May 2021

May 2021 Hydrogen and Fuel Cell Safety Report

SANDIA Publishes Report on Hydrogen Regulatory Framework

by Karen Quackenbush, FCHEA

Sandia National Laboratories has published a new report (SAND2021-2955), Federal Oversight of Hydrogen Systems, by Austin R. Baird, Brian D. Ehrhart, Austin M. Glover, and Chris B. LaFleur. The report seeks to clear up any ambiguity as to which Federal regulations are applicable to hydrogen and where regulatory gaps may exist.

The infrastructure of hydrogen systems and regulation enforcement entities are defined, and a visual map and reference table are developed. This regulatory map and table can be used to identify the boundaries of federal oversight for each component of the hydrogen supply value chain which includes production, storage, distribution, and use. The report is a resource that identifies which federal agencies have oversight of various hydrogen systems and modes of transport, based on current regulations. Additionally, this report identifies, to the extent possible, whether hydrogen is specifically included or excluded from certain activities, installations, or modes of transport based on the current regulations.

It is important to note that the effort does not include an analysis of the hydrogen requirements where they do exist. For example, Table 3-1. Overview of Regulation and Oversight of Hydrogen Systems, we see that OSHA Regulations on hydrogen storage are covered in CFR 29, Part 1910, and the column on the right indicates this regulation is “H2-Ready”. This categorization is not meant to imply that further work to update this regulation is not needed – only that the regulations do include requirements for hydrogen. Indeed, industry has noted that the set-back distances in CFR 29 were last affirmed by OSHA in July 2006, and are based on NFPA 50A, Standard for Gaseous Hydrogen Systems at Consumer Sites, established in 1969, and NFPA 50B, Standard for Liquefied Hydrogen Systems at Consumer Sites, established in 1967. Both of these documents were withdrawn in 2004 and incorporated in to NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2005 edition. Since that time, NFPA 55 has maintained requirements for hydrogen storage, incorporating a risk-informed methodology for siting.  Therefore, work to update and harmonize requirements may still be warranted.

The report provides a clear description of the Federal regulatory framework for the entire hydrogen supply value chain, including a variety of processes from production and storage, to transportation and distribution, to end use, and summarizes applicable Federal regulations and regulatory bodies for each category of system along the hydrogen value chain. Table 3-1 also notes which regulations currently have hydrogen directly listed, regulations that cover general flammable or otherwise hazardous gases or liquids that should indirectly cover hydrogen, and regulations that are specific to some other material (such as natural gas) that will need to be modified to include hydrogen. By so doing, the report is a valuable tool for prioritizing regulatory efforts to ensure proposed future changes address gaps and updates to reflect the current state of technology and learnings.

You can download a PDF copy of this report here.

Electrolyzer Standards Seek to Address Industry Needs

By Karen Quackenbush, FCHEA

As the national trade association for the fuel cell and hydrogen energy industry, the Fuel Cell and Hydrogen Energy Association (FCHEA) utilizes a Working Group structure to facilitate focused effort in each of the three following applications: Portable Power, Stationary Power, and Transportation, which fuel cell includes vehicles and the hydrogen infrastructure to support them. FCHEA Working Groups provide regular opportunities to engage industry in developing Regulations, Codes, and Standards (RCS), assess RCS priorities and needs, and identify opportunities to harmonize requirements.

FCHEA’s Stationary Power Working Group (SPWG), has noted the need for robust, harmonized standards for electrolyzers. The SPWG has been in discussions with IEEE regarding upcoming changes to IEEE 1547-2018 - IEEE Standard for Interconnection and Interoperability of Distributed Energy Resources with Associated Electric Power Systems Interfaces. Grid interconnection falls under the guidance of IEEE 1547-2018 for technical requirements.   Electric Utilities and Regulators rely heavily on these requirements for project specification and approval.

There is also significant work in the International community on developing revised and new requirements for electrolyzers. ISO 22734:2019 - Hydrogen generators using water electrolysis — Industrial, commercial, and residential applications, provides general requirements and test protocols for electrolyzers. The process for adopting this standard in North America has recently been announced. Once published, a national adoption of ISO 22734 could form the basis for approval of fuel cell systems utilizing electrolysis for grid service.

A proposed revision to ISO 22734: 2019 is in ballot. This new project would provide additional safety requirements specific to dynamic operation, and once complete, would be published as ISO 22734-1: Hydrogen generators using water electrolysis -- Industrial, commercial, and residential applications --Part 1: General requirements, test protocols and safety requirements. The scope of this project covers the revision of ISO 22734:2019 in order to establish any additional safety requirements and test methods needed for:

i) operation of water electrolysis systems coupled with the electricity distribution grid and/or fluctuating and intermittent renewable energy sources (RES) in a dynamic mode.

ii) safety requirements for venting of oxygen

iii) requirements for scale up including electrolyzer systems installed into buildings

iv) other areas, such as

a. including learnings from other enclosed systems (e.g. HRS) and pre-normative research projects;

b. safety integrated systems;

c. power electronics for connection to the grid; and

d. specific requirements when incorporated into specific applications, e.g. as part of HRS, or hydrogen grid injection system

Performance requirements for electric grid balancing are to be addressed in the separate ISO TC 197 working group (WG32) developing ISO TR 22734-2 - Hydrogen generators using water electrolysis — Part 2: Testing guidance for performing electricity grid service.

