SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
1823.02
"
REPORTING
AND
RECORD
KEEPING
REQUIREMENTS
UNDER
THE
PFC
EMISSION
REDUCTION
PARTNERSHIP
FOR
THE
SEMICONDUCTOR
INDUSTRY"

September
6,
2001
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION.
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1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION.
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2
2(
a)
Need
and
Authority
for
the
Collection
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2
2(
b)
Practical
Utility
and
Users
of
the
Data
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3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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3
3(
a)
Nonduplication
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3
3(
b)
Public
Notice
Request
Prior
to
ICR
Submission
to
OMB
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3
3(
c)
Consultations
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3
3(
d)
Effects
of
Less
Frequent
Collection
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4
3(
e)
General
Guidelines
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4
3(
f)
Confidentiality
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5
3(
g)
Sensitive
Questions
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5
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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4(
a)
Respondents/
SIC
and
NAICS
Codes
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5
4(
b)
Information
Requested.
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5
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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5(
a)
Agency
Activities
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9
5(
b)
Collection
Methodology
and
Management.
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10
5(
c)
Small
Entity
Flexibility
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10
5(
d)
Collection
Schedule
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10
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION.
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10
6(
a)
Estimating
Respondent
Burden
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10
6(
b)
Estimating
Respondent
Costs
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11
6(
c)
Estimating
Agency
Burden
and
Cost
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12
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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12
6(
e)
Bottom
Line
Burden
Hours
and
Costs
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14
6(
f)
Reasons
for
Change
in
Burden
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14
6(
g)
Burden
Statement
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15
1
1
PFCs
are
the
most
potent
greenhouse
gases
known.
In
comparison
to
an
equivalent
amount
of
the
common
greenhouse
gas
carbon
dioxide,
PFCs
are
6,000
­
24,000
times
more
potent.
Also,
the
atmospheric
lifetimes
of
the
PFCs
range
from
2,600
to
50,000
years.
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
This
ICR
is
entitled
"
Reporting
and
Recordkeeping
Requirements
under
the
Perfluorocompound
(
PFC)
Emission
Reduction
Partnership
for
the
Semiconductor
Industry,"
EPA
ICR
number
1823.02.

1(
b)
Short
Characterization
In
April
1993,
President
Clinton
issued
the
Climate
Change
Action
Plan
(
CCAP),
which
establishes
the
nation's
commitment
to
return
U.
S.
greenhouse
gas
emissions
to
their
1990
levels
by
the
year
2000.
EPA's
PFC
Emission
Reduction
Partnership
for
the
Semiconductor
Industry
is
an
important
program
contributing
to
the
overall
reduction
in
greenhouse
gas
emissions
from
projected
2000
levels.
This
program
serves
as
an
expansion
of
Action
#
40
of
the
CCAP.
The
PFC
Emission
Reduction
Partnership
for
the
Semiconductor
Industry,
along
with
ENERGY
STAR
Buildings,
Green
Lights,
ENERGY
STAR
Computers,
and
other
similar
EPA
programs,
is
a
voluntary
effort
aimed
at
preventing
pollution
rather
than
controlling
it
after
its
creation.
These
programs
focus
on
reducing
greenhouse
gas
emissions.

The
PFC
Emission
Reduction
Partnership
for
the
Semiconductor
Industry
is
a
voluntary,
non­
regulatory
program
that
promotes
reduction
of
perfluorocompound
(
PFC)
1
emissions,
e.
g.,
perfluoromethane
(
CF
4),
perfluoroethane
(
C
2
F
6),
sulfur
hexafluoride
(
SF
6),
nitrogen
trifluoride
(
NF
3),
and
perfluoropropane
(
C
3
F
8),
from
the
semiconductor
industry.
(
A
single
hydrofluorocarbon,
trifluoromethane
(
CHF
3
)
is
included
in
the
program
with
the
PFCs
due
to
its
high
global
warming
potential.)
Semiconductor
manufacturers
participate
in
the
Partnership
with
EPA
to
make
reductions
in
the
normalized
rate
of
PFC
emissions
from
semiconductor
manufacturing
operations.
This
program
is
intended
to
decrease
atmospheric
pollution
from
greenhouse
gas
emissions.
In
turn,
EPA
agrees
to
work
with
the
industry
to
serve
as
a
clearinghouse
of
technical
information
on
successful
strategies
for
reducing
PFC
emissions
that
are
economically,
technically,
and
environmentally
sound,
conduct
preliminary
assessments
of
the
possibility
that
substitute
chemicals
are
greenhouse
gases,
publicize
Partner
Companies'
successes
in
reducing
PFC
emissions,
and
share
information
about
potential
replacement
compounds.

