Review Comments by Experts on the Second Order Draft of Volume 3 of 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories
Comment ID Volume

Chapter

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7546

3

0

1432

3

3

192

193

1434

3

3

192

193

368

3

3

798

967

Comment

ExpertResponse

During the review exams, we learned, that the 'IPCC guidance has been
Eva Krtkova
structured so that any country, regardless of experience or resources, shouldbe able to produce reliable estimates of its emissions and removals of thesegases. In particular, default values of the various parameters and EFs
required are supplied for all sectors, so that, at its simplest, a country needs
only supply national AD. The apporach also allows countries with more
information and resources to use more detailed country-specificmethodologies while retaining compatibility, comparibility and consistency
between countries.' However, the way the guidance is proposed now is not
fulfilling this statement. Some of the parts in the IPPU are written in very
difficult and hard-to-understand ways, which will not help the countries toreport and understand the processes in easy way.

Noted

Edit Table 3.3 footnotes -- "Old (pre-1975) plants means that the EF is to be Robert Lanza
used for all process technologies that were installed before 1975 and thatare still operating.""** Applies to all single-pressure plants using all levels of N2O abatement Robert Lanza
measures… these abatement measures include all levels of abatement..."
The application of single EF to all levels of abatement for single pressure
plants (whether low, medium, or high pressure) suggests that theeffectiveness achieved by each level of abatement is the same for all typesof single pressure plants and for all types of abatement. Similarly for dualpressure plants, the EFs are the same regardless of the level of abatement
technology applied. The rationale for this assumption should be explicitly
addressed in the footnote and/or text of this section.

Accepted

Equipment Leaks: This is unnecessarily over-complicated. The extent ofArchie McCulloch
this leakage is alreadfy included in process efficiencies if Tier 2
methodology is followed. Consequently, as a minimum, the good practice
should be to assess the extent of these emissions to establish whether or notthey are significant. The methodology should then be appropriate withappropriate default factors. Currently the methodology is opaque, relies
heavily on work by USEPA that is over 20 years old and many of theimportant parameters are missing. So much space in the Guidelines for sucha relatively unimportant loss process gives a false emphasis.

Authors notes
Through the IPCC report preparation process for the IPPU Volumerefinement, the Lead Authors, Co-ordinating Lead Authors and Review
Editors have together sought to ensure that the guidelines are sufficiently
detailed, clear and consistent, to provide a range of methods for countries toapply. We acknowledge that some IPPU source methodologies are more
complex than others, reflecting the range of parameters that are necessary as
inputs to generate emission estimates. We consider the output in the Final
Drafts to be proportionate and consistent across the IPPU Volume, reflecting
current scientific knowledge for each source category, and considering therange of methods required to enable reporting where resources for national
inventory compilation may be more limited.

Noted

The number of acid nitric plants in the world is reduced and there is no avariety of both process technologies combined with the different levels ofabatement (secondary catalyst is the most common abatement type). The
implied emissions factors in most of the countries show similar values
independently of the single pressure technology and the level of abatement.
In addition, a breakdown of EFs by level of abatement would correspond toa level of detail of a tier 3. From the measurements done to Joint
Implementation and Clean Development Mechanism projects (monitoring
reports are available on the registers of UNFCCC website), it appears that
there are no big differences among low, medium and high single pressure
plants final emission factor when using different abatement technologies(although the most common one is secondary catalyst). On the contrary, it
appears to be that these final emission factors are more dependent on the ageof the technologies (at least they are very high in developing countries). The
EF proposed is very conservative as this is the approach followed by the
IPCC Guidelines in all categories for tiers 1 and 2. For the dual pressuretechnology only the difference in the EF resulting from measurements inboth dual L/M and dual M/H was taken into account (1 kg N2O per tonne
HNO3) and applied to the conservative factor of 2.5. The implied emissions
factors from the Annex I inventory submissions confirmed the order ofmagnitude of the EFs proposed.

Rejected

A discussion of equipment leaks is an important addition to the methodology
as these emissions can be a significant component of overall production andtransformation process emissions, and the degree of emphasis in section
3.10 is appropriate. In general, where data are available, the emissions fromequipment leaks do vary from facility to facility. The equipment leakemissions on average are 25 to 40 percent of the total production process
emissions (median values vary from 10 to 40 percent over time). We also
note that as facilities begin to improve control of process vents and process
vent emissions decrease, the relative percentage of equipment leaks has
increased over time.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

368 (c'd)Authors notes
We agreed with the commenter that equipment leak emissions are inherently
included in the calculation under Tier 2. We also agreed that the leakdetermination framework is dated, however, there is no reason to believethat the framework is not correct. For example, the general approach forestimating equipment leak emissions based on the Correlation Approach or
the Unit-specific Correlation Approach continue to be an appropriate
approach. Moreover, there is no reason to believe that the leaking offluorochemical gases through chemical manufacturing piping, valves,
flanges, and seals would be significantly different than the leaking of more
traditional organic chemicals for which the equipment leak protocol wasderived. We note that under a Tier 3 methodology, measurement or process
knowledge of the actual F GHG component is made or used. With respect tothe commenter suggestion that default factors for equipment leaks should be
used, these would be appropriate for Tier 1, however, for Tier 3 a sitespecific measurement is appropriate, as reflected in use of the Screening
Approach, Correlation Approach, or Unit-Specific Correlation Approach.
Commenters indicated that the methodology is complicated and opaque. We
agreed that the equipment leak methodology may be complicated, especially
if the inventory compiler does not have experience in estimating equipment
leak emissions. The discussion included in the guidance is a streamlined
version of the approaches outlined in the U.S. EPA Equipment Leak
Protocol document, and inventory staff may refer to the Protocol document
for more information (the reference to the original EPA document isincluded in section 3.10).

370

3

3

807

808

Archie McCulloch
The assumption that the USEPA data, for organic compounds in general,can be applied directly to fluorinated chemicals needs to be substantiated insome way.

Accepted

372

3

3

842

847

Parameters need to be subscripted

Archie McCulloch

Accepted

1650

3

3

854

854

"+/-10 percent" here?

Robert Lanza

Rejected

Additional text has been included in the section discussion. We agreed thatthe equipment leak approaches were developed primarily for estimating
volatile organic compound emissions. In addition, we also noted that theequipment used for production of chemicals that emit VOCs and theequipment used for production of fluorochemicals that emit fluorinatedGHGs are similar. The choice of equipment component used is mostly
based on the physical state of the chemical (gas, liquid) and the temperatureand pressure of the process stream. For a given set of physical parameters,
differences in the chemical properties between hydrocarbon andfluorochemicals are not expected to significantly affect the leak rate fromvalves, flanges, seals, etc. In addition, the U.S. EPA Equipment Leak
Protocol document does include some information on speciating emissions,
non-VOCs, and inorganics that may be helpful in developing an appropriate
approach. We do emphasize, however, that the measurement principle forthe monitoring equipment must be capable of detecting fluorinatedcompounds. Fluorinated compounds typically have dramatically different
response factors than hydrocarbons, and in some cases, have little to no
response on analytical equipment commonly used for hydrocarbon leakdetection. Appropriate analytical principles must be used for measurementof fluorochemicals.
The appropriate subscripts have been added to the variable definitions forEquation 3.43B.
We are not clear on what the reviewer referred to on this line of the draft
document, and because there was no clear context for the comment, we were
not able to respond to the comment.

ExpertResponse

374

Comment ID Volume
3

3

Chapter

867

From line To line
868

The regression equation is not mentioned anywhere in the text, either before Archie McCulloch
or after the intercept and slope appear in this equation. At the very least,
this needs a reference.

Accepted withmodification

In the paragraph before Equation 3.43C, the Unit-Specific Correlation
Approach is discussed, including the need for measurements and data
gathering necessary to develop the correlation between the screening value
and the mass emission rate (i.e., the correlation or relationship developed
between the screening value and the mass emission rate is the regression
equation). What the reviewer may be suggesting is that the values of theslope and intercept should be provided somewhere in the guidelines. The
values of the slope and intercept should be evaluated at the facility, process,unit, etc. and are not provided in the guidelines. To help clarify that the
regression equation is the correlation, the term "regression equation" hasbeen added to the discussion. We also included an additional note for eachdefinition of the regression variables, i.e., for the intercept (B0) and slope(B1), to link them back to the measurements, data gathering, and correlation.

376

3

3

867

869

Parameters need to be subscripted

Archie McCulloch

Accepted

The appropriate subscripts have been added to the variable definitions forEquation 3.43C.

382

3

3

871

Presumably the Beta parameters are from the unspecified regression
equation.

Archie McCulloch

Accepted withmodification

In the paragraph before Equation 3.43C, the Unit-Specific Correlation
Approach is discussed, including the need for measurements and data
gathering necessary to develop the correlation between the screening value
and the mass emission rate (i.e., the correlation or relationship developed
between the screening value and the mass emission rate is the regression
equation). What the reviewer may be suggesting is that the values of theslope and intercept should be provided somewhere in the guidelines. The
values of the slope and intercept should be evaluated at the facility, process,unit, etc. and are not provided in the guidelines. To help clarify that the
regression equation is the correlation, the term "regression equation" hasbeen added to the discussion. We also included an additional note for eachdefinition of the regression variables, i.e., for the intercept (B0) and slope(B1), to link them back to the measurements, data gathering, and correlation.

2752

3

3

917

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Accepted

918

Comment

Authors notes

We agreed with the commenter and have added the appropriate citation
format.

Comment ID Volume378

3

Chapter
3

From line To line
939

940

Comment
It cannot possibly be "good practice to assume that the mass emitted
consists of the fluorinated GHGs listed in Table 3.28b in the proportions
provided". The substances that escape from equipment are process (andproduct) specific. Application of the Guidelines as written would suggest
emissions of NF3 or PFC-14 from a plant producing HFC-134a, which is
nonsense.

ExpertArchie McCulloch

Response
Noted

Authors notes
We anticipated that use of the default emission factor in Table 3.28A alongwith use of the default representative composition in Table 3.28B in essence
provides a fluorinated GHG default emission factor. For example, thedefault EF value of 0.04 kg fluorinated GHG emissions/kg fluorochemical
produced times the production value in kg fluorochemical produced times
0.12 perfluorocyclobutane would provide a de facto default emission factorof 0.0048 kg perfluorocyclobutane/kg fluorochemical produced.
We anticipated that the default representative composition provided in Table
3.28B would be used when the compiler does not have understanding of thefluorinated GHG emitted from fluorochemical production in the country,
region, or facility. We fully agreed with the commenter that the fluorinated
GHG emitted from equipment is specific to the process and product. We
would not want to suggest that a fluorinated GHG be reported as emitted in
the inventory when it is known not to be. We agreed that when theemissions are well understood or even when partially understood, thisknowledge should be used to determine the specific fluorinated GHG toinclude in the inventory. In instances where it is known based on process
knowledge that a particular fluorinated GHG would not be emitted, it would
be inappropriate to include that GHG in the emissions estimate, as would
leaving off a fluorinated GHG that was known to be emitted. We anticipatedthat the compiler would use the best information available.

378 (c'd)

2914

3

3

954

954

Lack comma in bibliographic citation

Poot-Delgado Carlos Antonio Accepted

When the default emission factor is used to determine if the source is a key
category, the inventory compiler would need to apply a GWP to the mt
emissions. In this instance, an alternative to using an assumed chemicalcomposition, as would be done with Table 3.28B, is to provide arepresentative default GWP. This would need to be determined based on
industry, facility, and process knowledge about the country-specificemission profiles.
We agree with the commenter and have added the appropriate citation
format (added comma after O’Connell).

Comment ID Volume
380

3

Chapter
3

From line To line
966

967

Comment"When less is known about the plant and processes, it is good practice to
use the default emission factor in Table 3.28a." is only acceptable if theuncertainty in the default factor is reduced. Currently the range is from0.001 to 0.2. Furthermore, the description of the method to calculate thisshows that it is the factor for TOTAL emissions from the chemical plant,
the risk of double counting should be recognised in the text.

ExpertResponse

Archie McCulloch

Accepted withmodification

Authors notes
Use of the default emission factor provided in Table 3.28A for "all otherfluorochemicals" is for a Tier 1 emission estimate. As the commenter
noted, the emissions from multiple emission sources such as process vents,
equipment leaks, and container venting are included in the default emission
factor. When using the Tier 1 default emission factor, an inventory compiler
will be able to include the emissions from each of these emission sources
and would not need to estimate these using another approach. It is not
anticipated that another approach would be necessary for estimating theemissions for these sources and therefore doublecounting of emissions isunlikely. If additional information is available on the production processes
and container venting, then perhaps another tier to estimate emissions would
be appropriate.
The Tier 1 methodology encompasses a default emission factor (for all otherfluorochemicals) that was developed for production and transformation
processes of different types, products, and facilities, and therefore tends tohave a higher uncertainty. While the uncertainty for applying the default
emission factor to a single facility is high, use of the factor in the inventory
across multiple facilities gives a lower level of uncertainty, as discussed in
the section. We would like to note that the 2006 Guidelines does not present
the uncertainty for the previous default emission factor (0.005), and there is
no way of knowing whether the uncertainty for that value is any better orworse than the new refined default emission factor presented for the 2019
Refinements Guidelines. With respect to the reviewer's concern regarding
double counting emissions, we added a note to the discussion that when the
Tier 1 calculation is conducted, the default emission factor is multiplied by
the total mass of fluorinated chemical produced. It is not anticipated that
there would be any double counting in this instance.

7468

3

3

1060

1736

7474

3

3

1063

1064

3988
2916

3
3

3
3

1072
1075

1075

Some statements are reiterated several times enlarging the chapter 3.11 and Jens Reichel
makes it difficult to extract new information. E.g. the statement to ensurethat no gaps and double counting occur or that it is good practice toestimate emissions from hydrogen production by using the methodologicalguidance in Vol. 3 IPPU if hydrogen is produced as an intermediate productin industries (refineries, ammonia, methanol). I propose to concentrate thisstatements at one place and to highlight it.
This phrase defines the general scope of the new section 3.11 but table 3.29 Jens Reichel(lines 1156 - 1157) also defines exclusions from that. I propose toconcentrate a clear scope with all exceptions at the beginning of that
section.
Replace "does" with "do"Andrea Tilche
Verify bibliographic citation format
Poot-Delgado Carlos Antonio

Rejected

Essentially all the text is needed, as the text will be used as a methodreference, and not be read as a book. Hence, the information is placed
together with the details so that it is likely to be read when it is needed. One
sentence in the introduction to section 3.11.2.1 has been removed as a
response to the comment.

Rejected

The next paragraph (lines 1065 - 1069) defines the exceptions. This isconsidered sufficient for an introduction.

2918

3

3

1084

1084

Verify bibliographic citation format

3506

3

3

1090

1092

In earlier guidelines there have not been mentioned that emissions from
Pia-Kristiina Forsell
biological feedstocks in IPPU sector have to be reported in memo item.
This need to report use of biomass as feedstocks in IPPU sector as a memo
item does not appear to be included in the original draft Table of Contents/Chapter Outline as attached to the Terms of Reference for the 2019
Refinement.

Rejected

3990

3

3

1095

"for example" should be written in full

Andrea Tilche

Accepted

1436

3

3

1107

1107

Edit "… activity data may not be sufficient to enable separate…"

Robert Lanza

Accepted

Accepted
Accepted

The text has been modified.

Poot-Delgado Carlos Antonio Accepted

The text has been modified.
It is within the scope of hydrogen production, which is within the TOC.

Comment ID Volume

Chapter

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Comment

Expert

1438

3

3

1109

1111

1440

3

3

1136

1137

1442

3

3

1139

1139

1444

3

3

1171

1171

7470

3

3

1182

1195

The rules for reporting recovered CO2 as emission of the Hydrogenproduction sector or not should be in alignment with the rules of reporting
recovered CO2 in ammonia production (Vol. 3 chapter 3.2 Box 3.1 on p.
3.14 of the 2006 IPCC guidelines).

Jens Reichel

1446

3

3

1183

1183

Edit "… permanent storage, or may be emitted to the atmosphere."

Robert Lanza

1448

3

3

1187

1188

Edit "… if emissions from the downstream sector are not…"

Robert Lanza

1450

3

3

1190

1190

3992

3

3

1191

Edit "… If the downstream emissions are not reported in the corresponding Robert Lanza
sectors…""emission" should be "emissions"
Andrea Tilche

3994

3

3

1194

1452

3

3

1194

3996

3

3

1205

3504

3

3

1212

1241

1454

3

3

1217

1217

1456

3

3

1229

1458

3

3

2920

3

1460
1462

1195

Text Box 3.16 refers to the circumstances under which emissions from
Robert Lanzahydrogen production would be reported under Refineries or underAmmonia Production; the text in this section should refer to Text Box 3.16
to provide guidance on when emissions from hydrogen production are to bereported under these processes and when emissions from hydrogenproduction are to be reported under Chemical Industry/Hydrogen
Production. Ths is not only a matter of "national circumstances" as isreferred to in Line 1109
Edit "… Hydrogen gas not defined as pure is defined as a "gas mixture" that Robert Lanza
contains compounds other than H2.
Syngas and other gas mixtures may be produced by other means besides
Robert Lanza
partial oxidation (see technologies listed in Table 3-29)"Current sector" refers to the Hydrogen Production part of this chapter?
Robert Lanza

Response
Rejected

Authors notes
The reference to Text Box 3.16 is considered clear enough. Moreover, thereference to "national circumstances" is deliberately leaving some space forinterpretation, in order to make the guidance pragmatic for the inventory
compilers.