IEC/TC 105 – Fuel Cell Technologies, has also published standards and new activities developing International Standards for fuel cell modules in reverse mode:

IEC 62282-8-301 ED1 - Fuel cell technologies – Part 8-301 Energy storage systems using fuel cell modules in reverse mode – Power to methane energy systems based on solid oxide cells including reversible operation - Performance test methods, is under development.

The following standards have already been published:

• IEC 62282-8-101:2020 - Fuel cell technologies - Part 8-101: Energy storage systems using fuel cell modules in reverse mode - Test procedures for the performance of solid oxide single cells and stacks, including reversible operation.

• IEC 62282-8-102:2019 - Fuel cell technologies - Part 8-102: Energy storage systems using fuel cell modules in reverse mode - Test procedures for the performance of single cells and stacks with proton exchange membrane, including reversible operation

• IEC 62282-8-201:2020 - Fuel cell technologies - Part 8-201: Energy storage systems using fuel cell modules in reverse mode - Test procedures for the performance of power-to-power systems

FCHEA will continue to engage in these activities, and work to ensure harmonized requirements to facilitate use of electrolyzer technology in fuel cell energy systems.

NFPA Update

by Karen Quackenbush, FCHEA

NFPA 2 and NFPA 55 are now in the Second Draft phase of developing 2023 editions. First Draft Reports have been posted for public comments, due on June 3, 2021. You can view and make Public Comments on the First Draft Report of NFPA 2 here and the First Draft Report of NFPA 55 here.

NFPA 2 also has posted a Tentative Interim Amendment (TIA) to the published 2020 edition. The TIA was processed by the Technical Committee on Hydrogen Technology, and was issued by the Standards Council on April 15, 2021, with an effective date of May 5, 2021.

Tentative Interim Amendment (TIA): TIA 20-1.  This TIA revises section 10.5.1.6.2 and associated Annex note to limit public dispensing of gaseous hydrogen fuel to fuel supply containers on hydrogen motor vehicles that comply with at least one of the following:

• SAE J2579, Standard for Fuel Systems in Fuel Cell and Other Hydrogen Vehicles

• UN Global Technical Regulation No. 13, Global technical regulation on hydrogen and fuel cell vehicles

You can view or download this TIA here.

IEC Develops Fuel Cell Standard for Trains

by Karen Quackenbush, FCHEA

IEC is paving the way for hydrogen and fuel cells to be widely used for transport. IEC Technical Committee 9, which prepares standards for railway equipment and systems, has recently embarked on the development of a new standard, IEC 63341-1, specifying fuel cells for the propulsion of trains as well as any rolling stock type of transport, including light rail vehicles, tramways and metros.

Julien D’Arbigny, the new IEC Convenor for this project, recently told IEC’s online publication e-tech that this new IEC effort will be focusing on the definition of the interface as well as the description of environmental conditions, for instance temperature and humidity levels, shock, vibration and noise.

The new document will also describe the design requirements to ensure that the fuel cell system complies with railway applications. Other sections of the standards will address the safety, reliability and protection requirements needed for designing and installing the fuel cell system, as well as the validation process for these requirements.

It is anticipated this effort will be done in cooperation with IEC/TC 105: Fuel Cell Technologies.

To read the entire article in e-tech, click here.

ISO Publishes Updates to Directives

by Karen Quackenbush, FCHEA

A new edition of the ISO/IEC Directives, Part 1 (17th edition) and the Consolidated ISO Supplement has been published on 1 May 2021 (12th edition). Key changes include the following:

• Rotating secretariats: An option of secretariat rotation has been added in clause 1.9.1.

• Systematic review: An addition in clause 2.9.2 to allow the committee to prepare a recommendation, to be approved by its P-members, on the future of the deliverable which will be made available with the SR ballot.

• Minor revisions: A clarification in clause 2.9.1 that a final draft of the revised deliverable shall be submitted to ISO/CS within a maximum of 16 weeks for an 8-week FDIS vote or 12 weeks in the case of Vienna Agreement documents.

• Publicly Available Specifications (PAS) – to approve a modification in clause 3.2 that a PAS might be proposed from the outset, when a committee wishes to deliver content quickly to the market or during the development of an IS or TS, when the project cannot meet the publication deadline.

• Adoption of (amended) common Annex on ‘Selection Criteria for People Leading the Technical Work’: to approve including Annex SQ of the ISO Supplement as a new Annex L in the Directives, Part 1 and amend the text to include references to IEC.

The 2021 version of the documents with a list the modified clauses is available for download here.