Natural Gas Measurement Technical Standards Regulations, 2019

At Josh and Mak International, we are dedicated to providing comprehensive legal advice on regulatory standards within the energy sector. This article provides an in-depth overview of the Natural Gas Measurement (Technical Standards) Regulations, 2019. These regulations, issued by the Oil and Gas Regulatory Authority (OGRA), are crucial for ensuring accurate and reliable measurement of natural gas in transmission, distribution, and sale activities in Pakistan.

Scope and Applicability

The Natural Gas Measurement Technical Standards Regulations, 2019, are designed to ensure the accuracy, consistency, and reliability of gas measurement across the entire natural gas supply chain. These regulations apply to all licensees engaged in the regulated activities of natural gas transmission, distribution, and sale.

Key Provisions of the Regulations

1. Short Title and Commencement

• These regulations are cited as the OGRA Natural Gas Measurement (Technical Standards) Regulations, 2019, and they came into force immediately upon their publication.

2. Applicability

• The regulations apply to all licensees undertaking the regulated activities of transmission, distribution, and sale of natural gas. Compliance with these standards is mandatory for ensuring the accuracy of gas measurement.

3. Definitions

• The regulations define critical terms, such as:
  • Accuracy of Meter: The degree to which a meter correctly measures the volume of gas, determined by comparing the volume registered by the meter with a prover.
  • Calibration: Procedures that establish the accuracy of a measuring device by comparing it to a calibration instrument with traceable accuracy.
  • Correct Meter: A meter that measures natural gas with an accuracy of ±2% or other determined accuracy.
  • Prover: A device used for measuring the accuracy of gas meter registration.

4. Compliance Compulsory

• All licensees must comply with the prescribed technical standards. The Authority, in consultation with licensees, may review and alter these standards as necessary.

5. Accuracy of Gas Meters

• Licensees must ensure that gas meters installed in their systems and at consumers’ premises measure accurately. Diaphragm and rotary gas meters must measure within ±2% accuracy.

6. Initial Verification of New Gas Meters

• The accuracy of new gas meters must be verified before field use, based on sampling frequencies:
  • 100% verification for meters with a minimum capacity of 900 cubic feet per hour (Ft³/Hr) and above.
  • 10% verification for meters with a capacity between 400 and 899 Ft³/Hr.
  • 1% verification for meters with a maximum capacity of 399 Ft³/Hr and below.

7. Periodical Reverification of Gas Meters

• Meters must be periodically reverified for accuracy:
  • Every 15 years for domestic consumer meters.
  • Every 5 years for commercial consumer meters.
  • Every 2 years for industrial and other categories of consumer meters.

8. General Instructions on Inspection of Gas Meters

• The Authority can require calibration/proving of a meter at any time.
• Authorized persons may witness inspections, including initial and periodic accuracy verifications.
• Licensees must record and keep data related to all meter tests for two years.
• Maintenance history for meters with a capacity of 900 Ft³/Hr and above should be kept for five years after they are no longer operational.

9. Accuracy of Provers and Calibration Equipment

• Provers and calibration instruments must be tested for accuracy before initial use, after repairs, and periodically:
  • Portable and stationary provers every three years.
  • Calibration instruments annually.
  • Master meters annually.
  • Other measurement devices, such as pressure gauges and flow computers, have specific calibration frequencies.

10. Applicable Standards for Provers and Calibration Instruments

• Installation, testing, operation, maintenance, and calibration of provers must follow American Gas Association (AGA) standards.

11. Applicable Standards for Different Metering Systems

• Orifice Metering Systems: Must comply with AGA standards for design, installation, and operation.
• Gas Turbine Metering: Installation, calibration, and maintenance must follow AGA standards.
• Diaphragm and Rotary Metering Systems: Must adhere to ANSI and AGA standards.
• Ultrasonic Metering Systems: Must follow AGA Report No. 9 standards.
• Correction for Deviations: Computation of compressibility factors must follow AGA standards.

12. Other Applicable Standards

• Chart Recorders and Fixed Pressure Factor Metering: Must comply with AGA standards.
• Electronic Devices: Installation and calibration must adhere to AGA standards.
• Design of Meter and Regulator Stations: Must follow AGA recommendations for noise abatement and flow control.
• Measurement of Gas Properties: Must adhere to AGA, GPA, or ASTM standards.
• Meter Repair and Selection: Must follow AGA standards.