Accepted
Accepted
Accepted withmodification
Accepted

Accepted withmodification
Accepted

Text is revised into: "...produced by technologies partially oxidising thefeedstock."No, the sector of the main product. Text revised accordingly.
Two changes have been made throughout the chapter: 1) The requirement todocument the subsequent emissions in other sectors and/or the permanentstorage to be allowed to subtract the recovered CO2 from the hydrogensector is now withdrawn. 2) The text now specifies that the emissions shouldbe allocated to the downstream manufacturing sector.
Revised according to the idea in the review comment, but more elaborated toincrease clearity.

Accepted
Accepted

Some words are missing in the sentence. I do not understand "emission the Andrea Tilche
Hydrogen"

Accepted

Edit "… permanent storage should be transparently described and must be Robert Lanza
documented in accordance with IPCC Guidelines." According to IPCC
Guidelines permanent storage of CO2 is to be documented in order to becredited with reducing CO2 emissions from CO2-emitting processes. If thepermanent storage is not adequately documented, no subtraction of CO2
emissions from the process should occur.
"for example" should be written in full
Andrea Tilche

Accepted"emissions in the Hydrogen"Accepted

Pia-Kristiina Forsell
Box 3.18, if there is still no evidence that CH4 and N2O emissions will
occur from hydrogen production this box (or information) is better to put inan appendix.
For process combustion sources referred to here, why would N2O emission Robert Lanza
factors and CH4 emission factors for combustion sources in the Energy
Chapter not be applicable here? It is understandable that activity data andemission factors for fugitive emissions of CH4 from these processes may bedifficult to obtain, but it should be feasible to characterize the process
combustion sources.

Rejected1229"… maximum of 2% is reported…" Ths refers to 2 percent of the feedstock? Robert Lanza
Or 2 percent of the product? Or 2 percent of some other metric?

Accepted

1233

1233

3

1245

1246

Edit "… used as a fuel in the production process, in which case CO2
emissions are produced."
Lack comma in bibliographic citation

3

3

1259

1259

Edit "…itself and also in combustion…"

Robert Lanza

Accepted

3

3

1260

1260

Edit "… efforts are being made…"

Robert Lanza

Accepted

Rejected

Robert Lanza

Accepted withmodification
Poot-Delgado Carlos Antonio Accepted

The box is describing an exclusion due to negligible amounts and scarcescientific basis, while the scope of the appendix is suggestions for further
methodological development.
It is in line with the other chemical industry sectors not to include emissionsof CH4 and N2O from combustion of fuel derived from the feedstock.

The percentage refers to the produced gas. The text has been revised
accordingly.
Revised according to the idea in the review comment, but more elaborated toincrease clearity.
The text has been modified.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

3998

3

3

1262

"for example" should be written in full

Andrea Tilche

Accepted

1464

3

3

1264

1265

"… and partial oxidation technologies (Table 3.29)…" Partial oxidation
technologies are not referred to in Table 3.29. Suggest that this be
explained in the text
Edit "…(except for a small residue…)

Robert Lanza

Accepted

1466

3

3

1266

1266

Robert Lanza

Accepted

1468

3

3

1270

1270

Text here should explain that syngas processes are not covered in thissection, and explain why they aren't covered.
"e.g. sold" - not clear

Robert Lanza

Accepted

Explanation is given in the end of the paragraph.

4000

3

3

1272

Andrea Tilche

Accepted

Revised into "(e.g. sold for use in a downstream sector)"

1470

3

3

1283

1283

2922

3

3

1290

1291

Edit "… the CO2 emissions should be…"

Robert Lanza

Accepted

The text of the flow diagram is not distinguishedPoot-Delgado Carlos Antonio Accepted

1472

3

3

1296

1296

The text (note) here should explain how emissions from combustion of gas Robert Lanza
to produce steam should be reported.

Rejected

1474

3

3

1316

1316

Robert Lanza

Accepted

2924

3

3

1319

1319

Edit "… the ratio of consumed feedstock carbon atoms to produced CO2
molecules is 1:1."
Verify bibliographic citation format

Poot-Delgado Carlos Antonio Accepted

The text has been modified.

1476

3

3

1327

1327

Robert Lanza

3

3

1336

1336

Robert Lanza

Accepted withmodification
Accepted

Text is revised in accordance with comment id 1468, but is not moved as it
belongs under the sub-title "Partial oxidation technologies"1478

See comment under Line 1270; this explanation should be moved forwardin the text
Edit "… the feedstock may be natural gas…"

1480

3

3

1339

1449

Robert Lanza

Accepted

2926

3

3

1340

1340

Edit "… Surplus hydrogen might be separated from the syngas andpurified…"
check chemical formula

Poot-Delgado Carlos Antonio Rejected

CO is correct.

1482

3

3

1340

1340

Edit"… ratio in the syngas for downstream use."

Robert Lanza

2928

3

3

1345

1346

Verify bibliographic citation format of source

Revised according to the idea in the review comment, but more elaborated toincrease clearity.
The text has been modified.

1484

3

3

1351

1352

Edit "… splitting, do not emit direct GHG emissions but do have emissions Robert Lanza
arising…"

Accepted withmodification

1486

3

3

1359

1359

Accepted

1488

3

3

1366

1366

Edit "…Methane and CO2 being produced are parts of the fermentation gas Robert Lanza
product…"
Edit "… or hydrogen production capacity…"
Robert Lanza

Accepted

1490

3

3

1371

1371

Robert Lanza

Accepted"...either" is replaced with "...one".

1492

3

3

1371

1371

Robert Lanza

Accepted

Generic guidance has been provided. The paragraph has been moved to theend of the introduction to Ch. 3.11.2.1.

4002

3

3

1378

Andrea Tilche

Accepted

1494

3

3

1385

1386

"Recovered CO2 from the process is typically..." The methodology should Robert Lanza
account for the possibilty that CO2 produced by the H2 production process
could be vented directly to the atmosphere and not be stored or used in adownstream process.

Rejected

1496

3

3

1386

1386

Edit " … permament storage."

Robert Lanza

Accepted

1498

3

3

1426

1426

Edit "… in Ch. 1. vol. 1…"

Robert Lanza

Accepted

Robert Lanza

This reference is circular; "either of the methodolgical approaches" would
be two approaches, the parentheses (ammonia, methanol, and hydrogen)refer to three approaches;
Suggest including text describing how the ammonia and methanol
methodologies are to be used in this case.
There is a typo "insofar" - it seems.

Accepted withmodification
Poot-Delgado Carlos Antonio Accepted

1500

3

3

1426

1426

"Guidelines(5)" -- footnote 5 does not appear on this page.

1502

3

3

1457

1457

"CO2 recovered" The methodology should account for the possibilty that
Robert Lanza
CO2 produced by the H2 production process could be vented directly to theatmosphere and not be stored or used in a downstream process.

Reference to Table 3.29 is removed.

Figure updated in a clearer version.
Figures 3.18 and 3.19 are for showing the most common methods for
producing hydrogen gas, not for showing how to report the emissions. This
guidance is given elsewhere in Ch. 3.11.

Changed into "...splitting, are without GHG emissions in the hydrogenproduction process." This aviods using the term "direct emissions", which
may be confusing. Emissions arising from producing the electricity,
production equipment, etc. is not part of the hydrogen sector. This is in linewith the overall principles in the GL and should not need mentioning.

This guidance is about recovery. If the CO2 is vented directly to the air, it is
not recovered.

Noted

After revising other parts of the text, it now does.

Rejected

If the CO2 is vented directly to the air, it is not recovered.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

1504

3

3

1463

1463

"whether internal or external energy sources are used…" Suggest adding
Robert Lanza
text here explaining how GHG emissions from internal energy sources andexternal energy sources are to be reported.

RejectedBox 3.16, which is referrenced in the end of the paragraph, is explaining
this.

7472

3

3

1480

1484

It is possible that inventory compiler gets information about the producedhydrogen amount in m3 instead of tonnes. Than a uniform conversion
factor from m3 to tonnes should be used that is also published in the
updated IPCC guidelines.

Jens Reichel

Rejected

Hydrogen production in tonnes gives the absolute amounts. Volume to massconversion should follw national standards. This is in line with general GL
principles. One sentence added to the text to clarify this.

1506

3

3

1493

1493

"CO2 recovered" The methodology should account for the possibilty that
Robert Lanza
CO2 produced by the H2 production process could be vented directly to theatmosphere and not be stored or used in a downstream process.

Rejected

If the CO2 is vented directly to the air, it is not recovered.

7478

3

3

1508

1508

The possibility to use a Tier 2 method if plant specific factors are notavailable does it include also the ecxeption of the Tier 2 method in line
1472 to use the Tier 1 method?

Jens Reichel

NotedLine 1472 revised: "...are not available and hydrogen production is not a key
category". Now the exception in line 1514 is in line with the general GL
methodology, and any further explanation is considered not necessary.

2930

3

3

1567

1568

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Accepted

1508

3

3

1567

1568

Noted

The ratio of biomass/non-biomass is not specified for the carbon content
factor in the reference material (Wallman et al., 1998).

1510

3

3

1592

1595

"Mixed waste gasification" is there a ratio of biogenic / non-biogenic waste Robert Lanza
content being assumed here for this EF? If so the EF table should include afootnote noting that the the waste is assumed to contain x percent biogenic
material and y percent nonpbiogenic material.
This text should be moved forward into the introduction to the hydrogen
Robert Lanza
production section.

RejectedBox 3.16 on double counting says the same thing, just with another wording.
The box is referenced in the introduction. This is considered sufficient.

1512

3

3

1593

1593

Edit "… if the fuel is derived from the feedstock…"

Robert Lanza

Accepted

1514

3

3

1621

1622

Edit "… if the fuel is derived from the feedstock…"

Robert Lanza

Accepted

4004

3

3

1674

"for example" should be written in full

Andrea Tilche

Accepted

4006

3

3

1676

"for example" should be written in full

Andrea Tilche

Accepted

1516

3

3

1682

1685

If the permanent storage of CO2 is not properly documented the amount of Robert Lanza
CO2 assumed to be recovered and stored (and subtracted) should be zerofor the purposes of inventory calculations, and there would be no reason to
include a non-zero factor in the uncertainty analysis in this case. Only CO2
storage that is properly documented should be credited as a subtraction at
any point in the inventory process, including in the uncertainty analysis. If
the permanence of the CO2 storage is not properly documented there
should be no uncertainty whatsoever in the assumption that the subtractionis zero in this case. Suggest deleting the 20 percent assumption here.

Noted

1518

3

3

1687

1687

Edit "… Where the activity data are obtained…"

Robert Lanza

Accepted

1520

3

3

1721

1721

Edit "… specific data are required…"

Robert Lanza

Accepted

7476

3

3

1728

1735

The mentioned requirements for reporting and documentation are very
Jens Reichel
unspecific for traceability or review. Please list some specific requirements
as a common base like it is the case for nitric or adipic acid. Also therequirement to describe where in the inventory other hydrogen production
is reported according to the scope of the section 3.11.

Accepted

1522

3

3

1732

1732

Edit "… process data are considered…"

Accepted

7458

3

3

Robert Lanza

Jens Reichel
regarding storage of mineral oil products used for chemical industry as
feedstock, in Vol 2 Chap.4 is a reference to the IPPU sector but I couldn't
find where to report those emissions (except for ethylene on page 3.74 in2006 GL- unchanged text) - please also provide a typical emission factor for
major feedstocks

Noted

The text has been modified.

The principle for accounting for recovery has been changed, according toreview comment 7470. Hence, the basis for this review comment is nolonger there.

Elaborated text has been provided.

No action can be taken because comment is out of scope of 2019
Refinement. The page 3.74 in 2006 GL is in the sub sector 3.9
Petrochemical and carbon black production (no refinement )Comment ID Volume

Chapter

From line To line

4642

3

3

292

3

4

207

207

1524

3

4

245

245

255

1526

3

4

255

4008

3

4

257

1528

3

4

257

1530

3

4

258

1532

3

4

1534

3

4010

3

1536

Comment

ExpertResponse

Authors notes

The use of flaring in the chemical industry is not described at all. It would Ole-Kenneth Nielsenbe very relevant to describe the types of chemical industry where flaring ismost frequently occurring and provide guidance on how to estimate andwhere to report emissions. Noting that the flaring in the energy sector
currently is for oil and natural gas production/treatment and hence does notnecessarily covers the possible flaring associated with all types of chemicalindustry.

Noted

No action can be taken because comment is out of scope of 2019
Refinement. The flaring in the chemical industry is descibed in the sub
section 3.9 Petrochemical and carbon black production. And noted that themost of CO2 emissions from flaring are deducted in the carbon mass balancebecause the corresponding emissions are estimated with the methodology
described in Chapter 4 Volume 2This line is shaded but there's a stylistic change in subparagraph marks. It Sergii Shmarinwould be better to use the IPCC 2006 version.
Figure 4.1 does not illustrate other carbon-containing materials that may be Robert Lanza
used in iron and steel production including limestone/dolomite, that woul
be included in the mass balance method. Can the figure e edited to add
other inputs to the iron and steelmaking process?

Rejected

The shading is meaning that the parts were not revised.

Rejected

The limestone and dolomite consumption for iron and steel production CO2emissions have to be accounted in Lime production category. This is why
the Figure 4.1. will not be changed in this 2019 Refinement.

Edit "but not GHG emissions"

Robert Lanza

Accepted

GHGs →The verb "occur" should replace "occuring" - it seems.

Andrea Tilche

Accepted

occuring → occure

258

Edit "where GHG emissions occur. The term coking..."Robert Lanza

Accepted

258

Edit "a thermal distillation process"Robert Lanza

259

260

4

261

261

Edit "volatile matter from the coking coal, in the form of gases or liquids, to Robert Lanza
produce coke. Related to the treatment…
Edit "including coal tar and light oil"
Robert Lanza

Accepted

4

268

There is a typo "under in"

Andrea Tilche

Accepted

3

4

271

271

Edit "Fugitive emissions consist of"Robert Lanza

comprise → consist

1538

3

4

278

278

Flaring may occur for other reasons besides emergencies and consumer
maintenance.

Robert Lanza

Accepted withmodification
Accepted

2356

3

4

297

Ingrid Mawdsley

Accepted withmodification

CO gas is leaked to some extent from the process, so human has detector incase of approaching body of facilities/BF etc. but amount of emissions arelimitted.

1540

3

4

298

Robert Lanza

Accepted withmodification

The COG vented to the atmosphere occurs in very seldom situations. Beingso, the LA´s concluded that the GHG emissions associated to this are
negligeble. This was addressed in the FD text.

294

3

4

303

Sergii Shmarin

Accepted

The phrase has been deleted.

1542

3

4

308

Table 4.1 It is stated that the European EF includes CO as it eventually oxidises toCO2. This could be interpreted as being inconsistent with how emissions
are reported, since CO is reported separately as indirect greenhouse gas
emissions.
298
Flaring may occur for other reasons besides emergencies and consumer
maintenance; also there may be circumstances in which COG is vented tothe atmosphere without being flared; suggest editing Table 4.1a to accountfor the possibility of venting of uncombusted COG and nonemergency/maintenance flaring of COG.
304
Sentence "If the category is key, it is good practice to estimate emissions
using a Tier 2 or Tier 3 approach." seems to be excess because it justduplicates the general principles described in Volume 1.
308
Edit "data are available"

4012

3

4

315

1544

3

4

321

4014

3

4

324

296

3

4

327

4016

3

4

329

298

3

4

329

330

There is no any comment or limitation for Tier 3a. For example, if we
Sergii Shmarin
have/use installation-specific Carbon content in coke and other parameters
are country-specific, which method is used?

1546

3

4

330

330

Under Tier 1b table cell Edit "...described in the Energy volume should be
conducted, as this would be a double counting."

327

Noted
Accepted
like→including

The text was changed to "among other reasons" in line 278 and Table 4.1A
(line 298).

Robert Lanza

Noted

Andrea Tilche

Noted

Edit "For Tier 1 this assumption is the..."Robert Lanza

Noted

Replace "an" with "a"Andrea Tilche

Noted"...measurement data is…". Please, change "is" to "are".

Sergii Shmarin

Noted

Table 4.1B - row two fifth column the verb "occurred" is not correct

Andrea Tilche

Accepted withmodification
Rejected

The text has been changed in FD from occurred → conducted

Accepted withmodification

The text has been changed in FD from occurred → conducted

There shoud be a comma - it seems.
321

GHG emissions

Robert Lanza

This explanation has been done in decision tree Figure 4.6.

Comment ID Volume

Chapter

From line To line

1548

3

4

330

330

1550

3

4

331

332

300

3

4

331

8550

3

4

331

4018

3

4

338

1552

3

4

338

1554

3

4

339

302

3

4

2478

3

1556

Comment

ExpertResponse

Authors notes

Is ISO 14404 being used as the QA Standard for the entire iron and steel
and metallurgical coke section? If so the section would merit from
including a brief description of the provisons of the ISO 14404 QA
requirements.
Edit "Tier 1 and Tier 3 methodologies to estimate CH4 emissions areprovided for emissions from quenching toweres and stacks. The Tier 1amethod uses default emission factors. The Tier 3 method uses
measurements."

Robert Lanza

Accepted withmodification

The line would be modified without refering to QA standard of ISO 14404.

Robert Lanza

Accepted

Redraft in line 484

332

It's strange that there are tiers 1 and 3 for CH4 but tier 2 is not presented.
Probably, tier 2 could be approach based on county specific data on CH4emissions per unit.

