Page 1 of 34 January 4, 2012

I. Executive Summary

The “Mandatory Reporting Rule for Greenhouse Gases: Additional Sources of Fluorinated 

Gases; Final Rule” (MRR) sets a default Destruction or Removal Efficiency (DRE) of 60% for 

all abatement devices treating F-gas and Nitrous Oxide (N2O) emissions from semiconductor 

manufacturing processes. This value is significantly below the abatement system manufacturers 

expected DREs for F-gases, which can range from 70% to 99% depending on the abatement 

system and the F-gas. Under the rule, if a semiconductor manufacturer wishes to perform testing 

to demonstrate that their abatement systems are performing at or above the default DRE of 60%, 

the MRR requires a semiconductor manufacturer to annually test 20% or 3 of each class of 

abatement systems. This results in facilities having to test between 22 and 74% of the installed 

abatement systems to use a more representative DRE. This annual testing will cost a facility,

from $90 K to $810 K per year depending on the number of installed systems, .3 to 2.5 full time 

equivalents to manage the testing program, and 18 to 135 days of lost production time for the 

tools being tested; all of this to accurately represent the emissions reductions that are being

achieved from the company’s substantial investment in voluntary abatement systems.

SIA has collected abatement system inventory data from 9 U.S. semiconductor manufacturing 

facilities and DRE test data on 72 abatement devices from two semiconductor manufacturers. 

Based on the analysis of this data, SIA is proposing an alternative method to group abatement 

systems and apply the DREs to F-gas emissions. This alternative is based on a combination of 

the process types as defined in the MRR and the gas or gas groups being treated by the 

abatement units. We have data that support industry level DREs at 90% or 99% for 4 of these 

categories based on a statistical analysis of the testing data. We have also developed a sampling 

based testing protocol for generating site specific DREs for a specific process category and gas 

or gas group that reduces the required abatement unit testing by 16% to 50%. The proposed 

revised default DREs and the revised testing protocol for site specific DREs will reduce the need 

for and the cost of testing by over 90% while providing EPA and the industry with more accurate 

emissions estimates for the facilities that employ abatement systems to reduce F-gas emissions. 

SIA commented on the proposed rule stating that this testing requirement was unnecessarily and 

overly burdensome. In rejecting those comments, EPA indicated that we had not provided the 

data needed to alter these requirements. Our ability to create and file data on DRE testing was 

limited by the relatively short comment period and limited, available data. As the agency is

aware, we have worked for months on developing and presenting data on DRE performance of 

fab controls. This report presents the results of that work and does provide an analytical basis for 

a practical and effective way of determining and applying DREs to fab controls.

II. Facility Level DREs and Process for Assessing Site Specific DREs

A. Description of Data Collected

A.1: Installed Abatement Systems in the United States
Page 2 of 34 January 4, 2012

In June of 2011 the SIA and ISMI members were surveyed to determine the number of POU 

GHG abatement units installed in U.S. semiconductor facilities (fabs). In addition to the number 

of units, the survey asked for the name of the device manufacturer, the device model and the 

gases being treated by each device. The data was used to assess how many devices would have 

to be tested to enable a facility to use site specific DREs to calculate emissions under the 

requirements of the Mandatory Reporting Rule (MRR), as well as under alternate approaches to 

grouping abatement units. The MRR requires annual testing of 20% or at least three units for 

every “class” where class is defined by the combination of device manufacturer, device model 

and gas or gases being treated. Any change in any one of the three parameters signifies a new 

class under the rule. 

Five large U.S. semiconductor manufacturing companies (A through E) responded to the survey. 

The survey participants represent a significant percentage of the installed abatement units in the 

U.S. There are 1307 abatement devices installed at 9 manufacturing facilities. This represents 

approximately 50% of all the POU GHG abatement devices in U.S. fabs, based on an ISMI 

survey conducted in 2010 to determine the number of abatement systems installed at U.S. 

semiconductor manufacturing facilities.

The Tables I through VII in Appendix A detail the site specific abatement system inventories,

including the number of devices and device models at each facility and the percent of the total 

abatement device inventory which would have to be tested annually based on the current MRR 

subpart I requirement. 

A.2: Abatement System MRR and Alternative Groupings or Categorization

Table A-1 shows the number of POU GHG abatement devices by company and fab. It also 

illustrates the number of devices that would have to be tested based on different groupings of 

abatement systems, including the required Subpart I groupings, when applying the requirement 

to test 20% or 3 per group per year MRR requirement. 

The grouping identified as “MRR”, shows that under the MRR a total of 450 out of 1307 devices 

or 34% of all units would have to be tested annually. This significantly exceeds the 20% 

postulated by the MRR as the required percentage of units sampled per year and is due to the 

great variety of device models used and the different combinations of gases that are treated by 

each device. The other groupings look at the effect of splitting each fab’s device inventory into 

less granular categories such as by device model (without regard to gases treated); by process 

category, etch/CVD/other (without regards to mfr. or model); and by gas type, Perfluorinated 

Compounds (PFCs) or NF3 (without regard to mfr., model or individual gases treated). Each of

these less granular categories result in fewer devices that have to be tested compared to the 

grouping by “class”, as required by the MRR. However, the alternate approaches to 

categorization of abatement devices still result in a very large number of tests each year and 

leave in place significant impediments to achieving a more representative DRE than the 60% 

default value allowed under the MRR.
Page 3 of 34 January 4, 2012

Table A-1 - Number of Devices Requiring Annual Testing Based on Grouping 

Company A B C D E

Fab A Fab B Fab C Fab E Fab X Fab Y Total

Total Inventory 462 167 2 157 190 74 78 42 135 1307

Grouping Used to Determine 

Testing Requirements & 

Number of Tests

 MRR Provisions 135 62 2 36 42 27 58 18 70 450

 Group by Model 99 38 2 35 40 21 21 15 39 310

 Group by Process

 (Etch/CVD/Other) 94 34 2 33 39 17 18 11 28 276

 Group by gas (PFC/NF3 only) 93 34 2 32 38 15 16 11 28 269

Table A-2 uses the data from Table A-1 and converts it to a percent of each fab’s device 

inventory. For the MRR “class” categorization anywhere from 22% to 100% of a fab’s device 

inventory would have to be tested each year. Large fabs with the fewest device 

manufacturer/models combinations approach the 20% annual testing requirement while fabs with 

a greater variety in device models and more R & D activities (i.e., more gas combinations) result 

in a higher number of testing requirements. Applying less detailed groupings to set the annual 

testing requirements approaches 20% annual testing for many, but not all, fabs.

Table A-2 - Percent of Total Inventory Requiring Annual Testing

Company A B C D E

Fab A Fab B Fab C Fab E Fab X Fab Y

% of % of % of % of % of % of % of % of % of

Abatement System 

Groupings Total Total Total Total Total Total Total Total Total

MRR 29 37 100 22 22 36 74 42 51

Model 21 22 100 22 21 28 26 35 28

Etch/CVD/Other 20 20 100 20 20 22 23 26 20

PFC/NF3 only 20 20 100 20 20 20 20 26 20

Based on the survey, a total of six manufacturers (MfrZ, MfrX, MfrY, MfrW, MfrT and MfrV) 

supplied the POU GHG abatement devices to the five companies. Of these MfrZ, MfrX, and 

MfrY provided by far the greatest number of devices. Based on the collected inventory data, the 

preponderance of POU F-gas abatement devices (96%) use combustion technology. The 

majority of the devices use natural gas and air and/or oxygen to achieve high temperatures in the 

combustion chamber for the destruction of the fluorinated compounds. Just a few of the devices 

(4%) are pre-vacuum pump plasma devices (see Appendix A, Table III). 
Page 4 of 34 January 4, 2012

A.3: Manufacturer’s DREs

The destruction/removal efficiencies (DREs) reported by the device manufacturers are 

summarized in Table A-3. MfrZ broke down their data by model, as some models achieve lower 

DREs and are not suited for certain gases, like CF4 and SF6. All reported DREs are in the 70-

99% range. 

