On Monday, Spire, Inc., the American Public Gas Association (APGA) and AGA filed joint comments (attached) on the DOE Request for Information (RFI) pertaining to Energy Conservation Standards for residential water heaters. The DOE notice initiated a data collection process to consider whether to amend DOE’s current energy conservation standards for residential water heaters. Specifically, the RFI solicited information to help DOE determine whether amended standards for consumer water heaters would result in significant energy savings and whether such standards would be technologically feasible and economically justified. A summary of the Spire Inc., APGA and AGA comments are as follows:

At the request from a member company operating in Minnesota, AGA’s Ted Williams provided draft recommendations for responding to public comments associated with indoor air quality (IAQ) submitted to the State docket associated with the proposed RNG interconnection tariff.  IAQ issues were just one of several major challenges posed for the RNG tariff.  Among familiar IAQ claims presented in other filings and public comments, the organization advocating against the tariff cited study results from a 2020 California Energy Commission sponsored study claiming potential DNA damage and mutagenicity effects from RNG from standard bench tests associated with DNA damage and mutagenicity, in this instance based upon exposures to emissions from the combustion of RNG.  AGA’s recommendations for response covered the study’s failure to take into account, for comparison purposes, displaced energy sources and emissions that would present their own risks in terms of DNA damage and mutagenicity potentials.  These would including electromagnetic fields (EMF) from substitution of gas-fired appliances to high-energy electric appliances (see the link), process-related emissions from cooking which include volatile organic compounds among other known carcinogens, combustion-related emissions resulting from upstream natural gas consumption for power generation, and combustion emissions from other carbon-based fuels at the point of use.  As a consequence, the comparison of natural gas and RNG in terms of DNA damage and mutagenicity potentials is decidedly narrow and presented without sufficient context to evaluate potential societal risk of alternatives.  As the statement filed in rate case point outs and as demonstrated in the cited report, findings with respect to even this limited comparison are tentative and require additional research. 

 

At the request of CSA Group in support of a September webinar sponsored by Natural Resources Canada, BECS staff has submitted the scope of a proposed AGA presentation covering North American technical and policy issues associated with introducing natural gas/hydrogen blends and hydrogen as a fuel gas into the North American natural gas transmission and distribution infrastructure.  AGA participation was recommended by the Canadian Gas Association (CGA) based upon ongoing and planned end use appliance testing on natural gas/hydrogen blends, but the AGA presentation will only focus upon infrastructure issues.  The presentation will dovetail with recent CGA/AGA literature review of infrastructure issues, and CGA is expected to cover this work in its presentation on the webinar.  A principal focus of the AGA presentation would be on U. S. technical and policy issues and uncertainties.  While other North American activities to date have focused upon review of technical literature and other sources supporting introduction of natural gas/hydrogen blends and hydrogen fuel gas, this presentation would emphasize reported gaps in fundamental information relating to pipeline integrity, potential tariff and contractual barriers, gas interchangeability limits and unknowns, and potential issues of heterogeneous compositions in pipeline operations and custody transfer.  Research efforts to address these issues would be briefly summarized along with suggested strategies for moving forward for introducing these fuel gases.

 

At the invitation of SGA and Spire Inc., Ted Williams will present an overview of end use codes and standards issues and their critical contribution to the continuing direct use of natural gas at the SGA Virtual Conference, “2020 Natural Gas Connect” on Thursday, July, 16th.   In addition, Southern Company Gas and BECS Committee member Andrea Papageorge  will participate as the session host.  Details of the event are available here.  At the request of the sponsors, the AGA presentation will focus upon end use codes and standards basics for a general gas industry audience with some references to currently-active issues such as the AGA and American Public Gas Association (APGA) appeal 4 onerous provisions being considered for adoption in the 2021 International Energy Conservation Code (IECC).  In addition to the link provided above, individuals who are interested in participating in the event and wanting more detailed information on the event program should consider contacting Tom Schultz of Spire Inc., ([email protected] ) or Andrea Papageorge of Southern Company Gas ([email protected] ).

 

This week in an effort spearheaded by AGA’s Office of General Counsel, a MOU covering upcoming emissions testing of residential gas-fired cooking appliances was executed covering the handling of the testing program information among the three organizations anticipated to sponsor the testing and issues of program governance.  The MOU does not cover development of the testing program scope of work or other technical aspects of the program but establishes the working relationship of the three organizations.  With completion of the MOU, the three organizations have engaged in preliminary discussions of the technical program and are working out details for the establishment of a technical working group to organize the project and oversee its execution.  It is anticipated that organization of the technical working group will be completed in the next few weeks, where upon the finalization of a scope of work, solicitation of the primary testing organization, and other details of implementing the specific testing, will be undertaken.  With the addition of PERC and with support of the AHAM membership, the general boundaries of the testing program in terms of number of gas-fired appliances to be tested should be agreed to by the time of the first technical group meeting.  AGA anticipates that the technical working group will meet weekly until the testing program is set up and underway.

Under its contract with CSA Group, the major sponsor of the testing program along with AHRI and AGA, AEI delivered its draft report on the testing and test results of natural gas/hydrogen appliance testing  for sponsor review.  AGA BECS staff will begin review of the draft report early next week.  In parallel and at the request of CSA Group, BECS staff is taking the lead in developing a summary report on the testing program.  As background, the BECS Committee requested the initial testing program and is a principal proponent of the testing program and AGA staff has essential background on the drivers behind initiatives to introduce natural gas/ hydrogen mixtures into North American natural gas systems.  As discussed in earlier “Friday Updates,” this program is exploratory in natural and not intended to produce definitive results regarding appliance compatibility with the natural gas/hydrogen mixtures tested (5% and 15% hydrogen by volume).  Instead, the reporting is intended to inform the ANSI-accredited Z21/Z83 Technical Committee on potential further testing or possible standards actions.  In parallel and with support of CSA Group, additional testing of older “used” appliances and their operational response to high concentrations of hydrogen in natural gas is being discussed.   The draft report review of AGA is expected to be completed by the end of next week and the drafting of CSA Group report completed in early August.

 

[This is a weekly feature of the “Friday Update” covering state code calendar activities as presented by the online utility “Fiscal Note,” which is sponsored by APGA and AGA Code and Standards.]

 

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