Safety requirements related to the end-user equipment

This LAP is concerned with the safety requirements (and design and operational aspects) for commercial and domestic end-user equipment operating with hydrogen based SNG blends (via methanation) injected into the gas grid

Glossary:

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

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 2-6 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 legislation for injection of upgraded SNG (to natural gas quality in terms of gross calorific value) is existing whereas the rules for injection of hydrogen are not in place currently BUT following the so far used approach upgraded SNG doesn’t change the quality of natural gas in terms of gross calorific value whereas hydrogen does. Since the customers pays for the consumed energy and not for the consumed volume, there is a need to adapt the billing to the changed gross calorific value. In addition the so called Wobbe index changes because of the change of the gross calorific value etc. A changed Wobbe index might cause damages to the equipment if the nozzle of the regarding equipment is not adapted.
Question 2 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.
In Austria max. 4% Percent (Mol) can be injected into natural gas grids; see standard:/guideline ÖVGW 31 plus ÖVGW 33 = specification of natural gas quality
Question 3 Changes to gas supply composition may have implications for the design of gas appliances (safety) and the relevant legislation. What are the implications you expect with regard to the possible concentrations of hydrogen in the H2NG blend?
Since the so called Wobbe index changes – caused by the change of the gross calorific value etc. of the mixture – in comparison to natural gas or upgraded SNG – there might be a need to change the nozzles of the equipment. A non–adapted Wobbe index might cause damages to the equipment. This is a serious issue for older smaller gas fired turbines. In addition there might be a need for additional sensors which are capable to detect hydrogen.
Question 4 For which end user applications do you foresee the main consequences and at which level? Could you please provide references to underpin your opinion?
In terms of number of the impacted devices it might be gas boilers. The question here is the allowed range for the change of the Wobbe Index – hence impacts on the threshold oof hydrogen to be mixed with natural gas – without damaging the material and at the same time not lowering the efficiency. When it comes to older smaller gas fired turbines the consequences might be significant in terms of money.
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
In Austria – because of the relatively low threshold of max. 4% hydrogen in the natural gas mixture, implications for CNG compression and storage and use in CNG vehicles might be of smaller nature but with increasing hydrogen share in the mixture the impacts might be significant since the diffusion rate of hydrogen is very high in comparison to natural gas. When it comes to higher hydrogen shares in the natural gas mixture – so above 4% – the consequences have to be analysed in depth. An adequate number of tests is needed..

National legislation:

EU Legislation:

  • Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control (IED)
    The Directive, which applies to the production of hydrogen (production on an industrial scale by chemical or biological processing) (Annex I, point 4.2) contains inter alia:
    • Basic obligations of the operator (Article 11)
    • The content of permitting applications (Article 12)
    • Permitting Conditions (Article 14)
    • Emission limit values, (Article 15)
    • Monitoring requirements (Article 16)
    • Access to information and public participation (Article 24)

    The meaning of "production on an industrial scale by chemical or biological processing in Annex I section 4" has been clarified by the EU Commission, in support of transposition and implementation measures. :

    Annex I Section 4 (“chemical industry”) refers to “production on an industrial scale” and contains no quantitative capacity thresholds. The scale of chemical manufacture can vary from a few grams (of a highly specialised product), to many tonnes (of a bulk chemical product); yet both may correspond to “industrial scale” for that particular activity.

    Various criteria should be taken into account to decide whether production is “on an industrial scale”, including such factors as the nature of the product, the industrial character of the plant and machinery used, production volume, commercial purpose, production solely for own use, environmental impact. Such considerations should take account of the primary objective of the IED as expressed in Article 1 as to "prevent or, where that is not practicable, to reduce emissions into air, water and land and to prevent the generation of waste, in order to achieve a high level of protection of the environment taken as a whole", complemented by the general principle set in Article 11 (c) that "no significant pollution is caused".

    The fact that the activity is carried out for "commercial purposes" may be a strong indicator of "industrial scale", […] However, it may not be sufficient to use the “commercial purpose” of an activity as the sole determinant of "industrial scale". It may also be important to take into account the potential environmental impact of a production sequence.


    Directive 2010/75/EU established an integrated approach towards prevention and control. This integrated approach means that the permits must take into account the whole environmental performance of the plant, covering e.g. emissions to air, water and land, generation of waste, use of raw materials, energy efficiency, noise, prevention of accidents, and restoration of the site upon closure. The permit conditions including emission limit values must be based on the Best Available Techniques (BAT).
  • Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment (SEA Directive)
    The Directives (and their subsequent amendments) define a strategic environmental impact assessment procedure. The procedure is summarized as follows: the developer may request the competent authority define what should be covered by the EIA information to be provided by the developer (scoping stage); the developer must provide information on the environmental impact (EIA report – Annex IV); the environmental authorities and the public (and affected Member States) must be informed and consulted; the competent authority decides, taken into consideration the results of consultations. The public is informed of the decision afterwards and can challenge the decision before the courts.

    In line with the EIA Directive, Production and Storage of Hydrogen falls within the projects listed in Annex II (6a and 6c -production of chemicals; and storage facilities for chemical product), for which Member States shall determine whether the project shall be made subject to an assessment or not. In some EU countries, storage of 5 tons of hydrogen or more falls within the scope of the Directives.

    The latest amendment, (Directive 2014/52/EU) introduces minimum requirements with regards to the type of projects subject to assessment, the main obligations of developers, the content of the assessment and the participation of the competent authorities and the public.
    X
  • 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