WP7 INTERACTION WITH AUTHORITIES

Transcription

1 WP7 INTERACTION WITH AUTHORITIES Deliverable D7.1 IDENTIFICATION AND SELECTION OF AUTHORITIES AND KEY ORGANISATIONS Per S. Heggem Norman L. Newhouse Frederic Barth Dissemination Level: PU Acknowledgement This project is co-financed by European funds from the Fuel Cells and Hydrogen Joint Undertaking under FCH-JU Grant Agreement Number The project partners would like to thank the EU for establishing the Fuel cells and hydrogen framework and for supporting this activity.

2 R E P O R T Disclaimer The staff of DeliverHy partners prepared this report. The views and conclusions expressed in this document are those of the staff of the respective DeliverHy partner(s). Neither the DeliverHy partner(s), nor any of their employees, contractors or subcontractors, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, product, or process enclosed, or represents that its use would not infringe on privately owned rights.

3 CONTENTS EXECUTIVE SUMMARY... II 1 INTRODUCTION REGULATION CODE AND STANDARDS FOR EUROPE The regulatory landscape in Europe Standards landscape Key principles in standard development MAJOR CHALLENGES TO OVERCOME Regulatory obstacles Maximum size of pressure vessels Lack of references to ISO standards in Regulations Regulatory design requirements Obstacles related to International Standards Lack of ISO Standards for pressure receptacles larger than 3000L Periodic inspection and testing Service life IDENTIFICATION AND SELECTION OF AUTHORITIES AND KEY ORGANISATIONS Regulatory bodies Standardisation bodies European Gas industry FURTHER PLANS WITHIN THE SCOPE OF THE DELIVERHY PROJECT PUBLIC i

4 EXECUTIVE SUMMARY This report describes the relation and interaction between the Regulatory bodies and the Standardisation bodies and how regulation codes and standard work is organized in Europe. Major obstacles for introduction of high capacity transport equipment needed for efficient distribution of compressed hydrogen is identified and described. These obstacles will be discussed with representatives for relevant parties involved in regulation, codes and standard work. The FCH-JU DeliverHy project has identified a limited group of representatives from Authorities and key organisations that will be approached for discussions and consultations on the addressed topics. The target is to establish an as good as possible communication for best advises and support on how to get relevant regulation codes and standards updated and new technology implemented as soon as possible for the purpose described in the DeliverHy project. ii PUBLIC

5 1 INTRODUCTION Transport of dangerous goods, including compressed gases such as hydrogen, needs to be regulated in order to prevent, as far as possible, accidents to persons or property and damage to the environment, the means of transport employed or to other goods. However, with different regulations in every country and for different modes of transport, international trade in chemicals and dangerous products would be seriously impeded, if not made impossible and unsafe. Moreover, dangerous goods are also subject to other kinds of regulations, e.g. work safety regulations, consumer protection regulations, storage regulations, environment protection regulations. The ADR and UN Model regulation is very specific on classification and grouping of dangerous goods and less specific on technical issues. The ADR categorizes products in classes in function of their physical and chemical properties. Technical performance issues/requirements are left over to relevant international standardisation bodies. It is to the Regulators decision to decide on which standards to be referenced in the regulations. A good relation between the Regulatory bodies (regulatory experts) and the Standardization bodies (technical experts) are therefore of great importance when new technology, new materials, new standards or any update of existing references are necessary. PUBLIC 3

