0604gasinterchangeabilitystaffpaper PDF
0604gasinterchangeabilitystaffpaper PDF
0604gasinterchangeabilitystaffpaper PDF
Prepared for:
Prepared by:
Ted A. Williams
Director, Codes, Standards & Technical Support
American Gas Association
April 2006
Disclaimer
This report was prepared by American Gas Association (AGA) Staff for the
purpose of summarizing prior technical work, research, and technical application
of gas interchangeability principles and practices. Neither AGA, its members, nor
any person acting on behalf of these organizations:
• Assumes any liability with respect to the use of, or for damages resulting
from the use of, any information disclosed in this report.
2
Table of Contents
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35.
4
The objective of this Staff Paper is to discuss technical aspects of gas
interchangeability including its meaning, the objective of gas interchangeability
criteria, combustion issues and failure modes associated with non-
interchangeable gases, technical history and background, use of indices as
metrics, examples of interchangeability requirements in other countries as of this
writing, and criteria for acceptability. Because of the wealth of technical
documentation of gas interchangeability science and applications, references to
important work are provided, and descriptions of these studies are not provided
here in most cases. Emphasis is placed upon domestic appliances because,
despite the large customer class using these devices and the wealth of
information available on testing and gas interchangeability studies on them,
recent debate over impacts upon appliance function and residential consumers
may not be receiving equitable consideration, in the authors opinion. This Staff
Paper does not address issues of gas composition as it relates to potential
issues of U. S. gas supply, distribution of costs that may be associated with
bringing interchangeable gases to market, the diversity of end uses and potential
inconsistencies of gas interchangeability requirements among end uses, or
issues of implementation and policy associated with gas interchangeability
criteria and requirements.
In 2004, the Natural Gas Council (NGC), a coalition of natural gas trade
associations composed of the Interstate Natural Gas Association of America
(INGAA), the Natural Gas Supply Association (NGSA), the Process Gas
Consumers Group (PGCG), and AGA, recognized the need for the U. S. natural
gas industry and its customers to develop industry based recommendations for
addressing changes in gas composition brought on by changes in domestic gas
and anticipated LNG importation. The NGC recognized the need to expand
participation on issues of gas quality, including gas interchangeability, to other
stakeholders concerned with gas supply, transportation, and end use. This
expanded ad hoc group was convened in 2004 as "NGC+." The Gas
Interchangeability Task Group was organized by NGC+ representing over 40
stakeholder organizations including gas producers, pipelines, local distribution
companies (LDCs), end use equipment manufacturers, trade associations, and
regulators. In development of its "White Paper on Natural Gas Interchangeability
and Non-Combustion End Use," the Task Group developed the following
definition of gas interchangeability:
1
Gas Interchangeability Task Group. White Paper on Natural Gas Interchangeability and Non-
Combustion End Use. Natural Gas Council Interchangeability Task Group, 2005, p. 3.
5
1.2 Historical Definitions from the Gas Industry Literature
Prior to the NGC+ work, the LDC industry had developed a variety of
definitions of gas interchangeability as part of its seven decades of work in this
area (i.e., beginning formally in the 1930s). The following are examples of these
definitions, which are different but consistent:
• Suppliers must furnish a fuel gas that burns safely and performs
adequately in the appliances and equipment connected to their lines.
Thus, as fuel gases become more varied and maintaining a uniform product
becomes increasingly difficult or impossible, the definition of acceptable
variations in the composition of the gas becomes more vital. A responsive
change is now taking place in the was the gas industry looks at
interchangeability."3
2
American Gas Association. Gas Engineers Handbook. Segler, C. George, Editor-in-Chief, The
Industrial Press: New York, NY, 1965. p. 12/239.
3
American Gas Association. Utilization, Volume V: Gas Engineering and Operating Pracitce,
Book U-1 Residential/Commercial, American Gas Association: Arlington, VA, 1994, p. 24.
