National Renewable Energy Laboratory

Innovation for Our Energy Future

A national laboratory of the U.S. Department of Energy

Office of Energy Efficiency & Renewable Energy

NREL is operated by Midwest Research Institute ● Battelle Contract No. DE-AC36-99-GO10337

Technical Report

NREL/TP-560-49165

September 2010

Stationary Fuel Cell Application 

Codes and Standards:

Overview and Gap Analysis 

Chad W. Blake and Carl H. Rivkin
National Renewable Energy Laboratory

1617 Cole Boulevard, Golden, Colorado 80401-3393

303-275-3000 • www.nrel.gov

Operated for the U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

by Midwest Research Institute • Battelle

Contract No. DE-AC36-99-GO10337

Technical Report

NREL/TP-560-49165

September 2010

Stationary Fuel Cell Application 

Codes and Standards:

Overview and Gap Analysis 

Chad W. Blake and Carl H. Rivkin

Prepared under Task No. H274.7170
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iii

Executive Summary

Codes and standards are implemented to ensure that processes and products meet uniform 

requirements. These requirements pertain to either safety or performance specifications. 

The Codes and Standards Group at the National Renewable Energy Laboratory (NREL) 

conducted an analysis of the full range of codes and standards that apply to stationary 

fuel cell applications to determine where the gaps are located in the codes and standards 

and what work must be performed to fill these gaps. The major codes and standards are in 

place to allow for the implementation of stationary fuel cells. Fuel cells projects may be 

slowed by issues of coordination or clarity in codes and standards but are not being 

stopped by these gaps. The fuel cell technologies that are making the most commercial 

progress are:

1. Polymer Electrolyte Membrane (PEM) fuel cells used primarily for backup power 

2. Phosphoric Acid fuel cells 

3. Solid Oxide Fuel Cells

4. Molten Carbonate fuel cells. 

Table 1 summarizes key gaps in existing stationary fuel cell application codes and 

standards identified during analysis. The individual sections provide additional extensive 

listings of codes and standards gaps. The gaps listed in this table were deemed more 

important by the authors or the experts interviewed by the authors. 

This report was written with input from experts in stationary fuel cell applications. 

Table 2 identifies the various experts who provided input to this report. 

Table 1: Summary of Stationary Fuel Cell Application Codes and Standards Gaps

Stationary fuel cell 

application Codes and 

Standards Gap

Documents 

Impacted Gap Resolution

Coordination between 

installation documents 

and design and 

component standards

Multiple

Ongoing monitoring 

of the codes and 

standards 

development 

process

Coordination between 

domestic documents 

and international 

standards

Multiple

Ongoing monitoring 

of the codes and 

standards 

development 

process
iv

Stationary fuel cell 

application Codes and 

Standards Gap

Documents 

Impacted Gap Resolution

Lack of understanding 

of fuel cell technologies, 

specifically the storage 

of alternative fuels, on 

the part of code officials

Multiple 

Outreach efforts to 

code official and 

project developers
v 

Table 2: Codes and Standards Experts 

Expert Organization Area of Expertise

Connie Bielawski CSA America Component Standards

Chad Blake NREL Codes and Standards

William Collins UTC Power Fuel Cells

Michael Penev NREL Fuel Cell Analysis

Chris Radley Altergy Systems Fuel Cell Systems

Carl Rivkin NREL Codes and Standards

Doug Wheeler Consultant to NREL Fuel Cells

Joseph Zerbo Salt River Project Electric Utility
vi

Executive Summary ........................................................................................................... 

Table of Contents

iii

Purpose ................................................................................................................................ 1

Codes and Standards – Generic Overview .......................................................................... 2

Fuel Cell Technologies Codes and Standards Project ........................................................ 4

Stationary Fuel Cell Technologies ...................................................................................... 8

Codes and Standards Structure ......................................................................................... 10

Gaps in Codes and Standards ............................................................................................ 16

Summary ........................................................................................................................... 17

Conclusion ........................................................................................................................ 19

References ......................................................................................................................... 20

APPENDIX I .................................................................................................................... 21

Figure 1: Codes and Standards Hierarchy .......................................................................... 

