that his company is making. It has, for example, invested more than $100 million in emissions control technology at its Fayetteville, North Carolina plant. “We’re currently sold out and working to expand capacity here in the United States,” Newman said. Chemours plans to enlarge its West Virginia production facility, he said. Located just across the river from Ohio, the factory is well positioned to supply Intel’s giant chip fab near Columbus, now under construction. “Imagine making something for the semiconductor industry in what people think of as coal country,” Newman said. All told, the company is investing up to $1 billion in fluoropolymers, including those for use in semiconductors. The combination of reshoring and PFAS is “a very complicated discussion,” said Zhanyun Wang, a scientist and PFAS researcher with EMPA-Swiss Federal Laboratories for Materials Testing and Research. “There’s a lot of resistance from the industry because, of course, if we want to do the change, it costs.” That’s especially problematic if the United States and the European Union impose regulations and other parts of the world do not. However, he said, such regulations could be designed to spur new innovations. “The semiconductor industry has a lot of R&D power,” he said. “We’re currently sold out and working to expand capacity here in the United States,” Newman said. Chemours plans to enlarge its West Virginia production facility, he said. Located just across the river from Ohio, the factory is well positioned to supply Intel’s giant chip fab near Columbus, now under construction. “Imagine making something for the semiconductor industry in what people think of as coal country,” Newman said. All told, the company is investing up to $1 billion in fluoropolymers, including those for use in semiconductors. The combination of reshoring and PFAS is “a very complicated discussion,” said Zhanyun Wang, a scientist and PFAS researcher with EMPA-Swiss Federal Laboratories for Materials Testing and Research. “There’s a lot of resistance from the industry because, of course, if we want to do the change, it costs.” That’s especially problematic if the United States and the European Union impose regulations and other parts of the world do not. However, he said, such regulations could be designed to spur new innovations. “The semiconductor industry has a lot of R&D power,” he said. In July 2015, when industrial giant DuPont spun off its performance chemicals division and named it Chemours for “chemistry” plus the “Nemours” part of DuPont’s full name, the new company was saddled with debt and potentially toxic assets. “I think investors were worried if we were going to be solvent,” then-CEO Mark Vergnano told Fortune in 2016. “Were we going to make it through this or not?” Vergnano proceeded to pull off a dramatic turnaround by slashing costs, selling off non-essential businesses and gaining market share for its refrigerants business. 4|Page 431 Big Expense Newman, who had been the company’s chief financial officer during those years and is one of the country’s top Black executives, became CEO in 2021. The company’s revenue ballooned to a peak of $6.8 billion in 2022, driven by strong pricing. Its advanced performance materials business, which includes the Teflon lineup of fluorine chemicals, gained price increases of 18% and reached total sales of $1.6 billion as it focused on high-tech markets including advanced electronics and clean energy. In July 2015, when industrial giant DuPont spun off its performance chemicals division and named it Chemours for “chemistry” plus the “Nemours” part of DuPont’s full name, the new company was saddled with debt and potentially toxic assets. “I think investors were worried if we were going to be solvent,” then-CEO Mark Vergnano told Fortune in 2016. “Were we going to make it through this or not?” Vergnano proceeded to pull off a dramatic turnaround by slashing costs, selling off non-essential businesses and gaining market share for its refrigerants business. 4|Page 431 Big Expense Newman, who had been the company’s chief financial officer during those years and is one of the country’s top Black executives, became CEO in 2021. The company’s revenue ballooned to a peak of $6.8 billion in 2022, driven by strong pricing. Its advanced performance materials business, which includes the Teflon lineup of fluorine chemicals, gained price increases of 18% and reached total sales of $1.6 billion as it focused on high-tech markets including advanced electronics and clean energy. The semiconductor industry “didn’t want to use fluoropolymers, not because they were concerned about them, but because fluoropolymers are expensive,” said Gerardo Familiar, president of Chemours’ Advanced Performance Materials division, which includes fluorine chemicals. But alternatives have been scarce because of fluoropolymers’ resistance to corrosion and ability to work at high temperatures and to last for a long time. He said that fluoropolymers like PFA are “substances of low concern,” and that they should be considered differently than PFAS. “Those materials last a very, very, very long time, but they make your manufacturing very, very, very safe for the people who are there because you don’t have an issue with corrosion,” he said. The conundrum, he said, is how to manufacture them responsibly and what to do with the materials at the end of their life. The semiconductor industry “didn’t want to use fluoropolymers, not because they were concerned about them, but because fluoropolymers are expensive,” said Gerardo Familiar, president of Chemours’ Advanced Performance Materials division, which includes fluorine chemicals. But alternatives have been scarce because of fluoropolymers’ resistance to corrosion and ability to work at high temperatures and to last for a long time. He said that fluoropolymers like PFA are “substances of low concern,” and that they should be considered differently than PFAS. “Those materials last a very, very, very long time, but they make your manufacturing very, very, very safe for the people who are there because you don’t have an issue with corrosion,” he said. The conundrum, he said, is how to manufacture them responsibly and what to do with the materials at the end of their life. Some smaller companies are working on replacing PFAS in electronics manufacturing. Danvers, Massachusetts-based Transene, a privately held business founded in 1965, partnered with Toxics Use Reduction Institute (TURI) researchers at University of Massachusetts Lowell to develop alternatives for its etching solutions used in the semiconductor industry. The vast majority of customers have made the switch, and others are working through their qualification process. “You keep hearing from the industry, ‘We need 10 or 15 years to make a change,’” said Greg Morose, research professor at UMass Lowell and research manager at TURI, who worked with Transene. “We basically did the research in 18 months, which is really rapid.” 5|Page 432 Phasing Out PFAS But that’s just one small company, and one use of PFAS within a semiconductor fab. David Zamarin, founder of venture-backed DetraPel, which works on sustainable coatings for food packaging and textiles, said he received inquiries from semiconductor and electronics manufacturers, but that the cost and time didn’t make it economically viable. In the electronics industry, even companies that have set goals of getting rid of PFAS are moving slowly. Apple, for example, has promised to “thoughtfully phase out PFAS in a way that does not result in regrettable substitutions.” Some smaller companies are working on replacing PFAS in electronics manufacturing. Danvers, Massachusetts-based Transene, a privately held business founded in 1965, partnered with Toxics Use Reduction Institute (TURI) researchers at University of Massachusetts Lowell to develop alternatives for its etching solutions used in the semiconductor industry. The vast majority of customers have made the switch, and others are working through their qualification process. “You keep hearing from the industry, ‘We need 10 or 15 years to make a change,’” said Greg Morose, research professor at UMass Lowell and research manager at TURI, who worked with Transene. “We basically did the research in 18 months, which is really rapid.” 5|Page 432 Phasing Out PFAS But that’s just one small company, and one use of PFAS within a semiconductor fab. David Zamarin, founder of venture-backed DetraPel, which works on sustainable coatings for food packaging and textiles, said he received inquiries from semiconductor and electronics manufacturers, but that the cost and time didn’t make it economically viable. In the electronics industry, even companies that have set goals of getting rid of PFAS are moving slowly. Apple, for example, has promised to “thoughtfully phase out PFAS in a way that does not result in regrettable substitutions.” Newman said that fluorine chemicals can be made responsibly. Chemours has committed to eliminating at least 99% of PFAS air and water emissions from its manufacturing processes by 2030. Chemours is also working on sustainable technologies, he said, such as renewable membranes for green hydrogen production marketed under the Nafion brand name and low- global-warming refrigerants for heating and cooling buildings. “We felt because of our legacy we needed to lean into this mantra of being a different kind of chemistry company and showcasing the fact that we could be a leader in emissions reduction,” Newman said. “Our chemistry really enables a lot of the future economy.” 6|Page 433 Newman said that fluorine chemicals can be made responsibly. Chemours has committed to eliminating at least 99% of PFAS air and water emissions from its manufacturing processes by 2030. Chemours is also working on sustainable technologies, he said, such as renewable membranes for green hydrogen production marketed under the Nafion brand name and low- global-warming refrigerants for heating and cooling buildings. “We felt because of our legacy we needed to lean into this mantra of being a different kind of chemistry company and showcasing the fact that we could be a leader in emissions reduction,” Newman said. “Our chemistry really enables a lot of the future economy.” 6|Page 433 CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT A project of the Pacific Studies Center P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 http://www.cpeo.org TO: Micron Project, Office of Economic Development, Onondaga County FROM: Lenny Siegel, Center for Public Environmental Oversight DATE: October 30, 2023 SUBJECT: SEQRA Scope of Work for Micron Semiconductor Fabrication Thank you for the opportunity to comment on the September 12, 2023 Draft SEQRA Scope of Work for Micron Semiconductor Fabrication. I have been asked by residents of Onondoga County to offer my comments. I have nearly five decades of experience monitoring and influencing the worker health and environmental impacts of the semiconductor industry, through the Pacific Studies Center, the Project on Health and Safety in Electronics, the Silicon Valley Toxics Coalition, and the Center for Public Environmental Oversight, as well as my service as Council Member and Mayor of Mountain View, the birthplace of the commercial semiconductor industry. CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT A project of the Pacific Studies Center P.O. Box 998, Mountain View, CA 94042 Voice/Fax: 650-961-8918 http://www.cpeo.org TO: Micron Project, Office of Economic Development, Onondaga County FROM: Lenny Siegel, Center for Public Environmental Oversight DATE: October 30, 2023 SUBJECT: SEQRA Scope of Work for Micron Semiconductor Fabrication Thank you for the opportunity to comment on the September 12, 2023 Draft SEQRA Scope of Work for Micron Semiconductor Fabrication. I have been asked by residents of Onondoga County to offer my comments. I have nearly five decades of experience monitoring and influencing the worker health and environmental impacts of the semiconductor industry, through the Pacific Studies Center, the Project on Health and Safety in Electronics, the Silicon Valley Toxics Coalition, and the Center for Public Environmental Oversight, as well as my service as Council Member and Mayor of Mountain View, the birthplace of the commercial semiconductor industry. The semiconductor industry produces remarkable products that we all use. Unfortunately, its environmental and workplace health record is less than remarkable. The MEW Superfund Area here in Mountain View was the home of some of the earliest successful integrated circuit manufacturers. The wafer fabs are gone, but despite the scores (hundreds?) of millions of dollars spent thus far on subsurface remediation, the contamination—including the risk of public exposure—will remain for decades more, if not longer. The same is true at other Silicon Valley sites. The SEQRA process provides an opportunity to identify and minimize, in advance, the environmental hazards of semiconductor production. By doing so, it can lead to appropriate regulation, research on waste management and pollution prevention, and investments in safer facilities. Semiconductor production is essentially a series of chemical processes that use a wide variety of hazardous substances. The industry explains, “While in the 1980s semiconductor fabs used 434 2 The semiconductor industry produces remarkable products that we all use. Unfortunately, its environmental and workplace health record is less than remarkable. The MEW Superfund Area here in Mountain View was the home of some of the earliest successful integrated circuit manufacturers. The wafer fabs are gone, but despite the scores (hundreds?) of millions of dollars spent thus far on subsurface remediation, the contamination—including the risk of public exposure—will remain for decades more, if not longer. The same is true at other Silicon Valley sites. The SEQRA process provides an opportunity to identify and minimize, in advance, the environmental hazards of semiconductor production. By doing so, it can lead to appropriate regulation, research on waste management and pollution prevention, and investments in safer facilities. Semiconductor production is essentially a series of chemical processes that use a wide variety of hazardous substances. The industry explains, “While in the 1980s semiconductor fabs used 434 2 fewer than 20 elements, today they are using over 50% of the nonradioactive elements in the periodic table.”1 Those include toxic heavy metals. The industry is a major user of Per- and Polyfluorinated Substances (PFAS), also known as “Forever Chemicals” because they persist and bioaccumulate in the environment and even human bloodstreams. As New York state agencies are well aware, these compounds are toxic, even at extremely low exposure concentrations, through multiple pathways. But industry has become reliant on PFAS without first examining the human and environmental risks. It explains, “Without PFAS, the ability to produce semiconductors (and the facilities and equipment related to and supporting semiconductor manufacturing) would be put at risk.”2 Use and release of the industry’s hazardous building blocks are regulated by both state and federal statutes and regulations, but the public is generally unaware of the series of upcoming permit applications that Micron is expecting to make. The SEQRA review should list all anticipated permitting processes, with the anticipated schedule of public comment periods, and it should require public notification to interested parties of each permit application as it is submitted. fewer than 20 elements, today they are using over 50% of the nonradioactive elements in the periodic table.”1 Those include toxic heavy metals. The industry is a major user of Per- and Polyfluorinated Substances (PFAS), also known as “Forever Chemicals” because they persist and bioaccumulate in the environment and even human bloodstreams. As New York state agencies are well aware, these compounds are toxic, even at extremely low exposure concentrations, through multiple pathways. But industry has become reliant on PFAS without first examining the human and environmental risks. It explains, “Without PFAS, the ability to produce semiconductors (and the facilities and equipment related to and supporting semiconductor manufacturing) would be put at risk.”2 Use and release of the industry’s hazardous building blocks are regulated by both state and federal statutes and regulations, but the public is generally unaware of the series of upcoming permit applications that Micron is expecting to make. The SEQRA review should list all anticipated permitting processes, with the anticipated schedule of public comment periods, and it should require public notification to interested parties of each permit application as it is submitted. It should also identify hazardous substances, whether or not they currently have promulgated exposure standards. For example, the industry reports, “Most PFAS are not regulated pollutants and therefore unless company specific provisions are in place, the wastewater from processes that use aqueous wet chemical formulations that contain PFAS would likely be discharged to the publicly owned treatment works without substantive removal of the PFAS.”3 Furthermore, potential workplace exposures should not be ignored because exposures are below the Occupational Exposure Level (OEL) or even a fraction of the OEL, as industry suggests.4 In most cases OELs, such as the Occupational Safety and Health Administration’s (OSHA) Permissible Exposure Limits (PELs), are orders of magnitude above what the science— including U.S. EPA studies—dictates. While the draft Scope of Work proposes many useful Technical Chapters, there is room for more specificity. I focus on the use and release of hazardous substances. For Solid Wastes and Hazardous Materials, the Scope of Work states, “The chapter will identify any hazardous materials (including any chemical or petroleum bulk storage) that would be used, stored, transported, or generated by the Proposed Project and measures to protect It should also identify hazardous substances, whether or not they currently have promulgated exposure standards. For example, the industry reports, “Most PFAS are not regulated pollutants and therefore unless company specific provisions are in place, the wastewater from processes that use aqueous wet chemical formulations that contain PFAS would likely be discharged to the publicly owned treatment works without substantive removal of the PFAS.”3 Furthermore, potential workplace exposures should not be ignored because exposures are below the Occupational Exposure Level (OEL) or even a fraction of the OEL, as industry suggests.4 In most cases OELs, such as the Occupational Safety and Health Administration’s (OSHA) Permissible Exposure Limits (PELs), are orders of magnitude above what the science— including U.S. EPA studies—dictates. While the draft Scope of Work proposes many useful Technical Chapters, there is room for more specificity. I focus on the use and release of hazardous substances. For Solid Wastes and Hazardous Materials, the Scope of Work states, “The chapter will identify any hazardous materials (including any chemical or petroleum bulk storage) that would be used, stored, transported, or generated by the Proposed Project and measures to protect 1 “Background on Semiconductor Manufacturing and PFAS,” Semiconductor Association (SIA) PFAS Consortium, May 17, 2023, p. 54. The SIA PFAS Consortium is made up of chipmakers and their suppliers of equipment and materials. To sign up to receive their technical papers, go to https://www.semiconductors.org/pfas/ . I am attaching this document. 2 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 3. I am also attaching this document. 3 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 3 4 “Background on Semiconductor Manufacturing and PFAS,” SIA PFAS Consortium, May 17, 2023, p. 25. 435 3 against releases to the environment. Any warranted remedial approaches for addressing identified or potential contaminated materials would be described.” I suggest that the Review describe any permitting required for the Treatment, Storage, and Disposal of hazardous materials and solid wastes, and that it list the storage requirements, such as double-walled tanks and piping, necessary to prevent environmental releases. Furthermore, how will employees be educated about the risk from leaks and spills, as well as what to do when they occur? 1 “Background on Semiconductor Manufacturing and PFAS,” Semiconductor Association (SIA) PFAS Consortium, May 17, 2023, p. 54. The SIA PFAS Consortium is made up of chipmakers and their suppliers of equipment and materials. To sign up to receive their technical papers, go to https://www.semiconductors.org/pfas/ . I am attaching this document. 2 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 3. I am also attaching this document. 3 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 3 4 “Background on Semiconductor Manufacturing and PFAS,” SIA PFAS Consortium, May 17, 2023, p. 25. 435 3 against releases to the environment. Any warranted remedial approaches for addressing identified or potential contaminated materials would be described.” I suggest that the Review describe any permitting required for the Treatment, Storage, and Disposal of hazardous materials and solid wastes, and that it list the storage requirements, such as double-walled tanks and piping, necessary to prevent environmental releases. Furthermore, how will employees be educated about the risk from leaks and spills, as well as what to do when they occur? To what degree will disposal—including landfilling and incineration—create off-site hazards? Industry reports, “Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerized to be treated at an offsite licensed treatment and disposal facility, as a blended fuel by high temperature incineration or reprocessing.”5 Perfluorinated compounds are particularly difficult to destroy using incineration. Furthermore, even when permitted by regulatory agencies, incineration may release products of incomplete combustion into the atmosphere. For Air Quality, the Scope of Work barely mentions the potential emissions of highly toxic air contaminants. Historically the industry has used lethal gases such as arsine and phosphine, as well as toxic gases such as hydrogen chloride (the gaseous form of hydrochloric acid). Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipment to respond safely to such releases. Employees should be warned about the toxicity of gases used by the industry and trained to protect themselves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity. To what degree will disposal—including landfilling and incineration—create off-site hazards? Industry reports, “Organic waste, including organic liquids containing PFAS, is typically segregated, collected, and containerized to be treated at an offsite licensed treatment and disposal facility, as a blended fuel by high temperature incineration or reprocessing.”5 Perfluorinated compounds are particularly difficult to destroy using incineration. Furthermore, even when permitted by regulatory agencies, incineration may release products of incomplete combustion into the atmosphere. For Air Quality, the Scope of Work barely mentions the potential emissions of highly toxic air contaminants. Historically the industry has used lethal gases such as arsine and phosphine, as well as toxic gases such as hydrogen chloride (the gaseous form of hydrochloric acid). Micron should identify plans to notify first responders and public of any toxic air releases, and first responders should be provided in advance with training and equipment to respond safely to such releases. Employees should be warned about the toxicity of gases used by the industry and trained to protect themselves from potential releases, both at low levels associated with chronic toxicity as well as higher levels with acute toxicity. I am surprised and disappointed that no chapter is listed for Wastewater and Stormwater. The release of toxic contaminants through water pathways is one of the most serious threats of semiconductor productions. Releases of certain contaminants in wastewater could compromise the operations of the Oak Orchard Wastewater Treatment Plant, even undermining compliance with its discharge permit. The draft Scope of Work mentions industrial pre-treatment. Not only should that be described in an environmental review chapter, but the review should identify ways to pre-treat hazardous chemicals, perhaps even reusing some, before comingling with other wastes. This is particularly important for PFAS, because in the future more PFAS compounds are likely to be subjected to enforceable environmental standards, many at very low concentrations. In fact, given the vast number of PFAS used by the semiconductor industry, the Review should identify methods for sampling total organic fluorine, not just targeted compounds. “At present, only a small percentage of PFAS compounds within typical semiconductor wastewater are detectable and quantifiable using conventional U.S. EPA analytical methods for PFAS-containing 5 “Background on Semiconductor Manufacturing and PFAS,” SIA PFAS Consortium, May 17, 2023, p. 30. 436 4 I am surprised and disappointed that no chapter is listed for Wastewater and Stormwater. The release of toxic contaminants through water pathways is one of the most serious threats of semiconductor productions. Releases of certain contaminants in wastewater could compromise the operations of the Oak Orchard Wastewater Treatment Plant, even undermining compliance with its discharge permit. The draft Scope of Work mentions industrial pre-treatment. Not only should that be described in an environmental review chapter, but the review should identify ways to pre-treat hazardous chemicals, perhaps even reusing some, before comingling with other wastes. This is particularly important for PFAS, because in the future more PFAS compounds are likely to be subjected to enforceable environmental standards, many at very low concentrations. In fact, given the vast number of PFAS used by the semiconductor industry, the Review should identify methods for sampling total organic fluorine, not just targeted compounds. “At present, only a small percentage of PFAS compounds within typical semiconductor wastewater are detectable and quantifiable using conventional U.S. EPA analytical methods for PFAS-containing 5 “Background on Semiconductor Manufacturing and PFAS,” SIA PFAS Consortium, May 17, 2023, p. 30. 436 4 materials.”6 However, U.S. EPA has a draft method (1621) for measuring total organic fluorine.7 Furthermore, academic researchers are finding that failure to measure total fluorine misses discharges of significant quantities of PFAS pollutants. “[B]ecause many studies of total organic fluorine have shown that total PFAS concentrations are at least 10 times higher than the sum of target PFASs. However, this does reinforce the idea that PFAS monitoring should incorporate complementary target and nontarget analyses or otherwise include measures of total organic fluorine to accurately assess PFAS abundance and potential environmental impacts.”8 Furthermore, there should be a chapter on Life-Cycle Environmental Impacts. What hazardous substances remain in the finished semiconductor products, including packaging. At the end-of- life, are there mechanisms for preventing the environmental release of semiconductor hazardous substances? Industry’s PFAS Consortium reports, “At the end-of-life of the product containing the semiconductor, or any parts replaced during the manufacture of semiconductors, would enter waste disposal streams where any PFAS contained therein could enter the environment.”9 Are manufacturers responsible for end-of-life pollution? materials.”6 However, U.S. EPA has a draft method (1621) for measuring total organic fluorine.7 Furthermore, academic researchers are finding that failure to measure total fluorine misses discharges of significant quantities of PFAS pollutants. “[B]ecause many studies of total organic fluorine have shown that total PFAS concentrations are at least 10 times higher than the sum of target PFASs. However, this does reinforce the idea that PFAS monitoring should incorporate complementary target and nontarget analyses or otherwise include measures of total organic fluorine to accurately assess PFAS abundance and potential environmental impacts.”8 Furthermore, there should be a chapter on Life-Cycle Environmental Impacts. What hazardous substances remain in the finished semiconductor products, including packaging. At the end-of- life, are there mechanisms for preventing the environmental release of semiconductor hazardous substances? Industry’s PFAS Consortium reports, “At the end-of-life of the product containing the semiconductor, or any parts replaced during the manufacture of semiconductors, would enter waste disposal streams where any PFAS contained therein could enter the environment.”9 Are manufacturers responsible for end-of-life pollution? Finally, there are those who argue that a thorough environmental review, as I have suggested, would unnecessarily delay the operation of new, advanced wafer fabrication plants. I find it hard to believe that documenting potential hazardous substance and waste impacts in advance would hamper the construction of a factory that is not expected to begin production until 2032. Micron—indeed, all semiconductor manufacturers—should already know what hazardous substances it uses and releases. Shouldn’t the public also know? The semiconductor and computer manufacturing industry, such as IBM’s complex in Endicott, New York, has a long history of causing pollution that threatens public health and the environment. An industry that claims that PFAS—chemicals that are persistent, bioaccumulative, and extremely toxic in low concentrations—are essential to its operations should be required to come clean about its environmental and public health hazards. Finally, there are those who argue that a thorough environmental review, as I have suggested, would unnecessarily delay the operation of new, advanced wafer fabrication plants. I find it hard to believe that documenting potential hazardous substance and waste impacts in advance would hamper the construction of a factory that is not expected to begin production until 2032. Micron—indeed, all semiconductor manufacturers—should already know what hazardous substances it uses and releases. Shouldn’t the public also know? The semiconductor and computer manufacturing industry, such as IBM’s complex in Endicott, New York, has a long history of causing pollution that threatens public health and the environment. An industry that claims that PFAS—chemicals that are persistent, bioaccumulative, and extremely toxic in low concentrations—are essential to its operations should be required to come clean about its environmental and public health hazards. 6 “PFOS and PFOA Conversion to Short-Chain PFAS-Containing Materials Used in Semiconductor Manufacturing,” SIA PFAS Consortium, June 5, 2023, p. 11. 7 Draft Method 1621: Screening Method for the Determination of Adsorbable Organic Fluorine (AOF) in Aqueous Matrices by Combustion Ion Chromatography (CIC), U.S. EPA, April 2022, https://www.epa.gov/system/files/documents/2022-04/draft-method-1621-for-screening-aof- in-aqueous-matrices-by-cic_0.pdf 8 Paige Jacob, Kristas Barzen-Hanson, and Damian Helbling, “Target and Nontarget Analysis of Per- and Polyfluoralkyl Substances in Wastewater from Electronics Fabrication Facilities,” Environmental Science & Technology, February 16, 2021, p. 2353. https://pubs.acs.org/doi/10.1021/acs.est.0c06690 9 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 90, 437 6 “PFOS and PFOA Conversion to Short-Chain PFAS-Containing Materials Used in Semiconductor Manufacturing,” SIA PFAS Consortium, June 5, 2023, p. 11. 7 Draft Method 1621: Screening Method for the Determination of Adsorbable Organic Fluorine (AOF) in Aqueous Matrices by Combustion Ion Chromatography (CIC), U.S. EPA, April 2022, https://www.epa.gov/system/files/documents/2022-04/draft-method-1621-for-screening-aof- in-aqueous-matrices-by-cic_0.pdf 8 Paige Jacob, Kristas Barzen-Hanson, and Damian Helbling, “Target and Nontarget Analysis of Per- and Polyfluoralkyl Substances in Wastewater from Electronics Fabrication Facilities,” Environmental Science & Technology, February 16, 2021, p. 2353. https://pubs.acs.org/doi/10.1021/acs.est.0c06690 9 “The Impact of a Potential PFAS Restriction on the Semiconductor Sector,” SIA PFAS Consortium, April 13, 2023, p. 90, 437 REVIEW Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng Cornell University, Department of Material Science and Engineering, Ithaca, New York, United States REVIEW Review of essential use of fluorochemicals in lithographic patterning and semiconductor processing Christopher K. Ober ,* Florian Käfer , and Jingyuan Deng Cornell University, Department of Material Science and Engineering, Ithaca, New York, United States Abstract. We identify and describe categories of fluorochemicals used to produce advanced semiconductors within the lithographic patterning manufacturing processes. Topics discussed include the per- and polyfluoroalkyl substance (PFAS) materials used and their necessary attrib- utes for successful semiconductor manufacturing, consisting of photoacid generators, fluorinated polyimides, poly(benzoxazole)s, antireflection coatings, topcoats, and embedded barrier layers, fluorinated surfactants, and materials for nanoimprint lithography. In particular, an explanation is given of the particular function that these PFAS materials contribute. It is noted that in almost all cases fluorine-free alternatives are very unlikely to provide the essential properties present in PFAS systems. Nonfluorinated alternative compounds are discussed where available. Finally, a summary table is provided listing the families of materials discussed, the critical purpose served, what the PFAS compound provides, and the prospects for alternatives. © The Authors. Published by SPIE under a Creative Commons Attribution 4.0 International License. Distribution or repro- duction of this work in whole or in part requires full attribution of the original publication, including its DOI. [DOI: 10.1117/1.JMM.21.1.010901] Keywords: fluorochemicals; per- and polyfluoroalkyl substance; photolithography; semicon- ductor processing. Paper 22003V received Jan. 21, 2022; accepted for publication Mar. 3, 2022; published online Mar. 31, 2022. Abstract. We identify and describe categories of fluorochemicals used to produce advanced semiconductors within the lithographic patterning manufacturing processes. Topics discussed include the per- and polyfluoroalkyl substance (PFAS) materials used and their necessary attrib- utes for successful semiconductor manufacturing, consisting of photoacid generators, fluorinated polyimides, poly(benzoxazole)s, antireflection coatings, topcoats, and embedded barrier layers, fluorinated surfactants, and materials for nanoimprint lithography. In particular, an explanation is given of the particular function that these PFAS materials contribute. It is noted that in almost all cases fluorine-free alternatives are very unlikely to provide the essential properties present in PFAS systems. Nonfluorinated alternative compounds are discussed where available. Finally, a summary table is provided listing the families of materials discussed, the critical purpose served, what the PFAS compound provides, and the prospects for alternatives. © The Authors. Published by SPIE under a Creative Commons Attribution 4.0 International License. Distribution or repro- duction of this work in whole or in part requires full attribution of the original publication, including its DOI. [DOI: 10.1117/1.JMM.21.1.010901] Keywords: fluorochemicals; per- and polyfluoroalkyl substance; photolithography; semicon- ductor processing. Paper 22003V received Jan. 21, 2022; accepted for publication Mar. 3, 2022; published online Mar. 31, 2022. 1 Introduction The use of fluorochemicals in lithography and semiconductor patterning plays a critical role in the success of semiconductor technology. The addition of small quantities of fluorinated mate- rials enables patterning capabilities that are otherwise not possible to achieve, and this leads to superior device performance. The compact size of the fluorine atom and its strong electron- withdrawing characteristics make it stand out in the periodic table and gives fluorocarbon mate- rials unique properties, unmatched by other chemical compounds. Fluorochemicals have found use in semiconductor processing for good technical reasons. 1 Introduction The use of fluorochemicals in lithography and semiconductor patterning plays a critical role in the success of semiconductor technology. The addition of small quantities of fluorinated mate- rials enables patterning capabilities that are otherwise not possible to achieve, and this leads to superior device performance. The compact size of the fluorine atom and its strong electron- withdrawing characteristics make it stand out in the periodic table and gives fluorocarbon mate- rials unique properties, unmatched by other chemical compounds. Fluorochemicals have found use in semiconductor processing for good technical reasons. 1. The presence of fluorine near acidic groups can convert them from an acid to a superacid, an essential characteristic for photoacid generators (PAGs) needed in advanced photoresists. 2. Fluorocarbon materials have low surface energy characteristics and act as superior barrier layers (including water repellence), which provide useful properties in photoresists and in antireflection coatings used in immersion lithography while also providing excellent release properties because they do not adhere strongly to other materials. 3. Fluorinated materials have unique solubility characteristics and can prevent intermixing between layers in a complex system such as an antireflection coating. Fluorinated materi- als are both hydrophobic and oleophobic and thus have reduced or no miscibility with essentially all fluorine-free classes of polymers. 4. Fluoropolymers have a low refractive index compared with any material except air and provide useful optical properties in photoresists and antireflection coatings. 5. They possess low dielectric constant and are especially good electrical insulators, an important feature when polyimides are patterned and retained in the final device. 1. The presence of fluorine near acidic groups can convert them from an acid to a superacid, an essential characteristic for photoacid generators (PAGs) needed in advanced photoresists. 2. Fluorocarbon materials have low surface energy characteristics and act as superior barrier layers (including water repellence), which provide useful properties in photoresists and in antireflection coatings used in immersion lithography while also providing excellent release properties because they do not adhere strongly to other materials. 3. Fluorinated materials have unique solubility characteristics and can prevent intermixing between layers in a complex system such as an antireflection coating. Fluorinated materi- als are both hydrophobic and oleophobic and thus have reduced or no miscibility with essentially all fluorine-free classes of polymers. 4. Fluoropolymers have a low refractive index compared with any material except air and provide useful optical properties in photoresists and antireflection coatings. 5. They possess low dielectric constant and are especially good electrical insulators, an important feature when polyimides are patterned and retained in the final device. *Address all correspondence to Christopher K. Ober, c.ober@cornell.edu J. Micro/Nanopattern. Mater. Metrol. 010901-1 Jan–Mar 2022 • Vol. 21(1) 438 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . *Address all correspondence to Christopher K. Ober, c.ober@cornell.edu J. Micro/Nanopattern. Mater. Metrol. 