ANRE has drawn up and proposed for debate a Draft Order amending the Regulation for metering traded gas no. 62/2008, through which it wants to change only one figure. The minimum methane content of natural gas delivered to be 85% instead of the current level of 70%. As of 2008, the sale of natural gas in Romania is made in kWh energy units, which makes it mandatory to continuously determine the composition and correct energy contained depending on the components existing in gas. Given that in Romania and Europe gas is mainly used in combustion processes, the important parameters are the quantity of energy contained by natural gas and their relative density and the ratio of methane, ethane, propane and butane is less important. The methane quantity becomes important however in chemical processing, where a large methane composition increases significantly productivity in the chemical industry. The regulation for metering the gas quantities traded in Romania was drawn up in 2008 and subsequently numerous elements that needed improvement were signaled to ensure a correct metering of gas for its trading. In the 12 years of application of this Regulation, but especially over the past few years, there have been several amendment and improvement proposals submitted to ANRE by gas market participants. Several proposals have remained however without debate, although their objective was a fair metering of flows/energy of gas sold and the supply of quality gas. For example: correlating the value of the dew point of water vapors with the value provided in the Romanian national standard SR 3317/2015; optimizing the limit value of the dew point of water vapors to reduce the operating expenses of gas producers in Romania; the double standard for the dew point of hydrocarbons; harmonizing the limits of parameters of gas properties with those included in the best practices of European operators CBP 2005-001/01. While the elements reported in this Metering Regulation are not under discussion, there is a request from the representatives of the Hungarian gas industry and immediately a Draft Order is issued which changes a single figure, namely the concentration of methane in gas delivered (traded) on the territory of Romania or from Romania to EU countries (Hungary or Bulgaria) and sets without technical or economic arguments that this ratio should be at least 85% for methane. I analyzed the Hungarian standards on gas quality in Hungary, MSZ ISO 13686: 2013 and MSZ 1648: 2016 and there is no limit value provided for the methane content. The transmission operator FGSZ, through the annex to the transmission contract regarding gas specifications:
does not impose and makes no reference to the methane content in the composition of gas accepted in the Hungarian gas transmission system. Transgaz confirms through the annex to the interconnection agreement Romania-Hungary:
that a 70% methane content is acceptable for takeover in the Hungarian system. I conducted the same analysis for the other EU member country, Bulgaria, connected to the national gas transmission system in Romania through Giurgiu-Ruse and Negru Voda-Kardam points. For this direction as well, Transgaz confirms that the Bulgarian operator requires a minimum content of 70% methane in the composition of gas transported:
In ANRE’s explanatory memorandum supporting this change there is no reference to the economic impact of this legislative act. In Romania there are fields that do not continuously fulfill this requirement of permanently having gas with a methane content of over 85%, a requirement which is not a condition or recommendation in the European standards (see EN 16726 or EASEE CBP 2005), so these fields should not be closed or limited in gas deliveries when the methane level is below 85%. This means economic losses and a decrease in Romania’s gas production, with the increase in imports that lately have been made especially from Hungary. Moreover, a review of the Metering Regulation requested for over 3 years by Romanian companies could have been at least one complete and take into account the requirement mentioned above together with its influence on the other quality parameters under the Regulation affected by this change, but which remain in force. The explanatory memorandum of ANRE does not mention why it intends to make such change given that natural gas is sold depending on its energy value, which is proportional with the composition of gas. Maybe to save the domestic gas production in the neighboring country, where fields that produce gas with 55% methane and which co-mingled with gas with an 85% methane ratio would reach the required limit? Maybe to increase and secure the productivity of the petrochemical industry of the neighboring country? Maybe to increase gas import in Romania? Irrespective of the real reason why it proposes the amendment of the Regulation, this example shows again the defiant and unprofessional way of working procedures in ANRE, procedures that neglect through the proposed draft the total impact on gas producers and consumers in ROMANIA.
Translation from Romanian by Romaniascout.