Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse Gases 

Source Category of the Greenhouse Gas Reporting Rule 

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ICR WORKSHEET CHANGE 

Greenhouse Gas Reporting Program: Final Amendments and Confidentiality Determinations for Subpart I

OVERVIEW

In October 2009, EPA finalized the Mandatory Reporting of Greenhouse Gases Rule (the GHG Reporting Rule) (7

30, 2009). The 2009 final rule includes reporting of GHGs from certain facilities and suppliers. Although EPA proposed Grequirements for subpart I, Electronics Manufacturing, on April 10, 2009 (74 FR 16448), it did not include subpart I in the EPA re-proposed the data reporting requirements on April 12, 2010 (75 FR 18652) and finalized the data reporting requiremfour other source categories of fluorinated GHGs (subparts L, DD, QQ, and SS) on December 1, 2010 (75 FR 74774). 

This ICR change worksheet affects facilities currently subject to subpart I, i.e., electronics manufacturing facilities 

greater than 25,000 metric tons of CO2e per year, in combination, from electronics manufacturing processes (such as plasm

deposition, chamber cleaning, and heat transfer fluid use) and all other applicable source categories in Part 98. EPA origin

and burden for the recordkeeping and reporting requirements associated with this subpart in the Information Collection Req

Mandatory Reporting of Greenhouse Gases, Additional Sources of Fluorinated GHGs – Final Rule (EPA ICR number 2373

number 2060-0650). Subsequently, in 2012, the ICR for the Greenhouse Gas Reporting Program (GHGRP) was renewed to 

ongoing information collection burden (EPA ICR number 2300.10, OMB control number 2060-0629), incorporating 2060-

EPA is now finalizing specific provisions related to subpart I that revise certain calculation methods and add a new 

method, amend data reporting requirements, clarify terms and definitions, make technical corrections, provide confidentiali

the new and revised data elements, amend subpart A to reflect changes to the reporting requirements of subpart I, and remo

was applicable for limited time periods that is now no longer applicable. These changes result in an overall reduction in infburden. 

EPA is finalizing these amendments to (1) modify calculation methods and data requirements to better reflect new 

current practice; (2) provide additional calculation methods to allow individual facilities to choose the method best suited fprovide flexibility in implementation to balance the burden associated with existing requirements; and (4) address sensitive 

concerns raised by industry, while ensuring that reporters continue to provide EPA with reliable facility-specific GHG data

amendments ensure that EPA receives high quality and current facility-specific data and allow EPA to accurately characteremissions from the electronics manufacturing industry. 

EPA is finalizing the following reporting requirement and recordkeeping requirement amendments in the subpart I 
Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse Gases 

Source Category of the Greenhouse Gas Reporting Rule 

2

Table 1: Changes to Reporting Requirements 

Data Element Change/Revision Original Citation New or Revised Citation 

Annual manufacturing capacity of facility as determined in Equation I-5. 

Revised to report manufacturing capacity on a fab basis, rather than facility. 

98.96(a) NA 

The diameter of wafers manufactured at the facility. 

Revised to report wafer size on a fab basis, rather than facility.

98.96(b) NA 

Annual emissions of each F-GHG emitted from each process type for which your facility is required to calculate emissions as calculated in Equations I-6 and I-7. 

Revised to apply only when default gas utilization rate and by-product formation rate procedures in 40 CFR 98.93(a) are used to calculate emissions. Revised so that requirement applies to “fab” instead of facility. 

98.96(c)(1) NA 

Annual emissions of each F-GHG emitted from each individual recipe (including those in a set of similar recipes) or process sub-type. 

Removed requirement to report emissions by individual recipe (including those in a set of similar recipes). 

98.96(c)(2) NA 

Emissions of N2O emitted from each chemical vapor deposition process and from other N2O 

using manufacturing processes as calculated in Equation I-10. 

Revised to clarify that facilities report N2O 

emitted from the aggregate of all chemical vapor deposition processes and from the aggregate of all other N2O-using 

manufacturing processes. Revised so that requirement applies to “fab” instead of facility. 

98.96(c)(3) NA 

Annual emissions of each F-GHG emitted from each stack system when you use the procedures specified in 40 CFR 98.93(i). 

Added reporting requirement in conjunction with the optional stack testing method. 

NA 98.96(c)(5) 

Data elements reported when you use factors for F-GHG process utilization and by-product formation rates other than the defaults provided in Tables I–3, I–4, I–5, I–6, and I–7 to this subpart and/or N2O utilization factors other than 

the defaults provided in Table I–8 to subpart I. 

Removed and reserve all of 98.96(f) because of changes to remove the use of recipespecific gas utilization rates and by-product formation rates. 