Table A-3 - DRE Values Reported by Device Manufacturers 

MfrZ MfrZ MfrZ MfrZ MfrX MfrY

Gas

Models

I-N

Models 

G&H

Models 

E&F

Models 

A-E Model A Model A

CF4 no value 90 90 no value 90 92

C2F6 no value 95 95 95 98 no value

C3F8 no value 95 95 95 98 99

c-C4F8 no value 99 99 99 98 no value

cC4F8O no value 99 99 99 no value no value

C4F6 no value 99 99 99 98 no value

C5F8 no value 99 99 99 no value no value

CHF3 no value 99 99 99 98 99

CH2F2 no value 99 99 99 no value 99

CH3F no value 99 99 99 no value 99

NF3 70 99 99 99 98 98

SF6 no value 95 95 90 98 97

N2O no value no value no value no value no value 69

A.4: Abatement System Testing Data

Two semiconductor manufacturers have completed destruction efficiency testing on their 

abatement devices. The data is provided in Appendix B. One company tested 52 abatement 

units in 2011, and performed five retests after the abatement device was serviced to address a 

low DRE identified by the first test. The retests were done on two MfrZ Model I units abating 

NF3 emissions and three MfrZ Model A units abating a mixture of etch gases which included 

CF4. A second company provided test data on 20 units, 7 abating etch emissions and 13 abating 

clean emissions. At the time of the setting of the default DRE and the DRE testing requirements 

in the final rule, EPA indicated that the agency had very limited data available to establish both 

the default values and the testing requirements. After months of work, ISMI and SIA and the 

members have compiled and analyzed a large data set on the population and performance of Fgas abatement systems. These data can now be used to set more accurate default DREs and 

practical and effective testing provisions. The testing data is analyzed and discussed in section 

B.1 of this briefing paper.

B. Proposal of Industry Level DRE Values and a Location-Specific DRE Testing Process
Page 5 of 34 January 4, 2012

The analysis of the MRR testing requirements against the 9 facility abatement system inventories

(both under the MRR abatement system categorization requirements and several simplified 

categorization approaches) illustrate the extensive and costly annual testing required under the 

rule. The MRR requires an overly granular classification system and an annual number of DRE 

tests that goes far beyond what is statistically required to accurately characterize DREs for the 

purpose of estimating GHG emissions from abated facilities. Under the current MRR 

requirements, characterization of the emissions reductions achieved by company’s use of 

abatement devices requires hundreds of thousands of dollars of annual expense for testing and 

significant disruption to fab operations (see section D).

In sections B and C, SIA presents a statistical analysis of the collected abatement system testing 

data to propose and provide technical justification for a simplified abatement system DRE testing 

structure. This structure groups DREs by process type and gas or gas groups, supports modified 

industry-wide DREs for 4 process/ gas or gas group categories, and proposes a simplified, 

sampling-based method to develop and validate site-specific DREs where needed.

B.1 Statistical Analysis of Abatement Device Performance

Summary of DRE Results

Abatement system DRE testing data from two device manufacturers have been combined to

produce a substantial database on abatement device performance in plasma etch and chamber 

cleaning. The database contains a total of 145 tests covering 7 different input gases and four 

EPA process categories1. In this count, a test consists of a specific abatement device used to 

abate emissions from a specified process type with a measured DRE for one input gas. Most 

etch abatement devices were tested on multiple gases (counted as separate tests for each gas), 

while chamber cleaning abatement devices were tested only on NF3. A total of 72 different 

abatement devices have been tested, and the database amounts to an appreciable fraction – 2.5%

or one in every 40 devices – of the total population of devices in the U.S. semiconductor 

industry. The database is large enough and sufficiently robust in coverage to establish average 

DREs by process type with good precision.

Table B-1 summarizes the testing results for the average DRE by process type and input gas. In 

etch, CF4 is known to be difficult to disassociate and this is reflected in the testing performance 

of many CF4 abatement devices. Although some devices achieved DREs in excess of 80%, the 

overall average was 54.5% ± 7.5% (one-sigma standard error). The 60% default DRE in the 

EPA rule is contained within the ± one-sigma error limits of the 54.5% average, which is not 

statistically different from 60%.

For the other gases and processes, the abatement devices performed at high DREs. In plasma 

etch, DREs were measured for NF3, SF6, and four different PFCs. The average DREs for the 

gases cluster around 99% with remarkable consistency. Given the high DRE level, the 

individual results by gas are equivalent to 99% for all practical purposes, differing at most by 

less than 0.3%. The overall average for these gases is 99.07% ± 0.13% and not statistically 

 

1

 No testing was performed on devices used to abate emissions from wafer cleaning, the fifth EPA process type. 

Separately, SIA has proposed to combined wafer cleaning with the plasma etch process for emissions calculations, 

and we would propose to account for wafer cleaning abatement using the DREs established for etch.
Page 6 of 34 January 4, 2012

different from 99%. This result is supported by a sample of N=73 tests, including 14 to 20 tests 

for four of the six gases.

In chamber cleaning, a total of 49 tests have been performed for NF3. The average DRE is 

estimated to be 88.7% ± 3.7% (one-sigma) for in-situ plasma cleaning and 88.4% ± 2.6% (onesigma) for remote plasma cleaning. Only one test is available for thermal cleaning; while no 

statistical inference is possible, the test is consistent with an average DRE of 90% or more. 

Combining the data for all three processes results in an overall average DRE of 88.7% ± 2.1%

(one-sigma) for NF3 abatement in chamber cleaning. Tests performed using analysis of variance 

demonstrate that there is no statistically significant difference in the average DRE by subprocess, 

so that a single value of 90% can be used to represent the DRE for all three NF3 based chamber 

cleaning process categories.

The statistical analysis detailed in table B-1 demonstrates that revised, industry-level DREs can 

be assigned for the three NF3 chamber clean process types and all F-gas etch processes, with the 

exception of CF4. 

Table B-1. Summary of Average DREs in Abatement Testing

Process Gas N 

(Tests)

Average DRE (%)

(± standard error)

Plasma Etch

 Etch (CF4) CF4 23 54.5 ± 7.5

 Etch (Other Gases) NF3 14 99.27 ± 0.13

 SF6 4 99.14 ± 0.31

C2F6 1 99.0 

C4F8 20 98.91 ± 0.13

CHF3 19 99.18 ± 0.36

CH2F2 16 98.94 ± 0.19

 All Etch (Excluding CF4) NF3/Other 73 99.07 ± 0.13

Chamber Cleaning

 In-situ Plasma NF3 22 88.7 ± 3.7

 Remote Plasma NF3 26 88.4 ± 2.6

 Thermal Clean NF3 1 98.9 

All Chamber Cleaning NF3 49 88.7 ± 2.1

Discussion of Results

The data demonstrate that statistically significant DRE differences exist for NF3 between plasma 

etch and chamber cleaning processes. With the exception of abatement of CF4, the average DRE 

is remarkably consistent among NF3, SF6, and other PFC gases within etch. The average NF3 
Page 7 of 34 January 4, 2012

DRE for chamber cleaning is also consistent among the process types. The devices offered by 

leading manufacturers for etch abatement are certified to achieve consistently high and 

comparable DRE levels for NF3 and other gases, with lower performance levels for CF4. 

Among devices commonly used in chamber cleaning abatement, manufacturer device 

specifications do not vary by process subtype. Thus, the consistency of device performance for 

NF3 and related etch gases and for NF3 in chamber cleaning is a reasonable and expected result.

In the testing performed at one company, the abatement DRE test results for many of the CF4 

units were lower than expected and below the manufacturer’s DRE. The CF4 molecule is 

difficult to break up as illustrated by its low utilization rate in the etch processes and the fact that 

CF4 has the lowest expected DRE of the F-gases used in semiconductor manufacturing. While 

several of the abatement units did achieve destruction efficiencies at/above the manufacturer’s 

expected DRE, indicating the units can function as intended, the range of DREs and the number 

of results below the expected results indicate that the operations and maintenance procedures at 

the testing facility need to be revised to achieve better CF4 DREs. It is noteworthy that units 

treating multiple gases including CF4 achieved the expected DRE on all the other gases. The 

facility team is working with the abatement system vendor to improve the operations and 

maintenance process to achieve the expected CF4 DREs. Once this process is completed, it is 

expected that a sample of the units will be retested to validate the improved DRE.

Figure B-1 shows measured DREs for individual tests (symbols) and average performance values 

(horizontal lines) for five different device types used in chamber cleaning to demonstrate that

device performance is consistent over time. The MfrZ Model I and Models A-G devices used 

for NF3 abatement in chamber cleaning achieve the same average efficiency level (DRE~88%) 

whether installed 8 to 10 years ago or in the last 1 to 4 years. Similar trends are seen for the 

MfrZ Model D and Model J device types. Abatement DRE for NF3 in chamber cleaning does 

not decline with age for devices of a given type; we expect the same result for NF3 and related 

gases in etch and also for CF4.

