Safety requirements (compliance with safety regulation / risk control expectations)

This LAP is concerned with risk management and safety requirements for hydrogen injection and transport in the high pressure TSO transmission gas grid and the regulatory oversight to ensure safe operations

Glossary:

Safety regarding the handling and precautions to be taken when dealing with pure hydrogen and blend of H2 and NG when injected in the grid
Is it a barrier?
Neutral
Type of Barrier
Structural barriers, Regulatory gap
Assessment Severity
1

Questions:

Question 1 Which safety precautions are needed at your facilities when dealing with hydrogen and how is this related to legal and administrative procedures (e.g. ATEX, leakage detection, etc.)?
No specific rulling about hydrogen, thus the overall rulling about dealing with hazardos gas apply, also high pressure unit maintenance rullings , Overall rulling about chemical production apply, it is necessary to carry out risk assessment (building authority requirement), regarding from the size of facility it may be necessary to provide environmental impact assessment or initial (environmental impact) assessment.
Question 2 Which additional safety requirements are needed for the injection of hydrogen compared to the injection of natural gas?
Not determinated. The rulling determines that the system user must establish the connection, therefore by using different gases, different safety requirements may arise from industry part of view.
Question 3 For which aspects is it needed to have good agreements about safety between the supplier and TSO?
It is the part of the system user agreement.
Question 4 Which is the competent authority or entity with regard to safety requirements?
State environmental service, State Fire and Rescue service of Latvia ( Supervises if the overall safety rulings are observed
Describe the comparable technology and its relevance with regard to hydrogen
Bio–methane

National legislation:

EU Legislation:

  • 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 2010/75/EU on industrial emissions (integrated pollution prevention and control (IED)
    The Directive, which applies to the production of hydrogen (production on an industrial scale by chemical or biological processing) (Annex I, point 4.2) contains inter alia:
    • Basic obligations of the operator (Article 11)
    • The content of permitting applications (Article 12)
    • Permitting Conditions (Article 14)
    • Emission limit values, (Article 15)
    • Monitoring requirements (Article 16)
    • Access to information and public participation (Article 24)

    The meaning of "production on an industrial scale by chemical or biological processing in Annex I section 4" has been clarified by the EU Commission, in support of transposition and implementation measures. :

    Annex I Section 4 (“chemical industry”) refers to “production on an industrial scale” and contains no quantitative capacity thresholds. The scale of chemical manufacture can vary from a few grams (of a highly specialised product), to many tonnes (of a bulk chemical product); yet both may correspond to “industrial scale” for that particular activity.

    Various criteria should be taken into account to decide whether production is “on an industrial scale”, including such factors as the nature of the product, the industrial character of the plant and machinery used, production volume, commercial purpose, production solely for own use, environmental impact. Such considerations should take account of the primary objective of the IED as expressed in Article 1 as to "prevent or, where that is not practicable, to reduce emissions into air, water and land and to prevent the generation of waste, in order to achieve a high level of protection of the environment taken as a whole", complemented by the general principle set in Article 11 (c) that "no significant pollution is caused".

    The fact that the activity is carried out for "commercial purposes" may be a strong indicator of "industrial scale", […] However, it may not be sufficient to use the “commercial purpose” of an activity as the sole determinant of "industrial scale". It may also be important to take into account the potential environmental impact of a production sequence.


    Directive 2010/75/EU established an integrated approach towards prevention and control. This integrated approach means that the permits must take into account the whole environmental performance of the plant, covering e.g. emissions to air, water and land, generation of waste, use of raw materials, energy efficiency, noise, prevention of accidents, and restoration of the site upon closure. The permit conditions including emission limit values must be based on the Best Available Techniques (BAT).
  • 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
  • Regulation (EU) 2016/426 of the European Parliament and of the Council of 9 March 2016 on appliances burning gaseous fuels and repealing Directive
    This Regulation applies to appliances burning gaseous fuels used for cooking, refrigeration, air-conditioning, space heating, hot water production, lighting or washing, and also forced draught burners and heating bodies to be equipped with such burners and to safety devices, controlling devices or regulating devices and sub-assemblies thereof, designed to be incorporated into an appliance or to be assembled to constitute an appliance (fittings).

