Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse GasesSource Category of the Greenhouse Gas Reporting Rule1ICRWORKSHEETCHANGEGreenhouse Gas Reporting Program: Final Amendments and Confidentiality Determinations for Subpart IOVERVIEWIn October 2009, EPA finalized the Mandatory Reporting of Greenhouse Gases Rule (the GHG Reporting Rule) (74 FR 56260; October30, 2009). The 2009 final rule includes reporting of GHGs from certain facilities and suppliers. Although EPA proposed GHG reportingrequirements for subpart I, Electronics Manufacturing, on April10, 2009 (74 FR 16448), it did not include subpart I in the 2009 final rule. Instead,EPA re-proposed the data reporting requirements on April 12, 2010 (75 FR 18652) and finalized the data reporting requirements for subpart I andfour other source categories of fluorinated GHGs (subpartsL, 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 that emit equal to orgreater than 25,000 metric tons of CO2e per year, in combination, from electronics manufacturing processes (such as plasma etching, thin filmdeposition, chamber cleaning, and heat transfer fluid use) and all other applicable source categories in Part 98. EPA originally addressed the costand burden for the recordkeeping and reporting requirements associated with this subpart in the Information Collection Request(ICR) for theMandatory Reporting of Greenhouse Gases, Additional Sources of Fluorinated GHGs – Final Rule (EPA ICR number 2373.05; OMB controlnumber 2060-0650). Subsequently, in 2012, the ICR for the GreenhouseGas Reporting Program (GHGRP) was renewed to reflect all of theongoing information collection burden (EPA ICR number 2300.10,OMB control number 2060-0629), incorporating 2060-0650.EPA is now finalizing specific provisions related to subpart I that revise certain calculation methods and add a new optional calculationmethod, amend data reporting requirements,clarify terms and definitions, make technical corrections, provide confidentiality determinationsforthe new and revised data elements, amend subpart A to reflect changes to the reporting requirementsof subpart I, and remove rule language thatwas applicable for limited time periods that is now no longerapplicable. These changes result in an overall reduction in information collectionburden.EPA is finalizing these amendments to (1) modify calculation methods and data requirements to better reflect new industry dataandcurrent practice; (2) provide additional calculation methods toallow individual facilities to choose the method best suited for their operations; (3)provide flexibility in implementation to balance the burden associated with existing requirements; and (4) address sensitive business informationconcerns raised by industry, while ensuring that reporters continue to provide EPAwith reliable facility-specific GHG data. Additionally, theamendments ensure that EPA receives high quality and current facility-specific data and allow EPA to accurately characterize and analyze GHGemissions from the electronics manufacturing industry.EPA is finalizing the following reporting requirement and recordkeeping requirement amendments in the subpart I rule:Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse GasesSource Category of the Greenhouse Gas Reporting Rule2Table 1: Changes to Reporting RequirementsData Element Change/RevisionOriginalCitationNew orRevisedCitationAnnual manufacturing capacity of facility asdetermined in Equation I-5.Revised to report manufacturing capacity ona fab basis, rather than facility.98.96(a) NAThe diameter of wafers manufactured at thefacility.Revised to report wafersize on a fab basis,rather than facility.98.96(b) NAAnnual emissions of each F-GHG emitted fromeach process type for which your facility isrequired to calculate emissions as calculated inEquations I-6 and I-7.Revised to apply only when default gasutilization rate and by-product formation rateprocedures in 40 CFR 98.93(a) are used tocalculate emissions. Revised so thatrequirement applies to “fab” instead offacility.98.96(c)(1) NAAnnual emissions of each F-GHG emitted fromeach individual recipe (including those in a set ofsimilar recipes) or process sub-type.Removed requirement to report emissions byindividual recipe (including those in a set ofsimilar recipes).98.96(c)(2) NAEmissions of N2O emitted from each chemicalvapor deposition process and from other N2Ousing manufacturing processes as calculated inEquation I-10.Revised to clarify that facilities report N2Oemitted from the aggregate of all chemicalvapor deposition processes and from theaggregate of all other N2O-usingmanufacturing processes. Revised so thatrequirement applies to “fab” instead offacility.98.96(c)(3) NAAnnual emissions of each F-GHG emitted fromeach stack system when you use the proceduresspecified in 40 CFR 98.93(i).Added reporting requirement in conjunctionwith the optional stack testing method.NA 98.96(c)(5)Data elements reported when you use factors forF-GHG process utilization and by-productformation rates other than the defaults providedin Tables I–3, I–4, I–5, I–6, and I–7 to thissubpart and/or N2O utilization factors other thanthe defaults provided in Table I–8 to subpart I.Removed and reserve all of 98.96(f) becauseof changes to remove the use of recipespecific gas