CHIPS and Science Act Demands New Attention on EHS

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September 22, 2022 - The newly-approved CHIPS and Science Act will provide nearly $52 billion in government grants and incentives toward domestic semiconductor, solar panel, and electric vehicle manufacturing. Despite previous initiatives to begin U.S. production of these high-tech products, 75% of the global supply of advanced semiconductors specifically are currently manufactured in East Asia.

This legislation is anticipated to better position the U.S. against current and future supply chain disruptions that have plagued nearly every industry from automobiles to cell phones to home appliances well before the pandemic began in early 2020. Additionally, this Act is slated to authorize further funding over the next five years to advance scientific research, invest in workforce training, and expand 5G wireless technology.

Of the nearly 100,000 jobs the bill is expected to create, this now places an even larger, and more imminent demand for environmental, health, and safety (EHS) expertise. And while each EHS aspect will require special attention throughout the all planning, development, and construction phases, one area in particular must be addressed well before any construction crew can break ground.

Semiconductor manufacturing facilities located in the United States are required to obtain air permits prior to constructing a new facility, expanding an existing facility, or modifying operations. The air permit(s) specify applicable emission standards and work practices and likely require the installation of Best Available Control Technology (BACT) to reduce air emissions from their operations. Specifically, emissions from these facilities must maintain National Ambient Air Quality Standards (NAAQS) and may not exceed established health risk standards for specific hazardous/toxic chemicals.

Currently, as site selection planning is underway in three states, Arizona, Ohio, and Texas, each of these areas have their own permitting needs. Preparing permit applications alone for projects of this magnitude is no small undertaking and requires a specifically trained air quality compliance professional who clearly understands what is necessary. Timing varies within these different states, so checking with local agencies and inquiring about programs to expedite permitting if needed is critical. In addition, it is important that the definition of construction and modification are clearly understood. In many cases, the permit authorization must be in hand by the time any construction (i.e., foundations set, mechanical run, etc.) related to the emission source is undertaken.

Follow along with our thought leadership on Experts Corner as BSI leaders discuss the implications of the new CHIPS and Science Act and the impact this legislation may have on your organization.