NumberReviewer Affiliation Section Section Title From Page To Page From Line To Line Comment Primary EPA Response1 Joe Van Gompel Glade Consulting LLC 1.2 Protocol Objectives 5 5 30 32ESH usually refers to Environmental, Safety, and Health, not Environmental,Safety and, HandlingThe noted error will be corrected.2 Joe Van Gompel Glade Consulting LLC 1.3 Protocol Scope 5 5 37 37CH4 should be CF4. The noted error will be corrected.3 Joe Van Gompel Glade Consulting LLC 2.1.1Description ofExperimental System8 8 30 41Include in this list vacuum pump purges and additional purges between theprocess chamber and the POU abatement device. Sometimes these purgesmay be inside the POU abatement device itself. These are critical and must beaccounted for.This will be added.4 Joe Van Gompel Glade Consulting LLC 2.2.1Method 1—DilutionAdjusted ConcentrationMeasurement11 11 10 10"...while dataiscollected..." should be "...while dataarecollected..." Data isplural.The noted error will be corrected.5 Joe Van Gompel Glade Consulting LLC 2.2.1Method 1—DilutionAdjusted ConcentrationMeasurement11 11 8 26Note that if the DRE measurement made under Method 1 is for CF4, thenMethod 1 is adequate as CF4 is the most difficult of the PFCs (includingbyproducts) to destroy. If CF4 is destroyed to 0.95, then it is certain that thebyproducts with the chamber tool on will be destroyed to 0.95 or greater.No response is required.6 Joe Van Gompel Glade Consulting LLC 2.2.1Method 1—DilutionAdjusted ConcentrationMeasurement11 11 8 26Can Method 1 be performed with dummy wafers and the plasma on? This wouldgive the full range of byproducts while allowing the tool operator to run thedesired PFC gases for as long as required to achieve steady state conditionsduring the measurements.The Protocol provides the flexibility to accommodate such diversity provided (1) the performancestandard is achieved and (2) departures are documented and certified by the analyst.7 Joe Van Gompel Glade Consulting LLC 2.2.3 Equipment Needed 12 12 23 27Mass flow controllers on the separate slip streams may not be adequate toensure uniform mixing from multiple chambers when doing SMPSIF. Thisapproach demands accurate knowledge of the purge flow from the vacuumpump. This value as measured from the vacuum pump may not be accurate,especially from older vacuum pumps. Accurate knowledge of vacuum pumppurge rates is a critical part of the Description of the System, 2.1.1.EPA believes this comment is multiple comments and to address it EPA would like clarification.Further discussion is needed.8 Joe Van Gompel Glade Consulting LLC 2.2.4 FTIR and QMS Protocols 13 13 16 16Remove the double periods at the end of 2 of the sentences. The noted error will be corrected.9 Joe Van Gompel Glade Consulting LLC 2.2.4 FTIR and QMS Protocols 13 13 22 22Normalizing QMS signals to the N+ ion may not account for changes in the N2flow from certain processes when N2 purges change during the course of theprocess run. This detail must also be addressed in the Description of theSystem 2.1.1.Normalization to N has worked well in EPA's and APCI's experience. It's part of APCI's bestpractice. Experience shows that signal drift is uniform across all measured masses, sonormalizing to nitrogen accounts for any drift. EPA will explain this idea in the footnote.NumberReviewer Affiliation Section Section Title From Page To Page From Line To Line Comment Primary EPA Response10 Joe Van Gompel Glade Consulting LLC 2.2.5 Calibration Curves 13 13 30 33Some FTIR quantitative analysis software packages (e.g. AutoQuant Pro usedby Midac Corporation) has the ability to shift to different absorbance peaks overseveral orders of magnitude depending on the concentration of the materialbeing measured. In this case, multiple gas cells may not be required.EPA will include a footnote to incorporate the comment, noting, however, that shifting to anotherpeak may risk influence of interferent that also absorbs at that same wave number. Using multipath cells is best practice for this FTIR application.11 Joe Van Gompel Glade Consulting LLC 2.2.5 Calibration Curves 14 14 Figure 2 Figure 2Figure 2 is not a good example – R2 and Y-intercept data are not shown on theplot.EPA will update the figure to include the R2 and y-intercept values on the plot.12 Joe Van Gompel Glade Consulting LLC 2.3Data Treatment andAnalysis16 22 N/A N/AWhere did the heavy math and statistics come from? That is neither in thereferenced Sematech article nor in the referenced IPCC article. Is this in the 40CFR? It is ponderous – must the workup be that complex? To what end? Canan example Excel spreadsheet be included? Fewer workup errors would occur ifyou don’t force everyone (and there are precious few statisticians out there) towork it out for him/ herself. If this level of statistical analysis is required, then aseries of Excel spreadsheets should be included to minimize errors. Einsteinsaid “Make things as simple