Help with FITS please

[bottleveg]

I wonder if someone could help me with this? I believe the answer will also be helpful to others in a similar situation.
I have applied for ROC/FITS CHP (before the deadline), basically a Lister SOM running on used vegetable oil.
I have received a Q from OFGEM, re my application, thus: -

1.   “Please provide a fuel specification for the fuels that you intend to use. Please refer to sections 3.11-3.15 of the Fuel measurement and sampling guidance and to the sample fuel specification in Appendix 6 for more details;
2.          Please note that once a sufficiently robust fuel specification has been agreed, the biomass GCV sampling referred to in paragraphs 2.7-2.13 of the questionnaire will not be required for our purposes. This is providing that no fossil fuels are utilised.”

Unfortunately, or maybe fortunately, my mind is constructed to fix and build things so ‘official’ paperwork often makes little sense to me.
Any advice would be greatly appreciated.
                                            Mark.

[GavinA]

Fuel Specification
The fuel used shall be a variable blend of used vegetable oil and sunflower oil, collected from xxxx sources, filtered to remove impurities, and then burnt in a specially adapted Lister SOM generator.

Contamination
The fuel used shall be filtered to remove any solid particulate contamination. No fuels other than waste vegetable oil or sunflower oil shall be used in the blend, and post modification, the generator is unsuited to the use of fossil fuel derived diesel or biodiesel.

Fuel Measurement and Sampling Procedure
Records shall be kept of the volume of all waste vegetable and waste sunflower oil fuels used, together with the volume of any impurities removed during the filtering process, and made available upon request.

Waste handling records for the transport and storage of waste veg oil shall be kept as additional evidence of the original source of the waste vegetable oil and waste sunflower oil used.

All such records shall be kept for a minimum period of 10 years, and shall be signed and dated by an authorised operator.


***

I'm assuming here that you have a waste handlers license, and will therefore have to keep records of all shipments of waste veg oil brought onto the premises anyway? These may double up ok as your records of the volume of fuel used / evidence that you're using waste veg oil, or you may need to weigh or measure the volume of each shipment as it comes in, and keep seperate records, eg if you're getting half filled containers coming in etc.

after reading through the bumf, and the example given in the sections they talk about, I'm pretty sure this should cover it, but I've not done one of these before, so won't be offended if someone comes along and wants to edit it or whatever.

good luck, hope this helps.

[bottleveg]

Gavin, many thanks for such a quick and detailed response. That looks like the answer I needed. A couple of things-
“the generator is unsuited to the use of fossil fuel derived diesel or biodiesel.” But it will burn them?
“All such records shall be kept for a minimum period of 10 years” Why ten years? I’m sure the EA rule is two. Please don’t think I’m picking, I’m just keen to better my understanding.
Yes I have a full EA transport and trading licence with my main business so my personal collections of waste oil are documented and covered by waste transfer notes.
              Thank you for your help, Mark

[GavinA]

Gavin, many thanks for such a quick and detailed response. That looks like the answer I needed. A couple of things-
“the generator is unsuited to the use of fossil fuel derived diesel or biodiesel.” But it will burn them?

that bit was a bit of poetic license, as I'm obviously not sure of your set up. Are you actually using veg oil directly in the generator, or converting it to biodisel first? If using veg oil directly, presumably you've added some sort of heat exchanger thing to pre-heat the veg oil so that it burns ok and doesn't clog it all up, and tuned the engine a bit? actually, on reflection it probably is best to take that bit out or alter it a bit, as it's not really true and they may pick up on it.

“All such records shall be kept for a minimum period of 10 years” Why ten years? I’m sure the EA rule is two. Please don’t think I’m picking, I’m just keen to better my understanding.
Yes I have a full EA transport and trading licence with my main business so my personal collections of waste oil are documented and covered by waste transfer notes.
              Thank you for your help, Mark

I don't know the specific's for this stream, but have just been going through the REAL assurance code , and it wants us to keep full records of everything relating to everything for 10 years, so I plucked that figure out of thin air based on that. Essentially if you're not actually offering to send them copies of the paperwork, then I reckon keeping the records for 10 years is probably a good precaution for you anyway, in case anyone ever decides to challenge you about it further down the line. It strikes me that biodiesel / waste veg oil generators would be prime candidates for some dishonest types to use to rip the FIT off if their procedures get lax at any point (probably now), at which point they'll probably do spot checks on everyone else, and if your records don't go back far enough to cover all your payments, it's possible they could try to claw that money back years down the line. Best to cover your back I reckon, but it's up to you, 2 years may also be fine, I'd just not risk it for the sake of a few extra files.

[Ted]

And just to clarify a couple of things for any bystanders that may read this thread:

 - this type of system is eligible to be registered with OFGEM to claim Renewable Obligation Certificates - ROCs - which should not be confused with Feed In Tariffs. This technology type has not currently been included in the final FITs scheme.

- OFGEM need to satisfy themselves of the % of the input fuel that is provably from a waste source and is not a fossil fuel. If they deem that less than 100% of the input is from a waste source then the same % will be applied to the electrical output meter readings and a correspondingly lower number of ROCs will be awarded.

[bottleveg]

Thanks for adding that Ted. So if our applications are accepted then we will probably just continue on the ROCS scheme? So it may not be worth the expense of a grid tie and feed in meter?

[guydewdney]

what are you doing about the questio of 'calorific value' which I have been asked?

[bottleveg]

what are you doing about the questio of 'calorific value' which I have been asked?

Would this link help?
http://www.shortcircuit.com.au/warfa/paper/paper.htm
http://www.engineeringtoolbox.com/fuels-higher-calorific-values-d_169.html