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

Comment

ExpertResponse

748

3

3

It can be evaluated that the point covering a wide range ofHideshi Iki

Noted

1516

3

3

1518

3

3

….and equipment leaks. In addition, users of fluorinated GHGs Archie McCulloch
may return empty containers (e.g., cylinders) to the production
facility for reuse; prior to reuse, the residual fluorinated GHGs
may be removed from the container and, unless they arerecovered and recycled or destroyed, these are also an emission
source. In many cases, these "heels" are contaminated and sent
for immediate destruction. Text and calculation should reflect
this.
Archie McCulloch….other fluorinated greenhouse gases. The default emission
factors in Table 3.29 are expressed in terms of kg CO2eemitted/kg CO2e produced (that is, both emissions andproduction are GWP-weighted). [We are considering
presenting default emission factors in terms of kg CO2eemitted/kg fluorinated compound produced, which would
better account for the fact that high-GWP emissions may result
from the production of low-GWP products.] The suggestedchange makes no sense. 1. This is a factor, and all that thechange would do is alter the value of the factor. 2. Process
vents and equipment leaks are more likely to contain the
product material than anything else, so the basic premise of the
proposed change is incorrect. 3. The default factor isunrealistically high; 0.1 kgCO2eq/kgCO2eq of HFC is 10%
which is a factor of over 100 higher than the measured factor
for ODS (which have equivalent physical & chemical
properties). The default factor in the 2006 Guidelines was
0.5%, so why the change?

Authors notes

Accepted

We agree with the commenter and have incorporated the revised text
as suggested by adding the text "in many cases, these 'heels' arecontaminated and sent for immediate destruction."

Rejected

Recent publicly available data show that the emissions are higher thanthe previously cited default factor for fluorochemical processes. In
the U.S., production and transformation facilities report their F GHG
emissions from fluorinated gas production and their fluorinated GHG
products to the U.S. EPA under the Greenhouse Gas Reporting
Program (GHGRP). Analysis of these emissions and production data
show that the actual, controlled emissions from fluorochemical
processes are in the range of 0.003 to 0.008, and these emission
factors align with the 0.005 factor previously cited. [Schaffner, et. al.,2018] Tier 1 default emission factors, however, should not reflect theapplication of abatement. Further analysis to estimate emissions on a
pre-abatement basis show that the emissions from fluorochemical
processes are higher than the 0.005 factor previously cited. We
believe the 0.005 factor is inline with actual emissions and is not
representative of pre-abatement emissions from fluorochemical
processes. While the commenter notes that the accepted convention
is that the type of fluorinated GHG emitted is generally expected to be
similar to the product produced, the data from the GHGRP show thatfor some processes the type of fluorinated GHG emitted is from a
byproduct reaction that produces a fluorinated GHG byproduct that is
not similar to the intended product. Process vents and equipment
leaks do indeed emit product materials, as the commenter cites, but
reactants and byproduct compounds may also be present in theseprocess streams. There are processes in the GHGRP data set that
manufacture low GWP products, however, the byproduct reactions
produce high GWP compounds that are emitted. For example, HFO
products will have emissions of Saturated HFCs from the production
process.

Comment ID Volume Chapter From line To line

Comment

Expert1518 (c'd)

Archie McCulloch

1518 (c'd)

Archie McCulloch

1348

3

3

1

1693

Storage and Transport of chemical products: All the different David Kuntze
products in the chemical industry (Refinerys, ammonia, nitricacid, …) are transported and stored. During these processes the
products emit. Where shall these emissions be reported. I think
the easiest way is to add these emissions on the emissions forthe different source categorys. Based on
AR_produced_amounts x EF_storage_handling =EM_Storage_Handling. The EF_Storage_handling can be a
Default-EF for total chemical industry as T1 method. And in
future product specific EFs can be developed. The otherpossibility is to add storage and handling at 2B10 comparable
to the NFR category 2B10b.

Response

Authors notes
The recently developed emission factors indicate that emissions
following control for fluorochemical processes in the GHGRP data set
range from 0.003 to 0.008. The commenter indicates that the EEA
includes an emission factor of 0.06 percent (or 0.0006), 0.07 percent(or 0.0007), and 0.12 per cent (or 0.0012) for 2016 through 2014,
respectively, on a controlled basis for processes that use ODS as
feedstock to manufacture other fluorinated products, and thisemission factor agrees readily well with the GHGRP data set. The
recently developed emission factors from the GHGRP data set
indicate that emissions on a pre-abatement basis from fluorochemical
processes range from 0.02 to 0.05. While the recently developed
emission factors are higher than the previous accepted default
emission factor (0.005) in section 3.10.2 of the 2006 IPCC
Guidelines, these newer data demonstrate that the emissions arehigher than previously understood. The 2006 Guidelines default
emission factor of 0.005 is likely underestimating the emissions fromfluorochemical processes and should be revised to reflect the newunderstanding. [Looks like the commenter is referring to an EF from
ODS feedstock use in other manufacturing processes, and this value isa value that accounts for treatment/control. See p.7 of 2016
Executive Summary. What is the measured factor for ODS? “A
number of ODS serve as feedstock for the manufacture of otherproducts such as refrigerants, foam blowing agents, polymers,
pharmaceuticals and agricultural chemicals.” “In 2016, the emission
rate from feedstock uses amounted to 0.06 %. The fact that the 2016average emission rate is similar to 2015 and lower than the emission
rate for earlier years appears to point towards improvements inemission control by industry.”]
U.S. EPA Greenhouse Gas Reporting Program. For reporting years
2010 through 2016. Accessed May 2018.
https://www.epa.gov/ghgreporting

Noted

Schaffner, K.S., D.O. Schaeffer, J.B. Coburn, B.T. Mader, and G.M.
Watson. Draft Development of Default Emission Factors for
Fluorochemical Production Using Data Reported through the U.S.
EPA Greenhouse Gas Reporting Program. June 2018.
No action can be taken because the comment is out of scope of the2019 Refinement.
However, the authors note that emissions from venting residual FGHG products from storage cylinders are covered in the Refinement
to Chapter 3.10.2, Emissions from production of fluorinatedcompounds (other than HFC-23 emissions from HCFC-22
production).

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

8678

3

3

1

Ole-Kenneth Nielsen
The use of flaring in the chemical industry is not describedvery well. It would be very relevant to describe the types ofchemical industry where flaring is most frequently occurringand provide guidance on how to estimate and where to reportemissions. Noting that the flaring in the energy sector currently
is for oil and natural gas production/treatment and hence does
not necessarily covers the possible flaring associated with all
types of chemical industry.

Noted

No action can be taken because the comment is out of scope of the2019 Refinement.

4510

3

3

100

HNO3, subscript

Kewei Yu

Accepted

4518

3

3

1001

good practice in italic

Kewei Yu

Accepted

856

3

3

1001

1001

946

3

3

1003

1003

4274

3

3

1004

1004

4520

3

3

1006

948

3

3

1006

1006

950

3

3

1009

1009

952

3

3

1011

1011

206

3

3

1012

1013

750

3

3

1012

1017

1693

ExpertVirginia Sena
I think it is better to delete the reference to Table 3.29 in thisline, since it is adequately introuced below in the text (in lines
1012 to 1013)
as Box 3.18 is referred to in line 1129, and also referred to in Robert Lanza
Line 1003, consider moving the text box to the vicinity of line
1129, or in the vicinity of line 1003, where the text box is firstreferred to.
I suggest that the authors add "and methanol" after "a fuelNaofumi Kosaka
cell". If my understanding is correct, Toyota's Mirai and
Honda's Clarity Fuel Cell do not use methanol, so these fuelcell vehicles do not emit CO2 from tailpipes. I assume that line
1004 intends to the reforming of methanol discussed in table3.29.
better use %Kewei Yu

Accepted

AcceptedBox moved to (former) line 1019.

Accepted

Text rewritten to clarify that the issue is relevant only if the fuel cellconsumes fuels containing carbon.

Accepted"The most common [hydrogen production] methods at present Robert Lanza…""electrolysis of water."Robert Lanza

Accepted

Robert Lanza"using fossil input" -- clarify whether this is referring to"feedstock" (raw material) to the process and/or referring to"fuel" (that provides heat) to the process. Clarify throughout
this section where the text is discussing "fuel" and where thetext is discussing "feedstock." In Ammona Production,
emissions from the "feedstock" (i.e., the raw material to theprocess) and emissions from the "fuel" (i.e., that provides heatto the process) are both reported under IPPU.
Koichi Kojima
In table 3.29 many comment in sector colum like "No
emission". You should explain why you use this word, because
I guess you want to explain Hydrgen sector is good fortechnology like "Water electrolysis". I hope you to show what
sector you select.

Accepted

Terminology made consistent throughout chapter, and definitions
provided in box.

Accepted

Explanations have been provided in footnotes to the table.

Accepted

Explanation have been provided in footnotes to the table.

Among Table 3.29, the emission of water electrolysis seems to Hideshi Iki
depend on the power supply configuration. The meaning
differs from “No emissions” such as Photo catalytic splitting. It
would be better to mention about that or to be allocated to theEnergy sector.

Accepted

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

752

3

3

1012

1017

On hydrogen carriers such as organic hydride, CO2 emissions Hideshi Iki
should be taken into account in total from production of carrier
to generation of hydrogen. In addition, if CO2 is emitted as aresult of using hydrogen carriers, it is reasonable to beallocated to the Energy Sector or users. It should be better tomention that in some way.

ExpertAccepted withmodification

The authors have made some additional comments to clarify thissection: 1) Releasing hydrogen from cyclohexane etc. generates noprocess emissions, only emissions from fuel combustion. I.e.
emissions should be allocated to Energy (stationary combustion).
However, parts of the text have been re-written, as these gas stations
might produce hydrogen as their main product. 2) For the reformingof methanol, the method is provided already, but Table 3.29 has also
been revised to clarify.

2436

3

3

1016

1018

Hideaki Tazawa
Organic hydride shall be added to Table 3.29 (Current
Hydrogen Production Methods).
Sample of description is as follows;-----------------------------------------------------------------------------------------------------------------------------------------------Category| Technology|Feedstock|Status of Development |Sector-----------------------------------------------------------------------------------------------------------------------------------------------Main Product hydrogen| Dehydrogenation| Organic
Hydride(Note3)| Minor and increasing | Noemissions(Note4)------------------------------------------------------------------------------------------------------------------------------------------------

Accepted withmodification

The authors have made some additional comments to clarify thissection: 1) Releasing hydrogen from cyclohexane etc. generates noprocess emissions, only emissions from fuel combustion. I.e.
emissions should be allocated to Energy (stationary combustion).
However, parts of the text have been re-written, as these gas stations
might produce hydrogen as their main product. 2) For the reformingof methanol, the method is provided already, but Table 3.29 has also
been revised to clarify.

Rejected

The authors consider that the extensive guidance provided istransparent.

Following 2 sentences shall be added as footnotes of Table
3.29.
3 Organic Hydride is mainly used for hydrogen carrier andstorage with a combination of hydrogenation anddehydrogenation.
4 If thermal sources are required in hydrogenation or
dehydrogenation process, the emissions are allocated to theenergy sector.
Summary of current hydrogen production methods and theMiriam Lev-On
allocation of emissions to the sector are shown in Table 3.29.
Recommend inclusion of an additional column in Table 3.29 tostate specifically where these emissions should be reported inorder to avoid double counting.
Comments on Table 3.29
Robert Lanza

10068

3

3

1016

1019

954

3

3

1017

1018

956

3

3

1017

1018

Comments on Table 3.29 -- Under the "Category" column -Robert Lanza"Main Product Hydrogen" -- see comments on lines 999-1001,
clarify the definition of "main product."

Accepted

958

3

3

1017

1018

Accepted

960

3

3

1017

1018

Comments on Table 3.29 -- Under the "Technology" column -- Robert Lanza
replace "Fuel Reforming" with "Steam Reforming"
Comments on Table 3.29 -- Under the "Feedstock" column -- Robert Lanza
does Ammonia" in this column refer to the raw material(feedstock) to the reforming process, or does "Ammonia" referto the Ammonia Production process that produces hydrogen as
an intermediate? Ammonia is also listed under "byproduct orintermediate product." Consider clarifying this difference in afootnote to the table.

Noted

Rejected

The authors consider that the extensive guidance provided istransparent.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

962

3

3

1017

1018

Comments on Table 3.29 -- Under the "Sector" column -Robert Lanzaclarify (in a footnote) that for a waste process that involves
both biogenic and non-biogenic raw material (feedstock) thatfor the same process biogenic emissions are reported to the
IPPU Memo and non-biogenic emissions are reported to IPPU

ExpertAccepted

A footnote has been added.

964

3

3

1017

1018

Accepted withmodification

The explanatory note has been rewritten to be clearer, and a newcolumn has been added to the table, to explain the allocation
principle.

966

3

3

1017

1018

Accepted

Explanations have been provided in footnotes to the table.

968

3

3

1017

1018

Accepted withmodification

970

3

3

1017

1018

Comments on Table 3.29 -- Under the "Sector" column -Robert Lanza
include an explanation in Table 3.29 of why the Ammonia
refroming process (row 4 of Table 3.29) is to be reported under
Energy (stationary combustion) and not under IPPU.
Robert Lanza
Comments on Table 3.29 -- Under the "Sector" column -clarify under water electrolysis that there are "no IPPU
emissions" from the water electrolysis process (emssions
related to electricity production for the process would bereported under Energy.)
Robert Lanza
Comments on Table 3.29 -- Under the "Sector" column -clarify under fermentation whether the "insignificant"emissions refer to CO2, CH4, or both; emissions of CH4 may
not be "insignificant" for large-scale processes.
Comments on Table 3.29 -- Under the "Sector" column -Robert Lanzaclarify under photo voltaic that there are "no IPPU emissions"from the photo voltaic process (emssions related to electricity
production for the process would be reported under Energy.)

The supporting text for biological methods has been rewritten toreflect that the methane is part of the product and produced in ananaerobic atmosphere, and hence none of this methane will be emitted
in the hydrogen production sector.
Explanations have been provided in footnotes to the table.

972

3

3

1017

1018

Rejected

The authors consider that there is no need for a such distinction, asintermediate product and by-product emissions are treated the same
way.

974

3

3

1017

1018

Accepted withmodification

976

3

3

1017

1018

Responding to three comments in one: 1) Accepted. Refineries is nota technology. Rewritten. 2) For hydrogen production in refineries, theexisting methodology in Vol. 2 Energy (Ch. 4.2) may be used, and it
will be improved in the 2019 Refinement. Clarifying box will be
provided in the Energy chapter. 3) Box 3.18 has been moved to(former) line 1019.
The authors consider that the extensive guidance provided istransparent.

978

3

3

1017

1018

Comments on Table 3.29 -- Under the "Category" column -Robert Lanzaconsider including separate subheadings for "intermediate"
processes and "byproduct" processes in Table 3.29 andidentiying which processes listed in the table are"intermediatel" processes and which processes listed in thetable are "byproduct" processes.
Comments on Table 3.29 -- Under the "Technology" column -- Robert Lanza"refineries" is not a technology. Text box 3.18 indicates thatemissions from hydrogen production in the refinery sector is tobe reported under the refining subcategory of the Energy
sector. Refer to the text box in Table 3.29, consider moving thetext box forward to be in the vicinity of the table.
Comments on Table 3.29 -- Under the "Technology" column -- Robert Lanzaclarify whether Ammonia Production" (listed under"Byproduct or Intermediate") is a different process than"Ammonia" listed above under "Steam Reforming" and "Main
Product Hydrogen"
Comments on Table 3.29 -- Under the "Technology" column -- Robert Lanza
Text box 3.18 indicates that emissions from hydrogenproduction as an intermediate product of ammonia production
are to be reported under the Ammonia Production subcategoryof the IPPU sector. Refer to the text box in Table 3.29,
consider moving the text box forward to be in the vicinity ofthe table.

Accepted

Rejected

Accepted withmodification

Addressing two comments in one: 1) Accepted. Reference to the text
box has been added; 2) the text box has been moved to (former) line
1019.

Comment ID Volume Chapter From line To line

Comment

980

3

3

1017

1018

Accepted

982

3

3

1017

1018

Comments on Table 3.29 -- Under the "Sector" column -Robert Lanzaemissions from methanol and ethylene production processes
are to be reported under the "Petrochemical and Carbon Black"subcategory of the IPPU Sector.
Comments on Table 3.29 -- Under the "Sector" column -Robert Lanzaemissions from steel production processes are to be reported
under the "Iron and Steel and Metallurgical Coke" subcategoryof the IPPU Sector.

Expert

984

3

3

1017

1018

Accepted

986

3

3

1017

1018

4522

3

3

1030

Comments on Table 3.29 -- Under the "Technology" column -- Robert Lanzaclarify what type of "soda" is being referred to in "sodaproduction."
Comments on Table 3.29 -- Under the Table 3.29 footnote 1, Robert Lanza
note that In Ammona Production, emissions from the"feedstock" (i.e., the raw material to the process) and emissions
from the "fuel" (i.e., that provides heat to the process) are bothreported under IPPU, and not under tje stationary combustion
subcategory of the Energy Sector.
production in italic?
Kewei Yu

988

3

3

1031

1031

Accepted

A clarification has been added.

5410

3

3

1033

1042

"Therefore, the emissions estimates are independent of how the Robert Lanzahydrogen is being used." Consider noting here that the sector
and subcategory the hydrogen is used on does affect where theemissions are to be reported.
This category includes only CO2 emissions. However, if
Takashi Morimoto
natural gas or other fossil gas is used as a raw material, CH4
could also be emitted. It would be necessary to consider adding
CH4 emissions to this category if CH4 emissions fromhydrogen production is not negligible.

Noted

990

3

3

1038

1040

The authors note that there may be minor methane emissions, but theavailable literature references all indicate that methane emissions are
extremely low and the dataset is also very limited. Therefore, at thistime it is not possible to derive methods and EFs for methane
emission estimates, which are regarded as sufficiently low to beconsidered insignificant.
The next section of text clarifies these issues and we have a reference
to Table 3.29 already in the text.

992

3

3

1042

1042

994

3

3

1051

1051

…and the combustion [reactions] there is an approximate…" -- Robert Lanzaclarify which combustion processes are being referred to here.

Accepted

5314

3

3

1054

1055

Accepted withmodification

996

3

3

1055

1055

IPPU memo item mentioned, but I can´t find the IPPU memo Pia-Kristiina Forsell
item from my CRF reporter, only memo item I can find isunder Energy sector. Is there a decision to include memo items
to IPPU also?
…the CO2 should be [reported] in the IPPU Memo Item…
Robert Lanza

998

3

3

1055

1055

Robert Lanza

Accepted

4524

3

3

1065

"Waste may contain both fossil and biogenic materials" -consider adding this statement as a footnote to Table 3.29
H2, subscript

Kewei Yu

Accepted… can be placed in either of two categories depending on the Robert Lanza
degree of conversion…" -- clarify which of the technologies inTable 3.29 fall into each of the two categories. Consider adding
a column or other indicator to Table 3.29 indicating thecategory of each technology in the table.
… have hydrogen as a byproduct or intermediate product" -Robert Lanzaconsider identifying separately in Table 3.29 which
technologies produce hydrogen as an intermediate and which
produce hydrogen as a byproduct.

Response

Authors notes

Accepted

Noted

The authors note that this does not apply to the mentioned footnote,
which regards reforming of ammonia feedstock (not production ofammonia). No changes necessary.

Accepted

Rejected

Rejected

The authors consider that there is no need for a such distinction, asintermediate product and by-product emissions are treated the sameway.

The authors note that there is no need at this stage to specify the typeof memo item. Hence, the specification "IPPU" is removed from alltext.

Accepted
A footnote has been added.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

1000

3

3

1087

1088

Accepted

The text has been rewritten.

1002

3

3

1101

1101

Robert Lanza"…details about syngas) which in most cases is the final
product." -- see comments under line 984, clarify thedefinition of "final product;" the Ammonia Production IPPU
subcategory includes emission factors for a "partial oxidation"ammonia production technology. There are also syngas
processes in which the hydrogen-containing syngas is anintermediate product used to produce ammonia and for which
the syngas is not a final product.
"…and other gases [including CO2 and methane.]"Robert Lanza

Expert

4526

3

3

1111

better use %Kewei Yu

Accepted

1004

3

3

1113

1114

editing convention, using "e.g.," or "f. ex."

Robert Lanza

Accepted

1006

3

3

1116

1116

"Biological methods [including] fermentation…"

Robert Lanza

Accepted

1008

3

3

1118

1118

"… hydrogen containing minor amounts of CO2, methane, and Robert Lanza
other…" -- clarify here how methane emissions from biologicalprocesses are to be reported

Accepted

The authors have clarified the text; no emissions are to be reported.

1352

3

3

1120

1120

Noted

1010

3

3

1120

1120

David Kuntze
Biogenic processes to produce H2 are excluded because theCO2 emissions are not originating from fossil sources and weare not obliged to report CO2 emissions from biogenic sources.
This is correct. But these biogenic processes produce also
relevant amounts of CH4. In line 1120 the GLs estimate an
amount of about 2%. I porpose to include the biogenic
processes in the reporting but not for CO2, but for CH4
emissions.
…. A maximum of 2 percent of the hydrogen production." -Robert Lanzaclarify if this is 2 percent by weight of the hydrogen productionor 2 percent by volume of the hydrogen production.

Methane is part of the product and produced in an anaerobic
athmosphere, and hence none of this methane will be emitted in thehydrogen production sector. There may be minor methane emissions,but the available literature references all indicate that methane
emissions are extremely low and the dataset is very limited. Therefore,
at this time it is not possible to derive methods and EFs for methane
emission estimates, which are regarded as sufficiently low to beconsidered insignificant.
The literature source is not specific on type of percentage. The authorsof the hydrogen chapter have taken it as molar percentages of the
produced hydrogen gas; if we assume it to be percentage by weight,
then the produced hydrogen is even purer and the methane content
even lower. The text has been rewritten to reflect that the methane ispart of the product and produced in an anaerobic atmosphere, andhence none of this methane will be emitted in the hydrogenproduction sector.

1012

3

3

1120

1120

…. A maximum of 2 percent of the hydrogen production." -this may not be an insigificant amount of methane emissions
for a large-scale biological hydrogen production process.

Robert Lanza

Noted

328

3

3

1122

1123

it is stated that coal gasification for city gas should beconsidered in the hydrogen production sector but there isneither a method nor an emission factor provided (at least forCH4 in respect of the high methane content of town gas9

Christian Boettcher

Accepted withmodification

Accepted

Accepted withmodification

Methane is part of the product and produced in an anaerobic
athmosphere, and hence none of this methane will be emitted in thehydrogen production sector. There may be minor methane emissions,but the available literature references all indicate that methane
emissions are extremely low and the dataset is very limited. Therefore,
at this time it is not possible to derive methods and EFs for methane
emission estimates, which are regarded as sufficiently low to beconsidered insignificant.
Authors have provided clarifications in the revised text, to specify
that production of hydrogen as part of mixtures is not covered by thissection.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

10070

3

3

1125

1129

Miriam Lev-On
Propose including a citation to the 2009 API GHG
Compendium, Section 5.2.2 Refinery Hydrogen Plants, forfurther elaboration of the methodology for estimating GHG
emissions for Steam Reformers. The methodology is applicable
both to refinery and stand-alone H2 manufacturing plants withapplicable feedstock and CO2 capture and removal.

Accepted withmodification

The reference has been included; no change in method description isconsidered necessary by the authors.

1014

3

3

1127

1127

Accepted withmodification

The authors have provided a clarification in a separate paragraph,rather than a textbox.

1016

3

3

1128

1129

AcceptedBox moved to (former) line 1019.

1018

3

3

1130

1130

…(i.e., raw materials and fuels data)" --- clarify that emissions Robert Lanza
resulting from raw materials use and emissions resulting fromfuels use are both to be reported under IPPU. Consider
providing a text box example describing the [separate] use offuel and raw materials in hydrogen production processes,
similar to the description in Ammonia Production, in which
natural gas participates in the steam reforming chemical
reaction as a raw material and natural gas also provides heat tothe process as a fuel.
as Box 3.18 is referred to in line 1129, and also referred to in Robert Lanza
Line 1003, consider moving the text box to the vicinity of line
1129, or in the vicinity of line 1003, where the text box is firstreferred to.
"…relevant data [are] available…"
Robert Lanza

5316

3

3

1138

1139

Pia-Kristiina Forsell
Using production capacity gives normally over estimation ofemissions that is the reason not to suggest to use it as default
method and mention that it is good practice to use it. Even inammonia chapter capacity data has been multiplied withcapacity utilisation factor, not the total capacity data used.
And to think about calculation of baseline emissions ofhydrogen production, this guideline (as good practice!) makes
recommendation to over estimate emissions of base year!

Accepted withmodification

1020

3

3

1153

1153

"…production data [are] not available…"

Accepted

5318

3

3

1153

1154

1022

3

3

1155

1155

1024

3

3

1159

1159

The mentioning that "It is good practice to avoid double
Pia-Kristiina Forsell
counting with other sector" is unnecessary, that is a fact.
…(i.e., raw materials and fuels data)" --- clarify that emissions Robert Lanza
resulting from raw materials use and emissions resulting fromfuels use are both to be reported under IPPU. Consider
providing a text box example describing the [separate] use offuel and raw materials in hydrogen production processes,
similar to the description in Ammonia Production, in which
natural gas participates in the steam reforming chemical
reaction as a raw material and natural gas also provides heat tothe process as a fuel.
clarify "plastic" here -- what type(s) of plastic are being
Robert Lanza
referred to?

4276

3

3

1159

1159

The 2006 IPCC Guidelines (Volume 5, Tables 2.4 and 2.5)
provide the fossil carbon content of plastics (75% of dry
weight for municipal solid waste and 80% for industrial solid
waste). However, I do not find the net calorific values ofplastics in the guidelines.

ExpertRobert Lanza

Naofumi Kosaka

Accepted
Guidance has been provided in the 'activity data' section, but has been
improved in both places. The authors also note that Tier methods havebeen changed in the updated version of the document.

Accepted
Accepted withmodification

The authors have provided a clarification in a separate paragraph,rather than a textbox.

Accepted

A footnote is provided in table 3.30 stating that the factors relate to
mixed plastic. For CCF the value for "other petroleum products" in
Vol.2 Ch. 1 Table 1.3 is used.
All factors are now given in Table 3.30. Moreover, the NCV value isprovided in a footnote.

Accepted

Comment ID Volume Chapter From line To line

Comment

8652

3

3

1159

1161

1026

3

3

1164

1164

5304

3

3

1164

1178

Ole-Kenneth Nielsen
It is not clear what is the assumption behind the CCF forplastic. The value of 20 kg/GJ could not be reproduced basedon the cited reference. It is quite easy to estimate the CCF fordifferent types of plastic. However, it should be stated in the
GL what mix of plastics is assumed, so that users can evaluate
it.
"it is assumed that the same material is used for both raw
Robert Lanzamaterial and fuel in a given production method…" -- is it
necessary to make this assumption for hydrogen production?
Or could the method be modified to allow for separate
emissions calculations to be conducted for fuel and for raw
material?
These paragraphs (three altogether) are not dealing with Tier 1 Pia-Kristiina Forsell
method to calculate emissions, but general information of goodpractice. These paragraphs are better to include in 3.11.1
Introduction or 3.11.2 Methodological issues.

Response

Authors notes

Accepted

A footnote is provided in table 3.30 stating that the factors relate to
mixed plastic. For CCF the value for "other petroleum products" in
Vol.2 Ch. 1 Table 1.3 is used.

Accepted withmodification

The guidance has been rewritten to say that: "Emissions fromcombustion should be included only if the fuel is derived from thefeedstock."

Accepted withmodification

Sections of text that are not specific to Tier 1 method have been
moved to the 3.11.2.1 introduction.

1028

3

3

1165

1165

"it is good practice to use the CCF for the raw material" -- can Robert Lanza
the method be modified to allow use of both the CCF for thefuel and the CCF for the raw material? Both the CCF for the
raw material and the CCF for the fuel would be known, or there
would be default factors for both.