utilization rates and by-productformation rates.98.96(f) NAAnnual gas consumption for each F-GHG andN2O as calculated in Equation I–11 of thissubpart, including where your facility used lessthan 50 kg of a particular F-GHG or N2O duringthe reporting year. For all F-GHGs and N2O usedat your facility for which you have not calculatedemissions using Equations I–6, I–7, I–8, I–9, andI–10, the chemical name of the GHG used, theChanged to recordkeeping requirement.Revised so that requirement applies to “fab”instead of facility. Added applicableequation references for the optional stacktesting method.98.96(g) 98.97(k)Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse GasesSource Category of the Greenhouse Gas Reporting Rule3Data Element Change/RevisionOriginalCitationNew orRevisedCitationannual consumption of the gas, and a briefdescription of its use.All inputs used to calculate gas consumption inEquation 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 duringthe reporting year, as calculated using Equation I12.Changed to recordkeeping requirement. 98.96(i) 98.97(n)All inputs used to calculate disbursements foreach F-GHG and N2O used in Equation I–12including all facility-wide gas-specific heelfactors used for each F-GHG and N2O.Changed to recordkeeping requirement. 98.96(j) 98.97(n)Annual amount of eachF-GHG consumed foreach recipe, process sub-type, or process type, asappropriate, and the annual amount of N2Oconsumed for each chemical vapor deposition andother electronics manufacturing productionprocesses, as calculated using Equation I–13.Changed to recordkeeping requirement.Removed “recipe-specific” requirements.Revised to read “...annual amount of N2Oconsumed for the aggregate of all CVDprocesses and from the aggregate of all otherelectronics manufacturing productionprocesses...”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 inyour facility-specificengineering model toapportion gas consumption.Correct citation and revised to indicatewhether direct measurements is used.98.96(m)(i) 98.96(m)(1)Start and end dates selected under 40 CFR98.94(c)(2)(i).Corrected citation. 98.96(m)(ii) 98.96(m)(2)Certification that the gases you selected under 40CFR 98.94(c)(2)(ii) correspond to the largestquantities consumed on amass basis, at yourfacility in the reporting year for the plasmaetching process type and the chamber cleaningprocess type.Corrected citation. 98.96(m)(iii) 98.96(m)(3)The result of the calculation comparing the actualand modeled gas consumption under 40 CFR98.94(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-GHGconsumption between fabs, certification that thegases you selected under 40 CFR 98.94(c)(2)(ii)correspond to the largestquantities consumed ona mass basis, of F-GHG used at your facilityduring the reporting year for which you arerequired to apportion.Added requirement. NA 98.96(m)(5)Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse GasesSource Category of the Greenhouse Gas Reporting Rule4Data Element Change/RevisionOriginalCitationNew orRevisedCitationFraction of each F-GHG or N2O fed into recipe,process sub-type, or process type that is fed intotools connected to abatement systems.Moved to recordkeeping, and removedrecipe-specific references.98.96(n) 98.97(o)Fraction of each F-GHG or N2O destroyed orremoved in abatement systems connected toprocess tools where recipe, process sub-type, orprocess type j is used, as well as all inputs andcalculations used to determine the inputs forEquation I-14.Moved to recordkeeping, removed recipespecific references, and revised to also applyto the optional stack testing method.98.96(o) 98.97(p)Inventory and description of all abatementsystems through which F-GHGs or N2O flow atyour facility, including the number of systems ofeach manufacturer, model numbers, manufacturerclaimed F-GHG and N2O destruction or removalefficiencies, if any, and records of destruction orremoval efficiency measurements over their inuse lives. The inventory of abatement systemsmust describe the toolswith model numbers andthe recipe(s), process sub-type, or process typefor which these systems treat exhaust.Revised the inventory to include only thosesystems for which the facility is claiming FGHG or N2O destruction or removal.Revised to report only (1) the number ofdevices controlling emissions for eachprocess type, for each gas used in thatprocess for which control credit is beingtaken;and (2) the basis of the DRE being used(default or site specific testing) for eachprocess type and for each gas.Revised to not require reporting the modelnumber of the tools associated with eachabatement system, and to remove the recipespecific references.98.96(p) NACertification that each abatement system isinstalled, maintained, and operated according tomanufacturer specifications. All inputs toabatement system uptime calculations, the defaultor measured DRE used for each abatementsystem, and the description of the calculationsand inputs used to calculate class averages formeasured DRE values.The certification is revised to include that allsystems are installed, maintained, andoperated according to the site maintenanceplan for abatement systems.All inputs to abatement system uptimecalculations, the default or measured DREused for each abatement system, and thedescription of the calculations and inputsused to calculate class averages for measuredDRE values moved to recordkeeping in98.97(d).In place of reporting the information anddata on uptime and DRE calculations for98.96(q) 98.97(d)Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse GasesSource Category of the Greenhouse Gas Reporting Rule5Data Element Change/RevisionOriginalCitationNew orRevisedCitationabatement systems, the reporter mustcalculate and report an effective fab-wideDRE, as required in 98.96(r).Inputs to the F-HTF mass balance equation,Equation I-16, for each F-HTFChanged to recordkeeping. 