NREL is a national laboratory of the U.S. Department of Energy, Office of Energy 

Efficiency & Renewable Energy, operated by the Alliance for Sustainable Energy, LLC.

Contract No. DE-AC36-08GO28308

Codes and Standards 

Requirements for 

Deployment of Emerging 

Fuel Cell Technologies

R. Burgess, W. Buttner, and C. Rivkin

Technical Report

NREL/TP-5600-52641

December 2011
NREL is a national laboratory of the U.S. Department of Energy, Office of Energy 

Efficiency & Renewable Energy, operated by the Alliance for Sustainable Energy, LLC.

National Renewable Energy Laboratory

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Contract No. DE-AC36-08GO28308

Codes and Standards 

Requirements for 

Deployment of Emerging 

Fuel Cell Technologies

R. Burgess, W. Buttner, and C. Rivkin

Prepared under Task No. H274.7310

Technical Report

NREL/TP-5600-52641

December 2011
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Executive Summary

The objective of this NREL report is to provide information on codes and standards that would 

ease the implementation of emerging fuel cell technologies. This information should help project 

developers, project engineers, code officials and other interested parties in developing and 

reviewing permit applications for regulatory compliance.

Specifically, this report reviews the codes and standards of two emerging hydrogen powered fuel 

cell technology markets; forklift trucks and backup power units. It includes hydrogen indoor 

fueling equipment and outdoor bulk hydrogen storage systems associated with these markets.

The fuel cell backup power units fit well in applications where a power outage would have 

serious negative consequences and have high reliability, low maintenance, and clean operation. 

Hydrogen powered fuel cell forklift trucks are becoming cost competitive with battery powered 

ones due to productivity gains that offset the costs of converting the trucks to hydrogen and 

installing the fueling infrastructure. The Defense Distribution Depot Susquehanna Pennsylvania 

(DDSP) converted half of their fleet of eighty forklift trucks to run on hydrogen-powered fuel 

cells in 2009. The Marine Corps Logistics Base (MCLB) located in Barstow, CA will install a 

hydrogen powered fuel cell power plant to be used for backup power at the base fire station. The 

DDSP installation involves the installation of bulk liquefied and gaseous hydrogen storage 

facility, construction of indoor hydrogen dispensers, and the forklift truck conversion. The 

MCLB installation requires the installation of a stationary fuel cell and the associated hydrogen 

storage. The DDSP installation is more complex and uses both cryogenic hydrogen storage and 

high-pressure gaseous hydrogen storage. The operation of the DDSP installation also involves 

far more personnel. The bulk hydrogen storage system must be refilled and maintained. The 

dispensing systems must be operated by trained personnel. The forty hydrogen-powered forklifts 

require forklift operators. Additionally, the forty forklifts must be maintained by personnel from 

the two companies that performed the forklift conversions or provided new forklifts. Twenty of 

the forklifts in operation were conversions of existing forklift trucks and twenty are new forklift 

trucks. The operation of the fuel cell at MCLB requires only infrequent replenishment of the 

hydrogen fuel.

As a result of the differences in the complexity of these two operations, the codes and standards 

requirements they are subject to vary significantly and the level of effort required to achieve 

regulatory approval also varies proportionately. In both cases, the Authority Having Jurisdiction 

(AHJ) is the facility owner. They are both Department of Defense (DoD) facilities subject to the 

Unified Facilities Criteria 03-600-1 Fire Protection Engineering for Facilities. This document 

contains safety requirements but also refers out to and requires compliance with the International 

Building Code (IBC) and the National Fire Codes (NFC).
iv

Table of Contents

I. ....................................................................................................Introduction Page 1

II. ............................................The Defense Depot Susquehanna, PA (DDSP) Page 1

II.1 ...............................................The DDSP Hydrogen Powered Forklift Deployment

II.1.1................................................... Site Visit and Review of DDSP Site Operations

II.1.2 .................................................. The Hydrogen Dispensing and Storage Facility

II.1.3..........................................................................The Hydrogen-Powered Forklifts

II.1.3.1.......................................................... Comparison to Battery Powered Forklifts

II.1.3.2...............................................................................................Forklift Operators

II.1.4................................................................Events, Failures, and Incidental Issues

II.2 .......................................Comprehensive codes and standards evaluation Page 9

I.2.1 ...............................................................................................Absence of Criteria

II.2.2..................................................................................................Existing Facilities

II.2.3 .....................................................Summary of UFC Code Compliance Analysis

II.3 ............................................................. Recommendations on Compliance Issues

III ........................................ The Marine Corps Logistics Base Barstow, CA Page 32

III.1..................The MCLP Proposed Stationary Fuel Cell Backup Power Deployment

III.1.1............................................ Site Visit and Review of the MCLB Site Operations

III.1.2.............................................................. Incidental Issues/Site Permitting Issues

III.2.................................................Comprehensive codes and standards evaluations

IV ................................................................................................. Conclusions Page 47
1

I Introduction

The deployment of hydrogen fuel cell systems is expanding as a clean and efficient alternative to 

fossil fuels. Fuel cells have been shown to be a cost-effective alternative to conventional power 

systems. Fuel cells have found applications in backup power systems for buildings, power 

systems for electric-drive forklifts, lighting, backup power in the communication industry, as 

well as power systems for passenger and commercial road vehicles. One impediment for facile 

deployment is that permitting officials are oftentimes unfamiliar with these new technologies, 

even though the underlying codes and standards have been developed. Herein we review the 

deployment of two emerging hydrogen technologies--hydrogen powered forklifts and hydrogen 

powered stationary fuel cells for backup power. These two projects are at different levels of 

maturity. Whereas the hydrogen powered forklift deployment is an on-going and growing 

deployment, the implementation of the stationary fuel cell for backup power has been proposed 

but remains in the planning phase. A description of the two technologies will be presented, 

along with issues and lessons learned encountered during the permitting process and deployment, 

as well as an assessment of the field performance of the technology employed for the forklift 

project. The main focus of this report, however, is to facilitate the permitting process by 

providing to officials, end-users and other interested parties a comprehensive survey of the 

pertinent codes that apply to the two case studies addressed herein.

II The Defense Distribution Depot Susquehanna, PA (DDSP)

The Defense Distribution Depot Susquehanna, Pennsylvania (DDSP) is a major distribution 

depot operating in support of Department of Defense (DOD) off-shore activity, including 

Afghanistan and Iraq and is managed by the Defense Logistics Agency (DLA) of the DOD. The 

material support does not include munitions, fuels, or other materials that could pose significant 

fire or reactivity hazards. The DDSP also does not store food, which eliminates the need for 

refrigeration or air-conditioning and allows for the use of propane powered forklift trucks. 

Material within the depot is loaded on to trucks for road transport to an air deployment center. 

Operation at DDSP is essentially 24/7 around the clock, but the heaviest activity is during the 

weekday day shift with lower activity during evenings, nights, and weekends. The DDSP 

operations are critical to DOD, and the loss of the building and its inventory management 

capability would have a significant adverse impact on the ability of DOD to fulfill its mission in 

Iraq, Afghanistan, and other operations. Thus, the implementation of new technology, such as 

hydrogen-powered forklifts, was rigorously scrutinized for assurances of safe and reliable 

deployment and operation. Although some buildings within the Susquehanna complex are 

nearly 100 years old, the DDSP Storage facility is approximately 20 years old. The distribution 

depot is a building of 1.8 million square feet, with an elevated ceiling with a height of 25 feet or 

greater.

An overview of site operations and a review of the underlying codes and standards as they 

pertain to the deployment of hydrogen-powered fuel cells are presented below.
2

II.1 The DDSP Hydrogen-Powered Forklift Deployment

The DDSP was selected for deployment of hydrogen-powered forklifts. The DDSP project is 

part of a larger alternative energy deployment program supported by the Department of Defense,

to utilize hydrogen powered forklifts within DLA facilities. The DDSP site was selected by the 

DLA to demonstrate the viability of hydrogen-powered forklifts and the required support 

systems, especially indoor hydrogen dispensing, and to assess the performance relative to 

conventionally-powered forklifts. The DDSP warehouse is very large and as such it has been 

argued that it simulates the characteristics of an outdoor space for hydrogen releases 1.

 Personnel

from the NREL Codes and Standards Group performed a third party codes and standards 

compliance review during the initial permitting process for this project in 2008 2

. The size of the 

original hydrogen power forklift fleet during the initial deployment phase was 40. Although the 

first phase of the project was completed in February 2011, the hydrogen-powered forklift fleet 

remains operational and has expanded to 55 forklifts, including the original 40. The use of 

hydrogen-powered forklifts and associated support systems (dispensing, storage) at the DDSP 

represents an active, on-going, and successful deployment of emerging fuel cell technologies. 

Although the site is self-insured, Factory Mutual did set up and held a meeting at the DDSP for 

formulating parameters for underwriting other hydrogen deployments.

II.1.1 Site Visit and Review of the DDSP Site Operations

On August 4, 2010 Carl Rivkin, Robert Burgess, and William Buttner of the NREL Hydrogen 

Codes and Standards Group made a site visit to the DDSP to review and assess the on-going 

hydrogen fuel cell powered forklift program. Mr. Robert Skinnell, Equipment Services Manager 

at the DDSP, was the primary point of contact and escort for the duration of the site visit. The 

focus of the site visit was to review the forklift operations with emphasis on safety and on codes 

and standards compliance. The occurrence of possible adverse and unexpected events was 

specifically addressed during the site visit. The building and operations are self-insured. 

Nevertheless, loss of the DDSP support operations could have severe adverse impact on DOD 

off-shore operations. In addition to safety and compliance to codes and standards, operational 

efficiency (e.g., performance, reliability, design strengths, design limitations, operator’s 

perceptions) and future plans of the hydrogen powered forklifts were addressed during the site 

visit. Information exchange was achieved primarily through interaction between NREL and 

DLA site personnel.

The facility was not air conditioned, except for some office areas, and thus could get quite warm. 

On the day of the NREL site visit, the outdoor temperature was above 90oF, and there was also 

high humidity. Large ceiling fans were mounted on the ceiling for ventilation. The potential 

impact of the large ceiling fans on other fire suppression systems (e.g., the ceiling fans may alter 

air and heat dispersion patterns which then might impact triggering of sprinkler systems) was 

discussed. Because of these concerns a decision was made by site personnel that the fans are to 

be turned off in the event of a hydrogen release. Although the outdoor temperature was hot, the 

indoor temperature within the facility was not overly uncomfortable. Apparently however, 

temperatures can still get quite warm within certain spaces (e.g., loading and unloading trucks), 
3

which is exacerbated by the heat generated from the fuel cells. Heaters are used in winter in the 

DDSP facility to maintain a reasonable indoor working temperature during the cold months.

