March 6, 2012 1

Questions for SIA on Abatement System DRE, Uptime, and Related Requirements

On January 10, 2012, SIA provided data to EPA on abatement system uptime, abatement system 

inventories, and destruction or removal efficiency (DRE) measurement. This document

represents EPA’s questions on the data and information submitted with respect to SIA’s concerns 

about DRE measurement. These questions are to ensure that the Agency understands SIA’s 

data/analyses and has enough information to support a new rulemaking to address these technical 

concerns. For the most part, the questions are clarifications on the information presented by SIA 

and not requests for additional data. We do not intend for these questions to result in extensive 

additional analysis or work, please let us know if that is not the case. 

EPA appreciates the significant amount of information SIA has shared. It is very helpful and 

provides the largest abatement system DRE data set for Subpart I available to EPA. Based on 

the abatement system inventory information SIA has provided, EPA has estimated that the 

following installed percentages of systems by manufacturers: 

~56 % of systems are MfrZ, 

~21% of systems are MfrX, 

~14% of systems are MfrY, and 

~9 % of systems are from MfrW, MfrT and MfrV.

We have done some additional work to better define the current inventory of installed abatement 

units at US fabs. We have captured additional information from two device manufacturers to 

complete their inventories. We also determined that for the uninventoried units from the 2012 

survey (approximately 900 abatement units at Mfr. C fabs), the distribution between combustion 

and plasma units is similar to the inventoried units for manufacturer C. This enables us to state 

that over 95% of the U.S. installed base of abatement units use combustion, and that over 70% of 

the combustion units are manufactured by MfrZ. 

Breakdown of POU F-Gas Abatement Devices Based 

on 2011 Survey 

Company MFR Combustion Plasma Total

A MfrX 277 277

A MfrY 183 183

A MfrW 2 2

B MfrZ 167 167

C MfrZ 311 311

C MfrT 31 52 83

C MfrV 29 29

D MfrZ 165 165

E MfrZ 135 135

F MfrZ 48 48

Total Units 1348 52 1400

% of Total 96.3% 3.7%

% by Manufacturer

% MfrZ 59.0%

% MfrX 19.8%
March 6, 2012 2

% MfrY 13.1%

% MfrW, MfrT, MfrV 4.4% 3.7%

We believe that the fact that the over 95% of the abatement units are combustion units enable the 

use of the available test data that we submitted to EPA to establish industry level DREs. Setting 

industry level, default DREs is justified by the following information:

o the tested units are representative of over 68% of the inventoried abatement units, 

o combustion technology is straightforward; and 

o the manufacturer’s design DREs are consistent across the different brands of combustion 

units. 

Also based on the information SIA provided, EPA estimated that the data that SIA has collected 

was based on testing of abatement systems from predominantly one manufacturer, MfrZ (~97% 

of tests). 

Based on EPA’s initial review, it appears that the data in SIA’s DRE report supports the concept

that achievable DREs vary by gas, process, and abatement system design/model. EPA agrees 

that an approach to provide a variety default DREs (e.g., by gas, process, abatement device, etc.) 

appears to be a viable option, with some further discussion and work. 

Default DRE Measurements and Data

1. On pages 4 and 7, SIA indicates that in the testing, the abatement DRE test results for 

some CF4 and NF3 units were lower than expected and below the manufacturer’s DRE. 

SIA further indicates that one company “performed five retests after the abatement device 

was serviced to address a low DRE identified by the first test.” It is further stated that, 

while some units performed as intended, some operations and maintenance procedures 

needed to be revised to achieve the expected CF4 DREs.

a. Can SIA explain why the CF4 and NF3 DREs were low on the malfunctioning 

units?

A key contributing cause to the low DREs on abatement units treating CF4 is the fact that

process flow rates (the volume into the abatement system) and/or the abatement discharge flow 

rates (the volume out) exceeded the manufacturer’s recommended flow rates. These combustion 

units have a recommended volume into the abatement unit of up to 250 standard liters per 

minute ( slpm) and a recommended volume out of up to 1,000 slpm. A review of the files “Etch 

Abatement Units with flow data. Xls”, which provides the flow rates in and out of the tested 

abatement units and the associated dilution rates, illustrate the relationship between these two 

flow rates and lower CF4 DREs. That relationship is not present for the DREs of other F-gases, 

which are more easily destroyed. The higher flow rates resulted either from inaccurately sized 