Participation
in
the
program
begins
with
completion
of
a
Memorandum
of
Understanding
(
MOU)
that
outlines
responsibilities
of
the
PFC
Emission
Reduction
Partnership.
This
MOU
reflects
a
voluntary
agreement
between
a
semiconductor
manufacturer
(
the
"
Partner
Company")
and
EPA
(
collectively,
the
"
Parties").
By
joining
the
Partnership,
a
Company
agrees
to
submit
a
2
Company­
specific
annual
report,
identifying
an
overall
estimate
of
PFC
emissions
and
a
normalized
PFC
emissions
rate
(
i.
e.,
amount
of
emissions
per
unit
of
production),
to
a
third
party
designated
by
the
participating
Companies.
The
MOU
also
specifies
that
the
Partner
Company
will
direct
the
designated
third
party
to
create
a
confidential
data
depository
for
the
information
supplied
by
the
Partner
Company.
In
addition,
the
MOU
states
that
the
Partner
Company
will
direct
the
designated
third
party
to
prepare
an
industry­
wide
annual
report,
to
be
submitted
to
EPA,
that
aggregates
PFC
emissions
estimates,
and
provides
each
Partner
Company's
normalized
PFC
emissions
rate
on
a
"
blind"
basis.
("
Blind"
means
company­
identifying
information
for
each
emissions
estimate
is
not
provided
to
EPA.)
The
Partner
Company
also
agrees
that
it
will
share
with
the
EPA
and
others
in
the
semiconductor
industry
information
about
successful
PFC
emission
reduction
processes
and
technologies
that
the
Partner
Company
considers
nonconfidential.
This
agreement
can
be
terminated
by
either
Party
30
days
after
the
receipt
of
written
notice
by
the
other
Party
with
no
penalties
or
continuing
obligations.

The
MOU
applies
only
to
PFC
emissions
emanating
from
the
manufacture
of
semiconductor
devices
in
the
U.
S.

2.
NEED
FOR
AND
USE
OF
THE
INFORMATION
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
The
Climate
Change
Action
Plan,
issued
by
President
Clinton
in
April
1993,
establishes
the
nation's
commitment
to
returning
U.
S.
greenhouse
gas
emissions
to
their
1990
levels.
The
PFC
Emission
Reduction
Partnership
for
the
Semiconductor
Industry
is
an
important
action
contributing
to
the
overall
reduction
of
greenhouse
gas
emissions.
The
PFC
Emission
Reduction
Partnership
also
supports
EPA's
pollution
prevention
goals.
Authority
for
collection
of
this
information
is
provided
in
Sections
7403(
a)(
1),
(
b)(
6),
and
(
g)(
1)
[
Clean
Air
Act
§
103].

EPA
has
developed
this
ICR
to
obtain
authorization
to
collect
information
from
Companies
participating
in
the
PFC
Emission
Reduction
Partnership
for
the
Semiconductor
Industry.
By
participating
in
the
program,
a
Partner
Company
agrees
to
the
terms
of
various
information
collections
specified
by
EPA
in
the
Memorandum
of
Understanding
(
MOU).
The
Partner
Company
should
submit
the
MOU
to
EPA.
In
addition,
the
Partner
Company
should
submit
to
a
designated
third
party
a
Company­
specific
annual
report
that
includes
an
overall
estimate
of
the
Partner
Company's
PFC
emissions
and
a
normalized
PFC
emissions
rate.

An
industry­
designated
third
party
aggregates
information
on
Company­
specific
PFC
emissions
into
an
industry­
wide
annual
report,
and
combined
with
information
on
Partner
Companies'
normalized
rates
of
PFC
emissions
(
submitted
on
a
blind
basis),
EPA
is
able
to
evaluate
the
overall
PFC
emission
reductions
achieved
by
the
voluntary
program.
3
Through
the
information­
sharing
provision,
the
EPA
will
collect
information
about
successful
PFC
emission
reduction
processes
and
technologies
that
participating
Partner
Companies
consider
nonconfidential.

2(
b)
Practical
Utility
and
Users
of
the
Data
The
Agency
will
use
the
MOU
to
establish
a
framework
for
a
voluntary
agreement
with
Companies
in
the
Partnership.
EPA
will
use
information
submitted
in
the
industry­
wide
annual
reports
to
demonstrate
that
Partner
Companies
are
reducing
PFC
emissions
from
semiconductor
manufacturing
operations.
EPA
also
will
use
the
information
on
an
annual
basis
to
develop
the
Inventory
of
U.
S.
Greenhouse
Gas
Emissions
and
Sinks.
The
U.
S.
government
committed
to
developing
and
maintaining
the
Inventory
under
the
United
Nations
Framework
Convention
on
Climate
Change
(
UNFCCC).
In
addition,
EPA
will
use
the
information
collected
to
evaluate
the
quantity
of
emissions
prevented
and
to
publicize
Company
and
Partnership
successes.
EPA
may
also
use
aggregated
data
to
disseminate
information
concerning
the
Partnership.
It
is
expected
that
the
industry
will
employ
this
information
to
understand
the
extent
and
rate
of
growth
of
its
PFC
emissions
in
the
U.
S.
To
further
this
process,
information
sharing
provided
by
Partner
Companies
will
be
used
by
EPA
to
publicize
new
processes
or
technologies
that
lower
emissions
rates,
and
by
the
Partner
Companies
themselves
to
improve
their
environmental
performance.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
is
not
collected
by
any
other
EPA
program
or
Federal
agency.
The
PFCs
currently
are
not
regulated
chemicals,
and
the
emissions
of
the
gases
are
not
tracked
elsewhere.
No
data
bases
are
otherwise
available
for
obtaining
this
information.

3(
b)
Public
Notice
Request
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
issued
a
public
notice
in
the
Federal
Register
[
66
FR
33680]
soliciting
public
comments
for
a
60­
day
period
ending
August
24,
2001.
EPA
received
no
public
comments
on
the
ICR
during
the
comment
period.

3(
c)
Consultations
In
the
fall
of
2000,
EPA
consulted
with
eight
Companies
in
the
PFC
Emission
Reduction
Partnership
to
obtain
feedback
on
the
burdens
and
costs
associated
with
the
Partnership's
paperwork
activities.
EPA
tried
to
ensure
that
the
Partner
Companies
contacted
were
representative
of
Companies
across
the
Partnership.
After
collecting
their
feedback,
EPA
developed
an
average
burden
and
cost
estimate
for
each
respondent
activity
in
this
ICR
and
4
incorporated
these
estimates
into
the
ICR's
burden
and
cost
calculations.
See
Section
6
of
this
ICR
for
these
calculations.