The deployed Material Handling Equipment (MHE) includes approximately 80 forklifts. Of 

these, there are 20 hydrogen-powered forklifts (Forklift Model 1) that were provided by 

Manufacturing Team 1, comprised of a forklift manufacturer and a fuel cell stack manufacturer 

(Fuel Cell Developer 1), and 20 hydrogen-powered forklifts (Forklift Model 2) provided by 

Manufacturing Team 2, which was also comprised of a forklift manufacturer and a fuel cell stack 

manufacturer (Fuel Cell Developer 2). The hydrogen-powered forklifts were retrofitted from 

battery-powered forklifts that were modified to accommodate the fuel cell power systems. Both 

forklift systems were 4000 pound forklifts. Forklift Model 1 system had a slightly wider frame, 

which had an impact on performance by allowing the installation of alternative, larger capacity 

fuel tank. The deployment of the 40 forklifts was part of a 2-year deployment supported by the 

Department of Defense 3 and was initiated in February 2009 and scheduled for completion in 

February 2011. The remaining 40 forklifts are mostly battery powered with a few systems 

powered by propane. Robert Skinnell indicated that he plans to continue and expand the 

deployment of the hydrogen powered forklifts after completion of the pilot program in February 

2011. This is the case, and as of March 2011, the hydrogen forklifts were still operational and 

the fleet has expanded to 55. The additional 15 forklifts were a third model type [R. Skinnell, 

Personal Communication March 16, 2011]4 using Fuel Cell Developer 2 fuel cells.

Mr. Henry Hoffman, Fire Chief at the DDSP facility, was involved with the initial approval 

process for the hydrogen-powered forklift demonstration. At the beginning of the proposed 

deployment Mr. Hoffman stated that he had a concern about the operation of hydrogen fuel cell 

forklifts within the facility, due in part to a lack of historical data on their operation, especially a 

lack of data on their safety record. He believed that the critical mission fulfilled by the depot 

necessitated caution. During the planning phase of the project, he was opposed to the proposed 

indoor fueling. Ultimately, however, indoor fueling systems were installed within the DDSP. 

The fueling system included the hydrogen dispensers (also called the fueling station) which 

delivery to the hydrogen forklifts. At one time a centrally located fueling station within the 

facility was proposed, but this would have required piping of hydrogen from the outdoor storage 

facility to the indoor dispensing station. To minimize the piping network, a decision was made 

that required that the dispensing station to be located on the indoor wall adjacent to the outdoor 

storage facility. The down side to this decision was that a portion of the fuel cell forklift fleet 

would operate several hundred meters away from the dispensing units, and thus require 

additional transit time.

The safety systems installed with the dispenser units were also discussed. Hydrogen sensors are 

installed around the dispensing units (one above and one internal to each dispensing unit). The 

sensors are designed to shut down the flow of hydrogen if an upset condition is detected. Mr. 

Hoffman stated that he insisted that the sensor alarms would also be wired into the site fire alarm 

system; this appears to be the case for the operational system. The outdoor storage system also 

has sensors including heat trace sensors. However, site personnel reported that there had been no 

significant safety incidents associated with the operations of the forklifts, the indoor dispensing, 
4

and the outdoor hydrogen storage system. Based upon the design of the dispensing system and 

on the operational experiences at the DDSP, Mr. Hoffman stated that indoor fueling and 

hydrogen forklift operation could be performed safely at the facility. As of March, 2011, the 

forklift and support systems have been safely operating at DDSP for nearly 2 years 5

.

II.1.2 The Hydrogen Dispensing and Storage Facility

Refueling of the hydrogen forklifts is performed at one of two hydrogen dispensing units, both of 

which are located together along an inside wall adjacent to the outdoor hydrogen storage facility. 

Maintenance and design of the dispensing units and storage facility were and remain the 

responsibility of a commercial hydrogen producer and supplier. Inspections and required 

maintenance are performed on a weekly basis. A contract is in place with the hydrogen supplier 

to provide hydrogen and to support the maintenance activity of the site dispensing and storage 

system. The hydrogen supplier also maintains the safety system for the dispenser and storage 

tanks. The safety system includes the use of hydrogen detectors, but no specific details were 

available during the site visit on the maintenance schedule of the dispensing units or the sensors. 

It can be assumed that calibration is performed as specified either by the sensor manufacturer or 

by the hydrogen supplier’s policy for safety sensors.

A queue of three forklifts, all of the Manufacturer Team 2 design, was waiting for fuel at the 

time of the NREL visit. The Forklift Model 2 tank capacity was 0.5Kg, but each of the three 

trucks took only between 0.25 and 0.35 Kg during the fill. Multiple refuelings of the Forklift 

Model 2 units are required during a shift. With the exception of connecting the dispenser fueling 

hose to the forklift, the fueling operation is automated and fail-safe in that if proper connections 

or communication is not established between the forklift and dispenser, fueling will not proceed. 

Hydrogen refueling was performed by a dedicated personnel specifically assigned to operate the 

dispensing units, although Robert Skinnell was proposing to have lift operators refuel their own 

vehicles. This is currently being negotiated with the forklift operator union. If approved, 

operators will receive thorough training on operation of the dispensers. The training will also 

include a transition period during which time a person highly trained in the dispenser operations 

will be present during all fills performed by lift drivers. Refueling by forklift operators would 

allow for opportunistic refueling and lower the number of required personnel to perform site 

operations, which could represent a significant cost savings. The dispenser operator reviewed 

the fueling procedure with NREL personnel. The dispenser nozzle is attached to the forklift (a 

mechanical slider secures the nozzle in place). Upon installation of the nozzle, feedback 

between the forklift and the dispenser verifies the connection and performs critical measurements 

(e.g., the pressure in the storage tank). Once the checkout is complete, the fueling operation can 

proceed, which for the Forklift Model 2 system requires approximately 40 seconds. Apparently 

forklift information is automatically logged during the fill (presumably to keep track of hydrogen 

use, lift ID number, hours of operation and other parameters). While NREL personnel were 

present, both dispensers successfully completed a fill. However, when a second fill was 

attempted on dispenser 1 (when facing the wall, the dispenser on the left) the system failed to get 

appropriate pressure feedback; the forklift had to move to the other dispenser to perform the fill. 
5

The fill was completed using dispenser 2 without a problem. Later in the day, Mr. Skinnell 

independently noted to the NREL group that one dispenser was less reliable than the other, and 

indicated that the problem was associated with the Infra Red (IR) ring, which provides 

communication between the forklift and dispenser unit. In contrast to the Forklift Model 2

design, the Forklift Model 1 system has a tank capacity of 1.5Kg of hydrogen (at 5000 psi, 

although the storage tank can operate up to 10000 psi) and a fill can take several minutes. 

However, with a full tank, the Forklift Model 1 system can normally operate on a full 8-hour 

shift without refueling.

No release or adverse event was ever recorded due to the dispensing units. However, during the 

development of the outdoor storage facility, hydrogen tube trailers were temporarily used to keep 

the DDSP facility supplied with hydrogen. The trailers were outdoor systems. At one point 

during the development of the outdoor storage facility a hydrogen sensor installed within the 

control box of the tube trailer system indicated the presence of hydrogen. A subsequent 

inspection with handheld monitors confirmed a leaky connection. There was no significant 

adverse event (fire, bursting, etc.) as a result of this event. Although only minimal details on this 

release were available from DDSP personnel, additional details of this are reportedly on-file 

within the NREL Technology Validation program 6

. The hydrogen supplier would also have 

additional details, but their records were not available to NREL. Nevertheless, it is noted herein 

that the use of a hydrogen sensor as an independent component of the safety system successfully 

warned of a leak in the outdoor storage facility prior to an adverse event.

The DDSP hydrogen storage facility is outdoors along the wall adjacent to the indoor dispenser 

units. The storage units are approximately 30 feet from the building and comprised of a large 

storage tank with a capacity in excess of 9000 gallons of liquid hydrogen. This tank is connected 

to a bank of gaseous hydrogen storage tanks. The hydrogen is piped as a gas to the dispensers. 

There is no on-site production, so all hydrogen is transported to the site with land vehicles. 

Steam Methane Reforming for on-site hydrogen production had been considered for the DDSP. 

However, there were purportedly operational issues with the SMR process at a DLA facility in 

Georgia, and therefore all hydrogen is trucked in to the DDSP facility. The delivered cryogenic 

hydrogen has worked out well for the DDSP. An unofficial estimate for the cost of hydrogen 

was $7/Kg, which, according to the Forklift Model 1 field engineer present at the DDSP facility 

during the NREL site visit, corresponds to approximately $1.00 per hour of operation. These are 

only rough estimates however, and neither cost parameter has been validated. The storage 

facility includes pumping stations. As with the dispensers, design, operation, and maintenance 

are performed by the hydrogen supplier. It was reported by DDSP personnel that the initial 

development of the storage facility required extensive maintenance work by the hydrogen 

supplier. However, Robert Skinnel noted that at no time was hydrogen unavailable to support 

the required operations within the Depot, although at one time, one of the two dispensers was 

down for several days over a weekend, and thus required site operations to proceed without a 

backup fueling facility. Robert Skinnell noted that the hydrogen storage capacity greatly exceeds 

the demands for all the hydrogen forklift operations. Thus there is sufficient hydrogen capacity 

to support other hydrogen technologies, including the hydrogen powered bus which had been
6

scheduled for delivery to the DDSP, as well as the possible expanded use of hydrogen powered 

forklifts within the DDSP. Additional hydrogen powered forklifts and other vehicle types have 

since been acquired by the DDSP, but the hydrogen bus program did not materialize 7.

II.1.3 The Hydrogen-Powered Forklifts

At the time of the NREL site visit, there were two different model hydrogen-powered forklifts in 

operation at the DDSP, including 20 forklifts provided by Manufacturing Team 1 and 20 forklifts 

provided by Manufacturing Team 2. Two groups of DDSP forklift operators have been trained 

for operating the prototype forklifts. One group is dedicated to the Forklift Model 1 system, the 

other group to the Forklift Model 2 system. Operators are typically assigned a forklift at the 

beginning of the shift. In other words, as a general rule they do not operate “their personal” 

truck, although there seems to be some exceptions to this (specifically, one driver has chosen one 

truck as her own, in part because she maintains it cleanliness and readiness to her liking).

