MEMORANDUM - PROPOSED DATA CATEGORY ASSIGNMENTS FOR SUBPART I 2012 AMENDMENTS

To:	Docket EPA-HQ-OAR-2011-0028

From:	Alexis McKittrick, EPA/Climate Change 

Date: 	August 28, 2012

Subject:	Proposed data category assignments for data reporting elements in 40 CFR part 98, subpart I.  
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In this memorandum, we show the proposed data category assignments for data reporting elements in Subpart I  -  Electronics Manufacturing of Part 98 as referenced in the Mandatory Reporting of Greenhouse Gases Rule: Proposed Amendments and Confidentiality Determinations for Subpart I. The table below shows the proposed assignment of each data reporting element into one of 10 data categories (excluding inputs to emission equations). The table also shows the proposed confidentiality determination for data elements in the two data categories for which a categorical confidentiality determination was not made.

For descriptions of the direct emitter data categories and the categorical confidentiality determinations made for eight of these categories, see the preambles to the proposed and final rulemakings: Proposed Confidentiality Determinations for Data Required Under the Mandatory Greenhouse Gas Reporting Rule and Proposed Amendment to Special Rules Governing Certain Information Obtained Under the Clean Air Act published on July 7, 2010 (75 FR 39094); and Confidentiality Determinations for Data Required under the Mandatory Greenhouse Gas Reporting Rule and Amendment to Special Rules Governing Certain Information Obtained under the Clean Air Act published on May 26, 2011 (76 FR 30782). 

Copies of the proposed and final rules are available on EPA's website: http://www.epa.gov/climatechange/emissions/CBI.html, at the following links: http://www.gpo.gov/fdsys/pkg/FR-2010-07-07/pdf/2010-16317.pdf and http://www.gpo.gov/fdsys/pkg/FR-2011-05-26/pdf/2011-12930.pdf. 





                                  Appendix A
                                       
       Proposed Data Category Assignments for Subpart I 2012 Amendments
                                       
List of Proposed Data Category Assignments
Note:
In the May 26, 2011, Final CBI rule (76 FR 30782), the EPA issued categorical confidentiality determinations for eight direct emitter categories. Two of the data categories ("Unit/Process `Static' Characteristics That are Not Inputs to Emission Equations" and "Unit/Process `Operating' Characteristics That are Not Inputs to Emission Equations") do not have categorical confidentiality determinations, and these CBI determinations are proposed on an element-by-element basis. In this action, the EPA is proposing to assign 13 new or revised data elements to data categories for which EPA issued categorical confidentiality determinations. The EPA is proposing to assign 12 new or revised data elements to the "Unit/Process `Static' Characteristics That are Not Inputs to Emission Equations" and "Unit/Process Operating Characteristics That are Not Inputs to Emission Equations" data categories and make confidentially determinations for these reporting elements individually. The table below identifies the proposed data categories and the confidentiality determination for the new or revised data elements in the proposed subpart I amendments. 

