Proposed EPA Greenhouse Gas Reporting Rule SESHA Hill Country Chapter July 21, 2009

1. Proposed EPA Greenhouse Gas Reporting Rule SESHA Hill Country Chapter July 21, 2009 Brett Jay Davis, PE Zephyr Environmental Corporation bdavis@zephyrenv.com, 512 879-6628

2. Presentation Outline • Overview of Rule • Terms and Definitions • Proposed Rules for Semiconductor Manufacturers* • Calculating Emissions • Monitoring and QA/QC Requirements • Data Reporting • Recordkeeping • Next Steps and Closing Thought * The Subpart I – Electronics Manufacturing of the rule would also apply to LCD, PV and MEMs manufacturers. Subpart OO would apply to Suppliers of Industrial Greenhouse Gases.

3. Acrynoms • Dilution Factor (DF) • Destruction and Removal Efficiency (DRE) • Fluorinated Greenhouse Gases (F-GHGs) • Greenhouse Gases (GHG) • Heat Transfer Fluids (HTF) • Metric Ton Carbon Dioxide Equivalent (mtCO2e)

4. Overview of Rule • Required by FY2008 Consolidated Appropriations Act signed by President Bush in December 2007 • Rule was promulgated pursuant to general rulemaking authority under Clean Air Act • Intended to create more robust national GHG registry, inform policy development, track GHG emissions trends and raise awareness of GHG emissions

5. Overview of Rule • Rule applies to: • Categorical reporters - “all in” at any emission or production rate • Threshold reporters - >25,000 mtCO2e • Capacity reporters - including semiconductor manufacturing at >1080 m2 silicon per year • Applicability based on actual emissions • “Once in, always in” for annual reporting

6. Semiconductor RequirementsCalculating Emissions • Emissions for the gases in Table I-1 must be calculated using prescribed equations in the rule • Utilization rates and by-product emissions factors can be from Table 1-2 or as measured using the ISMI’s Guideline for Environmental Characterization of Semiconductor Process Equipment • Measured values required for chamber cleaning and etch at >10,500 m2 silicon per year (approx. 3000 wafer/wk @ 300mm) • There are separate equations for • Fluorinated GHGs from plasma etching • Fluorinated GHGs from chamber cleaning • Nitrous oxide from chemical vapor deposition • Fluorinated GHGs from heat transfer fluid use • Combustion related emissions for CO2, N2O and CH4 must also be calculated

7. Semiconductor RequirementsCalculating Emissions TABLE I–1 F–GHGs: • CF4 • C2F6 • C3F8 • c-C4F8 • c-C4F8O • C4F6 • C5F8 • CHF3 • CH2F2 • NF3 • SF6 • HTFs (CF3-(O-CF(CF3)-CF2)n-(O-CF2)m-O-CF3, CnF2n+2, CnF2n+1(O)CmF2m+1, CnF2nO, (CnF2n+1)3N)

8. Semiconductor RequirementsCalculating Emissions TABLE I–2 - DEFAULT EMISSION FACTORS FOR SEMICONDUCTOR MANUFACTURING There is also a Table I–4 with default emissions factors for PV Manufacturing

9. Semiconductor RequirementsMonitoring and QA/QC Requirements • Monitoring of Gases • Monitor changes in container mass using scales, with accuracy of one percent of full scale or better, or • Monitor the mass flow using flowmeters, with an accuracy of one percent of full scale or better. • Abatement Device DRE • The DRE of abatement devices must be determined either • Experimentally, or • By testing by a third party, according to EPA’s Protocol. • QA/QC of Instruments • Flowmeters, scales, load cells, and volumetric and density measurement devices shall be calibrated annually using suitable standards and suitable published methods or per procedures specified by the manufacturer. • All instruments used to determine concentrations of G-GHGs shall be calibrated prior to DRE, gas utilization, or product formation measurement using certified standards.

10. Semiconductor RequirementsData Reporting All reporters must include the following information: • Facility name or supplier name (as appropriate), street address, physical address, and Federal Registry System identification number. • Year covered by the report. • Date of submittal. • Annual emissions of CO2, CH4, N2O, and each fluorinated GHG. • Total annual mass of CO2 captured in metric tons. • A signed and dated certification statement provided by the designated representative of the owner or operator,

11. Semiconductor RequirementsData Reporting Electronics manufacturers must also report: • Emissions of each GHG emitted from all plasma etching, chamber cleaning and chemical vapor deposition processes, and all HTF use. • The method used for estimating F–GHG emissions, including determination of mass of input F–GHG gases and selection of emission factors. • Production in terms of substrate surface area (e.g., silicon, PV-cell, LCD). • Factors used for gas process utilization and by-product formation, and the source and uncertainty for each factor. • The verified DRE and its uncertainty for each abatement device used. • Fraction of each gas fed into each process type with abatement devices. • Description of abatement devices, including the number of devices of each manufacturer and model. • For heat transfer fluid emissions, inputs in the mass-balance equation. • Example calculations for F–GHG, N2O and heat transfer fluid emissions. • Estimate of the overall uncertainty in the emissions estimate.

12. Semiconductor RequirementsRecordkeeping The following information is required to be kept by all reporters for five years: • A list of all units, operations, processes, and activities for which GHG emissions were calculated. • The data used to calculate the GHG emissions for each unit, operation, process, and activity, categorized by fuel or material type. • Documentation of the process used to collect the necessary data for the GHG emissions calculations. • The GHG emissions calculations and methods used. • All emission factors used for the GHG emissions calculations. • Any facility operating data or process information used for the GHG emissions calculations. • Names and documentation of key facility personnel involved in calculating and reporting the GHG emissions. • The annual GHG emissions reports. • A log book, documenting procedural changes (if any) to the GHG emissions accounting methods and changes (if any) to the instrumentation critical to GHG emissions calculations. • Missing data computations. • A written quality assurance performance plan (QAPP) .

13. Semiconductor RequirementsRecordkeeping Electronics manufacturers must also retain the following records for five years: • Data used to estimate emissions including all spreadsheets and copies of calculations used to estimate emissions. • Documentation for the values used for GHG utilization rates and by-product emission factors, including documentation that these were measured using the ISMI Guideline. • The date and results of the initial and any subsequent tests of emission control device DRE, including the following information: • Dated certification, by the technician who made the measurement, that the dilution factor was determined using the tracer method. • Dated certification, by the technician who made the measurement, that the DRE was calculated using the specified formula. • Documentation of the measured flows, concentrations and calculations used to calculate DF, relative precision (e), and DRE. • The date and results of the initial and any subsequent tests to determine process tool gas utilization and by-product formation factors. • Abatement device calibration and maintenance records.

14. Next Steps and Closing Thought Next Steps: • Monitor rule development • Conduct applicability assessment • Develop non-applicability or compliance strategy • Develop and implement data acquisition and recordkeeping systems • Capacity Reporters: Prepare for testing Closing Thought: After 20 years, the “Toxics Release Inventory” (TRI) reporting rule continues to result in emissions reductions, without any penalty or mandatory reductions provisions. Could a GHG reporting rule achieve similar results?