EPA
consulted
with
the
following
Partner
Companies:

NAME
OF
CONTACT
NAME
OF
ORGANIZATION
PHONE
NUMBER
Jim
Jewett
Intel
(
480)
554­
3621
Joe
Mauser
Philips
(
505)
822­
7634
Coleen
Miller
&
Tina
Gilliland
Texas
Instruments
(
512)
356­
7430
Mishelle
Noble
Dominion
Semiconductor
(
703)
396­
1120
Jamie
Rubin
Agilent
Technologies
(
970)
288­
4880
David
Sovie
Eastman
Kodak
(
716)
722­
9124
Tom
Tamayo
International
Business
Machines
(
802)
769­
4950
Diane
Van
Schoten
Advanced
Micro
Devices
(
408)
749­
2045
3(
d)
Effects
of
Less
Frequent
Collection
EPA
requests
that
the
Partner
Company
submit
information
on
its
PFC
emissions
to
the
designated
third
party
once
per
year.
The
designated
third
party
will
submit
an
industry­
wide
annual
report
to
EPA
once
per
year.
EPA
believes
that
any
reduction
in
the
frequency
of
this
information
collection
would
impede
efforts
by
EPA
to
evaluate
results
of
this
program.
In
particular,
if
information
were
submitted
less
than
once
per
year,
emission
inventories
of
greenhouse
gases
prepared
by
the
government
on
an
annual
basis
would
suffer
because
the
information
used
in
such
inventories
would
be
dated.
A
less
frequent
collection
would
not
enable
EPA
to
judge
annual
greenhouse
gas
emission
reductions
across
the
CCAP
programs
or
to
submit
an
accurate
assessment
to
the
UNFCCC.

3(
e)
General
Guidelines
This
ICR
adheres
to
the
guidelines
stated
in
the
Paperwork
Reduction
Act
of
1995,
OMB's
implementing
regulations,
OMB's
Information
Collection
Review
Handbook,
and
other
applicable
OMB
guidance.
5
3(
f)
Confidentiality
No
confidential
information
will
be
submitted
to
EPA
at
any
point
in
the
information
collection
process.
Information
submitted
to
EPA
in
the
industry­
wide
annual
report
will
be
either
aggregated
or
provided
on
a
"
blind"
basis.
Further,
data
will
be
released
by
the
designated
third
party
only
if
a
sufficient
number
of
semiconductor
companies
participates
in
the
Partnership
so
that
aggregated
emissions
data
cannot
be
correlated
back
to
an
individual
Partner
Company
or
a
small
group
of
Partner
Companies.
In
addition,
other
information
regarding
successful
PFC
reduction
strategies
shared
with
EPA
by
the
Partner
Companies
is
nonconfidential.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
or
of
matters
usually
considered
private
to
individuals
will
be
asked.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
and
NAICS
Codes
The
following
is
the
Standard
Industrial
Classification
(
SIC)
code
and
the
corresponding
North
American
Industry
Classification
System
(
NAICS)
code
associated
with
industries
most
likely
to
be
affected
by
the
information
collection
requirements
covered
under
this
ICR:

SIC
NAICS
3674
Semiconductor
and
Related
Device
Manufacturing
334413
These
SIC
and
NAICS
codes
refer
to
the
industry
respondents
for
the
Partnership.
These
SIC
and
NAICS
codes
are
applicable
because
the
Companies
in
the
Partnership
are
semiconductor
manufacturing
companies.

4(
b)
Information
Requested
Companies
participating
in
the
PFC
Emission
Reduction
Partnership
submit
a
Memorandum
of
Understanding
(
MOU)
to
the
EPA.
The
Partner
Companies
also
agree
to
submit
to
the
designated
third
party
a
Company­
specific
annual
report
that
provides
an
overall
estimate
of
PFC
emissions
and
a
normalized
PFC
emissions
rate.
The
designated
third
party
will
submit
to
EPA
an
industry­
wide
annual
report
that
provides
an
aggregated
estimate
of
PFC
emissions.
In
addition,
each
Partner
Company's
normalized
PFC
emissions
rate
will
be
reported
through
the
designated
third
party
to
EPA
on
a
"
blind"
basis.
EPA
may
review
Company­
specific
annual
reports
on
the
premises
of
the
designated
third
party,
after
the
third
party
has
removed
Company­
identifying
information.
In
addition,
by
signing
the
MOU,
Partner
Companies
agree
to
share
information
about
successful
PFC
emission
reduction
processes
with
the
EPA
and
others
in
6
the
semi­
conductor
industry.
Each
of
these
information
collections
is
described
separately
below,
along
with
the
respective
data
items
and
respondent
activities.

Memorandum
of
Understanding
A
number
of
Partner
Companies
worked
with
EPA
to
prepare
the
MOU
establishing
the
terms
of
participation
in
the
PFC
Emission
Reduction
Partnership.
After
finalizing
the
MOU,
each
Company
must
review,
sign,
and
submit
it
to
the
Agency.

(
i)
Data
Item

Memorandum
of
Understanding.

(
ii)
Respondent
Activities

Prepare
the
MOU
in
conjunction
with
EPA;


Review
and
sign
the
MOU;
and

Submit
the
MOU
to
EPA.