    Article 7 sets the obligations of manufacturers which should inter alia:
    • ensure that appliances and fittings meet the essential requirements set out in Annex I.
    • draw up the technical documentation referred to in Annex III (‘technical documentation’)
    • carry out the relevant conformity assessment procedure
    • keep the technical documentation and the EU declaration of conformity for 10 years
    • ensure that procedures are in place for series production to remain in conformity
    • carry out sample testing of appliances made available on the market,
    • investigate, and, if necessary, keep a register of complaints, of non-conforming appliances and fittings and recalls of such appliances and fittings, and shall keep distributors informed of any such monitoring.
    • ensure that their appliances and fittings bear a type, batch or serial number or other element allowing their identification, and the inscriptions provided for in Annex IV.
    • indicate on the appliance their name, registered trade name or registered trade mark, and the postal address at which they can be contacted
    • ensure that the appliance or fitting is accompanied by instructions and safety information
    • ensure that the fitting is accompanied by a copy of the EU declaration of conformity containing, inter alia, instructions for incorporation or assembly, adjustment, operation and maintenance
    • take corrective measures necessary to bring that appliance or fitting into conformity, to withdraw it or recall it, if appropriate.
    • where the appliance or the fitting presents a risk, immediately inform the competent national authorities giving details, in particular, of the non-compliance and of any corrective measures taken
    • provide competent national authority with all the information and documentation necessary to demonstrate the conformity of the appliance.

    Article 9 sets obligations for importers which should inter alia:
    • ensure that the appropriate conformity assessment procedure has been carried out
    • ensure that the manufacturer has drawn up the technical documentation, that the appliance bears the CE marking and is accompanied by instructions and safety information and that the manufacturer has complied with the requirements set out in Article 7(5) and (6).
    • indicate on the appliance their name, registered trade name or registered trade mark, and the postal address at which they can be contacted
    • ensure that the appliance is accompanied by instructions and safety information in accordance with point 1.5 of Annex I, in a language which can be easily understood by consumers and other end-users, as determined by the Member State concerned.
    • ensure that the fitting is accompanied by a copy of the EU declaration of conformity containing, inter alia, instructions for incorporation or assembly, adjustment, operation and maintenance in accordance, in a language which can be easily understood by appliance manufacturers, as determined by the Member State concerned.
    • ensure that, while an appliance or a fitting is under their responsibility, storage or transport conditions do not jeopardise its compliance with the essential requirements
    • carry out sample testing of appliances made available on the market, investigate, and, if necessary, keep a register of complaints, of non-conforming appliances and fittings and recalls of such appliances and fittings, and shall keep distributors informed of any such monitoring.
    • for 10 years after the appliance or the fitting has been placed on the market, keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities and ensure that the technical documentation can be made available to those authorities, upon request
    • further to a reasoned request from a competent national authority, provide it with all the information and documentation necessary to demonstrate the conformity of an appliance or a fitting in a language which can be easily understood by that authority

    Article 10 sets the obligations of distributors which should inter alia:
    • verify that the appliance bears the CE marking and that it is accompanied by instructions and safety information and that the manufacturer and the importer have complied with the requirements set out in Article 7(5) and (6) and Article 9(3) respectively
    • not make the appliance or the fitting available on the market until it has been brought into conformity.
    • ensure that, while an appliance or a fitting is under their responsibility, storage or transport conditions do not jeopardise its compliance with the essential requirements
    • make sure that the corrective measures necessary to bring that appliance or fitting into conformity, to withdraw it or recall it, if appropriate, are taken. Furthermore, where the appliance or the fitting presents a risk, distributors shall immediately inform the competent national authorities of the Member States in which they made the appliance or the fitting available on the market to that effect, giving details, in particular, of the non-compliance and of any corrective measures take