Both the Forklift Model 1 and Forklift Model 2 vehicles are specified for 4000 pound capacity, 

although the Forklift Model 1 units have a wider platform. Forklift Model 1 units were installed 

on forklift platforms with a wider base, which accommodated a 1.5 Kg capacity storage tank. In 

contrast, the Forklift Model 2 units had a 0.5Kg capacity storage tank. The difference in tank 

capacity had a significant impact on the capability of the respective forklifts. The Forklift Model 

1 system with a 1.5Kg tank could operate 8 to 10 hours on a single fill, predicated of course on 

the specific work load. Nevertheless, operators felt they could run the truck for a full shift (8 and 

possibly even 10 hours) on a single fill. This was viewed as a very important positive feature for 

Forklift Model 1 and dramatically affected perception of the relative overall performance of the 

two forklift models. In contrast, the Forklift Model 2 system, with a 0.5 Kg capacity tank 

required multiple fills for a single shift. The NREL team was informed that Fuel Cell Developer 

2 projected 8 hour operation time on a single fill had they been able to install a 1.5Kg hydrogen 

storage tank on the forklift. Operator ratings, hence salaries, are predicated upon their 

productivity. Forklift down-times, such as refueling or battery change outs, will adversely 

impact productivity. Thus, at best, operators viewed the multiple fills as an inconvenience, but 

one that will decrease their productivity. In contrast to operator’s perception, site personnel 

indicated that Forklift Model 2 outperformed Forklift Model 1 in terms of overall reliability and 

maintenance requirements.

During the NREL visit, representatives from the Fuel Cell Developer 1 and Forklift Model 1 

were on-site at the DDSP facility performing regular/routine maintenance on a forklift. 

Representatives of Manufacturing Team 1 have a regular presence at the DDSP facility, 

maintaining their fleet of forklifts. During the NREL site visit, the compressor that controls air 

intake was being overhauled. However, the maintenance by Fuel Cell Developer 1 personnel did 

not affect operator’s use of the forklifts and forklifts were available for all required activity. The 

Manufacturing Team 1 site representatives described issues and performance details associated 

with the operation of the Forklift Model 1 system. Currently, fuel cells with over 4000 hours of 

operation are in use at the DDSP facility, and the proposed/expected lifetime is 10000 hours. 

When new, the open circuit potential of each cell (there are 90 cells in each fuel cell pack) is 
7

0.9V; the lifetime is defined as when one cell is at a Voc of 0.6 V. The cells are capable of 

outputting 50 amps at 72V, but the voltage is regulated down to 36V with internal circuitry. An 

internal capacitor pack levels the power output under heavy demands. Chemical filters, possibly 

two in series, scrub the air intake. There are two hydrogen sensors installed within the case to 

monitor for leaks. These sensors would be good test candidates for the NREL Safety Sensor 

Test Laboratory 8.

II.1.3.1 Comparison to Battery Powered Forklift Systems

Hydrogen-powered forklifts are considered as potential replacements to conventional batterypowered forklifts. The conversion to fuel cell systems can have significant advantages 

associated with improved productivity. There are several significant short-comings associated 

with the use of battery packs in forklifts. Recharging and change out times are obvious issues. 

Battery maintenance is another concern. Conventional battery systems will need periodic 

replacement of water, and failure to maintain proper water levels will shorten the working life of 

the battery pack. In response to this, several years ago the DDSP obtained Gel-Pack battery 

systems for use in battery-powered forklifts. Since the GelPack is a sealed design, this battery 

system does not require water replenishment. Circumventing the water maintenance 

requirements was viewed as highly advantageous because water management, which as a manual 

operation, was not always performed as needed, resulting in a shortened battery lifetime. 

Unfortunately, the GelPacks however have aged, and whereas a new pack could hold sufficient 

charge for a full shift (or close to a full shift), the battery’s capacity degraded as the pack aged. 

Multiple battery pack change outs are now required to power a forklift for a full 8-hour in a shift, 

and this adversely impacts productivity. Since the GelPacks have decreased capacity that 

precludes 8-hour operation, another alternative battery pack system has been acquired. The new 

battery packs, which cost about $4000 per pack, are of the classic design that requires water 

replenishment. The new packs have, however, a capacity that can last for a full 8 hour shift of 

conventional forklift use. There have also been dramatic upgrades in the battery charging 

facility within the DDSP. A new, multimillion dollar facility for battery change out, charging, 

and maintenance is now on-line. A discharged battery pack can be removed from a forklift and 

replaced with a fully charged pack in about 4 minutes. Thus, the forklift operational time with a 

fully charged battery is comparable to the forklift operational time achieved with a full 1.5Kg 

capacity tank. The battery change-out time and hydrogen-fueling time are also comparable. 

Thus, loss of productivity due to “down times” is comparable for the hydrogen-powered and 

battery-powered forklifts. The new battery packs are expected to have a 5 year lifetime, 

although it is not yet clear whether the new batteries will maintain such large capacity after they 

have been in service for several years. In addition to rapid battery exchange, the new charging 

station has the capability of monitoring the state of the battery (including charging, water 

maintenance schedule, etc.) that will alert site personnel of the need to add water, although actual 

water maintenance activity will still be performed manually. Battery maintenance within the 

DDSP, including water management issues, are now specifically the responsibility of dedicated 

charging station personnel, and this adaptation has improved compliance to battery maintenance 

requirements. There remains one significant operational advantage of the hydrogen fuel cell 
8

forklifts relative to battery powered systems. The power, which the fuel cell will deliver will not

degrade during operation (i.e., as the hydrogen fuel in the tank is used), whereas the available 

power stored within the battery will degrade as the battery is discharged through use. The ability 

to maintain full operational power translates to increased productivity.

II.1.3.2 Forklift Operators

A critical review of forklift performance (real and perceived) was obtained from discussions with 

several operators. Specifically NREL personnel obtained feedback from three Forklift Model 1 

operators and two Forklift Model 2 operators. The perceived performance capabilities of Forklift 

Model 1 and Forklift Model 2 were significantly different. The major factor for this difference 

was the maintenance and operational requirements of the two designs. Forklift Model 1 was 

installed with a 1.5 Kg hydrogen storage tank, which allowed for 8 to 10 hours continuous 

operation, whereas Forklift Model 2 was installed with a 0.5Kg hydrogen storage tank, which 

required multiple refuelings per shift. Fueling operations translated into more downtime during a 

normal 8 hour shift, and this adversely impacts productivity (although operators were not 

penalized for downtime at the DDSP). The use of hydrogen powered forklifts was a deployment 

project, implemented in part to help develop products and markets for emerging technologies. 

Thus, prototype systems (that is, experimental, pre-production systems) were used. 

Nevertheless, operators of Forklift Model 1 expressed enthusiasm for the technology and would 

like to keep the system. The ability to maintain full power regardless of hydrogen level in the 

tank was viewed very highly. Conversely, Forklift Model 2’s internal diagnostic system 

(warning lights) was complicated and not intuitive. This, coupled with the multiple refueling 

requirements, led to a less than enthusiastic view of the forklift. The NREL team was informed 

that Fuel Cell Developer 2 projected 8 hour operation had they been able to install a 1.5Kg.

II.1.4 Events, Failures, and Incidental Issues

There have been no reportable releases of hydrogen that impacted or potentially impacted site 

operations or that posed a significant risk to the facility 9. Furthermore, overall performance of 

the support systems (storage and dispensers) and forklifts were such that the operation of the 

DDSP facility was not adversely affected. The hydrogen sensors at the dispenser detected no 

hydrogen releases; nor did NREL personnel hear of any releases detected by the sensors installed 

in the Forklift Model 1 (NREL personnel received no information indicating that sensors are or 

are not installed in the Forklift Model 2 trucks, but it is likely that some sensor technology is 

present). There were however, some less than ideal events and performance observations. One 

dispensing unit appears to have problems. This was even observed during our site visit when 

one truck had to move from dispenser 1to dispenser 2 for refueling. Although relocating to the 

second dispenser unit for refueling took only a couple of minutes (40 seconds or so for the actual 

fill), a significant impact could occur if the second dispenser failed. The nozzle was replaced, 

apparently due to support hardware associated with communication between the forklift and the 

dispenser. Robert Skinnell noted the existence of problems during the development of the 

hydrogen storage and transport system (to the dispensers), and that engineers for the hydrogen 

supplier made frequent trips to DDSP during the initial installation of the facility.
9

In terms of operation, the forklifts and infrastructure performed as well as conventional battery 

technology. Normal routine operations (refueling time and frequency during a shift) require 

comparable time to conventional systems (battery exchange time and frequency during a shift). 

The hydrogen support systems never had a failure that shut down operation. Nor had there been 

an event associated with the hydrogen support systems that posed a safety risk. The safety 

sensors at the dispensers never had a false alarm. Safety sensors in the developmental (and 

temporary) outdoor storage system did identify a leak.

II.2 Comprehensive codes and standards evaluation

The list of codes and standards citations contained in Table 1. Code and Standards Citations for 

Bulk Hydrogen Storage Facilities and Indoor Hydrogen Dispensing Operationscontain the most 

commonly used codes and standards for the installation and operation of stationary hydrogen 

fuel cell power systems.

Table 1 is an extensive listing of codes and standards that apply to indoor hydrogen dispensing 

operations and hydrogen storage systems. The table is not a complete listing of all of the codes 

and standards citations but instead lists key requirements or sections of documents.

Unified Facilities Criteria (UFC 3-600-1, 26 September 2006) Fire Protection Engineering for 

Facilities, the Department of Defense document prescribes the use of the safety codes in the

following subsections when performing a fire safety analysis.

II.2.1 Absence of Criteria

The UFC gives the following guidance for determining which requirements apply to a specific 

component or process. When a specific application is not covered by the criteria cited in the

UFC, follow national building codes, recognized industry standards, and standard engineering 

practices. In the absence of such technical information, contact the DOD component authority 

having jurisdiction (refer to paragraph 1-4.6).

Code review for the hydrogen fueling operation using the UFC directed codes.

USC, Title 15, Section 272, identifies the necessary consensus technical standards required to 

implement policy objectives and activities within the area of fire protection engineering for the 

DOD. Compliance with criteria issued in accordance with this UFC does not constitute an 

exception to the public laws. Fire protection criteria must conform to the requirements of this 

UFC, the National Fire Codes, published by the National Fire Protection Association (NFPA), 

except as modified by this UFC, and portions of the International Building Code (IBC), 

published by the International Code Council, as specifically referenced by this UFC. Additional 

criteria include portions of the Factory Mutual Global Property Loss Prevention Data Sheets 

(FM Global Data Sheets), as specifically referenced by this UFC. Buildings required to be 

accessible must meet the provisions of Federal Standard FED-STD-795, Uniform Federal 

Accessibility Standard (UFAS) at http://www.access-board.gov/ufas/ufas-html/ufas.htm, and the 
10

Americans With Disabilities Act Accessibility Guidelines (ADAAG) at http://www.accessboard.gov/adaag/html/adaag.htm

Note 1: UFC 1-200-01 identifies the base line building code as the International Building Code 

to be used for all DoD construction. NFPA 5000 Building Construction and Safety 

Code, State or Local building codes will not be used.