Company­
specific
Annual
Report
The
Partner
Company
agrees
that
it
will
prepare
a
Company­
specific
annual
report
to
be
submitted
to
the
designated
third
party.
The
report
form
requests
two
estimates
of
PFC
emissions
from
the
Partner
Company's
U.
S.
manufacturing
operations:
(
1)
an
overall
estimate
of
PFC
emissions
and
(
2)
a
normalized
PFC
emissions
rate
which
is
correlated
to
a
common
unit
of
production.
These
estimates
will
aggregate
the
emissions
of
various
types
of
PFCs
(
e.
g.,
perfluoromethane
(
CF
4),
perfluoroethane
(
C
2
F
6),
sulfur
hexafluoride
(
SF
6),
nitrogen
trifluoride
(
NF
3),
trifluoromethane
(
CHF
3),
and
perfluoropropane
(
C
3
F
8)).
The
report
form
also
requests
a
written
explanation
of
the
methodology
used
to
generate
such
estimates.
The
Partner
Company
must
submit
its
Company­
specific
annual
report,
containing
PFC
emissions
estimates
and
a
normalized
PFC
emissions
rate
for
the
previous
calendar
year,
to
the
designated
third
party
by
July
1st
of
the
subsequent
year.
Because
emissions
estimates
have
potential
competitive
significance,
they
will
be
maintained
on
a
Company­
specific
confidential
basis.

(
i)
Data
items
The
Company­
specific
annual
report
must
include
the
following
information:


The
Partner
Company
name,
name
of
a
designated
Partner
Company
representative,
contact
phone
number,
and
fax
number;


Reporting
period;


Overall
estimate
of
PFC
emissions
for
all
U.
S.
facilities
operated
by
the
Partner
Company;
7

Normalized
estimate
of
PFC
emissions;
and

Description
of
methodology
used
for
calculating
PFC
emissions
estimate.
The
following
is
to
be
included
for
the
methodology
elements:

S
Description
of
how
PFC
usage
was
determined;

S
Description
of
source
of
emissions
factors
and
how
they
were
applied;

S
Description
of
the
factors
the
Partner
Company
used
to
normalize
PFC
emissions
estimates
for
effects
of
overall
increases
in
production
and
chip
complexity;

S
Description
of
how
reductions
due
to
abatement
or
other
reduction
techniques
were
accounted
for;
and
S
An
example
calculation
(
optional).

(
ii)
Respondent
activity
°
Partner
Companies
will
complete
and
submit
to
the
designated
third
party
the
Company­
specific
annual
report
for
each
calendar
year
the
MOU
is
in
effect
(
due
July
1
of
subsequent
year).

Industry­
wide
Annual
Reports
The
designated
third
party
is
responsible
for
maintaining
the
Company­
specific
annual
reports
and
compiling
them
into
an
industry­
wide
annual
report.
The
designated
third
party
will
create
a
confidential
data
depository
containing
the
annual
reports
supplied
by
the
Partner
Companies.
The
designated
third
party
will
provide
to
EPA
an
industry­
wide
annual
report.
This
report
will
be
in
the
form
of
a
letter
to
EPA.
Based
on
the
Company­
specific
annual
reports,
the
designated
third
party
will
provide
an
aggregated,
overall
PFC
emissions
estimate.
The
designated
third
party
will
also
provide
normalized
PFC
emissions
rates
for
each
Partner
Company,
on
a
blind
basis.

The
third
party
will
make
available
to
EPA
emissions
estimates
prepared
by
the
Partner
Companies
and
the
written
explanation
of
the
methodology
used.
This
information
will
be
reviewed
by
EPA
on
the
designated
third
party's
premises.
The
designated
third
party
will
remove
Company­
identifying
information
from
such
documents
before
they
are
reviewed
by
EPA.

(
i)
Data
items
The
confidential
data
depository
will
include
the
following
information:


The
Partner
Company
name,
name
of
a
designated
Partner
Company
representative,
contact
phone
number,
and
fax
number;


Reporting
period;
8

Overall
estimate
of
PFC
emissions
for
all
U.
S.
facilities
operated
by
the
Partner
Company;


Normalized
estimate
of
PFC
emissions;
and

Description
of
methodology
used
for
calculating
PFC
emissions
estimates.

The
industry­
wide
annual
report
prepared
by
the
designated
third
party
will
include
the
following
information:


Reporting
period;


Total
number
of
participating
semiconductor
manufacturers;


Total
PFC
emissions
estimate
for
the
semiconductor
industry;
and

Normalized
rate
of
PFC
emissions.

(
ii)
Respondent
activities
In
developing
and
submitting
this
information,
the
designated
third
party
will
perform
the
following
activities:


Develop
and
update
confidential
data
depository;


Receive
Company­
specific
annual
reports
and
enter
into
confidential
data
depository;


Complete
and
submit
to
EPA
the
industry­
wide
annual
report
containing
an
aggregated
PFC
emissions
estimate
and
each
Partner
Company's
normalized
PFC
emissions
rate
on
a
blind
basis;


File
and
maintain
copies
of
annual
reports;
and

Make
emissions
estimates
and
written
explanations
of
the
methodology
prepared
by
Partner
Companies
available
to
EPA
for
review.

Information
Sharing
Each
Partner
Company
agrees
that
it
will
share
with
EPA
and
others
in
the
semiconductor
industry
information
about
successful
PFC
emission
reduction
processes
and
technologies
that
the
Partner
Company
considers
nonconfidential.