6
"…for a substitute gas to be interchangeable with the base gas, the base
settings of primary air and gas input rate must be within the flame limits of
the substitute gas."4
Gas interchangeability criteria emerged in the early days of the natural gas
industry as a means of avoiding end use combustion problems before they
occurred in widespread fashion in the field. Specific statements of the need for
gas interchangeability criteria are rare in the early industry literature, probably
because of the obvious importance addressing the suitability of gases before
they were introduced as substitutes for other supplies and the need to avoid
problems in the field. Two statements were offered in 1946 that suggest this:
and
Concerns of the gas industry to questions about gas supply and end use can be
traced to a number of aspects of the early gas industry. However, the presence
of significant concentrations of carbon monoxide (CO) in manufactured or "town
4
American Gas Association. Gas Engineers Handbook. Segler, C. George, Editor-in-Chief, The
Industrial Press: New York, NY, 1965. p. 12/239.
5
American Gas Association Laboratories, Interchangeability of Other Fuel Gases with Natural
Gases, Research Bulletin Number 36. AGA Committee on Mixed Gas Research, Joint
Committee of Natural Gas Department and Technical Section, American Gas Association :
Cleveland, Ohio, 1946, p. 2.
7
gas" and poisoning incidents from unburned gas undoubtedly contributed to
these concerns as well as the need to better understand and anticipate problems
of end use before they occurred.
8
While gas interchangeability can be determined for any combustion-
related end use, historical focus of interchangeability studies have focused
almost exclusively on appliances and equipment comprising residential and light
commercial end uses. As discussed in Section 5, historical U. S. testing data
covers several thousand appliances and appliance-type gas burners. While no
limitation exists for conducting similar tests on industrial burners and gas
turbines, the U. S. gas industry emphasized appliance applications for several
reasons:
6
U. S. Department of Energy, Energy Information Administration , "Natural Gas Statistics for
2004," http://tonto.eia.doe.gov/dnav/ng/.
7
American Gas Association. Utilization, Volume V: Gas Engineering and Operating Pracitce,
Book U-1 Residential/Commercial, American Gas Association: Arlington, VA, 1994, p. 28.
9
Questar discussed in the Gas Interchangeability White Paper summarizes
unique issues and challenges of such programs to accommodate a
monotonic change in gas supply.8
8
Gas Interchangeability Task Group. White Paper on Natural Gas Interchangeability and Non-
Combustion End Use, Appendix D. Natural Gas Council Interchangeability Task Group, 2005,
pp. 27-30.
9
Op cit, p. 29.
10
Rana, H., and Johnston, D. "An Empirical Approach to Evaluating Gas Interchangeabiiity,"
2003 AGA Operations Conference Paper, 03-OP-41, May 2003.
10
Some makes and models of equipment many not be able to cope with a
change in fuel gas."11
The last point listed above suggests a number of issues with respect to
changes in appliance technology and the robustness of past gas
interchangeability testing. Recently, increasing attention has been given to
concerns over more advanced end use burner technologies designed for higher
combustion efficiencies and lower atmospheric emissions, specifically oxides of
nitrogen (NOx). Arguments have been put forward that the current data base on
so-called "legacy appliances" does not represent these technologies adequately.
While this may be true, per se, it does not dismiss the relevance of the existing
published gas interchangeability research. This research, which focuses on
conventional "atmospheric" or Bunsen-type burners used in appliances, is
generally applicable to the vast majority of burners used in the U. S. gas
appliance stock.
Features of appliances other than general burner design may have even
more importance to gas interchangeability. These include, but are not limited to,
the following:
• Burner material
• Safety
• Reliability of Performance
12
"28th Annual Portrait of the U. S. Appliance Industry," Appliance, September 2005, p. 7.
12
3.2 Combustion Failure Modes
13
Figure 1. Bunsen Burner Example.13
13
American Gas Association Laboratories. Fundamentals of Gas Combustion, Revised.
Prepared for American Gas Association and Gas Appliance Manufacturers Association, 1996, p.
20.
14
Ibid, p. 29.
14
Complete combustion that results from primary aeration and full
secondary aeration to its complete stoichiometric end products is shown in
Equation 1 for methane:
The formation of unstable hydroxyl (OH) radicals (not shown for simplicity)
facilitates this sequence through the formation of CO in the inner reaction zone of
these flames. Subsequently CO is recombined in the outer reaction zone to
complete combustion to CO2.
