BY EMAIL 

Mr. Reid Harvey 

Acting Director, Climate Change Division 

USEPA Headquarters 

Ariel Rios Building 

1200 Pennsylvania Avenue, N. W. 

Mail Code: 6207J 

Washington, DC 20460 

Re: EPA Docket # EPA-HQ-OAR-2009-0927 

The Semiconductor Industry Association (SIA) submits this letter in support of the anticipated 

proposal by the Environmental Protection Agency (EPA) to make limited, short-term revisions to 

the Mandatory Reporting of Greenhouse Gases: Additional Sources of Fluorinated GHGs, 

codified at 40 C.F.R. Part 98 Final Subpart I. 

SIA has filed both a petition for review and petition for reconsideration raising various feasibility, 

cost and confidentiality issues with the current Final Subpart I. Over the last several months, 

SIA and EPA have been engaged in discussions to explore a resolution of this matter. SIA has 

proposed that EPA revise Subpart I to provide facilities with a menu of options as an alternative 

to the existing method contained in the final rule and has committed to gather data sufficient to 

demonstrate the viability of these options. 

SIA appreciates EPA's willingness to support this effort by using its Section 307(d)(7)(B) 

authority to extend the June 30 BAMM deadlines, while engaging in an expedited rulemaking to 

provide semiconductor facilities with limited, short-term flexibility for reporting years 2011 and 

2012. This approach should provide SIA and its members sufficient time to gather data on 

alternative reporting methods for potential inclusion in a revised Final Subpart I. 

As discussed with EPA during our meetings of January 11 and 24, March 15, and May 11 and 

12, the alternatives being proposed by SIA are the following: 

• Etch process subcategories and default emissions factors • Abatement • Stack testing 

SIA and its member companies, in collaboration with technical support from the International 

Sematech Manufacturing Initiative (lSMI), are implementing a workplan under a robust schedule 
and develop default emission factors. Our group has identified 1500

2000 300mm etch data 

points and over 500 200mm data points and we are evaluating approximately 20 data 

parameters in this process. We anticipate that we will provide EPA with an analysis of the 300 

mm data by July 1,2011 and an analysis of the 200 mm data by July 15, 2011. The SIA group 

will use this data to identify sub-process level categories that are representative of process 

emissions, provide an initial estimate of default emissions factors for each category, and 

determine what, if any, additional data collection work is required to validate that the default 

factors are representative of each identified etch category. This approach is projected to 

achieve accuracy in emissions reporting comparable to the proxy 2d method established in the 

final rule with precision improvements over the 2b and 2c methods, while minimizing SIA's 

concerns about technical infeasibility, cost, and disclosure of confidential business information. 

It is SIA's intent to complete accuracy and precision characterizations on the proposed 

categories and default factors when compared to the IPCC tier 2b, tier 2c, and tier 3 methods 

(Tier 3 will act as a proxy for the comparison to the proxy 2d method proposed in the final 

subpart I regulation), as well as a sensitivity analysis of the impact of changes in the emissions 

factors on the estimate of the emissions for a facility. 

2.	 Direct Estimation of Emissions Based on Use Allocation and Application of 

Abatement Unit Destruction Efficiency (ORE) 

For those facilities with a significant number of abatement units, the SIA group is working to test 

abatement unit destruction efficiencies for all gas types treated and apply destruction 

efficiencies directly to allocated emissions. We are in the process of identifying facilities with 

abatement systems and analyzing the impact of this approach. Our goal is to provide EPA with data on this alternative by September 2011, as work to compare the accuracy, precision and 

sensitivity of this alternative depends on development of the etch emissions categories 

discussed in item 1. 

3.	 Stack Testing 

SIA is working to obtain data that will allow EPA to validate stack testing pursuant to Method 

301 based on the two accepted analytical methods for F-gas analysis, FTIR and GC-MS. SIA is 

evaluating the data collected to date, as well as conducting additional tests that are designed to 

determine the most appropriate combination of sample point locations, sampling frequencies, 

collection of fab operating data, and analytical methodology, to achieve high quality emission estimates. These evaluations are being conducted at several fabs during normal operating 

conditions. SIA is also working with analytical laboratories to develop analytical method 

validation workplans. Upon obtaining EPA's concurrence with these workplans, SIA will then 

complete the validation effort pursuant to these workplans. Likewise, as the pilot test data 

becomes available, SIA intends to work with EPA to refine the methodology for using production 

data in conjunction with stack sampling results to produce annual emissions estimates. 
We appreciate EPA

s ongoing and constructive discussions with us to explore these alternatives 

and we believe that, given the additional time provided by the expedited rulemaking to work on 

these options, we can develop alternative reporting methods that EPA can consider for inclusion 

in a new final rule. 

Sincerely, 

David Isaacs Vice President, Government Policy