## 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 (N 2 

## O) emissions from semiconductor

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

expected DREs for F

- gas es , which can range from 7 0% to 99% depending on the abatement

system and the F

- gas

. Under the rule, i f a sem iconductor 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. Thi s 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 vo luntary 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 manufactur ers

. Based on the analysis of this data, SIA is prop osing 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 dat a 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 th at 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 an d the industry with more accurate

emissions estimates for the facilities that employ abatement system s to reduce F

- gas emissions.

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

overly burdensome. In rej ecting 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 t o 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 P OU

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 asse ss how many devices would have

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

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

grouping abatement units . The MRR requ ires 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 t he 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 faciliti es.

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 annua lly 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 hav e to be tested based on different group ings 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

e a ch 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

catego ry

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

, P erfluorinated

Compounds (P FC s) 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 tes ted 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 7 8 42 135 1307

Grouping Used to D etermine

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 2 0 % annual testing requirement while fabs with

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

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

testing requirements approach es 20% annual testing for many, but not all, fabs

.

Table A

- 2

- Percent of Total Inventory Requiring Ann ual 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

, M fr X

, M fr Y

, MfrW

, M fr T and MfrV )

supplied the POU GHG abatement devices to the five companie s. Of these MfrZ

, M fr X , and

M fr Y 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 destruct ion/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. A ll 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

c

C4F8O 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 val ue 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

aba tement devices. The data is pr ovided 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 Mod el 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 d efault 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 compile d and analyzed a large data set on the population and performance of F

gas 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 sectio n

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 categor ization 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 bey ond what is statistically required to accurately characterize DREs for the

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

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

abatement d evices requires hundreds of thousands of dollars of annual expense for testing and

significant disruption to fab operations (see section D).

In section s 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 g as or gas groups, supports modified

industry

- wide DREs for 4 process/ gas or gas group categories, and proposes a s implified,

s ampling

- based method to develop and validate site

- specific DREs where needed

.

B.1 Statistical Analysis of Abatement Device Performance

Summary of DRE Results

A batement system DRE testing data from two device manufacturers ha ve been combined to

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

cleaning. The database contains a total of 14 5 tests covering 7 different input gases and four

EPA process categories 1 

## . In this count, a test consists of a specifi c 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 we re 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. T he 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 disass ociate 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 5 4

. 5 % ± 7. 5 % (one

- sigma standard error). The 60% default DRE in the

EPA rule is contained within the ± one

- sigma error limits of th e 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 DRE s 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 t hese 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 c leaning 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=7 3 tests, including 14 to 20 tests

for four of the six gases.

In chamber cleaning, a total of 4 9 tests ha ve been performed for NF3. The avera ge DRE is

estimated to be 88.7 % ± 3. 7 % (one

- sigma) for in

- situ plasma cleaning and 88.4% ± 2.6% (one

sigma) for remote plasma cleaning. Only one test is available for thermal cleaning; while no

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

Comb ining the data for all three processes results in an o verall 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 stati stically significant diff erence in the average DRE by sub process,

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 r evised, 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 ± 0.1 3

CHF3 19 99.18 ± 0.3 6

CH2F2 16 98. 94 ± 0. 19

Al l Etch (Excluding CF4) NF3/Other 73 99.0 7 ± 0.1 3

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 4 9 88.7 ± 2. 1



## Discussi on 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 . T he 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 o ther gases, with lower performance levels for CF4.

Among devices commonly used in chamber cleaning abatement, manufacturer device

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

NF3 and related etch gases an d 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 t o 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/ a bove 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 t o achieve better CF4 DRE s . 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

( horizo ntal 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 lev el (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. A batement DRE for NF3 in chamber cleaning does

not decline with age for devices of a given type ; w e expec t the same result for NF3 and related

gases in etch and also for CF4.