Accepted withmodification

The guidance has been rewritten to say that: "Emissions fromcombustion should be included only if the fuel is derived from thefeedstock."

858

3

3

1168

1168

The reference to table 3.11.2 is not correct. It may be "Table
Virginia Sena
3.30" the correct one.
The IPCC GLs write that CO2 EM from biogenic sources shall David Kuntze
be reported at IPPU Memo item. I do not know this memo
item in the CRF tables. To my knowledge this memo item does
not exist. But I see the necessarity to create this. But as in thisprocess only the GLs are changed My proposal is to leave the
IP memo item in the text and to add a footnote to it, that thismemo item is planned to be added at the CRF tables. As longas the memo item for IP does not exist, the CO2 emissions
from biogenic sources shall not be reported.
"..biogenic carbon shares [of the feedstock]" -- there is at least Robert Lanzaa theoretical possibility that the fuel could also contain abiogenic component.
"…typically sold for use in other manufacturing industries…" -- Robert Lanza
CO2 recovered from ammonia production in ammoniafertilizer plants may be used for urea production. The methodshould account for other production processes in which
recovered CO2 may be used as a feedstock in the same facility
rather than being sold or stored.

Noted

The text has been rewritten in response to other comments, so thiscomment no longer applies.
The authors note that there is no need at this stage to specify the typeof memo item. Hence, the specification "IPPU" is removed from all
text.

1334

3

3

1170

1170

1030

3

3

1171

1171

1032

3

3

1173

1174

1336

3

3

1173

1178

1034

3

3

1181

1181

As for the lines 1407-1410 the following sentence should be
added: If the emissions are not reported at the respective
sectors, it is good practice to not subtract these recoveredamounts from the CO2 emissions.
"…or hydrogen production [are] not available."

ExpertAccepted withmodification

Accepted

The text has been rewritten to address this.

Accepted

The text has been rewritten, and text moved to introduction of Ch.
3.11.2.1.

David Kuntze

Accepted

The text has been added to introduction of Ch. 3.11.2.1.

Robert Lanza

Accepted

Comment ID Volume Chapter From line To line

Comment

1344

3

3

119

119

1036

3

3

1190

1190

6408

3

3

1194

4278

3

3

1194

1195

Ammonia production and the problem of the correct allocation David Kuntzeof the energy demand. The IPCC GLs 2006 recommend forammonia production that all process and energy emissions
from ammonia production should be allocated at 2B1. This is avery difficult recommendation, because countries are using
energy balances. And in these it is not possible to identify theenergy demand from ammonia production. Also it is very
difficult to subtract these emissions from the emissions from
CRF 1. Because then this will lead to a gap with the Refenece
approach. As in the countries under the UNFCCC convention
both methods exist, I propose to change the IPCC GL for 2B1
and to allow to use both methods. So it is allowed to report theenergy emissions at CRF 1 and CRF 2. When the IPCC GL
2006 for ammonia production will not be changed there will bealways very difficult discussions between Reviewers andPartys.
Clarify the definition of the "FRF" "feedstock requirement
Robert Lanza
factor." The text refers to "raw material and fuel" ascomprising "feedstock" in various places; consider whether it
is feasible to modify the method to allow for separate
calculations for "fuel" and "raw material," as these could be
two different materials that have carbon contents.
default feedstock specific requirements are given only in table Ekaterina Imshennik
3.30
I suggest that the authors delete "feedstock specific feedstock Naofumi Kosaka
requirement factors (FRFj) and" because Table 1.3 in Vol.2
only include carbon content factors.

ExpertResponse

Authors notes

Noted

No action can be taken because the comment is out of scope of the2019 Refinement.

Accepted withmodification

Responding to two comments in one: 1. Rejected. Clarification isalready included in the second paragraph after the definition. 2. The
guidance has been rewritten to say that: "Emissions from combustion
should be included only if the fuel is derived from the feedstock."

Accepted

Cross-reference changed.

Accepted

Cross-reference changed.

1338

3

3

1195

1196

"…if hydrogen production is not a key category, …." But Tier David Kuntze
2 is already enough for key categories. I see it not necessary to
propose a method of the T2 method to be used that can beused, if it is not a key category. This is also not good as it
makes the job for the reviewers more difficult. Because thepartys can report a method as T2 but it is not T2. And so far a
T2 method always fulfills the requirements of a Key category.
This should be left like this. My proposal is to delete themethods that can be used for a T2 method if the source
category is not a key category.

Accepted

Paragraph deleted.

8654

3

3

1195

1198

This sentence is currently not clear. Why the reference to 5 %and how does it link to the previous sentence?

Ole-Kenneth Nielsen

Accepted

Paragraph deleted.

1038

3

3

1196

1196

"up to 5 %..." -- clarify what the basis is for this value, or forthe value that would replace it based on the text note.

Robert Lanza

Accepted

Paragraph deleted.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

1040

3

3

1200

1200

…(i.e., raw materials and fuels data)" --- clarify that emissions Robert Lanza
resulting from raw materials use and emissions resulting fromfuels use are both to be reported under IPPU. Consider
providing a text box example describing the [separate] use offuel and raw materials in hydrogen production processes,
similar to the description in Ammonia Production, in which
natural gas participates in the steam reforming chemical
reaction as a raw material and natural gas also provides heat tothe process as a fuel.

ExpertAccepted withmodification

The authors have provided a clarification in a separate paragraph,rather than a textbox.

1042

3

3

1201

1202

"it is assumed that the same material is used for both raw
material and fuel in a given production method…" -- is it
necessary to make this assumption for hydrogen production?
Or could the method be modified to allow for separate
emissions calculations to be conducted for fuel and for raw
material?

Accepted withmodification

The guidance has been rewritten to say that: "Emissions fromcombustion should be included only if the fuel is derived from thefeedstock."

5306

3

3

1201

1214

Accepted withmodification

Sections of text that are not specific to Tier 1 method have been
moved to the 3.11.2.1 introduction.

860

3

3

1205

1205

Same information given as in line 1164-1178 (more reasons to Pia-Kristiina Forsell
describe these information in Introduction or Methodologicalissues.
It is written "good practise" instead of "good practice".
Virginia Sena

Accepted

Text rewritten.

1044

3

3

1208

1208

Accepted

1046

3

3

1210

1211

Accepted

The text has been rewritten, and text moved to introduction of Ch.
3.11.2.1.

1048

3

3

1224

1224

"..biogenic carbon shares [of the feedstock]" -- there is at least Robert Lanzaa theoretical possibility that the fuel could also contain abiogenic component.
"…typically sold for use in other manufacturing industries…" -- Robert Lanza
CO2 recovered from ammonia production in ammoniafertilizer plants may be used for urea production. The methodshould account for other production processes in which
recovered CO2 may be used as a feedstock in the same facility
rather than being sold or stored.
refer to previous comments, define "main product"
Robert Lanza

Accepted

A new text box has been added, which also includes "main product","feedstock", "raw material", "fuel", "pure hydrogen" and "gasmixtures".

1050

3

3

1230

1231

"…[should] be obtained from producers."

Accepted

1354

3

3

1230

1268

1340

3

3

1232

1234

1052

3

3

1234

1234

In line 1230 and in line 1268 plant specific feedstock
David Kuntze
requirement factors (FRF) are mentioned. It seems that thedifferentiation between 3a and 3b is than not obvious. Only thedecision tree shows then that in T3a no plant specific feedstock
requirement factor should be used. The text should be
improved.
David Kuntze"If data on actual hydrogen production is not available for aselection of plants, it should be considered to use production
capacity as an estimate of production for these plants, ..." Thisis a Tier 3 method. So does this sentence mean that a country
can use a Tier3 method and use for this for all plants as AD theproduction capacity? I would think that production capacity
should not be used in a Tier 3 method and my proposal is todelete the production capacity in the section for the TIER 3
method.
"… or use a Tier 2 method [that uses aggregate production
Robert Lanzadata.]"

Robert Lanza

Robert Lanza

Noted

The method description has been revised to cite provision of plant
specific estimation based on feedstock consumption.

Accepted

Paragraph deleted.

Accepted

Paragraph deleted.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

8656

3

3

1238

1243

Again the reference to 5 % is not clear. If using a tier 3 then the Ole-Kenneth Nielsen
data are known. If the intention is to say that in some cases a
Party may use tier 3 for a number of plants accounting for X %of the production, the Party can apply tier 1 for 100-X % of the
production, then this point can be made more clearly.

ExpertAccepted

Paragraph deleted.

4280

3

3

1239

1243

Accepted

Paragraph deleted.

1054

3

3

1240

1240

Accepted

Paragraph deleted.

5308

3

3

1244

1254

I suggest that the authors delete "If … CCF." because tier 3 is Naofumi Kosaka
not applied when this category is not a key category according
to Figure 3.20.
"up to 5 %..." -- clarify what the basis is for this value, or for Robert Lanza
the value that would replace it based on the text note.
Some repetition of the paragraphs over mentioned.
Pia-Kristiina Forsell

1056

3

3

1247

1247

Accepted

The text has been rewritten, and text moved to introduction of Ch.
3.11.2.1.

1058

3

3

1248

1248

"…typically sold for use in other manufacturing industries…" -- Robert Lanza
CO2 recovered from ammonia production in ammoniafertilizer plants may be used for urea production. The methodshould account for other production processes in which
recovered CO2 may be used as a feedstock in the same facility
rather than being sold or stored.
"…storages. Stored carbon is solid carbon or coke…" -- thisRobert Lanza
combination of sentences is unclear, the carbon sent to storages(presuably by underground injection) is not the same "stored
carbon" as what is turned into solid carbon or coke."

Accepted

A clarification has been provided.

5320

3

3

1259

1267

Accepted

The equation has been corrected to apply consistent units.

1060

3

3

1264

1264

Equation 3.47. There is a mistake in the equation. In the
Pia-Kristiina Forsell
equation the consumption of feedstock are tonnes ant it should
be multiplied with caloric value to get consumption as GJ (orMJ).
refer to previous comments, define "main product"
Robert Lanza

Accepted

A new text box has been added, which also includes "main product","feedstock", "raw material", "fuel", "pure hydrogen" and "gasmixtures".

1062

3

3

1269

1269

"…consumption data [are] not necessary…"

Robert Lanza

Accepted

1342

3

3

1269

1271

"Note that plant specific consumption data is not necessary in David Kuntze
the Tier 3b method, since all the feedstock is assumed to beconverted to CO2 emissions or stored as solid carbon." I do notagree with this. In the IP section T3 was always plant specific.
This should be left like this. With this method I also not
obviously see the difference between T2 and T3. Reviewers
rely on the information T3 = plant specific for IP section.

Accepted

5310

3

3

1272

1282

Some repetition of the paragraphs over mentioned.

Noted

Pia-Kristiina Forsell

Noted

The method was proposed having steam reforming of natural gas inmind. However, the composition of coal can vary greatly, evenbetween plants, and hence a plant specific Tier method based on
consumption data is now provided, and a new Tier 2 method based on
consumption data with country specific carbon content factors as
well. The former Tier 3b method is now placed at the Tier 1 level.
Moreover, the letters a and b are switched to allow for a new Tier 1cmethod based on national level activity data and at the same time
have the Tier methods at a given level labelled sorted by lettersaccording to the uncertainty. Accordingly, the former Tier 3b method
is now Tier 1a, and methods labelled 'a' has the lowest uncertainty atthat Tier level.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

1064

3

3

1275

1275

"…typically sold for use in other manufacturing industries…" -- Robert Lanza
CO2 recovered from ammonia production in ammoniafertilizer plants may be used for urea production. The methodshould account for other production processes in which
recovered CO2 may be used as a feedstock in the same facility
rather than being sold or stored.

ExpertAccepted

The text has been rewritten, and text moved to introduction of Ch.
3.11.2.1.

1066

3

3

1276

1276

"…storages. Stored carbon is solid carbon or coke…" -- thisRobert Lanza
combination of sentences is unclear, the carbon sent to storages(presuably by underground injection) is not the same "stored
carbon" as what is turned into solid carbon or coke."

Accepted

A clarification has been provided.

1068

3

3

1286

1286

CO2 -- check subscripts throughout section

Accepted

1070

3

3

1288

1288

1072

3

3

1298

1301

1074

3

3

1303

1305

1076

3

3

1312

1322

8658

3

3

1323

1324

consider developing a standard format for figure notes, table
Robert Lanza
notes, text notes, etc.
Consider whether the Tier 1 method can be modified to allow Robert Lanzafor separate calculations for different materials used for fueland for raw material.
Consider whether the Tier 2 method can be modified to allow Robert Lanzafor separate calculations for different materials used for fueland for raw material.
Consider whether the Tier 3 method can be modified to allow Robert Lanzafor separate calculations for different materials used for fueland for raw material.
The references in Table 3.30 should be assigned to the relevant Ole-Kenneth Nielsen
technologies rather than all just listed at the bottom, i.e. it
should be clear which references have been used for which
process. The CCFs seems to be consistent with the CCFs
reported in the 2006 GL in the energy sector, with the
exception of bioethanol (biogasoline), this discrepancy should
be addressed. The global average seems to be a weighted
average using less than 100 %, what has been assumed in theweighting for the remaining 4 %? It would also be good, if it isstated what year the global average is representative for (i.e. 49% natural gas, 29 % LPG/naphtha and 18 % coal), i.e. is thisthe average in 2017 and would this be markedly different ine.g. 1990 or 2000. How big is the potential error in applying
this for a long time-series, e.g. 1990 to today.

754

3

3

1323

1324

In Table 3.30, is there a consistency in the relative order among Hideshi Iki
the producing methods of FR and CCF in each manufacturingmethod? (e.g. Black liquor requires more raw material thanwaste materials and coal)

1078

3

3

1324

1324

Comments on Table 3.30

Robert Lanza

Noted

1080

3

3

1324

1324

Comments on Table 3.30 -- Under the "Production Process"column -- replace "Fuel Reforming" with "Steam Reforming"
30

Robert Lanza

Accepted

Robert Lanza

Accepted
Accepted withmodification
Accepted withmodification
Accepted withmodification
Accepted withmodification

Noted

The guidance has been rewritten to say that: "Emissions fromcombustion should be included only if the fuel is derived from thefeedstock."
The guidance has been rewritten to say that: "Emissions fromcombustion should be included only if the fuel is derived from thefeedstock."
The guidance has been rewritten to say that: "Emissions fromcombustion should be included only if the fuel is derived from thefeedstock."
Addressing four comments in one: 1. Rejected, as most of thereferences are relevant to several production processes. 2: Accepted.
The CCF figures are consistent with Other Liquid Biofuels in Table
1.3 (Vol. 2, Ch. 1), and Table 3.30 is changed accordingly. 3:
Accepted. The remaining 4 % of the global average is electrolysis, inaddition to other very minor technologies. It is added to the footnote.
4: Literature is scarce, but the global average seems to have been
relatively stable over the years (see f. ex. Ogden 1999 and Speirs et al.
2017). The factor is to be used in the Tier 1c method, only, i.e. theone with the highest uncertainty.

More abundant technologies are placed higher than less abundantones, but the sorting is not strict.

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

1082

3

3

1324

1324

Comments on Table 3.30 -- For the carbon content factors in
Table 3.30 provide a reference to TABLE 1.3 DEFAULTVALUES OF CARBON CONTENT in Volume 1

Robert Lanza

Accepted

1084

3

3

1324

1324

Comments on Table 3.30 -- for note "*" clarify "plastic" -what type(s) of plastic are being referred to?

Robert Lanza

Accepted

1086

3

3

1324

1324

Accepted

1088

3

3

1324

1324

1090

3

3

1324

1324

1092

3

3

1324

1324

1094

3

3

1324

1324

1096

3

3

1324

1324

Comments on Table 3.30 -- for note "**" -- clarify that theRobert Lanza
natural gas and LNG percentages refer to the steam reforming
production process and that the coal percentage refers to thegasification process. Provide a reference for the production
data referred to in the note.
Comments on Table 3.30 -- for note "***" -- clarify that theRobert Lanza
natural gas and LNG percentages refer to the steam reforming
production process and that the coal percentage refers to thegasification process. Provide a reference for the production
data referred to in the note.
Comments on Table 3.30 -- consider developing a standard
Robert Lanza
format for figure notes, table notes, text notes, etc. It is notclear from the format of the notes, numbers, asterisks, etc.
which reference is associated with which feedstock
requirement factor. Consider reformatting the table so thateach line contains the feedstock requirement factor and its
associated reference.
Robert Lanza
Comments on Table 3.30 -- NETL 2017 included in thereference section in Line 1683, is not referenced in Table 3.30.
If NETL 2017 was used in preparing the factors in Table 3.30,
indicate which factors are based on NETL 2017.
Robert Lanza
Comments on Table 3.30 -- NETL 2017 includes data points
for each of two coal gasifier technologies, and includes data
points for three different types of coal. Pitt 8 coal is a highBTU value coal with a heat value of approx. 13,120 BTU/lb;
Wyodak coal is a low-BTU value coal with a heat value ofapprox. 8,220 BTU/lb. The NETL 2017 data show different
conversion efficiencies for the two coal types from the same
gasification process. Consider whether NETL 2017 and similar
data for coal gasifiers can be used to provide separate factors
for lower-BTU value coals and higher BTU-value coals rather
than a providing only a single factor applicable to a range ofcoal heat contents.
Comments on Table 3.30 -- JRC 2014 included in Table 3.30 Robert Lanza
does not appear in the reference list for Chapter 3.11.

1098

3

3

1324

1324

Comments on Table 3.30 -- The full reference for GREET(2013) is Updates to Parameters of Hydrogen Production
Pathways in GREET™, Amgad Elgowainy, Jeongwoo Han,
and Hao Zhu, Systems Assessment Group, Energy Systems
Division, Argonne National Laboratory, October 7, 2013

Robert Lanza

Authors notes

A footnote is provided in table 3.30 stating that the factors relate to
mixed plastic. For CCF the value for "other petroleum products" in
Vol.2 Ch. 1 Table 1.3 is used.

Accepted

Accepted withmodification

Addressing two comments in one: 1: Accepted, a standard format has
been implemented. 2: Rejected as several references are applicable toseveral production processes.

Accepted

Accepted withmodification

Accepted
Accepted

The authors have revised the uncertainty range of FRF, increased
from +/- 15% to +/- 20%. After method revision this applies to Tier 1
only, while both Tier 3 methods are plant specific.

Comment ID Volume Chapter From line To line

Comment

1100

3

3

1324

1324

1102

3

3

1324

1324

Robert Lanza
Comments on Table 3.30 -- The PNNL 2017 hydrogenproduction efficiency calculator for coal gasification, NETL
2017 data for coal gasification, and GREET 2013 data for coalgasification all include electricity generation. Consider inTable 3.30 including for coal gasification two separate factors
for the feedstock requirement that goes to hydrogen production
and the feedstock requirement that goes to electricity
production (for example, GREET 2013 includes a factor forkWh generated/mmBtu hydrogen produced for coalgasification). It could be the case that if only the feedstock
requirement that goes to hydrogen production is included in thetable, the feedstock requirement that goes to electricity
productio could be misreported. In incorporating the two
separate feedstock requirement factors indicate that thefeedstock use for hydrogen production and the feedstock use
for electricity production are to be reported separately if theelectricity is exported.
Robert Lanza
Comments on Table 3.30 -- The PNNL 2017 hydrogenproduction efficiency calculator for central biomass
gasification and the GREET 2013 data for biomass gasification
both include values for the amount of biomass consumption
and the amount of natural gas consumption for the gasification
process. Consider in Table 3.30 including for biomass
gasification separate factors for the natural gas feedstock
requirement of the biomass gasification process and thebiomass feedstock requirement of the biomass gasification
process, considering that the CO2 emissions from the biomass
feedstock to the process and the CO2 emissions from thenatural gas feedstock to the process are to be reported
separately. Including only a single factor for the combined
natural gas consumption and biomass consumption could resultin the natural gas component of the feedstock and the biomass
component of the feedstock being misreported.

1104

3

3

1333

1333

207

3

3

1336

1336

4512

3

3

135

894

3

3

135

4528

3

3

1351

1106

3

3

1351

4530

3

3

1352

1108

3

3

1360

141

1352

1361

ExpertFor "national production data" clarify whether this refers to
Robert Lanzadata only for the amount of hydrogen produced as a "mainproduct" only? Or would this refer also to data for intermediate
and byproduct hydrogen production?
Why you select 80 percent?
Koichi Kojima

Response

Authors notes

Accepted

The authors have reviewed the literature sources and revised thefactors accordingly, to remove any energy use not being a direct partof the hydrogen production process. Changes are minor, as inhydrogen production the amount of electricity being used in the
production process is small.

Accepted withmodification

The guidance has been rewritten to say that: "Emissions fromcombustion should be included only if the fuel is derived from thefeedstock."

Accepted

Clarification has been added by cross-reference to box 3.16 on double
counting.

Noted

This is the percentage used in Ch. 3.2 Ammonia production.

N2O, subscritp, check other places

Kewei Yu

Accepted

N2O -- check subscripts throughout section

Robert Lanza

Accepted

CO2, subscript, good practice in italic

Kewei Yu

Accepted

CO2 -- check subscripts throughout section

Robert Lanza

Accepted

CO2 subscript

Kewei Yu

Accepted"up to 5 %..." -- clarify what the basis is for this value, or forthe value that would replace it based on the text note.

Robert Lanza

Accepted

Paragraph deleted.

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

8660

3

3

1384

1410

Ole-Kenneth Nielsen

Accepted

A row has been added to table 1.2 in Vol. 3 Ch. 1 with the following
information: Type of use = Feedstock; Example of fuel types = naturalgas, oils, coal; Product/process = hydrogen; Chapter = 3.11.

862

3

3

1388

1388

Considering that the guidance on hydrogen production is newand that it could be significant in many countries, it is very
important that this new guidance is tied in with the existingguidance on feedstocks and non-energy use of fuels, i.e. it isnecessary that Chapters 1.3-1.5 of Volume 3 are updated toreflect this new significant source that will affect thecompleteness checks and verification approaches outlined as
good practice.
It is written "good practise" instead of "good practice".

Virginia Sena

Accepted

1110

3

3

1391

1392

"… other sectors, including Ammonia Production (IPPU) andPetroleum Refining (Energy) must be excluded from…"

Robert Lanza

Accepted

1112

3

3

1395

1395

5322

3

3

1395

1410

as Box 3.18 is referred to in line 1129, and also referred to in Robert Lanza
Line 1003, consider moving the text box to the vicinity of line
1129, or in the vicinity of line 1003, where the text box is firstreferred to.
Box 3.18, Double counting. Should it be possible to not to
Pia-Kristiina Forsell
subtract the recovered CO2 which is going to be used
immediately after recovering? Like CO2 in soft drink industry.

5102

3

3

1397

1397

…When hydrogen is a by-product or intermediate product, its Kristina Juhrichgood practice to report the CO2 emissions in the sector of themain product.… In the categories where refineries have to bereported (1.A.1.b and 1.B.2.aiii) is no methodical description
available. Combustion related emissions from hydrogenproduction are automatically included in 1.A.1.b. But process
related emissions from hydrogen production are not mentioned
in 1.A.1.b and 1.B.2.aiii. This is a dead link.

Noted

1330

3

3

1397

1410

If only H2 production as main product is reported at thiscategory I see here the danger of missing emissions. There isthen always a high possibility that there is a gap.

David Kuntze

Accepted

Authors have added text clarifications to address this comment.

60

3

3

1399

1403

Rejected

The authors consider that the extensive guidance provided istransparent.

1114

3

3

1400

1401

Accepted withmodification

Reference to the aggregate sector is now provided.

1116

3

3

1404

1405

"Emissions from production of hydrogen reported in the
Mingshan Su
Energy Sector and IPPU sectors other than hydrogenproduction must be excluded from the hydrogen production
sector" seems to indicate that hydrogen production is not aprocess in IPPU but a 3rd sector. If hydrogen production is not
a process in IPPU it is better to design a seperate Vollume forit.
"… these sectors include Petroleum Refining (Energy, Oil and Robert Lanza
Natural Gas Systems) and Ammonia Production (IPPU,
Chemical Industry)."
Fuel consumed as part of the [hydrogen] production process
Robert Lanza(e.g., fuel combusted directly to provide process heat to the
production process) should be reported in the Hydrogen
Production sector. Fuel consumed for other purposes should
be reported in other sectors..."AcceptedBox moved to (former) line 1019.

Accepted

Text has been revised, notably to alert users to the risk of double
counting emissions, as it might be a difficult task for the hydrogenproducers to document reporting in the downstream sectors (dataavailability, etc.).
The existing methodology in Vol. 2 Energy (Ch. 4.2) may be used,
and it will be improved in the 2019 Refinement. Clarifying box will
be provided in the Energy chapter.

Accepted

Comment ID Volume Chapter From line To line

Comment

5104

3

3

1404

1406

Kristina JuhrichThis sentence should remain unchanged. It gives scope ofinterpretation. Strict rules regarding allocation issues are notuseful. National circumstances should be considered. It should
be possible for a country to follow the structure of their energy
statistic (including the IEA questionnaire) which has a clear
definition on energetic and non-energetic use. The Guidelines
deviate from this definition in several cases which causes
problems.

Noted

1332

3

3

1407

1410

Accepted

Text has been revised, notably to alert users to the risk of double
counting emissions, as it might be a difficult task for the hydrogenproducers to document reporting in the downstream sectors (dataavailability, etc.).

1118

3

3

1407

1410

Accepted withmodification

The authors note that the bullet point does not mention selling or
storing. The text has been revised from "manufacturing industries" to"production processes".

8662

3

3

1407

1410

David Kuntze
All CO2 recovered and used somewhere else, should bereported there. Ok, but then it should be said, that only CO2
recovered can be subtracted, that is reported elsewhere, toavoid a gap in the reporting of emissions. It is the same
disucussion as for ammonia. The easiest way is to report all
CO2 emissions at the H2 production and to not subtract therecovered CO2. I propose the follwing sentence: If theemissions are not reported at the respective sectors, it is goodpractice to not subtract these recovered amounts from the CO2
emissions.
CO2 recovered from ammonia production in ammoniaRobert Lanza
fertilizer plants may be used for urea production. The methodshould account for other production processes in which
recovered CO2 may be used as a feedstock in the same facility
rather than being sold or stored.
Ole-Kenneth Nielsen
In order to ensure transparency, it would be good, if it was
described as good practice to report on the downstream uses, sothat it is possible to verify that they have been correctly
accounted for in the relevant sectors.

Accepted

Guidance with reference to the NIR has been included.

4532

3

3

1409

Proper noun for the sector.

5440

3

3

141

4534

3

3

1412

844

3

3

142

143

The parenthesis "(listed in Table 3.3)" is not correct. It will be Virginia Senacorrect to only write: "The five production processes types are
distinguished according to the pressures applied in theoxidation and absorption stage as presented in Table 3.3.A.".
And the "A" for Table 3.3.A, in capital letter.

Accepted withmodification

1120

3

3

1426

1426

"Fuel requirement factors" -- edit -- these are referred toelsewhere in the section as "Feedstock requirement factors."

Robert Lanza

Accepted

1122

3

3

1426

1426

"[Feedstock] requirement factors (FRFs): Uncertainty in thedefault [feedstock] requirement factors …"

Robert Lanza

Accepted

1124

3

3

1428

1428

"i.e., how much feedstock [(fuel) is combusted for processheat] per tonne of…"

Robert Lanza

Accepted

151

ExpertResponsehydrogen? Letter case

Kewei Yu

Rejected

The default factors as given in Table 3.3 are considered as
being reasonable.
avoid starting a sentence with an abbreviation

Tiffanie Stephani

Accepted

Kewei Yu

Accepted

Authors notes

The sentence (listed in Table 3.3) has been deleted, however, we still
prefer to use “a” instead of “A” because Table 3.3.a is an additional
information (sub-section) of Table 3.3. If we name the table as Table
3.3.A then the next table must be named as Table 3.3.B.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

1126

3

3

1428

1430

Robert Lanza
Consider whether the method can be modified to allow for
separate calculations for fuel and raw material, as it is possiblethat the fuel and raw material to a hydrogen production process
could be different materials with different heat contents andcarbon contents. PNNL 2017 and GREET 2013 (referenced inTable 3.30) show data for biomass gasification in which theraw material is biomass and the fuel is natural gas.