6 2 REGULATION CODE AND STANDARDS FOR EUROPE In order to ensure consistency between all these regulatory systems, the United Nations has developed mechanisms for the harmonization of hazard classification criteria and hazard communication tools (GHS) as well as for transport conditions for all modes for transport (TDG). It is in this context that the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) was done at Geneva on 30 September 1957 under the auspices of the UNECE, and it entered into force on 29 January The Agreement itself was amended by the Protocol amending article 14 (3) done at New York on 21 August 1975, which entered into force on 19 April The regulatory landscape in Europe The Agreement itself is short and simple. The key article says that apart from some excessively dangerous goods, other dangerous goods may be carried internationally in road vehicles subject to compliance with: the conditions laid down in Annex A for the goods in question, in particular as regards their packaging and labelling; and the conditions laid down in Annex B, in particular as regards the construction, equipment and operation of the vehicle carrying the goods in question. Annexes A and B have been regularly amended and updated since the entry into force of ADR. Recommendations on the Transport of Dangerous Goods, Model Regulations are developed under the auspices of the Sub-Committee of Experts on the Transport of Dangerous Goods (SCETDG). In addition, the United Nations Economic Commission for Europe (UNECE) administers regional agreements that ensure the effective implementation of these mechanisms as far as transport of dangerous goods by road, rail and inland waterways is concerned. The structure is consistent with that of the UN Recommendations on the Transport of Dangerous Goods, Model Regulations, the International Maritime Dangerous Goods Code (of the International Maritime Organization), the Technical Instructions for the Safe Transport of Dangerous Goods by Air (of the International Civil Aviation Organization) and the Regulations concerning the International Carriage of Dangerous Goods by Rail (of the Intergovernmental Organisation for International Carriage by Rail). For the transport of products belonging to the class covering hydrogen, the technical requirements applying to the transportable containers are to a large extent defined by reference to international standards. 4 PUBLIC

7 2.2 Standards landscape The international standards providing the technical requirements applicable to the transportable units for the transport of compressed hydrogen are developed by ISO/TC 58 Gas cylinders, ISO/TC58SC3 Cylinder design and ISO/TC58 SC 4 Operational requirements for gas cylinders. There are a number of standards addressing the different types of pressure vessels and their periodic inspection/requalification, but not all are referenced in the ADR regulation Key principles in standard development The key principles for developing ISO standards are as follows: (Extract from the ISO web page) ISO standards respond to a need in the market ISO does not decide when to develop a new standard. Instead, ISO responds to a request from industry or other stakeholders such as consumer groups. Typically, an industry sector or group communicates the need for a standard to its national member who then contacts ISO. ISO standards are based on global expert opinion ISO standards are developed by groups of experts from all over the world, that are part of larger groups called technical committees. These experts negotiate all aspects of the standard, including its scope, key definitions and content. ISO standards are developed through a multi-stakeholder process The technical committees are made up of experts from the relevant industry, but also from consumer associations, academia, NGOs and government. ISO standards are based on a consensus Developing ISO standards is a consensus-based approach and comments from stakeholders are taken into account. In cases the ISO organisation is not dealing with specific topics of interest for Europe, Europe has the possibility to make European EN standards and have these referenced in the ADR. This will in case take care of the European interest, but can easily represent an obstacle when later on discussing a global harmonization of the same topic. Introduction of more hydrogen into the global community is still in an early stage of deployment of hydrogen into the community, which represents both challenges and opportunities regarding Regulation, Codes and Standard work on a global level. PUBLIC 5

8 Development of ISO standards for pressure vessels covering all types of applications relevant for compressed hydrogen is therefore of great importance. If too many national, regional or continental regulations will be developed for solving a temporary local challenge, it might quickly develop into a hurdle when coming to global harmonisation of the same topics, as a global harmonisation process must take into consideration already existing and valid national, regional or continental regulations unless they are voluntarily withdrawn. Hydrogen as an energy carrier in the community is still in an early stage and larger pressure vessels carrying high pressure hydrogen have still the opportunity to become harmonized on a global level if sufficient effort is given to developing ISO standards before national, regional or continental standards becomes into force. 6 PUBLIC

9 3 MAJOR CHALLENGES TO OVERCOME At this stage of the DeliverHy the project has identified that introduction of transport units based on pressure vessels larger than cylinders (>150L), made of composite material and designed for a pressure higher than commonly used in the gas industry today, will increase the payload and by that improve distribution economy for hydrogen and reduce the Green House Gas (GHG)-impact significantly. The DeliverHy project has so far identified 6 major obstacles for introduction of higher capacity transport modules in Europe. Restriction on maximum size of pressure vessels Lack of reference to existing ISO standards in Regulations Regulatory design requirements (clarification needed) Lack of ISO standards for pressure vessels larger than 3000L Inappropriate requirements on periodic inspection and testing Inappropriate requirements on how to determine service life 3.1 Regulatory obstacles In the ADR there is a strict adherence to the definitions. Lack of a definition for the size or form of use can prevent use of some pressure vessels. Of greatest importance and relevance is the definition of: Cylinder. A transportable pressure receptacle of water capacity not exceeding 150 liters Tube. A seamless transportable pressure receptacle of water capacity exceeding 150 liters but not more than 3000 liters Pressure receptacle. Collective term that includes cylinders, tubes and bundles of cylinders. Bundles of cylinders. An assembly of cylinders that are fastened together and which are interconnected by a manifold as a unit. The total water shall not exceed 3000 liters Maximum size of pressure vessels In existing ADR and UN Model Regulations there is no pressure receptacle with volume exceeding 3000 Liters capacity. A new type of pressure vessel will have to be defined and implemented into the regulations or alternatively the definition of tube extended with regards to volume. At the time of making the first versions of UN Model regulation there was no need for defining seamless receptacles larger than 3000 Liters, as there was no technology available that could make them larger. Today the technology is available PUBLIC 7

