DECISION PAPER
PROPOSED MODIFICATIONS TO
GAS SUPPLY CODE
24 OCT 2014
ENERGY MARKET AUTHORITY
991G Alexandra Road #02-29
Singapore 119975
www.ema.gov.sg
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Disclaimer:
The information in this document is subject to change and shall not be treated as
constituting any advice to any person. It does not in any way bind the Energy Market
Authority to grant any approval or official permission for any matter, including but not
limited to the grant of any exemption nor to the terms of any exemption. The Energy
Market Authority reserves the right to change its policies and/or to amend any
information in this document without prior notice. Persons who may be in doubt
about how the information in this document may affect them or their commercial
activities are advised to seek independent legal advice or any other professional
advice as they may deem appropriate. The Energy Market Authority shall not be
responsible or liable for any consequences (financial or otherwise) or any damage or
loss suffered, directly or indirectly, by any person resulting or arising from the use of
or reliance on any information in this document.
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1
Introduction
1.1
The Gas Supply Code sets out the obligations of gas licensees to comply with
the standards and procedures for the safe operation of the gas supply system.
1.2
The Gas Supply Code also describes the rights and obligations of the gas
licensees in respect of the conveyance of gas and provision of gas supply.
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Proposed Modifications
2.1
EMA had proposed modifications to the Gas Supply Code. The proposed
modifications require the gas licensees including Gas Transporter, Onshore
Receiving Facility Operators, LNG Terminal Operator, and Gas Shippers to
comply with the operating procedures established by the EMA in its capacity
as the Gas System Operator (GSO).
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Public Consultation
3.1
Pursuant to Clause 1.6 of the Gas Supply Code, EMA had sought written
representations on the proposed modifications to the Gas Supply Code on 14
Jul 2014. Written representations from ConocoPhillips Singapore Operations
Pte Ltd, Keppel Gas Pte Ltd and Sembcorp Gas Pte Ltd were received when
the consultation closed on 21 Aug 2014.
3.2
Appendices 1 and 2 set out the modifications to the Gas Supply Code (taking
into account the written representations) and EMA’s response to the written
representations respectively.
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4
EMA’s Decision
4.1
EMA has carefully considered the written representations from the
respondents and has decided to modify the Gas Supply Code as set out in
Appendix 1. The proposed Gas Supply Code modifications shall take effect
when the Gas Network Code is amended for EMA to take on the role as the
Gas System Operator (GSO).
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Appendix 1
Proposed Modifications to the Gas Supply Code
Modification
Ref. No.
GSC/2014/19
Clause
1.3
Original Text
New insertion
Modified Text
“System Stress” is the occurrence of any of the circumstances where the
operating state of the Transportation System falls outside its designed operating
range and the Gas System Operator (GSO) is of the reasonable opinion that:
(a) The safe and reliable conveyance of gas in Transportation System is at
risk;
(b) The maintenance of safe and reliable pressures in the Transportation
System is at risk; or
(c) There exist such other circumstances affecting the Transportation System
that would or is reasonably likely to constitute a gas emergency.
GSC/2014/20
12.5
New insertion
In the case where the Transportation System is entering or under system stress,
each of the gas transporter, onshore receiving facility operators, LNG terminal
operator and gas shippers shall comply with the relevant operating procedures
established by the Authority to return the Transportation System to its normal
operating condition.
Appendix 2
EMA’s Response to Written Representations
Modification
Ref. No.
GSC/2014/19
Clause
1.3
Written Representations
EMA’s Response
ConocoPhillips Singapore Operations Pte. Ltd
Need EMA's help to elaborate on the definition of:
(i) "designed operating range" and
(ii) the condition that is considered as "gas emergency"
An example of the operating state of the Transportation
System falling outside its designed operating range would be
when landing pressures (at the receiving point at Sembcorp
Gas’s Onshore Receiving Facility in the case of West Natuna
gas supply) falling below the Prescribed Security Limits
(currently set at 37.2barg for Network 1). Another example
would be when the gas quality is outside Singapore
Specifications at the Transmission Network Injection Point.
Generally, the Transportation System would be under “gas
emergency” when the security of supply of gas to consumers is
compromised, e.g. the activation of the Emergency Shutdown
Valve (ESDV) at the onshore receiving facility or at the LNG
terminal.
GSC/2014/20
12.5
While CSOP principally agree with the concept offered by
EMA which plan to take the GSO roles from Power Gas.
It will be very difficult to comment on this additional
clause 12.5 without having any information in regards to
the "relevant operating procedures". It would be helpful if
we could receive an overview (draft) of the expected
relevant operating procedures.
The gas transporter has published operating procedures in
respect of its GSO role such as the Injection Operating
Procedure which covers, inter alia, the treatment of noncompliant gas, and the Implementation of Curtailment
Procedure which covers, inter alia, the actions to be taken in a
System Stress situation.
These are some examples of the relevant operating
We also have an inquiry in regards to the following procedures. EMA will administer these operating procedures
Modification
Ref. No.
Clause
Written Representations
EMA’s Response
statement "with the relevant operating procedures after it takes over the GSO function. EMA will consult relevant
established by the Authority",
parties in the development of new operating procedures, or
modifications of the existing operating procedures before
(i) will the relevant operating procedure be signed by issuing them.
