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October 17, 2012
GHG proposal for electronics manufacturing

               Based on continuing discussions with the Semiconductor Industry Association (SIA), the EPA is proposing significant amendments to calculation and monitoring requirements for electronics manufacturers as required under the Agency’s December 2010 GHG mandatory reporting rule (MRR) for the sector. The Agency does not expect to finalize the proposal until 2013.  This means that affected facilities would first use the amended procedures beginning in 2014, and the first reports of GHG emissions estimated with those procedures would be due in 2015.  For reporting years 2012 and 2013, facilities are expected to calculate emissions and other relevant data using the existing requirements under 40 CFR Part 98.

               In January 2011, the SIA submitted a petition asking the EPA to reconsider various aspects of the MMR affecting the industry.  Since then the Agency has published five actions in response to the petition, addressing areas that include use of best available monitoring methods (BAMM), emissions calculation procedures, extension of reporting deadlines, and data confidentiality determinations.  

Calculation options

               The current proposal would affect all facilities that manufacture electronics, including those that manufacture semiconductors (including light- emitting diodes), micro-electro-mechanical systems, liquid crystal displays, or photovoltaic cells. The proposed changes are summarized as follows:

  • Calculation methods would be revised to provide all electronics manufacturing facilities the choice of two methods to calculate annual emissions and to remove the option for electronics manufacturing facilities to determine and use recipe-specific gas utilization rates and by-product formation rates.
  • Provide the option for reporters to use either default gas utilization rates and by-product formation rates, which the EPA is proposing to revise for semiconductor manufacturing facilities to reflect new industry data provided to the Agency, or to conduct stack testing to establish site-specific emissions factors for fluorinated GHG emissions.
  • Include provisions to ensure that the EPA receives accurate and current facility-specific data.
  • Include provisions for the periodic review of industry advances and changes that may impact the default gas utilization rates and by-product formation rates and default destruction or removal efficiency (DRE) values used to estimate emissions to encourage the continued collection of data that represent current industry practices.
  • Include a stack testing approach that allows for estimation of emissions based on periodic direct measurements of stack emissions from facilities.

According to the EPA, the proposed amendments would allow the EPA to accurately characterize and analyze GHG emissions from facilities in the electronics manufacturing sector while reducing the compliance burden for the industry.

Protected data

The Agency is also proposing confidentiality determinations for 10 data categories.  The proposal adheres to the Clean Air Act requirement that “emissions data” in regulated programs may not be withheld from the public.  Confidential business information (CBI) protection would also not apply to certain nonemissions data such as test and calibration methods.  CBI would apply to production/throughput data that are not inputs to emissions equations; raw materials data that are not inputs to emissions equations; and detailed process- specific and vendor information submitted in petitions to extend the use of BAMM.  The EPA is also proposing to evaluate the CBI status of unit static and unit operating characteristics on a case-by-case basis.

               The Agency’s proposed amendments to the MRR requirements affecting the electronics manufacturing sectors were published in the October 16, 2012, FR.

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