Figure B-1. Chamber-Clean NF3 Abatement DREs by Device Model and Age

60

70

80

90

100

0 2 4 6 8 10

NF3 DRE (Perce nt)

Age of Device

Model I

Model G

Model D

Model J

Model N
Page 8 of 34 January 4, 2012

For this reason, we do not believe it is necessary or appropriate to require testing of all abatement 

devices every five years, as in the EPA rule, for the purpose of monitoring DRE performance 

over time. Instead, revised default DREs can be assigned to the 4 categories detailed in Table B1 and we propose a representative sampling method to establish and maintain site-specific DREs 

where a facility is achieving higher average DREs than the default or for a process type/gas 

combination for which no DRE data is currently available.

The dataset is composed of 126 tests conducted in 2011 by one company using EPA Method 1 

and 19 tests conducted between 2003 and 2011 by a second company using a method 

comparable to EPA Method 2. We performed an analysis of variance to determine whether there 

is a detectable difference in the average DRE due to test method. For the second company’s 

abatement DRE testing, excluding CF4 results, there is a -1.3% difference for the four tests 

conducted using the EPA Method 2 equivalent. Three of the four etch process tests using 

Method 2 are for a device type not tested using EPA Method 1, and the observed difference may 

reflect a make/model (not test method) difference in performance. At most, any test method 

difference would appear to be very small.

For NF3 in chamber cleaning, the effect of test method is confounded with Model D device

performance, because 10 of the 12 tests conducted using the EPA Method 2 equivalent are of 

Model D devices operated in the high-fire mode. Once we account for the increased DRE of 

Model D devices in the high-fire mode, the analysis of variance shows that differences due to 

test method are not statistically significant (probability > 90% of occurring by chance).

Thus, differences in the average DRE based on test method, if any, are too small to be detected

in this data. We conclude that it is appropriate to pool the data from the two sources for purposes 

of establishing DREs.

B.2 Establishing Improved Default DREs for Abatement

Based on the EPA rule and the preceding analysis of the SIA database, we conclude that the 

available information supports establishing the improved default DREs shown in Table B-2. For 

CF4, we are proposing that the 60% default value in the EPA rule be retained, because the 

available CF4 testing for etch is consistent with EPA’s 60% default. 

For the other gases in etch, we propose to establish a single 99% default value covering NF3, 

SF6, and all other PFCs. The testing in the SIA database covers NF3, SF6, and 4 of the 8 

additional PFCs. As Table B-3 shows, the etch gases (other than CF4) can be placed into three 

groups based on the typical DRE specification for MfrZ abatement equipment used in etch (the 

specifications for other manufacturers would be similar). The SIA database contains testing for 

at least two gases in each group, and that testing uniformly indicates an average DRE of 99% by 

gas and across groups. From this one can reasonably expect etch abatement devices to achieve 

the same level of performance on the gases that have not been tested.

For NF3 chamber clean processes, we propose a default DRE value of 90% based on the 49 tests. 

The same default value is proposed for each of the chamber clean processes, but the structure 

would allow for the possibility that the DRE could vary by process on a site-specific basis. 
Page 9 of 34 January 4, 2012

Although C2F6 is a major gas used for chamber cleaning in 200 mm and C3F8 is also used in a 

limited number of applications, the SIA database does not have DRE testing data for either gas. 

In the absence of test data to characterize abatement performance for these gases, we propose to 

retain the 60% default DRE in the EPA rule for C2F6 and C3F8 in chamber cleaning. 

Nevertheless, we believe the actual DRE for these gases will be higher and, therefore, companies 

that use these gases in chamber cleaning will have an incentive to conduct testing to establish 

alternative DREs if they believe that device performance is actually better. 

We also propose to retain EPA’s 60% default DRE for N2O.
Page 10 of 34 January 4, 2012

Table B-2. Proposed Default DREs

Process Gas Default 

DRE Basis

Plasma Etch

 Etch CF4 60% EPA rule, supported 

by SIA database

 Etch NF3, SF6

All Other PFCs 99% SIA database

Chamber Cleaning

 All Sub-processes NF3 90% SIA database

 All Sub-processes Other Gases 60% EPA rule a/

N2O

 All Processes N2O 60% EPA rule a/

a/ SIA database does not contain information characterizing abatement 

performance for these gases in chamber cleaning.

Table B-3. Coverage of NF3, SF6, and Other PFCs For Etch

in SIA Database

Typical Specification 

MfrZ Abatement a/

Average DRE in 

SIA Database

Group 1 NF3 ≥ 99% 99.3%

Group 2 SF6 ≥ 95% 99.1%

C2F6 ≥ 95% 99.0%

C3F8 ≥ 95% Not tested

Group 3 C4F8 ≥ 99% 98.9%

C4F6 ≥ 99% Not tested

C5F8 ≥ 99% Not tested

CHF3 ≥ 99% 99.2%

CH2F2 ≥ 99% 98.8%

CH3F ≥ 99% Not tested

a/

 Table 4. Expected DRE Values for MfrZ Abatement Systems. Columns 1 and 2 

give the specifications for MfrZ etch abatement devices in the SIA database.

B.3 Application of the DRE Values:

Table B-2 details the process/gas categories for which SIA proposes that industry-level or sitespecific DREs be established. The industry-level and site-specific (section C.2) DRE values 

would be applied by category and gas type under the 2 factor model GHG emissions estimation 
Page 11 of 34 January 4, 2012

model (detailed by SIA/ISMI in a separate briefing paper delivered to EPA on 11/3/2011). 

Companies can use the default value or perform testing to create a site-specific DRE for one or 

more categories where warranted by the abatement systems used at that facility. Application of 

the average DRE at the gas and process level will greatly simplify apportioning of the gas use to 

the abatement units for the following reasons:

1. Under the 2 factor model, gas use is already being apportioned to the 5 process 

categories, or 4 if the wafer clean category is combined with the etch category. 

2. Abatement units can be easily assigned to each process and gas type, simplifying the 

calculation of abatement system uptime (see section III) and its application to the process 

gas and CO2e emissions numbers. Utilizing the proposed SIA approach for managing 

DREs will enable a facility to directly apply the average uptime for a group of abatement 

units to the process/gas emissions data.

3. Where the manufacturing equipment within a given process/gas category are not all 

abated, companies will be able use a simplified apportioning process based on their 

knowledge of the distribution of the abatement systems. 

SIA/ISMI is proposing that the Subpart I requirements detailed in (98.94.f.4 page 74825) be 

eliminated and replaced with the SIA/ISMI proposal.

C. Methodology to Develop Site Specific DREs

C.1 Process to Establish a DRE for a specified process group and gas type

Based on the analysis of the available testing data and the discussion in section B.2, SIA/ISMI 

has proposed revised industry wide DRE values based on process category and gas types for:

1. All F-gases used in the etch category, with the exception of CF4;

2. CF4 used in etch; 

3. NF3 used in three chamber clean categories: in-situ plasma clean, remote plasma clean, 

and thermal cleans; and \

4. Other F-gases used in chamber clean.

These default values have been generated from DRE testing performed on a sample of the 

installed base of abatement systems of two manufacturers. The tested units were installed from 

2002 to 2010. As a result, the test data represents different vintages of abatement systems. It 

includes newer designs capable of performing more consistently and at higher average DREs as 

equipment manufacturers have learned from the experience with earlier units and new or 

improved device technologies have been developed. While the analysis of the testing data in 

Section B.2 indicated that the DRE of individual units did not undergo statistically significant 

degradation with age, Figure B-1 did illustrate that the older units had a generally a lower 

average DRE and higher variability in their DRE values than the newer technology units (for 

example, comparing the DREs of the newer technology Model C unit to the Model I unit). 
Page 12 of 34 January 4, 2012

As companies outfit a new facility and/or install new manufacturing tools with new abatement 

devices, upgrade or replace older abatement devices, or improve operations and maintenance 

procedures at a given facility, the average DRE for a given process category and gas or gas group 

can improve over the proposed defaults. In those cases, it is appropriate for a location to have the 

option to perform abatement system DRE testing and establish a site-specific DRE where 

abatement system improvements or upgrades have been made. This will enable companies to 

benefit from their investment and efforts to improve abatement system DREs and to more 

accurately estimate their site emissions. 

Based on an analysis of the abatement system inventories presented in Appendix A, we propose 

the following process to establish a site specific DRE for a given process category and gas/gas 

group combination:

1. Over a two year period, perform DRE testing on 10% of the abatement system inventory 

each year (20% of the total) to establish a site-specific DRE for the given process 

category and gas/gas group. 

2. For every three year period thereafter, test 15% of the installed abatement system 

inventory to validate or affirm the site-specific DRE. 

