SUMMARY STATEMENT: In support of the DOE\'s Voluntary Reporting of
Greenhouse Gases (1605(b)) Program, the American Society for Testing
Materials recommends incorporation of ASTM-D6866 into the procedures of
the DOE\'s 1605b program.   ASTM-D6866 is directly applicable to the
monitoring of emission inventories and calculation of emissions
reductions.  In practice, both greenhouse (GHG) and climate neutral
(biogenic) CO2 or methane emissions within bulk air samples are
quantified in a single measurement.  Direct measurements can be made on
emissions in each category listed under chapter 1 of the Guidelines:
stationary source combustions, mobile sources, industrial sources,
indirect sources, geologic sequestration, agricultural emissions and
sequestration and forestry emissions.   A compelling argument exists for
insertion of ASTM-D6866 methodology into Chapter 2 (Emission
Reductions).  It provides a single value, standardized, and easily
understandable reference for both intra-industry and inter-industry
reduction evaluation.  It satisfies the requirements of objectivity,
consistency, completeness, and verifiability.  It represents an accurate
and economical tool for Small Emitters to report carbon dioxide and
methane inventories and reductions. Estimation of fossil fuel usage
based on accounting records is minimized and largely replaced with a
direct measurement on the\
emissions themselves.  In summary, ASTM D6866 measurements are directly
applicable to the entirety of the Guidelines with regards to GHG and
carbon-neutral CO2 and methane emissions.

Applications of ASTM D6866 for 1605b Categories

Applicability of ASTM-D6866 for Stationary Source Combustion : CO2

ASTM-D6866 makes a direct measurement of the percentage carbon-neutral
CO2 within combustion emissions. A single result is provided (e.g. 63%
Biomass CO2). A facility knowing its total tonnage CO2 output and D6866
result can directly calculate the tonnage of both carbon-neutral CO2 and
fossil CO2 expelled, regardless of feedstock variability.  A
verification and monitoring tool is provided for (1) separating and
subtracting the carbon-neutral CO2 component from the emission
inventory, (2) increasing the accuracy of the greenhouse gas inventory
and (3) calculating GHG reductions. ASTM D6866 measurements can also be
made on solid and liquid fuels.

The following stationary source combustions can be monitored using ASTM
D6866:

Municipal Solid Waste\
Landfill Gas\
Biogenic Fuels (Bagasse, Wood, Wood Waste, Ethanol and Bio-diesel)\
Petroleum-Based Waste and Byproduct Fuels (including tires and
lubricants)\
Special Situations: Nonfuel Use of Fossil Fuels

Applicability of ASTM-D6866 for Mobile Sources : Renewable Fuels

ASTM-D6866 is presently under review for inclusion in EPA 40 CFR Part
80: Renewable Fuels Standard Requirements for 2006.

ASTM-D6866 makes a direct measurement on the % renewable content vs.
fossil content of gasoline blends regardless of chemical composition. In
doing so, it identifies fuel blends containing renewable ethanol vs.
synthetic ethanol derived from coal or natural gas.

Since renewable ethanol is synthesized from modern day plants and the
gasoline itself is synthesized from fossil petroleum, a measure on the
blend will directly quantify the amount of renewable ethanol in that
blend. A blend containing 10% renewable ethanol will give a result of\
10% renewable content, whereas a blend containing 10% synthetic ethanol
will give a result of 0% renewable content, even though in both cases
10% ethanol is present in the gasoline blend. This characterization
supports the underlying intent behind bio-ethanol use. It also adds
protection to domestic stakeholders in the absence of truly verifiable
origin of imported ethanol.

ASTM D6866 can also be used for verification of bio-diesel and
bio-diesel derived products such as lubricants. The same principles of
ASTM D6866 for ethanol measurements apply to bio-diesel.

Applicability of ASTM-D6866 for Industrial Processes

As with stationary source combustion, any industrial process that
generates CO2 during a combustion process can use ASTM D6866 to estimate
the carbon-neutral fraction of the total CO2 emitted. Some industrial
processes that liberate CO2 include, but not limited to:

Aluminum Production\
Ammonia Production\
Cement Production\
Clinker Production (including CO2 emitted from the production of lime)\
Metal Production\
Hydrogen Production\
Methanol Production\
Iron and Steel Production\
Soda Ash Production

Other industrial processes combust waste to generate electricity,
liberating CO2 as a resultant byproduct. ASTM D6866 quantifies the
carbon-neutral CO2 within the facility emissions. Combustion of waste
material and wastewater sludge are examples of combusted waste.\
Examples of Industries that combust waste to produce electricity are the
paper / pulp and medical waste disposal sectors.

Bio-Methane from waste material can also be captured and converted into
electricity. This methane can be monitored with ASTM D6866.

Applicability of ASTM-D6866 for Agricultural Applications

Livestock waste is an important producer of bio-methane. This
bio-methane can be combined with petroleum-based gases. These mixed
gases can be monitored with ASTM D6866.