as possible, but not simpler”.EPA does not believe this is "heavy math". Rather, it's standard statistics for computingaverages when the variances across measurements that comprise the average vary, which isthe case when measuring absorbances, for example. Simple (unweighted) averages do not takeadvantage of all the information. A set of measurements with larger variance should not getsame weight as a set of measurement with low variance, which is what happens with simple(unweighted) averages. Further, with MS Excel, the calculations are easily automated. Finally,because a performance metric and performance standard is essential to the protocol it becomesnecessary to standardize the method for calculating the averages and standard deviations for theperformance metric.13 Mehran Moalem Applied Materials Inc. General General N/A N/A N/A N/AWe have not sent a comment because the draft is pretty good overall and wellwritten. It also includes the concerns we had expressed before so just wantedto say that the draft is good and our lack of comment is not for not havingreviewed the draft.No response is required.14 Mike ShererSherer ConsultingServices Inc.1 Introduction 4 4 5 5Perfluorocarbon should be perfluorocompound, as NF3 and SF6 are notperfluorocarbons. In addition, CHF3 and CH2F2 are hydrofluorocarbons (HFC).The noted error will be corrected.15 Mike ShererSherer ConsultingServices Inc.1 Introduction 4 4 24 24Decomposition should be changes to deposition. CVD is chemical vapordeposition,notdecomposition.The noted error will be corrected.16 Mike ShererSherer ConsultingServices Inc.1.1 Protocol Purpose 4 4 40 40SF6 is not a chamber cleaning gas. C2F6 and C3F8 are other common chamberclean gases.The noted error will be corrected.17 Mike ShererSherer ConsultingServices Inc.1.1 Protocol Purpose 4 4 41 43The last sentence in paragraph 2, [A variation of Method 1 may be used whenbyproducts are formed, provided appropriate steps are taken to add, to theinfluent abatement-system flow of unutilized PFC(s), proper amounts ofbyproduct PFC.] is hard to understand.EPA will rewrite the sentence to clarify it.18 Mike ShererSherer ConsultingServices Inc.1.2 Protocol Objectives 5 5 30 32ESH should be Environmental, Safety, andHealth,not Environmental, Safetyand,HandlingThe noted error will be corrected.19 Mike ShererSherer ConsultingServices Inc.1.3 Protocol Scope 5 5 37 37CH4 should be CF4. Also not aware that C3F6, which is listed, is used as aninput gas in a fab.The noted error will be corrected.20 Mike ShererSherer ConsultingServices Inc.1.3 Protocol Scope 6 6 9 13This one sentence is long and awkward. Can it be split up? EPA will rewrite the sentence to clarify it.21 Mike ShererSherer ConsultingServices Inc.1.4 History of the Protocol 7 7 16 16Capitalize fourier transform infrared spectrometer. Also “(FTIR)” should be after“infrared” and before “spectrometer”.The noted error will be corrected.22 Mike ShererSherer ConsultingServices Inc.1.4 History of the Protocol 7 7 30 30The word “and” should be “an” before words “EPA Method”. The noted error will be corrected.23 Mike ShererSherer ConsultingServices Inc.1.4 History of the Protocol 7 7 Footnote 6 Footnote 6Please explain why the PFC emissions would be significant during this method.Other procedures like calibrations and operating MFC at 120% of flow couldpossibly allow much more PFC emissions to occur.It is not a matter of now allowing an amount of emissions that are judged to be significant. It hasalways been EPA policy not to permit turning off abatement systems, and hence emitting whatwould be otherwise abated emissions, in order to test their actual or potential performance.24 Mike ShererSherer ConsultingServices Inc.2.2.2Method 2—Total VolumeMeasurement11 11 36 36Separate “singleor” into two words, single or. The noted error will be corrected.25 Mike ShererSherer ConsultingServices Inc.General General N/A N/A N/A N/AIn several locations SEMATCH should be SEMATECH. The noted error will be corrected.NumberReviewer Affiliation Section Section Title From Page To Page From Line To Line Comment Primary EPA Response26 Mike ShererSherer ConsultingServices Inc.2.2.3 Equipment Needed 12 12 16 16“SF6,it” should be two words. The noted error will be corrected.27 Mike ShererSherer ConsultingServices Inc.2.2.3 Equipment Needed 12 12 17 19Please provide examples on how the analyst must provide compellingdemonstration that less than 1 percent of the gas is destroyed.We expect experienced analysts to provide the required demonstrations and this expectation willbe further clarified in the Protocol. One approach, though, might be using, in a single experiment,both CF4 and SF6 as tracer gases, and calculating the ratio of the outlet:inlet ratios for each. Ifthe two ratios were equal (or say with 1 percent of each other), then one would be safe inconcluding that neither was being destroyed by the abatement system so either could