[Federal Register Volume 87, Number 236 (Friday, December 9, 2022)]
[Notices]
[Pages 75641-75642]
[FR Doc No: 2022-26732]

=======================================================================
-----------------------------------------------------------------------

DEPARTMENT OF HOMELAND SECURITY

Federal Emergency Management Agency

[Docket ID: FEMA-0022-0047; OMB No. 1660-0118]

Agency Information Collection Activities: Proposed Collection;
Comment Request; Homeland Security Exercise and Evaluation Program
(HSEEP) Documentation

AGENCY: Federal Emergency Management Agency, Department of Homeland
Security.

ACTION: 60-Day notice of revision and request for comments.

-----------------------------------------------------------------------

SUMMARY: The Federal Emergency Management Agency (FEMA), as part of its
continuing effort to reduce paperwork and respondent burden, invites
the general public to take this opportunity to comment on an extension,
with change, of a currently approved information collection. In
accordance with the Paperwork Reduction Act of 1995, this notice seeks
comments concerning the After Action Report/Improvement Plans,
Integrated Preparedness Plans, and Support Request Forms to the
National Exercise Program which are used to validate current
preparedness capabilities and support future national exercise efforts.

DATES: Comments must be submitted on or before February 7, 2023.

ADDRESSES: To avoid duplicate submissions to the docket, please submit
comments at

www.regulations.gov under Docket ID FEMA-0022-0047. Follow the
instructions for submitting comments.
    All submissions received must include the agency name and Docket
ID. Regardless of the method used for submitting comments or material,
all submissions will be posted, without change, to the Federal
eRulemaking Portal at http://www.regulations.gov, and will include any
personal information you provide. Therefore, submitting this
information makes it public. You may wish to read the Privacy and
Security Notice that is available via a link on the homepage of
www.regulations.gov.

FOR FURTHER INFORMATION CONTACT: You may contact the Information
Management Division for copies of the proposed collection of
information at email address: [email protected] or Kristen Fish, Supervisory Emergency
Management Specialist at [email protected] or<PHONE_NUMBER>.

SUPPLEMENTARY INFORMATION: Presidential Policy Directive 8 (PPD-8:
National Preparedness), issued on March 30, 2011, establishes a
National Preparedness Goal (NPG) that identifies the core capabilities
necessary for preparedness and a National Preparedness System (NPS)
which guides activities to enable the Nation to achieve the NPG. The
NPS allows the Nation to track the progress of our ability to build and
improve the capabilities necessary to prevent, protect against,
mitigate the effects of, respond to, and recover from those threats
that pose the greatest risk to the security of the Nation.
    The NPS provides an integrated approach to preparedness that can be
implemented and measured at all levels of government. This system is an
all-of-Nation and whole community approach to preparedness, from
neighborhood organizations to civic groups and private businesses. It
contains a methodical approach integrated across the preparedness cycle
and links together programs and requirements into a comprehensive
system, driving rational decision-making and allowing for a direct and
defensible assessment of progress against clearly defined objectives.
    The NPS is based on a consistent methodology for assessing the
threats and hazards facing a given jurisdiction. The findings of the
assessment drive planning factors and all other components of the
preparedness cycle including resource requirements, existing
capabilities and capability gaps, driving investments to close those
gaps, making and validating improvements in capabilities through
training and exercising, and continually assessing progress.
    Section 648(b)(1) of the Post-Katrina Emergency Management Reform
Act of 2006 (6 U.S.C. 748(b)(1)) also provides for these exercises and
states the Administrator ``shall carry out a national exercise program
to test and evaluate the national preparedness goal, National Incident
Management System, National Response, and other related plans and
strategies.'' The Homeland Security Exercise and Evaluation Program
(HSEEP) provides the program structure, multi-year planning system,
tools, and guidance necessary for entities to build and sustain
exercise programs that enhance homeland security capabilities, and
ultimately, preparedness. The HSEEP After Action Report Improvement,
Integrated Preparedness Plan, and National Exercise Program Support
Request Forms provide the standardized methods for reporting the
results of exercises, identifying exercise program priorities, and
submitting exercise nominations necessary to validate national
preparedness capabilities.

Collection of Information

    Title: Homeland Security Exercise and Evaluation Program (HSEEP)
Documentation.
    Type of Information Collection: Extension, with change, of a
currently approved information collection.
    OMB Number: 1660-0118.
    FEMA Forms: FEMA Form FF-008-FY-21-102 (formerly 091-0-1), After
Action Report/Improvement Plan (AAR/IP); FEMA Form FF-008-FY-21-100
(formerly 008-0-26), Integrated Preparedness Plan (IPP); FEMA Form FF-
008-FY-21-101 (formerly 008-0-27), National Exercise Program (NEP)
Support Request Form.
    Abstract: The Homeland Security Exercise and Evaluation Program
(HSEEP) Documentation collection provides reporting on the results of
preparedness exercises and provides assessments of the respondents'
capabilities so that strengths and areas for improvement are
identified, corrected, and shared as appropriate prior to a real
incident. This information is also required to be submitted as part of
certain FEMA grant programs.
    Affected Public: State, Local, or Tribal Governments.
    Estimated Number of Respondents: 253.
    Estimated Number of Responses: 471.
    Estimated Total Annual Burden Hours: 14,458.
    Estimated Total Annual Respondent Cost: $794,901.
    Estimated Respondents' Operation and Maintenance Costs: 0.
    Estimated Respondents' Capital and Start-Up Costs: 0.
    Estimated Total Annual Cost to the Federal Government: $70,218.

Comments

    Comments may be submitted as indicated in the ADDRESSES caption
above. Comments are solicited to (a) evaluate whether the proposed data
collection is necessary for the proper performance of the agency,
including whether the information shall have practical utility; (b)
evaluate the accuracy of the agency's estimate of the burden of the
proposed collection of information, including the validity of the
methodology and assumptions used; (c) enhance the quality, utility, and
clarity of the information to be collected; and (d) minimize the burden
of the collection of information on those who are to respond, including
through the use of appropriate automated, electronic, mechanical, or
other technological collection techniques or other forms of information
technology, e.g., permitting electronic submission of responses.

Millicent Brown Wilson,
Records Management Branch Chief, Office of the Chief Administrative
Officer, Mission Support, Federal Emergency Management Agency,
Department of Homeland Security.
[FR Doc. 2022-26732 Filed 12-8-22; 8:45 am]
BILLING CODE 9111-1A-P


[Federal Register Volume 86, Number 220 (Thursday, November 18, 2021)]
[Notices]
[Pages 64593-64595]
[FR Doc No: 2021-25112]

-----------------------------------------------------------------------

DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

[Docket No. NHTSA-2019-0129; Notice 1]

Transamerica Tire Co. Ltd., Receipt of Petition for Decision of
Inconsequential Noncompliance

AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).

ACTION: Receipt of petition.

-----------------------------------------------------------------------

SUMMARY: Transamerica Tire Co. Ltd. (Transamerica) has determined that
certain Transeagle ST tires manufactured by Shandong Yinbao Tyre
(Yinbao) do not fully comply with Federal Motor Vehicle Safety Standard
(FMVSS) No. 119, New Pneumatic Tires for Motor Vehicles with a GVWR of
More than 4,536 kilograms (10,000 pounds) and Motorcycles.
Transamerica, on behalf of Yinbao, filed a noncompliance report dated
November 21, 2019. Transamerica petitioned NHTSA on November 25, 2019,
and amended its petition on April 22, 2021, for a decision that the
subject noncompliance is inconsequential as it relates to motor vehicle
safety. This document announces receipt of Transamerica's petition.

DATES: The closing date for comments on the petition is December 20,
2021.

ADDRESSES: Interested persons are invited to submit written data,
views, and arguments on this petition. Comments must refer to the
docket number and notice number cited in the title of this notice and
may be submitted by any of the following methods:
     Mail: Send comments by mail addressed to the U.S.
Department of Transportation, Docket Operations, M-30, West Building
Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC
20590.
     Hand Delivery: Deliver comments by hand to the U.S.
Department of Transportation, Docket Operations, M-30, West Building
Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC
20590. The Docket Section is open on weekdays from 10 a.m. to 5 p.m.
except for Federal Holidays.
     Electronically: Submit comments electronically by logging
onto the Federal Docket Management System (FDMS) website at https://www.regulations.gov/. Follow the online instructions for submitting
comments.
     Comments may also be faxed to<PHONE_NUMBER>.
    Comments must be written in the English language, and be no greater
than 15 pages in length, although there is no limit to the length of
necessary attachments to the comments. If comments are submitted in
hard copy form, please ensure that two copies are provided. If you wish
to receive confirmation that comments you have submitted by mail were
received, please enclose a stamped, self-addressed postcard with the
comments. Note that all comments received will be posted without change
to https://www.regulations.gov, including any personal information
provided.
    All comments and supporting materials received before the close of
business on the closing date indicated above will be filed in the
docket and will be considered. All comments and supporting materials
received after the closing date will also be filed and will be
considered to the fullest extent possible.
    When the petition is granted or denied, notice of the decision will
also be published in the Federal Register pursuant to the authority
indicated at the end of this notice.
    All comments, background documentation, and supporting

materials submitted to the docket may be viewed by anyone at the
address and times given above. The documents may also be viewed on the
internet at https://www.regulations.gov by following the online
instructions for accessing the dockets. The docket ID number for this
petition is shown in the heading of this notice.
    DOT's complete Privacy Act Statement is available for review in a
Federal Register notice published on April 11, 2000, (65 FR 19477-78).

