Beta Analytic Inc.

(Headquarters) Beta Analytic Limited

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

May 5, 2009

Reference: Docket ID No. EPA–HQ–OAR–2008–0508: Mandatory Reporting of

Greenhouse Gases; Proposed Rule – Comments on the use of ASTM D6866

Dear Ms. Cook:

In several sections of the proposed greenhouse gas reporting protocol, the EPA solicits
comments on how to better quantify the biomass fraction of fuels. There is a readily
available method called ASTM D6866 that can precisely and accurately quantify the
biomass fraction of any type of fuel or material (gas, liquids, or solids).

This 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 fuels and materials since municipal solid waste is in essence a
heterogeneous fuel / material.

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 (or in the case of a gas sample, biogenic CO2) can be
calculated easily from the overall carbon atoms (or CO2) 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 make the determination of 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 greenhouse gas reporting rule. The EPA should expand the use of ASTM
D6866 to include all heterogeneous and alternative fuels, including those referenced in
Table C-2 on page 16640 of the EPA protocol.

Current regional protocols in the US, such as California's AB 32 and the Western
Climate Initiative, allow the use of ASTM D6866 for heterogeneous fuels. Below are two
links where ASTM D6866 is cited for heterogeneous fuels in these two protocols:

California's AB32: (Operator advised to use ASTM D6866 to determine CO2 emissions
from the combustion of biomass, municipal solid waste, or waste-derived fuels with
biomass.)
Page 93, http://www.arb.ca.gov/regact/2007/ghg2007/frofinoal.pdf

Western Climate Initiative: (Operator that combusts fuels or fuel mixtures that contain
biomass shall determine the biomass-derived portion of CO2 emissions using ASTM
D6866.)
Page 79, http://www.westernclimateinitiative.org/ewebeditpro/items/O104F20744.pdf

The European Union also allows the use of carbon-14 for measuring heterogeneous
fuels, particularly for solid recovered fuels (SRF) and refuse-derived fuels (RDF). A
carbon-14 method called CEN/TS 15747:2008 was developed for these types of fuels. It
is almost identical to ASTM D6866. In fact, CEN/TS 15747:2008 cites ASTM D6866 as
the premise for the method.

In 2007, the European Union published a FAQ for the EU Emissions Trading Scheme.
On pages 16 and 17, carbon-14 is cited as an acceptable method for determining the
biogenic fraction of heterogeneous fuels. Both ASTM D6866 and CEN/TR 15991:2007
(precursor to CEN/TS 15747:2008) are cited as acceptable carbon-14 methods. The EU
ETS FAQ can be found at this link:
http://ec.europa.eu/environment/climat/emission/pdf/mrg2faq_sep_2007.pdf

Of course, it must be noted that Europe, California, and the Western Climate Initiative
are not the only entities advocating the use of carbon-14 for heterogeneous fuels.
Australia has also advocated its use, particularly for blended fuels. More information on
the Australian protocol can be found here (see pages 114 to 115):
http://www.climatechange.gov.au/reporting/publications/pubs/nger-technical-guidelines-
v1-1.pdf

Lastly, we would like to add that The Climate Registry's Greenhouse Gas Reporting
Protocol (please see page 65) also advocates the use of ASTM D6866 for biomass
derived fuels. More information can be found at this link:
http://www.theclimateregistry.org/downloads/GRP.pdf

In light of the acceptance of the ASTM D6866 method for all heterogeneous fuels, we
believe that the method should be allowed for all fuel types (i.e. gas, liquids or solids).
The method works equally well for any material. Under certain circumstances (e.g. plant
operators without CEMS), sampling the liquid or solid fuel itself might make more sense.

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Of course, it is better to sample the final CO2 emission to determine the biogenic fraction
from the combustion. Nonetheless, there are situations where analyzing the liquid or
solid fuel is more economical, particularly if a representative sample can be submitted to
the laboratory. This is often the case for the cement industry that is concurrently doing a
host of other tests on their solid fuels. In that regard, the CEN/TS 15747:2008 method
was created in Europe because the cement and paper/pulp industries are important
users of SRF/RDF. They perform a host of tests on the SRF/RDF itself, along with the
biogenic fraction determination.

On that note, the EU ETS FAQ cited before contains sampling recommendations on
page 17 for liquid and solid fuels.

We would like to mention that the ASTM D6866 method would address perfectly the
concerns cited in Section V, Subpart MM (pages 16569 to 16575). The method can
determine unambiguously the biomass fraction of any fuel mix. 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 biocarbon in the fuel mix. In a similar light, the ASTM D6866 can help
resolve biocarbon fraction ambiguities in complex fuel mixes such as Hydrogenation-
Derived Renewable Diesel (HDRD).

Lastly, we would like to suggest that the Tier 4 calculation allow the use of ASTM D6866
to calculate the biogenic CO2 fraction of any waste fuel or material, not just municipal
solid waste. Since the ASTM D6866 method works equally well for any waste materials
that contain a biomass fraction, the EPA protocol should include along with municipal
solid waste, the use of ASTM D6866 for any waste materials, waste fuels, tires and
alternative fuels in the Tier 4 biogenic calculation protocol.

In summary, we are advocating through this public comment that the EPA should allow
the use of ASTM D6866 for all heterogeneous/alternative fuels (i.e. those that contain a
biomass fraction) to determine the biogenic percentage. We are also advocating that
plant operators be allowed to use the ASTM D6866 method to determine the biogenic
fraction on the fuel itself when gas sampling is difficult. Contrary to emission factors or
other methods (e.g. manual sorting), the carbon-14 method can accurately determine
the biogenic fraction on any type of fuel (gas, liquid, or solid).

As can be seen with the national and international GHG protocols cited in this comment,
the ASTM D6866 method has been accepted widely throughout the world for the
measurement of the biogenic fraction of heterogeneous fuels. It is important that the
EPA GHG protocol adopt similar reporting methods to ensure that CO2 emissions
calculated in the United States are the same as the CO2 emissions calculated with these
other protocols.

Sincerely,

Thierry Sam Tamers

Director