ExpertAccepted withmodification

The guidance has been rewritten to say that: "Emissions fromcombustion should be included only if the fuel is derived from thefeedstock."

8664

3

3

1433

1433

The use of the Latin phrase seems unnecessary.

Ole-Kenneth Nielsen

Rejected

4536

3

3

1443

replae "percentage points" with "%"Kewei Yu

Rejected

To make that change would alter the meaning.

1128

3

3

1443

1443

"An increase of +/- 10 percentage points…" -- clarify -- an"increase" isn't "+/-" which could be an +10 percentage point
increase or a - 10 percentage point decrease.

Robert Lanza

Rejected

The authors consider that the text is appropriate for the description of
uncertainty.

208

3

3

1443

1443

Why you select 10 percent? I find 15 percent is most common Koichi Kojima
value in table 3.30. And compared with table 3.29 and table
3.30 I find major technologies uncertainty is 10 or 15, but 15 isthree times and 10 is two times.

Noted

The guidance has been rewritten to say that: "Emissions fromcombustion should be included only if the fuel is derived from thefeedstock." Therefore this comment is no longer relevant.

4282

3

3

1446

1446

Naofumi Kosaka

Accepted

8666
1130

3
3

3
3

1446
1447

1446
1447

I suggest that the authors replace "member state" by "country
with similar circumstances".
The use of the term 'Member State' should be avoided.
"An increase of 20 percentage point…" See comment on Line1443, does this mean a "+/-" or just a "+?"

Ole-Kenneth Nielsen
Robert Lanza

Accepted
Accepted

1132

3

3

1448

1448

Robert Lanza

Accepted

1134

3

3

1449

1449

"A default increase in the downward uncertainty" -- clarify, it
is unclear what the downward uncertainty refers to here.
Clarify -- "biogenic share" of what?

Robert Lanza

Accepted

Rewritten and moved to "Activity data uncertainties".

1136

3

3

1449

1449

Robert Lanza

Accepted

Rewritten and moved to "Activity data uncertainties".

1138

3

3

1449

1449

Clarify -- "low value" -- what value is it? Low compared towhat value?
Clarify -- "reported data" -- based on what reported data?

Robert Lanza

AcceptedPhrase removed.

209

3

3

1458

1458

Why you select 5 percent?

Koichi Kojima

NotedSame as Ch. 3.2 Ammonia production.

210

3

3

1462

1462

Why you select 20 percent? Default value in table 3.30 is 30
percent.

Koichi Kojima

Noted

There is not a default value for this in Table 3.30. The uncertainty is
considered medium sized, based on expert judgement. A plant willprobably not change production technology over the years, and hencea big variation in factors is not expected.

1140

3

3

1474

1475

CO2 and H2 -- check subscripts throughout section

Robert Lanza

Accepted

1142

3

3

1476

1476

"no fossil fuel use or loss" -- clarify - this refers to no fossil fuel Robert Lanza
use to provide process heat to the production process and that
only raw material, and no fuel, is used in the process?

Noted

The authors have revised the text to clarify this point.

1346

3

3

151

152

Table 3.3: For nitric acid production Germany proposes aDavid Kuntze
further category: Plants with two catalysts. This reduces the EFeven more. The main reason for the further reduction is
because when one catalyst is cleaned the other one is stillworking.

Noted

This category could be added if enough information is available bytechnology and using 2 catalysts. However, there are very few plants
and all in Europe using this abatement and as European plants areusing T3 as measurement is mandatory under the ETS and what weare updating is T2 it migth be no relevant to include it as there will bea risk of countries using an EF which is lower than in reality.

The sign can be +/-Comment ID Volume Chapter From line To line

Comment

8644

3

3

151

152

8646

3

3

151

152

Table 3.3 presents an EF for 'Old' production process defined Ole-Kenneth Nielsen
as pre-1975. It is not clear what this EF is intended to be used
for, e.g. is it applicable until a certain year and if so what year.
Many inventories estimate emissions back to 1990, should thisEF be used for all processes in 1990? More guidance should be
provided on the applicability of this EF.
Footnote b and d to Table 3.3 both mentions 2017 submissions Ole-Kenneth Nielsen
by Annex 1 Parties as reference for several EFs. It is not clear
whether the Parties using default EFs from the 2006 IPCC GL
have been taken out of the dataset. Also, several of the data
points referenced from the BREF document are significantly
outside of the range of the EFs provided considering theuncertainty listed. It seems that either the EFs of theuncertainty ranges should be updated. An example: Dualpressure (L/M) default EF is 7 with an uncertainty of 10 %.
The only plant of this type in the BREF is reported with anemission level of 3.4-4.9, i.e. considerably outside the range ofthe default EF.

Expert

896

3

3

152

152

Comments on Table 3.3

898

3

3

152

152

900

3

3

152

152

Comments on Table 3.3 -- N2O -- check subscripts throughout Robert LanzasectionRobert Lanza
Comments on Table 3.3 -- For Single Low Pressure Plants -provide a reference for the 5 kg/tonne emission factor-- there
are no source notes for this line in the table

902

3

3

152

152

Comments on Table 3.3 -- For Single High Pressure Plants -provide a reference for the 9 kg/tonne emission factor -- there
are no source notes for this line in the table

904

3

3

152

152

Comments on Table 3.3 -- The "*" note does not appear to be Robert Lanza
associated with any "*" in the table itself; consider establishinga standard convention for notes and sources in tables
throughout the document.

Robert Lanza

Robert Lanza

Response

Authors notes

Accepted

The word "Old (pre-1975) plants" means that the EF is to be used forthe technology that was built before 1975 and it is still operating (thissituation still exist in some countries). An explanatory footnote has
been added.

Accepted

Parties using default EFs from the 2006 IPCC GL have been taken outof the dataset. Concerning the EF presented in the BREF for Dual
L/M pressure plants the data comes from N2O emission levels of theAustrian nitric acid plants relating to catalytic ammonia combustionof the Austrian nitric acid plants (with abatement). The data source in
the BREF is the report called STATE-OF-THE-ART
FOR THE PRODUCTION OF NITRIC ACID WITH REGARD TO
THE IPPC DIRECTIVE, Herbert WIESENBERGER, 2001, and IPCC
data 20 years ago was not very realiable. Even this report also
indicates that discrepancies might be caused by analytical problems
with measurements. Nowadays, N2O concentrations are measured
continuously, which is the more reliable method. Some more recent
data can be found in UNFCCC NIRs submissions of Canada, Croatia
and Italy for this technology (the results show higher values). In
addition, the BREF indicates for EU designed dual plants a EF rangeof 8 - 10 (although it is not specified if it is L/M or M/H).
Nevertheless, the uncertainty range has been updated to take into
account the data source for the Austrian plants.

Noted
Accepted
Noted

This EF was not updated, it is default IPCC2006 GLs. Based on the
IPCC2006 GLs, the source of EF is Van Balken (2005) and European
Fertilizer Manufacturrers Association. Therefore we did not put thesources. It is coherent with the information presented by the Parties intheir GHG inventory submissions and based on measurements.

NotedThis EF was not updated, it is default IPCC2006 GLs. Based on the
IPCC2006 GLs, the source of EF is Van Balken (2005) and European
Fertilizer Manufacturrers Association. Therefore we did not put thesources. It is coherent with the information presented by the Parties intheir GHG inventory submissions and based on measurements.
Notes are indicated with * and sources with letters

Accepted

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

906

3

3

152

152

Comments on Table 3.3 -- It is not clear from the "*" note how Robert Lanza(whether) tailgas destruction technologies are being
distinguished from NSCR technologies or other abatement
technologies in the single pressure emission factors referred toin the "*" note. In the 2006 Guidelines for Nitric Acid
Production, TABLE 3.2 N2O ABATEMENT APPROACHESAND ABATEMENT MEASURES. shows four levels ofabatement, primary, secondary, tertiary, and quaternary.

ExpertAccepted

EF from plants with tail gas destruction technologies are not being
distinguished from NSCR or other abatement technologies in the
single pressure because the EF is almost the same for all types ofabatement, i.e. 2.5. (Sources: IPCC2006 and 2017 Annex I Party
GHG Inventory Submissions available at
http://unfccc.int/national_reports/annex_i_ghg_inventories/national_i
nventories_submissions/items/10116.php). For instance, the EF with
NSCR in USA is 3.3 while the 2006 IPCC GLs provided an EF of 2
for NSCR and 2.5 for tailgas destruction. Having a look to EF
measurements for all levels of abatement technologies it was possible
to regroup the EF with abatement in a single one representative for all
single pressures processes and all levels of abatement. Nevertheless,the note has been redrafted for providing more clarity.

908

3

3

152

152

Comments on Table 3.3 -- Provide a basis and explanaton for
the uncertainty estimates for each of the emission factors

Robert Lanza

Noted

The uncertainty levels are estimated from the range of EF found frommeasurements in the references. It is planned to obtain a wider rangeof measurements from the bigger producer countries to estimate andconfirme the uncertainty values proposed using the Good PracticeGuidance and Uncertainty Management in National Greenhouse Gas
Inventories of the 2006 IPCC Guidelines.

910

3

3

152

152

Comments on Table 3.3 -- Provide for footnote (b) an
explanation of which national inventory submittals included
N2O emission factors for nitric acid production and how theemission factors reported in the national inventories weretranslated into the 8 kg/tonne emission factor.

Robert Lanza

Rejected

For this case the EF published in the CRF tables and NIR submitted
to the UNFCCC by Finland, Italy and Slovakia were used. From thegroup of countries using each technology an EF range is established
for the technology without abatement measures and then the average
proposed and the range taken into account in the uncertainty levels
proposed. We do not think we should mention countries or plants due
to confidentiality issues (even if the GHG inventories are publicly
available and the BREF document published data by plant from EU
plants). The number of plants by country is usually very small and we
think there could be an issue if we provide the name of the countries
and/or plants.

912

3

3

152

152

Robert Lanza
Comments on Table 3.3 -- Provide for footnote (d) an
explaination of which national inventory submittals included
N2O emissions and how these were used with emission factors
from the other sources cited in footnote (d) to estimate theemission factors for the various various dual pressure
processes.

Rejected

The EF published in the bibliography together with the EF reported in
the CRF tables and NIR submitted to the UNFCCC are used all
together. From the group of countries and plants using eachtechnology an EF range is established for the technology withoutabatement measures and then the average proposed. We do not think
we should mention countries due to confidentiality issues (even if the
GHG inventories are publicly available) and also due to the changesof technologies in time in all countries. The number of plants bycountry is usually very small and we think there could be an issue if
we provide the name of the countries.

914

3

3

152

152

Comments on Table 3.3 -- for example, Germany and Australia Robert Lanza
report Tier 3 plant-specific emission factors for N2O emissions
from nitric acid production

Noted

Data from these two countries could not be used because they publish
only the IEF for all plants and with abatement so these countries weretaken out of the dataset. However, the biggest HNO3 producers in the
EU are being contacted to validate the EF proposed and Germany is
one of the countries that confirmed the realibility of the updated EF
proposed.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

916

3

3

152

152

Comments on Table 3.3 -- Provide for footnote (c) a basis and Robert Lanza
explanaton for the conservativeness factor for NSCR

ExpertAccepted withmodification

918

3

3

152

152

Robert Lanza
Comments on Table 3.3 -- Some other chemical industry
subcategories, e.g., petrochemical (ethylene) production,
include geographic adjustment factors, see e.g., 2006
Guidelines TABLE 3.15 DEFAULT GEOGRAPHIC
ADJUSTMENT FACTORS FOR TIER 1 CO2 EMISSION
FACTORS FOR STEAM CRACKING ETHYLENE
PRODUCTION. Consider using geographic adjustment factors
in a similar manner to the national inventory data for N2Oemissions from nitric acid production, rather than having one
set of world-wide emission factors, as some national
inventories are reporting plant-specific emission factors?

Rejected

The explanation was wrong in indicating that a conservativenessfactor has been applied for NSCR. This has been corrected. EF fromplants with tail gas destruction technologies are not being
distinguished from NSCR or other abatement technologies in the
single pressure technologies because the EF is almost the same for all
types of abatement, i.e. 2.5. (Sources: IPCC2006 and 2017 Annex I
Party GHG Inventory Submissions available at
http://unfccc.int/national_reports/annex_i_ghg_inventories/national_i
nventories_submissions/items/10116.php). For instance, the EF with
NSCR in USA is 3.3 while the 2006 IPCC GLs provided an EF of 2
for NSCR and 2.5 for tailgas destruction. Having a look to EF
measurements for all levels of abatement technologies it was possible
to regroup the EF with abatement in a single one representative for all
single, all M/H dual and all L/H pressures processes and all levels ofabatement. Nevertheless, the note has been redrafted for providing
more clarity.
The geografic differences can be easily figured out when looking at
the GHG inventories of all countries. In fact, EU plants have thelowest EF and they are all using T3 due to the fact that the ETS makemeasurements mandatory. This table is going to be used by non EU
countries as it provides T2 EF. There are few plants producing HNO3
worldwide and, out of EU there are no geographic differences, butemissions depend on the technology. Geographic differences havebeen also taken into account by proposing EF by technology and EF
for outdated or old plants (pre-1975).

920

3

3

152

152

Comments on Table 3.3 -- In the 2006 Guidelines TABLE 3.3 Robert Lanza
DEFAULT FACTORS FOR NITRIC ACID PRODUCTION
includes a separate default factor for plants with NSCR.
Consider including a similar "plants with NSCR" factor in therevised table of default factors.

Rejected

5442

3

3

153

153

Noted

1520

3

3

1627

1627

Fertilizers Europe agrees to the comments made for Tier 3 and Tiffanie Stephaninotes that for most nitric acid plants in Europe detailed plantdata are available and thus the tier 3 method will be the mostappropriate.
change to ………. Fluorocarbons Environmental Acceptability Archie McCulloch
Study, Arlington, U.S.A., 2004. Available at
http://agage.mit.edu/data/afeas-data Out of date website

Noted

EF from plants with tail gas destruction technologies are not being
distinguished from NSCR or other abatement technologies in the
single pressure technologies because the EF is almost the same for all
types of abatement, i.e. 2.5. (Sources: IPCC2006 and 2017 Annex I
Party GHG Inventory Submissions available at
http://unfccc.int/national_reports/annex_i_ghg_inventories/national_i
nventories_submissions/items/10116.php). For instance, the EF with
NSCR in USA is 3.3 while the 2006 IPCC GLs provided an EF of 2
for NSCR and 2.5 for tailgas destruction. Having a look to EF
measurements for all levels of abatement technologies it was possible
to regroup the EF with abatement in a single one representative for all
single, all M/H dual and all L/H pressures processes and all levels ofabatement. Nevertheless, the note has been redrafted for providing
more clarity.

The final list of references is subject to change and will be formatted
in the final draft

Comment ID Volume Chapter From line To line

Comment

1144

3

3

1660

1660

4284

3

3

1660

1660

1146

3

3

1683

1683

1148

3

3

1683

1683

1150

3

3

1686

1687

The full reference for GREET (2013) is Updates to Parameters Robert Lanzaof Hydrogen Production Pathways in GREET™,
Amgad Elgowainy, Jeongwoo Han, and Hao Zhu, Systems
Assessment Group, Energy Systems Division, Argonne
National Laboratory, October 7, 2013
I suggest that the authors check the citation again. The number Naofumi Kosaka
of authors is not two but three. The document name ends at not
Patyways but GREET.
The National Energy Technology Laboratory (2017). The
Robert Lanza
National Energy Technology Laboratory -- provide the title ofthis reference
NETL 2017 is not referenced in Table 3.30. If NETL 2017 was Robert Lanza
used in preparing the factors in Table 3.30, indicate which
factors are based on NETL 2017.
The URL for the Pacific Northwest Laboratories Hydrogen
Robert Lanza
Production Energy Conversion Efficiencies is:https://www.h2tools.org/hyarc/hydrogen-data/hydrogenproduction-energy-conversion-efficiencies

Expert

6314

3

3

204

594

4582

3

3

2293

6316

3

3

665

6402

3

3

698

846

3

3

698

848

3

3

4508

3

850
852

Response

Authors notes

Accepted

Accepted

Accepted

Accepted

Reference has been added to Table 3.30.

Accepted

Excellent and comprehensive HFC-23 emissions methodology, Anny Huang
no changes recommended.
CO2 emission
Kewei Yu

Noted

Strongly recommend that the final Guidelines version does
Anny Huang
include default emission factors currently described in the draft
text "We are considering presenting defaul emission
factors……which would better account for the fact that highGWP emissions may result from the production of low-GWP
products."
Mij instead of Mijk
Ekaterina Imshennik

Accepted[See response to comment #1518.]

Accepted698

The comma before the word "plants" has to be moved to after
the word "plants". It has to be: "Mijk = mass emitted from jstreams in each plant over all i plants, as determined from amass balance."

Virginia Sena

Accepted

We agree with the commenter and have corrected the typographicalerror as suggested.
We agree with the commenter and have corrected the typographicalerror as suggested.

699

699

Virginia Sena

Accepted

3

75

81

The parenthesis at the end of the line has to be deleted. The
parenthesis is closed in the next line.
leter case issues

Kewei Yu

Accepted

3

3

858

858

3

3

867

867

667

The reference to the Table should be "Table 3.29A" instead of Virginia Sena
"Table 3.29".
The reference to the Table should be "Table 3.29A" instead of Virginia Sena
"Table 3.29".

Thank you for your comment.

Accepted

Accepted
Accepted

We agree with the commenter and have corrected the typographicalerror as suggested.
We agree with the commenter and have corrected the typographicalerror as suggested.
We agree with the commenter and have corrected the typographicalerror as suggested.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

6828

3

3

876

In Germany, the SF6 emitted during the production of SF6 is Edgar Dullni
not reported to UBA (German environmental agency)
because there is only one SF6 manufacturer (compliance). The
emission factor for returned and reused gas is 0.005.

Accepted withmodification

We are unable to find the Preisegger reference to help provide any
additional context for the selection of the original value 0.002 or thecommenter's suggested value of 0.005. It is also not clear if the 0.002
value represents a controlled or uncontrolled number. The expert
reviewer does not provide documentation of the suggested 0.005
value, so we are not able to revise the value without including areference in the 2019 Refinement section 3.10. Therefore, we willretain the original 0.002 value as is listed in the orginal 2006
guideline, as this value successfully completed the peer review
process at that time. We included a note in the 2019 Refinement toclarify we do not know if this value represents emissions from acontrolled or uncontrolled process .

4514

3

3

895

good practice in italic

Accepted

854

3

3

895

6404

3

3

921

6406

3

3

921

6312

3

3

977

We agree with the commenter and have corrected the typographicalerror as suggested.
We agree with the commenter and have corrected the typographicalerror as suggested.
We agree with the commenter that the revised version of Figure 3.17
in the FOD of section 3.10 that was available under the Expert
Review beginning in December 2017 had an error. Based on further
review of the figure, we determined that Figure 3.17 should not be
modified under the refinement. We reverted back to the original
Figure 3.17 from the 2006 Guidelines. Another comment received on
Figure 3.17, see below, resulted in a revision to Footnote 2 to the
Figure 3.17.
We believe the commenter refers to Footnote 2 to Figure 3.17 thatindicates Tier 2 may only be used for key category determination andis not useful for emission estimations for the inventory. We agreewith the commenter that there may be instances where Tier 2 would
be an appropriate methodology. The original footnote makes
reference to the fact that HCFC-22 production is a relatively simple
reaction process with two reactants and one by-product (HFC-23) that
accounts for the majority of the total byproducts. Because there is one
significant byproduct, the mass balance approach in Tier 2 isrelatively straightforward. For fluorochemical processes covered
under section 3.10.2, there tend to be more complex processes withmultiple reactants and multiple by-products, which are perhaps toocomplicated for the mass balance methodology under Tier 2.
However, in instances where a fluorochemical process under section
3.10.2 is a relatively simple process, i.e., few reactants and one
product, Tier 2 could be appropriately applied. The Footnote 2 to
Figure 3.17 has been refined to indicate that Tier 2 would beappropriate only for certain simple processes. The text in section
3.10.2.2 has not been refined.
The authors note that impurities are removed in a separate step using
energy from electricity or stationary combustion on site (i.e. sector 1
Energy). Hence, no change is needed.

882

895

ExpertKewei Yu

The reference to the Table should be "Table 3.29A" instead of Virginia Sena
"Table 3.29".
The decision tree should be refined. After "Are detailed data
Ekaterina Imshennik
available jn plant-specific estimates?" "No" and "yes" areconfused.

Emission estimates from key category can be made using Tier2 Ekaterina Imshennik
methodology. It is not mandatory to use Tier 3.

1495

Although the method for hydrogen production is defined indetail, it seems that there is no definition on the purity ofhydrogen. It is necessary to define the purity of hydrogen.
Because hydrogen to be supplied to a fuel cell is required tohave high purity, and generation of CO 2 due to energy
required for the purification process should be taken into
consideration.

Ryo Nakajima

Accepted
Accepted withmodification

Accepted

Noted

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

922

3

3

984

984

Robert Lanza

924

3

3

984

984

delete "methanol" -- Table 3.29 indicates that methanol is an"experimental" process"final product" -- clarify the defintiion of "final product,"consider adding a text box describing the definitions of "final
product" intermediate" and "byproduct"

Accepted withmodification
Accepted

Table 3.29 has been revised to reflect that methanol reforming is not"experimental" but "minor and increasing".
A new text box has been added, which also includes "main product","feedstock", "raw material", "fuel", "pure hydrogen" and "gasmixtures".

926

3

3

984

984

Accepted

A new text box has been added, which also includes "main product","feedstock", "raw material", "fuel", "pure hydrogen" and "gasmixtures".

4516

3

3

988

"final product" -- defined as a) the hydrogen is exported offsite Robert Lanza
to a separate facility; b) the hydrogen is sold as a commercial
product; c) similar definition
CO2, subscript
Kewei Yu

Accepted

928

3

3

988

988

CO2 -- check subscripts throughout section

Robert Lanza

Accepted

930

3

3

989

989

"maximum of 2 % is normal" -- specify 2 percent of what…
e.g., 2 percent by weight of the total amount of hydrogenproduced?

Robert Lanza

Accepted withmodification

932

3

3

989

989

"minor" -- 2 percent may not be a "minor" amount of CH4
emissions from large-scale processes, considering that theemissions are methane, not CO2.

Robert Lanza

Accepted withmodification

8648

3

3

989

989

Ole-Kenneth Nielsen
It is stated that biological technologies might generate minor
amounts of CH4 and that at present a maximum of 2 % isnormal. It is not clear what the 2 % refer to. Is the CH4
emission 2 % of the hydrogen produced? If so, this would seem
like a significant emission. This would be elaborated further.

Accepted withmodification

The literature source is not specific on type of percentage. The authorsof the hydrogen chapter have taken it as molar percentages of the
produced hydrogen gas; if we assume it to be percentage by weight,
then the produced hydrogen is even purer and the methane content
even lower. The text has been rewritten to reflect that the methane ispart of the product and produced in an anaerobic atmosphere, andhence none of this methane will be emitted in the hydrogenproduction sector. The term "normal" has been changed to "reported",
as literature is scarce.

934

3

3

990

990

"combustion of fossil fuels" -- would this combustion of fossil Robert Lanza
fuels be reported under "energy" or under "IPPU?" In Ammona
Production, emissions from the "feedstock" (i.e., the raw
material to the process) and emissions from the "fuel" (i.e., thatprovides heat to the process) are both reported under IPPU.

Accepted

A clarification has been provided.

936

3

3

992

992

CO2 -- check subscripts throughout section

Accepted

Robert Lanza

Robert Lanza

The literature source is not specific on type of percentage. The authorsof the hydrogen chapter have taken it as molar percentages of the
produced hydrogen gas; if we assume it to be percentage by weight,
then the produced hydrogen is even purer and the methane content
even lower. The text has been rewritten to reflect that the methane ispart of the product and produced in an anaerobic atmosphere, andhence none of this methane will be emitted in the hydrogenproduction sector. The term "normal" has been changed to "reported",
as literature is scarce.
The text has been rewritten to reflect that the methane is part of the
product and produced in an anaerobic atmosphere, and hence none ofthis methane will be emitted in the hydrogen production sector. The
term "normal" has been changed to "reported", as literature is scarce.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

8650

3

3

993

994

The statement that only GHG emissions from fossil feedstocks Ole-Kenneth Nielsen
should be included in the inventory seems inaccurate. If there
were CH4 emissions from biological processes (see alsocomment to Volume 3, Chapter 3, Line 989) they should be
included in the inventory. If they are insignificant that could bestated and no methodology be provided, but stating that theinventory should only include emissions from processes using
fossil fuels seems inaccurate.

Accepted

The text has been rewritten to address this comment.

938

3

3

994

994

CO2 -- check subscripts throughout section

Accepted

4884

3

3

994

995

Accepted withmodification

940

3

3

995

996

What does 'the IPPU memo item' refer to? Is it a memo item
Elsa Hatanaka
that needs to newly be included in the IPCC Reporting tables(in Vol.1)?)"negligible" -- 2 percent may not be a "minor" amount of CH4 Robert Lanzaemissions from large-scale processes, considering that theemissions are methane, not CO2.

942

3

3

999

1001

Accepted

944

3

3

999

1001

5100

3

3

999

1003

"main product" -- Clarify the definition of "main product." See Robert Lanza
comments to line 984, consider a text box to clarify thedefinition of "main product.""byproduct" and "intermediate product" -- consider adding a
Robert Lanza
text box describing the definitions of "main product""intermediate product" and "byproduct."…When hydrogen is a by-product or intermediate product, its Kristina Juhrichgood practice to report the CO2 emissions in the sector of themain product. For instance…in refineries… In the categories
where refineries have to be reported (1.A.1.b and 1.B.2.aiii 4)
is no methodical description available. Combustion related
emissions from hydrogen production are automatically
included in 1.A.1.b. But process related emissions fromhydrogen production are not described in 1.A.1.b and1.B.2.aiii. This is a dead link.

5522

3

4

2514

3

4

5084

3

4

1004

1004

ExpertRobert Lanza

Accepted withmodification

Accepted

Noted

Christine Dubois
Section 4.4 Primary Aluminium Production - General
information: Many 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 andtrade). 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 freeallowance. We welcomed the proposition to develop a
consistent time series but the method must be accurate to avoid
any uncertainty increasing.

Noted

Proof reading is needed

Anna Mikis

Accepted

insert comma after "ratio"

Christopher Bayliss

Accepted

The authors note that there is no need at this stage to specify the typeof memo item. Hence, the specification "IPPU" is removed from alltext.
The text has been rewritten to reflect that the methane is part of the
product and produced in an anaerobic atmosphere, and hence none ofthis methane will be emitted in the hydrogen production sector. The
term "normal" has been changed to "reported", as literature is scarce.
A new text box has been added, which also includes "main product","feedstock", "raw material", "fuel", "pure hydrogen" and "gasmixtures".
A new text box has been added, which also includes "main product","feedstock", "raw material", "fuel", "pure hydrogen" and "gasmixtures".
The existing methodology in Vol. 2 Energy (Ch. 4.2) may be used,
and it will be improved in the 2019 Refinement. Clarifying box will
be provided in the Energy chapter.

No action needed

Edited text

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

5404

3

4

1004

1014

Rejected

The consistency of the numbers across facilities would argue to justify
suggested approach. However, there is evidence in repeat
measurements at individual facilities that when HVAE emissions are
reduced LVAE emissions are also reduced which would favor a ratio
approach in any time series approach. Many of the factors involved in
reducing HVAE emissions also reduce the propensity for LVAE
emissions to occur. We agree with the reviewer that the best way toestablish a LVAE and HVAE emissions factor is using the T3
approach.

