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US EPA Amended Renewable Fuel Standard Requires ASTM D6866 Testing for MSW-Derived Biofuels

The US EPA’s amended Renewable Fuel Standard, also called RFS2, requires ASTM D6866 testing to determine the biogenic fraction of transportation fuels derived from municipal solid waste (MSW), where the renewable portion of the fuel cannot be determined based on the relative energy content of the renewable biomass and fossil feedstock. ASTM D6866 can also be used to measure the biogenic fraction of partially renewable fuels, which are produced by simultaneously co-processing renewable biomass and non-renewable feedstock. Knowing the biogenic fraction of these partially renewable fuels is necessary in generating their Renewable Identification Numbers (RINs).

The RFS2 applies to entities that produce, distribute, or sell transportation fuels within the U.S. during a compliance period. Producers and importers of fuels not designated or intended for use as a transportation fuel, heating oil, or jet fuel may not generate RINs for their products.

A copy of the amended RFS2 was first published in the EPA website on February 3, 2010. The official version of the RFS2 will be published in the Federal Register. The amended RFS2 is effective on July 1, 2010.

Renewable Fuels from Municipal Solid Waste

Under the RFS2, the EPA allows producers using MSW-derived feedstock to generate RINs for the renewable fraction of the fuel. The biogenic portion of the renewable fuel is determined through the ASTM D6866 test. Producers of partially renewable fuel can use their ASTM D6866 test results for generating RINs. Alternatively, they can calculate the renewable portion of the fuel based on the relative energy content of the renewable biomass and fossil feedstock. Regardless of their chosen approach, the biofuel producers must separately verify that their renewable feedstocks meet the EPA’s definition of renewable biomass.

The biofuel producers and importers will assign a D code of 3 in their RIN for the biogenic portion of their MSW-derived fuels. In establishing this D code, the EPA presumes that the biogenic fraction is 100% cellulosic, which is the predominant component of MSW.

Source: Page 14876 of the RFS2

ASTM D6866 Testing of Transportation Fuels

Biofuel producers opting for ASTM D6866 testing are required by the EPA to apply the test to every batch of fuel or to a composite sample consisting of fuels taken from every batch produced within one calendar month. For composite samples, the EPA says that the resulting renewable fraction will be applied to all batches of fuel produced in the next month to determine the appropriate number of RINs that must be generated. For the first month, the producer can estimate the non-fossil fraction and then make a correction as needed in the second month. The producer will be required to recalculate this renewable fraction for the subsequent months.

The EPA has also added a provision in the RFS2 for exporters of renewable fuels that are in the form of a blend with gasoline or diesel. Exporters may determine the amount of renewable fuel in a blend by obtaining the information from their supplier, using ASTM D6866 to determine the renewable content of the fuel, or by assuming the maximum concentration of the renewable fuel in the blend as allowed by law and/or regulation.

Source: Page 14880 of the RFS2

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