EMA and the Licensee?
(ii) will the Licensee be given the opportunity to comment
the draft of the relevant operating procedures?
GSC/2014/20
12.5
Sembcorp Gas Pte Ltd
SembGas notes the intent, however we have commercial
arrangements with our legacy End Users with regards to
the curtailment procedure arising from any Upstream
interruption in gas supply, whereby the autogens will be
curtailed first, instead of the gencos, which differs from
the Implementation of Curtailment Procedure (ICP) under
the GNC that is currently in place. We would like to
further discuss with EMA on the above.
GSC/2014/20
12.5
The System Stress Curtailment Plan for Network 1 shall
continue to be managed by the Sembcorp Gas for as long as
Network 1 remains independent of the rest of the natural gas
Transportation System and Sembcorp Gas the only Shipper in
Network 1.
EMA will have a further discussion with Sembcorp Gas on this
matter.
Keppel Gas Pte Ltd
We noted the insertion of “System Stress” in the Gas
Supply Code, is largely similar to the one found in
Section M, Gas Network Code (“GNC Definition”),
except that the “Transportation System” in the GNC
Definition is now replaced by “Gas Transmission
Network”.
We would like to clarify with EMA if “Gas
Transmission Network” is intended to refer to the
The Transportation System comprises both the
Transmission Network and the Distribution Network. EMA in
its capacity as the GSO shall direct operation of the
Transmission Network whereas the Distribution Network
shall continue to be operated by the gas transporter.
To avoid ambiguity, the definition of “System Stress” in the Gas
Supply Code is amended to cover the “Transportation System”
so that it is consistent with the definition in the Gas Network
Modification
Ref. No.
Clause
Written Representations
same defined term under
“Transmission Network”.
the
EMA’s Response
GNC,
i.e.
From the proposed wordings, “System Stress” only
apply to “Gas Transmission Network”, which is
dissimilar to the GNC’s definition of “System Stress”
that extends to the Distribution Networks.
The current proposal effectively introduces two
definitions of “System Stress”. Is it envisaged
that there be two different types of “System
Stress” response procedures arising from the
different definitions? If yes, could the EMA
provide more details on such changes?
For instance, different responses (depending on
whether it is initiated by the newly incorporated GSO,
or PowerGas) could be one of the intents of
differentiating the definitions.
Could the EMA clarify if the definition of “System
Stress” in the Gas Supply Code is intended to be
different from that in the Gas Network Code
(including the circumstances which give rise to
“System Stress”)?
For the benefit of Retailers who are serving
Distribution Network customers, in the event that
Distribution Networks enter into “operating states
which are out of the design operating range”, could
the EMA clarify which entity (PowerGas, or EMAPSOD) would be responsible for managing such
Code.
With regard to Keppel Gas’s suggestion to define the basis for
revising “design operating range”, such operational matters will
be addressed in the relevant operating procedures instead of
in the Gas Supply Code.
Modification
Ref. No.
Clause
Written Representations
EMA’s Response
gas emergencies, and what would the response
actions entail for such distribution network
offtakers? Or, is it envisaged that Distribution
Networks would not be declared to enter into
“System Stress”?
Response obligations arise from the “operating state
of the Gas Transmission Network fall(ing) outside its
designed operating range”.
Currently, although significant responsibilities arise
from “design operating range”, this term is only
prescribed in the SOP, but it had not been technically
defined.
Considering that the gas market will evolve in the
near term, and to prevent potential disputes which
can arise from the revision of design operating
range (which triggers the System Stress response
obligations), Keppel suggests that the bases for
revising the “design operating range” (to cater for
future market/ network conditions) be clearly
defined.
GSC/2014/20
12.5
Under the GNC, operating procedures relevant to a The gas transporter has published the operating procedures in
Shipper’s obligation have been all captured as Defined respect of its GSO role such as the Injection Operating
Terms, and thus form part of the GNC.
Procedure which covers, inter alia, the treatment of noncompliant gas, and the Implementation of Curtailment
SOPs that govern Shipper’s contractual obligations Procedure which covers, inter alia, the actions to be taken in a
system stress.
arising from GNC are:
These
are
some
examples
of
the relevant
operating
Modification
Ref. No.
Clause
Written Representations
ICP
IOP
Local Operating Procedures
SOP for Gas Connection
System Stress Operating Procedure
System Stress Procedures
Transmission Network Injection Point
Procedures
Upstream Facility Connection Procedures.
EMA’s Response
procedures. EMA will administer these operating procedures
after it takes over the GSO function. EMA will consult relevant
parties in the development of new operating procedures, or
modifications of the existing operating procedures before
issuing them.
Operating
To be consistent with the approach and framework within
which existing Shippers operate, the operating
procedures should be specifically identified under the
Gas Supply Code (or referenced to the GNC) for greater
clarity and transparency.
The Gas Network Code has already in place the various
operating procedures to address System Stress
situations, and has proven adequate to manage gas
situations.
Under the existing GNC framework (which we envisage
the PSOD to be one of the contracting parties under the
GNC), if the PSOD in its capacity as the GSO intends to
introduce new operating procedures for System Stress
situations, the existing GNC framework allows for it.
Parties would have to go through a consultative process
to formalize and introduce such changes.