Fuel Cell Power Generators - A Guide For Implementation

Fuel Cell Power Electrical Generators - Permitting Guide For Telecom Providers

Installation & Permitting...... 4 Reference Documents...... 4 Organizations:...... 4 Relevant Documents for Compliance (mandated by code or law):...... 4 Other Referenced Documents for Compliance:...... 4 International Fire Code (IFC)- implementation by state governments:...... 5 International Fuel & Gas Code (IFGC)- implementation by state governments:...... 5 General Safety Requirements (independent of fuel or fuel cell type):...... 6 Specific Requirements for the Fuel Cell Power System (power generator)...... 7 Federal Communication Commission (FCC)...... 7  Definitions...... 7  Components & Systems Certifications...... 7  Labeling & Signage...... 7 NFPA 2 Hydrogen Technologies Code - 2011 edition - (reference only)...... 8  Components & Systems Certifications...... 8 NFPA 853 Installation of Stationary Fuel Cell Power Systems -2010 edition...... 8  Components & Systems Certifications...... 8  Location, Capacity, Siting, & Setbacks...... 8  Piping, Valves, Regulators, Fuel Controls...... 9  Vents & Ventilation...... 9  Fire & Emergency Response...... 10  Fire Prevention & Emergency Plan:...... 10 NFPA 70 National Electric Code -2014 edition...... 10  Definitions...... 10  Components & Systems Certifications...... 11  Piping, Valves, Regulators, Fuel Controls (including pressure relief devices)...... 11  Labeling & Signage...... 11 ANSI FC 1-2012 Stationary Fuel Cell Power Systems...... 12  Location, Capacity, Siting, & Setbacks...... 12  Piping, Valves, Regulators, Fuel Controls...... 12 ANSI FC 3-2004 Portable Fuel Cell Power Systems...... 12  Location, Capacity, Siting, & Setbacks...... 12  Piping, Valves, Regulators, Fuel Controls...... 12 Specific Requirements for the Fuel Supply (including storage and delivery)...... 13 OSHA (29CFR1910): Subpart H - Hazardous Materials...... 13  Definitions...... 13 29CFR1910.101 Compressed gases (general requirements)...... 14  Container types & design & storage construction...... 14  Piping, Valves, Regulators, Fuel Controls...... 14 29CFR1910.103(b) Gaseous hydrogen systems...... 15  Location, Capacity, Siting, & Setbacks...... 15  Container types & design & storage construction...... 16  Piping, Valves, Regulators, Fuel Controls...... 16  Labeling & Signage...... 16 29CFR1910.103(c) Liquified hydrogen systems...... 16  Location, Capacity, Siting, & Setbacks...... 16  Container types & design & storage construction...... 17  Piping, Valves, Regulators, Fuel Controls...... 17  Labeling & Signage...... 17 Safe Transportation of Gaseous Hydrogen, Methane, & gas mixtures - Identified by 49CFR172.101 Hazardous Materials Table...... 18 Safe Transportation of Liquified Hydrogen, Liquified Methane or Natural Gas - Identified by 49CFR172.101 Hazardous Materials Table...... 19

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International Fire Code (IFC)- hydrogen & other flammable gases:...... 20  Definitions:...... 20  Components & Systems Certifications...... 20  Location, Capacity, Siting, & Setbacks...... 20  Container types & design & storage construction...... 20  Piping, Valves, Regulators, Fuel Controls...... 21  Labeling & Signage...... 21  Fire & Emergency Response...... 21 International Fire Code (IFC)- additional requirements for hydrogen-generating and refueling operations...... 21  Location, Capacity, Siting, & Setbacks...... 21 International Fuel Gas Code (IFGC) - Gaseous Hydrogen Systems...... 21  Components & Systems Certifications...... 21  Location, Capacity, Siting, & Setbacks...... 22  Container types & design & storage construction...... 22  Piping, Valves, Regulators, Fuel Controls...... 22  Labeling & Signage...... 23 International Fuel Gas Code (IFGC) - Liquified Hydrogen Systems...... 23  Components & Systems Certifications...... 23 International Fuel Gas Code (IFGC) - additional requirements for indoor hydrogen-generating and refueling operations...... 23  Location, Capacity, Siting, & Setbacks...... 23  Vents & Ventilation...... 23 NFPA 2 Hydrogen Technologies Code - 2011 edition (reference only)...... 24  Container types & design & storage construction...... 24  Labeling & Signage...... 24 NFPA 55 Compressed Gases and Cryogenic Fluids Code - 2013 edition...... 24  Definitions...... 24  Piping, Valves, Regulators, Fuel Controls...... 25  Labeling & Signage...... 25 NFPA 55 Compressed Gases and Cryogenic Fluids Code - additional requirements for hydrogen-generating and refueling operations...... 26  Definitions...... 26  Components & Systems Certifications...... 26  Location, Capacity, Siting, & Setbacks...... 26  Piping, Valves, Regulators, Fuel Controls...... 26  Vents & Ventilation...... 27  Fire & Emergency Response...... 27 Fuel: Flammable Liquids - Methanol...... 28 OSHA (29CFR1910): Subpart H - Hazardous Materials Methanol...... 28 29CFR1910.106 Flammable Liquids...... 28  Location, Capacity, Siting, & Setbacks...... 28  Vents & Ventilation...... 29 29CFR1926.152 Flammable Liquids (Safety & Health Regulations for Construction)...... 30  Container types & design & storage construction...... 30 Safe Transportation of Methanol - Identified by 49CFR172.101 Hazardous Materials Table...... 30  Fuel Transportation & Site Refueling...... 31  Fire & Emergency Response...... 31 Hazardous Substances - Reportable Quantity (RQ) - Methanol...... 31 International Fire Code (IFC)- methanol & other flammable liquids:...... 32  Definitions...... 32  Components & Systems Certifications...... 33  Location, Capacity, Siting, & Setbacks...... 33  Container types & design & storage construction...... 33  Piping, Valves, Regulators, Fuel Controls (including pressure relief devices)...... 33  Vents & Ventilation...... 34  Labeling & Signage...... 34  Fuel Transportation & Site Refueling...... 36  Fire & Emergency Response...... 36

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International Fuel Gas Code (IFGC) - Liquid Fuel...... 37  Components & Systems Certifications...... 37 NFPA 30 Flammable & Combustible Liquids Code - 2012 edition...... 37  Definitions...... 37  Components & Systems Certifications...... 38  Location, Capacity, Siting, & Setbacks...... 38  Container types & design & storage construction...... 39  Piping, Valves, Regulators, Fuel Controls...... 40  Vents & Ventilation...... 40  Labeling & Signage...... 41  Fuel Transportation & Site Refueling...... 41  Fire & Emergency Response...... 42 By application:...... 43 Telecom Use...... 43

of 44 version: 5May2014 Fuel Cell Power Electrical Generators - Implementation Guide For Telecom Providers Installation & Permitting Where public safety is under control of a local Authority Having Jurisdiction (AHJ), the fuel cell will require a permit to be installed and connected. The AHJ may be a federal, state, local, or other regional department or individual such as a fire chief, fire marshal, or permitting agency. The AHJ has responsibility and authority for permitting and defines the requirements as dictated by local codes, state and federal law.

The fuel cell power system (power generator) and the fuel supply (including storage and delivery) have separate compliance requirements.