Legal and Operational Implications

Compliance:

• Adherence to these standards is mandatory. Non-compliance can result in legal and financial penalties and disrupt gas measurement accuracy and reliability.

Accuracy and Reliability:

• The regulations ensure the accuracy of gas measurement, essential for fair billing and operational efficiency. Regular calibration and verification reduce errors and enhance trust in gas measurements.

Safety and Risk Management:

• By following these technical standards, licensees can mitigate risks associated with inaccurate gas measurements, which can lead to safety hazards and financial losses.

Data Management:

• Licensees must maintain detailed records of all meter tests and calibrations, ensuring traceability and accountability.

International Standards:

• The regulations align with international standards (e.g., AGA, ANSI), facilitating global best practices in gas measurement.

Critical Analysis of the Natural Gas Measurement Technical Standards Regulations, 2019

While the Natural Gas Measurement Technical Standards Regulations, 2019, provide a comprehensive framework for ensuring the accuracy and reliability of gas measurement, several areas require critical examination. This analysis highlights potential deficiencies and areas for improvement in the regulations.

Identified Deficiencies

Complexity and Implementation Challenges The regulations are highly technical and detailed, which can present significant implementation challenges for licensees, particularly smaller companies or those with limited technical expertise. The complexity of the standards may require extensive training and investment in specialized equipment, which could be burdensome for some licensees.

Ambiguity in Definitions and Standards While the regulations provide definitions for key terms, some areas remain ambiguous or lack specificity. For example:

• The term “Correct Meter” is defined as having an accuracy of ±2%, but the regulations allow for the Authority to determine different accuracies for different meter types. This flexibility can lead to inconsistencies and confusion about the acceptable accuracy standards for various meters.
• The procedures for “Calibration” and “Proving” could benefit from more detailed guidelines to ensure uniform application across the industry.

Frequency of Reverification The schedule for periodic reverification of gas meters may not be stringent enough to ensure ongoing accuracy. For instance:

• Meters at domestic premises are required to be reverified only once every 15 years, which is a long interval given the potential for wear and tear. More frequent reverification could improve accuracy and reliability.
• Similarly, the five-year interval for commercial meters and the two-year interval for industrial meters might need to be reassessed to ensure they remain accurate throughout their operational life.

Lack of Specific Penalties for Non-Compliance The regulations mandate compliance but do not specify clear penalties for non-compliance. This lack of enforcement mechanisms can undermine the effectiveness of the standards. Clear, defined penalties for failing to adhere to the technical standards would enhance compliance and accountability.

Inadequate Provisions for Technological Advancements The regulations are based on existing technologies and standards but do not sufficiently address the rapid advancements in gas measurement technologies. Incorporating provisions for regularly updating the standards to reflect technological advancements would ensure that the regulations remain relevant and effective.

Data Management and Record-Keeping While the regulations require licensees to maintain records of meter tests and calibrations, the specified durations for keeping these records might not be adequate for all regulatory or operational needs. For example:

• The requirement to keep data for only two years after a meter is tested or no longer operational may not be sufficient for long-term auditing and compliance verification. Extending the record-keeping duration could improve transparency and accountability.

Insufficient Guidelines for Field Calibration The regulations mention field calibration of measuring devices but do not provide detailed guidelines on how to perform these calibrations under various operational conditions. More explicit instructions and best practices for field calibration would ensure consistency and accuracy across different environments.

Regulatory Oversight and Flexibility The regulations allow the Authority to review and alter standards in consultation with licensees, but this process might lack transparency and consistency. Establishing a clear, transparent process for reviewing and updating standards, with input from all stakeholders, would enhance the credibility and effectiveness of the regulations.

Emergency and Contingency Provisions The regulations do not sufficiently address procedures for handling emergencies or unexpected failures of measurement devices. Including specific provisions for emergency response and contingency planning would ensure that licensees are better prepared to manage and mitigate the impact of unforeseen events on gas measurement accuracy.

Conclusion

While the Natural Gas Measurement Technical Standards Regulations, 2019, provide a comprehensive framework for ensuring accurate gas measurement, addressing the identified deficiencies could enhance their effectiveness and practicality. Simplifying the implementation process, clarifying definitions, increasing the frequency of reverification, specifying penalties for non-compliance, accommodating technological advancements, and improving data management and emergency provisions would contribute to a more robust regulatory environment. At Josh and Mak International, we are committed to assisting our clients in navigating these regulations and advocating for continuous improvements. For detailed advice and support, please contact our expert team at [email protected]