5550

3

4

1012

1014

Accepted

No action needed

1708

3

4

1015

1027

Based on the numbers in Table 1 in (Marks and Nunez 2018) it Ole Kjos
would make more sense to report LVAE emissions based on
CF4/ton Al for both Tier 2 and Tier 3 as well as for Tier 1.
These numbers seem to be very consistent around 0.015 to
0.018 kg CF4/ton Al for all PB technologies, while the HVAE
numbers improves a lot due to the different design and control
improvements from the old legacy PB cells to the new modern
PB cells. This indicates that LVAE and HVAE does not have a
direct relationship, and hence it only introduces additional
uncertainties to report LVAE as a function of HVAE. The
reduction in HVAE is to a large degree due to improvements in
automated anode effect termination and avoidance systems.
These systems might prevent an HVAE, but are not very
efficient in avoiding the LVAE preceding the HVAE, and fairto say these systems are not designed to do so either.
Therefore, it is difficult to see why a reduction in HVAE
should automatically lead to a reduction in LVAE which would
be the case if LVAE is reported as a factor of HVAE.
Reporting LVAE as a function of produced metal, butpreferably with Tier 3 type factors calculated for each plantmakes much more sense and will probably give equal or better
accuracy while maintaining a simpler and more transparent
approach.
The decision not to consider C2F6 emissions from LVAE is
Christine Dubois
welcomed
There are inconsistencies related to Equation 4.26B. As it isVirginia Senadeveloped, "LVAE_E CF4" units will be "square Kg" insteadof "Kg". I think the "MPi" term of the equation has to bedeleted, and also that the "Ratio" has no units (instead of kg
CF4/tonne Al as it is written in line 1026).

ExpertAccepted

Edited text

4540

3

4

102

103

Tier 2, a space

Accepted

Typo corrected in the text

5086

3

4

1024

1024

replace "ECF4" with "ECF4,i"

Christopher Bayliss

Accepted

Edited text

5088

3

4

1025

1025

subscript 4 in CF4

Christopher Bayliss

Accepted

Corrected

9546

3

4

1026

1027

No units for the LVAE/HVAE ratio.

Nadia Morais

Accepted

Edited text

5540

3

4

1037

1038

Christine Dubois

Accepted

Edited text

5090

3

4

1037

1043

In the title, HAVE should be HVAE
EF CF4 and EF C2F6, units should be (kg/tonne
Al)/(min/celldays)
spelling of HVAE incorrect in tables 4.15 and 4.16 (HAVE)

Christopher Bayliss

Accepted

Edited text

8680

3

4

1037

1043

There is no references cited for the default EFs presented inTable 4.15 and Table 4.16. The references used should be
provided for each of the technologies listed.

Ole-Kenneth Nielsen

Accepted

Edited tables and reference added

5544

3

4

1037

1048

Table 4,15 indicates slope term for Tier 1 EFCF4 for HVAE
and LVAE is lower than EFC Tier 2 shown in table 4,16
(HVAE) for different technology PFPB. The units should be(kgCF4/mt Al)/(Min/cellday). Should explain why is Tier 1
lower than Tier 2. We know Tier 1 uncetanties are higher but
perhaps a comment or explanation should be included.

Christine Dubois

Rejected

Heading incorrect in first draft - values are not comparable assuggested

Kewei Yu

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

9548

3

4

1042

1043

Nadia Morais

5542

3

4

1042

1043

Christine Dubois

Accepted withmodification
Accepted

Removed footnote - previous heading for CF4 was incorrect and has
now been amended so units are correct
Edited text

5092

3

4

1042

1043

Christopher Bayliss

Accepted

Edited text

5094

3

4

1042

1043

Christopher Bayliss

Accepted

Edited text

9550

3

4

1047

1048

Table 4.16 : not the good units for the tier 2 Slope Coefficientand the note «b» does not appear at the bottom of the table.
In the title, HAVE should be HVAE
EF CF4, units should be (kg/tonne Al)/(min/celldays)
second column in table 4.16 mislabelled - should read SCF4
(kg/tonne Al/AE-mins/cell-day
no footnote 'b' to accompany reference in Uncertainty Range
column of table 4.16
Uncertainty of the LVAE/HVAE ratio must be specified.

Nadia Morais

Accepted

Uncertainties included

1350

3

4

1049

1056

David Kuntze
The EF under Tier 3 for PFC emissions from aluminium
production is requested to be measured. But in the old IPCC
GLs 2006 there was the collection efficiency to be accounted(see old IPCC GLs 2006, p. 4.54, table 4.16, note C. I propose
to add the information Collection efficiency = CWPB 98%,
SWPB
90%, VSS 85%, HSS 90% in the text for the developement of a
Tier 3 EF.

Rejected

The updated factors don’t necessarily reflect the percentage collection
efficiencies noted in comment. While those percentage are typical forthe technologies mentioned the updated emission factors and slope
factors are calculated based on actual measurements and the measured
fluoride collection efficiencies for the measured facilities (using thefluoride collection efficiency as a proxy for PFC collection
efficiency). Therefore a T3 EF would have efficiency related toindividual site.

5548

3

4

1086

1139

For GHG regulation, taxes and cap and trade system, thegovernment choice year baseline to calculate the CO2
reduction. Changing the historical result is important but it
must be accurate as it is impact the regulation compliance

Accepted

Modifications were applied to the time-consistency section to ensure
consistency through time for historical data.

9552

3

4

1101

1102

Accepted withmodification

Edited text accordingly for Tier 2. There was no modification
regarding tier 3 due to the fact the such coefficients are based on
smelter data. For this reason, backcasting using tier 3 should still use
the specific factor defined during that specific period.

6128

3

4

1119

1121

Accepted

Edited text

5546

3

4

1123

1139

Accepted

Section on time consistency was edited accordingly.

4552

3

4

1125

Last sentence : specify that this methodology concerns the Tier Nadia Morais
2 method. Because I understand that the 2007 and up backcast
data concerns the users of the tier 2 method and not the usersof tier 3 overvoltage method (no good practice specified in the
document to backcast the HVEA emissions for the users of tier
3 overvoltage method).
The IAI is referenced two times in lines 1119 and 1120 but
Jooil Kim
noted as if they were different entities with differingreferences?
Section 4.4.2.7 developing a consistent time series : for
Christine Dubois
aluminium smelters using Tier 1 or Tier 2, the proposition for
HVAE is to backcast calculation for PFC emission from 2007.
It is not clear for LVAE if we have to backcast emission from2007 or not. And if we are using Tier 3 factor, could we use
Tier 2 factor for LVAE PFC emissions?
Xiping is given name, check the reference
Kewei Yu

Accepted

Edited text

9554

3

4

1128

I found some contradictions in these lines. The impact of the
Nadia Morais
LVEA emissions backcast on the cap and trade regementation
should be considered. I understand that the backcast with tier 2
is interresting to understand the level of LVEA PFC in theatmosphere but not enough acurate for facilities regulation at
this time.

Accepted

Added some words to add precision regarding the "national level"

1139

Christine Dubois

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

4176

3

4

1133

1139

For backcasting purposes, it may be more accurate to assume a Stephanie Bogle
minimum LVAE emission factor instead of omitting the LVAE
emissions entirely. However, I haven't had the opportunity toreview the data in the cited paper.

ExpertRejected

There was no observation of LVAE in the past (2006 and less) due tothe change in technologies and increasing amperage. For this reason,
there is only a minimal error in omitting LVAE prior to a certain datein time (2006). For the period between 2006 and 2019, there is toomuch uncertainty and variations associated to the LVAE EF to allow
its usage for individual smelters backcasting.

6130

3

4

1145

1147

Past IAI reports have found and used different emission factors Jooil Kim
specific to China, so there exists instances of regional
differences. Perhaps the authors would clasify this as adifference in "work practices in use in the country or region"?
In it's current form, this sentence gives the impression that
there aren't significant differences in emissions between
countries and regions, and I think that could be misleading.

Rejected

Differences are in work practices and tech not country specific

5406

3

4

1225

1226

Ole Kjos
A good methodology for measurement and quantification of
LVAE is essential, and needs to be specified either in the
document or with a reference. Especially the level ofquantification (LOQ) is important as a higher LOQ will detect
a lower share of the total LVAE emissions, and hence give alower reported value. On the other hand, it is essential not toanalyse below LOQ, as it will then include noise in the dataset,
which will lead to a substantial over-estimation of theemissions. To have comparable measurements across facilities
it is essential to have the same LOQ when estimating LVAE.
Ideally LOQ for LVAE should be defined as a fraction of the
produced gases to be independent of suction rates, i.e. LOQ
CF4 could be 1/1000000 of the CO2 level. Figure 3 from
Aarhaug et.al, Light metals 2018 compares two instrumentswith different sensitivity, and how that affect the instruments
actual ability to estimate emissions. If none, or too low LOQ
were to be used then one would potentially report the
integrated noise area, as seen in "ProtIR" data before 12:00.
Also, if using IUPAC defined LOQ on both ProtIR and Bomem
results, they would give significant different reported values
due to lower noise and higher sensitivity of the Bomem. A
consensus for the required detection level to establish LVAE
quantification needs to be outlined, there should be arequirement that all measurements are proven to conform withthis detection limit, and too report uncertainty budgets as well.

Accepted withmodification

Edited text to clarify - reviewers notes are mostly out of scope of GL
but should be considered for future protocols to support new GL.

8682

3

4

1225

1226

Not sure that it is the role of inventory compilers to encourage Ole-Kenneth Nielsen
industry how to do estimates. It seems that role would fit betterwith regulatory authorities or the international branch
association. This sentence should be deleted or reformulated.

Accepted

Text removed

6132

3

4

1258

1258

Jooil Kim

Rejected

Method adopted is the same for both gases so no need to separate

4554

3

4

1276

Table 4.17: Include separate reporting of CF4 and C2F6
emissions in the table, as suggested in line 1250.
5%, remove a space

Kewei Yu

Accepted

Text has been removed.

4556

3

4

1287

1289

parallel and sequential, in italic or not?

Kewei Yu

Rejected

Not in italic. Text has been corrected.

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

6418

3

4

1314

1320

The text is the same as in lines 1307 - 1313

Ekaterina Imshennik

Accepted

Doubled text has been removed.

1710

3

4

1314

1320

Accepted

Doubled text has been removed.

8684

3

4

1335

1336

Accepted>1% has been replaced by <1%.

6422

3

4

1336

1336

Virginia Sena
These 2 parapraphs are the same as the 2 paragraphs above(lines 1307 to 1313).
If the sources are negligible then they are presumably <1 % and Ole-Kenneth Nielsen
not >1 %. The same goes for line 1349-1350.
Should be < 1%
Ekaterina Imshennik

Accepted>1% has been replaced by <1%.

6420

3

4

1350

1350

Should be < 1%

Accepted>1% has been replaced by <1%.

1712

3

4

1376

1382

Accepted

The text has been corrected.

4558

3

4

1381

Please review the punctuation (dots at the end of the sentences) Virginia Senain this paragraph. Also, in line 1382, it is written "...m thepresence..." instead of "...in the presence..." The paragraphmay be: "The first stage of carbonization ends atconcentrations of 3-4 g/l of Al2O3. Alumina hydrate is thenseparated and the second stage of carbonization is carried on to
sodium hydrocarbonate concentrations of 10-15 g/l of
NaHCO3. The precipitate is sodium hydroalumocarbonate as
mentioned above. Since the carbonate-containing solutions arefurther processed to yield sodium carbonate and potassium
carbonate, they must not contain more than 0.1-0.15 g/l of
Al2O3. It is for this reason that carbonization must be carriedon up to 10-15 g/l of NaHCO3 concentrations since thesolubility of the alumocarbonate is sharply reduced in thepresence of substantial amounts of hydrocarbonate."m?
Kewei Yu

Accepted

The text has been corrected.

6424

3

4

1385

Noted

Cross cutting issue - may need input from CLAs for next draft

4560

3

4

1405

1714

3

4

1405

4542

3

4

4562

3

4564

1399

Ekaterina Imshennik

Lime is used in numerous industrial processes. It will be better Ekaterina Imshennik
to estmate this CO2 sink in individual sink category on thebase of total amount of lime used in all industrial processes, inorder not to make this methodology too complicated.
is very depends on, grammar

Kewei Yu

Accepted

The text has been corrected.

Virginia Sena

Accepted

The text has been corrected.

141

It is written "… capture is very depends on…" instead of "…
capture is very dependent on …"
Tier 2, letter case

Kewei Yu

Accepted

Edited text

4

1426

replace carbon dioxide or methane with ""CO2 and CH4"

Kewei Yu

Accepted

The text which contains the appropriate phrases has been corrected.

3

4

1454

lime production in bold?

Kewei Yu

Accepted

The text has been corrected. The text is normal

6426

3

4

1454

Accepted

Additional clarification has been added.
Equation 4.27A for Tier 1 has been corrected .

4566

3

4

1458

8686

3

4

1477

4568

3

4

1483

1405

1456

Emissions from lime production are accounted for in category Ekaterina Imshennik
2.A.2 Lime production. The estimation of CO2 emission fromlime production in alluminium industry will cause double
counting. Moreover, this text is not in line with the Equation
4.27A for Tier 1.
sintering process in bold?
Kewei Yu

Accepted

The text has been corrected. The text is normal

1478

A tier 1 EF is referenced to section 4.4.5.3. However, in thissection on tier 1 EF is provided.
better use %Ole-Kenneth Nielsen

Accepted

The table with Tier 1 EF is provided in section 4.4.5.3.

Kewei Yu

Accepted

The text has been corrected.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

6428

3

4

1496

1497

It is not necessary to mention lime calcination in this decision Ekaterina Imshennik
tree. CO2 emissions from lime production should be accounted
for in 2.A.2 source category Lime production according to
IPCC Guidlines. It should not be accounted for in thiscategory.

ExpertRejected

Appropriate description has been added to Chapter 4.4.5.2. Tier 1
Method: If lime production process at alumina plants has not been
considered at national level, this process shall be considered as source
related to alumina production emission and shall be mentioned indecision tree. It is necessary to check prior collecting data for national
inventory.

6430

3

4

1509

1509

If Tier 2 method makes use of typical industry values for
impurities this values should be provided in the 4.4.5.3
Subsection. Otherwise, the terminology shall correspond withterminology of Equations, where word "impurity" is not used.

Ekaterina Imshennik

Accepted

Tier 2 method has bee removed.

6432

3

4

1509

1511

Too little information about Tier 2 methodology which usually Ekaterina Imshennik
becomes more in demand for inventory compilers than Tier 3.

Accepted

Tier 2 method has bee removed.

4570

3

4

1526

better use 5%

Kewei Yu

Accepted

The text has been corrected.

6440

3

4

1545

1549

Is it possible to use data on amount of carbonates consumed
and corresponding carbon content or carbonate consumption
rate per 1 tonne of alumina produced?

Ekaterina Imshennik

Rejected

it is not possible to use data on amount of carbonates consumed andcorresponding carbon content or carbonate consumption rate per 1
tonne of alumina produced.

6434

3

4

1550

1551

Accepted

An appropriate comment is added to avoid double counting.

6436

3

4

1553

1563

Ekaterina Imshennik
It has already been accounted for in the category 2.A.2. It is
double counting
CO2 emissions from soda ash use are accounted for in category Ekaterina Imshennik
2.A.4b. If soda ash is generated in the production process it isnecessary to know how it is used at the plant and how it isaccounted for by national statistics to avoid double counting.

Accepted

An appropriate comment is added to avoid double counting.

4572

3

4

1557

1560

CNa2Ok? CNa2O?

Kewei Yu

Accepted

The text has been corrected.

68

3

4

1613

1613

Please check the page note 2.

Mingshan Su

Accepted

The text has been corrected.

8688

3

4

1622

1628

There is no tier 1 EF available, which is highly unusual as this Ole-Kenneth Nielsen
would be perhaps the only source covered by the IPCC GL,
where a tier 1 EF is not provided. As this is unlikely to be a
KC, most countries would look to apply a tier 1. Therefore, it isnecessary to present a default tier 1 EF. Also, how would users
assess whether this would be a KC without having a default
EF. Furthermore, the tier 1 methodology as presented inequation 4.27a requires a tier 1 EF.

Accepted

The table with Tier 1 EF is provided.

6438

3

4

1623

1628

Accepted

The table with Tier 1 EF is provided.

6442

3

4

1674

1691

The default emission factors must be provided for Tier 1 (see Ekaterina Imshennik
Instructions to Experts and Authors, para 25, 26 and 41 )It is proposed to inventory compilers to collect plant level data Ekaterina Imshennik
for implementation of Tier 1 methodology. It seems rather likeplant-level Tier 3 approach.

Accepted

The table with Tier 1 EF is provided.

6444

3

4

1693

1720

Ekaterina Imshennik
It is unlikely that the detailed sintering process data arecollected by national statistics. Consequently, there is nopractical difference between Tier 2 and Tier 3 methodologies.
It means that all inventory compilers have to use Tier 3
methodology and plant-level data or the Tier 1 methodology (ifthe default emission factors are provided).

Accepted

Tier 2 method has bee removed.

4574

3

4

1716

better use 5%

Accepted

The text has been corrected.

Kewei Yu

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

8690

3

4

1811

1817

Ole-Kenneth Nielsen

Accepted

The table with Tier 1 EF is provided in section 4.4.5.3.

8692

3

4

1835

1836

Currently, it doesn't make sense to ask inventory compilers tocompare with IPCC default EFs, when no default EFs areprovided!
The reference to section 4.4.3.2 seems to be incorrect.

Ole-Kenneth Nielsen

Accepted

The reference has been replaced to Section 4.4.5.3.

4576

3

4

1946

,as follows:?

Kewei Yu

Accepted

Typo corrected in the text

4578

3

4

1951

1716

3

4

1986

1991

69

3

4

1986

6134

3

4

1718

3

4

61

3

1720

replace carbon dioxide with ""CO2"

Kewei Yu

Accepted

Typo corrected in the text

Virginia Sena

Accepted

Added defition of "MPi"1992

The term MPi for Equation 4.35 is not defined. It may be:
Total metal production for RE metal/alloy typei (tonnes RE metal).
Please define MPi.

Mingshan Su

Accepted

Added defition of "MPi"

1990

1991

MPi not defined.

Jooil Kim

Accepted

Added defition of "MPi"

1994

1994

Virginia Sena

Accepted

Typo corrected in the text

4

206

335

It is written "...the lack of published data means that than
individual.." instead of "...the lack of published data meansthat individual…".
It is better to put this section in Vollume 3(Energy Sector) to
avoid reporting CO2 emssion from coke production in IPPU
sector.

Mingshan Su

Rejected

3

4

2060

2061

The allocation of the emissions between IPPU and Energy has been
agreed and in general terms are consistent with 2006 IPCC
Guidelines. The only difference is related with the allocation of the
fugitive emissions.
Typo corrected in the text

5868

3

4

207

207

9598

3

4

208

208

1152

3

4

208

208

4286

3

4

208

208

1154

3

4

208

209

4886

3

4

2095

2095

Is it normal to use 'recommend' in IPCC Guidelines?

6136

3

4

2096

2097

1722

3

4

2113

2113

4888

3

4

2115

2115

1724

3

4

2115

2115

Virginia Sena
At least one quotation mark is missing in the sentence:"...facilities can refer to this as ‘net anode or net carbon
consumption."
Following line 207, suggest inclusion of information
Vincent Camobreco
discussing off-site coke production CO2 emissions. 2006
Guidelines are very explicit between on- and off-site emissions
and this chapter would benefit from inclusion

Accepted

Raul Salas Reyes
Change "should" to "shall" Where it says "The emissions
should be reported". It will then read as "The emissions shall bereported under the…"
Line 208 and Line 324 read "Energy Sector Category Acii"
Robert Lanza
Line 267, Line 280, and Line 295 read "Energy Sector
Category 1.A.1c" Check for consistency
I suggest that the authors replace "1Acii" by "1A1ci" to be
Naofumi Kosaka
consistent with Table 8.2 in Volume 1.
edit -- "The CO2 emissions should be reported under theRobert Lanza
Energy Sector Category 1.A.1c. Manufacture of Solid Fuels,
and the CH4 emissions should be reported under Category
1.B.1d "Fugitive Emissions

Noted

Accepted

The detailed explanation of the offsite and insite processes will beprivided.

Accepted

The crosscheck of the categories numeration will be provided.

Accepted

The crosscheck of the categories numeration will be provided.

Accepted

The crosscheck of the categories numeration will be provided.

Elsa Hatanaka

Rejected"these are to rare earth industry are currently unavailable,"revise english
It is written "perfromance" instead of "performance".

Jooil Kim

Accepted

There is similar wording in the existing 2006 IPCC GL's for Primary
Aluminium GHG emissions
Wording adjusted

Virginia Sena

Accepted

Typo corrected in the text

This line does not connect to the previous or latter line.
(editorial)
The line has neither start nor end and is not connected withother lines.

Elsa Hatanaka

AcceptedTypo, line has been deleted

Virginia Sena

AcceptedTypo, line has been deleted

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

6138

3

4

2115

2115

Shown in error, erase line?

Jooil Kim

AcceptedTypo, line has been deleted

4998

3

4

2119

2120

In this decision tree one no should be yes: Is this a key category Päivi Lindh-> yes (not no) -> collect process data…

Accepted

Decision tree updated

4580

3

4

2224

6144

3

4

2238

2238

replace carbon dioxide with ""CO2"

Kewei Yu

Accepted

Change madeJooil Kim"aluminium" production? Did the authors mean "rare earth
metall/alloy" production instead?
Jooil Kim
As the authors acknowledge, there is a severe lack ofmeasurements regarding emissions in the rare earth industry,making it difficult to provide clear guidelines for estimating
GHG emissions from these processes. On the other hand, andas with the LVAE emissions in the aluminum industry, I
believe these IPCC guidelines can provide an important firststep. As such, I would stress that future efforts are necessary to
improve these methods as more data becomes available.

Accepted

Change made

6146

3

4

2239

2239

Noted

Comment only, no changes made since none requested

1698

3

4

227

227

Reference to Table 4.1 is not correct. The correct one is Table Virginia Sena
4.3.
It is written "...facility CO¬2 emission factors..." instead of "… Virginia Senafacility CO2 emission factors…".
Correct "CO-2" with proper subscript
Jooil Kim

Accepted

1726

3

4

2293

2293

6140

3

4

2293

2293

6142

3

4

2331

2332

Table 4.30: Include separate reporting of CF4 and C2F6
emissions in the table, as suggested in lines 2324-2325.

3332

3

4

235

236

9600

3

4

235

236

1318

3

4

2351

2352

1320

3

4

2357

2358

Accepted

Change madeAccepted

Change madeAccepted

This comment was already addressed in the FOD text, however, theTable now has some adjusted wording to clarify thisVeronika Ginzburg
Table 4.1A Tiers 1b, 2 and 3 are not consistent with Energy
Sector. Methodology provided in energy sector is based on theamount of COG combusted as fuel. Use of simplified cokebalance approach will lead to high uncertainties, becauseamount of coal consumed for coke production is usually notincluded in statistics and could be only roughly evaluated. In
additional, carbon content in coal as well as in coke could vary
for different coal types.

Accepted withmodification

The Tiers 1b, 2 and 3 approaches will be revised.

Is it possible to elaborate under Tier 3, what does "quality ofRaul Salas Reyes
carbonaceuous materials" means in this case? Also, an
equation supporting the Tier 3 method would increase theclarity of this Tier.
Robert LanzaFor EEA 2016 clarify in the citation which section(s) of theguidebook were used.
The full reference for the JRC 2013 document is: JRC
Robert Lanza
Reference Report:Best Available Techniques (BAT) Reference
Document for Iron and Steel Production, Industrial Emissions
Directive 2010/75/EU (Integrated Pollution Prevention andControl), Rainer Remus, Miguel A. Aguado-Monsonet. Serge
Roudier, Luis Delgado Sancho, 2013

Accepted withmodification

The detailed explanation will be provided.

Noted

The list of literature is subject to change and will be formatted in the
final draft
The list of literature is subject to change and will be formatted in the
final draft

Jooil Kim

Noted

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

1322

3

4

2359

2360

The full reference for EPA Office of Air and Radiation (OAR) Robert Lanza
2008 document is: TECHNICAL SUPPORT DOCUMENT
FOR THE IRON AND STEEL SECTOR: PROPOSED RULE
FOR MANDATORY REPORTING OF GREENHOUSEGASES Office of Air and Radiation U.S. Environmental
Protection Agency September 9, 2008

ExpertNoted

The list of literature is subject to change and will be formatted in the
final draft

1324

3

4

2364

2365

Noted

The list of literature is subject to change and will be formatted in the
final draft

1326

3

4

2367

2367

The full reference for EPA Office of Air Quality Planning and Robert Lanza
Standards (OAQPS) 2012 document is: Available andEmerging Technologies for Reducing Greenhouse Gas
Emissions from the Iron and Steel Industry Prepared by the
Sector Policies and Programs Division. Office of Air Quality
Planning and Standards. U.S. Environmental Protection
Agency. September 2012.
There are several PDF documents on the ThyssenKrupp
Robert Lanza
Industrial Solutions coke plant technologies website; clarify
which documents were used.

Noted

The list of literature is subject to change and will be formatted in the
final draft

1156

3

4

239

239

Footnote "1" is inherent to the text description and should not
be a footnote; incorporate footnote text into the main text;
check spelling of "coqueification"

Robert Lanza

Noted

62

3

4

241

241

repeated comma.

Mingshan Su

Noted

1700

3

4

241

241

Typing error: "coke, , ascension pipes, coke pushing…" instead Virginia Senaof "coke, ascension pipes, coke pushing…"

Noted

8670

3

4

241

241

Accepted

1158

3

4

242

242

Footnote 2 references IPPC 2013. However, this is referenced Ole-Kenneth Nielsen
differently in the list of references.
delete "difficult to quantfy" -- Line 551 refers to fugitive CH4 Robert Lanzaemissions data from coke production stacks and coke ovenquenching towers; indicate here that emission factors for cokeoven fugitive CH4 emissions have been developed based on
direct measurement data.

1160

3

4

242

242

9616
8668

3
3

4
4

249
251

1164

3

4

3334

3

5184

3

Accepted withmodification

Robert Lanza

Noted

249
255

"coke , ascension" -- missing word here? Or close up comma
spacing.
I suggest that the authors replace "4.3.3" with "4.3.2.2".
A reference is made that methodologies for estimating flaring
from metal production are included in Volume 2 Chapter 2.
This does not seem to be correct. This should be clarified.

Naofumi Kosaka
Ole-Kenneth Nielsen

Noted
Accepted withmodification

254

254

[check "Volume 2 Chapter 2"

Robert Lanza

Accepted withmodification

4

254

255

Veronika Ginzburg

Noted

4

257

258

Emissions from flaring process considered as fugitive. The
methodology should be provided in Volume 2 chapter 4 (seeVol2_Ch4_FOD table 4.3.4)
footnote 1: …recovery technology…

Kari Grönfors

Noted

The list of literature is subject to change and will be formatted in the
final draft
The detailed explanation will be provided.

The clarification between Energy and IPPU sectors required.

The fugutive emissions concidered as a part of Volume 2.
Methodology for the flaring process emissions will be provided in theVolume 3.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

3336

3

4

258

335

Veronika Ginzburg
Production based method can be used only as verification
approach to ensure that carbon balance is kept. Whilemethodology provided in the Energy sector (vol.2 ch.2) should
be used to estimate the corresponding GHGs emissions. See
also comments for lines 235-236, table 4.1A. The same is forTier 2 and Tier 3.

ExpertRejected

The allocation of the emissions between IPPU and Energy has been
agreed and in general terms are consistent with 2006 IPCC
Guidelines.