.

Note 2: Projects that have significant time delays between the award for design and the 

beginning of construction must be re-evaluated and corrected to comply with any new 

editions of criteria (including codes and standards) that have been published.

II.2.2 Existing Facilities

Existing facilities must meet the requirements of NFPA 101, Life Safety Code, for existing 

occupancies.

These requirements translate into the application of the following codes and standards:

1. International Building Code 2006 edition

2. NFPA 101 Life Safety Code 2006 edition

3. All NFC (NFPA) codes and standards as applicable, including NFPA 52 Vehicular Fuel 

Systems Code 2006 edition and NFPA 55 Standard for the Storage, Use, and Handling of 

Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, 

and Tanks 2005 edition.

In addition to the codes listed in the UFC the International Fire Code, International Fuel Gas 

Code and International Mechanical Code were reviewed because they contained provisions that 

dealt specifically with hydrogen safety. The 2006 editions (most recent) of the International 

codes were used in this review.

II.2.3 Summary of UFC Code Compliance Analysis

Based on the information submitted by the hydrogen supplier, the proposed hydrogen fueling 

operation would comply with the applicable code requirements as defined by Unified Facilities 

Criteria (UFC) (3-600-01 26 September 2006). Table 1. Codes and Standards for Bulk 

Hydrogen Storage Facilities and Indoor Hydrogen Dispensing lists codes and standards citations 

that would apply to the storage and dispensing operation. These citations were in effect during 

the pre-construction review period (May 2008). Since May 2008, several of these documents 

have been updated and NFPA hydrogen requirements have been consolidated into NFPA 2 

Hydrogen Technologies Code.

The following list includes key code compliance areas an evaluation of the code compliance 

status for these areas.
11

Sprinkler protection. The hydrogen storage would be entirely outdoors. Therefore, the 

proposed process would not add any additional storage to the building. Therefore, no new 

sprinkler system capacity requirements would be triggered.

UFC requires the following for automatic sprinkler systems.

“6-1.1 Automatic Sprinkler Protection

Complete automatic sprinkler protection must be provided for buildings that include personnel 

housing and lodging. NFPA 13 or NFPA 13R, Sprinkler Systems in Residential Occupancies up 

to and Including Four Stories in Height, sprinkler systems are permitted when listed for the 

specific use.”

The analysis is based on the assumption that the existing building complies with this requirement 

to provide automatic sprinkler system protection.

Ventilation. The size and number of openings in the building made it very difficult to measure 

volumetric flow rate through the building. Although no quantitative assessment has been made 

of the building ventilation, the site industrial hygienist has made qualitative assessments of the 

building ventilation. He felt the ventilation was adequate to allow for the dispersion of a 

hydrogen release if the large overhead ceiling fans that drive air downward were turned off.

In the event of a hydrogen release, the large overhead fans shall be turned off. This action 

should be incorporated into the standard operating procedures that define building operations.

Electrical. The proposed process meets the requirements of the National Electric Code NFPA 

70 as referenced in NFPA 52 and NFPA 55.

Life Safety Code. The proposed fueling system would not change the facilities life safety 

requirements or compliance status. The indoor fueling equipment is not in an egress path. The 

question was raised as to whether placing a hydrogen dispensing station indoors would obviate 

the path of egress closest to the dispenser. However, the dispenser is not located in the path of 

egress and therefore would not eliminate any existing egress paths.

Fire Alarm System. NFPA 72 requires that the alarm for the fueling system be tied into the 

existing system. This connection will be made before the system is operated. The fueling system 

will be shut down if the alarm is activated. The building should be evacuated as required in the 

plan required under IFC 2209.4 shown in the table of code requirements. The connection to the

existing system must be coordinated between the system designer/installer and the hydrogen 

supplier.

Hydrogen Storage System Siting Requirements. Drawings of the H2Fueling Station Layout 

in the final design package for the outdoor drawings show that the system would meet the tabular 

requirements shown in 11.3.2.2 from NFPA 55 shown earlier. Note that this system would have 

to comply with both the separation distances for liquefied hydrogen storage systems and gaseous 
12

systems because the liquid hydrogen is being vaporized and stored as gaseous hydrogen before 

being dispensed into the forklift vehicles.

Additional recommendations. The following recommendations were made during the preconstruction plan review. To ensure that this system is installed correctly and is operated safely 

will require extensive coordination with site personnel. Although the system design material and 

supporting information would show compliance with code requirements as defined in UFC 3-

600-1, this does not necessarily mean that the system will be installed as designed and that 

operational requirements will be met.

To ensure that the system is installed as designed and operated safely, it is recommended that a 

team be formed consisting of at least the Air Products project manager, the site facilities 

manager, and the site fire personnel that would perform at least the following functions:

Monitor the installation of the system

Monitor the pressure testing of the system after it is installed

Develop the required site emergency response and training plans

Document that the employees have been trained

State, in the emergency response plan, when the large overhead fans must be shut off to prevent 

any hydrogen release from dispersing

Document any incidents

And document when the system is not performing in the accepted performance range and take 

corrective action.

Table 1. Code and Standards Citations for Bulk Hydrogen Storage Facilities and Indoor 

Hydrogen Dispensing Operations list codes and standards that the project must comply with as 

a result of the UFC reference to the International Building Code (IBC) and the National Fire 

Codes (NFC). The IBC refers to the International Fire Code (IFC), International Mechanical Code 

(IMC) and International Fuel Gas Code (IFGC) that contain hydrogen specific requirements in the 

I codes.

Table 1. Codes and Standards Citations for Bulk Hydrogen Storage Facilities and Indoor 

Hydrogen Dispensing Operations.

Annual Inspections

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations 

(Compressed Gas Association, 2005)

7.0 Maintenance and Repair

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association, 2004)

9 Maintenance
13

International Fire Code (International Code Council, 2009)

406.2 Frequency

901.6.2 Records 

907.2 Inspection, Testing, and Maintenance

2206.2.1.1 Inventory Control for Underground Tanks

3204.5.2 Corrosion Protection

3205.4 Filling and Dispensing

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.2.15 General System Requirements

Balance of Plant

Piping & Tubing

ASME B31.3, Process Piping (American Society of Mechanical Engineers, 

2006)

F323.4(5) Specific Material Considerations-Metals

IX K305 Pipe

ASME B31.12, Hydrogen Piping and Pipelines

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations 

(Compressed Gas Association, 2005)

3.1 General

3.2 Piping Materials

5.0 Installation

5.1 Piping Installation General

5.2 Piping Installation Above Ground Installation

5.3 Piping Installation Underground Installation

International Fire Code (International Code Council, 2009)

2201.1 Scope

2209.3.2.3 Indoors

2209.3.2.6 Canopy Tops

3501.1 Scope

International Fuel Gas Code (International Code Council, 2009)

101.2.1 Gaseous Hydrogen Systems

704 Piping, Use, and Handling

705 Testing of Hydrogen Piping Systems
14

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.8 Installation of Piping and Hoses

9.9 System Testing

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

11.2.3 Piping, Tubing, and Fittings

CGA H-3 Cryogenic Hydrogen Storage (Compressed Gas Association, 

2006)

10.0 External piping

Pressure Relief

CGA S-1.3, PRD Standards Part 3 - Stationary Storage Containers for 

Compressed Gases (Compressed Gas Association, 2005)

5.3.2 Nonliquid Compressed Gases

International Fire Code (International Code Council, 2009)

2209.2.1 Approved Equipment

2209.5.4.2 Pressure Relief Devices

3003.3 Pressure Relief Devices

3203.2 Pressure Relief Devices

3203.3 Pressure Relief Vent Piping

3203.5.4 Physical Protection

3203.8 Service and Repair

3205.1.2.3.2 Shutoff Valves on Piping

International Fuel Gas Code (International Code Council, 2009)

703.3 Pressure Relief Devices

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

5.4 Pressure Relief Devices

5.6 Pressure Gauges

5.7 Pressure Regulators

9.6 Installation of Pressure Regulators

9.7 Installation of Pressure Gauges

14.6 Pressure Relief Devices

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

7.1.2.5 Pressure-Relief Devices

10.2.1 Pressure-Relief Devices
15

Valving & Fittings

ASME B31.3, Process Piping (American Society of Mechanical Engineers, 

2006)

IX K306 Fittings, Bends, and Branch Connections

IX K307 Valves and Specialty Components

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations 

(Compressed Gas Association, 2005)

3.3.2 Isolation Valves

3.3.3 Emergency Isolation Valves

3.3.4 Excess Flow Valves

3.3.5 Check Valves

3.3.7 Gasket and Sealing Materials

3.3.8 Additional Requirements

5.0 Installation

5.1 Installation General

International Fire Code (International Code Council, 2009)

2209.5.2 Emergency Shutoff Valves

2211.8.1.2.4 Grounding and bonding

2703.2.2 Piping, Tubing, Valves, and Fittings

2703.9.3 Protection from Vehicles

2703.10.1 Valve Protection

2705.1.10 Liquid Transfer

3003.6 Valve Protection

3005.3 Piping Systems

3005.4 Valves

3203.2.6 Shutoffs Between Pressure Relief Devices and Containers

3205.1.2 Piping Systems

3205.3.2 Emergency Shutoff Valves

3503.1.3 Emergency Shutoff

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

5.9 Valves

Venting and Other Equipment

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association, 2004)

6.0 Vent System
16

6.2 Sizing 

6.3 Design 

6.4 Materials 

6.5 Components 

7 Installation 

International Fire Code (International Code Council, 2009)

2209.5.4 Venting of Hydrogen Systems 

2211.8.1.2 Atmospheric Venting of Hydrogen from Motor Vehicle Fuel Storage 

Containers 

3003.16.8 Connections 

3005.5 Venting 

3203.3 Pressure Relief Vent Piping 

3204.4.5 Venting of Underground Tanks 

International Fuel Gas Code (International Code Council, 2009)

703.4 Venting 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

5.5 Vent Pipe Termination 

9.3.3.3 Indoors 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

10.2.2 Pressure-Relief Devices

Canopy Tops

International Building Code (International Code Council, 2009)

406.5.2.1 Canopies use to support gaseous hydrogen systems 

International Fire Code (International Code Council, 2009)

