EPA’s Revised GHG Rule for Electronics and Semiconductor Manufacturers Reply

The United States Environmental Protection Agency (EPA) has issued a pre-published version of their revised Greenhouse Gas reporting rule for electronics and semiconductor manufacturers(40 CFR Part 98 Subpart I). There are many changes in this revision that will reduce the QA/QC requirements of the rule.

The major highlights include modifications to the apportioning model requirement as well as the addition of a stack testing option for reporting emissions. For those facilities that track actual gas consumption, the apportioning model will no longer be required. However, for the facilities that will still need the apportioning model to track their gas usage, the verification standard used to measure actual gas usage from modeled gas usage will be increased from 5 percent to 20 percent. The stack testing option is an alternative method for calculating process gas emissions in place of the standard calculations provided by the subpart.

As the regulation is effective January 2014, RY2013 reporting will not be affected. The regulation will affect 2014 reporting which will be submitted in 2015.

If you have any questions, or require more information or assistance, please contact John Baycroft at 508.970.0033 ext. 144 or jbaycroft@capaccio.com.