Number Reviewer Affiliation Section Section Title From Page To Page From Line To Line Comment 

1 Joe Van Gompel Glade Consulting LLC 1.2 Protocol Objectives 5 5 30 32

ESH usually refers to Environmental, Safety, and Health, not Environmental, Safety and, Handling

The noted error 

2 Joe Van Gompel Glade Consulting LLC 1.3 Protocol Scope 5 5 37 37

CH4 should be CF4. The noted error 

3 Joe Van Gompel Glade Consulting LLC 2.1.1 Description of Experimental System 8 8 30 41

Include in this list vacuum pump purges and additional purges between the process chamber and the POU abatement device. Sometimes these purges may be inside the POU abatement device itself. These are critical and must be accounted for.

This will be add

4 Joe Van Gompel Glade Consulting LLC 2.2.1

Method 1—Dilution 

Adjusted Concentration 

Measurement

11 11 10 10

"...while data is collected..." should be "...while data are collected..." Data is 

plural.

The noted error 

5 Joe Van Gompel Glade Consulting LLC 2.2.1

Method 1—Dilution 

Adjusted Concentration 

Measurement

11 11 8 26

Note that if the DRE measurement made under Method 1 is for CF4, then Method 1 is adequate as CF4 is the most difficult of the PFCs (including byproducts) to destroy. If CF4 is destroyed to 0.95, then it is certain that the byproducts with the chamber tool on will be destroyed to 0.95 or greater.

No response is 

6 Joe Van Gompel Glade Consulting LLC 2.2.1

Method 1—Dilution 

Adjusted Concentration 

Measurement

11 11 8 26

Can Method 1 be performed with dummy wafers and the plasma on? This would give the full range of byproducts while allowing the tool operator to run the desired PFC gases for as long as required to achieve steady state conditions during the measurements.

The Protocol prstandard is ach

7 Joe Van Gompel Glade Consulting LLC 2.2.3 Equipment Needed 12 12 23 27

Mass flow controllers on the separate slip streams may not be adequate to ensure uniform mixing from multiple chambers when doing SMPSIF. This approach demands accurate knowledge of the purge flow from the vacuum pump. This value as measured from the vacuum pump may not be accurate, especially from older vacuum pumps. Accurate knowledge of vacuum pump purge rates is a critical part of the Description of the System, 2.1.1.

EPA believes thFurther discuss

8 Joe Van Gompel Glade Consulting LLC 2.2.4 FTIR and QMS Protocols 13 13 16 16

Remove the double periods at the end of 2 of the sentences. The noted error 

9 Joe Van Gompel Glade Consulting LLC 2.2.4 FTIR and QMS Protocols 13 13 22 22

Normalizing QMS signals to the N+ ion may not account for changes in the N2 flow from certain processes when N2 purges change during the course of the process run. This detail must also be addressed in the Description of the System 2.1.1.

Normalization to practice. Expernormalizing to n
Number Reviewer Affiliation Section Section Title From Page To Page From Line To Line Comment 

10 Joe Van Gompel Glade Consulting LLC 2.2.5 Calibration Curves 13 13 30 33

Some FTIR quantitative analysis software packages (e.g. AutoQuant Pro used by Midac Corporation) has the ability to shift to different absorbance peaks over several orders of magnitude depending on the concentration of the material being measured. In this case, multiple gas cells may not be required.

EPA will include peak may risk ipath cells is bes

11 Joe Van Gompel Glade Consulting LLC 2.2.5 Calibration Curves 14 14 Figure 2 Figure 2

Figure 2 is not a good example – R2 and Y-intercept data are not shown on the plot. 