Crop residue burning is another agricultural application that can use
ASTM D6866 for monitoring purposes. For example, burning of crop
residues in the production of ethanol can monitored with ASTM D6866. As
with stationary source combustion, the carbon-neutral CO2 liberated in
the combustion process can be determined.

Origin/History of ASTM-D6866

ASTM-D6866 is a standardized method of radiocarbon dating techniques. A
working standard was completed in 2004 and is now cited in Federal Law
(7 CFR part 2902). It was written at the request of the USDA to satisfy
legislation requiring Federal agencies to give preferred\
procurement to manufacturers using the greatest amount of renewable
biomass (vs. plastic or other fossil components) in their products (per
the Farm Security and Rural Investment act of 2002). A standardized
method was needed to verify manufacturers\' claims of renewable content.
Radiocarbon dating was directly applicable, but was an unregulated
industry. The USDA needed standardization of the techniques and
reporting for the purposes of inclusion in regulatory policy.  The
standardized method is equally applicable to gases, solids, and liquids.

In October 2006, testimony was made before the EPA for inclusion of
ASTM-D6866 into EPA 40 CFR Part 80: Renewable Fuels Standard
Requirements for 2006. The method had direct applicability towards
providing a standardized and verifiable means to validate the origin of
ethanol within fuel blends as being from either renewable or fossil
(synthetic) sources. With worldwide growth in synthetic ethanol
production, inclusion of ASTM-D6866 into the standard was warranted for
the purposes of protecting the intent and integrity of the RFS, tracing
origin, protecting domestic stakeholders from poorly traceable ethanol
imports (with regard to renewable vs. synthetic origin), and protecting
the integrity and validity of awarded tax credits. That testimony is
presently under review.

Understanding ASTM-D6866 results: Greenhouse Gas Emissions

The application of ASTM-D6866 to derive a \"Biomass CO2 content\" for
carbon dioxide effluents is built upon the same concepts as those used
by the US Department of Agriculture to derive the biobased content of
manufactured products containing biomass carbon. It is done by comparing
a relative amount of radiocarbon (C14) in an unknown sample to that of a
modern reference standard. The ratio in contemporary biomass will be
100% and the ratio in fossil materials will be zero. Carbon dioxide
derived from combustion of a mixture of present day biomass and fossil
carbon will yield an ASTM-D6866 result that directly correlates to the
amount of biomass carbon combusted and carbon-neutral CO2 generated.

The modern reference standard is a National Institute of Standards and
Technology (NIST) standard with a defined radiocarbon content of 100%
contemporary carbon for the year AD 1950. AD 1950 was chosen since it
represented a time prior to thermo-nuclear weapons testing which
introduced large amounts of excess radiocarbon into the atmosphere with
each explosion (termed \"bomb carbon\"). This was a logical point in
time to use as a reference since this excess bomb carbon would change
with increased or decreased weapons testing. A fixed correction for this
effect is applied per the ASTM-D6866 requirements, applying specifically
to carbon removed from the atmospheric CO2 reservoir since about 1996.
Carbon removed prior to about 1996 will contain elevated radiocarbon
signatures, not directly applicable to the\
ASTM-D6866 correction. Typical areas to which the correction may not
apply are landfills more than 5-10 years old and to trees which began to
grow more than 20 years ago.

Carbon dioxide effluent derived from combustion of 100% present day
biomass will yield results of 100% renewable content. Carbon dioxide
effluent derived from the combustion of 100% fossil fuel will yield
results of 0% renewable content. Carbon dioxide produced from mixed
fuels (biomass plus fossil fuel) will yield a percentage result in
direct proportion to the biomass carbon consumed vs. fossil carbon
consumed in the combustion. The final result is referred to as the\
MEAN BIOMASS CO2 CONTENT and assumes all the carbon in the carbon
dioxide was derived from either present day living or fossil sources.

The results provided in this report involved materials provided without
any source information. This situation is highly probable in a real life
situation. The MEAN VALUE quoted in this report encompasses an absolute
range of 6% (plus and minus 3% on either side of the MEANBIOMASS CO2
CONTENT to account for variations in end component radiocarbon
signatures (a conservative approximation). It is presumed that all
materials are present day or fossil in origin and that the desired
result is the amount of biomass component \"present\" in the\
material, not the amount of biomass material \"used\" in the
manufacturing process. The most conservative interpretation of the
reported percentages is as maximum values.

ASTM-D6866 results relate directly to the percentage carbon-neutral CO2
in an incineration effluent. A value of 71% renewable content measured
on CO2 effluent would indicate that 71% of the exhausted CO2 was from
biomass (29% from fossil fuel). It does not represent the weight of
biomass combusted or the weight of fossil fuel combusted. This is
advantageous since the weight of the fuels only indirectly relate to the
up-take of carbon dioxide from the atmosphere. The respiration uptake
compound was carbon dioxide and the combustion effluent was carbon
dioxide. The ASTM-D6866 result directly and\
specifically relates to the amount of biogenic / carbon-neutral CO2\
consumed and expelled.

\--\
Darden Hood\
President

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