(
i)
Data
item

Documentation
describing
applicable
PFC
reduction
processes
and
technologies.

(
ii)
Respondent
activity

The
Partner
Companies
will
share
information
about
successful
PFC
emission
reduction
processes
and
technologies
by
submitting
this
information
to
EPA.
9
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
Partnership
requires
EPA
to
perform
certain
activities
associated
with
the
MOU,
the
Company­
specific
Annual
Report,
the
Industry­
wide
Annual
Report,
and
the
Information
Sharing.
Each
of
these
four
information
collections,
and
the
Agency's
activities
associated
with
them,
are
described
in
more
detail
below.

Memorandum
of
Understanding
EPA
must
perform
the
following
activities
related
to
the
MOU
for
Partner
Companies:


Develop
the
MOU
in
conjunction
with
Partner
Companies;


Disseminate
the
MOU;
and

Review
the
completed
MOU.

Company­
specific
Annual
Reports
EPA
will
perform
the
following
activities
with
regard
to
the
Company­
specific
annual
report
submitted
by
the
Partner
Company
to
the
designated
third
party:


Review
Company­
specific
annual
reports
on
the
premises
of
the
designated
third
party,
on
a
blind
basis.

Industry­
wide
Annual
Reports
EPA
will
perform
the
following
activities
with
regard
to
the
industry­
wide
annual
report
submitted
by
the
designated
third
party
to
EPA:


Receive
and
review
the
industry­
wide
annual
report;
and

File
and
maintain
copies
of
the
report.

Information
Sharing
EPA
will
perform
the
following
activities
with
respect
to
information
sharing
with
the
Partner
Company
and
the
public:


Establish
and
maintain
clearinghouse
of
technical
information
on
successful
strategies
for
reducing
PFC
emissions;
and

Provide
public
recognition
of
Partner
Companies'
achievements
in
reducing
PFC
emissions
and
for
their
public
service
in
protecting
the
environment.
10
5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
uses
electronic
equipment
such
as
personal
computers
and
applicable
data
base
software.
EPA
will
ensure
the
accuracy
and
completeness
of
collected
information
by
reviewing
each
Partner
Company's
submitted
information.
EPA
will
maintain
files
of
MOUs
and
other
reports.
Public
access
to
the
overall
annual
emission
estimate
will
be
possible
through
annual
CCAP
reporting,
EPA's
annual
Inventory
of
U.
S.
Greenhouse
Gas
Emissions
and
Sinks,
and
informational
materials
EPA
will
prepare
to
publicize
the
successes
of
the
Partnership.

EPA
is
currently
developing
an
Internet
web
page
for
this
program
that
will
facilitate
access
to
general
program
information
and
allow
interested
parties
to
download
the
MOU,
guidelines
for
estimating
emissions,
and
the
annual
report
form.

5(
c)
Small
Entity
Flexibility
EPA
has
designed
its
report
forms
to
minimize
respondent
burden
while
obtaining
sufficient
and
accurate
information.
In
addition,
the
burden
associated
with
the
Partnership
is
inherently
minimized
since
the
initial
agreement
to
participate
is
voluntary.

5(
d)
Collection
Schedule
EPA
collects
information
in
the
MOU,
which
is
completed
and
submitted
by
the
Partner
Company.
EPA
will
collect
emissions
reports
from
the
designated
third
party
on
an
annual
basis.
EPA
may
collect
other
program
information
on
a
periodic
basis
or
as
the
information
is
submitted.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
Exhibit
1
presents
the
estimated
annual
respondent
burden
and
costs
for
information
collection
activities
associated
with
the
PFC
Emission
Reduction
Partnership
for
the
Semiconductor
Industry.
The
exhibit
includes
the
number
of
hours
required
to
conduct
the
information
collection
activity
and
the
cost
associated
with
each
requirement.
In
developing
burden
estimates
for
each
information
collection
requirement
in
this
ICR,
EPA
consulted
with
Companies
in
the
Partnership.
(
See
Section
3(
c)
of
this
ICR
for
information
on
the
consultations.)
As
shown
in
Exhibit
1,
EPA
estimates
a
total
average
annual
respondent
burden
of
approximately
14,950
hours.
Assumptions
used
in
calculating
this
estimate
are
described
below.
11
6(
b)
Estimating
Respondent
Costs
Labor
Costs
EPA
estimates
respondent
labor
costs
(
hourly
rate
plus
overhead
and
fringe)
based
on
the
average
hourly
labor
rates
of
the
Partner
Companies'
and
designated
third
party's
employees,
as
applicable.
For
the
Partner
Companies,
EPA
estimates
average
hourly
labor
rates
of
$
161.61
for
legal
staff,
$
96.56
for
managerial
staff,
$
71.98
for
technical
staff,
and
$
36.18
for
clerical
staff.
These
labor
rates
are
based
on
consultations
with
eight
Partner
Companies.
For
the
designated
third
party,
which
is
currently
a
law
firm,
EPA
estimates
an
average
hourly
labor
rate
of
$
300.00
for
legal
staff
and
$
115.00
for
paralegal
staff.
No
other
labor
categories
would
be
used
in
carrying
out
its
activities.
EPA
obtained
this
feedback
from
consultation
with
the
law
firm
currently
supporting
the
Partner
Companies.
Table
1
summarizes
the
labor
rates.

