Safety requirements and process (safety distances internal / external)

This LAP analyses, in general, the safety requirements (regulations and standards) associated with the approval of HRS. In particular, this LAP looks at the general rules applicable to an HRS (e.g. permitting regime, agreement) apart from the land use planning, including but not limited to:
a) environmental assessment (e.g.: emissions (IED), noise, etc.)
b) risk assessment
c) technical, including internal/external safety distances safety requirements
d) Personnel safety requirements

The LAP also explores whether it is allowed to install an HRS indoors (for example for forklifts) as well as the additional requirements applicable when an HRS is installed indoors.

Glossary:

Safety requirements are the legal (regulations and standards) requirements for safety assessment for the approval of HRS. One of the measures for safety operation of a HRS is the creation of safety distances.
The safety distance is the minimum separation between a hazard source and an object (human, equipment or environment) that will mitigate the effect of a likely foreseeable incident and prevent minor incident from escalating into larger incident.

Pan-European Assessment:

Safety requirements, risk assessments, safety distances and other requirements covered in this section are essential elements which ensure the long-term sustainability of any future HRS network, therefore, although they impose high costs (both economically, as well as in time required for planning, building and permitting), overall, they are seen as necessary investments for a safe, sustainable operation of the HRSs.
Currently, there is no clear set of safety requirements, (including distances, permits, assessments) defined specifically for Hydrogen Refueling stations in most European countries. In practice, the requirements imposed on HRS projects will be based case-by-case risk assessments or represent precautious estimations by local authorities. In this sense, a regulatory gap and, to a certain extent, a structural barrier can be observed.

The regulatory gap for safety requirements specific to HRS has several major consequences:
• HRS operators face uncertainty during permitting: there is no standardized approach by the administration for the interpretation of the applicable regulation, which can lead to non–uniform interpretation by different authorities,
• Unreasonably high requirements: Authorities which wish to exercise a high degree of precaution in the face of limited experience with hydrogen technologies interpret general (industrial) regulations by imposing the “maximum” level prescribed
• Duplication of efforts, without added safety benefits: every new HRS project is treated on a case by case basis which increases the necessity of individual (case–by–case) modelling, calculation, planning, etc. Designs which have been deemed safe already could be replicated at lower administrative and economic cost, however this does not appear to be the case in most countries.
• Disincentive HRS with on-site production: the authorization procedure for HRS with on–site production is cumbersome and, in some cases, prohibitive

The administrative practice and existing rules in some countries impose excessive safety distances for Hydrogen Storage, this is seen as a structural barrier, as imposing unreasonable safety distances prevents the adaptation of conventional refueling stations to include hydrogen re-fueling within existing locations, therefore resulting in a major barrier for the accelerated uptake of hydrogen mobility.
Is it a barrier?
Yes
Type of Barrier
Regulatory gap
Assessment Severity
2
Assessment
Taking into account that a number of ISO standarts are applicable in Latvia, the safety ISO 17268:2012; ISO/TS 19880-1:2018; The minimum safety requirements are set. Overall rulling about actions with flamable substances are applicable.

Questions:

