 ADVANCE \d6 

SUPPORTING STATEMENT FOR

REPORTING AND RECORDKEEPING REQUIREMENTS UNDER THE PERFLUOROCOMPOUND
(PFC) REDUCTION/CLIMATE PARTNERSHIP FOR THE SEMICONDUCTOR INDUSTRY
(REINSTATEMENT)

EPA ICR NUMBER 1823.04

OMB CONTROL NUMBER 2060-0382

TABLE OF CONTENTS

  TOC \o "1-2" \h \z \u    HYPERLINK \l "_Toc197947169"  1.
IDENTIFICATION OF THE INFORMATION COLLECTION	  PAGEREF _Toc197947169 \h 
3  

  HYPERLINK \l "_Toc197947170"  1(a)	Title and Number of the Information
Collection	  PAGEREF _Toc197947170 \h  3  

  HYPERLINK \l "_Toc197947171"  1(b)	Short Characterization	  PAGEREF
_Toc197947171 \h  3  

  HYPERLINK \l "_Toc197947172"  2.	NEED FOR AND USE OF THE INFORMATION
COLLECTION	  PAGEREF _Toc197947172 \h  4  

  HYPERLINK \l "_Toc197947173"  2(a)	Need and Authority for the
Collection	  PAGEREF _Toc197947173 \h  4  

  HYPERLINK \l "_Toc197947175"  2(b)	Practical Utility and Users of the
Data	  PAGEREF _Toc197947175 \h  5  

  HYPERLINK \l "_Toc197947176"  2(c)	Assessment of Partnership’s
Achievements	  PAGEREF _Toc197947176 \h  5  

  HYPERLINK \l "_Toc197947177"  3.	NONDUPLICATION, CONSULTATIONS, AND
OTHER COLLECTION CRITERIA	  PAGEREF _Toc197947177 \h  7  

  HYPERLINK \l "_Toc197947178"  3(a)	Nonduplication	  PAGEREF
_Toc197947178 \h  7  

  HYPERLINK \l "_Toc197947179"  3(b)	Public Notice Request Prior to ICR
Submission to OMB	  PAGEREF _Toc197947179 \h  7  

  HYPERLINK \l "_Toc197947180"  3(c)	Consultations	  PAGEREF
_Toc197947180 \h  8  

  HYPERLINK \l "_Toc197947181"  3(d)	Effects of Less Frequent Collection
  PAGEREF _Toc197947181 \h  8  

  HYPERLINK \l "_Toc197947182"  3(e)	General Guidelines	  PAGEREF
_Toc197947182 \h  9  

  HYPERLINK \l "_Toc197947183"  3(f)	Confidentiality	  PAGEREF
_Toc197947183 \h  9  

  HYPERLINK \l "_Toc197947184"  3(g)	Sensitive Questions	  PAGEREF
_Toc197947184 \h  9  

  HYPERLINK \l "_Toc197947185"  4.	THE RESPONDENTS AND THE INFORMATION
REQUESTED	  PAGEREF _Toc197947185 \h  9  

  HYPERLINK \l "_Toc197947186"  4(a)	Respondents and SIC/NAICS Codes	 
PAGEREF _Toc197947186 \h  9  

  HYPERLINK \l "_Toc197947187"  4(b)	Information Requested	  PAGEREF
_Toc197947187 \h  9  

  HYPERLINK \l "_Toc197947188"  5. 	THE INFORMATION COLLECTED--AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF
_Toc197947188 \h  12  

  HYPERLINK \l "_Toc197947189"  5(a)	Agency Activities	  PAGEREF
_Toc197947189 \h  12  

  HYPERLINK \l "_Toc197947190"  5(b)	Collection Methodology and
Management	  PAGEREF _Toc197947190 \h  13  

  HYPERLINK \l "_Toc197947191"  5(c)	Small Entity Flexibility	  PAGEREF
_Toc197947191 \h  14  

  HYPERLINK \l "_Toc197947192"  5(d)	Collection Schedule	  PAGEREF
_Toc197947192 \h  14  

  HYPERLINK \l "_Toc197947193"  6.	ESTIMATING THE BURDEN AND COST OF THE
COLLECTION	  PAGEREF _Toc197947193 \h  14  

  HYPERLINK \l "_Toc197947194"  6(a)	Estimating Respondent Burden	 
PAGEREF _Toc197947194 \h  14  

  HYPERLINK \l "_Toc197947195"  6(b)	Estimating Respondent Costs	 
PAGEREF _Toc197947195 \h  14  

  HYPERLINK \l "_Toc197947196"  6(c)	Estimating Agency Burden and Cost	 
PAGEREF _Toc197947196 \h  15  

  HYPERLINK \l "_Toc197947197"  6(d) 	Estimating the Respondent Universe
and Total Respondent Burden and Costs	  PAGEREF _Toc197947197 \h  16  

  HYPERLINK \l "_Toc197947198"  6(e)	Bottom Line Burden and Costs	 
PAGEREF _Toc197947198 \h  17  

  HYPERLINK \l "_Toc197947199"  6(f)	Reasons for Change in Burden	 
PAGEREF _Toc197947199 \h  17  

  HYPERLINK \l "_Toc197947200"  6(g)	Burden Statement	  PAGEREF
_Toc197947200 \h  17  

 

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title and Number of the Information Collection

This Information Collection Request (ICR) is entitled "Reporting and
Recordkeeping Requirements under the Perfluorocompound (PFC)
Reduction/Climate Partnership for the Semiconductor Industry," OMB
Control Number 2060-0382, EPA ICR number 1823.04.  This ICR is a
reinstatement of a previously approved ICR.