Table
1:
Average
Hourly
Respondent
Labor
Rates
Type
of
Respondent
Legal
Managerial
Technical/
Paralegal
Clerical
Partner
Companies
$
161.61
$
96.56
$
71.98
$
36.18
Designated
Third
Party
$
300.00
Not
applicable
$
115.00
Not
applicable
Capital
and
Operation
and
Maintenance
(
O&
M)
Costs
The
Companies
participating
in
the
Partnership
are
not
required
to
incur
any
notable
capital
costs
under
the
Partnership
(
i.
e.,
for
analytical
equipment
used
to
develop
PFC
emissions
factors).
The
Partner
Companies'
equipment
suppliers
normally
provide
emissions
readings
to
them
as
a
standard
business
practice.
In
addition,
emissions
factors
tables
are
available
to
the
industry
through
the
Inter­
Governmental
Panel
on
Climate
Change.

Companies
participating
in
the
Partnership
may
incur
annual
operation
and
maintenance
(
O&
M)
costs.
Partner
Companies
may
incur
O&
M
costs
by
continuing
to
develop
and
operate
gas
tracking
programs,
operating
and
maintaining
analytical
equipment
to
allow
for
continued
analysis
of
emissions,
and
submitting
information
to
EPA
(
based
on
postage
costs
of
$
3.00
per
mailing).
Partner
Companies
also
may
incur
O&
M
costs
associated
with
travel
to
meetings
as
a
part
of
their
sharing
of
information.
12
6(
c)
Estimating
Agency
Burden
and
Cost
Exhibit
2
presents
the
estimated
Agency
burden
hours
and
costs
associated
with
the
information
collection
activities
for
this
ICR.
Agency
labor
costs
are
based
on
the
2000
GS
pay
schedule.
EPA
estimates
an
average
hourly
labor
cost
(
labor
plus
overhead)
of
$
65.98
for
legal
staff
(
GS­
14,
Step­
10),
$
42.14
for
managerial
staff
(
GS­
12,
Step­
6),
$
29.26
for
technical
staff
(
GS­
10,
Step­
3),
and
$
18.08
(
GS­
5,
Step­
4)
for
clerical
staff.
To
derive
hourly
estimates,
EPA
divided
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
Federal
work
year.
EPA
then
multiplied
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.
As
shown
in
Exhibit
2,
EPA
estimates
that
the
annual
Agency
burden
for
all
activities
covered
in
this
ICR
is
607
hours
at
a
total
cost
of
$
20,315.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Respondent
Burden
and
Costs
Respondent
Universe
Table
2
summarizes
the
number
of
Companies
expected
to
participate
in
the
Partnership
during
the
three­
year
effective
life
of
this
ICR.
In
total,
EPA
expects
21
Companies
to
renew
their
membership
with
the
PFC
Emissions
Reduction
Partnership
(
in
Year
1)
and
two
new
Companies
to
join
the
Partnership
during
each
year
of
this
ICR's
three­
year
effective
life.
The
following
paragraphs
discuss
the
information
collections
these
Partner
Companies
will
perform
under
the
Partnership.
Exhibit
1
calculates
the
annual
burden
and
cost
to
Partner
Companies
in
performing
these
collections.

Table
2:
Number
of
Companies
in
the
Partnership
During
the
Three­
Year
Life
of
ICR
Year
1
Year
2
Year
3
Current
Partner
Companies
21
23
25
New
Partner
Companies
2
2
2
Total
23
25
27
Memorandum
of
Understanding
As
shown
in
Table
2,
EPA
estimates
that,
over
the
three­
year
life
of
this
ICR,
27
Companies
will
participate
in
the
Partnership.
A
number
of
Companies
worked
with
EPA
to
prepare
the
Memorandum
of
Understanding
(
MOU)
establishing
the
terms
of
participation
in
the
Partnership.
Companies
then
reviewed,
signed
and
submitted
the
MOU
to
EPA
to
begin
their
13
2
EPA
and
Partner
Companies
prepared
the
MOU
in
2000.
The
next
MOU
will
be
prepared
in
2010.
participation
in
the
Partnership.
As
shown
in
Exhibit
1,
EPA
has
annualized
the
one­
time
burden
of
MOU
preparation
over
three
years
to
estimate
that
nine
Partner
Companies
will
prepare
and
submit
an
MOU
each
year.
[
Note
that
Exhibit
1
calculates
respondent
burden
and
costs
on
an
annual
basis.
The
exhibit
calculates
the
burden
and
cost
of
one­
time
activities
(
i.
e.,
activities
performed
once
during
the
three­
year
period
of
this
ICR)
by
dividing
the
total
number
of
respondents
by
three
(
e.
g.,
27
Partner
Companies
/
3
years
=
9
Partner
Companies
per
year).
2]

Company­
Specific
Annual
Report
Each
Partner
Company
agrees
to
prepare
a
Company­
specific
annual
report
to
be
submitted
to
the
designated
third
party.
The
report
will
contain
PFC
emissions
estimates
and
a
normalized
PFC
emissions
rate
for
the
previous
calendar
year.
In
estimating
burden
and
costs
for
this
information
collection,
EPA
believes
that
Companies
new
to
the
Partnership
(
i.
e.,
2
each
year)
will
incur
a
greater
burden
in
preparing
their
first
report
(
i.
e.,
for
their
first
year
of
membership),
than
in
preparing
reports
for
their
subsequent
years
of
membership.
That
is,
Companies
new
to
the
Partnership
may
encounter
a
one­
time
learning
curve
in
compiling
and
examining
data
for
their
"
first­
year"
reports.
After
gaining
such
experience,
these
Partner
Companies
would
likely
incur
a
lower
burden
in
preparing
their
"
subsequent­
year"
reports.