3. The site-specific DRE used for reporting under the MRR will be calculated initially as the 

average of the first two years of testing and thereafter as the average DRE of the most 

recent DRE data set representing 30% of the abatement system inventory. 

C.2 Application of the Site-Specific DRE Process

To demonstrate how the proposed sampling approach will work, we have prepared two examples 

of circumstances where additional testing might be done to establish alternative DREs for 

individual facilities. The first example shows testing intended to improve on a relatively low 

DRE, while the second example shows testing intended to improve on a relatively high DRE. 

The calculations represent the statistics for testing 15% of relevant devices in each 3 year period,

once the baseline period has been completed. A larger number of tests (20% of the devices 

tested) would be performed in the initial 2-year baseline period. Because the size of the 

abatement device population will vary by facility, the calculations consider a range from low to 

high that has been developed from the device inventories discussed previously.

Table C-1 summarizes the results for the two examples. The table shows the amount of testing

that would be required under the proposed approach and the statistical precision achieved in

estimating the average DREs. The expected values characterizing the device population being 

tested (average DRE and its standard deviation) are taken from the SIA database where the 

devices performed well. Because the required samples exceed 10% of the device populations in 

all cases, a finite population correction2is applied to account for the reduction in the estimated 

uncertainty when the number of devices tested becomes an appreciable fraction of the total 

 

2

 This well-known correction reduces the variance by a factor of (N-n)/(N-1) , where N is the population size and n 

is the sample size to account for the fact that the sampling remove the uncertainty for a fraction f = n/N of the 

population. 
Page 13 of 34 January 4, 2012

population being studied. Based on the reduced variance, a one-sided 95% confidence interval is 

then computed for comparison with the proposed default DRE that would otherwise be 

applicable. This confidence interval is one in which there is only a 5% chance that the actual 

DRE would be smaller than the lower confidence limit.

Example 1 considers the testing that would be needed to establish an alternative DRE for CF4 

abatement in the etch process where the company believes that the actual DRE is 80% versus the 

default of 60%. The expected standard deviation is taken from the standard deviation for the 

CF4 abatement tests in which devices performed well, but has been adjusted upward from 7.5% 

to 10% to make the example more conservative. Based on the inventories provided in Appendix 

A, facilities may have anywhere from 6 to 41 devices abating CF4 emissions from the etch 

process, and the proposed sampling approach would require that 3 to 6 devices be tested in each 

facility. At the low end of the range, a minimum of 3 tests would be performed, which amounts 

to testing one-half of the abatement devices in the facility. These sample sizes would be 

sufficient to establish the actual average DRE to precisions of ±13% in the low case and ±8% in 

the high case. This level of precision would be sufficient to demonstrate, with 95% confidence, 

that the actual average DRE exceeds the proposed default value of 60% for CF4 abatement.

Example 2 considers the testing that would be needed to establish an alternative DRE for NF3

abatement in the in-situ plasma chamber cleaning process, in a circumstance where the company 

believed that the devices installed actually achieved 95% abatement instead of the 90% default 

that is proposed for chamber cleaning. The expected average DRE and its standard deviation are

values taken from a subset of the SIA database. Based on the inventories, facilities may have 

anywhere from 24 to 58 devices abating NF3 emissions from in-situ cleaning, and the proposed 

sampling approach would require that 4 to 9 devices be tested in each facility. These sample 

sizes would be sufficient to establish the actual average DRE to precisions of ±5% in the low 

case and ±3% in the high case. As in the first example, this level of precision would be

sufficient to demonstrate, with 95% confidence, that the actual average DRE exceeds the 

proposed default value of 90% for NF3 abatement in chamber cleaning.

The two examples bracket the range of circumstances in which testing is likely to be used to 

establish site-specific DREs. In both cases, the testing required by the proposed sampling 

approach is sufficient to characterize the average DRE with a good level of precision and to 

demonstrate with high statistical confidence the appropriateness of establishing an alternative 

DRE. We conclude that the proposed sampling approach offers both a level of precision that is

fully satisfactory for a reporting rule and a reasonable balance between acceptable precision and 

the testing burden (discussed in Section D).
Page 14 of 34 January 4, 2012

Table C-1. Examples of Testing to Establish Alternative DREs

at the Facility Level

Example 1 Example 2

Scenario

CF4 DRE

Etch Process

NF3 DRE

In-Situ Plasma

Chamber Cleaning

Proposed Default DRE 60% 90%

Expected Values for Device Population

Average DRE 80% 95%

Std Deviation of DRE 10% 5%

Low High Low High

Size of Device Population 6 41 24 58

Number of Units to be Tested

(15% of Population) 3 6 4 9

Finite Population Correction for Variancea/ 0.600 0.875 0.870 0.860

t-statistic (95% confidence, one-sided) 2.92 2.02 2.35 1.86

± DRE Confidence Interval 13% 8% 5% 3%

DRE Lower Confidence Limit 67% 72% 90% 92%

Notes: a/ Multiplicative factor to correct observed variance in sample to estimate of 

population variance.

D. Analysis of Costs and Benefits

The current MRR requirements for abatement DRE testing to permit facilities to use accurate, 

site-specific DRE numbers are very costly. For the facility that performed 57 abatement system 

DRE tests in 2011, the testing cost was $5-6 K per unit, and three units could be tested in a week. 

The total testing cost was $285 K and the testing took 19 weeks of time. In addition, it required 

one full time equivalent (FTE) person from the manufacturing and facility engineering team to 

monitor and manage the testing, and it caused a loss of one day’s production on the tool on 

which the abatement unit was being tested for a total of 57 days of lost production time. 

Extending these costs to the testing requirements for the nine fabs detailed in Table A-1, the 

annual cost of testing to the MRR rule would be $2.3 M to $2.7 M, require 150 weeks of testing 

time with 9 FTEs of support time, and cause a loss of 450 days of tool production time with the 

associated risks of loss of additional production time or unexpected disruption that often occurs 

when performing atypical operations in the manufacturing area. This is an inordinately large 

expense to get an accurate representation of the emissions reductions that companies achieve 
Page 15 of 34 January 4, 2012

through their investment in abatement units. EPA has consistently stressed the importance of 

getting accurate emissions estimate reporting through the MRR; the stated desire for accuracy 

cannot be satisfied using the 60% default DRE for all abatement units.

SIA’s proposed alternative significantly reduces the cost impacts of using more accurate 

abatement system DRE values. The proposed industry level DREs for the abatement of all etch 

process F-gases excluding CF4 and NF3 based chamber cleans enable companies to provide 

more accurate emissions estimates at no additional costs. Where a company wants to improve 

the DRE value due to the site-specific abatement system installations, SIA’s proposed testing

protocol for site-specific DREs reduces testing costs to $30 K to $60 K per year with a 

drastically reduced personnel commitment and disruption risk while generating a statistically 

sound, site-specific, category based DRE. 

E. Calculation of Abatement System Uptime

E.1: Alternate Equation for the Calculation of Abatement Uptime 

In subpart I, the percentage of abatement system uptime is calculated by equation I-15:

up = tp/Tp where:

up: the uptime of the abatement system p expressed as a decimal fraction. 

tp : the total time the abatement system is in operational mode when fluorinated GHGs or N2O 

are flowing through production tool(s) connected to abatement system p.

Tp: The total time in which fluorinated GHGs or N2O are flowing through the production tool(s) 

connected to abatement system p.

p: Abatement system.

The requirements for this equation create two difficulties:

1. Unless the production tools are interlocked with the abatement systems, such that the 

production tool stops flowing F-gas or N2O gases when the abatement unit stops functioning, 

facilities do not have a methodology to track and match abatement system operation to the 

points in time when GHG or N2O gases are flowing to the tool. While tools may have these 

interlocks at a given facility, it is unlikely that all tools will be set-up with interlocks as it is 

better to run some processes to completion before idling the tool.

2. Most facilities do not currently have the data collection and management capability to track 

the time that F-gas or N2O gas is flowing through a tool. 

Hence, in many instances, manufacturers cannot collect the data required to perform this 

calculation. Hardware and/or software would need to be installed to both collect data on when 

gas is flowing to the tool and to identify if the abatement is or is not operational while the gas 

flow is occurring. This will require significant investment and effort, when there are alternative 

calculation approaches available that can utilize data currently available at facilities today and 

which provide a more conservative estimate of uptime than the subpart equation I-15 for the 
Page 16 of 34 January 4, 2012

typical operating conditions in the fabricator where the abatement unit is operational for a high 

percentage of the time that the production tool(s) are operational; 75% or greater at all facilities 

for which data was available and at many of these facilities uptime was greater than 95%.

