Folks, I ask for personal reasons (paranoia about word back to our local authorities, possibly getting the inspector mentioned into trouble with his superiors!) that you don't crosspost this beyond this particular list.
Our coop, a which is a medium-scale homebrew operation involving equipment built out of several 55 gallon drums, had an unofficial visit (or more like a conversation ) with a toxics inspector from the health department. he was at our site (pre-arranged visit) to look at something unrelated to the co-op. (no one from the coop was present for the conversation unfortunately). The facilities manager of our site (not a coop member, more like a landlord) made us remove all of our equipment before the inspector's visit, then had a verbal conversation with the toxics guy about what we were doing. the conversation was informal. The outcome of it is that the inspector thought that there were a few homebrewers operating in town, and he was worried about them- but it was interpreted by our facility manager as not being a very serious worry. At our site the inspector was concerned about the following: 1. containment (110%. I am unclear if this means that a site has to have 110% containment for all of it's potential fluid contents or only for 110% of the maximum amount expected to escape from one tank- for instance we store things in 6 drums- do we need 6 times 55 gallons times 110% containment, or only 110 percent of 55 gallons?) Typical containment pallets (we have several already, at $300 a piece) that are designed for holding 4 drums, have 66 gallons capacity- ie 110% of one drum's spills. A cofferdam across the entrance to our liquid-impervious 'building' was one solution discussed as suitable containment. Our 'building' was already liquidproofed as part of it's other non-coop use- they store liquids in a tank there- so it already has this cofferdam/fiberglass or epoxy 'liquidproof' liner (ie they painted lots of fiberglass resin all over the floor and walls and checked it for liquidtightness) arrangement, and this is OK by the inspector. 2. closed systems with no vapor escape (we were already going there anyway for obvious health reasons. It is easy to do with processors. It is much harder to do (for homebrewers, not producers with custombuilt equipment) once you start talking about bubblewash tanks. I am of course aware that this is very different in industry- but for a large homebrew operation it is helpful to wash in a cylindrical tank and to be able to see into it. In the case of tanks built from 55 gallon drums, one could presumably silicone a sheet of glass over a de-greased open head of a drum, but condensation onto the glass would keep you from seeing much, I imagine. Haven't tested this glass-top wash tank theory yet. In industry this is less of an issue because 1. you work with something better than a 55gallon drum 2. you presumably have better quality control than beginning homebrewers do and you don't deal with wash problems as much. Or you do acid esterification as part of your process and don't deal with washing problems. And your washing process is presumably not bubblewash. we already do not store any methanol- we let our methanol supplier store it and we go and buy it as we need it, and use it all at once. anyway- those are two issues from a very informal conversation- the guy wasn't inspecting us. I heard about a year ago that the DOE was considering a 'certification' program for homebrewers. Though I think this program is a terrible idea and will result in controls that we don't want (rumor department says that the DOE's biodiesel people doesn't think much of us, and consider us a timebomb waiting to explode, I've heard from a couple of sources)- it might be a good idea to contact them and find out what they think one should do (hopefully without the process of 'asking them' leading to their ideas somehow becoming local law anywhere!). This will be different than what local officials will think- we argued with our household toxics waste management/coop member guy that biodiesel is not classified as hazardous- and had to pull out the MSDS to prove it, for instance- there will no doubt be differing interpretations of safe handling for some of the processes- I can't imagine that amateur methanol recovery won't give some officials the 'heebie jeebies', for instance. yet homebrewers (and distillers) do it safely all the time and it is an important part of the process. anyway I agree that amongst ourselves we should develop some kind of checklist of safety and facilities safety practices. Most of this is just a matter of research on existing regulations and common sense. As I have posted in the past, however, I do not think that the regulatory officials are the ones to do it- and that homebrewers and small producers should somehow be in control of that process... and more importantly that we should be VERY wary of any of this translating into regulation against homebrewers in particular. As I have often noted also, there are differences between homebrewers and small producers as well. Both manage to operate safely but the idea of homebrewers scares people not used to the idea... The regulations that are in place now that affect homebrewers handling small amounts of chemicals are not unreasonable (though they can be expensive to comply with for a small business handling larger amounts of chemicals). It is important to note the difference- if you start a business or a legal coop it's a different picture than if you're making fuel in a 30 gallon former water heater in your back yard. The story about the other coop's issues with their bulk fuel tank referred to a tank of a few hundred gallons capacity- something that differs from one kind of zoning to another. As often is the case there are less regulations in areas with agricultural zoning than in cities (where so many of us are trying to start coops) It would be easy for a process like this (gathering info and coming up with voluntary safety suggestions) to be hijacked by the paranoid or misinformed, especially those in a local government capacity. Mark At 11:53 PM 2/9/2003 -0500, you wrote: >Well? > >Sure, economies of scale can make a dif on afforability. > >But I haven't yet seen much in the way of any comprised list