2209.3.2.6 Canopy Tops 

2209.3.3 Canopies 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.3.2.3 Outdoors 

Compressed Hydrogen Gas Storage

Equipment Location

International Fire Code (International Code Council, 2009)

2209.3 Location on Property 
17

3503 General Requirements 

3504 Storage 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.3 System Siting 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

10.3.2 Specific Requirements 

General Safety Requirements

International Fire Code (International Code Council, 2009)

2209.5 Safety Precautions 

2211.7 Repair Garages for Vehicles Fueled by Lighter-than-Air Fuels 

2211.8 Defueling of Hydrogen from Motor Vehicle Fuel Storage Containers 

3003 General Requirements 

3503 General Requirements 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.2.3 Equipment Security and Vehicle Protection 

9.2.4 Out of Service Bulk Storage

9.2.5 Equipment Security and Vehicle Protection

9.2.6 Cargo Transport Unloading

9.2.7 Control Device Icing

9.2.8 Vehicle Ignition Classification

9.2.9 Fueling Connection Leak Prevention

9.2.10 Compression and Processing Equipment 

9.2.11 Reference to NFPA 37 for Compressor Installations 

9.2.12 Electrical Classification for Compressors 

9.2.13 Liquid Carryover Prevention 

9.2.14 Detection for Dispensing Equipment 

9.2.15 General System Requirements 

9.2.16 General System Requirements 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases 

and Cryogenic Fluids in Portable and Stationary Containers, Cylinders and 

Tanks (National Fire Protection Association, 2005)

7.1.4 Security 
18

Storage Containers

CGA PS-20, Direct Burial of Gaseous Hydrogen Storage Tanks 

(Compressed Gas Association, 2006)

CGA PS-21, Adjacent Storage of Compressed Hydrogen and Other 

Flammable Gases (Compressed Gas Association, 2005)

International Fire Code (International Code Council, 2009)

2703.2.1 Design and Construction of Containers, Cylinders, and Tanks 

3003.2 Design and Construction 

3503.1.2 Storage Containers 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

5.3 Design and Construction of Containers 

Compression Systems and Equipment

International Fire Code (International Code Council, 2009)

2209.2 Equipment 

2209.3 Location on Property 

2209.5.3.1 System Requirements 

2209.5.4.2.1 Minimum Rate of Discharge 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.2.7 Control Device Icing

9.2.8 Vehicle Ignition Classification

9.2.9 Fueling Connection Leak Prevention

9.2.10 Compression and Processing Equipment 

9.2.11 Reference to NFPA 37 for Compressor Installations 

9.2.12 Electrical Classification for Compressors 

9.2.13 Liquid Carryover Prevention 

9.2.14 Detection for Dispensing Equipment 

9.3.1 General 

14.8 Stationary Pumps and Compressors 

Design

Barrier Walls

International Fire Code (International Code Council, 2009)

2209.3.1.1 Barrier Wall Construction – Gaseous Hydrogen 
19

Equipment

International Fire Code (International Code Council, 2009)

2209.2 Equipment 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.2 General System Requirements 

Fuel Stations

International Fire Code (International Code Council, 2009)

35 Flammable Gases 

2209.1 General 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

7.3 Motor Fuel Dispensing Facilities 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.3 System Siting 

14.2 Facility Design 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

7.1.6 Separation from Hazardous Conditions 

Weather Protection

International Fire Code (International Code Council, 2009)

2209.3.2.2 Weather Protection 

2704.13 Weather Protection 

Dispensing

Electrical Equipment

International Fire Code (International Code Council, 2009)

2201.5 Electrical 

2205.4 Sources of Ignition 

2209.2.3 Electrical Equipment 

2211.3.1 Equipment 

2211.8.1.2.4 Grounding and bonding 

2703.9.4 Electrical Wiring and Equipment 

3003.8 Wiring and Equipment 

3003.16.14 Classified Areas 

3203.7 Electrical Wiring and Equipment 

3503.1.5.1 Bonding of Electrically Conductive Materials and Equipment 
20

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

6.7 Emergency Electrical Disconnects 

8 Electrical Installations 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.11 Installation of Electrical Equipment 

9.12 Stray or Impressed Currents and Bonding 

Fuel Lines

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations 

(Compressed Gas Association, 2005)

3.0 Piping System Criteria 

International Fire Code (International Code Council, 2009)

2201 Scope 

2209.3.2.3 Indoors 

2209.3.2.6 Canopy Tops 

3501.1 Scope 

International Fuel Gas Code (International Code Council, 2009)

101.2.1 Gaseous Hydrogen Systems 

704 Piping, Use, and Handling 

705 Testing of Hydrogen Piping Systems 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

5.8 Fuel Lines 

Gaseous Dispensers

International Fire Code (International Code Council, 2009)

2209.2 Equipment 

2209.3 Location on Property 

2209.4 Dispensing into Motor Vehicles at Self-Service Hydrogen Motor FuelDispensing Facilities 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.2 General System Requirements 

9.3 System Siting 

Hoses and Connectors

International Fire Code (International Code Council, 2009)

2209.2 Equipment 
21

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

5.10 Hose and Hose Connections 

Liquid Dispensers

International Fire Code (International Code Council, 2009)

2206.7.4 Dispenser Emergency Valve 

2206.7.5 Dispenser Hose 

2206.7.6 Fuel Delivery Nozzles 

2209.2 Equipment 

2209.3 Location on Property 

2209.4 Dispensing into Motor Vehicles at Self-Service Hydrogen Motor FuelDispensing Facilities 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

6.3 Requirements for Dispensing Devices 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

14 Liquid Hydrogen Fueling Facilities 

Vehicle Connectors

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

5.11 Vehicle Fueling Connection 

SAE J2600, Compressed Hydrogen Surface Vehicle Refueling Connection 

Devices (Society of Automotive Engineers, 2002)

Dispensing, Operations, and Maintenance Safety

Gaseous Hydrogen

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association, 2004)

9 Maintenance 

International Fire Code (International Code Council, 2009)

2204 Dispensing Operations 

2209.4 Dispensing into Motor Vehicles at Self-Service Hydrogen Motor FuelDispensing Facilities 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

9.2.2 Tank Filling and Bulk Delivery 

9.4 Operating Requirements for Attended Self-Service Motor Fuel Dispensing 

Facilities 
22

9.5 Operating Requirements for Unattended Self-Service Motor Fuel Dispensing 

Facilities 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.13 System Operation 

9.14 Fire Protection 

9.15 Maintenance System 

Liquid Hydrogen

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association, 2004)

9 Maintenance 

International Fire Code (International Code Council, 2009)

2204 Dispensing Operations 

2209.4 Dispensing into Motor Vehicles at Self-Service Hydrogen Motor FuelDispensing Facilities 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

9.2.2 Tank Filling and Bulk Delivery 

9.4 Operating Requirements for Attended Self-Service Motor Fuel Dispensing 

Facilities 

9.5 Operating Requirements for Unattended Self-Service Motor Fuel Dispensing 

Facilities 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

14.4.6 Liquid Hydrogen Vehicle Dispensing Systems 

14.4.9 Liquid Hydrogen Vehicle Dispensing Systems 

14.4.10 Liquid Hydrogen Vehicle Dispensing Systems 

14.4.11 Liquid Hydrogen Vehicle Dispensing Systems 

14.13 Maintenance 

Fire Safety

Construction

International Fire Code (International Code Council, 2009)

911 Explosion Control 

2209.5 Safety Precautions 

International Fuel Gas Code (International Code Council, 2009)

706.3 Outdoor Gaseous Hydrogen Systems 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection Association, 

2010)
23

9.12 Stray or Impressed Currents and Bonding 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire Protection 

Association, 2010)

7.1.6 Separation from Hazardous Conditions 

Equipment

International Fire Code (International Code Council, 2009)

404 Fire Safety and Evacuation Plan 

406 Employee Training and Response Procedures 

407 Hazard Communication 

906 Portable Fire Extinguishers 

907 Fire Alarm and Detection Systems 

2209.4 Dispensing into Motor Vehicles at Self-Service Hydrogen Motor FuelDispensing Facilities 

2209.5 Safety Precautions 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.2.3 Equipment Security and Vehicle Protection 

9.2.4 Out of Service Bulk Storage

9.2.5 Equipment Security and Vehicle Protection 

9.2.15 General System Requirements 

9.3.3 Indoors 

9.14 Fire Protection 

14.2.4 Indoor Fueling 

14.4.3 Liquid Hydrogen Vehicle Dispensing Systems 

Signage

International Fire Code (International Code Council, 2009)

2204.3.5 Emergency Procedures 

2209.5.2.1 Identification 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.3.3.12 Warning Signs 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

6.12 Hazard Identification Signs 

10.2.4 Marking 

11.3.1.4 General 
24

Liquid Hydrogen Storage

Equipment Location

International Fire Code (International Code Council, 2009)

2209.3 Location on Property 

3203.5.4 Physical Protection 

3203.6 Separation from Hazardous Conditions 

3204.3.1.1 Location 

3204.4.2 Location 

3504 Storage 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

11.3.1 General 

11.3.2 Specific Requirements 

General Safety Requirements

International Fire Code (International Code Council, 2009)

2209.5 Safety Precautions 

2211.7 Repair Garages for Vehicles Fueled by Lighter-than-Air Fuels 

2211.8 Defueling of Hydrogen from Motor Vehicle Fuel Storage Containers 

3003 General Requirements 

3203 General Safety Requirements 

3503 General Requirements 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

14.2 Facility Design 

Storage Containers

International Fire Code (International Code Council, 2009)

2703.2 Systems, Equipment, and Processes 

3203.1 Containers 

3203.5 Security 

3203.6 Separation from Hazardous Conditions 

3204.3.1 Stationary Containers 

3204.4 Underground Tanks 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

5.3 Design and Construction of Containers 
25

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

11.3.2 Specific Requirements 

11.4.2 Underground Tanks 

CGA H-3 Cryogenic Hydrogen Storage (Compressed Gas Association, 

2006)

6.0 Tank design and manufacturing criteria

7.0 Inner vessel

8.0 Outer jacket

On-Site Hydrogen Production

International Fire Code (International Code Council, 2009)

2209.3.1 Separation from Outdoor Exposure Hazards 

International Fuel Gas Code (International Code Council, 2009)

703.1 General Requirements 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

5.2 System Approvals 

Operation Approvals

Dispensing

International Fire Code (International Code Council, 2009)

2204.2 Attended Self-Service Motor Fuel-Dispensing Facilities 

2204.3 Unattended Self-Service Motor Fuel-Dispensing Facilities 

2209.4 Dispensing into Motor Vehicles at Self-Service Hydrogen Motor FuelDispensing Facilities 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