SUPPLEMENTARY INFORMATION:

I. Overview

    Transamerica has determined that certain tires manufactured by
Yinbao do not fully comply with paragraphs S6.5 and S6.5(b) of FMVSS
No. 119, New Pneumatic Tires for Motor Vehicles with a GVWR of More
than 4,536 kilograms (10,000 pounds) and Motorcycles (49 CFR 571.119).
Transamerica, on behalf of Yinbao, filed a noncompliance report dated
November 21, 2019, pursuant to 49 CFR part 573, Defect and
Noncompliance Responsibility and Reports. Transamerica also petitioned
NHTSA on November 25, 2019, for an exemption from the notification and
remedy requirements of 49 U.S.C. Chapter 301 on the basis that this
noncompliance is inconsequential as it relates to motor vehicle safety,
pursuant to 49 U.S.C. 30118(d) and 30120(h) and 49 CFR part 556,
Exemption for Inconsequential Defect or Noncompliance.
    This notice of receipt, of Transamerica's petition, is published
under 49 U.S.C. 30118 and 30120 and does not represent any agency
decision or other exercises of judgment concerning the merits of the
petition.

II. Tires Involved

    Approximately 9,551 Transeagle ST radial tires, sizes ST235/85R16,
ST235/80R16, and ST225/90R16, manufactured between September 23, 2017,
and August 10, 2019, are potentially involved.

III. Noncompliance

    Transamerica explains that the noncompliance is that the subject
tires were inadvertently labeled with a Tire Identification Number
(TIN) that contains an incorrect manufacturer's code and, therefore, do
not meet the requirements specified in paragraph S6.5(b) of FMVSS No.
119. The manufacturer's code is the part of the TIN that is comprised
of a group of six symbols located immediately following the three-
symbol plant code and before the date code, for all new tires. In
addition, the manufacturer's code contains an additional character at
the end of the labeled sequence, inadvertently producing a 14 character
TIN instead of 8-13 character TIN. Specifically, the subject tires were
incorrectly marked with the TIN as ``1BP TTFEFTL'' whereas they should
have been marked as follows:

 ST235/85R16: ``1BP TTFEFT''
 ST235/80R16: ``1BP TFEFTL''
 ST225/90R16: ``1BP TTFEF'' \1\
---------------------------------------------------------------------------

    \1\ In its amended petition submitted on April 22, 2021,
Transamerica acknowledges that this TIN provided as the correction
to these tires is also noncompliant because it does not contain six
symbols as required.
---------------------------------------------------------------------------

IV. Rule Requirements

    Paragraphs S6.5 and S6.5(b) of FMVSS No. 119 include the
requirements relevant to this petition. These requirements state that
each tire shall be marked on one or both sidewalls with the TIN that
meets the requirements of 49 CFR part 574.

V. Summary of Transamerica's Petition

    The following views and arguments presented in this section, ``V.
Summary of Transamerica's Petition,'' are the views and arguments
provided by Transamerica. They have not been evaluated by the Agency
and do not reflect the views of the Agency.
    Transamerica describes the subject noncompliance and contends that
the noncompliance is inconsequential as it relates to motor vehicle
safety.

Background

    On October 21, 2019, Transamerica received a letter from NHTSA
explaining that NHTSA's Office of Vehicle Safety Compliance ``has
received information alleging that at least one of the tires
manufactured by [Yinbao] and imported by [Transamerica] may not be in
compliance with [FMVSS] No. 119.'' Accordingly, the letter included a
``photo showing a labeling failure on the tires branded Transeagle ST
radial size 235/85R16.'' Specifically, it is alleged that ``[t]he tires
appear to have an improper 14 character [TIN] instead of the 8-13
character TIN required by FMVSS No. 119.''
    Transamerica offers the following views and arguments in support of
its petition:
    1. Upon the receipt of NHTSA's inquiry, Transamerica conducted an
investigation to determine the validity of the allegations and the
universe of tires affected by such noncompliance. Transamerica found
that a total number of 9,551 tires branded Transeagle ST radial tires
size ST235/85R16, ST235/80R16, and ST225/90R16 contained an incorrect
manufacturer's code in their TIN labels molded on the sidewall of the
tires. Transamerica says that except for the incorrect manufacturer's
code, all other information labeled on the tires was correct, including
the plant information and the date of production, and that the
Transeagle ST tires otherwise comply with all applicable standards.
Both Yinbao and Transamerica state that they are not aware of any
crashes, injuries, customer complaints, or field reports in connection
with this noncompliance.
    2. Transamerica claims that the noncompliance is inconsequential
because the subject tires meet all FMVSS and performance standards, the
noncompliance is one of labeling, and the inaccurate manufacturer's
code would not affect the manufacturer's or the consumers' ability to
identify them should the tires be recalled for performance related
noncompliance.
    a. The sole noncompliance at issue relates to an inadvertently
labeled manufacturer's code in the TIN on certain tires. While the
subject tires contain an improper manufacturer's code, they are in all
other respects properly labeled and meet all performance requirements
under FMVSS. Inaccurate manufacturer's code identification upon which a
consumer would not reasonably be expected to rely, does not have any
effect on the operational safety of the vehicles on which these tires
are mounted.
    b. Furthermore, the inaccurate manufacturer's code identification
will not affect Transamerica's, Yinbao's, or the consumers' ability to
identify the subject tires, should they be recalled for performance
related to the noncompliance. First, the tires' TIN bears the correct
plant's code and date code, and is still tied to Yinbao's manufacturing
facility. Thus, Transamerica, Yinbao, or the consumers would be
reasonably able to identify the subject tires in the event of a recall.
    c. Transamerica states that they have taken measures to ensure that
the tires can be registered correctly. There is a ``Tire Registration''
option on Transamerica's website where consumers can register their TIN
and contact information. Transamerica has taken steps to ensure that
the incorrect TINs with the additional characters can also be
registered for any future recalls or warranty issues. Furthermore,
Transamerica has already corrected the molds at the applicable
manufacturing plant, such that no additional tires were fabricated with
the noncompliance. Transamerica stated that they will also improve
their internal processes to prevent future TIN errors.

    d. Transamerica states that NHTSA has previously granted petitions
for inconsequential noncompliance where TIN information labels are
incorrect or missing information and that granting this petition would
be consistent with NHTSA's prior decisions on petitions involving tires
labeled with inaccurate TIN information. Transamerica cites the
following petitions:
     Michelin North America, Inc., Grant of Petition for
Decision of Inconsequential Noncompliance, 81 FR 76412 (November 2,
2016).
     Cooper Tire & Rubber Company, Grant of Application for
Decision of Inconsequential Noncompliance, 63 FR 29059 (May 27, 1998).
     Tireco, Inc., Grant of Petition for Decision of
Inconsequential Noncompliance, 80 FR 66614 (October 29, 2015).
     Cooper Tire & Rubber Company, Grant of Petition for
Decision of Inconsequential Noncompliance, 71 FR 4397 (January 26,
2006).
     Cooper Tire & Rubber Company, Grant of Petition for
Decision of Inconsequential Noncompliance, 82 FR 52966 (November 15,
2017).
     Yokohama Tire Corporation, Grant of Petition for Decision
of Inconsequential Noncompliance, 84 FR 64403 (November 21, 2019).
    Transamerica concludes by again contending that the subject
noncompliance is inconsequential as it relates to motor vehicle safety,
and asking that its petition to be exempted from providing notification
of the noncompliance, as required by 49 U.S.C. 30118, and a remedy for
the noncompliance, as required by 49 U.S.C. 30120, be granted.
    Transamerica's complete petition and all supporting documents are
available by logging onto the Federal Docket Management System (FDMS)
website at: https://www.regulations.gov and following the online search
instructions to locate the docket number listed in the title of this
notice.
    NHTSA notes that the statutory provisions (49 U.S.C. 30118(d) and
30120(h)) that permit manufacturers to file petitions for a
determination of inconsequentiality allow NHTSA to exempt manufacturers
only from the duties found in sections 30118 and 30120, respectively,
to notify owners, purchasers, and dealers of a defect or noncompliance
and to remedy the defect or noncompliance. Therefore, any decision on
this petition only applies to the subject tires that Transamerica and
Yinbao no longer controlled at the time it determined that the
noncompliance existed. However, any decision on this petition does not
relieve tire distributors and dealers of the prohibitions on the sale,
offer for sale, or introduction or delivery for introduction into
interstate commerce of the noncompliant tires under their control after
Transamerica and Yinbao notified them that the subject noncompliance
existed.

(Authority: 49 U.S.C. 30118, 30120: delegations of authority at 49
CFR 1.95 and 501.8)

Otto G. Matheke III,
Director, Office of Vehicle Safety Compliance.
[FR Doc. 2021-25112 Filed 11-17-21; 8:45 am]
BILLING CODE 4910-59-P


[Federal Register Volume 82, Number 49 (Wednesday, March 15, 2017)]
[Notices]
[Pages 13917-13918]
[FR Doc No: 2017-05174]

-----------------------------------------------------------------------

DEPARTMENT OF TRANSPORTATION

Federal Aviation Administration

Agency Information Collection Activities: Requests for Comments;
Clearance of Renewed Approval of Information Collection: Medical
Standards and Certification

AGENCY: Federal Aviation Administration (FAA), DOT.

