Beta Analytic's Comments on the Use of ASTM D6866 for MSW as Recommended by the U.S. EPA

8/14/2019 Beta Analytic's Comments on the Use of ASTM D6866 for MSW as Recommended by the U.S. EPA

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Beta Analytic LimitedLondon Bioscience Innovation Centre2 Royal College StreetLondon NW10NHUnited KingdomTel: (44) 207 617 7490Fax: (44) 207 160 5350Email: [email protected]

Beta Analytic Inc. (Headquarters)4985 SW 74 CourtMiami, Florida 33155USATel: (1) 305-662-7760Fax: (1) 305-663-0964Email: [email protected] site: www.betalabservices.com

U.S. EPAAttention: Ms. Carole CookOffice of Atmospheric ProgramsClimate Change Division, Mail Code 6207JWashington, DC 20460

May 5, 2009

Reference: Docket ID No. EPAHQOAR20080508: Mandatory Reporting ofGreenhouse Gases; Proposed Rule Comments on the use of ASTM D6866

Dear Ms. Cook:

In several sections of the proposed greenhouse gas reporting protocol, the EPA solicitscomments on how to better quantify the biomass fraction of fuels. There is a readilyavailable method called ASTM D6866 that can precisely and accurately quantify thebiomass fraction of any type of fuel or material (gas, liquids, or solids).

This method is already adopted in the current reporting rule under the Tier 4 samplingprotocol for municipal solid waste (pages 16636 to 16639). The EPA should broaden theuse of this method for all fuels and materials since municipal solid waste is in essence aheterogeneous fuel / material.

The ASTM D6866 method is a standardized version for industrial use of radiocarbondating, an analytical technique that was developed in the 1950s. Radiocarbon dating hasbeen used for decades for dating archaeological artifacts. The same principles of dating(i.e. analysis of the carbon-14 atom) can also be used to measure the biomasscomponent of fuels and materials. Biomass contains a well-characterized amount ofcarbon-14 that is easily distinguished from other materials such as fossil fuels that do notcontain any carbon-14. Since the amount of carbon-14 in biomass is well known, apercentage of biogenic carbon (or in the case of a gas sample, biogenic CO2) can becalculated easily from the overall carbon atoms (or CO2) in the sample.

Although ASTM D6866 is now used throughout the world to measure biomass carbon /CO2, the origins of the method are American. It was written at the request of the USDAto satisfy legislation requiring federal agencies to prefer procurement frommanufacturers using the greatest amount of biomass in their products (per the FarmSecurity and Rural Investment act of 2002). It was quickly established that radiocarbondating was the only viable and accurate technique to make the determination of thebiomass percentage. A working standard of radiocarbon dating for industrial use wascompleted in 2004 and is now cited in US Federal Law (7 CFR part 2902).


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We believe that the ASTM D6866 method should be allowed for all heterogeneous fuels(i.e. those that contain a biomass fraction), not just municipal solid waste as cited in thecurrent EPA greenhouse gas reporting rule. The EPA should expand the use of ASTMD6866 to include all heterogeneous and alternative fuels, including those referenced inTable C-2 on page 16640 of the EPA protocol.

Current regional protocols in the US, such as California's AB 32 and the WesternClimate Initiative, allow the use of ASTM D6866 for heterogeneous fuels. Below are twolinks where ASTM D6866 is cited for heterogeneous fuels in these two protocols:

California's AB32: (Operator advised to use ASTM D6866 to determine CO2 emissionsfrom the combustion of biomass, municipal solid waste, or waste-derived fuels withbiomass.)Page 93, http://www.arb.ca.gov/regact/2007/ghg2007/frofinoal.pdf

Western Climate Initiative: (Operator that combusts fuels or fuel mixtures that containbiomass shall determine the biomass-derived portion of CO2 emissions using ASTMD6866.)

Page 79, http://www.westernclimateinitiative.org/ewebeditpro/items/O104F20744.pdf

The European Union also allows the use of carbon-14 for measuring heterogeneousfuels, particularly for solid recovered fuels (SRF) and refuse-derived fuels (RDF). Acarbon-14 method called CEN/TS 15747:2008 was developed for these types of fuels. Itis almost identical to ASTM D6866. In fact, CEN/TS 15747:2008 cites ASTM D6866 asthe premise for the method.