The fuel cell type determines the fuel used, either gas (pure hydrogen, or a mixture of hydrogen-containing flammable gases) or liquid (methanol, or methanol/water mixture). Reference Documents Organizations: ANSI - American National Standards Institute - responsible for approval of US standards ASTM - American Society for Testing and Materials - standards writing organization for materials testing. CSA - Canadian Standards Association - a Nationally Recognized Test Laboratory & standards writing organization. FCC - Federal Communications Commission - responsible for control and use of RF spectrum. FCC regulations for controlling and limiting equipment RF emissions are part of the US Code of Federal Regulations, Title 47, Part 15 (47CFR15) - Radio Frequency Devices. ICC - International Code Council - international standards writing organization. IEC - International Electrotechnical Committee - international standards writing organization. OSHA - Occupational Safety & Health Administration - part of the US Department of Labor. OSHA regulations are part of the US Code of Federal Regulations, Title 29, Part 1910 (29CFR1910). NFPA - National Fire Protection Agency - US national standards writing organization. UL - Underwriters Laboratories, Inc. - a Nationally Recognized Test Laboratory & standards writing organization

Relevant Documents for Compliance (mandated by code or law): ANSI FC 1 Standard for Stationary Fuel Cell Power Systems (2012 edition) ANSI FC 3 Standard for Portable Fuel Cell Power Systems (2004 edition) IFC International Fire Code (2012 edition most recent; prior editions 2009, 2006, 2003 are still enforced) IFGC International Fuel Gas Code (2012 edition most recent; prior editions 2009, 2006, 2003 are still enforced) NFPA 30 Flammable and Combustible Liquids Code (2012 edition) NFPA 54 National Fuel Gas Code (2012 edition) NFPA 55 Compressed Gases and Cryogenic Fluids Code (2013 edition; prior editions are still enforced) NFPA 70 National Electrical Code (2014 edition) NFPA 853 Installation of Stationary Fuel Cell Power Systems (2010 edition) 29CFR1910 Occupational Health and Safety (OSHA) 47CFR15 Federal Communication Commission (FCC) 49CFR172 Department of Transportation (DOT)

Other Referenced Documents for Compliance: ASME/ANSI B31.3 Process Piping ANSI/IEC 60529 Degrees of protection provided by enclosures ANSI Z21.21/CSA 6.5 Standard for Automatic Valves for Gas Appliances With Distributed Energy Resources ASTM E 108 Standard Test Methods for Fire Tests of Roof Coverings IBC International Building Code IMC International Mechanical Code NFPA 2 Hydrogen Technologies Code (2011 edition) NFPA 24 Standard for the Installation of Private Fire Service Mains and Their Appurtenances NFPA 80 Standard for Fire Doors and Other Opening Protectives NFPA 90A Standard for the Installation of Air-Conditioning and Ventilating Systems NFPA 101 Life Safety Code NFPA 220 Standard Types of Building Construction NFPA 251 Standard Methods of Tests of Fire Resistance of Building Construction and Materials

ANSI/UL 991 Standard for Tests for Safety-Related Controls Employing Solid-State Devices UL 429 Electrically Operated Valves UL 790 Standard Test Methods for Fire Tests of Roof Coverings UL1741 Standard for Inverters, Converters, Controllers and Interconnection System Equipment for Use

Fuel cell power systems and their fuel supplies must meet a number of compliance requirements for safe and legal operation. Below is a detailed list of compliance requirements for the power system and fuel supplies, covering hydrogen gas (H2), liquid hydrogen, biogas (e.g.; methane & hydrogen mix), and liquid fuels (e.g.; methanol). This list is not intended to replace existing code; consult referenced standards for exact language and requirements.

Order of Precedence for Code Compliance: 1. Code of Federal Regulations; specifically, OSHA (Title 29), FCC (Title 47), DOT (Title 49) 2. State government-approved safety & design codes - typically adopted from International Code Council (ICC); these include the International Fire Code (IFC), International Fuel & Gas Code (IFGC), International Building Code (IBC), etc. 3. State, county, or local municipality approved standard or code. 4. ANSI-approved standards invoked by CFR, state, or local codes; including NFPA, ASME, UL, etc.

Codes & standards relevant for Fuel Cell Power Systems (power generator): NFPA 853 Installation of Stationary Fuel Cell Power Systems (2010 edition) NFPA 70 National Electrical Code (2014 edition) ANSI FC 1 Standard for Stationary Fuel Cell Power Systems (2012 edition) ANSI FC 3 Standard for Portable Fuel Cell Power Systems (2004 edition)

Codes & standards relevant for Fuel Storage: 29CFR1910 Occupational Health and Safety (OSHA) 49CFR172 Department of Transportation (DOT) IFC International Fire Code (2012 edition most recent; 2009, 2006, 2003 are still enforced) IFGC International Fuel Gas Code (2012 edition most recent; 2009, 2006, 2003 are still enforced) NFPA 30 Flammable and Combustible Liquids Code (2012 edition) NFPA 54 National Fuel Gas Code (2012 edition) NFPA 55 Compressed Gases and Cryogenic Fluids Code (2013 edition; prior editions are still enforced) NFPA 853 Installation of Stationary Fuel Cell Power Systems (2010 edition)

International Fire Code (IFC)- implementation by state governments: - enacted as state and/or local law, versions (released by date) adopted by each state (as of Oct 2013): IFC2012 - 2012 edition (most recent): CA, MS, SC, UT, WA, WY IFC2009 - 2009 edition: AL, AK, ID, IL, IA, NC, OH, OK, OR, PA, SD, VA IFC2006 - 2006 edition: AZ, AR, CO, D.C., GA, IN, KS, KY, MN, NV, NJ, NY, TN, TX IFC2003 - 2003 edition: CT, NM

International Fuel & Gas Code (IFGC)- implementation by state governments: - enacted as state and/or local law, versions (released by date) adopted by each state (as of Oct 2013): IFGC2012 - 2012 edition (most recent): MS, RI, SC, UT, WA, WV, WY IFGC2009 - 2009 edition: AL, AK, AZ, CO, FL, ID, IL, LA, MI, MT, NJ, NC, ND, OH, OK, OR, PA, VA, WI IFGC2006 - 2006 edition: AR, D.C., GA, IN, KY,MN, NY, TX, IFGC2000 - 2000 edition: MO

General Safety Requirements (independent of fuel or fuel cell type):

 Noise: The US National Institute for Occupational Safety and Health (NIOSH) establishes recommendations for public health (recommendation only): Centers for Disease Control and Prevention/NIOSH publication 98-126 Section 1.1.2 Time-Weighted Average (TWA) - Recommended Exposure Level (REL) of 85dBA over 8hrs; exposure time is reduced by 50% for every 3dB above 85dBA. Section 1.3 Noise Exposure Assessment (method for compliance) per ANSI Standard Measurement of Occupational Noise Exposure S12.19-1996.

OSHA limits the maximum noise (sound level) exposure in an occupational (workplace) environment. 29CFR1910.95 Occupational noise exposure A-weighted sound level, slow response filter, permissible noise exposures are limited by level and duration. Per Table G-16 Permissible Noise Exposures, the sound level is 90dBA over 8hrs (Table allows for higher levels for shorter durations, not to exceed 115dBA for 15 minutes or less).

The following categories for compliance are used:  Definitions  Components & Systems Certifications  Location, Capacity, Siting, & Setbacks  Container types & design & storage construction  Piping, Valves, Regulators, Fuel Controls (including pressure relief devices)  Vents & Ventilation  Labeling & Signage  Fuel Transportation & Site Refueling  Fire & Emergency Response

of 44 version: 5May2014 Fuel Cell Power Electrical Generators - Implementation Guide For Telecom Providers Specific Requirements for the Fuel Cell Power System (power generator)

Compliance Notes: 1. Fuel cell power systems (power generators) do not require 3rd party safety certification per OSHA (Code of Federal Requirements 29, Section 1910) directives. 2. The International Mechanical Code 2012, 2009, 2006 editions - Section 924 Stationary Fuel Cell Power Systems require testing to ANSI FC 1, and installation per NFPA 853 (for systems <10MW output). 3. NFPA 2 & NFPA 853 requires safety certification to ANSI FC 1 for AHJ approval (permit) of the installation. 4. NFPA 2 has not been adopted as code (regardless of the use of 'code' in its title) - the NFPA created this document as a single source for hydrogen safety, but at present is not legally adopted by any state legislature. Requirements for NFPA 2 are provided here for reference only (e.g.; if an AHJ chooses to invoke it; this standard may be adopted in future code revisions). NFPA 853 is used for the fuel cell power system installation, NFPA 55 is used for the compressed & flammable gas fuel (e.g.; hydrogen), and NFPA 30 is used for flammable liquid fuel (e.g.; methanol) per the ICC and incorporated into state laws. 5. It is the responsibility of the fuel cell power system manufacturer to prove compliance to all legal requirements prior to deploying these products into telecom applications.

Certified approval to ANSI FC 1 is provided by a National Recognized Testing Laboratory (NRTL) in the USA. OSHA has established the NRTL program in compliance with 29CFR 1910.7 for US third-party certification of products to safety standards. For a list of approved NRTLs and details of the program, refer to: https://www.osha.gov/dts/otpca/nrtl/index.html

Compliance requirements identified for each relevant document.