ACTION: Notice and request for comments.

-----------------------------------------------------------------------

SUMMARY: In accordance with the Paperwork Reduction Act of 1995, FAA

invites public comments about our intention to request the Office of
Management and Budget (OMB) approval to renew and revise a previously
approved information collection. The information collected is used to
determine if applicants are medically qualified to perform the duties
associated with the class of airman medical certificate sought. The FAA
is announcing its intent to reduce the burden associated with this
information collection in response to its implementation of section
2307 of Public Law 114-190. Section 2307 of Public Law 114-190
established a new voluntary program of physical examination and
education requirements for certain pilots in command in lieu of those
pilots holding a medical certificate.

DATES: Written comments should be submitted by April 14, 2017.

ADDRESSES: Interested persons are invited to submit written comments on
the proposed information collection to the Office of Information and
Regulatory Affairs, Office of Management and Budget. Comments should be
addressed to the attention of the Desk Officer, Department of
Transportation/FAA, and sent via electronic mail to
<EMAIL_ADDRESS>or faxed to<PHONE_NUMBER>, or mailed to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, Docket Library, Room 10102, 725 17th Street NW.,
Washington, DC 20503.

FOR FURTHER INFORMATION CONTACT: Ronda Thompson by email at:
<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION: You are asked to comment on any aspect of
this information collection, including (a) Whether the proposed
collection of information is necessary for FAA's performance; (b) the
accuracy of the estimated burden; (c) ways for FAA to enhance the
quality, utility and clarity of the information collection; and (d)
ways that the burden could be minimized without reducing the quality of
the collected information. The agency will summarize and/or include
your comments in the request for OMB's clearance of this information
collection.
    OMB Control Number: 2120-0034.
    Title: Medical Standards and Certification.
    Form Numbers: FAA Forms 8500-7, 8500-8, 8500-14, 8500-20.
    Type of Review: Revision of an information collection.
    Background: The Federal Aviation Administration (FAA) Extension,
Safety, and Security Act of 2016 (Pub. L. 114-190) (FESSA) was enacted
on July 15, 2016. Section 2307 of FESSSA, medical certification of
certain small aircraft pilots, directed the FAA to ``issue or revise
regulations to ensure that an individual may operate as pilot in
command of a covered aircraft'' if the pilot and aircraft meet certain
prescribed conditions as outlined in FESSA. The FAA notes that the use
of section 2307 by any eligible pilot is voluntary. Persons may elect
to use these alternative pilot physical examination and education
requirements or may continue to operate using any FAA medical
certificate.
    The FAA is publishing a final rule, Alternative Pilot Physical
Examination and Education Requirements, to implement the provisions of
section 2307 (RIN 2120-AK96).
    Respondents: Approximately 198,847 (8500-8) form applicants.
    Frequency: On occasion.
    Estimated Average Burden per Response: 3 minutes.
    Estimated Total Annual Burden: 9,900 hours.

    Issued in Washington, DC, on March 9, 2017.
Ronda L. Thompson,
FAA Information Collection Clearance Officer, Performance, Policy &
Records Management Branch, ASP-110.
[FR Doc. 2017-05174 Filed 3-14-17; 8:45 am]
BILLING CODE 4910-13-P


77868 3 37.5% 2,420 4.1% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 77905 8 21.6% 2,132 0.0%

77971 1 100.0% 0 0.0%

77977 5 83.3% 1,216 79.1%

77978 9 21.4% 1,887 0.2%

77979 7 23.3% 7,074 0.0%

77983 5 14.7% 1,465 0.0%

78012 1 14.3% 84 0.0%

78071 5 21.7% 3,395 1.5%

78112 10 66.7% 1,532 21.5%

78114 3 100.0% 493 100.0%

78118 1 33.3% 0 0.0%

78132 2 40.0% 2,203 6.3%

78150 1 100.0% 0 0.0%

78154 1 33.3% 38 22.4%

78204 1 100.0% 1,359 100.0%

78210 1 50.0% 31 0.1%

78213 1 33.3% 203 0.1%

78214 1 100.0% 580 100.0%

78215 2 100.0% 535 100.0%

78216 2 40.0% 125 13.1%

78218 2 25.0% 774 24.8%

78219 15 44.1% 3,531 2.8%

78220 1 11.1% 1,779 30.4%

78223 7 100.0% 900 100.0%

78226 2 66.7% 1,823 14.9%

78236 2 66.7% 102 100.0%

78343 9 42.9% 5,553 0.7%

78359 3 9.4% 1,025 0.2%

78363 1 100.0% 16 100.0%

78370 2 100.0% 52 100.0%

78403 1 5.0% 119 0.0%

78407 19 21.6% 7,361 0.3%

78408 3 100.0% 91 100.0%

78409 9 47.4% 7,568 3.4%

78410 8 18.6% 4,035 0.5%

78419 1 33.3% 2 0.0%

78540 1 14.3% 565 13.6%

78550 3 25.0% 629 1.1%

78586 1 100.0% 1,100 100.0% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 78611 5 55.6% 0 0.0%

78624 1 50.0% 5 23.3%

78629 3 100.0% 3 100.0%

78641 1 50.0% 1,437 1.9%

78654 2 100.0% 1,480 100.0%

78724 3 30.0% 66 0.6%

78728 1 50.0% 721 94.7%

78741 1 8.3% 18 0.2%

78748 1 100.0% 1,681 100.0%

78759 1 12.5% 1,404 19.5%

78843 1 100.0% 0 100.0%

78945 2 16.7% 1,701 0.2%

79007 10 27.8% 1,614 0.0%

79008 7 25.0% 4,755 0.4%

79027 1 16.7% 200 0.1%

79045 1 100.0% 133 100.0%

79065 2 9.1% 280 0.0%

79072 1 50.0% 0 0.0%

79086 9 32.1% 4,108 1.1%

79107 2 18.2% 650 0.2%

79109 1 20.0% 0 0.0%

79118 1 50.0% 4 0.0%

79124 1 12.5% 123 2.9%

79360 7 100.0% 199 100.0%

79404 8 72.7% 170 0.0%

79415 1 25.0% 150 46.9%

79535 1 100.0% 713 100.0%

79549 1 100.0% 44 100.0%

79556 3 75.0% 1,230 99.7%

79603 1 25.0% 151 0.2%

79604 12 80.0% 3,442 26.7%

79703 3 75.0% 4,050 12.0%

79711 1 33.3% 943 2.0%

79714 2 28.6% 287 0.1%

79720 3 17.6% 1,085 0.4%

79745 8 100.0% 554 100.0%

79761 6 100.0% 0 0.0%

79762 13 56.5% 6,090 32.8%

79765 11 78.6% 1,339 33.0% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 79766 12 37.5% 6,847 0.4%

79778 6 100.0% 444 100.0%

79905 26 57.8% 12,112 22.6%

79922 3 75.0% 2,208 63.7%

79924 1 100.0% 20 100.0%

79926 7 100.0% 1,375 100.0%

79927 1 9.1% 5 0.0%

79932 2 50.0% 350 100.0%

79934 1 33.3% 430 0.2%

80002 4 57.1% 3,305 38.0%

80011 4 30.8% 1,338 1.5%

80014 1 100.0% 0 0.0%

80021 1 100.0% 10 100.0%

80022 26 43.3% 10,377 3.6%

80026 1 100.0% 0 0.0%

80027 1 100.0% 1 100.0%

80110 1 11.1% 55 34.2%

80125 1 50.0% 0 0.0%

80204 1 25.0% 0 0.0%

80207 1 100.0% 165 100.0%

80216 16 45.7% 4,154 0.3%

80221 1 25.0% 890 5.4%

80223 2 40.0% 18 0.0%

80233 1 33.3% 1 0.0%

80239 1 33.3% 200 19.4%

80301 1 5.6% 600 0.3%

80303 1 100.0% 0 0.0%

80401 2 16.7% 1,800 0.3%

80501 1 33.3% 1,048 98.9%

80537 4 100.0% 5 100.0%

80550 1 10.0% 297 0.1%

80551 1 11.1% 98 0.0%

80601 4 57.1% 1,100 0.6%

80640 6 60.0% 3,876 23.1%

80642 2 40.0% 690 17.8%

80759 1 100.0% 0 0.0%

80860 2 22.2% 916 0.9%

80907 1 14.3% 10 0.1%

80913 1 25.0% 0 0.0% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 81001 3 16.7% 361 2.5%

