SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
1823.03
A
REPORTING
AND
RECORD
KEEPING
REQUIREMENTS
UNDER
THE
PFC
REDUCTION/
CLIMATE
PARTNERSHIP
FOR
THE
SEMICONDUCTOR
INDUSTRY@

November
12,
2004
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION          ..
.
.1
1(
a)
Title
of
the
Information
Collection...................................................................................
1
1(
b)
Short
Characterization.....................................................................................................
1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION.
               .
.
2
2(
a)
Need
and
Authority
for
the
Collection..............................................................................
2
2(
b)
Practical
Utility
and
Users
of
the
Data..............................................................................
2
2(
c)
Assessment
of
Partnership=
s
Achievements.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
. ..
.3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA                  ...            
5
3(
a)
Nonduplication
................................................................................................................
5
3(
b)
Public
Notice
Request
Prior
to
ICR
Submission
to
OMB.................................................
5
3(
c)
Consultations...................................................................................................................
5
3(
d)
Effects
of
Less
Frequent
Collection..................................................................................
6
3(
e)
General
Guidelines...........................................................................................................
6
3(
f)
Confidentiality
.................................................................................................................
6
3(
g)
Sensitive
Questions..........................................................................................................
7
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED      ..
.
.
.
.
.
.7
4(
a)
Respondents/
SIC
and
NAICS
Codes................................................................................
7
4(
b)
Information
Requested.....................................................................................................
7
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
10
5(
a)
Agency
Activities...........................................................................................................
11
5(
b)
Collection
Methodology
and
Management.
....................................................................
11
5(
c)
Small
Entity
Flexibility...................................................................................................
11
5(
d)
Collection
Schedule
.......................................................................................................
11
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION.
.
.
.
.
.
.
.
.
.
.
.
12
6(
a)
Estimating
Respondent
Burden......................................................................................
12
6(
b)
Estimating
Respondent
Costs.........................................................................................
12
6(
c)
Estimating
Agency
Burden
and
Cost
..............................................................................
13
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
..................................
13
6(
e)
Bottom
Line
Burden
Hours
and
Costs
...........................................................................
14
6(
f)
Reasons
for
Change
in
Burden.......................................................................................
15
6(
g)
Burden
Statement
..........................................................................................................
15
1
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)
Reduction/
Climate
Partnership
for
the
Semiconductor
Industry,"
EPA
ICR
number
1823.03.

1(
b)
Short
Characterization
In
April
1993,
President
Clinton
issued
the
Climate
Change
Action
Plan
(
CCAP),
which
established
the
Nation=
s
commitment
to
return
U.
S.
greenhouse
gas
emissions
to
their
1990
levels
by
the
year
2000.
EPA=
s
PFC
Reduction/
Climate
Partnership
for
the
Semiconductor
Industry
is
an
important
program
contributing
to
the
overall
reduction
in
greenhouse
gas
emissions
from
projected
2010
levels.
The
semiconductor
industry
partnership,
along
with
EPA=
s
ENERGY
STARJ
programs
and
the
Voluntary
Aluminum
Industrial
Partnership(
VAIP)
are
voluntary
initiatives
seeking
to
reduce
greenhouse
gas
emissions
using
a
pollution
prevention
approach.

The
PFC
Reduction/
Climate
Partnership
for
the
Semiconductor
Industry
is
a
voluntary
program
that
promotes
reduction
of
perfluorocompound
(
PFC)
1
emissions,
e.
g.,
perfluoromethane
(
CF4),
perfluoroethane
(
C2F6),
sulfur
hexafluoride
(
SF6),
nitrogen
trifluoride
(
NF3),
and
perfluoropropane
(
C3F8),
from
semiconductor
manufacturing.
(
A
single
hydrofluorocarbon,
trifluoromethane
(
CHF3
)
is
included
in
the
program
with
the
PFCs
due
to
its
high
global
warming
potential.)
EPA=
s
semiconductor
industry
partners
have
committed
to
reduce
their
PFC
emissions
10
percent
below
their
1995
baseline
level.
As
a
partner
to
the
industry,
EPA
serves
as
a
clearinghouse
of
technical
information
on
successful
strategies
for
reducing
PFC
emissions
that
are
economically,
technically,
and
environmentally
sound.
EPA
also
helps
assess
the
global
warming
potential
of
potential
substitute
chemicals
and
publicly
recognizes
the
partner
companies=
achievements.