serve as aalternative tracer to the noble gas. This approach relies on the substantially different C-F and S-Fbond energies, 485 kJmol and 284 kJ/mol (298K), respectively. In this method, outlet:inlet ratio isthe inverse of the dilution factor.28 Mike ShererSherer ConsultingServices Inc.2.2.4 FTIR and QMS Protocols 13 13 16 16Remove the double periods at the end of the sentence. The noted error will be corrected.29 Mike ShererSherer ConsultingServices Inc.2.2.5 Calibration Curves 13 13 28 28“Dec” should be “December”. The noted error will be corrected.30 Mike ShererSherer ConsultingServices Inc.2.2.6Flow and DilutionMeasurements15 15 32 32Separate “3-5different” into two words. The noted error will be corrected.31 Mike ShererSherer ConsultingServices Inc.5 References 25 25 19 19“Beau” should be “Beu.” The noted error will be corrected.32 Mike ShererSherer ConsultingServices Inc.Another methodology is to accurately flow a non-reactive gas (e.g. CF4)into POU abatement device outlet and measure the concentrationdownstream (usually by FTIR). This methodology requires the followingcriteria to be utilized:1. The non-reactive gas used must be sampled at POU abatement device outletto determine that this gas is not present.2. The non-reactive gas must be injected across the POU abatement deviceoutlet duct. This can be accomplished by using an injection probe with equallyspaced holes.3. The location selected for downstream non-reactive gas analysis must be atleast eight duct diameters downstream from non-reactive gas injection location.4. The location selected for downstream non-reactive gas analysis must be usedfor POU abatement device outlet sampling. This will ensure that any dilution thatoccurs from POU abatement device outlet to this sampling location will beaccounted for.5. It is recommended that the downstream non-reactive gas analysis location betraversed with the sampling probe at a few locations to ensure the non-reactivegas is well mixed. For example, if the duct is 10 centimeters, theduct can be traversed every 2 centimeters to prove each probe location hassame non-reactive gas concentration.EPA, in principle, considers such an approach equivalent to using Kr in those instances whereQMS is not available. EPA, however, has not seen test results from in-fab experiments that showthis method would achieve the performance standard, although EPA believes such a methodshould be capable of achieving the performance standard. Further, it seems there should beanother criterion that specifies that the downstream sampling port be a certain distance ahead ofany header. Finally, without evidence that the method can achieve the performance standard itseems premature to include the method in the protocol. EPA is considering evaluating thesuggested alternative through measurement study in the future. EPA would welcome a review ofany exisitng test results using this method.33ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)General General N/A N/A N/A N/ADocument is still written from the perspective of semiconductor manufacturing. Ifintent is to be applicable to all electronics operations using long-lived fluorinatedgases, protocol needs to be re-worded to be generally applicable to otheroperations besides wafer manufacturing.EPA will clarify in the document language so the Protocol is clearly applicable to otherelectronics manufacturing sectors.34ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)General General N/A N/A N/A N/ANeed to apply to other types of abatement besides thermal units (e.g., plasma). The Protocol focused on thermal abatement systems because dilution is greatest. EPA believesthat tracer Kr tracer method is suited to POU plasma systems. EPA, however, is not aware ofsuch systems in actual use.35ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)General General N/A N/A N/A N/ANeed to integrate JEITA alternative method for measuring dilution through thesystem.EPA has not seen any data on the JEITA method. EPA would welcome a review of any exisitngtest results using this method.36ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)General General N/A N/A N/A N/AIt would be useful if EPA would provide a spreadsheet to assist in capture,manipulation, and reduction of data.EPA leaves this to the discretion of the analyst.Suggested additional methodology to determine the POU abatement device outletvolumetric flow rate.NumberReviewer Affiliation Section Section Title From Page To Page From Line To Line Comment Primary EPA Response37ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)Real LifeIssues NotAddressed inthe ProtocolN/A N/A N/A N/A N/A1. What it takes to construct the "calibration curve", reference library shouldbracket concentrations seen in the field.2. Reference conditions should be reasonably close to sample conditions (temp,press, path length) and will impact data.3. Analysis method will take significant work to determine optimal