Subpart I; Recipe-Specific Emission Factors Greenhouse Gas Reporting Program This fact sheet is designed to provide clarification on how to implement provisions related to the development and use of recipe-specific utilization and by-product formation rates (emission factors) under Subpart I: Electronics Manufacturing. How should a facility handle multi-step etch recipes where different steps use process parameters that fluctuate by more than 10 percent? Should each step be treated as if it is an individual recipe? EPA does not require facilities to treat each step of an etch recipe as an "individual recipe" as defined in Subpart I. EPA recognizes that etch recipes may consist of multiple steps, and in some cases may consist of as many as 10-30 distinct steps (e.g., stabilization step, RF power ramp step, plasma ON step...), each with varying process parameters. Some of these parameters, including reactor pressure, individual gas flow rates, and applied radio frequency (RF) power, may vary by more than 10 percent from one step to another. As a means to reduce burden for facilities that are required or elect to develop and use recipe- specific emission factors, EPA is permitting a facility to apply the same emission factors to a set of "similar recipes." To assist facilities in comparing recipes for similarity, EPA is providing the following guidance on how a facility could perform the comparison using a time-weighted average (TWA) approach. This guidance is not intended to preclude facilities from using other approaches permissible under the rule, such as a consumption-weighted average approach. To compare two individual recipes and determine whether they are "similar," a facility can take into account the differences between TWAs of reactor pressure, individual fluorinated GHG (F- GHG) gas flow rates, and (total) applied radio frequency (RF) power over multi-step recipes. The time-weighted average approach (as opposed to a simple average approach), would account for the fact that longer steps will have a larger impact on the overall emission factors than shorter steps. This approach is consistent with the 2006 International SEMATECH Manufacturing Initiative's Guideline for Environmental Characterization of Semiconductor Process Equipment (2006 ISMI Guidelines) and industry common practices where emission factors are averaged over the entire recipe (not measured for each distinct step). To determine the TWA value for a particular parameter (X=gas flow, pressure or total power), a facility would multiply the value for that parameter for a given step ']' by the duration of that step, sum up the results of the multiplication over all steps, and divide the result of the summation by the total recipe time. This weighted-averaging method is represented mathematically in the equation below: United Slates Environmental Protection Agency April 2011 1 40CFR98 ------- X TWA d Where: XTWA = time-weighted average of pressure or total RF power or gas flow for a particular recipe (Torrs or W or seem) Xj = pressure or total RF power or gas flow during step j (Torrs or W or seem) dj = duration of step j (min) d = total duration of recipe (min) n = total number of steps using F-GHGs during etch recipe To compare recipes with respect to similarity, a facility would then compare the TWA values of pressure, total RF power, or gas flow to determine if they deviate by more than +/-10% between recipes. If not, the two recipes would be considered "similar." An example calculation is provided below for two recipes with three steps each. Duration (min) CF4 flow (seem) C2F6 flow (seem) Pressure (Torrs) RF Power 1(W) RFpower2(W) Total RF power (W) RECIPE A Stepl 0.25 100 20 2 150 1000 1150 Step 2 2 150 30 4 200 1000 1200 StepS 0.25 120 20 2 150 1000 1150 TWA 142 28.0 3.60 190 1000 1190 RECIPE B Stepl 0.25 110 10 2 120 1500 1620 Step 2 1.83 140 33 4 180 1000 1180 StepS 0.25 120 20 2 120 1000 1120 TWA 135 29.1 3.57 167 1054 1221 Similarity between A&B -5.2% 4.1% -0.8% -12% 5.4% 2.58% In this example, recipes A and B are considered "similar" for the following reasons. First, recipes A and B are similar with respect to the CF4 and C2F6 TWA flows because the differences in these values are 5.2% and +4.1% respectively. Recipes A and B are also similar with respect to pressure because the difference between the TWA values for pressure is -0.8%. Finally, recipes A and B are similar with respect to total RF power because the difference between the TWA totals is only +2.58%. This is so even though the difference between RF power 1 for recipes A and B is -12%, because it is total power that is taken into account. Because RF power 2 has a stronger impact on the utilization efficiency of the gas (higher power) and because RF power 2 varies by +5.4%, the change in RF power 2 compensates for the diminution in RF power 1. How can a facility obtain recipe-specific emission factors? A facility may develop (or obtain) recipe-specific emission factors in multiple ways. Some examples are presented below: • Make direct measurements on-site at the facility. April 2011 40 CFR 98 ------- • Obtain measurement information, and hence emission factors, from tests performed by a third party, such as a tool supplier. Any measurements made by a third party are required to have been made for recipes that are similar recipes (as defined in §98.98) to those used at the facility. • Use factors from another facility that uses similar recipes. (For example, there are instances where a company operating multiple facilities will use the same or similar recipes in more than one facility; in this instance, measured recipe-specific emission factors for a recipe used at one facility may also be used for estimating emissions from the use of the same or a similar recipe at another facility.) • Work collaboratively with other facilities, companies, or research organizations in the industry to obtain recipe-specific emission factors. An emission factor may be shared for all similar recipes, regardless of where the factor was measured. Note, in a given reporting year, a facility must develop new recipe-specific emission factors only for recipes that are not similar to any recipe whose emission factors have already been measured in a previous reporting year. All recipe-specific emission factors must be measured using the 2006 International SEMATECH Manufacturing Initiative's Guideline for Environmental Characterization of Semiconductor Process Equipment (International SEMATECH #06124825A-ENG). Alternatively, a facility may use recipe-specific emission factors that were developed prior to January 1, 2007, provided they were measured using the 2001 International SEMATECH's Guidelines for Environmental Characterization of Semiconductor Equipment (International SEMATECH #01104197A-XFR). Can a third party take part in collaborative work to obtain recipe-specific emission factors? Yes, Subpart I does not prohibit involvement of third parties in collaborative efforts to develop and obtain recipe-specific emission factors. For example, multiple facilities may work together to develop and obtain recipe-specific emission factors by working through a third party. In this instance, facilities may submit blinded recipe information to a third party, and then work with the third party to collaborate on a single study to identify similar recipes and develop recipe- specific emission factors that could be used by multiple facilities. Facilities must comply with all applicable recordkeeping and reporting requirements. In particular, facilities must maintain documentation that the emission factors were measured for recipes that are similar to the recipes used at their facility, as required by §98.97(b)(2). Facilities must also comply with the certification requirement at §98.96(f). For More Information This document is provided solely for informational purposes. It does not provide legal advice, have legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations, responsibilities, expectations, or benefits in regard to any person. The series of April 2011 3 40CFR98 ------- information sheets is intended to assist reporting facilities/owners in understanding key provisions of the final rule. Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more information, including the final preamble and rule, additional information sheets on specific industries, the schedule for training sessions, and other documents and tools. For questions that cannot be answered through the Web site, please contact us at: ghgmrr@epa.gov. April 2011 4 40CFR98 ------- |