Figure B

- 1 . Chamber

- Clean NF3 Abatement DRE s 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 approp riate 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 B

1 and we propos e a repre sentative 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 12 6 te sts conducted in 2011 by one c ompany using EPA Method 1

and 19 tests conducted between 2003 and 2011 by a second c ompany 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 , e xcluding CF4 results

, there is a

- 1.3% difference for the four tests

conducted using the EPA Method 2 equivalent. T hree 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 effe ct of tes t 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 b e 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 concl ude 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 t he

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 t han CF4) can be placed into three

groups based on the typical DRE specification for MfrZ abateme nt 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 proces ses, 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

Alt hough C 2 F 6 is a major gas used for chamber cleaning in 200 mm and C3F8 is also used in a

limited number of applications , t he 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, c ompanies

that use these gases in chamber cleaning will hav e 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 N 2 

## O.

## Page 10 of 34 January 4, 2012 Table B

- 2. Proposed Default DREs

Process Gas Default

DRE Basis

Plas ma 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/



### N 2 

### O

All Processes N 2 

### O 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/ 

### Aver age 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 specification s 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 site

spec ific 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 (detail ed by SIA/ISMI in a separate briefing paper delivered to EPA o n 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 managi ng

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 sim plif ied 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. Metho dology 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 bas ed 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. O ther 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 represe nts different vintages of abatement systems . It

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

equipment manufacturers have learn ed 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, F igure B

- 1 did illustrate that the older units had a generally a lower

av erage 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 c ategory and gas or gas group

can improve over the proposed defaults. In those cas es, 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 an d 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 give n 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 ever y 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 calculat ed 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 wher e 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 device s 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 summarize s the results for the two examples. The table show s the amount of testing

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

estimat ing the average DRE s . The expected values characterizing the device population b eing

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

devices performed well

. Because the required sample s exceed 10% of the device populations in

all cases, a finite population correction 2 

## is applied to account fo r 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 t he 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 t he 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 es tablish 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 dev ices 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 , f acilities may hav e anywhere from 6 to 41 devices abating CF4 emissions from the etch

process, and t he 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 siz es 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 dem onstrate, with 95% confidence,

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

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

abatement in the in

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

believed that the devices insta lled actually achieve d 95% abatement instead of the 90% default

that is proposed for chamber cleaning

. T he expected average DRE and its standard deviation are

values taken from a subset of the SIA database

. Based on the inventories, facilities may have

a nywhere 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 preci sions 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 cha mber 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 w ith a good level of precision and to

demonstrate with high statistical confidence the appropriateness of establishing an alternative

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

fully satisfactory for a rep orting 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 DRE s

at the Facility Level

Example 1 Example 2

Scenario CF4 DRE

Etch Process N F3 DRE

In

- Situ Plasma

Chamber Cleaning

Proposed Default D RE 60% 90%

Expected Values for Device Population

Average DRE 80% 95%

Std Deviation of DRE 1 0% 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 Variance a/ 

### 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 Low er Confidence Limit 67% 72% 90% 92%

Notes: a/ 

### Multiplicative facto r 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 facilit ies 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 aba tement 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 week s 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 manufa cturing 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 emission s 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 valu e due to the site

- specific abatement system installations, SIA ’s proposed testing

protocol for site

- specific DRE s reduces testing costs to $30 K to $60 K per year with a

drastically reduced personnel commitment and disruption risk while generating a statis tically

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:

u p 

## = t p 

## / T

p 

## where:

u p 

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

t p 

## : 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.

T

p 

## : 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 N 2 

## O 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 N 2 

## O 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 h ave the data collection and management capability to track

the time that F

- gas or N 2 

## O 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 ne ed 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

calculati on 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 simplif ication to equation I

15. 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 th e 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, T P 

## is replaced with the n umber of minutes in a year

(525,6 00) or for the me asurement period; t

p 

## is replaced with t pd



## – the abatement system

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

u p 

## = 1

– t pd 

## /525,600 where:

u p 

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

t p d 

## : 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 v alidate that the typically operating

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

proposed uptime calculation become s less conservative than Subpart I Eq. I

- 15 3



## .

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

also the different configurations between abatement system s 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 o perations.

