Development, Adoption, and Implementation of Codes and Standards for Stationary Fuel Cell Power Plants

This article is one of a three-part series of articles that is intended to inform those involved with electrical installations and inspections about fuel cell technology. One article provides general information on fuel cell technology. Another article focuses on specific details associated with interconnection of a stationary fuel cell power plant to the electric grid. This article provides a more general overview of all codes and standards activities affecting stationary fuel cells. It identifies and provides an update on the status of development of codes and standards for fuel cells and information on the mechanisms by which they will be adopted and implemented. The primary focus of the information is on stationary fuel cell applications. Although some of the information relates to non-stationary fuel cell applications, it is possible those non-stationary applications could be used to provide power to a building electrical system and so relevant information is presented for them as well.

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The voluntary sector — as opposed to federal, state, and local authorities — develop most of the codes and standards adopted and implemented in the United States that apply to buildings and their systems. Federal, state and local authorities, however, adopt and implement these documents.

Voluntary standards (standards) are developed by a number of organizations, and involve all interested and affected parties as part of the development process. As shown in the main table below, the American National Standards Organization (ANSI), the American Society of Mechanical Engineers (ASME), the National Fire Protection Association (NFPA), Underwriters Laboratories (UL) and the Institute of Electrical & Electronics Engineers (IEEE) are examples of standards organizations that are developing standards that address some aspect of stationary fuel cell power plants, related equipment and their installation.

Model building codes are also developed in the voluntary sector, and also involve all interested and affected parties. Model building codes are complete “models” for building construction regulations that can be adopted by federal, state, or local agencies for the purpose of addressing public health and life-safety in the built environment.

Model building codes have been developed and maintained for a number of years by three separate organizations in the U.S. These organizations are the Building Officials & Code Administrators International (BOCA), International Conference of Building Officials (ICBO), and Southern Building Code Congress International (SBCCI). To address the desire for one U.S. model code, these three organizations formed the International Code Council (ICC) in 1994 with, among others, the goal of producing one set of model building codes. The 2000 edition of the ICC International Codes has just been published, and replaces the three separate model building codes developed by the above three ICC members. As noted below, a number of the ICC codes contain provisions for stationary fuel cell power plants. Also of importance, these model building codes also adopt by reference many standards; making a model building code a complete package to address building health and life-safety for adoption by federal, state and local authorities.

The adoption of model codes and standards occurs at many levels of government within the U.S., and serves to implement what have been developed in the voluntary sector. The legislative branch of the U.S. government (Congress) has the power to pass laws governing building design and construction, but rarely does. Only in cases where federal preemption is warranted will they act. The regulatory branch of the U.S. government (federal agencies such as those responsible for defense, energy, environment and education) may also be granted authority by Congress to adopt and implement building regulatory programs. Generally speaking, they rely on the voluntary sector model codes and standards noted above, rather than developing their own criteria. They may develop their own criteria where model codes and standards are not available, or where additional criteria are needed to address issues of concern to them as actual owners of buildings. Examples of federal preemption include minimum appliance efficiency standards, manufactured housing design and construction, and accessibility for the physically disabled.

The majority of building regulations are adopted at the state and local level of government. The authority and scope of these regulations can run from a mandatory statewide requirement that cannot be changed by any unit of local government, to the complete absence of any statewide code and complete control of building regulations at the local level. On a very basic level about half of the 50 U.S. states have adopted mandatory statewide building codes of some kind, and authority to adopt codes in the other half of the states resides with local government. Through these state and local requirements, as well as some federal requirements for construction that is financed or supported by the U.S. government, virtually all buildings are covered in some way by some form of minimum building regulation.

To date the majority of building regulations adopted throughout the U.S. do not have any provisions specifically covering fuel cells, although those adopted provisions do provide some basis for acceptance of fuel cells on the basis for equivalent safety to other systems and equipment allowed by those codes. As noted below, the ICC codes do contain such provisions and reference the ANSI Z21.83 standard for the technology. When these ICC codes are adopted, which will occur over the next few years, the timely acceptance of fuel cells should be enhanced because specific criteria will be included in the codes for fuel cells.

From the standpoint of electrical issues the ANSI Z21.83 standard will cover the electrical safety of the stationary fuel cell power plant. Anything within the power plant or accessories outside the plant but supplied by the manufacturer and listed as part of a matched assembly should have had their safety addressed by that standard and other standards as evidenced by the mark of an approved testing and certification agency. The installation of that power plant, however, is addressed in NFPA Standard 853 and by other codes. This, in addition to the reference of the model building codes to NFPA 70 (National Electrical Code), ensures issues associated with connection of the electrical output of the fuel cell to the building electrical system are addressed. Because the electrical system is “blind” as to how the electrical power was generated, there are really no new or unique issues for those installing or inspecting the electrical system between the fuel cell and the load served. Because a fuel cell produces DC power, there will be an inverter associated with the power plant. As noted above, where that inverter is external to the power plant there may be additional issues for the electrical installation and inspection personnel to address. Where the power output of the power plant is interconnected with the electrical grid there will be other electrical issues that will need to be addressed. While covered in broad terms in some of the codes and standards mentioned below, the third article in this series focuses solely on this issue.