98.96(f) NA 

Annual gas consumption for each F-GHG and N2O as calculated in Equation I–11 of this 

subpart, including where your facility used less than 50 kg of a particular F-GHG or N2O during 

the reporting year. For all F-GHGs and N2O used 

at your facility for which you have not calculated emissions using Equations I–6, I–7, I–8, I–9, and I–10, the chemical name of the GHG used, the 

Changed to recordkeeping requirement. Revised so that requirement applies to “fab” instead of facility. Added applicable equation references for the optional stack testing method. 

98.96(g) 98.97(k) 
Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse Gases 

Source Category of the Greenhouse Gas Reporting Rule 

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Data Element Change/Revision Original Citation New or Revised Citation 

annual consumption of the gas, and a brief description of its use. All inputs used to calculate gas consumption in Equation I-11 for each F-GHG and N2O used. 

Changed to recordkeeping requirement. 98.96(h) 98.97(k)(1) 

Disbursements for each F-GHG and N2O during 

the reporting year, as calculated using Equation I12. 

Changed to recordkeeping requirement. 98.96(i) 98.97(n) 

All inputs used to calculate disbursements for each F-GHG and N2O used in Equation I–12 

including all facility-wide gas-specific heel factors used for each F-GHG and N2O. 

Changed to recordkeeping requirement. 98.96(j) 98.97(n) 

Annual amount of each F-GHG consumed for each recipe, process sub-type, or process type, as appropriate, and the annual amount of N2O 

consumed for each chemical vapor deposition and other electronics manufacturing production processes, as calculated using Equation I–13. 

Changed to recordkeeping requirement. Removed “recipe-specific” requirements. Revised to read “...annual amount of N2O 

consumed for the aggregate of all CVD processes and from the aggregate of all other electronics manufacturing production processes...” 

98.96(k) 98.97(m) 

All apportioning factors used to apportion FGHG and N2O consumption. Changed to recordkeeping requirement. 98.96(l) 98.97(c)(1) Identification of the quantifiable metric used in your facility-specific engineering model to apportion gas consumption. 

Correct citation and revised to indicate whether direct measurements is used. 

98.96(m)(i) 98.96(m)(1) 

Start and end dates selected under 40 CFR 98.94(c)(2)(i). 

Corrected citation. 98.96(m)(ii) 98.96(m)(2) 

Certification that the gases you selected under 40 CFR 98.94(c)(2)(ii) correspond to the largest quantities consumed on a mass basis, at your facility in the reporting year for the plasma etching process type and the chamber cleaning process type. 

Corrected citation. 98.96(m)(iii) 98.96(m)(3) 

The result of the calculation comparing the actual and modeled gas consumption under 40 CFR 98.94(c)(2)(iii). 

Corrected citation and revised to read “...modeled gas consumption under §98.94(c)(2)(iii) and (iv), as applicable.” 

98.96(m)(iv) 98.96(m)(4) 

If you are required to apportion F-GHG consumption between fabs, certification that the gases you selected under 40 CFR 98.94(c)(2)(ii) correspond to the largest quantities consumed on a mass basis, of F-GHG used at your facility during the reporting year for which you are required to apportion. 

Added requirement. NA 98.96(m)(5) 
Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse Gases 

Source Category of the Greenhouse Gas Reporting Rule 

4

Data Element Change/Revision Original Citation New or Revised Citation 

Fraction of each F-GHG or N2O fed into recipe, 

process sub-type, or process type that is fed into tools connected to abatement systems. 

Moved to recordkeeping, and removed recipe-specific references. 

98.96(n) 98.97(o) 

Fraction of each F-GHG or N2O destroyed or 

removed in abatement systems connected to process tools where recipe, process sub-type, or process type j is used, as well as all inputs and calculations used to determine the inputs for Equation I-14. 

Moved to recordkeeping, removed recipespecific references, and revised to also apply to the optional stack testing method. 

98.96(o) 98.97(p) 

Inventory and description of all abatement systems through which F-GHGs or N2O flow at 

your facility, including the number of systems of each manufacturer, model numbers, manufacturer claimed F-GHG and N2O destruction or removal 

efficiencies, if any, and records of destruction or removal efficiency measurements over their inuse lives. The inventory of abatement systems must describe the tools with model numbers and the recipe(s), process sub-type, or process type for which these systems treat exhaust. 

Revised the inventory to include only those systems for which the facility is claiming FGHG or N2O destruction or removal. Revised to report only (1) the number of devices controlling emissions for each process type, for each gas used in that process for which control credit is being taken; and (2) the basis of the DRE being used (default or site specific testing) for each process type and for each gas. Revised to not require reporting the model number of the tools associated with each abatement system, and to remove the recipespecific references. 

98.96(p) NA 

Certification that each abatement system is installed, maintained, and operated according to manufacturer specifications. All inputs to abatement system uptime calculations, the default or measured DRE used for each abatement system, and the description of the calculations and inputs used to calculate class averages for measured DRE values. 