81007 2 66.7% 1,977 38.4%

81050 4 44.4% 1,105 9.5%

81052 1 16.7% 540 0.8%

81132 2 100.0% 0 0.0%

81226 2 100.0% 743 100.0%

81505 5 71.4% 3,022 28.3%

82005 1 100.0% 0 0.0%

82007 2 18.2% 2,184 0.0%

82009 1 100.0% 15 100.0%

82240 1 50.0% 0 0.0%

82334 1 6.3% 44 0.0%

82401 1 20.0% 52 0.0%

82609 3 23.1% 1,624 3.5%

82636 13 100.0% 3,121 100.0%

82644 2 66.7% 13 0.4%

82701 7 63.6% 6,021 32.9%

82717 1 50.0% 75 3.2%

82718 8 32.0% 1,721 0.1%

82723 1 50.0% 13 0.0%

82901 4 50.0% 309 0.2%

82930 2 28.6% 90 1.8%

83001 1 100.0% 1,425 100.0%

83201 2 20.0% 1,512 0.8%

83211 1 50.0% 0 0.0%

83221 2 40.0% 2 1.5%

83245 2 66.7% 1,215 0.9%

83276 1 5.0% 190 0.0%

83318 2 40.0% 638 0.0%

83338 2 50.0% 23 24.2%

83401 1 100.0% 2 100.0%

83415 1 33.3% 1,360 20.2%

83440 1 100.0% 2 100.0%

83501 7 18.4% 2,695 0.1%

83639 5 100.0% 136 100.0%

83687 2 18.2% 3,099 0.3%

83716 3 27.3% 1,974 2.3%

83837 2 100.0% 0 0.0%

83854 1 20.0% 520 0.3% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 83861 1 100.0% 0 0.0%

84006 7 35.0% 2,581 0.0%

84016 6 35.3% 645 0.6%

84029 6 8.3% 2,398 0.0%

84043 1 33.3% 1,545 21.2%

84044 4 18.2% 1,540 0.0%

84050 1 33.3% 540 5.2%

84054 11 39.3% 1,999 2.7%

84057 1 14.3% 100 0.1%

84070 1 50.0% 846 0.5%

84087 8 25.0% 3,299 3.1%

84088 7 41.2% 653 1.7%

84103 10 47.6% 907 0.6%

84104 3 13.6% 254 0.1%

84116 7 20.6% 1,530 0.5%

84118 3 37.5% 6 0.0%

84119 1 33.3% 750 3.1%

84120 2 28.6% 174 0.1%

84302 6 85.7% 3,137 20.9%

84307 4 57.1% 2,768 0.5%

84330 1 14.3% 511 0.0%

84335 1 33.3% 1,106 0.9%

84401 5 41.7% 3,050 13.0%

84402 1 50.0% 174 7.4%

84404 5 26.3% 2,167 0.1%

84405 2 100.0% 771 100.0%

84513 1 8.3% 0 0.0%

84532 9 100.0% 0 0.0%

84535 9 100.0% 0 0.0%

84601 1 100.0% 82 100.0%

84606 1 16.7% 62 0.0%

84624 2 8.7% 1,900 0.1%

84648 2 66.7% 0 0.0%

84720 5 62.5% 0 0.0%

84751 1 100.0% 0 0.0%

84770 1 20.0% 29 0.0%

85007 9 56.3% 5,511 3.8%

85008 1 11.1% 445 5.2%

85009 7 46.7% 3,181 3.5% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 85019 17 94.4% 2,537 96.8%

85021 1 100.0% 1,149 100.0%

85027 1 50.0% 1,423 2.1%

85029 2 66.7% 401 42.2%

85031 1 100.0% 4 100.0%

85041 7 87.5% 4,861 65.5%

85043 26 50.0% 8,641 2.1%

85202 1 10.0% 250 0.3%

85210 4 57.1% 3,245 2.2%

85220 4 100.0% 2,990 100.0%

85222 1 10.0% 580 0.9%

85224 1 5.6% 1,700 3.1%

85225 1 50.0% 23 21.3%

85226 3 11.1% 589 1.2%

85231 1 16.7% 0 0.0%

85242 1 10.0% 94 0.1%

85248 1 10.0% 1,223 1.4%

85281 2 12.5% 0 0.0%

85283 2 40.0% 1,475 2.6%

85311 2 100.0% 94 100.0%

85322 1 100.0% 8 100.0%

85326 2 100.0% 53 100.0%

85335 6 85.7% 911 24.4%

85337 4 80.0% 0 0.0%

85338 2 33.3% 653 0.9%

85353 1 25.0% 475 1.8%

85365 1 33.3% 58 100.0%

85366 1 100.0% 1,220 100.0%

85369 5 71.4% 343 0.1%

85539 5 71.4% 239 3.2%

85540 2 18.2% 3,100 0.1%

85603 1 50.0% 86 0.0%

85614 3 30.0% 1,459 0.1%

85629 1 20.0% 837 0.2%

85648 1 33.3% 1,770 26.1%

85653 2 66.7% 1,115 80.2%

85706 1 8.3% 720 1.0%

85707 1 100.0% 14 100.0%

85713 6 75.0% 1,088 2.2% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 85745 1 100.0% 1,727 100.0%

85747 1 20.0% 3 0.0%

85936 1 10.0% 0 0.0%

86321 8 66.7% 741 0.2%

86324 3 100.0% 595 100.0%

86401 6 31.6% 3,995 7.9%

86413 2 100.0% 501 100.0%

87031 2 100.0% 3 100.0%

87059 2 66.7% 362 10.2%

87102 1 25.0% 594 1.7%

87105 1 100.0% 594 100.0%

87113 1 11.1% 1,520 14.3%

87117 1 100.0% 0 0.0%

87347 7 43.8% 1,617 1.5%

87401 15 100.0% 4,765 100.0%

87413 7 58.3% 3,909 14.0%

88008 3 37.5% 623 1.0%

88012 1 100.0% 350 100.0%

88031 1 100.0% 26 100.0%

88043 1 16.7% 1,300 0.1%

88103 1 100.0% 0 100.0%

88130 5 100.0% 2,180 100.0%

88210 3 17.6% 2,058 0.8%

88211 8 100.0% 485 100.0%

88240 11 57.9% 2,157 4.9%

88260 1 10.0% 25 0.0%

88330 2 50.0% 0 0.0%

89014 1 100.0% 41 100.0%

89015 3 33.3% 1,279 0.1%

89029 1 6.3% 41 0.0%

89045 2 25.0% 902 0.3%

89191 5 71.4% 39 0.0%

89316 1 50.0% 0 0.0%

89408 3 18.8% 5 0.0%

89414 4 12.9% 1,087 0.0%

89419 3 33.3% 1,790 9.1%

89429 1 100.0% 2 100.0%

89431 2 40.0% 0 0.0%

89438 6 21.4% 1,146 0.0% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 89439 1 16.7% 1,865 4.1%

89506 5 38.5% 1,824 0.6%

89521 1 100.0% 0 0.0%

89701 1 50.0% 0 0.0%

89706 3 42.9% 0 0.0%

89801 2 18.2% 62 0.0%

89803 3 12.0% 59 0.0%

89820 6 40.0% 3,154 1.0%

89821 5 33.3% 4,493 1.0%

89822 8 27.6% 1,451 0.0%

90001 5 38.5% 1,616 1.3%

90011 9 100.0% 160 100.0%

90013 1 100.0% 40 100.0%

90016 1 50.0% 323 16.9%

90021 1 25.0% 15 42.9%

90023 21 32.3% 3,358 0.4%

90031 3 75.0% 2,577 40.4%

90032 2 66.7% 4 2.6%

90040 17 34.0% 3,561 2.2%

90045 1 50.0% 0 0.0%

90051 2 100.0% 6 100.0%

90058 11 28.9% 6,260 1.6%

90059 2 100.0% 0 0.0%

90061 10 100.0% 3,690 100.0%

90063 3 25.0% 1,650 1.4%

90064 1 100.0% 0 0.0%

90220 3 37.5% 373 6.7%

90221 8 47.1% 1,994 8.6%

90222 1 11.1% 78 6.9%

90224 1 33.3% 0 0.0%

90241 1 33.3% 282 0.8%

90245 7 15.9% 2,479 0.1%

90248 4 18.2% 1,568 4.8%

90249 1 25.0% 50 2.1%

90250 3 42.9% 165 4.5%

90255 1 16.7% 25 0.0%

90262 4 26.7% 693 1.5%

90280 16 45.7% 2,038 1.4%

90301 1 8.3% 41 3.8% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 90404 2 50.0% 10 1.3%

90501 5 62.5% 47 12.8%

90502 2 28.6% 1,165 4.6%

90503 19 59.4% 5,788 1.0%

90504 1 33.3% 16 1.0%

90505 2 16.7% 0 0.0%

90509 4 13.3% 308 0.0%

90601 2 100.0% 0 0.0%

90620 2 40.0% 233 52.1%

90631 1 33.3% 0 0.0%

90638 7 53.8% 814 6.2%

90640 8 53.3% 1,347 6.3%

90660 2 100.0% 0 0.0%

90670 26 38.2% 7,056 1.3%

90704 2 100.0% 219 100.0%

90723 11 42.3% 2,401 2.9%

90731 9 64.3% 2,674 7.1%

90744 73 57.0% 17,257 1.0%

90745 14 51.9% 5,551 21.3%

90746 1 12.5% 3 0.0%

90749 9 29.0% 610 0.1%

90802 7 77.8% 2,070 15.1%

90805 18 72.0% 4,115 3.1%

90806 16 94.1% 1,378 20.9%

90807 3 100.0% 0 0.0%

90810 26 46.4% 8,187 5.4%

90813 18 78.3% 613 0.3%

91010 3 37.5% 2 0.0%

91016 1 14.3% 171 0.5%

91311 3 17.6% 1,290 0.5%

91324 1 20.0% 35 0.1%

91342 3 42.9% 554 10.7%

91350 2 50.0% 1,576 12.6%

91352 10 71.4% 60 0.1%

91355 2 25.0% 103 1.0%

91367 2 66.7% 1,988 3.1%

91406 6 60.0% 1,043 0.5%

91411 7 100.0% 1,208 100.0%

91605 1 16.7% 235 0.3% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 91702 7 25.0% 309 0.7%