010901-1 Jan–Mar 2022 • Vol. 21(1) 438 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . This document provides a systematic overview of the photolithography process and key fluorinated materials involved, provides insight into performance requirements, and describes why fluorinated chemicals help achieve needed characteristics. Photolithography, a critical process step in the production of a semiconductor, uses a photo- resist to transfer a pattern. The primary component of a photoresist is a photopolymer whose solubility will be changed upon exposure to short wavelength radiation. In addition, the photo- resist contains a deposition solvent and several small-molecule compounds. The desired solu- bility change must be great enough that a developer (a solvent that removes the unwanted region of a resist pattern) does not swell the remaining photoresist. The development process must be able to discriminate between exposed and unexposed regions as small as a few nanometers in size. The unremoved photoresist must protect the underlying substrate from the next process steps in semiconductor manufacturing. Each stage in the process must be virtually perfect with yields well above 99%, because there may be hundreds of process steps used to manufacture each advanced semiconductor device. Without those very high yields, semiconductor manufac- turing would fail. The basic lithography process used globally today for advanced semiconductor manufactur- ing and the foreseeable future employs chemically amplified photoresists. Chemical amplifica- tion was a key invention needed to overcome the challenge of limited light sources but was also found to provide superior patterning performance. In such resist systems a photopolymer that contains acid cleavable protecting groups is combined with a photoactive compound, such as a PAG. In its native state, the photoresist polymer with protecting groups is soluble in organic solvents. Upon exposure to UV radiation, the PAG releases acid. Frequently, a subsequent post- exposure bake (PEB) step leads to the acid-catalyzed removal of protecting groups, thereby transforming the hydrophobic photopolymer into one that is soluble in an aqueous base devel- oper. The single photon of light needed to release one acidic proton is “amplified” by the more efficient acid-catalyzed deprotection process. By transforming the solubility of the photoresist, a high contrast patterning process needed in semiconductor manufacturing becomes possible. The combination of photoresist polymer and PAG to make the photoresist system is an essential part of this process and fluorination in the PAG provides the high acidity necessary for chemical amplification to work and will be described subsequently. The lithographic process is a complex series of steps requiring, at times, several complex properties in a single material or other cases combination of different materials used in the same process step. An example of the latter can be represented by the use of an antireflective coating in combination with a photoresist. An antireflection coating (ARC) is important to prevent light reflected from the semiconductor substrate, which would otherwise alter the very precise molecular scale patterns required for today’s semiconductor devices. An ARC does this by min- imizing the refractive index difference across each interface of all layers in the system. As an example, a top ARC (TARC) is a layer that sits on top of the already complex photoresist. It must not intermix with the photoresist, and it can also serve as a protective layer for this complex, multilayer lithographic system. Finally, it must be easily removed. Only a fluorinated material has a significantly lower refractive index and fluorination also provides these additional proper- ties. More details for ARCs will be discussed below. Additional uses of fluorochemicals in photolithography processes are also discussed in this paper. It is worth noting that while there are many types of fluorochemicals, our survey of the technical literature reveals that there are several specific examples of fluorocompounds that are currently in use by the semiconductor industry in the lithography process including (1) perfluor- oalkyl acid compounds (C4 or less), used in PAGs; (2) hexafluoroisopropanol, fluorotelomers, and fluoroacrylate side-chain units may be used in photoresists to incorporate specific function- alities including barrier properties and low surface energy; (3) hexafluoropropyl units are used in sub-units of some classes of polyimides for thermal stability and low dielectric constant; (4) spe- cialized per- and polyfluoroalkyl substances (PFAS) are used in ARCs; (5) PFAS are also include surfactants (used as coating leveling agents) to improve coating uniformity in a number of prod- ucts used in lithographic processes. A key feature of the addition of a fluorinated component is that its addition provides a necessary additional characteristic to the material while minimally compromising its other critical properties. Examples of these materials and uses are tabulated in This document provides a systematic overview of the photolithography process and key fluorinated materials involved, provides insight into performance requirements, and describes why fluorinated chemicals help achieve needed characteristics. Photolithography, a critical process step in the production of a semiconductor, uses a photo- resist to transfer a pattern. The primary component of a photoresist is a photopolymer whose solubility will be changed upon exposure to short wavelength radiation. In addition, the photo- resist contains a deposition solvent and several small-molecule compounds. The desired solu- bility change must be great enough that a developer (a solvent that removes the unwanted region of a resist pattern) does not swell the remaining photoresist. The development process must be able to discriminate between exposed and unexposed regions as small as a few nanometers in size. The unremoved photoresist must protect the underlying substrate from the next process steps in semiconductor manufacturing. Each stage in the process must be virtually perfect with yields well above 99%, because there may be hundreds of process steps used to manufacture each advanced semiconductor device. Without those very high yields, semiconductor manufac- turing would fail. The basic lithography process used globally today for advanced semiconductor manufactur- ing and the foreseeable future employs chemically amplified photoresists. Chemical amplifica- tion was a key invention needed to overcome the challenge of limited light sources but was also found to provide superior patterning performance. In such resist systems a photopolymer that contains acid cleavable protecting groups is combined with a photoactive compound, such as a PAG. In its native state, the photoresist polymer with protecting groups is soluble in organic solvents. Upon exposure to UV radiation, the PAG releases acid. Frequently, a subsequent post- exposure bake (PEB) step leads to the acid-catalyzed removal of protecting groups, thereby transforming the hydrophobic photopolymer into one that is soluble in an aqueous base devel- oper. The single photon of light needed to release one acidic proton is “amplified” by the more efficient acid-catalyzed deprotection process. By transforming the solubility of the photoresist, a high contrast patterning process needed in semiconductor manufacturing becomes possible. The combination of photoresist polymer and PAG to make the photoresist system is an essential part of this process and fluorination in the PAG provides the high acidity necessary for chemical amplification to work and will be described subsequently. The lithographic process is a complex series of steps requiring, at times, several complex properties in a single material or other cases combination of different materials used in the same process step. An example of the latter can be represented by the use of an antireflective coating in combination with a photoresist. An antireflection coating (ARC) is important to prevent light reflected from the semiconductor substrate, which would otherwise alter the very precise molecular scale patterns required for today’s semiconductor devices. An ARC does this by min- imizing the refractive index difference across each interface of all layers in the system. As an example, a top ARC (TARC) is a layer that sits on top of the already complex photoresist. It must not intermix with the photoresist, and it can also serve as a protective layer for this complex, multilayer lithographic system. Finally, it must be easily removed. Only a fluorinated material has a significantly lower refractive index and fluorination also provides these additional proper- ties. More details for ARCs will be discussed below. Additional uses of fluorochemicals in photolithography processes are also discussed in this paper. It is worth noting that while there are many types of fluorochemicals, our survey of the technical literature reveals that there are several specific examples of fluorocompounds that are currently in use by the semiconductor industry in the lithography process including (1) perfluor- oalkyl acid compounds (C4 or less), used in PAGs; (2) hexafluoroisopropanol, fluorotelomers, and fluoroacrylate side-chain units may be used in photoresists to incorporate specific function- alities including barrier properties and low surface energy; (3) hexafluoropropyl units are used in sub-units of some classes of polyimides for thermal stability and low dielectric constant; (4) spe- cialized per- and polyfluoroalkyl substances (PFAS) are used in ARCs; (5) PFAS are also include surfactants (used as coating leveling agents) to improve coating uniformity in a number of prod- ucts used in lithographic processes. A key feature of the addition of a fluorinated component is that its addition provides a necessary additional characteristic to the material while minimally compromising its other critical properties. Examples of these materials and uses are tabulated in J. Micro/Nanopattern. Mater. Metrol. 010901-2 Jan–Mar 2022 • Vol. 21(1) 439 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-2 Jan–Mar 2022 • Vol. 21(1) 439 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . the Appendix. This paper discusses current PFAS use in the field of photolithography, explains why certain materials are used, reviews in part the current understanding of PFAS degradation during processing, and where possible, identifies alternative materials. One of the special features of the C─F bond is its strength compared with the C─C bond due to the electron-withdrawing power of the fluorine atom. This attribute is the basis of many of the technical benefits of fluorinated materials in semiconductor processing but leads to its chemical stability and environmental persistence. Fluorination brings specific improvement in perfor- mance, and its targeted incorporation can minimize the quantities of material needed to achieve that performance. Such aspects are discussed in the context of PAGs. Thus, despite the remark- able performance improvement in many aspects of the lithographic process provided by fluo- rochemicals (PFAS) that makes possible the semiconductor revolution with its benefit to society, the large and growing environmental and societal concerns surrounding PFAS may counterbal- ance the positive technological benefits of these materials. The reader is referred to a discussion of such PFAS concerns in a well-written review article, but photolithography chemicals are largely glossed over.1 Going forward, due to environmental and regulatory concerns, perfor- mance equivalent alternatives for many of these applications still need to be identified and this will be a major research challenge. This paper presents a detailed discussion of the different types of PFAS used in advanced lithographic patterning and semiconductor manufacturing paying specific attention to the unique physical-chemical attributes of these chemistries that make them essential for semiconductor manufacturing. Specifically, we break the PFAS used in semiconductor manufacturing into six main categories of fluorochemicals used in photolithography and semiconductor patterning. For each category, we discuss the critical function served by the fluorochemicals and why the spe- cific fluorocompounds are used, based on the unique properties provided by the chemical. However, it is worth noting that there are required processes in the semiconductor manufactory using per-fluorinated compounds such as etch gases for metal etching, wet cleaning chemicals to clean and condition substrate, and other minor processes that are not covered further in this paper. Based on concerns regarding the high persistence, bioaccumulation potential, and potential toxicity of PFAS studied to date, it has been suggested that the use of PFAS be limited to essen- tial uses only. We discuss whether viable alternatives exist for each of these applications and the character- istics that must be achieved to find an alternative compound where none currently exists. Finally, we apply the essential use concept described by Cousins et al.2 to show that these compounds should be considered essential for certain processes in semiconductor manufacturing (i.e., photo- lithography and patterning) because they provide for vital functions and are currently without established alternatives. The prior paper did an excellent job of discussing different aspects of PFAS use. In this paper, we focus our discussion of essential use as “necessary for highly impor- tant purposes in semiconductor manufacturing for which alternatives are not yet established.” We describe the many uses and unique properties of PFAS chemicals, which in our opinion justifies their current use as essential in microelectronics manufacturing and for which alterna- tives have not yet been adequately identified. This paper is not intended to be an extensive listing of every example of fluorochemical used in photolithography but does attempt to explain strat- egies and classes of material used in the manufacturing of semiconductors. the Appendix. This paper discusses current PFAS use in the field of photolithography, explains why certain materials are used, reviews in part the current understanding of PFAS degradation during processing, and where possible, identifies alternative materials. One of the special features of the C─F bond is its strength compared with the C─C bond due to the electron-withdrawing power of the fluorine atom. This attribute is the basis of many of the technical benefits of fluorinated materials in semiconductor processing but leads to its chemical stability and environmental persistence. Fluorination brings specific improvement in perfor- mance, and its targeted incorporation can minimize the quantities of material needed to achieve that performance. Such aspects are discussed in the context of PAGs. Thus, despite the remark- able performance improvement in many aspects of the lithographic process provided by fluo- rochemicals (PFAS) that makes possible the semiconductor revolution with its benefit to society, the large and growing environmental and societal concerns surrounding PFAS may counterbal- ance the positive technological benefits of these materials. The reader is referred to a discussion of such PFAS concerns in a well-written review article, but photolithography chemicals are largely glossed over.1 Going forward, due to environmental and regulatory concerns, perfor- mance equivalent alternatives for many of these applications still need to be identified and this will be a major research challenge. This paper presents a detailed discussion of the different types of PFAS used in advanced lithographic patterning and semiconductor manufacturing paying specific attention to the unique physical-chemical attributes of these chemistries that make them essential for semiconductor manufacturing. Specifically, we break the PFAS used in semiconductor manufacturing into six main categories of fluorochemicals used in photolithography and semiconductor patterning. For each category, we discuss the critical function served by the fluorochemicals and why the spe- cific fluorocompounds are used, based on the unique properties provided by the chemical. However, it is worth noting that there are required processes in the semiconductor manufactory using per-fluorinated compounds such as etch gases for metal etching, wet cleaning chemicals to clean and condition substrate, and other minor processes that are not covered further in this paper. Based on concerns regarding the high persistence, bioaccumulation potential, and potential toxicity of PFAS studied to date, it has been suggested that the use of PFAS be limited to essen- tial uses only. We discuss whether viable alternatives exist for each of these applications and the character- istics that must be achieved to find an alternative compound where none currently exists. Finally, we apply the essential use concept described by Cousins et al.2 to show that these compounds should be considered essential for certain processes in semiconductor manufacturing (i.e., photo- lithography and patterning) because they provide for vital functions and are currently without established alternatives. The prior paper did an excellent job of discussing different aspects of PFAS use. In this paper, we focus our discussion of essential use as “necessary for highly impor- tant purposes in semiconductor manufacturing for which alternatives are not yet established.” We describe the many uses and unique properties of PFAS chemicals, which in our opinion justifies their current use as essential in microelectronics manufacturing and for which alterna- tives have not yet been adequately identified. This paper is not intended to be an extensive listing of every example of fluorochemical used in photolithography but does attempt to explain strat- egies and classes of material used in the manufacturing of semiconductors. 2 Photoacid Generators PAGs are photoactive compounds that generate acids upon exposure to high-energy light [deep ultraviolet (DUV) or extreme ultraviolet (EUV)]. These photoactive compounds were originally used for applications in photopolymerization in the early 1960s.3 After the introduction of chemically amplified resists (CARs) in the 1980s, they have been used in semiconductor manu- facturing as key components in advanced photoresists. It is important to understand that the process of chemical amplification requires a very strong acid in the PAG to function well. PAGs are now highly evolved with over 40 years of in-depth research and development for photoresist applications. A positive tone resist polymer after deprotection, for example, contains 2 Photoacid Generators PAGs are photoactive compounds that generate acids upon exposure to high-energy light [deep ultraviolet (DUV) or extreme ultraviolet (EUV)]. These photoactive compounds were originally used for applications in photopolymerization in the early 1960s.3 After the introduction of chemically amplified resists (CARs) in the 1980s, they have been used in semiconductor manu- facturing as key components in advanced photoresists. It is important to understand that the process of chemical amplification requires a very strong acid in the PAG to function well. PAGs are now highly evolved with over 40 years of in-depth research and development for photoresist applications. A positive tone resist polymer after deprotection, for example, contains J. Micro/Nanopattern. Mater. Metrol. 010901-3 Jan–Mar 2022 • Vol. 21(1) 440 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-3 Jan–Mar 2022 • Vol. 21(1) 440 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . weak acid groups that will act to buffer (weaken) the acidity of the deprotection process. Without the presence of the strong fluorosulfonic (or stronger) acid, the catalyzed deprotection process will be less efficient or may not even occur. Sulfonate anions without fluorination have repeat- edly been shown to be inadequate for use ineffective 193 nm chemically amplified photoresists and this is well known in the photoresist community. The unique characteristics of fluorine (noted below), which lead to very strong proton donation by fluorinated sulfonic acids, are essen- tial in CARs. This intrinsic benefit of fluorinated acids makes it extremely difficult to eliminate the use of fluorinated acids whilst retaining the key performance characteristics of CARs needed for advanced photolithography in microelectronics manufacturing. Other attributes of a PAG that depend less on the acid and more on the chromophore include quantum yield at the wavelength of use, the sensitivity of the overall resist formulation (e.g., 15 to 60 mJ∕cm2 ), miscibility in the resist matrix, thermal and hydrolytic stability and shelf life of the photoresist, solubility in aque- ous base developer for positive tone develop or organic solvent for negative tone development followed by removal in the resist strip operation. In general, PAGs are divided into two catego- ries: either ionic or covalent (nonionic) structures. As the name suggests, ionic PAGs consist of two portions: a cation and an anion. In addition, covalent PAGs are uncharged, nonpolar com- pounds that are constructed of covalent bonds but are generally less sensitive and therefore less effective than ionic PAGs. The availability of both ionic and covalent PAGs offers process flex- ibility. In some cases, the presence of ionic groups may lead to storage instability of the photo- resist mixture or the inhomogeneous distribution of photoactive compounds in the photoresist, thus making a nonionic PAG necessary. However, most photoresist compositions that are used in semiconductor manufacturing employ ionic PAGs because of their greater sensitivity. Examples of PAGs are shown in Figs. 1 (ionic) and (covalent). In either case, a fluorinated sulfonic acid would be used to make an effective PAG. The photoefficiency difference between ionic and covalent PAGs, which leads to higher quantum yields in the ionic PAG is controlled by the cation.4 The low diffusivity and high strength of the acid resulting from the photolysis of the cation are controlled by the resulting accompa- nying fluorosulfonate anion. These anions are used in virtually all current commercial photo- resists. Limited diffusivity is important to achieving high-resolution patterns because excess diffusion of the PAG has been shown to limit the resolution of the images produced in a CAR. While aromatic sulfonic esters are shown in some nonionic PAGs described in Fig. 2, the strength of the resulting sulfonic acid after photolysis is not as high as the ionic PAGs with fluorinated sulfonate anions. weak acid groups that will act to buffer (weaken) the acidity of the deprotection process. Without the presence of the strong fluorosulfonic (or stronger) acid, the catalyzed deprotection process will be less efficient or may not even occur. Sulfonate anions without fluorination have repeat- edly been shown to be inadequate for use ineffective 193 nm chemically amplified photoresists and this is well known in the photoresist community. The unique characteristics of fluorine (noted below), which lead to very strong proton donation by fluorinated sulfonic acids, are essen- tial in CARs. This intrinsic benefit of fluorinated acids makes it extremely difficult to eliminate the use of fluorinated acids whilst retaining the key performance characteristics of CARs needed for advanced photolithography in microelectronics manufacturing. Other attributes of a PAG that depend less on the acid and more on the chromophore include quantum yield at the wavelength of use, the sensitivity of the overall resist formulation (e.g., 15 to 60 mJ∕cm2 ), miscibility in the resist matrix, thermal and hydrolytic stability and shelf life of the photoresist, solubility in aque- ous base developer for positive tone develop or organic solvent for negative tone development followed by removal in the resist strip operation. In general, PAGs are divided into two catego- ries: either ionic or covalent (nonionic) structures. As the name suggests, ionic PAGs consist of two portions: a cation and an anion. In addition, covalent PAGs are uncharged, nonpolar com- pounds that are constructed of covalent bonds but are generally less sensitive and therefore less effective than ionic PAGs. The availability of both ionic and covalent PAGs offers process flex- ibility. In some cases, the presence of ionic groups may lead to storage instability of the photo- resist mixture or the inhomogeneous distribution of photoactive compounds in the photoresist, thus making a nonionic PAG necessary. However, most photoresist compositions that are used in semiconductor manufacturing employ ionic PAGs because of their greater sensitivity. Examples of PAGs are shown in Figs. 1 (ionic) and (covalent). In either case, a fluorinated sulfonic acid would be used to make an effective PAG. The photoefficiency difference between ionic and covalent PAGs, which leads to higher quantum yields in the ionic PAG is controlled by the cation.4 The low diffusivity and high strength of the acid resulting from the photolysis of the cation are controlled by the resulting accompa- nying fluorosulfonate anion. These anions are used in virtually all current commercial photo- resists. Limited diffusivity is important to achieving high-resolution patterns because excess diffusion of the PAG has been shown to limit the resolution of the images produced in a CAR. While aromatic sulfonic esters are shown in some nonionic PAGs described in Fig. 2, the strength of the resulting sulfonic acid after photolysis is not as high as the ionic PAGs with fluorinated sulfonate anions. O O S O O O F S F F F F O S F F S F O F F FO 1 4 O O S O O O F S F F F F O S F F S F O F F FO 1 4 O F O O S F F O S I O F F S O N Br F O O 2 5 O F O O S F F O S I O F F S O N Br F O O 2 5 F F F F F F I O O O S F S S O F O F FO F FO F 6 3 Fig. 1 Representative ionic PAGs: 1,2,3,4 Sulfonium PAG and 5,6 Iodonium PAG. F F F F F F I O O O S F S S O F O F FO F FO F 6 3 Fig. 1 Representative ionic PAGs: 1,2,3,4 Sulfonium PAG and 5,6 Iodonium PAG. J. Micro/Nanopattern. Mater. Metrol. 010901-4 Jan–Mar 2022 • Vol. 21(1) 441 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-4 Jan–Mar 2022 • Vol. 21(1) 441 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . O O O O O O O F F F F S S N S F O O O O O F F F F O 7 8 9 Fig. 2 Representative nonionic covalent PAGs. O O O O O O O F F F F S S N S F O O O O O F F F F O 7 8 9 Fig. 2 Representative nonionic covalent PAGs. Covalent PAGs do not suffer from the sorts of phase separation, low miscibility, and dark loss (the dissolution of unexposed photoresist) issues that may occur in ionic PAG-containing resist formulations, but the quantum yield of photoacid generation is generally lower for covalent PAGs so this and other factors drive the ultimate choice of PAG.5 In order to increase the acidity of the photoacid, perfluorinated methylene units may be placed next to the sulfonate group in both ionic and covalent PAGs. The polarization present in the C─F bond due to the electron- withdrawing character of fluorine stabilizes the acid anion and makes the acid stronger. A sulfonic acid such as methane sulfonic acid has a pK a of −2 (already a strong acid) but trifluor- omethyl sulfonic acid (triflic acid) has a pK a of −14. Any induction effect is significantly smaller after two or three CF2 units, so the relative benefit of fluorination is significantly reduced as the neighboring CF2 units are further away from the acid group. The original choice of longer sequence perfluorinated sulfonates (six or more) has not been explained in patents or the liter- ature but was likely due to the effectiveness of the resulting PAG, the reduced diffusivity because it is a larger molecule, its availability, and the lack of volatility in this material. For example, the volatility of the small triflate anion limits its use in a production photoresist PAG because the resulting concentration gradients in such photoresist films harm performance. However, shorter CF2 segments (1 or 2) next to the anion and connected to other units of higher mass have been shown to make effective PAGs (see Sec. 2.3).6 Finally, the diffusivity of the PAG will affect pattern resolution (less diffusion enhances resolution) and can be addressed by the use of a higher molar mass PAG/acid and even covalent attachment of the PAG to the photoresist polymer itself (see Sec. 2.4). Although actively used in some applications, triflic acid is not always a useful component in a PAG since it may have significant deficiencies when used in a very high-resolution CAR system; it is volatile and may evaporate during the PEB step leading to composition gradients that are detrimental to image resolution and it readily diffuses during annealing, which may, in turn, lead to pattern degradation from deprotection chemistry occurring in unexposed areas, effectively reducing image contrast and disrupting pattern formation. Covalent PAGs do not suffer from the sorts of phase separation, low miscibility, and dark loss (the dissolution of unexposed photoresist) issues that may occur in ionic PAG-containing resist formulations, but the quantum yield of photoacid generation is generally lower for covalent PAGs so this and other factors drive the ultimate choice of PAG.5 In order to increase the acidity of the photoacid, perfluorinated methylene units may be placed next to the sulfonate group in both ionic and covalent PAGs. The polarization present in the C─F bond due to the electron- withdrawing character of fluorine stabilizes the acid anion and makes the acid stronger. A sulfonic acid such as methane sulfonic acid has a pK a of −2 (already a strong acid) but trifluor- omethyl sulfonic acid (triflic acid) has a pK a of −14. Any induction effect is significantly smaller after two or three CF2 units, so the relative benefit of fluorination is significantly reduced as the neighboring CF2 units are further away from the acid group. The original choice of longer sequence perfluorinated sulfonates (six or more) has not been explained in patents or the liter- ature but was likely due to the effectiveness of the resulting PAG, the reduced diffusivity because it is a larger molecule, its availability, and the lack of volatility in this material. For example, the volatility of the small triflate anion limits its use in a production photoresist PAG because the resulting concentration gradients in such photoresist films harm performance. However, shorter CF2 segments (1 or 2) next to the anion and connected to other units of higher mass have been shown to make effective PAGs (see Sec. 2.3).6 Finally, the diffusivity of the PAG will affect pattern resolution (less diffusion enhances resolution) and can be addressed by the use of a higher molar mass PAG/acid and even covalent attachment of the PAG to the photoresist polymer itself (see Sec. 2.4). Although actively used in some applications, triflic acid is not always a useful component in a PAG since it may have significant deficiencies when used in a very high-resolution CAR system; it is volatile and may evaporate during the PEB step leading to composition gradients that are detrimental to image resolution and it readily diffuses during annealing, which may, in turn, lead to pattern degradation from deprotection chemistry occurring in unexposed areas, effectively reducing image contrast and disrupting pattern formation. 2.1 Ionic PAGs and Their Photochemistry Most ionic PAGs used in lithography are onium salt derivatives. Such ionic compounds consist of an onium moiety as the cation and sulfonate groups as the anion.4 Upon exposure, photolysis occurs and photoacid is formed. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. Returning to Fig. 1, ionic PAGs are generally composed of either diaryliodonium or triarylsulfonium photoactive units to form a salt with an appropriate anion. Triarylsulfonium PAGs usually have longer shelf life compared with diaryliodonium salt. However, a diaryliodonium salt has higher absorptivity in particular for next-generation 13.5-nm wavelength EUV photons. The mechanism of photolysis of diaryliodonium salt4 and triarylsul- fonium salts7,8 has been studied extensively. Reported photolysis mechanisms for diaryliodo- nium salt and triarylsulfonium salts are shown in Figs. 3 and 4, respectively. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. In Fig. 3, the energy required to cleave the aromatic C (sp2 ) and iodine bond is somewhat higher compared with the energy required to promote bond cleavage between the aromatic C (sp2 ) and sulfur bond (Fig. 4). 2.1 Ionic PAGs and Their Photochemistry Most ionic PAGs used in lithography are onium salt derivatives. Such ionic compounds consist of an onium moiety as the cation and sulfonate groups as the anion.4 Upon exposure, photolysis occurs and photoacid is formed. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. Returning to Fig. 1, ionic PAGs are generally composed of either diaryliodonium or triarylsulfonium photoactive units to form a salt with an appropriate anion. Triarylsulfonium PAGs usually have longer shelf life compared with diaryliodonium salt. However, a diaryliodonium salt has higher absorptivity in particular for next-generation 13.5-nm wavelength EUV photons. The mechanism of photolysis of diaryliodonium salt4 and triarylsul- fonium salts7,8 has been studied extensively. Reported photolysis mechanisms for diaryliodo- nium salt and triarylsulfonium salts are shown in Figs. 3 and 4, respectively. The quantum yield of the photoacid is directly impacted by the cation fragment. The acidity of the generated photoacid as noted above is controlled by the anionic fragment in the PAG (usually a fluorinated sulfonic acid). The rate of photoacid release is controlled by both cation and anion. In Fig. 3, the energy required to cleave the aromatic C (sp2 ) and iodine bond is somewhat higher compared with the energy required to promote bond cleavage between the aromatic C (sp2 ) and sulfur bond (Fig. 4). J. Micro/Nanopattern. Mater. Metrol. 010901-5 Jan–Mar 2022 • Vol. 21(1) 442 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 3 Proposed photolysis mechanism for diaryliodonium salt under DUV exposure. Reproduced from Ref. 8. S O3S(CF2)3CF3 hv hv S S hv S 1% J. Micro/Nanopattern. Mater. Metrol. 010901-5 Jan–Mar 2022 • Vol. 21(1) 442 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 3 Proposed photolysis mechanism for diaryliodonium salt under DUV exposure. Reproduced from Ref. 8. S O3S(CF2)3CF3 hv hv S S hv S 1% 3% 20% 7% S 1% Primary photoproducts 2% Secondary photoproducts S Polymer 1% In-cage products Cage-escape products Fig. 4 Proposed photolysis mechanism for triarylsulfonium salt in solid poly(methyl methacrylate) matrix exposed to 266-nm irradiation (2631 mJ · cm−2 ). Reproduced from Ref. 9. 3% 20% 7% S 1% Primary photoproducts 2% Secondary photoproducts S Polymer 1% In-cage products Cage-escape products Fig. 4 Proposed photolysis mechanism for triarylsulfonium salt in solid poly(methyl methacrylate) matrix exposed to 266-nm irradiation (2631 mJ · cm−2 ). Reproduced from Ref. 9. Generally, the sulfonium PAG family is more widely used than iodonium PAGs considering its greater sensitivity and longer shelf life when used in either DUV or EUV lithography. Reference 8 reports solution results for exposure of the triphenylsulfonium cation. More recent results of solid-state polymer matrix results are shown in Fig. 4.9 Solid-state studies at 193, 248, and 266 nm exposures reveal additional products including in all cases, two previously unre- ported Triphenyl sulfonium photoproducts, triphenylene, and dibenzothiophene. Generally, the sulfonium PAG family is more widely used than iodonium PAGs considering its greater sensitivity and longer shelf life when used in either DUV or EUV lithography. Reference 8 reports solution results for exposure of the triphenylsulfonium cation. More recent results of solid-state polymer matrix results are shown in Fig. 4.9 Solid-state studies at 193, 248, and 266 nm exposures reveal additional products including in all cases, two previously unre- ported Triphenyl sulfonium photoproducts, triphenylene, and dibenzothiophene. 2.2 Nonionic Covalent PAGs and Their Photochemistry Although ionic PAGs have higher sensitivity in lithographic applications, they may be less solu- ble and more prone to phase separation in photoresist formulations. It is worth recalling that the PAG is needed to generate acid in the exposed regions to deprotect the photoresist and thereby change its solubility. Uniform distribution of a PAG is an essential attribute to excellent perfor- mance in a photoresist. Detrimental interaction between ionic structures in a photoresist and an ionic PAG may also occur in future resist materials.10 To overcome such issues, covalent PAGs J. Micro/Nanopattern. Mater. Metrol. 010901-6 Jan–Mar 2022 • Vol. 21(1) 443 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use 2.2 Nonionic Covalent PAGs and Their Photochemistry Although ionic PAGs have higher sensitivity in lithographic applications, they may be less solu- ble and more prone to phase separation in photoresist formulations. It is worth recalling that the PAG is needed to generate acid in the exposed regions to deprotect the photoresist and thereby change its solubility. Uniform distribution of a PAG is an essential attribute to excellent perfor- mance in a photoresist. Detrimental interaction between ionic structures in a photoresist and an ionic PAG may also occur in future resist materials.10 To overcome such issues, covalent PAGs J. Micro/Nanopattern. Mater. Metrol. 010901-6 Jan–Mar 2022 • Vol. 21(1) 443 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Pathway A 2 (2) H2O Ar + H2SO3 Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Pathway A 2 (2) H2O Ar + H2SO3 O O O Ar Irradiation Ar Ar S S + S O O O O O O H2O / O2 O Ar + S OH HO O Photoacid generation Pathway B O O O Ar Irradiation Ar Ar S S + S O O O O O O H2O / O2 O Ar + S OH HO O Photoacid generation Pathway B O O O Ar Ar Ar Irradiation + S S S OH O O O O O Photoacid generation Fig. 5 Photoacid generation mechanism for arylsulfonate esters. O O O Ar Ar Ar Irradiation + S S S OH O O O O O Photoacid generation Fig. 5 Photoacid generation mechanism for arylsulfonate esters. O N O S R O Iminosulfonates Irradiation O O O S R HO S R O O O O N O S R Photoacid generation O O Imidosulfonates Fig. 6 Photoacid generation mechanism for iminosulfonates and imidosulfonates. O N O S R O Iminosulfonates Irradiation O O O S R HO S R O O O O N O S R Photoacid generation O O Imidosulfonates Fig. 6 Photoacid generation mechanism for iminosulfonates and imidosulfonates. may be attractive alternatives.4 In general, covalent PAGs are derivatives of arylsulfonates,11 iminosulfonates,12 and imidosulfonates.13 Arylsulfonate esters can be easily synthesized from phenol and sulfonyl chlorides. A similar effort to create fluorinated sulfonate ester-containing covalent PAGs has not taken place because such PAGs have not been as effective in photoresist applications. The photoacid generation mechanism is proposed based on the nonfries photolytic ArO─S bond cleavage (pathway A) or pseudofries rearrangement (pathway B), which is more likely to occur for electron-rich aryl sulfonates as shown in Fig. 5.14,15 It is worth noting that in pathway A, in the presence of oxygen and water, stronger sulfonic acid is generated. In the absence of oxygen, weaker sulfurous acid is produced. Iminosulfonates and imidosulfonates have similar chemical structures with the N─O bond undergoing homolytic cleavage upon irradiation to generate sulfonyloxy radicals, which subsequently capture hydro- gens from nearby molecules to afford the corresponding sulfonic acid as shown in Fig. 6. may be attractive alternatives.4 In general, covalent PAGs are derivatives of arylsulfonates,11 iminosulfonates,12 and imidosulfonates.13 Arylsulfonate esters can be easily synthesized from phenol and sulfonyl chlorides. A similar effort to create fluorinated sulfonate ester-containing covalent PAGs has not taken place because such PAGs have not been as effective in photoresist applications. The photoacid generation mechanism is proposed based on the nonfries photolytic ArO─S bond cleavage (pathway A) or pseudofries rearrangement (pathway B), which is more likely to occur for electron-rich aryl sulfonates as shown in Fig. 5.14,15 It is worth noting that in pathway A, in the presence of oxygen and water, stronger sulfonic acid is generated. In the absence of oxygen, weaker sulfurous acid is produced. Iminosulfonates and imidosulfonates have similar chemical structures with the N─O bond undergoing homolytic cleavage upon irradiation to generate sulfonyloxy radicals, which subsequently capture hydro- gens from nearby molecules to afford the corresponding sulfonic acid as shown in Fig. 6. 2.3 Alternatives to Current PAGs PAGs other than iodonium and sulfonium units as well as those that do not contain traditional PFAS have also been studied for use in photolithography. To be used successfully in a CAR photoresist, the resulting acid must be as acidic as a perfluorosulfonic acid, lack volatility so that it does not evaporate during the PEB step, and in the next generation photoresists possess minimum diffusivity (to enable high-resolution pattern formation). The PAG-resist combination should have a sensitivity in the range between 10 and 75 mJ∕cm2 under exposure conditions i.e., the source wavelength and tool-specific settings. Some new photoresists attach the PAG directly to the photopolymer chain to both limit diffusion and deal with issues of stochastic variations that may be present in photoresists consisting of mixtures of polymer and photoactive molecules. Nontraditional PFAS Covalent PAGs: Nitrobenzyl esters have found some application in DUVL and may be extendable to EUV lithography.10 Such molecules can generate photoacid 2.3 Alternatives to Current PAGs PAGs other than iodonium and sulfonium units as well as those that do not contain traditional PFAS have also been studied for use in photolithography. To be used successfully in a CAR photoresist, the resulting acid must be as acidic as a perfluorosulfonic acid, lack volatility so that it does not evaporate during the PEB step, and in the next generation photoresists possess minimum diffusivity (to enable high-resolution pattern formation). The PAG-resist combination should have a sensitivity in the range between 10 and 75 mJ∕cm2 under exposure conditions i.e., the source wavelength and tool-specific settings. Some new photoresists attach the PAG directly to the photopolymer chain to both limit diffusion and deal with issues of stochastic variations that may be present in photoresists consisting of mixtures of polymer and photoactive molecules. Nontraditional PFAS Covalent PAGs: Nitrobenzyl esters have found some application in DUVL and may be extendable to EUV lithography.10 Such molecules can generate photoacid J. Micro/Nanopattern. Mater. Metrol. 010901-7 Jan–Mar 2022 • Vol. 21(1) 444 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 7 Chemical structure for non-PFAS covalent PAGs: (a) nitrobenzyl ester and (b) terarylene backbone-based PAG. J. Micro/Nanopattern. Mater. Metrol. 010901-7 Jan–Mar 2022 • Vol. 21(1) 444 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 7 Chemical structure for non-PFAS covalent PAGs: (a) nitrobenzyl ester and (b) terarylene backbone-based PAG. upon irradiation through o-nitrobenzyl rearrangement to generate nitrobenzaldehyde and a sulfonic acid such as triflic acid shown in Fig. 7. The chemical structure is shown in Fig. 7(a). The terarylene skeleton-based self-contained PAG is another potential candidate for some applications. The photoacid generation is triggered by the 6π-electro-cyclization reaction of photochromic triangular terarylenes.16 The chemical structure is shown in Fig. 7(b). Similarly, a triflate ester is used in the reported structure to release triflic acid upon exposure. While these and other structures can be used to demonstrate PAG concepts, they are unlikely to be as useful in new high-resolution photoresist systems because they use triflate groups. Alternative acids may be used to make more suitable PAGs from the moieties in Fig. 7. Should a useful PAG be produced from these types of photoactive structures the resulting sulfonic acid will need to be less volatile and less mobile in the polymer film? A higher molar mass, much less volatile, lower diffusivity anion might work well with these mate- rials in a functioning photoresist system. Nontraditional PFAS Ionic PAGs: Ionic PAGs derived from 2-phenoxytetrafluoroethane sulfonate were introduced by Ober and coworkers in 2007.17 This PAG was tested under e-beam and EUV radiation and showed high sensitivity, resolution, and acceptably low line edge deviations. The use of such a fluorosulfonic acid has the advantage that it limits fluorine content yet produces a very strong acid with both limited volatility and diffusivity by placing a CF2 group next to the acid group. Such an approach (discussed more below) can be used to minimize fluorine incorporation while placing this structure where it is most valuable. Its chemical structure is shown in Fig. 8(a). This PAG was tested for its envi- ronmental degradation and its effect on bacterial populations when first reported and found to be benign under the rules of that time. The good lithographic results suggest that shorter fluorinated segments (two or possibly one CF2 unit adjacent to the sulfonic acid) may make useful ionic PAGs. It should be noted that the building blocks for sulfonic acids with one CF2 are the subject of experimental studies. The pentacyanocyclopentadienide PAG is another potential ionic PAG candidate in some applica- tions. Its lithographic performance was demonstrated by Varanasi and coworkers in 2010, and it stands out for the amount of publicity it received.18 The chemical structure is shown in Fig. 8(b). While announced in 2010 as part of IBM’s efforts to reduce Perfluorooctanoic acid (PFOA) in its manufacturing process, to the best of our knowledge, this PAG was not commercialized. upon irradiation through o-nitrobenzyl rearrangement to generate nitrobenzaldehyde and a sulfonic acid such as triflic acid shown in Fig. 7. The chemical structure is shown in Fig. 7(a). The terarylene skeleton-based self-contained PAG is another potential candidate for some applications. The photoacid generation is triggered by the 6π-electro-cyclization reaction of photochromic triangular terarylenes.16 The chemical structure is shown in Fig. 7(b). Similarly, a triflate ester is used in the reported structure to release triflic acid upon exposure. While these and other structures can be used to demonstrate PAG concepts, they are unlikely to be as useful in new high-resolution photoresist systems because they use triflate groups. Alternative acids may be used to make more suitable PAGs from the moieties in Fig. 7. Should a useful PAG be produced from these types of photoactive structures the resulting sulfonic acid will need to be less volatile and less mobile in the polymer film? A higher molar mass, much less volatile, lower diffusivity anion might work well with these mate- rials in a functioning photoresist system. Nontraditional PFAS Ionic PAGs: Ionic PAGs derived from 2-phenoxytetrafluoroethane sulfonate were introduced by Ober and coworkers in 2007.17 This PAG was tested under e-beam and EUV radiation and showed high sensitivity, resolution, and acceptably low line edge deviations. The use of such a fluorosulfonic acid has the advantage that it limits fluorine content yet produces a very strong acid with both limited volatility and diffusivity by placing a CF2 group next to the acid group. Such an approach (discussed more below) can be used to minimize fluorine incorporation while placing this structure where it is most valuable. Its chemical structure is shown in Fig. 8(a). This PAG was tested for its envi- ronmental degradation and its effect on bacterial populations when first reported and found to be benign under the rules of that time. The good lithographic results suggest that shorter fluorinated segments (two or possibly one CF2 unit adjacent to the sulfonic acid) may make useful ionic PAGs. It should be noted that the building blocks for sulfonic acids with one CF2 are the subject of experimental studies. The pentacyanocyclopentadienide PAG is another potential ionic PAG candidate in some applica- tions. Its lithographic performance was demonstrated by Varanasi and coworkers in 2010, and it stands out for the amount of publicity it received.18 The chemical structure is shown in Fig. 8(b). While announced in 2010 as part of IBM’s efforts to reduce Perfluorooctanoic acid (PFOA) in its manufacturing process, to the best of our knowledge, this PAG was not commercialized. Fig. 8 Chemical structure of untraditional ionic PAGs: (a) 2-phenoxytetrafluoroethane sulfonate PAG and (b) pentacyanocyclopentadienide PAGs. J. Micro/Nanopattern. Mater. Metrol. 010901-8 Jan–Mar 2022 • Vol. 21(1) 445 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 8 Chemical structure of untraditional ionic PAGs: (a) 2-phenoxytetrafluoroethane sulfonate PAG and (b) pentacyanocyclopentadienide PAGs. J. Micro/Nanopattern. Mater. Metrol. 