Beta Analytic Public Comment On Us Epa Proposed Mandatory Reporting Rule

Beta Analytic Inc. (Headquarters) 4985 SW 74 Court Miami, Florida 33155 USA Tel: (1) 305-662-7760 Fax: (1) 305-663-0964 Email: [email protected] Web site: www.betalabservices.com

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 Email: [email protected]

U.S. EPA Attention: Ms. Carole Cook Office of Atmospheric Programs Climate Change Division, Mail Code 6207–J Washington, DC, 20460 May 12, 2009

Reference: Docket ID No. EPA–HQ–OAR–2008–0508: Section V, Subpart MM (Suppliers of Petroleum 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 the proposed greenhouse gas reporting protocol, the EPA solicits comments on how to better quantify the biogenic fraction of fuels derived from biomass. There is a readily available method called ASTM D6866 that can precisely and accurately quantify the biogenic fraction of any type of fuel 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 broaden the use of this method for all biomass-derived fuels and blended fossil and biomass fuel mixtures since municipal solid waste is in essence a heterogeneous fuel with biomass and fossil components. The ASTM D6866 method is a standardized version for industrial use of radiocarbon dating, an analytical technique that was developed in the 1950s. Radiocarbon dating has 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 fuels and materials. Biomass contains a well-characterized amount of carbon-14 that is easily distinguished from other materials such as fossil fuels that do not contain any carbon-14. Since the amount of carbon-14 in biomass is well known, a percentage of biogenic carbon can be calculated easily from the overall carbon atoms in the sample. Although ASTM D6866 is now used throughout the world to measure biomass carbon / CO2, the origins of the method are American. It was written at the request of the USDA to satisfy legislation requiring federal agencies to prefer procurement from manufacturers using the greatest amount of biomass in their products (per the Farm Security and Rural Investment act of 2002). It was quickly established that radiocarbon dating was the only viable and accurate technique to determine the biomass percentage. A working standard of radiocarbon dating for industrial use was completed in 2004 and is now cited in US Federal Law (7 CFR part 2902).

Beta Analytic

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 EPA reporting rule. The ASTM D6866 method would be ideal for determining precisely and accurately the biomass carbon fraction of fuels under the requirements of Section V, Subpart MM of the proposed greenhouse gas reporting rule. We would also like to mention that the ASTM D6866 is the only analytical method that can determine the biomass carbon fraction of fuels that are chemically identical. For example, synthetic ethanol made from fossil fuels is chemically indistinguishable from bioethanol made from a biomass feedstock. ASTM D6866 is the only method that can determine precisely the percentage of biogenic carbon in ethanol samples. The same holds true for methanol from biomass and fossil fuel sources. In a similar light, the ASTM D6866 method can help resolve biomass fraction ambiguities in complex fuel mixes such as Hydrogenation-Derived Renewable Diesel (HDRD). To further add weight to our argument that ASTM D6866 should be allowed in the greenhouse gas reporting rule to determine the biogenic carbon fraction of biomass-derived fuels, we are including three links of recently published research notes on the carbon-14 technique for these types 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. QUANTITATIVE DETERMINATION 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/V olume48/Number3/315-323.pdf Reddy, C.M., J.A. DeMello, C.A. Carmichael, E.E. Peacock, L. Xu, and J.S. Arey, Determination of Biodiesel Blending Percentages Using Natural Abundance Radiocarbon Analysis: Testing the Accuracy of Retail Biodiesel Blends, Environmental Science & Technology 2008 42 (7), 24762482. http://pubs.acs.org/doi/abs/10.1021/es071814j Rodger Sparks Nancy Beavan-Athfield, Methodology for testing the percentage of modern biological component in biofuel blends with radiocarbon dating, GNS Science Consultancy Report 2007/343 November 2007. http://74.125.47.132/search?q=cache:grfBeV7S5HkJ:www.eeca.govt.nz/eeca-library/renewableenergy/biofuels/report/biofuels-testing-report08.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 biomass fraction 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

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