91706 1 50.0% 750 7.0%

91710 2 20.0% 1,327 5.8%

91730 12 24.5% 3,518 0.9%

91731 2 12.5% 6 0.0%

91733 1 25.0% 0 0.0%

91744 1 25.0% 332 74.4%

91745 4 36.4% 29 0.0%

91746 6 54.5% 820 3.2%

91748 3 30.0% 773 1.6%

91750 2 25.0% 12 0.5%

91752 1 20.0% 587 0.5%

91761 13 59.1% 363 0.2%

91766 4 57.1% 998 0.9%

91768 2 50.0% 291 1.0%

91773 2 100.0% 192 100.0%

91786 1 50.0% 106 2.3%

91911 2 33.3% 1,529 5.0%

92020 7 43.8% 3,149 8.5%

92022 2 100.0% 11 100.0%

92054 2 25.0% 0 0.0%

92065 1 100.0% 82 100.0%

92069 1 20.0% 0 0.0%

92071 1 50.0% 1,532 19.0%

92083 2 16.7% 103 0.2%

92101 1 20.0% 40 0.3%

92106 1 100.0% 0 0.0%

92108 19 86.4% 2,804 25.5%

92113 14 51.9% 9,491 9.4%

92121 4 50.0% 581 6.8%

92123 1 12.5% 0 0.0%

92126 3 33.3% 160 20.4%

92131 1 20.0% 10 0.3%

92173 1 33.3% 37 12.5%

92227 2 40.0% 57 0.0%

92278 2 66.7% 0 0.0%

92309 1 100.0% 0 0.0%

92310 5 55.6% 1 0.0%

92316 24 92.3% 4,500 24.4% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 92324 4 40.0% 2,270 4.7%

92335 10 35.7% 5,267 2.5%

92337 3 15.0% 571 0.6%

92345 1 25.0% 217 2.2%

92356 1 50.0% 15 0.0%

92368 2 20.0% 1,279 0.9%

92374 2 66.7% 27 50.0%

92376 3 100.0% 52 100.0%

92392 1 100.0% 532 100.0%

92503 1 33.3% 0 0.0%

92504 2 40.0% 852 1.1%

92508 2 100.0% 1,478 100.0%

92509 12 80.0% 4,261 36.2%

92570 2 40.0% 1,879 16.6%

92571 1 100.0% 0 0.0%

92583 1 100.0% 23 100.0%

92590 1 8.3% 103 0.1%

92606 3 37.5% 0 0.0%

92614 2 33.3% 0 0.0%

92627 2 33.3% 305 1.2%

92647 6 85.7% 495 51.8%

92648 1 33.3% 0 0.0%

92649 6 66.7% 4,347 96.2%

92677 1 100.0% 153 100.0%

92701 1 50.0% 149 3.5%

92704 3 12.5% 3,053 5.6%

92705 2 25.0% 336 2.5%

92707 11 50.0% 2,219 1.7%

92801 3 37.5% 1,028 7.3%

92806 7 23.3% 149 0.0%

92807 5 55.6% 3,993 1.9%

92821 1 12.5% 1 0.0%

92831 4 18.2% 1,693 1.5%

92841 4 57.1% 833 8.0%

92865 8 28.6% 4,714 1.4%

92867 2 20.0% 64 0.1%

92868 2 66.7% 230 0.2%

92870 1 25.0% 505 17.6%

92880 8 40.0% 330 0.6% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 93001 1 100.0% 614 100.0%

93003 2 100.0% 22 100.0%

93021 2 28.6% 10 0.1%

93033 4 40.0% 1,140 4.9%

93117 1 100.0% 0 0.0%

93245 2 50.0% 1,135 100.0%

93270 2 66.7% 20 0.1%

93272 1 100.0% 1,569 100.0%

93274 1 10.0% 0 0.0%

93291 1 12.5% 5 0.0%

93308 28 44.4% 5,351 3.5%

93313 1 100.0% 1,448 100.0%

93420 7 31.8% 2,885 1.8%

93446 1 25.0% 32 0.1%

93454 1 33.3% 1,549 7.2%

93455 1 100.0% 373 100.0%

93501 2 25.0% 721 2.3%

93502 1 50.0% 148 0.4%

93536 1 100.0% 82 100.0%

93554 3 100.0% 580 100.0%

93555 1 50.0% 0 0.0%

93561 1 100.0% 1 100.0%

93562 2 25.0% 560 0.6%

93627 1 33.3% 778 6.0%

93630 1 100.0% 151 100.0%

93637 5 71.4% 607 0.6%

93639 3 75.0% 13 0.0%

93657 1 25.0% 24 0.4%

93662 2 100.0% 246 100.0%

93701 1 50.0% 0 0.0%

93706 1 16.7% 0 0.0%

93721 2 100.0% 163 100.0%

93725 4 80.0% 3,264 13.3%

93901 1 100.0% 300 100.0%

93954 6 54.5% 2,991 1.0%

94063 1 14.3% 35 0.0%

94070 3 50.0% 1,001 10.3%

94080 9 64.3% 2,177 19.1%

94085 1 50.0% 88 94.6% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 94124 2 100.0% 28 100.0%

94128 1 20.0% 250 1.9%

94501 1 33.3% 196 22.1%

94509 3 50.0% 2,047 9.2%

94510 8 28.6% 3,257 0.3%

94533 4 22.2% 383 0.3%

94538 5 17.9% 2,946 0.5%

94544 3 30.0% 230 1.0%

94545 8 38.1% 611 0.7%

94551 1 100.0% 65 100.0%

94553 40 40.8% 10,264 0.4%

94558 1 33.3% 348 0.4%

94559 1 50.0% 2 0.0%

94560 3 30.0% 10 0.0%

94565 19 35.8% 5,668 1.9%

94572 2 9.1% 1,250 0.2%

94577 4 44.4% 3,297 1.0%

94590 3 100.0% 45 100.0%

94601 2 25.0% 1,363 3.3%

94607 1 33.3% 35 1.1%

94608 2 33.3% 304 4.9%

94621 1 50.0% 125 0.8%

94801 6 18.8% 1,826 0.2%

94802 16 88.9% 159 9.6%

94804 9 31.0% 2,480 3.5%

94952 3 60.0% 0 0.0%

95014 3 75.0% 122 0.3%

95017 2 100.0% 32 100.0%

95023 4 66.7% 1,075 96.5%

95035 4 36.4% 168 1.4%

95050 3 18.8% 1,805 0.8%

95122 1 50.0% 6 0.1%

95125 1 50.0% 1,224 81.7%

95131 11 35.5% 3,123 0.9%

95133 6 37.5% 2,981 2.5%

95138 1 100.0% 0 0.0%

95203 13 48.1% 3,789 1.0%

95206 4 22.2% 201 0.2%

95208 1 20.0% 1 1.3% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 95215 1 100.0% 0 0.0%

95301 2 50.0% 1 100.0%

95324 1 25.0% 700 0.0%

95330 1 33.3% 836 4.7%

95354 1 14.3% 513 2.8%

95357 1 33.3% 0 0.0%

95367 1 10.0% 36 0.0%

95376 6 50.0% 733 5.4%

95389 1 100.0% 0 0.0%

95457 7 50.0% 1,310 0.1%

95482 7 77.8% 2,659 74.1%

95492 1 50.0% 120 12.4%

95531 1 50.0% 0 0.0%

95564 1 16.7% 740 0.0%

95624 5 50.0% 5 0.0%

95670 2 50.0% 30 0.0%

95677 1 25.0% 1,962 1.6%

95678 1 33.3% 0 0.0%

95691 10 50.0% 4,053 11.9%

95695 1 100.0% 0 0.0%

95818 8 57.1% 2,912 40.7%

95824 1 33.3% 0 0.0%

95827 2 66.7% 1,643 37.5%

95901 2 100.0% 500 100.0%

95928 4 80.0% 478 60.7%

95950 1 100.0% 0 0.0%

96003 1 25.0% 334 1.1%

96007 1 33.3% 1,096 7.1%

96094 1 50.0% 790 0.6%

96705 6 75.0% 3,555 17.2%

96707 12 36.4% 5,151 0.4%

96720 6 66.7% 2,028 0.7%

96752 1 50.0% 83 1.8%

96766 1 100.0% 1 100.0%

96817 21 84.0% 4,290 9.1%

96857 1 25.0% 18 0.0%

96860 1 25.0% 290 0.3%

96913 5 83.3% 4,598 65.9%

96915 3 60.0% 680 0.5% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 96925 3 42.9% 2,647 10.4%