The certification is revised to include that all systems are installed, maintained, and operated according to the site maintenance plan for abatement systems. All inputs to abatement system uptime 

calculations, the default or measured DRE used for each abatement system, and the description of the calculations and inputs used to calculate class averages for measured DRE values moved to recordkeeping in 98.97(d). In place of reporting the information and data on uptime and DRE calculations for 

98.96(q) 98.97(d) 
Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse Gases 

Source Category of the Greenhouse Gas Reporting Rule 

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Data Element Change/Revision Original Citation New or Revised Citation 

abatement systems, the reporter must calculate and report an effective fab-wide DRE, as required in 98.96(r). 

Inputs to the F-HTF mass balance equation, Equation I-16, for each F-HTF 

Changed to recordkeeping. 98.96(r) 98.97(r) 

An effective fab-wide DRE calculated using Equation I-26, I-27, and I-28, as appropriate. 

Added requirement NA 98.96(r) 

Estimates of missing data where missing data procedures were used to estimate inputs into the F-HTF mass balance equation under 40 CFR 98.95(b). 

Changed to recordkeeping. 98.96(s) 98.97(s) 

A brief description of each “best available monitoring method” used according to 40 CFR 98.94(a), the parameter measured or estimated using the method, and the time period during which the “best available monitoring method” was used. 

Removed the reporting requirement because the BAMM provisions in 98.94(a) will be obsolete at the time these amendments are final. 

98.96(t) NA 

For reporting year 2012 only, the date on which you began monitoring emissions of F-HTF whose vapor pressure falls below 1 mm of Hg absolute at 25 degrees C. 

Removed the requirement because these provisions will be obsolete at the time these 

amendments are final. 

98.96(v) NA 

The date of any stack testing conducted during the reporting year, and the identity of the stack tested. 

Added requirement in conjunction with optional stack testing method. 

NA 98.96(w)(1) 

An inventory of all stacks from which process FGHG are emitted. For each stack system, indicated whether the stack is among those for which stack testing was performed as per 40 CFR 98.3(i)(3) or not performed per 40 CFR 98.93(i)(2). 

Added requirement in conjunction with optional stack testing method. 

NA 98.96(w)(2) 

If emissions reported under 40 CFR 98.96(c) include emissions from research and development activities, the approximate percentage of total GHG emissions that are attributable to research and development activities. 

Added requirement. NA 98.96(x) 

If your semiconductor manufacturing facility emits more than 40,000 mtCO2e, a triennial technology assessment report that includes information such as how gases and technologies have changed, the effect on emissions of the implementation of new process technologies, and 

Added requirement. NA 98.96(y) 
Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse Gases 

Source Category of the Greenhouse Gas Reporting Rule 

6

Data Element Change/Revision Original Citation New or Revised Citation 

default utilization and by-product formation rates collected in the previous 3 years. 

Additionally, EPA proposed confidential business information determinations for subpart I on February 22, 2012 (

finalized them on August 13, 2012 (77 FR 48072). The EPA also proposed confidentiality determinations for the new and the proposed amendments on October 16, 2012 (77FR 63538) and will finalize them in the same action as the final rule am

The EPA made two key changes in these amendments that reduce the burden on facilities. These changes are the ad

as an optional emission monitoring method (i.e., creating a choice of two calculation methods) and the removal of the requ

facilities to determine and use recipe-specific gas utilization rates and by-product formation rates. Specifically, the rule wofor reporters to either (1) use default gas utilization rates and by-product formation rates, which have been revised to reflec

provided to the EPA, or (2) conduct stack testing to establish site-specific emission factors for fluorinated GHGs that woul

fluorinated GHG emissions. Overall, these changes would reduce industry reporting burden. 

 EPA’s cost analysis estimates that for the minimum reporting under the final subpart I amendments, the total burde

for the private sector is a reduction of approximately 17,661 hours and $4,551,316 per year. The overall burden reduction 

adjustment and a program change. The adjustment is related to EPA’s revised estimate of the number of reporters (using th2012 reporters), and the program change reflects the reduction in burden associated with the final regulatory changes. For t

burden calculation, EPA has assumed that facilities will choose to use default gas utilization rates. While the option to con

like be more costly overall than the option to use default gas utilization rates, EPA notes all reporters have the option to use thus has based its estimates on the less burdensome option. 

CONCLUSION  EPA has reviewed the technical amendments covered in this final rule and determined that there is a reduction in b

reporters. These changes provide additional flexibility in choosing calculation methodologies and move many reporting rerecordkeeping, and, therefore, reduce the burden on facilities. The final rule requires reporters to submit reports starting in 

cover the 2014 reporting year) with these amendments.