Mass Flow Controllers that were measuring/delivering the process gas and dilution flows to 

provide the correct mix of gases needed for safe handling of pyrophoric gases on the tool or the 

failure of the switching mechanism that adjusts the dilution rates based on the gas being fed to 

the process (for example, higher dilution rates are required for safety reasons during a H2 gas 

feed). For the CF4 DREs, the abatement system manufacturer is assessing other potential 

contributing causes of lower than expected DREs. SIA will provide an expanded response to this 

question sometime in March based on the additional information supplied by the equipment 

manufacturer. 
March 6, 2012 3

For the CVD clean abatement units, which abate only NF3, there were only three tested units 

with a DRE lower than the manufacturer’s design DRE, out of the 35 units tested. Two systems 

were likely affected by high flow rate and one system was not. The file “CVD abatement units 

with flow rates.xls” provides the flow rates and dilution rates for the CVD clean abatement unit 

tests. The abatement system manufacturer is assessing other potential contributing causes which 

resulted in lower than expected DREs on the two CVD clean abatement units. SIA will provide 

an expanded response for both the NF3 and CF4 abatement units in March based on the 

additional information supplied by the equipment manufacturer. 

b. Can SIA indicate whether there are any general criteria that could be applied to 

ascertain whether a unit is under performing or needs service without having to 

measure the abatement system DRE? 

SIA is still considering the answer to this question and will provide a response before the end of 

March.

. 

c. Can SIA clarify whether the initial testing data and the retest data for the retested 

units are in Tables VI and VII in Appendix B? If so, please identify this data.

Tables VI and VII have been updated to clearly identify the retests.

d. Can SIA indicate what criteria were used to determine whether a retest needed to 

occur?

Retests were done where abatement units were performing significantly below the abatement 

equipment manufacturer’s design DRE and where the initial test was done in the first set of tests 

in April and May so a retest could be scheduled during the second set of testing in August and 

September. 

As discussed above, this round of abatement DRE testing was done to generate data for use in 

addressing DREs for the reporting rule. Where tested values are below the design DREs, they 

reduce the average DRE for the gas/process category and are represented in the average DRE in 

the installed base. Device manufacturers have an incentive to work to maximize the DRE of 

each unit as they are making significant investments in capital and operating expense for the 

units. The need for retesting should be left to the device manufacturer based on their corrective 

actions to improve the unit DREs, their current testing plans for the abatement units (where they 

are using a site specific DRE), and the expected increase in the DRE that will be realized 

through their investment in unit testing. Abatement unit testing in an operating semiconductor 

fab costs $6-8,000 per unit or $10-20,000 per unit when only a few units are being tested; 

moreover, testing requires production disruptions and engineering resources. On this basis, 

retesting should not be mandated in the rule so long as the data from the low DRE test is 

included in the site specific process/gas type average.

2. What method/protocol did SIA use for the DRE measurement tests (e.g., the EPA DRE 

Protocol) and did that method/protocol account for dilution by the abatement system? 
March 6, 2012 4

The 57 tests performed at the one facility were performed in accordance with the procedure for 

Method 1 as described in the “Protocol for Measuring Destruction or Removal Efficiency (DRE) 

of Fluorinated Gas Abatement Equipment in Electronics Manufacturing March 2010” as 

specified in the Subpart I regulations. F-gases were flowed to the abatement units without 

operation of the tool plasma generator to simplify the testing process. Dilution rates were 

measured as required by the Protocol. Two example test reports, one for a tool specific 

abatement system and one for an area abatement system that abates several etch tools are 

provided in the files “FE05-002 DRE Test Report 13 Dec 2011.pdf” and “FK04 05 06 Backup 

DRE Test Report 13 Dec 2011.pdf” (This is the test of the area unit).

1

These example files detail 

the methods use for measuring the dilution rates.

The majority of the testing reported from the other manufacturer was completed prior to March

2010. They were, however, done in general accordance with the Method 2 requirements and 

tested the DREs for the abatement units under actual fab operating conditions (with process 

gases flowing through the chamber with the tool plasma generator activated). Dilution 

measurements varied over the variety of tests due to various methods being developed over the 

course of time. Some of the dilution measurement methods used were primarily the QMS method 

specified in the rule and the post-POU FTIR dilution method. Variations of these methods may 

have been used, depending on the year in which the measurement was made. 