Sergii Shmarin

Accepted

Tier 2 por CH4 in IPPU I&S has been included334

The methodology to estimate CH4 fugitive emissions in Section 4.3.3
Takuji Terakawa
Chapter 4 Volume 2 does not include a tier 2 method, but the decision treeof this section includes a description of the tier 2 method. The description
should be consistent with Volume 2.
Remove "for" after apply
Andrea Tilche

Accepted

Tier 2 por CH4 in IPPU I&S has been included

338

Edit "the amount of coke produced (tonnes) in the country…"

Robert Lanza

Noted

339

"the following equation is used" --- The Equation 4.1 text box actuallycontains two equations (one for CO2 and one for CH4) that should be
separated.

Robert Lanza

Accepted

The equations from CH4 and CO2 will be separated in FD.

340

343

Accepted

The FD text will reflect the changes proposed.

4

340

343

Accepted

3

4

352

352

Equation 4.1. Let me propose you to change the abreviation "CO" because it Sergii Shmarin
looks a little bit confused like CO is Carbon monoxide". One more thing.
Indices 2 and 4 for CO2 and CH4 have the same size as for the capitalletters (C, H, O).
Mingshan Su
It is better to describe the two equations in 2 separate paragraphs. For
example Equation 4.1(a) and Equation 4.1(b).
Suggest establishing a convention to use the terms "coking coal" rather than Robert Lanza"metallurgical coal" or vice versa, throughout the document

The equations were separated in FD, however the equation 4.1 is for CO2
and the equation 4.1a is for CH4.
Coking coal is commonly used. Metallurgical coal was changed to it in FD
text.

2486

3

4

362

362

metallurgical coal should be coking coal

Mingshan Su

Accepted

1558

3

4

362

363

Accepted

1560

3

4

363

363

Suggest establishing a convention to use the terms "coking coal" rather than Robert Lanza"metallurgical coal" or vice versa, throughout the document
Edit "tonnes C / tonne coke"
Robert Lanza

Noted

Accepted

Accepted

Coking coal is commonly used. Metallurgical coal was changed to it in FD
text.
Coking coal is commonly used. Metallurgical coal was changed to it in FD
text.
FD text changed according comment made

2660

3

4

363

363

“tonnes C / tonnes coal”should be ”tonnes C / tonnes coke”.

Xiangzheng Deng

Accepted

FD text changed according comment made

2488

3

4

363

363

tonnes C / tonnes coal should be tonnes C / tonnes coke

Mingshan Su

Accepted

FD text changed according comment made

1562

3

4

366

366

Edit ..."appropriate where national…"

Robert Lanza

Accepted

FD text changed according comment made

304

3

4

367

367

I propose to change the word "are" in "national statistics...are available" to Sergii Shmarin"...is available".

Rejected

Statistics are plural, therefore "are" is correct, not "is"

1564

3

4

368

369

Edit "The following equation is used with a country-specific carbon
content." [tabme 4.3 does not contain country-specific carbon contents;
table 4.3 contains material-specific carbon contents/

Robert Lanza

Accepted withmodification

FD text changed according comment made

308

3

4

370

384

3

4

373

383

Accepted withmodification
Acceptedx means general expression for materials, a brief explanation has been added

306

1566

3

4

377

377

There is no such a parameter as Cx (or index x) in the equation 4.2 but at Sergii Shmarin
the bottom of the narrative they are presented. Please, fix it and unify.
The units have been changed from tonnes to kg without necessary reasons Sergii Shmarincompared with IPCC 2006. It can lead to potential mistakes in compilers'
activity and complicate the filling of CRF-reporter.
Suggest establishing a convention to use the terms "coking coal" rather than Robert Lanza"metallurgical coal" or vice versa, throughout the document

Accepted

Coking coal is commonly used. Metallurgical coal was changed to it in FD
text.

1568

3

4

382

382

Accepted

Examples added

The section would benefit from identfying examples of "b" byproducts
including coal tar, light oil, etc."

Robert Lanza

FD text changed according comment made

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

1570

3

4

382

383

Edit "and either transferred off site to other facilities or flared (kg)"Robert Lanza

Accepted

1572

3

4

386

386

Edit "are estimated as fugitive emisisons using the methodology…

Robert Lanza

Accepted

310

3

4

392

392

Accepted

1574

3

4

394

397

The word "installation" is used in the Table 4.1b but later instead of it the Sergii Shmarin
word "plant". Probably, it would be better to unify it.
Edit so that there are three bullet points, not two" 1) For CO2, monitoring of Robert Lanza
direct sources; 2) for CH4, monitoring of direct sources; and 3) For CO2,
carbon mass balance approach…"

1576

3

4

398

398

Edit "all direct individual sources"

Robert Lanza

Accepted

4020

3

4

399

Put "for" after word "account"

Andrea Tilche

Noted

1578

3

4

401

402

Line 330 refers to QA practices included in ISO 14404; Is ISO 14404 being Robert Lanza
used as the standard for QA, or recommendations in Volume 1, Chapter 6,
or both? The section would benefit from a summary of the relevant
requriements of ISO 14404 if the standard is being applied to this section.

312

3

4

407

407

Symbol "2" in "...CO2 emissions" is written as a big symbol.

Sergii Shmarin

Noted

1580

3

4

407

408

Is there a similar flowchart for CH4 emissions?

Robert Lanza

Accepted

1582

3

4

407

408

Edit "country-specific carbon contents available?"

Robert Lanza

Noted

314

3

4

407

408

There is a number of mistakes presented in the different blocks of the figure Sergii Shmarin
4.6. Some of them are: too many symbols ")" or not enough "("; no gaps
between the words; change "are" to "is" or "content" to "contents" etc.

4022

3

4

410

1584

3

4

410

412

316

3

4

410

412

4024

3

4

411

Edit to add Figure numbers to the Figure titles in the text: "Figure 4.7:
Robert Lanza
Decision Tree for Estimation of CO2 Emissions…" "Figure 4.8: Decision
Tree for Estimatiing CH4 emissions…"
Could you please unify the category/activity title: "Iron & Steel Production" Sergii Shmarinor "Iron and Steel Production"
Replace "&" with "and"Andrea Tilche

1586

3

4

413

415

Why is only uncertainty for sinter production noted here? Are pellet
production and DRI production equally relevant to the same relianc oassumptions?

Robert Lanza

318

3

4

418

418

Symbol "2" in "...CO2 emissions" is written as a big symbol.

Sergii Shmarin

320

3

4

420

421

Noted

322

3

4

423

423

There're points (".") in the end of the figure blocks. But for the new schemes Sergii Shmarin
this symbol is not presented. Please, unify.
Symbol "4" in "…CH4 emissions" is written as a big symbol.
Sergii Shmarin

1588

3

4

436

436

Edit "production in blast furnaces that is not…"

Accepted with modification

1590

3

4

438

438

1592

3

4

441

441

324

3

4

446

464

Edit "take into account emissions from both iron production and steel
Robert Lanza
production."
Edit "separately estimate the emissions from national sinter production and Robert Lanza
national pellet production using Equations 4.7 and 4.8.
Symbol "2" in "...CO2 emissions" is written as a big symbol.
Sergii Shmarin

1594

3

4

477

477

Edit "…is appropriate where the inventory complier has access tonational…"

Robert Lanza

Accepted

7552

3

4

484

484

Coralie Jeannot

7554

3

4

512

512

Add the same sentence as for the Tier 1 method: “Total emissions are thesum of Equations 4.9, 4.10 and 4.11.”
To avoid confusion with the blast furnace for the iron production, replace“blast furnace” by “ignition furnace” in the sentence: “COG: quantity ofcoke oven gas consumed in ignition furnace in sinter production (…)”

Accepted withmodification
Accepted withmodification

Put "this" instead of this "these" and replace "outline" with "outlines"

Andrea Tilche

Robert Lanza

Coralie Jeannot

The text revieved to esure the consistency

Accepted

Accepted withmodification

The line 330 would be modified without referring to QA standards of ISO
14404.

The decision tree for CH4 would be provided similar to CO2.

Accepted

Noted
Accepted

Noted
Accepted
Accepted

The uncertainty for pellet production and DRI production is equally relevantto the same for sinterAccepted

Accepted
Accepted
Accepted
Accepted

The FD text was changed to: Total emissions are the sum of Equations 4.9,
4.10 and 4.11. for those processes that occur in the country.
FD text was changed to: quantity of coke oven gas consumed in ignition
furnace for sinter production.

Comment ID Volume

Chapter

From line To line

Comment

Expert

4

516

518

These other materials are not shown in Figure 4.1, suggest that they be
included in the Figure.

2480

3

4

524

528

Since electricity generation is a typical energy sector activity the "emissions Mingshan Sufrom the combustion of blast furnace gas, coke oven gas and converter gas"
"to produce electricity in an internal power plant to cover the internal
needs" is better to be reported under Energy Sector.

Rejected

2350

3

4

529

531

The paragraph can be interpreted as all emissions from combustion of fuels Ingrid Mawdsley
are to be reported in IPPU. However, fuels (e.g. part of the natural gas) may
also be used solely for energy purposes. This is the case in Sweden.

Accepted withmodification

FD text changed accordingly to comemnt and a note added in order to clarify
that NG has a double role in this type of DRI technology (heat and reducing
agent).

1598

3

4

544

544

Edit "defailt carbon contents from Table 4.3"

Robert Lanza

Accepted

FD text changed accordingly to comment

1600

3

4

545

545

Edit "production is a key category."

Robert Lanza

Accepted

FD text changed accordingly to comment

2352

3

4

565

569

It would be helpful to inventory compilers if it was also mentioned whether Ingrid Mawdsley
CH4 emissions from pellets production specifically are relevant or not.

Accepted withmodification

There is a paragraph "the possible existance of relevant emissions whenanthracites is used"

1602

3

4

570

571

Edit: Unclear from this sentence whether the text is indicating tht CH4 and Robert Lanza
N2O emissions are "possibly small" or that N2O emissions (but not CH4
emissions) are "possibly small." Can we be concise and state that the CH4
and N2O emissions are expected to be negligible?

Accepted withmodification

The phrase was deleted as the emissions from flaring will be addressed in a
new item in IPPU at the same time it isconsistent with the fugitive emissions
text from coke production in the Energy chapter.

326

3

4

570

571

Probably, the word "insignificant" is more appropriative than "small".

Accepted withmodification

7556

3

4

572

572

2354

3

4

586

589

Add the sentence: “Total emissions are the sum of Equations 4.12, 4.13 and Coralie Jeannot
4.14.”
Explanation of "DRI" in Equation 4.14 is missing.
Ingrid Mawdsley

Accepted withmodification
Rejected

The phrase was deleted as the emissions from flaring will be addressed in a
new item in IPPU at the same time it isconsistent with the fugitive emissions
text from coke production in the Energy chapter.
FD text was changed to: Total emissions are the sum of Equations 4.12, 4.13
and 4.14. for the processes that occur in the country.
The X from EFX is DRI

1604

3

4

594

595

Edit: "…and provides a discussion of carbon contents to be used…"

Robert Lanza

Noted

1606

3

4

603

603

Edit "…recovery of chemicals, and all byproducts are burned."

Robert Lanza

328

3

4

609

609

Term "organic liquids" seems to be in a contradiction with line 36 of theSergii Shmarin
Glossary because coal tars and light oils are a part of coal/coke massbalance having a fossil fuel nature. From the other hand organic liquids area particular case of organic matter. Otherwise, the Glossary needs
clarification.

Accepted withmodification
Accepted

1608

3

4

610

610

Edit "...one-third of the coke oven gas..."Robert Lanza

Accepted

4026

3

4

612

I do not understand the use of the word "European"

Andrea Tilche

330

3

4

612

I propose to add word "ones" after "…European".

Sergii Shmarin

Accepted withmodification
Accepted withmodification

Sergii Shmarin

Accepted withmodification

Authors notes

3

612

Robert Lanza

Response1596

FD text was change to address comment 1596 and anthracite was defined as
one of the Pma. However figure 4.1 will not be changed as it is out of thescope of 2019 IPCC Refinement.
The Chapter 2 "Stationary combustion" from the Volume 3 explains that thereporting of emissions from gases obtained from processing feedstock andprocess fuels obtained directly from the feedstock follows the principle
stated in Section 1.2 of Volume 3. In summary, if the emissions occur in the
IPPU source category which produced the gases emitted they remain as
industrial processes emissions in that source category. If the gases areexported to another source category in the IPPU sector, or to the energy
sector, then the fugitive, combustion or other emissions associated withthem should be reported in the sector where they occur. Inventory compilers
are reminded to discriminate between emissions from processes where thesame fossil fuel is used both for energy and for feedstock purposes (e.g.
synthesis gas production, carbon black production), and to report theseemissions in the correct sectors. The information for clarification ofemissions to be split between Energy and IPPU is provided in the Box 1.1,
Introduction to the IPPU Chapter.

FD text was changed
FD text was changed accordinly to the comment in IPPU sector.

This word is a part of the name of referenceThis word is a part of the name of referenceComment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

Accepted withmodification
Accepted withmodification

FD text was changed"lowered to 0.30 tCO2/t coke" -- can we include this emission factor in the Robert Lanza"Emission Factor" column as a separate emission factor rather than
incuding the emission factor under the "Source" column? The emission
factor would be easier for readers to find if it was in the "Emission Factor"
column.

Accepted withmodification

The emission factor column includes the mean value. For more detailed
information on the lower EF please look to the source column.

Accepted withmodification

The emission factor column includes the mean value. For more detailed
information on the lower EF please look to the source column.

616"EU Average CO2 Factor…" -- can we include this emission factor in the Robert Lanza"Emission Factor" column as a separate emission factor rather than
incuding the emission factor under the "Source" column? The emission
factor would be easier for readers to find if it was in the "Emission Factor"
column.
Edit "up to 20 years old" and "more than 20 years old"Robert Lanza

FD text was changed

615

616

Edit "…non-recovery byproduct process."

Robert Lanza

4

615

616

Robert Lanza

3

4

615

637

1622

3

4

623

624

Robert Lanza

Accepted withmodification

The emission factor column includes the mean value. For more detailed
information on the lower EF please look to the source column.

1624

3

4

623

624

This table may merit including region-specific emission factors for cokeproduction rather than including only one average emission factor
It would be better to mention References in other way. Now, the table
looks not friendly use. Moreover, phrases are not aligned and there is toomuch empty space left. This table has to be modified…a lot.
This table may merit including a specific emission factor for "carbonatecontaining ores" rather than only a single emision factor if there aresufficent supporting data to establish a range of values (a factor of two isreferred to), rather than including this discussion under the "Sources"
column in the table.
This table may merit including region-specific emission factors for sinterproduction rather than including only one average emission factor

Accepted withmodification
Accepted withmodification
Accepted withmodification
Accepted withmodification

Robert Lanza

Accepted withmodification

The emission factor for sinter production has been added.

7558

3

4

636

636

Accepted withmodification

Table 4.1 has the oldest EF deleted. New references has been found and aAvalue of 1.58 has been now included

1626

3

4

636

637

Coralie Jeannot
Why are there 2 rows for the BOF?
We may assume that the EF of 1.39 (VS the current one in GL 2006: 1.46)
is the new EF proposed for the 2019 Refinement. But, if we do not mistake,the EU ETS benchmark value under the EU ETS phase 3 (2013-2020)
Decision 2011/278/UE, annex I, Table 1, is 1.328 allowances/t (i.e. t
CO2/t) and not 1.39 (in the annex I: row “Hot metal” which includes the
BOF).
Do the two emission factors for BOF in this table represent regional
Robert Lanzadifferences? If so there should be modifying text in the "Steelmaking
method" column indicating how (where) each of these emission factors
should be applied.

Accepted withmodification

Table 4.1 has the oldest EF deleted. New references has been found and aAvalue of 1.58 has been now included

1628

3

4

636

637

Is the "global average" value still needed here? This value dates from the
distribution of iron and steel production techologies that was extant in2004. This is likely obsolete in 2019; suggest deleting this value

Accepted

Global average has been deleted

4640

3

4

655

656

It is not helpful to have a default EF listed as a range of 1-80 g/tonnes as is Ole-Kenneth Nielsen
the case for CH4 from coke production. Without any further guidance, whatis the user supposed to do with this? If no better knowledge is available thegeometric mean could be listed as the default EF and the uncertainty would
then reflect the large range. This has not been corrected between the FOD
and SOD.

Accepted withmodification

The upper value has been considered for Tier1, that is coherent with othernew value reported by Japan.

1630

3

4

655

656

A range of 1-80 is quite large; can this range be qualified in some manner? Robert Lanza

Accepted withmodification

The upper value has been considered for Tier1, that is coherent with othernew value reported by Japan.

1610

3

4

615

616

Edit "factor, not including advanced energy…." under "Source" column."

Robert Lanza

332

3

4

615

616

It's better to unify the number of rounding in, for example, 0,5103 tCO2 / t Sergii Shmarincoke and 0,517 tCO2 / t. Moreover, points (".") should be used instead ofcommas (for all the table).

1612

3

4

615

616

1614

3

4

615

616

1616

3

4

615

1618

3

4

1620

3

334

Sergii Shmarin

Robert Lanza

The Table 4.1 text was incorporated in FD text and the table now presents
only 1 CO2 EF for coke production.