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.
2
Participation
in
the
program
begins
with
completion
of
a
Memorandum
of
Understanding
(
MOU)
that
outlines
responsibilities
of
the
PFC
Reduction/
Climate
Partnership.
This
MOU
reflects
a
voluntary
agreement
between
a
semiconductor
manufacturer
(
the
APartner
Company@)
and
EPA
(
collectively,
the
AParties@).
By
joining
the
Partnership,
a
Company
agrees
to
submit
a
Company­
specific
annual
report,
identifying
an
overall
estimate
of
PFC
emissions
by
gas,
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
annual
emissions
by
gas
on
a
Ablind@
or
anonymous
basis.
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
applies
only
to
PFC
emissions
originating
from
U.
S.
semiconductor
manufacturing
sites
and
can
be
terminated
by
either
Party
30
days
after
the
receipt
of
written
notice
by
the
other
Party
with
no
penalties
or
continuing
obligations.

2.
NEED
FOR
AND
USE
OF
THE
INFORMATION
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
President
Bush
launched
the
Climate
VISION
initiative
in
February
2003
as
part
of
his
plan
to
reduce
the
national
greenhouse
gas
intensity
(
the
amount
of
greenhouse
gases
emitted
per
dollar
of
GDP)
by
18
percent
over
10
years.
EPA=
s
semiconductor
industry
partners
are
contributing
to
the
Climate
VISION=
s
efforts
to
reduce
U.
S.
greenhouse
gas
emissions
by
striving
to
reduce
their
absolute
PFC
emissions
10
percent
below
their
1995
baseline
level
(
see
www.
climatevision.
gov/
sectors/
semiconductors).
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
Reduction/
Climate
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
submits
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
by
gas
type.

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=
PFC
emissions
(
submitted
on
a
blind
basis),
EPA
is
able
to
evaluate
the
overall
PFC
3
emission
reductions
achieved
by
the
voluntary
program.
The
MOU=
s
information­
sharing
provision
allows
EPA
to
collect
and
share
information
about
successful
PFC
emission
reduction
processes
and
technologies
that
Partner
Companies
consider
nonconfidential.

2(
b)
Practical
Utility
and
Users
of
the
Data
The
Agency
has
used
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
reduce
emissions,
and
by
the
Partner
Companies
themselves
to
improve
their
environmental
performance.

2(
c)
Assessment
of
Partnership=
s
Achievements
In
2001,
OMB
requested
EPA
to
evaluate
the
extent
to
which
the
Partner
Companies
would
have
reduced
their
PFC
emissions
in
the
absence
of
the
Partnership.
EPA
constructed
a
top­
down
vintage
model
to
better
understand
the
industry=
s
diverse
and
dynamic
manufacturing
technologies
and
estimate
the
U.
S.
industry=
s
Abusiness
as
usual@
(
BAU)
PFC
emissions.

When
estimating
air
emissions
from
any
source,
it
is
customary
practice
to
express
the
emissions
as
a
product
of
two
factors:
an
emissions
factor,
expressed
as
emissions
per
unit
of
activity
and
an
activity
factor,
expressed
in
this
case
as
a
quantity
of
silicon
consumed
during
semiconductor
manufacture.
EPA=
s
PFC
Emissions
Vintage
Model
(
PEVM)
derives
its
PFC
emissions
factor
from
the
Partners=
annual
reports
and
U.
S.
silicon
consumption
is
derived
from
reports
and
projections
provided
by
VLSI
Research
(
www.
vlsiresearch.
com).