Federal Communication Commission (FCC)  Definitions Compliance is mandated in the USA by federal law. per 47CFR Part 15 - Radio Frequency Devices - Subpart B: Unintentional Radiators. o Radiated and AC conducted RF emission limits by type of application/installation o Class A for industrial/commercial (non-residential), o Class B for residential; o limits per 47CFR15.107 & 109.  Components & Systems Certifications In compliance with US Code of Federal Regulations 47 Part 15, fuel cell power systems are electrical generators and require verification testing by a test laboratory accredited by the National Voluntary Laboratory Accreditation Program (NVLAP); the American Association of Laboratory Accreditation (A2LA); or an accredited laboratory designated by the Commission under the terms of a negotiated Mutual Recognition Agreement (MRA). For information on FCC-approved laboratories: https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm

Following a successful test with report from the accredited laboratory, the manufacturer issues a Declaration of Conformity (DoC) for each model successfully tested. A successful test report from the accredited laboratory meets the requirements for verification testing and the DoC is the manufacturer's resulting claim for compliance. o Compliance is required per model number; o be rated for the Class of installation, and o must carry the FCC logo and warnings on the nameplate and on the inside cover of the product manuals per 47CFR15.19(a)(3).  Labeling & Signage - Nameplate: o The product nameplate for each model of power generator must carry the NRTL Mark (in compliance with FC 1), FCC Mark, and compliance warnings (per FCC by law and FC 1 by code).

NFPA 2 Hydrogen Technologies Code - 2011 edition - (reference only)  Components & Systems Certifications o Requires listing (certified approval) of the stationary fuel cell power system to ANSI FC 1 [NFPA2-2011 12.3.1.1.1.1] o Modular (engineered and field-constructed) systems shall meet intent of ANSI FC 1 [NFPA2-2011 12.3.1.1.2.1]

NFPA 853 Installation of Stationary Fuel Cell Power Systems -2010 edition  Components & Systems Certifications o Requires listing (certified approval) of the stationary fuel cell power system to ANSI FC 1 [NFPA853-2010 4.2 & 4.3] o Modular (engineered and field-constructed) systems require a fire risk evaluation by a registered engineer or AHJ-acceptable 3rd party. [NFPA853-2010 4.4]  Location, Capacity, Siting, & Setbacks - Siting: [NFPA853-2010 5.1.1] o anchored to a foundation, physically protected, o above base flood elevation, o resistant to rain, snow, ice, freezing temperatures, wind, seismic events, and lightning, o accessible to service & fire department personnel, o locate exhaust vents away from building openings, o located 5 ft. (1.5m) from other flammable or hazardous chemicals - Outdoor Installations [NFPA853-2010 5.2]: o do not direct exhaust vents onto walkways or pedestrian paths o fuel-bearing components located 15 ft. (4.6m) from building openings, including HVAC intakes, - or - If fuel cell power system is 50kW or less, this is modified by Section 9.2 to: o fuel-bearing components located 10 ft. (3m) from building openings, including HVAC intakes, and o exhaust outlets not directed onto pedestrian walkways. - Indoor Installations [NFPA853-2010 5.3]: o power system in a room separated from the rest of the building by floor, wall, and ceiling (including piping seals and joints) with 1-hour fire resistance rating (per NFPA 251 Standard Methods of Tests of Fire Resistance of Building Construction and Materials), o with fire doors (per NFPA 80 Standard for Fire Doors and Other Opening Protectives), o dampers (per NFPA 90A Standard for the Installation of Air-Conditioning and Ventilating Systems), o and egress (per NFPA 101 Life Safety Code) or the locally adopted building code. - or - If fuel cell power system is 50kW or less, this is modified by Section 9.3 to:  fuel cells supplied by natural gas, propane, or fuel oil and located in residences do not require fire-rated separations [NFPA853-2010 9.3.1];  fuel cells supplied by methanol or other alcohol fuels and located in residences do not require fire-rated separations if meet requirements of Sections 9.3.6.1 through 9.3.6.4 [NFPA853-2010 9.3.2] For liquid fuel: . <0.019 m3 (5 gal) of liquid fuel within the entire system including piping, during all modes of operation, standby, and shutdown [NFPA853-2010 9.3.6.1], . bulk fuel storage located outside [NFPA853-2010 9.3.6.2], . solid pipe or tube or all-welded, soldered, or brazed construction for indoor piping up to and through the fuel cell power system enclosure [NFPA853-2010 9.3.6.3], . requires leakage detection and automatic isolation of the indoor fuel piping from the outdoor bulk fuel supply upon detection of fuel leakage (using pump stoppage, valve closure, or other manufacturer supplied control). . Requires an automatic isolation valve at the tank for outdoor bulk fuel storage located at an elevation above the fuel cell power system. [NFPA853-2010 9.3.6.4] o Liquid fuel systems shall be provided with curbing, diking, or drainage in accordance with NFPA 30, Flammable and Combustible Liquids Code. [NFPA853-2010 8.1.5.2] - Rooftop Installations [NFPA853-2010 5.4]: o roofing material below and within 12 inches (30.5cm) horizontally from the power system, or . components shall be non-combustible, or

. have Class A rating per either - ASTM E 108 Standard Test Methods for Fire Tests of Roof Coverings or - UL 790 Standard Test Methods for Fire Tests of Roof Coverings - Electrical: o Electrical connections and grounding per NFPA 70 National Electrical Code; specifically, Article 692 Fuel Cell Systems. [NFPA853-2010 5.5.1] o dry type transformers in use around/inside fuel cell; installed per NFPA 70 National Electric Code. o oil-filled transformers >500 gallons (>1892 L) require protection from one of the following: 1. 25 ft (7.6 m) minimum spacing between transformer containment & other structures, or 2. 2-hr-rated fire barrier, extending 1ft (30.5cm) above and 2ft (61cm) beyond the sides of transformer and other adjacent structures or equipment, or 3. automatic deluge water spray system per NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection; 0.25 gpm/ft2 (10.2 L/min*m2) minimum spray density over all transformer surfaces.  Container types & design & storage construction - Fuel Storage: o Gas Hydrogen storage per NFPA 55 Compressed Gases and Cryogenic Fluids Code. [NFPA853-2010 6.4.1] o Liquid Hydrogen storage per NFPA 55 Compressed Gases and Cryogenic Fluids Code. [NFPA853-2010 6.4.2] o Liquid fuel storage & piping per NFPA 30 Flammable and Combustible Liquids Code [NFPA853-2010 6.5.4] o Natural gas (methane) storage & piping per NFPA 54 National Fuel Gas Code [NFPA853-2010 6.2.1] o Compressed natural gas (CNG) piping & valves per NFPA 52 Vehicular Fuel Systems Code [NFPA853-2010 6.2.2] o Biogas (from decomposition of organic matter) storage, piping, valves, & regulators per NFPA 54 National Fuel Gas Code [NFPA853-2010 6.5.3] o Liquified Petroleum Gas (LP-Gas) storage & piping per NFPA 58 Liquified Petroleum Gas Code [NFPA853-2010 6.3]  Piping, Valves, Regulators, Fuel Controls o Hydrogen piping per ASME/ANSI B31.3 Process Piping. [NFPA853-2010 6.4.3] o requires an accessible manual shutoff valve located within 6 ft. (1.8m) of the storage container. [NFPA853-2010 6.4.3.1] o requires a 2nd accessible manual shutoff valve located within 6 ft. (1.8m) of the storage container [NFPA853-2010 6.4.3.2] - unless: . power system is enclosed by a room with 1-hour fire resistance rating per NFPA 251 Standard Methods of Tests of Fire Resistance of Building Construction and Materials, . with fire doors per NFPA 80 Standard for Fire Doors and Other Opening Protectives . and dampers per NFPA 90A Standard for the Installation of Air-Conditioning and Ventilating Systems, - or - . hydrogen storage is within 6 ft. (1.8m) of the fuel cell power system. o requires the manual shutoff valve be located outside the 1-hour fire resistance-rated room. [NFPA853- 2010 6.4.3.3] o requires an automatic shutoff valve interlocked with gas detection for fuel sources located outdoors and serving an indoor fuel cell power system. [NFPA853-2010 6.4.3.4] o requires ventilation to the outdoors for Class I Division 2 areas due to hydrogen piping. [NFPA853-2010 6.4.3.6] - Biogas fuel supplies: o gas storage, piping, valves, and regulators designed and installed per NFPA 54 National Fuel Gas Code. [NFPA853-2010 6.5.3] - Power & Ground: o containers & piping requires electrical grounding per NFPA 70 National Electrical Code. [NFPA853-2010 6.4.3.7]  Vents & Ventilation o natural ventilation is allowed (by verification). [NFPA853-2010 7.2.2]