FD text was changed
The emission factor column includes the mean value. For more detailed
information on the lower EF please look to the source column.
FD text was changed

Comment ID Volume

Chapter

From line To line
656

ExpertResponse

Default emission factor for CH4 emissions from coke production; according Pia-Kristiina Forsell
to the source of emission factor, the factor is from a single plant andtherefore could not be used as default.
The "not" should be replaced with "no"Andrea Tilche

Comment

Accepted withmodification

Authors notes

3508

3

4

655

4028

3

4

659

1632

3

4

659

659

Edit "…if there is no information…"

1634

3

4

674

675

Use of default values would be inconsistent with the definition of a Tier 3 Robert Lanza
method, which depends on monitoring data. Suggest modifying or deleting
this discussion that suggests default factors would be used in a Tier 3
methodAccepted withmodification

There are two options for tier 3: (1) using the monitoring data, (2) using
facility specific data for carbon content and input/output data for carbon
mass balance. The text in FD was modified to clarify this situation.

3404

3

4

679

680

Accepted withmodification

The Table 4.3 carbon contents for fuels has been leave as in 2006
Guidelines. For the rest of the process material, has been updated (samevalues than in SOD)

336

3

4

679

680

Tier2 material specific carbon contents are updated but, In energy sector
Eunae Seo
carbon emission factors are not changed, so it need to consider the revision
EF in energy sector for consistency.
Especially emission factors of new guidance for fugitive emissions fromcoke production in energy sector(Volume3, Chapter4, Line 2796~2797) are
different with IPPU sector eventhough emission source is samee.g) Blast Furnace Gas(IPPU) 0.17tC/ton -> 0.243tC/ton(Updated)(Energy) 2.47TJ/Gg * 70.8kg/GJ / 10^3 = 0.17tC/ton(not updated)
Could you please unify abbreviation "KG" and "kg" and rounding level after Sergii Shmarinpoint, for example, three symbols after point. In "The amount of CO2
emissions from charcoal can..." symbol "2" became too big for some reason
despite the fact that this part is shaded.

338

3

4

682

682

Sergii Shmarin

Noted

1636

3

4

717

717

Strange symbols are presented in my monitor between the numbers in
4.2.2.4.
Edit "...sintering, ironmaking, blast furnace steelmaking…"

Robert Lanza

Accepted

340

3

4

729

729

2482

3

4

730

731

Robert Lanza

The word "is" is excess for "...as is shown in Figure 4.8a, according to:" or Sergii Shmarin
the word "it" before "is" would be appropriative.
Combustion of blast furnace gas, coke oven gas and converter gas for
Mingshan Su
sintering is mainly for energy purpose and it is better to be reported in
Energy sector.

Japanese EF literature was also used.

Accepted
Accepted

Accepted

Noted
Rejected

The Chapter 2 "Stationary combustion" from the Volume 3 is providing the
explanation that the reporting of emissions from gases obtained fromprocessing feedstock and process fuels obtained directly from the feedstock
follows the principle stated in Section 1.2 of Volume 3. In summary, if theemissions occur in the IPPU source category which produced the gases
emitted they remain as industrial processes emissions in that source
category. If the gases are exported to another source category in the IPPU
sector, or to the energy sector, then the fugitive, combustion or otheremissions associated with them should be reported in the sector where theyoccur. Inventory compilers are reminded to discriminate between emissions
from processes where the same fossil fuel is used both for energy and forfeedstock purposes (e.g. synthesis gas production, carbon black production),and to report these emissions in the correct sectors. The information forclarification of emissions to be split between Energy and IPPU is provided
in the Box 1.1, Introduction to the IPPU Chapter.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

2484

3

4

735

739

The emissions from the combustion of blast furnace gas, coke oven gas and Mingshan Su
converter gas to produce electricity in an internal power plant should bereported in Energy sector even if the electricity is produced to cover theinternal needs since producing electricity is for energy purpose and it is atypical energy sector activity.

Rejected

The Chapter 2 "Stationary combustion" from the Volume 3 is providing the
explanation that the reporting of emissions from gases obtained fromprocessing feedstock and process fuels obtained directly from the feedstock
follows the principle stated in Section 1.2 of Volume 3. In summary, if theemissions occur in the IPPU source category which produced the gases
emitted they remain as industrial processes emissions in that source
category. If the gases are exported to another source category in the IPPU
sector, or to the energy sector, then the fugitive, combustion or otheremissions associated with them should be reported in the sector where theyoccur. Inventory compilers are reminded to discriminate between emissions
from processes where the same fossil fuel is used both for energy and forfeedstock purposes (e.g. synthesis gas production, carbon black production),and to report these emissions in the correct sectors. The information forclarification of emissions to be split between Energy and IPPU is provided
in the Box 1.1, Introduction to the IPPU Chapter.

7562

3

4

737

743

The split (export (à Energy) VS internal needs (à IPPU)) seems to be very
tricky to do for the operators. But I am waiting for their feedback on thatquestion.

Coralie Jeannot

Noted

The Chapter 2 "Stationary combustion" from the Volume 3 is providing the
explanation that the reporting of emissions from gases obtained fromprocessing feedstock and process fuels obtained directly from the feedstock
follows the principle stated in Section 1.2 of Volume 3. In summary, if theemissions occur in the IPPU source category which produced the gases
emitted they remain as industrial processes emissions in that source
category. If the gases are exported to another source category in the IPPU
sector, or to the energy sector, then the fugitive, combustion or otheremissions associated with them should be reported in the sector where theyoccur. Inventory compilers are reminded to discriminate between emissions
from processes where the same fossil fuel is used both for energy and forfeedstock purposes (e.g. synthesis gas production, carbon black production),and to report these emissions in the correct sectors. The information forclarification of emissions to be split between Energy and IPPU is provided
in the Box 1.1, Introduction to the IPPU Chapter.

342

3

4

747

747

Symbol "2" in "...CO2 emissions" is written as a big symbol.

Sergii Shmarin

Noted

7560

3

4

748

748

In the Figure 4.8a(new):Coralie Jeannot
Change « LDG » into « BOF » in order to be consistent with the overall
document, where LDG is not used.
For the Power Plant box, for 1 and 2: after “Energy”, add: “(electricity
and/or heat production)”.
For the black box on “Heat (hot rolling mills (…)”: delete the brackets andadd “Heat used for rolling mills (…)” to avoid any confusion with the“Energy produced” in the black box “Power Plant” (for which theallocation of the CO2 emissions depends on the use of the energy).

Accepted withmodification

The comment is mostly excepted excluding the changing of the naming from
"LDG" to "BOF". We should also consider the naming BOFg in this casebecause we are dealing with a gas.

Comment ID Volume

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From line To line
749

Comment

ExpertAuthors notes

3

4

748

4030

3

4

754

Remove the word "has" - it seems.

Andrea Tilche

Noted

4032

3

4

776

I do not understand "as in the last one"

Andrea Tilche

Noted

1640

3

4

776

776

Noted

4034

3

4

808

809

The phrase "as in the last one" is unclear; is this phrase referring to the ISO Robert Lanza
14404 standard? Or to the 2019 refinement?
I do not see the figures 4.2-4.5
Andrea Tilche

4036

3

4

813

Remove "d" in the word "used"

Andrea Tilche

Accepted

1642

3

4

813

813

Edit "...a real flux of these gases…"

Robert Lanza

4038

3

4

818

Replace the word "choose" with "choosing"

Andrea Tilche

Accepted withmodification
Accepted

1644

3

4

820

820

Robert Lanza

Accepted

1646

3

4

845

845

Footnote: Suggest defining the term "converted gas" earlier in the section
rather than in a footnote at the end of the section.
"+/-10 percent" here?

Robert Lanza

Noted

1648

3

4

845

845

"+/- 5 percent" here?

Robert Lanza

Noted

344

3

4

850

851

How can be the range of uncertainties the same for tier 1 and tier 2
Sergii Shmarinespecially for simple linear equation? If it is so, there is no sence to apply ahigher level methoodology because it will not make any influence oncommon national one. Of course, it can be a key category, but the common
rules exist to stimulate countries to make their common uncertainty as low
as possible based on priority weak points.

Accepted

The uncertainty for Tier 1 was recalculated.

8862

3

4

864

In Section 4.3 (Ferroalloy production), it is recommended that IPCC
provides methodologies to account for relevant GHG emissions fromproduction of Fe-Vanadium, Fe- Molybdenum and Fe-Titanium alloys.

Mingming Wang

Noted

No action can be taken because comment is out of scope of 2019
Refinement

7864

3

4

867

Section 4.4 Primary Aluminium Production - General information: Many Christine Dubois
countries proposed CO2 reduction for years to come and are placing or had
placed regulations about GHG emissions and requirements (for example
taxes and cap and trade). Year baselines are different and reduction
objectives could be different too. There could free allowance given by
government based on regulated targets. The change proposed could impact
the compliance of those regulations and free allowance. We welcomed the
proposition to develop a consistent time series but the method must be
accurate to avoid any uncertainty increasing.

Noted

1492

The note "natural gas, fuel oil, etc, for combustion to be reported under
Robert Lanza
ENERGY" in Figure 4-8a is inconsistent with the text in Line 786-787 that
reads "…besides blast furnaces, often using natural gas or coal instead ofcoke, and these carbon sources should be accounted for in the same manneras coke becase they are being used for the same purpose." Natural gas,coal, fuel oil, and etc., that are being used in the ironmaking process(whether in a blast furnace or other type of ironmaking process) for thesame purpose as coke (i.e., as a reducing agent) should be reported in thesame manner as the use of coke is reported. See also Figure 4.1 that
illustrates direct coal injection into the blast furnace. Fuel oil, natural gas,coal and etc. that is combusted for the purposes of energy, e.g., to generate
electricity for export, would be reported under Energy, but the Figure 4-8a
footnote as written could mislead the reader as to the distinction between
reporting emissions to Energy and reporting emissions to IPPU. Suggest
editing the footnote for clarification.

Response

1638

Accepted withmodification

Rejected

The note in Figure 4.8a should not be consistent with the text in lines 786787 because of difference between the processes. The lines 786-787 refer tothe direct reduction but not the Figure 4.8a. The Figure 4.1 modified withdeletion of the footnote.

The Figures 4.2 - 4.5 are out of scope of the 2019 Refinement. These Figures
are in the chapter "4.2.1 Introduction" in the text of IPCC 2006 Guidelines.

The explanation for "Converted gas" provided at the beginning of thechapter.

Comment ID Volume

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From line To line

7918

3

4

867

1492

8668

3

4

867

1492

Comment

ExpertGeneral comments: it is important to have the most accurate PFC inventory. Christine Dubois
Including LVAE will be important. But based on the fact
- there is no specified sampling method for LVAE,- that only 40% of the aluminum production is targeted,- that the actual data we have for LVAE varies enormously without
understanding why,- that the uncertainty are high,- there is no information for smelter using overvoltage to backcast their past
result which will be important for GHG cap and trade regulation and- that work is a first step to include LVAE,
would it be possible to add this section as a work in progress or actual
information and integrate a transition phase to eventually add LVAE PFC
emission in the inventory when we will have a sampling method having
LVAE PFC included and have more data to consider in the Tier 2 to reduce
the uncertainty?
General comment to PFC accounting
Henrik Åsheim

Response

Authors notes

Noted

Noted

The guidelines and EFs are a snap shot of current understanding and so will
always have an expiration date - processes/industry is not static . The EFDB
is a useful resource to use to keep EFs as up to date as possible.
The guidelines are not intended to be as prescriptive as to push users tohigher tiers with penalty factors.

7466

3

4

868

870

The intention to use the updated sub-chapter 4.4 in conjunction with the old Jens Reichel
4.4 Chapter 4, Volume 3 of the 2006 IPCC guidelines where relevant
makes it complex to understand the requirements for GHG emission
reporting according to the IPCC guidelines. Please rework the sub-chapter
in that way that the new sub-chapter 4.4 can be used instead of the old one.

Accepted

An explanatory section at the start of updated chapter 4.4. has been provided
summarising with bullet points, the main changes between 2006 IPCC GL'sand 2019 IPCC Refinements. This clarifies that (1) Updates have been madeto PFC emissions accounting from primary aluminium smelting and (2)New guidance has been given to CO2 emissions accounting from alternative
alumina refining processes. However, for CO2 emissions from primaryaluminium smelting, users should instead use the 2006 IPCC GL's (sections
4.4.2.1 and 4.4.2.2).

7494

3

4

868

870

It is specified that the DRAFT 2019 Refinement should be used in
Nadia Morais
conjunction with the 2006 IPCC Guidelines.
In order to avoid confusion in the future use of the final 2019 IPCC, theinchanged portion of 2006 IPCC should be integrated in the 2019 IPCC. In
this way, only one document can be referred in 2019.

Accepted withmodification

A new explanatory section makes it clear that 2006 IPCC GLs should only
be used for CO2 emissions accounting from primary aluminium smelting(outside scope of 2019 IPCC refinments Table of Contents). In all othersections / cases, the 2019 IPCC Refinments should be used in place of the2006 IPCC GLs.

Comment ID Volume
7866

3

Chapter
4

From line To line
889

903

Comment

ExpertThere is new technology types defined in the 2019 refinement. It is
Christine Dubois
indicated that the growth in technology without fully automated anodeeffect intervention strategies for PFC GHG emissions has risen from <30%
in 2006 to >60% in 2017. in the document "updated factor for calculation
PFC emission from Primary aluminium production" indicate that thissmelter count AE from 2minutes, below 2 min it is considered as "flash
AE". This explain the new technology type "Modern Point-Fed Prebake
without fully automated anode effect intervention strategies for PFC
emission (PFPBmw). The division of PFPB Legacy and PFPB Modern
based on the amperage is not clear. Why PFPB having automatic AE
intervention capacity is now divided into 2 technologies as Legacy PointFed prebake (PFPB L) and Modern Point-Fed Prebake (PFPB M)? The PFC
emission are measured per tonne of aluminium, it includes the effects ofamperage and current efficiency (see line 1083 in the document). Also, as
the performance of AE will come from alumina injection, AE control
automatic system and algorithm independently of the current, I don't
understand why it is separated. Does the Tier 2 HVAE slope difference
between smelters <350ka and >350ka come from their operation andequipment or from the the amperage? if this subcategory is created based on
actual data, it might not be true in the near future with all the change thatthose smelter does to improve their operation.
Alcoa has aluminum smelter operating with amp <350ka and >350ka, we
see difference in the AE duration and PFC emission when there isdifference with the control system and alumina injection. For smelter
having similar alumina injection and similar automatic control system, we
have similar AE manual killed, similar AE frequency and similar AE
duration independly on the ka.

Response
Noted

Authors notes
Separating Legacy from Modern based on amperage can be a bit arbitrary on
the margins but the logic of separating the technology into two is driven
primarily from the desire to add PFC emissions that are not associated withrecorded anode effects into the emissions inventory. The “modern” cells
typically have a larger number of anodes, and operate at higher amperage.
These cells typically have a lower recorded anode effect frequency, one
major factor being that voltage excursions that begin on one or two anodes
don’t always get propagated into a full anode effect with overall cell voltage
exceeding 8V. These voltage excursions in a portion of the cell do,
however, release PFC emissions. Therefore these “modern” high amperagecells have a different characteristic ratio of non-AE PFC emissions to AE
emissions, that is, the high amperage modern cells typically have higher nonAE to AE emission ratios. Thus, a separate category is defined for those cells
that characteristically have low AE emissions but high non-AE emissions.
Yes, the HAVE slope factors are based on actual measurement data, and,perhaps you may be right that these factors might change over time withchanges in work practices. The suggested factors are averages of measured
data and we know that high voltage PFC emission slope factors are
dependent on anode effect duration. If practices change so that anode effectduration distribution changes toward shorter AEs the slope factor will
increase – and, similarly, if the anode effect duration distribution tilts toward
longer duration, then the slope factors will decrease. The best and mostaccurate emission factors will result from Tier 3 facility specificmeasurements, and, remeasurement if work practices and operations datachange significantly.
Alcoa has been active in making measurements of emissions to determine
facility specific slope factors and this is the most accurate method for PFC
accounting.
Current wording is correct

8636

3

4

892

892

...without fully automated anode… should perhaps be ...with fully
automated anode…

Henrik Åsheim

Rejected

8638

3

4

894

903

Is it perhaps enough to divide PFPB in two types - one with and one
Henrik Åsheim
without automatic AE detection and termination. Latest findings show that
HVAE/LVAE is not specific to one or the other, rather it is more dependanton technology and process control.

Rejected

The logic of separating the technology into two is driven primarily from thedesire to add PFC emissions that are not associated with recorded anodeeffects into the emissions inventory. The “modern” cells typically have alarger number of anodes, and operate at higher amperage. These cells
typically have a lower recorded anode effect frequency, one major factor
being that voltage excursions that begin on one or two anodes don’t always
get propagated into a full anode effect with overall cell voltage exceeding
8V. These voltage excursions in a portion of the cell do, however, release
PFC emissions. Therefore these “modern” high amperage cells have a
different characteristic ratio of non-AE PFC emissions to AE emissions, thatis, the high amperage modern cells typically have higher non-AE to AE
emission ratios. Thus, a separate category is defined for those cells thatcharacteristically have low AE emissions but high non-AE emissions.

7868

3

4

932

933

I agree with the sentence: " to use higher Tier methods because emission
Christine Dubois
rates can vary greatly, and the uncertainty associated with Tier 1 factors isvery high" and it can be added that "and uncertainty associated with Tier 2
still high also".

Rejected

Uneccessary wording - uncertainties are clearly stated in the tables.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

7496

3

4

938

941

No refinement was made to the 4.4.2.1 section.
Nadia Morais
However, new quantification formula was now used in the industry for CO2
emissions from prebaked anode consumption. Equation 4.21 substract the
impurity (%S and %ash) form the net prebaked anode consumption to
calculate CO2 emissions. Insted of that, the COMMISSIONREGULATION (EU) No 601/2012, use directly the %C with the net
prebaked anode consumption to calculate those emissions.
The 2019 Refinement should add a new formula in option of Equation 4.21
to give the opportunity to use the %C.