010901-8 Jan–Mar 2022 • Vol. 21(1) 445 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . O CF2CF2OCF2CF2SO3- F F AcO F F F F F AcO F SO3- O S O O O O O O F O F F F F AcO OAc F F F OH HO Lactone PAG Sugar sweet PAG OH HO O F F HO O F SO3- OH F O O O O Deactylated linear sweet PAG-K F F O F O O F O CF2CF2OCF2CF2SO3- O CF2CF2OCF2CF2SO3- F F AcO F F F F F AcO F SO3- O S O O O O O O F O F F F F AcO OAc F F F OH HO Lactone PAG Sugar sweet PAG OH HO O F F HO O F SO3- OH F O O O O Deactylated linear sweet PAG-K F F O F O O F O CF2CF2OCF2CF2SO3- Methoxy sugar B sweet PAG Lithocholic acid PAG Methoxy sugar B sweet PAG Lithocholic acid PAG HO F F HO F SO3- F O O O F F F O CF2CF2OCF2CF2SO3- HO OH F Hydroxy sugar B sweet PAG Dihydrocholesterol PAG Fig. 9 Chemical structures for natural products-based PAGs. HO F F HO F SO3- F O O O F F F O CF2CF2OCF2CF2SO3- HO OH F Hydroxy sugar B sweet PAG Dihydrocholesterol PAG Fig. 9 Chemical structures for natural products-based PAGs. Finally, PAGs based on glucose or other natural products have been explored. These PAGs were demonstrated to be functional materials for some high-resolution photoresist applications ena- bling sub-100nm features using ArF laser and e-beam lithography. Moreover, these PAGs showed successful microbial degradation to smaller molecular units under aerobic conditions. The chemical structures are shown in Fig. 9. Such studies revealed the successful biodegradation of these PFAS units to smaller oxidized components as well as low bacterial cytotoxicity19,20 of the photoactive sulfonium subunit. In general, the anionic units underwent biodegradation using sludge from a local municipal waste- water treatment plant. The sugar or cholesterol groups appeared to degrade easily leaving only a short, fluorinated acid residue. An advantage of these structures is that the residues retain polar functional groups and are therefore more hydrophilic than PFOS/PFAS units. This makes them less likely to accumulate in fatty tissues, but further studies are needed to identify any bioac- cumulation characteristics. The photoactive cation unit but not the fluorinated anion was gen- erally found to be cytotoxic to the bacteria. Importantly, the short, fluorinated segment enabled the formation of a high-performance PAG that could be subjected to successful biological degradation. More recently, patents have appeared that describe a number of related chemical structures, the goal of which is intended to deliver strong PAG performance and minimize the size of the fluorinated unit in the fluorosulfonic acid or eliminate it entirely. These patents claim excellent lithographic performance.21 These and other patents describe PAGs with shorter fluorinated segments,22 some of which are designed to fall into small molecular pieces.23 To assess their viability as alternative PAGs their performance characteristics (sensitivity, acid strength, and diffusivity) and environmental characteristics (fluorine content, degradation products, and toxicity) will need to be assessed. Finally, PAGs based on glucose or other natural products have been explored. These PAGs were demonstrated to be functional materials for some high-resolution photoresist applications ena- bling sub-100nm features using ArF laser and e-beam lithography. Moreover, these PAGs showed successful microbial degradation to smaller molecular units under aerobic conditions. The chemical structures are shown in Fig. 9. Such studies revealed the successful biodegradation of these PFAS units to smaller oxidized components as well as low bacterial cytotoxicity19,20 of the photoactive sulfonium subunit. In general, the anionic units underwent biodegradation using sludge from a local municipal waste- water treatment plant. The sugar or cholesterol groups appeared to degrade easily leaving only a short, fluorinated acid residue. An advantage of these structures is that the residues retain polar functional groups and are therefore more hydrophilic than PFOS/PFAS units. This makes them less likely to accumulate in fatty tissues, but further studies are needed to identify any bioac- cumulation characteristics. The photoactive cation unit but not the fluorinated anion was gen- erally found to be cytotoxic to the bacteria. Importantly, the short, fluorinated segment enabled the formation of a high-performance PAG that could be subjected to successful biological degradation. More recently, patents have appeared that describe a number of related chemical structures, the goal of which is intended to deliver strong PAG performance and minimize the size of the fluorinated unit in the fluorosulfonic acid or eliminate it entirely. These patents claim excellent lithographic performance.21 These and other patents describe PAGs with shorter fluorinated segments,22 some of which are designed to fall into small molecular pieces.23 To assess their viability as alternative PAGs their performance characteristics (sensitivity, acid strength, and diffusivity) and environmental characteristics (fluorine content, degradation products, and toxicity) will need to be assessed. 2.4 Polymer-Bound PAGs One approach to increasing the resolution to photolithography is to employ PAG that is incor- porated into the photoresist polymer structure.24 It has the advantage of making the distribution more uniform and at the same time limits the diffusivity of the sulfonate anion since it is bound to the photoresist polymer. Resolution is set in part by the diffusivity of the PAG in the photoresist formulation, which is associated with the size of the molecule. The smaller the anion, the farther the photogenerated proton can diffuse in a given time. If the PAG acid diffuses too broadly then deprotection of the photoresist takes place in unwanted regions and makes the pattern larger, less precise, and “blurry.” These pattern irregularities are characterized in terms of line edge roughness, line width roughness, and critical dimension uniformity. Examples of bound-PAG structures have been reported and two are described below shown in Fig. 10. 2.4 Polymer-Bound PAGs One approach to increasing the resolution to photolithography is to employ PAG that is incor- porated into the photoresist polymer structure.24 It has the advantage of making the distribution more uniform and at the same time limits the diffusivity of the sulfonate anion since it is bound to the photoresist polymer. Resolution is set in part by the diffusivity of the PAG in the photoresist formulation, which is associated with the size of the molecule. The smaller the anion, the farther the photogenerated proton can diffuse in a given time. If the PAG acid diffuses too broadly then deprotection of the photoresist takes place in unwanted regions and makes the pattern larger, less precise, and “blurry.” These pattern irregularities are characterized in terms of line edge roughness, line width roughness, and critical dimension uniformity. Examples of bound-PAG structures have been reported and two are described below shown in Fig. 10. J. Micro/Nanopattern. Mater. Metrol. 010901-9 Jan–Mar 2022 • Vol. 21(1) 446 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 10 Examples of polymer-bound PAGs. (a) Single CF2 unit next to sulfonate21 and (b) single CF2 unit next to sulfonate in a structure that falls apart on exposure; groups (R1, and R2) not specified groups while R3 is a linking group.20 J. Micro/Nanopattern. Mater. Metrol. 010901-9 Jan–Mar 2022 • Vol. 21(1) 446 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 10 Examples of polymer-bound PAGs. (a) Single CF2 unit next to sulfonate21 and (b) single CF2 unit next to sulfonate in a structure that falls apart on exposure; groups (R1, and R2) not specified groups while R3 is a linking group.20 This strategy also lowers concerns about “stochastics,” i.e., the chemical heterogeneity of a photoresist mixture at the dimensions of the pattern are thought to also contribute to the limit of resolution of today’s most advanced lithographic processes. Upon exposure, the fluorosulfonate group becomes protonated, catalyzes deprotection of the rest of the photoresist chain, but the strongly acidic proton cannot diffuse broadly because it remains near the anion bound to the polymer chain and thereby forms higher resolution patterns. By attaching the same number of PAG units to each polymer chain, then the PAG is uniformly distributed throughout the photo- resist film. This strategy is being seriously considered for future generations of photoresists, particularly for use in EUV lithography.25 These examples share several common features, including the attachment of the anion to the polymer backbone. Since many CAR photoresists are based on (meth) acrylates, examples reported for 193 nm (DUV) resists [shown in Figs. 10(a) and 10(b)] possess a sulfonate anion and an adjacent CF2 unit, which then is connected to the methacrylate monomer through an ester linkage. While it has not been established if one or two CF2 units are needed to produce sufficiently strong anion, this example demonstrates one approach and good prospects for polymer-bound PAGs. This strategy also lowers concerns about “stochastics,” i.e., the chemical heterogeneity of a photoresist mixture at the dimensions of the pattern are thought to also contribute to the limit of resolution of today’s most advanced lithographic processes. Upon exposure, the fluorosulfonate group becomes protonated, catalyzes deprotection of the rest of the photoresist chain, but the strongly acidic proton cannot diffuse broadly because it remains near the anion bound to the polymer chain and thereby forms higher resolution patterns. By attaching the same number of PAG units to each polymer chain, then the PAG is uniformly distributed throughout the photo- resist film. This strategy is being seriously considered for future generations of photoresists, particularly for use in EUV lithography.25 These examples share several common features, including the attachment of the anion to the polymer backbone. Since many CAR photoresists are based on (meth) acrylates, examples reported for 193 nm (DUV) resists [shown in Figs. 10(a) and 10(b)] possess a sulfonate anion and an adjacent CF2 unit, which then is connected to the methacrylate monomer through an ester linkage. While it has not been established if one or two CF2 units are needed to produce sufficiently strong anion, this example demonstrates one approach and good prospects for polymer-bound PAGs. 3 Fluorinated Polyimides In an increasing number of applications, the photopatterned polymer is not removed but is retained as part of the device, even though the lithographic requirements are not as stringent as the high-resolution photoresist systems discussed above. Their use ranges from semiconduc- tor packaging to lithographic insulation patterns for integrated circuits. Under these circumstan- ces a completely different photopolymer must be used and have properties of very high thermal stability, strong mechanical properties (high Young’s modulus, good fracture toughness), low dielectric constant (be an insulator), and moisture resistance.26 In this highly demanding application only a few polymers can provide this complex set of properties and, among them, polyimides have been found to provide the best trade-off between processing and performance. Polyimides themselves bring many of these necessary attributes but the intro- duction of fluorinated groups is used to incorporate a chemical function capable of withstand- ing high process temperature, making the final material more moisture resistant and providing a lower dielectric constant than otherwise possible without compromise to other necessary properties. The technical literature reveals that polyimides are used in a number of processes and appli- cations in photolithography.27 Polyimides are a family of polymers characterized by high thermal 3 Fluorinated Polyimides In an increasing number of applications, the photopatterned polymer is not removed but is retained as part of the device, even though the lithographic requirements are not as stringent as the high-resolution photoresist systems discussed above. Their use ranges from semiconduc- tor packaging to lithographic insulation patterns for integrated circuits. Under these circumstan- ces a completely different photopolymer must be used and have properties of very high thermal stability, strong mechanical properties (high Young’s modulus, good fracture toughness), low dielectric constant (be an insulator), and moisture resistance.26 In this highly demanding application only a few polymers can provide this complex set of properties and, among them, polyimides have been found to provide the best trade-off between processing and performance. Polyimides themselves bring many of these necessary attributes but the intro- duction of fluorinated groups is used to incorporate a chemical function capable of withstand- ing high process temperature, making the final material more moisture resistant and providing a lower dielectric constant than otherwise possible without compromise to other necessary properties. The technical literature reveals that polyimides are used in a number of processes and appli- cations in photolithography.27 Polyimides are a family of polymers characterized by high thermal J. Micro/Nanopattern. Mater. Metrol. 010901-10 Jan–Mar 2022 • Vol. 21(1) 447 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-10 Jan–Mar 2022 • Vol. 21(1) 447 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . stability, excellent thin film mechanical properties, good adhesion properties, and a low dielectric constant and dissipation factor. In particular, rigid functional groups such as phenylene- and less polar functional groups provide low dielectric constant (Δk) and good mechanical toughness (resistance to tearing). Polyimides are unique as a family of polymers because they have among the highest glass transition (softening) temperatures known in a polymer (>200°C) and they are thermally stable because the polymer chain consists of interconnected aromatic rings. These properties make polyimides able to withstand the high-temperature processing used in semicon- ductor manufacturing. Like all polymers, they can be etched with the right etchants and therefore patterned, they are amorphous and transparent so they can be used to guide light and they have a lower dielectric constant than many other components in a device so they can be insulators, but unlike other polymers they come with the ability to withstand very high-temperature processing without physical softening and deformation. They often remain in the semiconductor device, unlike most other photolithographic layers. Photopatternable polyimides are generally made from a poly(amic acid) precursor such as one made from oxydianiline (ODA) (Y═O) and a dianhydride (such as pyromellitic dianhy- dride), which can be spin coated onto a substrate (see Fig. 11). However, photocrosslinkable acrylate (or similar) groups are incorporated in the soluble pol- y(amic acid). A photoradical initiator is used to crosslink the acrylate groups and the pattern is developed in this negative tone system. Then a high-temperature bake step is used to transform the poly(amic acid) to the polyimide (with loss of the acrylate groups) to form its final high thermal stability, patterned and insoluble polyimide form. Any component in the final polyimide must withstand this high-temperature bake step. Among the applications of polyimides in microelectronics processing, they find use as thick film photoresist, sacrificial layers, and structural layers. It is notable that the structure of a fluo- rinated unit, when incorporated into the polyimide, largely employs the identical hexafluoroi- sopropyl unit regardless of the application.28–30 Hence, in the most common examples, the polyimides consist of tetracarboxylic acid anhydride derivatives and aromatic diamines, as shown in Fig. 11. The polyimide polymer itself has a softening temperature too high for melt processing, but this group of polymers offers processing through its poly(amide) intermediate. The intermediate is soluble, can be coated in a thin or thick film, and after patterning is converted to the polyimide through the heating step making it an ideal material for integration with semi- conductor manufacturing. The soluble intermediate can be made into a polymer that is directly photo-patternable as shown in the poly(amide) in Fig. 11. The acrylate modified poly(amide) is photo-crosslinked upon exposure to UV radiation in the presence of a photoradical generator and then a pattern is formed. After development, the patterned polymer is subsequently transformed to the final polyimide by thermal processing. It is known in the art that the insertion of the fluorinated hexafluoroisopropyl functional group into the backbone provides a combination of better solubility in processing solvents, lower dielectric constant (more insulating), and pro- vides higher thermal and thermooxidative stability compared with other alternate chemical functions.31 stability, excellent thin film mechanical properties, good adhesion properties, and a low dielectric constant and dissipation factor. In particular, rigid functional groups such as phenylene- and less polar functional groups provide low dielectric constant (Δk) and good mechanical toughness (resistance to tearing). Polyimides are unique as a family of polymers because they have among the highest glass transition (softening) temperatures known in a polymer (>200°C) and they are thermally stable because the polymer chain consists of interconnected aromatic rings. These properties make polyimides able to withstand the high-temperature processing used in semicon- ductor manufacturing. Like all polymers, they can be etched with the right etchants and therefore patterned, they are amorphous and transparent so they can be used to guide light and they have a lower dielectric constant than many other components in a device so they can be insulators, but unlike other polymers they come with the ability to withstand very high-temperature processing without physical softening and deformation. They often remain in the semiconductor device, unlike most other photolithographic layers. Photopatternable polyimides are generally made from a poly(amic acid) precursor such as one made from oxydianiline (ODA) (Y═O) and a dianhydride (such as pyromellitic dianhy- dride), which can be spin coated onto a substrate (see Fig. 11). However, photocrosslinkable acrylate (or similar) groups are incorporated in the soluble pol- y(amic acid). A photoradical initiator is used to crosslink the acrylate groups and the pattern is developed in this negative tone system. Then a high-temperature bake step is used to transform the poly(amic acid) to the polyimide (with loss of the acrylate groups) to form its final high thermal stability, patterned and insoluble polyimide form. Any component in the final polyimide must withstand this high-temperature bake step. Among the applications of polyimides in microelectronics processing, they find use as thick film photoresist, sacrificial layers, and structural layers. It is notable that the structure of a fluo- rinated unit, when incorporated into the polyimide, largely employs the identical hexafluoroi- sopropyl unit regardless of the application.28–30 Hence, in the most common examples, the polyimides consist of tetracarboxylic acid anhydride derivatives and aromatic diamines, as shown in Fig. 11. The polyimide polymer itself has a softening temperature too high for melt processing, but this group of polymers offers processing through its poly(amide) intermediate. The intermediate is soluble, can be coated in a thin or thick film, and after patterning is converted to the polyimide through the heating step making it an ideal material for integration with semi- conductor manufacturing. The soluble intermediate can be made into a polymer that is directly photo-patternable as shown in the poly(amide) in Fig. 11. The acrylate modified poly(amide) is photo-crosslinked upon exposure to UV radiation in the presence of a photoradical generator and then a pattern is formed. After development, the patterned polymer is subsequently transformed to the final polyimide by thermal processing. It is known in the art that the insertion of the fluorinated hexafluoroisopropyl functional group into the backbone provides a combination of better solubility in processing solvents, lower dielectric constant (more insulating), and pro- vides higher thermal and thermooxidative stability compared with other alternate chemical functions.31 Fig. 11 Synthesis and structure of polyimides for photolithographic processes. J. Micro/Nanopattern. Mater. Metrol. 010901-11 Jan–Mar 2022 • Vol. 21(1) 448 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 11 Synthesis and structure of polyimides for photolithographic processes. J. Micro/Nanopattern. Mater. Metrol. 010901-11 Jan–Mar 2022 • Vol. 21(1) 448 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . It must be noted that similar insulator properties have been claimed for the targeted optimi- zation of a polyimide chemical structure without the presence of fluorinated residues such as CF3 - and others, which has been successfully demonstrated in at least one scientific study.32 Araki et al.32 recently described the synthesis of a novel low dielectric constant (Δk) and low dissipation factor (Δf) polyimides suitable for insulator of redistribution layers used as an inter- poser layer in wafer-level packaging. However, this polyimide replaces the thermally stable aromatic structure with a silicone segment (chemically identical to bathtub caulk) to achieve the insulating properties. While this new polyimide has good dielectric properties, unmentioned in the report is the fact it undoubtedly has poor mechanical properties, thermal stability and introduces a softening temperature well below materials used in this semiconductor manufac- turing application. To demonstrate equivalence to the fluorinated polyimides, it would be nec- essary to evaluate these new polymers in a series of comparative studies. It is likely that the lower glass transition temperature and the higher associated thermal expansion changes of the silicone- based system would lead to mechanical stresses that severely limit its use outside of simple packaging applications. No literature was found on the in-process or environmental degradation of these fluorinated polyimides. It must be noted that similar insulator properties have been claimed for the targeted optimi- zation of a polyimide chemical structure without the presence of fluorinated residues such as CF3 - and others, which has been successfully demonstrated in at least one scientific study.32 Araki et al.32 recently described the synthesis of a novel low dielectric constant (Δk) and low dissipation factor (Δf) polyimides suitable for insulator of redistribution layers used as an inter- poser layer in wafer-level packaging. However, this polyimide replaces the thermally stable aromatic structure with a silicone segment (chemically identical to bathtub caulk) to achieve the insulating properties. While this new polyimide has good dielectric properties, unmentioned in the report is the fact it undoubtedly has poor mechanical properties, thermal stability and introduces a softening temperature well below materials used in this semiconductor manufac- turing application. To demonstrate equivalence to the fluorinated polyimides, it would be nec- essary to evaluate these new polymers in a series of comparative studies. It is likely that the lower glass transition temperature and the higher associated thermal expansion changes of the silicone- based system would lead to mechanical stresses that severely limit its use outside of simple packaging applications. No literature was found on the in-process or environmental degradation of these fluorinated polyimides. 4 Fluorinated Polybenzoxazoles Building on the properties described for fluorinated polyimides, the industry has requested materials with similar properties, which could be patterned using the more generally acceptable aqueous tetramethylammonium hydroxide based developers. One way to achieve this end was to replace the polyamic acid derivative precursors with polyhydroxyamide precursors to polybenzoxazole, which could, after patterning and cyclization, yield a polybenzoxazole (Fig. 12). The phenolic group allows for development by aqueous base, whereas use of classical diazonaphthoquinone (DNQ) photoactive units to modify the base solubility as in positive-tone photoresists allows for the needed selective patterning (Fig. 13).4 Alternatively, other protective groups such as acid-labile ethers and a PAG can also be used, as are common in advanced positive tone photoresists. These materials provide properties similar to polyimides, including thermal stability, tensile strength, and transparency as polyimides while also allowing easier processing. The incorporation of a hexafluoroisopropylidene containing monomer again confers the needed properties of transparency in 365 nm applications, good moisture resistance, thermal stability, reduced darkening after cure, and the correct solubility in aqueous development. Other additives are used to further control base solubility.33–36 The DNQ PAC may either be added to the formulation or incorporated into the polymer backbone as shown below. 4 Fluorinated Polybenzoxazoles Building on the properties described for fluorinated polyimides, the industry has requested materials with similar properties, which could be patterned using the more generally acceptable aqueous tetramethylammonium hydroxide based developers. One way to achieve this end was to replace the polyamic acid derivative precursors with polyhydroxyamide precursors to polybenzoxazole, which could, after patterning and cyclization, yield a polybenzoxazole (Fig. 12). The phenolic group allows for development by aqueous base, whereas use of classical diazonaphthoquinone (DNQ) photoactive units to modify the base solubility as in positive-tone photoresists allows for the needed selective patterning (Fig. 13).4 Alternatively, other protective groups such as acid-labile ethers and a PAG can also be used, as are common in advanced positive tone photoresists. These materials provide properties similar to polyimides, including thermal stability, tensile strength, and transparency as polyimides while also allowing easier processing. The incorporation of a hexafluoroisopropylidene containing monomer again confers the needed properties of transparency in 365 nm applications, good moisture resistance, thermal stability, reduced darkening after cure, and the correct solubility in aqueous development. Other additives are used to further control base solubility.33–36 The DNQ PAC may either be added to the formulation or incorporated into the polymer backbone as shown below. Base polymer HO OH X COHN NHCO Y Oxazole ring Precursor polymer CABC n heat O O X Y -H2O N N n After postbake (Polybenzoxazole) Fig. 12 Figure showing ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. Base polymer HO OH X COHN NHCO Y Oxazole ring Precursor polymer CABC n heat O O X Y -H2O N N n After postbake (Polybenzoxazole) Fig. 12 Figure showing ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. J. Micro/Nanopattern. Mater. Metrol. 010901-12 Jan–Mar 2022 • Vol. 21(1) 449 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 13 Ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. J. Micro/Nanopattern. Mater. Metrol. 010901-12 Jan–Mar 2022 • Vol. 21(1) 449 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 13 Ring closure of precursor polymer to form polybenzoxazole polymer after thermal treatment. 5 Antireflection Coatings and Topcoats The purpose of an antireflection coating (ARC) is to prevent reflection of the imaging radiation from interface layers that produce unwanted exposure effects including standing waves. An important attribute of an ARC is to tune the refractive index difference across each interface, and reflection from the many interfaces between layers is suppressed. A difference in refractive index is essential in preventing unwanted reflection of imaging radiation, which otherwise has a detrimental effect on pattern exposures. Fluorinated materials are important because they have a lower refractive index than virtually any other material category. For example, the refractive index of poly(trifluoroethyl methacrylate) is 1.418 compared with a polymer chemically similar to photoresist materials, poly(2-methoxy styrene) with its refractive index of 1.585, a significant and critical difference for an antireflection coating. Ideally a TARC, e.g., should have an RI value of ∼1.3 and even with fluorinated materials, a good TARC refractive index is currently between 1.4 and 1.45. In addition to their optical properties, ARCs must not intermix with the photoresist as the different layers are deposited, and fluorination helps make that possible. Important requirements for ARCs also include ease of etching, their adhesion to a substrate, and precise thickness deposition.37–39 Bottom ARCs (BARCs) are also used to form a level surface for a photoresist. Processing of ARC and topcoat materials depend very much on where they sit in the lithographic stack (on top or on the bottom) and a combination of etch, rinse and/or devel- opment steps are used in processing. This paper does not detail these differences. TARC materi- als require first and foremost controlled and reduced refractive index (RI), good mechanical properties for film formation as well as excellent etch characteristics (faster etching than the photoresist). The low RI properties and immiscibility (by being both nonpolar and oleophobic) with the photoresist are mainly achieved by the incorporation of short, fluorinated groups such as CF3 - and C2 F4 - units in the TARC, although longer fluorinated segments have been used. An example of a generic chemical structure of an ARC is shown in Fig. 14 in which a base soluble fluoropolymer is displayed.40 It is also possible to achieve immiscibility between ARC and resist using cyclic perfluori- nated ether units in the ARC41 Finally, fluorinated surfactants have also been used to improve ARC coating quality, and more is discussed about such surfactants below. There are two possible geometries that work to limit reflection: TARC and BARC antireflection coating materials. The name specifies wherein the multilayer stack the ARC is located. Figure 15 shows the arrange- ment of the silicon substrate, the photoresist, and a TARC.42 The radiation path is different in the air, the TARC, and the photoresist since each has a different refractive index. By using a low RI TARC (due to its fluorination) and by finding the 5 Antireflection Coatings and Topcoats The purpose of an antireflection coating (ARC) is to prevent reflection of the imaging radiation from interface layers that produce unwanted exposure effects including standing waves. An important attribute of an ARC is to tune the refractive index difference across each interface, and reflection from the many interfaces between layers is suppressed. A difference in refractive index is essential in preventing unwanted reflection of imaging radiation, which otherwise has a detrimental effect on pattern exposures. Fluorinated materials are important because they have a lower refractive index than virtually any other material category. For example, the refractive index of poly(trifluoroethyl methacrylate) is 1.418 compared with a polymer chemically similar to photoresist materials, poly(2-methoxy styrene) with its refractive index of 1.585, a significant and critical difference for an antireflection coating. Ideally a TARC, e.g., should have an RI value of ∼1.3 and even with fluorinated materials, a good TARC refractive index is currently between 1.4 and 1.45. In addition to their optical properties, ARCs must not intermix with the photoresist as the different layers are deposited, and fluorination helps make that possible. Important requirements for ARCs also include ease of etching, their adhesion to a substrate, and precise thickness deposition.37–39 Bottom ARCs (BARCs) are also used to form a level surface for a photoresist. Processing of ARC and topcoat materials depend very much on where they sit in the lithographic stack (on top or on the bottom) and a combination of etch, rinse and/or devel- opment steps are used in processing. This paper does not detail these differences. TARC materi- als require first and foremost controlled and reduced refractive index (RI), good mechanical properties for film formation as well as excellent etch characteristics (faster etching than the photoresist). The low RI properties and immiscibility (by being both nonpolar and oleophobic) with the photoresist are mainly achieved by the incorporation of short, fluorinated groups such as CF3 - and C2 F4 - units in the TARC, although longer fluorinated segments have been used. An example of a generic chemical structure of an ARC is shown in Fig. 14 in which a base soluble fluoropolymer is displayed.40 It is also possible to achieve immiscibility between ARC and resist using cyclic perfluori- nated ether units in the ARC41 Finally, fluorinated surfactants have also been used to improve ARC coating quality, and more is discussed about such surfactants below. There are two possible geometries that work to limit reflection: TARC and BARC antireflection coating materials. The name specifies wherein the multilayer stack the ARC is located. Figure 15 shows the arrange- ment of the silicon substrate, the photoresist, and a TARC.42 The radiation path is different in the air, the TARC, and the photoresist since each has a different refractive index. By using a low RI TARC (due to its fluorination) and by finding the Fig. 14 Composition of a commercial ARC; n ¼ m.40 J. Micro/Nanopattern. Mater. Metrol. 010901-13 Jan–Mar 2022 • Vol. 21(1) 450 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 15 Light path of top coat/antireflective coating and resist film stack.43 optimal TARC film thickness reflection can be minimized.44–47 Both the phase match and inten- sity match conditions must be satisfied. This follows Airy’s original 19th-century derivation. If both conditions are met perfectly, the reflection amplitude is zero and all light is coupled into the film. This added ARC layer of lower RI results in a superior pattern with higher resolution. Fig. 14 Composition of a commercial ARC; n ¼ m.40 J. Micro/Nanopattern. Mater. Metrol. 010901-13 Jan–Mar 2022 • Vol. 21(1) 450 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 15 Light path of top coat/antireflective coating and resist film stack.43 optimal TARC film thickness reflection can be minimized.44–47 Both the phase match and inten- sity match conditions must be satisfied. This follows Airy’s original 19th-century derivation. If both conditions are met perfectly, the reflection amplitude is zero and all light is coupled into the film. This added ARC layer of lower RI results in a superior pattern with higher resolution. 5.1 Bottom Antireflective Coatings Some fluorine-containing acrylate and methacrylate-based copolymers may be used as compo- nents in BARC antireflection coating materials (as shown in Fig. 16). BARC materials used for 193-nm lithography include copolymers of acrylates/methacry- lates/alicyclic units as well as bis(benzocyclobutene) and fluorinated arylene ethers.31 Besides the use of acrylate-based copolymers, it has been reported that perfluoroalkyl silanes (shown in Fig. 13) and poly(ethoxy siloxanes) (not shown) are used as BARC materials. In all these materials the fluorinated component aids in preventing intermixing between the antireflec- tion coating and the photoresist. If mixing were to occur then the performance of the ARC (top or bottom) and the photoresist will be greatly diminished, because the thin photoresist layers will no longer be optically uniform. It should also be noted that fluorine “free” alternative BARCs are known, and they similarly must prevent mixing between ARC layers and photoresists without fluorination. Material suppliers have shown fast etching BARCs for 193-nm lithography. Such materials were targeted for first and second reflectivity minima thickness, are immiscible with photoresists (by being crosslinked), and are not affected by base developers, see Fig. 17. However, these materials were introduced before the advent of 193-nm immersion lithog- raphy. In addition, disposal of hydrophilic ARCs is complicated when ARC and resist disposal cannot be disposed of via the same waste system. 5.1 Bottom Antireflective Coatings Some fluorine-containing acrylate and methacrylate-based copolymers may be used as compo- nents in BARC antireflection coating materials (as shown in Fig. 16). BARC materials used for 193-nm lithography include copolymers of acrylates/methacry- lates/alicyclic units as well as bis(benzocyclobutene) and fluorinated arylene ethers.31 Besides the use of acrylate-based copolymers, it has been reported that perfluoroalkyl silanes (shown in Fig. 13) and poly(ethoxy siloxanes) (not shown) are used as BARC materials. In all these materials the fluorinated component aids in preventing intermixing between the antireflec- tion coating and the photoresist. If mixing were to occur then the performance of the ARC (top or bottom) and the photoresist will be greatly diminished, because the thin photoresist layers will no longer be optically uniform. It should also be noted that fluorine “free” alternative BARCs are known, and they similarly must prevent mixing between ARC layers and photoresists without fluorination. Material suppliers have shown fast etching BARCs for 193-nm lithography. Such materials were targeted for first and second reflectivity minima thickness, are immiscible with photoresists (by being crosslinked), and are not affected by base developers, see Fig. 17. However, these materials were introduced before the advent of 193-nm immersion lithog- raphy. In addition, disposal of hydrophilic ARCs is complicated when ARC and resist disposal cannot be disposed of via the same waste system. (a) F F F F CF3 O O n CF3 F F F F (b) n n O O O Si (CF2)5CF3 O O CF3 HO CF3 CF3 CF3 OH (a) F F F F CF3 O O n CF3 F F F F (b) n n O O O Si (CF2)5CF3 O O CF3 HO CF3 CF3 CF3 OH Fig. 16 (a) Fluorinated arylene ethers and (b) acrylate/methacrylate perfluoroalkyl silane-based BARC and TARC materials. J. Micro/Nanopattern. Mater. Metrol. 010901-14 Jan–Mar 2022 • Vol. 21(1) 451 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 17 Representative BARC material.52 Fig. 16 (a) Fluorinated arylene ethers and (b) acrylate/methacrylate perfluoroalkyl silane-based BARC and TARC materials. J. Micro/Nanopattern. Mater. Metrol. 010901-14 Jan–Mar 2022 • Vol. 21(1) 451 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Fig. 17 Representative BARC material.52 5.2 Top Antireflective Coatings Antireflective coatings may also be placed on top of a photoresist stack to reduce optical issues. The comments related to BARCs above about refractive index and miscibility are relevant to TARC materials as well. Issues of wetting and interactions with water arise when 193-nm immer- sion lithography is used. In this variation of high-resolution lithography, a droplet of water is placed between the photoresist stack surface and the stepper (exposure) lens. As the wafer is patterned, the water film must not wet the wafer surface, or else the patterning process will fail since the rapid movement of the stepper would rapidly lead to the breakdown of the immersion layer. A very hydrophobic, nonwetting surface makes the immersion process work well and prevents leaching of the photoactive component. For immersion lithography, control of substrate reflectivity is critical and for this reason immersion, BARCs are favored over TARC when using this process. Similar chemical strategies have been used to make fluorinated TARCs and topcoats (below), where fluorinated acrylate- and methacrylate-based copolymers are used, but they are optimized for different property sets.48 Jung et al.49 showed a TARC material based on these components, which are easily developable but possess a relatively low refractive index of 1.55. Furthermore, by increasing the fluorine content of the TARC material, a high dissolution rate and receding contact angles >70 deg could be achieved. 5.2 Top Antireflective Coatings Antireflective coatings may also be placed on top of a photoresist stack to reduce optical issues. The comments related to BARCs above about refractive index and miscibility are relevant to TARC materials as well. Issues of wetting and interactions with water arise when 193-nm immer- sion lithography is used. In this variation of high-resolution lithography, a droplet of water is placed between the photoresist stack surface and the stepper (exposure) lens. As the wafer is patterned, the water film must not wet the wafer surface, or else the patterning process will fail since the rapid movement of the stepper would rapidly lead to the breakdown of the immersion layer. A very hydrophobic, nonwetting surface makes the immersion process work well and prevents leaching of the photoactive component. For immersion lithography, control of substrate reflectivity is critical and for this reason immersion, BARCs are favored over TARC when using this process. Similar chemical strategies have been used to make fluorinated TARCs and topcoats (below), where fluorinated acrylate- and methacrylate-based copolymers are used, but they are optimized for different property sets.48 Jung et al.49 showed a TARC material based on these components, which are easily developable but possess a relatively low refractive index of 1.55. Furthermore, by increasing the fluorine content of the TARC material, a high dissolution rate and receding contact angles >70 deg could be achieved. 5.3 Topcoats Sanders wrote an extensive review of resist systems for 193-nm immersion lithography and dis- cussed the need for topcoats.41 These are materials used as the upper layer in the resist stack that was optimized for the purpose of preventing immersion liquid (water) from leaching photoactive materials from the photoresist during the patterning process and for base development. In that report, he describes several compositions that work well as topcoats. These include perfluoro ethers as well as polymers with hexafluoroisopropanol units and those with short-chain perfluor- oalkyl units. All approaches reported function well as barrier materials. In addition to immersion topcoats, which are directly coated on the resist, material suppliers have also developed highly functionalized fluorinated amphiphilic molecular structures, which provide the same properties as a topcoat. The advantage of this approach is that the material, known as an embedded barrier layer (EBL), is formulated directly in the resist, and no separate topcoat coating step is required. Such photoresists are known as topcoat-free resists.50 Such EBL materials may have similar fluorinated components as those found in fluorinated topcoats and fluorinated ARCs, but their application and processing are different. Other approaches to low RI materials include the incorporation of air pockets using silica nanoparticles. However, this approach did not gain industry acceptance, because it was not pos- sible to implement with the necessary process reliability and reproducibility. In addition, dyed TARCs (limited by the availability of appropriate chromophores) have been developed that reduce the need for fluorination using anomalous dispersion optical effects but do not eliminate the need for fluorinated components for performance reasons discussed above. Finally, the only molecular unit that comes close to fluorochemicals in low surface energy are silicones, but they have the disadvantage that they have low softening temperatures and are very 5.3 Topcoats Sanders wrote an extensive review of resist systems for 193-nm immersion lithography and dis- cussed the need for topcoats.41 These are materials used as the upper layer in the resist stack that was optimized for the purpose of preventing immersion liquid (water) from leaching photoactive materials from the photoresist during the patterning process and for base development. In that report, he describes several compositions that work well as topcoats. These include perfluoro ethers as well as polymers with hexafluoroisopropanol units and those with short-chain perfluor- oalkyl units. All approaches reported function well as barrier materials. In addition to immersion topcoats, which are directly coated on the resist, material suppliers have also developed highly functionalized fluorinated amphiphilic molecular structures, which provide the same properties as a topcoat. The advantage of this approach is that the material, known as an embedded barrier layer (EBL), is formulated directly in the resist, and no separate topcoat coating step is required. Such photoresists are known as topcoat-free resists.50 Such EBL materials may have similar fluorinated components as those found in fluorinated topcoats and fluorinated ARCs, but their application and processing are different. Other approaches to low RI materials include the incorporation of air pockets using silica nanoparticles. However, this approach did not gain industry acceptance, because it was not pos- sible to implement with the necessary process reliability and reproducibility. In addition, dyed TARCs (limited by the availability of appropriate chromophores) have been developed that reduce the need for fluorination using anomalous dispersion optical effects but do not eliminate the need for fluorinated components for performance reasons discussed above. Finally, the only molecular unit that comes close to fluorochemicals in low surface energy are silicones, but they have the disadvantage that they have low softening temperatures and are very J. Micro/Nanopattern. Mater. Metrol. 