### 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

rep resent s 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/analys es and has enough information to support a new rulemaking to add ress 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 extensi ve

additional analysis or work, please l et 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 invento ry 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

, Mfr T and MfrV

.

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

units at US fabs. W

e have captured additional information from two device manufacturers to

complete their inventories . We also determined that for the uni n ventorie d 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 u nits 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

% M fr Y 13. 1%

% MfrW

, M fr T

, 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 industr y level DREs

. Setting

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

o t he tested units are represent ative of over 6 8 % of the inventorie d abatement unit s,

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 t he 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 revi ew, 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 page s 4 and 7, SIA indicates that in the testing, the abatement DRE test results for

some CF 4 

## and NF 3 

## 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 opera tions and maintenance procedures

needed to be revised to achieve the expected CF 4 

## DREs.

a. Can SIA explain why the CF 4 

## and NF 3 

## DRE s 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 provide s 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 Contro llers 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 tha n expecte d 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 d esign 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 i n 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 V I I 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 determ ine whether a retest needed to

occur?

Retests were done where abatement units were p erforming 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 dis cussed 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 th e average DRE in

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

e ach uni t as they are making significant investments in capital and operating expense for the

units. The need for retesting should be left to the de vice 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 investmen t 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 meth od/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 Fluori nated 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 wer e

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 meth od. 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 met hod 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. SI A has attached the report

“Compa rison 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 S ubpart I. This method is more e fficient, 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 Manufacturi ng March 2010”

.

In addition, t he modifications to Su b part I should also set broad criteria, similar to that found in

Subpart L 98.124(e)(1) & (2) , that assur es 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 ga ses for which DREs were me asured?

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

chamb er

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 i ndicate 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

conclus ions 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 publish ed, 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 be low 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 meas urements available for C 4 

## F 8 

## etch and 22

measurements available for NF 3 

## in

- situ plasma chamber clean. However in tables VI and

VII respectively, in Appendix B, there are only 14 measurements for C 4 

## F 8 

## etch and 21

measurements for NF 3 

## in

- situ plasma respectiv ely. Can SIA please clarify why these

numbers do not match?

Response

. A. Table B

- 1 was wrong in regard to the C 4 

## F 8 

## etch measurements and a corrected

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

inadver tently grouped C 4 

## F 6 

## and C

4 

## F 8 

## into a single entry labeled C 4 

## F 8 

## 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 C 4 

## F 6 

## further supports the conclusion that

consistently high DREs are achieved on average for the F

- gases used in etch, with the exception

of CF 4



## .

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 (Excl uding 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 CF 4 

## , 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 individu al gases. Test

data exist to support this conclusion for NF 3 

## , SF 6 

## 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 A batement Systems. Columns 1 and 2 give the

specifications for MfrZ etch abatement devices in the SIA database.



## B. In regard to the measurements for NF 3 

## 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 s pecific “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 NF 3 

## used in chamber cleaning, the relevant inventory is that for devices abating NF 3 

## from chamber

### March 6, 2012 8



## cleaning processes. This category

- specific inventory multiplied by the percentages specified in

steps 1 an d 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 wo uld 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 proces s:

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) Abatem ent 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

in ventory 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

w ill 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, th ey 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 revisio ns to equations I

- 14 and I

- 15 in subpart I based on

SIA’s DRE data ?

Equation I

- 14 should be modified as follows:

D ip 

### = d ip 

### * U ipT 

### where:

D ip = 

### The fraction of the input gas consumed by abatement units.

d ip 

### = Industry level or site specific abateme nt system DRE for the process type/gas combination.

U ipT 

### = 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 pape r 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 proces s

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 apportio ning 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 categori es 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 f ollows:

U ip d T 

### = ( 1

– T ip dT 

### / T opsT 

### ) where:



## U ipT 

### : the total uptime

, expressed as a fraction

, of all of the abatement system s abating a given process

type/gas combination.

T ip d T 

### : the total time, in minutes, that all of the abatement system s abating a given process type/gas

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

T io ps: T 

### : The total n umber of minutes in the year times the number of abatement units for a given

process/gas type . Where a tool and its a ssociated 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 availabl e 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 in stalled and available for use.

T = Total time

F abs 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

allo w 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 iss ue with re porting 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 requ irements 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 re quire 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 d ata 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 aba tement

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 gase s 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 unit s 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 numbe r 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 em issions (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 re flect 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 Fi re 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 L ow 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 6/27/20 07 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 L ow fire 9.1 1 NF3 94.08

36 5/10/2011 X X 4/7/2003 Lo w f ire 8.1 1 NF3 84.60

37 5/17/2011 X X 3/26/2003 L ow 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 6/11/200 7 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 2/26/200 7 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 Mfr Z

Model

O MfrT

Model

B Date of

Installation Comments Device

Age

Yrs USEPA

Test

Method POU Input

Gas DRE

1 9/7/2011 X 9/13/20 04 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 4 9.01

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 YE S 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 5/26/2 011 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 8/18/20 11 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