Approval for landing/bunkering installations

This LAP contains information about the procedures for landing and bunkering installations associated with hydrogen transport on vessels. It provides information on the responsible approving authority and the particularities of the procedure when considering hydrogen in it’s liquid or compressed form.

Glossary:

Protection of employees from explosion risk in areas with potentially explosive atmospheres, relating to a set of zone definitions, minimum safety and health requirements, and criteria for the selection of equipment and protective systems in the different zones

Pan-European Assessment:

In most countries, requirements for bunkering (loading) of hydrogen as a fuel on–board the vessel are not yet developed. It is likely that, for now, general rules stemming from storage of hydrogen (see category 2) and rules covering HRS’s (see category 4.4) would apply. It is worth noting that, given the high energy demand of medium to large vessels, the quantities involved will be in the order of several tonnes, hence hydrogen storage facilities would likely be subject to significant obligations and requirements (e.g. SEVESO)

Existing rules for safe handling of inflammable, reactive and pressurized substances (e.g. which cover inter alia LNG) currently apply, however, it is not certain how these would be adapted to hydrogen. From this point of view, this process is characterized by a clear regulatory gap.

Early indication would show that further risk studies and technology qualification is required for the establishment of specific regulatory guidance covering liquid and compressed gaseous hydrogen for landing and bunkering installations. This is further indication that specific regulatory solutions to this regulatory gap are years away. Although there is limited practical experience, the lack of clarity as to the applicable rules s further reinforces the severity of the administrative barriers faced by the introduction of hydrogen as a fuel in the maritime sector.
Is it a barrier?
Yes
Type of Barrier
Regulatory gap
Assessment Severity
2
Assessment
Onshore landing and bunkering installations for hydrogen fall under the same legislation and requirements as those for onshore landing and bunkering of other flammable gases. As the legislation in this area is function–based rather than providing detail regulation, new legal–administrative procedures specifically for hydrogen may not be needed. However, there is the need for close assessment and consideration of specific guidelines for hydrogen installations. In cases involving storage of more than 5 tons of hydrogen, an application for special consent from the Norwegian Directorate for Civil Protection (DSB) is required. and it is foreseen that from the latter half of 2018 all bunkering of hydrogen for passenger ships will require DSB consent.

The LAP is basically the same for hydrogen as for onshore landing and bunkering of other flammable gases, and according to the relevant authority specific requirements may not be needed. However, the need for close assessment and requirement of special consent /approval from the Directorate for Civil Protection when passenger ships are concerned has implications in terms of time costs and cost/competence required to carry out extensive risk assessments.

The cost of hiring a consultant for the required quantitative assessment may be 100 000–200 000 NOK, while the processing time for applications for special consent from the Directorate for Civil Protection is minimum 3 months. In practice, revisions may be required and it may take considerably longer. The ongoing projects that we are aware of are research and development projects involving extensive dialogue between operators, research institutions and the relevant authorities.

Questions:

Question 1 Which is the responsible approval authority?
Norwegian Directorate for Civil Protection (DSB)
Question 2 Is the procedure different than for conventional vessels? a) If yes, what is the procedure to follow? E.g.: Requirement for additional certificates and documents: all cases additional requirements in case of liquid hydrogen additional requirements in case of compressed hydrogen b) How much time does it take and what are the additional costs incurred?
Yes, the procedure is different, as described below.
Question 2 Is the procedure different than for conventional vessels? a - If yes, what is the procedure to follow? E.g.: Requirement for additional certificates and documents: all cases additional requirements in case of liquid hydrogen additional requirements in case of compressed hydrogen
a - i. As per now, onshore landing, bunkering and storage facilities fall under the Norwegian Regulation for safe handling of inflammable, explosive and pressurized substances, including relevant installations and equipment. Small installations may be established freely. According to paragraph 17 of the same regulation, all bunkering installations for hydrogen harbouring more than 5 tons of inflammable gas require special consent from DSB. Following an ongoing revision of the Regulation (expected to enter into force in the second half of 2018), all bunkering of hydrogen for passenger ships will require special consent. The requirement is already applied in practice, through individual decisions According to the EMSA Study on the use of fuel cells in shipping (DNV GL 2017), current procedures for bunkering of LNG are based on cryogenic insulation, and double piping when going inside the vessel. Together with the experience from hydrogen filling stations for cars, this will be the first knowledge basis for all cases. Further risk studies and technology qualification is needed, both for liquid and compressed gaseous hydrogen. All pressurized components, such as tanks, piping and equipment, must be in compliance with EU Directive 97/23 – PED. ii. According to the EMSA Study, it is possible that N2 filling of voids/double pipes may be required or necessary. A water curtain on the ship side is required for bunkering of LNG according to IGF, and this will likely be expected for liquid hydrogen as well. Material certification for the low temperatures is required for liquid hydrogen storage as well as gas dispersion, and safety analyses are also needed. The potential vapour dispersion in case of accidental LH2 release is another topic that needs further study. iii. The technology available for land transport needs to be qualified for larger filling volumes and relevant marine impacts. Further risk studies (including evaluation of gas leaks, gas dispersion and relevant consequences) are needed.
Question 2 Is the procedure different than for conventional vessels? b - How much time does it take and what are the additional costs incurred?
b - Applying for special consent from DSB is a time–consuming process. The normal processing time is 3 months, including a 4–week hearing period, but it may also take considerably longer, if revision is required. A comprehensive, quantitative risk assessment is required for approval, and this is often outsourced to a consultant. The costs depend on case and are difficult to specify – could be 100 000–200 000 NOK, according to DSB. Detailed guidelines for how to apply are found at DSB's website: https://www.dsb.no/lover/farlige–stoffer/veiledning–til–forskrift/temaveiledning–om–innhenting–av–samtykke/
Question 3 Who can do the technical implementation work?
The actor/s in charge of the project must be one or more enterprises with liability. This goes for the responsible applicant, as well as the engineering, executing and controlling parties, both in the engineering and execution phase. The actors must have sufficient competence, including knowledge of relevant rules and regulations as well as technical construction and operation of installation and equipment, and relating to the risk and complexity of the installation. Practical and theoretical knowledge in the relevant fields shall be well documented.
Describe the comparable technology and its relevance with regard to hydrogen
Conventional fossil fuel, LNG and biomethanol as fuel for fuel cells are the relevant technologies to compare with. The Regulation for safe handling of inflammable, reactive and pressurized substances, including relevant installations and equipment, applies to all. The requirement of consent comes in for installations harbouring above 5 tons of hydrogen and must be foreseen for all bunkering of hydrogen for passenger ships.

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 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 2009/16/EC on port State control
    Directive 2009/16 introduces within the EU a port State control
    system based on the inspections performed within the Community and the Paris MOU. It’s purpose is to increase compliance with international and relevant Community legislation on maritime safety, maritime
    security, protection of the marine environment and onboard
    living and working conditions of ships of all flags;

    It does so by establishing common criteria for control of ships by the
    port State and by harmonising procedures on inspection and
    detention
  • Directive 2013/38/EU of the European Parliament and of the Council of 12 August 2013 amending Directive 2009/16/EC on port State control
    Directive 2009/16 introduces within the EU a port State control
    system based on the inspections performed within the Community and the Paris MOU. It’s purpose is to increase compliance with international and relevant Community legislation on maritime safety, maritime
    security, protection of the marine environment and onboard
    living and working conditions of ships of all flags;

    It does so by establishing common criteria for control of ships by the
    port State and by harmonising procedures on inspection and
    detention