010901-15 Jan–Mar 2022 • Vol. 21(1) 452 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . oxygen plasma etch-resistant. Where ARCs need to be removed using such etch methods, alter- native structures with silicones do not provide needed properties. J. Micro/Nanopattern. Mater. Metrol. 010901-15 Jan–Mar 2022 • Vol. 21(1) 452 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . oxygen plasma etch-resistant. Where ARCs need to be removed using such etch methods, alter- native structures with silicones do not provide needed properties. 6 Fluorinated Surfactants and Surface Leveling Agents Surfactants in general are “surface-active agents” that consists of a hydrophobic segment and a hydrophilic unit. Surfactants can be used in a variety of coating applications for improving film quality, changing surface interaction,51 and wetting characteristics, and component mixing. The hydrophobic portion of a surfactant can consist of such moieties as hydrocarbon, silicone, or perfluorocarbon segments while the hydrophilic portion of a surfactant can be charged or neutral. Specific performance advantage of fluorinated surfactants is that the surface activity is much higher than equivalent hydrocarbon or silicone surfactants as indicated by the requirement for less surfactant material in a formulation to achieve its critical micelle concentration. Fluorinated surfactants may be used in several applications in photoresist processing. For example, they can be used to improve photoresist deposition and eliminate defects during photo- resist coating. Fluorinated surfactants have been used to improve the development process of an exposed photoresist. They are used to improve the uniformity of an ARC coating process and are especially effective when fluorinated ARCs are involved. Thick film photoresists benefit from surfactants in the formulation to achieve good coating uniformity. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality to reduce layer contamination and increase process yield) and the surface activity of fluorocarbon surfactants makes them readily useable with other ARCs and photoresist materials. Fluorinated nonionic surfactants have been used in a wide range of lithographic processes due to their very low surface energy, thermal-and mechanical stability, and low refractive index. Nanoimprint lithography (below) is making use of fluorinated surfactants to reduce defects caused by the removal of the template in the patterning process.53,54 Lin et al.55 demonstrated the use of methyl perfluorooctanoate to significantly reduce defects of printed patterns. Another example was shown by Zelsmann et al.56 applying perfluorooctyl-triethoxysilane and perfluoro- octyl-trimethoxysilane. Besides use in nanoimprint lithography, fluorosurfactant-assisted photo- lithography was demonstrated by Sakanoue et al. using commercial polymeric fluorosurfactants, such as Surflon S-386, S-651 (AGC) and Novec FC-4432 (3M).57 It should be noted that, due to the unique properties of fluorinated surfactants, examples of nonfluorinated surfactants with equivalent characteristics to those of fluorinated surfactants are limited and have been used in few resist formulations. 6 Fluorinated Surfactants and Surface Leveling Agents Surfactants in general are “surface-active agents” that consists of a hydrophobic segment and a hydrophilic unit. Surfactants can be used in a variety of coating applications for improving film quality, changing surface interaction,51 and wetting characteristics, and component mixing. The hydrophobic portion of a surfactant can consist of such moieties as hydrocarbon, silicone, or perfluorocarbon segments while the hydrophilic portion of a surfactant can be charged or neutral. Specific performance advantage of fluorinated surfactants is that the surface activity is much higher than equivalent hydrocarbon or silicone surfactants as indicated by the requirement for less surfactant material in a formulation to achieve its critical micelle concentration. Fluorinated surfactants may be used in several applications in photoresist processing. For example, they can be used to improve photoresist deposition and eliminate defects during photo- resist coating. Fluorinated surfactants have been used to improve the development process of an exposed photoresist. They are used to improve the uniformity of an ARC coating process and are especially effective when fluorinated ARCs are involved. Thick film photoresists benefit from surfactants in the formulation to achieve good coating uniformity. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality to reduce layer contamination and increase process yield) and the surface activity of fluorocarbon surfactants makes them readily useable with other ARCs and photoresist materials. Fluorinated nonionic surfactants have been used in a wide range of lithographic processes due to their very low surface energy, thermal-and mechanical stability, and low refractive index. Nanoimprint lithography (below) is making use of fluorinated surfactants to reduce defects caused by the removal of the template in the patterning process.53,54 Lin et al.55 demonstrated the use of methyl perfluorooctanoate to significantly reduce defects of printed patterns. Another example was shown by Zelsmann et al.56 applying perfluorooctyl-triethoxysilane and perfluoro- octyl-trimethoxysilane. Besides use in nanoimprint lithography, fluorosurfactant-assisted photo- lithography was demonstrated by Sakanoue et al. using commercial polymeric fluorosurfactants, such as Surflon S-386, S-651 (AGC) and Novec FC-4432 (3M).57 It should be noted that, due to the unique properties of fluorinated surfactants, examples of nonfluorinated surfactants with equivalent characteristics to those of fluorinated surfactants are limited and have been used in few resist formulations. 7 Nanoimprint Lithography While nanoimprint lithography is not today a mainstream patterning technology, it has the poten- tial to be introduced soon for specific patterning applications. A mold with nm-scale features is used to imprint polymer or a photopolymerizable monomer mixture to form the pattern in the transparent mold.58,59 In the former case, many polymers have been explored for nanoimprinting but a mold release agent such as a poly(perfluoroether) is usually added to the surface of the mold. In the latter case, fluorochemical units such as those used in BARCs and ARCs including perfluoralkyl segments or hexafluoroisopropanol groups have been used.60 In all cases, removal of the polymer from the mold is an important step in the production of the pattern and for this reason, fluoropolymers are frequently used. It is worth being aware of this approach to high- resolution pattern formation because some early attempts at process development depend on the use of fluorinated photoresists. The fluoropolymer has, in addition to excellent release proper- ties, the advantage that air, which can be trapped in the process, is easily dissolved in the fluo- ropolymer thereby eliminating trapped bubbles and does not seem to affect pattern formation. Therefore, fluoropolymers are often preferred in this process. This technology area is new enough that little or no reported work has been carried out on the environmental fate of such materials. Alternate materials for this process include silicones that can be used for their mold release properties.61 This area is attracting strong interest and demonstrates that nonfluorinated materials 7 Nanoimprint Lithography While nanoimprint lithography is not today a mainstream patterning technology, it has the poten- tial to be introduced soon for specific patterning applications. A mold with nm-scale features is used to imprint polymer or a photopolymerizable monomer mixture to form the pattern in the transparent mold.58,59 In the former case, many polymers have been explored for nanoimprinting but a mold release agent such as a poly(perfluoroether) is usually added to the surface of the mold. In the latter case, fluorochemical units such as those used in BARCs and ARCs including perfluoralkyl segments or hexafluoroisopropanol groups have been used.60 In all cases, removal of the polymer from the mold is an important step in the production of the pattern and for this reason, fluoropolymers are frequently used. It is worth being aware of this approach to high- resolution pattern formation because some early attempts at process development depend on the use of fluorinated photoresists. The fluoropolymer has, in addition to excellent release proper- ties, the advantage that air, which can be trapped in the process, is easily dissolved in the fluo- ropolymer thereby eliminating trapped bubbles and does not seem to affect pattern formation. Therefore, fluoropolymers are often preferred in this process. This technology area is new enough that little or no reported work has been carried out on the environmental fate of such materials. Alternate materials for this process include silicones that can be used for their mold release properties.61 This area is attracting strong interest and demonstrates that nonfluorinated materials J. Micro/Nanopattern. Mater. Metrol. 010901-16 Jan–Mar 2022 • Vol. 21(1) 453 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . perform well, but at this time it has not been established if silicone materials are superior in performance. Etch characteristics and wear properties are of course different between fluoropol- ymers and silicones. J. Micro/Nanopattern. Mater. Metrol. 010901-16 Jan–Mar 2022 • Vol. 21(1) 453 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . perform well, but at this time it has not been established if silicone materials are superior in performance. Etch characteristics and wear properties are of course different between fluoropol- ymers and silicones. 8 PFOS/PFAS Remediation As noted above, the strength of the C─F bond creates materials with unique and technologically useful properties in semiconductor processing. That same bond strength also results in strong re- sistance toward physical, chemical, and biological degradation. Due to this strong resistance to degradation, PFAS compounds in general are extremely stable in the environment. In addition, such compounds have been found to be bioaccumulative.62 Extensive literature exists describing the detection of a number of PFAS compounds in drinking water.63 Postuse PFAS waste treatment methods including advanced oxidation processes,64 reductive decomposition processes (aqueous electrons, hydrated electrons, etc.), and incineration have been developed for mitigation purposes.59 Among these methods, advanced oxidation processes do not show high efficacy for PFAS degradation due to the high electronegativity of the fluorine atoms. More work will need to be done to assess the relevance to the kinds of fluorinated materials discussed in this paper. Recent actions by the EPA include interim recommendations for addressing groundwater contaminated with PFOA and PFOS, published method 533 for detection of PFAS compounds in drinking water, an updated list of 172 PFAS chemicals subject to toxics release inventory reporting, a proposal to regulate PFOA and PFOS in drinking water and significant new use rule for certain PFAS in manufactured products.65 Significant data gaps presently exist in dealing with PFAS and PFOS materials. The EPA is also leading a national effort to under- stand PFAS and reduce PFAS risks to the public through the implementation of its PFAS action plan and through active engagement and partnership with other government agencies and constituencies.66 8 PFOS/PFAS Remediation As noted above, the strength of the C─F bond creates materials with unique and technologically useful properties in semiconductor processing. That same bond strength also results in strong re- sistance toward physical, chemical, and biological degradation. Due to this strong resistance to degradation, PFAS compounds in general are extremely stable in the environment. In addition, such compounds have been found to be bioaccumulative.62 Extensive literature exists describing the detection of a number of PFAS compounds in drinking water.63 Postuse PFAS waste treatment methods including advanced oxidation processes,64 reductive decomposition processes (aqueous electrons, hydrated electrons, etc.), and incineration have been developed for mitigation purposes.59 Among these methods, advanced oxidation processes do not show high efficacy for PFAS degradation due to the high electronegativity of the fluorine atoms. More work will need to be done to assess the relevance to the kinds of fluorinated materials discussed in this paper. Recent actions by the EPA include interim recommendations for addressing groundwater contaminated with PFOA and PFOS, published method 533 for detection of PFAS compounds in drinking water, an updated list of 172 PFAS chemicals subject to toxics release inventory reporting, a proposal to regulate PFOA and PFOS in drinking water and significant new use rule for certain PFAS in manufactured products.65 Significant data gaps presently exist in dealing with PFAS and PFOS materials. The EPA is also leading a national effort to under- stand PFAS and reduce PFAS risks to the public through the implementation of its PFAS action plan and through active engagement and partnership with other government agencies and constituencies.66 9 Summary Fluorinated materials play a useful and often essential role in many aspects of semiconductor processing. In our review of the technical literature, we have examined six major applications of fluorochemicals in photolithography and semiconductor processing and identified an emerging technology, nanoimprint lithography, see Table 1. These fluorochemicals are employed as com- ponents of PAGs, as components of photoresists, as elements of high-temperature polymers, and as ingredients in ARCs, BARCs, and as topcoats, frequently satisfying the “essential use” cri- terion. However, there is a strong societal interest in eliminating their use, and “essential use” is a stopgap situation in which replacements are actively sought. The “essential use” concept expects that PFAS uses considered essential today should be continually reviewed for potential removal or replacement by new technologies and be targeted by innovation toward alternatives. The con- cept does not support long-term and large-scale remediation technologies to justify the ongoing use of PFAS chemicals. Thus, the challenges going forward are to find a means to replace PFAS components that achieve or surpass today’s current performance characteristics in the following current and pos- sible future lithography systems. 9 Summary Fluorinated materials play a useful and often essential role in many aspects of semiconductor processing. In our review of the technical literature, we have examined six major applications of fluorochemicals in photolithography and semiconductor processing and identified an emerging technology, nanoimprint lithography, see Table 1. These fluorochemicals are employed as com- ponents of PAGs, as components of photoresists, as elements of high-temperature polymers, and as ingredients in ARCs, BARCs, and as topcoats, frequently satisfying the “essential use” cri- terion. However, there is a strong societal interest in eliminating their use, and “essential use” is a stopgap situation in which replacements are actively sought. The “essential use” concept expects that PFAS uses considered essential today should be continually reviewed for potential removal or replacement by new technologies and be targeted by innovation toward alternatives. The con- cept does not support long-term and large-scale remediation technologies to justify the ongoing use of PFAS chemicals. Thus, the challenges going forward are to find a means to replace PFAS components that achieve or surpass today’s current performance characteristics in the following current and pos- sible future lithography systems. 1. The use of fluorination in PAGs is to enhance the acidity (make pK a ≪ 1) of the acid produced in the region of exposure of a photoresist. The formation of acid to induce a solubility change is the critical step in today’s chemically amplified photoresists, the workhorse family of photoresists that enable the production of the vast majority of semi- conductors. The presence of a fluorinated unit adjacent to the sulfonic acid gives the acid its ability to efficiently release a proton that reacts with the resist polymer to create a solubility switch. Subsequent development forms a pattern in the photoresist. Today there is no effective alternative to a fluorinated sulfonic acid and this situation applies to chemi- cally amplified photoresists across all wavelengths of lithography from 248 nm to EUV. Efforts to reduce the amount of fluorination in a PAG molecule have been demonstrated, but a survey of the current literature has not shown that complete elimination of 1. The use of fluorination in PAGs is to enhance the acidity (make pK a ≪ 1) of the acid produced in the region of exposure of a photoresist. The formation of acid to induce a solubility change is the critical step in today’s chemically amplified photoresists, the workhorse family of photoresists that enable the production of the vast majority of semi- conductors. The presence of a fluorinated unit adjacent to the sulfonic acid gives the acid its ability to efficiently release a proton that reacts with the resist polymer to create a solubility switch. Subsequent development forms a pattern in the photoresist. Today there is no effective alternative to a fluorinated sulfonic acid and this situation applies to chemi- cally amplified photoresists across all wavelengths of lithography from 248 nm to EUV. Efforts to reduce the amount of fluorination in a PAG molecule have been demonstrated, but a survey of the current literature has not shown that complete elimination of J. Micro/Nanopattern. Mater. Metrol. 010901-17 Jan–Mar 2022 • Vol. 21(1) 454 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-17 Jan–Mar 2022 • Vol. 21(1) 454 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . fluorination has produced a successful alternative. However, it is very likely that fluorine- free alternatives, which perform equally well and can easily take the place of the fluo- rinated compounds used today, will be more widely used, and developed in the coming years. Fluorinated polyimides use the presence of a fluorinated unit to improve the dielec- tric constant of the material and make it a better insulator while retaining excellent thermal stability. This combination of characteristics has not been effectively achieved by alter- nate means. 2. Other materials like poly(benzoxazole)s also receive an important performance boost from the incorporation of a fluorinated unit. 3. Antireflection coatings (ARC, BARC, and TARC) and other coatings such as topcoats or EBL use fluorinated components to limit the miscibility of this added layer with a photo- resist or other organic layer in the semiconductor manufacturing process. As surface layers, they also provide barrier properties and when used as a topcoat act to protect the photoresist from interactions with the immersion fluid (currently water) used in 193-nm lithography. However, while these features can in part be replicated by other systems the necessary combination of properties (immiscibility, surface wetting properties, barrier properties, low refractive index) has not been successfully achieved. 4. Fluorinated surfactants provide a specific performance advantage since their surface energy is much lower than hydrocarbon or silicone surfactants resulting in the need for less surfactant material in formulations. Additionally, properties including very low sur- face energy, thermal and mechanical stability, and low refractive index provide benefits to coating and etching processes. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality), and the surface activity of fluorocarbon surfactants makes them readily useable with ARCs and photoresist materials. 5. Nanoimprint lithography may become an important technology for some specialized forms of nanopatterning, and there is interest in the use of fluoromaterials in nanoimprint lithography. Current studies have not yet fully demonstrated that fluorine-free alternatives are successful in producing fine-featured patterns in a production capable system. fluorination has produced a successful alternative. However, it is very likely that fluorine- free alternatives, which perform equally well and can easily take the place of the fluo- rinated compounds used today, will be more widely used, and developed in the coming years. Fluorinated polyimides use the presence of a fluorinated unit to improve the dielec- tric constant of the material and make it a better insulator while retaining excellent thermal stability. This combination of characteristics has not been effectively achieved by alter- nate means. 2. Other materials like poly(benzoxazole)s also receive an important performance boost from the incorporation of a fluorinated unit. 3. Antireflection coatings (ARC, BARC, and TARC) and other coatings such as topcoats or EBL use fluorinated components to limit the miscibility of this added layer with a photo- resist or other organic layer in the semiconductor manufacturing process. As surface layers, they also provide barrier properties and when used as a topcoat act to protect the photoresist from interactions with the immersion fluid (currently water) used in 193-nm lithography. However, while these features can in part be replicated by other systems the necessary combination of properties (immiscibility, surface wetting properties, barrier properties, low refractive index) has not been successfully achieved. 4. Fluorinated surfactants provide a specific performance advantage since their surface energy is much lower than hydrocarbon or silicone surfactants resulting in the need for less surfactant material in formulations. Additionally, properties including very low sur- face energy, thermal and mechanical stability, and low refractive index provide benefits to coating and etching processes. Fluorocarbon surfactants are more easily etched than silicone surfactants in oxygen plasma (a desirable quality), and the surface activity of fluorocarbon surfactants makes them readily useable with ARCs and photoresist materials. 5. Nanoimprint lithography may become an important technology for some specialized forms of nanopatterning, and there is interest in the use of fluoromaterials in nanoimprint lithography. Current studies have not yet fully demonstrated that fluorine-free alternatives are successful in producing fine-featured patterns in a production capable system. Appendix Table 1 summarizes the function of the fluorinated compounds required for the main lithographic processes. In addition, non-fluorinated alternatives and their current feasibility are shown. Table 1 Purpose, properties of fluorocompounds for lithographic patterning and semiconductor processing. Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative Appendix Table 1 summarizes the function of the fluorinated compounds required for the main lithographic processes. In addition, non-fluorinated alternatives and their current feasibility are shown. Table 1 Purpose, properties of fluorocompounds for lithographic patterning and semiconductor processing. Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative PAGs Generation of strong Fluorinated All successfully Not yet acid upon exposure to sulfonium- and demonstrated demonstrated in UV light, when iodonium-acid salts/ alternatives have completely fluorine- fluorination acid strong fluorinated segments free materials groups. Control of electronegativity of —some down to one location and F atom—creates CF2 unit distribution of superacid material generated acids, capable of mixing especially in high- with photoresist resolution applications Antireflection Low refractive index, Largely fluorinated Fluorine-free ARC requirements coatings (top and low surface energy, units in acrylate/ alternatives known. different in 193- and bottom versions and good barrier methacrylate/ But necessary 193-nm immersion have different properties styrene-based properties not yet lithography— requirements) copolymers, very low broadly fluorine-free refractive index, and demonstrated in 193 systems not fully excellent barrier immersion demonstrated properties PAGs Generation of strong Fluorinated All successfully Not yet acid upon exposure to sulfonium- and demonstrated demonstrated in UV light, when iodonium-acid salts/ alternatives have completely fluorine- fluorination acid strong fluorinated segments free materials groups. Control of electronegativity of —some down to one location and F atom—creates CF2 unit distribution of superacid material generated acids, capable of mixing especially in high- with photoresist resolution applications Antireflection Low refractive index, Largely fluorinated Fluorine-free ARC requirements coatings (top and low surface energy, units in acrylate/ alternatives known. different in 193- and bottom versions and good barrier methacrylate/ But necessary 193-nm immersion have different properties styrene-based properties not yet lithography— requirements) copolymers, very low broadly fluorine-free refractive index, and demonstrated in 193 systems not fully excellent barrier immersion demonstrated properties J. Micro/Nanopattern. Mater. Metrol. 010901-18 Jan–Mar 2022 • Vol. 21(1) 455 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Table 1 (Continued). Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative J. Micro/Nanopattern. Mater. Metrol. 010901-18 Jan–Mar 2022 • Vol. 21(1) 455 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Table 1 (Continued). Known or potential Lithographic Fluorocompound(s) nonfluorine- processing Critical purpose in use/unique containing Current viability need served properties provided alternatives of alternative Topcoat Provides barrier layer Largely fluorinated Lacking satisfactory Not yet (for 193-nm for 193-nm immersion acrylate/ options demonstrated in immersion photoresists applied on methacrylate/ fluorine-free photoresist) top of photoresist and styrene-based materials prevents leaching of copolymers, excellent photoactive barrier properties with components. Protects fluorinated the photoresist from components contact with immersion liquid (water) EBL (for 193-nm Forms a protective Largely acrylate/ Lacking satisfactory Not yet immersion surface layer for 193- methacrylate/ options demonstrated in photoresist) nm immersion styrene-based fluorine-free photoresists and copolymers, excellent materials prevents leaching of barrier properties with photoactive fluorinated components. components Incorporated as part of photoresist and segregates to film surface during the coating process. Protects the photoresist from contact with immersion liquid (water) Polyimides Required stress buffer Tetracarboxylic acid Novel polyimides— Not yet (photopatternable) coat between chip and anhydride derivatives suitable fluorine-free demonstrated in package to prevent and aromatic alternatives have not fluorine-free premature device diamines/solubility in demonstrated equal materials failure; especially good organic solvents, low performance electrical insulating dielectric constants, characteristics and high thermal and thermooxidative stability; requires negative tone solvent to develop Polybenzoxazoles Stress buffer coat to Low dielectric Novel Not yet (photopatternable) prevent premature constants, and high polybenzoxazoles— demonstrated in device failure; high- thermal and suitable fluorine-free fluorine-free temperature stability thermooxidative alternatives have not materials and good insulating stability; processed demonstrated equal characteristics using positive resist performance developer Nanoimprint Excellent release Fluoropolymers/low Silicone-based Potentially good but Lithography characteristics; low surface adherence release agents not yet established fluoropolymers surface energy and fluoromonomers reported to dissolve trapped air making them ideal for filling the micromolds of nanoimprint lithography Nonionic Improve coat quality in Nonionic fluorinated For a number of Not yet fluorinated thin lithographic films segments with water- applications, demonstrated in surfactants (e.g., photoresists and soluble units alternatives have not fluorine-free BARCs); compatibility demonstrated equal materials with photoresists and performance TARC/BARC structures; high efficiency of fluorinated surfactants requires very little additive and enables better performance Topcoat Provides barrier layer Largely fluorinated Lacking satisfactory Not yet (for 193-nm for 193-nm immersion acrylate/ options demonstrated in immersion photoresists applied on methacrylate/ fluorine-free photoresist) top of photoresist and styrene-based materials prevents leaching of copolymers, excellent photoactive barrier properties with components. Protects fluorinated the photoresist from components contact with immersion liquid (water) EBL (for 193-nm Forms a protective Largely acrylate/ Lacking satisfactory Not yet immersion surface layer for 193- methacrylate/ options demonstrated in photoresist) nm immersion styrene-based fluorine-free photoresists and copolymers, excellent materials prevents leaching of barrier properties with photoactive fluorinated components. components Incorporated as part of photoresist and segregates to film surface during the coating process. Protects the photoresist from contact with immersion liquid (water) Polyimides Required stress buffer Tetracarboxylic acid Novel polyimides— Not yet (photopatternable) coat between chip and anhydride derivatives suitable fluorine-free demonstrated in package to prevent and aromatic alternatives have not fluorine-free premature device diamines/solubility in demonstrated equal materials failure; especially good organic solvents, low performance electrical insulating dielectric constants, characteristics and high thermal and thermooxidative stability; requires negative tone solvent to develop Polybenzoxazoles Stress buffer coat to Low dielectric Novel Not yet (photopatternable) prevent premature constants, and high polybenzoxazoles— demonstrated in device failure; high- thermal and suitable fluorine-free fluorine-free temperature stability thermooxidative alternatives have not materials and good insulating stability; processed demonstrated equal characteristics using positive resist performance developer Nanoimprint Excellent release Fluoropolymers/low Silicone-based Potentially good but Lithography characteristics; low surface adherence release agents not yet established fluoropolymers surface energy and fluoromonomers reported to dissolve trapped air making them ideal for filling the micromolds of nanoimprint lithography Nonionic Improve coat quality in Nonionic fluorinated For a number of Not yet fluorinated thin lithographic films segments with water- applications, demonstrated in surfactants (e.g., photoresists and soluble units alternatives have not fluorine-free BARCs); compatibility demonstrated equal materials with photoresists and performance TARC/BARC structures; high efficiency of fluorinated surfactants requires very little additive and enables better performance J. Micro/Nanopattern. Mater. Metrol. 010901-19 Jan–Mar 2022 • Vol. 21(1) 456 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Acknowledgments The authors gratefully acknowledge the Semiconductor PAG Consortium for financial support in the preparation of this manuscript. In particular, we thank Brook Tvermoes (IBM) for very helpful input in the preparation of this manuscript. Each author contributed significantly to the writing of this manuscript. The basis of this manuscript was a report commissioned by the Semiconductor PAG Consortium. J. Micro/Nanopattern. Mater. Metrol. 010901-19 Jan–Mar 2022 • Vol. 21(1) 456 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Acknowledgments The authors gratefully acknowledge the Semiconductor PAG Consortium for financial support in the preparation of this manuscript. In particular, we thank Brook Tvermoes (IBM) for very helpful input in the preparation of this manuscript. Each author contributed significantly to the writing of this manuscript. The basis of this manuscript was a report commissioned by the Semiconductor PAG Consortium. References 1. J. Glüge et al., “An overview of the uses of per- and polyfluoroalkyl substances (PFAS),” Environ. Sci.: Process. Impacts 22, 2345–237 (2020). 2. I. T. 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Wenjie et al., “Lithography performance and environmental compatibility of PFOS-free photoacid generators,” Green Mater. 5, 173–181 (2017). 21. T. W. Y. Ohsawa, T. Kinsho, and K. Kobayashi, “Sulfonate salts and derivatives, photoacid generators, resist compositions, and patterning process,” US Patent 7511169B2 (2006). 22. S. N. T. Ishimaru et al., “Fluorinated sulfonate esters of aryl ketones for non-ionic photoacid generators,” US Patent 9,983,475B2, (45) (2018). References 1. J. Glüge et al., “An overview of the uses of per- and polyfluoroalkyl substances (PFAS),” Environ. Sci.: Process. Impacts 22, 2345–237 (2020). 2. I. T. Cousins et al., “The concept of essential use for determining when uses of PFASs can be phased out,” Environ. Sci.: Process. Impacts 21, 1803–1815 (2019). 3. G. Oster and N. Yang, “Photopolymerization of vinyl monomers,” Chem. Rev. 68, 125–151 (1968). 4. T. A. Engesser et al., “Reactive p-block cations stabilized by weakly coordinating anions,” Chem. Soc. Rev. 45, 789–899 (2016). 5. S.-Y. Moon and J.-M. Kim, “Chemistry of photolithographic imaging materials based on the chemical amplification concept,” J. Photochem. Photobiol. C 8, 157–173 (2007). 6. J. F. Cameron and T. M. Zydowsky, “Photoacid generator and photoresists comprising same,” US Patent 6849374B2 (2005). 7. J. V. Crivello and J. H. W. Lam, “Photoinitiated cationic polymerization with triarylsulfo- nium salts,” J. Polym. Sci.: Polym. Chem. Ed. 17, 977–999 (1979). 8. S. Tagawa et al., “Radiation and photochemistry of onium salt acid generators in chemically amplified resists,” Proc. SPIE 3999, 204–213 (2000). 9. E. Despagnet-Ayoub et al., “Triphenylsulfonium topophotochemistry,” Photochem. Photobiol. Sci. 17, 27–34 (2018). 10. H. Xu et al., “EUV photolithography: resist progress in metal–organic complex photore- sists,” J. Micro/Nanolithogr. MEMS, MOEMS 18, 011007 (2018). 11. F. M. Houlihan et al., “Nitrobenzyl ester chemistry for polymer processes involving chemi- cal amplification,” Macromolecules 21, 2001–2006 (1988). 12. M. Ikbal et al., “Synthesis, photophysical and photochemical properties of photoacid generators based on N-hydroxyanthracene-1,9-dicarboxyimide and their application toward modification of silicon surfaces,” J. Org. Chem. 77, 10557–10567 (2012). 13. J.-P. Malval et al., “Photochemistry of naphthalimide photoacid generators,” J. Phys. Chem. A 112, 3879–3885 (2008). 14. J. Andraos et al., “Model studies on the photochemistry of phenolic sulfonate photoacid generators,” Chem. Mater. 10, 1694–1699 (1998). 15. M. Terpolilli et al., “Cationic and radical intermediates in the acid photorelease from aryl sulfonates and phosphates,” Photochem. Photobiol. Sci. 10, 123–127 (2011). 16. T. Nakashima et al., “Self-contained photoacid generator triggered by photocyclization of triangle terarylene backbone,” J. Am. Chem. Soc. 137, 7023–7026 (2015). 17. R. Ayothi et al., “Arylonium photoacid generators containing environmentally compatible Aryloxyperfluoroalkanesulfonate Groups,” Chem. Mater. 19, 1434–1444 (2007). 18. M. Glodde, S. Liu, and P. R. Varanasi, “Fluorine-free photoacid generators for 193 nm lithography based on non-sulfonate organic superacids,” J. Photopolym. Sci. Technol. 23, 173–184 (2010). 19. Y. Yi et al., “Sulfonium salts of alicyclic group functionalized semifluorinated alkyl ether sulfonates as photoacid generators,” Chem. Mater. 21, 4037–4046 (2009). 20. S. Wenjie et al., “Lithography performance and environmental compatibility of PFOS-free photoacid generators,” Green Mater. 5, 173–181 (2017). 21. T. W. Y. Ohsawa, T. Kinsho, and K. Kobayashi, “Sulfonate salts and derivatives, photoacid generators, resist compositions, and patterning process,” US Patent 7511169B2 (2006). 22. S. N. T. Ishimaru et al., “Fluorinated sulfonate esters of aryl ketones for non-ionic photoacid generators,” US Patent 9,983,475B2, (45) (2018). J. Micro/Nanopattern. Mater. Metrol. 010901-20 Jan–Mar 2022 • Vol. 21(1) 457 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-20 Jan–Mar 2022 • Vol. 21(1) 457 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . 23. T. Y. T. Masuyama and K. Ichikawa, “Salt, acid generator, resist composition and method for producing resist pattern,” US Patent 2020/0057369 A1 (2020). 24. M. O. T. Fujiwara, K. Katayama, and K. Yamada, “Iodonium salt, resist composition and pattern forming process,” US Patent 2020/0081341 (2020). 25. R. D. Allen et al., “Investigation of polymer-bound PAGs: synthesis, characterization and initial structure/property relationships of anion-bound resists,” J. Photopolym. Sci. Technol. 22, 25–29 (2009). 26. L. C. P. Cheang and C. Reynaga, “Optimization of photosensitive polyimide process for cost effective packaging,” in Surf. Mount Technol. Semin., pp. 1–18 (1996). 27. G. A. W. Wilson, “Review of polyimides used in the manufacturing of micro systems,” NASA, NASA/TM-2007-214870 (2007). 28. T. Omote et al., “Photoreactive fluorinated polyimide protected by tetrahydropyranyl group (THP) based on photoinduced acidolysis properties and kinetics for acidolysis,” J. Photopolym. Sci. Technol. 5, 323–326 (1992). 29. M.-H. Chen et al., “Preparation of photosensitive polyimides (PSPIs) and their feasible evaluation for lithographic insulation patterns (LIPs) of integrated circuits (ICs) without negative photoresists,” Mater. Sci. Semicond. Process. 88, 132–138 (2018). 30. Y. Inoue, T. Higashihara, and M. Ueda, “Alkaline-developable positive-type photosensitive polyimide based on fluorinated Poly(amic acid) and fluorinated diazonaphthoquinone,” J. Photopolym. Sci. Technol. 26, 351–356 (2013). 31. M. G. Dhara and S. Banerjee, “Fluorinated high-performance polymers: Poly(arylene ether) s and aromatic polyimides containing trifluoromethyl groups,” Prog. Polym. Sci. 35, 1022– 1077 (2010). 32. H. Araki et al., “Low permittivity and dielectric loss polyimide with patternability for high frequency applications,” Proc. Electron. Compon. Technol. Conf., Vol. 2020, pp. 635–640 (2020). 33. H. Ahne, E. Kuhn, and R. Rubner, “Heat resistant positive resists containing polyoxazoles,” US Patent 4339521A, Siemens AG (1982). 34. D. N. K. Werner and H. Mueller, “Heat resistant polyamide and polybenzoxazole from bis-((amino-hydroxyphenyl)hexafluoroisopropyl)diphenyl ethers,” US Patent 4845183A, Hoechst Celanese Chemical Co EMD Performance Materials Corp CNA Holdings LLC (1987). 35. H. Ahne, E. Kuhn, and R. Rubner, “Radiation-reactive precursor stages of highly heat- resistant polymers,” US Patent 4371685A, Siemens AG (1981). 36. A. N. Pamela et al., “Photosensitive resin compositions,” US Patent 6214516B1, Fujifilm Electronic Materials USA Inc. (2000). 37. H. L. Chen et al., “Low-dielectric constant bisbenzo(cyclobutene) and fluorinated poly(arylene)ether films as bottom anti-reflective coating layers for ArF lithography,” J. Vac. Sci. Technol., B: Microelectron. Nanometer Struct.–Process., Meas., Phenom. 19, 2381–2384 (2001). 38. B.-T. Liu, W.-D. Yeh, and W.-H. Wang, “Preparation of low refractive index fluorinated materials for antireflection coatings,” J. Appl. Polym. Sci. 118, 1615–1619 (2010). 39. F. Houlihan et al., “Second-generation radiation sensitive developable bottom anti-reflective coatings (DBARC) and implant resists approaches for 193-nm lithography,” Proc. SPIE 6519, 65190L (2007). 40. Y. Yasushi and T. Akiyama, “Composition for antireflection coating and method for forming pattern,” US Patent 7365115B2, Merck Patent GmbH (2003). 41. D. P. Sanders, “Advances in patterning materials for 193 nm immersion lithography,” Chem. Rev. 110, 321–360 (2010). 42. S.-H. Hsu et al., “Challenges of non-PFOS top antireflective coating material,” Proc. SPIE 6923, 69232M (2008). 43. Personal communication, R. Dammel, Merck Inc., Somerville, New Jersey (2022). 44. W.-S. Huang et al., “New 193-nm top antireflective coatings for superior swing reduction,” Proc. SPIE 6153, 61530S (2006). 45. T. Couteau and M. Carcasi, “Topside anti-reflective coating process and productivity improvements on KrF lithography,” Proc. SPIE 6153, 61533H (2006). 23. T. Y. T. Masuyama and K. Ichikawa, “Salt, acid generator, resist composition and method for producing resist pattern,” US Patent 2020/0057369 A1 (2020). 24. M. O. T. Fujiwara, K. Katayama, and K. Yamada, “Iodonium salt, resist composition and pattern forming process,” US Patent 2020/0081341 (2020). 25. R. D. Allen et al., “Investigation of polymer-bound PAGs: synthesis, characterization and initial structure/property relationships of anion-bound resists,” J. Photopolym. Sci. Technol. 22, 25–29 (2009). 26. L. C. P. Cheang and C. Reynaga, “Optimization of photosensitive polyimide process for cost effective packaging,” in Surf. Mount Technol. Semin., pp. 1–18 (1996). 27. G. A. W. Wilson, “Review of polyimides used in the manufacturing of micro systems,” NASA, NASA/TM-2007-214870 (2007). 28. T. Omote et al., “Photoreactive fluorinated polyimide protected by tetrahydropyranyl group (THP) based on photoinduced acidolysis properties and kinetics for acidolysis,” J. Photopolym. Sci. Technol. 5, 323–326 (1992). 29. M.-H. Chen et al., “Preparation of photosensitive polyimides (PSPIs) and their feasible evaluation for lithographic insulation patterns (LIPs) of integrated circuits (ICs) without negative photoresists,” Mater. Sci. Semicond. Process. 88, 132–138 (2018). 30. Y. Inoue, T. Higashihara, and M. Ueda, “Alkaline-developable positive-type photosensitive polyimide based on fluorinated Poly(amic acid) and fluorinated diazonaphthoquinone,” J. Photopolym. Sci. Technol. 26, 351–356 (2013). 31. M. G. Dhara and S. Banerjee, “Fluorinated high-performance polymers: Poly(arylene ether) s and aromatic polyimides containing trifluoromethyl groups,” Prog. Polym. Sci. 35, 1022– 1077 (2010). 32. H. Araki et al., “Low permittivity and dielectric loss polyimide with patternability for high frequency applications,” Proc. Electron. Compon. Technol. Conf., Vol. 2020, pp. 635–640 (2020). 33. H. Ahne, E. Kuhn, and R. Rubner, “Heat resistant positive resists containing polyoxazoles,” US Patent 4339521A, Siemens AG (1982). 34. D. N. K. Werner and H. Mueller, “Heat resistant polyamide and polybenzoxazole from bis-((amino-hydroxyphenyl)hexafluoroisopropyl)diphenyl ethers,” US Patent 4845183A, Hoechst Celanese Chemical Co EMD Performance Materials Corp CNA Holdings LLC (1987). 35. H. Ahne, E. Kuhn, and R. Rubner, “Radiation-reactive precursor stages of highly heat- resistant polymers,” US Patent 4371685A, Siemens AG (1981). 36. A. N. Pamela et al., “Photosensitive resin compositions,” US Patent 6214516B1, Fujifilm Electronic Materials USA Inc. (2000). 37. H. L. Chen et al., “Low-dielectric constant bisbenzo(cyclobutene) and fluorinated poly(arylene)ether films as bottom anti-reflective coating layers for ArF lithography,” J. Vac. Sci. Technol., B: Microelectron. Nanometer Struct.–Process., Meas., Phenom. 19, 2381–2384 (2001). 38. B.-T. Liu, W.-D. Yeh, and W.-H. Wang, “Preparation of low refractive index fluorinated materials for antireflection coatings,” J. Appl. Polym. Sci. 118, 1615–1619 (2010). 39. F. Houlihan et al., “Second-generation radiation sensitive developable bottom anti-reflective coatings (DBARC) and implant resists approaches for 193-nm lithography,” Proc. SPIE 6519, 65190L (2007). 40. Y. Yasushi and T. Akiyama, “Composition for antireflection coating and method for forming pattern,” US Patent 7365115B2, Merck Patent GmbH (2003). 