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Beta Analytic LimitedLondon Bioscience Innovation Centre2 Royal
College StreetLondon NW10NHUnited KingdomTel: (44) 207 617 7490Fax:
(44) 207 160 5350Email: [email protected]
Beta Analytic Inc. (Headquarters)4985 SW 74 CourtMiami, Florida
33155USATel: (1) 305-662-7760Fax: (1) 305-663-0964Email:
[email protected] Site:
http://www.betalabservices.com/
Beta Public Comment on Biodiesel, Glycerol, and the Renewables
Obligation
Mr. Fletcher,
Please find below our answers to your questions for the
biodiesel, glycerol and renewablesobligation consultation.
Chapter 1, Question 1: Chapter 1 summarises the most frequently
used manufacture process forBiodiesel. Are you aware of any
techniques used, available or foresee in the near future thatshould
be taken into account?
We are not aware of any future techniques that need to be taken
into account.
Chapter 1, Question 2: Can any further evidence be provided to
show that the source of thetransferred hydrogen atoms within the
glycerol cannot come from the methane used in themanufacture of the
methanol?
We believe that this would not be possible. On the other hand,
we believe that radiocarbon datingcan be used to determine whether
the glycerol is derived from fossil fuels, such as methanolmade
from fossil fuel methane.
By analyzing the carbon atoms with radiocarbon dating of both
the biodiesel and the glycerolproduced in the manufacturing
process, one can easily determine whether glycerol might becoming
from fossil fuel derived methane.
Radiocarbon dating is regularly used to determine the biomass
percentage of biofuels such asbiodiesel. Consequently, there is no
reason why this method cannot be used to address whetherglycerol is
made from fossil fuel components. In fact, radiocarbon dating has
been standardizedas an analytical method called ASTM D6866
precisely for this type of determination.
Radiocarbon dating has been used for decades for dating
archaeological artifacts. The sameprinciples of dating (i.e.
analysis of the carbon 14 atom) can also be used to measure
thebiomass component of materials. In effect, biomass contains a
well-characterized amount ofcarbon 14 that is easily distinguished
from other materials such as fossil fuels that do not containany
carbon 14. Since the amount of carbon 14 in biomass is well known,
a percentage ofbiomass carbon can be calculated easily from the
overall carbon atoms in the sample.
Although ASTM D6866 is now used throughout the world to measure
biomass carbon, the origins
of the method are American. It was written at the request of the
USDA to satisfy legislationrequiring Federal agencies to give
preferred procurement to manufacturers using the greatestamount of
biomass in their products (per the Farm Security and Rural
Investment act of 2002). Itwas quickly established that radiocarbon
dating was the only viable accurate technique to makethe
determination of the biomass percentage. A working standard of
radiocarbon dating forindustrial use was completed in 2004 and is
now cited in US Federal Law (7 CFR part 2902).
Our firm, Beta Analytic, has been in direct contact for the past
year and half with OFGEM withregard to their Renewable Obligation
Certificate program for Energy from Waste Combined Heatand Power
plants. A study was commissioned on behalf of OFGEM by the
Renewable Energy
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Association, with Beta Analytic, Columbia University and
Fichtner's participation to demonstratethe viability of radiocarbon
dating for determining the biomass fraction of materials. I
haveattached to this email a copy of this study.
The study clearly shows that radiocarbon can accurately
determine the biomass fraction ofdifferent materials (see in
particular page 20). Furthermore, the study demonstrates
thatradiocarbon dating can be used to determine the energy produced
from biomass. The sameprincipals and findings in this report can be
used to bolster the use of radiocarbon dating as aviable analytical
method for verifying the biomass fraction of biodiesel and
glycerol.
Chapter 3, Question 1: Are there any circumstances in which
Biodiesel (produced using methanolderived from natural gas) would
not contain atoms from the natural gas?
In general, we believe that this would not be possible. On the
other hand, as stated above,radiocarbon dating can easily determine
whether biodiesel is made with fossil fuel feedstocks.Precision of
the method is excellent with an error of less than +/- 0.3%. We
therefore believe thatradiocarbon dating can easily address whether
biodiesel is manufactured with methanol derivedfrom natural
gas.
Chapter 3, Question 2: What are your views on this approach to
the eligibility of Biodiesel?
As stated above, we believe that radiocarbon dating using the
standardized method ASTM D6866can easily address the issue of
eligibility of biodiesel.
Chapter 4, Question 1: What are your views on the proposed
interpretations?
We believe some of the interpretations are overly restrictive
since radiocarbon dating can addresssome, if not all the concerns
of the biomass fraction of glycerol.
Chapter 4, Question 2: Do you agree with our preferred option of
adopting the total exclusioninterpretation?
We believe that this option is overly restrictive considering
that radiocarbon dating can addresssome, if not all the concerns of
the biomass fraction of glycerol.
Chapter 4, Question 3: Do you agree with our assessment of the
benefits and consequences ofeach interpretation, and do you foresee
any others for either interpretation provided in thischapter?
Radiocarbon dating is a cost effective method to verify whether
glycerol is made with fossil fuelfeedstocks. We therefore believe
that the total exclusion suggestion is too restrictive since
aproven analytical is available for determining the biomass
fraction of glycerol.
Chapter 4, Question 4: Are there any other valid interpretations
that should be evaluated in orderto determine Ofgem's policy on
glycerol?
Yes. Ofgem should take into account the composition of the
carbon atoms during themanufacture of both biodiesel and glycerol
to make the proper interpretation whether to allow theuse of
glycerol in the Renewable Obligations program. As stated above,
radiocarbon can be usedto make this determination.
Chapter 4, Question 5 (glycerol's use in Anaerobic Digestion):
Would there be any impact onAnaerobic Digestion if either
interpretation for glycerol was adopted? If so would this
besignificant?
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We believe that it would have an impact, but we are not in the
measure to attest how large wouldbe the impact.
Chapter 4, Question 6 (glycerol's use in Anaerobic Digestion):
Is there any information that wouldshow glycerol's methane
producing ability, which Ofgem could use to form our policy and
allow usto determine the renewable fraction of the biogas from an
anaerobic digester using glycerol?
Yes. Radiocarbon dating can easily determine the renewable
fraction of the biogas from ananaerobic digester using glycerol.
See the answer to question 2, chapter 1 for an explanation
ofradiocarbon dating.
Sincerely,
Thierry Sam TamersDirector