Figure
1
near
the
end
of
this
document
depicts
the
Partners=
actual
PFC
emissions
through
2003
as
compared
to
expected
BAU
emissions.
Figure
1
also
presents
the
estimated
reduction
of
the
partners=
BAU
emissions
attributable
to
the
advent
and
adoption
of
copper
interconnects.
A
full
description
of
EPA=
s
PEVM
used
to
estimate
BAU
emissions
with
and
without
copper
interconnects
is
available
at
www.
epa.
gov/
semiconductor­
pfc/
resources.
html.

Copper
interconnect
technology
evolved
since
the
inception
of
the
partnership
in
1996
and
was
designed
primarily
to
enable
faster
and
smaller
products.
The
smaller
less
resistive
4
interconnects
have
also
delivered
the
added
benefit
of
reducing
the
number
of
PFC
emitting
process
steps.
EPA
has
determined
that
the
copper
interconnect
is
the
only
new
manufacturing
technology
developed
to
date
without
the
Partnership's
influence
that
reduces
the
semiconductor
industry=
s
PFC
emissions
intensity.

The
Partner
Companies
have
identified
and
are
implementing
several
other
new
manufacturing
technologies
and
process
improvements
aimed
at
significantly
improving
their
environmental
performance.
In
response
to
EPA's
voluntary
initiative,
the
Partner
Companies
and
their
material
suppliers
have
developed
new
production
technologies
including:

$
remote
NF3
plasma
cleaning
for
chemical
vapor
deposition
(
CVD)
chambers,

$
process
optimizations,

$
alternative
chemicals,
and
$
advanced
PFC
emissions
abatement
devices.

Remote
NF3
chamber
cleaning
reduces
PFC
emissions
by
greater
than
99
percent
as
compared
to
the
traditional
C
2
F
6
cleaning
process.
This
technology
is
now
found
on
all
new
CVD
equipment
sold
in
the
U.
S.
and
is
being
retrofitted
to
existing
equipment
by
some
Partner
Companies.

In
addition,
Partner
Companies
have
revisited
their
established
manufacturing
processes
and
successfully
adjusted
their
production
process
Arecipes@
(
i.
e.,
parameters
such
as
the
PFC
gas
flow
rates,
plasma
power,
and
pressure)
to
reduce
PFC
use.
The
Partners
have
also
improved
the
equipment=
s
ability
to
detect
the
process
endpoint
and
thus
ensure
PFC
gas
flow
delivery
only
when
necessary.
These
types
of
process
optimizations
have
reduced
PFC
emissions
and
in
some
cases
improved
throughput
thereby
delivering
the
added
benefit
of
increased
productivity.

EPA=
s
Semiconductor
Partnership
and
its
aggressive
PFC
emission
reduction
goal
have
sent
a
clear
message
to
the
industry=
s
equipment
and
chemical
suppliers.
The
industry=
s
suppliers
are
responding
by
designing
new
chemicals
with
lower
global
warming
impact
and
improved
abatement
devices
that
can
neutralize
PFC
emissions
before
being
exhausted
to
the
atmosphere.
For
example,
prior
to
the
Partnership,
the
industry=
s
abatement
devices
were
designed
to
control
regulated
criteria
pollutants
but
these
devices
would
not
destroy
the
very
stable
and
non­
reactive
PFC
gases.
Today,
equipment
suppliers
offer
a
menu
of
abatement
options
capable
of
controlling
regulated
pollutants
and
PFC
emissions
in
one
device.
Many
Partner
Companies
are
choosing
to
upgrade
their
abatement
systems
to
address
PFC
emissions
and
most
new
fabrication
facilities
are
completely
outfitted
with
the
cleaner
advanced
technologies.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
5
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
is
not
collected
by
any
other
EPA
program
or
Federal
agency.
The
PFCs
are
not
currently
regulated
chemicals,
and
the
emissions
of
the
gases
are
not
tracked
elsewhere.
No
databases
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
[
August
23,
2004
Vol.
69,
Number
162,
Page
51831­
51832]
soliciting
public
comments
for
a
60­
day
period
ending
October
22,
2004.
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
Reduction/
Climate
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
incorporated
these
estimates
into
the
ICR=
s
burden
and
cost
calculations.
The
Partnership=
s
composition
and
responsibilities
have
not
changed
significantly
since
2000.
Therefore,
EPA
has
not
adjusted
the
burden
estimates
for
the
partnership=
s
activities.
EPA
has
adjusted
the
compensation
level
for
the
labor
categories
using
Department
of
Labor
statistics.
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
6
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
track
annual
greenhouse
gas
emission
reductions
for
the
Climate
VISION
initiative
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.

