H2/SNG quality requirements

This LAP is concerned with the measurement, monitoring, metering and billing basis for hydrogen based SNG (via methanation) injected and transported within the gas grid at DSO or TSO level

Glossary:

Requirements related to the quality of SNG from (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.
Is it a barrier?
No
Assessment Severity
0

Questions:

Question 1 Is the legislation with regard to injection of Methane (SNG) via methanation from hydrogen the same as for hydrogen? if yes, question 2-5 are the same as for category 7, application 1: injection of hydrogen in the gas grid and do not have to be answered
No. The injection of H2 directly to the gas grid is not allowed in Spain while the SNG is allowed under specific constraints.
Question 2 What is the basis for the billing of SNG from hydrogen and SNG from Hydrogen Natural Gas Mixtures? Only the energy flow (kWh) or are other properties involved?
The energy flow is the property in which is based the billing. The origin of the gas does not affect it. There is an open market for gas in Spain, so the price is adjusted via a legislated system by the Market Operator, which is MIBGAS.
Question 3 What are the legal and administrative requirements and responsibilities with regard to real-time Measurement Technologies for the monitoring and billing of SNG from hydrogen Natural-Gas Mixtures? Do they differ from the requirements for natural gas?
The information obtained in the measurements has to be saved. The measurements have to be permitted by the installation owners. The measurements are the same ones than for NG, because the law is based on NG. In the connection points, the responsible of the installation can be the TSO, the Technical Manager of the System, or the commercial entities. In the supplier side, ownership can be from the final customer, a DSO or the commercial entities.
Question 4 Are there other, SNG from hydrogen quality related, legal and administrative requirements to allow the injection of SNG from hydrogen in the grid?
The law 34/1998 in its article 54.3 say that the composition is regulated before the injection of the SNG. This regulation is given by the "PD–01 «Measurement, Quality and Odorization of Gas»" where the composition limits are defined for natural gas and SNG, regarding quality.
Question 5 How is the responsibility in your country organized with regard to the measurement and other injection related quality requirements? Is this the responsibility of the producer, the TSO/DSO or a third party?
Producer should measure it. TSO also has to do it..
Describe the comparable technology and its relevance with regard to hydrogen
Natural Gas, biogas, natural gas mixtures with air.

National legislation:

EU Legislation:

  • 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.
  • Regulation 715/2009 on conditions for access to the natural gas transmission networks
    Regulation 715/2009 sets non-discriminatory rules for access conditions to (a) natural gas transmission systems; (b) LNG facilities and storage facilities taking into account the special characteristics of national and regional markets

    To achieve this, it sets harmonised principles for tariffs, or the methodologies underlying their calculation, for access to the network, but not to storage facilities, the establishment of third-party access services and harmonised principles for capacity-allocation and congestion-management, the determination of transparency requirements, balancing rules and imbalance charges, and the facilitation of capacity trading.
  • Regulation (EC) No 713/2009 of the European Parliament and of the Council of 13 July 2009 establishing an Agency for the Cooperation of Energy Regulators
    Article 1 Project matter and scope
    This regulation aims at:
    (a) setting non–discriminatory rules for access conditions to natural gas transmission systems taking into account the special characteristics of national and regional markets with a view to ensuring the proper functioning of the internal market in gas;

    Article 8 “Tasks as regards terms and conditions for access to and operational security of cross border infrastructure
  • Commission Regulation (EU) 2015/703 of 30 April 2015 establishing a network code on interoperability and data exchange rules
    The network code on interoperability aligns the complex technical procedures used by network operators within the EU, and possibly with network operators in the Energy Community and other countries neighbouring the EU.Article 7, Measurement principles for gas quantity and quality. In addition to interconnection points, Article 17 shall apply to other points on transmission network where the gas quality is measured. Article 18 shall apply to transmission systems. This Regulation may also apply at entry points from and exit points to third countries, subject to the decision of the national authorities.