6.2 General Requirements 

6.3 Requirements for Dispensing Devices 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

14.4.1 Liquid Hydrogen Vehicle Dispensing Systems 

14.4.2 Liquid Hydrogen Vehicle Dispensing Systems 

14.4.3 Liquid Hydrogen Vehicle Dispensing Systems 

14.4.11 Liquid Hydrogen Vehicle Dispensing Systems 
26

Fire And Emergency Planning

International Fire Code (International Code Council, 2009)

404 Fire Safety and Evacuation Plan 

406 Employee Training and Response Procedures 

407 Hazard Communication 

906 Portable Fire Extinguishers 

907 Fire Alarm and Detection Systems 

2209.3.2.6.2 Fire-Extinguishing Systems 

2209.4 Dispensing into Motor Vehicles at Self-Service Hydrogen Motor FuelDispensing Facilities 

2209.5.1 Protection from Vehicles 

2209.5.2 Emergency Shutoff Valves 

2209.5.3 Emergency Shutdown Controls 

2209.5.4 Venting of Hydrogen Systems 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

7.3.5 Fixed Fire Protection 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.2.16 General System Requirements 

9.10.5 Installation of Emergency Shutdown Equipment 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

4.1 Permits 

4.2 Emergency Plan 

7.1.6 Separation from Hazardous Conditions 

Fuel Delivery

International Fire Code (International Code Council, 2009)

105.6.8 Compressed Gases 

105.6.10 Cryogenic Fluids 

2205.1 Tank Filling Operation for Class I, II, or IIIA Liquids 

3205.4 Filling and Dispensing 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

6.3.7 Requirements for Dispensing Devices 
27

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.2.3 Equipment Security and Vehicle Protection 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

10.3 Location of Gaseous Hydrogen Systems 

Ignition Control

International Fire Code (International Code Council, 2009)

2209.3.2.3.3 Ignition Source Control 

3503.1.4 Ignition Source Control 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

4.8 Ignition Source Controls 

7.6.3 Ignition Source Control 

Personnel Issues and Training

International Fire Code (International Code Council, 2009)

406 Employee Training and Response Procedures 

2209.4 Dispensing into Motor Vehicles at Self-Service Hydrogen Motor FuelDispensing Facilities 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

9.4 Operating Requirements for Attended Self-Service Motor Fuel Dispensing 

Facilities 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

4.6 Personnel Training 

4.7 Fire Department Liaison 

Signage

International Fire Code (International Code Council, 2009)

2204.3.5 Emergency Procedures 

2209.3.2.3.2 Smoking 

2209.3.2.6.3 Signage 

2209.5.2.1 Identification 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.3.3.12 Warning Signs 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

4.9 Signs 
28

Vehicle Access

International Fire Code (International Code Council, 2009)

105.6.8 Compressed Gases 

105.6.10 Cryogenic Fluids 

105.6.39 Repair Garages and Motor Fuel-Dispensing Facilities 

404.3.2 Fire Safety Plans 

3205.4 Filling and Dispensing 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages 

(National Fire Protection Association, 2003)

6.3.7 Requirements for Dispensing Devices 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.2.3 Equipment Security and Vehicle Protection 

14.2.1.6 General 

14.4.2 Liquid Hydrogen Vehicle Dispensing Systems 

14.4.5 Liquid Hydrogen Vehicle Dispensing Systems 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

10.3 Location of Gaseous Hydrogen Systems 

Setbacks and Footprints

Liquid Systems

International Fire Code (International Code Council, 2009)

2209.3.1 Separation from Outdoor Exposure Hazards 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

14.2.2 Siting 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire

Protection Association, 2010)

11.3.2.1 Specific Requirements 

11.3.2.2 Specific Requirements 

Outdoor Gaseous Systems

International Fire Code (International Code Council, 2009)

2209.3.1 Separation from Outdoor Exposure Hazards 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

9.3.1.3 General 
29

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

10.3.2.1 Specific Requirements 

10.3.2.2 Minimum Distance 

Transportation

Compressed Hydrogen Gas

CGA P-1, Safe Handling of Compressed Gases in Containers (Compressed 

Gas Association, 2006)

4.1 Transportation Regulating Authorities 

4.2 Container Regulations 

4.3 Container Filling Regulations 

4.4 Regulating Authorities of Employee Safety and Health 

6.2 Flammable Gases 

International Fire Code (International Code Council, 2009)

2705 Use, Dispensing, and Handling 

3005.7 Transfer 

3505 Use 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

4 General Requirements 

7.3.1.10 Use and Handling 

Liquid Hydrogen

CGA P-12, Safe Handling of Cryogenic Liquids (Compressed Gas 

Association, 2005)

5.5.4 Additional Safety Practices for Liquid Hydrogen 

6.4 Hydrogen Fires 

7.9 Handling Considerations for Hydrogen and Helium Transfer 

International Fire Code (International Code Council, 2009)

2705 Use Dispensing and Handling 

3201.1 Scope 

3203.6.1.1 Point-of-Fill Connections 

3205.4.2 Vehicle Loading and Unloading Areas 

NFPA 52, Vehicular Gaseous Fuel Systems Code (National Fire Protection 

Association, 2010)

14.3 Cargo Transport Unloading 
30

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

4 General Requirements 

8.3.5 Overfilling 

8.13.1.2 Attended Delivery 

8.13.10.3 Filling and Dispensing 

Natural Gas

ASME B31.8, Gas Transmission and Distribution Systems (American 

Society of Mechanical Engineers, 2003)

Vaporizers

International Fire Code (International Code Council, 2009)

2209.2 Equipment 

2209.3 Location on Property 

3203.1.3 Foundations and Supports 

3203.2.2 Vessels or Equipment Other than Containers 

3203.5.3 Securing of Vaporizers 

International Fuel Gas Code (International Code Council, 2009)

708 Design of Liquefied Hydrogen Systems Associated with Hydrogen Vaporization 

Operations 

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

11.2.5 Liquefied Hydrogen Vaporizers 
31

II.3 Recommendations on any compliance issues

Although the site visit conducted by NREL personnel brought to light many operational issues, 

most of them logistical concerns as opposed to safety concerns, there was no information that 

indicated that the site was out of compliance with the UFC or other safety requirements.

Recommendations on how the findings could be applied to other projects

There were several issues that became apparent during the site inspection that would potentially 

improve operations and safety. These issues include the following:

1. As a part of the project design phase, define forklift operating schedules and demands and 

match forklift performance to forklift operational demands to the extent possible.

2. Locate forklift fueling equipment to reduce forklift downtime during shifts

3. Design forklift exhaust and other operating characteristics to accommodate operator safety 

and comfort

4. Review hydrogen dispensing and storage operations history with site safety personnel during 

the project design phase to address safety concerns
32

III.1 The Marine Corps Logistics Base Barstow, CA 

The Marine Corps Logistic Base at Barstow, CA was selected for deployment of a stationary 

hydrogen fuel cell system to provide backup power. The MCLB is located outside of Barstow, 

CA. This region of California is desert-like and sparsely populated. The base is located on 

Interstate 40, 3 1/2 miles east of the city of Barstow. The MCLB is a vital link in the logistics 

complex that provides the weapons systems, equipment and special logistics essential to 

supporting the assigned missions of the Fleet Marine Forces. To accomplish this, Barstow is 

positioned in a strategic geographical location. Barstow lies at the junction of three major 

highways systems of I-15, I-40, and Highway 58, and is the located at the hub of all west coast 

rail traffic for the Burlington Northern/Santa Fe and the Union Pacific railroads. It is in the 

immediate proximity of the regional air, Daggett Airport. Barstow, CA is within 150 miles of 

the two major seaports of Los Angeles and San Diego. Because of its arid desert climate, 

equipment can be stored outdoors with minimal maintenance required.

III.1 The MCLB Proposed Stationary Fuel Cell Backup Power 

Deployment

The MCLB has several groups and facilities that support the base’s mission, including the Nebo 

Annex. The Nebo Annex (shown in Figure III-1) encompasses 1,879 acres (8 km2

) and 

functions as base headquarters and is the main facility for administration, storage, recreational 

activities, shopping, and housing functions. The base fire station is also located within the Nebo 

Annex.

Figure III-1: The Nebo Complex, location of the MCLB headquarters and fire station.
33

The MCLB plans call for the installation of a stationary fuel cell to provide backup power at the 

fire station located on the Nebo Complex. The power requirement for this facility is estimated 

to be 20 kW. The MCLB Barstow currently uses diesel generators for backup power; this 

includes the backup power system for the MCLB fire station. The diesel generators require 

significant maintenance and are now required to obtain a permit from the South Coast Air 

Quality Management District in order to operate due to their emissions. The MLCB Barstow 

wishes to use fuel cell technology for power backup systems due to its high reliability, low 

maintenance, and clean operation. The DOE is assisting the MCLB in this project by providing 

some of the funding through an interagency agreement. This information was conveyed to 

NREL by DOE personnel working on the project. This partnership with DOE is part of an effort 

to advance the use of stationary fuel cells.

An overview of site operations and a review of the underlying codes and standards as they 

pertain to the deployment of hydrogen-powered fuel cells are presented below.

III.1.1 Site Visit and Review of the MCLB Site Operations

On April 27, 2010, Carl Rivkin from NREL Codes and Standards Group visited the MCLB site. 

Mr. Rivkin met with Sharon Ott from the MCLB Public Works Division. Installation and 

approval of the stationary power fuel cell power system was not yet completed at the time of the 

NREL site visit, nevertheless the site operations were reviewed and NREL assisted in identifying 

pertinent code requirements, which would facilitate permitting. These documents are identified 

in Table 3 Codes and Standards Citations for Stationary Fuel Cells.

III.1.2 Incidental Issues/ Site Permitting Issues

This project is located at a Department of Defense facility and thus is not subject to the 

permitting requirements of the local enforcing authorities, which are the City of Barstow, CA 

and Fresno County. Therefore, the administrative process for permitting is potentially less 

complex than with facilities that might require permits from multiple Authorities Having 

Jurisdiction (AHJs) within the jurisdiction that address different aspects of the project. As 

discussed below, DOD facilities are subject to the Unified Facilities Criteria (UFC) 3-600-01 

Fire Protection Engineering for Facilities. The UFC document requires compliance with the 

International Building Code and all National Fire Protection Association documents collectively 

referred to as the National Fire Code (NFC). UFC 3-600-01 refers to NFPA 853 Standard for 

Installation of Stationary Fuel Cell Power Systems 2009 edition, which is the primary installation 

document for stationary fuel cells. In turn, NFPA 853 refers NFPA 55 Code for Compressed 

Gases and Cryogenic Fluids 2010 edition (NFPA 55). 