o requires a cover or filter on the inlet vent to prevent foreign matter from entering the system. [NFPA853- 2010 7.2.3] o control interlock to shut down the system upon loss of mechanical ventilation if required. [NFPA853-2010 7.1.4] o control interlock to shut down the system upon loss of mechanical exhaust if required. [NFPA853-2010 7.3.4] o requires ventilation and exhaust system to provide negative or neutral pressure in the room with respect to the building (implies indoor application). [NFPA853-2010 7.1.2] - Ventilation for Indoor Installations: . requires room exhaust rate not less that 150 CFM (45 m3/min.) and not less than 1 CFM/ ft.2 (0.3 m3/min. per square meter) of floor area. [NFPA853-2010 7.3.3] . requires venting of sources of gas to outside building at least 15 ft (4.6m) from building openings. [NFPA853-2010 7.4.1] . requires vents to prevent entry of water or foreign objects. [NFPA853-2010 7.4.2]  Fire & Emergency Response - For liquid fuel supplies: o liquid fuel storage sites require fire hydrants [NFPA853-2010 8.1.1] . per NFPA 30 Flammable and Combustible Liquids Code & . NFPA 24 Standard for the Installation of Private Fire Service Mains and Their Appurtenances . supplying water of at least 250 GPM (946 L/min.) for 2 hours. - or - . be protected in accordance with a fire risk evaluation. o engineered and field-constructed fuel cells (per Section 4.4) require automatic fire detection and alarm system per NFPA 72 National Fire Alarm and Signaling Code. [NFPA853-2010 8.1.2] o Indoor: o automatic fire suppression system that shuts off the fuel supply when activated is required for liquid fuel pumps, [NFPA853-2010 8.1.5.2 & 8.1.5.3] o liquid fueled systems require leak detection [NFPA853-2010 8.1.5.9] o Combustible gas detector(s) required in the fuel cell power system enclosure, the exhaust system, or the room containing the fuel cell power system, including all indoor or separately enclosed gas compressors. [NFPA853-2010 8.1.5.4 & 8.1.5.5] . except if used for a fuel cell power system <50kW where the fuel is either odorized natural gas or LP-gas, or listed for indoor use. [NFPA853-2010 9.5.1] o hydrogen detector required in room when gaseous or liquefied hydrogen is piped into the room from outside. [NFPA853-2010 8.1.5.6] o criteria for combustible gas detection systems, including detection specific to hydrogen: (1) leakage sources and fuel type determines where to locate the detection device(s). (2) The combustible gas detection system shall activate an alarm at 25% of the lower flammable limit (LFL) and shut down the power system fuel supply at 60% LFL, (3) using the lowest LFL of the gas or gas mixture. [NFPA853-2010 8.1.5.7] o Where leak detection is provided, fuel cell power systems that do not use gaseous fuels and do not generate flammable gas mixtures in any part of their systems shall not be required to have combustible gas detection to be installed. [NFPA853-2010 8.1.5.8]  Fire Prevention & Emergency Plan: o see Section 8.2 for specific details required for Fire Prevention and Emergency Plan.

NFPA 70 National Electric Code -2014 edition specifically - Article 692 Fuel Cell Systems  Definitions o Fuel Cell System defined as a complete aggregate of equipment used to convert chemical fuel into usable electricity; with power conditioners and auxiliary equipment; including a reformer if present. [NFPA70-2014 692.2] o Classification of Locations: . Class I locations (i.e. Division 1, Division 2; flammable concentrations likely to ignite) same as 29CFR1910.307. . Class I Group Classifications (flammable gas or vapor): [NFPA70-2014 500.6]

 Group B: (hydrogen)  Group C: (ethylene)  Group D: (propane, methane, methanol, ethanol)  Components & Systems Certifications o Fuel Cell System shall be evaluated and listed for its intended application prior to installation. [NFPA70- 2014 692.6]  Piping, Valves, Regulators, Fuel Controls (including pressure relief devices) - Power: o Disconnecting means using a readily accessible circuit breakers or manually operated switches required to connect all current carrying conductors from the fuel cell power source to all the other conductors in a building or structure. [NFPA70-2014 692.13 & 692.17] o Overcurrent protection required for the fuel cell; overcurrent devices readily accessible. [NFPA70-2014 692.9] o Fuel cell is permitted to supply AC power to a building or structure. [NFPA70-2014 692.10]; transfer switch required if connected to non-grid-interactive systems that use utility backup. [NFPA70-2014 692.59] o Wiring per Chapter 3 of NFPA70. [NFPA70-2014 692.31]; for guidance on ampacity for conductors, see Table 310.15(B)(16). - Ground: o AC & DC output systems require grounding; DC ground bonded to AC ground; grounding conductor sized based on overcurrent device rating…see Table 250.122 Minimum Size Equipment Grounding Conductors for Grounding Raceway & Equipment. [NFPA70-2014 692.41]  Labeling & Signage o A permanent plaque or directory installed at each service equipment location noting all electrical power sources on or in the premises. [NFPA70-2014 692.4(B)] o Nameplate identifies the rated circuit current. [NFPA70-2014 692.8] o If the fuel cell power system employs an AC inverter for generating single-phase 120V, and is connected to a 3-wire 120/240V service with no 240V loads and no multiwire branch circuits, and the overcurrent device connected to the fuel cell output must be rated less than the load - then the equipment must be marked as follows: " WARNING SINGLE 120-VOLT SUPPLY. DO NOT CONNECT MULTIWIRE BRANCH CIRCUITS!" [NFPA70-2014 692.10(C)] - At the disconnecting means for the fuel cell power generator: o Disconnecting means for ungrounded conductors - where terminals may be energized in the open position requires a warning sign with the following words (or equivalent): "DANGER ELECTRIC SHOCK HAZARD DO NOT TOUCH LIVE TERMINALS. TERMINALS ON BOTH THE LINE AND LOAD SIDES MAY BE ENERGIZED IN THE OPEN POSITION" [NFPA70-2014 692.17] o Rated Output: Marking at the disconnecting means for the fuel cell power source specifying the fuel cell system, the output voltage, the output power rating, and continuous output current rating. [NFPA70-2014 692.53] o Fuel Shut Off: manual fuel shutoff valve location must be marked at the disconnecting means. [NFPA70- 2014 692.54] o Electrical Energy Storage within the fuel cell power system: if the fuel cell power system stores electric energy (i.e.; battery or transient power module), warnings required at disconnecting means as follows (or equivalent): "WARNING FUEL CELL POWER SYSTEM CONTAINS ELECTRICAL ENERGY STORAGE DEVICES" [NFPA70-2014 692.56]

ANSI FC 1-2012 Stationary Fuel Cell Power Systems  Location, Capacity, Siting, & Setbacks o no Fuel Storage requirements  Piping, Valves, Regulators, Fuel Controls o FC 1 requires the fuel supplied to the fuel cell power system pass through at least two automatic valves, in series, each of which serves as an operating valve and safety shutoff valve. Typical fuel control design places one valve inside the fuel cabinet or compartment (primary valve) and the other within the fuel cell power generator (secondary valve). o The valves must be compliant to UL 429 Electrically Operated Valves, or ANSI Z21.21/CSA 6.5 Standard for Automatic Valves for Gas Appliances. [ANSI FC1-2012 1.11.2.2.a] - Power & Ground: o Grounding and power connections in compliance with NFPA 70 National Electric Code - Article 692 Fuel Cell Systems.