41. D. P. Sanders, “Advances in patterning materials for 193 nm immersion lithography,” Chem. Rev. 110, 321–360 (2010). 42. S.-H. Hsu et al., “Challenges of non-PFOS top antireflective coating material,” Proc. SPIE 6923, 69232M (2008). 43. Personal communication, R. Dammel, Merck Inc., Somerville, New Jersey (2022). 44. W.-S. Huang et al., “New 193-nm top antireflective coatings for superior swing reduction,” Proc. SPIE 6153, 61530S (2006). 45. T. Couteau and M. Carcasi, “Topside anti-reflective coating process and productivity improvements on KrF lithography,” Proc. SPIE 6153, 61533H (2006). J. Micro/Nanopattern. Mater. Metrol. 010901-21 Jan–Mar 2022 • Vol. 21(1) 458 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . J. Micro/Nanopattern. Mater. Metrol. 010901-21 Jan–Mar 2022 • Vol. 21(1) 458 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . 46. D. Sanders et al., “High contact angle fluorosulfonamide-based materials for immersion lithography,” Proc. SPIE 7639, 763925 (2010). 47. M. Khojasteh et al., “Building an immersion topcoat from the ground up: materials perspec- tive,” Proc. SPIE 6519, 651907 (2007). 48. D. P. Sanders, R. Sooriyakumaran, and R. A. DiPietro, “Hexafluoroalcohol-functionalized methacrylate monomers for lithographic/nanopatterning materials,” in Material Matters, K. Patel, Ed., IBM Almaden Research Center, San Jose, California (2011). 49. Q. Lin et al., “Resolution enhanced top antireflective coating materials for ArF immersion lithography [6153-74],” Proc. SPIE, 61531Z (2006). 50. D. Wang et al., “Novel embedded barrier layer materials for ArF non-topcoat immersion applications,” Proc. SPIE 7140, 71402I (2008). 51. J. Kaitz et al., “High contact angle embedded barrier layer materials for next-generation 193 immersion lithography,” Proc. SPIE 11612, 116120U (2021). 52. C. Neef et al., “New BARC materials for the 65-nm node in 193-nm lithography,” Proc. SPIE 5376, 684–688 (2004). 53. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” J. Micro/Nanolithogr., MEMS, MOEMS 12, 031114 (2013). 54. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” Proc. SPIE 7970, 79700T (2011). 55. M. Lin et al., “Role of surfactants in adhesion reduction for step and flash imprint lithog- raphy,” J. Micro/Nanolithogr., MEMS, MOEMS 7, 033005 (2008). 56. M. Zelsmann et al., “Degradation and surfactant-aided regeneration of fluorinated anti- sticking mold treatments in UV nanoimprint lithography,” Microelectron. Eng. 87, 1029–1032 (2010). 57. T. Sakanoue et al., “Fluorosurfactant-assisted photolithography for patterning of perfluor- opolymers and solution- processed organic semiconductors for printed displays,” Appl. Phys. Express 7, 101602 (2014). 58. S. Ito et al., “Investigation of fluorinated (Meth)Acrylate monomers and macromonomers suitable for a hydroxy- containing acrylate monomer in UV nanoimprinting,” Langmuir 30, 7127–7133 (2014). 59. K. Honda et al., “Room-temperature nanoimprint lithography for crystalline poly(fluor- oalkyl acrylate) thin films,” Soft Matter 6, 870–875 (2010). 60. M. Zelsmann et al., “Double-anchoring fluorinated molecules for antiadhesion mold treat- ment in UV nanoimprint lithography,” J. Vac. Sci. Technol., B: Microelectron. Nanometer Struct.–Process. Meas., Phenom. 27, 2873–2876 (2009). 61. L. J. Guo, “Nanoimprint lithography: methods and material requirements,” Adv. Mater. 19, 495–513 (2007). 62. K. H. Kucharzyk et al., “Novel treatment technologies for PFAS compounds: a critical review,” J. Environ. Manage. 204, 757–764 (2017). 63. Z. R. Hopkins et al., “Recently detected drinking water contaminants: GenX and other per- and polyfluoroalkyl ether acids,” J. AWWA 110, 13–28 (2018). 64. H. F. Schröder and R. J. W. Meesters, “Stability of fluorinated surfactants in advanced oxi- dation processes— a follow up of degradation products using flow injection– mass spec- trometry, liquid chromatography–mass spectrometry and liquid chromatography–multiple stage mass spectrometry,” J. Chromatogr. A 1082, 110–119 (2005). 65. A. J. R. Gillespie, “US EPA’s science-based approach to understanding and managing envi- ronmental risk from PFAS,” 2020, https://www.epa.gov/sites/production/files/2020-09/ documents/epa_pfas_rd_overview_complete_2020_0 9_25.pdf 66. A. Hanf, “Research on per- and polyfluoroalkyl substances (PFAS),” 2021, https://www.epa .gov/chemical-research/research-and-polyfluoroalkyl-substances-pfas 46. D. Sanders et al., “High contact angle fluorosulfonamide-based materials for immersion lithography,” Proc. SPIE 7639, 763925 (2010). 47. M. Khojasteh et al., “Building an immersion topcoat from the ground up: materials perspec- tive,” Proc. SPIE 6519, 651907 (2007). 48. D. P. Sanders, R. Sooriyakumaran, and R. A. DiPietro, “Hexafluoroalcohol-functionalized methacrylate monomers for lithographic/nanopatterning materials,” in Material Matters, K. Patel, Ed., IBM Almaden Research Center, San Jose, California (2011). 49. Q. Lin et al., “Resolution enhanced top antireflective coating materials for ArF immersion lithography [6153-74],” Proc. SPIE, 61531Z (2006). 50. D. Wang et al., “Novel embedded barrier layer materials for ArF non-topcoat immersion applications,” Proc. SPIE 7140, 71402I (2008). 51. J. Kaitz et al., “High contact angle embedded barrier layer materials for next-generation 193 immersion lithography,” Proc. SPIE 11612, 116120U (2021). 52. C. Neef et al., “New BARC materials for the 65-nm node in 193-nm lithography,” Proc. SPIE 5376, 684–688 (2004). 53. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” J. Micro/Nanolithogr., MEMS, MOEMS 12, 031114 (2013). 54. T. Ogawa et al., “Reactive fluorinated surfactant for step and flash imprint lithography,” Proc. SPIE 7970, 79700T (2011). 55. M. Lin et al., “Role of surfactants in adhesion reduction for step and flash imprint lithog- raphy,” J. Micro/Nanolithogr., MEMS, MOEMS 7, 033005 (2008). 56. M. Zelsmann et al., “Degradation and surfactant-aided regeneration of fluorinated anti- sticking mold treatments in UV nanoimprint lithography,” Microelectron. Eng. 87, 1029–1032 (2010). 57. T. Sakanoue et al., “Fluorosurfactant-assisted photolithography for patterning of perfluor- opolymers and solution- processed organic semiconductors for printed displays,” Appl. Phys. Express 7, 101602 (2014). 58. S. Ito et al., “Investigation of fluorinated (Meth)Acrylate monomers and macromonomers suitable for a hydroxy- containing acrylate monomer in UV nanoimprinting,” Langmuir 30, 7127–7133 (2014). 59. K. Honda et al., “Room-temperature nanoimprint lithography for crystalline poly(fluor- oalkyl acrylate) thin films,” Soft Matter 6, 870–875 (2010). 60. M. Zelsmann et al., “Double-anchoring fluorinated molecules for antiadhesion mold treat- ment in UV nanoimprint lithography,” J. Vac. Sci. Technol., B: Microelectron. Nanometer Struct.–Process. Meas., Phenom. 27, 2873–2876 (2009). 61. L. J. Guo, “Nanoimprint lithography: methods and material requirements,” Adv. Mater. 19, 495–513 (2007). 62. K. H. Kucharzyk et al., “Novel treatment technologies for PFAS compounds: a critical review,” J. Environ. Manage. 204, 757–764 (2017). 63. Z. R. Hopkins et al., “Recently detected drinking water contaminants: GenX and other per- and polyfluoroalkyl ether acids,” J. AWWA 110, 13–28 (2018). 64. H. F. Schröder and R. J. W. Meesters, “Stability of fluorinated surfactants in advanced oxi- dation processes— a follow up of degradation products using flow injection– mass spec- trometry, liquid chromatography–mass spectrometry and liquid chromatography–multiple stage mass spectrometry,” J. Chromatogr. A 1082, 110–119 (2005). 65. A. J. R. Gillespie, “US EPA’s science-based approach to understanding and managing envi- ronmental risk from PFAS,” 2020, https://www.epa.gov/sites/production/files/2020-09/ documents/epa_pfas_rd_overview_complete_2020_0 9_25.pdf 66. A. Hanf, “Research on per- and polyfluoroalkyl substances (PFAS),” 2021, https://www.epa .gov/chemical-research/research-and-polyfluoroalkyl-substances-pfas Christopher K. Ober is the Francis Bard professor of materials engineering at Cornell University. He has pioneered new materials for photolithography and studies the biology- materials interface. He received his BSc degree in honors chemistry (Co-op) from the University of Waterloo, Ontario, Canada, in 1978 and his MS and PhD degrees in polymer sci- ence and engineering from the University of Massachusetts (Amherst) in 1982. From 1982 to J. Micro/Nanopattern. Mater. Metrol. 010901-22 Jan–Mar 2022 • Vol. 21(1) 459 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . Christopher K. Ober is the Francis Bard professor of materials engineering at Cornell University. He has pioneered new materials for photolithography and studies the biology- materials interface. He received his BSc degree in honors chemistry (Co-op) from the University of Waterloo, Ontario, Canada, in 1978 and his MS and PhD degrees in polymer sci- ence and engineering from the University of Massachusetts (Amherst) in 1982. From 1982 to J. Micro/Nanopattern. Mater. Metrol. 010901-22 Jan–Mar 2022 • Vol. 21(1) 459 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use Ober, Käfer and Deng: Review of essential use of fluorochemicals in lithographic patterning. . . 1986, he was a senior member of the research staff at the Xerox Research Centre of Canada, where he worked on marking materials. He joined Cornell University in the Department of Materials Science and Engineering in 1986. Recently, he served as interim dean of the College of Engineering. Currently, he is a director of the Cornell Nanoscale Facility. From 2014 to 2021, he served on the executive committee (its governing group) of The International Union of Pure and Applied Chemistry (IUPAC). He is a fellow of the ACS (2009), APS (2014), and AAAS (2014). He is a SPIE Senior Member (2018). He received his ACS Award in applied polymer science in 2006, the Gutenberg Research Award in 2009, the Society of Polymer Science Japan (SPSJ) International Prize in 2013, and the Japan Photopolymer Science and Technology Outstanding Achievement Award in 2015. 1986, he was a senior member of the research staff at the Xerox Research Centre of Canada, where he worked on marking materials. He joined Cornell University in the Department of Materials Science and Engineering in 1986. Recently, he served as interim dean of the College of Engineering. Currently, he is a director of the Cornell Nanoscale Facility. From 2014 to 2021, he served on the executive committee (its governing group) of The International Union of Pure and Applied Chemistry (IUPAC). He is a fellow of the ACS (2009), APS (2014), and AAAS (2014). He is a SPIE Senior Member (2018). He received his ACS Award in applied polymer science in 2006, the Gutenberg Research Award in 2009, the Society of Polymer Science Japan (SPSJ) International Prize in 2013, and the Japan Photopolymer Science and Technology Outstanding Achievement Award in 2015. Florian Käfer received his PhD from the University of Bayreuth, Germany, in 2019. Throughout his PhD thesis he focused on the synthesis of new thermoresponsive polymers and their applications. Since 2018, he is a postdoctoral fellow in the Department of Materials Science and Engineering at Cornell University, supervised by professor Christopher Ober. Thereby, he is focused on the synthesis of polymer-grafted nanoparticles as well as the design and synthesis of sequence-controlled small molecules as future photoresist materials for extreme ultraviolet (EUV) photolithography. Jingyuan Deng graduated from Nagoya University in 2016 with a BEng in applied chemistry and the University of Tokyo in 2018 with an MEng in chemistry and biotechnology. He is cur- rently pursuing his PhD in materials chemistry under the supervision of professor Christopher Ober at Cornell University. His current research focuses on the development of novel photoresist materials for EUV lithography. Florian Käfer received his PhD from the University of Bayreuth, Germany, in 2019. Throughout his PhD thesis he focused on the synthesis of new thermoresponsive polymers and their applications. Since 2018, he is a postdoctoral fellow in the Department of Materials Science and Engineering at Cornell University, supervised by professor Christopher Ober. Thereby, he is focused on the synthesis of polymer-grafted nanoparticles as well as the design and synthesis of sequence-controlled small molecules as future photoresist materials for extreme ultraviolet (EUV) photolithography. Jingyuan Deng graduated from Nagoya University in 2016 with a BEng in applied chemistry and the University of Tokyo in 2018 with an MEng in chemistry and biotechnology. He is cur- rently pursuing his PhD in materials chemistry under the supervision of professor Christopher Ober at Cornell University. His current research focuses on the development of novel photoresist materials for EUV lithography. J. Micro/Nanopattern. Mater. Metrol. 010901-23 Jan–Mar 2022 • Vol. 21(1) 460 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use 461 462 463 ________________________________________ From: Sara Pieklik Sent: Tuesday, October 31, 2023 6:28:58 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Community input - Micron NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To whom it may concern: J. Micro/Nanopattern. Mater. Metrol. 010901-23 Jan–Mar 2022 • Vol. 21(1) 460 Downloaded From: https://www.spiedigitallibrary.org/journals/Journal-of-Micro/Nanopatterning,-Materials,-and-Metrology on 30 Oct 2023 Terms of Use: https://www.spiedigitallibrary.org/terms-of-use 461 462 463 ________________________________________ From: Sara Pieklik Sent: Tuesday, October 31, 2023 6:28:58 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Community input - Micron NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. To whom it may concern: We have an opportunity, and Micron has the monetary means, to lead by example. I have two young boys that thrive outdoors, and whose mental health visibly suffers when we spend too much time inside. As a mom, it is difficult to find places to take my toddlers where they can be in a natural environment without it being a “trip” to get there. As a teacher, I have taught hundreds of middle schoolers and know the importance of mental health and how being outside can positively affect mental health, demeanor, attitude, and outlook. Please consider letting part of Micron’s investment in our community be one with POSITIVE LASTING impacts on the small part of our world around us. Please consider the following ideas, and dream even bigger, push this company to make our community BETTER for generations to come. Learn from our local history of the travesty of what was once a thriving Onondaga Lake, and what industry turned it into, and not only mitigate the environmental impact of the Micron plant, but use their investment as an opportunity to not just preserve but build up our environment and natural spaces. I want my kids, all the kids I will teach, all the kids in our community, to know and be able to access nature regularly. I don’t want to have to take my children on a trip, outside of our local community, to go be in nature. A natural environment should be the norm, not a “field trip.” Suggestions: We have an opportunity, and Micron has the monetary means, to lead by example. I have two young boys that thrive outdoors, and whose mental health visibly suffers when we spend too much time inside. As a mom, it is difficult to find places to take my toddlers where they can be in a natural environment without it being a “trip” to get there. As a teacher, I have taught hundreds of middle schoolers and know the importance of mental health and how being outside can positively affect mental health, demeanor, attitude, and outlook. Please consider letting part of Micron’s investment in our community be one with POSITIVE LASTING impacts on the small part of our world around us. Please consider the following ideas, and dream even bigger, push this company to make our community BETTER for generations to come. Learn from our local history of the travesty of what was once a thriving Onondaga Lake, and what industry turned it into, and not only mitigate the environmental impact of the Micron plant, but use their investment as an opportunity to not just preserve but build up our environment and natural spaces. I want my kids, all the kids I will teach, all the kids in our community, to know and be able to access nature regularly. I don’t want to have to take my children on a trip, outside of our local community, to go be in nature. A natural environment should be the norm, not a “field trip.” Suggestions: Donating enough money to the CNY Land Trust to create public green spaces that exceeds the footprint of their facilities and the support infrastructure. I would like to see 6,000+ acres preserved. Donate enough money to the Onondaga Earth Corps to exceed their annual funding needs. This organization helps teach young people about ecology and fits in with Micron’s STEM education mission goal. 1 464 Demand that new housing have walkable community parks that exceed the WHO recommendation of green space per person, and demand current brownfield sites be priority of new development. Completely utilize their rooftop space and parking areas for solar PV generation. Ensure the out-going water is potable and free of whatever chemicals are added to it through their processes and that they recycle the water they use on site to reduce demand from our surrounding ecosystems. Demand outdoor lighting be minimal and not face upward or outward if possible. Create a transportation plan that prioritizes walk-ability, bicycling and mass transit over automobiles. Sincerely, Sara Pieklik Mom of 2 toddlers Teacher of middle school math Facilitator at Micron’s Liverpool Chip Camp Concerned community member Liverpool, NY Sent from my iPhone Donating enough money to the CNY Land Trust to create public green spaces that exceeds the footprint of their facilities and the support infrastructure. I would like to see 6,000+ acres preserved. Donate enough money to the Onondaga Earth Corps to exceed their annual funding needs. This organization helps teach young people about ecology and fits in with Micron’s STEM education mission goal. 1 464 Demand that new housing have walkable community parks that exceed the WHO recommendation of green space per person, and demand current brownfield sites be priority of new development. Completely utilize their rooftop space and parking areas for solar PV generation. Ensure the out-going water is potable and free of whatever chemicals are added to it through their processes and that they recycle the water they use on site to reduce demand from our surrounding ecosystems. Demand outdoor lighting be minimal and not face upward or outward if possible. Create a transportation plan that prioritizes walk-ability, bicycling and mass transit over automobiles. Sincerely, Sara Pieklik Mom of 2 toddlers Teacher of middle school math Facilitator at Micron’s Liverpool Chip Camp Concerned community member Liverpool, NY Sent from my iPhone 2 465 From: Gonzalez-Trelles, Melissa D Sent: Tuesday, October 31, 2023 8:43:02 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: Sullivan, Tim R ; dep.r7@dec.ny.gov ; dep.r4@dec.ny.gov ; Margaret Crawford Subject: Micron Semiconductor Manufacturing Campus, Town of Clay NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Good Afternoon, This responds to the Onondaga County’s Notice of Positive Declaration, Availability of Draft Scope and Public Scoping Session issued by the Onondaga County Industrial Development Authority (IDA) pursuant to the State Environmental Quality Review Act (SEQRA) for the proposed Micron Semiconductor Fabrication Project to be located in the Town of Clay, Onondaga County, New York. Regards, Melissa Gonzalez-Trelles (she/they) Secretary US Fish & Wildlife Service Ecological Services 1 466 New York Field Office 2 465 From: Gonzalez-Trelles, Melissa D Sent: Tuesday, October 31, 2023 8:43:02 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Cc: Sullivan, Tim R ; dep.r7@dec.ny.gov ; dep.r4@dec.ny.gov ; Margaret Crawford Subject: Micron Semiconductor Manufacturing Campus, Town of Clay NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Good Afternoon, This responds to the Onondaga County’s Notice of Positive Declaration, Availability of Draft Scope and Public Scoping Session issued by the Onondaga County Industrial Development Authority (IDA) pursuant to the State Environmental Quality Review Act (SEQRA) for the proposed Micron Semiconductor Fabrication Project to be located in the Town of Clay, Onondaga County, New York. Regards, Melissa Gonzalez-Trelles (she/they) Secretary US Fish & Wildlife Service Ecological Services 1 466 New York Field Office 3817 Luker Road Cortland, NY 13045 (607)299-0624 2 467 United States Department of the Interior FISH AND WILDLIFE SERVICE 3817 Luker Road Cortland, New York 13045 October 31, 2023 Mr. Robert Petrovich Executive Director Onondaga County Industrial Development Authority 335 Montgomery Street Syracuse, NY 13202 Dear Mr. Petrovich: This responds to the Onondaga County’s Notice of Positive Declaration, Availability of Draft Scope and Public Scoping Session issued by the Onondaga County Industrial Development Authority (IDA) pursuant to the State Environmental Quality Review Act (SEQRA) for the proposed Micron Semiconductor Fabrication Project to be located in the Town of Clay, Onondaga County, New York. Thank you for including the U.S. Fish and Wildlife Service (Service) as an interested agency for the SEQRA process. 3817 Luker Road Cortland, NY 13045 (607)299-0624 2 467 United States Department of the Interior FISH AND WILDLIFE SERVICE 3817 Luker Road Cortland, New York 13045 October 31, 2023 Mr. Robert Petrovich Executive Director Onondaga County Industrial Development Authority 335 Montgomery Street Syracuse, NY 13202 Dear Mr. Petrovich: This responds to the Onondaga County’s Notice of Positive Declaration, Availability of Draft Scope and Public Scoping Session issued by the Onondaga County Industrial Development Authority (IDA) pursuant to the State Environmental Quality Review Act (SEQRA) for the proposed Micron Semiconductor Fabrication Project to be located in the Town of Clay, Onondaga County, New York. Thank you for including the U.S. Fish and Wildlife Service (Service) as an interested agency for the SEQRA process. Supporting documents issued by the IDA include the Environmental Assessment Form and Addendum dated September 12, 2023, and application for funding dated July 14, 2023. The Draft Scope of Work (DSOW) was updated on September 20, 2023, and includes the areas to be studied and documented in a Draft Environmental Impact Statement (DEIS) Report. The DSOW was received in our office on September 25, 2023, and the IDA is accepting our comments until October 31, 2023. We understand the US Department of Commerce (DOC) is the lead federal agency for the project and the U.S. Army Corps of Engineers (Corps) will be involved with the project through permitting pursuant to Section 404 of the Clean Water Act. As you may be aware, federal agencies, such as the DOC and Corps, have responsibilities under Section 7 of the Endangered Species Act (ESA) (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.) to consult with the Service regarding projects that may affect federally listed species or designated critical habitat, and confer with the Service regarding projects that are likely to jeopardize federally proposed species and/or adversely modify proposed critical habitat. 468 Project Description Supporting documents issued by the IDA include the Environmental Assessment Form and Addendum dated September 12, 2023, and application for funding dated July 14, 2023. The Draft Scope of Work (DSOW) was updated on September 20, 2023, and includes the areas to be studied and documented in a Draft Environmental Impact Statement (DEIS) Report. The DSOW was received in our office on September 25, 2023, and the IDA is accepting our comments until October 31, 2023. We understand the US Department of Commerce (DOC) is the lead federal agency for the project and the U.S. Army Corps of Engineers (Corps) will be involved with the project through permitting pursuant to Section 404 of the Clean Water Act. As you may be aware, federal agencies, such as the DOC and Corps, have responsibilities under Section 7 of the Endangered Species Act (ESA) (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.) to consult with the Service regarding projects that may affect federally listed species or designated critical habitat, and confer with the Service regarding projects that are likely to jeopardize federally proposed species and/or adversely modify proposed critical habitat. 468 Project Description The Micron Corporation proposes to construct four fabrication (Fab) facilities in two phases on an approximately 1,400-acre area currently owned by the IDA. Two Fabs would be built together in Phase 1 and two would be bult 10 years later in Phase 2. The SEQRA review and DSOW will encompass the full build out of four Fabs. Each Fab will be approximately 1.2 million square feet in size and require additional utility, warehouse and testing space. This will encompass an additional approximately 870,000 square feet of space for each set of Fabs. A facility of this size will require extensive infrastructure work to support the manufacturing facilities. For example, a new or upgraded interchange on Interstate 81will be needed in Clay. Utility work will include new power lines and substations, natural gas pipelines, water and sewer treatment facilities and lines and industrial gas storage. These improvements will be required both on and off site. A modification to an existing rail line will also be implemented to facilitate cargo delivery. In addition, access roads, parking lots, storm water detention basins and wastewater pretreatment and storage will be built on site. The Micron Corporation proposes to construct four fabrication (Fab) facilities in two phases on an approximately 1,400-acre area currently owned by the IDA. Two Fabs would be built together in Phase 1 and two would be bult 10 years later in Phase 2. The SEQRA review and DSOW will encompass the full build out of four Fabs. Each Fab will be approximately 1.2 million square feet in size and require additional utility, warehouse and testing space. This will encompass an additional approximately 870,000 square feet of space for each set of Fabs. A facility of this size will require extensive infrastructure work to support the manufacturing facilities. For example, a new or upgraded interchange on Interstate 81will be needed in Clay. Utility work will include new power lines and substations, natural gas pipelines, water and sewer treatment facilities and lines and industrial gas storage. These improvements will be required both on and off site. A modification to an existing rail line will also be implemented to facilitate cargo delivery. In addition, access roads, parking lots, storm water detention basins and wastewater pretreatment and storage will be built on site. The Micron site was formerly named the White Pine Commerce Park and has been studied for industrial use since 1991. Onondaga County originally purchased 340 acres of property and this area was the focus of a Generic Environmental Impact Statement (GEIS) Report completed in 2002. Most of the current 1,400-acre site was reviewed in a Supplemental GEIS in 2021. Draft Scope of Work The DSOW contains the areas to be studied and documented in the DEIS. This includes applicable social and natural resources affected by the project on site and in the larger central New York region. Section five of the DSOW provides general topics and specific technical studies proposed to inform the DEIS. We note that while the list of resources includes wetlands, floodplains, and vegetated habitat, there is no mention of an analysis of the project’s effects on wildlife. The DSOW should be amended to include literature review and field observations of wildlife using the site at all times of the year, including winter and migration seasons. Potential impacts to wildlife that should be considered in the DEIS include, but are not limited to, noise, lighting, pollution, human activity and traffic. Potential loss of habitat and fragmentation appear to be substantial and will negatively affect many species. This information should be included in the DSOW and documented in the DEIS. The Micron site was formerly named the White Pine Commerce Park and has been studied for industrial use since 1991. Onondaga County originally purchased 340 acres of property and this area was the focus of a Generic Environmental Impact Statement (GEIS) Report completed in 2002. Most of the current 1,400-acre site was reviewed in a Supplemental GEIS in 2021. Draft Scope of Work The DSOW contains the areas to be studied and documented in the DEIS. This includes applicable social and natural resources affected by the project on site and in the larger central New York region. Section five of the DSOW provides general topics and specific technical studies proposed to inform the DEIS. We note that while the list of resources includes wetlands, floodplains, and vegetated habitat, there is no mention of an analysis of the project’s effects on wildlife. The DSOW should be amended to include literature review and field observations of wildlife using the site at all times of the year, including winter and migration seasons. Potential impacts to wildlife that should be considered in the DEIS include, but are not limited to, noise, lighting, pollution, human activity and traffic. Potential loss of habitat and fragmentation appear to be substantial and will negatively affect many species. This information should be included in the DSOW and documented in the DEIS. In regard to site vegetation, the DSOW should include mapping of vegetation communities, surveys to document endemic plants and identification of rare species and communities as well as invasive plant species. Information should also be provided on the present and future threats of spreading invasive plants to and from the site. An invasive species management plan should be developed for the site in consultation with the New York State Department of Environmental Conservation (NYSDEC). Micron and its consultants have gathered information on federally listed species using the Service’s Information, Planning and Consultation (IPaC) system. This information should be included in the DEIS along with a description of studies completed thus far. For example, the 2 469 Service and the Micron team, along with staff from the NYSDEC, have discussed studies of two endangered bat species believed to be using the site. In regard to site vegetation, the DSOW should include mapping of vegetation communities, surveys to document endemic plants and identification of rare species and communities as well as invasive plant species. Information should also be provided on the present and future threats of spreading invasive plants to and from the site. An invasive species management plan should be developed for the site in consultation with the New York State Department of Environmental Conservation (NYSDEC). Micron and its consultants have gathered information on federally listed species using the Service’s Information, Planning and Consultation (IPaC) system. This information should be included in the DEIS along with a description of studies completed thus far. For example, the 2 469 Service and the Micron team, along with staff from the NYSDEC, have discussed studies of two endangered bat species believed to be using the site. Based on information in IPaC, the project is within the range of the federally listed endangered Indiana bat (Myotis sodalis) and the federally listed endangered northern long-eared bat (Myotis septentrionalis). Accordingly, Micron initiated acoustic surveys of these species at sample locations on the site. A summary of the survey results should be included in the DEIS. The documented call locations should be analyzed in regard to tree removal and habitat modification. This information should inform what the potential effects to these listed species may be and what, if any, measures could be implemented to mitigate adverse effects. The Service will continue to work with Micron and other partners in evaluating the project’s effects on federally listed species. Since federal agencies will be funding, permitting and/or approving aspects of the project, section 7 consultation under the ESA will be required. More information about the process can be found here: https://www.fws.gov/service/esa-section-7-consultation. Based on information in IPaC, the project is within the range of the federally listed endangered Indiana bat (Myotis sodalis) and the federally listed endangered northern long-eared bat (Myotis septentrionalis). Accordingly, Micron initiated acoustic surveys of these species at sample locations on the site. A summary of the survey results should be included in the DEIS. The documented call locations should be analyzed in regard to tree removal and habitat modification. This information should inform what the potential effects to these listed species may be and what, if any, measures could be implemented to mitigate adverse effects. The Service will continue to work with Micron and other partners in evaluating the project’s effects on federally listed species. Since federal agencies will be funding, permitting and/or approving aspects of the project, section 7 consultation under the ESA will be required. More information about the process can be found here: https://www.fws.gov/service/esa-section-7-consultation. The DSOW indicates that wetlands will be identified and delineated in consultation with the US Army Corps of Engineers. We understand that most of that field work has been completed. However, the DSOW does not indicate if or how wetland functions and services will be evaluated and reported. This information is important in understanding the habitat and social values (flood flow attenuation, sediment and nutrient retention, pollution abatement, etc.) these areas provide. Documentation in the DEIS is also important to understand what is being potentially lost from the project and what mitigation is required of Micron to replace these functions and services. In line with section 404 of the Clean Water Act, the project design must avoid, minimize, and mitigate potential impacts to aquatic resources to the greatest extent practicable. This review approach should be added to the DSOW. The DSOW indicates that wetlands will be identified and delineated in consultation with the US Army Corps of Engineers. We understand that most of that field work has been completed. However, the DSOW does not indicate if or how wetland functions and services will be evaluated and reported. This information is important in understanding the habitat and social values (flood flow attenuation, sediment and nutrient retention, pollution abatement, etc.) these areas provide. Documentation in the DEIS is also important to understand what is being potentially lost from the project and what mitigation is required of Micron to replace these functions and services. In line with section 404 of the Clean Water Act, the project design must avoid, minimize, and mitigate potential impacts to aquatic resources to the greatest extent practicable. This review approach should be added to the DSOW. Wetland mitigation is mentioned in the DSOW as potentially occurring on and off site. While the extent of potential wetland impacts is not yet known, it appears to be a substantial amount based upon the extent of wetlands found on the 1400-acre site. Mitigation for unavoidable impacts should occur within the same watershed (as defined by the 8-digit hydrologic code) and be as close to the impacted wetlands as practicable. Micron has inquired about mitigation options including the purchase of credits at third party wetland mitigation banks or in-lieu fee sites. The Service does not support the complete purchase of available credits for the Micron project as that reduces the effectiveness of the mitigation program. Wetland mitigation is mentioned in the DSOW as potentially occurring on and off site. While the extent of potential wetland impacts is not yet known, it appears to be a substantial amount based upon the extent of wetlands found on the 1400-acre site. Mitigation for unavoidable impacts should occur within the same watershed (as defined by the 8-digit hydrologic code) and be as close to the impacted wetlands as practicable. Micron has inquired about mitigation options including the purchase of credits at third party wetland mitigation banks or in-lieu fee sites. The Service does not support the complete purchase of available credits for the Micron project as that reduces the effectiveness of the mitigation program. We note that the DSOW does not mention stream impacts or mitigation. As proposed, it appears that the Micron facility will result in the loss of hundreds to thousands of feet of perennial and intermittent stream habitat. This issue should be added to the DSOW and a thorough evaluation provided in the DEIS. If there are no existing data for Youngs Creek, then Micron should perform field studies to gather information on the physical, biological and chemical characteristics of streams on the site. The completed Environmental Assessment Form for the project indicates that approximately 48 million gallons of water will be needed per day to operate the Fabs. The DSOW should identify where the discharge point(s) of effluent will be located and the potential effect these discharges will have on local surface waters. Also, the DEIS should include an analysis of the impacts to aquatic life because of the discharges. 3 470 We note that the DSOW does not mention stream impacts or mitigation. As proposed, it appears that the Micron facility will result in the loss of hundreds to thousands of feet of perennial and intermittent stream habitat. This issue should be added to the DSOW and a thorough evaluation provided in the DEIS. If there are no existing data for Youngs Creek, then Micron should perform field studies to gather information on the physical, biological and chemical characteristics of streams on the site. The completed Environmental Assessment Form for the project indicates that approximately 48 million gallons of water will be needed per day to operate the Fabs. The DSOW should identify where the discharge point(s) of effluent will be located and the potential effect these discharges will have on local surface waters. Also, the DEIS should include an analysis of the impacts to aquatic life because of the discharges. 3 470 The DSOW briefly addresses the topics of indirect and cumulative impacts as well as growth inducing aspects associated with secondary development (i.e. new housing and commercial construction). However, the text indicates that these topics will be evaluated in terms of human health and the built environment and not the natural environment. Secondary growth impacts of the Micron project have the potential to be wide ranging and substantial. We encourage the IDA to closely work with experts in planning, academia as well as agencies such as the Service and the NYSDEC to identify potential impacts of growth on the region’s habitat and associated wildlife species. A thorough analysis of secondary and cumulative impacts in the DEIS should follow the recommendations of the Council of Environmental Quality’s National Environmental Policy Act Handbook found at: https://ceq.doe.gov/publications/NEPA-CEQA_Handbook.html. Summary The DSOW briefly addresses the topics of indirect and cumulative impacts as well as growth inducing aspects associated with secondary development (i.e. new housing and commercial construction). However, the text indicates that these topics will be evaluated in terms of human health and the built environment and not the natural environment. Secondary growth impacts of the Micron project have the potential to be wide ranging and substantial. We encourage the IDA to closely work with experts in planning, academia as well as agencies such as the Service and the NYSDEC to identify potential impacts of growth on the region’s habitat and associated wildlife species. A thorough analysis of secondary and cumulative impacts in the DEIS should follow the recommendations of the Council of Environmental Quality’s National Environmental Policy Act Handbook found at: https://ceq.doe.gov/publications/NEPA-CEQA_Handbook.html. Summary The proposed Micron project has the potential to cause substantial if not significant environmental impacts to a wide range of natural resources. Not only will the 1,400-acre Micron site be affected but numerous other areas will be developed to support the facility. The Onondaga County IDA has the responsibility to adequately document and evaluate the potential effects to the resources. We have concerns about potential near term and long-term effects to federally listed species, aquatic resources such as streams and wetlands, invasive species, native wildlife, and existing habitat. A concerted effort should be made to account for all foreseeable regional development that will be attributed to the Micron project. This information is essential to avoiding, minimizing, and mitigating impacts as required by SEQRA and federal laws. Thank you for your coordination and consideration of these comments. If you require additional information, please contact Tim Sullivan at 607-753-9334 or tim_r_sullivan@fws.gov. Future correspondence with us on this project should reference project file 2024-0005791. The proposed Micron project has the potential to cause substantial if not significant environmental impacts to a wide range of natural resources. Not only will the 1,400-acre Micron site be affected but numerous other areas will be developed to support the facility. The Onondaga County IDA has the responsibility to adequately document and evaluate the potential effects to the resources. We have concerns about potential near term and long-term effects to federally listed species, aquatic resources such as streams and wetlands, invasive species, native wildlife, and existing habitat. A concerted effort should be made to account for all foreseeable regional development that will be attributed to the Micron project. This information is essential to avoiding, minimizing, and mitigating impacts as required by SEQRA and federal laws. Thank you for your coordination and consideration of these comments. If you require additional information, please contact Tim Sullivan at 607-753-9334 or tim_r_sullivan@fws.gov. Future correspondence with us on this project should reference project file 2024-0005791. Sincerely, Digitally signed by IAN DREW IAN DREW Date: 2023.10.31 15:48:39 -04'00' Ian Drew Field Supervisor cc: NYSDEC, Syracuse, NY (K. Balduzzi) NYSDEC, Albany, NY (D. Roesenblatt) USACOE, Auburn, NY (M. Crawford) 4 471 From: Michael Wolfson Sent: Wednesday, November 1, 2023 3:58:33 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: MICRON SCOPING COMMENTS NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Chairman Pat Hogan, OCIDA, enclosed are my scoping comments Michael A. Wolfson, MD 1 472 *)%.,+ /%,-)+( %,**'+0/ *736248 $# 1:85;:9" *& Sincerely, Digitally signed by IAN DREW IAN DREW Date: 2023.10.31 15:48:39 -04'00' Ian Drew Field Supervisor cc: NYSDEC, Syracuse, NY (K. Balduzzi) NYSDEC, Albany, NY (D. Roesenblatt) USACOE, Auburn, NY (M. Crawford) 4 471 From: Michael Wolfson Sent: Wednesday, November 1, 2023 3:58:33 AM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: MICRON SCOPING COMMENTS NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Chairman Pat Hogan, OCIDA, enclosed are my scoping comments Michael A. 