The last of these factors can be a first order impact of introducing non-
interchangeable fuels. However, other flame changes due to longer flame
15
Peeters,J. and Mahnen,G., "Reaction Mechanisms and Rate Constants of Elementary Steps in
Methane-Oxygen Flames," Fourteenth Symposium (International) on Combustion, pp. 133-146,
1973.
16
Smoot, L., Hecker, W., and Williams, G., "Prediction of Propagating Methane-Air Flames,"
Combuston and Flame, Vol. 26, pp. 323-342, 1976.
17
Tsatsaronic, G., "Prediction of Propagating Laminar Flames in Methane, Oxygen, Nitrogen
Mixtures," Combustion and Flame, Vol. 33, pp. 217-239, 1978.
15
lengths and other altered shapes, contributing to the other three factors, may be
sources of increased frequency of incomplete combustion as well. In fact, and as
will be discussed later, specific design features of burners in combustion
chambers may have much to do with differences in gas interchangeability
performance of among appliances. However, historical data from
interchangeability tests suggests that these effects are second order impacts on
CO generation.
The Levinsky paper provides the most current and complete discussion of
practical issues of appliance sooting.
18
Levinsky, H. "Report of 'Identification of the Concentration and Combination of Higher
Hydrocarbons in Natural Gas Likely to Cause Sooting in Gas Appliances," Report to the
Department of Trade and Industry, United Kingdom, p. 3, 2005.
16
not be obvious where soot is not visible or obvious, and fouling may occur in
areas of the appliance not readily detected by the consumer.
Yellow tipping as well as other flame behaviors are used to both diagnose
appliance operational problems and for empirical research on performance and
interchangeability. In fact, the gas interchangeability indices discussed later in
this paper, for the most part, associate gas compositions and properties with
these directly observable behaviors. Gas utility training and service
organizations have, for many years, emphasized identifying abnormal flame
behaviors including flame lifting, flash back, and yellow tipping and adjustment to
proper appearance as part of training of service personnel. Training has
included use of training media including slide presentations, videos, and printed
materials. One established objective source for visual interpretation of normal
and abnormal flame behaviors, published in 1950, is the AGA Flame Code
classification method19 represented in Table 1 and recently applied in
interchangeability studies by GTI.20
+5 Flames lifting from ports with no flame on 25% or more of the ports
+4 Flames tend to lift from ports, but become stable after short period of operation
+3 Short inner cone, flames may be noisy
+2 Inner cones distinct and pointed
+1 Inner cones and tips distinct
0 Inner cones rounded, soft tips
-1 Inner cones visible, very soft tips
-2 Faint inner cones
-3 Inner cones broken at top, lazy wavering flames
-4 Slight yellow streaming in the outer mantles, or yellow fringes on tops of inner cones.
Flames deposit no soot on impingement
-5 Distinct yellow in outer mantles or large volumes of luminous yellow tips on inner
cones. Flames deposit soot on impingement.
19
Interchangeability of Various Fuel Gases with Manufactured Gases, AGA Research Bulletin
No. 60, American Gas Association Laboratories, 1950.
20
Gas Interchangeability Tests: Evaluating the Range of Interchangeability of Vaporized LNG
and Natural Gas, Final Report, Gas Technology Institute, April 2003.
17
Another source depicting normal and abnormal flames with color
photography is a U. S. Environmental Protection Agency publication, “Guidelines
for Adjustment of Atmospheric Gas Burners for Residential and Commercial
Space Heating and Water Heating,” published in 1979.21 While burner
adjustment to flame appearance depends upon subjective interpretation of
installers, service technicians, and even gas interchangeability researchers,
relatively consistent performance in terms of more objective criteria (e.g.,
calculated air-free CO emissions based on CO measurements in combustion
products) is generally achieved.
21
Guidelines for Adjustment of Atmospheric Gas Burners for Residential and Commercial Space Heating
and Water Heating, U. S. Environmental Protection Agency, February 1979, EPA-600/8-79-005.
22
Gas Interchangeability Task Group. White Paper on Natural Gas Interchangeability and Non-
Combustion End Use, Appendix C. Natural Gas Council Interchangeability Task Group, 2005,
pp. 66-77.