ANSI FC 3-2004 Portable Fuel Cell Power Systems  Location, Capacity, Siting, & Setbacks - Fuel Storage: o Cylinders containing hazardous compressed gases shall comply with the requirements of the ASME Boiler and Pressure Vessel Code, Section VIII or Title 49 of the US Code of Federal Regulations, Title 49 CFR, Hazardous Materials Regulations, Chapter 1, Subchapter C, Part 178 - Specifications for Packagings. o Removable compressed gas fuel containers shall be equipped with a cylinder valve compliant with the applicable requirements in CGA V-9, Standard for Compressed Gas Cylinder Valves and include a connection fixture that will not allow the flow of gas until a positive seal has been achieved. o Fuel containers require mechanical restraint; can't displace more than an inch (25.4mm) when a lateral force equal to the weight of the container is applied from any direction at the center of the vertical height of the cylinder. [ANSI FC1-2012 1.2.3]  Piping, Valves, Regulators, Fuel Controls o FC 3 requires the fuel supplied to the fuel cell power system pass through at least one automatic valve. o A second automatic valve in series with the first is required if the fuel supply quantity exceeds 25% of LFL if fully released into a volume of 500ft3 (14.1 m3). This does not apply if the fuel cell power system is intended and marked for outdoor use only (single valve only required). [hydrogen supply: 25% of LFL = 1% by volume; > 5ft3 (0.14 m3) of H2 supply requires a second valve]. o The valves must be compliant to UL 429 Electrically Operated Valves, ANSI Z21.21/CSA 6.5 Standard for Automatic Valves for Gas Appliances, FMRC 7400 Liquid & Gas Safety Shutoff Valve, or other nationally recognized standards. [ANSI FC1-2012 1.29.1] - Power & Ground: o Power wiring in compliance with NFPA 70 National Electric Code - Articles 110 & 400 o Grounding in compliance with NFPA 70 National Electric Code - Articles 250.20 & 240.34

of 44 version: 5May2014 Fuel Cell Power Electrical Generators - Implementation Guide For Telecom Providers Specific Requirements for the Fuel Supply (including storage and delivery)

Fuel Supply Compliance Notes:

Determining Code Compliance: Different requirements exist for placement and storage the fuel by type; e.g., gaseous hydrogen, liquid hydrogen, flammable gas (methane or other hydrogen-rich gas), and flammable liquids (methanol). 1. Fuel supplies and fuel storage locations are defined by OSHA directives; the setback distances were derived from the 1969 edition of NFPA 50A - which was made obsolete and replaced by the NFPA as an updated NFPA 55. 2. AHJs have the authority to chose compliance to NFPA 55 in place of default OSHA setback requirements if allowed by local code. 3. Local jurisdictions (state, county, township, borough, etc.) may (by legislation) adopt other safety standards as local code in place of OSHA directives. Federal law (OSHA, other Codes of Federal Regulations) are legally mandated unless other standards or codes are adopted by the state legislature. 4. Each state or local agency within the state makes use of the International Code Council (ICC) international codes for fire safety (International Fire Code - IFC) and fuel & gas safety (International Fuel & Gas Code - IFGC) by incorporating these safety standards into state code. Other ICC international codes for safety are also used, but the IFC and IFGC are specifically relevant for fuel use and storage. 5. Each state ratifies the version (by year of release) of ICC standards and continue to use prior versions until the state legislatures update their state law; this requires evaluation of prior editions to address compliance nation-wide.

A list of ICC standards and the state & local adoption of versions of each ICC standard can be found at ICC's website (select "ADOPTIONS" tab for adoptions of Plumbing Mechanical, Fuel Gas - PMG - codes): http://www.iccsafe.org/cs/PMG/Pages/default.aspx For access to the text of each ICC document:: http://publicecodes.cyberregs.com/icod/ simply stated - for fuel storage & use: comply to OSHA, or by state legal adoption of IFC & IFGC - which invoke compliance to NFPA 55 (and other standards).

Notes for the following compliance review: 1. Evaluation for gaseous and liquid hydrogen, methane, and methanol. Does not cover ammonia or petroleum gases (i.e.; propane, butane, etc.) 2. Evaluation for transportation by road, train, airplane; does not include transportation by sea.

These requirements are specific to the fuel, capacities, and methods of storage, and location Fuel: Flammable Gases - Hydrogen & Liquified Hydrogen Flammable Gases - Methane or other hydrogen-rich gases Flammable & Hazardous Liquid - Methanol

OSHA (29CFR1910): Subpart H - Hazardous Materials OSHA defines liquid hydrogen as liquefied hydrogen with separate requirements (compared to either gaseous hydrogen or flammable liquids).  Definitions o Hydrogen gas - Class I (Flammable gases, vapors, liquids), Group B: Hydrogen, o Methane gas - Class I (Flammable gases, vapors, liquids), Group D: Hydrocarbons, other: Hazardous (classified) locations (29CFR1910.307; definition of terms: 29CFR1910.399) o " Class I, Division 1: Normally explosive and hazardous

(i) In which ignitable concentrations of flammable gases or vapors may exist under normal operating conditions; or (ii) In which ignitable concentrations of such gases or vapors may exist frequently because of repair or maintenance operations or because of leakage; or (iii) In which breakdown or faulty operation of equipment or processes might release ignitable concentrations of flammable gases or vapors, and might also cause simultaneous failure of electric equipment.

Note to the definition of “Class I, Division 1:” This classification usually includes ….all other locations where ignitable concentrations of flammable vapors or gases are likely to occur in the course of normal operations."

o " Class I, Division 2: Not normally present in an explosive concentration (but may accidently exist). (i) In which volatile flammable liquids or flammable gases are handled, processed, or used, but in which the hazardous liquids, vapors, or gases will normally be confined within closed containers or closed systems from which they can escape only in the event of accidental rupture or breakdown of such containers or systems, or as a result of abnormal operation of equipment; or (ii) In which ignitable concentrations of gases or vapors are normally prevented by positive mechanical ventilation, and which might become hazardous through failure or abnormal operations of the ventilating equipment; or (iii) That is adjacent to a Class I, Division 1 location, and to which ignitable concentrations of gases or vapors might occasionally be communicated unless such communication is prevented by adequate positive-pressure ventilation from a source of clean air, and effective safeguards against ventilation failure are provided.

Note to the definition of “Class I, Division 2:” This classification usually includes locations where volatile flammable liquids or flammable gases or vapors are used, but which would become hazardous only in case of an accident or of some unusual operating condition. The quantity of flammable material that might escape in case of accident, the adequacy of ventilating equipment, the total area involved, and the record of the industry or business with respect to explosions or fires are all factors that merit consideration in determining the classification and extent of each location.

Piping without valves, checks, meters, and similar devices would not ordinarily introduce a hazardous condition even though used for flammable liquids or gases. Locations used for the storage of flammable liquids or liquefied or compressed gases in sealed containers would not normally be considered hazardous unless also subject to other hazardous conditions.

Electrical conduits and their associated enclosures separated from process fluids by a single seal or barrier are classed as a Division 2 location if the outside of the conduit and enclosures is a nonhazardous location."

29CFR1910.101 Compressed gases (general requirements).  Container types & design & storage construction - (Fuel Storage) Containers: o Inspection of compressed gas cylinders "…Visual and other inspections shall be conducted as prescribed in the Hazardous Materials Regulations of the Department of Transportation (49 CFR parts 171-179 and 14 CFR part 103). Where those regulations are not applicable, visual and other inspections shall be conducted in accordance with Compressed Gas Association Pamphlets C-6-1968 and C-8-1962…" [29CFR1910.101(a)] o Compressed gases. "The in-plant handling, storage, and utilization of all compressed gases in cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks shall be in accordance with Compressed Gas Association Pamphlet P-1-1965..." [29CFR1910.101(b)]  Piping, Valves, Regulators, Fuel Controls - Safety relief (overpressure release) devices: o Safety relief devices for compressed gas containers. Compressed gas cylinders, portable tanks, and cargo tanks shall have pressure relief devices installed and maintained in accordance with Compressed Gas Association Pamphlets S-1.1-1963 and 1965 addenda and S-1.2-1963…" [29CFR1910.101(c)]