List of Figures

3

Figure 2: The NREL Codes and Standards Project ............................................................ 6

Figure 3: The Codes and Standards Development Process ................................................ 7

Figure 4: Stationary Fuel Cell Technologies [4] ................................................................. 8

Figure 5: Comparison of Fuel Cell Technologies [7] ......................................................... 9

Table 1: Summary of Stationary Fuel Cell Application Codes and Standards Gaps ......... 

List of Tables

iii

Table 2: Codes and Standards Experts ................................................................................ v

Table 3: Code and Standard Citations for Stationary Fuel Cell Applications .................. 10

Table 4: Codes and Standards Gaps for Stationary Fuel Cell Applications ..................... 17
1 

Purpose

The purpose of this report is to identify gaps in stationary fuel cell application codes and 

standards and to recommend actions that provide a means to fill these gaps. The focus of 

this gap analysis is on stationary fuel cell applications. The existence of these gaps 

represents barriers to the implementation of stationary fuel cell systems. This analysis 

also identifies specific activity that leads to the elimination of the codes and standards 

gaps. These recommendations will help define codes and standards development work 

and priorities. This report presents a comprehensive summary of the codes and standard 

gaps for stationary fuel cell applications. 

Codes and standards facilitate the development and implementation of new technologies. 

This is especially true in cases where commercial success is predicated upon 

contributions from multiple industries, such as stationary fuel cells. Stationary fuel cell 

equipment must be available that is compatible with other existing power equipment. At 

the same time, it is also required that fuel be available for the stationary fuel cell 

application, thereby requiring transit, storage, and transfer infrastructure. To ensure 

national security for the United States and to alleviate the dependence on imported fossil 

fuels, the U.S. Department of Energy (DOE) Fuel Cell Technologies Program supports 

the use of stationary fuel cells.

The use of alternative fuels is growing and the number of stationary fuel cell applications 

that operate on such fuel has dramatically increased in the past decade. Unique 

infrastructure impacts will be encountered, including production capacity and impact on 

existing demands and safety, as well as achieving appropriate stationary fuel cell 

application performance in a consumer market. 

The number of stationary fuel cell applications powered by non-conventional alternative 

fuels is growing. To facilitate the development of the emerging markets, the stationary 

fuel cell application Codes and Standards Group at NREL initiated a study to identify 

specific gaps in the codes and standards structure for stationary fuel cell applications. 

This codes and standards analysis was broadened to include regulatory or policy issues 

that impede application of a technology. This gap analysis involved a comprehensive 

review of the existing codes and standards currently applied to each fuel type. To ensure 

a thorough analysis was performed, experts in the fuel cell industry with extensive handson experience were consulted. These experts provided unique insights into the status of 

the identified applications. The expert discussions were incorporated into the following 

analysis. See Appendix I for brief expert biographies. 
2 

Codes and Standards – Generic Overview

Codes and standards are developed to ensure that processes and products meet uniform 

requirements. Codes and standards guide the implementation of energy technology by 

providing an accessible framework that sets unified engineering and design 

specifications. Performance specifications, component compatibility, and safety are all 

addressed by codes and standards. Although often interchangeable, the terms code and 

standard have distinct meanings and implications. Both should be written in legally 

enforceable language. However, as defined in fire and building codes, a code dictates that 

a requirement must be met and is often implemented and enforced by Authorities having 

Jurisdiction (AHJs). A standard defines how to fulfill the requirement dictated by the 

code. For example, a building code might require a certain type of building to use 

sprinkler protection. A sprinkler standard, which could be referenced within the code, 

specifies the requirements for building sprinkler systems. The standard, on its own, does 

not require anything; it merely defines metrics within the context of the standard itself. 

For enforceability, the standard is incorporated into a code or regulation that mandates 

compliance to the standard. Figure 1 illustrates the codes and standards hierarchy.

Codes, and by extension standards cited within codes, are legally enforceable documents 

when a jurisdiction adopts them either by reference or direct incorporation into the 

jurisdiction’s regulations. Standards, referenced in the code, then become legally 

enforceable documents when the code is adopted. Codes and standards for the built 

environment are typically enforced at the local level by the town or county building and 

fire department, the typical AHJ for local governments. Stationary fuel cell application 

codes and standards are typically enforced at the federal (at government facilities) or state 

levels, which tend to have greater self-enforcement than built environment codes and 

standards.

Codes and standards in the United States are, for the most part, promulgated under a 

system of rules established by the American National Standards Institute (ANSI) [3]. 