Question 1: What are the main requirements with their applicable regulations for building an HRS (e.g. permitting regime, agreement) apart from the land use planning
Latvian national law determines that hydrogen refuelling infrastructure that is publicly available must be in line with ISO/TS 19880-1:2018. The refuelling station must use the algorithme of the refuelling according to the ISO/TS 19880-1:2018 and the connection between the refuelling station and the FCEV must be according to the ISO 17268:2012
Question 1 What are the main requirements with their applicable regulations for building an HRS (e.g. permitting regime, agreement) apart from the land use planning? Please list them including: a - environmental assessment (e.g.: emissions (IED), noise, etc.)
No minimum or maximum level of hydrogen production capacity is given. If the Hydrogen production facility exceeds 1tonn per day, it is determined as “High-risk local object”. a. It may be necessary to perform Environmental impact assessment to receive the permit of polluting activities of Category A,B,C categorry pollution permit is necessary: • Regarding the pollution permit type - The pollution permit Type catogeries A,B,C differ regarding the capability of the hydrogen production facility it is granted by the State environment service. The difference from A; B and C category permit is the quantity of pollutants that will be created during the operation phase. For every HRS (including or not including the on-site production) it is necessary to receive at least C category permit. • For Gas refuelling stations it is necessary to receive C category permitt. • If the hydrogen is produced on-site using steam methane reforming and the rated thermal input is from 0,2 to 5 megawatts, if biomass (also wood and peat) or gaseous fuels are used in the combustion installation. (C category permitt) B category permit is necessary to obtain if: • petrol stations with 2 000 or more cubic metres of fuel per year (the total largest amount of fuel pumped during the last three years) • If the hydrogen is produced on-site using steam methane reforming and the rated thermal input is from 5 to 50 megawatts, if biomass (also wood and peat) or gaseous fuels are used in the combustion installation. For storage units: 4.2. installations for the storage of unpacked organic or inorganic chemical substances, chemical products or intermediary products, if one tonne or more is stored, for the storage of enzymes – 20 tonnes or more. By exceeding these B permitt tresholds it is necessary to obtain A category permit • Responsible entity - state environmental entity Storrage A storage unit with substances that, in accordance with fire safety regulatory enactments, are specified as highly flammable, explosive and extremely flammable liquids, gases and mixtures thereof – more than 2,5m3 can be deployed if a specific permit for works with dangerous goods and mixtures is received form Ministry of Environmental Protection and Regional Development of the Republic of Latvia. • B category pollution permit is necessary if 4.2. installations for the storage of unpacked organic or inorganic chemical substances, chemical products or intermediary products, if one tonne or more is stored, for the storage of enzymes – 20 tonnes or more.
Question 1 What are the main requirements with their applicable regulations for building an HRS (e.g. permitting regime, agreement) apart from the land use planning? Please list them including: b - risk assessment
b - Risk assessment or Initial risk assesment is necessary to receive the building permit.
Question 1 What are the main requirements with their applicable regulations for building an HRS (e.g. permitting regime, agreement) apart from the land use planning? Please list them including: c - technical, including internal/external safety distances safety requirements
c - written concept for the prevention of hazardous accidents; a written concept about working with dangerous equipment; Check of installation of the object including ground every 10 years. Explosive environment assessment every two years. – necessary to receive category C operating permit. – Maximal external safety distance will apply (50 m)
Question 1 What are the main requirements with their applicable regulations for building an HRS (e.g. permitting regime, agreement) apart from the land use planning? Please list them including: d - Personnel safety requirements
d - occupational safety requirements 353. In a facility where leakage of flammable gases is possible, measures shall be taken to prevent the formation of explosive concentrations. 354. An object containing a gas appliance with a total rated thermal input of more than 50 kW, as well as a gas leakage warning detector is installed in the gas apparatus (regardless of the gas apparatus capacity) in the cellar or basement floor. The gas leak alarm detector is maintained. 358. In the case of a gas-compressed gas compressor station, devices for the remote control of ventilation equipment shall be located at the entrance 362.3. in the facility and in the area where activities with flammable and oxidizing gases are carried out, workers wear clothing from static electricity and nailing and clothing that can spark. 428. The safety data sheets of such substances or other equivalent information on the physical and chemical properties of the dangerous substances concerned, the hazards and potential effects on the environment and human health are available at the facility where the dangerous substances are stored. This information must be sufficient to identify potential threats to the environment, human life, health and property caused by the substance or products concerned and to ensure adequate action in the event of a fire or explosion. 