8/14/2019 Beta Analytic Public Comment on US EPA Proposed Mandatory Reporting Rule

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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. EPAAttention: Ms. Carole CookOffice of Atmospheric ProgramsClimate Change Division, Mail Code 6207JWashington, DC, 20460

May 12, 2009

Reference: Docket ID No. EPAHQOAR20080508: Section V, Subpart MM (Suppliers ofPetroleum Products) of the Mandatory Reporting of Greenhouse Gases; Proposed Rule - Comments on the use of ASTM D6866

Dear Ms. Cook:

In Section V, Subpart MM (Suppliers of Petroleum Products pages 16569 to 16575) of theproposed greenhouse gas reporting protocol, the EPA solicits comments on how to betterquantify the biogenic fraction of fuels derived from biomass. There is a readily available methodcalled ASTM D6866 that can precisely and accurately quantify the biogenic fraction of any type offuel derived from biomass and blended fuel mixtures that contain both fossil and biomass fuels.

The ASTM D6866 method is already adopted in the current reporting rule under the Tier 4

sampling protocol for municipal solid waste (pages 16636 to 16639). The EPA should broadenthe use of this method for all biomass-derived fuels and blended fossil and biomass fuel mixturessince municipal solid waste is in essence a heterogeneous fuel with biomass and fossilcomponents.

The ASTM D6866 method is a standardized version for industrial use of radiocarbon dating, ananalytical technique that was developed in the 1950s. Radiocarbon dating has been used fordecades for dating archaeological artifacts. The same principles of dating (i.e. analysis of thecarbon-14 atom) can also be used to measure the biomass component of fuels and materials.Biomass contains a well-characterized amount of carbon-14 that is easily distinguished fromother materials such as fossil fuels that do not contain any carbon-14. Since the amount ofcarbon-14 in biomass is well known, a percentage of biogenic carbon can be calculated easilyfrom 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 was the only viable and accurate technique todetermine the biomass percentage. A working standard of radiocarbon dating for industrial usewas completed in 2004 and is now cited in US Federal Law (7 CFR part 2902).

8/14/2019 Beta Analytic Public Comment on US EPA Proposed Mandatory Reporting Rule

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Beta Analytic

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We believe that the ASTM D6866 method should be allowed for all heterogeneous fuels (i.e.those that contain a biomass fraction), not just municipal solid waste as cited in the current EPAreporting rule. The ASTM D6866 method would be ideal for determining precisely and accuratelythe biomass carbon fraction of fuels under the requirements of Section V, Subpart MM of theproposed greenhouse gas reporting rule.

We would also like to mention that the ASTM D6866 is the only analytical method that candetermine the biomass carbon fraction of fuels that are chemically identical. For example,synthetic ethanol made from fossil fuels is chemically indistinguishable from bioethanol madefrom a biomass feedstock. ASTM D6866 is the only method that can determine precisely thepercentage of biogenic carbon in ethanol samples. The same holds true for methanol frombiomass and fossil fuel sources. In a similar light, the ASTM D6866 method can help resolvebiomass fraction ambiguities in complex fuel mixes such as Hydrogenation-Derived RenewableDiesel (HDRD).

To further add weight to our argument that ASTM D6866 should be allowed in the greenhousegas reporting rule to determine the biogenic carbon fraction of biomass-derived fuels, we areincluding three links of recently published research notes on the carbon-14 technique for thesetypes of fuels. As can be seen from these research notes, the carbon-14 method works very well

in determining the biomass 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.

Sincerely,

Mauricio Larenas