98.96(r) 98.97(r)An effective fab-wide DRE calculated usingEquation I-26, I-27, and I-28, as appropriate.Added requirement NA 98.96(r)Estimates of missing data where missing dataprocedures were used to estimate inputs into theF-HTF mass balance equation under 40 CFR98.95(b).Changed to recordkeeping. 98.96(s) 98.97(s)A brief description ofeach “best availablemonitoring method” usedaccording to 40 CFR98.94(a), the parameter measured or estimatedusing the method, and the time period duringwhich the “best available monitoring method”was used.Removed the reporting requirement becausethe BAMM provisions in 98.94(a) will beobsolete at the time these amendments arefinal.98.96(t) NAFor reporting year 2012 only, the date on whichyou began monitoring emissions of F-HTF whosevapor pressure falls below 1 mm of Hg absoluteat 25 degrees C.Removed the requirement because theseprovisions will be obsolete at the time theseamendments are final.98.96(v) NAThe date of any stack testing conducted duringthe reporting year, and the identity of the stacktested.Added requirement in conjunction withoptional stack testing method.NA 98.96(w)(1)An inventory of all stacks from which process FGHG are emitted. Foreach stack system,indicated whether the stack is among those forwhich stack testing was performed as per 40 CFR98.3(i)(3) or not performed per 40 CFR98.93(i)(2).Added requirement in conjunction withoptional stack testing method.NA 98.96(w)(2)If emissions reported under 40 CFR 98.96(c)include emissions from research and developmentactivities, the approximate percentage of totalGHG emissions that are attributable to researchand development activities.Added requirement. NA 98.96(x)If your semiconductor manufacturing facilityemits more than 40,000 mtCO2e, a triennialtechnology assessmentreport that includesinformation such as howgases and technologieshave changed, the effect on emissions of theimplementation of new process technologies, andAdded requirement. NA 98.96(y)Information Collection Request Memo for Subpart I of the Fluorinated Greenhouse GasesSource Category of the Greenhouse Gas Reporting Rule6Data Element Change/RevisionOriginalCitationNew orRevisedCitationdefault utilization and by-product formation ratescollected in the previous 3 years.Additionally, EPA proposed confidential business information determinations for subpartI on February 22, 2012 (77 FR 10434) andfinalized them on August 13, 2012 (77 FR 48072). The EPA alsoproposed confidentiality determinations for the new and reviseddata elements inthe proposed amendments on October 16, 2012 (77FR 63538) and will finalize them in the same action as the final rule amendments.The EPA made two key changes in these amendments that reducethe burden on facilities. These changes are the addition of stacktestingas an optional emission monitoring method (i.e., creating a choiceof two calculation methods) and the removal of the requirements for certainfacilities to determine and use recipe-specific gas utilization rates and by-product formation rates. Specifically, the rule would provide the optionfor reporters to either (1) use default gas utilization rates andby-product formation rates, which have been revised to reflect new industry dataprovided to the EPA, or (2) conduct stack testing to establish site-specific emission factors for fluorinated GHGs that would be used to calculatefluorinated 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 burden reductionof the rulefor the private sector is a reduction of approximately 17,661hours and $4,551,316 per year.The overall burden reduction reflects both anadjustment and a program change. The adjustment is related toEPA’s revised estimate of the number of reporters (using the actual number of2012 reporters), and the program change reflects the reduction in burden associated with the final regulatory changes. For thepurposes of theburden calculation, EPA has assumed that facilities will choose touse default gas utilization rates. While the option to conduct stack testing wouldlike be more costly overall than the option to use default gas utilization rates, EPAnotes all reporters have the option to use either method, andthus has based its estimates on the less burdensome option.CONCLUSIONEPA has reviewed the technical amendments covered in this final rule and determined that there is a reduction in burden for subpart Ireporters. These changes provide additional flexibility in choosing calculation methodologies and move many reporting requirements torecordkeeping, and, therefore, reduce the burden on facilities.The final rule requires reporters to submit reports starting in2015 (which wouldcover the 2014 reporting year) with these amendments.