EPA will update 

12 Joe Van Gompel Glade Consulting LLC 2.3 Data Treatment and Analysis 16 22 N/A N/A

Where did the heavy math and statistics come from? That is neither in the referenced Sematech article nor in the referenced IPCC article. Is this in the 40 CFR? It is ponderous – must the workup be that complex? To what end? Can an example Excel spreadsheet be included? Fewer workup errors would occur if you don’t force everyone (and there are precious few statisticians out there) to work it out for him/ herself. If this level of statistical analysis is required, then a series of Excel spreadsheets should be included to minimize errors. Einstein said “Make things as simple as possible, but not simpler”.

EPA does not baverages when the case when advantage of alsame weight as (unweighted) avbecause a perfonecessary to stperformance m

13 Mehran Moalem Applied Materials Inc. General General N/A N/A N/A N/A

We have not sent a comment because the draft is pretty good overall and well written. It also includes the concerns we had expressed before so just wanted to say that the draft is good and our lack of comment is not for not having reviewed the draft.

No response is 

14 Mike Sherer Sherer Consulting Services Inc. 1 Introduction 4 4 5 5 Perfluorocarbon should be perfluorocompound, as NF3 and SF6 are not perfluorocarbons. In addition, CHF3 and CH2F2 are hydrofluorocarbons (HFC). The noted error 

15 Mike Sherer Sherer Consulting Services Inc. 1 Introduction 4 4 24 24 Decomposition should be changes to deposition. CVD is chemical vapor deposition, not decomposition. The noted error 

16 Mike Sherer Sherer Consulting Services Inc. 1.1 Protocol Purpose 4 4 40 40

SF6 is not a chamber cleaning gas. C2F6 and C3F8 are other common chamber clean gases.

The noted error 

17 Mike Sherer Sherer Consulting Services Inc. 1.1 Protocol Purpose 4 4 41 43

The last sentence in paragraph 2, [A variation of Method 1 may be used when byproducts are formed, provided appropriate steps are taken to add, to the influent abatement-system flow of unutilized PFC(s), proper amounts of byproduct PFC.] is hard to understand.

EPA will rewrite 

18 Mike Sherer Sherer Consulting Services Inc. 1.2 Protocol Objectives 5 5 30 32

ESH should be Environmental, Safety, and Health, not Environmental, Safety 

and, Handling

The noted error 

19 Mike Sherer Sherer Consulting Services Inc. 1.3 Protocol Scope 5 5 37 37

CH4 should be CF4. Also not aware that C3F6, which is listed, is used as an input gas in a fab.

The noted error 

20 Mike Sherer Sherer Consulting Services Inc. 1.3 Protocol Scope 6 6 9 13

This one sentence is long and awkward. Can it be split up? EPA will rewrite 

21 Mike Sherer Sherer Consulting Services Inc. 1.4 History of the Protocol 7 7 16 16 Capitalize fourier transform infrared spectrometer. Also “(FTIR)” should be after “infrared” and before “spectrometer”. The noted error 

22 Mike Sherer Sherer Consulting Services Inc. 1.4 History of the Protocol 7 7 30 30

The word “and” should be “an” before words “EPA Method”. The noted error 

23 Mike Sherer Sherer Consulting Services Inc. 1.4 History of the Protocol 7 7 Footnote 6 Footnote 6

Please explain why the PFC emissions would be significant during this method. Other procedures like calibrations and operating MFC at 120% of flow could possibly allow much more PFC emissions to occur.

It is not a mattealways been EPwould be otherw

24 Mike Sherer Sherer Consulting Services Inc. 2.2.2 Method 2—Total Volume Measurement 11 11 36 36 Separate “singleor” into two words, single or. The noted error 

25 Mike Sherer Sherer Consulting Services Inc. General General N/A N/A N/A N/A In several locations SEMATCH should be SEMATECH. The noted error 
Number Reviewer Affiliation Section Section Title From Page To Page From Line To Line Comment 

26 Mike Sherer Sherer Consulting Services Inc. 2.2.3 Equipment Needed 12 12 16 16 “SF6,it” should be two words. The noted error 

27 Mike Sherer Sherer Consulting Services Inc. 2.2.3 Equipment Needed 12 12 17 19

Please provide examples on how the analyst must provide compelling demonstration that less than 1 percent of the gas is destroyed.