of 44 version: 5May2014 Fuel Cell Power Electrical Generators - Implementation Guide For Telecom Providers 29CFR1910.103(b) Gaseous hydrogen systems  Location, Capacity, Siting, & Setbacks - Location: [29CFR1910.103(b)(2)] system shall be located such that: o shall be readily accessible to delivery equipment and to authorized personnel; o shall be located above ground; o not located beneath electric power lines; o not close to flammable liquid piping or other flammable gas piping; o and not higher than flammable liquid storage except where dikes, diversion curbs, grading, or separating solid walls are used to prevent accumulation of flammable liquids under the system. o The area within 15 feet of any hydrogen container shall be kept free of dry vegetation and combustible material. [29CFR1910.103(b)(5)] - Capacity & setback distances: 29CFR1910.103(b)(2)(ii)(a) Table H-1 limits o >15,000 CF gas storage to separate buildings or outdoors; o 3,000-15,000 CF is limited to outdoors, in a separate building, or in a special room, o and allows <3000 CF to be stored inside building exposed to other occupancies. 29CFR1910.103(b)(2)(ii)(d) defines requirements for H2 storage <3000 CF inside a building: o adequately ventilated per 29CFR1910.103(b)(3)(ii)(b), o inlet opening located near the floor in exterior walls only, o outlet openings at high point in room in exterior walls or roof, o inlet & outlet openings shall have a minimum total area of 1 sq. ft. per 1000 CF of room volume, o discharge from outlet directed to a safe location.  20 feet from stored flammable materials or oxidizing gases,  25 feet from open flames, ordinary electrical equipment, or other sources of ignition,  25 feet from concentrations of people,  50 feet from ventilation intakes for air-conditioning equipment and air compressors,  50 feet from other flammable gas storage,  protected from damage or injury due to falling objects or working activity in the area; o also, more than one system of 3000 CF or less may be installed in the same room, separated by at least 50 feet, and each meeting the requirements above.

Table H2 defines the setback distances by storage capacity: [29CFR1910.103(b)(2)(ii)(c)] type of outdoor exposure example <3,000 3,000 - >15,000 CF 15,000 CF CF 1. Building or structure a. Wood frame construction a. 10 ft. a. 25 ft. a. 50 ft. - see NFPA 220 Standard b. Heavy timber, or ordinary construction b. 0 ft. b. 10 ft. b. 25 ft. Types of Building Construction c. Fire-resistive construction c. 0 ft. c. 0 ft. c. 0 ft. (1969 ed.) 2. Wall openings a. Not above any part of a system a. 10 ft. a. 10 ft. a. 10 ft. b. Above any part of a system b. 25 ft. b. 25 ft. b. 25 ft. 3. Flammable liquids a. 0 to 1000 gallons a. 10 ft. a. 25 ft. a. 25 ft. above ground b. >1000 gallons b. 25 ft. b. 50 ft. b. 50 ft. 4. Flammable liquids a. Tank a. 10 ft. a. 10 ft. a. 10 ft. below ground <1000 gallons b. Vent or fill opening of tank b. 25 ft. b. 25 ft. b. 25 ft. 5. Flammable liquids a. Tank a. 20 ft. a. 20 ft. a. 20 ft. below ground >1000 gallons b. Vent or fill opening of tank b. 25 ft. b. 25 ft. b. 25 ft. 6. Flammable gas storage, High a. low pressure: 0-15,000 CF a. 10 ft. a. 25 ft. a. 25 ft. & Low pressure b. high pressure: >15,000 CF b. 25 ft. b. 50 ft. b. 50 ft. 7. Oxygen storage a. 0 - 12,000 CF - see NFPA 51 (1969 ed.) - - - b. > 12, 000 CF - see NFPA 566 (1969 ed.) - - - 8. Fast-burning solids 50 ft. 50 ft. 50 ft. 9. Slow-burning solids 25 ft. 25 ft. 25 ft. 10. Open flame or sources of ignition 25 ft. 25 ft. 25 ft. 11. Inlets to air compressors, ventilation, or air conditioning equip. 50 ft. 50 ft. 50 ft. 12. Concentrations of people 25 ft. 50 ft. 50 ft.

The distances in Table H-2 type of outdoor enclosure Items 1 and 3 to 10 inclusive do not apply where protective structures such as adequate fire walls are located between the system and the exposure. Refer to OSHA 29CFR1910.103(b)(3) for additional definitions and requirements for building construction types.

 Container types & design & storage construction - (Fuel Storage) Containers: o containers designed, constructed, tested to ASME Boiler & Pressure Vessel Code, Section VIII, Unfired Pressure Vessels 1968 (per Sec. 29CFR1910.6) [29CFR1910.103(b)(1)(i)(a)(1)], - or - o containers designed, constructed, and tested in accordance with US Dept. of Transportation (DOT) Specifications and Regulations. [29CFR1910.103(b)(1)(i)(a)(2)]  Piping, Valves, Regulators, Fuel Controls - Safety relief (overpressure release) devices: Hydrogen containers shall be equipped with safety relief devices as required by o ASME Boiler & Pressure Vessel Code, Section VIII, Unfired Pressure Vessels 1968, or o by DOT Specifications and Regulations. [29CFR1910.103(b)(1)(ii)(a)]  Labeling & Signage o each portable container shall be legibly marked with the name "Hydrogen" per Sec. 1910.253(b)(1)(ii); each manifolded hydrogen supply shall be legibly marked with the name "Hydrogen" or a legend such as "This unit contains hydrogen". [29CFR1910.103(b)(1)(i)(c)] o The hydrogen storage location shall be permanently placarded as follows: "HYDROGEN - FLAMMABLE GAS - NO SMOKING - NO OPEN FLAMES" or equivalent. [29CFR1910.103(b)(1)(v)]

29CFR1910.103(c) Liquified hydrogen systems  Location, Capacity, Siting, & Setbacks - Location: system shall be located such that: o shall be readily accessible to mobile supply equipment and to authorized personnel; o not located beneath electric power lines; o not close to flammable liquid lines, flammable gas lines, or lines carrying oxidizing materials; o and not higher than flammable liquid storage except where dikes, diversion curbs, grading, or separating solid walls are used to prevent accumulation of liquids within 50 feet of the liquefied hydrogen container. o Storage sites shall be fenced and posted to prevent entrance by unauthorized personnel. [29CFR1910.103(c)(2)(i)] o Adequate lighting shall be provided for nighttime transfer operation. [29CFR1910.103(c)(3)(i)(e)] - Capacity & setback distances: Table H-3 limits [29CFR1910.103(c)(2)(ii)(a)] o 51 to 300 gallons is limited to outdoors, a separate building, or in a special room, o 301 to 600 gallons is limited to outdoors, or in a separate building, o >600 gallons liquid hydrogen storage to outdoors only, o and allows 39.63 (150 liters) to 50 gallons to be stored inside building exposed to other occupancies. o does not apply to storage of dewars used in laboratories for experimental purposes. liquid H2 storage 50 gallons or less inside a building: [29CFR1910.103(c)(2)(iii)] o adequately ventilated per 29CFR1910.103(c)(1)(iv)(b) and 29CFR1910.103(c)(2)(i)(f):

 designed and located so that moisture cannot collect and freeze in a manner that would interfere with proper operation,  safety relief devices vented unobstructed to the outdoors at a minimum elevation of 25 feet above grade to a safe location. o 20 feet from stored flammable liquids or materials, o 25 feet from open flames, ordinary electrical equipment, or other sources of ignition, o 25 feet from concentrations of people, o 50 feet from ventilation intakes for air-conditioning equipment and air compressors, o 50 feet from other flammable gas storage or storage oxidizing gases, o protected from damage or injury due to falling objects or working activity in the area, o containers are firmly secured and stored in an upright position, o no smoking, welding, or cutting operations while hydrogen is in the room.