Several Standards Development Organizations (SDOs) develop codes and standards 

according to ANSI rules for document development and maintenance. 
3 

Figure 1: Codes and Standards Hierarchy
4 

Fuel Cell Technologies Codes and Standards Project

NREL’s Codes and Standards Group applied a comprehensive approach to addressing 

codes and standards gaps for the Fuel Cell Technologies Program. Codes and standards 

issues as they related to safety, fuel quality, education and outreach programs, as well as 

production, transit, and storage infrastructure were addressed. The success of this activity 

clearly demonstrates that this approach would facilitate implementation of the other fuel 

cell applications. Accordingly, NREL’s Codes and Standards Group addressed all 

stationary fuel cell application codes and standards. The approach used for hydrogen 

technologies, which included National Template for Codes and Standards, Research, 

Training and Outreach, and Codes and Standards Development, has been applied to all 

stationary fuel cell application codes and standards. Figure 2 illustrates the outline for the 

comprehensive Codes and Standards Program. 

National Templates 

A national template for specific stationary fuel cell applications has been developed. The 

template provides an overview of the codes and standards associated with stationary fuel 

cell applications. The codes and standards referenced in each section are intended to 

provide a comprehensive listing of codes and standards that pertain to stationary fuel cell 

applications.

Research 

Often, sufficient data does not exist to allow for the defensible development of an 

enforceable standard. When the need for technical information for a code or standard is 

identified, a research program is initiated and designed to provide the necessary data. The 

research is performed within the national laboratory system, directly or through managed 

subcontracts, and the result is presented directly to the technical committee responsible 

for producing or revising a code or standard. 

Training and Outreach 

The NREL Codes and Standards Group has an active Training and Outreach Program, 

providing multi-media and on-site training opportunities for code officials and other 

stakeholders. Training opportunities for fuel cells are available through online resources, 

printed media, fact sheets, and on-site training workshops. Online resources include case 

studies of various facilities (e.g., cell towers and fueling stations), searchable databases of 

relevant codes organized by topic and code organization, and networking opportunities 

with personnel experienced in the permitting process. Special topics are also included 

online, such as the “Introduction to Hydrogen for Code Officials” short course [1]. 

Complementing the online resources are live training workshops and presentations to 

various code officials. Special emphasis is on the training workshop for permitting 

officials, of which more than 10 were held in two years [2]. The NREL Training and 

Outreach Program also provides Third Party Reviews for key programs (e.g., fork lift 

operations). Printed media includes handouts at workshops, and hydrogen fact sheets. 

The success of the Hydrogen Training and Outreach Program ensures that comparable 

programs for alternative fuels are highly beneficial. 
5 

Fuel Cell Technologies Codes and Standards Development Process

Codes and standards development is occurring within the domestic market and in the 

international arena. Typically, codes and standards are written through a consensus 

process by a committee comprised of interested parties and stakeholders. To ensure a 

balanced representation among stakeholders during the development process, the 

committee is comprised of representatives from industry, end-users, and regulatory 

agencies. NREL is represented on several codes and standards technical committees as 

well as actively monitoring the activities of several committees. Using information from 

these technical committee activities, NREL determines where research or data are needed 

to help develop new codes and standards requirements, and also ensures harmonization 

between domestic and international standards. NREL conducts research at NREL or 

coordinates research so it is conducted at other DOE laboratories or independent 

laboratories under the auspices of DOE to produce the required information. NREL then 

presents this information directly to the codes and standards technical committees for use 

in document development. By working directly with the codes and standards 

development committees, NREL ensures that the information needed for new codes and 

standards requirements is presented directly to the committee and that committee 

members have an opportunity to discuss and, therefore, clearly understand the 

information. In addition, NREL’s participation on the codes and standards committees

ensures harmonization between standards. Figure 3 illustrates the NREL Codes and 

Standards development protocol, which is consistent with the procedure mandated by 

ANSI.

The process of working directly with the codes and standards technical committees has 

been effective. Several projects progressed as a result of this direct participation in the 

codes and standards development process, including the following: 

1. National Fire Protection Association (NFPA) 2 Hydrogen Technologies Codes 

2. ISO Draft International Standard (DIS) 26142 Hydrogen Detection Apparatus. 
6 

Figure 2: The NREL Codes and Standards Project 
7 

`

Figure 3: The codes and standards development process
8 

Stationary Fuel Cell Technologies

There are several types of stationary fuel cell technologies available today. The four 

most common types are shown in Figure 4. The primary difference between the 

technologies is the electrolyte and associated difference in optimum operating 

temperatures. 