 Rule Citation for Data Reporting Element (proposed for new data elements; no change from previous citation for revised data elements)
                           Data Element Description
                                New or revised?
Data Category Assignment (proposed for new data elements; no change for revised data elements)
                   Categorical  or Individual Determination
    (proposed for new data elements; no change for  revised data elements)
                                  98.96(c)(1)
On a fab basis, each fluorinated GHG emitted from each process type for which your fab is required to calculate emissions as calculated in Equations I - 6 and I - 7.
Revised so reporting is on a fab-basis instead of a facility-basis.
Emissions
                            Emission data (not CBI)
                                  98.96(c)(2)
On a fab basis, each fluorinated GHG emitted from each process type or process sub-type as calculated in Equations I - 8 and I - 9.
Revised to remove references to "recipe-specific" and revise to fab-basis.
Emissions 
                            Emission data (not CBI)
                                  98.96(c)(3)
On a fab basis, N2O emitted from all chemical vapor deposition processes and N2O emitted from all other N2O-using manufacturing processes as calculated in Equation I - 10.
Revised so reporting is on a fab-basis instead of a facility-basis.
Emissions
                            Emission data (not CBI)
                                  98.96(c)(5)
When you use the procedures specified in §98.93(i) of this subpart, annual emissions of each fluorinated GHG  on a fab basis.
New
Emissions 
                            Emission data (not CBI)
                                  98.96(m)(1)
Identification of the quantifiable metric used in your fab-specific engineering model to apportion gas consumption for each fab.
Revised to apportion gas for each fab.
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations
                No categorical determination; no determination
                                  98.96(m)(3)
Certification that the gas(es) you selected under §98.94(c)(2)(ii) for each fab corresponds to the largest quantity(ies) consumed on a mass basis, of fluorinated GHG used at your fab during the reporting year for which you are required to apportion.
Revised to a fab basis and to remove reporting by process type.
Test & Calibration Methods 
                         Not emission data and not CBI
                                  98.96(m)(4)
The result of the calculation comparing the actual and modeled gas consumption under §98.94(c)(2)(iii) and (iv), as applicable.
Revised to include  comparison results from stack test method.
Test & Calibration Methods 
                         Not emission data and not CBI
                                  98.96(m)(5)
If required to apportion fluorinated GHG consumption between fabs as required by §98.94(c)(2)(v), certification that the gas(es) you selected under §98.94(c)(2)(ii) corresponds to the largest quantity(ies) consumed on a mass basis, of fluorinated GHG used at your facility during the reporting year for which you are required to apportion.
New
Test & Calibration Methods 
                         Not emission data and not CBI
                                   98.96(p)
Inventory of all abatement systems through which fluorinated GHGs or N2O flow at your facility and for which you are claiming destruction or removal efficiency.
Revised to clarify applicability to abatement systems for which you claim destruction or removal efficiencies.
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations
                 No categorical determination; proposed as CBI
                                   98.96(p)
Description of all abatement systems through which fluorinated GHGs or N2O flow at your facility and for which you are claiming destruction or removal efficiency.
Revised to clarify applicability to abatement systems for which you claim destruction or removal efficiencies.
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations
               No categorical determination; proposed as not CBI
                                  98.96(p)(1)
The number of abatement systems controlling emissions for each process sub-type, or process type, as applicable, for each gas used in the process sub-type or process type.
Revised to be reported on a gas and process type/subtype basis.
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations
                 No categorical determination; proposed as CBI
                                  98.96(p)(2)
The basis of the destruction or removal efficiency being used (default or site specific measurement according to §98.94(f)(4)(i)) for each process sub-type or process type and for each gas.
New
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations
               No categorical determination; proposed as not CBI
                                   98.96(q)
For all abatement systems through which fluorinated GHGs or N2O flow at your facility for which you are reporting controlled emissions, a certification that all abatement systems at the facility have been installed, maintained, and operated in accordance with the manufacturer's specifications and according to the site maintenance plan for abatement systems that is developed and maintained in your records.
Revised to add reference to site maintenance plan.
Unit/Process 'Operating' Characteristics That are Not Inputs to Emission Equations
               No categorical determination; proposed as not CBI
                                   98.96(r)
Effective facility-wide destruction or removal efficiency value calculated using Equations I-26, I-27, and I-28.
New
Unit/Process 'Operating' Characteristics That are Not Inputs to Emission Equations
               No categorical determination; proposed as not CBI
                                  98.96(w)(1)