regions foranalysis to minimize interfererants.4. Heated versus unheated sample lines?5. Optics integrity, fouling due to particulates.6. Signal to noise and resulting detection limits.7. Detector saturation.8. Moisture issues, spectra interference.All of this is specified in the FTIR appendix in 2006 ISMI Guidelines, which the Protocolreferences. Referencing 2006 ISMI Guidelines seems sufficient.38ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)1.1 Protocol Purpose 5 5 15 16Avoid use of "level playing field", not understood by 2nd language people. EPA will adjust the language.39ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)1.2 Protocol Objectives 5 5 25 26Is there a reason to limit applicability to thermal abatement systems? How aboutother types of abatement?While the abatement systems tested in the development of this Protocol were thermal, EPA doesnot see any reason in principle why this Protocol would not be applicable to other abatementsystems in electronics manufacturing facilities. EPA will modify the Protocol to broaden it'sapplicability.40ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)1.2 Protocol Objectives 5 5 25 26Isn’t this protocol supposed to apply to all electronics PFC DRE abatementcharacterizations? If so, strike “during normal wafer processing”.See response to Comment #33.41ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)1.2 Protocol Objectives 5 5 30 32ESH should be Environmental, Safety, andHealth,not Environmental, Safetyand,HandlingThe noted error will be corrected.42ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)1.3 Protocol Scope 5 6 41 7References ISMI 2006 guideline. Please note that ISMI Guideline is currentlybeing revised in a coordinated effort with ISMI’s international membership. Hereand throughout the document, should reference the 2009 SEMATECHGuideline, which will be finalized soon.EPA will keep reference to the 2006 ISMI Guidelines in the DRE Protocol. Appendix B of the2009 ISMI Guidelines outlines one option where dilution is measured by injecting an inert tracerat the abatement system outlet and then concentration is measured at some point downstreamusing an FTIR. However this method has not been tested in an in-fab setting to ensure itsreliability (e.g., to ensure that dilution is properly accounted for). This same method is notavailable in the 2006 ISMI Guidelines. For this reason EPA has not incorporated the 2009 ISMIGuidelines into the DRE Protocol. See also response to comment 32.43ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)1.3 Protocol Scope 6 6 18 19The method stipulates that the relative error must achieve plus or minus 5 %.Presumably they mean < 5% relative error.This is correct, the plus or minus 5% refers the relative error. EPA will clarify this in the Protocol.44ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)1.3 Protocol Scope 6 6Footnotes 3and 4Footnotes3 and 4Selection of fraction emitted as the benchmark/performance metric seemspredicated on low DRE. For a well functioning abatement unit with DREapproaching 1, all the same issues will occur with using the relative error offraction emitted as are identified with using the relative error of DRE as DREapproaches 0. The benchmark metric and performance standard defined for thisprotocol should not be so sensitive to the DRE itself. Should the acceptable errorbe defined as a percentage of the unabated emission value instead? Whilefootnote 4 argues that the proposed 5% relative error performance standard isachievable, it is not clear that this is true across the full range of DREs.EPA is modifying the performance metric and performance standard accordingly. The modifiedperformance metric is (i) fraction of emitted gas (=Cout/Cin) measured under actual or emulatedprocess conditions when Cout > C* (where C* >> CDL, the detection limit) or (ii) fraction C*/CInwhen Cout≤C*. The revised Protocol will include a table of C* values for relevant F-GHGs.The performance standard is relative error of fraction emitted≤±10%, 95% CI, calculated usingmethod of weighted variances.45ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)1.4 History of the Protocol 7 721 andFootnote 621 andFootnote 6We question the cost-benefit of the ban on the detuning (bypass) method. Giventhe short duration of the test protocol, and in recognition that the method is for asingle tool with relatively low emissions; we questionwhether the ban on the de-tuning method is justifiable....i.e., “prevents asignificant quantity of PFC emissions.”See answer to comment #2.46ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.1Prepare MeasurementPlan8 8 7 19An advance plan is good. However, we should take care to ensure that, asworded, the measurement plan does not require a visit to the site 2 weeks inadvance of the work.As worded, the Protocol does not require a visit to the site 2 weeks in advance of the work. Theplan should be submitted to the