In all cases, the stationary fuel cell utilizes a fuel gas to produce electricity by the use of 

an electrolyte between an anode and cathode. 

Figure 4: Stationary Fuel Cell Technologies [4] 

There are also several challenges relative to fuel cell technology commercialization [5]. 

Cost and durability are the major barriers; however, several other hurdles exist depending 

upon which technology and application is employed. System size, air, and thermal and 

water management are all barriers to fuel cell technology commercialization. 

A fuel processor converts fuel fed to the fuel cell into a usable form [6]. A processor 

may not be required when hydrogen is the feed gas; however, the hydrogen may need to 

be purified. If the system is powered by a hydrogen-rich, conventional fuel, such as 

methanol, gasoline, diesel, or gasified coal, a reformer is typically used to convert 

hydrocarbons into a gas mixture of hydrogen and carbon compounds called "reformate." 

In many cases, the reformate is then sent to another reactor to remove impurities to 
9 

tolerable levels before it is sent to the fuel cell stack. This process prevents impurities in 

the gas from binding with the fuel cell catalysts. This binding process is also called 

"poisoning" because it reduces the efficiency and life expectancy of the fuel cell. It is 

important to note that when hydrogen is used as the fuel fed to the fuel cell, generally the 

hydrogen is produced by steam methane reforming of compressed natural gas. Further 

research efforts are ongoing to capture the carbon compounds produced during this 

process.

Some fuel cells, such as molten carbonate and solid oxide fuel cells, operate at 

temperatures high enough that the fuel can be reformed in the fuel cell itself. This is 

called internal reforming. Fuel cells that use internal reforming still need traps to remove 

impurities from the unreformed fuel before it reaches the fuel cell.

Both internal and external reforming release carbon dioxide, but less than the amount 

emitted by internal-combustion engines, such as those used in gasoline-powered vehicles.

In addition to the technologies discussed above, there are other types of fuel cells 

available, but not commonly used. Figure 5 shows a comparison of fuel cell 

technologies. 

Figure 5: Comparison of Fuel Cell Technologies [7] 
10

Codes and Standards Structure

Table 3, below, contains citations for codes and standards that are applicable to stationary 

fuel cell applications. The citation set is generally focused on hydrogen applications and 

are for a typical application; however, there may be variations in specific jurisdications.

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

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
11

Codes and Standards Citations for Stationary Fuel Cell Applications

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

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
12

Codes and Standards Citations for Stationary Fuel Cell Applications

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

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
13

Codes and Standards Citations for Stationary Fuel Cell Applications

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

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
14

Codes and Standards Citations for Stationary Fuel Cell Applications

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

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
15

Codes and Standards Citations for Stationary Fuel Cell Applications

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
16

Gaps in Codes and Standards

Model and Design Codes

Model codes and standards exist for the installation of stationary fuel cell applications. 

In general, the codes and standards are complete with no large gaps. However, in some 

cases, there is some confusion that exists at the installer and inspector level, generally 

regarding the storage of alternative fuels. For example, an instance was cited where 

neither party could determine which separation distances apply according to NFPA 55, 

10.3.2.2.2. 

Appliances and Generators 

There are currently no listings that apply to hydrogen generators that are not a part of the 

fuel cell system. The Underwriters Laboratory (UL) listing for generators is currently 

held up because the Compressed Gas Association (CGA) has not granted rights to ISO 

for referencing CGA standards. Until this gap is filled, FC-1 and NFPA 853 could be used. 

Component Standards

Currently, there are no component standards for hydrogen use in low- and high-pressure 

systems, including valves, regulators, fittings, flexible connectors, etc. 

Qualification Testing

Qualification testing standards for plastic and composite components need to be 

developed. 

Hazardous Waste

Some fuel cell systems with internal reformers contain materials that are considered 

hazardous waste when removed from the system for replacement. This waste disposal 

issue may add to the system cost and could be potentially addressed through using less 

hazardous materials.