In 2007, the European Union published a FAQ for the EU Emissions Trading Scheme.On pages 16 and 17, carbon-14 is cited as an acceptable method for determining thebiogenic fraction of heterogeneous fuels. Both ASTM D6866 and CEN/TR 15991:2007(precursor to CEN/TS 15747:2008) are cited as acceptable carbon-14 methods. The EU

ETS FAQ can be found at this link:http://ec.europa.eu/environment/climat/emission/pdf/mrg2faq_sep_2007.pdf

Of course, it must be noted that Europe, California, and the Western Climate Initiativeare not the only entities advocating the use of carbon-14 for heterogeneous fuels.Australia has also advocated its use, particularly for blended fuels. More information onthe Australian protocol can be found here (see pages 114 to 115):http://www.climatechange.gov.au/reporting/publications/pubs/nger-technical-guidelines-v1-1.pdf

Lastly, we would like to add that The Climate Registry's Greenhouse Gas ReportingProtocol (please see page 65) also advocates the use of ASTM D6866 for biomass

derived fuels. More information can be found at this link:http://www.theclimateregistry.org/downloads/GRP.pdf

In light of the acceptance of the ASTM D6866 method for all heterogeneous fuels, webelieve that the method should be allowed for all fuel types (i.e. gas, liquids or solids).The method works equally well for any material. Under certain circumstances (e.g. plantoperators without CEMS), sampling the liquid or solid fuel itself might make more sense.


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Of course, it is better to sample the final CO2 emission to determine the biogenic fractionfrom the combustion. Nonetheless, there are situations where analyzing the liquid orsolid fuel is more economical, particularly if a representative sample can be submitted tothe laboratory. This is often the case for the cement industry that is concurrently doing ahost of other tests on their solid fuels. In that regard, the CEN/TS 15747:2008 methodwas created in Europe because the cement and paper/pulp industries are important

users of SRF/RDF. They perform a host of tests on the SRF/RDF itself, along with thebiogenic fraction determination.

On that note, the EU ETS FAQ cited before contains sampling recommendations onpage 17 for liquid and solid fuels.

We would like to mention that the ASTM D6866 method would address perfectly theconcerns cited in Section V, Subpart MM (pages 16569 to 16575). The method candetermine unambiguously the biomass fraction of any fuel mix. For example, syntheticethanol made from fossil fuels is chemically indistinguishable from bioethanol made froma biomass feedstock. ASTM D6866 is the only method that can determine precisely thepercentage of biocarbon in the fuel mix. In a similar light, the ASTM D6866 can help

resolve biocarbon fraction ambiguities in complex fuel mixes such as Hydrogenation-Derived Renewable Diesel (HDRD).

Lastly, we would like to suggest that the Tier 4 calculation allow the use of ASTM D6866to calculate the biogenic CO2 fraction of any waste fuel or material, not just municipalsolid waste. Since the ASTM D6866 method works equally well for any waste materialsthat contain a biomass fraction, the EPA protocol should include along with municipalsolid waste, the use of ASTM D6866 for any waste materials, waste fuels, tires andalternative fuels in the Tier 4 biogenic calculation protocol.

In summary, we are advocating through this public comment that the EPA should allowthe use of ASTM D6866 for all heterogeneous/alternative fuels (i.e. those that contain a

biomass fraction) to determine the biogenic percentage. We are also advocating thatplant operators be allowed to use the ASTM D6866 method to determine the biogenicfraction on the fuel itself when gas sampling is difficult. Contrary to emission factors orother methods (e.g. manual sorting), the carbon-14 method can accurately determinethe biogenic fraction on any type of fuel (gas, liquid, or solid).

As can be seen with the national and international GHG protocols cited in this comment,the ASTM D6866 method has been accepted widely throughout the world for themeasurement of the biogenic fraction of heterogeneous fuels. It is important that theEPA GHG protocol adopt similar reporting methods to ensure that CO2 emissionscalculated in the United States are the same as the CO2 emissions calculated with theseother protocols.

Sincerely,

Thierry Sam TamersDirector

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Beta Analytic's Comments on the Use of ASTM D6866 for MSW as Recommended by the U.S. EPA