Comment Details
| Comment Author: | Thierry Sam Tamers |
| Organization: | Beta Analytic Inc. |
| Comment Date: | Wednesday, 20 May 2009 |
| Comments: |
Attachment 1: General Provisions: Dear Sir / Madam: We would like to bring to your attention that there might be a misinterpretation that sewage, as mentioned in the definition of "waste derived fuel", is entirely from biomass. Our internal tests using method ASTM D6866 and numerous research publications (two cited below) have demonstrated that sewage contains an important amount of fossil carbon from sources such as detergents, shampoos, etc. We therefore recommend that the Western Climate Initiative include sewage, along with other materials/fuels that contain fossil carbon, in the sub-category of heterogeneous fuels such as municipal solid waste as cited in the "waste derived fuel" definition. W Giger, PH Brunner, and C Schaffner, 4-Nonylphenol in sewage sludge: accumulation of toxic metabolites from nonionicsurfactants, Science 10 August 1984, Vol. 225. no. 4662, pp. 623 - 625. http://www.sciencemag.org/cgi/content/abstract/225/4662/623 J. McEvoy and W. Giger, Accumulation of linear alkylbenzenesulphonate surfactants in sewage sludges, Naturwissenschaften, Volume 72, Number 8 / August, 1985, 429-431. http://www.springerlink.com/content/m445654ju0011888/ Sincerely, Thierry Sam Tamers Director Email: ttamers@betalabservices.com European Facility: Beta Analytic Limited London Bioscience Innovation Centre 2 Royal College Street London NW10NH United Kingdom Tel: (44) 207 617 7490 Fax: (44) 207 160 5350 North American Facility: Beta Analytic Inc. 4985 SW 74 Court Miami, Florida 33155 USA Tel: (1) 305-662-7760 Fax: (1) 305-663-0964 BETA is accredited to ISO/IEC 17025:2005 International Standard on the General Requirements for the competence of testing and calibration laboratories. This is the highest level of recognized quality attainable by a testing or calibration laboratory (PJLA Testing Accreditation # 59423). |