4538

3

4

26

27

CO2 subscript, check other places

Accepted

Edited text

1702

3

4

261

261

Accepted withmodification

The CH4 default emission factors will be reviewed.

63

3

4

262

269

The reference to Table 4.1 is not enough, since Table 4.1
Virginia Sena
contains only default emission factors for CO2. Reference toTable 4.2 (containing CH4 default emission factors) is alsoneeded.
It is better to describe the two equations in 2 separate
Mingshan Su
paragraphs. For example Equation 4.1(a) and Equation 4.1(b).

1704

3

4

266

266

Taking into account the units for the default emission factors Virginia Senain Table 4.1 (tonnes CO2/ tonnes coke production) the unit forCO2 emissions should be "tonnes" instead of "kg".

Accepted

6410

3

4

266

269

Accepted

3338

3

4

267

267

Units for emissions, emission factors and activity data should Ekaterina Imshennik
correspond each other
It is not right. COG could be combusted in different categories Veronika Ginzburg
of A1 (1A1a - energy industry, main heat and electricity
production; 1A1cii - manufacture of solid fuels; 1A2c chemical industry; 1A2a - iron and steel; and other industries,etc.) and accordingly emissions also could be reported indifferent categories

1166

3

4

267

267

1706

3

4

269

269

6414

3

4

271

309

1168

3

4

272

272

Kewei YuLine 208 and Line 324 read "Energy Sector Category Acii"
Robert Lanza
Line 267, Line 280, and Line 295 read "Energy Sector
Category 1.A.1c" Check for consistency
The units and the reference Table for CH4 emission factor are Virginia Sena
incorrect. The line should be: " EF = emission factor, tonnes
CO2 / tonne coke production (Table 4.1) or kg CH4/ tonnecoke prodcution (Table 4.2).
Ekaterina Imshennik
There is an inconsistency between Tier1b and Tier2. Using
Tier1b we account for all coke oven gas and all coke oven byproducts combusted. No other fuels used for coke production
are accounted for. Using Tier2 we account only for coke ovengas combusted in coke production process. We consider thatcoke oven by-products are transferred offsite and are not
combusted in the process. We also account for some other fuelsconsumed (combusted) such as natural gas, blast furnace gas
and so on. It meens that we estimate different emission sources
using these two methodologies. In my opinion, it may cause
doublecounting or omission of CO2 emissions.
Edit to "…all of the recovered coke oven byproducts…"

Robert Lanza

Noted

Rejected

The equation 4.1 refers to the Tier 1, where it is considered that all
COG is burned in the coke ovens.

Accepted

Accepted withmodification

Accepted withmodification

Accepted

CO2 t/t, ch4 g/t, because of the small amount of ch4 emissions
comparing to the CO2.

Comment ID Volume Chapter From line To line

Comment

6412

3

4

272

273

1170

3

4

295

295

1172

3

4

297

298

Ekaterina Imshennik
According to equation 4.1A, all coke oven gas and all cokeoven by-products are combusted. Only metallurgical coke is
not combusted. The amount of carbon contained in this byproducts is not deducted Only metallurgical coke is not
combusted. The amount of carbon contained in this byproducts is not deducted from the amount of carbon in raw
material. There is a contradiction between the equation 4.1.A
and the phrase " Tier 1b assumes that all of coke oven byproducts are transferred off site"!
Line 208 and Line 324 read "Energy Sector Category Acii"
Robert Lanza
Line 267, Line 280, and Line 295 read "Energy Sector
Category 1.A.1c" Check for consistency
Clarify definition of PM(a) = "quantity of other process
Robert Lanzamaterial (a) not listed as a separate term in Equation 4.2A,
consumed in the country for metallurgical coke production(kg); other process materials used may include natural gas, fueloil, and converter gas."

Expert

1174

3

4

303

303

1176

3

4

305

305

4544

3

4

307

5186

3

4

307

1178

3

4

1180

3

4

1182

3

1184

Response

Authors notes

Rejected

The Tier 1b assumes that the by-products are not burnt at the coke
plant which is consistent with the equation 4.1A.

Accepted

Accepted withmodification

To be rewrite with more clarifications.

Consider including separate variables in Equation 4.2A for
Robert Lanza
discrete coke oven byproducts, e.g., one variable for coal tar, asecond variable for light oil, etc., rather than having only one
variable [COB(b)] in summation; cosider including a separate
variable in Equation 4.2A for flaring.

Accepted withmodification

The equation has been change, dividing byproducts and emissions
from flaring. However, the COB(b) per byproduct were notseparated. In addition, in the caption of the equation, the place where
the emissions from flaring are estimated (the chapter from fugitives
from fuel transformation in the energy chapter,is also indicated).

Identify here the table where the the default carbon contents of Robert Lanzamaterial inputs can be found.
Chapter 2, letter case
Kewei Yu

Noted

307

should be: …Volume 4 chapter 2...

Kari Grönfors

Noted

315

315

"CH4" check subscripts

Robert Lanza

Noted

324

324

Robert Lanza

Accepted

4

325

325

Line 208 and Line 324 read "Energy Sector Category Acii"
Line 267, Line 280, and Line 295 read "Energy Sector
Category 1.A.1c" Check for consistency
Identify in Line 208 that only direct emissions are to bereported in Energy Sector Category 1.A.1c and that fugitive
emissions are to be reported in Category 1.B.1d "Fugitive
Emissions from Fuel Transformation:

Robert Lanza

Accepted

3

4

331

331

"CO2" check subscripts

Robert Lanza

Noted

9602

3

4

332

333

The Figure 4.6 only gives the option to proceed with a Tier 2 Raul Salas Reyes
method if the category is key. Nevertheless, above in lines 212
and 213, it guides the user to chose between a Tier 2 or Tier 3
method if the category is key. I suggest revising the flowchart
so that the question on the key category gives both the options
to proceed with a Tier 3 or Tier 2 method, and describe what
can assist the user in deciding which method to use.

Accepted withmodification

1186

3

4

345

345

Delete comma

Robert Lanza

Noted

1188

3

4

347

347

Clarify what "industry-wide data" are being referred to here

Robert Lanza

Accepted

Noted

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

1190

3

4

372

372

Robert Lanza

Noted

1192

3

4

374

374

edit "national sinter production and national pellet
production..."edit "if the process materials used are known…"

Robert Lanza

Noted

1194

3

4

411

412

Robert Lanza

Noted

1196

3

4

415

416

edit …"considered under Tier 2, including [provide examples
from Section 4.2.2.5 of what other process inputs and outputs
are being referred to here]
This sentence is unclear, either clarify what "othermethodologies" are being referred to, or delete the sentence.

Robert Lanza

Accepted

5870

3

4

415

416

Vincent Camobreco

Accepted withmodification

271

3

4

421

455

Fehmi Par Bekci

Accepted

1198

3

4

435

435

Consider for this variable deleting the "m3" units and casting Robert Lanza
all of the equations in units of GJ and/or tonnes consistent withthe units in the carbon content and heat content tables (e.g.,
Volume 2 Chapter 1 TABLE 1.3 DEFAULT VALUES OF
CARBON CONTENT); or consider including a table of default
values to convert m3 units to tonnes or GJ units.

Accepted withmodification

1200

3

4

439

439

Consider for this variable deleting the "m3" units and casting Robert Lanza
all of the equations in units of GJ and/or tonnes consistent withthe units in the carbon content and heat content tables (e.g.,
Volume 2 Chapter 1 TABLE 1.3 DEFAULT VALUES OF
CARBON CONTENT); or consider including a table of default
values to convert m3 units to tonnes or GJ units.

Accepted withmodification

1202

3

4

445

445

Consider for this variable deleting the "m3" units and casting Robert Lanza
all of the equations in units of GJ and/or tonnes consistent withthe units in the carbon content and heat content tables (e.g.,
Volume 2 Chapter 1 TABLE 1.3 DEFAULT VALUES OF
CARBON CONTENT); or consider including a table of default
values to convert m3 units to tonnes or GJ units.

Accepted withmodification

1204

3

4

447

447

Consider for this variable deleting the "m3" units and casting Robert Lanza
all of the equations in units of GJ and/or tonnes consistent withthe units in the carbon content and heat content tables (e.g.,
Volume 2 Chapter 1 TABLE 1.3 DEFAULT VALUES OF
CARBON CONTENT); or consider including a table of default
values to convert m3 units to tonnes or GJ units.

Accepted withmodification

1206

3

4

449

450

Clarify definition of PM(a) = "quantity of other processmaterial (a) not listed as a separate term in Equation 4.10,
consumed for metallurgical coke and sinter production in
integrated coke production and iron and steel production
facilities (tonnes); other process materials used may include
natural gas and fuel oil."

Robert Lanza

Accepted withmodification

Suggested rewrite of sentence to: "In calculating pellet
production emissions, energy consumption and heating value
and carbon content of the fuel can be used similarly to theother methodologies."
In figure 4.8A it is seen that there is LDG from steel making
process. However the equation 4.9 does not refer to the LDG.

Authors notes

The authors have reviewed this section of text and deleted thissentence as the rest of the guidance presents the method options; thissentence is not needed.

To be rewrited and clarified.

Comment ID Volume Chapter From line To line

Comment

64

3

4

457

460

Accepted

1208

3

4

460

460

4546

3

4

461

Since electricity generation is a typical energy sector activity Mingshan Su
the "emissions from the combustion of blast furnace gas, cokeoven gas and converter gas" "to produce electricity in aninternal power plant to cover the internal needs" is better to bereported under Ehergy Sector.
Clarify "the methodology for that corresponds to…" Clarify
Robert Lanza
what specific method in Volume 2 Chapter 2 is being referredto hereChapter 2, letter case
Kewei Yu

1210

3

4

463

463

Edit -- "combusting fuel (e.g., natural gas)…"Robert Lanza

Noted

1212

3

4

484

484

Edit -- "Equations 4.9 through 4.11 (Tier 2) also describe…"

Robert Lanza

Noted

1214

3

4

491

491

Edot -- "furnace charge"

Robert Lanza

Noted

1216

3

4

495

495

Edit -- "for CH4 emissions…"

Robert Lanza

Noted

1218

3

4

497

497

Accepted

1220

3

4

500

500

Edit -- "There is no Tier 2 method for estimating fugitive CH4 Robert Lanzaemissions."
Edit -- "The Tier 1 method for estimating CH4 emissions
Robert Lanza(Tables 4.12 through 4.14) is based on emission factors andnational production statistics."

1222

3

4

523

524

Edit -- ""This section provides default emssion factors forRobert Lanza
estimating CO2 and CH4 emissions in the Tier 1a method andalso discusses carbon contents to be used in carbon massbalances in the Tier 2 and Tier 3 methods."

Accepted withmodification

1224

3

4

530

530

Noted

1226

3

4

531

532

1228

3

4

534

534

Robert Lanza
Edit -- "typical processes for the BOF, EAF, and OHF
steelmaking methods…"
Edit -- "There are two types of cokemaking processes: theRobert Lanza
byproduct recovery process and the non-recovery process. The
byproduct recovery process recovers the numerous chemical
byproducts of the coke making process. In the non-recovery
process, all of the coke oven gas produced by the process isburned for energy recovery and no byproducts are recovered. ;instead of recovery this process offers the potential for heatrecovery and cogeneration of electricity."
Edit -- "Consequently, the non-recovery ovens do not leak…" Robert Lanza

1230

3

4

539

539

1232

3

4

540

541

Edit -- "only about one-third of the coke oven gas isconsumed…"
Edit-- "stacks and quenching towers from non-recovery andbyproduct recovery processes as well as data from the wide
range of European and Chinese coke ovens whose
variability…"

ExpertResponse

Authors notes

Accepted

Noted

Noted

Accepted withmodification

Accepted but made a different change.The difference is related withthe wording. As as suggested, the paragrph was eddited and thefollowing phrase was included: This section provides default emission
factors for CO2 and CH4 to be used in Tier 1a for coke production
and Tier 1 for iron and steel production, and provides a discussion on
carbon contents to be used in carbon balances approaches at higher
tiers.

Accepted but made a different change.

Noted

Robert Lanza

Noted

Robert Lanza

Accepted

Accepted . We decided to accept this suggestion, without changes

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

6416

3

4

544

545

Table 4.1. First two lines. Why is so great difference between Ekaterina Imshennik
Tier1 emission factors Coke oven Non recovery of byproducts USA 1.23 and Coke oven Byproduct recovery-USA 0.21. The
products' output from coke oven is Coke -73 - 77%, dry cokeoven gas - 15 - 18%, by-products - 5 - 6.5%.

ExpertAccepted withmodification

Default values are re-evalueted for setting a most appropritate one
number with some technical description in the range of values. A
produxction process with implementing a full set of energy-saving
technologies is lowest value in the number.

8672

3

4

544

545

In several cases the process description in Table 4.1 mentions Ole-Kenneth Nielsen
either USA, China or European Countries. It should be
elaborated further what EFs should be considered the default
for countries outside these specified countries. For 'Coke Oven:… European Countries' there is no reference provided, thisshould be corrected. In addition, the range is very narrow and it
seems pointless to have an EF of 0.5103 for plants less than 20
years old and an EF of 0.5170 for older plants. Surely, thisdifference would be within the uncertainty range. For ironproduction, DRI production and pellet production the EFs arereferenced to the 2001 BREF document. However, a revised
version was adopted in 2013. Why has this not been reflected?
Users of the Guidelines would no longer be able to find the2001 BREF document online.

Rejected

Due to availability of published references, at this momment three
countries/region have published appropirate information.

7162

3

4

544

547

Accepted withmodification

Fruehan et al. (2000) "Theoretical Minimum Energies To Produce
Steel for Selected Conditions" js added to the valid reference fordiscussing dafault value for coking porcess and sitering process. (Thereference to be submitted to TSU.)

1234

3

4

545

546

Accepted

Source of data is clearly presented by modification of originaldescriptions.

1236

3

4

545

546

Accepted

Source of data and information are clearly presented by modificationof original descriptions, including correction of published year. (Thereference to be submitted to TSU.)

1238

3

4

545

546

Accepted

Source of data and information are clearly presented by modificationof original descriptions, including correction of published year. (Thereference to be submitted to TSU.)

5188

3

4

545

547

In Table 4.1, the most emission factors are smaller than the
Junichiro Oda
actual typical practice (global average level) except the firstline (1.23 tonne CO2 per tonne coke produced). We shouldrefer to Fruehan et al. (2000), which provides the actual levelsof energy intensity and CO2 intensity.
Edits to Table 4.1 -- First row -- EPA 2008a is "Compilation of Robert Lanza
Emission Factors in AP42"; clarify in the wording of Table 4-1
and in the Section 4.2 reference section that EPA 2012 is theactual referenced document, not EPA 2008a.
Edits to Table 4-1 -- First row -- "Section D.2.5 GHG
Robert Lanza
Emissions from Coke Plants (EPA, 2008a)" of the EPA 2012reference document is on Page D-9 of the reference document;
clarify in the wording of Table 4-1 and in the Section 4.2
reference section that EPA 2012 is the actual referenced
document, not EPA 2008a.
Edits to Table 4-1 -- Second row -- "Section D.2.5 GHG
Robert Lanza
Emissions from Coke Plants (EPA, 2008a)" of the EPA 2012reference document is on Page D-9 of the reference document;
clarify in the wording of Table 4-1 and in the Section 4.2
reference section that EPA 2012 is the actual referenced
document, not EPA 2008a.
Table 4.1 includes probably emission factors for both energy Kari Grönfors
based emissions (coke ovens) and non-energy emissions (otherprocesses). This is slightly confusing, please clarify reporting
categories in table.

Accepted withmodification

Additional information is described in the box for understanding
emissions source and reporting categories, such as IPPU and Energy.

1240

3

4

547

547

Accepted

A reference is clearly identified for the source of data andinformation.

Edits to Table 4.1 -- Fourth row -- identify the reference for the Robert Lanza
values in the Fourth Row

Comment ID Volume Chapter From line To line

Comment

1242

3

4

547

547

1244

3

4

547

547

Edits to Table 4-1 -- Fourth row -- the values in the fourth row Robert Lanza
have commas (EU style), other values in this table havedecimal points (U.S. style); what is the style convention forcommas vs. decimal points?
Robert Lanza
Edits to Table 4-1 -- Fifth row -- the footnote in Table 3.4
Page 96 of the IPPC BAT 2013 reference document reads"Where carbonate iron ores are used, the concentration of CO2
in the waste gas is increased so that the application of EOS
may strongly inhibit the sinter process. The CO2 emissions inplants which do not use carbonate ores average from 161 to
368 kg/t sinter whereas in plants which do use carbonate ores
the average can be up to twice as high." Consider including
two separate default factor entries in Table 4-1 for sinterproduction, one default factor entry for carbonate ores and one
default factor entry for non-carbonate ores, rather thanincluding a range of default factors in one table entry.

ExpertResponse

Authors notes

Accepted

A consistent characters are used with necessary revision.

Accepted withmodification

One number is set for a default value by getting a representing value
through averaging values in literatures, including EU, USA andChina. A default value is for non-carbonate iron ores case with adding
technical information for cabonate iron ores case. (The reference tobe submitted to TSU.)

1246

3

4

547

547

Edits to Table 4-1 -- Twelfth row -- the footnote notation * 1 is Robert Lanzaout of place, there is no corresponding footnote in the list offootnotes at the end of Table 4-1.

Accepted

1248

3

4

547

547

Edits to Table 4-1 -- Twelfth row and fiftteenth row -- both the Robert Lanza
twelfth row (BOF factor) and the fifteenth row (global averagefactor) have an asterisk [*] footnote; the text in the asterisk
footnote at the bottom of the table appears to refer to the global
average factor, not the BOF factor.

Accepted

1250

3

4

547

547

Robert Lanza

Accepted

Corrected for a consistent description.

1252

3

4

547

547

Robert Lanza

Accepted

Corrected for a consistent description.

1254

3

4

547

547

Robert Lanza

Accepted

A consistent characters are used with necessary revision.

1256

3

4

547

547

Robert Lanza

Accepted

Corrected for a consistent description.

1258

3

4

547

547

Robert Lanza

Accepted

Corrected for a consistent description.

1260

3

4

556

556

Edits to Table 4-1 -- footnotes -- the (4) value in the footnotes
has no text associated with it
Edits to Table 4-1 -- footnotes -- Table 4-1 row four and Table
4-1 row five both have the (2) value in the footnotes; there is
no footnote (1) in Table 4-1 row one through row three; itappears from the text of footnote (1) that footnote (1) is
associated with Table 4-1 row four.
Edits to Table 4-1 -- footnotes -- the values in footnote (1)(0,510) and footnote (3) (0,265) at the end of Table 4-1 havecommas (EU style), other values in this table have decimal
points (U.S. style).
Edits to Table 4-1 -- footnotes -- there are three different
notations for footnotes in Table 4-1: numbers (1); asterisks **;and "notes." Consider using a single style for all footnotes inTable 4-1.
Edits to Table 4-1 -- footnotes -- for "not applicable to EAFs
that use pig iron as a raw material" consider describing what
Emission Factors would apply in this situation; the Emission
Factors for pig iron production could be applied to thissituation.
Edit -- "pelletizing"

1262

3

4

557

557

Edit -- "per MJ of Coke Breeze"

Robert Lanza

Noted

Robert Lanza

Noted

Comment ID Volume Chapter From line To line

Comment

8674

3

4

565

566

1264

3

4

566

566

1266

3

4

589

589

1268

3

4

589

589

It is not helpful to have a default EF listed as a range of 1-80
Ole-Kenneth Nielsen
g/tonnes. Without any further guidance, what is the user
supposed to do with this? If no better knowledge is available
the geometric mean could be listed as the default EF and theuncertainty would then reflect the large range.
Edits to Table 4-2 -- First Row -- 1 - 80 is a very wide range
Robert Lanza
for a default factor. The JRC BAT reference document Table
5.2 footnote (13) indicates that this range of 1 - 80 is derived
from data for a single coke plant in the EU. Consider using
additional references or at minimum footnoting the 1 - 80
range to indicate that the range is derived from data for a single
plant.
Edits to Table 4-3 -- footnotes -- there are three different
Robert Lanza
notations for footnotes in Table 4-3 numbers (1); asterisks **;and "notes." Consider using a single style for all footnotes inTable 4-3.
Edits to Table 4-3 -- footnotes -- in citing ISO Standards
Robert Lanza
include the year of publication (edition) of the ISO standard,e.g., ISO 14404-1 (2013); ISO 14404-2 (2013).

1270

3

4

595

595

Edits-- "coke produced is assumed to be…"

Robert Lanza

Accepted

1272

3

4

599

599

Edits -- "usable ingots"

Robert Lanza

Accepted

1274

3

4

603

603

5914

3

4

625

651

Robert Lanza
Edits -- "in addition to the amounts of on-site (in integrated
iron and steel plants) and off-site (in merchant coke plants)
metallurgical coke produced in the country."Due to many countries having different national circumstances Vincent Camobreco
regarding their allocation of fuel data and statistics between theenergy and industrial sector (some data may not be
dissagregated enough to distinguish or allocation fuel data to a
specific industrial category/sector) more discussion should
occur in this section to allow for countries to choose country
specific approaches that make sense for their specificcircumstances. Deviating too much from the 2006 GLs could
result in many countries having to redo their fuel and emissions
relationships between IPPU and Energy, taking up significant
resources that could be used to improve other categories. If a
country can justify their country-specific approach forallocating certain emissions between IPPU and Energy, andtransparently reports this information, some issues may still
occur in terms of comparability but overall adjustment could
be avoided that would reduce the overall accuracy ofemissions. This could be a point across more of the IPPU
chapter, rather than specific to the Iron and Steel chapter.

1276

3

4

627

627

Edits -- "in integrated iron and steel plants, these processes
may be connected to each other…" [for merchant plants theseprocesses would not necessarily be connected to each other.]

ExpertRobert Lanza

Response

Authors notes

Accepted

Accepted withmodification

Accepted

Corrected for a consistent description.

Accepted

Accepted

Rejected

Accepted

The allocation of the emissions between IPPU and Energy has been
agreed and in general terms are consistent with 2006 IPCC
Guidelines. The only difference is related with the allocation of the
fugitive emissions.

Comment ID Volume Chapter From line To line

Comment

1278

3

4

629

629

65

3

4

639

640

Edits -- "risk of double counting of emissions or omission ofRobert Lanzaemissions."
Combustion of blast furnace gas, coke oven gas and converter Mingshan Su
gas for sintering is mainly for energy purpose and it is better tobe reported in Energy sector.

Expert

1282

3

4

639

651

66

3

4

644

648

Clarify that these bullet points refer to CO2 emissions; as does Robert Lanza
the introductory paragraph above; add a paragraph clarifying
how CH4 emissions are to be reported.
The emissions from the combustion of blast furnace gas, coke Mingshan Suoven gas and converter gas to produce electricity in an internal
power plant should be reported in Energy sector even if theelectricity is produced to cover the internal needs since
producing electricity is for energy purpose and it is a typicalenergy sector activity.

Response

Authors notes

Accepted

Accepted . We decided to accept this suggestion, without changes

Rejected

The allocation of the emissions between IPPU and Energy has been
agreed and in general terms are consistent with 2006 IPCC
Guidelines. The only difference is related with the allocation of the
fugitive emissions.

Accepted

Rejected

The allocation of the emissions between IPPU and Energy has been
agreed and in general terms are consistent with 2006 IPCC
Guidelines. The only difference is related with the allocation of the
fugitive emissions.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

5106

3

4

644

648

The sentence: "…The emissions from the combustion of blast Kristina Juhrich
furnace gas, coke oven gas and converter gas to produce
electricity in an internal power plant should be reported
under…" should be changed into: "…The emissions from the
combustion of blast furnace gas, coke oven gas and convertergas to produce electricity in an internal power plant can bereported under Energy." The line 646 - 648 should be deleted.
It's not practical to distinguish between public and industrial
electricity generation. Most of the industrial plants feed into
the public network. Several public power plants provide
industrial plants with electricity and heat. Besides theownership of the plants changes regularly. Usually a mix ofderived gases and natural gas is used for power plants andboilers. The natural gas used in the same plant has to bereported in the Energy sector. According to the Guidelines theuse of derived gases of a refinery is considered as combustion;
the use of derived gases in an iron and steel power plant is
considered as a process. This is too confusing. It would be
more practical to follow the structure of the national and the
IEA energy balance were derived gases are considered as asecondary fuel that is used for energy purposes. A power plant
is a power plant. For the calculation of other greenhouse gases
and precursors it is necessary to consider the power plant as aunit in order to calculate fuel related emission factors. A
different calculation method for CO2 increases the complexityof the inventory, which is always a source of errors. Emissions
are not comparable. Fuel related implied emission factors arecomparable. For the review process a carbon balance isnecessary. It's not a problem to summarize 1.A.2.a and 2.C.1
emissions for the review processes. The complete allocation to
IPPU is useful for some countries depending on the data
availability and structure. For other countries it's more practicalto allocate emissions to the energy sector. The increase offlexibility regarding the allocation methods of the Guidelines
does not harm. It would facilitate the work of inventory
compilers and review experts. Moreover, it would make sense
to reflect reality in the Guidelines (see attached file).

ExpertRejected

The allocation of the emissions between IPPU and Energy has been
agreed and in general terms are consistent with 2006 IPCC
Guidelines. The only difference is related with the allocation of the
fugitive emissions.

1280

3

4

648

648

Addition -- "in situations where some of the electric power
Robert Lanza
produced is used within the plant to meet plant needs and someof the electric power produced is exported to the grid or otherfacilities, emissions would be reported separtely in IPPU and in
Energy based on the amount of electricity used within the plant
and the amount of electricty exported.

Rejected

The allocation of the emissions between IPPU and Energy has been
agreed and in general terms are consistent with 2006 IPCC
Guidelines. The only difference is related with the allocation of the
fugitive emissions.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

8676

3

4

651

651

It is stated that emissions from flaring should be reported under Ole-Kenneth Nielsen
energy. However, currently the guidance in the energy sector isfor 'fugitive emissions from oil and natural gas systems'.
Therefore, more guidance should be provided on specificallywhere the emissions should be reported (considering that only
oil and natural gas is used in the energy sector) and also what
methodology should be used, i.e. what EFs should be used.

ExpertAccepted withmodification

The section on "Relationship to the Energy Sector" has been revised
to explain more clearly that the flaring emissions associated with cokeproduction should be reported under Energy (with a cross-reference tothe new Energy-fugitives guidance in Volume 2), whilst the emissionsof flaring of other process gases in I&S production should be reported
in IPPU. In both the Energy and IPPU volumes, the appropriate
methodologies and EFs are presented.

5872

3

4

653

654

Accepted withmodification

The Figure 4.8A has been revised to provide a clearer graphic toexplain good practice reporting allocations, and further the LAs haveprovided references to the figure within the surrounding explanatory
text.

9618

3

4

656

681

Recommend providing greater discussion or at least a
Vincent Camobreco
footnote/description that better explains Figure 4.8A, as it issomewhat confusing, even with the text provided between lines
632 and 651
I understand that ISO 14404 does not distinguish the emissions Naofumi Kosaka
between energy and IPPU sectors. However, I read thedescription of lines 678 through 681 as if ISO 14404
distinguishes the sectors. I understand that ISO 14404 also take
into account the emissions from generation of electricity andheat purchased from outside the iron and steel industry while
the IPCC Guidelines deal with the emissions under energy
sector. As I am not familiar with the ISO, I suggest that theauthors recheck facts. It is important to show how theboundaries are different between the IPCC Guidelines and ISO
14404.

1284

3

4

659

660

Noted

1286

3

4

665

665

1288

3

4

669

669

Edits -- "The World Steel Association established such a
Robert Lanza
method in 2007"
Edits -- in citing ISO Standards include the year of publication Robert Lanza(edition) of the ISO standard, e.g., ISO 14404-1 (2013); ISO
14404-2 (2013).
Clarify -- "basic imports and exports" means "primary inputs to Robert Lanza
the plant and primary outputs from the plant?"