429. When using hazardous substances, observe the instructions given by the manufacturers in the safety data sheets. When using and storing hazardous substances that are not known to be explosive and fire hazard, the same fire safety measures as for explosive substances or products shall be carried out. 431. In industrial buildings and premises where explosive atmospheres may occur, automatic airborne analyzers shall be installed indicating explosive concentrations. Automatic air analyzers are maintained and operated in accordance with the manufacturer's technical regulations. 439. A foam concentrate shall be provided for the economic activity object or territory where the dangerous substances with a total volume of 5000 m3 or more are stored. The amount of foam concentrate is ensured by the largest reservoir, laying area, filling and draining site, pumping station, manifold and quay trenching area with a triple reserve. The requirements of this paragraph do not apply to objects in which hazardous substances are stored under ground 455. In explosive atmospheres, explosion-proof portable electrical equipment and communication means are used. An electrical installation, electrical facility, and electrical device in an object and territory in which an explosive environment may occur shall be in an explosion-proof construction in conformity with the zoning of an explosive environment. The work environment shall be regarded as explosive if a mixture with air of flammable, highly flammable or extremely flammable substances and products in the form of gas, vapour, mist or dust (hereinafter – flammable substances) exists or may occur in which under normal atmospheric conditions after ignition the fire spreads throughout the mixture volume. A workplace shall be regarded as explosive if explosive atmosphere is present or may occur therein causing a risk to the safety and health of employees, and special provisions and measures are necessary for protection against such risk. Explosive workplaces shall be classified in zones on the basis of the frequency of occurrence and duration of the existence of the explosive atmosphere: 7.1. Zone 0 – a place in which an explosive atmosphere consisting of a mixture with air of flammable substances in the form of gas, vapour or mist is present continuously, for a long period or frequently; 7.2. Zone 1 – a place in which an explosive atmosphere consisting of a mixture with air of flammable substances in the form of gas, vapour or mist may sometimes occur under normal working conditions when performing activities specified in the technological (work) process; 7.3. Zone 2 – a place in which an explosive atmosphere consisting of a mixture with air of flammable substances in the form of gas, vapour or mist may not occur under normal working conditions when performing activities specified in the technological (work) process, but if it occurs, is present for a short period of time only; The employer shall ensure that an inspection is performed in newly established or reconstructed workplaces in order to determine whether it is an explosive workplace. If it has been determined that it is an explosive workplace, the employer shall ensure assessment of the risk caused by the explosive atmosphere. The employer shall provide an assessment of the risk caused by explosive atmospheres in conformity with internal supervision of the work environment and risk assessment procedures of the work environment of an undertaking. In assessing the risk caused by explosive atmospheres the following shall be taken into account: 10.1. the possibility of an occurrence of explosive atmospheres and their persistence; 10.2. the possibility of the presence of ignition sources, frequency and power of exposure thereof, as well as the impulse of energy produced, including electrostatic discharges; 10.3. work equipment, substances, processes utilised and interaction thereof; and 10.4. amount of anticipated effects. In assessing the risk caused by explosive atmospheres the possibility of the spread of explosive atmospheres through openings and insufficiently tight connections in work equipment, premises, workplaces, as well as the potential spread thereof under normal working conditions and emergency situations shall be determined. The risk caused by explosive atmospheres shall be assessed not less frequently than once a year, as well as when a new workplace has been created or changes have been made in any of the existing workplaces (for example, there are changes in work processes, methods, work equipment, utilisation of substances and products and production thereof) that might increase the risk caused by an explosive atmosphere and affect the safety and health of employees at work. Work equipment and protective systems for work in explosive atmospheres shall be selected in accordance with characteristics of the explosive atmosphere (physical and chemical properties of flammable substances and mixtures thereof) and risk assessment.
Question 1 What are the main requirements with their applicable regulations for building an HRS (e.g. permitting regime, agreement) apart from the land use planning? Please list them including: e - others
e - n/a
Question 2 Is it allowed to install and HRS inside for example for forklifts? Is there any additional requirements when you install the HRS inside? If yes, what are the legal requirement? Did they hamper you to install them inside? What are the main requirements with their applicable regulations for building an HRS (e.g. permitting regime, agreement) apart from the land use planning? Please list them including:
2 – no experience
Describe the comparable technology and its relevance with regard to hydrogen
Refuelling stations for conventional fuels, gas refuelling stations

