General comments (1) Price level needs to be specified (recommended: € 2000). Operation and maintenance costs (O+M) should be splitted into fixed (depending on investments) and variable (depending on the actual use of the plant). Emission controls already included for each reference installation (RI) should be specified. For each control technology (CT) emission reductions and costs should be given in terms of additional reductions/costs compared with the RI. Way of calculating of variable costs should be specified for each RI and (if different) for each CT. The documents should provide the total abatement cost, per unit of activity. Interest rate for calculating annuity should be 4% per year

General comments (2) Data necessary for calculating variable O+M costs need to be specified for each CT. Different technologies may require different data and thus different table formats!! Emissions of PM should be given as TSP (total suspended particles), PM fine (<2.5 μm) and PM coarse (2.5 – 10 μm). For some activities a clear distinction between stack and fugitive emissions needs to be made. It is of particular importance for PM emissions from industrial processes. Technologies for controlling fugitive emissions should be specified separately.

General comments (3) Add for each sector a short description of the current EU emission control legislation (as it has been done in the VOC documents). In all documents a definition of applicability should be included. For instance: Applicability means the Maximum possible application rate of a particular technology, as percentage of total national activity of the given reference installation. Activity levels for each combination of reference installation and control technology should be given for the period 2000 – 2020 with 5- years intervals. Uncertainties should be specified separately for emission factors for each pollutant. A separate assessment should be performed for cost items. In the current layout of the tables the uncertainty parameter cannot be determined at all. Documents require language editing.

Petroleum industry - general A good starting point. Paragraph about current EU emission legislation applicable to the sector (as in the VOC documents) would be very useful. Some numbers can already be used to create input to RAINS. Total costs per unit of activity calculated with 4% interest rate should be calculated in order to allow comparison with other sources. Names of the tables should be possibly unified across the documents (coordinate with CITEPA). Tables *.6: “Technical description (characterization) of abatement techniques” present parameters needed to calculate variable costs. Consider changing the name of the table. Coordinate with CITEPA.

Combustion in refineries (1) Specify clearly the unit for capacity (MW thermal input or MW electric?) Give energy inputs, energy outputs and own use for RI. This can be done in relative terms per unit of fuel input to the plant. Are energy efficiency measures applicable? Technologies for controlling SO2 and PM emissions are missing. Perhaps the RI with SO2 and PM controls is appropriate for the EU countries. It is definitely not a case in some east European countries.

Combustion in refineries (2) For option depending on fuel switching the substitution ratio should be given (i.e., units of GAS /unit of HF replaced for the same output of the plant). Difference in electricity consumption and values necessary for calculation of variable costs need to be given. The most important ones are: fuel and electricity prices, change in the demand for and costs of labor, sorbents, waste disposal (FGD installation which seems to be included in the RI will not be needed any more). Some data are missing e.g., costs for SCR installation. Why SCR is not applicable for HF plant?

Refinery process furnaces Second Para in sec. 4.3: PM is also a relevant pollutant Specify clearly capacity unit Control assumed for the RI seems to be HF with 1% S. Is this assumption applicable to sources in all countries, also in eastern Europe? Technologies for controlling SO2 and PM emissions are missing Is switching to gas a viable option? Are energy efficiency measures applicable?

Fluid catalytic cracking The Heavy Oil Residue Cracker (HORC) and the Residue Catalytic Cracker (RCC) have different structures of inputs and outputs. The value of output is definitely different. Thus can RCC be really treated as an abatement option for Fluid Catalytic Cracking Unit? Are the differences in the value of products included in the O+M costs? In Para 5.4.2 the description of CO boiler (RCC) is missing Current low implementation of SNCR in Europe does not mean that that option cannot be used in the future Structure of Table 5.6 needs to include parameters not only for NOx control technologies but also for other options (e.g., wet scrubbing) Why technical lifetime of SCR is only 8 years? The lifetime of the RI is 20 years. Does the CT lifetime need to be specified separately?

Sulfur recovery plants Specify clearly capacity unit. Plant size (or capacity) should be possibly in the same unit as the activity unit for the emission factor. Here the size seems to be in terms of S recovered per day. If, for any reason, the capacity unit is different, appropriate “conversion factor” should be given Provide all parameters necessary for calculating variable costs