During the site visit, NREL personnel reviewed the proposed fuel cell site outside of the base fire 

department. One of the most difficult code compliance issues with this project was siting the 

bulk gaseous hydrogen storage system for the fuel cell. Because the location for the fuel cell was 

determined by its intended application, backup power for the fire station, the storage system 

location was required to be proximate to the fire station. Despite the base being located in a 
34

sparsely populated area and the building density on the base being relatively low, the hydrogen 

storage was limited to an area where there were siting restrictions. On other projects in other 

locations, an up front evaluation of potential locations for siting the hydrogen storage system 

could make the project installation easier. NFPA 55 provides guidance on setback distances for 

hydrogen storage facilities. NFPA provides prescriptive tables that provide setback distances of 

various exposures (see Table 10.3.2.2.1 in NFPA 55, shown as Table 2). These prescriptive set 

back distances are reproduced in Table III-1 of this report. Figure III-2 shows the location of 

the storage system and key separation distances proscribed by NFPA 55. Because of the 

restriction placed on the hydrogen storage by the NFPA prescriptive tables for setback distances, 

there were few locations where the storage system could be located. For example the most 

restrictive setback distances for siting this fuel cell as per NFPA 52 are likely as follows 

(assuming this will be a system that falls into the 250 psig to 3000 psig range):

1. Distance to lot lines -45 feet (use equation a or b, Table III-1)

2. Openings (operable) in buildings – 45 feet (use equation a, Table III-1)

3. Air intakes – 45 feet (use equation a, Table III-1)

4. Parked cars – 25 feet (use equation c, Table III-1)

The 2010 edition of NFPA 55 provides an alternative method to determine the separation 

distances for siting a bulk gaseous hydrogen storage system. This alternative computational 

method is based on calculating distances using pipe diameters (see Table 10.3.2.2.1.1 in NFPA 

55). These computational set back distances are reproduced in Table III-2 of this report. The 

computational method is guided by pipe diameter. The computational method may results in less 

restrictive setback distances. Assuming a 1⁄2 inch pipe diameter the following distances are 

calculated:
35

1. Distance to lot lines - feet (use equation a or b, Table III-2) Approximately 19 feet

2. Openings (operable) in buildings – feet (use equation a, Table III-2) Approximately 31 feet

3. Air intakes – feet (use equation a, Table III-2) Approximately 31 feet 

4. Parked cars – feet (use equation c, Table III-2) Approximately 14 feet

The computational method of determining separation distances results in smaller separation 

distances than those shown in the prescriptive table. This outcome is based on the pipe diameter 

selected. In other situations the computed distances could be greater than those shown in the 

prescriptive tables. It is recommended that an analysis of the setback distances based on the 

computational methods provided in NFPA 55 should be performed as part of the siting 

evaluation for any project where site space issues may exist.
36

Table 2. Separation Distances for Bulk Gaseous Hydrogen Storage Systems from Various 

Exposures (Table 10.3.2.2.1 (b) from the 2010 edition of NFPA 55 Gaseous and 

Cryogenic Fluids Code)
37
38

Table 3-2.Computional method based on pipe diameter for determination of 

separation Distances for Bulk Gaseous Hydrogen Storage Systems from 

Various Exposures (Table 10.3.2.1.1 .1(b) from the 2010 edition of NFPA 55 

Gaseous and Cryogenic Fluids Code)

III.2 Comprehensive codes and standards evaluation 

The codes and standards that apply to the installation and operation of stationary fuel cells are 

relatively mature and well defined. The basic code structure is shown in Figure III-2. The 

pyramid in Figure III-2 shows that the regulatory chain starts with a jurisdiction’s adoption of a 

building code. In this case the building code is first referred to in Unified Facilities Criteria 

(UFC) 3-600-01 Fire Protection Engineering for Facilities document that DoD facilities are 

subject to. The UFC document requires compliance with the International Building Code and all 

National Fire Protection Association documents collectively referred to as the National Fire 

Code (NFC).
39

Figure 2. Codes and Standards Hierarchy and Progress

The primary installation document for stationary fuel cells is NFPA 853 Standard for Installation 

of Stationary Fuel Cell Power Systems 2009 edition. This document is referred to in the Unified 

Facilities Criteria (UFC) 3-600-01 Fire Protection Engineering for Facilities document. This 

document sets requirements for the installation of PEM hydrogen fuel cells as well as other types 

of fuel cells. NFPA 853 refers to CSA FC 1 for the design of the fuel cell. NFPA 853 refers to 

NFPA 55 Code for Compressed Gases and Cryogenic Fluids for the hydrogen storage system 

requirements. NFPA 55 contains the table of separation, Table 1 distances for bulk gaseous 

hydrogen storage systems that may present difficulties for siting systems in very space restricted 

locations. Note that the separation distance requirements that are found in NFPA 55 have also 

been extracted into NFPA 2 Hydrogen Technologies Code. The requirements of FC1 are not 

explored in this report because this analysis is directed at the requirements for siting the fuel cell. 

At the time of the site visit the fuel cell had not been selected and therefore could not be 

reviewed for compliance with FC 1.

One of the most difficult code compliance issues with this project was siting the bulk gaseous 

hydrogen storage system for the fuel cell. Because the location for the fuel cell was determined 

by its intended application, backup power for the fire station, the storage system location was 

restricted to be proximate to the fire station. Despite the base being located in a sparsely 

populated area and the building density on the base being relatively low, the hydrogen storage 

was limited to an area where there were siting restrictions. On other projects in other locations, 

an up front evaluation of potential locations for siting the hydrogen storage system could make 

the project installation easier.

The citations include references to several key documents such as CSA America FC 1 -2004 

Stationary Fuel cell Power Systems, NFPA 853 Standard for the Installation of Stationary Fuel 

Cell Power Systems, and NFPA 55 Code for Compressed gases and Cryogenic Fluids. These 
40

three documents address the design and performance of the fuel cell, (F/C 1), the installation of 

the fuel cell (NFPA 853), and the storage of the hydrogen to power the fuel cell (NFPA 55). The 

requirements that are in NFPA 55 and NFPA 853 have also been extracted into NFPA 2 

Hydrogen technologies Code. There are also citations referenced from the International Building 

Code (IBC), the International Fire Code (IFC) and International Fuel Gas Code (IFGC) and the 

International Mechanical Code (IMC) that set general system safety requirements system 

construction, material storage, ventilation, and operation. The IFC addresses areas such as 

training and incident planning and the Maximum Allowable Quantities (MAQs) for storing 

hydrogen. NFPA 55 includes the MAQ requirements for indoor storage (it does not conflict 

with the IFC) and also contains requirements for bulk outdoor hydrogen storage systems. The 

IMC sets requirements for exhaust systems for enclosed installations, and the IFGC sets 

requirements for installation and testing of hydrogen piping systems.

The F/C 1 sets detailed system design requirements that address system performance and 

selection of system materials. The requirements cover general construction and performance, 

indoor installations, and direct vent fuel cells. There are performance testing requirements for 

these three categories of fuel cells. NFPA 853 sets system installation requirements that define 

where systems can be located. These locations include rooftop installations. NFPA 853 also 

addresses system fire protection requirements in detail.

There are also electrical safety requirements found in NFPA 70. The electrical requirements 

found in Article 692 address safe wiring, system grounding, and connection to other circuits.

Comprehensive codes and standards evaluation including any applicable local 

ordinances

Table 3: Code and Standard citations for Stationary Fuel Cell Applications

Codes and Standards Citations for 

Stationary Fuel Cell Applications

Construction Approval

NFPA 70, National Electric Code (National Fire Protection 

Association, 2008)

Article 692

ANSI/CSA America FC 1-2004, Stationary Fuel Cell Power 

Systems (American National Standards Institute and Canadian 

Standards Association, 2004)

1.2 Power Systems Design

1.3 General Design Requirements

1.3.2 Protection from Environmental Conditions

1.3.3 Electrical Safety

1.3.5 Steam Backflow

1.3.6 FC System Purging

1.3.7 Safe Handling During Moving
41

Codes and Standards Citations for 

Stationary Fuel Cell Applications

1.3.8 Shock and Vibration Protection

1.3.9 Requirements for Not-Listed Equipment

1.3.11 Temperature Limits

1.4 Materials

1.5 General Construction and Assembly

1.6 Enclosures and Associated Construction

1.8.1 Metallic Piping

1.9 Drain, Venting and Ventilation Exhaust Systems

1.12.1 Manual Valves

1.12.2 Automatic Valves

1.12.3 Pressure Regulators

1.15 Electrical Equipment and Wiring

1.19.1 Materials for Markings

1.19.2 FC Labeling Requirements

1.19.4 - 1.19.7 Electrical Diagrams

International Building Code (International Code Council, 2009)

307.1.1 Maximum Allowable Quantities

414.1 General

414.2 Control Areas

414.4 Hazardous Materials Systems

414.6 Outdoor Storage, Dispensing, and Use

907 Fire Alarms and Detection Systems

1609 Wind Loads

1612 Flood Loads

1805 Footings and Foundation

International Fire Code (International Code Council, 2009)