Noted

No action can be taken because comment is out of scope of 2019
Refinement

7870

3

4

944

944

At the section 4.4.2.2 it is indicated no refinement. In the original
Christine Dubois
document, the section of "Choice of emission factors for CO2 emission
from primary aluminium production - Tier 2 and Tier 3 emission factors forCO2 emissions - CO2 emissions for Prebake cells (CWPB and SWPB)"
still use the formula with %S and %ash in baked anodes to determine CO2
emission coming from anode consumption. A new formula could be add tothe actual one to integrate regulation which asking emitter to use %C in theformula instead of % S and % ash to calculate CO2 coming from anodeconsumption. One of the regulation is the COMMISSION REGULATION(EU) No 601/2012. The request to comply should be integrated in therefinement 2019. The lab car be accreditated for % C analysis as well as %S. Two formulas should be available in the IPCC 2019 document, one
using %S and%ash and the other using %C in the baked anode. The table
4.11 can be updated adding %C as a alternative of the %S and %ash.

Noted

No action can be taken because comment is out of scope of 2019
Refinement

7872

3

4

947

958

The document is presenting new definitions as in box 4.2 for high and low Christine Dubois
voltage anode effect description. Similarly a new definition should be
added to describe the ratio LVAE/HAVE that later is used to estimate low
voltage emissions. Since the LVAE could be significant to best AE
performer smelters, and there is no process correlation between both LV
and HV PFC emissions, the term should be clearly defined as a first step toestimate low voltage emission. Tier 3 will be the only approach to accountfor both emissions.

Accepted withmodification

We have removed the T2 ratio method for LVAE emission estimation but it
remains an option for a T3 level, along with T3 direct measurement options.

7498

3

4

957

958

Accepted withmodification

Description that LVAE is a new concept is provided in the text body, insteadof Box 4.2 as suggested.

4040

3

4

958

Add at the end of the BOX 4.2 : «The LVEA is a concept relatively new and Nadia Morais
no measurement protocol are actually available to improve consistency andalignment across the industry.»
Replace the word "doesn't"with does not.
Andrea Tilche

Accepted

Changed in text

8566

3

4

965

965

"release both CF4 and C2F6 emissions" emissions is per definition released, Ole Kjos
should be rewritten

Accepted

Changed in text

7500

3

4

970

970

Nadia Morais

Accepted

Changed in text

7876

3

4

976

978

Change «because the information was not available» for «because theinformation and the methodology measurement was not available».
Tier 2 is also having a high uncertainty compared to Tier 3.

Christine Dubois

Noted

Tier 2 usually has higher uncertainty than Tier 3 as Tier 3 is site specific.

Comment ID Volume

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Comment

ExpertAuthors notes
The overvoltage EF from the 2006 guidelines should be used for Tier 2
estimations from 1990 up to 2019. It is only for future estimations that Tier
2 estimates are not recommended. The total number of facilities using theovervoltage method is too low to determine an EF representative of the
global industry for national inventories. However, the possibility remains to
use Tier 3 EF for future estimations.

Noted

We have removed T2 HVAE/LVAE ratio due to the high uncertainties andhave added other T3 options.

Accepted

A Tier 3e method has been provided for the option to account for facilityspecific Total PFCs using direct measurements.

IPCC or IAI should have a team who works on on a methodology to
Christine Dubois
standardise the measurement of LVAE PFC emissions. In the 2019refinement, PFC from LVAE will be added to HVAE but there is no
indication how to measure it and add it during the PFC sampling. Industry
will do the Tier 3 the best way they can do but there will be no common
method. On air emission, having a specified sampling method, lab analysis
reference and calculation is the key to national reporting.
Also, as integrating LVAE PFC emissions is new, would it be possible toput a transition phase?

Noted

IAI will coordinate work on updated measurement protocol utilisingexpertise of member companies on LVAE measurements. A transition phase
is not possible but the separation of LV and HV and wording around higher
uncertainties and the 'first estimate' nature of LV are included so inventory
compilers are aware of the challenges. The guidelines are for National andGlobal GHG inventories and site specific information on sampling etc will
be covered in a separate protocol.

992

Remove : «as data related to LVAE are not typically included»

Nadia Morais

Accepted

Changed in text

996

998

The method proposed has an important uncertainty, for country having
GHG regulation including GHG emission from process as PFC, it has an
impact. The objective is to declare accurate GHG emission and the
proposed method (divided PFPB legacy and modern and adding LVAE
with HVAE) raised uncertainty.

Christine Dubois

Noted

In the 2006 guidelines,the Tier 2 slope and overvoltage coefficients were notcalculated on the same basis. In the 2019 refinements, the recommendation
was to use "range uncertainty" based on the impact that a tier 2 EF might
have on the uncertainty of individual facilities. For this reason, the 2019refinements values are correct. In addition, if you were to consider the old
2006 EF values, the level of "range uncertainty" would be similar.

1000

1004

Christine Dubois
Adding the LVAE PFC emission for PFPB with full control system,
represent an annual average carbon cost of
US $150 000 for each Alcoa aluminium smelters operating in
Québec/Canada where there is GHG cap. The average was done for 2007 to2017 PFC emission and this cost estimation was done for 2018. Québec
carbon cost increase each year of 5% + %indexation of the cost.

Noted

No action can be taken because comment is out of scope of 2019
Refinement

3

4

984

987

8760

3

4

988

998

8640

3

4

990

998

7878

3

4

991

995

7502

3

4

992

7880

3

4

7886

3

4

4.4.2.3 CHOICE OF METHOD FOR PFCS: it is written "In the 2006 IPCC Christine Dubois
Guidelines, two methods for calculating coefficients for HVAE PFCs were
outlined: slope and overvoltage. The overvoltage method is not widely usedanymore so this update will cover the methods with reference to the slopemodel only. If the overvoltage method is still used, it should be adopted at
the Tier 3 level only". For country having GHG cap and trade including
process emission, it will be difficult to backcast PFC emission and include
LVAE for smelter using overvoltage it there is no indication for thismethod. We need to considered this method as the regulated target are
based on past data. It will be difficult to backcast the emission from 2007 if
there is no tier 2 factor for overvoltage. We may have historical data
updated with LVAE CO2 emissions and some not as the Tier 2 factor won't
be available.
Using HVAE as a proxy for process control and LVAE emissions is
Ole Kjosdifficult to justify from a theoretical point, as these two phenomenas canocurr independently of each other, this is reflected in the very highuncertainty (poor correlation) of the data on a matematical level. Whenlooking at Dion et al TMS2018:, in figure 2, variations in LVAE/HAVE
ratios is illustraded, and for almost all factories the upper level is more than
3x the lower level, wich suggests that even for individual facilities this is apoor correlation. For some of the plants measured it is difficult to see thespan, but this is due to the scale of the y-axis, the variation is large whenlooking at relative difference between the lowest and highest level for eachplant.
It is true that most smelter do not gather any data that can reasonably
Henrik Åsheim
calculate LVAE. However, it can be measured by a few different methods(absorbents, canister, high LOD FTIR, (QCL,) etc.), and longterm/continuous measurements should maybe be adressed as a top Tier
option?

Response
Rejected

7874

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

7884

3

4

1001

1015

When we do PFC sampling to get a Tier 3 factor, it is a picture of theChristine Dubois
operation when we did the PFC sampling. It is important that the operationis the picture of operation we have normally. As it is a PFC emission
sampling of the PFC emission population, to ensure a good representationof the slope factor used and operations, it is important to validate key
operating parameters such as the ratio of AEkilled manually/AEtotal, AE
duration, AE duration-frequency. If there is a permanent changed, slope
factor might be change too and need to be validate.

Noted

Details on sampling procedures are not for inventory guidelines but should
be included in measurement protocol.

7882

3

4

1006

1009

It is indicated the high performing facilities are those that operate with less Christine Dubois
than 0,02min/cellday which is very low. It is not specified if it is for one
pot, a potline weekly/monthly/annual result. Because AE may not bemeasured exactly based on the same parameters and since aluminium
smelter may not have the same constraint like curtailment and power
modulation period from power supplier, a suggestion would be to indicate
the percentile on annual result. For example 10 or 20 percentile of annual
AE. This will indicate that 10% or 20% of aluminium site is lower than thisAE min/cellday.

Rejected

We have removed reference to high performing facilities.

7504

3

4

1045

1062

The information about the LVAE is interesting but since this concept is
new and still developping, the sections about LVAE must be placed in aseperate section after le line #1292 : «Future opportunities».

Rejected

Inclusion of LVAE was mandated by IPCC based on existing
literature/science - we have endeavoured to make explicit that this is a firstattempt to estimate LVAE emissions at the national/global level.

8568

3

4

1048

1048

The uncertainty is claimed to be greater for tier 1, but this is not consistent Ole Kjos
with the uncertainty budgets in table 4.15 and 4.16. For all technologies,
except PFPB(L), the uncertainties for LVAE is lower with tier 1 than tier 2.
In addition the factors in table 4.16B (Tier2) have to be multiplied with thealready uncertain HVAE CF4 estimates giving a high propagateduncertainty, while numbers from 4.15 (tier 1) is multiplied with the very
accurate production tonnages of Al. There is therefore no reason to use Tier
2 on LVAE emissions, Tier 1 is more accurate, and simpler.

Accepted

We have removed Tier 2 due to the propagation of the uncertainties from
HVAE.

7506

3

4

1087

1087

Rejected

This format is widely used across the guidelines - the numbering or lettering
is not intended to rank which method is best but is merely a way to describe
the many different methods available for inventory compilers to use
depending on their needs e.g. the availability of data, key category etc. We
have provided a table for clarity on the different methods proposed.

8642

3

4

1087

1087

Accepted

We have provided a summary table of the different methods and tiers
proposed.

7508

3

4

1109

1109

The 2019 Refinement introduce a new concept of letter with the «Tier»
Nadia Morais
definition (ex: Tier 2A and Tier 3A) . Furter in the text we see Tier 2b andTier 3b. Adding letter to «Tier» create confusion and gives the impressionthat «A» is better than «B». I suggest to remove the letter and simply
indicate the Tier number like the 2006 IPCC for the Slope Coefficient andOvervoltage Coefficient who are both Tier 3 but have different equation
number.
There are very many different Tier 3s (and Tier 2s). There's Tier 3, Tier 3a Henrik Åsheim
and two different Tier 3b. If one should have this many options, perhaps itis better to name all with a sub-index.
Add HVAE to ECF4
Nadia Morais

Accepted

Changed in equation

7510

3

4

1111

1111

Add HVAE to EC2F6 and ECF4

Nadia Morais

Accepted

Changed in equation

7512

3

4

1115

1115

Correction of the units : kg CF4/t Al per (mV.day/cell-day*CE)

Nadia Morais

Rejected

No refinment has been made to the Overvoltage calculation method, andunits are as per 2006 Guidelines.

7514

3

4

1116

1116

Correction of the units : mV/cell-day

Nadia Morais

Rejected

No refinment has been made to the Overvoltage calculation method, andunits are as per 2006 Guidelines.

Nadia Morais

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

7888

3

4

1122

1176

to measure PFC coming from HVAE, we have a method (Protocol for
Christine Dubois
Measurement of Tetrafluoromethane (CF4) andHexafluoroethane (C2F6) Emissions from Primary Aluminum Production
US Environmental Protection Agency & International Aluminium Institute2008) , I agree with the proposition of Tier 2b and Tier 3b as it is an option,
not an obligation. This method increase PFC inventory accuracy when slope
data are available and when data process can be extract to use this formula.

2932

3

4

1124

1125

Verify bibliographic citation format

7890

3

4

1130

1131

It is indicated that both approcheds quantify the PFC emission fromChristine Dubois
individual HVAEs based on process parameters that are known or
calculated by the cell control système. It is important to know that somesystem extract data for each pot but for a period of time which can be 4
hours or 12 hours for example. Thereby, for each pot, we will have the total
AE duration for all AE occur during this period of time. As exemple, if thesystem extract data for 4 hours for pot number 1, we may have one AE at 35
sec. But we might have two AE with the total of 155 sec and we don't know
the duration for each of the two AE.

Noted

In order to adequately use non-linear HVAE methodology, it is good practicethat the cell control system allows for distinction between individual HVAE
durations. In the case where a facility does not have the ability to dissociateindividual HVAE parameters, another estimation methodology would be
preferable.

7516

3

4

1131

1131

Nadia Morais

Rejected

2934

3

4

1132

1133

Add at the end of the sentence : «However, it's possible that the plant
specific extraction data system from database don't give the informationneeded for the calculations».
Verify bibliographic citation format

Uneccessary wording - if the data is unavailable then another method should
be adopted. However, wording has been added that the Tier 2b/3b methods
require the ability to extract individual HVAE data
Format is in agreement with Environmental Conservation style.

7518

3

4

1136

1136

Nadia Morais

2936

3

4

1138

1138

Add at the end of the sentence : «No measurement protocol are available
now to determine Tier 3 based on individual anode effect measurement»
Verify bibliographic citation format

8644

3

4

1138

1138

7892

3

4

1138

1176

8646

3

4

1154

7894

3

4

7896

3

4

Noted

Poot-Delgado Carlos Antonio Noted

Poot-Delgado Carlos Antonio Noted
Accepted withmodification
Poot-Delgado Carlos Antonio Noted

An update measurement protocol will be developed and published through
IAI.

Format is in agreement with Environmental Conservation style.

Included wording to indicate absence of existing protocol but also plans for
update in near future to support guidelines.
Format is in agreement with Environmental Conservation style.

2018a and 2018b references of "Marks and Nunez" seems to have been
Henrik Åsheim
switched throughout the document
Having an exemple in annex could help to understand the formula 4.27A, Christine Dubois
4.27B and 4.27D and make sure we put the correct data with correct unit.
The formula 4.27A and 4.27B have been tested with fictitious data.
Formula 4.27A seems to work but I was not able to get something fromformula 4.27B and 4.27D. It is not clear how to use this formula. As it is for
PFC emission from HVAE based on individual AE measurement, shouldboth formula give similar PFC emission result?

Accepted

There was indeed an inversion in the reference.

Accepted

Examples of calculations for the tier 2b methodology were added in theworksheet for easier use of the equations.

1154

2018a and 2018b references of "Dion et al." seems to have been switchedthroughout the document

Henrik Åsheim

Accepted

There was indeed an inversion in the reference.

1177

1204

There is no indication from when AE should be measured specifically for
pot start. Some primary aluminium smelters is measuring AE from themoment the pot has power (without any bath or alumina), some will begin
to measure when bath is added in the pot, others when alumina is added in
the pot as example. This difference could be important when we calculate
the annual AE (min/cellday). It could be nice to have guidelines when AE
should begin to be measure for a pot start.

Christine Dubois

Accepted withmodification

Start-up description (Box 4.2a) includes a definition of cell start-up andindication of when PFCs generation is expected to be possible - startingfrom the moment when anode beam is first raised and metal starts to be
produced.

1177

1204

This new box about high voltage anode effect following start-up of
Christine Dubois
electrolysis cell was added and recommend that proposed Tier 2b non linear
approach from equation 4.27 (A or B) would lead to more correct
quantification of these data when no specific measurement data are
available. Alcoa experience, not published, is that low voltage is alsopresent during pot starts and therefore the most accurate approach is direct
Tier 3 measurement during pot-start, not Tier 2b.

Accepted

Tier 3d method provides for a means to estimate total (LVAE + HVAE)
emissions from cell start-up using facility-specific emission factors obtained
during measuremnts. An alternative Tier 3e direct measurement approach isalso provided as a separate method.

2938

3

4

1180

1181

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Noted

Format is in agreement with Environmental Conservation style.

2940

3

4

1182

1182

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Noted

Format is in agreement with Environmental Conservation style.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Poot-Delgado Carlos Antonio Noted

Authors notes

2942

3

4

1189

1189

Verify bibliographic citation format

Format is in agreement with Environmental Conservation style.

7520

3

4

1193

1194

START-UP : it's interesting to add the BOX 4.2A to the 2019 Refinement. Nadia Morais
The only thing I suggest to add is the possibility to use a Tier 3 Slope
Coefficient or Overvoltage Coefficient specific for start-up in addition of
the Tier 3 kg CF4/Cell start-up.

Accepted

Tier 3a OV or Slope Method has been added as a possible Tier 3 method forcell start up emissions, provided a separate coefficient is used for start-up vs.
normal operations

7898

3

4

1195

1198

For one smelter, we now use a different slope for anode duration
Christine Dubois(min/cellday) for pot start-up. The two first day of operation, the AE
duration are much longer. The total anode duration-frequency (min/cellday)of the first 2 days of pot operation is multiply by a slope((kgCF4/mt)/(min/cellday)). The monthly PFC emission is the PFC
summation of "normal pot operation" and "pot start", both using specific
PFC slope in (kgCF4 or C2F6/mt)/(min/cellday). The formulain line 1195
to 1199 indicate that we have to use a factor based on kgCf4/cell start-up.
Will it be possible to have the option of both?

Accepted

Tier 3a OV or Slope Method has been added as a possible Tier 3 method forcell start up emissions, provided a separate coefficient is used for start-up vs.
normal operations

2944

3

4

1202

1203

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Noted

Format is in agreement with Environmental Conservation style.

7522

3

4

1206

1230

The information about the LVAE is interesting but since this concept is
new and still developping, the sections about LVAE must be placed in aseperate section after le line #1292 : «Future opportunity».

