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
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).
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
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,
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.