You are seeing our new document Reader view. Click here to revert. Feel free to leave us feedback on this feature .
×
  • Embed Doc
  • Copy Link
  • Readcast
  • Collections
  • CommentGo Back
Download
 
Beta Analytic LimitedLondon Bioscience Innovation Centre2 Royal College StreetLondon NW10NHUnited KingdomTel: (44) 207 617 7490Fax: (44) 207 160 5350Email: info@betalabservices.comBeta Analytic Inc. (Headquarters)4985 SW 74 CourtMiami, Florida 33155USATel: (1) 305-662-7760Fax: (1) 305-663-0964Email: info@betalabservices.comWeb site:www.betalabservices.com
 U.S. Environmental Protection AgencyAir and Radiation Docket and Information Center -Mailcode: 2822TAttention: Docket ID EPA-HQ-OAR-2005-01611200 Pennsylvania Ave., NWWashington DC 20460May 28, 2009Reference: Docket ID EPA-HQ-OAR-2005-0161: Comments on the use of ASTM D6866 andMunicipal Solid WasteDear Sir / Madam:The EPA solicits comments whether the biomass fraction of municipal solid waste should beallowed as a feedstock for biofuels. We believe that it should particularly since the ASTM D6866test can accurately determine the biomass fraction of the resultant fuel. It must be noted that theASTM D6866 method is already adopted in the current EPA's greenhouse gas reporting ruleunder the Tier 4 sampling protocol for municipal solid waste (pages 16636 to 16639), specificallyfor the measurement of the biogenic CO2 fraction.As a reminder, the ASTM D6866 method is a standardized version for industrial use ofradiocarbon dating, an analytical technique that was developed in the 1950s. Radiocarbon datinghas been 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 biomass component of fuelsand other materials. Biomass contains a well-characterized amount of carbon-14 that is easilydistinguished from other materials such as fossil fuels that do not contain any carbon-14. Sincethe amount of carbon-14 in biomass is well known, a percentage of biogenic carbon can becalculated easily from the overall carbon atoms in the sample.Although ASTM D6866 is now used throughout the world to measure biomass carbon / CO2, theorigins of the method are American. It was written at the request of the USDA to satisfy legislationrequiring federal agencies to prefer procurement from manufacturers using the greatest amountof biomass in their products (per the Farm Security and Rural Investment act of 2002). It wasquickly established that radiocarbon dating is the only viable and accurate technique to determinethe biomass 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).The ASTM D6866 method is the only analytical method that can determine the biomass carbonfraction of fuels that are chemically identical. For example, synthetic ethanol made from fossilfuels is chemically indistinguishable from bioethanol made from a biomass feedstock. ASTMD6866 is the only method that can determine precisely the percentage of biogenic carbon inethanol samples. The same holds true for methanol from biomass and fossil fuel sources. In asimilar light, the ASTM D6866 method can help resolve biomass fraction ambiguities in complexfuel mixes such as Hydrogenation-Derived Renewable Diesel (HDRD).
    of 00

    Leave a Comment

    You must be to leave a comment.
    Submit
    Characters: ...
    You must be to leave a comment.
    Submit
    Characters: ...