Nadia Morais

Rejected

Inclusion of LVAE was mandated by IPCC based on existing
literature/science - we have endeavoured to make explicit that this is a firstattempt to estimate LVAE emissions at the national/global level.

7900

3

4

1206

1232

As spectified in the document, all the technology named PFPB MW will not Christine Dubois
have LVAE CF4 emission, only a portion of technology are targeted which
represent around 40% of the total aluminium production. In the table 4.15,
there is no LVAE Tier 1 factor for PFPB MW. In the table 4.16B, there is
no LVAE/HVAE ratio for PFPB MW also. The uncertainty of adding
LVAE even using Tier 2 of table 4.16B is quit important for PFPB ROW.
The uncertainty vary inside the range of +431 to -98%.
As not all aluminum smelters are targeted, that the uncertainties are high,that there is no sampling method specified to integrate the LVAE emission
and that proposition is a first step toward total emissions reporting, would it
be possible to add this section as a work in progress or actual informationand integrate a transition phase to eventually add LVAE PFC emission in
the inventory when we will have a sampling method having LVAE PFC
included and have more data to consider in the Tier 2 to reduce theuncertainty?

Rejected

PFPB MW T1 EFs already include LVAE component as the measurement
data that underpins the EF was 'total emissions' i.e. HV and LV. Therefore
LVAE will be accounted for >95% of aluminium production.
Addressing LVAE emissions was specified in the IPCC mandate and thecompleteness of the inventory is improved even if this is associated with ahigh degree of uncertainty.
These EFs and guidance are for National GHG inventories - the EFs arealways an average of a variable dataset which leads to a certain degree of
uncertainty if adopting at the facility level.
We recognise the significant contribution that the addition of LVAE
emissions may have on PFPB M classes and have provided options to users
e.g. keep HVAE and LVAE separate for T2 or adopt T3 site specific options
or T3C direct measurement which could be on a total emissions basis.

2946
8648

3
3

4
4

1215
1221

1215
1221

Verify bibliographic citation format
Poot-Delgado Carlos Antonio Noted
It seems a stretch to base LVAE on HVAE and let them follow each other Henrik Åsheim
Notedlinearly. With 0 HVAE one would also get 0 LVAE. In one of the
supporting documents (Dion et al. LM2018 pp. 1457-1462) there is a plotof the LVAE/HVAE ratio for different smelter (Fig. 2) and the text suggeststhat there is little variation within one smelter. The scale on the y-axis canlikely confuse a bit, but it seems to easily be a difference of 2-3 times
within the smelter and a huge difference smelter to smelter.

Format is in agreement with Environmental Conservation style.
We have removed T2 ratios and this is no longer an issue.

8650

3

4

1235

1235

Accepted

Reference to high performing facility has been removed.

8758

3

4

1240

1240

Fig 4.12 indicates that for a high performing facility it doesn't matter if you Henrik Åsheim
calculate emissions from Tier 2 or Tier 3. Is not part of the point that Tier 3
is more accurate and should it not be an incentive to get there?
Continuous measurements, and how to use such measurements in
Ole Kjosinventories, should be addressed. Development is ongoing, and more
affordable instruments might very well be available long time before next
review. A generic guide on how to report such measurements as part of theinventory could be written independent of technology.

Noted

An update measurement protocol will be published through IAI.

Comment ID Volume

Chapter

From line To line

Comment

8570

3

4

1247

1247

Footnote b in CF4 Uncertainty range does not make sense, just a typing
error?

8652

3

4

1247

1247

8654

3

4

1247

1247

7524

3

4

1247

7902

3

4

1250

7904

3

4

1254

8656

3

4

1254

1254

7906

3

4

1256

1278

7908

3

4

1257

2948

3

4

1258

ExpertOle KjosResponse

Authors notes

Rejected

Not a typing error - the EF is based on a single data point therefore a range
cannot be provided.

Henrik Åsheim
HVAE-CF4-EF_CF4 (kg/tonne Al). The values (0.029, 0.030, etc.) aretaken from Total CF4 in the supporting document. It should perhaps be the
AE related data.
LVAE-CF4-EF_CF4. The value from Legacy PFPB (0.016) is taken from Henrik Åsheim"pre 2013" while the rest is "post 2013" and "post 2013" data is available

Accepted

Changed in table

Accepted

Changed in table

1248

The information about the LVAE is interesting but since this concept is
new and still developping, the right section in the table 4.15 about LVAE
must be placed in a seperate section after le line #1292 : «Future
opportunity».

Rejected

Inclusion of LVAE was mandated by IPCC based on existing
literature/science - we have endeavoured to make explicit that this is a firstattempt to estimate LVAE emissions at the national/global level.

1255

Table 4.16 shows the new Tier 2 slope factors for new grouping technology Christine Dubois
for calculation of high voltage PFC emissions using slope methodology andTable 4.16 b, shows the new Tier 2 slope factors for new grouping
technology for calculation of low voltage PFC emissions based on median
LVAE/HVAE ratios. Since the industry will need to report total PFC
emissions, a new table should be added to combine both emissions to makeit more clear. For example for PBPF Legacy, the combine slope will be
0.127 + 0.127 * 0.4 = 0.178

Accepted

Equation 4.24A added, for total PFCs as sum of all PFCs - HVAE, LVAE
emissions and also any cell start up emissions

Christine Dubois
In the table 4.16 at the data for PFPB legacy, the SC CF4 is 0,127. In the
publication of "Updated factors for calculating PFC emissions from primaryaluminium production-table 3 Recommended upates to Tier 2 slope andRC2F6/CF4 coefficients for calculating HVAE CF4 emission factors, Jerry
Marks and Pernelle Nunez" the data is 0,111 which is the PFPB outside
China (ROW) Post 2013 Legacy PFPB ROW. The 0,127 is coming fromthe "Pre 2013 Legacy PFPB ROW" see Table 1 of J. Marks and P Nunez
document. Why the data from Pre 2013 instead of Post 2013 was chosen for
IPCC document?
Henrik Åsheim
Legacy PFPB data is from "pre 2013" while the rest is "post 2013". Post
data available for all in original material.
The HAVE PFC emissions rate coefficients based on individual anode
Christine Dubois
effect durations should be tested with a larger data set before being
proposed in 2019 Refinement. Our experience from Alcoa smelters is that
limited data is not consistent in each anode effect duration submitted, either
overestimating or underestimating the emissions. Furthermore, these are
only applied to high voiltage emisions. We prefer to use Tier 3 direct
measurements with canisters that will measure total emissions with repeats
every three years. This will warranty accurate emissions and be better thanthese Tier 2b slope approach with limited time from plant personnel tocalculate emissions of individual anode effect durations. The IAI shouldsponsor a study to improve both approaches and proposed which one will
give more accurate numbers.

Accepted

Changed in table

Accepted

Changed in table

Accepted withmodification

We acknowledege there will always be limitations with default coefficientsand these guidelines are intended as National or Global inventory estimatesand not for facility specific calculations where they will likely
over/underestimate (except Tier 3). The Tier 2B approaches have beentested on approixmately 3000 individual AEs over multiple facilities andmeasurement campaigns. We have added a direct measurement option toaddress your point on canister and total emissions reporting (which is a very
accurate way to account for emissions). The IAI project nomination process
is an open process to which anyone can submit a proposal for considerationof IAI funding - Alcoa is always welcome to submit such a proposal
detailing a plan to improve the approaches.

Accepted

Changed in table

Nadia Morais

in the table 4.16 at the data for PFPB legacy, the C2F6/CF4 is 0,114. in the Christine Dubois
publication of "Updated factors for calculating PFC emissions from primaryaluminium production-table 3 Recommended upates to Tier 2 slope andRC2F6/CF4 coefficients for calculating HVAE CF4 emission factors, Jerry
Marks and Pernelle Nunez" the data is 0,073 which is the Avg AE
RC2F6/CF4 of the post 2013 legacy PFPB ROW. The 0,114 indicated in
the IPCC document is the data of avg. AE RC2F6/CF4 for pre2013 legacy
PFPB ROW (see table 1 of the "Updated factor for calculating PFC
emissions from primary aluminium production"). Why IPCC chose pre
2013?
1258

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Noted

Format is in agreement with Environmental Conservation style.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

8658

3

4

1261

1261

Second line of table. 6 s should possibly be 5s.

Henrik Åsheim

Accepted

Changed in text

8660

3

4

1261

1261

Last line of table. The formula for "0 s" AE should likely be divided byHenrik Åsheim
1000 to match the rest of the formulas. This is also incorrect in the original
material (a small mixup with g/kg). Otherwise a "0 s" AE would be counted
as approximately 2500 s of 100 % CF4 production.

Accepted

The formula has been edited.

2950
2952

3
3

4
4

1263
1266

1263
1266

Lack comma in bibliographic citation
Verify bibliographic citation format in footnote

Poot-Delgado Carlos Antonio Noted
Poot-Delgado Carlos Antonio Noted

Format is in agreement with Environmental Conservation style.
Format is in agreement with Environmental Conservation style.

7526

3

4

1279

1284

Nadia Morais

Rejected

8662

3

4

1284

1284

The information about the LVAE is interesting but since this concept is
new and still developping, the text and the table 4.16B about LVAE must
be placed in a seperate section after le line #1292 : «Future opportunity».
Uncertainties of Tier 2 LVAE for all but legacy PFPB is higher than the
Tier 1 equivalent. This is before taking into account the uncertainties in
HVAE as LVAE of Tier 2 is based on HVAE. This is unfortunate as itprovides little incentive to move to a higher Tier.

Henrik Åsheim

Noted

Inclusion of LVAE was mandated by IPCC based on existing
literature/science - we have endeavoured to make explicit that this is a firstattempt to estimate LVAE emissions at the national/global level.
We have removed T2 - no longer an issue.

7528

3

4

1290

1291

Move the sentence «For LVAE, facitity-specific ratios can be established Nadia Morais
based on direct measurement of HAE and LVAE for a period of time» afterline 1292 in the proposed specific section for LVAE : «Futur opportunity».
Add at the end of the sentence : «no measurement protocol are actuallyavailable to improve consistency and alignment across the industry».

Rejected

Inclusion of LVAE was mandated by IPCC based on existing
literature/science - we have endeavoured to make explicit that this is a firstattempt to estimate LVAE emissions at the national/global level. Have
included a comment on the development of an industry protocol.

7530

3

4

1301

1301

Add at the end of the sentence : Tier 3 can also uses anode effecte
overvoltage and current efficiency

Nadia Morais

Accepted

Included in text

8664

3

4

1303

1303

Missing "Tier" in front of "2"

Henrik Åsheim

Accepted

7910

3

4

1352

1370

Smelter using overvoltage must have information on how to backcast their Christine Dubois
emission if we updated PFC emission. It is important for GHG regulationthat our data will be as much accurate as possible

2954
7912

3
3

4
4

1354
1355

1355
1357

Verify bibliographic citation format
Poot-Delgado Carlos Antonio Noted
Alcoa has aluminum smelter operating with amp <350ka and >350ka, we Christine Dubois
Noted
see difference in the AE duration and PFC emission when there isdifference with the control system and alumina injection. For smelter
having similar alumina injection and similar automatic control system, we
have similar AE data (manual killed, frequency and duration) independly on
the ka.

Accepted withmodification

There was no direct correction to adress this specific issue. However, a table
was added regarding time consistency to adress specifically which
guidelines to use for each specific period. Indirectly, this issue should becovered by using the respective table.
Format is in agreement with Environmental Conservation style.
Separating Legacy from Modern based on amperage can be a bit arbitrary on
the margins but the logic of separating the technology into two is driven
primarily from the desire to add PFC emissions that are not associated withrecorded anode effects into the emissions inventory. The “modern” cells
typically have a larger number of anodes, and operate at higher amperage.
These cells typically have a lower recorded anode effect frequency, one
major factor being that voltage excursions that begin on one or two anodes
don’t always get propagated into a full anode effect with overall cell voltage
exceeding 8V. These voltage excursions in a portion of the cell do,
however, release PFC emissions. Therefore these “modern” high amperagecells have a different characteristic ratio of non-AE PFC emissions to AE
emissions, that is, the high amperage modern cells typically have higher nonAE to AE emission ratios. Thus, a separate category is defined for those cells
that characteristically have low AE emissions but high non-AE emissions.
Alcoa has been active in making measurements of emissions to determine
facility specific slope factors and this is the most accurate method for PFC
accounting.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

7914

3

4

1356

1357

With GHG regulation, GHG emission calculation are regulated and inside
the regulation we have the formula or information on calculation for GHG
emission. For aluminium sector, information on calculation for GHG
emission are based on IAI, GHG protocole and IPCC protocole. Updating
PFC calculation will impact the national inventory and industry GHG
reporting which is directly connect with the country reduction target.

8666

3

4

1357

1357

There is today a very high uncertainty with the LVAE data. Backcasting it Henrik Åsheim
to earlier dates with todays emission factors seem unwise as it is impossible
to know how these emission factors have varied over time. It is likely betterto focus on improving the future with e.g. more measurements, different
measurement techniques etc.

2956

3

4

1364

1364

Lack comma in bibliographic citation

7916

3

4

1367

1369

Christine Dubois
Past inventory management must be clear and accurate. Carbon freeallowance is given based on past benchmark or based on past year as 20072010 data for the WCI regulation. If we include LVAE for future, we needto adjust as much accurate we can past result. If there is a potential tooverestimate the past inventory by backcasting PFC emission, there is also arisk to overestimate the actual PFC emission as the uncertainty is more
+431 than -98.

1369

Lack comma in bibliographic citation

Poot-Delgado Carlos Antonio Noted

Format is in agreement with Environmental Conservation style.

Replace "that" with "than"Andrea Tilche

Accepted

Changed in text

Add at the end of the sentence : «no measurement protocol are actuallyavailable to improve consistency and alignment across the industry».

Nadia Morais

Accepted withmodification

Included some wording to explain protocol is under development but not yet
available

Christine Dubois

Noted

Updated guidelines for Aluminium GHGs have been as per the IPCC
mandate, which includes providing guidance on LVAE PFCs.
Consdierations for GHG regulation are beyond the scope of these guidelines.

Accepted withmodification

It is not suggested to backcast further than 2006. Major revisions to LVAE
estimations were performed between the SOD and the FD in order to makesure that the methods with the lowest uncertainty remained. Finally, there isa suggestion added in the time-serie consistency to use actual smelters Tier 3
coefficient when backcasting instead of technology specific coefficient,which should also reduce the uncertainty.
Format is in agreement with Environmental Conservation style.

Poot-Delgado Carlos Antonio Noted
Accepted withmodification

Major revisions to LVAE estimations were performed between the SOD and
the FD in order to make sure that the methods with the lowest uncertainty
remained. Finally, there is a suggestion added in the time-serie consistency
to use actual smelters Tier 3 coefficient when backcasting instead oftechnology specific coefficient, which should also reduce the uncertainty.

2958

3

4

1369

4042

3

4

1419

7532

3

4

1422

4044

3

4

1507

Replace "processis" with "process is"Andrea Tilche

Accepted

4046

3

4

1609

Andrea Tilche

Accepted

4048

3

4

1850

Andrea Tilche

4050

3

4

1882

Replace "remove also some" with "also remove some" - just a suggestion.
It’s a question of taste.
The sentence "Emission factors for alumina production are as follows"
should be followed by some explanation.
Replace "consideration" with "considerations"

Accepted withmodification
Accepted

4052

3

4

1908

"%" should be written in full

Andrea Tilche

Accepted

Replaced by word "percentage"

4054

3

4

2104

The word "terms" should be followed by "of"Andrea Tilche

Accepted

Corrected in text

4056

3

4

2288

remove "s" after "fundamentals"

Andrea Tilche

Accepted

Corrected in text

2960

3

4

2297

2297

Verify bibliographic citation format in footnote

Poot-Delgado Carlos Antonio Noted

8576

3

4

2371

2372

There exist very limited information on quantifications of PFC emissions Ole Kjos
from RE metal production. The few recent pubications used here contains
data with huge variations. As a first approach it is a good starting point, but
the very different numbers for RE iron alloys is questionable as they are
difficult to explain this from a theoretical perspective. Laboratory work
published in Metallurgical and materials transactions B by Martinez et.al.
have demonstrated RE-iron alloys to be produced in laboratory scale
without any PFC at all, and in work that will be published soon on the sameprocess have demonstrated it to operate at a 1000A pilot cell without PFC
emissions.

1422

Andrea Tilche

Noted

The appropriate text has been removed

Format is in agreement with Environmental Conservation style.
Our understanding is that Dy-Fe and other high metal point (>1300 deg C)
rare earth metals require alloying with iron for economic production;
indications within the Chinese industry is that it also requires higher
operational cell voltage than production of Nd and other RE metals/alloys,
which may also increase the risk of PFC generation. Therefore the higher
emission factors appear to be consistent with these process observations, atleast in China. There were no industrial emission factors available prior to
the Literature Cut off Date that has suggested otherwise.
However, it is acknowledged that the industry is developing quickly, andother low PFC emisison technologies may soon be operating on industrial
scale. Guidance has been added to highlight this. In the case of major
technological developments and/or automation to reduce PFCs, it is goodpractice to employ Tier 3 facility specific emission factors.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

2962

3

4

2371

2372

Verify bibliographic citation format in footnote

Poot-Delgado Carlos Antonio Noted

Format is in agreement with Environmental Conservation style.

2964

3

4

2377

2378

Verify bibliographic citation format in footnote

Poot-Delgado Carlos Antonio Noted

Format is in agreement with Environmental Conservation style.

4058

3

4

2379

Replace "&" with "and"Andrea Tilche

2966

3

4

2382

2383

Verify bibliographic citation format in footnote

Poot-Delgado Carlos Antonio Noted

Format is in agreement with Environmental Conservation style.