In a previous communication to EPA, SIA proposed the following simplification to equation I15. EPA acknowledged the applicability of this approach to the calculation of abatement system 

uptime in Section 3: BAMM Implementation Examples in the document “Additional Guidance 

About Requests for the Use of Best Available Monitoring Methods (BAMM) beyond 2011 

(subpart I: Electronics Manufacturing)” published by EPA in September 2011.

In the proposed uptime calculation method, TP is replaced with the number of minutes in a year 

(525,600) or for the measurement period; tp is replaced with tpd – the abatement system 

downtime as tracked by facility reporting systems, and equation 15 is modified to:

up = 1 – tpd/525,600 where:

up : the uptime of the abatement system p expressed as a decimal fraction

tpd : the total time, in minutes, that the abatement system is not operational for the reporting year.

p : Abatement system.

E.2: Existing Fab Uptime Data

SIA was able to get abatement unit specific uptime data for two fabs from different companies 

and an average uptime assessment and example data for abatement unit uptime for two fabs from 

a third company. The data from the four fabs enable SIA to validate that the typically operating 

uptime for abatement units exceeds the 40% threshold at which the sample calculations for the 

proposed uptime calculation becomes less conservative than Subpart I Eq. I-153. 

The data provided also demonstrates the different methods used to track abatement uptime and 

also the different configurations between abatement systems and their associated tools. 

However, all abatement systems operations are consistently tracked. The collected data 

facilitates a conservative estimate of abatement system downtime to capture the potential for 

increased GHG emissions during maintenance operations. 

 

Company E, Fab 1 has 150 abatement devices installed on etch and CVD tools. All the devices 

are combustion devices, most with integral scrubbers, and they are manufactured by MfrZ. The 

facility has 6 models installed. In Fab 1 all of the manufacturing tools are interlocked with their 

abatement systems; this approach is not used across the industry.

Abatement system uptime for this fab was calculated by taking the number of scrubber 

maintenance orders per each installed unit over a six month period and assuming 4 hours of 

 

3

SIA submitted two documents, “SIA submission to EPA on two issues June 2011” and “Calculation of Abatement 

System Uptime” which provided sample calculations of abatement system uptime for different conditions using the 

proposed equation.
Page 17 of 34 January 4, 2012

downtime for each incident. The 4 hour downtime average was determined based on Company 

E’s experience with their abatement devices. The average abatement uptime was above 95%. 

The number of abatement system work orders by abatement unit and the individual abatement 

unit uptime results are provided in the file “Fac A 6 Months of Abatement System Uptime 

Calc.xls” provided to EPA in a previous communication. The uptime calculations are 

conservative, as once the abatement device goes down at this facility the tool gas flow is stopped. 

Company E does not track the actual time that the abatement unit and its associated equipment is 

off-line when an abatement unit failure occurs so it is necessary to use an estimate of downtime 

to provide the uptime estimate. 

Company C, Fab 1 collected abatement system downtime for unscheduled maintenance for 56 

units in one of their fabs. The data was provided in a previous communication in the spreadsheet 

file “POU DRE 2010.xlsx” which is included with this transmittal. This file shows the percent 

uptime per month, calculated by subtracting the number of hours of downtime from the total 

number of hours in the month and dividing that result by the total number of hours in the month. 

Uptime percentages are also calculated by tool and for two twelve month periods. There are 

several relevant observations that can be made based on the data provided in the spreadsheet.

1. While individual months may have uptimes of less than 95%, the overall uptime average for 

most equipment exceeds 95% on an annual basis. 

2. Grouping of the uptime information by relevant equipment or process type provides 

representative data and can simplify the data collection and reporting.

Company D collected abatement uptime for two 200 mm fabs. These fabs have a maintenance 

data collection system which tracks abatement uptime and scheduled and unscheduled downtime. 

The operating information is collected through work orders that are generated based on the 

information gathered by the maintenance team during maintenance rounds. One fab with 20 

abatement units show an average uptime of greater than 95% while the other with 41 abatement 

units show an average uptime of approximately 74%. The lower uptime of the second fab is 

primarily due to an abnormal period with much older abatement units going through a 

concentrated series of maintenance activities. The uptime and maintenance information for each 

unit is presented in a dashboard format. Examples of the dashboard metrics are provided in the 

spreadsheet file “Company C 200mm Abatement Uptime” submitted to EPA in a previous 

communication. The spreadsheet presents the overall metrics for each fab and some examples of

uptime performance for individual combustion abatement devices. Each abatement unit has its 

own individual report. Examples are provided because the system does not allow the easy export 

of data into a spreadsheet format. 

While the overall abatement unit uptime for one of the example fabs is below the 95%, the 

average uptime is well above the 40% at which the sample calculations (SIA provided to EPA in 

their June transmittal), showing that the proposed equation provided a more conservative 

estimate of uptime than the current Subpart I equation I-15. 

The proposed uptime equation to calculate abatement system uptime using the total measurement 

time period (525,600 minutes in a year) as the divisor against the abatement system downtime is 

the best equation to use to calculate and measure abatement system uptime. It has several 

benefits:
Page 18 of 34 January 4, 2012

1. It enables companies to track operating parameters that they already track for operational 

purposes: measured abatement system downtime or abatement system work orders.

2. The equation, as constructed, calculates the effect of the abatement system on the 

emissions as if that gas is flowing the total time the abatement system is down. This 

would not be the case on an operating tool as gas flow is intermittent. For the purposes of 

calculating the facility emissions, this abatement system uptime calculation provides a 

conservative estimate of emissions both in terms of uptime calculated with the current 

Subpart I equation and with regards to the total volume of gas flow treated through the 

abatement unit. 

The equation allows companies to use abatement system downtime collected through their 

existing maintenance management systems and report a representative abatement system uptime 

value without having to track tool operational time or the time is gas flowing to the tool; 

parameters which are either not or not easily available from current manufacturing control 

systems. The examples of the abatement uptime system calculation from the representative fabs 

provide a working example of how the data would be managed. It is important that EPA allows 

facilities flexibility for calculating abatement system downtime hours, as different fabs manage 

and track their maintenance activities in different ways as depicted by the three examples 

provided. 

In addition, based on the work done to prepare this example, SIA recommends that EPA allow 

companies to calculate abatement system uptime by the process categories in which F-gas use 

and emissions are reported. This will allow companies to easily match abatement uptime to the 

reported F-gas use and emissions estimates calculations. Allowing this type of grouping avoids 

the serious difficulty in apportioning gas usage at an individual tool level, as noted by SIA in its 

petition for reconsideration and its continuing dialogue with EPA on modifications to the 

Subpart I rule. It is important to allow abatement system uptimes to be matched to the use 

categories to minimize the reporting burden associated with applying abatement DREs to the 

emissions estimates.

III. Alternate Reporting Requirements for Maintenance Data:

SIA is also proposing to reduce the data submittal on abatement system testing and O&M data

as required in section 98.96(n) to (q). As written, sections (n) and (o) require reporting of 

apportioning of gas use and estimation of the fraction of gases destroyed even where the facility 

is not applying the DRE to the estimated F-gas and N2O emissions. These requirements compel

facilities with abatement systems to submit hundreds or thousands of pages of documents to 

EPA. These submittals offer no value to EPA or to SIA members.

Sections (n) and (o) should be combined with section (q), required only when the facility is 

applying abatement system DRE to the gas use to reduce estimated emissions, and the records 

should be maintained at the facility for inspection, not submitted to EPA each year. The portion 

of section (p) requiring identification of the manufacturing equipment and gases abated by each 

unit should also be maintained at the facility. 
Page 19 of 34 January 4, 2012

For annual reporting to EPA, SIA proposes the following approach to managing abatement 

system test and O&M data.

1. A report of the abatement systems groupings, the number of abatement units in each 

group, the number of tests required to be done for each group over the specified testing 

period, the number of tests done to date by year in the specified testing period, the DREs 

of the individual units tested in each grouping, the average DRE of those tests completed 

in that reporting year, and the average DRE for the category that is being used to report 

emissions (reflecting the first two years of testing or the most recent 30% of the testing 

results.). This requirement would replace the requirements in sections 98.96 (n) to (q) for 

reporting to EPA

2. A certification, signed by the designated facility manager, that the abatement units are 

being installed and maintained in accordance with the facility O&M plan, which is based 

on the manufacturer’s recommended installation and O&M plan requirements. 