If you elect to calculate fab-level emissions of fluorinated GHG using the stack testing procedures specified in §98.93(i), the date of any stack testing conducted during the reporting year.
New
Test & Calibration Methods 
                         Not emission data and not CBI
                                  98.96(w)(1)
If you elect to calculate fab-level emissions of fluorinated GHG using the stack testing procedures specified in §98.93(i), the identity of the stack tested.
New
Facility and Unit Identifier Information 
                            Emission data (not CBI)
                                  98.96(w)(2)
If you elect to calculate fab-level emissions of fluorinated GHG using the stack testing procedures specified in §98.93(i), an inventory of all stacks from which process fluorinated GHG are emitted.
New
Facility and Unit Identifier Information 
                            Emission data (not CBI)
                                  98.96(w)(2)
If you elect to calculate fab-level emissions of fluorinated GHG using the stack testing procedures specified in §98.93(i), for each stack system, indicate whether the stack is among those for which stack testing was performed as per §98.93(i)(3) or not performed as per §98.93(i)(2) (for exempt low emitting stacks).
New
Calculation Methodology & Method, Tier 
                            Emission data (not CBI)
                                   98.96(x)
If the emissions reported under paragraphs (c) include emissions from research and development activities, report the approximate percentage of total GHG emissions that are attributable to research and development activities, using the following ranges: less than 5 percent, 5 percent to less than 10 percent, 10 percent to less than 25 percent, 25 percent to less than 50 percent, 50 percent and higher.
New
Calculation Methodology & Method, Tier 
                            Emission data (not CBI)
                                98.96(y)(2)(i)
If your semiconductor manufacturing facility emits in 2015 more than 40,000 mtCO2e of GHG emissions from the electronics manufacturing processes subject to reporting, a triennial (every 3 years) technology assessment report including a description of how the gases and technologies used in semiconductor manufacturing using 200 mm and 300 mm wafers in the United States have changed in the past 3 years and whether any of the identified changes are likely to have affected the emissions characteristics of semiconductor manufacturing processes in such a way that the default utilization and byproduct formation rates or default DRE values may need to be updated. 
New
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations 
                  No categorical determination; proposed CBI
                                98.96(y)(2)(ii)
If your semiconductor manufacturing facility emits in 2015 more than 40,000 mtCO2e of GHG emissions from the electronics manufacturing processes subject to reporting, a triennial (every 3 years) technology assessment report including a description of the effect of the implementation of new process technologies and/or finer line width processes in 200 mm and 300 mm technologies, the introduction of new tool platforms, and the introduction of new processes on previously tested platforms.
New
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations
                  No categorical determination; proposed CBI
                               98.96(y)(2)(iii)
If your semiconductor manufacturing facility emits in 2015 more than 40,000 mtCO2e of GHG emissions from the electronics manufacturing processes subject to reporting, a triennial (every 3 years) technology assessment report including a description of the status of implementing 450 mm wafer technology and the potential need to create or update emission factors compared to 300 mm technology.
New
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations
                  No categorical determination; proposed CBI
                                98.96(y)(2)(iv)
If your semiconductor manufacturing facility emits in 2015 more than 40,000 mtCO2e of GHG emissions from the electronics manufacturing processes subject to reporting, a triennial (every 3 years) technology assessment report including any utilization and by-product formation ratesor DRE data that have been collected in the previous 3 years that support the changes or continuities in semiconductor manufacturing processes described in the report.
New
Emissions 
                            Emission data (not CBI)
                                98.96(y)(2)(v)
If your semiconductor manufacturing facility emits in 2015 more than 40,000 mtCO2e of GHG emissions from the electronics manufacturing processes subject to reporting, a triennial (every 3 years) technology assessment report including a description of the use of a new gas, use of an existing gas in a new process type or sub-type, or a fundamental change in process technology.
New
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations
                  No categorical determination; proposed CBI
                                  98.96(y)(3)
If, on the basis of the information reported in paragraph (y)(2), the triennial report indicates that GHG emissions from semiconductor manufacturing may have changed from those represented by the default emission factors in Tables I-3, I-4, or I-5, or the default DRE values in Table I-13, the report must lay out a data gathering and analysis plan that includes the testing of tools to determine the potential effect on current emission factors and DRE values under the new conditions, and a planned analysis of the effect on overall facility emissions using a representative gas-use profile for a 200 mm, 300 mm, or 450 mm fab (depending on which technology is under consideration).
New
Unit/Process 'Static' Characteristics That are Not Inputs to Emission Equations
                  No categorical determination; proposed CBI