Fuel Quality

There is currently no fuel quality specification standard for stationary fuel cell 

applications that utilize hydrogen as a fuel. ISO TC197 Working Group 14 has been 

formed for the purpose of drafting a fuel specification standard. Domestically, industry 

focus is to utilize SAE J2719 specification as a reference in CGA 5.5.

Product Standard Including “Bumping” Refills of Stationary Storage

There is no domestic product standard for the dispensing of hydrogen for stationary fuel 

cell applications. Furthermore, there is no process for refilling stationary storage systems 

for stationary fuel cell applications (bumping). The fuel cells used for backup power 

typically do not require frequent filling or cylinder replacement so this has not been an 

issue that has impeded operating fuel cells.

Coordination of International and Domestic Fuel Cell Standards

Most fuel cell manufacturers sell their products in more than one country. Selling in 

multiple country markets can create the need for coordination between U.S. and 

international fuel cell standards. This coordination has been, for the most part, addressed 

through industry representation on domestic and international standards development 

committees.
17

Summary

Table 4 presents a summary of the identified Codes and Standards Gaps for alternative 

fuels used with stationary fuel cell systems. Also included in the table is the impacted 

document and proposed means to address the gap. 

Table 4: Codes and Standards Gaps for Stationary Fuel Cell Applications

Codes and Standards Gap Documents Impacted Gap Resolution

Model and Design Codes – 

Coordination Issues

NFPA 55, NFPA 853, 

ASME B31.12, CGA 

F/C 1

Work with the SDOs and 

assist as needed to ensure 

the required cross 

references are placed in 

the installation and storage 

documents.

Appliances/Generators – UL listing 

is held up at CGA by not granting 

rights in ISO documents (22374) for 

reference

UL 2264 A,B, and C, 

CGA documents, ISO 

22374

Work with SDOs to develop 

a path for referencing CGA 

documents.

Component Standards for hydrogen 

use in low- and high-pressure 

systems (valves, regulators, fittings, 

flexible connectors, etc.) need more 

detailed requirements, such as 

those found in NFPA 54 for natural 

gas applications

NFPA 853 and FC-1 

Review existing documents 

for natural gas, specifically 

NFPA 54, and consider 

writing parallel 

requirements in NFPA 853 

and FC-1. 

Qualification Testing Standards for 

plastic and composite components UL, CGA, CSA, ASTM 

Develop testing standards 

for system components as 

needed – NFPA 853 and 

FC-1.

Coordination of International and 

Domestic Fuel Cell Standards

Multiple SDOs and 

documents

Track domestic and 

international fuel cell 

standards to ensure no 

major conflicts impede the 

applications of fuel cell 

technologies.
18

There is currently no hydrogen Fuel 

Quality Standard written specifically 

for fuel cells

CGA, ISO

There is a CGA commodity 

standard for hydrogen that 

is currently being used for 

fuel cells. On the 

International level ISO 

T/C197 Hydrogen 

technologies Working 

Group 14 is developing a 

fuel quality standard for 

hydrogen for stationary fuel 

cells. Domestically, 

industry focus is to utilize 

SAE J2719 specification as 

a reference in CGA 5.5. 

Lack of understanding of fuel cell 

technology, specifically the storage 

of alternative fuels, on the part of 

enforcing authorities

Multiple documents

Continue outreach to code 

officials in the form of web 

materials, online training, 

and codes and standards 

workshops.
19

Conclusion

The previous sections presented the status of the codes and standards for stationary fuel 

cell applications. The broad conclusion of this report is that, because of the development 

of several key documents, and Article 692 of the NEC, stationary conventionally fueled 

fuel cell systems can be installed and operated without significant codes and standards 

delays. There is an ongoing need to coordinate alternative fuel storage installation and 

component product safety standards, and domestic and international standards. The 

mechanisms to accomplish this coordination are to a large extent in place and functional. 

These mechanisms include industry participation on the various codes and standards 

technical committees responsible for these various aspects of fuel cells, and DOE 

monitoring and participation in the codes and standards development process. 

