Beta Analytic Inc.

(Headquarters) Beta Analytic Limited

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Miami, Florida 33155 2 Royal College Street
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Web site: www.betalabservices.com Email: info@betalabservices.com

U.S. Environmental Protection Agency

Air and Radiation Docket and Information Center -
Mailcode: 2822T
Attention: Docket ID EPA-HQ-OAR-2005-0161
1200 Pennsylvania Ave., NW
Washington DC 20460

May 28, 2009

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

Municipal Solid Waste

Dear Sir / Madam:

The EPA solicits comments whether the biomass fraction of municipal solid waste should be
allowed as a feedstock for biofuels. We believe that it should particularly since the ASTM D6866
test can accurately determine the biomass fraction of the resultant fuel. It must be noted that the
ASTM D6866 method is already adopted in the current EPA's greenhouse gas reporting rule
under the Tier 4 sampling protocol for municipal solid waste (pages 16636 to 16639), specifically
for 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 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 other 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 is 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).

The ASTM D6866 method 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).
 Beta Analytic

Although the ASTM D6866 method cannot determine the different renewable biomass feedstock
percentages, it can determine with excellent accuracy and precision the biomass carbon fraction
of fuels. Recent blending fuel incidents in Nebraska
(http://www.wowt.com/news/headlines/27142054.html) and the Reddy paper cited below
demonstrate the need for an analytical test such ASTM D6866 to verify the exact blend
percentages. 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 United
States.

To further add weight to our argument that ASTM D6866 method should be used to determine the
biomass fraction of biofuels and biomass/fossil fuel blends, 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), 2476-
2482.

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/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 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. This widely accepted method is also
being considered as a biomass carbon verification test for the Renewable Transportation Fuels
Obligation in the United Kingdom.

Sincerely,

Thierry Sam Tamers

Director