As
shown
in
Exhibit
1,
EPA
estimates
that
two
Companies
each
year
will
be
new
to
the
Partnership
and
that
each
will
incur,
on
average,
about
637
hours
in
preparing
and
submitting
their
first­
year
reports
to
the
designated
third
party.
EPA
further
estimates
that,
over
the
threeyear
life
of
this
ICR,
23
Partner
Companies
on
average
will
submit
subsequent­
year
reports
to
the
designated
third
party
each
year
and
incur,
on
average,
about
292
hours
per
report.

Industry­
wide
Annual
Report
The
designated
third
party
will
be
responsible
for
receiving
and
tracking
the
Companyspecific
annual
reports
and
compiling
them
into
an
industry­
wide
annual
report.
The
designated
third
party
will
create
and
update
a
confidential
data
depository
containing
the
annual
reports
supplied
by
the
Partner
Companies.
The
designated
third
party
will
provide
to
EPA
an
industrywide
annual
report.
Based
on
the
Company­
specific
annual
reports,
the
designated
third
party
will
provide
an
aggregated,
overall
PFC
emissions
estimate.
The
designated
third
party
will
also
provide
normalized
PFC
emissions
rates
for
each
Partner
Company,
on
a
blind
basis.

In
addition,
the
designated
third
party
will
make
available
to
EPA
emissions
estimates
prepared
by
the
Partner
Companies
and
the
written
explanation
of
the
methodology
used.
This
information
also
will
be
maintained
on
site
by
the
designated
third
party
and
reviewed
by
EPA
on
the
designated
third
party's
premises.

These
assumptions
are
reflected
in
Exhibit
1.
14
Information
Sharing
The
Companies
participating
in
the
Partnership
agree
to
share
with
EPA
information
about
successful
PFC
emission
reduction
processes
and
technologies
that
the
Partner
Companies
consider
nonconfidential,
and
will
share
such
nonconfidential
information
with
others
in
the
semiconductor
industry.
Partner
Companies
may
incur
burden
and
costs
for
attending
meetings
(
including
travel
and
lodging
costs),
participating
in
teleconferences
with
EPA
and
industry,
and
other
outreach
efforts.
EPA
estimates
that
an
average
of
25
Partner
Companies
will
share
information
each
year.
These
assumptions
are
reflected
in
Exhibit
1.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Respondent
Tally
In
Exhibit
1,
EPA
estimates
the
total
annual
respondent
burden
and
cost
for
the
PFC
Emission
Reduction
Partnership
to
be
approximately
14,950
hours
and
$
1,275,143.
The
bottom
line
respondent
burden
over
the
three­
year
period
covered
by
this
ICR
is
approximately
44,850
hours,
at
a
total
cost
of
approximately
$
3,825,429.

Agency
Tally
As
shown
in
Exhibit
2,
the
annual
Agency
burden
and
cost
are
estimated
to
be
approximately
607
hours
and
$
20,315
per
year.
The
bottom
line
Agency
burden
over
the
three­
year
period
covered
by
this
ICR
is
approximately
1,821
hours,
at
a
total
cost
of
approximately
$
60,945.

Variations
in
the
Annual
Bottom
Line
EPA
anticipates
no
significant
variation
in
the
annual
respondent
reporting
and/
or
recordkeeping
burden
over
the
next
three
years.

6(
f)
Reasons
for
Change
in
Burden
The
number
of
burden
hours
has
changed
from
the
previous
ICR
because
the
number
of
Companies
in
the
Partnership
has
decreased
from
30
to
27.
In
addition,
the
previous
ICR
did
not
include
respondent
burden
hours
for
the
Partner
Companies
to
prepare
the
MOU
or
for
the
designated
third
party
to
compile
the
industry­
wide
annual
report.
This
ICR
incorporates
burden
hours
for
these
activities.

6(
g)
Burden
Statement
The
annual
reporting
burden
for
this
information
collection
is
estimated
to
range
from
about
566
to
911
hours
per
Partner
Company.
This
burden
includes
time
for
completing
the
15
MOU
(
one­
time
activity)
and
the
Company­
specific
annual
report
and
for
sharing
information
with
the
public.
There
is
no
recordkeeping
burden
for
Partner
Companies.
The
annual
reporting
burden
is
estimated
to
be
about
eight
hours
for
the
designated
third
party.
This
burden
includes
time
for
preparing
and
submitting
the
industry­
wide
annual
report
and
making
emissions
data
available
to
EPA.
The
annual
recordkeeping
burden
to
the
designated
third
party
is
estimated
to
be
about
46
hours.
This
burden
includes
time
for
developing/
updating
the
data
depository,
receiving
and
entering
Company­
specific
reports
into
the
depository,
and
filing
and
maintaining
copies
of
Company­
specific
annual
reports.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
1.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2137),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1823.02
and
OMB
control
number
2060­
0382
in
any
correspondence.
16
EXHIBIT
1
PFC
EMISSION
REDUCTION
PARTNERSHIP
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
INFORMATION
COLLECTION
ACTIVITY
Legal
Manager
Technical/

Paralegal
Clerical
Respon.

Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Cost
O&
M
Cost
Number
of
Respon.
or
Activities
Total
Hours/

Year
Total
Cost/

Year
Memorandum
of
Understanding
Work
with
EPA
to
prepare
MOU
6.23
10.50
35.63
0.00
52.36
$
4,585.36
$
0.00
$
0.00
9
471.24
$
41,268.22
Review
and
sign
MOU
2.08
3.50
11.88
0.00
17.46
$
1,529.23
$
0.00
$
0.00
9
157.14
$
13,763.08
Submit
the
MOU
to
EPA
0.00
0.00
0.00
0.20
0.20
$
7.24
$
0.00
$
3.00
9
1.80
$
92.12
Subtotal
8.31
14.00
47.51
0.20
70.02
$
6,121.82
$
0.00
$
3.00
9
630.18
$
55,123.42
Company­
specific
Annual
Report
Complete
and
submit
first
Company­
specific
annual
report
0.25
81.56
502.30
52.50
636.61
$
45,970.84
$
0.00
$
2,164.00
2
1,273.22
$
96,269.68
Complete
and
submit
subsequent
Company­
specific
annual
reports
0.25
34.40
241.30
16.00
291.95
$
21,309.72
$
0.00
$
2,164.00
23
6,714.85
$
539,895.57
Subtotal
0.00
varies
varies
varies
varies
varies
$
0.00
varies
varies
7,988.07
$
636,165.25
Industry­
wide
Annual
Report
Develop/
update
data
depository
1.00
0.00
5.00
0.00
6.00
$
875.00
$
0.00
$
0.00
1
6.00
$
875.00
Receive
Company
specific
annual
reports
and
enter
into
data
depository
15.00
0.00
15.00
0.00
30.00
$
6,225.00
$
0.00
$
0.00
1
30.00
$
6,225.00
Complete
and
submit
Industry­
wide
annual
report
2.00
0.00
2.00
0.00
4.00
$
830.00
$
0.00
$
0.00
1
4.00
$
830.00
File
and
maintain
copies
of
annual
reports
0.00
0.00
10.00
0.00
10.00
$
1,150.00
$
0.00
$
0.00
1
10.00
$
1,150.00
Make
emissions
estimates
and
written
explanations
of
the
methodology
prepared
by
Companies
available
to
EPA
for
review
2.00
0.00
2.00
0.00
4.00
$
830.00
$
0.00
$
0.00
1
4.00
$
830.00
Subtotal
20.00
0.00
34.00
0.00
54.00
$
9,910.00
$
0.00
$
0.00
1
54.00
$
9,910.00
Information
Sharing
Share
information
about
successful
PFC
reduction
processes
and
technologies
6.25
44.44
196.40
4.00
251.09
$
19,582.78
$
0.00
$
3,375.00
25
6,277.25
$
573,944.52
Subtotal
6.25
44.44
196.40
4.00
251.09
$
19,582.78
$
0.00
$
3,375.00
25
6,277.25
$
573,944.52
TOTAL
varies
varies
varies
varies
varies
varies
varies
varies
varies
14,949.50
$
1,275,143.20
17
EXHIBIT
2
PFC
EMISSION
REDUCTION
PARTNERSHIP
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
INFORMATION
COLLECTION
ACTIVITY
Legal
Manager
Technical
Clerical
Agency
Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Cost
O&
M
Cost
Number
of
Respon.
or
Activities
Total
Hours/

Year
Total
Cost/

Year
Memorandum
of
Understanding
Develop
the
MOU
4.00
60.00
40.00
24.00
128.00
$
4,396.64
$
0.00
$
0.00
0.33
42.24
$
1,450.89
Disseminate
the
MOU
0.00
0.00
0.00
1.00
1.00
$
18.08
$
0.00
$
0.00
9
9.00
$
162.72
Review
the
completed
MOU
0.00
4.00
4.00
0.00
8.00
$
285.60
$
0.00
$
0.00
9
72.00
$
2,570.40
Subtotal
varies
varies
varies
varies
varies
$
4,700.32
varies
varies
varies
123.24
$
4,184.01
Company­
specific
Annual
Report
Review
Company­
specific
annual
reports
on
premises
of
designated
law
firm
0.00
8.00
4.00
0.00
12.00
$
454.16
$
0.00
$
0.00
25
300.00
$
11,354.00
Subtotal
varies
varies
varies
varies
varies
$
454.16
varies
varies
varies
300.00
$
11,354.00
Industry­
wide
Annual
Report
Receive
and
review
industry­
wide
annual
report
0.00
40.00
8.00
0.00
48.00
$
1,919.68
$
0.00
$
0.00
1
48.00
$
1,919.68
File
and
maintain
copies
of
annual
report
0.00
0.00
0.00
0.25
0.25
$
4.52
$
1.90
$
0.00
1
0.25
$
6.42
Subtotal
varies
varies
varies
varies
varies
$
1,924.20
varies
varies
varies
48.25
$
1,926.10
Information
Sharing
Establish
and
maintain
clearinghouse
of
technical
information
0.00
40.00
28.00
0.00
68.00
$
2,504.88
$
0.00
$
0.00
1.00
68.00
$
2,504.88
Provide
public
recognition
of
Companies'

achievements
0.00
40.00
28.00
0.00
68.00
$
2,504.88
$
0.00
$
0.00
1.00
68.00
$
345.92
Subtotal
varies
varies
varies
varies
varies
$
5,009.76
varies
varies
varies
136.00
$
2,850.80
TOTAL
varies
varies
varies
varies
varies
$
12,088.44
varies
varies
varies
607.49
$
20,314.91
NOTE:
Certain
values
which
refer
to
a
quantity
of
persons
working
on
a
task
are
expressed
in
decimals.

This
is
a
result
of
converting
data
covering
the
period
of
the
ICR
(
3
years)
into
an
annual
estimate.