The stationary fuel cell technologies that currectly are being commercially applied are:

1.PEM

2.Phosphoric Acid 

3.Molten Carbonate 

4. Solid Oxide 

Although there are several fuels that are used to power stationary fuel cells, hydrogen, as 

it does with other applications, presents some of the greatest codes and standards 

challenges. These challenges include siting hydrogen storage systems, identifying 

materials and components compatible with hydrogen use, and educating code officials on 

how hydrogen is used in fuel cells. There were cases were hydrogen powered fuel cells 

were initially viewed as combustion devices (i.e. boilers) and combustion requirements 

were to be applied. 
20

References 

1. U.S. Department of Energy, Hydrogen Program “Introduction to Hydrogen for 

Code Officials.” http://www.hydrogen.energy.gov/code_official_training.html. 

Accessed August 2, 2010 

2. U.S. Department of Energy, Hydrogen Program “Permitting Hydrogen Facilities.” 

Hydrogen Fueling Station Related Links 

http://www.hydrogen.energy.gov/permitting/stations_related.cfm. Accessed 

August 2, 2010 

3. American National Standards Institute (ANSI), “Standards Activities Overview.” 

Overview of the U.S. Standardization System 

http://www.ansi.org/standards_activities/overview/overview.aspx. Accessed 

August 2, 2010 

4. California Stationary Fuel Cell Collaborative “Fuel Cell Technologies.” 

http://www.casfcc.org/2/StationaryFuelCells/FuelCellTechnologies.aspx. 

Accessed August 2, 2010 

5. Energy Efficiency & Renewable Energy, Fuel Cells “Fuel Cell Technology 

Challenges.” 

http://www1.eere.energy.gov/hydrogenandfuelcells/fuelcells/fc_challenges.html. 

Accessed August 2, 2010 

6. Energy Efficiency & Renewable Energy, Fuel Cells “Fuel Cell Systems.” 

http://www1.eere.energy.gov/hydrogenandfuelcells/fuelcells/fc_systems.html. 

Accessed August 2, 2010 

7. Energy Efficiency & Renewable Energy, Fuel Cells “Types of Fuel Cells.” 

http://www1.eere.energy.gov/hydrogenandfuelcells/fuelcells/fc_types.html. 

Accessed August 2, 2010 
21

APPENDIX I:

Biographies (in alphabetical order):

Connie Bielawski, MBA

Project Manager

Ms. Bielawski is a Project Manager in the Alternative Energy Program at CSA. Ms. 

Bielawski is responsible for managing and providing support to Technical and 

Advisory Committees for Natural Gas and Hydrogen Vehicle related Standards 

Development projects. Ms. Bielawski is the secretariat for TC 105 Working Groups 1, 

3, and 8. Ms. Bielawski holds a Bachelor’s Degree in Biology and a Master of 

Business Administration from Cleveland State University. 

Chad Blake

Senior Project Leader, NREL

Chad Blake is a Senior Project Leader in the Codes and Standards Group of the 

Hydrogen Technologies and Systems Center at NREL in Golden, Colorado. He has 

worked at several DOE laboratories for 15 years in nuclear, energy, government, 

operations, and research environments. He joined NREL in 2007 and currently leads 

codes and standards hydrogen fuel quality efforts as well as R&D on other renewable 

transportation fuels. He is a member of the International Energy Agency’s Task 19, 

the DOE Hydrogen Safety Panel, and several codes and standards related committees.

William P. Collins 

UTC Power

William Collins holds a Bachelor of Science in mechanical engineering from the 

University of Connecticut and a Master of Science in management from Rensselaer 

Polytechnic Institute. Mr. Collins has more than 30 years experience in the fields of 

power generation, fuel cells, and hydrogen. He is a member of the SAE Fuel Cell 

Vehicles Standards Committee, the CSA America Fuel Cell Tag, the NFPA Electrical 

Generating Committee, the ASME B31 Section 12 book committee, and the US-TAG 

for ISO TC197. 
22

Biographies (in alphabetical order):

Michael M. Penev

Senior Analyst, NREL

Michael Penev provides techno-economic analysis for hydrogen infrastructure and fuel 

cell technology deployment scenarios and advises on fuel cell market transformation 

activities. Additionally, Michael represents NREL on DOE’s Hydrogen Production 

Technology Team, which consults on hydrogen production pathways and reviews 

project progress. 

Previous to joining NREL, Mr. Penev was employed for 7 years by Plug Power Inc in 

Latham, New York and 1 year in the Netherlands. In this position he worked as a 

systems engineer and specialized in fuel processor and fuel cell system design, as well 

as system integration. Mr. Penev has extensive experience with both PEM and PBI 

fuel cell systems.

