May 1 7 , 2012

1 

### Proposal to Incorporate ISMI 2009 Guideline References in Subpart I
The ISMI environmental characterization guideline was written to encompass the measurements that can be used to quantify all environmental impacts of semiconductor process tools, attached peripheral equipment and point of use abatement devices. The scope of the guideline goes well beyond addressing point of use (POU) abatement testing ; therefore, only thos e sections that apply to POU abatement testing should be included in Subpart I. I mprovements to the measurement processes have been gained through appl ication of the 2009 ISMI guideline methods in operating fabs over the last three years by the industry and testing contractors. The language from the 2009 Guideline that SIA proposes for the rule follows , with some revisions where needed to reflect increas ed knowledge

. I talics are used to for clarifying text

. The EPA DRE protocol currently references the 2006 ISMI guideline and should be revised

. Proposed Text for Inclusion in Subpart I:
Mass Spectrometry testing will be conducted in accordance with provisions of Appendix A.1 in the 2009 ISMI Environmental Characterization Guideline

. FTIR testing will be conducted in accordance with the provisions of Appendi x A.2

. NOTE: Appendix A.2 references in several places the use of a calibration transfer stand ard (CTS). As we read Appendix A.2, it is not required and it is important that, a s the Agency incorpor ates Appendix A.2 into the rule, its applicability remains limited . The use of a CTS is necessary , in certain instances, to validate optical pathlength for spectrometers where cell optical pathl ength is variable. For fixed pathlength spectrometers, the use of a CTS standard as described in Appendix A.2 is not needed and should not be required.

In addition to the methods listed in the EPA DRE Protocol, th e following alternative method (a combination of modifications to Appendix B.1.5 and EPA Method 7E) may be used to determine POU abatement device outlet total volumetric flow.
Changes to Appendix B.1.5 and Method 7E include:

 Allowance for introduction of the non

- reactive gas between the oxidizer and the scrubber in the point of use abatement device

.
 Removed the 8 duct diameter requirement that appears in B.1.5.

 Removed the allowance that stratification testing is not required for ducts 4” diameter or le ss that appears in Method 7E ( because stratification can occur in smaller ducts )

.
 Removed the requirement to sample for twice the system response time for each traverse. This comes from Method 7E but is not relevant to FTIR.

 The allowed percentage variati ons in Method 7E have been doubled but the ppm v alternative criterion has been removed.

 Added a description of the number of measurements and flow rates required for determining POU abatement device effluent flow by this method using FTIR

.May 1 7 , 2012

2 Another methodology is to accurately flow a non

- reactive gas (e.g., CF4) into the POU abatement device outlet, or between the oxidizer and the scrubber, and measure the concentration downstream (usually by FTIR). The following criteria must be fulfilled when using this methodology:

1. The POU abatement device outlet must be sampled to ensure that the non

- reactive gas is not present. 2. The non

- reactive gas can be injected across the duct. This can be done using an injection probe with equally spaced holes. 3. The location selected for downstream non

- reactive gas sampling must also be used for POU abatement device outlet sampling. This will ensure that any dilution from POU abatement device outlet to this sampling location will be accounted for. 4. The sampling location should be traversed with the sampling probe measuring the non
reactive gas concentrations to ensure homogeneity of the non

- reactive gas and POU abatement device effluent (i.e. stratification test). To test for st ratification, measure the

non
- reactive gas concentr ations at three points on a line passing through the centroidal area. Space the three points at 16.7, 50.0, and 83.3 percent of the measurement line. Calculate the individual point and mean non

- reactive g as concentrations. If the non

reactive gas concentra tion at each traverse point differs from the mean concentration for all traverse points by no more than: (a) ± 10.0 percent of the mean concentration, the gas stream is considered unstratified and you may collect samples from a single point that most close ly matches the mean. If the 10.0 percent criterion is not met, but the concentration at each traverse point differs from the mean concentration for all traverse points by no more than: (a) ± 20.0 percent of the mean, the gas stream is considered to be min imally stratified, and you may take samples from three points. Space the three points at 16.7, 50.0, and 83.3 percent of the measurement line. If the gas stream is found to be stratified because the 20.0 percent criterion for a 3

- point test is not met, lo cate traverse points for the test in accordance with Table 1

– 1 or Table 1

– 2 of EPA Method 1. 5. A minimum of 40 non

- reactive gas concentration measurements will be collected a t 3

- 5 different injected non

- reactive gas flow rate s for determination of POU abatem ent device effluent flow. The total volumetric flow of the POU abatement device exhaust will be calculated consistent wi th the EPA Protocol Equations 1 through 7.