facility personnel 2 weeks prior to the visit to the site.47ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.1.1Description ofExperimental System8 8 30 41Should some level of tool and abatement process operating conditions becollected during the measurements? Include in protocol as a suggestion.EPA will expand the list in Section 2.1.1 to include process operating conditions.48ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.1.1Description ofExperimental System8 8 30 41Should the list be more explicit with regard to the recording of operatingconditions, so that the results are “bridgeable” from one test to another?EPA will expand the list in Section 2.1.1 to include process operating conditions.49ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.1.3 Required Resources 9 9 Figure 1 Figure 1Will MFCs function in this configuration, the schematic locates them on thesuction side of the pump? They would be at negative pressure, typical MFCsneed pressure (i.e. 20-50psi) to function properly.EPA has used this set up in an in fab experiment, and there have been no issues with theMFC's. MFCs can be used at negative pressure provided there is a pressure drop across theMFCi.e., inlet has to be at a higher pressure than outlet.50ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.1.3 Required Resources 9 9 Figure 1 Figure 1What is a "calibration system"? Is this gas delivery via MFC? Need more info, if itis MFCs then same comment as above.The protocol requires the same methods of instrument calibration as in 2006 ISMI Guidelineappendixes. Yes, gas delivery is via MFC using pressurized cylinders which provides for a largepressure drop across MFC,51ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.1.3 Required Resources 9 9 Figure 1 Figure 1Need to specify minimum distance between pump exhaust and FTIR2 inlet toavoid recirculation issues.The Protocol will be modified to advise the analyst to be mindful of recirculation issues andplacement into returning the sample to the exhaust line.NumberReviewer Affiliation Section Section Title From Page To Page From Line To Line Comment Primary EPA Response52ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.1.5 Safety 10 10 9 9Mentions “integrated circuit fabrication environment.” Don’t forget this issupposed to apply to flat panel and solar facilities.See response to Comment #33.53ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2MeasurementMethodology10 11 22 6SIA or ISMI GHG WG should ensure that the proposed < 5 % relative error is anappropriate and readily achievable error threshold.EPA agrees. EPA has demonstrated that the <5% relative error is achievable through ourmeasurement studies. See response to comment #44.54ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2MeasurementMethodology10 11 22 6Include JEITA alternative for measuring dilution. See response to Comment #35.55ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2.1Method 1—DilutionAdjusted ConcentrationMeasurement11 11 8 26The use of the term "scrubber" is confusing if not misleading, because this termis widely used in the chemical engineering literature to refer to gas to liquidtransfer processes. In this procedure the subject is a “POU abatement device”which in fact may be fitted with a true scrubber to remove fluoride ions from theabatement unit gas effluent stream.EPA is referring to the POU abatement system when the term scrubber is used. To ensure thereis no confusion, EPA will no longer use the terms interchangeably in the Protocol, and will use"abatement system" throughout.56ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2.3 Equipment Needed 12 13 10 2Is NDIR an appropriate method for abatement effluent characterization? Shouldit be included? If it is included, what is needed to obtain good results?NDIR is not intended to characterize emissions; instead it's intended to monitor the concentrationof a specific F-GHG that's leaving the abatement system. NDIR is suggested as way formonitoring changes in the performance of the abatement system57ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2.3 Equipment Needed 12 13 Table 1 Table 1What is a metal bellows sample pump? Do we mean flex foreline fitting bellows?Do we mean metal diaphragm? If so what type of metal? Might not hold up tocorrosives.A metal bellows sample pump is a dry mechanical pump that utilizes metal bellows technologyas the pumping chamber. They are designed specifically for emissions testing and corrosiveservice.58ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2.3 Equipment Needed 12 13 Table 1 Table 1Sample filter, pore size spec? Material spec? Could impact pressure drop/datasignificantly over time for dirty processes and unheated lines.EPA does not believe such detail is necessary since the users of the Protocol are expected to beexperienced in in-fab emissions and abatement system testing. This expectation will be furtherclarified in