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
Ablind@
basis.
Further,
data
will
be
released
by
the
designated
third
party
only
if
a
sufficient
number
of
semiconductor
companies
participate
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.
7
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
Reduction/
Climate
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
by
individual
gas
type.
The
designated
third
party
will
submit
to
EPA
an
industry­
wide
annual
report
that
provides
an
aggregated
estimate
of
PFC
emissions.
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
the
semiconductor
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
Reduction/
Climate
Partnership.
After
reviewing
the
MOU,
each
Company
must
sign
and
submit
it
to
the
Agency.
There
are
currently
24
semiconductor
manufacturers
representing
80
percent
of
the
U.
S.
industry
participating
in
the
partnership.
All
24
companies
have
already
reviewed
and
signed
MOUs
with
EPA.
EPA
is
not
actively
recruiting
new
partners
so
the
MOU
activities
and
associated
burden
estimates
have
been
removed
from
this
ICR
renewal.
8
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
partners
agree
to
report
an
estimate
of
PFC
emissions
by
specific
gas
type
(
e.
g.,
perfluoromethane
(
CF4),
perfluoroethane
(
C2F6),
sulfur
hexafluoride
(
SF6),
nitrogen
trifluoride
(
NF3),
trifluoromethane
(
CHF3),
and
perfluoropropane
(
C3F8)).
The
partner=
s
report
may
also
include
a
written
explanation
of
the
methodology
used
to
generate
such
estimates.
The
Partner
Company
must
submit
its
Company­
specific
annual
PFC
emissions
report
to
the
designated
third
party
by
April
15
of
each
year
for
the
previous
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;


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

$
Description
of
how
PFC
usage
was
determined;

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

$
Description
of
how
reductions
due
to
abatement
or
other
reduction
techniques
were
accounted
for;
and
$
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
April
15
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
9
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,
partnership
report
estimating
PFC
emissions
by
gas.

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;


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


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;
and

Total
PFC
emissions
estimate
for
the
semiconductor
industry
partnership.

(
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;


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
10
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.

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
Companyspecific
Annual
Report,
the
Industry­
wide
Annual
Report,
and
the
Information
Sharing.
Each
of
these
three
ongoing
information
collections,
and
the
Agency=
s
activities
associated
with
them,
are
described
in
more
detail
below.

Memorandum
of
Understanding
EPA
developed
an
MOU
in
cooperation
its
industry
partners
and
has
signed
agreements
with
the
majority
of
the
U.
S.
industry.
EPA
does
not
expect
to
take
any
further
actions
related
to
the
partnership=
s
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
11
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.

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
database
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
EPA=
s
partnership
Internet
web
site
(
www.
epa.
gov/
semiconductor­
pfc),
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.

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
receive
the
Partnership=
s
emissions
report
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.
12
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
Reduction/
Climate
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
current
Partner
Companies.
(
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
13,266
hours.
Assumptions
used
in
calculating
this
estimate
are
described
below.