1290

3

4

676

676

Clarify -- meaning of "free allocation"

Accepted

1292

3

4

678

678

5408

3

4

678

679

Edits -- in citing ISO Standards include the year of publication Robert Lanza(edition) of the ISO standard, e.g., ISO 14404-1 (2013); ISO
14404-2 (2013). Also indicate whether this refers to ISO
14404-1 (2013) and/or ISO 14404-2 (2013); they are two
separate standards.
Takashi Morimoto
On line 678, it is written that "There is a difference between
2019 Guidelines Refinement and ISO 14404, related with CO2emissions allocation between IPPU and Energy sectors". The
ISO 14404 methodology is being used in many countries and it
seems to be more appropriate for CO2 and energy managementin the iron and steel industry. Taking it into account, the ISO
14404 methodology should also be applicable for national
GHG inventory if the explanation that the methodology appliedis scientifically reasonable and double counting or omission
has not occurred is provided in the NIR.

Robert Lanza

Accepted

Accepted

Accepted

Accepted

Accepted withmodification

Accepted . We decided to accept this suggestion, without changes

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

1294

3

4

678

680

Robert Lanza
related to the allocation of CO2 emissions to the IPPU and
Energy sectors. According to the ISO Standards CO2
emissions from metallurgical coke producrtion, sintering, blast
furnace, direct produced iron production, steel production, andreheating furnaces and rolling are all reported under Energy,
and only the CO2 emissions from limestone and dolomite use
are reported under IPPU.

ExpertAccepted withmodification

The allocation of the emissions between IPPU and Energy has been
agreed and in general terms are consistent with 2006 IPCC Guidelines
and could not be changed in the Refiniment (there is no mandate).

5874

3

4

679

679

Noted

1296

3

4

688

688

1298

3

4

688

689

1300

3

4

694

695

It is unclear to me what this sentence means, specificall "as in Vincent Camobreco
the last one"
Edits -- "from any general energy statistics (e.g., natural gas
Robert Lanza
consumption for iron and steel production) if they are included
there.
Edits -- "Iron can also be produced in other types of ironRobert Lanza
making processes besides blast furnaces, such as direct reducediron processes…"
Consider expanding this discussion to indicate that it isRobert Lanza
desirable to report use of limestone and dolomite in iron andsteel making under iron and steel, and not under the minerals
sector, if sufficient data are available to report limestone anddolomite use under iron and steel making.

1302

3

4

707

708

1304

3

4

713

713

1306

3

4

714

714

5876

3

4

715

5878

3

4

1308

3

4

1310

3

1312
9620

Noted

Accepted

Accepted . We decided to accept this suggestion, without changes

Rejected

This is out of the IPCC Refinement Authors Mandate.

Edits -- "Process emissions should include all carbon inputs to Robert Lanza
the blast furnace.In a typical integrated iron and steel plant
adjustiments may need to be made…"

Accepted withmodification

The emissions calculation for the typical integrated iron and steel
plant will be reviewed.

Noted

715

Edits -- "assumes an average mix of fuels use, including coke Robert Lanzaoven gas, blast furnace gas…"
Edits -- "On the other hand, Tier 2 and Tier 3, which are based Robert Lanzaon the carbon balance approach..."Believe this meant to say "combined use"
Vincent Camobreco

Noted

717

717

Believe this meant to say "combined use"

Noted

720

720

4

733

733

Robert Lanza
Consider adding a more explict recommendation not to mix
tiers unless necessary.
Consider adding here that emissions from electricity generation Robert Lanzaand consumption are treated as part of the Energy sector, not
IPPU.

3

4

735

735

Edits -- "Although the OHF process…"

Robert Lanza

Noted

3

4

747

748

The uncertainty of tier 1 default emission factor is 25% in the2006 IPCC Guidelines but 40% in the 2019 Refinement. Itmeans the 2006 IPCC Guidelines underestimate theuncertainty. It is desirable to describe reasons of the change.

Naofumi Kosaka

Accepted

1314

3

4

749

749

Edits -- "+/- 10 percent"Robert Lanza

Noted

1316

3

4

752

752

9594

3

4

766

Edits -- Table 4.4 -- provide references / sources forRobert Lanza
uncertainties in Table 4.4.
In Section 4.3 (Ferroalloy production), it is recommended that Mingming Wang
IPCC provides methodologies to account for relevant GHG
emissions from production of Fe-Vanadium, Fe- Molybdenum
and Fe-Titanium alloys.

Vincent Camobreco

Noted

Accepted
Accepted withmodification

Noted
Noted

The allocation of the emissions between IPPU and Energy has been
agreed and in general terms are consistent with 2006 IPCC
Guidelines. The only difference is related with the allocation of the
fugitive emissions.

The list of literature is subject to change and will be formatted in the
final draft.
No action can be taken because comment is out of scope of the 2019
Refinement.

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

5000

3

4

774

774

Christopher Bayliss

Accepted

Edited text

5002

3

4

775

775

replace with "This section covers emissions from primaryaluminium production processes, including..."replace "ore" with "refining"

Christopher Bayliss

Accepted

Edited text

5004

3

4

777

778

replace with "Primary aluminium production typically begins Christopher Bayliss
with the mining of aluminium containing ores (bauxites). Most
bauxite is refined through the Bayer Process, which thermochemically extracts aluminium oxide (alumina) from the ore."

Accepted

Edited text

5006

3

4

785

785

replace with " Alumina is reduced to molten aluminium metal
via the electrolytic Hall-Héroult Process."

Christopher Bayliss

Accepted

Edited text

5008

3

4

786

786

insert "can" between "cells" and "differ"

Christopher Bayliss

Accepted

Edited text

5010

3

4

787

791

Christopher Bayliss

Accepted withmodification

Included some comments on noteworthy changes in production in text

5012

3

4

792

792

would be interesting and useful to include the (current) global
production split between technologies (%), but also what thislooks like compared to 2006
delete "lines operating with"

Christopher Bayliss

Accepted

Edited text

9542

3

4

792

800

New technologies types : The definitions must be precise
because they will eventually be included in the regulations. Is
the term «anode» refer to the anode block or the anodic set ?

Nadia Morais

Accepted withmodification

Decision to remove reference to anodes as decided not best defining
factor. Focus to remain on amperage.

5524

3

4

792

803

Christine Dubois
The technology named CWPB Centre-worked Prebake is
proposed to be divided in 3 technologies: PFPB L, PFPB M,
PFPB MW.
It is not clear which category will it be for older cell desingsoriginally for line current around 300KA (<350KA) when they
were started and are operating now or in the near future withline current over 350KA and for some of them over 400KA. It
is the same situation for AP18 technology which was operated
at 180KA and can be operate now at more than 230KA. The
definition must include those cell operation. Free allowancecalculation are based on technology performance and it isimportant to cover all technology in operation at this moment.
CO2 free allowance is based on technology for some countries.
The new categories must be well defined to avoid any
confusion on a regulation compliance perspective.

Accepted withmodification

The comment was not adressed directly but there was a redefinition of
the PFPB L, PFPB M, and PFPB MW definition which should reducethe confusion. Additionnally, there was modifications in the time
consistency section which should minimize confusion to evaluate
2017 and back emissions.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

6106

3

4

792

803

Noted

No action needed

5014

3

4

794

796

Accepted

Edited text

5016

3

4

810

810

Christine Dubois
For Cap-and-Trade System for greenhouse gas emission
allowances - Amendment in Québec, the CO2 free allowance
will be given based on SWPB and CWBP from 2021. Between
2013 and 2020, the free allowance is given based on prebake(CWBP and SWPB) and based on Söderberg. Until 2021, there
is no difference of free allowance given no matter the prebake
CWPB. Specifying three prebake technology CWPB, thealuminium sector will need precised definition as it could beconsidered by governement in future modification in theircarbon regulation. The data available need to demonstrate there
is difference between CWPB L and M. The regulation for 20212023 free allowance is "Order in Council 1125-2017" isattached. At page 75/117 of this document, the free allowanceto establishment covered prior to 2021 that is not consideredon a sectoral basis or establishment producing lime or liquidaluminum using a side-worked prebaked anode technology
indicaes the rules to calculate the free allowance . Free
allowance for prebaked CWPB is indicated at page 88/117.
Splitting the CWPB technology could have an impact on
further regulation and definition must represent the actual
operation.
replace with "...new cell technologies that operate at line
Christopher Bayliss
currents in excess of 350kA and/or with 24 or more anodes percell (including: AP3x, AP4x, APXe/AP60, EGA DX andDX+);"
replace "re-establish" with "increase rapidly"
Christopher Bayliss

ExpertAccepted

Edited text

5018

3

4

814

815

Accepted

Edited text

5020

3

4

821

822

Accepted

Edited text

4548

3

4

824

Christopher Bayliss
replace with "...where anode effects are terminated primarily
through manual operator intervention, which can result inhigher PFC emissions."
replace with "Emissions of the perfluorocarbons (PFCs)
Christopher Bayliss
tetrafluoromethane (CF4) and hexafluoroethane (C2F6) during
process upset conditions known as "anode effects" (forwhich..."
SO2, subscript
Kewei Yu

Accepted

Edited text

67

3

4

824

824

2 and 6 in SO2 and SF6 should be in subscript.

Mingshan Su

Accepted

Edited text

5022

3

4

824

824

quantify - possibly using 2015 LCI data from IAI

Christopher Bayliss

Rejected

5024

3

4

824

824

Christopher Bayliss

Accepted

5026

3

4

824

824

replace with "Also emitted are smaller amounts of carbon
monoxide (CO), sulfur dioxide (SO2) and non-methane
volatile organic compounds (NMVOC)."...and throughout, ensure numeric subscripts for molecules

Volumes are greater than PFC but impact is lower - have modified
text to make this clear. Including quantities could cause confusion.
Edited text

Christopher Bayliss

Accepted

Edited text

6118

3

4

824

824

Subscripts for "SO2" and "SF6"

Jooil Kim

Accepted

Edited text

5028

3

4

824

826

replace with "Sulfur hexafluoride (SF6) is not emitted during
the electrolytic process and is only rarely used when fluxing
specialized, high magnesium aluminium alloys, from whichsmall quantities can be released as fugitive emissions."

Christopher Bayliss

Accepted

Edited text

5030

3

4

830

830

delete "at a minimum level"

Christopher Bayliss

Accepted

Edited text

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

6120

3

4

837

837

subscript "CO2"

Jooil Kim

Accepted

Edited text

5526

3

4

837

839

Section 4,4,2,1: there is no refinement proposed. For the anode Christine Dubois
consumption calculation, To apply Equation 4,21, we need thesulphur and ash analized to calculate the CO2 emissions
coming from the anode consumption. For Europe primaryaluminum smelters, they have to comply with the
COMMISSION REGULATION (EU) No 601/2012 (21 June2012), in this regulation, for calculation they used the carbon
content for mass balance methodology as required for the CO2
coming from anode consumption. Could it be considered to
add a second formula for this section for the site that have totake the carbon content instead of sulphur and ash content?

Noted

No action can be taken because the comment is out of scope of the2019 IPCC Refinement.

6122

3

4

841

841

subscript "CO2"

Accepted

Edited text

5032

3

4

849

849

insert "cell" between "causes" and "voltage"

Christopher Bayliss

Accepted

Edited text

5034

3

4

850

850

replace with "...operating range. However, PFC gases..."Christopher Bayliss

Accepted

Edited text

5528

3

4

851

856

section 4,4,2,3 - General comment: HVAE is defined when the Christine Dubois
voltage is higher than 8 volts and LVAE is when the voltage islower than 8 volts. There is no indication from when AE
should be measured specifically for pot start. Some primaryaluminium smelters is measuring AE from the moment the pot
has power (without any bath or alumina), some when bath isadded in the pot, some when alumina is added in the pot as
example. This difference could be important when we calculate
the annual AE (min/cellday).

Accepted

An additionnal section was included in the SOD specifically to
discuss the best practices regarding HVAE from pot start-up

Jooil Kim

5036

3

4

855

855

replace "and" with "with consequent"

Christopher Bayliss

Rejected

Edited text in response to another comment and removed 'and'

5402

3

4

855

856

Needs rewriting, as it is now it is a bit confusing

Ole KjosAccepted

Edited text

4550

3

4

857

80% by weight

Kewei Yu

Accepted

Edited text

5038

3

4

861

861

replace "identified based on" with "characterised as"

Christopher Bayliss

Accepted

Edited text

5040

3

4

861

861

delete "of"Christopher Bayliss

Accepted

Edited text

5042

3

4

862

862

replace "similar" with "more"

Christopher Bayliss

Accepted

Edited text

5044

3

4

865

865

replace "were" with "have been"

Christopher Bayliss

Accepted

Edited text

5530

3

4

866

868

Accepted

Edited text

5046

3

4

875

875

It is written "These LVAE emissions have been largely omitted Christine Dubois
from inventories to date but are nonetheless likely to be
widespread and as such, methodologies are now included as toensure GHG inventories are as complete as possible". Since wehave gotten more information with PFC samplingmeasurements since 2010, we would suggest changing thewording to: "LVAE emissions have not been considered fromthe inventories to date, because the information was notavailable, but should now be included to ensure GHG
inventories are as complete as possible"
insert "emissions" between "PFC" and "should"
Christopher Bayliss

Accepted

Edited text

5048

3

4

878

878

delete "in turn"Accepted

Edited text

Christopher Bayliss

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

5536

3

4

881

884

Accepted

Edited text to reflect that if T2 overvoltage was being used, then bestpractice is to switch to slope

5538

3

4

885

894

Accepted

Edited text

5050

3

4

886

886

4.4.2.3 CHOICE OF METHOD FOR PFCS: it is written "In Christine Dubois
the 2006 IPCC Guidelines, two methods for calculating
coefficients for HVAE PFCs were outlined: slope andovervoltage. The overvoltage method is not widely usedanymore so this update will cover the methods with reference
to the slope model only. If the overvoltage method is still used,
it should be adopted at the Tier 3 level only". 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.
It is said that there is currently no generally recognized means Christine Dubois
to calculate LVAE CF4 emissions from the process control
data and that the most accurate approach to date is tocontinuously measure both LVAE and HAVE emissions,which are not practiced regularly. It should be emphasized thatthe initial approach to calculate LVAE from HVAE is a firstattempt to estimate total emissions to include LVAE innational inventories. However, further work is needed tostandarize the measurement, estimate the frequency ofmeasurements and calculation of the LVAE emissions, which
can be very low for measurement technologies and canintroduces inaccuracies if guidelines are not followed. In
addition installation of measurement technologies can also bevery expensive.
insert comma after "factor"
Christopher Bayliss

ExpertAccepted

Edited text

5052

3

4

886

887

sentence unclear - suggest remove "respectively"

Christopher Bayliss

Accepted

Edited text

5054

3

4

890

890

"to measure continuously"

Christopher Bayliss

Accepted

Edited text

5056

3

4

891

892

Accepted

Edited text

6124

3

4

892

894

Accepted

Edited text

5532

3

4

902

903

replace with "Moreover, there is currently no official
Christopher Bayliss
methodology to standardise the measurement of LVAE PFC
emissions at this time."
Comment: I support the authors' comments regarding our
Jooil Kim
current limited understanding of LVAE PFC emissions, andthat research has shown the emissions are important enough towarrant at least some "first step" efforts. It is highly
recommended that this subject is revisited in the near future,when more data becomes available and these processes are
better understood.
Christine Dubois
It is indicated that high performing facilities are those that
operate with less than 0,02min/cellday which is very low.
Because AE may not be measured exactly based on the same
parameters (including pot start and from when) and sincealuminium smelter may not have the same constraint likecurtailment and power modulation period from power supplier,a suggestion would be to indicate the 20percentile on annual
result.

Rejected

A percentile approach would involve annual recalculation and changeof the definition

6126

3

4

903

911

Rejected

Relates to wider discussion on IPCC coefficient determination andnot sector specific

Question: Do regulations or specific guidelines exist to ensure Jooil Kim
that the coefficients are robust? Perhaps they should bereiterated here?

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

5058
5060

3
3

4
4

907
914

907
914

delete comma after "or", insert comma after "curtailments"
lowercase "method" to replace "Method"

Christopher Bayliss
Christopher Bayliss

Accepted
Accepted

Edited text
Edited text

5062

3

4

923

923

replace "are" with "is"Christopher Bayliss

Accepted

Edited text

5064

3

4

928

996

Accepted

Edited text

5066

3

4

938

938

should ECF4 be written HVAE ECF4 to remain consistent with Christopher Baylisslabelling or LVAE ECF4 in, for instance, line 952
replace "types" with "type i" (as 936 and 937)
Christopher Bayliss

Accepted

Edited text

5068

3

4

942

943

Christopher Bayliss

Accepted

Edited text

5070

3

4

945

945

use acronyms for SWPB, HSS and VSS (also maintainconsistency in order - here and line 920 swaps VSS and HSS
from the order they are listed in lines 802-803)
replace "are" with "is"Christopher Bayliss

Accepted

Edited text

5072

3

4

964

964

insert "emissions" between "effect" and "and"Christopher Bayliss

Accepted

Edited text

5534

3

4

971

972

It is written: "Equation 4.27 should be used when anode effect Christine Dubois
minutes per cell day are recorded". It refers to Equation 4.27
but this equation is missing in the revised document Chapter 4
Metal industry emissions (IPCC2019 refinement). In the actual
document (IPCC 2006), Equation 4,27 refer to the PFC
emission by overvoltage method. (Tier 2 and Tier3 method).

Accepted

Edited text

5074

3

4

974

974

remove "Then"

Christopher Bayliss

Accepted

Edited text

5076

3

4

979

979

is "represents" the right word?

Christopher Bayliss

Accepted

Edited text

5078

3

4

991

992

"HVAE emissions of..."Christopher Bayliss

Accepted

Edited text

5080

3

4

993

993

Accepted

Edited text

5082

3

4

996

996

Tier 2 would use SCF4,i - slop coefficient by cell type i for
Christopher Bayliss
CF4, though the same calculation (without i) would be used forTier 3...i dont know if this might confuse reader...way throughmight be similar as expressed in 1025-1026"weight fraction of HVAE C2F6/HVAE CF4..."
Christopher Bayliss

Accepted

Edited text

9544

3

4

997

998

Edited text

2516

3

6

7448

3

6

104

107

Jennifer Politsch
The pretense of this text in yellow seems ambiguous.
Conditions for formation of NH3 should be linked to the input
chemistry as in all other condtions manufacturer should certifythat they are setup to not emit N2O. Formation of CF4 should
be only from input chemicals and not as a function of how thedevice is setup. the manufacturer should be including this in
the certification process. If device is setup for example to abate
N2O at the expense of forming CF4 than facility should
establish site specific factors. Developing language or
calculationson speicfic fuel/O2 ratios seems onerous and would
be dependent on every use case.

10172

3

6

104

107

Greenhouse gas combustion emissions factors are define in
40CFR98 Subpart C. The IPCC volume 2 has a combustion
section.

Add the Overvoltage Coefficient equations (Équation 4.27
from the IPCC 2006) for the Tier 3 overvoltage users.

Nadia Morais

Accepted

Chapter needs proof-reading.

Anna Mikis

Accepted

Tina Gilliland

Rejected

Noted

Agree that clarification is needed and that a suitable reporting
approach still must be devised.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

7450

3

6

117

117

Jennifer Politsch
Is any country using Tier 1 calculation? If not it should be
removed from chapter as an option. Obtaining production
figures is not easy or readily shared by companies (CBI) so it
would seem to be difficult to complete this inaccurate
calculation. If it is being used should it be adjusted to accountfor device complexity

ExpertRejected

Even though no country is using the Tier 1 approach, themethodology will still be useful in the case of a new country
developing new electronic device manufacturing facilities. TSU's
recommendation is that we keep the Tier 1 approach even though it
may not be currently used.

7452

3

6

117

121

Recommend adding language calling out how inaccurate Tier 1 Jennifer Politsch
emissions are

Rejected

10174

3

6

117

121

Tier 1 method is stated as the least accurate. Is their supporting Tina Gilliland
data that the Tier 1 method is being used by the industry
subsectors in any country?

Noted

Comment is unclear; did the commenter mean "how much"inaccurate? It is not possible to quantify the inaccuracy of the Tier 1
method because this will be facility-dependent.
To the best of the authors' knowledge there is no evidence that theTier 1 method is used by any country, but for the reasons discussed in
the answer to comment # 7450, the decision is to keep the Tier 1
method as an applicable approach.

7454

3

6

124

124

See comment for Volume 3, Chapter 6, Start line 89, end line
89. Replace CVD with thin-film

Jennifer Politsch

RejectedLine 124 of the FOD refers to the process categories of the Tier 2b
method of the 2006 Guidelines, which were defined as 1) etch and 2)
CVD cleaning. Thus "CVD" on line 124 of the FOD will be replacedby "CVD cleaning" but not by "thin film". The new process types forthe 2019 Refinement are defined on lines 127-128.

10176

3

6

124

124

Same comment as line 97.

Tina Gilliland

Noted

7456

3

6

128

128

recommend removing CVD as the other cleaning types listed
include CVD processes

Jennifer Politsch

Rejected

The numbering of equations will be finalized once the Tier 3
methodologies will be finalized.
Comment is unclear: "Other" refers to processes using N2O that are
not CVD processes. However, to remove any possible ambiguity, theprocess denomination will be changed from "CVD" to "TFD (ThinFilm Deposition)" in the text (line 128) and in the EF tables of theTier 2c method (Tables 6.3h and 6.3i). Include definition of TFD
where appropriate in the document and double check for consistency
througout. Then, remove one of the two N2O columns (just have one
N2O column).

7458

3

6

130

130

Accepted

7460

3

6

140

140

Will the apportioning guidance include language similar to the Jennifer Politsch
EPA reporting rule text? For the purposes of this chapter it islikely not necessary to get to the nuance of different fabs oneach site. However the ability to model chemical usage oflargest used gases to 20% provides more certainty on theappporitioning calculations. calculations should include
facility heel factors of containers instead of a default 10% or
the apportioning calculation checks will not be as accurate
Methodlogical in title is misspelled. Should be Methodoligical Jennifer Politsch

10178

3

6

140

140

Methodological is misspelled.

Tina Gilliland

Accepted

7462

3

6

145

145

Recommend replacing "the brand of process tools," to"manufacturing process types and subtypes,"

Jennifer Politsch

Accepted withmodification

Modify sentence to read: "...vary according to the gases and process
types and subtypes used in manufacturing, as well as the brand...".

10180

3

6

145

145

Tina Gilliland

3

6

159

159

Tina Gilliland

Accepted withmodification
RejectedSame answer as for comment ID 7462

10182

Replace "brand of process tool" with "manufacturing process
types and subtypes".
Utilization is misspelled.

10184

3

6

159

166

In the 40CFR98 Subpart I petition for rulemaking docket, thedemonstrated data indicated that the emissions factors cover arange of parameters.

Tina Gilliland

Noted

Regarding apportioning, the general agreement is that Subpart I
apportioning rules should be the starting point. A separate discussion
will be held to review possible simplifications.
Regarding heel factors, there will be a 10% default and guidance todevelop facility-specific heel factors.

Accepted

British spelling is used in IPCC/UN documents.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

7464

3

6

159

169

Jennifer Politsch
many of the processing conditions have been studied andidentified as not having a significant impact reference. Pleaseconsider reference below.
https://www.semiconductors.org/clientuploads/directory/Docu
mentSIA/SIA%20Climate%20Negotiations/SIA%20Climate%
20Negotiations_copy/120228%20etch%20report%20to%20EP
A.pdf

ExpertNoted

The link refered to by the commenter is broken. The language of thefirst sentence of the paragraph (lines 159-162) is hypothetical("…emission factors can be strongly affected… and... can differ…").
The second sentence of the paragraph (line 162-166) was modified touse "can be affected" instead of "are affected" and "can substantiallyfluctuate" instead of "will substantially fluctuate". Regarding the third
sentence of the paragraph, it is well known that the efficacy of FC
emission control equipment depends on operating and maintaining
the equipment according to the manufacturer’s specifications and that
increased gas flows, improper temperature settings, and failure to
perform required maintenance can individually and collectively
negatively impact performance; nevertheless, taking into account thecommenter's opinion, the verb "will" in this sentence was replaced by"can".

7466

3

6

166

166

recommend changing "In addition, the efficacy of FC emission Jennifer Politschcontrol equipment depends" to "In addition, the efficacy of FC
emission control equipment depends on whether it is designed
to abated fluorinated GHGs or N2O, "Accepted withmodification

Sentence has been changed to "the efficacy of greenhouse gas
emission control equipment depends on whether it is designed toabate the target gas and on operating and maintaining the equipment
according to the manufacturer’s specifications..."

10186

3

6

166

169

Run on sentence. End the sentence on line 167 after
Tina Gilliland
manufacturer's specification. Delete the rest of the line 167
through 169. Add that this sentence: "FC emissions control
equipment must be designed to abate fluorinated greenhousegases and must be operated and maintained properly to acheive
expected performance.

Accepted

The suggestion offered by the commenter is addressed in themodification agreed to in the answer to comment ID 7466.

6830

3

6

170

171

Delete line break

Accepted

7468

3

6

178

181

Noted

10188

3

6

182

182

7472

3

6

182

187

difficult to fully comment without table 6.9. in the following
Jennifer Politschreference uncertainty or relative errors were not aligned withstatement of >100% if sample size was large enough andreflective of process:https://www.semiconductors.org/clientuploads/directory/Docu
mentSIA/SIA%20Climate%20Negotiations/SIA%20Climate%
20Negotiations_copy/120228%20etch%20report%20to%20EP
A.pdf
Tina Gilliland
To improve the accuracy of Tier 1 if needed, could purchasedata be used instead of FC usage data?
Is any country using Tier 1 calculation? If not it should beJennifer Politsch
removed from chapter as an option. Obtaining production
figures is not easy or readily shared by companies (CBI) so it
would seem to be difficult to complete this inaccurate
calculation. If it is being used should it be adjusted to accountfor device complexity

7470

3

6

184

184

replace "are not" with "is not"Accepted

Edgar Dullni

Jennifer Politsch

Rejected
Rejected

Tier 1 does not use FC usage data, but surface area of substrate usedduring production.
See response to comment ID10174 regarding the use of the Tier 1
method. It is not deemed feasible to adjust the Tier 1 method based on
device complexity. A sentence will be added after the sented endingon line 185: "... Data are not available. It should also be noted that theaccuracy of the Tier 1 default factors is expected to decrease as thecomplexity of the devices manufactured increases. Further, the Tier 1
method...

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

7474

3

6

188

191

Tier 2a and 2b require distinguishing between NF3 and NF3 in Jennifer Politschother processes. If this is possible why would it not be possible
to distinguish or apportion between 200mm and 300mm use.
Also this distinction would be needed to apportion toabatement device installation. Also apportioning between CVD(thin-films) and other processes.

ExpertNoted

The reason for the distinction between the Tier 2a and Tier 2b
methods is that some facilities have multiple wafer size tools served
by a single gas distribution system and do not measure gas
consumption separately by wafer size. Yet, in devising the Tier 2amethod, the consensus is that making no distinction by process type(in particular not making the distinction between NF3 remotecleaning and other NF3-using processes) would result in significant
inaccuracies in emissions estimates; therefore, limited apportioning is
indeed required when using the Tier 2a method to distinguishbetween NF3 and/or C3F8 remote cleaning versus 'other' NF3 and/or
C3F8 process types and to distinguish between N2O TFD and 'other'N2O-using processes. The authors acknowledge that this approachalso requires apportioning to abatement device installation and such
issue will be addressed in the Second Order Draft.

10190

3

6

188

200

Should Tier 2a and 2b be combined to not distinguish wafer
sizes but rather process type. 40CFR98 Subpart I docket
indicated process type dominates accuracy.

Tina Gilliland

Rejected

See answer to comment ID 7474. When possible, distinguishingemission factors by wafer size is an important element of ensuring
greater accuracy. The purpose of the Tier 2a and 2b methodologies isto provide a simplified approach to avoid complex apportioning ofgas usage among process types and subtypes (except, e.g., fordistinguishing between NF3 remote cleaning and other NF3-using
processes). Greater sophistication in terms of process distinction isachieved by using the Tier 2c method.