96950 14 100.0% 5,568 100.0%

97005 1 25.0% 450 4.8%

97013 2 33.3% 0 0.0%

97015 2 28.6% 2,066 13.1%

97022 1 100.0% 500 100.0%

97051 3 17.6% 1,870 0.1%

97055 1 100.0% 9 100.0%

97058 4 80.0% 307 3.1%

97062 2 25.0% 73 0.5%

97071 5 62.5% 1,909 11.8%

97124 1 6.7% 0 0.0%

97140 1 100.0% 41 100.0%

97141 1 25.0% 968 100.0%

97202 2 25.0% 0 0.0%

97203 16 43.2% 7,616 0.3%

97206 1 12.5% 480 1.5%

97210 41 58.6% 25,697 1.9%

97211 2 66.7% 104 0.3%

97217 3 13.6% 728 0.3%

97218 2 40.0% 451 3.5%

97221 1 100.0% 500 100.0%

97222 1 14.3% 350 0.8%

97224 3 75.0% 898 8.5%

97227 14 100.0% 1,949 100.0%

97230 3 27.3% 1,978 13.8%

97231 2 33.3% 233 9.6%

97267 1 50.0% 0 0.0%

97303 2 14.3% 1,211 3.4%

97309 1 12.5% 537 2.1%

97321 6 14.3% 1,715 0.1%

97333 2 100.0% 1,165 100.0%

97338 1 14.3% 60 0.4%

97348 3 18.8% 1,859 0.2%

97370 1 100.0% 54 100.0%

97383 1 100.0% 274 100.0%

97391 1 10.0% 25 0.0%

97402 12 30.0% 1,442 0.3%

97459 3 75.0% 2,754 7.5% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 97470 1 25.0% 128 0.1%

97477 5 41.7% 2,236 3.2%

97478 2 12.5% 68 0.0%

97479 1 100.0% 1,248 100.0%

97501 1 12.5% 31 0.0%

97503 1 10.0% 15 0.0%

97526 1 25.0% 0 0.0%

97601 1 25.0% 876 0.2%

97603 3 75.0% 2,570 1.2%

97701 1 100.0% 1 100.0%

97754 1 100.0% 0 0.0%

97756 1 25.0% 42 4.6%

97801 4 80.0% 39 0.3%

97812 1 6.3% 117 0.0%

97818 1 11.1% 0 0.0%

97828 1 100.0% 0 0.0%

97850 1 16.7% 107 0.0%

97862 1 100.0% 0 0.0%

98001 1 100.0% 600 100.0%

98014 1 100.0% 0 0.0%

98021 2 100.0% 5 100.0%

98032 6 31.6% 3,123 0.5%

98046 1 100.0% 10 100.0%

98055 9 50.0% 2,369 2.3%

98065 2 100.0% 1,862 100.0%

98072 3 75.0% 477 100.0%

98101 1 100.0% 0 0.0%

98102 1 50.0% 55 42.3%

98106 3 42.9% 124 0.7%

98107 4 36.4% 1,934 14.2%

98108 11 50.0% 1,038 1.3%

98134 21 67.7% 5,415 63.4%

98168 2 100.0% 165 100.0%

98178 2 25.0% 374 4.5%

98188 1 25.0% 797 19.2%

98203 4 19.0% 1,750 0.5%

98221 18 31.0% 5,083 0.5%

98226 1 33.3% 492 0.8%

98230 7 28.0% 209 0.1% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 98248 12 40.0% 6,882 1.3%

98272 1 50.0% 171 1.1%

98284 1 50.0% 0 0.0%

98368 1 12.5% 31 0.0%

98390 3 100.0% 1,130 100.0%

98409 3 33.3% 1 0.0%

98421 8 14.3% 2,562 0.2%

98422 1 33.3% 1 0.0%

98424 1 50.0% 118 1.8%

98433 1 33.3% 0 0.0%

98446 1 20.0% 0 0.0%

98498 1 100.0% 174 100.0%

98507 1 25.0% 305 0.1%

98532 1 16.7% 630 53.3%

98537 1 12.5% 560 0.3%

98625 1 5.3% 77 0.1%

98626 1 100.0% 484 100.0%

98632 7 16.7% 425 0.0%

98660 6 60.0% 260 27.4%

98671 7 70.0% 2,249 8.8%

98901 2 50.0% 0 0.0%

98936 1 100.0% 1,574 100.0%

98944 2 50.0% 15 33.3%

99001 1 100.0% 1,274 100.0%

99016 1 33.3% 500 14.8%

99163 2 100.0% 0 0.0%

99166 1 25.0% 4 0.0%

99212 7 46.7% 757 2.5%

99215 4 36.4% 1,106 3.1%

99216 4 23.5% 2,708 1.2%

99218 1 50.0% 0 0.0%

99301 8 38.1% 748 4.9%

99336 5 71.4% 1,090 0.1%

99337 2 33.3% 279 0.1%

99352 2 25.0% 1 0.0%

99363 2 11.1% 119 0.0%

99501 15 60.0% 7,590 0.0%

99506 1 100.0% 6 100.0%

99515 3 100.0% 1,858 100.0% Table 9: Option 4 Community Data Loss Analysis Zip Codes Where One or More Form R Converts to a Form A When the Threshold for Non PBT Chemicals is 2,000 Pounds ( based on RY 2002 data)

Forms Converting from Form R to Form A Total Release ( 8.1) Lbs No Longer Reported Zip Code Number Percent of Forms Number Percent of Total Releases 99553 1 100.0% 0 0.0%

99611 12 41.4% 5,247 0.3%

99613 1 100.0% 0 0.0%

99686 1 100.0% 241 100.0%

99701 3 100.0% 425 100.0%

99705 1 12.5% 43 0.1%

99752 1 10.0% 36 0.0%

99801 3 42.9% 919 0.0%


TECHNICAL SUPPORT FOR OTHER TECHNICAL ISSUES ADDRESSED IN REVISIONS TO SUBPART I       Office of Air and Radiation, U.S. Environmental Protection Agency