2968

3

4

2432

2433

Lack comma in bibliographic citation

Poot-Delgado Carlos Antonio Rejected

Format is in agreement with Environmental Conservation style.

4060

3

4

2442

replace "there" with "the"Andrea Tilche

2970

3

4

2443

2444

Lack comma in bibliographic citation

Poot-Delgado Carlos Antonio Rejected

Format is in agreement with Environmental Conservation style.

2972

3

4

2448

2448

Lack comma in bibliographic citation

Poot-Delgado Carlos Antonio Rejected

Format is in agreement with Environmental Conservation style.

2728

3

4

Table 4.1

The relationships of the various pargraphs inside the Source column forcoke production using by-product recovery technology, sinter production,iron production needs to be explained. (e.g. how does the USA example
relate to the default 0.52 tCO2/t coke description at the top of the Sourcecolumn for coke production using by-product recovery technology?)

Elsa Hatanaka

Accepted withmodification

The "Source" column was modificated and changes have made for the Table
4.1 to provide the proper explanation to the default EF.

8544

3

6

1

1262

For this charter, it shows how to calculate the consumption of Green house Zhiping An
gas.
But it does not consider scrubber’s DRE%. The different type scrubber
treats the waste gas that have different DRE% and produce byproduct.

Noted

The collected data include all the abatment technologies and the table 6.7
include the suitable abatmente technologies for gas type.

8242

3

6

1

1626

Rejected

7994

3

6

7

References to annual time period should be made more general to enable
Jeff Rudnik
calculations over diffferent time periods
I fully agree with the claims made in this chapter, however, GHG emissions Alma Vargas
from the electronic industry are much more dangerous than those of motor
vehicles and anthropogenic. In the electronic industry, the toxicity of its
gases is very high. In this sense, the non-existence of an effective andprecise method to measure this type of GHG emission should be a cause forconcern, and the treatment given by the chapter analyzed does not reflect
this concern.

GHG inventories are reported by countries by year rather than by other time
periods.
IPCC Guidance on GHG Inventories is intended to focus on GHG emissions,
not other types of emissions.

8272

3

6

156

160

Byproduct EF for CF4 should not be required or included if the abatement
is certified that it is designed to abate byproducts. Data set to support EFs
for CF4 reference is not cited in these sections and is not included in US
EPA Subpart I

Jeff Rudnik

Rejected

Referencing CF4 as by-product from process not as a formation ofabatement. Supplier certification included in flow diagram Figure 6.4 as
well.

8174

3

6

156

160

Add to the byproduct comment

Jeff Rudnik

Rejected

See commnet #8272

8176

3

6

168

169

Did 2006 IPCC have 3 methods or four? (Tier 1, Tier 2a, Tier 2b, and Tier Jeff Rudnik
3)

Accepted

Change made on final draft

8178

3

6

196

196

Change the word "brand" to "type"

Jeff Rudnik

Accepted

Change made on final draft

8180

3

6

210

210

Change the word "if" to "of"Jeff Rudnik

Accepted

Change made on final draft

8182

3

6

219

220

Remove "as well as on the abatement efficiency of all input gases andbyproducts" from the statement. Abatement efficiencies do not determine
which Method to select.

Jeff Rudnik

Accepted

The sentence was removed.

8184

3

6

223

223

What does inter alia mean?

Jeff Rudnik

Accepted

among other things

Accepted

Accepted

Rejected

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Unclear how Table 6.9 demonstrates a relative error > 100%. Perhaps you Jeff Rudnik
Rejectedmean relative error across types of semiconductor manufacturing and if so,please specify.
Add comment that it is expected that all gas and FC usage will be tracked to Jeff Rudnik
Rejected
the greatest extent possible.
check chemical formula
Poot-Delgado Carlos Antonio Accepted

Authors notes

8186

3

6

228

228

Out of Scope. It refers to 2006 guidelines

8188

3

6

233

235

2974

3

6

252

253

8190

3

6

322

322

The first process box asks if FC activity data is available? Please change to Jeff Rudnik
GHG as N2O and CO2 may be included. Change "Do reporting companies
measure emission at the stack level" to "Do reporting companies measure
GHG emissions at the stack level"?

Accepted

The changes addressed in final draft.

8192

3

6

350

350

Needs a back bracket within the equation

Jeff Rudnik

Accepted

Change made on final draft

8194

3

6

352

352

Change mass of gas I to kg of gas i.

Jeff Rudnik

Add Kg between parenthesis and changed kg to Kg all over the text.

8196

3

6

359

362

Accepted withmodification
Rejected

2976

3

6

377

377

Should this be m2 rather than Gm2? It appears that the emission factors are Jeff Rudnik
in emissions per m2.
check chemical formula
Poot-Delgado Carlos Antonio Accepted

8240

3

6

385

390

Strike last sentence "as if they were full" and replace with "using best
information available."

Jeff Rudnik

Rejected

The remaining gas in a container is difficult to be measured in a consistentmanner through different companies ans facilities. To ensure consistency
they should be always regarded as been 100% full.

8198

3

6

442

448

This language should be refined to account for variations due to technology Jeff Rudnik
development and ramping of new technologies. By definition, these will
have variations in their emissions that are more difficult to account for andmodel.

Accepted

A sentence was added "In the event of the introduction of new technologies
and/or significant changes to wafer throughput this assessment should be
repeated."

8278

3

6

442

448

Jeff Rudnik

Acceptedsee commnet #8198

4062

3

6

474

Recommend providing option to exclude R&D or tool commissioning
activities from 20% apportioning requirement (where possible) howeverneed to ensure those purchases are kept in the emission calculations.
Replace "used" with "use"Andrea Tilche

Accepted

Change made on final draft

8200

3

6

488

489

Remove the comment in brackets.

Jeff Rudnik

Accepted

Change made on final draft

2732

3

6

514

514

There should be a parenthesis '[' right before (1-hi) in Equation 6.6.

Elsa Hatanaka

Accepted

Change made on final draft

8202

3

6

516

516

Need a front bracket within the equation

Jeff Rudnik

Accepted

Change made on final draft

8538

3

6

523

524

Dk = overall reduction of gas k by-product emissions, fraction, calculated
per Equation 6.7 (replacing i by k indexes). I confuse that if this reduce ofgas , it includes the DER% of scrubber?

Zhiping An

Noted

Yes, Dk includes the DRE, fraction of gas used, and uptime for byproductgas created from i.

8270

3

6

525

530

Byproduct EF for CF4 should not be required or included if the abatement
is certified that it is designed to abate byproducts. Data set to support EFs
for CF4 reference is not cited in these sections and is not included in US
EPA Subpart I

Jeff Rudnik

Rejected

Referencing CF4 as by-product from process not as a formation ofabatement. Supplier certification included in flow diagramFigure 6.4 as
well.

2734

3

6

526

526

Should the ABF2, CF4 = Fraction of F2 explanation be more generalized to Elsa Hatanaka
fit under the ABi, CF4 definition ? (since there is no seperate mentioning of
ABF2, CF4 in Equation 6.6)

Accepted

Rewrote paragraph to clarify by-product emission factors from combustion(525-530 and 633-638)

8204

3

6

555

556

This variable is unclear and I am unsure how this is calculated.

Jeff Rudnik

Noted

Addressed in the final draft.

8286

3

6

555

556

In order to get information to populate the gamma variable appears torequire infomration similar to that required in Tier 2c for aip. Is there amore straightforward method to enable calculation of uncontrolled
emissions. Is this defined at the process or tool level?

Jeff Rudnik

NotedThis is clarified in the final draft. An explanation of how the gamma factor
is calculated was included.

8206

3

6

567

577

Update language to refer to time periods for which the inventory is taken
and to not be annual only. Inventories may span multiple years.

Jeff Rudnik

Rejected

GHG inventories are reported by countries by year rather than by other time
periods.

Out of Scope.
Change made on final draft

it is in the 2006 guideline original text
Change made on final draft

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

3

6

583

583

Change Table reference to Table 6.4

Jeff Rudnik

8210

3

6

599

599

Update Table references

Jeff Rudnik

Accepted

Corrected in the text. All the “≥300mm” was changed with “300mm” allover the text
Change made on final draft

8212

3

6

604

604

Accepted

Change made on final draft

8288

3

6

615

616

Change "As for the Tier 2a and 2b methods, the Tier 3b total" to "As for the Jeff Rudnik
Tier 2a and 2b methods, the Tier 2c total"
COF2 listed as input gas but not a byproduct. Is this a PFC as it qualifies
Jeff Rudnik
per current Table A-1 US EPA MRR

Rejected

The COF2 exists as byproduct but it have a very low impact and it have no
official GWP (the best extimated value is 1).

8290

3

6

620

630

COF2 listed as input gas but not a byproductRejected

8214

3

6

623

623

Add a back bracket to equation

Jeff Rudnik

Accepted

The COF2 exists as byproduct but it have a very low impact and it have no
official GWP (the best extimated value is 1).
Change made on final draft

8268

3

6

633

638

Jeff Rudnik

Rejected

4064

3

6

638

Byproduct EF for CF4 should not be required or included if the abatement
is certified that it is designed to abate byproducts. Data set to support EFs
for CF4 reference is not cited in these sections and is not included in US
EPA Subpart I
Replace "&" with "and"Andrea Tilche

Accepted

Change made on final draft

8216

3

6

647

652

Language is unclear. Please make this language easier to follow.

Jeff Rudnik

Noted

Change made on final draft

8218

3

6

685

694

Add substrate type.

Jeff Rudnik

Accepted

Change made on final draft

8266

3

6

695

700

Byproduct EF for CF4 should not be required or included if the abatement
is certified that it is designed to abate byproducts.

Jeff Rudnik

Rejected

8276

3

6

695

700

Data set to support EFs for CF4 reference is not cited in these sections and Jeff Rudnik
is not included in US EPA Subpart I

Rejected

Referencing CF4 as by-product from process not as a formation ofabatement. Supplier certification included in flow diagramFigure 6.4 as
well.
More recent data exists (SESHA April 2018)

8220

3

6

704

706

Although country specific default emission factors are less desired, if
Jeff Rudnik
utilizing country specific default emission factors the process should
include a step to accumulate industry wide data so as to ensure accurate andup to date country specific emission factors. SHould document need for amechanism to update the the specific emission factors.

Noted

Added a sentence to clarify that country-specific factors should include thefull range of processes used in the country in the relevant process type,including both changed or new and pre-existing processes.

8222

3

6

728

728

Remove the extra back parenteses

Jeff Rudnik

Accepted

Change made on final draft

8224

3

6

733

733

Change input process gases to input process gas.

Jeff Rudnik

Accepted

Change made on final draft

8226

3

6

746

746

Specify what fab type means.

Jeff Rudnik

Accepted

Corrected in the text. Change to Industry type (Semiconductor, MEMs, PV,
Display)

8228

3

6

748

748

Add examples

Jeff Rudnik

Accepted

Change made on final draft

8230

3

6

749

749

Add examples

Jeff Rudnik

Accepted

Change made on final draft

4066

3

6

764

766

The sentence is too long. Please revisit and make it shorter.

Andrea Tilche

Accepted

Change made on final draft

8232

3

6

771

771

Add language about phase in for measured emission factors from the body Jeff Rudnikof the language. For the third diamond, is there a list of what has beencharacterizaed? How would a new inventory compiler know what waspreviously characterized? For the fourth diamond, specify that greenhousegases refer to those defined in the IPCC.

Rejected

There is no formal "list" of equipment platform characterized. The authors
believe that it is not necessary to specify within figure 6.2 which greenhousegases are defined by the IPCC. The default EF tables specify the gases thatare currently known to be used for chapter 6.

4068

3

6

802

806

The equation seems not to be referred to in the text

Andrea Tilche

Accepted

Change made on final draft

8234

3

6

809

809

Jeff Rudnik

Rejected

8236

3

6

820

821

Other equations are in kg of chemical. Convert this equation from metrictons CO2e to kg of chemical.
Either remove CF from this equation or add it to all other equations

Jeff Rudnik

Rejected

8238

3

6

826

828

Either remove CF from this equation or add it to all other equations

Jeff Rudnik

Rejected

8298

3

6

864

864

For the definition of substantive changes, it includes a a decrease in tools
Jeff Rudnik
with POUs, but not an increase. Suggest modifying "decrease" to "change".

Accepted

This is preliminary estimate for purposes of assessing the magnitude of theCO2-equivalent emissions; needs to be in MTCO2e.
This is just a preliminary estimate intended to establish priority of stack
testing and is not meant for final inventory reporting.
This is just a preliminary estimate intended to establish priority of stack
testing and is not meant for final inventory reporting.
Change made on final draft

Jeff Rudnik

Accepted

Authors notes

8208

Referencing CF4 as by-product from process not as a formation ofabatement. Supplier certification included in flow diagramFigure 6.4 aswell.

Comment ID Volume

Chapter

From line To line
885

Comment

Expert

8300

3

6

882

States if expected byproduct or known used gas is not detected, use 1/2 the Jeff Rudnik
FDL. This could result in large emissions reporting due to large flow rates
typical in fab exaust systems.
Where are these tables?
Andrea Tilche

4070

3

6

945

8248

3

6

1127

1130

Check Section reference numbers to ensure they still exist or are correct

8250

3

6

1138

1138

Recommend changing word "gases" to "materials". It is confusing in section Jeff Rudnik
for liquid FCs

8252

3

6

1148

1148

Recommend change EFl to EFi in equation details

8246

3

6

1154

1154

8244

3

6

1154

1184

4072

3

6

1186

Break out Tier 2 into Tier 2a-all chemical purchased and Tier 2b - Equation Jeff Rudnik
6.25 methodology. There is not a footnote or documentation on GWP for all
liquid FC-s note in the intro section.
Should alternatives for calculation methodology be included which tracks Jeff Rudnik
usage without the complication of nameplate capacity or annual
inventories?
I do not see where the figure is decribed.
Andrea Tilche

8254

3

6

1188

1188

2978

3

6

1188

1189

8534

3

6

1198

8536

3

6

8280

3

8292

Jeff Rudnik

Jeff Rudnik

Response

Authors notes

Rejected

This is a standard stack testing method

Accepted

Added tables in FOD

Noted
Accepted
Accepted
Rejected

The method is not and should not be GWP-dependent.

Rejected

There is a Tier 1 alternative and the Tier 2 method is an inventory-based
method requiring that a reliable inventory be kept.

Accepted

Reference to Figure 6.3 corrected in SOD line 1129.

In the decision tree what examples that lead companies to decide to use the Jeff Rudnik
Accepted
Tier 1 method? The decision tree refers to the Electronics Industry as awhole?
The text of the flow diagram is not distinguishedPoot-Delgado Carlos Antonio Rejected

Text clarified in the introduction to section 6.2.1.2 and text in first diamondof decision tree (figure 6.3) will be changed to make it clear that the decision
criteria is about the existence of an HTF inventory.
Comment unclear.

1215

For the calculation of Tier 1 Method, in Table 6.2, why are there no N2O
and C - C4F8 influence factor values in the semiconductor?

Zhiping An

Accepted

Factors updated with new data

1216

1224

Rejected

Post-process CF4 emissions from NF3 remote cleaning are related to thecleaning of carbon-containing films. Such CF4 emissions have beenmeasured and quantified at the exhaust of process chambers in numerous
instances and constitute a distinct source of CF4 emission than the formationof CF4 within combustion-based abatement systems. CF4 production within
abatement systems are accounted for separately in new equation 6.6B
(which will be renumbered as equation 6.7 in the final draft)).

6

1217

1217

In Table 6.4 of Tier 2 B Method, the NF3 Remote Process IPCC believes Zhiping An
that a large number of BY - Product: CF4 will be produced.
However, in the actual manufacturing process, we have not found such asituation.
Maybe this situation will be happen in after Burn type scrubber treat.
Because Burn type scrubber use hydrocarbon fuel, but scrubber inlet (maintools exhaust) no this situation. If change scrubber type from burn to plasma
also no this byproduct.
Should the data table reference all sources or geographies associated with Jeff Rudnik
the underlying data

Noted

Addressed in FOD

3

6

1217

1217

COF2 listed as input gas but not a byproduct

Noted

2202

3

6

1217

1218

Accepted

2204

3

6

1217

1218

Table 6.3 : The source of "C2H5F, C3F8remote, COF2, F2, N2O TDF, N2O Hiroshi Itoother " not listed in Table I-11 ＆ Table I-12 of CFR part 98 Subpart I , isunknown.
Table 6.3 :The values calculated from Table I - 11 and Table I - 12 are
Hiroshi Ito
different from the values of "1 - Ui", "BCF 4" and "BC 2 F 6" of "CH 3 F"

Decision was made not to include COF2 as a byproduct (see earlier
comment).
Placeholder; data will be recalcuated;sources will be updated.

Accepted

Placeholder; data will be recalcuated;sources will be updated.

2206

3

6

1217

1218

Accepted

Placeholder; data will be recalcuated;sources will be updated.

2208

3

6

1217

1218

Accepted

Placeholder; data will be recalcuated;sources will be updated.

2210

3

6

1217

1218

Accepted

Placeholder; data will be recalcuated;sources will be updated.

2212

3

6

1217

1218

Table 6.3 :The value calculated from Table I-11 and Table I-12 are different Hiroshi Itofrom the values of "1-Ui" of "NF 3 Remote"Table 6.3 :The value calculated from Table I-11 and Table I-12 is different Hiroshi Itofrom the value of "BCH 3 F" of "NF 3"
Table 6.3 :The value calculated from Table I-11 and Table I-12 is different Hiroshi Itofrom the value of "BCH 3 F" of "SF 6"
Table 6.3 :The column of "C2HF5" calculated from Table I-11 and Table I- Hiroshi Ito
12 is missing from Table 6.3.