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STSJGMG 5TZSY^ XTQOJ \GXYK OSIOSKWGYTW TS ATIP 5ZY ATGJ2 3WK TYNKW OSIOSKWGYOTS XOYKX UWTUTXKJ2 ENGY [TQZRK GSJ Y^UKX TL \GXYK GWK UWTUTXKJ LTW OSIOSKWGYOTS2 ENGY GOW$\GYKW$ GSJ XTOQ UTQQZYGSY \OQQ WKXZQY LWTR \GXYK JOXUTXGQ TW OSIOSKWGYOTS2 ENGY GWK YNK K]UKIYKJ NKGQYN KLLKIYX TL XZIN \GXYK UWTJZIY YWKGYRKSYX2 0# ENGY OX YNK OJKSYOY^ TL OSJO[OJZGQX GSJ'TW ITSXZQYOSM LOWRX UWTUTXKJ LTW YNK JK[KQTURKSY TL GS 7:B2 CNK SGRKX TL OSJO[OJZGQX GSJ YNKOW UWTLKXXOTSGQ IWKJKSYOGQX$ RKYNTJX TL ITSYGIY H^ UNTSK TW KQKIYWTSOI RKGSX$ GSJ [KYYOSM TL XZIN ITSXZQYGSYX LTW ITSLQOIYX TL OSYKWKXY HKY\KKS YNK IOYO_KSX TL >STSJGMG 5TZSY^ RZXY HK OJKSYOLOKJ ST\& CNK UZHQOI RG^ GSJ XNTZQJ JKRGSJ YNGY ITSXZQYGSYX OSJKUKSJKSY TL >5:63 GSJ STSJGMG 5TZSY^ LTW GS^ Y^UKX TL \GXYK2 9T\ \OQQ \GXYK\GYKW HK YWKGYKJ$ O&K& \NKWK "TS YNK UQGSY MWTZSJX2 GY >STSJGMG 5TZSY^ LGIOQOYOKX2# GSJ \NGY Y^UKX TL ZUMWGJKX GSJ ITXY \OQQ HK SKKJKJ LTW IZWWKSY TW UWTUTXKJ ITZSY^ LGIOQOYOKX& 6TKX STSJGMG 5TZSY^ XTQOJ \GXYK OSIOSKWGYTW TS ATIP 5ZY ATGJ2 3WK TYNKW OSIOSKWGYOTS XOYKX UWTUTXKJ2 ENGY [TQZRK GSJ Y^UKX TL \GXYK GWK UWTUTXKJ LTW OSIOSKWGYOTS2 ENGY GOW$\GYKW$ GSJ XTOQ UTQQZYGSY \OQQ WKXZQY LWTR \GXYK JOXUTXGQ TW OSIOSKWGYOTS2 ENGY GWK YNK K]UKIYKJ NKGQYN KLLKIYX TL XZIN \GXYK UWTJZIY YWKGYRKSYX2 0# ENGY OX YNK OJKSYOY^ TL OSJO[OJZGQX GSJ'TW ITSXZQYOSM LOWRX UWTUTXKJ LTW YNK JK[KQTURKSY TL GS 7:B2 CNK SGRKX TL OSJO[OJZGQX GSJ YNKOW UWTLKXXOTSGQ IWKJKSYOGQX$ RKYNTJX TL ITSYGIY H^ UNTSK TW KQKIYWTSOI RKGSX$ GSJ [KYYOSM TL XZIN ITSXZQYGSYX LTW ITSLQOIYX TL OSYKWKXY HKY\KKS YNK IOYO_KSX TL >STSJGMG 5TZSY^ RZXY HK OJKSYOLOKJ ST\& CNK UZHQOI RG^ GSJ XNTZQJ JKRGSJ YNGY ITSXZQYGSYX OSJKUKSJKSY TL >5:63 GSJ STSJGMG 5TZSY^ NKGQYN IGWK LGIOQOYOKX$ OS UGWYOIZQGW TZW NTXUOYGQX$ \KWK XNTWY%XYGLLKJ K[KS HKLTWK YNK 5TWTSG[OWZX UGSJKROI& EGOYOSM YORKX GSJ HKJ XNTWYGMKX \KWK ZSLTWYZSGYKQ^ NOMNQOMNYKJ H^ 5T[OJ%)1 IGXKX GSJ NG[K ITSYOSZKJ& ENGY ORUWT[KRKSYX OS YNK NKGQYNIGWK X^XYKR GWK UWTUTXKJ YT WKRKJ^ YNKXK XNTWYITROSMX OS [OK\ TL YNK K]UKIYGYOTS TL UTYKSYOGQQ^ YNTZXGSJX TL SK\ WKXOJKSYX YT \TWP GY GSJ'TW XKW[K YNK STSJGMG 5TZSY^ AKXOJKSY * 474 From: straussnyc@verizon.net Sent: Wednesday, November 1, 2023 8:19:04 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Micron Project EIS NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Dear Onondaga County IDA: 1# >STSJGMG 5TZSY^ NKGQYN IGWK LGIOQOYOKX$ OS UGWYOIZQGW TZW NTXUOYGQX$ \KWK XNTWY%XYGLLKJ K[KS HKLTWK YNK 5TWTSG[OWZX UGSJKROI& EGOYOSM YORKX GSJ HKJ XNTWYGMKX \KWK ZSLTWYZSGYKQ^ NOMNQOMNYKJ H^ 5T[OJ%)1 IGXKX GSJ NG[K ITSYOSZKJ& ENGY ORUWT[KRKSYX OS YNK NKGQYNIGWK X^XYKR GWK UWTUTXKJ YT WKRKJ^ YNKXK XNTWYITROSMX OS [OK\ TL YNK K]UKIYGYOTS TL UTYKSYOGQQ^ YNTZXGSJX TL SK\ WKXOJKSYX YT \TWP GY GSJ'TW XKW[K YNK STSJGMG 5TZSY^ AKXOJKSY * 474 From: straussnyc@verizon.net Sent: Wednesday, November 1, 2023 8:19:04 PM (UTC+00:00) Monrovia, Reykjavik To: ED-Micron Subject: Micron Project EIS NOTICE: This email originated from outside of Onondaga County's email system. Use caution with links and attachments. Dear Onondaga County IDA: I know that I missed the deadline for providing specific comments on the Draft Scoping document for the EIS. Nevertheless, the Empire State Passengers Association would like encourage the Onondaga County IDA to consider the opportunity to mitigate transportation impacts of the Micron plant via improvements to freight and passenger rail access to Syracuse. ESPA was pleased to learn that Micron proposes to construct a freight rail line extension for the delivery of construction material to the site. As important is the question of how raw materials and completed products will move to and from the Micron plant. Truck only solutions would be undesirable for the Syracuse area and might not comply with the NY Climate Act. Similarly, the Micron plant will generate additional traffic from suppliers and other ancillary businesses in addition to the traffic volumes created by just the Micron plant. Improving passenger rail service to and from Syracuse can be part of the traffic management plan. I know that I missed the deadline for providing specific comments on the Draft Scoping document for the EIS. Nevertheless, the Empire State Passengers Association would like encourage the Onondaga County IDA to consider the opportunity to mitigate transportation impacts of the Micron plant via improvements to freight and passenger rail access to Syracuse. ESPA was pleased to learn that Micron proposes to construct a freight rail line extension for the delivery of construction material to the site. As important is the question of how raw materials and completed products will move to and from the Micron plant. Truck only solutions would be undesirable for the Syracuse area and might not comply with the NY Climate Act. Similarly, the Micron plant will generate additional traffic from suppliers and other ancillary businesses in addition to the traffic volumes created by just the Micron plant. Improving passenger rail service to and from Syracuse can be part of the traffic management plan. New York State has a new plan for improving intercity passenger rail service in upstate New York and advancing the construction of some of the Syracuse elements is highly recommended. You may read more about the Plan here: Empire Corridor Tier One EIS - Empire State Passenger Association (esparail.org) Appendix H provides the best project details chronologically. This could be part of the traffic mitigation and growth management plan for the project. 1 475 Please add my name to the e-mailing list for the environmental review. Thanks. Steve Strauss Executive Director Empire State Passengers Association www.esparail.org 646-334-4214 2 476 Page 1 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing New York State has a new plan for improving intercity passenger rail service in upstate New York and advancing the construction of some of the Syracuse elements is highly recommended. You may read more about the Plan here: Empire Corridor Tier One EIS - Empire State Passenger Association (esparail.org) Appendix H provides the best project details chronologically. This could be part of the traffic mitigation and growth management plan for the project. 1 475 Please add my name to the e-mailing list for the environmental review. Thanks. Steve Strauss Executive Director Empire State Passengers Association www.esparail.org 646-334-4214 2 476 Page 1 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 STATE OF NEW YORK 2 STATE OF NEW YORK 3 DEPARTMENT OF ENVIRONMENTAL CONSERVATION 4 3 DEPARTMENT OF ENVIRONMENTAL CONSERVATION 4 5 MICRON PROJECT SEQRA SCOPING 6 5 MICRON PROJECT SEQRA SCOPING 6 7 PUBLIC HEARING 8 9 DATE: October 11, 2023 at 6:36 p.m. 10 LOCATION: North Syracuse Jr. High 7 PUBLIC HEARING 8 9 DATE: October 11, 2023 at 6:36 p.m. 10 LOCATION: North Syracuse Jr. High 11 Auditorium 12 5353 West Taft Road 11 Auditorium 12 5353 West Taft Road 13 Clay, New York 13041 14 15 16 13 Clay, New York 13041 14 15 16 23 Reported by Nicole Bunnell 24 25 477 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 2 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 (The hearing commenced at 6:36 p.m.) 3 MR. PETROVICH: A little louder. A 4 little louder. Super. How about now? Can you hear 5 me all right? I'm usually not a soft talker. Good 6 evening, everyone. Thanks for coming. My name is 7 Bob Petrovich. I'm the Executive Director of the 23 Reported by Nicole Bunnell 24 25 477 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 2 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 (The hearing commenced at 6:36 p.m.) 3 MR. PETROVICH: A little louder. A 4 little louder. Super. How about now? Can you hear 5 me all right? I'm usually not a soft talker. Good 6 evening, everyone. Thanks for coming. My name is 7 Bob Petrovich. I'm the Executive Director of the 8 Onondaga County Industrial Development Agency, and -- 9 or commonly known as OCIDA. And I just want to take 10 care of a couple of housekeeping matters before we 11 get started this evening. Exits are at the rear of 12 the auditorium plainly marked. Restrooms can be found 13 out and to the left of the auditorium or you can go 14 up the stairs on the second floor. There are 15 restrooms there as well. 8 Onondaga County Industrial Development Agency, and -- 9 or commonly known as OCIDA. And I just want to take 10 care of a couple of housekeeping matters before we 11 get started this evening. Exits are at the rear of 12 the auditorium plainly marked. Restrooms can be found 13 out and to the left of the auditorium or you can go 14 up the stairs on the second floor. There are 15 restrooms there as well. 16 I do want to make a note at this 17 juncture that we do have available this evening 16 I do want to make a note at this 17 juncture that we do have available this evening 18 American Sign Language and Spanish language speaking 19 interpreters here for anyone in the audience that 20 needs those services. If anybody does need those 21 services, please let us know, and we will make sure 22 that someone at the registration desk facilitates 23 that on your behalf so that you can fully 24 participate. 18 American Sign Language and Spanish language speaking 19 interpreters here for anyone in the audience that 20 needs those services. If anybody does need those 21 services, please let us know, and we will make sure 22 that someone at the registration desk facilitates 23 that on your behalf so that you can fully 24 participate. 25 So I along with the IDA legal Counsel ARII@courtsteno.com www.courtsteno.com 478 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 3 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 are here this evening. I have Jeff Davis with me, 3 IDA counsel, and Amanda Fitzgerald. And we'll be 4 presiding over this evening's public scoping session 5 as we commence the environmental review of the Micron 25 So I along with the IDA legal Counsel ARII@courtsteno.com www.courtsteno.com 478 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 3 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 are here this evening. I have Jeff Davis with me, 3 IDA counsel, and Amanda Fitzgerald. And we'll be 4 presiding over this evening's public scoping session 5 as we commence the environmental review of the Micron 6 Semiconductor Manufacturing Facility, Project 7 proposed for Clay, New York. In July of 2023, 8 actually July 14th, OCIDA received an application for 9 financial assistance from Micron, and which no doubt 10 most of you in attendance here are aware of. Micron 11 intends to invest a hundred billion dollars over 12 twenty years to build a leading-edge semiconductor 13 manufacturing campus in the town of Clay at the 14 expanded White Pine Commerce Park located, generally, 15 at 5171, route 31, town of Clay, New York. 6 Semiconductor Manufacturing Facility, Project 7 proposed for Clay, New York. In July of 2023, 8 actually July 14th, OCIDA received an application for 9 financial assistance from Micron, and which no doubt 10 most of you in attendance here are aware of. Micron 11 intends to invest a hundred billion dollars over 12 twenty years to build a leading-edge semiconductor 13 manufacturing campus in the town of Clay at the 14 expanded White Pine Commerce Park located, generally, 15 at 5171, route 31, town of Clay, New York. 16 This project is required to be 17 reviewed under the State Environmental Quality Review 18 Act or SEQRA as it's known. In accordance with 16 This project is required to be 17 reviewed under the State Environmental Quality Review 18 Act or SEQRA as it's known. In accordance with 19 SEQRA, on September the 14th, OCIDA declared itself 20 as lead agency for SEQRA purposes. 19 SEQRA, on September the 14th, OCIDA declared itself 20 as lead agency for SEQRA purposes. 21 OCIDA also issued a positive 22 declaration due to the project's potential to result 23 in one or more significant adverse impacts and has 24 declared its intent to prepare a draft environmental 25 impact statement, or an EIS for short. The first ARII@courtsteno.com www.courtsteno.com 479 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 4 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 step in preparing an EIS is scoping. Scoping is a 3 process that develops a written document, the scope, 4 which outlines the topics and analyses of potential 5 environmental impacts of an action that will be 6 studied and addressed in the draft environmental 7 impact statement prepared for this project. 21 OCIDA also issued a positive 22 declaration due to the project's potential to result 23 in one or more significant adverse impacts and has 24 declared its intent to prepare a draft environmental 25 impact statement, or an EIS for short. The first ARII@courtsteno.com www.courtsteno.com 479 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 4 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 step in preparing an EIS is scoping. Scoping is a 3 process that develops a written document, the scope, 4 which outlines the topics and analyses of potential 5 environmental impacts of an action that will be 6 studied and addressed in the draft environmental 7 impact statement prepared for this project. 8 As part of OCIDA's determination that 9 an EIS is required, OCIDA drafted -- noticed a draft 10 scoping document and invited the public to review and 11 comment on that scoping document. OCIDA posted a 12 copy of the draft scoping document on its website for 13 public review. The purpose of tonight's scoping 14 session is for OCIDA as the lead agency in this 15 process to receive comments on the draft scoping 16 document. 8 As part of OCIDA's determination that 9 an EIS is required, OCIDA drafted -- noticed a draft 10 scoping document and invited the public to review and 11 comment on that scoping document. OCIDA posted a 12 copy of the draft scoping document on its website for 13 public review. The purpose of tonight's scoping 14 session is for OCIDA as the lead agency in this 15 process to receive comments on the draft scoping 16 document. 17 Tonight is not a question-and-answer 18 session, but an opportunity for the public to make 19 comments on the draft scoping document for the 20 record. There is a court reporter here tonight over 21 at the other table and -- who is making a record of 22 all comments made. If you do come forward and make 23 comments tonight, we ask that you please state your 24 full name and where you're from, and also speak 25 clearly and slowly so that the reporter can make an ARII@courtsteno.com www.courtsteno.com 480 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 5 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 accurate record of your statement. We ask those in 3 attendance to please show respect for the person that 4 is speaking, even if you do not agree with the 5 comment, and also to please hold applause or other 6 noise so that we may make an accurate record. 17 Tonight is not a question-and-answer 18 session, but an opportunity for the public to make 19 comments on the draft scoping document for the 20 record. There is a court reporter here tonight over 21 at the other table and -- who is making a record of 22 all comments made. If you do come forward and make 23 comments tonight, we ask that you please state your 24 full name and where you're from, and also speak 25 clearly and slowly so that the reporter can make an ARII@courtsteno.com www.courtsteno.com 480 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 5 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 accurate record of your statement. We ask those in 3 attendance to please show respect for the person that 4 is speaking, even if you do not agree with the 5 comment, and also to please hold applause or other 6 noise so that we may make an accurate record. 7 Given the number of people who have 8 pre-registered and who have signed up to speak 9 tonight, we are limiting comments to three minutes. 7 Given the number of people who have 8 pre-registered and who have signed up to speak 9 tonight, we are limiting comments to three minutes. 10 If you haven't sufficiently expressed your comment 11 within the three minutes, I think we have enough time 12 and have allowed you to get back in line and to have 13 a second round to make an additional comment. We -- 14 time permitting, our goal is to allow everyone to 15 speak and have the opportunity to do so. 10 If you haven't sufficiently expressed your comment 11 within the three minutes, I think we have enough time 12 and have allowed you to get back in line and to have 13 a second round to make an additional comment. We -- 14 time permitting, our goal is to allow everyone to 15 speak and have the opportunity to do so. 16 OCIDA encourages the public to 17 participate in this process. This is your 18 opportunity to voice -- to have your voice heard. If 19 you do not wish to make a comment here this evening, 20 you may submit your comment in writing via email or 21 US mail to OCIDA. 16 OCIDA encourages the public to 17 participate in this process. This is your 18 opportunity to voice -- to have your voice heard. If 19 you do not wish to make a comment here this evening, 20 you may submit your comment in writing via email or 21 US mail to OCIDA. 22 The contact information for submitting 23 comments can be found on the notice, and we have 24 copies of the notice available for you, if that's 25 convenient. You may take a copy with you this ARII@courtsteno.com www.courtsteno.com 481 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 6 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 evening and submit your written comment. The notice 3 and the contact information for submitting comments 4 can also be found on OCIDA's website. Identified on 5 the screen behind me are the email and mailing 6 address to submit written comments, as well as the 7 OCIDA website. We also include the project applicant 8 website for further information may be found on the 9 proposed project there. Written comments will be 10 accepted through October 20th. Your input, both 11 verbal comments here tonight and written comments 12 that are received by OCIDA, will help OCIDA prepare a 13 final scope, which will be released after all the 22 The contact information for submitting 23 comments can be found on the notice, and we have 24 copies of the notice available for you, if that's 25 convenient. You may take a copy with you this ARII@courtsteno.com www.courtsteno.com 481 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 6 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 evening and submit your written comment. The notice 3 and the contact information for submitting comments 4 can also be found on OCIDA's website. Identified on 5 the screen behind me are the email and mailing 6 address to submit written comments, as well as the 7 OCIDA website. We also include the project applicant 8 website for further information may be found on the 9 proposed project there. Written comments will be 10 accepted through October 20th. Your input, both 11 verbal comments here tonight and written comments 12 that are received by OCIDA, will help OCIDA prepare a 13 final scope, which will be released after all the 14 comments have been received and considered. Equal 15 weight is given to both verbal and written comments. 14 comments have been received and considered. Equal 15 weight is given to both verbal and written comments. 16 At this juncture, I will now turn the 17 meeting over to Jeff Davis, IDA Counsel. And we will 18 begin taking comments for the record. 19 MR. DAVIS: Thank you. Lisette, do 20 you want to say a few words? 21 MS. LISETTE: Thank you, Jeff. 22 MR. DAVIS: Thank you. we will get 23 started. I -- we have a few folks that pre- 24 registered and then thanks everyone for submitting 25 your names on comment cards. I'm just going to go ARII@courtsteno.com www.courtsteno.com 482 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 7 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 through the list as we received them. And as Bob 3 said, we'll work through things. Roughly three 4 minutes. So take your comments. I think someone 5 told me earlier that that was roughly the length of 6 the Gettysburg address, so if we can get through 16 At this juncture, I will now turn the 17 meeting over to Jeff Davis, IDA Counsel. And we will 18 begin taking comments for the record. 19 MR. DAVIS: Thank you. Lisette, do 20 you want to say a few words? 21 MS. LISETTE: Thank you, Jeff. 22 MR. DAVIS: Thank you. we will get 23 started. I -- we have a few folks that pre- 24 registered and then thanks everyone for submitting 25 your names on comment cards. I'm just going to go ARII@courtsteno.com www.courtsteno.com 482 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 7 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 through the list as we received them. And as Bob 3 said, we'll work through things. Roughly three 4 minutes. So take your comments. I think someone 5 told me earlier that that was roughly the length of 6 the Gettysburg address, so if we can get through 7 that, that would be great. If you want to have more 8 comments after the fact, you can get back in line as 9 Bob said, and we can hear further comments. First 10 up, Frank Sciortino, and after that would be Jay 11 Riordan. 12 Great. Frank, if you could come down 13 to the mic. Appreciate it. 7 that, that would be great. If you want to have more 8 comments after the fact, you can get back in line as 9 Bob said, and we can hear further comments. First 10 up, Frank Sciortino, and after that would be Jay 11 Riordan. 12 Great. Frank, if you could come down 13 to the mic. Appreciate it. 14 COURT REPORTER: Can you please have 15 them state and spell their name for the record? 16 MR. SCIORTINO: Don't start the clock 17 yet. 18 MR. DAVIS: What was that? 19 MR. SCIORTINO: I said don't start the 20 clock yet. 21 MR. DAVIS: No, not yet. 22 MR. SCIORTINO: I have a written. 23 COURT REPORTER: Thank you. 24 MR. DAVIS: And Frank, if you could 25 state your name and spell it for the record for the ARII@courtsteno.com www.courtsteno.com 483 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 8 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 court reporter, that would be very helpful. Thank 3 you. 4 MR. SCIORTINO: I will. Thank you. 5 My name is Frank Sciortino, S-C-I-O-R-T-I-N-O. And I 6 thank you for the opportunity. My name is Frank 14 COURT REPORTER: Can you please have 15 them state and spell their name for the record? 16 MR. SCIORTINO: Don't start the clock 17 yet. 18 MR. DAVIS: What was that? 19 MR. SCIORTINO: I said don't start the 20 clock yet. 21 MR. DAVIS: No, not yet. 22 MR. SCIORTINO: I have a written. 23 COURT REPORTER: Thank you. 24 MR. DAVIS: And Frank, if you could 25 state your name and spell it for the record for the ARII@courtsteno.com www.courtsteno.com 483 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 8 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 court reporter, that would be very helpful. Thank 3 you. 4 MR. SCIORTINO: I will. Thank you. 5 My name is Frank Sciortino, S-C-I-O-R-T-I-N-O. And I 6 thank you for the opportunity. My name is Frank 7 Sciortino and I live at 8853 Van Hoesen Road in the 8 town of Clay with my wife, Elaine. Elaine and I are 9 not opposed to the project. However, we do face the 10 potential for significant impact to the character of 11 our neighborhood and the value of our property if the 12 Micron project is approved. We live on the corner of 7 Sciortino and I live at 8853 Van Hoesen Road in the 8 town of Clay with my wife, Elaine. Elaine and I are 9 not opposed to the project. However, we do face the 10 potential for significant impact to the character of 11 our neighborhood and the value of our property if the 12 Micron project is approved. We live on the corner of 13 VerPlank Road and Van Hoesen Road, and the potential 14 impacts we face are traffic related and directly 15 associated with the plans for improvements to local 16 roads, namely Caughdenoy Road, Mud Mill Road, 17 VerPlank Road, and Van Hoesen Road. The impact on 18 traffic paragraph and the notice of intent to prepare 13 VerPlank Road and Van Hoesen Road, and the potential 14 impacts we face are traffic related and directly 15 associated with the plans for improvements to local 16 roads, namely Caughdenoy Road, Mud Mill Road, 17 VerPlank Road, and Van Hoesen Road. The impact on 18 traffic paragraph and the notice of intent to prepare 19 DEIS dated September 14th, 2023, identifies several 20 areas of concern. 19 DEIS dated September 14th, 2023, identifies several 20 areas of concern. 21 One, construction and operation of the 22 proposed Micron project is expected to generate a 23 substantial number of new vehicular trips on the 24 local and regional highway network, including local 25 roads I-81 and New York State Route 481. Two, ARII@courtsteno.com www.courtsteno.com 484 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 9 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 approximately 12,000 parking spaces are proposed. 21 One, construction and operation of the 22 proposed Micron project is expected to generate a 23 substantial number of new vehicular trips on the 24 local and regional highway network, including local 25 roads I-81 and New York State Route 481. Two, ARII@courtsteno.com www.courtsteno.com 484 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 9 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 approximately 12,000 parking spaces are proposed. 3 Three, there are approximately 10 to 30 commercial 4 trucks per peak hour anticipated during the operation 5 of the proposed facility. Four, additional vehicles 6 are anticipated for construction over the 7 approximately twenty-year build out. And five, 8 modification of existing roads as anticipated. 3 Three, there are approximately 10 to 30 commercial 4 trucks per peak hour anticipated during the operation 5 of the proposed facility. Four, additional vehicles 6 are anticipated for construction over the 7 approximately twenty-year build out. And five, 8 modification of existing roads as anticipated. 9 We request that the EIS address and 10 provide specific details for the proposed 11 improvements to the local roads named above. Details 12 regarding the size, number of lanes, speed limits, 13 expected volume of traffic, and expected changes for 14 the surrounding neighborhoods, along with the 15 specific timetable for the proposed improvements must 16 be provided in order to honestly assess the potential 17 impacts and give the surrounding residents adequate 18 notice of the changes that they will face. Anything 19 less will be deemed unacceptable and a failure to 20 address one of the most significant impacts 21 associated with the project. 9 We request that the EIS address and 10 provide specific details for the proposed 11 improvements to the local roads named above. Details 12 regarding the size, number of lanes, speed limits, 13 expected volume of traffic, and expected changes for 14 the surrounding neighborhoods, along with the 15 specific timetable for the proposed improvements must 16 be provided in order to honestly assess the potential 17 impacts and give the surrounding residents adequate 18 notice of the changes that they will face. Anything 19 less will be deemed unacceptable and a failure to 20 address one of the most significant impacts 21 associated with the project. 22 A second topic that my wife and I 23 would like to see addressed is the proposed project's 24 impact on property taxes in the town of Clay. I 25 understand that determining the precise impact at ARII@courtsteno.com www.courtsteno.com 485 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 10 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 this stage of the project would be difficult. 22 A second topic that my wife and I 23 would like to see addressed is the proposed project's 24 impact on property taxes in the town of Clay. I 25 understand that determining the precise impact at ARII@courtsteno.com www.courtsteno.com 485 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 10 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 this stage of the project would be difficult. 3 However, for future accountability, we would like to 4 see a discussion of the anticipated impacts on 5 property taxes with a general conclusion that states 6 that the proposed project is likely to one, cause an 7 increase in property taxes. Two, cause a decrease in 8 property taxes. Or three, have no impact on property 9 taxes. Thank you for the opportunity to have input 10 in the preparation of the DEIS for this project. 11 MR. DAVIS: Thank you. Is this back 12 on? Okay. Jay Riordon would be next, and after that 13 will be Donald Hughes. 14 MR. RIORDAN: Hi, I'm Jay Riordon. I 15 live at 8763 Brewerton Road in the town of Cicero. 16 MR. DAVIS: And Jay, can you just 17 spell your name please? 18 MR. RIORDAN: It's R-I-O-R-D-A-N. I'm 19 here representing the Cicero Democratic Committee. 3 However, for future accountability, we would like to 4 see a discussion of the anticipated impacts on 5 property taxes with a general conclusion that states 6 that the proposed project is likely to one, cause an 7 increase in property taxes. Two, cause a decrease in 8 property taxes. Or three, have no impact on property 9 taxes. Thank you for the opportunity to have input 10 in the preparation of the DEIS for this project. 11 MR. DAVIS: Thank you. Is this back 12 on? Okay. Jay Riordon would be next, and after that 13 will be Donald Hughes. 14 MR. RIORDAN: Hi, I'm Jay Riordon. I 15 live at 8763 Brewerton Road in the town of Cicero. 16 MR. DAVIS: And Jay, can you just 17 spell your name please? 18 MR. RIORDAN: It's R-I-O-R-D-A-N. I'm 19 here representing the Cicero Democratic Committee. 20 I'm also a candidate for town counselor in Cicero for 21 November. 22 MR. DAVIS: Yes. 23 MR. RIORDAN: But most of all, I'm 24 here as a Cicero resident who has already been 25 impacted by this project. So to kind of figure out ARII@courtsteno.com www.courtsteno.com 486 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 11 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 why, if you look up the address I just gave you, this 3 is the document that we're here to discuss tonight -- 4 MR. DAVIS: Can you hear him? 20 I'm also a candidate for town counselor in Cicero for 21 November. 22 MR. DAVIS: Yes. 23 MR. RIORDAN: But most of all, I'm 24 here as a Cicero resident who has already been 25 impacted by this project. So to kind of figure out ARII@courtsteno.com www.courtsteno.com 486 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 11 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 why, if you look up the address I just gave you, this 3 is the document that we're here to discuss tonight -- 4 MR. DAVIS: Can you hear him? 5 COURT REPORTER: Yeah, if he could 6 just speak up a little louder. 7 MR. DAVIS: Can you -- Jay, can you 8 speak up just a little bit more? We're not picking 9 you up. 10 MR. RIORDAN: Oh, okay. 11 COURT REPORTER: There you go. 12 MR. RIORDAN: Do you want to start 13 over or? 14 MR. DAVIS: Yes, please. 15 MR. RIORDAN: Okay. 16 MR. DAVIS: Well, yeah. Give it -- 17 give it a ring again so we can hear you a little bit 18 better. 19 MR. RIORDAN: Okay. Sounds good. 20 MR. DAVIS: Thank you. 21 MR. RIORDAN: All right. I'm Jay 22 Riordan. I live at 8763 Brewerton Road in the town 23 of Cicero. I do represent the Cicero Democratic 24 Committee. I'm also a candidate for town counselor 25 in November, but I'm also here as a Cicero Resident ARII@courtsteno.com www.courtsteno.com 487 5 COURT REPORTER: Yeah, if he could 6 just speak up a little louder. 7 MR. DAVIS: Can you -- Jay, can you 8 speak up just a little bit more? We're not picking 9 you up. 10 MR. RIORDAN: Oh, okay. 11 COURT REPORTER: There you go. 12 MR. RIORDAN: Do you want to start 13 over or? 14 MR. DAVIS: Yes, please. 15 MR. RIORDAN: Okay. 16 MR. DAVIS: Well, yeah. Give it -- 17 give it a ring again so we can hear you a little bit 18 better. 19 MR. RIORDAN: Okay. Sounds good. 20 MR. DAVIS: Thank you. 21 MR. RIORDAN: All right. I'm Jay 22 Riordan. I live at 8763 Brewerton Road in the town 23 of Cicero. I do represent the Cicero Democratic 24 Committee. I'm also a candidate for town counselor 25 in November, but I'm also here as a Cicero Resident ARII@courtsteno.com www.courtsteno.com 487 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 12 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 who's already been impacted by this -- by this 3 project. If you look up the address I just gave you 4 of where I live, you can see why that -- this 5 document in question that we're all here to discuss 6 tonight looks great. And we think it's an excellent 7 piece of planning work. 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 12 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 who's already been impacted by this -- by this 3 project. If you look up the address I just gave you 4 of where I live, you can see why that -- this 5 document in question that we're all here to discuss 6 tonight looks great. And we think it's an excellent 7 piece of planning work. 8 Congratulations to OCIDA and Micron on 9 reaching this milestone. The new Micron campus map on 8 Congratulations to OCIDA and Micron on 9 reaching this milestone. The new Micron campus map on 10 Page Number 14 shows new entrances in the town of 10 Page Number 14 shows new entrances in the town of 11 Cicero off Brewerton between NY-31 and Mud Mill, and 12 it shows the Micron campus itself extending into the 13 town of Cicero. This seems to be -- this seems to be 14 the first public OCIDA document that shows these 15 aspects regarding the town of Cicero. 11 Cicero off Brewerton between NY-31 and Mud Mill, and 12 it shows the Micron campus itself extending into the 13 town of Cicero. This seems to be -- this seems to be 14 the first public OCIDA document that shows these 15 aspects regarding the town of Cicero. 16 And these are two very new interesting 17 developments to residents of Cicero. These new 18 developments have heightened interest in this project 19 among town of Cicero residents like me, and also 20 within the organizations that I represent. 16 And these are two very new interesting 17 developments to residents of Cicero. These new 18 developments have heightened interest in this project 19 among town of Cicero residents like me, and also 20 within the organizations that I represent. 21 Furthermore, I think many Cicero 22 residents are surprised how fast the changes are 23 proceeding. There are particular concerns about 24 congestion and the possible new I-81 off ramp. 21 Furthermore, I think many Cicero 22 residents are surprised how fast the changes are 23 proceeding. There are particular concerns about 24 congestion and the possible new I-81 off ramp. 25 There's -- are environmental concerns, concerns about ARII@courtsteno.com www.courtsteno.com 488 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 13 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 population growth and new build development, and even 3 simpler things like, will our water and electricity 4 go out? And how do we -- as construction proceeds, 5 and how do we keep track of that? 25 There's -- are environmental concerns, concerns about ARII@courtsteno.com www.courtsteno.com 488 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 13 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 population growth and new build development, and even 3 simpler things like, will our water and electricity 4 go out? And how do we -- as construction proceeds, 5 and how do we keep track of that? 6 We want to work with OCIDA on ensuring 7 that Cicero residents can best get information on 8 this project, and especially its impact on Cicero. 6 We want to work with OCIDA on ensuring 7 that Cicero residents can best get information on 8 this project, and especially its impact on Cicero. 9 We hope that OCIDA will work with us, especially with 9 We hope that OCIDA will work with us, especially with 10 Cicero residents like me who are really interested in 11 this project. There are so many municipalities and 12 government levels involved that it can be hard forces 13 for a resident to easily follow new developments. 10 Cicero residents like me who are really interested in 11 this project. There are so many municipalities and 12 government levels involved that it can be hard forces 13 for a resident to easily follow new developments. 14 In particular, we’d really like to 15 work with OCIDA to help find a simple, easy way to 16 keep Cicero residents informed and involved. If 17 there is something we can do to promote easier 18 communication and involvement amongst Cicero 19 residents, please let us know. We think easy, simple 20 access to info is best. Thank you. Again, 21 congratulations on a well thought out and timely 22 document and on hitting this important milestone so 23 quickly. 24 MR. RIORDAN: Thank you, Jay. Donald 25 Hughs, and then after that will be Damian Ulatowski. ARII@courtsteno.com www.courtsteno.com 489 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 14 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 MR. HUGHES: So my name's Don Hughes. 3 And that's H-U-G-H-E-S, last name. I'm here on 4 behalf of the Sierra Club. I'm the conservation 5 chair of the local group, the Central Northern New 14 In particular, we’d really like to 15 work with OCIDA to help find a simple, easy way to 16 keep Cicero residents informed and involved. If 17 there is something we can do to promote easier 18 communication and involvement amongst Cicero 19 residents, please let us know. We think easy, simple 20 access to info is best. Thank you. Again, 21 congratulations on a well thought out and timely 22 document and on hitting this important milestone so 23 quickly. 24 MR. RIORDAN: Thank you, Jay. Donald 25 Hughs, and then after that will be Damian Ulatowski. ARII@courtsteno.com www.courtsteno.com 489 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 14 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 MR. HUGHES: So my name's Don Hughes. 3 And that's H-U-G-H-E-S, last name. I'm here on 4 behalf of the Sierra Club. I'm the conservation 5 chair of the local group, the Central Northern New 6 York Group. We have close to three thousand members 7 in our group, and the Sierra Club itself as a 8 national organization has over six hundred thousand 9 members across the country and affiliates in Canada, 10 Europe, and elsewhere. 6 York Group. We have close to three thousand members 7 in our group, and the Sierra Club itself as a 8 national organization has over six hundred thousand 9 members across the country and affiliates in Canada, 10 Europe, and elsewhere. 11 Recently, the Sierra Club, along with 12 several hundred other groups, sent a letter to the 13 leaders of the semiconductor industry, including the 14 CEO of Micron. And I'm not going to read that letter 15 for brevity's sake, but I want to tell you the 16 motivation. Our concerns stem from the 17 semiconductors' well-documented history starting in 11 Recently, the Sierra Club, along with 12 several hundred other groups, sent a letter to the 13 leaders of the semiconductor industry, including the 14 CEO of Micron. And I'm not going to read that letter 15 for brevity's sake, but I want to tell you the 16 motivation. Our concerns stem from the 17 semiconductors' well-documented history starting in 18 Silicon Valley and expanding globally, polluting the 19 environment, harming workers and their offspring. As 20 well as community residents, bus communities, 21 avoiding taxes and burden of communities with 22 significant problems. 18 Silicon Valley and expanding globally, polluting the 19 environment, harming workers and their offspring. As 20 well as community residents, bus communities, 21 avoiding taxes and burden of communities with 22 significant problems. 23 So I want to raise these issues and I 24 want to recommend or contrast this project with a 25 recent project which went through an extensive ARII@courtsteno.com www.courtsteno.com 490 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 15 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 environmental impact statement, mainly I-81. That 3 project as large it is, pales in comparison to the 4 Micron endeavor. It has a budget of about two-and-a- 5 half billion dollars, which is forty times smaller 6 than the anticipated outlay for Micron. Furthermore, 7 the environmental impacts of Micron will be far 8 larger than I-81 in Syracuse. 23 So I want to raise these issues and I 24 want to recommend or contrast this project with a 25 recent project which went through an extensive ARII@courtsteno.com www.courtsteno.com 490 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 15 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 environmental impact statement, mainly I-81. That 3 project as large it is, pales in comparison to the 4 Micron endeavor. It has a budget of about two-and-a- 5 half billion dollars, which is forty times smaller 6 than the anticipated outlay for Micron. Furthermore, 7 the environmental impacts of Micron will be far 8 larger than I-81 in Syracuse. 9 Micron will consume as much 10 electricity as the states of Vermont and New 9 Micron will consume as much 10 electricity as the states of Vermont and New 11 Hampshire combined, will use close to fifty million 12 gallons of water per day, which is more than the 13 entire city of Syracuse. And Micron will be using 14 chemicals. What I want to recommend to you is that 15 the scope, the DEIS, be expanded to include more 16 alternatives than what you've got. You have simply 17 no action, which is required full build out, half 18 build out. In contrast, I-81 project had multiple 19 design alternatives. So in addition to no build, 20 there were five alternatives included in the Viaduct 21 Category two. And we can even create seven tunnel 22 alternatives and four other alternatives. 11 Hampshire combined, will use close to fifty million 12 gallons of water per day, which is more than the 13 entire city of Syracuse. And Micron will be using 14 chemicals. What I want to recommend to you is that 15 the scope, the DEIS, be expanded to include more 16 alternatives than what you've got. You have simply 17 no action, which is required full build out, half 18 build out. In contrast, I-81 project had multiple 19 design alternatives. So in addition to no build, 20 there were five alternatives included in the Viaduct 21 Category two. And we can even create seven tunnel 22 alternatives and four other alternatives. 23 Micron, DEIS needs to greatly expand 24 its range of alternatives. Micron is to be commended 25 for committing itself to a large degree of ARII@courtsteno.com www.courtsteno.com 491 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 16 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 sustainability, but what is actually achievable? 3 That's the -- that's where the rubber meets the road. 23 Micron, DEIS needs to greatly expand 24 its range of alternatives. Micron is to be commended 25 for committing itself to a large degree of ARII@courtsteno.com www.courtsteno.com 491 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 16 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 sustainability, but what is actually achievable? 3 That's the -- that's where the rubber meets the road. 4 I suggest that the range of electricity options will 5 be considered, say, from 50 percent, 60 percent 6 renewable to a 100 percent renewable. The project is 7 planning to use a significant amount of water. How 8 much of this can be recycled, thereby reducing water 9 consumption? That should be examined as well. And 10 perhaps most importantly is the DEIS should look at a 11 range of alternatives to the chemicals. The 12 semiconductor industry uses perfluorinated 13 components, also known as forever chemicals. They're 14 highly toxic. We need to eliminate these things. 15 Let's not turn Lake Ontario. Thank you. 16 MR. DAVIS: Thank you. Damian 4 I suggest that the range of electricity options will 5 be considered, say, from 50 percent, 60 percent 6 renewable to a 100 percent renewable. The project is 7 planning to use a significant amount of water. How 8 much of this can be recycled, thereby reducing water 9 consumption? That should be examined as well. And 10 perhaps most importantly is the DEIS should look at a 11 range of alternatives to the chemicals. The 12 semiconductor industry uses perfluorinated 13 components, also known as forever chemicals. They're 14 highly toxic. We need to eliminate these things. 15 Let's not turn Lake Ontario. Thank you. 16 MR. DAVIS: Thank you. Damian 17 Ulatowski, and then next will be John Przepiora, 18 maybe. 19 MR. ULATOWSKI: Good evening. My name 20 is Damian Ulatowski. I'm here as both a citizen of 21 the Town of Clay; I'm also the supervisor for the 22 town of Clay. And primarily I'm here because I'm 23 responsible for the health, safety, and welfare of 24 our residents. 25 MR. DAVIS: Damian, can you speak up ARII@courtsteno.com www.courtsteno.com 492 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 17 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 just a little bit more? 3 MR. ULATOWSKI: Absolutely. 4 MR. DAVIS: Maybe move closer to the 5 mic, thanks. 6 MR. ULATOWSKI: Absolutely. You need 7 me to start over again or no? 8 MR. DAVIS: Speak -- you do need to 9 spell your name. 10 MR. ULATOWSKI: Okay. U-L-A-T-O-W-S- 17 Ulatowski, and then next will be John Przepiora, 18 maybe. 19 MR. ULATOWSKI: Good evening. My name 20 is Damian Ulatowski. I'm here as both a citizen of 21 the Town of Clay; I'm also the supervisor for the 22 town of Clay. And primarily I'm here because I'm 23 responsible for the health, safety, and welfare of 24 our residents. 25 MR. DAVIS: Damian, can you speak up ARII@courtsteno.com www.courtsteno.com 492 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 17 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 just a little bit more? 3 MR. ULATOWSKI: Absolutely. 