7476

3

6

204

204

Jennifer Politsch

3

6

204

204

7478

3

6

209

210

Further guidance on apportioning is necessary. Is the intent toprovide guidance and list a single method or list uncertainties
with various methods?

Jennifer Politsch

Accepted withmodification
Accepted withmodification
Accepted

See answer to comment 7456.

10192

See comment for Volume 3, Chapter 6, Start line 89, end line
89. Replace CVD with thin-film
CVD comments same as line 97.

10194

3

6

209

210

7480

3

6

214

226

Need to provide further guidance on apportioning. Also, is the Tina Gilliland
intent to list a single method or list uncertainties with various
methods?
Recommend less focus on FC byproducts formed during
Jennifer Politschplasma etching of c-containing Layers. The thickness of thelayers makes it difficult to obtain detectable amounts formed
with an input chemical does not contain carbon.

10196

3

6

216

230

This discussion assumes that the carbon containing films aretracked separately from other films. By-products formation
should be inclusive of all films.

7482

3

6

227

230

if option 2 is possible than use of any calculation method less Jennifer Politsch
than Tier 2c should not be an option. Default should be option
2 if there is any uncertainty. This will better align emission
inventories between IPCC and US EPA

Tina Gilliland

Tina Gilliland

Accepted

See answer to comment 7456.
Apportioning guidance is necessary. It is not yet clear whether
different apportioning approaches will be required for the Tier 2a, 2b,
and 2c methodolologies. With respect to the uncertainty ofapportioning methods, the current requirements of the US Subpart I
will be reviewed to determine whether they can applied to the IPCC
Refinement.
Further guidance on apportioning will be provided as part of the SOD.
See answer to comment ID 7478 for the second part of the comment.

Rejected

Data suggest it is not an insignificant source.

Rejected

The discussion does not assume that the carbon containing films aretracked separately from other films. While such possibility is
considered (option 1, lines 227-228), option 2) (lines 229-230)
considers the case where carbon containing films are not tracked. See
also response to comment ID 7480.
The issue of CF4 origination from the cleaning of carbon-containing
films will be taken into account in the Tier 2a and 2b methods.

Rejected

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

10198

3

6

227

230

Requiring any film containing carbon to apply by-productformation does not appear to improve accuracy of the method
and will likely over estimate emissions.

Tina Gilliland

Rejected

While option 2 as described in lines 229-230 of the FOD could lead tooversetimating emissions in cases when only a small fraction of thefilms actually being cleaned contain carbon, the determining factor isthat NOT taking into account byproducts formation during thecleaning of carbon-containing films would lead to an underestimationof emissions. Option 1 as described in lines 227-228 of the FOD
provides an approach to improve reporting accuracy in such case.

4584

3

6

23

24

QA/QC, letter case

Kewei Yu

Accepted

Checked text throughout to ensure consistency.

7486

3

6

239

242

Rejected

This is not what the data show if you look at the distribution functionsof Efs, which often have standards variations exceeding 100%.

7484

3

6

240

241

data submitted over last 10 years to IPCC, EPA shows that the Jennifer Politsch
cetnreline process conditions can be very forgiving. The
emissions collect by IPCC and for US EPA show that across awide range of technolgoy nodes, factory locations, andequipment types that the measured EFs are not widely variable
for same input chemicals and process categories
recommend centreline discussion or site specific Efs be based Jennifer Politsch
on testing frequency requirements (not too onerous or costly
but more frequent than one time).

Rejected

Emission factors are very stable so long as the process conditions are
fixed. A detailed discussion about "similarity" between recipes will be
included in SOD.

7488

3

6

265

265

Table 6.1 - Cannot fully review. Should this be updated toreference process and subprocess types (different types ofchamber clean for example).

Jennifer Politsch

Rejected

7490

3

6

270

272

Jennifer Politsch

Rejected

7492

3

6

270

272

should a component of the decision tree include what to do if
no published GWP or reference to a EPA table A-1 if notincluded in IPCC
Tier 1 decision tree. If production data is not available should
calculators be directed to Tier 2a or to not use Tier 1?

The table provides a summary of the information necessary to apply
the various tiered method. The table is not about making distinctions
by process or type or sub-type. The table will be finalized as part of
the SOD submission.
No GWP values are required to report emissions pertinent to Figure
6.1

Jennifer Politsch

Rejected

This scenario is not reasonable. If production data is not available, it
is not likely that gas consumption data would be available.

7494

3

6

276

276

Jennifer Politsch
Is any country using Tier 1 calculation? If not it should be
removed from chapter as an option. Obtaining production
figures is not easy or readily shared by companies (CBI) so it
would seem to be difficult to complete this inaccurate
calculation. If it is being used should it be adjusted to accountfor device complexity

RejectedSee discussion in the response to comment ID 7450.

7496

3

6

276

276

Rejected

8098

3

6

289

289

Noted

Table 6.2 is relevant to the Tier 1 method, which is based on substrate
prodcution and not gas consumption.
PV = Photovoltaic (defined on line 80).

8096

3

6

307

307

Noted

PV = Photovoltaic (defined on line 80).

864

3

6

321

321

Jennifer Politsch
Is table 6.2 going to include a reference to use an EF of 1 forany non-listed gases?
What is PV?, Does this represent all areas which may use Tier Jennifer Politsch
1, if any?
What is PV?, Does this represent all areas which may use Tier Jennifer Politsch
1, if any?
It is written "used" instead of "use" at the end of the line, and Virginia Sena
the quotation marks for letter i at the end of the line are notnecessary. The line should be: "...used in manufacturing
processes (Ui) and the formation of by-products during the useof each input gas i (... "Accepted

The second "used" on line 321 should be changed to "use" (the first"used" at the beginning of the line is correct)

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

7502

3

6

322

322

Tables 6.3A, 6.3B, 6.3C, and 6.3D could not be reviewed since Jennifer Politsch
not included in draft. However if facility cannot distinguishbetween wafer size or process subtypes suggest that Default
Efs for 2a and 2b be weighted for NF3 based on average NF3
apportioning between chamber clean non-RPC and other uses.

Expert

Noted

With respect to the comment about Tables 6.3A-D; such tables will be
developed as part of the SOD. Apportioning guidelines will also be
developed as part of the SOD, but in any case, the approach will not
be based on a weighting of emission factors but on an apportioning of
consumption.

7500

3

6

324

326

This sentence is repetitve with that before it in the paragraph.
Could instead say "Hence Tier 2b, 2c, and Tier 3 do not take
into account substrate size..."Jennifer Politsch

Accepted

10200

3

6

324

327

Tina Gilliland

Accepted

7510

3

6

344

346

Statement is repetitive. See comments above for lines 188
through 200.
Ei and BEi - Equation calculates to kg. Kg of each species
should not be added to get final emission inventory as eachchemical should be weighted to its specfic published GWP.
Within chapter there is inconsistent direction for summing
emissions and units. Sum should only be for when k= i and

The sentence on lines 320-322 will be changed to read: "The Tier 2amethod is based on default emission factors calculated over allprocesses and substrate sizes, representing average utilization
efficiencies of the gases used in manufacturing processes (Ui) and theformation of by-products during the used of each input gas ‘i' (BCF4,i, 321 BC2F6,i, BC3F8,i, BC4F6,i, BC4F8,i, BC5F8,i, BCH3F,i,
BCH2F2,i, or BCHF3,i)."See proposed changed in the answer to comment ID 7500.

Jennifer Politsch

Rejected

Emissions are not reported on the basis of CO2 equivalents but on amass basis for each compound and GWPs are not to be taken into
account as part of the methodology.

7512

3

6

344

346

Sum of all by-products k without use of GWP will lead toincorrect emissions in CO2e

Jennifer Politsch

Rejected

10202

3

6

344

346

Accepted

7498

3

6

352

352

8000

3

6

353

353

Is the intent to report kilograms emitted without multiplying by Tina Gilliland
the Global Warming Potential?
Ei - Equation calculates to kg. Kg of each species should not
Jennifer Politsch
be added to get final emission inventory as each chemical
should be weighted to its specfic published GWP. Withinchapter there is inconsistent direction for summing emissions
and units
Heel should be container specific and not a default value
Jennifer Politsch

Emissions are not reported on the basis of CO2 equivalents but on amass basis for each compound and GWPs are not to be taken into
account as part of the methodology.
Answer: Yes. See also answers to comments ID 7510 and 7512.

7504

3

6

354

355

This list is not inclusive of all gases or for future new gases.
Tables 6.3A, 6.3B, 6.3C, and 6.3D should reflect direction touse utilisation = 1 for any non-listed gases unless Tier 3 EF isdeveloped

7508

3

6

354

355

What is the definition of variable Fci? The listed gases now
include F2 and N2O. Should it be changed to GHG?

Rejected

Emissions are not reported on the basis of CO2 equivalents but on amass basis for each compound and GWPs are not to be taken into
account as part of the methodology.

Rejected

An option has been added to calculate facility-specific heels values,
but no container-specific value is envisioned or seemingly necessary.

Jennifer Politsch

Accepted withmodification

Jennifer Politsch

Accepted withmodification

The current list of gases 'i' is based on a comprehensive review of thelitterature and on a global survey of the different gases currently usedin production. Nevetheless, the authors agree that it is possible thatnew chemicals might be used in the future, for which emission factors
are not currently available. Guidance will be added to specify that -when no default EFs are available -- reporters might either 1) use a
Tier 3a approach whereby facility-specific emission factors would bemeasured, OR 2) assume that emissions equal consumption (i.e. thatthe utilization efficiency of the chemical is ZERO). The authors
assume that the commenter meant to suggest to use utilization = 0 (or(1-U=1)), not utilization =1 as stated in the comment. See lines 318322 in SOD.
The authors will consider changing the denomination for
consumption data to "C" across all tiered methods.

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

7522

3

6

354

355

Should N2O EF = 1 for Tier 2a because reporter is not able toapportion to different processes or wafer size?

Jennifer Politsch

Rejected

8002

3

6

363

363

Heel should be container specific and not a default value

Jennifer Politsch

Rejected

Default emission factors have been provided for the N2O CVD
category (denomination to be changed to N2O TFD) and for the"other" N2O category. Reporters will be required to apportion
consumption between the two N2O categories and guidance will be
provided as part of the SOD to such effect.
An option has been added to calculate facility-specific heels values,
but no container-specific value is envisionned or seemingly necessary.

70

3

6

365

365

Please give the unit of FCi.

Mingshan Su

Accepted

Unit of FCi (to be changed to Ci) shall be kg.

8004

3

6

366

366

this should not include a list or it should align with all default
EF table Byproduct options

Jennifer Politsch

Noted

The list of by-products was removed from the definition of Bk,i.
Instead, a reference to Table 6.3 was included in the text.

8006

3

6

368

368

Jennifer Politsch

RejectedDefinition of Dk on line 368 refers to equation 6.3a (not 6.3b)concerning the abatement of by-product k.

8078

3

6

376

377

Equation 6.3b referencse input gas and not byproduct formed.
Please make sure it is clear how to determine byproduct DRE
vs. input chemical DRE
Reduction is site and process specificJennifer Politsch

NotedDefinition of ai has been finalized as part of the SOD.

8008

3

6

379

379

tit should b

Jennifer Politsch

Rejected

Comment not understood.

8012

3

6

381

396

Where is variable "a" in na or ma defined?

Jennifer Politsch

Noted

The 'a' index refers to the number of tools (n or m) abated. The
method of equation 6.3c will be finalized as part of the SOD.

7514

3

6

385

385

The resolution of equation is difficult to read

Jennifer Politsch

Noted

7516

3

6

388

388

should include references to requirements that equipment thatis designed, maintained, and certified to achive the DRE.

Jennifer Politsch

Accepted

8014

3

6

389

390

What does suitable mean? Please include references toappropriate language in chapter.

Jennifer Politsch

Accepted

8016

3

6

389

393

# of tools may not define # of abatement. Recommend
changing to # of abatement for thin-film and etch/wafer
cleaning equipment

Jennifer Politsch

Rejected

8010

3

6

390

390

Jennifer Politsch

Accepted

7518

3

6

390

390

See comment for Volume 3, Chapter 6, Start line 89, end line
89. Replace CVD with thin-film
why does it list CVD specifically?

An explanation of what constitutes a "suitable emissions control
technology" was added to the text, refering to section 6.2.2.1 for moredetails.
Same comment as comment ID 7516. An explanation of what
constitutes a "suitable emissions control technology" was added to thetext, refering to section 6.2.2.1 for more details.
While the number of tools may not indeed equal the number ofabatement systems, the purpose of equation 6.3c is to estimate thefraction of gas i volume fed into tools equiped with emission control
technologies capable of abating gas i.
See answer to comment ID 7456.

Jennifer Politsch

Noted

Changing 'CVD' to 'TFD' removes the ambiguity.

8022

3

6

392

392

Jennifer Politsch

Accepted

See answer to comment ID 7456 and 7518.

7520

3

6

392

392

See comment for Volume 3, Chapter 6, Start line 89, end line
89. Replace CVD with thin-film
why does it list CVD specifically?

Jennifer Politsch

Noted

Changing 'CVD' to 'TFD' removes the ambiguity.

8018

3

6

393

396

what does "SOD" mean?

Jennifer Politsch

Noted

Second Order Draft.

8020

3

6

393

396

Is the intent of gamma to weight thin-films vs. plasmaetch/wafer cleaning fraction abated? In order to know if thisdefault fraction is representative of a facility emissions theywould need to be able to apportion to this level. If so what is
the need for Tier 2a?

Jennifer Politsch

Noted

The intent of gamma is to reflect the difference in typical average
flows between etch and CVD; a default gamma value will be provided
based on best-available information to be derived as part of the SOD.
The authors agree that if the gamma factor is not representative of aparticular facility, apportioning will be required to derive a facilityspecific gamma value. Guidance will be provided as part of the SOD.
Need further discussion as to whether gamma needs to be gas-ispecific.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

8024

3

6

415

417

Only if backup is 100% fool proof should this be an option.
Jennifer Politsch
Interlocking is likely to result in close to 100% uptime but
should not result in an 100% uptime. Most facilities will allow
for operation to complete if possible safely even if abatement
faults so some gases may run unabated

Rejected

The authors feel that the current language of lines 415-417 isadequate.

8028

3

6

426

426

Jennifer Politsch

Accepted

8026

3

6

429

431

Jennifer Politsch

Rejected

The text should be changed to Bk,i (B sub k sub i). Also note that theequation numbering on line 421 is incorrect and will be changed.
See answer to comment ID 7510.

10204

3

6

429

432

Variable B_BP,I is not consistent nomenclature with equation
on row 361 . B_PEk
Ei and BEi - Equation calculates to kg. Kg of each species
should not be added to get final emission inventory as eachchemical should be weighted to its specfic published GWP.
Within chapter there is inconsistent direction for summing
emissions and units. Sum should only be for when k= i andSame comment as line 344 through 346.

Tina Gilliland

Rejected

See answer to comment ID 7510.

8030

3

6

448

451

Ei and BEi - Equation calculates to kg. Kg of each species
should not be added to get final emission inventory as eachchemical should be weighted to its specfic published GWP.
Within chapter there is inconsistent direction for summing
emissions and units. Sum should only be for when k= i and

Jennifer Politsch

Rejected

See answer to comment ID 7510.

866

3

6

468

475

Description for parameter "FC i,p" (as it is described in lines
459 to 460) is missing for Equation 6.8A.

Virginia Sena

Accepted

Description for parameter FCi,p (to be changed to Ci,p) has been
added below the box of equation 6.8a, as defined on line 459.

4586

3

6

469

489

gas I, type p, letter case and italic, and other places

Kewei Yu

Accepted

8032

3

6

483

488

Comments in yellow describe intent of variable but this level of Jennifer Politschdetail ideally will not be in final chapter

Noted

8034

3

6

512

513

Only if backup is 100% fool proof should this be an option.
Jennifer Politsch
Interlocking is likely to result in close to 100% uptime but
should not result in an 100% uptime. Most facilities will allow
for operation to complete if possible safely even if abatement
faults so some gases may run unabated

Rejected

8036

3

6

517

625

Noted

8038

3

6

517

625

Difficult to provide comments on entire sections that are still in Jennifer Politsch
progress
Preliminarily looks like equations will yield emissions in
Jennifer Politsch
metric tons which is different from results from Tier 1, 2a-c

Rejected

Preliminary estimate of emissions is in MTCO2e to determine whichstacks must be tested. Clarified in Second Order Draft.

7506

3

6

528

550

Rejected

8042

3

6

549

559

tier 3b - any purchase of gas which is not detectable or
Jennifer Politsch
included in Default Efs should be included in inventory withutilisation = 1
Ideally would provide references to Tier 2b equations necessary Jennifer Politsch
in preliminary calculation checks

8040

3

6

550

551

Assuming 100% utilization efficiency is not a suitable solution. The
provision of Subpart I for low use gases will be reviewed to determine
if they can used for IPCC purposes.
Revised draft guidance allows facilities to use either Tier 2a or Tier
2b to develop a preliminary estimate, depending on whether multiple
wafer sizes are used at the fab. A preliminary estimate of emissions isrequired to imprement the stack test method. A faciliy would use Tier
3 if they want a more accurate emissions estimate reflective of facility
emissions rather than industry defaults.
The definition of Cij was revised and an explanation of how todetermine consumption for stack systems was added.

How can consumpton be a ratio? If a ratio than doesn't seemcorrect to yield emissions in metric tons

ExpertJennifer Politsch

Accepted withmodification

Accepted

This section is still work in progress but the authors believe thatsufficient detail/guidance will be required for the user to understandthat the ai,p factor calculation approach will be different for theTier2a/2b methods and the Tier 2c method.
The authors feel that the current language of lines 415-417 isadequate.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

8044

3

6

589

589

no equations yield calculations in CO2e so requires additional Jennifer Politschequations or direction to complete this portion of the process

ExpertAccepted

Guidance has been provided to require use of the same conversion
factors used for key category analysis. Note that the purpose of thethreshold defined on lines 590-591 is only to select which stacks
should be tested, not for reporting final emissions, which will not be
expressed in CO2e but on a mass basis for each coumpound emitted.

8052

3

6

605

605

Jennifer Politsch
Stack testing protocols for other species (HF, HCl, etc) arebased on concentration measurements normalized to
production output or converted to lb/hr (for example). They are
not linked to input chemical use nor are do they require
creating an EF based on POU % uptime/DRE. The beginningof the section references other stack testing requirements sothis section should be more aligned to other stack testing
protocols.

Rejected

The stack testing method proposed here is different from established
air pollutant stack testing methods. Further detailed comments will be
added, in part based on the history of the stack testing method
development for the US GHGRP (Subpart I).

8046

3

6

605

606

References for EPA method 1 or 2 should be provided

Jennifer Politsch

Accepted

References added.

8048

3

6

611

611

Define or references for GD-043

Jennifer Politsch

Accepted

References added.

8050

3

6

619

621

Why would stack testing be used if entire calculation method
for Tier 2b are required for stack testing process?

Jennifer Politsch

Accepted

Revised draft guidance allows facilities to use either Tier 2a or Tier
2b to develop a preliminary estimate, depending on whether multiple
wafer sizes are used at the fab. A preliminary estimate of emissions isrequired to imprement the stack test method. A faciliy would use Tier
3 if they want a more accurate emissions estimate reflective of facility
emissions rather than industry defaults. (Same as answer to comment
ID 8042.)

8064

3

6

639

691

It should be noted that lower GWP HTF materials being
marketed are not always the best environmental choice. Someor many are regulated VOC pollutants and not ideal materials
to switch to. This should be highlighted as a potential side
effect or negative consequence to lower GWP emissions.

Jennifer Politsch

Accepted

A sentence was added noting that low-GWP HTFs may be regulated(e.g., as VOCs) in some regions.

8062

3

6

646

646

It doesn't show in equation 6.12A that the FC is assumed to be Jennifer Politsch
C6F14. Is this the default for all HTFs to assume they are
C6F14? If lower GWP materials are identified this will notallow facilities to take credit for the lower emissions. How
should HTF GWPs be based? Are additional GWPs to be added
to bring IPCC in line with EPA GHG MRR Table A-1 (default
GWP section based on stoichiometry?)

Rejected

The Tier 1 method has been revised to provide default Tier 1 emission
factors in kg/m2 for three HTFs that represent the three main types ofcompounds used as HTFs globally: HFE-449sl, C6F14, and PFPMIE.
These compounds and their Tier 1 default emission factors arepresented in Table 6.9 under "Choice of Emission Factors;" it would
be redundant to present them in Equation 6.12A as well. The Fifth
Assessment Report GWPs for these compounds range from 421 to
9710. To take credit for transitioning to a lower-GWP mix of HTFs,
reporters should use the Tier 2 HTF reporting method. Regarding theaddition of GWPs, the comment is rejected as IPCC-based
methodologies are to be based on reporting emissions on a mass basis
for each compound emitted.

868

3

6

646

650

Please check the Equation number for Equation 6.12A (in line Virginia Sena
646 and in line 650), once the yellow lines are ready, since thelast Equation above is Equation number 6.8E, and theEquations from 6.9 to 6.11 are missing in this FOD.

Noted

The numbering of equations will be finalized once the Tier 3
methodologies have been finalised.

8054

3

6

650

659

This section is confusing. What is Ei? How is it defined? Thissection results in emissions of Mt-CO2 but there is not use of
the GWP or conversion to Mt in the equation

Noted

See answer to comment ID 8062.

Jennifer Politsch

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

8056

3

6

650

659

Is ther any reason in having a Tier 1 for HTFs

Jennifer Politsch

Noted

A tier 1 method is required by the IPCC.

8060

3

6

665

667

Accepted

The sentence of lines 665-666 will be removed (The Tier 2 methodneglects… costly fluids).

8058

3

6

670

691

The language that Tier 2 neglects fluid losses during filling
Jennifer Politsch
new or existing equipment does not seem consistent with theequations for Tier 2. The net result after accounting for filling
new tools or removing entire tools should be the amountrequired to "top off" existing equipment.
This section is aligned with the EPA MRR and theJennifer Politsch
complication is necessary in facilities which areadding/removin a large number of tools. The purchase volumesof HTF can be large and if the use is not tracked appropriately
it will not correctly reflect emissions on an annual basis.

Noted

The authors agree.

4588

3

6

693

Rejected

No readability issue noted.

4172

3

6

704

759

It would be useful to explicitly include guidelines for
Stephanie Bogle
calculating emissions in cases where there is no emission factor
is listed (i.e. the emission factor is listed as "NA"). Current
practice in the US is to assign a utilization of 0 for these input
gases, resulting in an emission factor of 1. As the 2006
guidelines do not specify how to assign an emission factor tothese cases, they may end up being unaccounted for.

Accepted

See answer to comment ID 7504.

4174

3

6

725

750

C4F6 is unlikely to be a significant by-product in terms of
Stephanie Bogle
CO2e due to it's extremely low GWP and typically low byproduct emission factor. You may want to exclude it from theby-product list for simplicity.

Rejected

C4F6 is not included in the list of byproducts (B factors) but is
included as a process gas. C4F6 usage is not insignificant according
to the latest industry surveys and the potential for the formation of
CF4 and C2F6 as byproducts of the use of C4F6 is not negligible, inparticular for ≤200mm wafer size (according to US EPA 40 CFR 98
Subpart I Tables I-3 and I-4).

8066

3

6

768

771

Why is wet called out in Hot-wet < 800 and Hot-Wet > 800C.
The "wet" portion is not critical to GHG abatement.

Jennifer Politsch

Noted

The definitions and discussion related to Table 6.6A (now 6.7) havebeen updated.

8068

3

6

768

771

Please include more detailed description or distinction on
specific types such as cartridge, catalyst.

Jennifer Politsch

Noted

The definitions and discussion related to Table 6.6A (now 6.7) havebeen updated.

8070

3

6

768

771

it should be noted that not all hot-wet or combustion devies are Jennifer Politschdesigned to abate at default DRE values. For example mostCombustion POU for chamer clean (thin-films) are designed toabate NF3 but not any PFC byproducts such as CF4, CH3F...

Accepted

Refined guidance and methodological approaches will be added to theemissions control section as part of the SOD. The authors agree that
the Refined guidelines should allow reporters to claim abatement for
NF3 from CVD chamber cleaning while having zero DRE for otherbyproducts such as CF4 when the abatement device is only designed
for NF3/F2 abatement.

8100

3

6

768

771

It should be noted that not all combustion devices are designed Jennifer Politsch
to abate all FCs checked in the table.

Accepted

10206

3

6

768

773

Include references for abatement technologies. For example,
the catalyst only abates CF4 and NF3 or is there a technicalpaperthat only evaluated these gases.

The authors agree and refined guidance and methodologicalapproaches will be added to the emissions control section as part of
the SOD.
The authors agree and refined guidance and methodologicalapproaches will be added to the emissions control section as part of
the SOD.

Figure 6.2 is not readable

Kewei Yu

Tina Gilliland

Accepted

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

1856

3

6

768

793

Noted

The authors agree with the comment that DRE data should bereflective of properly maintained equipment. However, the comment
about the need to strongly regulate the operation of abatement systems
is rejected because the IPCC guidelines are not to be construed as
imposing regulatory requirements at national levels or otherwise.

7436

3

6

77

78

hiroshi ito
Default values of EF and DRE in combination of gas anddetoxification technology will be decided in the future (asTable6.6A), but when making a decision, you should not use
measurement results in bad maintenance state, measured only
in a/some country/ies.
(Bad maintenance state: a state where the original ability of theabatement system can not be realized.
These measurement results will indicate the capacity shortageof he abatement systems.
The data showing these lack of capability indicates that it must
be strongly regulated in the country to use the abatement
system in good maintenance state.
It should also be noted that, these data do not indicate thatcountries other than the country are also using abatement
systems in bad maintenance state.
Regardless of the number of the "lack" data, this holds.
recommend replacing lines with "As part of its manufacturing Jennifer Politsch
processes, the electronics industry uses greenhouse gases(GHG) in the form of fluorinated compounds (FCs) and nitrous
oxide (N2O) for plasma etching intricate patterns, cleaning
substrates, and tool manufacturing"
Why? It isn't such as but those are only ones compiled foremissions inventory in this chapter

ExpertRejected

There are no FC emissions related to tool manufacturing. The second
sentence of the comment is not understood.

300

3

6

770

771

Hot-wet should be changed to Heater-wet in Table 6.6.A.

Tsutomu Tsukada

Rejected

301

3

6

770

771

Hot-wet > 800 C can abate PFC gases more than 90% of DRE. Tsutomu Tsukada
Then x should be put in all the gases..

Rejected

Heater-wet is not a common or recognized terminology in theelectronics industry.
The Hot-wet >800 C technology is not capable of abating all PFC
under all conditions. Data is being collected to determine the gasesthat can effectively be abated by such technologies and the table will
be updated as part of the SOD.

8072

3

6

776

777

Add to decision tree after "Is the devise OEM certified to [2] to Jennifer Politschabate this gas" the question "Is the OEM certified DRE lower
than the default DRE in Table ... ?" If yes use OEM DER, If
No go to next question.

Accepted withmodification

The question in the decision tree will be revised to read: Is the device
OEm certify that the abatement device is certified to abate the target
gas at or above the default DRE?

8080

3

6

776

777

This decision tree or within the chapter do not specifically call Jennifer Politschout whether you can use default DRE or a combination ofdefault with Tier 3 on a gas by gas basis

Accepted

Guidance has been developed to allow reporters to use both default
and site specific DREs. Figure 6.3 was revised to address this issue.

8082

3

6

776

777

Should an option to use a different DRE for an input gas versus Jennifer Politsch
a byproduct gas? EPA subpart I calculation workbook(Sheet"Semiconductors f-GHG 300 mm", starting on Row 419
provides alternative DRE for byproducts separate from Input
chemical DRE

Noted

Yes, different DREs will be used for different input gases andbyproducts.

