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Co-oping the NBB membership sounds like a great idea if it can be done legally. I'm in if you sort out the details. I assume co-op members would pay different amounts, with respect to their produced quantity? (perhaps sold quantity makes more sense)
I'm working on buying a GC, and should have acquisition in January; I've had the same thoughts about the lab. Do the labs need to be certified, and are you willing to go through that process? You're obviously a sharp guy as your idea is great[]. I noted that you recommended to a student to use a vacuum to remove methanol in another thread. I can think of a LOT of reason [making this recommendation on a forum] is a BAD idea. Mentioning this type of thing lightly on a forum where such a diverse group of people, many of whom are chemically illiterate (and innumerate), congregate is asking for trouble. Have you ever seen what happens when methanol doesn't []condense and makes it into a piston (or diaphragm) vacuum pump? (you're a teacher ... know and address your audience)
"'To be neutral and to be passive is to collaborate with whatever is going on.' Democracy is not just a counting-up of votes, but a counting-up of actions.'" ~Howard Zinn
ebztz: You're obviously a sharp guy as your idea is great, but are you really a chemical engineer? Certified? I ask, as you recommended to a student to use a vacuum to remove methanol. I can think of a LOT of reason this is a BAD idea. Mentioning this type of thing lightly on a forum where such a diverse group of people, many of whom are chemically illiterate (and innumerate), congregate is asking for trouble. Have you ever seen what happens when methanol doesn't recondense and makes it into a piston (or diaphragm) vacuum pump? (you're a teacher ... know and address your audience)
ebztz
Why would using a vacuum to remove Methanol be a BAD idea, I would take a guess that there is not one "large scale" commercial plant that does not use vacuum to strip the Methanol from the different streams. Yes if you get methanol into a piston vacuum pump then you are more than likely to have a problem, however that does not mean it is a BAD idea to use the vacuum pump, it means that the person who designed the system or who is operating it is BAD. A correctly designed condenser and vacuum setup will work just fine.
Vacuum stripping is used all over the world to remove lower boiling point products, it is learnt by all Chemical Engineers during their time at University. The removal of Methanol from Biodiesel, Glycerin and Fatty acid are just three examples where vacuum stripping is used in the Biodiesel industry alone.
With regard to people who are
chemically illiterate (and innumerate)
I suggest that this forum is not somewhere to question a guys proffessional ability based upon something you obviuosly do not know much about yourself
Hey Fuzz,
My quarrel with Ogre's advice was specific (note that I mentioned addressing the audience). I did make edits so my point is more transparent and less accosting. He's recommending something in very vague terms that can be very dangerous if taken the wrong way (literally) by someone without experience or proper knowledge. I've used the forums for long enough to know making this kind of recommendation could get someone hurt. That's my only point.
I fully realize that type of technique is employed at the on large scale level (I'd love to have my own flash evaporator, not to mention a continuous process). What I said is remains true. I can list a good number of reason that mentioning such a thing in passing, here, isn't a good idea. I know you can too. The fact that Ogre missed this is probably a lack of experience with forum users.
Thanks for the anger and insults. Yep, you're correct about my improper word usage. Guess I should sleep (note the post time).
fuzznag:I suggest that this forum is not somewhere to question a guys proffessional ability based upon something you obviuosly do not know much about yourself
Since you're questioning my word imperfections, I thought reciprocate in kind.
ebztz:I've used the forums for long enough to know making this kind of recommendation could get someone hurt. That's my only point.
I've used the forums for long enough to know making this kind of recommendation could get someone hurt. That's my only point.
For what it's worth, I think you're off base here.
I don't know either of you and have no vested interest, but I don't think a discussion should be limited to protect the clueless. (Future Darwin Award Winners?.)
Reducing pressure to strip off flammable materials has been done daily by thousands for years. This doesn't mean we shoud "dumb down" or "mommyize" our discussions here does it?
You could have pointed out the very real possibility of inadvertently replacing the lubricating oil with methanol in a vacuum pump without questioning fuzz's teaching abilities, right?
Just sayin'
You both made good points IMHO.
Bob in Berthoud
I've seen this exact topic covered by a chemical engineer (from the UK) on the Infopop boards. That individual did an excellent job of concisely detailing the pros and cons of vacuum distillation; this included some warning for beginners (and a few examples of the bad things that could happen). If you read the Infopop threads, you'll note that many of them start with WARNINGS or DISCLAIMERS; I'm sure their presence isn't an accident, as you can also read numerous examples of people poisoning themselves, damaging something, etc.
IMO, those with knowledge have the responsibility to distribute it with appropriate care and in appropriate context. I did my undergraduate work at a teachers' college, and learned this is one of the ethics of teaching. To not do so is putting others in harms way, and is negligent. Flat out, I do expect more from someone that is professional teacher, chemist, and ChemE. Admittedly, calling the individual out on this oversight was very wrong on my part, which is why I modified my original post.