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 goal will
require a combination of short-, medium-, and long-term actions.
Initially, the Administration adopted policies to encourage industry to
take voluntary actions using available, cost-effective technologies and
best practices to reduce GHG emissions intensity.  The U.S.
Environmental Protection Agency’s (EPA’s) PFC Reduction/Climate
Partnership for the Semiconductor Industry is an important program
contributing to the overall reduction in GHG emissions from projected
2010 levels.  The semiconductor industry partnership, along with EPA’s
Energy Star programs and the Voluntary Aluminum Industrial Partnership
(VAIP), are all voluntary initiatives seeking to reduce GHG emissions
using a pollution prevention approach.

The PFC Reduction/Climate Partnership for the Semiconductor Industry
(referred to as the “PFC Reduction/Climate Partnership” or the
“Partnership” for the remainder of this ICR) is a voluntary program
that promotes reduction of fluorinated compound (FC) GHG 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 EPA and others in the semiconductor industry information about
successful PFC emission reduction processes and technologies that the
Partner Company considers non-confidential.  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.  

This ICR explains the information collection under the PFC
Reduction/Climate Partnership.  Sections 1 through 5 of the ICR describe
the information collection requirements (in regard to need and use of
the information collected).  Section 6 estimates the annual burden and
cost to the respondents and the Agency under these requirements.

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 GHG emissions intensity (the
amount of GHGs emitted per dollar of Gross Domestic Product [GDP]) by 18
percent over 10 years.  EPA’s semiconductor industry partners are
contributing to the Climate VISION’s efforts to reduce U.S. GHG
emissions by striving to reduce their absolute PFC emissions 10 percent
below their 1995 baseline level (see
www.climatevision.gov/sectors/semiconductors).  The PFC
Reduction/Climate 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) of the Clean Air Act. 
Additionally, the PFC Reduction/Climate Partnership is inline with the
EPA’s 2006-2011 Strategic Plan, which identifies “clean air and
global climate change” as one of the five Strategic Plan Goals, and
reductions in GHG emissions as one of the objectives under this Goal.

EPA has developed this ICR to obtain authorization to collect
information from Companies participating in the PFC Reduction/Climate
Partnership.  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,
combined with information on Partner Companies’ PFC emissions by gas
(submitted on a blind basis).  Using the information provided through
the Partnership the EPA is able to (1) evaluate the overall PFC emission
reductions achieved by the voluntary program, (2) develop estimates for
the total U.S. semiconductor emissions, (3) identify new technologies or
processes that reduce PFC emissions, and (4) serve as a technical
clearing-house to provide industry with pertinent information on
emissions estimation and reduction strategies.  The Partnership data is
a valuable resource for evaluating current and promoting future GHG
emissions reductions within the semiconductor industry.

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, which is important not only to assess whether
Partners are on track towards meeting their 2010 emissions reduction
goal, but also to evaluate reductions in emissions intensity by Partners
as part of President Bush’s Climate VISION initiative. In addition,
EPA will use the information collected to evaluate the quantity of
emissions prevented and to publicize Company and Partnership successes. 
EPA will also use the information on an annual basis to develop the
Inventory of U.S. Greenhouse Gas Emissions and Sinks.  The U.S.
Government is committed to developing and maintaining the Inventory
under the United Nations Framework Convention on Climate Change
(UNFCCC).  

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 non-confidential. 
Additionally, EPA’s review of the annual Partnership reports on a
“blind”-basis and discussions with Partner companies, allows EPA to
assess the need for information and to provide pertinent technical
information to assist Partner-Companies in achieving greater reductions.
 It is expected that the industry will use the information gathered
through the Partnership to understand the extent and rate of growth of
its PFC emissions in the U.S., and to continue to reduce their PFC
emissions and improve their environmental performance.