4 MR. DAVIS: Maybe move closer to the 5 mic, thanks. 6 MR. ULATOWSKI: Absolutely. You need 7 me to start over again or no? 8 MR. DAVIS: Speak -- you do need to 9 spell your name. 10 MR. ULATOWSKI: Okay. U-L-A-T-O-W-S- 11 K-I. First of all, I commend the visionaries who have 12 brought Micron to our communities. And I plan on 13 supporting it as much as we possibly can. We want to 14 make sure some environmental concerns are considered. 11 K-I. First of all, I commend the visionaries who have 12 brought Micron to our communities. And I plan on 13 supporting it as much as we possibly can. We want to 14 make sure some environmental concerns are considered. 15 For example, it's been admitted that there are some 16 chimneys or stacks on the individual pots, almost 163 17 feet tall. We're wondering why they are that height 18 and also what are they emitting? You would also like 19 to see some kind of safeguards put out so that, every 20 once in a while, the waters that are being thrown 21 back into where the rivers in our communities are 22 tested every three to four years to make sure they're 23 safe and not contaminated in any way. 15 For example, it's been admitted that there are some 16 chimneys or stacks on the individual pots, almost 163 17 feet tall. We're wondering why they are that height 18 and also what are they emitting? You would also like 19 to see some kind of safeguards put out so that, every 20 once in a while, the waters that are being thrown 21 back into where the rivers in our communities are 22 tested every three to four years to make sure they're 23 safe and not contaminated in any way. 24 Another concern that we have is 25 wastewater leaving the Micron facility. How are we ARII@courtsteno.com www.courtsteno.com 493 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 18 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 ensuring it's being conveyed to oak orchards safely? 24 Another concern that we have is 25 wastewater leaving the Micron facility. How are we ARII@courtsteno.com www.courtsteno.com 493 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 18 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 ensuring it's being conveyed to oak orchards safely? 3 And lastly, as I'm sure we'll hear many of the same 4 questions or comments from residences, how is traffic 5 going to be addressed as the scoping of the project 6 goes further and further and brings not only Micron 7 employees to our -- to our boundaries, but also those 8 support industries that are so vital to that 9 operation and will be instrumental in the growth of 10 our community. Thank you. 11 MR. DAVIS: Thank you. So we have 12 John, and then after that would be Mary Scanlon. 13 MR. PRZEPIORA: My name is John 14 Przepiora, P-R-Z-E-P-I-O-R-A. I'm a resident of the 15 city of Syracuse and Vice President and Director of a 16 not-for-profit organization founded in Syracuse, 17 Greeningusa. Our organization was founded on a need 18 to bring the Green revolution to Syracuse. We 19 believe economic progress is necessary to improve the 20 lives of people, but it must be done in a way to 21 protect the environment, protect the health of 22 people, and protect natural ecosystems. In addition, 23 the impacts, both positive and negative, must be 24 distributed in a just and equitable fashion. The 3 And lastly, as I'm sure we'll hear many of the same 4 questions or comments from residences, how is traffic 5 going to be addressed as the scoping of the project 6 goes further and further and brings not only Micron 7 employees to our -- to our boundaries, but also those 8 support industries that are so vital to that 9 operation and will be instrumental in the growth of 10 our community. Thank you. 11 MR. DAVIS: Thank you. So we have 12 John, and then after that would be Mary Scanlon. 13 MR. PRZEPIORA: My name is John 14 Przepiora, P-R-Z-E-P-I-O-R-A. I'm a resident of the 15 city of Syracuse and Vice President and Director of a 16 not-for-profit organization founded in Syracuse, 17 Greeningusa. Our organization was founded on a need 18 to bring the Green revolution to Syracuse. We 19 believe economic progress is necessary to improve the 20 lives of people, but it must be done in a way to 21 protect the environment, protect the health of 22 people, and protect natural ecosystems. In addition, 23 the impacts, both positive and negative, must be 24 distributed in a just and equitable fashion. The 25 biggest challenge of the Micron project is the ARII@courtsteno.com www.courtsteno.com 494 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 19 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 enormity of it. In order to fulfill the dreams that 3 this project offers and a just equitable, 4 economically, and environmentally sustainable manner, 5 the review process must be equally enormous and 6 thorough. The scoping document presented is a 7 reasonable first draft. 25 biggest challenge of the Micron project is the ARII@courtsteno.com www.courtsteno.com 494 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 19 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 enormity of it. In order to fulfill the dreams that 3 this project offers and a just equitable, 4 economically, and environmentally sustainable manner, 5 the review process must be equally enormous and 6 thorough. The scoping document presented is a 7 reasonable first draft. 8 It seems to be comprehensive, and we 9 support, including all of that has been proposed in 10 the draft, in the final scope. However, the draft is 11 not quite complete, and we believe there is room to 12 improve it. For example, the study area is off that 13 nebulous for many of the technical analysis included 14 in section 5.3. In many cases, it seems to be too 15 narrowly defined. The impacts relating to hazardous 16 materials must be thorough and specific. 8 It seems to be comprehensive, and we 9 support, including all of that has been proposed in 10 the draft, in the final scope. However, the draft is 11 not quite complete, and we believe there is room to 12 improve it. For example, the study area is off that 13 nebulous for many of the technical analysis included 14 in section 5.3. In many cases, it seems to be too 15 narrowly defined. The impacts relating to hazardous 16 materials must be thorough and specific. 17 Specificity must be added to this 18 section on this -- on this topic. Topics such as 19 worker health and safety, supply chain, transport, 20 storage, security, air quality, spill release 21 response, and residual disposal must be included. 17 Specificity must be added to this 18 section on this -- on this topic. Topics such as 19 worker health and safety, supply chain, transport, 20 storage, security, air quality, spill release 21 response, and residual disposal must be included. 22 Cradle to grave analysis must be provided to decision 23 makers as well as community members to be fully 24 informed. The section on community services and 25 recreation, it's kind of a jumble of important topics ARII@courtsteno.com www.courtsteno.com 495 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 20 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 and it needs a little more specificity. 22 Cradle to grave analysis must be provided to decision 23 makers as well as community members to be fully 24 informed. The section on community services and 25 recreation, it's kind of a jumble of important topics ARII@courtsteno.com www.courtsteno.com 495 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 20 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 and it needs a little more specificity. 3 The study area for that section may be 4 too restricted and notably absent our healthcare and 5 hospital services. The section on socioeconomic 6 condition seems to be comprehensive and proposes a 7 complete assessment of the growth the project will 8 induce and the economic and fiscal impact. Which 9 will be necessary to be utilized in other sections. 3 The study area for that section may be 4 too restricted and notably absent our healthcare and 5 hospital services. The section on socioeconomic 6 condition seems to be comprehensive and proposes a 7 complete assessment of the growth the project will 8 induce and the economic and fiscal impact. Which 9 will be necessary to be utilized in other sections. 10 For example, the impact of growth and its related 11 economic impact are likely to impact community 12 character in a significant way. 10 For example, the impact of growth and its related 11 economic impact are likely to impact community 12 character in a significant way. 13 I'm not talking about the visual 14 changes near the White Pine Park, but the potential 15 development in the greater Syracuse community. These 16 impacts, such as residential and commercial 17 developments, have the potential to change the 18 character of the neighborhoods throughout the greater 19 Syracuse area. The growth presents challenges as 20 well as opportunities, which should be understood by 21 decision makers and community members. It begs the 22 question how can such impacts be managed in a 23 sustainable, just, and equitable fashion. We have 24 additional comments that will be submitted in written 25 form. ARII@courtsteno.com www.courtsteno.com 496 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 21 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 13 I'm not talking about the visual 14 changes near the White Pine Park, but the potential 15 development in the greater Syracuse community. These 16 impacts, such as residential and commercial 17 developments, have the potential to change the 18 character of the neighborhoods throughout the greater 19 Syracuse area. The growth presents challenges as 20 well as opportunities, which should be understood by 21 decision makers and community members. It begs the 22 question how can such impacts be managed in a 23 sustainable, just, and equitable fashion. We have 24 additional comments that will be submitted in written 25 form. ARII@courtsteno.com www.courtsteno.com 496 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 21 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 But the most important thing to 3 understand, and I'll close with this point. This 4 project, which is double in size from the early 5 vision of the White Pine Park Project, deserves a 6 rigorous review consistent with the enormity of the 7 project. I urge you to create a final scope for the 8 review that is up to the task to get this right and 9 to protect the interest of today's community and its 10 members for generations to come. Thank you very much. 11 MR. DAVIS: Thank you. Mary Scanlon 12 and after Mary will be Diana Elliot. 13 MS. SCANLON: Evening. I'm Mary 14 Scanlon, S-C-A-N-L-O-N. I live 15 on Lakeshore Road in the town of 16 Cicero, 7267 Lakeshore Road. I was not prepared to 17 speak tonight, so I just had a few comments. A lot 18 of things that I had concerns with have already been 19 addressed. Property taxes for one. Also the traffic. 2 But the most important thing to 3 understand, and I'll close with this point. This 4 project, which is double in size from the early 5 vision of the White Pine Park Project, deserves a 6 rigorous review consistent with the enormity of the 7 project. I urge you to create a final scope for the 8 review that is up to the task to get this right and 9 to protect the interest of today's community and its 10 members for generations to come. Thank you very much. 11 MR. DAVIS: Thank you. Mary Scanlon 12 and after Mary will be Diana Elliot. 13 MS. SCANLON: Evening. I'm Mary 14 Scanlon, S-C-A-N-L-O-N. I live 15 on Lakeshore Road in the town of 16 Cicero, 7267 Lakeshore Road. I was not prepared to 17 speak tonight, so I just had a few comments. A lot 18 of things that I had concerns with have already been 19 addressed. Property taxes for one. Also the traffic. 20 I wasn't sure how many entrances to the campus there 21 were going to be, what the traffic flow was going to 22 be for the delivery trucks and what the route to the 23 highway was going to be. Also, I had concerns about 24 the wastewater storage and treatment and that has 25 also been discussed. What exactly is the industrial ARII@courtsteno.com www.courtsteno.com 497 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 22 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 wastewater? What is being treated? What's the 3 byproduct of the industry? What's the pollutant that 4 they're treating? And how will it be monitored? How 5 will we ensure that our -- the environment of our 6 community will be protected? And that's all I have. 7 Thank you. 8 MR. DAVIS: Thank you. Diana Elliot. 9 Next after that would be Jim Nistico. 10 MS. ELLIOTT: My name is Diana Elliot, 20 I wasn't sure how many entrances to the campus there 21 were going to be, what the traffic flow was going to 22 be for the delivery trucks and what the route to the 23 highway was going to be. Also, I had concerns about 24 the wastewater storage and treatment and that has 25 also been discussed. What exactly is the industrial ARII@courtsteno.com www.courtsteno.com 497 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 22 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 wastewater? What is being treated? What's the 3 byproduct of the industry? What's the pollutant that 4 they're treating? And how will it be monitored? How 5 will we ensure that our -- the environment of our 6 community will be protected? And that's all I have. 7 Thank you. 8 MR. DAVIS: Thank you. Diana Elliot. 9 Next after that would be Jim Nistico. 10 MS. ELLIOTT: My name is Diana Elliot, 11 E-L-L-I-O-T-T. I live in Syracuse. Can you hear me? 12 MR. DAVIS: I -- just speak a touch 13 louder. 14 MS. ELLIOTT: Okay. I'll be brief. 11 E-L-L-I-O-T-T. I live in Syracuse. Can you hear me? 12 MR. DAVIS: I -- just speak a touch 13 louder. 14 MS. ELLIOTT: Okay. I'll be brief. 15 I'm an architect and I was interested to learn about 16 the impact of embodied carbon as well as operational 17 carbon in both the Micron plant and the associated 18 growth. And further thoughts on this, I'll submit in 19 written comment. 20 MR. DAVIS: Thank you. Jim Nistico, 21 after that, will be Denise Androvette. 22 MR. NISTICO: Is this mic -- yeah. 15 I'm an architect and I was interested to learn about 16 the impact of embodied carbon as well as operational 17 carbon in both the Micron plant and the associated 18 growth. And further thoughts on this, I'll submit in 19 written comment. 20 MR. DAVIS: Thank you. Jim Nistico, 21 after that, will be Denise Androvette. 22 MR. NISTICO: Is this mic -- yeah. 23 Can you guys hear me? 24 MR. DAVIS: Yes. All right. 25 MR. NISTICO: Jim Nistico, and it's ARII@courtsteno.com www.courtsteno.com 498 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 23 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 spelled N-I-S-T-I-C-O. I am a business owner and a 3 resident in the town of Clay in the Laden Valley 4 development right across the street from where the 5 project is going to happen. And while I'm all for 6 this project as a business owner and I'm also excited 7 for the community, I do have a couple of concerns as 8 a citizen of the town of Clay. And, you know, again, 9 it's what everyone's mentioned, traffic. My thoughts 10 are to have Route 31 be six lanes from Baldwinsville 11 to Bridgeport, if that can be done smartly without 12 uprooting residences and businesses. 23 Can you guys hear me? 24 MR. DAVIS: Yes. All right. 25 MR. NISTICO: Jim Nistico, and it's ARII@courtsteno.com www.courtsteno.com 498 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 23 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 spelled N-I-S-T-I-C-O. I am a business owner and a 3 resident in the town of Clay in the Laden Valley 4 development right across the street from where the 5 project is going to happen. And while I'm all for 6 this project as a business owner and I'm also excited 7 for the community, I do have a couple of concerns as 8 a citizen of the town of Clay. And, you know, again, 9 it's what everyone's mentioned, traffic. My thoughts 10 are to have Route 31 be six lanes from Baldwinsville 11 to Bridgeport, if that can be done smartly without 12 uprooting residences and businesses. 13 And also the growth and expansion of 14 roadways in and around the campus of Micron where 15 it's going to be put. I did have thoughts of 16 possibly having, you know, obviously the exit off of 17 Mud Mill. I've heard rumors that that may happen and 18 maybe a parkway similar to a John Glen Boulevard to 19 give easy bypassing access to the Micron campus, if 20 at all possible, to help alleviate the traffic of the 21 current roads that exist now. 13 And also the growth and expansion of 14 roadways in and around the campus of Micron where 15 it's going to be put. I did have thoughts of 16 possibly having, you know, obviously the exit off of 17 Mud Mill. I've heard rumors that that may happen and 18 maybe a parkway similar to a John Glen Boulevard to 19 give easy bypassing access to the Micron campus, if 20 at all possible, to help alleviate the traffic of the 21 current roads that exist now. 22 Also, the noise when construction is 23 happening, just a little concern. I understand when 24 they start construction at the end of next year, 25 they're supposed to start production in two years, so ARII@courtsteno.com www.courtsteno.com 499 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 24 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 that sounds like they're going to be going 24/7 3 construction. Just curious if that's going to be 4 like overnight and be hearing noises overnight, 5 construction noises. But other than that, I'm all 6 for this project long as it's done smartly. I think 7 that this is nothing. You know, this is a great gift 8 for the Syracuse area and hopefully, it is done 9 smartly and correctly, and I look forward to seeing 10 what happens. That's all we got. 11 MR. DAVIS: Thank you. We have Denise 12 and then would be Debra Descocio. 13 MS. ANDROVETTE: Good evening. My 22 Also, the noise when construction is 23 happening, just a little concern. I understand when 24 they start construction at the end of next year, 25 they're supposed to start production in two years, so ARII@courtsteno.com www.courtsteno.com 499 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 24 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 that sounds like they're going to be going 24/7 3 construction. Just curious if that's going to be 4 like overnight and be hearing noises overnight, 5 construction noises. But other than that, I'm all 6 for this project long as it's done smartly. I think 7 that this is nothing. You know, this is a great gift 8 for the Syracuse area and hopefully, it is done 9 smartly and correctly, and I look forward to seeing 10 what happens. That's all we got. 11 MR. DAVIS: Thank you. We have Denise 12 and then would be Debra Descocio. 13 MS. ANDROVETTE: Good evening. My 14 name is Denise Androvette, A-N-D-R-O-V-E-T-T-E. I 15 live in the town of Salina. Number of well-spoken 16 individuals. I'm going to reiterate, as a member of 14 name is Denise Androvette, A-N-D-R-O-V-E-T-T-E. I 15 live in the town of Salina. Number of well-spoken 16 individuals. I'm going to reiterate, as a member of 17 Sierra Club and a very concerned citizen, that the 18 threat of the fluorocarbons, PFOS forever chemicals 19 for our community is very real. And I would expect 20 there would be a plan to 100 percent protect us from 21 exposure. This includes the construction workers 22 putting up the plant, and then the workers who will 23 be at the plant. 17 Sierra Club and a very concerned citizen, that the 18 threat of the fluorocarbons, PFOS forever chemicals 19 for our community is very real. And I would expect 20 there would be a plan to 100 percent protect us from 21 exposure. This includes the construction workers 22 putting up the plant, and then the workers who will 23 be at the plant. 24 And there's a questionable track 25 record of exposure to workers. I would think with ARII@courtsteno.com www.courtsteno.com 500 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 25 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 this extraordinary attempt, that great improvement 3 could happen for chemical safety. And I'm going to 4 throw in another comment that's missing when I hear 5 about twelve thousand parking spaces that there 6 should be comprehensive hub transportation plan 7 across on Onondaga County for workers to this Micron 8 plant. Thank you for your time. 9 MR. DAVIS: Thank you. We have 10 Deborah, and then next would be Peter Wirth. 11 MS. DESCOCIO: Okay. I'm Deborah 12 DeScocio. It's D-E- capital S-C-O-C-I-O. I'm here 13 as a citizen, but I'm also with the Sierra Club. I 14 sit on the Conservation Committee. (unintelligible) 24 And there's a questionable track 25 record of exposure to workers. I would think with ARII@courtsteno.com www.courtsteno.com 500 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 25 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 this extraordinary attempt, that great improvement 3 could happen for chemical safety. And I'm going to 4 throw in another comment that's missing when I hear 5 about twelve thousand parking spaces that there 6 should be comprehensive hub transportation plan 7 across on Onondaga County for workers to this Micron 8 plant. Thank you for your time. 9 MR. DAVIS: Thank you. We have 10 Deborah, and then next would be Peter Wirth. 11 MS. DESCOCIO: Okay. I'm Deborah 12 DeScocio. It's D-E- capital S-C-O-C-I-O. I'm here 13 as a citizen, but I'm also with the Sierra Club. I 14 sit on the Conservation Committee. (unintelligible) 15 have a carbon problem. I believe that the public 16 should be informed about the plan to prevent 17 fluorocarbons from being introduced into our local 18 air. Reducing emissions through clean energy usage 19 and energy conservation projects will make this inner 20 speed more sustainable. This must take place and the 21 public should be informed along the way. Thank you. 22 MR. DAVIS: Thank you, Deborah. Peter 23 Wirth, followed by Brian Heffron. 24 MR. WIRTH: My name's Peter Wirth, W- 25 I-R-T-H. I'm a resident of (unintelligible). And ARII@courtsteno.com www.courtsteno.com 501 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 26 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 15 have a carbon problem. I believe that the public 16 should be informed about the plan to prevent 17 fluorocarbons from being introduced into our local 18 air. Reducing emissions through clean energy usage 19 and energy conservation projects will make this inner 20 speed more sustainable. This must take place and the 21 public should be informed along the way. Thank you. 22 MR. DAVIS: Thank you, Deborah. Peter 23 Wirth, followed by Brian Heffron. 24 MR. WIRTH: My name's Peter Wirth, W- 25 I-R-T-H. I'm a resident of (unintelligible). And ARII@courtsteno.com www.courtsteno.com 501 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 26 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 I'm also a volunteer of the local Climate Change 3 Organization. Climate Change Awareness and action. 2 I'm also a volunteer of the local Climate Change 3 Organization. Climate Change Awareness and action. 4 If New York State is to meet the Greenhouse goals set 5 forth in the Climate Leadership Community Protection 4 If New York State is to meet the Greenhouse goals set 5 forth in the Climate Leadership Community Protection 6 Act passed in 2019, careful attention must be paid to 7 ensuring the energy at the plant will be fossil free. 6 Act passed in 2019, careful attention must be paid to 7 ensuring the energy at the plant will be fossil free. 8 CCAA, therefore, is highlighting the following 9 concerns. Heating in the plant should be electric 10 heat pumps, air or ground source, not gas furnaces. 8 CCAA, therefore, is highlighting the following 9 concerns. Heating in the plant should be electric 10 heat pumps, air or ground source, not gas furnaces. 11 And this should, by the way, include all the 12 buildings on the campuses, including the daycare 13 center, any administrative buildings, et cetera. 14 Cooling should be electrical. Based on conversations 15 we've had with Micron officials, they told us that 16 this should be possible to use electric heat pumps 17 for heating and cooling. 18 Cooking facilities. The cafeteria 19 will be designed to serve 9,000 employees. There 20 should be no natural gas in the cafete -- in the 21 cafeteria, or same thing with the cooking facilities 22 at the daycare center. Induction stoves, electrical, 23 for commercial use are available. And we've actually 24 been in contact with Micron concerning a designer in 11 And this should, by the way, include all the 12 buildings on the campuses, including the daycare 13 center, any administrative buildings, et cetera. 14 Cooling should be electrical. Based on conversations 15 we've had with Micron officials, they told us that 16 this should be possible to use electric heat pumps 17 for heating and cooling. 18 Cooking facilities. The cafeteria 19 will be designed to serve 9,000 employees. There 20 should be no natural gas in the cafete -- in the 21 cafeteria, or same thing with the cooking facilities 22 at the daycare center. Induction stoves, electrical, 23 for commercial use are available. And we've actually 24 been in contact with Micron concerning a designer in 25 Pittsburgh who designs commercial induction and ARII@courtsteno.com www.courtsteno.com 502 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 27 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 electric cooking facilities. Hot water use, no 3 natural gas electric hot waters. Electrical usage, 4 this is the 900-pound gorilla. The plant, according 5 to newspaper reports, would use as much electricity 6 as the state of Vermont, New Hampshire; it's like 7 sixteen billion kilowatts. All electricity from the 8 -- should be freed from fossil. Fossil free sources 9 of energy, no coal, gas, or oil-fired electrical 10 production. 25 Pittsburgh who designs commercial induction and ARII@courtsteno.com www.courtsteno.com 502 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 27 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 electric cooking facilities. Hot water use, no 3 natural gas electric hot waters. Electrical usage, 4 this is the 900-pound gorilla. The plant, according 5 to newspaper reports, would use as much electricity 6 as the state of Vermont, New Hampshire; it's like 7 sixteen billion kilowatts. All electricity from the 8 -- should be freed from fossil. Fossil free sources 9 of energy, no coal, gas, or oil-fired electrical 10 production. 11 As soon as possible, a plan should be 12 released as to where this energy will come from. 13 This is a massive undertaking on the site. Solar 14 production, despite a million square feet of roof 15 surfaces in the four buildings, which would be 16 available for rooftop solar. The initial 17 architectural drawings did not indicate any rooftop 18 solar. We also have very productive conversations 19 with Micron officials, and we were told that they're 20 in the process of coming up with this new 21 architectural drawings, which will reflect rooftop 22 solar. 23 There could be local solar farms. 24 There could be solar canopies in the parking lot. 11 As soon as possible, a plan should be 12 released as to where this energy will come from. 13 This is a massive undertaking on the site. Solar 14 production, despite a million square feet of roof 15 surfaces in the four buildings, which would be 16 available for rooftop solar. The initial 17 architectural drawings did not indicate any rooftop 18 solar. We also have very productive conversations 19 with Micron officials, and we were told that they're 20 in the process of coming up with this new 21 architectural drawings, which will reflect rooftop 22 solar. 23 There could be local solar farms. 24 There could be solar canopies in the parking lot. 25 You know, obviously given the massive amounts, no on ARII@courtsteno.com www.courtsteno.com 503 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 28 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 site solar will be enough for the production of 3 meeting the needs of the plant. 4 Natural gas usage. My understanding 5 is that there are plans for a sixteen-inch high 6 pressure pipeline carrying millions of cubic feet of 7 natural gas, a fossil fuel being constructed to the 8 Micron facility. The gas will be used as part of the 9 industrial process, greenhouse gas, and if at all 10 possible, natural gas should be replaced with green 11 hydrogen. Green hydrogen is hydrogen produced with 12 non-fossil fuel energy. If natural gas is not 13 replaced with green hydrogen, the plant should not be 14 referred to as using a 100 percent renewable energy. 25 You know, obviously given the massive amounts, no on ARII@courtsteno.com www.courtsteno.com 503 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 28 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 site solar will be enough for the production of 3 meeting the needs of the plant. 4 Natural gas usage. My understanding 5 is that there are plans for a sixteen-inch high 6 pressure pipeline carrying millions of cubic feet of 7 natural gas, a fossil fuel being constructed to the 8 Micron facility. The gas will be used as part of the 9 industrial process, greenhouse gas, and if at all 10 possible, natural gas should be replaced with green 11 hydrogen. Green hydrogen is hydrogen produced with 12 non-fossil fuel energy. If natural gas is not 13 replaced with green hydrogen, the plant should not be 14 referred to as using a 100 percent renewable energy. 15 As our county executive national grid 16 and other officials are currently referring to the 17 plant. We hope OCIDA will point out to county 18 officials and stakeholders that the plant is 19 currently designed should not be referred to as using 20 a 100 percent renewable energy, as this is misleading 21 to the public on the environmental impact of the trip 22 manufacturing process. Thank you. 23 MR. HUGHS: Thank you. Brian Heffron. 24 MR. HEFFRON: Hello. Good evening. 15 As our county executive national grid 16 and other officials are currently referring to the 17 plant. We hope OCIDA will point out to county 18 officials and stakeholders that the plant is 19 currently designed should not be referred to as using 20 a 100 percent renewable energy, as this is misleading 21 to the public on the environmental impact of the trip 22 manufacturing process. Thank you. 23 MR. HUGHS: Thank you. Brian Heffron. 24 MR. HEFFRON: Hello. Good evening. 25 Brian Heffron, B-R-I-A-N H-E-F-F-R-O-N, 8268 Mantova ARII@courtsteno.com www.courtsteno.com 504 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 29 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 Drive, Clay, New York. As a citizen of Clay, and I 3 wasn't going to speak tonight, but I just thought of 4 this here in listening to others. In the news this 5 week, there was an announcement about a multimillion- 6 dollar rail infrastructure improvement plan for -- in 7 Oswego County. 25 Brian Heffron, B-R-I-A-N H-E-F-F-R-O-N, 8268 Mantova ARII@courtsteno.com www.courtsteno.com 504 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 29 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 Drive, Clay, New York. As a citizen of Clay, and I 3 wasn't going to speak tonight, but I just thought of 4 this here in listening to others. In the news this 5 week, there was an announcement about a multimillion- 6 dollar rail infrastructure improvement plan for -- in 7 Oswego County. 8 That's a -- they're moving forward on 9 a grant, and much of that is a focus on moving 10 production or moving aluminum away from trucks that 11 are going into Canada more relying on aluminum that 12 will be coming from plants that are in the south part 13 of the country. 8 That's a -- they're moving forward on 9 a grant, and much of that is a focus on moving 10 production or moving aluminum away from trucks that 11 are going into Canada more relying on aluminum that 12 will be coming from plants that are in the south part 13 of the country. 14 It just brought, and I sort of a 15 thought to myself to make sure that the scope does 16 consider and focus and put ample attention towards 17 the rail line. I'm not sure if the current CSX line 18 that is moving across 31 is a part of what would be 19 an increase in that rail traffic because of -- if 20 that movement happened with that grant and that 21 played out in (unintelligible). But I just want to, 22 you know, make sure that the scope looks at the rail 23 lines and the impact of the rail service and of an 24 increase in that surface as we move forward here in 25 the future generation. Thank you. ARII@courtsteno.com www.courtsteno.com 505 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 30 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 MR. DAVIS: Thank you. Great. Thank 3 you. That is all the speakers that pre-registered 4 and filled out a comment card. So I am going to open 14 It just brought, and I sort of a 15 thought to myself to make sure that the scope does 16 consider and focus and put ample attention towards 17 the rail line. I'm not sure if the current CSX line 18 that is moving across 31 is a part of what would be 19 an increase in that rail traffic because of -- if 20 that movement happened with that grant and that 21 played out in (unintelligible). But I just want to, 22 you know, make sure that the scope looks at the rail 23 lines and the impact of the rail service and of an 24 increase in that surface as we move forward here in 25 the future generation. Thank you. ARII@courtsteno.com www.courtsteno.com 505 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 30 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 MR. DAVIS: Thank you. Great. Thank 3 you. That is all the speakers that pre-registered 4 and filled out a comment card. So I am going to open 5 it up to anybody that has sat out there and said that 6 they want to make a comment. You certainly are free 7 to come up to a microphone. It'll be the same 8 request that you try to keep your comments to three 9 minutes. 5 it up to anybody that has sat out there and said that 6 they want to make a comment. You certainly are free 7 to come up to a microphone. It'll be the same 8 request that you try to keep your comments to three 9 minutes. 10 State your name clearly and otherwise 11 we will keep this open in case anybody shows up or 12 decides that they want to speak over the next few 13 minutes, half hour or so. But we will accept any 14 further comments from anybody sitting out there. You 15 can certainly provide written comments written up 16 until the 20th. We encourage you to do that. I know 17 a few speakers said they would provide written 18 comments in their addresses earlier. 19 Yes, sir. 20 MR. HUGHES: I limited myself to three 21 minutes because that was the limit. But I do have 22 more extension comments. My comment is to elaborate 23 more on the forever chemicals. This is a great --. 24 MR. DAVIS: Can state your name again 25 please? ARII@courtsteno.com www.courtsteno.com 506 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 31 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 10 State your name clearly and otherwise 11 we will keep this open in case anybody shows up or 12 decides that they want to speak over the next few 13 minutes, half hour or so. But we will accept any 14 further comments from anybody sitting out there. You 15 can certainly provide written comments written up 16 until the 20th. We encourage you to do that. I know 17 a few speakers said they would provide written 18 comments in their addresses earlier. 19 Yes, sir. 20 MR. HUGHES: I limited myself to three 21 minutes because that was the limit. But I do have 22 more extension comments. My comment is to elaborate 23 more on the forever chemicals. This is a great --. 24 MR. DAVIS: Can state your name again 25 please? ARII@courtsteno.com www.courtsteno.com 506 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 31 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 MR. HUGHS: Sure, I'll certainly do 3 that. Don Hughes, H-U-G-H-E-S. And conservation 4 sheriff of the local Sierra Club group. So today's 5 the October 11th, six days ago in Forbes magazine an 6 article came out, More Domestic Chip-Making Means 7 More Forever Chemicals. So this is a major concern 8 of the Sierra Club and all those other co-signers in 9 that letter to the semiconductor industry. Forever 2 MR. HUGHS: Sure, I'll certainly do 3 that. Don Hughes, H-U-G-H-E-S. And conservation 4 sheriff of the local Sierra Club group. So today's 5 the October 11th, six days ago in Forbes magazine an 6 article came out, More Domestic Chip-Making Means 7 More Forever Chemicals. So this is a major concern 8 of the Sierra Club and all those other co-signers in 9 that letter to the semiconductor industry. Forever 10 Chemicals is the colloquial name for PFAS 11 polyfluoroalkyl substances. And the toxicity of 12 these things is -- a lot of is mind boggling. The 10 Chemicals is the colloquial name for PFAS 11 polyfluoroalkyl substances. And the toxicity of 12 these things is -- a lot of is mind boggling. The 13 EPA recently reduced the allowable amount of 14 perfluorooctanoic acid from seventy parts per 15 trillion to point five. That's parts per trillion, 16 not parts per billion or million, trillion. One in 17 ten to the twelfth. Tiny, tiny quantities are shown 18 to be toxic to babies. They are linked to cancer. 19 They're linked to genetic defects. 13 EPA recently reduced the allowable amount of 14 perfluorooctanoic acid from seventy parts per 15 trillion to point five. That's parts per trillion, 16 not parts per billion or million, trillion. One in 17 ten to the twelfth. Tiny, tiny quantities are shown 18 to be toxic to babies. They are linked to cancer. 19 They're linked to genetic defects. 20 This article talks about the 21 inevitability of PFAs. The guy from the chemical 22 maker Chemours says, “You cannot make chips without 23 the whole PFA infrastructure.” That's perfluor 24 compounds. We estimate that it's a modern-day fact 25 there's a half kilo of PFA in every square foot. So ARII@courtsteno.com www.courtsteno.com 507 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 32 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 on 400,000 to 600,000 square foot fab, that's two 3 hundred to three hundred metric tons of this stuff. 4 This EIS has got to evaluate these compounds. What's 5 written -- in the document right now it talks about 6 solid waste. And then there's a kind of a cursory 7 allusion to chemicals that you will -- DEIS will 8 identify any hazardous materials, including chemical 9 or petroleum bulk storage that would be used towards 10 transport or generated by the proposed project and 20 This article talks about the 21 inevitability of PFAs. The guy from the chemical 22 maker Chemours says, “You cannot make chips without 23 the whole PFA infrastructure.” That's perfluor 24 compounds. We estimate that it's a modern-day fact 25 there's a half kilo of PFA in every square foot. So ARII@courtsteno.com www.courtsteno.com 507 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 32 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 2 on 400,000 to 600,000 square foot fab, that's two 3 hundred to three hundred metric tons of this stuff. 4 This EIS has got to evaluate these compounds. What's 5 written -- in the document right now it talks about 6 solid waste. And then there's a kind of a cursory 7 allusion to chemicals that you will -- DEIS will 8 identify any hazardous materials, including chemical 9 or petroleum bulk storage that would be used towards 10 transport or generated by the proposed project and 11 measures to protect against releases to the 12 environment. We got to do better than that, folks. 13 This is a serious thing. We've seen what happened to 14 Onondaga Lake, with the industry that grew up there. 11 measures to protect against releases to the 12 environment. We got to do better than that, folks. 13 This is a serious thing. We've seen what happened to 14 Onondaga Lake, with the industry that grew up there. 15 This is a different animal clearly, but the toxicity 16 of these chemicals is not to be understated. We have 17 got to eliminate them. Thank you. 18 MR. DAVIS: Thank you. Anyone else? 15 This is a different animal clearly, but the toxicity 16 of these chemicals is not to be understated. We have 17 got to eliminate them. Thank you. 18 MR. DAVIS: Thank you. Anyone else? 19 Well, we're just going to sit here for a little 20 while. If you would like to end your evening this 21 evening, you can certainly get up and go. We will 22 keep this open in case there's any people that show 23 up that make -- want to make a comment between now 24 and seven-thirty. Thank you. You're welcome. 25 (The hearing concluded at 7:30 p.m.) ARII@courtsteno.com www.courtsteno.com 508 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 33 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 19 Well, we're just going to sit here for a little 20 while. If you would like to end your evening this 21 evening, you can certainly get up and go. We will 22 keep this open in case there's any people that show 23 up that make -- want to make a comment between now 24 and seven-thirty. Thank you. You're welcome. 25 (The hearing concluded at 7:30 p.m.) ARII@courtsteno.com www.courtsteno.com 508 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 33 1 10/11/23 - Micron Project SEQRA Scoping – Public Hearing 3 I, NICOLE BUNNELL, do hereby certify that the foregoing 4 was reported by me, in the cause, at the time and place, 5 as stated in the caption hereto, at Page 1 hereof; that 6 the foregoing typewritten transcription consisting of 7 pages 1 through 32, is a true record of all proceedings 8 had at the hearing. 3 I, NICOLE BUNNELL, do hereby certify that the foregoing 4 was reported by me, in the cause, at the time and place, 5 as stated in the caption hereto, at Page 1 hereof; that 6 the foregoing typewritten transcription consisting of 7 pages 1 through 32, is a true record of all proceedings 8 had at the hearing. 9 IN WITNESS WHEREOF, I have hereunto 10 subscribed my name, this the 18th day of October, 2023. 11 9 IN WITNESS WHEREOF, I have hereunto 10 subscribed my name, this the 18th day of October, 2023. 