G-25—Policy on the use of gas meters in hydrogen-blending activities in the natural gas network

Category: Gas
Issue date: 2023-04-13
Effective date: 2023-04-13
Revision number: n/a
Supersedes: n/a

Table of contents

1.0 Purpose

This bulletin establishes the temporary requirements and conditions for the use of gas meters in trade measurement associated with hydrogen blending in the natural gas network.

In addition, it introduces modifications to the sample selection requirements and reverification periods for meters that are authorized for this use.

Note: While this bulletin aims to facilitate the deployment of hydrogen blending in Canada, a more thorough analysis on the short-, mid- and long-term impacts of hydrogen-enriched natural gas on regulated meters will be done in collaboration with gas industry stakeholders while considering international research. Related legislation, specifications, policies and programs will be revised in a timely manner based on the results of this analysis.

2.0 Scope

This bulletin applies to all meters (i.e. in-service or new) approved by Measurement Canada (MC) for the measurement of natural gas that are used to measure hydrogen-enriched natural gas supplied to industrial end-users and to commercial and residential customers.

3.0 Authority

This bulletin is issued pursuant to subsection 9(1), section 12 and paragraph 33(1)(k) of the Electricity and Gas Inspection Act.

4.0 References

5.0 Background

In 2020, the Government of Canada, in support of its strengthened climate plan, developed the Hydrogen Strategy for Canada, which sets out an ambitious framework for actions that will make hydrogen a tool to achieve its goal of net-zero emissions by 2050 and position Canada as a global industrial leader of clean renewable fuels.

Hydrogen blending is an emerging practice in many countries currently relying on natural gas, including in Canada where multiple pilot projects are taking place across provinces and territories. It is known that the increased use of hydrogen in natural gas blends will directly impact several aspects of regulated meters used in trade measurement, including the material compatibility and durability as well as the metrology. Regulatory bodies around the world are progressing at various rates in developing and implementing new requirements and standards to oversee related metering and testing equipment.

While the natural gas industry and MC are in the early stages of determining the effects of hydrogen blending on meters, MC is committed to taking a leading role in assisting the gas industry in addressing the impact of hydrogen blending on meter performance and accuracy and in filling the gap with other jurisdictions. The policy set forth in this bulletin will help MC oversee and monitor hydrogen-blending activities by providing the minimum requirements and conditions to which all contractors involved in hydrogen-blending activities must comply while providing the necessary flexibility to deploy innovative hydrogen-blending initiatives and pilot projects. The policy will also help MC protect consumers and businesses against loss due to inaccurate measurement.

As part of its mandate, MC must ensure that gas industry stakeholders (for example, manufacturers and public utilities) comply with the Electricity and Gas Inspection Act (Act) and the Electricity and Gas Inspection Regulations (Regulations). However, when some flexibility in the administration of legislation is needed to respond to emerging technologies, the protection of consumers and vulnerable parties will be MC's primary focus when considering the strategy it must take to provide a level of flexibility or relief.

6.0 Definitions

Contractor
(fournisseur)
A person or body as defined in subsection 2(1) of the Act.
Hydrogen blending
(mélange d'hydrogène)
Injection of renewable hydrogen into natural gas streams.
MeterFootnote 1
(compteur)
A gas meterFootnote 1 as defined in subsection 2(1) of the Act.

7.0 Policy

7.1 General

In accordance with the requirements and conditions set forth in this bulletin, MC provides some relief from the legal requirements of the Act and Regulations through the following provisions:

  • Temporary authorization to use meter types or classes that have not been formally approved by MC's Engineering and Laboratory Services Directorate (ELSD) for measuring hydrogen-enriched natural gas.
  • Temporary modifications to sample selection requirements outlined in sampling plans for inspection S-S-04 and S-S-06.
  • Modifications to reverification periods pursuant to paragraph 12(1)(c) of the Act.

Note: Modifications to the measurement capabilities and characteristics of a meter (e.g. hydrogen compatibility) may not be covered by the meter's notice of approval. The manufacturer or approval applicant should consult bulletin GEN-26 and, if needed, contact the ELSD for assistance in this regard.