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
$
107.10
for
legal
staff,
$
94.21
for
managerial
staff,
$
73.85
for
technical
staff,
and
$
33.02
for
clerical
staff.
These
labor
rates
are
based
on
consultations
with
eight
Partner
Companies
and
adjusted
for
growth
in
employee
compensation
from
2001
to
first
quarter
of
20042.
Table
1
summarizes
the
labor
rates.

Table
1:
Average
Hourly
Respondent
Labor
Rates
Type
of
Respondent
Legal
Managerial
Technical
Clerical
Partner
Companies
$
107.10
$
94.21
$
73.85
$
33.02
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
2U.
S.
employee
compensation
costs
grew
by
19
percent
from
2001
to
Q1
2004.
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics:
www.
bls.
gov,
2004.
13
them
as
a
standard
business
practice.
In
addition,
emissions
factors
tables
are
available
to
the
industry
through
the
Intergovernmental
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.

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
2004
GS
pay
schedule
multiplied
by
1.6
to
estimate
total
salary
plus
benefits.
EPA
estimates
an
average
hourly
labor
cost
of
$
67.04
for
legal
staff
(
GS­
15),
$
56.99
for
managerial
staff
(
GS­
14),
$
48.22
for
technical
staff
(
GS­
13),
and
$
22.86
(
GS­
7)
for
clerical
staff.
As
shown
in
Exhibit
2,
EPA
estimates
that
the
annual
Agency
burden
for
all
activities
covered
in
this
ICR
is
227
hours
at
a
total
cost
of
$
11,815.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Respondent
Burden
and
Costs
Respondent
Universe
EPA
expects
the
current
24
Partner
Companies
to
maintain
their
active
participation
for
the
three­
year
effective
life
of
this
ICR
renewal.
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.

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
provide
an
estimate
of
the
company=
s
PFC
emissions
by
gas
for
the
previous
calendar
year.
Most
of
EPA=
s
current
Partner
Companies
have
participated
and
prepared
annual
reports
since
1999.
As
shown
in
Exhibit
1,
EPA
estimates
that
Partner
Companies
will
require
290.5
hours
to
prepare
and
submit
the
annual
reports
to
the
designated
third
party.
14
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.

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
activities
are
reflected
in
Exhibit
1.

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
the
all
24
Partner
Companies
will
share
information
each
year.
The
Partners=
expected
activities
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
13,050
hours
and
$
1,253,982.
The
bottom
line
respondent
burden
over
the
three­
year
period
covered
by
this
ICR
is
approximately
39,150
hours,
at
a
total
cost
of
approximately
$
3,761,946.
The
total
annual
capital
and
O&
M
costs
for
the
partnership
are
estimated
to
be
$
132,936
per
year.

Agency
Tally
As
shown
in
Exhibit
2,
the
annual
Agency
burden
and
cost
are
estimated
to
be
approximately
227
hours
and
$
11,815
per
year.
The
bottom
line
Agency
burden
over
the
three­
year
period
covered
by
this
ICR
is
approximately
681
hours,
at
a
total
cost
of
approximately
$
35,445.
15
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
no
new
partners
are
expected
to
review
and
sign
MOUs
with
EPA.
The
number
of
Companies
in
the
Partnership
is
expected
to
remain
stable
at
24.
This
ICR
has
removed
burden
hours
associated
with
the
MOU
activities.

6(
g)
Burden
Statement
The
annual
public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
542
hours
per
Partner
Company.
There
is
no
recordkeeping
burden
for
Partners.
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
updating
and
maintaining
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
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2004­
0228,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
is
16
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
Asearch,@
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OAR­
2004­
0228
and
OMB
control
number
2060­
0382
in
any
correspondence.
17
Figure
1.
U.
S.
Partner
Companies=
PFC
emission
with
and
without
EPA
Partnership.

Semiconductor
Partnership
Accomplishments
vs.

Business
As
Usual
(
BAU)

0
0.5
1
1.5
2
2.5
3
Year
PFC
Emissions
(

MMTCE)
BAU
BAU
with
Cu
Actual
Emissions
18