                                  August 2012

1. Introduction
This document presents technical support for the following proposed changes in subpart I, Electronics Manufacturing, of the Greenhouse Gas Reporting Program (GHGRP):
   * addressing situations where research and development (R&D) activities are integrated with regular facility production;
   * revising the definition of maximum substrate starts;
   * clarifying and revising the heel factor provisions;
   * revising the nitrous oxide(N2O) default emission factor and clarifying N2O regulatory language; and
   * revising the measurement equipment accuracy and precision requirements.
This document is based on information from Technical Support Document for Process Emissions from Electronics Manufacture (e.g., Micro-electro-mechanical systems, liquid crystal displays, photovoltaics, and semiconductors): Proposed Rule for Mandatory Reporting of Greenhouse Gases, Revised  -  November 2010 (hereafter, the November 2010 TSD, available in docket EPA-HQ-OAR-2009-0927).  It is also based on non-confidential materials submitted to the EPA by the Semiconductor Industry Association (SIA).
2. Integrated Production and Research and Development Processes
Per 40 CFR 98.2(a)(5), emissions resulting from research and development (R&D) activities are not considered to be part of any source category under the GHGRP. However, in its petition for reconsideration of subpart I, SIA raised the issue that for some electronics manufacturing facilities (particularly semiconductor facilities) R&D operations are integrated with regular manufacturing operations to better evaluate process manufacturability (SIA, 2011). Accordingly, SIA suggested that it would be burdensome on facilities that have integrated R&D activities to segregate R&D emissions from process emissions that are required to be reported. While the provisions in subpart A make it clear that reporting R&D emissions is not required, this does not preclude facilities that have integrated R&D activities to report those R&D emissions as part of regular facility manufacturing emissions. Since this is a important issue for subpart I, the EPA is proposing that subpart I facilities that include R&D emissions in their report (1) specify this in their report and (2) provide an estimated percent, on a carbon dioxide equivalent (CO2e) basis, of annual emissions that are attributable to R&D activities. To provide flexibility and ease burden on reporters, the EPA is not specifying the methods facilities must use to estimate the percent of R&D emissions; however, the EPA is proposing that facilities maintain records of the calculation of the percent of total emissions of F-GHG and N2O attributable to R&D activities. These provisions would reduce burden on reporters with integrated R&D activities while still collecting information that will allow the EPA to compare non-R&D emissions across industries within the GHGRP.
3. Calculating Annual Manufacturing Capacity and Applicability Determinations
In the December 2010 version of subpart I (75 FR 74774) EPA finalized a definition of maximum designed substrate starts that read as follows:
      Maximum designed substrate starts means the maximum quantity of substrates, expressed as surface area, that could be started each month during a reporting year if the facility were fully equipped as defined in the facility design specifications and if the equipment were fully utilized. It denotes 100 percent of annual manufacturing capacity of a facility.
Maximum designed substrate starts is used as the basis for determining a facility's annual manufacturing capacity in Equation I-5, and annual manufacturing capacity is subsequently used in subpart I threshold applicability determinations.
In its Petition for Reconsideration of subpart I, SIA noted however that, "The maximum capacity calculation, as set forth in the Final Subpart I, rests on two assumptions: (1) a facility has a full complement of equipment that corresponds to its design; and (2) this full complement of equipment is utilized to a maximum degree. Due to many factors, including ramping of production (both up and down) to meet market demand and retooling for new products, these assumptions do not reflect reality at most facilities most of the time." (SIA, 2011) In some cases, this may result in a facility triggering the reporting threshold in subpart I even though the actual capacity of the facility would not reach the estimated annual manufacturing capacity of the facility based on maximum designed substrate starts and calculated per the provisions in subpart I.
To better reflect a facility's actual potential to emit (on which threshold applicability calculations are based, see the November 2010 TSD), the EPA is proposing to amend the definition of "maximum designed substrate starts" so that it reflects the equipped capacity of the facility based on the equipment actually available for production and not on the designed capacity. The EPA is also proposing to revise the defined term to read "maximum substrate starts" to reflect the concept that annual capacity of a facility would no longer be based on the facility design, but actual installed capacity. The EPA is proposing to define "maximum substrate starts" as:
   The maximum quantity of substrates, expressed as surface area, that could be started each month during a reporting year based on the equipment installed in that facility and assuming that the installed equipment were fully utilized. Manufacturing equipment is considered installed when it is on the manufacturing floor and connected to required utilities.
4. Facility-Wide Gas-Specific Heel Factor Provisions
The December 2010 subpart I required facilities to re-calculate a facility-wide gas-specific heel factor if they use a trigger point for change out for a gas and container type that differs by more than five percent from the previously used trigger point for change out for that gas and container type. In its Petition for Reconsideration, SIA raised the following issue with regard to this requirement: "While this requirement seems reasonable on its face, adhering to the technical specifications of this requirement in practice raises compliance difficulties. For example, under this requirement, if the trigger point used by a facility for a 20-pound container is two pounds, then any change in that trigger point of more than 0.1 pounds would require a facility to `recalculate a facility-wide gas-specific heel factor,'..." (SIA, 2011) SIA further noted that such a small change may represent process adjustments made to ensure that high yields of products are maintained, or may represent minor trigger point variations that are inherent when dealing with small quantities of gas.
After considering this issue, the EPA has concluded that the intent of the provisions for recalculation of heel factors in subpart I in the December 2010 rule should be clarified. Therefore, the EPA is proposing an amendment to clarify the requirements in subpart I to state that a facility needs to recalculate a facility-wide gas-specific heel factor only if the facility executes a process change to modify the trigger point for a gas and container type that differs by more than five percent from the previously used trigger point for change out for that gas and container type. This amendment would clarify that variation in the actual heel left in gas containers would not result in a facility being required to recalculate heel factors. Recalculation of heel factors is needed only when there is an intentional change in the trigger point to reflect a process change at the facility.
SIA raised a similar measurement issue to the one described above for "small" gas containers with respect to the exceptional circumstance provisions in subpart I. The EPA included provisions in the December 2010 version of subpart I to account for situations or "exceptional circumstances" where gas containers are changed out at a point that deviates substantially from the a trigger point set for a given container. These exceptional circumstance provisions are intended to ensure that gas consumption is properly accounted for in these cases when estimating emissions. If an exceptional circumstance were to occur, subpart I requires that the amount of gas used for that container be manually measured (e.g., with a scale, pressure gauge, etc...) instead of relying on the heel factor for that gas and container type. EPA set the exceptional circumstance threshold at 20 percent or more than the set trigger point for change out for a container.
In its petition, SIA noted that the 20 percent limit presents difficulties when tracking exceptional circumstances for small containers because of the small quantities of gas that would be represented by an exceptional circumstance and that would have to be tracked. This comment prompted EPA to re-evaluate the exceptional circumstances threshold.
In looking at Table 1, which presents gas container data provided by SIA, it can be seen that the range in sizes of gas containers used in the semiconductor manufacturing industry is quite broad. In deciding how to define a small container the EPA took into account an example from SIA examining containers of 20 pounds (approximately 9.08 kg) (SIA, 2011). The EPA also concluded there was a logical break in the gas container size data at 20 pounds (approximately 9.08 kg) (see gray highlighted row in Table 1). The EPA then evaluated how the 20 pounds or less small gas containers criteria would impact the minimum quantity of gas that would be required to be tracked manually in the case of exceptional circumstances.
The EPA evaluated three alternative exceptional circumstance thresholds (25 percent, 50 percent, and 75 percent) to determine how an alternative threshold would translate into minimum gas quantities (kg) that would have to be manually tracked. It can be seen in moving from the current 20 percent threshold to a 25 percent threshold does not change the quantity of gas for small containers that would have to be tracked manually significantly, or at all in some cases. In moving to a 50 percent from a 20 percent there are substantial changes in the quantity of gas associated with the exceptional circumstance threshold; in many cases double the quantity of gas. The quantities seen under the 50 percent column for small gas containers (above the gray line) are also similar to many quantities seen for large gas containers under the 20 percent column (under the gray line). Moving to a 75 percent exceptional circumstance threshold for small containers results in a much larger rise in the gas quantity associated with the exceptional circumstance threshold, mostly resulting in quantities that are bigger than those seen for some large gas containers at the 20 percent threshold (below the gray line). In light of this analysis the EPA is proposing to define an exceptional circumstance for small gas containers, defined as 9.08 kg (20 pounds) or less, as a 50 percent deviation from the trigger point for container change out. This proposed threshold would provide a balance between the feasibility and burden associated with tracking exceptional circumstances, taking into account normal variation in day-to-day container management that would be more likely to trigger an exceptional circumstance, while providing EPA with accurate gas usage information. For larger containers, the EPA is proposing to maintain the 20 percent exceptional circumstance threshold currently in subpart I.
          Table 1. Analysis of Exceptional Circumstances (SIA, 2012a)
                                      Gas
                            Full Weight of Gas (kg)
                                 Heel Fraction
                               Heel Weight (kg)
                             Used Gas Weight (kg)
  Mass of Gas (kg) Reflected at Different Exceptional Circumstance Thresholds