29CFR1910.103(b)(2)(ii)(c) Table H4 defines the setback distances by storage capacity: type of exposure 39.63 3,501 to 15,001 to (150 liters) 15,000 30,000 to 3500 gallons gallons gallons 1. Fire-resistive building and fire walls 5 ft. 5 ft. 5 ft. 2. Noncombustible building 25 ft. 50 ft. 75 ft. 3. Other buildings 50 ft. 75 ft. 100 ft. 4. Wall openings, air-compressor intakes, inlets for air- 75 ft. 75 ft. 75 ft. conditioning or ventilating equipment 5. Flammable liquids (above ground and vent or fill openings if 50 ft. 75 ft. 100 ft. below ground) 6. Between stationary liquefied hydrogen containers 5 ft. 5 ft. 5 ft. 7. Flammable gas storage 50 ft. 75 ft. 100 ft. 8. Liquid oxygen storage and other oxidizers 100 ft. 100 ft. 100 ft. 9. Combustible solids 50 ft. 75 ft. 100 ft. 10. Open flames, smoking and welding 50 ft. 50 ft. 50 ft. 11. Concentrations of people 75 ft. 75 ft. 75 ft. (for types of building construction, refer to NFPA No. 220 Standard Types of Building Construction -1969)

 Container types & design & storage construction - Containers: o containers designed, constructed, tested to . ASME Boiler & Pressure Vessel Code, Section VIII, Unfired Pressure Vessels 1968, or . API Standard 620 Recommended Rules for Design and Construction of Large, Welded, Low- Pressure Storage Tanks, Second Edition (June 1963) and appendix R (April 1965), [29CFR1910.103(c)(1)(i)(a)] - or - . portable containers designed, constructed, and tested in accordance with US Dept. of Transportation (DOT) Specifications and Regulations. [29CFR1910.103(c)(1)(i)(b)]  Piping, Valves, Regulators, Fuel Controls - Safety relief (overpressure release) devices: o Stationary liquefied hydrogen containers shall be equipped with safety relief devices sized in accordance with CGA Pamphlet S-1, Part 3, Safety Relief Device Standards for Compressed Gas Storage Containers; [29CFR1910.103(c)(1)(iv)(a)(1)] o Portable liquefied hydrogen containers complying with the U.S. Department of Transportation Regulations shall be equipped with safety relief devices as required in the U.S. Department of Transportation Specifications and Regulations. o Safety relief devices shall be sized in accordance with the requirements of CGA Pamphlet S-1, Safety Relief Device Standards, Part 1, Compressed Gas Cylinders and Part 2, Cargo and Portable Tank Containers. [29CFR1910.103(c)(1)(iv)(a)(2)]  Labeling & Signage o Sites shall be placarded as follows: "Liquefied Hydrogen - Flammable Gas - No Smoking - No Open Flames".[29CFR1910.103(c)(2)(i)(e)]

Safe Transportation of Gaseous Hydrogen, Methane, & gas mixtures - Identified by 49CFR172.101 Hazardous Materials Table (2) (8) (9) Hazardous Quantity limitations (3) (7) Packaging (1) materials (4) (6) (see §§173.27 and Hazard (5) Special (§173.***) Symb descriptions Identification Label 175.75) class or PG provisions ols and proper Numbers Codes Cargo Division (§172.102) Passenger shipping Exceptions Non-bulk Bulk aircraft aircraft/rail names only Hydrogen, 302, 2.1 UN1049 2.1 N89 306 302 Forbidden 150kg compressed 314 Methane or natural gas, 2.1 UN1971 2.1 306 302 302 Forbidden 150kg compressed Hydrogen 302, and Methane 2.1 UN2034 2.1 N89 306 302 314, Forbidden 150kg mixtures, 315 compressed (3) Hazard class or Division "2.1" : flammable gas per 49CFR173.115(a) definitions (4) Identification Numbers : United Nations (international) material designation for shipping identification number (6) Label Codes : Flammable Gas [see 49CFR172.417 for labeling] (7) Special provisions : N89 = When steel UN pressure receptacles are used, only those bearing the “H” mark are authorized. (8) Packaging : Exceptions [49CFR173.306] = Limited quantities of compressed gases. Non-bulk [49CFR173.302] = Filling of cylinders with nonliquefied (permanent) compressed gases. per 49CFR173.301b(f) Hydrogen bearing gases: A steel UN pressure receptacle bearing an “H” mark must be used for hydrogen bearing gases... per 49CFR173.302a(a)(4): DOT 3AX, 3AAX, and 3T cylinders are authorized for Division 2.1…materials and for carbon monoxide. DOT 3T cylinders are not authorized for hydrogen. When used in methane service, the methane must be a nonliquefied gas with a minimum purity of 98.0% methane and commercially free of corroding components. Bulk [49CFR173.314] = Compressed gases in tank cars and multi-unit tank cars. [49CFR173.315] = Compressed gases in cargo tanks and portable tanks. Container Types approved for Div. 2.1 material (hydrogen, etc.): DOT-51, MC-330, MC-331 (9) Quantity limitations : Forbidden to ship on passenger aircraft or passenger rail, limit of 150kg for cargo aircraft.

of 44 version: 5May2014 Fuel Cell Power Electrical Generators - Implementation Guide For Telecom Providers Safe Transportation of Liquified Hydrogen, Liquified Methane or Natural Gas - Identified by 49CFR172.101 Hazardous Materials Table (2) Hazardous (8) (9) (3) (7) (1) materials (4) (6) Packaging Quantity limitations Hazard (5) Special Symb descriptions and Identification Label (§173.***) (see §§173.27 and 175.75) class or PG provisions ols proper shipping Numbers Codes Passenger Cargo aircraft Division (§172.102) Exceptions Non-bulk Bulk names aircraft/rail only Hydrogen, 318, refrigerated liquid 2.1 UN1966 2.1 T75, TP5 None 316 Forbidden Forbidden (cryogenic liquid) 319 Methane or Natural Gas, 2.1 UN1972 2.1 T75, TP5 None None 318 Forbidden Forbidden refrigerated liquid (cryogenic liquid) (3) Hazard class or Division "2.1" : flammable (liquefied) gas per 49CFR173.115(a) definitions (4) Identification Numbers : United Nations (international) material designation for shipping identification number (6) Label Codes : Flammable Gas [see 49CFR172.417 for labeling] (7) Special provisions : T75 = "…refrigerated liquefied gases are authorized to be transported in portable tanks in accordance with the requirements of §178.277 of this subchapter." TP5 = " For a portable tank used for the transport of flammable refrigerated liquefied gases…the maximum rate at which the portable tank may be filled must not exceed the liquid flow capacity of the primary pressure relief system rated at a pressure not exceeding 120 percent of the portable tank's design pressure…a portable tank shall have an outage of at least two percent below the inlet of the pressure relief device or pressure control valve, under conditions of incipient opening, with the portable tank in a level attitude." (8) Packaging : Non-bulk [49CFR173.316] = Cryogenic liquids in cylinders. (a)(3) "The jacket covering the insulation on a cylinder used to transport any flammable cryogenic liquid must be made of steel." (a)(5) No aluminum valves, pipe, or fittings. (c) "…Specification DOT-4L cylinders (§178.57 of this subchapter) are authorized for the transportation of cryogenic liquids when carried in the vertical position as follows: (i) Each cylinder must be constructed, insulated and maintained so that during transportation the total rate of venting shall not exceed 30 SCF of hydrogen per hour. (ii) In addition to the marking requirements in §178.35 of this subchapter, the total rate of venting in SCF per hour (SCFH) shall be marked on the top head or valve protection band in letters at least one-half inch high as follows: “VENT RATE**SCFH” (with the asterisks replaced by the number representing the total rate of venting, in SCF per hour)." Bulk [49CFR173.318] = Cryogenic liquids in cargo tanks. See section 318 for detailed requirements. [49CFR173.319] = Cryogenic liquids in tank cars. See section 319 for detailed requirements. (9) Quantity limitations : Forbidden to ship on passenger aircraft, passenger rail, or cargo aircraft.