National legislation:

EU Legislation:

  • Directive 2012/18/EU of the European Parliament and of the Council of 4 July 2012 on the control of major-accident hazards involving dangerous substances (so-called SEVESO Directive)
    The Directive covers situations where dangerous substances may be present (e.g. during processing or storage) in quantities exceeding certain thresholds.

    It establishes:
    • General obligations on the operator (Article 5)
    • Notification (information on the form and amount of substances, the activity, and the surrounding environment) of all concerned establishments (Article 7),
    • The obligation to deploy a major accident prevention policy (Article 8),
    • The obligation to produce a safety report for upper-tier establishments (Article 10);
    • The obligation to produce internal emergency plans for upper tier establishments (Article 12);
    • Authorities to exert control of the siting of new establishments, modifications to new establishments, and new developments including transport routes, locations of public use and residential areas in the vicinity of establishments, (Article 13)
    • The obligation to conduct public consultations on specific individual projects that may involve risk of major accidents (Article 15)

    Annex I, Part 1, establishes Hydrogen as a dangerous substance (therefore within scope) and lists the quantity of hydrogen for the application of lower-tier requirements (≥ 5t) and upper-tier requirements (≥ 50t).

    For quantities of less than 5 tonnes of hydrogen, none of the obligations above would apply.

    The Directive is relevant for both the approval of bunkering / landing installations as well as on board transport of hydrogen
  • ATEX Directive 2014/34/EU - covering equipment and protective systems intended for use in potentially explosive atmospheres
    The Directive defines the essential health and safety requirements and conformity assessment procedures (Article 4) to be applied before products are placed on the EU market and is significant for the engineering of hydrogen production plants. It covers inter alia equipment and protective systems intended for use in potentially explosive atmospheres.

    The Directive requires employers to classify areas where hazardous explosive atmospheres may occur into zones. The classification given to a particular zone, and its size and location, depends on the likelihood of an explosive atmosphere occurring and its persistence if it does.

    The Directive requires the manufacturers to design their equipment to be suitable for use within their customer’s explosive atmosphere. Therefore, manufacturers of equipment rely upon their customer to give them information about the classification of the zone and the flammable substance(s) within that zone.

    The Directive describes the rules and regulations for all actors in the value chain, with respect to ensuring that only safe equipment for use in potentially explosive atmospheres are sold and applied. It provides regulation of how the equipment shall be constructed, produced and documented, as well as the rules for CE-labelling.

    It also contains, inter alia conformity assessment procedures (Art 13) EU declaration of conformity (Art 14) and General principles of the CE marking (Art 16)

    The Directive is relevant for the approval of landing / bunkering installations
  • Directive 2014/52/EU of the European Parliament and of the Council of 16 April 2014 amending Directive 2011/92/EU on the assessment of the effects of certain public and private projects on the environment).
    The Directives (and their subsequent amendments) define a strategic environmental impact assessment procedure. The procedure is summarized as follows: the developer may request the competent authority define what should be covered by the EIA information to be provided by the developer (scoping stage); the developer must provide information on the environmental impact (EIA report – Annex IV); the environmental authorities and the public (and affected Member States) must be informed and consulted; the competent authority decides, taken into consideration the results of consultations. The public is informed of the decision afterwards and can challenge the decision before the courts.

    In line with the EIA Directive, Production and Storage of Hydrogen falls within the projects listed in Annex II (6a and 6c -production of chemicals; and storage facilities for chemical product), for which Member States shall determine whether the project shall be made subject to an assessment or not. In some EU countries, storage of 5 tons of hydrogen or more falls within the scope of the Directives.

    The latest amendment, (Directive 2014/52/EU) introduces minimum requirements with regards to the type of projects subject to assessment, the main obligations of developers, the content of the assessment and the participation of the competent authorities and the public.
  • Directive 2011/92/EU of the European Parliament and of the Council of 13 December 2011 on the assessment of the effects of certain public and private projects on the environment (EIA Directive)
    The Directives (and their subsequent amendments) define a strategic environmental impact assessment procedure. The procedure is summarized as follows: the developer may request the competent authority define what should be covered by the EIA information to be provided by the developer (scoping stage); the developer must provide information on the environmental impact (EIA report – Annex IV); the environmental authorities and the public (and affected Member States) must be informed and consulted; the competent authority decides, taken into consideration the results of consultations. The public is informed of the decision afterwards and can challenge the decision before the courts.

    In line with the EIA Directive, Production and Storage of Hydrogen falls within the projects listed in Annex II (6a and 6c -production of chemicals; and storage facilities for chemical product), for which Member States shall determine whether the project shall be made subject to an assessment or not. In some EU countries, storage of 5 tons of hydrogen or more falls within the scope of the Directives.

    The latest amendment, (Directive 2014/52/EU) introduces minimum requirements with regards to the type of projects subject to assessment, the main obligations of developers, the content of the assessment and the participation of the competent authorities and the public.
  • Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment (SEA Directive)
    The Directives (and their subsequent amendments) define a strategic environmental impact assessment procedure. The procedure is summarized as follows: the developer may request the competent authority define what should be covered by the EIA information to be provided by the developer (scoping stage); the developer must provide information on the environmental impact (EIA report – Annex IV); the environmental authorities and the public (and affected Member States) must be informed and consulted; the competent authority decides, taken into consideration the results of consultations. The public is informed of the decision afterwards and can challenge the decision before the courts.