We expect expebe further clarifboth CF4 and Sthe two ratios wconcluding that alternative tracebond energies, the inverse of th

28 Mike Sherer Sherer Consulting Services Inc. 2.2.4 FTIR and QMS Protocols 13 13 16 16 Remove the double periods at the end of the sentence. The noted error 

29 Mike Sherer Sherer Consulting Services Inc. 2.2.5 Calibration Curves 13 13 28 28 “Dec” should be “December”. The noted error 

30 Mike Sherer Sherer Consulting Services Inc. 2.2.6 Flow and Dilution Measurements 15 15 32 32 Separate “3-5different” into two words. The noted error 

31 Mike Sherer Sherer Consulting Services Inc. 5 References 25 25 19 19

“Beau” should be “Beu.” The noted error 

32 Mike Sherer Sherer Consulting Services Inc.

Another methodology is to accurately flow a non-reactive gas (e.g. CF4) into POU abatement device outlet and measure the concentration downstream (usually by FTIR). This methodology requires the following criteria to be utilized:1. The non-reactive gas used must be sampled at POU abatement device outlet to determine that this gas is not present.2. The non-reactive gas must be injected across the POU abatement device outlet duct. This can be accomplished by using an injection probe with equally spaced holes.3. The location selected for downstream non-reactive gas analysis must be at least eight duct diameters downstream from non-reactive gas injection location.4. The location selected for downstream non-reactive gas analysis must be used for POU abatement device outlet sampling. This will ensure that any dilution that occurs from POU abatement device outlet to this sampling location will be accounted for.5. It is recommended that the downstream non-reactive gas analysis location be traversed with the sampling probe at a few locations to ensure the non-reactive gas is well mixed. For example, if the duct is 10 centimeters, the duct can be traversed every 2 centimeters to prove each probe location has same non-reactive gas concentration.

EPA, in principlQMS is not avathis method woshould be capaanother criterioany header. Finseems prematusuggested alterany exisitng tes

33 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) General General N/A N/A N/A N/A

Document is still written from the perspective of semiconductor manufacturing. If intent is to be applicable to all electronics operations using long-lived fluorinated gases, protocol needs to be re-worded to be generally applicable to other operations besides wafer manufacturing.

EPA will clarify electronics man

34 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) General General N/A N/A N/A N/A Need to apply to other types of abatement besides thermal units (e.g., plasma). The Protocol fo

that tracer Kr trasuch systems in 

35 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) General General N/A N/A N/A N/A Need to integrate JEITA alternative method for measuring dilution through the system. EPA has not se

test results usin

36 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) General General N/A N/A N/A N/A It would be useful if EPA would provide a spreadsheet to assist in capture, manipulation, and reduction of data. EPA leaves this 

Suggested additional methodology to determine the POU abatement device outlet 

volumetric flow rate. 
Number Reviewer Affiliation Section Section Title From Page To Page From Line To Line Comment 

37 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) Real Life Issues Not 

Addressed in 

the Protocol

N/A N/A N/A N/A N/A

1. What it takes to construct the "calibration curve", reference library should bracket concentrations seen in the field.2. Reference conditions should be reasonably close to sample conditions (temp, press, path length) and will impact data.3. Analysis method will take significant work to determine optimal regions for analysis to minimize interfererants.4. Heated versus unheated sample lines?5. Optics integrity, fouling due to particulates.6. Signal to noise and resulting detection limits.7. Detector saturation.8. Moisture issues, spectra interference.

All of this is spereferences. Ref

38 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 1.1 Protocol Purpose 5 5 15 16 Avoid use of "level playing field", not understood by 2nd language people. EPA will adjust 

39 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 1.2 Protocol Objectives 5 5 25 26 Is there a reason to limit applicability to thermal abatement systems? How about other types of abatement? While the abate

not see any reasystems in elecapplicability.