18
appliances produced inconsistent results for the NO2 fraction of total NOX. In
some appliances, the rise was dominated by NO, a highly reactive species that
interacts with building elements and quickly decays. In other appliances,
included unvented appliances, NO2 dominated the increase.23
Btu/scf
W = Eq. 3.
(specific gravity)0.5
The heat rate at the burner is more properly expressed as the Wobbe number
alone. For a given volumetric throughput adjustment, the appliance heat rate will
change proportionally by the change in the Wobbe number of the fuel supply
alone. Interchangeability issues are associated, at the appliance level, with such
a fuel change and absent any modification of the volumetric flow rate or burner
orifices.
The impact of such changes in appliance heat rate may be significant and
may exceed "overfire" limits specified in the Z21/83 design standards. Such
overfiring may lead to appliance problems.
23
Williams, T. Assessment of Changes to the Performance of Gas Appliances in Relation to
Variations in Gas Quality, prepared for Department of Trade and Industry, URN 05/1938, October
2005, pp. 66-77.
19
3.2.2.2 Jacket/Vent Overheating and Fire Hazards. Surface
temperature limits are imposed on appliances through the Z21/83 standards and
are accompanied, where needed, by clearance minimums from combustible
materials. Higher appliance throughputs from overfiring may lead to the
exceeding of these limits, and clearance requirements may no longer be
sufficient. Such high temperatures may pose consumer hazards from touching
hot surfaces or, at an extreme, lead to fire hazards.
3.2.3.1 Flame Lifting. Flame lifting is due to the burner flame front
leaving the burner head leading to inherent instability, or the ability to stay lit, and
changes in the temperature profile affecting heated surfaces. Lifting of the flame
front is fundamentally due to the burning rate decreasing below the flow rate
through the burner, and may be due to overly high burner port loadings and
overly rich mixtures at the burner head, too much primary air (overly lean)
conditions, or high levels of inerts in the fuel gas. Lifting flames may produce
excessive levels of CO.
24
Williams, T. Assessment of Changes to the Performance of Gas Appliances in Relation to
Variations in Gas Quality, prepared for Department of Trade and Industry, URN 05/1938, October
2005, p. 87.
20
3.2.3.2 Flashback. An early flame behavior covered in gas
interchangeability studies, flashback was mainly a behavior associated with
concentrations of hydrogen in fuel gases. Hydrogen's high burning rate in the
fuel gas mixture could facilitate moving the flame front from the burner heat
upstream into the burner body and tubing. Flame pulsation is a common
behavior associated with flashback. Hydrogen as a fuel gas constituent was an
issue when manufactured gas represented a significant portion of local gas
supplies. With the transition to natural gas in the U. S. system and the relative
absence of hydrogen from natural gas, this concerned lessened. In rare
instances, flashback can occur when a partial premixed burner is maladjusted to
an overly lean condition and stoichiometric combustion mixtures are achieve
through primary aeration.
25
Ibid, pp. ii, 75-76.
21
U. S. requirements for installation are embedded in design standard
requirements, installation codes, and manufacturers installation instructions.
Maintenance of residential combustion appliances is not required for private
homes, although product information and public service information promotes
annual service and adjustment. Appendix C of the Gas Interchangeability White
Paper lists detailed considerations for the installation and operation of residential
combustion appliances.26 The prevailing situation in the U. S. cannot support
extensive field adjustment, including checking firing rate, for U. S. residential
appliance, assuming that targets for adjustment could be agreed to. Current
service infrastructure limitations and costs of contractor labor to implement a
major program in this area are likely to be prohibitive. The field situation as
assessed by U. K. Department of Trade and Industry, discussed below, holds
important potential parallels to the options facing the U. S.
26
Gas Interchangeability Task Group. White Paper on Natural Gas Interchangeability and Non-
Combustion End Use, Appendix C. Natural Gas Council Interchangeability Task Group, 2005,
pp. 35-38.
22
While appliance design standards differ for vented and unvented
appliances, all Z21 design certified residential appliances incorporate
requirements addressing performance safety, including air free CO limits. Some
outside of the gas utility industry have commented that CO emissions from
vented appliances do not represent consumer risks comparable to unvented
appliances. However, in practice, vented appliances generally receive the same
scruitiny as unvented appliances in terms of emissions performance.
