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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.comBeta 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 6207–JWashington, DC, 20460May 12, 2009Reference: Docket ID No. EPA–HQ–OAR–2008–0508: Section V, Subpart MM (Suppliers ofPetroleum Products) of the Mandatory Reporting of Greenhouse Gases; Proposed Rule - – Comments on the use of ASTM D6866Dear 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 4sampling 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).
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