Karl,
It would be great if you could come up with such a plan. $100 would be too cheap, I do not think you could swing it for that price. I am guessing that $500 per group or person would probably be more in line for the EPA stuff. We currently pay $600/ASTM test, and would love to pay less, but I am not sure that you could go much lower than $400/test, just a guess, I do not have any facts to support my guess. The guys who do our testing, I can not believe they are making more than $200/test, maybe but I doubt it.
Would be happy to get on your band wagon once you had it going. Good Luck.
ps - what is up with the vacuum stuff, and how is that anywhere near related to this topic. To make matters worse, a lot people do use vacuums, and never have issues or problems, just because in some theoretical world bad thing can potentially happen does not mean that will.
The only real key element is you can't sell b100. the epa does not consider biodiesel a fuel, they do consider it a fuel aditive. the minium mixture for biodiesel is 1 gallon petrodiesel mixed with 999 gallons of oleodiesel. oleodiesel is biodiesel. that means that you register form 637 with the irs for being a fuel maker, and a fuel mixer. i think that's ab, and k. now you got o the epa and say it's a fuel aditive. that becomes baseline. and if you sell less then 50 million gallons a year you don't ahve to meet tire 1 or 2 testing. they could request tier 3, but i have never heard of it happoning with biodiesel. Now that you're registeded with the epa and irs you can claim a tax credit of 1 dollar per a gallon agribiodiesel, or .50 per a gallon from non agribiodiesel. and you can collect road tax so it is legal for road use.
If you search the epa cfr for biodiesel you will find info at about 40 cfr 79.56(e)(4)(ii)(B)(2)(A).
if you read all of CFR part 40 you will realize a lot below is several key points in the CFR. if you call the one guy in all the U.S. that you have to talk to about registration he will tell you it's atypical. If you know what you're talking about and point him towards the exception(40 cfr 79.56(e)(4)(ii)(B)(2)(A)) then he can't sidestep you, but then he wants your testing for tier 2. Then explain that your company produces less then 50 million a year and there is almost nothing he can do to stop from giving you the registration. After that if you are still fighting get a lawyer to read it over and write a letter. For a few hundred dollars you will probably get your answer.
Logan Vilas
(vii) In regard to nonbaseline diesel products formulated with mixed alkyl esters of plant and/or animal origin (i.e., “biodiesel” fuels, pursuant to §79.56(e)(4)(ii)(B)(2)):
(i) A separate non-baseline diesel group shall be defined by each individual alcohol or ether listed as a component in the registration application or basic registration data of any such fuel or additive.
(ii) For each such group, the representative to be used in testing shall be a formulation consisting of the diesel base fuel blended with the relevant alcohol or ether in an amount equivalent to the highest actual or recommended concentration-in-use of the alcohol or ether recorded in the basic registration data of any member fuel or additive product.
(2) A separate non-baseline diesel group is also defined for each of the following classes of oxygenating compounds: mixed nitroso-compounds; mixed nitro-compounds; mixed alkyl nitrates; mixed alkyl nitrites; peroxides; furans; mixed alkyl esters of plant and/or animal origin (biodiesel). For each such group, the representative to be used in testing shall be formulated as follows:
(A) For biodiesel groups, the representative shall be 100 percent biodiesel fuel.
(2) Provisions Applicable to Baseline and Non-baseline Products. A manufacturer with total annual sales less than $50 million is not required to meet the requirements of Tier 1 and Tier 2 (specified in §§79.52 and 79.53) with regard to such manufacturer's fuel and/or additive products which meet the criteria for inclusion in a Baseline or Non-baseline group pursuant to §79.56. Upon such manufacturer's satisfactory completion and submittal to EPA of basic registration data specified in §79.59(b), the manufacturer may request and EPA shall issue a registration for such product, subject to §79.51(c) and paragraphs (d)(4) and (d)(5) of this section.
Thankyou for compacting many of the legal "hurdles" that few seem to have a handle on!! A few questions if you please:
"The only real key element is you can't sell b100. the epa does not consider biodiesel a fuel, they do consider it a fuel aditive." Does this mean we as small producers need to come up with a new name for B100? Or just call it an additive vs. advertising B100 as a fuel?
"that means that you register form 637 with the irs for being a fuel maker, and a fuel mixer." Will this require that irs form 720? Sounds like it if we would be collecting road tax? BTW, what would the road tax for B100 be? How much per gallon? Also, would a BD producer be considered an "Alternative Fueler/Maker"? In Oklahoma, where I live, B100 is considered an alternative fuel, and as such has a $0.20/gal tax credit if certain hoops are jumped through. But if the EPA doesn't view this as fuel, then how does that impact registration?
Another thought is the bond needed for registration--how much and to whom is it rendered to/agency?
THanks! I'm sure I'll have more questions when these are answered. Feel free to email me directly if you would rather, although I'm sure others have similar concerns and would profit from this discussion.
Blessings,
Alan
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