40 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 1.2 Protocol Objectives 5 5 25 26 Isn’t this protocol supposed to apply to all electronics PFC DRE abatement characterizations? If so, strike “during normal wafer processing”. See response t41 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 1.2 Protocol Objectives 5 5 30 32 ESH should be Environmental, Safety, and Health, not Environmental, Safety and, Handling The noted error 

42 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 1.3 Protocol Scope 5 6 41 7

References ISMI 2006 guideline. Please note that ISMI Guideline is currently being revised in a coordinated effort with ISMI’s international membership. Here and throughout the document, should reference the 2009 SEMATECH Guideline, which will be finalized soon.

EPA will keep r2009 ISMI Guidat the abatemeusing an FTIR. reliability (e.g., available in the Guidelines into 

43 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 1.3 Protocol Scope 6 6 18 19 The method stipulates that the relative error must achieve plus or minus 5 %. Presumably they mean < 5% relative error. This is correct, 44 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 1.3 Protocol Scope 6 6 Footnotes 3 and 4 Footnotes 3 and 4

Selection of fraction emitted as the benchmark/performance metric seems predicated on low DRE. For a well functioning abatement unit with DRE approaching 1, all the same issues will occur with using the relative error of fraction emitted as are identified with using the relative error of DRE as DRE approaches 0. The benchmark metric and performance standard defined for this protocol should not be so sensitive to the DRE itself. Should the acceptable error be defined as a percentage of the unabated emission value instead? While footnote 4 argues that the proposed 5% relative error performance standard is achievable, it is not clear that this is true across the full range of DREs.

EPA is modifyinperformance mprocess conditiowhen Cout ≤ C*The performanc

method of weig

45 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 1.4 History of the Protocol 7 7 21 and Footnote 6 21 and Footnote 6

We question the cost-benefit of the ban on the detuning (bypass) method. Given the short duration of the test protocol, and in recognition that the method is for a single tool with relatively low emissions; we questionwhether the ban on the de-tuning method is justifiable....i.e., “prevents a significant quantity of PFC emissions.”

See answer to c

46 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.1 Prepare Measurement Plan 8 8 7 19 An advance plan is good. However, we should take care to ensure that, as worded, the measurement plan does not require a visit to the site 2 weeks in advance of the work. As worded, the 

plan should be 

47 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.1.1 Description of Experimental System 8 8 30 41 Should some level of tool and abatement process operating conditions be collected during the measurements? Include in protocol as a suggestion. EPA will expand 

48 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.1.1 Description of Experimental System 8 8 30 41 Should the list be more explicit with regard to the recording of operating conditions, so that the results are “bridgeable” from one test to another? EPA will expand 

49 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.1.3 Required Resources 9 9 Figure 1 Figure 1 Will MFCs function in this configuration, the schematic locates them on the suction side of the pump? They would be at negative pressure, typical MFCs need pressure (i.e. 20-50psi) to function properly. EPA has used t

MFC's. MFCs cMFCi.e., inlet h

50 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.1.3 Required Resources 9 9 Figure 1 Figure 1 What is a "calibration system"? Is this gas delivery via MFC? Need more info, if it is MFCs then same comment as above. The protocol re

appendixes. Yepressure drop a

51 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.1.3 Required Resources 9 9 Figure 1 Figure 1 Need to specify minimum distance between pump exhaust and FTIR2 inlet to avoid recirculation issues. The Protocol w

placement into 
Number Reviewer Affiliation Section Section Title From Page To Page From Line To Line Comment 

52 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.1.5 Safety 10 10 9 9 Mentions “integrated circuit fabrication environment.” Don’t forget this is supposed to apply to flat panel and solar facilities. See response t