10 for pressure vessels much larger than 3000 Liters, so at the moment lack of definition is a real obstacle in the ADR and UN Model Regulation. New type of pressure vessel has to be defined in ADR/UN Model Regulations for pressure vessels larger than 3000L Lack of references to ISO standards in Regulations In latest revision of ADR and UN Model Regulations there is no reference to ISO standards, even though there is ISO standard available covering both Cylinders and Tubes up to 450 Liters New ISO standards for pressure vessels in composite material is under development (ISO 17519) I for water volumes up to Liters and 100 MPa. This work is initiated by the industry to be able to support the developing hydrogen market with high capacity material for efficient hauling of hydrog Implement as soon as possible available and new ISO standards to the ADR/UN Model Regulations Regulatory design requirements In ADR and UN model regulations pressure vessels are grouped as follows: UN cylinders (ADR 6.2.2) non-un cylinders, general requirements (ADR 6.2.3) non-un cylinders that are built to referenced standards (ADR 6.2.4) non-un cylinders not built to referenced standards (ADR 6.2.5) 8 PUBLIC

11 Only for the last group the minimum burst/test pressure ratio, = 2.0 (= 3.0 x working pressure) is required (ADR ). This opens up for any standard to define and judge its own minimum burst/test pressure ratio. For permanently mounted pressure vessels in the automotive industry, a minimum burst/test ratio = 1.5 has been used for years for carbon fiber based cylinders, without any issues directly related to lack of performance of the composite material over the lifetime of the vehicles. Hydrogen requires a development of an infrastructure operating at higher pressure. Higher pressure and larger diameter pressure vessels will both lead to thicker and more robust composite structures less sensitive to external impact and more fire resistant and by that a reduction in the minimum burst/test pressure ratio will be proposed. This topic has to discussed and agreed upon by both the regulatory bodies as well as the standardization bodies. There are NO specific design requirements for pressure vessels in ADR or UN Model Regulation for pressure vessels designed in accordance with a referenced standard A regulatory change in many cases might therefore be a question about accepting a standard as a reference in ADR and UN-model regulation. This might call for a principle discussion between the Regulatory bodies and Standardization bodies on criteria for having an ISO standard reference in the ADR and UN Model regulations 3.2 Obstacles related to International Standards Lack of ISO Standards for pressure receptacles larger than 3000L Initiative has been taken and an expert Group has been established on the topic. The scope of work for the new standand is to to cover up to 10000L and pressure up to 100MPa. A Committee Draft of the new standard has been approved and will be discussed in coming meetings in the ISO TC 58/SC3/WG35 and in the next TC 58/SC3 meeting based on a request by the Chairman of the ISO TC58/SC3 for an update on technical development achieved by the composite industry over the last years Periodic inspection and testing For Europe, ADR makes the use of a referenced standard mandatory for periodic inspection and testing and requires of EN ISO 11623:2002 to be applied (except clause 4) PUBLIC 9

