was provided in response to Dave Conover's March 25 memo.
Points are presented roughly in the order in which they were received; the order does not
presume priority.
Needs that could be satisfied through codes, standards, guidelines, practices, etc. Safety of personnel and property. Safety considerations related to O&M. Ability to meet recognized national fire codes to minimize plant fire hazards. Standards in fuel cell construction to ensure safety. Quality of product (design, installation, operation, and performance). Reliability. Ensure compatibility with any electric system. Operational considerations need to address whatever switch/current breaker is used to
connect the fuel cell facility to the utility. Reduce negative impacts on utility system and upon safety of utility employees. Power quality for the interconnecting utility and its customers. Address environmental issues during installation (noise, construction conditions) that can
be mitigated by smart design. Terminology must be consistent and be defined, whenever possible, as closely to
terminology used by similar products now in the marketplace Allow for acceptance and technology recognition by the public and regulatory bodies. Framework for inspection personnel, architects, consultants and manufacturers on how
and where to install fuel cell power plants. Cross-border acceptance between the United States and Canada, without requalification,
changes and review and sealing of engineering documentation. Product standards ought to describe minimum safety requirements in design,
manufacturing quality, and testing of rated performance. A product listing should be
issued. An interface standard should describe the interface requirements, in this case connection
to the grid; cover safety aspects of design and operation. An installation standard should consider safety and fire as paramount to outdoor and
indoor installations. A performance standard should provide test methods for overall performance testing,
measuring thermal and electrical performance, and standard reporting methods which
would provide a baseline for comparison of different power plants. Ensure that units can be effectively and economically installed, and not be left to the local
inspectors' interpretation.
The design, installation, operation and safety of all power-generating systems is already
adequately covered by the relevant sections of existing codes and standards. Mass
produced "packaged" fuel cell power plants should probably be "listed" by a nationally
recognized testing laboratory so as to be in compliance with the NEC. Fuel cell power
plant technology, as well as any other "distributed utilities" technology, would also be well
served by a standardization of interconnect protocol. New standards to allow the interfacing of fuel cells and other modern solid-state power
producing electronics into the distribution power system. This is particularly true if the fuel
cell is to be used in the distributed generated mode. Certification standards and certification processes are needed for equipment use to
interface the electric portion of the fuel cell with the electric utility system. For example,
there should be a standard that defines diagnostic testing of the electrical protective
systems that are important to the interconnection of the fuel cell with the utility system. There is a need to coordinate the surge protection systems of the utility system with the
surge overvoltage controls associated with the fuel cell when it is operated in parallel with
the electric utility distribution system. This requires the development of new control
systems for the fuel cell output as well as an application guide. Most modern electric utility distribution systems have high speed, fuse saving reclosing of
the circuit. If it is desired for the fuel cell to have a high degree of availability the fuel cell
protective systems have to work in this environment. This requires a standard for the
protective control systems of the fuel cell, so the manufacturer can develop a control
scheme that makes the fuel cell's parallel operation seamless to the electric utility system
to which it is interconnected. Performance standards are needed for the fuel cell to define its ability to control power
flow, frequency, reactive requirements, stability, to load following and to be operated in a
load control economic dispatch mode. Guidelines are needed to define the interaction of
the fuel cell performance without loads connected to the interconnected electric utility
power distribution systems. In general, application guidelines and performance standards
are needed. Standard test Programs are needed to measure all of the Performance
factors of the fuel cell. The performance factors need to be defined that are important to the seamless
integration of the fuel cell into the electric Dower distribution systems.
Customers Facility/fuel cell plant owners (commercial, residential, and institutional users). Insurance
carriers. Permitting authorities and code officials. Local safety off1cials including fire fighters, emergency response officials. Electrical
workers. Utilities (in enforcement of power quality standards). Utility
engineers. Independent power producers. All customers served by the fuel cell facility, or that connect to any utility that receives
power from the fuel cell facility. Serving gas utilities, electric utilities.
Manufacturers who can design to a particular standard rather than for each installation
(e.g., harmonics, utility interconnection protection); their suppliers. Manufacturers of components/turnkey plants. Design firms (A&E firms); contractors, installers. Local code officials
Customer Needs Safety, generally and for personnel. Protection from mechanical, electrical fire. Explosive protection, to the fuel cell, and from the fuel cell to buildings and equipment. Reliability
of
operation. Unattended
continuous
operation. Ease of maintenance. Operational considerations related to the switch/circuit breaker that is used. Power quality at the utility or building distribution system interface. Information on proper application of fuel cells. General design requirements. Installation requirements (mechanical/electrical, safety). General operation insurance requirements. On-site hydrogen at pressure, and potential for forming explosive mixtures in enclosed
spaces, suggest that ignition sources (thermal and electrical), both fuel cell and
proximate equipment, need to be well isolated. DC power conversion and compatibility (voltage wave form and current protection) with
the grid interconnection -- through the meter panel where systems can back-feed. Small fuel cell systems would be expected to operate at low pressures though that may
not always be the case. Local code officials and utility engineers need reference codes and standards for early
fuel cell power plant installations. Jurisdictional clarification regarding which local codes officials need to inspect fuel cell
installations (building, electrical, plumbing). Manufacturers should be able to assess the requirements for design, manufacturing
quality, testing and installation requirements; manufacturers should be able to design the
equipment to the minimum standards required. Minimum quality requirements for manufacturing should be defined, so that
manufacturing facilities can be planned. Minimum testing requirements for compliance of the product manufacturer should be
defined. Codes and standards should be one related set of standards and codes, with no
duplication or ambiguity but complementing each other.
When the product meets the standards the product and installations are recognized and
accepted by all the regulating authorities and code off1cials. Acceptance throughout the United States and Canada, without requalification, testing, or
demonstrating product safety; standard installation drawings are acceptable for permit
applications, and units complying to the installation standard are acceptable to local
inspection personnel. Common definitions, terminology. Pressure vessel inspection and operation issues need to be dealt with. Standardization on grid connection and protection. Acceptability in/by overseas markets. The scope should cover similar issues covered by normal power production and electrical
distribution systems whether operating in a central or distributed mode; attention should
be paid to the same considerations for natural gas fired systems and appliances. Standards may require several subcategories to accommodate large central power
systems, smaller distributed cogeneration systems, and very small remote or portable
power generators. Care should be taken to not bias the effort to one type, size or application. Fuel cells will
appear in a variety of markets and sizes; each will have its own unique needs and risks,
as well as benefits. Regional variations in building codes, safety permitting, emissions controls will also
require inclusion or coverage. The international market and ISO 9000 quality assurance needs should also be
addressed. Standardization of interconnect protocol -- make it easier for the manufacturers to provide
the most cost effective relay protection; make it easier for the project developer to
quantify interconnect costs; would also speed the interconnect approval process.
Current Standards and Related Activities Bechtel: code