 ADVANCE \d6 

SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 1823.03

REPORTING AND RECORD KEEPING REQUIREMENTS UNDER THE PFC
REDUCTION/CLIMATE PARTNERSHIP FOR THE SEMICONDUCTOR INDUSTRY

March 11, 2008

	TABLE OF CONTENTS

	IDENTIFICATION OF THE INFORMATION
COLLECTION………………………….. . .1

1(a)	Title of the Information Collection	1

1(b)	Short Characterization	1

	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

	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

	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.	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

On February 14, 2002, President Bush announced a goal to reduce U.S.
greenhouse gas (GHG) emissions intensity – the ratio of emissions to
economic output by American industry – by 18 percent over the next 10
years without sacrificing economic growth. Achieving this aim will
require a combination of short-, medium-, and long-term actions.
Initially, the Administration has adopted policies to encourage industry
to take voluntary actions using available, cost-effective technologies
and best practices to reduce GHG emissions intensity.  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 Star 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 fluorinated compound (FC)
greenhouse gas emissions including 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 and support the
President’s Climate VISION initiative.  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.  

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 Partner Company) and EPA
(collectively, the Parties).  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 “blind” 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 voluntarily 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
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 “business 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
http://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 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 C2F6 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 “recipes” (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

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 [XXX, 2008 Vol. XX, Number 162,
Page 51831-51832] soliciting public comments for a 60-day period ending
October XXXX, 2008.  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 updated the compensation level for the labor
categories using U.S. Department of Labor’s Bureau of Labor Statistics
information.  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 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
“blind” 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.

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 21 semiconductor manufacturers
representing 80 percent of the U.S. industry participating in the
partnership.  All 21 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.  

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 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

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 Company-specific 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

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 reviewed available company Web sites for Partner companies that were
believed may be small entities.  Upon completion of the review, EPA
estimates none of its semiconductor industry Partners are small
entities.  Regardless, EPA has designed the program and reporting form
to minimize respondent burden while obtaining sufficient and accurate
information.  In addition, the burden associated with the PFC
Reduction/Climate Partnership for the Semiconductor Industry is
inherently reduced 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.

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 annual respondent burden of
approximately 11,426 hours.  Assumptions used in calculating this
estimate are described below.

6(b)	Estimating Respondent Costs

Labor Costs

EPA estimates respondent labor costs by adding U.S. wages to
employers’ costs for employee compensation for the appropriate
respondent categories and multiplying the total by 1.35 to adjust for an
assumed 35 percent overhead rate.  For the Partner Companies, EPA
estimates average hourly labor rates of $114.87 for legal staff, $113.02
for engineering managers, $64.15 for semiconductor production
technicians, and $67.03 for clerical staff.  Table 1 summarizes EPA’s
estimated labor rates as explained above.

	Table 1:

	Average Hourly Respondent Labor Rates

Type of Respondent	

Legal	

Engineering 

Managers	

Technical (Semiconductor Production)	

Clerical



Wages (hourly)	

$54.65	

$52.90	

$16.70	

$18.83

Employee Compensation (hourly)	$30.44	$30.82	$30.82	$30.82

Total Hourly Labor Rate = sum of above x 1.35	$114.87	$113.02	$64.15
$67.03



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 characterize PFC emissions and
provide this information 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 for the
information collection activities associated with this ICR.  EPA
estimates an average hourly labor cost (labor plus overhead) of $71.34
for legal staff, $66.72 for managerial staff, $48.91 for technical
staff, and $19.65 for clerical staff.  To derive these estimates, EPA
used the “Hourly Salary Table 2007 - GS” from the Department of
Personnel Management.  For purposes of this ICR, EPA assigned staff the
following government service levels:

Legal Staff				GS-15, Step 1

Managerial Staff			GS-14, Step 4

Technical Staff			GS-12, Step 5

Clerical Staff			GS-5, Step 1.

	To derive the loaded hourly estimates, EPA 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 218 hours at a total cost of $12,696.

6(d) 	Estimating the Respondent Universe and Total Respondent Burden and
Costs

Respondent Universe

EPA expects the current 21 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.

Industry-wide Annual Report

      

 	The designated third party will be responsible for receiving and
tracking the Company-specific 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 industry-wide 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 21 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 11,426
hours and $1,054,780.  The bottom line respondent burden over the
three-year period covered by this ICR is approximately 34,278 hours, at
a total cost of approximately $3,164,340.  The total annual capital and
O&M costs for the partnership are estimated to be $116,319 per year.

Agency Tally

As shown in Exhibit 2, the annual Agency burden and cost are estimated
to be approximately 218 hours and $12,696 per year.  The bottom line
Agency burden over the three-year period covered by this ICR is
approximately 654 hours, at a total cost of approximately $38,088.

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 not changed from the previous ICR but the
estimated annual burden cost increased to reflect updated labor
compensation rates as provided by the U.S. Department of Labor. The
number of Companies in the Partnership is expected to remain at 21. 
This ICR does not expect 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 544 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.  The
eight-hour estimate 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 roughly 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. 

  SEQ CHAPTER \h \r 1 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 Number EPA-HQ-OAR-2004-0228, which is available
for public viewing at the Air and Radiation Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301
Constitution Avenue, 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 and Information Center is (202) 566-1742.  

An electronic version of the public docket is available at
www.regulations.gov. This site can be used 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. When in the system, select “search,” 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.
EPA-HQ-OAR-2004-0228 in any correspondence.

Figure 1.  U.S. Partner Companies( PFC emission with and without EPA
Partnership. 



 

 FCs 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.

 U.S. Department of Labor, Bureau of Labor Statistics May 2007.   
HYPERLINK "http://www.bls.gov/news.release/pdf/ocwage.pdf" 
http://www.bls.gov/news.release/pdf/ocwage.pdf  

 U.S. Department of Labor, Bureau of Labor Statistics December 2007.  
HYPERLINK "http://www.bls.gov/news.release/pdf/ecec.pdf" 
http://www.bls.gov/news.release/pdf/ecec.pdf  

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