EPA Proposes New Calculation Methods for Electronics Makers' Greenhouse Gases

WASHINGTON, D.C.--The Environmental Protection Agency details new methods for electronics manufacturers to calculate their greenhouse gas emissions in a proposed rule to be published in the Federal Register Oct. 16.

The proposed rule would give electronics manufacturers the option of stack testing to calculate fluorinated greenhouse gas emissions. Currently, EPA's mandatory reporting rule requires the facilities to calculate their emissions using default gas utilization rates and by-product formation rates. Electronics manufacturers would be allowed to use the proposed calculation and monitoring methodologies beginning with the 2014 reporting year.

“Because stack testing is a direct measurement of facility emissions, it has the potential to provide a high-quality characterization of the emissions from the electronics manufacturing industry,” EPA said. “Electronics manufacturers are already using stack testing to comply with other air rules and operating permit requirements.”

The proposed rule would revise 40 C.F.R. Part 98 Subpart I.

EPA issued the final greenhouse gas reporting requirements for electronics manufacturing in December 2010 (75 Fed. Reg. 74,774).

Changes Proposed to Semiconductor Reporting.

Additionally, EPA proposed revisions to the default plasma etch and chamber cleaning gas utilization rates and by-product formation rates used to calculate fluorinated greenhouse gas emissions from plasma etch processes at semiconductor manufacturing facilities. Semiconductor manufacturers would be allowed to calculate their greenhouse gas emissions using those rates rather than developing recipe-specific utilization rates and by-product formation rates.

EPA had originally required only semiconductor facilities with an annual manufacturing capacity greater than 10,500 square meters of substrate per year making wafers with a diameter of 300 millimeters or less to report their emissions using the recipe-specific calculation methods. The proposed rule would eliminate the need for those facilities to develop recipe-specific methods for calculating emissions after EPA determined that doing so would be too technically burdensome and could reveal reporting companies' trade secrets.

Semiconductor Industry Sought Changes.

The Semiconductor Industry Association petitioned EPA in January 2011 to reconsider portions of the reporting rule. The association also filed a lawsuit in the U.S. Court of Appeals for the District of Columbia Circuit that is currently being held in abeyance (Semiconductor Industry Ass'n v. EPA, D.C. Cir., No. 11-1024, 1/31/11; 22 WCCR, 2/2/11).

The Semiconductor Industry Association could not be reached for comment.

EPA has already made several revisions to the reporting requirements for electronics manufacturers in response to the petition. Revisions include the period in which electronics manufacturers can use alternate methods to calculate their emissions without obtaining prior approval (76 Fed. Reg. 36,339), allowing the largest semiconductor manufacturers the option of calculating their emissions using default emissions factors rather than recipe-specific methods (76 Fed. Reg. 59,542), and requiring that electronics manufacturers report emissions from heat transfer fluids (77 Fed. Reg. 10,373; 164 WCCR, 8/23/12).

Comments on the proposed rule are due by Dec. 17. Comment can be made at http://www.regulations.gov and should reference docket No. EPA-HQ-OAR-2011-0028.

By Andrew Childers  

More information on the proposed greenhouse gas reporting rule for electronics manufacturers is available by contacting Carole Cook in EPA's Office of Atmospheric Programs at (202) 343-9263 or GHGReportingRule@epa.gov.