3. As discussed above, all other data, including abatement system test reports, installation 

certification records, equipment with abatement and abated gases, and O&M records, will 

be maintained at the facility and available for inspection by EPA. They will not be 

submitted to EPA on an annual basis.
Page 20 of 34 January 4, 2012

APPENDIX A: ABATEMENT SYSTEM INVENTORIES BY COMPANY

Table I- Company A - POU Abatement Device Testing Requirements

# of Required % of 

MFR Model Gases Treated Devices Tests/yr* Total

MfrX Model A CF4, CHF3, NF3, SF6 14 3

MfrX Model A CH2F2, CHF3, CF4, C4F8 14 3

MfrX Model A NF3 46 9

MfrX Model A C2F2, CHF2,CH3F, CF4, C3F8, C4F6, C4F8, C5F8 10 3

MfrX Model A C4F6, C4F8, CF4, CH2F2, CHF3, CH3F 5 3

MfrX Model A NF3 4 3

MfrX Model A CHF3, C4F6, C4F8, CF4 2 2

MfrX Model A CF4, CH2F2, CH3F, CHF3 16 4

MfrX Model F C4F6, C4F8, CF4, CH2F2, 13 3

MfrX Model F C4F6, CF4, C5F8, CH3F, CHF3 6 3

MfrX Model F NF3 33 7

MfrX Model D CH2F2, CH3F, CF4, C4F8, CHF3, C3F8, C4F6, C5F10 2 2

MfrX Model D C4F6, C4F8, CF4, CH2F2, CH3F 8 3

MfrX Model D C4F6, C3F8, CF4, CH2F2, CH3F 9 3

MfrX Model D CH2F2, CH3F, CF4, CHF3, C3F8, C4F6, C5F8 7 3

MfrX Model B NF3 8 3

MfrX Model B CH2F2, CHF2, CHF3, CF4, C3F8, C4F6, C4F8, C5F10 1 1

MfrX Model B CHF3, C4F6, C4F8, CF4 1 1

MfrX Model B C4F6, C4F8, CF4, CH2F2, CH3F 2 2

MfrX Model B NF3 7 3

MfrX Model C NF3 23 5

MfrX Model E NF3 46 9

MfrY Model A CF4, CHF3, NF3, SF6 14 3

MfrY Model A CF4, CHF3 4 3

MfrY Model A CF4, CH3F, CHF3, NF3, SF6 16 4
Page 21 of 34 January 4, 2012

MfrY Model A CHF3 5 3

MfrY Model B NF3, SF6 6 3

MfrY Model B NF3 46 9

MfrY Model C C4F8, CH2F2, CHF3, CF4, NF3, SF6 12 3

MfrY Model C CF4, SF6 2 2

MfrY Model C C4F8, CH2F2, CH3F, CHF3, CF4, NF3, SF6 11 3

MfrY Model C NF3 12 3

MfrY Model C CF4, CHF3, CH3F, NF3, SF6 15 3

MfrY Model C CF4, CHF3, CH3F, NF3, SF6, CH2F2 1 1

MfrY Model C CF4, SF6 2 2

MfrY Model C CF4, CHF3, SF6 5 3

MfrY Model C C4F6, C4F8, CF4, CH2F2, CHF3, CHF3 5 3

MfrY Model C CF4, CH3F, CHF3, NF3, SF6 11 3

MfrY Model D NF3 16 4

MfrW Model A CF4, CH3F 2 2

Grand Total 462 135 29

* Note: based on definition in MRR of "Class" as combination of mfr., model and gas treated
Page 22 of 34 January 4, 2012

Table II - Company B - POU Abatement Device Testing Requirements

# of Required % of

MFR Model Gases Treated Devices Tests/yr* Total

MfrZ Etch Model H CF4, SF6 6 3

MfrZ Etch Model H CF4, CHF3, CH3F, NF3, SF6 4 3

MfrZ Etch Model H CF4, CH2F2, CHF3, CH3F, NF3, SF6 6 3

MfrZ Etch Model H C4F6, CF4, CH3F, CH2F2, CHF3, NF3, SF6 5 3

MfrZ Etch Model H C4F6, C4F8, CF4, CH2F2, CHF3 1 1

MfrZ Etch Model H CF4 1 1

MfrZ Etch Model H C4F6, C4F8, C5F8, CF4, CH3F, CH2F2, CHF3 4 3

MfrZ Etch Model H C4F8, CF4, CH3F, CH2F2, CHF3, NF3 4 3

MfrZ Etch Model H CF4, CH3F, CH2F2, CHF3, SF6 1 1

MfrZ Etch Model H C4F6, C4F8, CF4, CH3F, CH2F2, CHF3 14 3

MfrZ Etch Model H C4F6, C4F8, CF4, CH2F2, CHF3 8 3

MfrZ Etch Model H C4F8, CF4, CH2F2, CHF3, NF3 8 3

MfrZ Etch Model H CF4, CH2F2, CHF3 2 2

MfrZ Etch Model H CF4, CH2F2, CHF3, NF3 6 3

MfrZ Etch Model H C4F6, C4F8, CF4, CH2F2, CH3F, CHF3 1 1

MfrZ Etch Model H CF4, CH2F2, CH3F, CHF3, NF3 1 1

MfrZ Etch Model H CF4, CH2F2, CH3F, NF3, SF6 6 3

MfrZ CVD Model J NF3 49 10

MfrZ CVD Model I NF3 18 4

MfrZ CVD Model N NF3 14 3

MfrZ CVD Model H NF3 6 3

MfrZ CVD Model D NF3 2 2

167 62 37%

* Note: based on definition in MRR of "Class" as combination of mfr., model and gas treated

Table III - Company C - POU Abatement Device Testing 

Requirements
Page 23 of 34 January 4, 2012

# of Required % of

MFR Model Gases Treated Devices Tests/yr* Total

Fab A

MfrZ Model G CF4, SF6 2 2 100%

Fab B

MfrZ Model H CHF3, SF6, CF4 26 5

MfrZ Model I NF3 36 8

MfrZ Model D NF3 30 6

MfrZ Model J NF3 24 5

MfrV Model A NF3 (from diffusion) 7 3

MfrT Model A NF3 (from diffusion) 19 4

MfrT Model B NF3, CHF3, CF4 11 3

MfrT Model B NF3 4 3

157 37 23

Fab C

MfrZ Model G CHF3, SF6, CF4 26 6

MfrZ Model D NF3 8 3

MfrZ Model I NF3 48 9

MfrZ Model A NF3 33 7

MfrZ Model J NF3 25 5

MfrV Model A NF3 16 4

MfrT Model A NF3 9 3

MfrT Model B NF3, CHF3, CF4 19 4

MfrT Model B NF3 6 3

190 44 23

Fab E

MfrZ Model H CHF3, SF6, CF4 9 3

MfrZ Model D NF3 3 3

MfrZ Model I NF3 17 4

MfrZ Model A NF3 13 3
Page 24 of 34 January 4, 2012

MfrZ Kronis NF3 11 3

MfrV Model A NF3 6 3

MfrT Model A NF3 3 3

MfrT Model B NF3, CHF3, CF4 6 3

MfrT Model B NF3 6 3

74 28 37

* Note: based on definition in MRR of "Class" as combination of mfr., model and gas treated
Page 25 of 34 January 4, 2012

Table IV - Company D - POU Abatement Device Testing Requirements

200mm Fabs # of Required % of 

MFR Model Gases Treated Devices Tests/yr* Total

MfrZ Model A NF3 3 3

MfrZ Model D C2F6 2 2

MfrZ Model D C2F6 4 3

MfrZ Model B NF3 5 3

MfrZ Model D CO2, N2O, C2F6 2 2

MfrZ Model D NF3, C2F6 2 2

MfrZ Model G NF3, CF4, N2O 2 2

MfrZ Model D N2O, NF3 5 3

MfrZ Model D C2F6, N2O 3 3

MfrZ Model A N2O 1 1

MfrZ Model A NF3 10 3

MfrZ Model A SF6 2 2

MfrZ Model A CHF3, CF4, SF6 2 2

MfrZ Model A C4F8, CO, SF6 5 3

MfrZ Model A NF3, CF4, CH3F, CHF3, SF6 2 2

MfrZ Model A N2O, C2F6 4 3

MfrZ Model A NF3, CF4, N2O 4 3

MfrZ Model A C2F6, NF3, CF4 2 2

MfrZ Model A C2F6, NF3 7 3

MfrZ Model A N2O, NF3 1 1

MfrZ Model A C4F8, SF6 1 1

MfrZ Model A C2F2, C4F8, SF6, CHF3 1 1

MfrZ Model A NF3, N2O, SF6 1 1

MfrZ Model I NF3, N2O 3 3

MfrZ Model I NF3 3 3

MfrZ Model N C2F6 1 1

78 58 74
Page 26 of 34 January 4, 2012

300mm Fab

MfrZ Model G CHF3 / SF6 / CF4 3 3

MfrZ Model C NF3 23 5

MfrZ Model J NF3 2 2

MfrZ Model J NF3 2 2

MfrZ Model I NF3 9 3

MfrZ Model I CHF3 / SF6 / CF4 1 1

MfrZ Model N NF3 2 2

42 18 42

* Note: based on definition in MRR of "Class" as combination of mfr., model and gas treated
Page 27 of 34 January 4, 2012