Several factors lead to this response.
• Vented appliances, due to their generally higher input rates than unvented
appliances and their usage patterns, require scrutiny for combustion
malfunction under a condition of venting system failure.
First, the appliance tests comprising the data base used for derivation of
gas interchangeability indices and evaluation of appliance populations is
extensive and covers thousands of data points. The following table from the
27
American Gas Association. Gas Engineers Handbook. Segler, C. George, Editor-in-Chief, The
Industrial Press: New York, NY, 1965. pp. 12/239-12/252.
28
American Gas Association Laboratories, Interchangeability of Other Fuel Gases with Natural
Gases, Research Bulletin Number 36. AGA Committee on Mixed Gas Research, Joint
Committee of Natural Gas Department and Technical Section, American Gas Association :
Cleveland, Ohio, 1946.
29
American Gas Association. Interchangeability: What It Means. Operating Section Topical
Technology Report, May 1978, pp 24-26 (from Weaver,1951).
30
American Gas Association. Utilization, Volume V: Gas Engineering and Operating Pracitce,
Book U-1 Residential/Commercial, American Gas Association: Arlington, VA, 1994, pp. 23-67.
31
Halchuk-Harrington, R. and Wilson, R. "AGA Bulletin #36 and Weaver Interchangeability
Methods: Yesterday's Research and Today's Challenges," AGA Operations Conference Paper
(not yet published), May 2006.
23
Halchuk-Harrington and Wilson paper is illustrative and does not include a
number of industry studies that apply gas interchangeability techniques.
Second, while the data covers many older appliances, very few of the
appliances tested are completely out of the U. S. appliance stock. As a result,
generalizations based on appliance type remain valid to support the use of the
current indices, if not the specific index limits proposed by the studies
themselves. However, within appliance types, specific design and construction
changes may make the historical studies less general to the current appliance
stock. In addition, most of these changes may make today's appliances more
sensitive to gas compositional changes. Such changes include:
Trends that may reduce sensitivity tend to require active combustion controls,
such as on modern instantaneous gas water heaters, but such controls are not
common in appliance design and appliances so equipped are not common in the
U. S. appliance stock.
32
Ibid, p. 3.
24
Third, researchers have been almost uniformly conservative in
extrapolating appliance test results to appliance populations outside of their test
program. Weaver, for example, cautions the users of his work to avoid overly
broad generalizations based on his results.33 Likewise, interchangeability studies
addressing specific interchangeability questions, such as importation of LNG into
Northeastern U. S. markets, have avoided suggestions of extending index limits
for interchangeability to other markets and even other nearby service territories.
33
Weaver, E. "Formulas and Graphs of Representing the Interchangeability of Fuel Gases,"
Journal of Research of the National Bureau of Standards, Vol. 46, No. 3, March 1951, pp. D321-
D322.
34
Reuther, J. Critique of ANSI Z21.1 Standard for CO Emissions From Gas-Fired Ovens and
Ranges, Gas Research Institute, September 1996, pp. 11-17.
25
that results are applicable to operation and over time. For example,
testing appliances on LNG vapor as assayed at liquefaction or the import
terminal may not give sufficient information on how the appliance would
operate on the same gas source following weathering of the liquid product.
Currently, three of these indices are used in the U. S. and are likely to
continue to be used in the near future:
• Wobbe Index
Both the AGA and Weaver indices were formulated to account for observed
atmospheric burner behaviors not directly addressed by the simpler Wobbe
index. These behaviors could be observed by field technicians as well as
researchers, making the resulting indices practical for use based on observation
of flame characteristics. The AGA and Weaver indices are fundamentally
empirical in their derivation and application to combustion appliances. The
Wobbe Index is extended to appliances based more on its theoretical
underpinnings. A more extensive critique of simple methods was offered in 1978
35
Halchuk-Harrington, R. and Wilson, R. "AGA Bulletin #36 and Weaver Interchangeability
Methods: Yesterday's Research and Today's Challenges," AGA Operations Conference Paper
(not yet published), May 2006.
26
and is documented in the report, "Interchangeability: What it Means."36
However, all three indices require the setting of index limits in practical
application. These limits are based on observed behaviors and may vary among
studies. Potential reasons for this variation are discussed below.