In the context of the testing methodology, SIA is also asking EPA to include the 2009 ISMI 

Guideline tracer release/FTIR monitoring approach as an acceptable method for determining 

POU abatement system effluent flow. Inclusion of the effluent flow measurement method can be 

done by incorporating the method into the EPA Protocol referenced above or specifically adding 

the method as a referenced method in Section 98.7 of the Subpart I regulation. The efficacy and 

appropriateness of using the FTIR monitoring methodology has been demonstrated by the stack 

testing work completed by SIA members over the past 12 months. SIA has attached the report 

“Comparison of Fourier Transform Infrared (FTIR) and Quadrupole Mass Spectroscopy (QMS) 

Methods for Determining POU Abatement System Effluent Flow”. This report provides the data 

needed to justify the inclusion of this method in Subpart I. This method is more efficient, costs 

significantly less per test, and provides results which are comparable to the approved methods 

detailed in the “Protocol for Measuring Destruction or Removal Efficiency (DRE) of 

Fluorinated Gas Abatement Equipment in Electronics Manufacturing March 2010”. 

In addition, the modifications to Subpart I should also set broad criteria, similar to that found in 

Subpart L 98.124(e)(1) & (2), that assures the quality of the testing procedure and analytical 

method used to perform required testing. 98.124(e) provides example methods, but also allows 

qualification of alternative methods, using accepted validation procedures, to enable 

development and early adoption of more efficient testing and analytical protocols using new or 

existing technologies. 

 

1

These two reports will not be provided as part of the docket documents.
March 6, 2012 5

3. Can SIA clarify how the measurements were taken at the facilities? Were they taken 

with different GHG flow rates over a variety of processes and tools? Can SIA provide

the flow rates, or the normalized flow rates, of the gases for which DREs were measured?

The two abatement system test reports provided with this response detail the test procedures 

used for the 57 tests performed in 2011. The file “2011 DRE flow summary 02812.xls” details 

the range of flow rates used in each test for each gas.

The remaining tests were done using actual process conditions and flows. The table below is a 

summary of the range of gas flows and the pre- and post-dilutions for the process conditions 

tested for each category and gas type.

# of 

emissions 

tests 

NF3 

Range

(sccm)

SF6 

Range 

(sccm)

CF4 

Range 

(sccm)

CHF3 

Range 

(sccm)

POU Inlet 

flow range 

(L/min)

POU Outlet 

flow range 

(L/min)

in-situ 

plasma 

chamber 

clean

6 1000-

3000

100-200 750-1000

Plasma 

Etch

2 10-30 100-300 70-200 20-80 300-600

remote 

plasma 

chamber 

clean

3 200-

2000

50-200 400-800

 

4. Can SIA please clarify whether all measurements were done on abatement systems 

specifically designed to abate F-GHGs?

All tested abatement systems were specifically designed to treat F-gases.

5. Can SIA please indicate if their testing supports any conclusions regarding how the 

performance of abatement systems changes (or does not change) between maintenance 

events?

The testing data that SIA has provided to EPA does not provide any basis for reaching any 

conclusions regarding the impact of the maintenance program on abatement system DRE. 

One manufacturer, in collaboration with ISMI, performed a test on the impact of maintenance 

activities on F gas abatement unit performance. This paper is not currently published, but is 

being reviewed to see if it can be made available. The basis was to test a POU abatement unit at 
March 6, 2012 6

the end of the PM cycle and after the PM was performed. The analytical results from the POU 

device before the PM was performed showed NF3 to be below the detection limit and therefore 

achieving a DRE of >99.9%. Based on this result, the decision was made not to perform any 

after PM measurements as there would not be any expected level of improvement.

6. Table B-1 indicates that there are 20 DRE measurements available for C4F8 etch and 22 

measurements available for NF3 in-situ plasma chamber clean. However in tables VI and 

VII respectively, in Appendix B, there are only 14 measurements for C4F8 etch and 21 

measurements for NF3 in-situ plasma respectively. Can SIA please clarify why these 

numbers do not match?

