8/14/2019 Beta Analytic Public Comment on EPA Renewable Fuel Standard Program

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Beta Analytic LimitedLondon Bioscience Innovation Centre2 Royal College StreetLondon NW10NHUnited KingdomTel: (44) 207 617 7490Fax: (44) 207 160 5350Email: info@betalabservices.com

Beta 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 20460

May 28, 2009

Reference: Docket ID EPA-HQ-OAR-2005-0161: Comments on the use of ASTM D6866 andMunicipal Solid Waste

Dear 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 of

radiocarbon 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 determine

the 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).

8/14/2019 Beta Analytic Public Comment on EPA Renewable Fuel Standard Program

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Beta Analytic

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Although the ASTM D6866 method cannot determine the different renewable biomass feedstockpercentages, it can determine with excellent accuracy and precision the biomass carbon fractionof fuels. Recent blending fuel incidents in Nebraska(http://www.wowt.com/news/headlines/27142054.html) and the Reddy paper cited belowdemonstrate the need for an analytical test such ASTM D6866 to verify the exact blendpercentages. As such, the ASTM D6866 test can be used to verify overall blending percentages,particularly imported biofuels where regulatory oversight might not be a rigorous as in the UnitedStates.

To further add weight to our argument that ASTM D6866 method should be used to determine thebiomass fraction of biofuels and biomass/fossil fuel blends, we are including three links ofrecently published research notes on the carbon-14 technique for these types of fuels. As can beseen from these research notes, the carbon-14 method works very well in determining thebiomass fraction of fuels.

Dijs, Ivo J; van der Windt, Eric; Kaihola, Lauri; van der Borg, Klaas. QUANTITATIVEDETERMINATION BY 14C ANALYSIS OF THE BIOLOGICAL COMPONENT IN FUELS.RADIOCARBON, Vol 48, Nr 3, 2006, p 315-323.

http://digitalcommons.library.arizona.edu/objectviewer?o=http://radiocarbon.library.arizona.edu/Volume48/Number3/315-323.pdf

Reddy, C.M., J.A. DeMello, C.A. Carmichael, E.E. Peacock, L. Xu, and J.S. Arey, Determinationof Biodiesel Blending Percentages Using Natural Abundance Radiocarbon Analysis: Testing theAccuracy of Retail Biodiesel Blends, Environmental Science & Technology 2008 42 (7), 2476-2482.

http://pubs.acs.org/doi/abs/10.1021/es071814j

Rodger Sparks Nancy Beavan-Athfield, Methodology for testing the percentage of modernbiological component in biofuel blends with radiocarbon dating, GNS Science Consultancy Report2007/343 November 2007.

http://74.125.47.132/search?q=cache:grfBeV7S5HkJ:www.eeca.govt.nz/eeca-library/renewable-energy/biofuels/report/biofuels-testing-report-08.pdf+"Methodology+for+testing+the+percentage+of+modern+biological+component+in+biofue

Lastly, it must be mentioned that ASTM D6866 is an accepted method for measuring the biomassfraction of fuels in the Australian, European Union, and other regional greenhouse gas protocols,such California's AB 32 and the Western Climate Initiative. This widely accepted method is alsobeing considered as a biomass carbon verification test for the Renewable Transportation FuelsObligation in the United Kingdom.

Sincerely,

Thierry Sam TamersDirector