Mr. Penev holds a master’s degree in mechanical engineering from Union College in 

Schenectady, New York, and a bachelor’s degree in chemical engineering from the 

University of Washington in Seattle, Washington. 

Chris Radley

Altergy Systems 

Mr. Radley leads Altergy’s Product Line Management organization, which includes 

Field Services. Prior to this, he led Altergy's Product and Process Engineering 

department. During his tenure, his team developed and listed Altergy's Freedom Power 

System product line for stationary backup power applications. He has worked with 

more than 80 local U.S. jurisdictions to obtain building permits related to the 

installation of stationary fuel cell power systems and has trained more than 300 

firefighters on fuel cell and hydrogen safety. 

Mr. Radley earned his Master of Business Administration degree from the University 

of California-Davis, and his Master of Science degree in Mechanical Engineering from 

California State University-Sacramento. He attained a Bachelor of Science degree in 

Aeronautical Engineering from Rensselaer Polytechnic Institute in Troy, New York. 

Mr. Radley was also a volunteer firefighter for 10 years.
23

Biographies (in alphabetical order):

Carl Rivkin, P.E.

Senior Project Leader II, NREL

Mr. Rivkin is the project leader for the Codes and Standards Project team at NREL in 

Golden, Colorado. The Codes and Standards Group at NREL has responsibility for 

implementing the U.S. National Template of Codes and Standards for alternative fuels 

for stationary fuel cell applications. This implementation effort runs the gamut from 

running a sensor test laboratory to evaluating the performance of chemical sensors to 

conducting codes and standards seminars to assisting code officials in permitting 

facilities.

Mr. Rivkin has more than 25 years of experience in safety and environmental 

engineering, including work at a regulatory agency. Prior to joining NREL, Mr. Rivkin 

worked for the NFPA on alternative energy code projects. He was also the editor of 

“The NFPA Guide to Gas Safety,” published in 2005, which has several chapters 

devoted to hydrogen and flammable gas safety. 

Mr. Rivkin has a bachelor’s degree in chemical engineering from the University of 

Michigan and an MBA from the University of Baltimore. He is a licensed Professional 

Engineer and Certified Safety Professional.

Douglas Wheeler

DJW Technology 

Douglas Wheeler is the owner of DJW TECHNOLOGY. Mr. Wheeler received his 

Master of Science from Case Western Reserve University and has more than 40 

years of experience in research, development, demonstration, and 

commercialization of energy technologies. Mr.Wheeler managed UTC Fuel Cells 

Advanced Technology Group and guided UTC Fuel Cells’ PEM technology team 

during the transition from Phosphoric Acid fuel cells to PEM fuel cells. He has 

participated in the commercialization of fuel cell systems and the development of 

hydrogen production technology. He was invited by DOE to review the status of 

fuel cell technology in Finland and worked with Sandia National Laboratory 

assessing Russian fuel cell technology for DOE. A cooperative research and 

development program was established with Russia and Sandia National Laboratory 

to develop fuel cell bipolar plates. Mr. Wheeler has conducted technical, 

manufacturing, and economic assessments of fuel cells and hydrogen technology. 

Mr. Wheeler has 18 U.S. Patents.
24

Biographies (in alphabetical order):

Joseph Zerbo

Power Generation Consultant - Salt River Project, Phoenix Valley, Arizona

Mr. Zerbo provides engineering assistance and training support to all generation 

facilities at the Salt River Project (SRP). He is responsible for the operations and 

maintenance of SRP’s renewable energy assets after their commissioning. Mr. Zerbo 

has 35 years of power generations operational experience and holds a Bachelor of 

Science degree from the State University of New York.

 
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Stationary Fuel Cell Application Codes and Standards: Overview 

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This report provides an overview of codes and standards related to stationary fuel cell applications and identifies 

gaps and resolutions associated with relative codes and standards. The Codes and Standards Group at the National 

Renewable Energy Laboratory (NREL) conducted an analysis of the full range of codes and standards that apply to 

stationary fuel cell applications to determine where the gaps are located in the codes and standards and what work 

must be performed to fill these gaps. The major codes and standards are in place to allow for the implementation of 

stationary fuel cells. 

15. SUBJECT TERMS

stationary fuel cells; codes and standards; gap analysis; fuel cell

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