the Protocol.59ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2.4 FTIR and QMS Protocols 13 13 8 22There seems to be confusion between sample rate, reported averages, FTIRscan rate "The sampling frequency for the FTIR should be less than 3 seconds".Is this a scan, reported average? If it is reported average it seems awfully low. Ithink scan rate will instrument dependent.This section will be revised to clarify the terms scan rate (a function of resolution), data points,requirements to achieve adequate temporal resolution and measurement precision. In the testsEPA performed, 4 FTIR scans were co-added, which takes 2.2 secs at 0.5 cm-1 resolution andprovides adequate temporal resolution to follow time-varying process emissions. Thus, eachdata point requires 2.2 sec, so 40 data points requires approximately 1.5 minutes.60ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2.4 FTIR and QMS Protocols 13 13 12 16FTIR absorbance range of "0.1 to 1" is somewhat arbitrary and detector specific. This is the same range prescribed in Appendix Aof the 2006 ISMI Guidelines.61ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2.5 Calibration Curves 13 14 24 25Why is a 6 point calibration curve required for QMS, but apparently only a 2 pointcalibration curve required for FTIR?EPA revised the text such that a minimum of three calibration points are required for FTIRcalibration such that expected measured absorbance range is covered. Having a minimum of 3concentration/flows for FTIR assures reliable information on linearity of calibration systems.However, the actual number of calibration points, above 3 points, is user determined. Quality ofcalibration may be judged by proximity of R2 to 1.00. For non-linear calibration curve, itsimportant that highest observed concentration is within not outside the range of concentrationsused to define the calibration curve. Experience with QMS supports using 6 calibration pointsdespite the QMS having a greater dynamic range than the FTIR.62ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2.5 Calibration Curves 14 14 16 20Is the stipulation of an R2 value of better than 0.98 mathematically consistentwith a RSE of better than 5 %?The two are unrelated. R2 measures the quality of the linear or polynomial fit; the lattermeasures the RSE of the slope.63ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.2.6Flow and DilutionMeasurements15 15 32 34Is the stipulation of a minimum of 3 flow rates with an average derived from aminimum of 40 distinct analytical measurements, for each flow rate, appropriate?How was this number selected?Using 40 data points provides for good precision, and is sufficient to easily achieve theperformance standard without taking too much time (1.5 minutes per data point as noted inresponse to Comment #59.64ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.3.1.1 Total Volume Flow 17 17 4 14We are confused why different minimum measurement data collection quantitiesof 640, 40, and 60 are alternately applied here. What is the basis for selectingthese numbers?EPA will correct a typo; all of these numbers should be 40 and this will corrected in the Protocol.A minimum of 40 measurements for each flow rate will provide good measurement precision.65ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.3.1.1 Total Volume Flow 17 17 16 19Why must there be a minimum of 180 TVF data points? What is the physical ormathematical basis for selecting this number?EPA revised this to be 120, which represents a minimum of 3 flow rates and 40 measurements.See response to comment #63.66ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)2.3.1.1 Total Volume Flow 16 19 32 10The statistical methods and equations, along with any specific sample numberrequirements they may have should be referenced to standard textbooks orsimilar reference material.EPA will include this standard and well-recognized text: "Data Analysis for Scientists andEngineers", Stuat L. Meyers, John Wiley & Sons, Inc., New York 1974. Page 146-147.67ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)3Benchmark RelativeError22 22 25 28"These formulas may not be applicable when using alterative methodologies tothose presented in this protocol are used..." Does this mean that alternativemethods are ok? It implies that way. Also note typo in quotes.The Protocol does allow for alternative experimental methodologies to be used, however dataanalysis methodologies presented in the Protocol are only applicable when there are an identicalnumber of measurements for each flow. EPA will clarify this in the Protocol.67ISMI GHG WorkingGroupInternational SematechManufacturing Initiative(ISMI)3Benchmark RelativeError22 22 21 28Defines benchmark as fraction destroyed (DRE), contrary to earlier definition asfraction emitted. See discussion of Section 1.3.The benchmark parameter is the true fraction emitted, not the fraction destroyed. EPA willcorrect this in Section 3.