                 20 Percent Exceptional Circumstance Threshold
                 25 Percent Exceptional Circumstance Threshold
                 50 Percent Exceptional Circumstance Threshold
                 75 Percent Exceptional Circumstance Threshold
                                      CF4
                                     0.82
                                     5.00%
                                     0.04
                                     0.78
                                     0.01
                                     0.01
                                     0.02
                                     0.03
                                     CH3F
                                     1.36
                                    21.00%
                                     0.29
                                     1.08
                                     0.06
                                     0.07
                                     0.14
                                     0.21
                                     C4F6
                                     2.72
                                     7.00%
                                     0.19
                                     2.53
                                     0.04
                                     0.05
                                     0.10
                                     0.14
                                     CH2F2
                                     3.18
                                    20.00%
                                     0.64
                                     2.54
                                     0.13
                                     0.16
                                     0.32
                                     0.48
                                     CH2F2
                                     4.54
                                    20.00%
                                     0.91
                                     3.63
                                     0.18
                                     0.23
                                     0.45
                                     0.68
                                     CH3F
                                     4.54
                                    21.00%
                                     0.95
                                     3.58
                                     0.19
                                     0.24
                                     0.48
                                     0.71
                                     CH3F
                                     6.80
                                    13.00%
                                     0.88
                                     5.92
                                     0.18
                                     0.22
                                     0.44
                                     0.66
                                     CHF3
                                     6.80
                                     5.00%
                                     0.34
                                     6.46
                                     0.07
                                     0.09
                                     0.17
                                     0.26
                                     C4F8
                                     6.94
                                    10.00%
                                     0.69
                                     6.25
                                     0.14
                                     0.17
                                     0.35
                                     0.52
                                     CH3F
                                     8.62
                                    10.00%
                                     0.86
                                     7.76
                                     0.17
                                     0.22
                                     0.43
                                     0.65
                                     C5F8
                                     8.98
                                    10.00%
                                     0.90
                                     8.08
                                     0.18
                                     0.22
                                     0.45
                                     0.67
                                      CF4
                                     18.14
                                     5.00%
                                     0.91
                                     17.24
                                     0.18
                                     0.23
                                     0.45
                                     0.68
                                      SF6
                                     18.14
                                     6.00%
                                     1.09
                                     17.06
                                     0.22
                                     0.27
                                     0.54
                                     0.82
                                     C4F8
                                     19.96
                                    10.00%
                                     2.00
                                     17.96
                                     0.40
                                     0.50
                                     1.00
                                     1.50
                                     CHF3
                                     21.32
                                    11.10%
                                     2.37
                                     18.95
                                     0.47
                                     0.59
                                     1.18
                                     1.77
                                     CHF3
                                     21.32
                                    11.10%
                                     2.37
                                     18.95
                                     0.47
                                     0.59
                                     1.18
                                     1.77
                                      NF3
                                     21.77
                                     5.00%
                                     1.09
                                     20.68
                                     0.22
                                     0.27
                                     0.54
                                     0.82
                                      NF3
                                     21.77
                                     5.00%
                                     1.09
                                     20.68
                                     0.22
                                     0.27
                                     0.54
                                     0.82
                                     C4F8
                                     22.68
                                    10.00%
                                     2.27
                                     20.41
                                     0.45
                                     0.57
                                     1.13
                                     1.70
                                      NF3
                                     22.68
                                     5.00%
                                     1.13
                                     21.55
                                     0.23
                                     0.28
                                     0.57
                                     0.85
                                      NF3
                                     22.68
                                     4.00%
                                     0.91
                                     21.77
                                     0.18
                                     0.23
                                     0.45
                                     0.68
                                     C4F8
                                     23.13
                                    10.00%
                                     2.31
                                     20.82
                                     0.46
                                     0.58
                                     1.16
                                     1.73
                                     C4F8
                                     31.75
                                     7.00%
                                     2.22
                                     29.53
                                     0.44
                                     0.56
                                     1.11
                                     1.67
                                     C4F8
                                     31.75
                                     5.00%
                                     1.59
                                     30.16
                                     0.32
                                     0.40
                                     0.79
                                     1.19
                                      CF4
                                     31.75
                                     5.00%
                                     1.59
                                     30.16
                                     0.32
                                     0.40
                                     0.79
                                     1.19
                                      CF4
                                     31.75
                                     5.00%
                                     1.59
                                     30.16
                                     0.32
                                     0.40
                                     0.79
                                     1.19
                                     CH2F2
                                     31.75
                                     2.90%
                                     0.92
                                     30.83
                                     0.18
                                     0.23
                                     0.46
                                     0.69
                                     CHF3
                                     34.02
                                    14.00%
                                     4.76
                                     29.26
                                     0.95
                                     1.19
                                     2.38
                                     3.57
                                     C2F6
                                     43.09
                                     6.00%
                                     2.59
                                     40.51
                                     0.52
                                     0.65
                                     1.29
                                     1.94
                                      SF6
                                     43.09
                                     6.00%
                                     2.59
                                     40.51
                                     0.52
                                     0.65
                                     1.29
                                     1.94
                                     C2F6
                                     45.36
                                     5.00%
                                     2.27
                                     43.09
                                     0.45
                                     0.57
                                     1.13
                                     1.70
                                      SF6
                                     45.36
                                     5.00%
                                     2.27
                                     43.09
                                     0.45
                                     0.57
                                     1.13
                                     1.70
                                      SF6
                                     45.36
                                    10.00%
                                     4.54
                                     40.82
                                     0.91
                                     1.13
                                     2.27
                                     3.40
                                      SF6
                                     45.36
                                     6.00%
                                     2.72
                                     42.64
                                     0.54
                                     0.68
                                     1.36
                                     2.04
                                      SF6
                                     45.36
                                     5.00%
                                     2.27
                                     43.09
                                     0.45
                                     0.57
                                     1.13
                                     1.70
                                     C3F8
                                     47.63
                                     9.50%
                                     4.52
                                     43.10
                                     0.90
                                     1.13
                                     2.26
                                     3.39
                                     C4F8
                                     49.58
                                     2.00%
                                     0.99
                                     48.59
                                     0.20
                                     0.25
                                     0.50
                                     0.74
                                      NF3
                                    219.99
                                     4.00%
                                     8.80
                                    211.19
                                     1.76
                                     2.20
                                     4.40
                                     6.60
                                      CF4
                                    260.82
                                     5.00%
                                     13.04
                                    247.77
                                     2.61
                                     3.26
                                     6.52
                                     9.78
                                      CF4
                                    326.59
                                     5.00%
                                     16.33
                                    310.26
                                     3.27
                                     4.08
                                     8.16
                                     12.25
                                     CHF3
                                    362.87
                                     5.00%
                                     18.14
                                    344.73
                                     3.63
                                     4.54
                                     9.07
                                     13.61
                                      NF3
                                    362.87
                                     1.90%
                                     6.89
                                    355.98
                                     1.38
                                     1.72
                                     3.45
                                     5.17
                                     C2F6
                                    430.91
                                     6.00%
                                     25.85
                                    405.06
                                     5.17
                                     6.46
                                     12.93
                                     19.39
                                      NF3
                                    498.95
                                    10.00%
                                     49.90
                                    449.06
                                     9.98
                                     12.47
                                     24.95
                                     37.42
                                     C4F8
                                    544.31
                                     2.00%
                                     10.89
                                    533.42
                                     2.18
                                     2.72
                                     5.44
                                     8.16

5. Estimating N2O Emissions
The EPA is proposing two amendments to the provisions for estimating N2O emissions from electronics manufacturing. The first is to clarify the intent of the provisions, and the second is to revise the default emission factor (EF) for N2O emissions from all processes other than chemical vapor deposition (CVD).
The EPA is proposing to revise the language in subpart I to clarify that the intent of the December 2010 final rule is to require facilities to estimate only two distinct types of N2O emissions (i.e., two N2O emissions numbers). These are (1) the aggregate of N2O emissions resulting from chemical vapor deposition (CVD) processes and (2) the aggregate of N2O emissions resulting from all other N2O-using processes at an electronics manufacturing facility. This clarification is being proposed in response to questions raised in SIA's petition about EPA's intent in the December 2010 final rule because of minor differences in wording in the rule sections for calculating and reporting emissions. These differences made the requirement ambiguous about whether reporting is for each kind of process or all processes combined.
Second, the EPA is proposing to revise the default emission factor provided in Table I-8 to subpart I representing non-CVD N2O-using processes in light of new emission data and information submitted as a result of investigating and developing the proposed stack testing option. N2O stack test data indicated that the N2O emission factors for a fab may be above 1.0 (for all processes). Table 2 below presents the emission factor data collected through stack testing from two companies.
                  Table 2. N2O Emission Factors (SIA, 2012b)
Company/Fab
Available N2O EFs
Average Fab N2O EFs
Company F Fab1
                                     0.87
                                     1.15

                                      1.7

                                     1.89

                                     0.77

                                     1.15

                                     0.54

Company F Fab 2
                                     1.76
                                     1.76
Company D
                                     0.34
                                     0.50

                                     0.66

Average Across All Three Fabs
                                     1.14
            Note: N2O data from Company F, Fab 1 for the years 2003 to 2005 were not used because
            it was reported to EPA that these EFs were based on incorrectly recorded N2O usage data.
            These data are not reflected in table above. (SIA, 2012c)
The EPA and SIA could not identify the cause of the N2O emission factors reported in Table 2 that are greater than 1.0 (SIA, 2012c). N2O is not generally known to be a by-product from processes used in electronics manufacturing; however, the data presented in Table 2 indicate that there may be a physical or chemical process that results  in N2O being formed. Therefore, the EPA is proposing to revise the default N2O emission factor for the aggregate of other N2O-using processes to be 1.14, based on the average of the data in Table 2. The EPA is not proposing to revise the default N2O EF for CVD processes because EPA has historical data supporting this EF (see the November 2010 TSD for a discussion of this data and setting the N2O CVD default EF) and no new data are available indicating this EF should be revised.

6. Accuracy and Precision of Measurement Equipment
The EPA is proposing to revise the accuracy and precision requirements for measurement equipment at 40 CFR 98.94(i). The December 2010 version of subpart I has a requirement that all measurement equipment (e.g., flow meters, weigh scales, pressure gauges, and thermometers) have an accuracy and precision of one percent of full scale or better. In light of new information submitted by SIA in its petition (SIA, 2011) and in response to questions from the EPA, the EPA is proposing to revise the accuracy and precision requirements of subpart I to 1) remove the subpart-specific requirements and 2) reference the general calibration and accuracy requirements in subpart A (see 40 CFR 98.3(i)). The EPA is proposing this modification because although the majority of new facilities and new equipment will be able to meet the one percent of full scale accuracy requirement, many older facilities have accuracies of two to four percent (SIA, 2011). Modifying the requirements would reduce the burden for facilities that would otherwise have to make capital investments to upgrade measurement equipment to meet the one percent of full scale provision. This provision modification is not expected to impact the accuracy of facility GHG emission estimates at facilities that are using measurement equipment that met the one percent of full scale standard. It may impact the accuracy of F-GHG emission estimates, particularly at older facilities that have less accurate measurement equipment.  The accuracy requirements in subpart A that EPA is proposing to apply to subpart I are a minimum requirement. Facilities that are currently meeting the higher accuracy standard in subpart I would be expected to continue to use the same monitoring equipment and achieve the same level of accuracy, and would not be expected to "fall back" to the minimum accuracy requirement in subpart A by, for example, replacing current equipment with less accurate monitoring equipment. Additionally, as older facilities and equipment are replaced and newer facilities come online, the industry is expected to trend towards using more accurate and precise measurement equipment.
7. References
SIA (2011). Semiconductor Industry Associated Petition for Reconsideration and Request for Stay Pending Reconsideration of Subpart I of the Final Rule for Mandatory Reporting of Greenhouse Gases. January 31, 2011. Available in docket EPA - HQ - OAR - 2011-0028.
SIA (2012a). Appendix 4 - Gas Cylinder Heel Triggers Industry. February 6, 2012.  Available in docket EPA - HQ - OAR - 2011-0028.
SIA (2012b). Response to EPA's Stack Test Question 1. March 7, 2012. Available in docket EPA - HQ - OAR - 2011-0028.
SIA (2012c). Outstanding Questions / Topics from SIA / EPA Discussions as of April 24, 2012 Response as of April 26, 2012. April 26, 2012. Available in docket EPA - HQ - OAR - 2011-0028.