The Wobbe Index has its origins in the 1920's with Italian physicist
Goffredo Wobbe.37 English translations of Wobbe's original work are rare, but
his work was quickly adopted by practical combustion investigators because of
the index's simplicity and intuitive reasonableness. In concept, the Wobbe Index
captures not only the volumetric energy value of the gas but also the ability of
that gas to be delivered to a burner as a function of its density. It, therefore,
describes the "heat rate" to the burner provided by the gas. As the Gas
Interchangeability White Paper states, the Wobbe Index is the most efficient and
robust interchangeability parameter for describing gases for the widest range of
end uses.38 Wobbe Index limits are used in conjunction with the AGA and
Weaver indices, in the case of the Weaver Heat Rate Ratio, JH (itself a Wobbe
Ratio) making up a portion of the overall index.
36
American Gas Association, Interchangeability: What It Means," Operating Section Topical
Technology Report, May 1978, pp. 1-2.
37
Wobbe, G. "A New Definition of the Quality of Gas," Ind. Gas Acquedolli, 1926.
38
Gas Interchangeability Task Group. White Paper on Natural Gas Interchangeability and Non-
Combustion End Use,. Natural Gas Council Interchangeability Task Group, 2005, p. 18.
39
Gas Interchangeability Task Group. White Paper on Natural Gas Interchangeability and Non-
Combustion End Use, Appendix D. Natural Gas Council Interchangeability Task Group, 2005,
pp. 1-6.
27
However, the White Paper and other sources point out that changes in
gas supply Wobbe Numbers alone do not account for changes in gas
combustion. Other, secondary effects are important to explain the changes in
combustion. In the case of efforts to develop more complete descriptions such
as the AGA and Weaver indices, these secondary effects are address directly
through empirical descriptions and index limits. In cases where Wobbe based
limits are retained, supplemental criteria are used. For example, the Interim
Guidelines for gas interchangeability proposed by the White Paper use Btu limits
on the gas to capture behaviors that would be more precisely calculated by the
more complex indices, specifically the Weaver Incomplete Combustion Index, JI,
which was shown to be the most sensitive index within the Weaver system.40
Use of factors such as a Btu limit in the case of the Interim Guidelines avoids the
need to calculate the full Weaver Index values and the need to specify an
adjustment gas, which in the case of applying the Interim Guidelines would have
been impractical. An alternative of tightening the Wobbe Index limits might
exclude the gases shown to be unacceptable using the Weaver Index, but it
would likely exclude a number of other gases that would be otherwise
acceptable. Therefore, using supplemental criteria to account for secondary
effects may help to maintain supply options.
40
Gas Interchangeability Task Group. White Paper on Natural Gas Interchangeability and Non-
Combustion End Use, Appendix G. Natural Gas Council Interchangeability Task Group, 2005.
28
appliance populations. However, in the development of the Interim Guidelines,
this was not found to be an insurmountable problem, and it was addressed by
incorporating local historical Wobbe Numbers as the basis for defining ranges of
interchangeable gases.
These are just some of the issues associated with use of gas
interchangeability indices in the U. S. Similar questions have arisen in the U. K.,
which uses the Dutton diagram as a fundamental tool of describing gas
interchangeability.41 This graphical approach to describing interchangeability
limits uses Wobbe Index in conjunction with the Incomplete Combustion Factor
(ICF) and Sooting Index (SI) to bracket gases in a manner similar to the Interim
guidelines. While derivation of the limits is done differently (e.g., the U. S. does
not use the SI parameter), the results in the U. K are surprisingly similar to those
resulting from the Interim Guidelines when similar adjustment gases are used.
41
Dutton, B, "A New Dimension to Gas Interchangeability, The Institute of Gas Engineers, 50th
Annual Meeting, November 1984.
42
Ho. B. "Gas Interchangeability/Quality Management & Their Impact on Technology," presented
at Platts Gas Interchangeability and Gas Quality Forum, Houston, TX, November 2005.