2(c)	Assessment of Partnership’s Achievements

In 2001, the Office of Management and Budget (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 the total manufactured layer area
(TMLA) of silicon during semiconductor manufacture.  EPA’s PFC
Emissions Vintage Model (PEVM) PFC emissions factor represents the
average emission factor from four historical Partnership years (i.e.,
1996 to 1999).  The emission factor does not reflect any emission
reduction measures, as Partners are not believed to have applied
significant reduction measures before 2000.  To estimate U.S. BAU
emissions the PEVM emission factor is multiplied by U.S. TMLA.  U.S.
TMLA is derived from (1) reports and projections of World silicon
consumption provided by VLSI Research Inc., (2) the share of U.S. TMLA
derived from the World Fab Watch database, and (3) the number of
interconnect layers by linewidth technology and device type (i.e.,
discrete, memory or logic) as provided in the International Technology
Roadmap for Semiconductors.,,    

Figure 1 near the end of this document depicts the Partners’ actual
PFC emissions through 2006, as compared to expected BAU emissions.  A
full description of EPA’s PEVM used to estimate BAU emissions is
available at:
http://www.epa.gov/semiconductor-pfc/documents/pevm_draft.pdf. 

The Partner Companies have identified and are adopting 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 98
percent as compared to the traditional C2F6 cleaning process. The
adoption of NF3 Remote Clean and in-situ NF3 technologies—both
alternatives to the traditional C2F6 cleaning process—account for
approximately two-thirds of the total emission reduction since 2000. 
These technologies are now available for all new 200- and 300-mm wafer
PECVD (plasma enhanced chemical vapor deposition) 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 also have
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 manufacturing productivity.

	

EPA’s PFC Reduction/Climate Partnership, through its aggressive PFC
emission reduction goal, has sent a clear message to the industry’s
equipment and chemical suppliers.  The industry’s suppliers are
responding by evaluating and designing new manufacturing technologies
with zero (when feasible) or much reduced carbon footprints. These new
designs include new chemicals with zero or lower global warming impacts,
point-of-use capture and recycle technology, 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.  Partner Companies are choosing to upgrade their abatement
systems to address PFC emissions and 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 on March 11, 2008 (73 FR 12996). 
The public comment periods extended through May 12, 2008.  EPA received
no public comments on this ICR in response to the Federal Register
notice.

3(c)	Consultations

In the fall of 2000, EPA consulted with eight companies in the PFC
Reduction/Climate Partnership to obtain feedback on the burden 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.  

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
frequently than once per year, emission inventories of GHGs prepared by
the Federal 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 GHG 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
non-confidential.

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 and SIC/NAICS Codes

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:

Industry Sector	SIC Code	NAICS Code

Semiconductor and Related Device Manufacturing	3674	334413



The above SIC and NAICS codes refer to the industry respondents for the
Partnership.  These SIC and NAICS codes are applicable because the
Partner Companies are semiconductor manufacturing companies. 

4(b)	Information Requested

Companies participating in the PFC Reduction/Climate Partnership submit
a 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. It also
agrees 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 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 activities

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 annual 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, where applicable.  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 Climate Change Action Plan
(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 websites for Partner Companies that were
believed to be small entities.  Upon completion of the review, EPA
estimates that 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 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.  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 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

Cost Data	

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 and costs for the
information collection activities covered in this ICR.  As shown in the
exhibit, 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 referred to the “Hourly Salary Table 2007 - GS” from
the Department of Personnel Management.  This publication summarizes the
unloaded (base) hourly rate for various labor categories in the Federal
Government. 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 Partner 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.  These activities
are reflected in Exhibit 1.

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 and Costs

Respondent Tally

In Exhibit 1, EPA estimates the total annual respondent burden and cost
for the information collection under the PFC Emission Reduction
Partnership to be approximately 11,426 hours and $938,461 (labor and
capital/O&M costs).  The bottom line respondent burden over the
three-year period covered by this ICR is approximately 34,277 hours and
at a total cost of approximately $2,815,383.  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 estimated to be $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

There is an increase of 11,426 hours in the total estimated burden
currently identified in the OMB Inventory of Approved ICR Burdens, which
reflects the burden for reinstating the entire program.  EPA has not
collected under this ICR since it expired in March 2008.  There is a
decrease of 1,624 hours from the last time this ICR was approved.  This
is because the number of respondents decreased from 24 to 21.  

6(g)	Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 544 hours per response.  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 3334, 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 and OMB Control Number 2060-0382 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.

 The TMLA includes both the area of the silicon wafer and the area of
the layers above the wafer, which are used to interconnect the circuit
elements of an integrated circuit (IC). TMLA is obtained by multiplying
the silicon wafer area by the total number of layers.

 VLSI Research, Inc. (2007)  Document 327028, V6.12.1—Worldwide
Silicon Demand by Wafer Size, by Linewidth and by Device Type. January
2007. Available online at <http://www.vlsiresearch.com>.

 Semiconductor Equipment and Materials Industry (2007) World Fab Watch,
January 2006 Edition.

 ITRS (2007) International Technology Roadmap for Semiconductors: 2006
Update. January 2007. This and earlier editions and updates are
available at <http://public.itrs.net.>

 The distinction between copper and no-copper interconnects is not used
in the latest version of PEVM because the industry has fully
incorporated the use of copper during IC manufacture, which is reflected
in the ITRS (cf. ITRS, 2007). Incorporating copper-interconnect
technology has the effect of lowering the BAU baseline emissions, for
which credit is not taken because its adoption was prompted by IC
performance not the reduction of PFC emissions.

 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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