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

8088

3

6

776

791

Jennifer PolitschWill there be specific language or references as to which
testing protocols will be acceptable for measuring or certifying
DRE performance. Requirement to account for dilution should
be in any acceptable testing protocol. References should be
provide. EPA method 1, 2 or ISMI methods for example.
Should JEITA or any other region methods be included? (Yes
if they account for dilution and concentration calibration).

ExpertAccepted

References to existing / recognized DRE testing standards will be
provided. It is agreed that such standard should account for dilution
effects.

8090

3

6

776

791

Should POU DRE section include details on how to test or
account for byproduct DRE performance?

Jennifer Politsch

Noted

8074

3

6

780

782

Noted

8076

3

6

785

785

This note [2] is complicated and difficult to follow. OEM
Jennifer Politschcertified should mean that it meets default DRE or
performance specifications agreed to by vendor for the tool
type/recipe conditions in which it is connected. These
performance specifications should not be so tight that they do
not cover the wide range of potential operational conditions
which may occur for the tool type.
This 5% requirement should only apply to those sites which are Jennifer Politsch
defining a site specific DRE which is greater than the default
DRE's published in this specification

No, the POU DRE section will only provide general guidance about
testing requirements but will provide references to existing /recognized DRE testing standards.
Regarding the lack of clarity, more refined guidance has been
provided in the SOD.
Regarding equipment design, that is out of the scope of thisrefinement and therefore this part of the comment is rejected.

Noted

This section is still under development / discussion and refined
guidance will be developed as part of the SOD.

10208

3

6

785

785

Noted

This section is still under development / discussion and refined
guidance will be developed as part of the SOD.

8086

3

6

786

787

Reference appears incomplete. Is this in reference to 40CFR98 Tina Gilliland
Subpart I FR 2013. Need to be clear on what 5% annual
requirement.
Is this going to be referenced to a comment associated with
Jennifer Politschdecision tree? If not language about accounting for dilution
should be included in the chapter under testing requirements

NotedThis section is still under development / discussion and refined
guidance will be developed as part of the SOD.

8084

3

6

788

790

This should be removed or added to language in decision tree Jennifer Politschadding option to use an OEM DRE less than default. Note: any
abatement should be certified by manufacturer at this lower
DRE only. Facility can implement Tier 3 option which requires
deriving a facility specific DRE if manufacturer will not certify
lower value.

Noted

This section is still under development / discussion and refined
guidance will be developed as part of the SOD.

8092

3

6

811

814

Should this table and details be removed if not being updated
since 2005?

Jennifer Politsch

Accepted

The text of lines 811-814 is outdated and will be updated as part of
the SOD. Table 6.7 will be removed from the Refined Guidelines.

8094

3

6

815

828

What is added to the calculation methodology to have thisJennifer Politsch
added discussion or % utilisation standard of differnce
facilities? Is the 86% supposed to be used for variable definedin Row 307 ("CPV = fraction of PV manufacture that uses
FCs, fraction."). If so the variable subscripts do not match.
Also the discussion in this paragraph is for % utilisation of a
facility and not the % of the manufacture process which uses
FCs

Accepted

7438

3

6

84

84

recommend changing "The gases include" to "Examples of FCs Jennifer Politsch
included are"
Why? The list is potentially not all inclusive and will still be
representative if production gases change in the future.

Noted

The 86% was an annual manufacturing capacity estimate from the2006 GL. The definition of Production ('P') in equation 6.1 states "Ifannual production is not available from an electronics producer, P
may be calculated as the product of the annual manufacturing
capacity and annual plant production capacity utilisation (fraction) ofthat producer." A list of databases providing design capacities wasadded to section 6.2.3 (Choice of activity data) and an explanation of
how design capacaties can be adjusted for utilization efficiencies wasadded to that section. A footnote refering to section 6.2.3 was added
to the definition of P in Equation 6.1.
Changed to "Examples of FCs included are".

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

7440

3

6

87

87

Delete carbonyl fluoride (COF2). It is not an emission but is an Jennifer Politsch
input chemical and does not have a documented GWP.

Rejected

COF2 was not deleted as an input gas because of the potential
formation of CF4 and C2F6 byproducts. Due to the lack of measured
EFs/BEFs for COF2, the default provision applies, which provides forusing (1-U)=0.8 and BEFs of 0.1 for CF4 and C2F6. Alternatively,
reporters can use the Tier 3a method to apply facility-specificmeasured emission factors.

7442

3

6

88

88

Accepted

7444

3

6

89

89

recommend change "(i) plasma etching silicon containing
Jennifer Politschmaterials" to "(i) plasma etching and wafer cleaning of silicon
containing materials"
recommend replacing "cleaning chemical vapour deposition
Jennifer Politsch(CVD) tool chamber-walls" to "cleaning thin-film tool chamberwalls after processing substrates."
Why? This aligns language to be more general as chambercleaning occurs in more than just CVD processes.
Recommend changing references througout document for CVD
to thin-films if this comment is adopted

1854

3

6

924,925.970,

hiroshi ito

Noted

7446

3

6

97

97

Jennifer Politsch

Accepted

10168

3

6

97

97

Some companies' HP's are listed as Reference. But some ofthem are not suitable as a reference, such as only data up to2010 are listed (too old), or/and only describe CO2 of energy
origin, not describe PFCs.
See comment for Volume 3, Chapter 6, Start line 89, end line
89. Replace CVD with thin-film
Need to define CVD as Chemical Vapor Deposition or Thin
Film. Chapter uses CVD and Thin Film throughout.

Tina Gilliland

Accepted

10170

3

6

98

98

Tina Gilliland

Accepted

4890

3

6

Table 6.6A

1524

3

7

100

101

456

3

7

106

106

Grammar error, need to change "results" to "result".

ExpertNF3 and SF6 need to be grouped separately from PFC
Elsa Hatanaka(Perfluorocarbon) gases.
……. Kuwait) will freeze HFC use by 2028. In this way it has Archie McCulloch
been estimated that up to 0.5° Celsius warming will be avoided
by the end of the century (Velders et al., 2009; 2012; 2015).
DELETE sentence “In this way………..2015) and thereferences.You must avoid giving the (false) impression that
this supposed 0.5degC is part of the 2degC aim of the Paris
Agreement. The fact is that 0.5degC was a consequence of the
spurious scenarios in Velders (2009) that was subsequently
reduced significantly in Velders (2012) and reduced again in
Velders (2015). The scenarios have little basis in fact and arecertainly not predictions, so you cannot say “will be avoided”.
The additional 0.5degC is a consequence of supposed rampant
growth in HFC production and use
I am concerned by the reliance in this chapter on such an old
IPCC/TEAP reference for the use pattern of alternatives; why
not use the most up to date UNEP/TEAP report (2016)?

Pauline Midgley

Accepted

Accepted
Accepted

Noted

The Applied Materials (2016) and IBM (2015) references have been
removed. The entire list of references was scrubbed one more time toremove those that are not appropriate for IPCC purposes.

The title in line 2 of Table 6.6A (now 6.7) has been updated to
ABATEMENT SUITABILITY TABLE
Sentences to be deleted. Not important for content.

Information from TEAP 2016 is used in the updated sections (table7.3a). The text that is referenced to in line 106 is still valid though.

Comment ID Volume Chapter From line To line

Comment

358

3

7

173

174

71

3

7

174

175

Domenico Gaudioso
The information provided in Table 7.3 is of limited use forinventory complilers, since it reports outdated information,with significant differences from country to country andtherefore not applicable for countries not referred to in the
Table. It could be replaced by Tables A5.19/A5.20 of the EEA
report "Fluorinated greenhouse gases 2017" (see also attachedfile Vol3_Chp7_L173-174)
Please define RAC
Mingshan Su

4896

3

7

268

269

Although the thinking of mentioning UNFCCC reporting
requirements here can be fully understood, is it normal tomention the UNFCCC context in the IPCC Guidelines?

4898

3

7

282

282

Noted

4900

3

7

284

284

It is much appreciated that 'gradual improvement' is expressly Elsa Hatanaka
taken note of here, since adding F-gas reporting will surely bechallenging for some countries.
Is it rather 'you should assess how much information and time Elsa Hatanaka
you need to achieve the desired aim' or 'you should decide howmuch time you want to spend to achieve the desired aim'?

Accepted

Sentence to be changed.

4902

3

7

292

295

Accepted

Information to be added.

870

3

7

300

300

It would be useful to mention this information with 'as of
Elsa Hatanaka
when'.
The reference to Box 7.4 is not correct. The Box that provides Virginia Senaa short description of common data sources is Box 7.3.A.

4904

3

7

305

305

Elsa Hatanaka
It might be useful to mention at the end of Step 5 that if nostatistics are currently available, the country needs to set up asystem of collection, since the situation has changed drasticallywith the Kigali amendment to the MP now in place.

Accepted withmodification

1526

3

7

338

339

Accepted

2456

3

7

350

351

Archie McCulloch
Like for all parts of the inventory, it is important that theassumptions applied in the calculation process are well
documented.Change is to are
As also in Box 7.2A (lines 252-253), the Box 7.2B gives
Päivi Lindh
guidance on the Tier 2 EF approach which would be beneficial
to point out in the heading of the Box.

1528

3

7

357

357

Archie McCulloch

Accepted

872

3

7

371

371

Virginia Sena

Accepted

874

3

7

388

388

Virginia Sena

Accepted

4592

3

7

391

FIGURE. SCHEMATIC EXAMPLE OF THE YEARLY
INVENTORY DEVELOPMENT. This attempt to illustrate a
vintaging model does not work well. It needs to have a clearer
relationship between the annual additions to the bank and thereleases. More thought is needed concerning the vertical scaleand how the growth in the bank and emissions progresses.
Writing needs to be larger.
The reference to Box 7.4 is not correct. The Box that provides
guide on how to put together information on what the banklooks like is Box 7.2.C.
The reference to Box 7.4 is not correct. The Box that provides
tips on where to find data (data sources) is Box 7.3.A.
"See" box 7.4?

Kewei Yu

Accepted

876

3

7

391

391

ExpertElsa Hatanaka

The reference to Box 7.4 is not correct. The Box that provides Virginia Sena
tips on where to find data (data sources) is Box 7.3.A.

Response

Authors notes

Noted

It is not our mandate to delete tables from the 2006 Guidelines, but toprovide updated information. We belive the new tables 7.3a-7-3c
provide the necessary information. The report containes information
only for EU-countries.

Accepted
Accepted

Sentence to be deleted.

Accepted

Accepted

Accepted

The FOD text has now been superceded. The Kigali amendment andMontreal Protocol is described in box 7.3 A

Comment ID Volume Chapter From line To line

Comment

1530

3

7

392

392

Accepted

2458

3

7

424

425

Archie McCulloch
3. Removal of substances exported, emitted, retired or
destroyed. Change destructed to destroyed
As also in Box 7.2A (lines 252-253), the Box 7.2C gives
Päivi Lindh
guidance on the Tier 2 EF approach which would be beneficial
to point out in the heading of the Box.

ExpertResponse

Authors notes

4594

3

7

427

428

bank?

Kewei Yu

Noted

4906

3

7

450

450

Elsa Hatanaka

Accepted

4596

3

7

455

Is it normal to mention the UNFCCC context in the IPCC
Guidelines?
(bank)?

Kewei Yu

Noted

4590

3

7

46

48

letter case, percentage?

Kewei Yu

Accepted

740

3

7

478

540

4992

3

7

478

546

The explanation is not clear about whether it is permitted or
Kendal Blanco Salas
not to use the values presented on Tables 7.9A and Table
7.9B.
There is valuable information on emission rates in new Tables Päivi Lindh
7.9a-7.9c. Text in lines 478-530 should give clear guidance
when to use default emission factors from Table 7.9 and whatis the status of the emission factors in Tables 7.9a-7.9c. This isalready done in current version in some extent but authors
could check if this could be done even more transparent way
when referring especially to Tables 7.9b and 7.9c. Related toTable 7.9a it is written that “Countries with similar regulations
or incentives in place can consider using these factors forrelevant years”. If a country uses these emission factors arethose considered Default or perhaps Other because not given in
Table 7.9? And if considered Default, for example reviewers
should be familiar with references behind the data given inthese Tables in order to be able to evaluate circumstances inwhich emission factors from different Tables can be applied.

878

3

7

491

492

There are two different references to find emission factors from Virginia Sena
the German study. The correct reference in Table 7.9.a.

Rejected

The reference in table 7.9 is correct

6832

3

7

531

531

In Table 7.9, col (k), the factor for the initial emission shouldhave the dimension % instead of %/year.because it isaccounted only once.

Edgar Dullni

Rejected

The units are stated to apply to both columns, "% of initial charge"and "% per year" for the operational loss, and therefore it is written"% of initial charge/year"

8694

3

7

531

532

It is unclear how the information provided in Table 7.9 is
Ole-Kenneth Nielsen
related to the information provided in Table 7.9a-c. For
example, the initial charge remaining in mobile AC is listed as
between 0 and 50 % in table 7.9, while table 7.9c lists between
27 and 55.6 %. Another example is industrial refrigeration
where table 7.9 provides an operating emission of between 7
and 25 %, while table 7.9a lists 4.71 %. It is necessary that the
information is harmonised. Also, it is necessary that it is madecompletely clear what the default values are so the users are notleft guessing on what value to use, if many different values arepresented. Based on the additional tables, it seems that it would
be obvious to split mobile AC into different vehicle categories
as data supporting this seem to be available.

Accepted

Accepted

Accepted

Accepted

Comment ID Volume Chapter From line To line

Comment

Response

Authors notes

6318

3

7

538

539

Recommend adding additional table to supplement Table 7.9A Anny Huang"German Study 2015". The existing operation emissions interms of percent of initial charge/year (annual leak rates) arevery low and likely represent the extremely well-managed
systems surveyed in the German study. If estimators use theleak rates in Table 7.9A, they will underestimate GHG
emissions from refrigeration and AC equipment. In California,
we collect annual data on refrigerant usage from thousands ofbusinesses and our data show much higher annual leak rates.
Recommend a new table with the same format as Table 7.9A,
to be titled "California Study 2014: Emission Factors forRefrigeration and Air-Conditioning Systems". Using the same
sub-applications, the alternative emissions factors (% of intial
charge/year) for California 2014 are as follows: Medium &Large Commercial Refrigeration (centralized): 15.0 - 21.0.
Small Commercial Refrigeration (condensing units): 14.5 15.0. Industrial Refrigeration including Food Processing andCold Storage: 6.8 - 28.8. AC Chiller: 1.4 - 6.9. AC
Multisplit/VRF: 10.0 - 11.3.

ExpertAccepted withmodification

Reference to California study used to strengthen the assessment ofdefault values in Table 7.9

1532

3

7

586

587

……………..consumption data on HFCs annually. This might Archie McCulloch
provide valuable data for the ODS-substitutes inventories. The
paragraph should be deleted. The Kigali Amendment applies to
HFCs in aggregate, so countries will only report their total
production and consumption of HFCs in CO2 equivalents. It
might mean that their accountancy systems will be in place toenable estimation of HFC emissions but there is no direct link
here between this emissions inventory and the data required for
the Montreal Protocol.

Rejected

The reporting requirement under the Kigali Amendment may welllead to countries collecting new data at a useful level of resolution for
national inventory compilers.

4994

3

7

591

592

Bulk importers do not always know in which types ofequipment imported gases are used. The sentence could
contain e.g. phrase “what equipment type it will be used in if
these data are available.”

Päivi Lindh

Accepted

880

3

7

744

744

The reference to Equation 7.8 is not correct. The correctreference to calculate total MAC emissions may be Equation
7.10 (from the 2006 IPCC Guidelines).

Virginia Sena

Accepted

1522

3

7

94

95

…...HFCs, having only an indirect impact on the ozone layer Archie McCulloch(Hurwitz et al., 2015), were not regulated under the Montreal
Protocol. However, during the 28th meeting of the parties(MOP28) held in Kigali (Rwanda) in October ….delete "having only an indirect impact on the ozone layer (Hurwitz etal., 2015)," Hurwitz et al., 2015 showed that the indirect effectof HFCs was small and due to their effect on stratospherictemperature, an attribute that they share with other well mixed
greenhouse gases. As it stands, the sentence gives a false senseof the history and politics of the change in the Montreal
Protocol to include HFCs.

Accepted

Comment ID Volume Chapter From line To line

Comment

4892

3

7

Table 7.3B

It would be useful to mention in the Table itself that it is based Elsa Hatanaka
on estimated consumption for HFCs in CO2 eq.

ExpertAccepted

4894

3

7

Table 7.3C

It would be useful to mention in the Table itself that it is based Elsa Hatanaka
on estimated consumption for HFCs in CO2 eq.

Accepted

2518

3

8

Section 8.5 needs proof-reading.

Accepted

6834

3

8

110

110

4598

3

8

21

41

9606

3

8

378

383

4600

3

8

390

4988

3

8

393

4602

3

8

4604

3

8

4606

3

9604

4990

Anna Mikis

Response

Authors notes

As evaluated in Table 1 of the attached paper for Germany,
Edgar Dullni
reported SF6 emissions aggregated under electrical equipment(chapter 8.2) not only contain emissions from electricalswitchgear, but also from accelerators (chapter 8.3) and solar
panels (chapter 6), which should be reported separately. This
could be improved by defining electrical equipment more
precise.
letter case
Kewei Yu

Noted

No action can be taken because the comment is out of scope of the2019 Refinement.

Accepted

Corrected

Raul Salas Reyes
Is it possible to change the names of the groups to avoid
describing them as high-GWP and low-GWP? My thoughts
when reading this is that a reader might understand that CH4,
C3F6, COF2, and C2H4 are less harmful GHGs as they havelower GWP values, which is somehow true but may motivate
industry to use these gases using this justification. I would liketo suggest two more generic names for the groups such as"High Value (HV)" and "Low Value (LV)".
CVD, appears only here
Kewei Yu

Accepted withmodification

Due to the confidentiality of data we will limit the emission factors to
the three principle gases (i.e. the high GWP gases, namely CF4,
C2F6, and CHF3) and allocate emissions to 33% each by weight. For
the avoidance of doubt, emissions will not be reported in CO2e but
emission factors will be expressed in terms of kg of CF4, C2F6, andCHF3 emitted per circuit board manufactured as this is the way thedata has been obtained. More details will be included in the SOD.

Noted

The acronym has been defined.

Päivi Lindh
Emission factors are given for high-volume manufacturing
environment. As the size of the chamber presumably reflects tothe amount of gases used in the process and accordingly to theemissions, it would be beneficial to give guidance how to use
this method and emission factors for smaller facilities (e.g.
research facilities) if the method is also presented in the final
version of the guidelines (noticed that chapter is still underdevelopment).

Accepted

The authors understand the Tier 1 emission factors that are currently
available are based on high-volume manufacturing. Further, theauthors acknowledge that the source of such Tier 1 emission factors
are currently equipment-specific and may evolve as new generationsof equipment and processes may be designed in R&D and released in
production. Thus, the SOD includes guidance to measure processspecific and equipment-specific emissions factors (based on a Tier 3
approach), with the long-term objective of collecting experimental
factors that will eventually enable the development of more refined
Tier 1 and/or Tier 2 approaches.

394

HVM should be placed before "environment"

Kewei Yu

Accepted

395

CO2, subscript, and other places

Kewei Yu

Accepted

8396

Table 8.11, C2F6?

Kewei Yu

Accepted

3

8

396

396

The acronym FTIR has not yet been defined. In addition, I
Raul Salas Reyes
would suggest to further elaborate what a working fab
installation means to increase the clarity of the 2019 guidelines

Noted

3

8

396

398

CH4, PFCs and HFCs should be reported separately andPäivi Lindh
therefore emission factors should be presented disaggregated in
the final version of the guidelines (noticed that the chapter isstill under development).

Accepted

411

Comment ID Volume Chapter From line To line

Comment

8696

3

8

396

398

It is a clear break with normal practice to present EFs in CO2e Ole-Kenneth Nielsen
and it is fundamentally at odds with the practice of reporting
national inventories in pure substances. Also, it begs thequestion of what common metric has been used to convert theemissions to CO2e. Noting that GWPs (and other metrics) areregularly updated, the GWP values used would have to be
defined. Either EFs should be presented in terms of puresubstances or this should be left out of the GL.

ExpertAccepted

4608

3

8

406

411

C2F6 and others, subscript

Noted

882

3

8

409

409

4986

3

8

467

468

Reference to Table 8.11 is not correct. The correct reference is Virginia Sena
Table 8.12.
The section for uncertainty assessment in IPCC 2006 Gls. is
Eva Krtková
not providing enough needed information. Also, there iscompletely missing guidance for uncertainties for emission
estimation from accelerators. Refinement is not providing any
new guidance in this matter. More broad guidance would behighly appreciated.
This new chapter is very substantial and it is unclear what the Ole-Kenneth Nielsen
relevance of this source to global emissions is. It should be
included in the introduction a description on the expected levelof emissions deriving from this activity. Currently, more than
20 pages are included with several subsections still to becompleted. This seems very excessive. Also, the text should
use the typical referencing rather than having references asfootnotes as has been done in the first-order draft.

Accepted withmodification
Noted

Kewei Yu

Response

Accepted

Authors notes

The authors further note that emissions will be reported in massterms, not CO2e.
Table 8.12 has been removed.
No action can be taken because the comment is out of scope of the2019 Refinement.
However, the authors note that the 2006 Guidelines do provide
guidance regarding assessing the uncertainty of accelerator emissions
in section 8.3.3 on page 8.33.
In light of the performed interviews and acquired information noemission levels could be obtained at the moment. Thus, no Tier 1 andTier 2 methods can be provided. The chapter will be substantiallyreduced and information will be included in the appendix consideringa Tier 3 approach in order to provide guidance for the measurent ofemission factors. The references will be corrected and adapted to
IPCC style.

8698

3

8

477

1193

884

3

8

493

493

Virginia Sena
Reference to Table 8.3 is not correct. Table 8.3 from 2006
IPCC Guidelines shows information on CLOSED PRESSURE
ELECTRICAL EQUIPMENT (HV SWITCHGEAR)CONTAINING SF6: DEFAULT EMISSION FACTORS. The
correct reference may be Table 8.15.

Accepted

The table number has been corrected.

886

3

8

495

495

Reference to Table 8.7 is not correct. Table 8.7 from the 2006 Virginia Sena
IPCC Guidelines shows infromation on SF6 EMISSIONS PER
PLANE PER YEAR. The correct reference may be Table 8.19.

Accepted

The table number has been corrected.

888

3

8

507

507

It is written " plasma-based-based" instead of "plasma-based". Virginia Sena

Accepted

4910

3

8

508

509

Accepted

4996

3

8

641

645

72

3

8

681

692

If there are challenges in acquiring data for EFs, it can easily Elsa Hatanaka
be assumed that the AD that is specific enough for thesesources will be extremely hard to acquire. Guidance on AD will
be of importance, and if good data/guidance cannot be
acquired in time, would it be better to move this section to anannex?
Guidelines should provide methods and emission factors to
Päivi Lindh
calculate emissions with Tier 1 or Tier 2 methods. Inventory
calculator has no mandate to demand facilities to measure theiremissions.
Please define the unit of FCi and revise unit of EFi.
Mingshan Su

890

3

8

689

689

The reference to Table 8.4 is not correct. Please include thecorrect one.

Virginia Sena

Noted

The authors further note that the potential concept for Tier 1 and /orTier 2 methodologies will be proposed as part of future developmentof guidance.

Accepted

The unit definition has been corrected (Kg).

Accepted

Corrected

Comment ID Volume Chapter From line To line

Comment

ExpertResponse

Authors notes

4610

3

8

694

m2of??

Kewei Yu

Accepted

Corrected

5588

3

8

71

199

Urban green areas are in the forefront of recent academic
researches with plenty of journal publications, books andconference proceeding. As the newest cited document comesfrom 2013, therefore literature background shall be widened
and renewed in order to be up-to-date. Comprehensive review
of recent literature in the topic may be needed.

Attila Buzasi

Noted[Transferred to AFOLU, must be Chapter 8 Volume 4]. Commenter isapparently referring to Volume 4, not Volume 3.

892

3

8

734

734

It is written "Di" instead of "Dk" in the equation.

Virginia Sena

Accepted

Corrected

9608

3

8

820

820

Is it possible to include a table with examples on the p types of Raul Salas Reyes
processes? This would increase the clarity of the guidelines forusers with less experience in this sector.

Noted

The authors further note that the potential concept for Tier 1 and /orTier 2 methodologies will be proposed as part of future developmentof guidance.

4908

3

8

general

Accepted

4912

3

8

Table 8.11

Elsa Hatanaka
Could all F-gases be expressed both in the chemical formulaand the common name? (i.e. CF4 (PFC-14))
The EF is expressed in grams, but would be more useful if it is Elsa Hatanaka
in kg or t, since it is rare to have an EF in grams in this sector.

4914

3

8

Table 8.12

The EF is expressed in grams, but would be more useful if it is Elsa Hatanaka
in kg or t, since it is rare to have an EF in grams in this sector.

Accepted

4612

3

AnnexesIn Table A1.1, letter case problems for word "issues","assessment", "transfer fluids", "anode" and others.

Accepted

Kewei Yu

Accepted

9648

981

1496

the "2" in CO2 should be made a subscript; overall the text is Yousef Alshammari
well written and show almost no errors. Just a few commentson the production of hydrogen; line 1044 the title may be betternamed as "Reforming Technologies" instead of "Complete
Oxidation" as this would make easier to understand and not to
confuse with full combustion which does not generate H2
Line 1063: the reader may confuse between gasification in
Figure 3.19 and Partial Oxidation in 1090. In fact, Gasification
is partial oxidation. Parital oxidation is not endothermic assuggested it is exothermic when oxygen is added to the system,
but it requires heat to generate steam which later is used in thewater gas shift reaction. Hence, I suggest moving thegasification processes to the Partial Oxidation Section in Line1090, and keeping line 1044 for the steam reofrming
technologies which are endothermic.

Accepted withmodification[Transferred from AFOLU, must be Chapter 3 Volume 3]. Addressing
several comments in one: 1. Accepted. Subscripts changed; 2. Noted;
3. Accepted with modification. Title retained in line 1044, butclarification included in the previuos paragraph saying that oxidation
here refers to feedstock carbon and not hydrogen; 4. Rejected.
Gasification can be both partial oxidation and complete oxidation (asdefined elsewhere in the hydrogen chapter). The water gas shift
reaction and PSA completes the oxidation; 5. Accepted. Sentenceabout endothermic is removed. According to f.ex.
https://www.netl.doe.gov/research/coal/energysystems/gasification/gasifipedia/gasification-chemistry the overall
reaction (excl. combustion) is endothermic, but the water-gas-shiftreaction is slightly exothermic.

9650

1072

1072

Equation 1b is not a hydrogen generation reaction and there is Yousef Alshammari
no need for this equation. A better euqation to be specified is
the water gas shift reaction
which follows the reforming of methane (equation 1a)
CO+H2O=CO2+H2 and that means equation (1a) should be
rewritten as CH4+H2O=CO+3H2 this is followed by the water
gas shift CO+H2O=CO2+H2

Rejected[Transferred from AFOLU, must be Chapter 3 Volume 3]. The
purpose of the equations is to show the conversion from organiccarbon into hydrogen (g) and CO2 in stoichiometric terms, and bothprocess emissions and process related combustion emissions are
relevant.

Comment ID Volume Chapter From line To line

Comment

9652

The same comment here as well, equation 2b is not a hydrogen Yousef Alshammari
generation reaction, this is combustion and has no relevance, it
should be rewritten as a partial oxidation reaction followed bywater gas shift, and the same comment for line (1082) equation
3b

1076

1082

ExpertResponse

Authors notes

Accepted withmodification[Transferred from AFOLU, must be Chapter 3 Volume 3]. The
guidance has been rewritten to say that: "Emissions from combustion
should be included only if the fuel is derived from the feedstock."