11 12 NICOLE BUNNELL, Reporter 13 14 15 16 17 18 19 20 21 22 23 24 25 ARII@courtsteno.com www.courtsteno.com 509 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 34 12 NICOLE BUNNELL, Reporter 13 14 15 16 17 18 19 20 21 22 23 24 25 ARII@courtsteno.com www.courtsteno.com 509 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 34 A applause 5:5 A-N-D-R-O-V-E-T-T-E 24:14 applicant 6:7 absent 20:4 application 3:8 Absolutely 17:3,6 Appreciate 7:13 accept 30:13 approved 8:12 accepted 6:10 approximately 9:2,3,7 access 13:20 23:19 architect 22:15 accountability 10:3 architectural 27:17,21 accurate 5:2,6 area 19:12 20:3,19 24:8 achievable 16:2 areas 8:20 acid 31:14 article 31:6,20 Act 3:18 26:6 aspects 12:15 action 4:5 15:17 26:3 assess 9:16 added 19:17 assessment 20:7 addition 15:19 18:22 assistance 3:9 additional 5:13 9:5 20:24 associated 8:15 9:21 22:17 address 6:6 7:6 9:9,20 11:2 attempt 25:2 12:3 attendance 3:10 5:3 addressed 4:6 9:23 18:5 21:19 attention 26:6 29:16 addresses 30:18 audience 2:19 adequate 9:17 auditorium 1:11 2:12,13 administrative 26:13 available 2:17 5:24 26:23 27:16 admitted 17:15 avoiding 14:21 adverse 3:23 aware 3:10 affiliates 14:9 Awareness 26:3 agency 2:8 3:20 4:14 B ago 31:5 agree 5:4 B-R-I-A-N 28:25 air 19:20 25:18 26:10 babies 31:18 alleviate 23:20 back 5:12 7:8 10:11 17:21 allow 5:14 Baldwinsville 23:10 allowable 31:13 Based 26:14 allowed 5:12 begs 20:21 allusion 32:7 behalf 2:23 14:4 alternatives 15:16,19,20,22,22 believe 18:19 19:11 25:15 15:24 16:11 best 13:7,20 aluminum 29:10,11 better 11:18 32:12 Amanda 1:20 3:3 biggest 18:25 American 2:18 billion 3:11 15:5 27:7 31:16 amount 16:7 31:13 bit 11:8,17 17:2 amounts 27:25 Bob 2:7 7:2,9 ample 29:16 boggling 31:12 analyses 4:4 Boulevard 23:18 analysis 19:13,22 boundaries 18:7 Androvette 22:21 24:13,14 brevity's 14:15 animal 32:15 Brewerton 10:15 11:22 12:11 announcement 29:5 Brian 25:23 28:23,25 anticipated 9:4,6,8 10:4 15:6 Bridgeport 23:11 anybody 2:20 30:5,11,14 brief 22:14 bring 18:18 A applause 5:5 A-N-D-R-O-V-E-T-T-E 24:14 applicant 6:7 absent 20:4 application 3:8 Absolutely 17:3,6 Appreciate 7:13 accept 30:13 approved 8:12 accepted 6:10 approximately 9:2,3,7 access 13:20 23:19 architect 22:15 accountability 10:3 architectural 27:17,21 accurate 5:2,6 area 19:12 20:3,19 24:8 achievable 16:2 areas 8:20 acid 31:14 article 31:6,20 Act 3:18 26:6 aspects 12:15 action 4:5 15:17 26:3 assess 9:16 added 19:17 assessment 20:7 addition 15:19 18:22 assistance 3:9 additional 5:13 9:5 20:24 associated 8:15 9:21 22:17 address 6:6 7:6 9:9,20 11:2 attempt 25:2 12:3 attendance 3:10 5:3 addressed 4:6 9:23 18:5 21:19 attention 26:6 29:16 addresses 30:18 audience 2:19 adequate 9:17 auditorium 1:11 2:12,13 administrative 26:13 available 2:17 5:24 26:23 27:16 admitted 17:15 avoiding 14:21 adverse 3:23 aware 3:10 affiliates 14:9 Awareness 26:3 agency 2:8 3:20 4:14 B ago 31:5 agree 5:4 B-R-I-A-N 28:25 air 19:20 25:18 26:10 babies 31:18 alleviate 23:20 back 5:12 7:8 10:11 17:21 allow 5:14 Baldwinsville 23:10 allowable 31:13 Based 26:14 allowed 5:12 begs 20:21 allusion 32:7 behalf 2:23 14:4 alternatives 15:16,19,20,22,22 believe 18:19 19:11 25:15 15:24 16:11 best 13:7,20 aluminum 29:10,11 better 11:18 32:12 Amanda 1:20 3:3 biggest 18:25 American 2:18 billion 3:11 15:5 27:7 31:16 amount 16:7 31:13 bit 11:8,17 17:2 amounts 27:25 Bob 2:7 7:2,9 ample 29:16 boggling 31:12 analyses 4:4 Boulevard 23:18 analysis 19:13,22 boundaries 18:7 Androvette 22:21 24:13,14 brevity's 14:15 animal 32:15 Brewerton 10:15 11:22 12:11 announcement 29:5 Brian 25:23 28:23,25 anticipated 9:4,6,8 10:4 15:6 Bridgeport 23:11 anybody 2:20 30:5,11,14 brief 22:14 bring 18:18 ARII@courtsteno.com www.courtsteno.com 510 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 35 brings 18:6 character 8:10 20:12,18 brought 17:12 29:14 chemical 25:3 31:21 32:8 budget 15:4 chemicals 15:14 16:11,13 24:18 build 3:12 9:7 13:2 15:17,18,19 30:23 31:7,10 32:7,16 buildings 26:12,13 27:15 Chemours 31:22 bulk 32:9 chimneys 17:16 Bunnell 1:23 33:3,12 Chip-Making 31:6 burden 14:21 chips 31:22 bus 14:20 Cicero 10:15,19,20,24 11:23,23 business 23:2,6 11:25 12:11,13,15,17,19,21 businesses 23:12 13:7,8,10,16,18 21:16 bypassing 23:19 citizen 16:20 23:8 24:17 25:13 byproduct 22:3 29:2 city 15:13 18:15 C Clay 1:13 3:7,13,15 8:8 9:24 cafete 26:20 16:21,22 23:3,8 29:2,2 cafeteria 26:18,21 clean 25:18 campus 3:13 12:9,12 21:20 23:14 clearly 4:25 30:10 32:15 23:19 Climate 26:2,3,5 campuses 26:12 clock 7:16,20 Canada 14:9 29:11 close 14:6 15:11 21:3 cancer 31:18 closer 17:4 candidate 10:20 11:24 Club 14:4,7,11 24:17 25:13 31:4 canopies 27:24 31:8 capital 25:12 co-signers 31:8 caption 33:5 coal 27:9 carbon 22:16,17 25:15 colloquial 31:10 card 30:4 combined 15:11 cards 6:25 come 4:22 7:12 21:10 27:12 30:7 care 2:10 coming 2:6 27:20 29:12 careful 26:6 commence 3:5 carrying 28:6 commenced 2:2 case 30:11 32:22 commend 17:11 cases 19:14 commended 15:24 Category 15:21 comment 4:11 5:5,10,13,19,20 Caughdenoy 8:16 6:2,25 22:19 25:4 30:4,6,22 cause 10:6,7 33:4 32:23 CCAA 26:8 comments 4:15,19,22,23 5:9,23 center 26:13,22 6:3,6,9,11,11,14,15,18 7:4,8 Central 14:5 7:9 18:4 20:24 21:17 30:8,14 CEO 14:14 30:15,18,22 certainly 30:6,15 31:2 32:21 Commerce 3:14 certify 33:3 commercial 9:3 20:16 26:23,25 cetera 26:13 Committee 10:19 11:24 25:14 chain 19:19 committing 15:25 chair 14:5 commonly 2:9 challenge 18:25 communication 13:18 challenges 20:19 communities 14:20,21 17:12,21 change 20:17 26:2,3 community 14:20 18:10 19:23,24 changes 9:13,18 12:22 20:14 20:11,15,21 21:9 22:6 23:7 ARII@courtsteno.com www.courtsteno.com 510 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 35 brings 18:6 character 8:10 20:12,18 brought 17:12 29:14 chemical 25:3 31:21 32:8 budget 15:4 chemicals 15:14 16:11,13 24:18 build 3:12 9:7 13:2 15:17,18,19 30:23 31:7,10 32:7,16 buildings 26:12,13 27:15 Chemours 31:22 bulk 32:9 chimneys 17:16 Bunnell 1:23 33:3,12 Chip-Making 31:6 burden 14:21 chips 31:22 bus 14:20 Cicero 10:15,19,20,24 11:23,23 business 23:2,6 11:25 12:11,13,15,17,19,21 businesses 23:12 13:7,8,10,16,18 21:16 bypassing 23:19 citizen 16:20 23:8 24:17 25:13 byproduct 22:3 29:2 city 15:13 18:15 C Clay 1:13 3:7,13,15 8:8 9:24 cafete 26:20 16:21,22 23:3,8 29:2,2 cafeteria 26:18,21 clean 25:18 campus 3:13 12:9,12 21:20 23:14 clearly 4:25 30:10 32:15 23:19 Climate 26:2,3,5 campuses 26:12 clock 7:16,20 Canada 14:9 29:11 close 14:6 15:11 21:3 cancer 31:18 closer 17:4 candidate 10:20 11:24 Club 14:4,7,11 24:17 25:13 31:4 canopies 27:24 31:8 capital 25:12 co-signers 31:8 caption 33:5 coal 27:9 carbon 22:16,17 25:15 colloquial 31:10 card 30:4 combined 15:11 cards 6:25 come 4:22 7:12 21:10 27:12 30:7 care 2:10 coming 2:6 27:20 29:12 careful 26:6 commence 3:5 carrying 28:6 commenced 2:2 case 30:11 32:22 commend 17:11 cases 19:14 commended 15:24 Category 15:21 comment 4:11 5:5,10,13,19,20 Caughdenoy 8:16 6:2,25 22:19 25:4 30:4,6,22 cause 10:6,7 33:4 32:23 CCAA 26:8 comments 4:15,19,22,23 5:9,23 center 26:13,22 6:3,6,9,11,11,14,15,18 7:4,8 Central 14:5 7:9 18:4 20:24 21:17 30:8,14 CEO 14:14 30:15,18,22 certainly 30:6,15 31:2 32:21 Commerce 3:14 certify 33:3 commercial 9:3 20:16 26:23,25 cetera 26:13 Committee 10:19 11:24 25:14 chain 19:19 committing 15:25 chair 14:5 commonly 2:9 challenge 18:25 communication 13:18 challenges 20:19 communities 14:20,21 17:12,21 change 20:17 26:2,3 community 14:20 18:10 19:23,24 changes 9:13,18 12:22 20:14 20:11,15,21 21:9 22:6 23:7 ARII@courtsteno.com www.courtsteno.com 511 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 36 24:19 26:5 curious 24:3 comparison 15:3 current 23:21 29:17 complete 19:11 20:7 currently 28:16,19 components 16:13 cursory 32:6 compounds 31:24 32:4 comprehensive 19:8 20:6 25:6 D concern 8:20 17:24 23:23 31:7 D-E- 25:12 concerned 24:17 Damian 13:25 16:16,20,25 concerning 26:24 DATE 1:9 concerns 12:23,25,25 14:16 dated 8:19 17:14 21:18,23 23:7 26:9 Davis 1:18 3:2 6:17,19,22 7:18 concluded 32:25 7:21,24 10:11,16,22 11:4,7,14 conclusion 10:5 11:16,20 16:16,25 17:4,8 condition 20:6 18:11 21:11 22:8,12,20,24 congestion 12:24 24:11 25:9,22 30:2,24 32:18 congratulations 12:8 13:21 day 15:12 33:10 conservation 1:3 14:4 25:14,19 daycare 26:12,22 31:3 days 31:5 consider 29:16 Deborah 25:10,11,22 considered 6:14 16:5 17:14 Debra 24:12 consistent 21:6 decides 30:12 consisting 33:6 decision 19:22 20:21 constructed 28:7 declaration 3:22 construction 8:21 9:6 13:4 declared 3:19,24 23:22,24 24:3,5,21 decrease 10:7 consume 15:9 deemed 9:19 consumption 16:9 defects 31:19 contact 5:22 6:3 26:24 defined 19:15 contaminated 17:23 degree 15:25 contrast 14:24 15:18 DEIS 8:19 10:10 15:15,23 16:10 convenient 5:25 32:7 conversations 26:14 27:18 delivery 21:22 conveyed 18:2 Democratic 10:19 11:23 cooking 26:18,21 27:2 Denise 22:21 24:11,14 cooling 26:14,17 DEPARTMENT 1:3 copies 5:24 Descocio 24:12 25:11,12 copy 4:12 5:25 deserves 21:5 corner 8:12 design 15:19 correctly 24:9 designed 26:19 28:19 COUNCIL 1:17 designer 26:24 counsel 2:25 3:3 6:17 designs 26:25 counselor 10:20 11:24 desk 2:22 country 14:9 29:13 despite 27:14 county 2:8 25:7 28:15,17 29:7 details 9:10,11 couple 2:10 23:7 determination 4:8 court 4:20 7:14,23 8:2 11:5,11 determining 9:25 Cradle 19:22 development 2:8 13:2 20:15 23:4 create 15:21 21:7 developments 12:17,18 13:13 CSX 29:17 20:17 cubic 28:6 develops 4:3 ARII@courtsteno.com www.courtsteno.com 511 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 36 24:19 26:5 curious 24:3 comparison 15:3 current 23:21 29:17 complete 19:11 20:7 currently 28:16,19 components 16:13 cursory 32:6 compounds 31:24 32:4 comprehensive 19:8 20:6 25:6 D concern 8:20 17:24 23:23 31:7 D-E- 25:12 concerned 24:17 Damian 13:25 16:16,20,25 concerning 26:24 DATE 1:9 concerns 12:23,25,25 14:16 dated 8:19 17:14 21:18,23 23:7 26:9 Davis 1:18 3:2 6:17,19,22 7:18 concluded 32:25 7:21,24 10:11,16,22 11:4,7,14 conclusion 10:5 11:16,20 16:16,25 17:4,8 condition 20:6 18:11 21:11 22:8,12,20,24 congestion 12:24 24:11 25:9,22 30:2,24 32:18 congratulations 12:8 13:21 day 15:12 33:10 conservation 1:3 14:4 25:14,19 daycare 26:12,22 31:3 days 31:5 consider 29:16 Deborah 25:10,11,22 considered 6:14 16:5 17:14 Debra 24:12 consistent 21:6 decides 30:12 consisting 33:6 decision 19:22 20:21 constructed 28:7 declaration 3:22 construction 8:21 9:6 13:4 declared 3:19,24 23:22,24 24:3,5,21 decrease 10:7 consume 15:9 deemed 9:19 consumption 16:9 defects 31:19 contact 5:22 6:3 26:24 defined 19:15 contaminated 17:23 degree 15:25 contrast 14:24 15:18 DEIS 8:19 10:10 15:15,23 16:10 convenient 5:25 32:7 conversations 26:14 27:18 delivery 21:22 conveyed 18:2 Democratic 10:19 11:23 cooking 26:18,21 27:2 Denise 22:21 24:11,14 cooling 26:14,17 DEPARTMENT 1:3 copies 5:24 Descocio 24:12 25:11,12 copy 4:12 5:25 deserves 21:5 corner 8:12 design 15:19 correctly 24:9 designed 26:19 28:19 COUNCIL 1:17 designer 26:24 counsel 2:25 3:3 6:17 designs 26:25 counselor 10:20 11:24 desk 2:22 country 14:9 29:13 despite 27:14 county 2:8 25:7 28:15,17 29:7 details 9:10,11 couple 2:10 23:7 determination 4:8 court 4:20 7:14,23 8:2 11:5,11 determining 9:25 Cradle 19:22 development 2:8 13:2 20:15 23:4 create 15:21 21:7 developments 12:17,18 13:13 CSX 29:17 20:17 cubic 28:6 develops 4:3 ARII@courtsteno.com www.courtsteno.com 512 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 37 Diana 21:12 22:8,10 emitting 17:18 different 32:15 employees 18:7 26:19 difficult 10:2 encourage 30:16 directly 8:14 encourages 5:16 Director 2:7 18:15 endeavor 15:4 discuss 11:3 12:5 energy 25:18,19 26:7 27:9,12 discussed 21:25 28:12,14,20 discussion 10:4 enormity 19:2 21:6 disposal 19:21 enormous 19:5 distributed 18:24 ensure 22:5 document 4:3,10,11,12,16,19 ensuring 13:6 18:2 26:7 11:3 12:5,14 13:22 19:6 32:5 entire 15:13 dollar 29:6 entrances 12:10 21:20 dollars 3:11 15:5 environment 14:19 18:21 22:5 Domestic 31:6 32:12 Don 14:2 31:3 environmental 1:3 3:5,17,24 4:5 Donald 10:13 13:24 4:6 12:25 15:2,7 17:14 28:21 double 21:4 environmentally 19:4 doubt 3:9 EPA 31:13 draft 3:24 4:6,9,12,15,19 19:7 Equal 6:14 19:10,10 equally 19:5 drafted 4:9 equitable 18:24 19:3 20:23 drawings 27:17,21 especially 13:8,9 dreams 19:2 estimate 31:24 Drive 29:2 et 26:13 due 3:22 Europe 14:10 evaluate 32:4 E evening 2:6,11,17 3:2 5:19 6:2 E-L-L-I-O-T-T 22:11 16:19 21:13 24:13 28:24 32:20 earlier 7:5 30:18 32:21 early 21:4 evening's 3:4 easier 13:17 everyone's 23:9 easily 13:13 exactly 21:25 easy 13:15,19 23:19 examined 16:9 economic 18:19 20:8,11 example 17:15 19:12 20:10 economically 19:4 excellent 12:6 ecosystems 18:22 excited 23:6 EIS 3:25 4:2,9 9:9 32:4 executive 2:7 28:15 elaborate 30:22 exist 23:21 Elaine 8:8,8 existing 9:8 electric 26:9,16 27:2,3 exit 23:16 electrical 26:14,22 27:3,9 Exits 2:11 electricity 13:3 15:10 16:4 expand 15:23 27:5,7 expanded 3:14 15:15 eliminate 16:14 32:17 expanding 14:18 Elliot 21:12 22:8,10 expansion 23:13 ELLIOTT 22:10,14 expect 24:19 email 5:20 6:5 expected 8:22 9:13,13 embodied 22:16 exposure 24:21,25 emissions 25:18 expressed 5:10 ARII@courtsteno.com www.courtsteno.com 512 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 37 Diana 21:12 22:8,10 emitting 17:18 different 32:15 employees 18:7 26:19 difficult 10:2 encourage 30:16 directly 8:14 encourages 5:16 Director 2:7 18:15 endeavor 15:4 discuss 11:3 12:5 energy 25:18,19 26:7 27:9,12 discussed 21:25 28:12,14,20 discussion 10:4 enormity 19:2 21:6 disposal 19:21 enormous 19:5 distributed 18:24 ensure 22:5 document 4:3,10,11,12,16,19 ensuring 13:6 18:2 26:7 11:3 12:5,14 13:22 19:6 32:5 entire 15:13 dollar 29:6 entrances 12:10 21:20 dollars 3:11 15:5 environment 14:19 18:21 22:5 Domestic 31:6 32:12 Don 14:2 31:3 environmental 1:3 3:5,17,24 4:5 Donald 10:13 13:24 4:6 12:25 15:2,7 17:14 28:21 double 21:4 environmentally 19:4 doubt 3:9 EPA 31:13 draft 3:24 4:6,9,12,15,19 19:7 Equal 6:14 19:10,10 equally 19:5 drafted 4:9 equitable 18:24 19:3 20:23 drawings 27:17,21 especially 13:8,9 dreams 19:2 estimate 31:24 Drive 29:2 et 26:13 due 3:22 Europe 14:10 evaluate 32:4 E evening 2:6,11,17 3:2 5:19 6:2 E-L-L-I-O-T-T 22:11 16:19 21:13 24:13 28:24 32:20 earlier 7:5 30:18 32:21 early 21:4 evening's 3:4 easier 13:17 everyone's 23:9 easily 13:13 exactly 21:25 easy 13:15,19 23:19 examined 16:9 economic 18:19 20:8,11 example 17:15 19:12 20:10 economically 19:4 excellent 12:6 ecosystems 18:22 excited 23:6 EIS 3:25 4:2,9 9:9 32:4 executive 2:7 28:15 elaborate 30:22 exist 23:21 Elaine 8:8,8 existing 9:8 electric 26:9,16 27:2,3 exit 23:16 electrical 26:14,22 27:3,9 Exits 2:11 electricity 13:3 15:10 16:4 expand 15:23 27:5,7 expanded 3:14 15:15 eliminate 16:14 32:17 expanding 14:18 Elliot 21:12 22:8,10 expansion 23:13 ELLIOTT 22:10,14 expect 24:19 email 5:20 6:5 expected 8:22 9:13,13 embodied 22:16 exposure 24:21,25 emissions 25:18 expressed 5:10 ARII@courtsteno.com www.courtsteno.com 513 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 38 extending 12:12 Frank 7:10,12,24 8:5,6 extension 30:22 free 26:7 27:8 30:6 extensive 14:25 freed 27:8 extraordinary 25:2 fuel 28:7,12 fulfill 19:2 F full 4:24 15:17 fab 32:2 fully 2:23 19:23 face 8:9,14 9:18 furnaces 26:10 facilitates 2:22 further 6:8 7:9 18:6,6 22:18 facilities 26:18,21 27:2 30:14 facility 3:6 9:5 17:25 28:8 Furthermore 12:21 15:6 fact 7:8 31:24 future 10:3 29:25 failure 9:19 far 15:7 G farms 27:23 gallons 15:12 fashion 18:24 20:23 gas 26:10,20 27:3,9 28:4,7,8,9 fast 12:22 28:10,12 feet 17:17 27:14 28:6 general 10:5 fifty 15:11 generally 3:14 figure 10:25 generate 8:22 filled 30:4 generated 32:10 final 6:13 19:10 21:7 generation 29:25 financial 3:9 generations 21:10 find 13:15 genetic 31:19 first 3:25 7:9 12:14 17:11 19:7 Gettysburg 7:6 fiscal 20:8 gift 24:7 Fitzgerald 1:20 3:3 give 9:17 11:16,17 23:19 five 9:7 15:20 31:15 given 5:7 6:15 27:25 floor 2:14 Glen 23:18 flow 21:21 globally 14:18 fluorocarbons 24:18 25:17 go 2:13 6:25 11:11 13:4 32:21 focus 29:9,16 goal 5:14 folks 6:23 32:12 goals 26:4 follow 13:13 goes 18:6 followed 25:23 going 6:25 14:14 18:5 21:21,21 following 26:8 21:23 23:5,15 24:2,2,3,16 foot 31:25 32:2 25:3 29:3,11 30:4 32:19 Forbes 31:5 good 2:5 11:19 16:19 24:13 forces 13:12 28:24 foregoing 33:3,6 gorilla 27:4 forever 16:13 24:18 30:23 31:7 government 13:12 31:9 grant 29:9,20 form 20:25 grave 19:22 forth 26:5 great 7:7,12 12:6 24:7 25:2 forty 15:5 30:2,23 forward 4:22 24:9 29:8,24 greater 20:15,18 fossil 26:7 27:8,8 28:7 greatly 15:23 found 2:12 5:23 6:4,8 green 18:18 28:10,11,13 founded 18:16,17 greenhouse 26:4 28:9 four 9:5 15:22 17:22 27:15 Greeningusa 18:17 ARII@courtsteno.com www.courtsteno.com 513 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 38 extending 12:12 Frank 7:10,12,24 8:5,6 extension 30:22 free 26:7 27:8 30:6 extensive 14:25 freed 27:8 extraordinary 25:2 fuel 28:7,12 fulfill 19:2 F full 4:24 15:17 fab 32:2 fully 2:23 19:23 face 8:9,14 9:18 furnaces 26:10 facilitates 2:22 further 6:8 7:9 18:6,6 22:18 facilities 26:18,21 27:2 30:14 facility 3:6 9:5 17:25 28:8 Furthermore 12:21 15:6 fact 7:8 31:24 future 10:3 29:25 failure 9:19 far 15:7 G farms 27:23 gallons 15:12 fashion 18:24 20:23 gas 26:10,20 27:3,9 28:4,7,8,9 fast 12:22 28:10,12 feet 17:17 27:14 28:6 general 10:5 fifty 15:11 generally 3:14 figure 10:25 generate 8:22 filled 30:4 generated 32:10 final 6:13 19:10 21:7 generation 29:25 financial 3:9 generations 21:10 find 13:15 genetic 31:19 first 3:25 7:9 12:14 17:11 19:7 Gettysburg 7:6 fiscal 20:8 gift 24:7 Fitzgerald 1:20 3:3 give 9:17 11:16,17 23:19 five 9:7 15:20 31:15 given 5:7 6:15 27:25 floor 2:14 Glen 23:18 flow 21:21 globally 14:18 fluorocarbons 24:18 25:17 go 2:13 6:25 11:11 13:4 32:21 focus 29:9,16 goal 5:14 folks 6:23 32:12 goals 26:4 follow 13:13 goes 18:6 followed 25:23 going 6:25 14:14 18:5 21:21,21 following 26:8 21:23 23:5,15 24:2,2,3,16 foot 31:25 32:2 25:3 29:3,11 30:4 32:19 Forbes 31:5 good 2:5 11:19 16:19 24:13 forces 13:12 28:24 foregoing 33:3,6 gorilla 27:4 forever 16:13 24:18 30:23 31:7 government 13:12 31:9 grant 29:9,20 form 20:25 grave 19:22 forth 26:5 great 7:7,12 12:6 24:7 25:2 forty 15:5 30:2,23 forward 4:22 24:9 29:8,24 greater 20:15,18 fossil 26:7 27:8,8 28:7 greatly 15:23 found 2:12 5:23 6:4,8 green 18:18 28:10,11,13 founded 18:16,17 greenhouse 26:4 28:9 four 9:5 15:22 17:22 27:15 Greeningusa 18:17 ARII@courtsteno.com www.courtsteno.com 514 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 39 grew 32:14 hitting 13:22 grid 28:15 Hoesen 8:7,13,17 ground 26:10 hold 5:5 group 14:5,6,7 31:4 honestly 9:16 groups 14:12 hope 13:9 28:17 growth 13:2 18:9 20:7,10,19 hopefully 24:8 22:18 23:13 hospital 20:5 guy 31:21 hot 27:2,3 guys 22:23 hour 9:4 30:13 housekeeping 2:10 H hub 25:6 H-E-F-F-R-O-N 28:25 Hughes 10:13 14:2,2 30:20 31:3 H-U-G-H-E-S 14:3 31:3 Hughs 13:25 28:23 31:2 half 15:5,17 30:13 31:25 hundred 3:11 14:8,12 32:3,3 Hampshire 15:11 27:6 hydrogen 28:11,11,11,13 happen 23:5,17 25:3 happened 29:20 32:13 I happening 23:23 I-81 8:25 12:24 15:2,8,18 happens 24:10 I-R-T-H 25:25 hard 13:12 IDA 2:25 3:3 6:17 harming 14:19 Identified 6:4 hazardous 19:15 32:8 identifies 8:19 health 16:23 18:21 19:19 identify 32:8 healthcare 20:4 impact 3:25 4:7 8:10,17 9:24,25 hear 2:4 7:9 11:4,17 18:3 22:11 10:8 13:8 15:2 20:8,10,11,11 22:23 25:4 22:16 28:21 29:23 heard 5:18 23:17 impacted 10:25 12:2 hearing 1:1,7 2:1,2 3:1 4:1 5:1 impacts 3:23 4:5 8:14 9:17,20 6:1 7:1 8:1 9:1 10:1 11:1 10:4 15:7 18:23 19:15 20:16 12:1 13:1 14:1 15:1 16:1 17:1 20:22 18:1 19:1 20:1 21:1 22:1 23:1 important 13:22 19:25 21:2 24:1,4 25:1 26:1 27:1 28:1 importantly 16:10 29:1 30:1 31:1 32:1,25 33:1,8 improve 18:19 19:12 heat 26:10,16 improvement 25:2 29:6 heating 26:9,17 improvements 8:15 9:11,15 Heffron 25:23 28:23,24,25 include 6:7 15:15 26:11 height 17:17 included 15:20 19:13,21 heightened 12:18 includes 24:21 Hello 28:24 including 8:24 14:13 19:9 26:12 help 6:12 13:15 23:20 32:8 helpful 8:2 increase 10:7 29:19,24 hereof 33:5 indicate 27:17 hereto 33:5 individual 17:16 hereunto 33:9 individuals 24:16 Hi 10:14 induce 20:8 high 1:10 28:5 induction 26:22,25 highlighting 26:8 industrial 2:8 21:25 28:9 highly 16:14 industries 18:8 highway 8:24 21:23 industry 14:13 16:12 22:3 31:9 history 14:17 32:14 ARII@courtsteno.com www.courtsteno.com 514 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 39 grew 32:14 hitting 13:22 grid 28:15 Hoesen 8:7,13,17 ground 26:10 hold 5:5 group 14:5,6,7 31:4 honestly 9:16 groups 14:12 hope 13:9 28:17 growth 13:2 18:9 20:7,10,19 hopefully 24:8 22:18 23:13 hospital 20:5 guy 31:21 hot 27:2,3 guys 22:23 hour 9:4 30:13 housekeeping 2:10 H hub 25:6 H-E-F-F-R-O-N 28:25 Hughes 10:13 14:2,2 30:20 31:3 H-U-G-H-E-S 14:3 31:3 Hughs 13:25 28:23 31:2 half 15:5,17 30:13 31:25 hundred 3:11 14:8,12 32:3,3 Hampshire 15:11 27:6 hydrogen 28:11,11,11,13 happen 23:5,17 25:3 happened 29:20 32:13 I happening 23:23 I-81 8:25 12:24 15:2,8,18 happens 24:10 I-R-T-H 25:25 hard 13:12 IDA 2:25 3:3 6:17 harming 14:19 Identified 6:4 hazardous 19:15 32:8 identifies 8:19 health 16:23 18:21 19:19 identify 32:8 healthcare 20:4 impact 3:25 4:7 8:10,17 9:24,25 hear 2:4 7:9 11:4,17 18:3 22:11 10:8 13:8 15:2 20:8,10,11,11 22:23 25:4 22:16 28:21 29:23 heard 5:18 23:17 impacted 10:25 12:2 hearing 1:1,7 2:1,2 3:1 4:1 5:1 impacts 3:23 4:5 8:14 9:17,20 6:1 7:1 8:1 9:1 10:1 11:1 10:4 15:7 18:23 19:15 20:16 12:1 13:1 14:1 15:1 16:1 17:1 20:22 18:1 19:1 20:1 21:1 22:1 23:1 important 13:22 19:25 21:2 24:1,4 25:1 26:1 27:1 28:1 importantly 16:10 29:1 30:1 31:1 32:1,25 33:1,8 improve 18:19 19:12 heat 26:10,16 improvement 25:2 29:6 heating 26:9,17 improvements 8:15 9:11,15 Heffron 25:23 28:23,24,25 include 6:7 15:15 26:11 height 17:17 included 15:20 19:13,21 heightened 12:18 includes 24:21 Hello 28:24 including 8:24 14:13 19:9 26:12 help 6:12 13:15 23:20 32:8 helpful 8:2 increase 10:7 29:19,24 hereof 33:5 indicate 27:17 hereto 33:5 individual 17:16 hereunto 33:9 individuals 24:16 Hi 10:14 induce 20:8 high 1:10 28:5 induction 26:22,25 highlighting 26:8 industrial 2:8 21:25 28:9 highly 16:14 industries 18:8 highway 8:24 21:23 industry 14:13 16:12 22:3 31:9 history 14:17 32:14 ARII@courtsteno.com www.courtsteno.com 515 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 40 inevitability 31:21 language 2:18,18 info 13:20 large 15:3,25 information 5:22 6:3,8 13:7 larger 15:8 informed 13:16 19:24 25:16,21 lastly 18:3 infrastructure 29:6 31:23 lead 3:20 4:14 initial 27:16 leaders 14:13 inner 25:19 Leadership 26:5 input 6:10 10:9 leading-edge 3:12 instrumental 18:9 learn 22:15 intends 3:11 leaving 17:25 intent 3:24 8:18 left 2:13 interest 12:18 21:9 legal 2:25 interested 13:10 22:15 length 7:5 interesting 12:16 Let's 16:15 interpreters 2:19 letter 14:12,14 31:9 introduced 25:17 levels 13:12 invest 3:11 limit 30:21 invited 4:10 limited 30:20 involved 13:12,16 limiting 5:9 involvement 13:18 limits 9:12 issued 3:21 line 5:12 7:8 29:17,17 issues 14:23 lines 29:23 It'll 30:7 linked 31:18,19 Lisette 6:19,21 J list 7:2 Jay 7:10 10:12,14,16 11:7,21 listening 29:4 13:24 little 2:3,4 11:6,8,17 17:2 Jeff 1:18 3:2 6:17,21 20:2 23:23 32:19 Jim 22:9,20,25 live 8:7,12 10:15 11:22 12:4 John 16:17 18:12,13 23:18 21:14 22:11 24:15 Jr 1:10 lives 18:20 July 3:7,8 local 8:15,24,24 9:11 14:5 jumble 19:25 25:17 26:2 27:23 31:4 juncture 2:17 6:16 located 3:14 LOCATION 1:10 K long 24:6 K-I 17:11 look 11:2 12:3 16:10 24:9 keep 13:5,16 30:8,11 32:22 looks 12:6 29:22 kilo 31:25 lot 21:17 27:24 31:12 kilowatts 27:7 louder 2:3,4 11:6 22:13 kind 10:25 17:19 19:25 32:6 know 2:21 13:19 23:8,16 24:7 M 27:25 29:22 30:16 magazine 31:5 known 2:9 3:18 16:13 mail 5:21 mailing 6:5 L major 31:7 Laden 23:3 maker 31:22 Lake 16:15 32:14 makers 19:23 20:21 Lakeshore 21:15,16 making 4:21 lanes 9:12 23:10 managed 20:22 ARII@courtsteno.com www.courtsteno.com 515 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 40 inevitability 31:21 language 2:18,18 info 13:20 large 15:3,25 information 5:22 6:3,8 13:7 larger 15:8 informed 13:16 19:24 25:16,21 lastly 18:3 infrastructure 29:6 31:23 lead 3:20 4:14 initial 27:16 leaders 14:13 inner 25:19 Leadership 26:5 input 6:10 10:9 leading-edge 3:12 instrumental 18:9 learn 22:15 intends 3:11 leaving 17:25 intent 3:24 8:18 left 2:13 interest 12:18 21:9 legal 2:25 interested 13:10 22:15 length 7:5 interesting 12:16 Let's 16:15 interpreters 2:19 letter 14:12,14 31:9 introduced 25:17 levels 13:12 invest 3:11 limit 30:21 invited 4:10 limited 30:20 involved 13:12,16 limiting 5:9 involvement 13:18 limits 9:12 issued 3:21 line 5:12 7:8 29:17,17 issues 14:23 lines 29:23 It'll 30:7 linked 31:18,19 Lisette 6:19,21 J list 7:2 Jay 7:10 10:12,14,16 11:7,21 listening 29:4 13:24 little 2:3,4 11:6,8,17 17:2 Jeff 1:18 3:2 6:17,21 20:2 23:23 32:19 Jim 22:9,20,25 live 8:7,12 10:15 11:22 12:4 John 16:17 18:12,13 23:18 21:14 22:11 24:15 Jr 1:10 lives 18:20 July 3:7,8 local 8:15,24,24 9:11 14:5 jumble 19:25 25:17 26:2 27:23 31:4 juncture 2:17 6:16 located 3:14 LOCATION 1:10 K long 24:6 K-I 17:11 look 11:2 12:3 16:10 24:9 keep 13:5,16 30:8,11 32:22 looks 12:6 29:22 kilo 31:25 lot 21:17 27:24 31:12 kilowatts 27:7 louder 2:3,4 11:6 22:13 kind 10:25 17:19 19:25 32:6 know 2:21 13:19 23:8,16 24:7 M 27:25 29:22 30:16 magazine 31:5 known 2:9 3:18 16:13 mail 5:21 mailing 6:5 L major 31:7 Laden 23:3 maker 31:22 Lake 16:15 32:14 makers 19:23 20:21 Lakeshore 21:15,16 making 4:21 lanes 9:12 23:10 managed 20:22 ARII@courtsteno.com www.courtsteno.com 516 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 41 manner 19:4 N Mantova 28:25 N-I-S-T-I-C-O 23:2 manufacturing 3:6,13 28:22 name 2:6 4:24 7:15,25 8:5,6 map 12:9 10:17 14:3 16:19 17:9 18:13 marked 2:12 22:10 24:14 30:10,24 31:10 Mary 18:12 21:11,12,13 33:10 massive 27:13,25 name's 14:2 25:24 materials 19:16 32:8 named 9:11 matters 2:10 names 6:25 Means 31:6 narrowly 19:15 measures 32:11 national 14:8 28:15 meet 26:4 natural 18:22 26:20 27:3 28:4,7 meeting 6:17 28:3 28:10,12 meets 16:3 near 20:14 member 24:16 nebulous 19:13 members 14:6,9 19:23 20:21 necessary 18:19 20:9 21:10 need 2:20 16:14 17:6,8 18:17 mentioned 23:9 needs 2:20 15:23 20:2 28:3 metric 32:3 negative 18:23 mic 7:13 17:5 22:22 neighborhood 8:11 Micron 1:1,5 2:1 3:1,5,9,10 4:1 neighborhoods 9:14 20:18 5:1 6:1 7:1 8:1,12,22 9:1 network 8:24 10:1 11:1 12:1,8,9,12 13:1 new 1:2,13 3:7,15 8:23,25 12:9 14:1,14 15:1,4,6,7,9,13,23,24 12:10,16,17,24 13:2,13 14:5 16:1 17:1,12,25 18:1,6,25 15:10 26:4 27:6,20 29:2 33:2 19:1 20:1 21:1 22:1,17 23:1 news 29:4 23:14,19 24:1 25:1,7 26:1,15 newspaper 27:5 26:24 27:1,19 28:1,8 29:1 Nicole 1:23 33:3,12 30:1 31:1 32:1 33:1 Nistico 22:9,20,22,25,25 microphone 30:7 noise 5:6 23:22 milestone 12:9 13:22 noises 24:4,5 Mill 8:16 12:11 23:17 non-fossil 28:12 million 15:11 27:14 31:16 North 1:10 millions 28:6 Northern 14:5 mind 31:12 not-for-profit 18:16 minutes 5:9,11 7:4 30:9,13,21 notably 20:4 misleading 28:20 note 2:16 missing 25:4 notice 5:23,24 6:2 8:18 9:18 modern-day 31:24 noticed 4:9 modification 9:8 November 10:21 11:25 monitored 22:4 number 5:7 8:23 9:12 12:10 motivation 14:16 24:15 move 17:4 29:24 NY-31 12:11 movement 29:20 moving 29:8,9,10,18 O Mud 8:16 12:11 23:17 oak 18:2 multimillion- 29:5 obviously 23:16 27:25 multiple 15:18 OCIDA 1:17 2:9 3:8,19,21 4:9,11 municipalities 13:11 4:14 5:16,21 6:7,12,12 12:8 ARII@courtsteno.com www.courtsteno.com 516 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 41 manner 19:4 N Mantova 28:25 N-I-S-T-I-C-O 23:2 manufacturing 3:6,13 28:22 name 2:6 4:24 7:15,25 8:5,6 map 12:9 10:17 14:3 16:19 17:9 18:13 marked 2:12 22:10 24:14 30:10,24 31:10 Mary 18:12 21:11,12,13 33:10 massive 27:13,25 name's 14:2 25:24 materials 19:16 32:8 named 9:11 matters 2:10 names 6:25 Means 31:6 narrowly 19:15 measures 32:11 national 14:8 28:15 meet 26:4 natural 18:22 26:20 27:3 28:4,7 meeting 6:17 28:3 28:10,12 meets 16:3 near 20:14 member 24:16 nebulous 19:13 members 14:6,9 19:23 20:21 necessary 18:19 20:9 21:10 need 2:20 16:14 17:6,8 18:17 mentioned 23:9 needs 2:20 15:23 20:2 28:3 metric 32:3 negative 18:23 mic 7:13 17:5 22:22 neighborhood 8:11 Micron 1:1,5 2:1 3:1,5,9,10 4:1 neighborhoods 9:14 20:18 5:1 6:1 7:1 8:1,12,22 9:1 network 8:24 10:1 11:1 12:1,8,9,12 13:1 new 1:2,13 3:7,15 8:23,25 12:9 14:1,14 15:1,4,6,7,9,13,23,24 12:10,16,17,24 13:2,13 14:5 16:1 17:1,12,25 18:1,6,25 15:10 26:4 27:6,20 29:2 33:2 19:1 20:1 21:1 22:1,17 23:1 news 29:4 23:14,19 24:1 25:1,7 26:1,15 newspaper 27:5 26:24 27:1,19 28:1,8 29:1 Nicole 1:23 33:3,12 30:1 31:1 32:1 33:1 Nistico 22:9,20,22,25,25 microphone 30:7 noise 5:6 23:22 milestone 12:9 13:22 noises 24:4,5 Mill 8:16 12:11 23:17 non-fossil 28:12 million 15:11 27:14 31:16 North 1:10 millions 28:6 Northern 14:5 mind 31:12 not-for-profit 18:16 minutes 5:9,11 7:4 30:9,13,21 notably 20:4 misleading 28:20 note 2:16 missing 25:4 notice 5:23,24 6:2 8:18 9:18 modern-day 31:24 noticed 4:9 modification 9:8 November 10:21 11:25 monitored 22:4 number 5:7 8:23 9:12 12:10 motivation 14:16 24:15 move 17:4 29:24 NY-31 12:11 movement 29:20 moving 29:8,9,10,18 O Mud 8:16 12:11 23:17 oak 18:2 multimillion- 29:5 obviously 23:16 27:25 multiple 15:18 OCIDA 1:17 2:9 3:8,19,21 4:9,11 municipalities 13:11 4:14 5:16,21 6:7,12,12 12:8 ARII@courtsteno.com www.courtsteno.com 517 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 42 12:14 13:6,9,15 28:17 perfluor 31:23 OCIDA's 4:8 6:4 perfluorinated 16:12 October 1:9 6:10 31:5 33:10 perfluorooctanoic 31:14 offers 19:3 permitting 5:14 officials 26:15 27:19 28:16,18 person 5:3 offspring 14:19 Peter 25:10,22,24 Oh 11:10 petroleum 32:9 oil-fired 27:9 Petrovich 1:19 2:3,7 okay 10:12 11:10,15,19 17:10 PFA 31:23,25 22:14 25:11 PFAs 31:10,21 once 17:20 PFOS 24:18 Onondaga 2:8 25:7 32:14 picking 11:8 Ontario 16:15 piece 12:7 open 30:4,11 32:22 Pine 3:14 20:14 21:5 operation 8:21 9:4 18:9 pipeline 28:6 operational 22:16 Pittsburgh 26:25 opportunities 20:20 place 25:20 33:4 opportunity 4:18 5:15,18 8:6 plainly 2:12 10:9 plan 17:12 24:20 25:6,16 27:11 opposed 8:9 29:6 options 16:4 planning 12:7 16:7 orchards 18:2 plans 8:15 28:5 order 9:16 19:2 plant 22:17 24:22,23 25:8 26:7 organization 14:8 18:16,17 26:3 26:9 27:4 28:3,13,17,18 organizations 12:20 plants 29:12 Oswego 29:7 played 29:21 outlay 15:6 please 2:21 4:23 5:3,5 7:14 outlines 4:4 10:17 11:14 13:19 30:25 overnight 24:4,4 point 21:3 28:17 31:15 owner 23:2,6 pollutant 22:3 polluting 14:18 P polyfluoroalkyl 31:11 P-R-Z-E-P-I-O-R-A 18:14 population 13:2 p.m 1:9 2:2 32:25 positive 3:21 18:23 Page 12:10 33:5 possible 12:24 23:20 26:16 pages 33:7 27:11 28:10 paid 26:6 possibly 17:13 23:16 pales 15:3 posted 4:11 paragraph 8:18 potential 3:22 4:4 8:10,13 9:16 Park 3:14 20:14 21:5 20:14,17 parking 9:2 25:5 27:24 pots 17:16 parkway 23:18 pre- 6:23 part 4:8 28:8 29:12,18 pre-registered 5:8 30:3 participate 2:24 5:17 precise 9:25 particular 12:23 13:14 preparation 10:10 parts 31:14,15,16 prepare 3:24 6:12 8:18 passed 26:6 prepared 4:7 21:16 peak 9:4 preparing 4:2 people 5:7 18:20,22 32:22 presented 19:6 percent 16:5,5,6 24:20 28:14,20 presents 20:19 ARII@courtsteno.com www.courtsteno.com 517 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 42 12:14 13:6,9,15 28:17 perfluor 31:23 OCIDA's 4:8 6:4 perfluorinated 16:12 October 1:9 6:10 31:5 33:10 perfluorooctanoic 31:14 offers 19:3 permitting 5:14 officials 26:15 27:19 28:16,18 person 5:3 offspring 14:19 Peter 25:10,22,24 Oh 11:10 petroleum 32:9 oil-fired 27:9 Petrovich 1:19 2:3,7 okay 10:12 11:10,15,19 17:10 PFA 31:23,25 22:14 25:11 PFAs 31:10,21 once 17:20 PFOS 24:18 Onondaga 2:8 25:7 32:14 picking 11:8 Ontario 16:15 piece 12:7 open 30:4,11 32:22 Pine 3:14 20:14 21:5 operation 8:21 9:4 18:9 pipeline 28:6 operational 22:16 Pittsburgh 26:25 opportunities 20:20 place 25:20 33:4 opportunity 4:18 5:15,18 8:6 plainly 2:12 10:9 plan 17:12 24:20 25:6,16 27:11 opposed 8:9 29:6 options 16:4 planning 12:7 16:7 orchards 18:2 plans 8:15 28:5 order 9:16 19:2 plant 22:17 24:22,23 25:8 26:7 organization 14:8 18:16,17 26:3 26:9 27:4 28:3,13,17,18 organizations 12:20 plants 29:12 Oswego 29:7 played 29:21 outlay 15:6 please 2:21 4:23 5:3,5 7:14 outlines 4:4 10:17 11:14 13:19 30:25 overnight 24:4,4 point 21:3 28:17 31:15 owner 23:2,6 pollutant 22:3 polluting 14:18 P polyfluoroalkyl 31:11 P-R-Z-E-P-I-O-R-A 18:14 population 13:2 p.m 1:9 2:2 32:25 positive 3:21 18:23 Page 12:10 33:5 possible 12:24 23:20 26:16 pages 33:7 27:11 28:10 paid 26:6 possibly 17:13 23:16 pales 15:3 posted 4:11 paragraph 8:18 potential 3:22 4:4 8:10,13 9:16 Park 3:14 20:14 21:5 20:14,17 parking 9:2 25:5 27:24 pots 17:16 parkway 23:18 pre- 6:23 part 4:8 28:8 29:12,18 pre-registered 5:8 30:3 participate 2:24 5:17 precise 9:25 particular 12:23 13:14 preparation 10:10 parts 31:14,15,16 prepare 3:24 6:12 8:18 passed 26:6 prepared 4:7 21:16 peak 9:4 preparing 4:2 people 5:7 18:20,22 32:22 presented 19:6 percent 16:5,5,6 24:20 28:14,20 presents 20:19 ARII@courtsteno.com www.courtsteno.com 518 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 43 President 18:15 purposes 3:20 presiding 3:4 put 17:19 23:15 29:16 pressure 28:6 putting 24:22 prevent 25:16 primarily 16:22 Q problem 25:15 quality 3:17 19:20 problems 14:22 quantities 31:17 proceeding 12:23 question 12:5 20:22 proceedings 33:7 question-and-answer 4:17 proceeds 13:4 questionable 24:24 process 4:3,15 5:17 19:5 27:20 questions 18:4 28:9,22 quickly 13:23 produced 28:11 quite 19:11 production 23:25 27:10,14 28:2 29:10 R productive 27:18 R-I-O-R-D-A-N 10:18 progress 18:19 rail 29:6,17,19,22,23 project 1:1,5 2:1 3:1,6,16 4:1 raise 14:23 4:7 5:1 6:1,7,9 7:1 8:1,9,12 ramp 12:24 8:22 9:1,21 10:1,2,6,10,25 range 15:24 16:4,11 11:1 12:1,3,18 13:1,8,11 14:1 reaching 12:9 14:24,25 15:1,3,18 16:1,6 read 14:14 17:1 18:1,5,25 19:1,3 20:1,7 real 24:19 21:1,4,5,7 22:1 23:1,5,6 24:1 really 13:10,14 24:6 25:1 26:1 27:1 28:1 29:1 rear 2:11 30:1 31:1 32:1,10 33:1 reasonable 19:7 project's 3:22 9:23 receive 4:15 projects 25:19 received 3:8 6:12,14 7:2 promote 13:17 recommend 14:24 15:14 property 8:11 9:24 10:5,7,8,8 record 4:20,21 5:2,6 6:18 7:15 21:19 7:25 24:25 33:7 proposed 3:7 6:9 8:22 9:2,5,10 recreation 19:25 9:15,23 10:6 19:9 32:10 recycled 16:8 proposes 20:6 reduced 31:13 protect 18:21,21,22 21:9 24:20 reducing 16:8 25:18 32:11 referred 28:14,19 protected 22:6 referring 28:16 Protection 26:5 reflect 27:21 provide 9:10 30:15,17 regarding 9:12 12:15 provided 9:16 19:22 regional 8:24 Przepiora 16:17 18:13,14 registered 6:24 public 1:1,7 2:1 3:1,4 4:1,10 registration 2:22 4:13,18 5:1,16 6:1 7:1 8:1 reiterate 24:16 9:1 10:1 11:1 12:1,14 13:1 related 8:14 20:10 14:1 15:1 16:1 17:1 18:1 19:1 relating 19:15 20:1 21:1 22:1 23:1 24:1 25:1 release 19:20 25:15,21 26:1 27:1 28:1,21 released 6:13 27:12 29:1 30:1 31:1 32:1 33:1 releases 32:11 pumps 26:10,16 relying 29:11 purpose 4:13 renewable 16:6,6 28:14,20 ARII@courtsteno.com www.courtsteno.com 518 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 43 President 18:15 purposes 3:20 presiding 3:4 put 17:19 23:15 29:16 pressure 28:6 putting 24:22 prevent 25:16 primarily 16:22 Q problem 25:15 quality 3:17 19:20 problems 14:22 quantities 31:17 proceeding 12:23 question 12:5 20:22 proceedings 33:7 question-and-answer 4:17 proceeds 13:4 questionable 24:24 process 4:3,15 5:17 19:5 27:20 questions 18:4 28:9,22 quickly 13:23 produced 28:11 quite 19:11 production 23:25 27:10,14 28:2 29:10 R productive 27:18 R-I-O-R-D-A-N 10:18 progress 18:19 rail 29:6,17,19,22,23 project 1:1,5 2:1 3:1,6,16 4:1 raise 14:23 4:7 5:1 6:1,7,9 7:1 8:1,9,12 ramp 12:24 8:22 9:1,21 10:1,2,6,10,25 range 15:24 16:4,11 11:1 12:1,3,18 13:1,8,11 14:1 reaching 12:9 14:24,25 15:1,3,18 16:1,6 read 14:14 17:1 18:1,5,25 19:1,3 20:1,7 real 24:19 21:1,4,5,7 22:1 23:1,5,6 24:1 really 13:10,14 24:6 25:1 26:1 27:1 28:1 29:1 rear 2:11 30:1 31:1 32:1,10 33:1 reasonable 19:7 project's 3:22 9:23 receive 4:15 projects 25:19 received 3:8 6:12,14 7:2 promote 13:17 recommend 14:24 15:14 property 8:11 9:24 10:5,7,8,8 record 4:20,21 5:2,6 6:18 7:15 21:19 7:25 24:25 33:7 proposed 3:7 6:9 8:22 9:2,5,10 recreation 19:25 9:15,23 10:6 19:9 32:10 recycled 16:8 proposes 20:6 reduced 31:13 protect 18:21,21,22 21:9 24:20 reducing 16:8 25:18 32:11 referred 28:14,19 protected 22:6 referring 28:16 Protection 26:5 reflect 27:21 provide 9:10 30:15,17 regarding 9:12 12:15 provided 9:16 19:22 regional 8:24 Przepiora 16:17 18:13,14 registered 6:24 public 1:1,7 2:1 3:1,4 4:1,10 registration 2:22 4:13,18 5:1,16 6:1 7:1 8:1 reiterate 24:16 9:1 10:1 11:1 12:1,14 13:1 related 8:14 20:10 14:1 15:1 16:1 17:1 18:1 19:1 relating 19:15 20:1 21:1 22:1 23:1 24:1 25:1 release 19:20 25:15,21 26:1 27:1 28:1,21 released 6:13 27:12 29:1 30:1 31:1 32:1 33:1 releases 32:11 pumps 26:10,16 relying 29:11 purpose 4:13 renewable 16:6,6 28:14,20 ARII@courtsteno.com www.courtsteno.com 519 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 44 replaced 28:10,13 S-C-I-O-R-T-I-N-O 8:5 reported 1:23 33:4 S-C-O-C-I-O 25:12 reporter 4:20,25 7:14,23 8:2 safe 17:23 11:5,11 33:12 safeguards 17:19 reports 27:5 safely 18:2 represent 11:23 12:20 safety 16:23 19:19 25:3 representing 10:19 sake 14:15 request 9:9 30:8 Salina 24:15 required 3:16 4:9 15:17 sat 30:5 residences 18:4 23:12 says 31:22 resident 10:24 11:25 13:13 Scanlon 18:12 21:11,13,14 18:14 23:3 25:25 Sciortino 7:10,16,19,22 8:4,5,7 residential 20:16 scope 4:3 6:13 15:15 19:10 21:7 residents 9:17 12:17,19,22 13:7 29:15,22 13:10,16,19 14:20 16:24 scoping 1:1,5 2:1 3:1,4 4:1,2,2 residual 19:21 4:10,11,12,13,15,19 5:1 6:1 respect 5:3 7:1 8:1 9:1 10:1 11:1 12:1 response 19:21 13:1 14:1 15:1 16:1 17:1 18:1 responsible 16:23 18:5 19:1,6 20:1 21:1 22:1 restricted 20:4 23:1 24:1 25:1 26:1 27:1 28:1 restrooms 2:12,15 29:1 30:1 31:1 32:1 33:1 result 3:22 screen 6:5 review 3:5,17 4:10,13 19:5 21:6 second 2:14 5:13 9:22 21:8 section 19:14,18,24 20:3,5 reviewed 3:17 sections 20:9 revolution 18:18 security 19:20 right 2:5 11:21 21:8 22:24 23:4 see 9:23 10:4 12:4 17:19 32:5 seeing 24:9 rigorous 21:6 seen 32:13 ring 11:17 semiconductor 3:6,12 14:13 Riordan 7:11 10:14,18,23 11:10 16:12 31:9 11:12,15,19,21,22 13:24 semiconductors' 14:17 Riordon 10:12,14 sent 14:12 rivers 17:21 September 3:19 8:19 road 1:12 8:7,13,13,16,16,17,17 SEQRA 1:1,5 2:1 3:1,18,19,20 10:15 11:22 16:3 21:15,16 4:1 5:1 6:1 7:1 8:1 9:1 10:1 roads 8:16,25 9:8,11 23:21 11:1 12:1 13:1 14:1 15:1 16:1 roadways 23:14 17:1 18:1 19:1 20:1 21:1 22:1 Robert 1:19 23:1 24:1 25:1 26:1 27:1 28:1 roof 27:14 29:1 30:1 31:1 32:1 33:1 rooftop 27:16,17,21 serious 32:13 room 19:11 serve 26:19 roughly 7:3,5 service 29:23 round 5:13 services 2:20,21 19:24 20:5 route 3:15 8:25 21:22 23:10 session 3:4 4:14,18 rubber 16:3 set 26:4 rumors 23:17 seven 15:21 seven-thirty 32:24 S seventy 31:14 S-C-A-N-L-O-N 21:14 sheriff 31:4 ARII@courtsteno.com www.courtsteno.com 519 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 44 replaced 28:10,13 S-C-I-O-R-T-I-N-O 8:5 reported 1:23 33:4 S-C-O-C-I-O 25:12 reporter 4:20,25 7:14,23 8:2 safe 17:23 11:5,11 33:12 safeguards 17:19 reports 27:5 safely 18:2 represent 11:23 12:20 safety 16:23 19:19 25:3 representing 10:19 sake 14:15 request 9:9 30:8 Salina 24:15 required 3:16 4:9 15:17 sat 30:5 residences 18:4 23:12 says 31:22 resident 10:24 11:25 13:13 Scanlon 18:12 21:11,13,14 18:14 23:3 25:25 Sciortino 7:10,16,19,22 8:4,5,7 residential 20:16 scope 4:3 6:13 15:15 19:10 21:7 residents 9:17 12:17,19,22 13:7 29:15,22 13:10,16,19 14:20 16:24 scoping 1:1,5 2:1 3:1,4 4:1,2,2 residual 19:21 4:10,11,12,13,15,19 5:1 6:1 respect 5:3 7:1 8:1 9:1 10:1 11:1 12:1 response 19:21 13:1 14:1 15:1 16:1 17:1 18:1 responsible 16:23 18:5 19:1,6 20:1 21:1 22:1 restricted 20:4 23:1 24:1 25:1 26:1 27:1 28:1 restrooms 2:12,15 29:1 30:1 31:1 32:1 33:1 result 3:22 screen 6:5 review 3:5,17 4:10,13 19:5 21:6 second 2:14 5:13 9:22 21:8 section 19:14,18,24 20:3,5 reviewed 3:17 sections 20:9 revolution 18:18 security 19:20 right 2:5 11:21 21:8 22:24 23:4 see 9:23 10:4 12:4 17:19 32:5 seeing 24:9 rigorous 21:6 seen 32:13 ring 11:17 semiconductor 3:6,12 14:13 Riordan 7:11 10:14,18,23 11:10 16:12 31:9 11:12,15,19,21,22 13:24 semiconductors' 14:17 Riordon 10:12,14 sent 14:12 rivers 17:21 September 3:19 8:19 road 1:12 8:7,13,13,16,16,17,17 SEQRA 1:1,5 2:1 3:1,18,19,20 10:15 11:22 16:3 21:15,16 4:1 5:1 6:1 7:1 8:1 9:1 10:1 roads 8:16,25 9:8,11 23:21 11:1 12:1 13:1 14:1 15:1 16:1 roadways 23:14 17:1 18:1 19:1 20:1 21:1 22:1 Robert 1:19 23:1 24:1 25:1 26:1 27:1 28:1 roof 27:14 29:1 30:1 31:1 32:1 33:1 rooftop 27:16,17,21 serious 32:13 room 19:11 serve 26:19 roughly 7:3,5 service 29:23 round 5:13 services 2:20,21 19:24 20:5 route 3:15 8:25 21:22 23:10 session 3:4 4:14,18 rubber 16:3 set 26:4 rumors 23:17 seven 15:21 seven-thirty 32:24 S seventy 31:14 S-C-A-N-L-O-N 21:14 sheriff 31:4 ARII@courtsteno.com www.courtsteno.com 520 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 45 short 3:25 stage 10:2 show 5:3 32:22 stairs 2:14 shown 31:17 stakeholders 28:18 shows 12:10,12,14 30:11 start 7:16,19 11:12 17:7 23:24 Sierra 14:4,7,11 24:17 25:13 23:25 31:4,8 started 2:11 6:23 Sign 2:18 starting 14:17 signed 5:8 state 1:2 3:17 4:23 7:15,25 significant 3:23 8:10 9:20 8:25 26:4 27:6 30:10,24 33:2 14:22 16:7 20:12 stated 33:5 Silicon 14:18 statement 3:25 4:7 5:2 15:2 similar 23:18 states 10:5 15:10 simple 13:15,19 stem 14:16 simpler 13:3 step 4:2 simply 15:16 storage 19:20 21:24 32:9 sir 30:19 stoves 26:22 sit 25:14 32:19 street 23:4 site 27:13 28:2 studied 4:6 sitting 30:14 study 19:12 20:3 six 14:8 23:10 31:5 stuff 32:3 sixteen 27:7 submit 5:20 6:2,6 22:18 sixteen-inch 28:5 submitted 20:24 size 9:12 21:4 submitting 5:22 6:3,24 slowly 4:25 subscribed 33:10 smaller 15:5 substances 31:11 smartly 23:11 24:6,9 substantial 8:23 socioeconomic 20:5 sufficiently 5:10 soft 2:5 suggest 16:4 solar 27:13,16,18,22,23,24 28:2 Super 2:4 solid 32:6 supervisor 16:21 soon 27:11 supply 19:19 sort 29:14 support 18:8 19:9 sounds 11:19 24:2 supporting 17:13 source 26:10 supposed 23:25 sources 27:8 sure 2:21 17:14,22 18:3 21:20 south 29:12 29:15,17,22 31:2 spaces 9:2 25:5 surface 29:24 Spanish 2:18 surfaces 27:15 speak 4:24 5:8,15 11:6,8 16:25 surprised 12:22 17:8 21:17 22:12 29:3 30:12 surrounding 9:14,17 speakers 30:3,17 sustainability 16:2 speaking 2:18 5:4 sustainable 19:4 20:23 25:20 specific 9:10,15 19:16 Syracuse 1:10 15:8,13 18:15,16 specificity 19:17 20:2 18:18 20:15,19 22:11 24:8 speed 9:12 25:20 spell 7:15,25 10:17 17:9 T spelled 23:2 table 4:21 spill 19:20 Taft 1:12 square 27:14 31:25 32:2 take 2:9 5:25 7:4 25:20 stacks 17:16 talker 2:5 ARII@courtsteno.com www.courtsteno.com 520 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 45 short 3:25 stage 10:2 show 5:3 32:22 stairs 2:14 shown 31:17 stakeholders 28:18 shows 12:10,12,14 30:11 start 7:16,19 11:12 17:7 23:24 Sierra 14:4,7,11 24:17 25:13 23:25 31:4,8 started 2:11 6:23 Sign 2:18 starting 14:17 signed 5:8 state 1:2 3:17 4:23 7:15,25 significant 3:23 8:10 9:20 8:25 26:4 27:6 30:10,24 33:2 14:22 16:7 20:12 stated 33:5 Silicon 14:18 statement 3:25 4:7 5:2 15:2 similar 23:18 states 10:5 15:10 simple 13:15,19 stem 14:16 simpler 13:3 step 4:2 simply 15:16 storage 19:20 21:24 32:9 sir 30:19 stoves 26:22 sit 25:14 32:19 street 23:4 site 27:13 28:2 studied 4:6 sitting 30:14 study 19:12 20:3 six 14:8 23:10 31:5 stuff 32:3 sixteen 27:7 submit 5:20 6:2,6 22:18 sixteen-inch 28:5 submitted 20:24 size 9:12 21:4 submitting 5:22 6:3,24 slowly 4:25 subscribed 33:10 smaller 15:5 substances 31:11 smartly 23:11 24:6,9 substantial 8:23 socioeconomic 20:5 sufficiently 5:10 soft 2:5 suggest 16:4 solar 27:13,16,18,22,23,24 28:2 Super 2:4 solid 32:6 supervisor 16:21 soon 27:11 supply 19:19 sort 29:14 support 18:8 19:9 sounds 11:19 24:2 supporting 17:13 source 26:10 supposed 23:25 sources 27:8 sure 2:21 17:14,22 18:3 21:20 south 29:12 29:15,17,22 31:2 spaces 9:2 25:5 surface 29:24 Spanish 2:18 surfaces 27:15 speak 4:24 5:8,15 11:6,8 16:25 surprised 12:22 17:8 21:17 22:12 29:3 30:12 surrounding 9:14,17 speakers 30:3,17 sustainability 16:2 speaking 2:18 5:4 sustainable 19:4 20:23 25:20 specific 9:10,15 19:16 Syracuse 1:10 15:8,13 18:15,16 specificity 19:17 20:2 18:18 20:15,19 22:11 24:8 speed 9:12 25:20 spell 7:15,25 10:17 17:9 T spelled 23:2 table 4:21 spill 19:20 Taft 1:12 square 27:14 31:25 32:2 take 2:9 5:25 7:4 25:20 stacks 17:16 talker 2:5 ARII@courtsteno.com www.courtsteno.com 521 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. Page 46 talking 20:13 track 13:5 24:24 talks 31:20 32:5 traffic 8:14,18 9:13 18:4 21:19 tall 17:17 21:21 23:9,20 29:19 task 21:8 transcription 33:6 taxes 9:24 10:5,7,8,9 14:21 transport 19:19 32:10 21:19 transportation 25:6 technical 19:13 treated 22:2 tell 14:15 treating 22:4 ten 31:17 treatment 21:24 tested 17:22 trillion 31:15,15,16 thank 6:19,21,22 7:23 8:2,4,6 trip 28:21 10:9,11 11:20 13:20,24 16:15 trips 8:23 16:16 18:10,11 21:10,11 22:7 trucks 9:4 21:22 29:10 22:8,20 24:11 25:8,9,21,22 true 33:7 28:22,23 29:25 30:2,2 32:17 try 30:8 32:18,24 tunnel 15:21 thanks 2:6 6:24 17:5 turn 6:16 16:15 thing 21:2 26:21 32:13 twelfth 31:17 things 7:3 13:3 16:14 21:18 twelve 25:5 31:12 twenty 3:12 think 5:11 7:4 12:6,21 13:19 twenty-year 9:7 24:6,25 two 8:25 10:7 12:16 15:21 23:25 thorough 19:6,16 32:2 thought 13:21 29:3,15 two-and-a- 15:4 thoughts 22:18 23:9,15 typewritten 33:6 thousand 14:6,8 25:5 threat 24:18 U three 5:9,11 7:3 9:3 10:8 14:6 U-L-A-T-O-W-S- 17:10 17:22 30:8,20 32:3 Ulatowski 13:25 16:17,19,20 throw 25:4 17:3,6,10 thrown 17:20 unacceptable 9:19 time 5:11,14 25:8 33:4 understand 9:25 21:3 23:23 timely 13:21 understanding 28:4 times 15:5 understated 32:16 timetable 9:15 understood 20:20 tiny 31:17,17 undertaking 27:13 today's 21:9 31:4 unintelligible 25:14,25 29:21 told 7:5 26:15 27:19 uprooting 23:12 tonight 4:17,20,23 5:9 6:11 urge 21:7 11:3 12:6 21:17 29:3 usage 25:18 27:3 28:4 tonight's 4:13 use 15:11 16:7 26:16,23 27:2,5 tons 32:3 uses 16:12 topic 9:22 19:18 usually 2:5 topics 4:4 19:18,25 utilized 20:9 touch 22:12 town 3:13,15 8:8 9:24 10:15,20 V 11:22,24 12:10,13,15,19 16:21 Valley 14:18 23:3 16:22 21:15 23:3,8 24:15 value 8:11 toxic 16:14 31:18 Van 8:7,13,17 toxicity 31:11 32:15 vehicles 9:5 ARII@courtsteno.com www.courtsteno.com 521 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. 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Page 47 vehicular 8:23 writing 5:20 verbal 6:11,15 written 4:3 6:2,6,9,11,15 7:22 Vermont 15:10 27:6 20:24 22:19 30:15,15,17 32:5 VerPlank 8:13,17 Viaduct 15:20 X Vice 18:15 vision 21:5 Y visionaries 17:11 yeah 11:5,16 22:22 visual 20:13 year 23:24 vital 18:8 years 3:12 17:22 23:25 voice 5:18,18 York 1:2,13 3:7,15 8:25 14:6 volume 9:13 26:4 29:2 33:2 volunteer 26:2 Z W W- 25:24 0 want 2:9,16 6:20 7:7 11:12 13:6 14:15,23,24 15:14 17:13 29:21 1 30:6,12 32:23 1 33:5,7 wasn't 21:20 29:3 10 9:3 waste 32:6 10/11/23 1:1 2:1 3:1 4:1 5:1 wastewater 17:25 21:24 22:2 6:1 7:1 8:1 9:1 10:1 11:1 water 13:3 15:12 16:7,8 27:2 12:1 13:1 14:1 15:1 16:1 17:1 waters 17:20 27:3 18:1 19:1 20:1 21:1 22:1 23:1 way 13:15 17:23 18:20 20:12 24:1 25:1 26:1 27:1 28:1 29:1 25:21 26:11 30:1 31:1 32:1 33:1 we'll 3:3 7:3 18:3 100 16:6 24:20 28:14,20 we're 11:3,8 12:5 17:17 32:19 11 1:9 we've 26:15,23 32:13 11th 31:5 we’d 13:14 12,000 9:2 website 4:12 6:4,7,8 13041 1:13 week 29:5 14 12:10 weight 6:15 14th 3:8,19 8:19 welcome 32:24 163 17:16 welfare 16:23 18th 33:10 well-documented 14:17 2 well-spoken 24:15 went 14:25 2019 26:6 West 1:12 2023 1:9 3:7 8:19 33:10 WHEREOF 33:9 20th 6:10 30:16 White 3:14 20:14 21:5 24/7 24:2 wife 8:8 9:22 3 Wirth 25:10,23,24,24 wish 5:19 30 9:3 WITNESS 33:9 31 3:15 23:10 29:18 wondering 17:17 32 33:7 words 6:20 4 work 7:3 12:7 13:6,9,15 worker 19:19 400,000 32:2 workers 14:19 24:21,22,25 25:7 481 8:25 ARII@courtsteno.com www.courtsteno.com 523 800.523.7887 10-11-2023, Public Meeting Associated Reporters Int'l., Inc. 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