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 mon th period and assuming 4 hours of

3 

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

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 dev ice goes down at this facility the too l 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

t o 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 inc luded 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 per centages 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 av erage 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 tw o 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 t he 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

primaril y 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 prov ided in the

spreadsheet file “C ompany 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. Eac h 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 t he 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 ), show ing that the proposed equation provided a more conservative

estimate of uptime than the current Subpart I equation I

- 15

.

The proposed up time 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 ha s 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 abatem ent 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 u ptime 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 u se 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 ar e 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 w orking example of how the data w ould be managed. It is important that EPA allo ws

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 e xample, 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

S ubpart 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 gase s destroyed even where the facility

is not applying the DRE to the estimated F

- gas and N2O emissions. T he se 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 i nspection, 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 followi ng 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 t ests 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

emission s (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, a ll 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

M fr X Model A CF4, CHF3, NF3, SF6 14 3

MfrX Model A CH2F2, CHF3, CF4, C4F8 1 4 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, C HF3 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 Mod el 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, C 4F8, CF4, CH2F2, CH3F 2 2

MfrX Model B NF3 7 3

MfrX Model C NF3 23 5

MfrX Model E NF3 46 9

M fr Y 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

Mfr W Mode l A CF4, CH3F 2 2

Grand Total 462 135 29

* Note: based on defin i tion 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 Require d % 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, CH2 F2, 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 Mo del 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

Requirem ents

## 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 M odel J NF3 24 5

MfrV Model A NF3 (from diffusion) 7 3

Mfr T Model A NF3 (from diffusion) 19 4

M fr T Model B NF3, CHF3, CF4 11 3

M fr T 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

M fr T Model A NF3 9 3

M fr T Model B NF3, CHF3, CF4 19 4

M fr T Model B NF3 6 3

190 44 23

Fab E

MfrZ Model H CHF3, SF6, CF4 9 3

M frZ 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

M fr T Model A NF3 3 3

M fr T Model B NF3, CHF3, CF4 6 3

M fr T Model B NF3 6 3

74 28 37

* Note: based on defini tion 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

Mfr Z 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

Mf rZ 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

* N ote: based on defin i tion 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 Mode l 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 DR Es

Line

Number Test Date MfrZ

Model

C MfrZ

Model

H Mfr Z

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 CH2 F2 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 Retes t 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 4/13/2 011 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 99.2 5

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 4/21/2011 X 3/28/2007 4 .1 1 YES NF3 98.37