7.2 Risk management plan

Meters must be kept in good repair and comply with the legal requirements. Contractors must develop and implement a risk management plan that includes strategies to mitigate the risk of inaccurate measurement of meters used to measure hydrogen-enriched natural gas as well as monitoring strategies.

Note:

  • Where subsection 7.5 below applies, mitigation strategies should include an analysis of how to manage increased fluctuations in gas quality and quantity due to hydrogen admixture.
  • MC may require a contractor to amend its risk management plan or may temporarily suspend the contractor's hydrogen-blending activities if MC considers that there is a risk of measurement inaccuracy. MC will consult with the gas contractor before taking any such action.

7.3 Concentration of hydrogen

The following requirements apply:

  1. Subject to the requirements stated below in items b, c and d, flowmeters may be used to measure natural gas containing higher volumes of hydrogen when:
    • the operating concentration of hydrogen is 25% or less by volume,
    • the operating pressure does not exceed 300 psig or psia, or the metric equivalent, and
    • the contractor complies with all applicable requirements of this bulletin, including the provision of information pursuant to paragraph 11.1(a).
  2. Where the operating concentration of hydrogen is 5% or less by volume, contractors must inform MC of their hydrogen-blending activities or projects.
  3. Where the operating concentration of hydrogen is between 5% and 10% by volume, contractors must contact MC and provide evidence (preferably objective) to demonstrate that the integrity of the flowmeters is maintained, and that there is no deterioration in performance resulting in non‑compliance with prescribed limits of error and inequitable impact to consumers.

    Note: Evidence could be, but is not limited to, any of the following:

    • monitoring activities in accordance with section 10;
    • test data or a certificate of approval from another national measurement authority or a national metrology institute recognized by ELSD;
    • a meter manufacturer's attestation in accordance with subsection 11.2.
  4. Where the operating concentration of hydrogen is greater than 10% by volume, contractors must obtain approval from MC after ELSD conducts a thorough evaluation of their hydrogen-blending activities or projects. Projects will be considered on a case-by-case basis.

7.4 Sale of gas by volume units

Where gas is sold by volume units, a contractor must ensure that any standard or method used for the calculation of gas characteristics and properties is applicable to hydrogen-enriched natural gas or that they are aware of any limitations on its applicability, if any.

Note: Contact ELSD for assistance in this regard, if needed.

7.5 Sale of gas by energy units

Where gas is sold by energy units and unless otherwise specified by MC, contractors must:

  • analyze the impact of hydrogen blending points in their network in consideration of the determination of the number of energy units, as well as gas sampling methods, and ensure that any sales per unit of measurement continue to be within the limits of error prescribed in section 46 of the Regulations.
  • determine the calorific value of the gas by measurement or calculation based on gas sampling using a device approvedFootnote 2 to measure the calorific value for the ranges of components present in the gas supplied;
  • ensure the deviation between the calorific value used for billing and the average calorific value delivered during the billing period is less than or equal to 0.25%.

8.0 Reverification periods

8.1 General

The initial and subsequent reverification periods for meters used to measure hydrogen-enriched natural gas are those set forth in bulletin G-18 and are subject to the following requirements:

  • Where the operating concentration of hydrogen is greater than 5% by volume, the initial and subsequent reverification periods set forth in bulletin G-18 may apply if the contractor's risk management plan is accepted by MC and the monitoring activities provide evidence of the continued meter accuracy and compliance with legal requirements.
  • Reverification periods may be formally shortened if results of previous, interim or future inspections or performance monitoring do not demonstrate that the subject meters remain in compliance with legal requirements or indicate a deterioration of performance that justifies shortening reverification period.

8.2 Lengthened reverification periods

Lengthened initial reverification periods and subsequent reverification periods are set forth in bulletin G-18 and subject to the following requirements:

  • Where the operating concentration of hydrogen is equal to or less than 5% by volume, the lengthened initial reverification period and subsequent reverification periods of meters may remain in effect until the expiry of the seal if the contractor's risk management plan is accepted by MC and the monitoring activities provide evidence of the continued meter accuracy and compliance with legal requirements.
  • Where the operating concentration of hydrogen is greater than 5% by volume, the initial reverification period and subsequent reverification periods of meters identified in bulletin G-03 must not be lengthened, unless otherwise specified by MC based on evidence that the lengthened period will not adversely affect confidence in the accuracy of the meters and their continued compliance with legal requirements.