Table V - Company E - POU Abatement Device Testing Requirements

# of Required* % of 

MFR Model Gases Treated Devices Tests/yr Total

MfrZ Model I NF3, N2O 16 4

MfrZ Model I N2O 1 1

MfrZ Model I NF3 4 3

MfrZ Model F CF4, CHF3 3 3

MfrZ Model C NF3 11 3

MfrZ Model C NF3, N2O 14 3

MfrZ Model F CF4, CHF3 1 1

MfrZ Model F CF4, CHF3 1 1

MfrZ Model F C4F6, C4F8, CF4,CH2F2, CHF3, SF6 1 1

MfrZ Model F C4F8, CF4,CH2F2, CHF3, SF6 1 1

MfrZ Model F C4F6, C4F8, CF4,CH2F2, CH3F, CHF3, NF3 5 3

MfrZ

Model F C5F8, C4F6, C4F8, CF4,CH2F2, CH3F, CHF3, 

NF3 1 1

MfrZ Model F CF4 15 3

MfrZ Model F C4F6, C4F8, CF4, CH2F2, CHF3 2 2

MfrZ Model F C4F8, CF4, CH2F2, CHF3 13 3

MfrZ Model F C4F8, CF4, CHF3 3 3

MfrZ Model F C4F6, C4F8, CF4, CH2F2, CHF3, CHF3, NF3 1 1

MfrZ Model C CHF3 4 3

MfrZ Model F

C5F8, C4F6, C4F8, CF4,CH2F2, CH3F, CHF3, 

NF3 2 2

MfrZ Model F CF4,CH2F2, CHF3, SF6 1 1

MfrZ Model F C5F8, CF4, CH2F2, CHF3, NF3 1 1

MfrZ Model F C4F8, CF4, CH2F2, CHF3, SF6 1 1

MfrZ Model H NF3 7 3

MfrZ Model H NF3, N2O 1 1

MfrZ Model H N2O 1 1

MfrZ Model H

C4F6, C4F8, CF4, CH2F2, CHF3, CHF3,CH3F, 

1 1
Page 28 of 34 January 4, 2012

NF3

MfrZ Model H CH2F2, CHF3 1 1

MfrZ Model H CF4, CH2F2, CHF3, SF6 1 1

MfrZ Model J NF3, N2O 5 3

MfrZ Model J NF3 5 3

MfrZ Model O N2O 1 1

MfrZ Model O NF3, N2O 1 1

MfrZ Model O CF4, CH2F2, CHF3, SF6 3 3

MfrZ Model O CF4, NF3 2 2

MfrZ Model O C4F6, CF4, CH2F2, CHF3 1 1

MfrZ Model N NF3 3 3

Total 135 70 51

* Note: based on definition in MRR of "Class" as combination of mfr., model and gas treated
Page 29 of 34 January 4, 2012