53 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2 Measurement Methodology 10 11 22 6 SIA or ISMI GHG WG should ensure that the proposed < 5 % relative error is an appropriate and readily achievable error threshold. EPA agrees. EP

measurement s

54 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2 Measurement Methodology 10 11 22 6 Include JEITA alternative for measuring dilution. See response t

55 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2.1 Method 1—Dilution Adjusted Concentration Measurement 11 11 8 26

The use of the term "scrubber" is confusing if not misleading, because this term is widely used in the chemical engineering literature to refer to gas to liquid transfer processes. In this procedure the subject is a “POU abatement device” which in fact may be fitted with a true scrubber to remove fluoride ions from the abatement unit gas effluent stream.

EPA is referring is no confusion"abatement sys

56 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2.3 Equipment Needed 12 13 10 2 Is NDIR an appropriate method for abatement effluent characterization? Should it be included? If it is included, what is needed to obtain good results? NDIR is not inte

of a specific F-Gmonitoring chan

57 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2.3 Equipment Needed 12 13 Table 1 Table 1 What is a metal bellows sample pump? Do we mean flex foreline fitting bellows? Do we mean metal diaphragm? If so what type of metal? Might not hold up to corrosives. A metal bellows 

as the pumping service.

58 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2.3 Equipment Needed 12 13 Table 1 Table 1 Sample filter, pore size spec? Material spec? Could impact pressure drop/data significantly over time for dirty processes and unheated lines. EPA does not b

experienced in clarified in the P

59 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2.4 FTIR and QMS Protocols 13 13 8 22

There seems to be confusion between sample rate, reported averages, FTIR scan rate "The sampling frequency for the FTIR should be less than 3 seconds". Is this a scan, reported average? If it is reported average it seems awfully low. I think scan rate will instrument dependent.

This section wilrequirements to EPA performedprovides adequdata point requ

60 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2.4 FTIR and QMS Protocols 13 13 12 16 FTIR absorbance range of "0.1 to 1" is somewhat arbitrary and detector specific. This is the sam

61 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2.5 Calibration Curves 13 14 24 25

Why is a 6 point calibration curve required for QMS, but apparently only a 2 point calibration curve required for FTIR?

EPA revised the calibration such concentration/flHowever, the acalibration may important that hused to define tdespite the QM

62 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2.5 Calibration Curves 14 14 16 20 Is the stipulation of an R2 value of better than 0.98 mathematically consistent with a RSE of better than 5 %? The two are un

measures the R

63 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.2.6 Flow and Dilution Measurements 15 15 32 34 Is the stipulation of a minimum of 3 flow rates with an average derived from a minimum of 40 distinct analytical measurements, for each flow rate, appropriate? How was this number selected? Using 40 data p

performance staresponse to Co

64 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.3.1.1 Total Volume Flow 17 17 4 14 We are confused why different minimum measurement data collection quantities of 640, 40, and 60 are alternately applied here. What is the basis for selecting these numbers? EPA will correc

A minimum of 4

65 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.3.1.1 Total Volume Flow 17 17 16 19 Why must there be a minimum of 180 TVF data points? What is the physical or mathematical basis for selecting this number? EPA revised thi

See response t

66 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI) 2.3.1.1 Total Volume Flow 16 19 32 10 The statistical methods and equations, along with any specific sample number requirements they may have should be referenced to standard textbooks or similar reference material. EPA will include 

Engineers", Stu

67 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI)

3 Benchmark Relative Error 22 22 25 28 "These formulas may not be applicable when using alterative methodologies to those presented in this protocol are used..." Does this mean that alternative methods are ok? It implies that way. Also note typo in quotes. The Protocol do

analysis methodnumber of mea

67 ISMI GHG Working Group International Sematech Manufacturing Initiative (ISMI)

3 Benchmark Relative Error 22 22 21 28 Defines benchmark as fraction destroyed (DRE), contrary to earlier definition as fraction emitted. See discussion of Section 1.3. The benchmark 

correct this in S