    In line with the EIA Directive, Production and Storage of Hydrogen falls within the projects listed in Annex II (6a and 6c -production of chemicals; and storage facilities for chemical product), for which Member States shall determine whether the project shall be made subject to an assessment or not. In some EU countries, storage of 5 tons of hydrogen or more falls within the scope of the Directives.

    The latest amendment, (Directive 2014/52/EU) introduces minimum requirements with regards to the type of projects subject to assessment, the main obligations of developers, the content of the assessment and the participation of the competent authorities and the public.
    X
  • Directive 1999/92/EC of the European Parliament and of the Council of 16 December 1999 on minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres
    Directive 1999/92/EC lays down minimum requirements for the safety and health protection of workers potentially at risk from explosive atmospheres which will apply to facilities involved in the production, storage and distribution of hydrogen. It sets out a number of specific obligations on the employer, including inter alia:

    • Prevention of and protection against explosions
    • Assessment of explosion risks
    • Special requirements for work equipment and workplaces
  • Directive 2014/68/EU of the European Parliament and of the Council of 15 May 2014 on the harmonisation of the laws of the Member States relating to the making available on the market of pressure equipment.
    The Pressure Equipment Directive, applies to the design, manufacture and conformity assessment of pressure equipment and assemblies with a maximum allowable pressure greater than 0.5 bar.

    Technical requirements and classification according to an ascending level of hazard, depending on pressure, volume or nominal size, the fluid group and state of aggregation, as well as conformity assessment procedures are laid down and required by the Directive

    Hydrogen is a fluid which falls under Group 1. Group 1 consists of dangerous fluids (flammable, toxic and/or oxidizing). As a result, a large part of the equipment for H2 production, storage and distribution must meet the technical requirements set out in the Pressure Equipment Directive (PED).

    The Directive is relevant for the approval of landing / bunkering installations
  • Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the deployment of alternative fuels infrastructure (AFID)
    The AFID establishes a common framework of measures for the deployment of alternative fuels infrastructure in the Union in order to minimize dependence on oil and to mitigate the environmental impact of transport.

    The Directive sets out minimum requirements for the building-up of alternative fuels infrastructure, including recharging points for electric vehicles and refuelling points for natural gas (LNG and CNG) and hydrogen, to be implemented by means of Member States' national policy frameworks, as well as common technical specifications for such recharging and refuelling points, and user information requirements.

    Article 2 defines ‘Alternative fuels’ as fuels or power sources which serve, at least partly, as a substitute for fossil oil sources in the energy supply to transport and which have the potential to contribute to its decarbonisation and enhance the environmental performance of the transport sector. They include, inter alia: hydrogen.

    It lays down, in Article 5, that Member States which decide to include hydrogen refuelling points accessible to the public in their national policy frameworks shall ensure that, by 31 December 2025, an appropriate number of such points are available, to ensure the circulation of hydrogen-powered motor vehicles, including fuel cell vehicles, within networks determined by those Member States, including, where appropriate, cross-border links.

    Annex II contains technical specifications for hydrogen refuelling points for motor vehicles and additionally lays down that:
    • Outdoor hydrogen refuelling points dispensing gaseous hydrogen used as fuel on board motor vehicles shall comply with the technical specifications of the ISO/TS 20100 Gaseous Hydrogen Fuelling specification.
    • The hydrogen purity dispensed by hydrogen refuelling points shall comply with the technical specifications included in the ISO 14687-2 standard.
    • Hydrogen refuelling points shall employ fuelling algorithms and equipment complying with the ISO/TS 20100 Gaseous Hydrogen Fuelling specification.
    • Connectors for motor vehicles for the refuelling of gaseous hydrogen shall comply with the ISO 17268 gaseous hydrogen motor vehicle refuelling connection devices standard.
  • Directive 2006/42/EC of 17 May 2006 on machinery
    Contents applied technical regulations for the construction of HRS.
  • Low Voltage Directive 2014/35/EU
    Contents applied technical regulations for the construction of HRS.
  • Simple Pressure Vessels Directive 2014/29/EU
    Contents applied technical regulations for the construction of HRS.
  • ISO/TS 19880–1:2016 Gaseous hydrogen — Fuelling stations — Part 1: General requirements
    One of the aims of the standard is to create common methodology for determining applicable safety distances based on local requirements and conventions.