of >regs that have to be met, or at least not in a public forum such >as this. Now would be as good a time as any to make a short and >long list and do a run down of how shadetree producers can >achieve the exact same end result as commercial manufacturers. > >As this is an international forum there will be some differences >from state to state. But the commercial principals and the >environmental principles remain relatively static throughout. > >So for starters? What about lined pipe in earthquake prone areas? >What about annual tank inspections and fees, whether under >pressure or not? What about the 110% impervious containment for >fluids by US EPA standard? Double walled tanks vs. dikes? >Methanol storage in bulk vs. 55 gallon drums? Closed loop vapor >containment? Alcohol, caustic and FFA recovery? Wastewater >treatment? > >Time to make a top 40 list for homebrewers. There's no reason to >not. > >Todd Swearingen > >----- Original Message ----- >From: girl mark <[EMAIL PROTECTED]> >To: <biofuels-biz@yahoogroups.com> >Sent: Sunday, February 09, 2003 12:55 PM >Subject: Re: [biofuels-biz] northern california biodiesel, and >blue sun biodiesel > > > > Mark, > > large-scale biodiesel manufacturers have an easier time dealing >with > > regulations than the little guys do. The hurdles I was pointing >out are the > > ones that slow down development of small producer business and >of coops- > > the big plants don't have these issues as much partly because >they're being > > built by larger corporations with more money. It's not that >there is > > regulation that keeps commercial biodiesel plants from going up >here, it's > > more that biodiesel has great potential as a small business, >and for the > > small producers to fill a unique role as small-scale >decentralized energy > > supply, and yet since energy isn't a sphere of small business >usually, > > there are many expensive hurdles to overcome before this is a >reality in > > city areas for instance. > > I think Blue Sun falls into the big guys category- BUT I don't >really know > > the business well and I don'tknow enough about them. and I;m >not sure of > > statistics on what constitutes a small producer versus a big >one- gallons > > output for instance. ANyway they have some serious investment >going into > > this, and are importing chemists from gerrmany who've worked on >similar > > projects I believe. > > Pacific is I believe also building a plant i n San Jose- >WVO-sourced. They > > are, you'll be interested to know, supposedly staying away from >doing any > > oil collections in santa cruz so as to leave it for all the >homebrewers. So > > I've been told by an employee whose working on the collections >end of it- > > hope it comes true. > > as far as santa rosa- I think you're thinking not of that place >but of > > Ukiah, where Yokayo Biofuels operates. They are a biodiesel >broker (they > > buy WVO derived biodiesel) who delivers to retail customers (ie >sells them > > a drum of fuel and a FillRite pump) all over northern >california. They also > > are trying to set up a gas station-style business in Ukiah >selling > > biodiesel, and got a lot of favorable press last month. They >are a great > > example of a small business doing a lot to bring biodiesel to >their region- > > its made it available to thousands of people without having to >convince a > > gas station owner to dedicate a tank (which is very hard to >convince one to > > do due to the economics). > > I don't have other classes scheduled yet. Join Burnveggies list >and you'll > > hear about any others coming up in this area.. > > mark > > > > > > At 08:06 AM 2/9/2003 -0800, you wrote: > > >Thanks for the information. Seems like Blue Sun has >considered and > > >dealt with many of the regulatory hurdles if they indeed have >real plans > > >for these large capacity processing plants. Perhaps they >could provide > > >the model for others. Then again, if they are a for profit > > >organization, they may not want to share the information for >fear of > > >competition. > > > > > >What of Pacific Biodiesel. They apparently are building >plants, and > > >have installed at least two, one in Hawaii, and one in Japan. >They must > > >have solved some of the regulatory problems as well, to put up >a plant > > >in the U.S. > > > > > >Are you a part of the group in Santa Rosa who plan to open a >fueling > > >station. This group got some good press in the Santa Cruz >Sentinel > > >about three weeks ago. Can't remember the name though. > > > > > >Is the class you teach available at other times than the one >you wrote > > >about? > > > > > >Mark F. > > > > > > > > > > > >Biofuels at Journey to Forever > > >http://journeytoforever.org/biofuel.html > > >Biofuel at WebConX > > >http://webconx.green-trust.org/2000/biofuel/biofuel.htm > > >List messages are archived at the Info-Archive at NNYTech: > > >http://archive.nnytech.net/ > > >To unsubscribe from this group, send an email to: > > >[EMAIL PROTECTED] > > > > > > > > > > > >Your use of Yahoo! Groups is subject to >http://docs.yahoo.com/info/terms/ > > > > > > Biofuels at Journey to Forever > > http://journeytoforever.org/biofuel.html > > Biofuel at WebConX > > http://webconx.green-trust.org/2000/biofuel/biofuel.htm > > List messages are archived at the Info-Archive at NNYTech: > > http://archive.nnytech.net/ > > To unsubscribe from this group, send an email to: > > [EMAIL PROTECTED] > > > > > > > > Your use of Yahoo! Groups is subject to >http://docs.yahoo.com/info/terms/ > > > > > > > > >Biofuels at Journey to Forever >http://journeytoforever.org/biofuel.html >Biofuel at WebConX >http://webconx.green-trust.org/2000/biofuel/biofuel.htm >List messages are archived at the Info-Archive at NNYTech: >http://archive.nnytech.net/ >To unsubscribe from this group, send an email to: >[EMAIL PROTECTED] > > > >Your use of Yahoo! Groups is subject to http://docs.yahoo.com/info/terms/ Biofuels at Journey to Forever http://journeytoforever.org/biofuel.html Biofuel at WebConX http://webconx.green-trust.org/2000/biofuel/biofuel.htm List messages are archived at the Info-Archive at NNYTech: http://archive.nnytech.net/ To unsubscribe from this group, send an email to: [EMAIL PROTECTED] Your use of Yahoo! Groups is subject to http://docs.yahoo.com/info/terms/