26 9/29/2011 X 3/28/2007 Retest 4.5 1 YES CF4 94.50

27 9/29/2011 X 3/28/2007 Retest 4.5 1 YES C4F6 98.81

28 9/29/2011 X 3/28/2007 Retest 4.5 1 YES C4F8 98.53

29 9/29/2011 X 3/28/2007 Retest 4.5 1 YES CH2F2 98. 78

30 9/29/2011 X 3/28/2007 Retest 4.5 1 YES CHF3 98.98

31 9/29/2011 X 3/28/2007 Retest 4.5 1 YES NF3 98.87

32 5/26/2011 X 9/12/2007 3.7 1 YES CF4 98.39

33 5/26/2011 X 9/12/2007 3.7 1 YES C4F8 98.82

34 5/26/2011 X 9/1 2/2007 3.7 1 YES CH2F2 98.99

35 5/26/2011 X 9/12/2007 3.7 1 YES CHF3 99.85

36 5/26/2011 X 9/12/2007 3.7 1 YES NF3 98.97

37 8/2/2011 X 10/6/2004 6.8 1 YES CF4 67.96

38 5/26/2011 X 1/25/2010 1.3 1 YES CF4 95.58

39 5/26/ 2011 X 1/25/2010 1.3 1 YES NF3 99.56

40 9/15/2011 X 11/4/2002 8.9 1 NO CF4 31.00

41 9/15/2011 X 11/4/2002 8.9 1 NO C4F8 99.57

42 9/15/2011 X 11/4/2002 8.9 1 NO CH2F2 99.40

43 9/15/2011 X 11/4/2002 8.9 1 NO CHF3 9 9.81

44 9/15/2011 X 11/4/2002 8.9 1 NO NF3 99.82

45 9/15/2011 X 11/4/2002 8.9 1 NO CF4 48.20

46 9/15/2011 X 11/4/2002 8.9 1 NO C4F8 99.54

47 9/15/2011 X 11/4/2002 8.9 1 NO CH2F2 99.49

48 9/15/2011 X 11/4/2002 8. 9 1 NO CHF3 99.75

49 9/15/2011 X 11/4/2002 8.9 1 NO NF3 99.78

50 8/25/2011 X 7/17/2003 8.1 1 NO CF4 0.00

51 8/25/2011 X 7/17/2003 8.1 1 NO C4F8 99.16

52 8/25/2011 X 7/17/2003 8.1 1 NO CH2F2 99.18

53 8/25/2011 X 7/ 17/2003 8.1 1 NO CHF3 99.71

54 8/25/2011 X 7/17/2003 8.1 1 NO NF3 99.18

55 8/25/2011 X 7/17/2003 8.1 1 NO CF4 0.00

56 8/25/2011 X 7/17/2003 8.1 1 NO C4F8 99.24

57 8/25/2011 X 7/17/2003 8.1 1 NO CH2F2 99.13

58 8/25/201 1 X 7/17/2003 8.1 1 NO CHF3 99.72

## Page 31 of 34 January 4, 2012

59 8/25/2011 X 7/17/2003 8.1 1 NO NF3 99.78

60 8/18/2011 X 3/18/2003 8.4 1 NO CF4 28.67

61 8/18/2011 X 3/18/2003 8.4 1 NO C4F8 99.48

62 8/18/2011 X 3/18/2003 8.4 1 NO CH2F2 99.62

63 8/18/2011 X 3/18/2003 8.4 1 NO CHF3 99.65

64 8/18/2011 X 3/18/2003 8.4 1 NO NF3 99.36

65 8/18/2011 X 3/18/2003 8.4 1 NO C4F6 99.41

66 8/18/2011 X 3/18/2003 8.4 1 NO CF4 14.95

67 8/18/2011 X 3/18/2003 8.4 1 N O CH2F2 98.97

68 8/18/2011 X 3/18/2003 8.4 1 NO C4F8 98.40

69 8/18/2011 X 3/18/2003 8.4 1 NO CHF3 99.69

70 8/18/2011 X 3/18/2003 8.4 1 NO NF3 99.38

71 8/18/2011 X 3/18/2003 8.4 1 NO C4F6 99.01

72 4/26/2011 X 12/5/ 2006 4.4 1 YES CF4 97.07

73 4/26/2011 X 12/5/2006 4.4 1 YES C4F8 97.49

74 4/26/2011 X 12/5/2006 4.4 1 YES CH2F2 97.98

75 4/26/2011 X 12/5/2006 4.4 1 YES CHF3 99.48

76 9/16/2011 X 6/2/2010 1.3 1 YES CF4 95.13

77 9/16/2 011 X 6/2/2010 1.3 1 YES C4F8 98.34

78 9/16/2011 X 6/2/2010 1.3 1 YES CHF3 99.38

79 9/19/2011 X 5/12/2010 1.4 1 YES CF4 76.06

80 9/19/2011 X 5/12/2010 1.4 1 YES C4F6 98.78

81 9/19/2011 X 5/12/2010 1.4 1 YES C4F8 99.14

82 9/19/2011 X 5/12/2010 1.4 1 YES CH2F2 99.07

83 9/19/2011 X 5/12/2010 1.4 1 YES CHF3 99.22

84 9/19/2011 X 5/12/2010 1.4 1 YES SF6 99.09

85 9/22/2011 X 1/15/2008 3.7 1 YES CF4 4.09

86 9/22/2011 X 1/15/2008 3.7 1 YES CH2F2 98.67

87 9/22/2011 X 1/15/2008 3.7 1 YES CHF3 99.60

88 9/22/2011 X 1/15/2008 3.7 1 YES SF6 98.44

89 9/22/2011 X 1/15/2008 3.7 1 YES NF3 98.42

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

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

92 12/14/2010 X 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 NF 3 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 F ire 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 99.9 5

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 F ire 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 H igh 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 L ow F ire 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 11/2 0/2006 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