Accepted

Placeholder; data will be recalcuated;sources will be updated.

2214

3

6

1217

1218

Table 6.3 :Since there are many unknown points in the numerical value ofthe table, it is presumed that mutual confirmation of leadauthers has notbeen completed. The values agreed upon by the leadauthers should bestated.

Accepted

Placeholder; data will be recalcuated;sources will be updated.

Jeff Rudnik

Hiroshi Ito

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

3410

3

6

1217

1226

To reduce the uncertainty of estimation, the emission factors need to move Eunae Seo
the decimal point of the left by changing the unit such as
0.00003kgCH2F2/kgSF6 -> 0.03kgkgCH2F2/tonSF6

Rejected

Duplicate

8282

3

6

1221

1221

Should the data table reference all sources or geographies associated withthe underlying data

Jeff Rudnik

Noted

Addressed in FOD

8294

3

6

1221

1221

COF2 listed as input gas but not a byproductJeff Rudnik

Noted

8284

3

6

1222

1222

Jeff Rudnik

Noted

2216

3

6

1222

1223

Hiroshi Ito

Accepted

See answer to same question regrding Table6.3

2218

3

6

1223

1224

Hiroshi Ito

Accepted

See answer to same question regrding Table6.3

8296

3

6

1223

1233

Should the data table reference all sources or geographies associated withthe underlying data
Table 6.5 :The source of "C2H5F, N2O TDF, N2O other " not listed inTable I-3 of CFR part 98 Subpart I , is unknown.
Table 6.6 :The source of "COF2, F2, N2O TDF, N2O other " not listed inTable I-4 of CFR part 98 Subpart I , is unknown.
COF2 listed as input gas but not a byproduct

Decision was made not to include COF2 as a byproduct (see earlier
comment).
Addressed in FOD

Jeff Rudnik

Noted

2048

3

6

1233

1236

Cartridge (Media consumed) row in table 6.7
Tsutomu Tsukada
x at C4F8, CHF3, NF3 and SF6 is incorrect. The media in the cartridge isalkali substance such as Ca (OH)2, which doesn't react with these gases.
x should be put at C3F6O (hexafluoroacetone) and COF2. These gases
react with the alkali substance.

Rejected

Decision was made not to include COF2 as a byproduct (see earlier
comment).
Some cartridges contain adsorption media that are designed to abate PFCs

2050

3

6

1233

1236

x should be marked to all gases in the table6.7 except N2O. It is common Tsutomu Tsukada
knowledge that CF4 has the strongest C-F bond among the listed gases, andbecause that the decomposition performance depends on the C-F bondstrength, all the listed PFC gases can be abated with same or higher
efficiency under the condition that CF4 can be abated.
Normally N2O is used with SiH4 for thin film deposition process and SiO2
is formed as a byproduct which damages the catalyst. This technology is
not suitable for N2O abatement.

Rejected

X's in Table 6.7 are based on experimental evidence regarding the suitabilityof certain abatement technologies to abate certain GHGs. Table 6.7 will be
updated for the final draft based on data collected.

2052

3

6

1233

1236

The temperature classification of Hot Wet in Table 6.7 is too rough. Since Tsutomu Tsukada
the decomposition performance of Hot Wet technology has clear
temperature dependence, I propose the following temperature classificationand each applicable gas list.
< 800 ﾟC COF2, C3F6O< 950 ﾟC COF2, C3F6O, C2H5F, C4F6O, C4F8O, NF3< 1200 ﾟC COF2, C3F6O, C2H5F, C4F6O, C4F8O, NF3, C2F6, C4F6,
C4F8, C3F8, CHF3, CH2F2, C4F6, C5F8, CH3F, C2F4, N2O< 1350 ﾟC COF2, C3F6O, C2H5F, C4F6O, C4F8O, NF3, C2F6, C4F6,
C4F8, C3F8, CHF3, CH2F2, C4F6, C5F8, CH3F, C2F4, N2O, SF6> 1350 ﾟC COF2, C3F6O, C2H5F, C4F6O, C4F8O, NF3, C2F6, C4F6,
C4F8, C3F8, CHF3, CH2F2, C4F6, C5F8, CH3F, C2F4, N2O, SF6, CF4

Noted

Table 6.7 updated for the final draft based on data collected.

2570

3

6

1233

1236

Rejected

Question is incoherent. Some cartridges are indeed capable of abating C4F8.
Table 6.7 will be updated for the final draft based on data collected.

2572

3

6

1233

1236

Rejected

Question is incoherent. Some cartridges are indeed capable of abating C4F8.
Table 6.7 updated for the final draft based on data collected.

8260

3

6

1237

1237

The C4F8 decomposition by Cartrige(Media consumed) in Table.6.7 is X Nobuhiro Natori(= Stuitable to use defalut DRE). However, I think that it should be “Notapplied” (blank).
At least, in our acquisition data, C4F8's DRE by Cartrige(Media consumed)
is > 99%.
The CF4 decomposition by Catalyst (Media not consumed) in Table.6.7 is Nobuhiro Natori
X (= Stuitable to use defalut DRE). However, I think that it should be “Notapplied” (blank).
At least, in our acquisition data, CF4's DRE by Catalyst is > 99%.
Note 5 does not appear in the figure
Jeff Rudnik

Noted

Clarified in FOD

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

8542

3

6

1237

1262

According to the Figure 6.4 show, the table 6.8 is showed the DRE%, after Zhiping An
install the scrubber. But as stated earlier, many gases will be generated byproduct. Did you consider the emission of by-products when defining DRE?
For example, C4F8 in tier 2b method calculates C4F8 0.13, b CF4: 0.11,
and table 6.8 calculates C4F8 60 %. Does the generated CF4 count?
If the calculation is included, then CF4: DRE 75 % is not reasonable.

Rejected

Confusion between by-product from process vs by-product from POU.

2054

3

6

1241

1242

Table number is wrong. Table 6.6A should be table 6.7.

Noted

Table numbers updated as part of the final draft.

4074

3

6

1242

Replace "table" with "Table"

Andrea Tilche

Noted

FOD updated

8258

3

6

1243

1245

Question on if we need to change this to be more general

Jeff Rudnik

Noted

Addressed in FOD

8256

3

6

1246

1248

Noted

Addressed in FOD

8262

3

6

1251

1251

Recommendation to change from "all parameters" to "all parameters which Jeff Rudnik
affect DRE". There are operating parameters that are required to ensure no
impact to fab tool that are not related to DRE.
Note 5 does not appear in the figure
Jeff Rudnik

Noted

Repeat of comment 8260

8264

3

6

1253

1257

Rejected

8274

3

6

1253

1257

Byproduct EF for CF4 should not be required or included if the abatement Jeff Rudnik
is certified that it is designed to abate byproducts.
Data set to support EFs for CF4 reference is not cited in these sections and Jeff Rudnik
is not included in US EPA Subpart I

ABNF3,CF4 and ABF2,CF4 are emission factors reflecting the poential
formation of CF4 within abatment systems.
Rejected based on new data.

8302

3

6

1261

1261

2056

3

6

1261

1262

2058

3

6

1261

2060

3

6

1261

Table 6.8 states it lists USEPA GHG default factors, but list N2O PE/WC
DREs at 60%, where Subpart I does not have a value here (only for CC).
Also, would it be possible to use manufactured performance specs whereavailable?
All the gases in table 6.7 are not included in table 6.8. The gases in Table
6.7 and 6.8 must be consistent in the final version of the guideline.

Tsutomu Tsukada

Rejected

Jeff Rudnik

Accepted withmodification

Table 6.8 updated in the final draft based on new data. The decision tree of
Figure 6.4 allows for the use of site-specific measured DREs (but not
performance specifications from the abatement OEM).

Tsutomu Tsukada

Noted

Tables 6.7 and 6.8 updated for the final draft based on data collected.

1262

The DRE values of Tier 2a and 2b on the Table6.8 are against to the theory Tsutomu Tsukada
of decomposition of PFC gases on the catalyst, hot-wet, combustion andplasm technology. When you use these abatement technologies maintained
and operated properly under tool suppliers' recommended condition, thePFC gas with lower C-F bond strength shows higher abatement
efficiency. The example of abatement efficiency is as follows,
Highest NF3 > C4F8, CH2F2, CH3F, C4F6 > C5F8 > C3F8, CHF3 >C2F6, N2O > SF6 > CF4 Lowest
If the data of the DRE efficiency are in different order from shown above,that indicates something is wrong with the data. That data possibly contains
data from fabs or tools with improper operation and/or maintenancecondition. If the order of DRE value of Table 6.8 is different from thetheory somehow, clear explanations are required.
The highest DRE is NF3 and the lowest DRE is CF4, and the DRE of theother gas should be between the NF3 and CF4 DRE.

Noted

Tables 6.7 and 6.8 updated for the final draft based on data collected.

1262

If abatement tools are set appropriately and the tool conditions are
Tsutomu Tsukada
maintained properly, DREs are independent from the condition of theprocess tools or wafer sizes. Therefore, the values of the DRE should beequal in all Tiers. If IPCC guideline doesn't assume that the abatement
tools are set in proper operation condition which guarantee certified DREs,
the data on the table 6.8 are meaningless.

Rejected

The statement is incorrect. DREs are not independent from the condition of
the process tools or wafer sizes. A final decision to have different DRE
values for different tiers will be made based on data. The IPCC guidelines
clearly require that abatement tools are certified to abate exhaust gases in theworst case scenario if the default DREs are used.

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

Authors notes

8540

3

6

1261

1262

I don't quite understand the basis of DRE calculation in Table 6.8.
Zhiping An
What are the numerator and denominator of this processing performance? Is
the ratio of main tools inlet and exhaust? Or the ratio of Scrubber inlet toexhaust? Or is it the ratio of main tools inlet to Scrubber exhaust?

Rejected

The DRE calculation conforms to accepted standards.

2220

3

6

1261

1262

Table 6.8: The order of sizes of the listed DREs is not consistent with the Hiroshi Itoease of decomposition of each PFC gas. These values may have beendeveloped based on the non-reproducible data measured by the abatement
device under insufficient capacity or insufficient maintenance. It isnecessary to reconsider the reliability of the numerical value. (Confirmationof reliability is also necessary for the unknown value commented above.)

Noted

Tables 6.7 and 6.8 updated for the final draft based on data collected.

7996

3

6

6.2.1.2

Rejected

The estimation of leakage in baed on a standard inventory method which
tracks the amount of HTF that is replenished during the reporting period.

2730

3

6

general

Accepted

This text has been added to the introduction.

4076

3

7

375

The document establishes that the leakage and evaporation of liquid
Alma Vargas
fluorinated compounds during their use constitutes an important source ofemissions of fluorinated gases; which is not debatable. However, in theestimation that takes into account the purchase / sale ratio, it does not value
the leakage, which, when going to the atmosphere, increases the FEI that
already exists, this could have an overestimation of the total volume of FEI
in a given territory. .
Elsa Hatanaka
It would be useful to mention in Ch6 that there is guidance in Ch8 on
waterproofing of electronic circuits.
Replace "table" with "Table"
Andrea Tilche

Accepted

4078

3

7

382

Replace "box" with "Box"Andrea Tilche

Accepted

4080

3

7

399

Replace "box" with "Box"Andrea Tilche

Accepted

4082

3

7

402

Replace "box" with "Box"Andrea Tilche

Accepted

4084

3

7

408

I do not understand the use of "for other"

Andrea Tilche

Accepted

2982

3

7

448

449

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Noted

Verified

2984

3

7

457

457

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Noted

Verified

2986

3

7

461

461

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Noted

Verified

2988

3

7

468

468

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Noted

Verified

2740

3

7

505

506

Emission factors in the low end of the ranges should especially apply for
Elsa Hatanaka
those countries that have a mondatory or voluntary system...' should be
modified to 'Emission factors in the low end of the ranges would only apply
to those countries that have a mondatory or voluntary system...'Accepted withmodification

2742

3

7

517

517

'All of these can reduce emission rates' is an unnecesary statement, since
reductions will come naturally with mitigation.

Elsa Hatanaka

Accepted

2980

3

7

531

532

Verify bibliographic citation format

Poot-Delgado Carlos Antonio Accepted

8304

3

7

541

542

Two of Table 7.9 column headers are difficult to understand - the meaning Y. Anny Huangof “charge” and “lifetime” are not clear. Recommend adding additional
text to Table 7.9 in order to clarify the table headings. A representation of
the Table 7.9 column headers is shown in the supporting document, withthe additional recommended text underlined and highlighted. Please see
the supporting document uploaded into the system as a separate file. [comments from Glenn Gallagher of the California Air Resources Board]

Accepted

The sentence was modified in order to be more clear: "For those countries
that have a mandatory or voluntary system in place to limit emissions during
equipment service, use, and disposal, emission factors in the low end of theranges would typically apply."

Comment ID Volume

Chapter

From line To line

Comment

ExpertResponse

2738

3

7

Box 7.2B

To make the diagram more easily understandable, e.g. 'New equipment
Elsa Hatanaka
charge (Bank) Year 0' should be modified to 'New equipment charge (Bank)
at Year 0' and 'Remaining Bank Year 0' should be modified to ' Remaining
Bank from Year 0'. Also, the 'Lifetime emissions' on Y0 should be modified
to 'Emissions in the first year of the lifetime,' since lifetime would imply thewhole lifetime. It would also be useful to have indicated somewhere in the
diagram that dotted lines are Emissions and solid lines are Charges.

Accepted

2736

3

7

Table 7.3B

The footnotes A and B in the Table title are reversed.

Accepted

8346

3

7

1832

3

8

18

1834

3

8

75

1836

3

8

1838

3

1840

3

2746

Elsa Hatanaka

Authors notes

I am concerned by the reliance in this chapter on such an old IPCC/TEAP Pauline Midgleyreference (2005) for the use pattern of alternatives; why not use the most up
to date UNEP/TEAP report (2016)?

Accepted withmodification

We have used UNEP/TEAP 2016 to update information within the
scop of the mandate. Other sections are left unrevised.

18

Typo: Portugal

Urs Berger

Accepted

Change made on final draft

75

Typo: PFCs with a small plural-s

Urs Berger

Accepted

Change made on final draft

447

447

I am not aware that fluorine-based treatment was/is used to enhancehydrophilicity of surfaces

Urs Berger

Accepted"or hydrophilicity" was eliminated.

8

471

471

Typo: emisson factors

Urs Berger

Accepted

Verified

8

481

481

Typo: emisson factors

Urs Berger

Accepted

Verified

3

8

Table 8.11

Accepted

Change made on final draft

1830

3

8

Accepted

Acronyms harmonised + included suitable text to explain which terminology
is followed.

2744

3

8

8.5: For clarity of guidance, it is necessary to remove the whole of 8.5 to the Elsa Hatanaka
Appendix if default EFs cannot be provided in the next draft.

Rejected

See answer to comment ID# 7584. The format for including this new source
category to Chapter 8 was discussed and agreed to with the IPCC Task Force
Bureau.

7862

3

Annex 4

18

26

There is a definition for LVAE as an anode effect (and emission of PFC
Christine Dubois
gases) in cases where the cell voltage doesn’t exceed the voltage threshold.
As the emission of PFC is indicated, it can be add that there is no protocoleof measurement for LVAE PFC emission at this moment.

Rejected

Information on the lack of a protocol for measurement has already been
included in both Aluminium and Rare Earth chapters. This glossary is only
relevant for defining HVAE and LVAE emissions.

7534

3

Annex 426

26

Rejected

1842

3

Appendix 1

61

61

Add at the end of the sentence : «The LVEA is a concept relatively new and Nadia Morais
no measurement protocol are actually available to improve consistency andalignment across the industry».
Typo: 2,0000 should probably read 20,000
Urs Berger

Accepted

Information on the lack of a protocol for measurement has already been
included in both Aluminium and Rare Earth chapters. This glossary is only
relevant for defining HVAE and LVAE emissions.
Change made on final draft

1844

3

Appendix 1

118

118

Typo: application techniques

Urs Berger

Accepted

Change made on final draft

1846

3

Appendix 1

220

220

Typo: thatUrs Berger

Accepted

Change made on final draft

1848

3

Appendix 1

495

495

Typo: orUrs Berger

Accepted

Change made on final draft

1850

3

Appendix 1

691

691

Typo: process types

Urs Berger

Accepted

Change made on final draft

1852

3

Appendix 1

802

802

Unlogical numbering of header

Urs Berger

Accepted

Change made on final draft

1854

3

Appendix 1

806

806

Typo: emisson estimates

Urs Berger

Accepted

Change made on final draft

The unit in the heading should be 'Emissions (g) /Circuit Board' instead of Elsa Hatanaka
Emissions/Circuit Board (g).
Please be clear and consistent in using accronyms for fluorinated chemicals. Urs Berger
It is unclear what is meant with PFCs. Perfluorocarbons (i.e. fully
fluorinated alkanes) or per- and polyfluorinated chemicals, which areabbreviated as PFASs in Appendix 1. Also, FC is defined twice, once as
fluorochemicals (line 357), once as fluorinated compounds (line 455). What
are FCs in relation to PFCs or PFASs? I suggest adhering to the terminology
by Buck et al. (2011) Perfluoroalkyl and Polyfluoroalkyl Substances in theEnvironment: Terminology, Classification, and Origins, Integr. Environ.
Assess. Manag. 7, 513-541