29
7.2 Current U. K. Activities
DTI is recommending "no change" from the U. K.'s current gas quality
specifications for imported gas, which includes a Wobbe range of 47.2 to 51.41
MJ/m3 (~1,267 to 1,380 Btu/scf) representing a range of +/- 4.3% of the midpoint
Wobbe. These specifications are currently in the U. K. Gas Safety Management
Regulations (GS(M)R) administered by the Health and Safety Executive and are
augmented by additional limits on incomplete combustion factor (ICF), an index
for carbon monoxide generation, and soot index (SI). These Wobbe limits,
including consideration of carbon monoxide (CO) generation in the ICF and
sooting, are consistent with the NGC Interim Guidelines with respect to
implications for gas suppliers even while they appear to be numerically
somewhat more conservative than the Interim Guidelines.
While gradations between the "change" and "no change" options can be
developed, DTI recognizes that, with respect to the near term, natural turnover of
appliances and the assumption of availability of new and more robust appliances
would not control for uncertainty of "at-risk" appliances remaining in the stock.
As a result, the benefits of intermediate policies between the "change" and "no
change" are, themselves, uncertain. The time scale for the DTI "no change"
30
approach (i.e., no change before 2020) allows for more comprehensive
approaches and appliance development to take place so that end use needs
could be matched with supplies.
The full record of DTI policy documents and research reports is available
through its website:
http://www.dti.gov.uk/energy/domestic_markets/gas_market/gas_quality.shtml
43
Weaver, E. "Formulas and Graphs of Representing the Interchangeability of Fuel Gases,"
Journal of Research of the National Bureau of Standards, Vol. 46, No. 3, March 1951, pp. D315-
D322.
32
emissions measurements in comparison with the Z21/83 design standard limits
as part of its qualification of low income housing appliances.44
While the following issues are beyond the scope of this document,
comments are offered based on recent work in gas interchangeability and public
policies regarding introduction of new supplies.
44
Joint Motion of Pacific Gas and Electric Company, San Diego Gas & Electric Company and
Southern California Gas Company Requesting Commission Approval of Proposed Settlement
Establishing Uniform Low Income Energy Efficiency Gas Appliance Flue Testing Carbon
Monoxide Threshold Levels, presented to California Public Utilities Commission, November 2004.
45
Reuther, J. Critique of ANSI Z21.1 Standard for CO Emissions From Gas-Fired Ovens and
Ranges, Gas Research Institute, September 1996.
46
Gas Interchangeability Task Group. White Paper on Natural Gas Interchangeability and Non-
Combustion End Use, Appendix D. Natural Gas Council Interchangeability Task Group, 2005,
pp. 27-30
33
immense.47 Equity refers to the allocation of costs of a specific alternative.
Allocation may be divided among stakeholders receiving new supply or other
formulae. Such an approach has been proposed in a recent case in Florida.48
47
Department of Trade and Industry. Partial Regulatory Impact Assessment, URN 05/1903,
December 2005.
48
Federal Energy Regulatory Commission Trial Staff, Initial Brief of the Commission Trial Staff,
AES Ocean Express, LLC v. Florida Gas Transmission Company, Docket No. RP04-249-001,
January 26, 2006.
49
Department of Trade and Industry. Partial Regulatory Impact Assessment, URN 05/1903,
December 2005, pp. 14-17, 18-20.
34
References
The following references were used in development of this report and are
cited, but they do not represent an exhaustive listing of relevant gas industry or
other literature on gas interchangeability:
35
Halchuk-Harrington, R. and Wilson, R. "AGA Bulletin #36 and Weaver
Interchangeability Methods: Yesterday's Research and Today's Challenges," AGA
Operations Conference Paper (not yet published), May 2006.
Joint Motion of Pacific Gas and Electric Company, San Diego Gas & Electric
Company and Southern California Gas Company Requesting Commission Approval of
Proposed Settlement Establishing Uniform Low Income Energy Efficiency Gas Appliance
Flue Testing Carbon Monoxide Threshold Levels, presented to California Public Utilities
Commission, November 2004.
Smoot, L., Hecker, W., and Williams, G., "Prediction of Propagating Methane-Air
Flames," Combuston and Flame, Vol. 26, pp. 323-342, 1976.
Wobbe, G. "A New Definition of Gas Quality," Ind. Gas Acquedolli, 1926.
36