12 Furthermore, for pressure vessels in composite material, ADR refers to the competent authority for defining periodic inspection frequencies as follows: In the packing instructions (P200, cl. 2) d) includes the following: NOTE: For pressure receptacles which make use of composite materials, the periodic inspection frequencies shall be as determined by the competent authority which approved the receptacles. Additionally, it is to be noted that the UN committee (SCETDG) in charge of proposing revisions of the model regulation (see 4.1) agreed in November 2012 to request the revision of the above Note as follows: NOTE: For pressure receptacles which make use of composite materials, the maximum test period shall be 5 years. The test period may be extended to that specified in Tables 1 and 2 (i.e. up to 10 years), if approved by the competent authority of the country of use. The adoption of this revision is likely to encourage the imposition by national authorities of specific methods in function of the test period requested. Such requirements should be part of the applicable standard covering design and manufacturing Service life For pressure vessels in composite material, ADR also refers to the competent authority for defining service based on a NOTE 2 in ADR : NOTE 2: After the first 15 years of service, composite cylinders manufactured according to these standards, may be approved for extended service by the competent authority which was responsible for the original approval of the cylinders and which will base its decision on the test information supplied by the manufacturer or owner or user. It is to be noted that the UN committee (SCETDG) in charge of proposing revisions of the model regulation agreed in November 2012 to request the revision of the above Note 2 as follows: NOTE 2: The service life of a composite cylinder shall not be extended beyond its initial approved design life. Regardless of the cylinder design life, composite cylinders shall not be filled after 15 years from the date of manufacture, unless the design has successfully passed a service life test programme. The programme shall be part of the initial design type 10 PUBLIC

13 approval and shall specify inspections and tests to demonstrate that cylinders manufactured accordingly remain safe to the end of their design life..the service life test programme and the results shall be approved by the competent authority that was responsible for the initial approval of the cylinder design. The notion behind the proposed revision ofnote 2 of ADR is that it is up to the competent authority to define the additional tests required to allow use beyond 15 years is questionable. Such requirements should be part of the applicable standard covering design and manufacturing. PUBLIC 11

14 4 IDENTIFICATION AND SELECTION OF AUTHORITIES AND KEY ORGANISATIONS To discuss the above listed obstacles, DeliverHy realize that the communication with all relevant parties is a very time consuming process. The topics addressed are challenging from a regulatory standpoint, and will need a systematic approach by a step by step confidence building process, well supported and documented by other FCH-JU projects and other R&D activities going on. To be able to have the topics addressed, and to take advice on how to move foreward, DeliverHy has identified the following Authorities and key organisations: 4.1 Regulatory bodies The following regulatory bodies is and will continuous be consulted on any issues related to ADR and UN model regulation The German Authority Bundesministerium für Verkehr, Bau und Stadtentwicklung (BMVBS) in Bonn, known for its competence in ADR. Norwegian Directorate for Civil Protection (DSB) in combination with Det Norske Veritas (DNV) as independent foundation with the purpose of safeguarding life, property, and the environment. DNV is delegated technical responsibility by DSB on specific ADR related topics and has also developed methodology on Qualification of new technology. 4.2 Standardisation bodies The most relevant ISO Technical Committee (TC) is the TC 58 Gas Cylinders. Within this TC, there are 2 Subcommittees of relevance for the DeliverHy. SC 3 Cylinder Design SC 4 Operational requirements Partners in DeliverHy are active in both subcommittees and several working groups within each subcommittee, which will ease the communication on all topics addressed by DeliverHy 4.3 European Gas industry Air Liquide and Linde both have long experience from hauling compressed hydrogen in steel cylinders and tubes, and they both have indicated strong interest for the improvements in hauling efficiency the larger pressure vessels in combination with higher pressure can give. Both companies are very active in the relevant ISO standardisation committees. 12 PUBLIC

15 We will in addition consult the European Industrial Gases Association (EIGA), in particular their internal working group dealing transport issues with the following focus To ensure that EIGA members interests are taken into account in international regulations such as the UN Model Regulations, ADR and European Directives. To review accidents and incidents, determine the causes and propose ways to avoid re-occurrence. To provide guidance on legislation and codes of good practice for transport operations PUBLIC 13

16 5 FURTHER PLANS WITHIN THE SCOPE OF THE DELIVERHY PROJECT Together with the selected authorities and key the key organizations identified for the purpose of described in this report, a strategy plan on how to implement the needed changes will be established and reported in DeliverHy delivery D7.2 and communication and harmonization efforts will be documented in DeliverHy delivery D 7.3. These reports will at least describe possible routes to be followed together with a timeline that will go beyond the timeframe of the FCH-JU DeliverHy project (ends Dec 2013) 14 PUBLIC