APPENDIX B: ABATEMENT SYSTEM DRE TEST DATA

Table VI: Etch Abatement Systems Measured DREs

Line 

Number Test Date

MfrZ 

Model 

C

MfrZ 

Model 

H

MfrZ

Model 

O

MfrT 

Model B

Date of 

Installation Comments

Device 

Age 

Yrs

USEPA 

Test 

Method

POU Input 

Gas DRE

1 9/7/2011 X 9/13/2004 7.0 1 YES CF4 42.49

2 9/7/2011 X 9/13/2004 7.0 1 YES CH2F2 99.51

3 9/7/2011 X 9/13/2004 7.0 1 YES CHF3 99.67

4 9/7/2011 X 9/13/2004 7.0 1 YES SF6 99.71

5 4/28/2011 X 7/3/2007 3.8 1 YES CF4 39.66

6 9/8/2011 X 7/3/2007 Retest 4.2 1 YES CF4 67.25

7 9/8/2011 X 7/3/2007 Retest 4.2 1 YES CH2F2 99.10

8 9/8/2011 X 7/3/2007 Retest 4.2 1 YES CHF3 99.55

9 9/8/2011 X 7/3/2007 Retest 4.2 1 YES SF6 99.31

10 4/13/2011 X 3/14/2007 4.1 1 YES CF4 49.01

11 4/13/2011 X 3/14/2007 4.1 1 YES C4F8 99.43

12 4/13/2011 X 3/14/2007 4.1 1 YES CH2F2 99.39

13 4/13/2011 X 3/14/2007 4.1 1 YES CHF3 99.42

14 4/13/2011 X 3/14/2007 4.1 1 YES NF3 99.34

15 9/15/2011 X 3/14/2007 Retest 4.5 1 YES CF4 47.26

16 9/15/2011 X 3/14/2007 Retest 4.5 1 YES CH2F2 96.65

17 9/15/2011 X 3/14/2007 Retest 4.5 1 YES C4F6 99.28

18 9/15/2011 X 3/14/2007 Retest 4.5 1 YES C4F8 99.01

19 9/15/2011 X 3/14/2007 Retest 4.5 1 YES CHF3 99.44

20 9/15/2011 X 3/14/2007 Retest 4.5 1 YES NF3 99.25

21 4/21/2011 X 3/28/2007 4.1 1 YES CF4 0.00

22 4/21/2011 X 3/28/2007 4.1 1 YES C4F8 97.76

23 4/21/2011 X 3/28/2007 4.1 1 YES CH2F2 99.12

24 4/21/2011 X 3/28/2007 4.1 1 YES CHF3 98.90
Page 30 of 34 January 4, 2012

25 4/21/2011X 3/28/20074.11 YES NF3 98.37

26 9/29/2011X 3/28/2007 Retest 4.51 YES CF4 94.50

27 9/29/2011X 3/28/2007 Retest 4.51 YES C4F6 98.81

28 9/29/2011X 3/28/2007 Retest 4.51 YES C4F8 98.53

29 9/29/2011X 3/28/2007 Retest 4.51 YES CH2F2 98.78

30 9/29/2011X 3/28/2007 Retest 4.51 YES CHF3 98.98

31 9/29/2011X 3/28/2007 Retest 4.51 YES NF3 98.87

32 5/26/2011X 9/12/2007 3.71 YES CF4 98.39

33 5/26/2011X 9/12/2007 3.71 YES C4F8 98.82

34 5/26/2011X 9/12/2007 3.71 YES CH2F2 98.99

35 5/26/2011X 9/12/2007 3.71 YES CHF3 99.85

36 5/26/2011X 9/12/2007 3.71 YES NF3 98.97

37 8/2/2011X 10/6/2004 6.81 YES CF4 67.96

38 5/26/2011X 1/25/2010 1.31 YES CF4 95.58

39 5/26/2011X 1/25/2010 1.31 YES NF3 99.56

40 9/15/2011X 11/4/2002 8.91 NO CF4 31.00

41 9/15/2011X 11/4/2002 8.91 NO C4F8 99.57

42 9/15/2011X 11/4/2002 8.91 NO CH2F2 99.40

43 9/15/2011X 11/4/2002 8.91 NO CHF399.81

44 9/15/2011X 11/4/2002 8.91 NO NF3 99.82

45 9/15/2011X 11/4/2002 8.91 NO CF4 48.20

46 9/15/2011X 11/4/2002 8.91 NO C4F8 99.54

47 9/15/2011X 11/4/2002 8.91 NO CH2F2 99.49

48 9/15/2011X 11/4/2002 8.91 NO CHF3 99.75

49 9/15/2011X 11/4/2002 8.91 NO NF3 99.78

50 8/25/2011X 7/17/2003 8.11 NO CF4 0.00

51 8/25/2011X 7/17/2003 8.11 NO C4F8 99.16

52 8/25/2011X 7/17/2003 8.11 NO CH2F2 99.18

53 8/25/2011X 7/17/2003 8.11 NO CHF3 99.71

54 8/25/2011X 7/17/2003 8.11 NO NF3 99.18

55 8/25/2011X 7/17/2003 8.11 NO CF4 0.00

56 8/25/2011X 7/17/2003 8.11 NO C4F8 99.24

57 8/25/2011X 7/17/2003 8.11 NO CH2F2 99.13

58 8/25/2011X 7/17/2003 8.11 NO CHF3 99.72
Page 31 of 34 January 4, 2012

59 8/25/2011X 7/17/2003 8.11 NO NF3 99.78

60 8/18/2011X 3/18/2003 8.41 NO CF4 28.67

61 8/18/2011X 3/18/2003 8.41 NO C4F8 99.48

62 8/18/2011X 3/18/2003 8.41 NO CH2F2 99.62

63 8/18/2011X 3/18/2003 8.41 NO CHF3 99.65

64 8/18/2011X 3/18/2003 8.41 NO NF3 99.36

65 8/18/2011X 3/18/2003 8.41 NO C4F6 99.41

66 8/18/2011X 3/18/2003 8.41 NO CF4 14.95

67 8/18/2011X 3/18/2003 8.41NO CH2F2 98.97

68 8/18/2011X 3/18/2003 8.41 NO C4F8 98.40

69 8/18/2011X 3/18/2003 8.41 NO CHF3 99.69

70 8/18/2011X 3/18/2003 8.41 NO NF3 99.38

71 8/18/2011X 3/18/2003 8.41 NO C4F6 99.01

72 4/26/2011X 12/5/2006 4.41 YES CF4 97.07

73 4/26/2011X 12/5/2006 4.41 YES C4F8 97.49

74 4/26/2011X 12/5/2006 4.41 YES CH2F2 97.98

75 4/26/2011X 12/5/2006 4.41 YES CHF3 99.48

76 9/16/2011X 6/2/2010 1.31 YES CF4 95.13

77 9/16/2011X 6/2/2010 1.31 YES C4F8 98.34

78 9/16/2011X 6/2/2010 1.31 YES CHF3 99.38

79 9/19/2011X 5/12/2010 1.41 YES CF4 76.06

80 9/19/2011X 5/12/2010 1.41 YES C4F6 98.78

81 9/19/2011X 5/12/2010 1.41 YES C4F8 99.14

82 9/19/2011X 5/12/2010 1.41 YES CH2F2 99.07

83 9/19/2011X 5/12/2010 1.41 YES CHF3 99.22

84 9/19/2011X 5/12/2010 1.41 YES SF6 99.09

85 9/22/2011X 1/15/2008 3.71 YES CF4 4.09

86 9/22/2011X 1/15/2008 3.71 YES CH2F2 98.67

87 9/22/2011X 1/15/2008 3.71 YES CHF3 99.60

88 9/22/2011X 1/15/2008 3.71 YES SF6 98.44

89 9/22/2011X 1/15/2008 3.71 YES NF3 98.42

90 1/13/2009X 10/23/2008 0.2 2* YES CF4 90.60

91 1/13/2009X 10/23/2008 0.2 2* YES CHF3 92.90

92 12/14/2010X tbd 2* YES CF4 84.00
Page 32 of 34 January 4, 2012

93 12/14/2010 X tbd 2* YES C2F6 99.00

94 12/14/2010 X tbd 2* YES CHF3 99.70

95 7/14/2011 X tbd 2* YES CF4 82.00

96 7/14/2011 X tbd 2* YES NF3 99.70
Page 33 of 34 January 4, 2012

Table VII: Chamber Clean Abatement Measured DREs

Chamber Cleaning Abatement Unit Type

Line 

Number Test Date In-Situ Plasma

Remote 

Plasma

Thermal 

Clean

MfrZ 

Model 

I

MfrZ 

Model 

C

MfrZ 

Model 

J

MfrZ 

Model 

J

MfrZ 

Model 

H

MfrZ 

Model 

D

MfrZ 

Model 

N

Date of 

Installation Comments Device Age Yrs

EPA DRE 

Test 

Method

Input 

Gas DRE

1 8/30/2011 X X X 6/4/2010 Low Fire 1.2 1 NF3 98.93

2 8/16/2011 X X 2/20/2002 Low Fire 9.5 1 NF3 72.32

3 8/16/2011 X X 2/20/2002 Low Fire 9.5 1 NF3 79.46

4 8/23/2011 X X 4/14/2003 Low Fire 8.4 1 NF3 78.54

5 8/23/2011 X X 4/14/2003 Low Fire 8.4 1 NF3 74.85

6 8/23/2011 X X 4/14/2003 Low Fire 8.4 1 NF3 96.95

7 6/8/2011 X X 5/4/2010 High Fire 1.1 1 NF3 97.37

8 9/14/2011 X X 2/11/2008 Low Fire 3.6 1 NF3 83.10

9 6/7/2011 X X 10/15/2008 High Fire 2.6 1 NF3 96.05

10 5/18/2011 X X 1/7/2003 Low Fire 8.4 1 NF3 85.52

11 8/16/2011 X X 2/13/2003 Low Fire 8.5 1 NF3 91.12

12 7/26/2011 X X 3/19/2008 Low Fire 3.4 1 NF3 99.77

13 5/12/2011 X X 5/16/2002 Low Fire 9.0 1 NF3 49.55

14 9/7/2011 X X 5/16/2002 Low Fire Retest 9.3 1 NF3 63.36

15 8/4/2011 X X 6/27/2007 High Fire 4.1 1 NF3 99.97

16 6/15/2011 X X 3/7/2003 High Fire 8.3 1 NF3 99.95

17 6/15/2011 X X 3/7/2003 High Fire 8.3 1 NF3 99.95

18 5/4/2011 X X 10/5/2004 High Fire 6.6 1 NF3 99.94

19 6/14/2011 X X 7/2/2002 Low Fire 9.0 1 NF3 99.98

20 4/28/2011 X X 5/3/2007 Low Fire 4.0 1 NF3 84.07

21 8/24/2011 X X 6/27/2007 Low Fire 4.2 1 NF3 84.07

22 5/19/2011 X X 6/24/2003 Low Fire 7.9 1 NF3 99.85

23 8/9/2011 X X 3/10/2003 Low Fire 8.4 1 NF3 84.93

24 5/24/2011 X X 6/27/2007 High Fire 3.9 1 NF3 100.00

25 7/26/2011 X X 11/2/2010 High Fire 0.7 1 NF3 99.90

26 5/24/2004 X X 12/16/2002 1.4 2* NF3 85.33
Page 34 of 34 January 4, 2012

27 10/21/2010 X X 11/19/2007 2.9 2* NF3 91.38

28 4/5/2011 X X 6/7/2010 High Fire 0.8 1 NF3 99.96

29 8/30/2011 X X 12/12/2002 Low Fire 8.7 1 NF3 92.09

30 5/5/2011 X X 7/17/2007 Low Fire 3.8 1 NF3 79.51

30.5 7/27/2011 X X 7/2/2002 Low Fire 9.1 1 NF3 50.51

31 9/19/2011 X X 7/2/2002 Low Fire 9.2 1 NF3 76.07

32 9/19/2011 X X 7/2/2002 Low Fire 9.2 1 NF3 85.44

33 9/27/2011 X X 7/2/2002 Low Fire 9.2 1 NF3 35.83

34 9/28/2011 X X 7/2/2002 Retest Low Fire 9.2 1 NF3 82.02

35 5/11/2011 X X 4/4/2002 Low Fire 9.1 1 NF3 94.08

36 5/10/2011 X X 4/7/2003 Low Fire 8.1 1 NF3 84.60

37 5/17/2011 X X 3/26/2003 Low Fire 8.1 1 NF3 87.20

38 9/13/2011 X X 2/5/2009 Low Fire 2.6 1 NF3 99.94

39 7/13/2004 X X 12/24/2002 1.6 2* NF3 94.60

40 7/9/2004 X X 4/28/2004 0.2 2* NF3 99.99

41 2/8/2005 X X 11/6/2004 0.3 2* NF3 99.90

42 3/20/2006 X X 9/1/2005 0.5 2* NF3 96.86

43 7/3/2008 X X 11/20/2006 1.6 2* NF3 99.70

44 2/15/2008 X X 6/11/2007 0.7 2* NF3 93.00

45 4/29/2008 X X 3/3/2006 2.2 2* NF3 100.00

46 10/15/2009 X X 1/21/2009 0.7 2* NF3 99.83

47 10/19/2010 X X 5/19/2006 4.4 2* NF3 100.00

48 10/19/2010 X X 2/26/2007 3.6 2* NF3 99.71