9.0 Meter inspection types

9.1 100% inspection

Note: 100% inspection applies to in-service meters that are not included as part of a seal extension granted following compliance sampling. This provides for the reverification or removal of these meters from service prior to the expiration of their seal period.

The following requirements apply:

  1. Where meters are subject to 100% inspection on or after the effective date of this policy, the following requirements apply:
    1. Meters must be retrieved and reverified (or reverified on site for some device types) prior to the expiration of their current seal period.
      Meters must be verified as per the applicable verification and reverification specification for the subject meter types.
    2. Reverification periods are set forth in section 8.0.
  2. Where meters subject to 100% inspection have been reverified prior to the effective date of this policy, the following requirements apply:
    1. The granted reverification period may be adjusted accordingly with the default initial seal period in consideration of the requirements of section 8.0.
    2. Meter owners who modify the reverification period according to 9.1(b)(i) must document and retain records of the modifications.

9.2 Acceptance sampling

Note: Acceptance sampling in accordance with specification S-S-04 can be used for the verification of isolated lots and short series of lots of homogeneous qualified meters and determining their reverification period.

In addition to the existing requirements under S-S-04, a lot submitted for acceptance sampling must consist of homogeneous meters as specified in the applicable verification and reverification specification for the subject meter type. Meter owners must document and retain the following information:

  • lot designation and meter types;
  • meter sampling records and associated lists used to process the lot's acceptance; and
  • manufacturer defects or recalls that may apply to the subject meters.

9.3 Compliance sampling

Note: Compliance sampling in accordance with specification S-S-06 can be used for the reverification of homogeneous lots of qualified in-service meters specified in bulletin S-02. This provides for removal of representative samples, assessment of their performance and potential granting of a seal period extension.

The following requirements apply:

  1. Where a lot is submitted for compliance sampling inspection on or after the effective date of this policy, the following requirements apply:
    1. The lot must comply with the homogeneity requirements specified in S-S-06 and the applicable verification and reverification specification for the subject meter type.
    2. From the main list of meters in the lot, filters must be applied to identify all meters used to measure hydrogen-enriched natural gas and the associated operating concentration of hydrogen.

      Note: Identified meters are subject to random sampling for monitoring purposes in accordance with section 10.0.

    3. Meter owners who form or subdivide lots to account for the difference in composition of the gas measured (i.e. traditional natural gas or hydrogen-enriched natural gas) and the time in usage (i.e. time on test), in addition to the homogeneity requirements specified in 9.3(a)(i) must document and retain the following information:
      • lot designation as per 9.3(a)(iv) and meter types,
      • meter and/or lot used in traditional natural gas or hydrogen-enriched natural gas applications,
      • meter sampling records and associated lists used to process the lot's compliance, and
      • manufacturer defects or recalls that may pertain to the subject meters.
    4. The lot number must be preceded by the letter "H" to distinguish it from meter lots used only in traditional natural gas applications.
    5. The granted seal period extension must be determined in consideration of the requirements specified in 8.2.
  2. Where a lot was submitted for compliance sampling and a seal extension was granted prior to the effective date of this policy, the following requirements apply:
    • The lengthened initial reverification period of such a lot remains effective for the lifetime of the lot.
    • The seal period extension that was previously granted remains valid.
    • The maximum seal period extension level that can be applied to the lot at subsequent sampling activities must be level 2.

10.0 Monitoring

In their risk management plan, contractors must include a strategy for monitoring meters used to measure hydrogen‑enriched natural gas until these meters are fully approved by MC for such use. The contractor:

  1. must provide details of their monitoring strategy for approval by MC;

    Note: MC reserves the right to modify the depth and breadth of monitoring.