401 General Emergency Planning and Preparedness

406 Employee Training and Response Procedures

2703.1 Hazardous Materials

2703.1.1 Maximum Allowable Quantities per Control Area

2703.1.3 Quantities Not Exceeding the Maximum Allowable Quantity 

per Control Area

2703.1.4 Quantities Exceeding the Maximum Allowable Quantity per 

Control Area

2703.2 Systems, Equipment, and Processes

2703.2.1 Design and Construction of Containers, Cylinders, and 

Tanks

2703.2.2 Piping, Tubing, Valves, and Fittings

2703.2.3 Equipment, Machinery, and Alarms

2703.2.4 Installation of Tanks

2703.2.5 Empty Containers and Tanks

2703.2.8 Seismic Protection

2703.2.9 Testing

2703.3 Release of Hazardous Materials

2703.4 Material Safety Data Sheets

2703.8 Construction Requirements
42

Codes and Standards Citations for 

Stationary Fuel Cell Applications

2703.8.1 Buildings

2703.8.2 Required Detached Buildings

2703.8.3 Control Areas

2703.8.4 Gas Rooms

2703.8.5 Exhausted Enclosures

2703.8.6 Gas Cabinets

2703.8.7 Hazardous Materials Storage Cabinets

2703.9 General Safety Precautions

2703.9.1 Personnel Training and Written Procedures

2703.9.1.1 Fire Department Liaison

2703.9.2 Security

2703.9.3 Protection from Stationary fuel cell applications

2703.9.4 Electrical Wiring and Equipment

2703.9.5 Static Accumulation

2703.9.6 Protection from Light

2703.9.7 Shock Padding

2703.9.8 Separations of Incompatible Materials

2703.9.9 Shelf Storage

2703.12 Outdoor Control Areas

2704 Storage

2705 Use, Dispensing, and Handling

3003.1 Containers, Cylinders, and Tanks

3003.2 Design and Construction

3003.3 Pressure Relief Devices

3003.4 Gas Marking

3003.4.1 Stationary Compressed Gas Containers, Cylinders, and 

Tanks

3003.4.2 Portable Containers, Cylinders, and Tanks

3003.4.3 Piping Systems

3003.5 Security

3003.6 Valve Protection

3003.6.1 Compressed Gas Container, Cylinder, or Tank Protective 

Caps or Collars

3003.7 Separations from Hazards

3003.8 Wiring and Equipment

3003.10 Unauthorized Use

3003.11 Exposure to Fire

3003.12 Leaks, Damage, or Corrosion

3003.13 Surface of Unprotected Storage or Use Areas

3003.14 Overhead Cover

3003.15 Lighting

3003.16.13 Accessway

3004 Storage of Compressed Gases

3005 Use and Handling of Compressed Gases

3005.1 Compressed Gas Systems

3005.2 Controls
43

Codes and Standards Citations for 

Stationary Fuel Cell Applications

3005.3 Piping Systems

3005.4 Valves

3005.5 Venting

3005.6 Upright Use

3005.7 Transfer

3005.9 Material-Specific Regulations

3005.10 Handling

3203.4 Liquid Marking

3503.1 Quantities Not Exceeding the Maximum Allowable Quantity 

per Control Area

3503.1.2 Storage Containers

3503.1.3 Emergency Shutoff

3503.1.4 Ignition Source Control

3503.1.5 Electrical

3503.2 Quantities Exceeding the Maximum Allowable Quantity per 

Control Area

3504.2 Outdoor Storage

3504.2.1 Distance Limitation to Exposures

3505 General Use

International Fuel Gas Code (International Code Council, 2009)

301 General

302 Structural Safety

303 Appliance Location

305 Installation

409 Shutoff Valves

633 Stationary Fuel Cell Power Systems

635 Gaseous Hydrogen Systems

703.2 Containers, Cylinders, and Tanks

703.3 Pressure Relief Devices

703.4 Venting

703.5 Security

703.6 Electrical Wiring and Equipment

704 Piping, Use and Handling

705 Testing of Hydrogen Piping Systems

706 Location of Gaseous Hydrogen Systems

International Mechanical Code (International Code Council, 2009)

301 General

302 Protection of Structure

303 Equipment & Appliance Location

304 Installation

305 Piping Support

401 General

501 Exhaust Systems

502 Required Systems

510 Hazardous Exhaust Systems

924 Stationary Fuel Cell Power Systems
44

Codes and Standards Citations for 

Stationary Fuel Cell Applications

926 Gaseous Hydrogen Systems

NFPA 55, Compressed Gases and Cryogenic Fluids Code 

(National Fire Protection Association, 2010)

7.1.1 Listed and Approved Hydrogen Equipment

7.1.2 Containers, Cylinders and Tanks

7.1.3 Listed and Approved Hydrogen Equipment 

7.1.4.3 Physical Protection

7.1.6 Separation from Hazardous Conditions

7.3.1.4 Valves

7.6 Flammable Gases

10.2 Design of Gaseous Hydrogen Systems

10.2.1 Pressure Relief Devices

10.2.1.1 Venting Requirements

10.2.5 Marking

10.3 Location of Gaseous Hydrogen Systems

10.3.2 Specific Requirements

10.4.1.2 Electrical Equipment Location

10.6 Fire Protection

NFPA 853, Standard for the Installation of Stationary Fuel Cell 

Power Systems (National Fire Protection Association, 2007)

4.2 Prepackaged, Self-Contained Fuel Cell Power Systems

4.3 Pre-Engineered Fuel Cell Power Systems

4.4 Engineered and Field-Constructed Fuel Cell Power Systems

5.1.1 General Siting

5.1.1 (2) General Siting

5.1.2 General Siting

5.1.3 General Siting

5.2 Outdoor Installations

6.1.2 General

6.4.1 Gaseous Hydrogen Storage

6.4.1 Ventilation Air

6.4.3 Hydrogen Piping

6.4.3.2 Hydrogen Piping

6.4.3.5 Hydrogen Piping

6.4.3.7 Hydrogen Piping

6.4.3.1 Hydrogen Piping

7.1.1 General

7.2.2 When Natural ventilation Permitted

7.3 Exhaust Systems

8.1.2 Fuel Cell Fire Protection and Detection

8.1.3 Electrical Equipment and Components

9.2 Outdoor Installations

9.5 Fire Protection

Operation Approval
45

Codes and Standards Citations for 

Stationary Fuel Cell Applications

ANSI/CSA America FC 1-2004, Stationary Fuel Cell Power Systems 

(American National Standards Institute and Canadian Standards 

Association, 2004)

1.18.2 Maintenance Manual

1.19.1 Materials for Markings

1.19.2 FC Labeling Requirements

1.19.4 - 1.19.7 Electrical Diagrams

CGA P-1, Safe Handling of Compressed Gases in Containers (Compressed 

Gas Association, 2006)

4.1 Transportation Regulating Authorities

4.2 Container Regulations

4.3 Container Filling Regulations

4.4 Regulating Authorities of Employee Safety and Health

6.2 Flammable Gases

International Fire Code (International Code Council, 2009)

105.6.8 Compressed Gases

404.3.2 Fire Safety Plans

406 Employee Training and Response Procedures

2703.2.6 Maintenance

2703.5 Hazard Identification Signs

2703.6 Signs

2705 Use, Dispensing, and Handling

3003.4 Gas Marking

3003.9 Service and Repair

3003.16.13 Accessway

3005.7 Transfer

3203.4 Liquid Marking

3505 General Use

International Fuel Gas Code (International Code Council, 2009)

707 Operation and Maintenance of Gaseous Hydrogen Systems

NFPA 55, Compressed Gases and Cryogenic Fluids Code (National Fire 

Protection Association, 2010)

4.6 Personnel Training

4.7 Fire Department Liaison

7.1.3 Listed and Approved Hydrogen Equipment

7.3.1.10 Use and Handling

8.3.5 Overfilling

10.2.5 Marking

10.3 Location of Gaseous Hydrogen Systems

10.6 Fire Protection

NFPA 853, Standard for the Installation of Stationary Fuel Cell Power 

Systems (National Fire Protection Association, 2007)

6.1.2 General

6.4.1 Gaseous Hydrogen Storage

6.4.3 Hydrogen Piping

8.2 Fire Prevention and Emergency Planning
46

Recommendations on any compliance issues

One important compliance issue that this project had was siting the hydrogen storage system for 

the fuel cell. One way to improve the siting process is to evaluate multiple locations for the fuel 

cell to determine whether there is a location that does not present siting issues. The siting issues 

referred to are the separation distances from exposures that bulk hydrogen systems must meet or 

comply with NFPA 2 Hydrogen Technologies Code 2011 edition. Hydrogen storage systems for 

stationary fuel cells typically fall into the greater than 250 psi and less than or equal to 3000 psi 

pressure range.

For the following exposures the there must be a 45 foot separation distance between the 

hydrogen storage system and the exposure:

1. Lot lines

2. Openings in buildings of fire rated or non-fire rated construction that have openable doors 

windows, or other openings

3. Ignition sources

4. Air intakes

These separation distances can pose difficulties for siting systems in even relatively 

unconstructed spaces.

Recommendations on how the findings could be applied to other projects

For all projects a pre design meeting with the enforcing authority should be held to describe the 

project and agree on which requirements the projects would be subject to. Because hydrogen 

storage system siting is likely a key compliance issue, this meeting would be an opportunity to 

review possible hydrogen storage system locations.
47

IV Conclusions

This report evaluated two emerging fuel cell projects for safety and codes and standards 

compliance. The backup power installation project was reviewed prior to construction so 

information on fuel cell operation could not be included in the report. The forklift project was 

evaluated after extensive construction and operational history.

There are a few overarching conclusions that apply to both projects:

1. There are codes and standards in place that specifically address the emerging fuel cell 

technologies that are the subject of this report

2. Although compliance with codes and standards does involve a significant effort, it does not 

prevent project implementation

3. Projects of similar complexity are subject to similar levels of control and the codes and 

standards compliance effort is of similar magnitude (Conversations with Fiedler Engineering)

4. A thorough codes and standards review early in the design or project development process 

has the potential to reduce codes and standards compliance issues resulting in shorter project 

review times and cost savings

5. Evaluating operator work structure and needs can increase the effectiveness of the 

technology and this evaluation should be performed as early in the project development 

process as possible.

6. Although a proposed project submission may show compliance with codes and standards the 

Authority Having Jurisdiction (AHJ) still has a lot of latitude in evaluating the project and 

requiring that additional safety measures be employed.

Another key to moving a project efficiently through the permitting process that was not 

addressed in the MCLB project is meeting with the AHJ prior to submitting a permit application 

or in the case of DoD facilities the documentation required to show compliance with UFC 3-600-

01. This meeting that precedes submitting an application has the following objectives:

Acquaint the AHJ with the project technology

Perform a detailed review of codes, standards, and regulations to ensure that both the 

permit applicant and the AHJ agree on what requirements the project must meet

Discuss the time frame for processing the application to ensure there is a common 

understanding of the process and time required to issue a permit or approval

Discuss the documentation required with the submission to ensure that the permit when 

submitted is complete

Review permits issued for similar installations to understand what compliance conditions 

might be placed on the operation

Discuss any recordkeeping or data reporting requirements that might be required to ensure that 

ongoing operations stay compliant.
48

Citations

1. e-mail communication with site industrial hygienist , Mr. John Folkomer July 16, 2008

2. Carl Rivkin, P.E of NREL was asked by the DLA to perform a third party safety review May 

2008

3. L. Plonsky, DLA project manger, Personnel Communication June 8, 2008

4. R. Skinnell, Personal Communication March 16, 2011

5. R. Skinnell, Personal Communication March 16, 2011

6. http://www.nrel.gov/hydrogen/proj_tech_validation.html

7. R. Skinnell, personal communication (March 16, 2011)

8. NREL Sensor Laboratory personnel Conversation August 4, 2011

9. R. Skinnell and H. Hoffman personal communication August 6, 2010