Response. A. Table B-1 was wrong in regard to the C4F8 etch measurements and a corrected 

table is given below in which new or changed information is highlighted in yellow. The analysis 

inadvertently grouped C4F6 and C4F8 into a single entry labeled C4F8 in the table. When the 

gases are divided and the tests recounted, we obtain the corrected values shown below that 

agree with EPA’s count. The new entry for C4F6 further supports the conclusion that 

consistently high DREs are achieved on average for the F-gases used in etch, 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

C4F6 5 99.06 ± 0.28

C4F8 14 98.85 ± 0.18

CHF3 19 99.18 ± 0.36

CH2F2 16 98.94 ± 0.19

 All Etch (Excluding CF4) NF3/Other 73 99.07 ± 0.13

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 49 88.7 ± 2.1
March 6, 2012 7

As a result, Table B-3 is also revised to indicate that, with the exception of CF4, default DREs 

can be established at the level of 99% for all of the gases used in etch considering both typical 

manufacturer DRE specifications and the consistency of the test data for individual gases. Test 

data exist to support this conclusion for NF3, SF6 and now five of the eight PFCs.

Table B-3. Coverage of NF3, SF6, and Other PFCs For Etch

in SIA Database

Typical Specification 

MfrZ Abatement a/

Average 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% 99.1%

C5F8 ≥ 99% Not tested

CHF3 ≥ 99% 99.2%

CH2F2 ≥ 99% 98.8%

CH3F ≥ 99% Not tested

a/

 Table 4. Design DRE Values for MfrZ Abatement Systems. Columns 1 and 2 give the 

specifications for MfrZ etch abatement devices in the SIA database.

B. In regard to the measurements for NF3 in-situ plasma, we have determined that one test 

was omitted from Table VII: Chamber Clean Abatement Measured DREs. A revised version of 

the table appears at the end of this document with the missing test added to the table and 

highlighted in yellow.

7. In Appendix B Table VI, what does a “NO” under the POU column indicate?

Response. “NO” indicates that the device is used for area abatement serving multiple gas 

streams, and not in a point of use (POU) setting.

Site-Specific Sampling Method

8. Can SIA please clarify whether the suggested percentages of abatement system testing in 

steps 2 and 3 apply to a specific “category” of abatement systems (i.e., by gas and 

process type) or to the entire facility abatement system inventory?

Response. The percentages would apply on a category basis to the inventory of abatement 

devices at the fab within the category. For example, to establish a site-specific DRE for NF3

used in chamber cleaning, the relevant inventory is that for devices abating NF3 from chamber 
March 6, 2012 8

cleaning processes. This category-specific inventory multiplied by the percentages specified in 

steps 1 and 2 would determine the number of tests to be conducted in the initial 2 years and in 

every 3-year period thereafter, respectively. As stated in step 3, after the first two years, the 

site-specific DREs used for the category in reporting under the MRR would be based on the 

latest 30 percent of the category-specific inventory.

9. Please describe the process SIA is proposing a facility would go through to select systems 

for testing and validation.

Response. There would be three steps in the proposed process:

a) Given a total number of tests to be performed in a category (determined from the 

category-specific inventory as described above), the tests will be allocated to abatement 

device make/model type groups in proportion to the distribution of devices in the 

category-specific inventory to establish targets for the sampling. This allocation assures 

that the sampling will match the distribution of devices in service within the category for 

the purpose of establishing a site-specific DRE for the category.

b) Abatement devices will be chosen randomly to fill the allocated targets by make/model 

type from the pool of matching devices that have not been tested in the current period. 

For example, we propose to test 15 percent of the installed category-specific device 

inventory in each 3-year period once the initial 2 year period has been concluded. A 

device already tested during the 3-year period would be excluded from the pool of 

devices to be sampled so that it will not be tested again in the same period. The pools 

will be reinitialized, without exclusions, at the beginning of each new 3-year period.

c) A device selected for sampling that is located at a pinch point in the production process 

cannot be made available for testing. When pinch point devices are selected, they will be 

replaced by another random draw from the pool of matching devices and then returned to 

the pool so that they are available for selection in the next round of testing.
March 6, 2012 9

Calculation and Reporting Requirements 

10. Does SIA have any suggested revisions to equations I-14 and I-15 in subpart I based on 

SIA’s DRE data? 

Equation I-14 should be modified as follows: 

Dip = dip * UipT where:

Dip = The fraction of the input gas consumed by abatement units.

dip= Industry level or site specific abatement system DRE for the process type/gas combination.

UipT= Total uptime for abatement systems supporting tools for a specific process type/gas combination 

as calculated by equation I-15.

i = gas type 

p = process type

In the abatement system briefing paper delivered to EPA on January 10, 2012, SIA proposed an alteration 

to equation I-15 in section E.1 and E.2 of the briefing paper to simplify the uptime calculation.