Implementation and enforcement of these adopted codes typically rests with local government. Through a review of plans and specifications, proposed construction can be approved. Through field inspections of actual construction, a verification of acceptance and approval to occupy and use buildings can be secured. In addition to local government, the serving electric utility may become involved in the approval process where they have requirements associated with interconnecting to the electric grid. The serving gas utility may become involved in providing and/or approving the service piping to the fuel cell.

The approval process undertaken by state and local authorities also involves verification of compliance with the adopted equipment standards. This verification is typically carried out by an accredited testing organization such as Underwriters Laboratories or CSA International. In addition they are typically also involved in certifying that continued production of the subject equipment meets the adopted standard and the manufacturer is implementing that necessary quality assurance measures. These activities are required by the model building codes and reference standards such as the National Electrical Code and are carried out by such third parties because it is impossible for each and every state and local agency to undertake these activities. Efforts, such as those of the National Evaluation Service, are undertaken on behalf of state and local agencies to review the activities of these third parties in addition to reviewing test results and other data that verify code compliance and then issuing an evaluation report that verifies the degree to which the subject of the report meets those codes.

A summary of the steps in this process might be portrayed as follows:

  • Standards are developed to cover the technology.
  • Model codes are revised to reference a standard and/or include new criteria to address the safe installation and use of the technology.
  • Federal, state and local agencies adopt model codes and/or those agencies develop and enact their own separate criteria.
  • Verification is made that the technology satisfies the subject standards.
  • Those wishing to use the technology submit plans and specifications covering the technology to the agency or agencies having jurisdiction.
  • Plans and specifications are approved based on specific conformance to codes and standards provisions or, where the codes do not provide specific requirements for the technology, are approved based on equivalence with the intent of adopted codes and standards.
  • The technology is installed and inspected for compliance with the approved plans and specifications and conditions of the permit covering the installation.

With respect to stationary fuel cells for buildings, there are standards in place to govern the design, construction and performance of fuel cell power plants, and there are organizations currently testing and certifying conformance to those standards. Those standards, however, do not presently cover the full range of available or anticipated fuel cell technologies.

To secure approval by the applicable federal, state and/or local agency, the proposed installation must meet adopted standards and codes. While the model codes have been recently revised to adopt available standards, those model codes have been adopted by only a few state and local agencies. During the next few years, those new model codes will be increasingly adopted. When what is adopted has not been updated to address fuel cells, then the fuel cell installation must be reviewed and approved on the basis of equivalent performance to other technology allowed by and specifically covered in the model code and standards adopted therein. This is typically called performance equivalency as an alternative method or material.

An evaluation of equivalent performance with respect to the adopted standards and codes and approval of the technology installation is the responsibility of the authority enforcing those codes. The manufacturer or one requesting approval of the installation has the responsibility for making the case for acceptance on the basis for equivalency. Until specific standards and codes are available to provide a specific basis for evaluation and approval of the technology, the authority having jurisdiction may refer to evaluation reports prepared by technical assessment or evaluation services. These reports verify equivalent performance with the adopted standards and codes. To facilitate the evaluation and approval of stationary fuel cell power plants on the basis of performance equivalency, an evaluation protocol has been published and is covered in the table below.

The protocol can be used by code officials to approve a fuel cell or by evaluation services in developing an evaluation report on behalf of the U.S. building regulatory community. Evaluation reports are used by architects, engineers, specifiers and code officials to augment the approval process by way of simple and timely confirmation of code compliance. Fuel cell standards in place today do not cover the full range of available or anticipated technologies, nor are there any criteria in the model codes to cover their installation and integration with the building or facilities with which they are associated. Thus, the protocol will provide the necessary criteria to consider the code-equivalent performance of those fuel cell products not specifically covered by adopted codes and standards.

These tables (link pdf) provides information on a number of U.S. and international standards and code activities related to fuel cells. More information on each can be secured from the appropriate code or standards group.

Dave Conover
Dave Conover has graduate and undergraduate degrees in mechanical engineering. He has been involved with the development, adoption, implementation and enforcement of building construction regulations, focused primarily on energy use and technology acceptance, since 1976. During his involvement with the building industry at the global, national and local level he has held positions with the American Gas Association, the National Conference of States on Building Codes and Standards, the International Code Council and PNNL. He also served as the CEO of the National Evaluation Service, a subsidiary of the three organizations who formed the ICC, focusing on evaluation of new technology for acceptance within building regulatory programs. At PNNL, he is currently focused on all aspects of energy codes and standards as well as development of new technology evaluation protocols.