NOTE:

DATE:	January 15, 2010

TO:		Docket EPA-HQ-OAR-2005-0161

FROM:	Jeff Herzog, Mechanical Engineer, U.S. EPA

SUBJECT:	Communications with Beta Analytic Inc. Regarding Test
Procedures to 

Determine the Biobased Content of Solid, Liquid, and Gaseous Samples 

Using Radiocarbon Analysis

On July 7, 2009 I spoke on the phone and exchanged emails with Thierry
Sam Tamers, Director of Beta Analytic Inc. regarding test procedure ASTM
D6866 “Standard Test Methods for Determining the Biobased Content of
Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis”.   In
response to my questions, Mr. Thierry related the following:

- Beta Analytic Inc. does testing per methods B and C in ASTM D6866.

- Test method B requires ~ 3 ml of sample

- Test method C requires ~40 ml of sample  

- Cost per test is $595 for both method B and C

- The cost per test may come down if the number of tests they do
increases.

- Beta Analytic commits to getting tests completed within 3 days.

- The test equipment used for method B costs ~ $1,400,000

- The cost of the Liquid Scintillation Counting (LSC) test equipment
used for methods A and C is ~ $15,000 to $20,000

- The estimates regarding the cost of testing equipment assume that
basic lab equipment is already in place (fume hood, etc..)

- Many labs have test equipment for methods A and C.   Fewer labs have
equipment for method B. 