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 

Subpart 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.

In order to calculate the abatement system uptime for a process type/ gas combination, the 

Equation and its associated variables should be revised as follows:

UipdT = (1 – TipdT/TopsT ) where:

UipT : the total uptime, expressed as a fraction, of all of the abatement systems abating a given process 

type/gas combination. 

TipdT : the total time, in minutes, that all of the abatement systems abating a given process type/gas 

combination are not operational when the abated tool is in operation for the reporting year.

Tiops:T : The total number of minutes in the year times the number of abatement units for a given 

process/gas type. Where a tool and its associated abatement unit is only operational (installed and 

available for use) for a portion of the year (e.g. it is removed from or installed in the fab in May) then the 

total operational minutes for that tool would be prorated for the time it is available for use to prevent 

overestimating the abatement system uptime.

i = gas type 
March 6, 2012 10

p = process type

d = abatement unit

ops = operational process tools of a given gas/process combination whose emissions are abated. A tool 

is considered operational when it is installed and available for use.

T = Total time

Fabs with more sophisticated monitoring systems, which are currently a very limited subset of fabs, may 

be able to track tool operational time to a more refined definition of tool operation. Where systems 

allow better tracking of the operational metric, the fab should be allowed to identify how operational 

time is being tracked in its GHG monitoring plan and report abatement system up-time using that 

operational definition. 

11. Please clarify whether the issue with reporting 40 CFR 98.96(n) and (o) or the inputs to 

equation 1-14 is with respect to requiring this information to be reported or the 

calculation methods associated with these reporting elements?

SIA has two concerns with the current reporting requirements detailed in 40 CFR (n),(o) and (p). 

1. Under 98.96, the regulations specifically state that facilities “...must include in each annual 

report the following information for each electronics manufacturing facility.” Sections (n),(o), 

and (p) then require detailed information about the allocation of gas use to and detailed 

information about abatement units, whether or not a given facility is claiming the abatement 

system DRE to reduce its estimated emissions for the facility. SIA submits that this data should 

only be required to be supplied if the facility is reducing its estimated emissions based on the 

DRE of deployed abatement units.

2. Sections (o) and (p) require the submission of volumes of documents to EPA about the 

abatement units. It is SIA’s belief that these requirements will result in the submission of 

hundreds of pages of documents by each fab with abatement systems to EPA each year. 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 inspection, 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. 

For annual reporting to EPA, SIA proposes the following approach to managing abatement system test 

and O&M data.

a) A report of the abatement systems groupings and the number of abatement units in each group. 

Where a site is testing for one or more site specific DREs for process type/gas combinations, it 

should also report to EPA the number of tests required to be done for each process type/gas 

group over the specified testing period, the number of tests 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 
March 6, 2012 11

to report emissions (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

b) 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. 

In addition, 98.96 sections (n)-(q)need to be modified to reflect the revised approach to calculating the 

abatement system uptime and the consumption of gas at the process type/gas level rather than at the 

recipe/gas level. 
March 6, 2012 12

Revised 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 NF3 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 fire 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 of JN02

Line 13 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 99.95

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 Fire Retest of JQ03 

Line 20 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 High Fire 0.7 1 NF3 99.90

26 5/24/2004 X X 12/16/2002 1.4 2* NF3 85.33
March 6, 2012 13

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 Low fire 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 11/20/2006 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
March 6, 2012 14

Table VI: Etch Abatement Systems Measured DREs

Line 

Number Test Date

MfrZ 

Model 

C

MfrZ 

Model 

H

MfrZ

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 CH2F2 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 Retest 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 4/13/2011 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
March 6, 2012 15

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 99.25

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

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 9/12/2007 3.7 1 YES CH2F2 98.99
March 6, 2012 16

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 99.81

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
March 6, 2012 17

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 8/25/2011 X 7/17/2003 8.1 1 NO CHF3 99.72

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 NO 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
March 6, 2012 18

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 9/16/2011 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

93 12/14/2010 X tbd 2* YES C2F6 99.00

94 12/14/2010 X tbd 2* YES CHF3 99.70
March 6, 2012 19

95 7/14/2011 X tbd 2* YES CF4 82.00

96 7/14/2011 X tbd 2* YES NF3 99.70