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US EPA Mandatory Reporting Rule Endorses ASTM D6866

  • The U.S. Environmental Protection Agency (EPA) requires annual reporting of a company’s greenhouse gas emissions
  • General stationary combustion units using municipal solid waste (MSW) and mixed fuels (biomass-derived with fossil fuels) can use ASTM D6866 to determine biogenic CO2
  • Beta Analytic is committed to provide ASTM D6866 testing to companies as they comply with the EPA mandatory reporting rule

ASTM D6866 for Biogenic CO2 Quantification

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Stationary combustion units using MSW and mixed fuels (biogenic fuels with fossil fuels) are allowed to use ASTM D6866 to measure the biogenic CO2 in their emissions.

According to the EPA’s Mandatory Reporting Rule:

“Perform the ASTM D7459–08 sampling and the ASTM D6866–08 analysis at least once in every calendar quarter in which MSW is combusted in the unit. Collect each gas sample during normal unit operating conditions for at least 24 total (not necessarily consecutive) hours, or longer if the facility deems it necessary to obtain a representative sample. Notwithstanding this requirement, if the types of fuels combusted and their relative proportions are consistent throughout the year, the minimum required sampling time may be reduced to 8 hours if at least two 8-hour samples and one 24-hour sample are collected under normal operating conditions, and arithmetic average of the biogenic fraction of the flue gas from the 8-hour samples (expressed as a decimal) is within ± 5 percent of the biogenic fraction from the 24-hour test.” – Page 79150

“For other units that combust combinations of biomass fuel(s) (or heterogeneous fuels that have a biomass component, e.g., tires) and fossil (or other non-biogenic) fuel(s), in any proportions, ASTM D6866–08 and ASTM D7459–08 may be used to determine the biogenic portion of the CO2 emissions in every calendar quarter in which biomass and non-biogenic fuels are co-fired in the unit. If the primary fuel for multiple units at the facility consists of tires, and the units are fed from a common fuel source, testing at only one of the units is sufficient.” – Page 79150

In December 2010, the EPA has amended the MRR to remove the restriction limiting the use of ASTM Methods D7459-08 and D6866-08 to units with CEMS. Rather, any unit that combusts combinations of fossil and biogenic fuels (or partly biogenic fuels such as tires), in any proportions, is allowed to determine biogenic CO2 emissions using the ASTM methods on a quarterly basis.

At least 24 cumulative hours of sampling per quarter are required although the EPA is allowing sources to demonstrate that 8 hours of sampling per quarter is sufficient. The demonstration requires a minimum of two 8-hour tests and one 24-hour test, performed under normal, stable operating conditions. The demonstration tests must be distinct, i.e., no overlapping of the 8-hour and 24-hour test periods is permitted. If the average biogenic fraction obtained from the 8-hour tests is within ± 5 percent of the results from the 24-hour test, then, in subsequent quarters, ASTM Method D7459-08 sampling time may be reduced to 8 hours. The results of the demonstration must be documented in the monitoring plan.

The EPA has also amended the MRR to allow the owner or operator to collect an integrated sample by extracting a small amount of flue gas (1 to 5 cubic centimeters) during every unit operating hour in the quarter to obtain a more representative sample for analysis. – Page 79150

The EPA has added an alternative calculation methodology for biogenic CO2 emissions from the combustion of tires and/or MSW which may be used when the total contribution of these fuels to the unit’s heat input is 10 percent or less. The EPA is also allowing this methodology to be used for small batch incinerators that burn no more than 1,000 tons of MSW per year. – Page 79143

The EPA MRR and other documents related to it can be downloaded here.

US EPA Mandatory Reporting Rule (MRR)

carbon dioxide emissions for ASTM Method D6866 testingAll companies with facilities emitting a minimum of 25,000 metric tons CO2 equivalent per year in combined emissions are required by the EPA to submit annual greenhouse gas reports no later than March 31 of each calendar year for GHG emissions in the previous calendar year. Gathering of data starts January 1, 2010, and the first report is due in March 2011. Carbon dioxide emissions from biomass combustion are excluded from the annual report while CH4 and N2O emissions from biomass combustion are included.

UPDATE: The US EPA has extended the 2011 deadline for GHG emissions reporting program from March 31 to September 30. The extension will allow the US EPA to further test their electronic reporting platform and provide industry with the opportunity to provide feedback and become familiar with the tool prior to reporting. All entities required to submit data must register with the electronic GHG reporting tool (e-GGRT) by August 1, 2011.

The MRR specifies the sources of emissions in various industries, the methodologies to use when calculating for annual emissions, as well as monitoring, record keeping, and verification requirements to ensure the accuracy of reported data.

General stationary combustion units are required to report annual CO2, CH4, and N2O emissions. The EPA describes stationary fuel combustion sources as “devices that combust solid, liquid, or gaseous fuel, generally for the purposes of producing electricity, generating steam, or providing useful heat or energy for industrial, commercial, or institutional use, or reducing the volume of waste by removing combustible matter.” Examples of stationary combustion units include boilers, simple and combined-cycle combustion turbines, engines, incinerators, and process heaters.

The MRR specified four calculation methodologies for CO2 emissions from fuel combustion. Those that use MSW as fuel and those that co-fire biomass fuels with fossil-based fuels are required to report biogenic CO2 emissions separate from their non-biogenic CO2 emissions.

ISO/IEC 17025:2005-Accredited Beta Analytic

Based in Miami, Florida, Beta Analytic is the world leader in ASTM D6866 testing. The company has contributed to the development of this ASTM standard. The method, which uses radiocarbon dating techniques, can determine biogenic CO2 by measuring the gas sample’s carbon 14 content. CO2 from combusted biomass still have carbon 14 left while CO2 from fossil fuel combustion no longer have this carbon isotope. This difference makes it possible to determine the exact percentage of the gas that came from renewable sources/biomass.

Beta Analytic supports initiatives in the reduction of greenhouse gas emissions and is committed to provide high-quality, reliable testing to fulfill the requirements of current climate change laws and regulations.