  2. must use a sampling method recognized by MC, subject to the requirements of this section;

    Note:

    • For novel pilot projects or initiatives, the minimum number of samples accepted by MC will be determined on a case-by-case basis, based on the information provided to MC.
    • An existing sampling plan as per subsections 9.2 or 9.3 can be used.
  3. must test the performance of the meters under the same conditions as the ones in service and provide the test plan to ELSD for approval and to confirm the applicable test points and accuracy tolerances;

    Note: Ideally, the test medium is hydrogen-enriched natural gas. Due to the very limited availability of testing facilities with hydrogen testing capabilities at the time of publication of this bulletin, performance testing may be done using alternative test medium under the following conditions:

    • The alternative test medium (e.g. air) has been approved by ELSD;
    • Performance testing is done by an organization accredited by MC pursuant to S-A-01, a recognized test facility pursuant to G-16 or another test facility or laboratory recognized by ELSD until further notice.
  4. may form a sample lot using a combination of:
    • existing lots of meters that are considered homogeneous (e.g. same make, model, capacity rating, seal period extension and level) and were produced by the same manufacturer within a four-year period; or
    • meters subject to 100% inspection as deemed most appropriate by the gas contractor with respect to risk assessment, homogeneity and time in usage requirements; and
  5. must document and maintain the associated lists of meters that were used for monitoring and the data obtained, and make them available to ELSD.

11.0 Administrative requirements

11.1 Documentation

The following requirements apply:

  1. The following information, but not limited to, must be provided or made available to MC prior to any hydrogen-blending activities done by a contractor:
    • business name and address;
    • MC registration number;
    • name and email address of contact person;
    • hydrogen blending rate(s) or gas composition data;
    • number and list of subject meters, including:
      • meter types, models and serial numbers;
      • operating range(s);
      • name of manufacturer;
      • notice of approval number;
      • inspection number (i.e. the unique identification number assigned by the meter owner);
      • seal period; and
      • type of inspection last performed (i.e. 100% inspection, acceptance sampling or compliance sampling) and inspection results;
    • a risk management plan which includes a monitoring strategy; and
    • any additional information related to the hydrogen-blending activities, or required by MC.
  2. Status reports on hydrogen-blending activities or on the progress of an initiative or pilot project, as well as on the monitoring activities must be provided to MC at least annually or upon request.

Note: Some of the information required in this section may be included in the annual meter population report on meters owned by gas contractors (GEN-45) and in the reports on meter inspections performed for the purpose of meter verification or reverification submitted by authorized service providers (GEN-46).

11.2 Letter of attestation

A meter manufacturer's letter of attestation must include the following statements:

  • (Insert the manufacturer's name) attests that the following meters (insert the make, model and Notice of Approval number of each meter) can be used to measure hydrogen-enriched natural gas with a proportion of hydrogen up to (insert %) by volume and will remain in full compliance with Measurement Canada requirements; and
  • The following specifications, procedures and test results (insert the document title, date and revision number) established by (insert the manufacturer's name) with respect to the performance testing of these meters with hydrogen-enriched natural gas, being attested to by (insert the manufacturer's name) are, upon request, subject to review and acceptance by Measurement Canada.

The letter of attestation must be signed by the meter manufacturer's head of engineering for the applicable meter types in support of the statements and conclusions being made.

Note: MC reserves the right to review any specifications, procedures and test results attested by the manufacturing corporation for compliance with the legal requirements.

12.0 Policy review and expiry

No date has been set for the review or the expiry of this policy. However, it will be updated as hydrogen‑blending activities evolve in Canada, as the impact on these activities on regulated meters used for trade measurement becomes known as a result of test data analysis, and as new international requirements and standards are developed and implemented. MC will work closely with gas industry stakeholders at the time of a revision.

13.0 Revisions

Not applicable.

Footnotes

Footnote 1

As the definition of "meter" in the Act is broad enough, it can be any gas metering device (i.e. flowmeters, ancillary devices and associated measuring instruments), any function, system or installation.

Return to footnote 1 referrer

Footnote 2

Any measuring device for which a notice of approval has been issued, unless the measuring device is being used in an initiative or pilot project where the operating concentration of hydrogen is 5% or less by volume and a temporary permission has been grated by ELSD to use of the device after a review of evidence (e.g. a manufacturer's attestation).

Return to footnote 2 referrer

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