Safety requirements related to the end-user equipment

This LAP is concerned with the safety requirements (and design and operation aspects) for commercial and domestic end user equipment operating with hydrogen gas blends resulting from hydrogen injected and distributed in the local gas grid at the DSO level

Glossary:

The requirements needed to guarantee the safety of the end user application.
Is it a barrier?
Yes
Type of Barrier
Economic barriers
Assessment Severity
3

Questions:

Question 1 Is there any legislation with regard to safety requirements related to end-user equipment (e.g.: limits in terms of H2 for use in gas appliances)? If yes, please answer the following question.
a) The most important safety requirement related to the end–user equipment is the obligation of the network operator to carry out an assessment of the grid compatibility after receiving a request for connection. b) UNECE Regulation 110 (Compressed and liquefied natural gas components) and the DIN 51624 establish a threshold of up to 2 Vol.–% hydrogen for the vehicle fuel CNG (compressed natural gas). If a CNG fuelling station is connected to the respective part of the gas grid, the admissible hydrogen concentration must not exceed 2 Vol.–%. c) In the event that no calibrated hydrogen content measuring system (process gas chromatograph) is installed, the hydrogen content must not exceed 0.2 Vol.–% (see the Technical Guideline of the Physical–Technical Federal Institute G 14). d) There is no normative limit for hydrogen admixture for the operation of conventional gas appliances burning gaseous fuels used for cooking, heating, hot water production etc.
Question 2 Changes to gas supply composition may have implications for gas appliances (safety) and the relevant legislation. What are the implications you expects with regard to the possible concentrations of hydrogen in the H2NG blend?
The current research results in Germany show that operation of gas appliances with hydrogen admixture up to 10 vol.% is possible without adaptation of the devices.
Question 3 For which end user applications do you foresee the main consequences and at which level? Could you please provide references to underpin your opinion?
DVGW Worksheet 262 describes threshold values for different gas applications. This relates in particular to the quality of gas and hydrogen concentration required by gas turbines, CHP motors and pore storage facilities as well as the failure to capture hydrogen concentrations using process gas chromatograph (PGS).
Question 4 Safety is the main topic with regard to the use of applications. Which additional safety precautions needed do you foresee? Could you please provide references to underpin your opinion?
There are no additional safety precautions to be foreseen.
Question 5 Changes to gas supply composition may have implications for CNG compression, storage, and use in CNG vehicles. What are the additional safety precautions needed? Could you please provide references to underpin your opinion?
By the assessment of the grid compatibility the network operator must determine hydrogen–sensitive applications in the grid and whether and to what extent hydrogen might come into contact with sensitive applications or interconnection points in downstream networks. The network operator may have to assess, whether the application of the affected customer (such as storage or gas turbine) may exceptionally be able to accept a higher hydrogen content. An affected customer is not required to accept higher hydrogen content if damage cannot be completely excluded, even if such content is increased for only a very short period of time.
Describe the comparable technology and its relevance with regard to hydrogen
Biogas

National legislation:

EU Legislation:

  • Regulation (EU) 2016/426 of the European Parliament and of the Council of 9 March 2016 on appliances burning gaseous fuels and repealing Directive
    This Regulation applies to appliances burning gaseous fuels used for cooking, refrigeration, air-conditioning, space heating, hot water production, lighting or washing, and also forced draught burners and heating bodies to be equipped with such burners and to safety devices, controlling devices or regulating devices and sub-assemblies thereof, designed to be incorporated into an appliance or to be assembled to constitute an appliance (fittings).

    Article 7 sets the obligations of manufacturers which should inter alia:
    • ensure that appliances and fittings meet the essential requirements set out in Annex I.
    • draw up the technical documentation referred to in Annex III (‘technical documentation’)
    • carry out the relevant conformity assessment procedure
    • keep the technical documentation and the EU declaration of conformity for 10 years
    • ensure that procedures are in place for series production to remain in conformity
    • carry out sample testing of appliances made available on the market,
    • investigate, and, if necessary, keep a register of complaints, of non-conforming appliances and fittings and recalls of such appliances and fittings, and shall keep distributors informed of any such monitoring.
    • ensure that their appliances and fittings bear a type, batch or serial number or other element allowing their identification, and the inscriptions provided for in Annex IV.
    • indicate on the appliance their name, registered trade name or registered trade mark, and the postal address at which they can be contacted
    • ensure that the appliance or fitting is accompanied by instructions and safety information
    • ensure that the fitting is accompanied by a copy of the EU declaration of conformity containing, inter alia, instructions for incorporation or assembly, adjustment, operation and maintenance
    • take corrective measures necessary to bring that appliance or fitting into conformity, to withdraw it or recall it, if appropriate.
    • where the appliance or the fitting presents a risk, immediately inform the competent national authorities giving details, in particular, of the non-compliance and of any corrective measures taken
    • provide competent national authority with all the information and documentation necessary to demonstrate the conformity of the appliance.

    Article 9 sets obligations for importers which should inter alia:
    • ensure that the appropriate conformity assessment procedure has been carried out
    • ensure that the manufacturer has drawn up the technical documentation, that the appliance bears the CE marking and is accompanied by instructions and safety information and that the manufacturer has complied with the requirements set out in Article 7(5) and (6).
    • indicate on the appliance their name, registered trade name or registered trade mark, and the postal address at which they can be contacted
    • ensure that the appliance is accompanied by instructions and safety information in accordance with point 1.5 of Annex I, in a language which can be easily understood by consumers and other end-users, as determined by the Member State concerned.
    • ensure that the fitting is accompanied by a copy of the EU declaration of conformity containing, inter alia, instructions for incorporation or assembly, adjustment, operation and maintenance in accordance, in a language which can be easily understood by appliance manufacturers, as determined by the Member State concerned.
    • ensure that, while an appliance or a fitting is under their responsibility, storage or transport conditions do not jeopardise its compliance with the essential requirements
    • carry out sample testing of appliances made available on the market, investigate, and, if necessary, keep a register of complaints, of non-conforming appliances and fittings and recalls of such appliances and fittings, and shall keep distributors informed of any such monitoring.
    • for 10 years after the appliance or the fitting has been placed on the market, keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities and ensure that the technical documentation can be made available to those authorities, upon request
    • further to a reasoned request from a competent national authority, provide it with all the information and documentation necessary to demonstrate the conformity of an appliance or a fitting in a language which can be easily understood by that authority

    Article 10 sets the obligations of distributors which should inter alia:
    • verify that the appliance bears the CE marking and that it is accompanied by instructions and safety information and that the manufacturer and the importer have complied with the requirements set out in Article 7(5) and (6) and Article 9(3) respectively
    • not make the appliance or the fitting available on the market until it has been brought into conformity.
    • ensure that, while an appliance or a fitting is under their responsibility, storage or transport conditions do not jeopardise its compliance with the essential requirements
    • make sure that the corrective measures necessary to bring that appliance or fitting into conformity, to withdraw it or recall it, if appropriate, are taken. Furthermore, where the appliance or the fitting presents a risk, distributors shall immediately inform the competent national authorities of the Member States in which they made the appliance or the fitting available on the market to that effect, giving details, in particular, of the non-compliance and of any corrective measures take