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Clarification of ICC Proposals Relating to Hydrogen and Scope
by David Johnston, Washington Gas and Karen Miller, National Hydrogen Association
The NHA has received a couple of inquiries relating to the May article in the Hydrogen Safety Report, ICC Public Hearings Demonstrate Support for Hydrogen Technologies. This article will attempt to clarify the status of the proposals discussed in the first article made to the International Fuel Gas Code (IFGC) Committee, and implications for those proposals moving forward.
First, I’d like to clarify that FG1-02 was not a proposal of the ICC Ad Hoc Hydrogen Committee (AHC). It is a proposal from David Johnston (co-author of this article) to clarify the scope of the International Fuel Gas Code. The purpose of FG1-02 is to fix a structural error in the scope section of the IFGC that makes application of the current scope of the code unclear. The proposal does not modify the current scope, which addresses only natural, LP gases and gas-air mixtures, but rearranges and restates these references to provide better clarity. No statement excluding hydrogen or any other actual or potential fuel gas is included in the proposal. The proposal was developed long before the inclusion of hydrogen became a controversial issue, and was done with the assistance of ICC staff who also recognize the present scope defect.
FG2-02, FG15-02, FG 41-02, and FG48-02 were hydrogen-specific proposals from the ICC AHC.
The IFGC Committee recommended approval of FG1-02, and disapproval of FG2-02, FG15-02, FG41-02, and FG48-02. In each of these cases, a floor action was taken whereby the opposite recommendations were made by the voting delegates on the floor. Both recommendations move on to the Final Action Hearings in Fort Worth, Texas September 29-October 4, 2002.
If the final action is consistent with the committee recommendations in each case, hydrogen will not be included in the IFGC. If the floor recommendations are ratified, hydrogen will be included in the next publication of the IFGC. But what happens if there is a mixed bag?
Where different proposals to modify the same section of the code are both passed, it is necessary and routine for ICC staff to merge the proposals into the section in a way that preserves the intent of both proposals as adopted. FG2-01, if passed, would add hydrogen to the scope. No single ICC proposal can unilaterally cancel the effect of another. If both FG1-02 and FG2-02 were to pass, the structural problem with the scope section would be fixed AND hydrogen would be added to the scope. Even if only FG1-02 passes, the scope would be fixed but still available for further amendment in the future. In this case, hydrogen would be left out of the IFGC in this round, resulting in a minimum 18-month delay in having hydrogen included in the IFGC.
Mr. Johnston and others are working closely with the ICC AHC to resolve technical issues and produce the most appropriate coverage for hydrogen. Stay tuned for the October issue of this report for the final action consideration results from Fort Worth.
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