H2 quality requirements
This LAP is concerned with the gas quality issues for hydrogen injection and transport in the low pressure DSO local gas grid, including gas quality monitoring and metering in relation to payment terms and responsibilities for monitoring and metering
Glossary:
Requirements related to the quality of hydrogen (in relation to the composition of the gas(blend) as well as its physical property
Hydrogen quality is a term to describe the gas quality for use in the natural gas grid.
Hydrogen quality is a term to describe the gas quality for use in the natural gas grid.
Is it a barrier?
Yes
Type of Barrier
Structural barriers, Operational barriers, Economic barriers, Regulatory gap
Assessment Severity
3
Assessment
The current legal and operational framework as managed by Romanian Energy Regulatory Authority covers natural gas only, it does not include any specification about injection of hydrogen in NG pipelines
Questions:
Question 1
What is the basis for the billing of Hydrogen and Hydrogen Natural Gas Mixtures? Only the energy flow (kWh) or are other properties involved?
TRANSGAZ is the TSO (According to the provisions of Law no. 123/2012 on electricity and natural gas, the transport and system operator is organised and operates according to the independent system operator model (ISO). However the network is configured for natural gas only. Hydrogen is not covered and there is no billing arrangement for hydrogen network injection / transportation
Describe the comparable technology and its relevance with regard to hydrogen
Natural gas grid injection.
National legislation:
-
The Romanian Standardisation Committee CT 395
The requirements for H2 quality can be national rules or internationally ones.
- The Romanian Energy Regulatory Authority is responsible under Romanian Primary Law for creating a modern energy sector, corresponding to the major principles and objectives of the European Union energy policy of electricity and natural gas market liberalization and capable of meeting consumer demand, ANRE has developed and issued in recent years approx. 986 orders, decisions and opinions in accordance with the obligations deriving from the primary national law and the European legislation
EU Legislation:
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Directive 2009/73/EC concerning common rules for the internal market in natural gas
Directive 2009/73/EC establishes common rules for the transmission, distribution, supply and storage of natural gas.
Its provisions and obligations apply to Hydrogen Gas by virtue of Article 1 (2), which states that the rules established by this Directive for natural gas, including LNG, shall also apply in a non–discriminatory way to biogas and gas from biomass or other types of gas in so far as such gases can technically and safely be injected into, and transported through, the natural gas system.
Article 25 establishes the “Tasks of the distribution system operator” which include: ensuring the long-term ability of the system to meet reasonable demands for the distribution of gas […];shall provide any other distribution, transmission, LNG, and/or storage system operator with sufficient information […] as well as to ensure that the system operator does not discriminate between system users or classes of system including, including e.g. when setting rules for the charging of system users, etc
Article 32 sets the rules on “Third party access”: access to the transmission and distribution system, and LNG facilities shall be based on published tariffs, applicable to all eligible customers, including supply undertakings, and applied objectively and without discrimination between system users.