International Fire Code (IFC)- hydrogen & other flammable gases:

Hazard definition & safety performance criteria: IFC2012: Chapter 50 Hazardous Materials - General Provisions IFC2009: Chapter 50 Hazardous Materials - General Provisions IFC2006: Chapter 50 Hazardous Materials - General Provisions IFC2003: Chapter 27 Hazardous Materials - General Provisions

Code Requirements for Flammable Gases (including Liquid Hydrogen): IFC2012: Chapter 58 Flammable Gases & Flammable Cryogenic Fluids - including H2, methane, and CO shall comply with NFPA 55 IFC2009: Chapter 35 Flammable Gases & Flammable Cryogenic Fluids - including H2, methane, and CO shall comply with NFPA 55 IFC2006: Chapter 35 Flammable Gases & Chapter 32 Flammable Cryogenic Fluids - including H2, methane, and CO shall comply with NFPA 55 IFC2003: Chapter 35 Flammable Gases; & Chapter 32 Flammable Cryogenic Fluids - including H2, methane, and CO shall comply with NFPA 50B

 Definitions: o all IFC editions define hydrogen gas or liquid as a Physical Hazard, Flammable gas, either Gaseous or Liquified. [IFC2012: Chapter 50; IFC2009, IFC2006, IFC2003: Chapter 27]  Components & Systems Certifications - Permitting: Compressed gases. IFC2012, 2009, 2006 [Section 105.6.8]; IFC2003 [Section 105.6.9] o An operational permit is required for the storage, use, or handling at normal temperature & pressure (NTP) of compressed gases in excess of…200 cubic feet (ft.3) per Table 105.6.8. Cryogenic fluids. IFC2012, 2009, 2006 [Section 105.6.10]; IFC2003 [Section 105.6.11] o An operational permit is required to produce, store, transport on site, use, handle, or dispense cryogenic fluids in excess of…more than 1 gallon inside building or 60 gallons outside building for flammable cryogenic fluid per Table 105.6.10.  Location, Capacity, Siting, & Setbacks - Fuel Storage: Indoor: IFC2012 Table 5003.1.1(1) Maximum Allowable Quantity [MAQ] per Control Area of Hazardous Materials Posing a Physical Hazard o MAQ: Storage & Closed-System Use - restricts Flammable Gas to 1000 ft3 and Liquified Flammable Gas to 150 lbs per control area, or else control area is classified as Occupancy Group H-2 (fire suppression required). o Maximum quantities increased by 100% if an approved sprinkler system is in place; limit: Flammable Gas to 2000 ft3 and Liquified Flammable Gas to 300 lbs per control area. [note d] o Maximum quantities increased by 100% if stored in approved gas cabinet or storage cabinet; limit: Flammable Gas to 2000 ft3 and Liquified Flammable Gas to 300 lbs per control area. [note e] o If both an approved gas cabinet and approved sprinkler system are used, the 100% increase in MAQ is applied accumulatively; limit: Flammable Gas to 4000 ft3 and Liquified Flammable Gas to 600 lbs per control area. [note d & e] Outdoor: IFC2012 Table 5003.1.1(3) Maximum Allowable Quantity [MAQ] per Control Area of Hazardous Materials Posing a Physical Hazard in an Outdoor Control Area: o MAQ: Storage - restricts Flammable Gas to 3000 ft3 and Liquified Flammable Gas to 300 lbs per control area. Total quantities for storage & use must not exceed Storage amounts. o MAQ: Closed-System Use - restricts Flammable Gas to 1500 ft3 and Liquified Flammable Gas to 150 lbs per control area.  Container types & design & storage construction o "Compressed gas containers, cylinders and tanks shall be designed, fabricated, tested, marked with the specifications of manufacture and maintained in accordance with the regulations of DOTn 49 CFR Parts 100-185 or the ASME Boiler and Pressure Vessel Code, Section VIII." [IFC2012 5303.2]

 Piping, Valves, Regulators, Fuel Controls IFC2012 Sec. 5003.2.2.1 & IFC2009,2006,2003 [Sec. 2703.2.2.1] o Pressure-handling components designed to withstand pressure, structural, seismic stress & exposure. o Readily accessible manual or automatic remotely activated fail-safe emergency shutoff valves installed at point of use and the tank, cylinder, or bulk source; clearly identified and indicated by a sign. o Approved leak detection and emergency shutoff or excess flow control required. - Pressure Relief Devices: o pressure relief devices sized and selected per CGA S-1.1, S-1.2, and S-1.3 or the ASME Boiler and Pressure Vessel Code, Section VIII. [IFC2012 5303.3.2] o "Pressure relief devices shall be arranged to discharge upward and unobstructed to the open air in such a manner as to prevent any impingement of escaping gas upon the container, adjacent structures or personnel. Exception: DOTn specification containers having an internal volume of 30 cubic feet (0.855 m3) or less." [IFC2012 5303.3.4] o pressure relief devices protected from freeze [IFC2012 5303.3.5]  Labeling & Signage o Piping & tubing identified per ASME A13.1 to indicated the material conveyed.  Fire & Emergency Response o Performance requirements (for Performance-based design alternative) - if chosen by mfg. [IFC2012 5001.3.3] o Hazardous Materials Management Plan (HMMP) - if required by AHJ [IFC2012 5001.5.1] o Hazardous Materials Inventory Statement (HMIS) - if required by AHJ [IFC2012 5001.5.2] o Fire Suppression required in Gas rooms [IFC2012 5003.8.4.1]

International Fire Code (IFC)- additional requirements for hydrogen-generating and refueling operations [IFC2012.2309]  Location, Capacity, Siting, & Setbacks Outdoors: o allowed per IFC Chapter 58, [IFC2012.2309.3.1.1] Indoors: o "Generation, compression, storage and dispensing equipment shall be located in indoor rooms or areas constructed in accordance with the requirements of the International Building Code, the International Fuel Gas Code and the International Mechanical Code and one of the following: 1. Inside a building in a hydrogen cutoff room designed and constructed in accordance with Section 421 of the International Building Code. 2. Inside a building not in a hydrogen cutoff room where the gaseous hydrogen system is listed and labeled for indoor installation and installed in accordance with the manufacturer’s installation instructions. 3. Inside a building in a dedicated hydrogen fuel-dispensing area having an aggregate hydrogen delivery capacity no greater than 12 standard cubic feet per minute (SCFM) and designed and constructed in accordance with Section 703.1 of the International Fuel Gas Code." [IFC2012.2309.3.1.2]

International Fuel Gas Code (IFGC) - Gaseous Hydrogen Systems  Components & Systems Certifications o Installation of gaseous hydrogen systems per IFGC Chapter 7 & IFC Chapters 53 & 58 [IFGC2012.701.1] o Permits per IFC Section 106. [IFGC2012.701.2] o Gaseous hydrogen systems, equipment and machinery shall be listed or approved [IFGC2012.704.1] o "Stationary fuel-cell power systems having a power output not exceeding 10 MW shall be tested in accordance with ANSI CSA America FC 1 and shall be installed in accordance with the manufacturer’s installation instructions, NFPA 853, the International Building Code and the International Fire Code." [IFGC2012.633.1] "This code shall not apply to the following:…

5. Industrial gas applications using gases such as acetylene and acetylenic compounds, hydrogen, ammonia, carbon monoxide, oxygen and nitrogen…." IFGC2012.101.2.4] - Pressure Testing requirement: o "Prior to acceptance and initial operation, all piping installations shall be inspected and pressure tested to determine that the materials, design fabrication and installation practices comply with the requirements of this code." [IFGC2012.705.1] o "Inspections shall consist of a visual examination of the entire piping system installation and a pressure test. Hydrogen piping systems shall be inspected in accordance with this code. Inspection methods such as outlined in ASME B31.3 shall be permitted where specified by the design engineer and approved by the code official. Inspections shall be conducted or verified by the code official prior to system operation." [IFGC2012.705.2] o "A hydrostatic or pneumatic leak test shall be performed. Testing of hydrogen piping systems shall utilize testing procedures identified in ASME B31.3 or other approved methods…" . See IFGC2012 Section 705.3 for additional piping test criteria & methods.  Location, Capacity, Siting, & Setbacks o Indoor limitation: "Flammable gas cylinders in occupancies regulated by the International Residential Code shall not exceed 250 cubic feet (7.1 m3) at normal temperature and pressure (NTP)." [IFGC2012.703.2.1] o pressure relief devices arranged to discharge unobstructed per IFC Section 2309 [IFGC2012.703.3.8]  Container types & design & storage construction o compressed gas containers, cylinders, and tanks per IFC Chapter 53 & 58 [IFGC2012.703.2] & designed, constructed, and tested per IFC Chapter 50, AMSE Boiler & Pressure Vessel Code (Section VIII) or DOTn 49CFR Parts 100-180 [IFGC2012.703.2.2]. o handling of compressed gas containers, cylinders, and tanks per IFC Chapter 50. [IFGC2012.704.4] o "Compressed gas containers, cylinders and tanks, except those with a water volume less than 1.3 gallons (5 L) and those designed for use in a horizontal position, shall be used in an upright position with the valve end up. An upright position shall include conditions where the container, cylinder or tank axis is inclined as much as 45 degrees (0.79 rad) from the vertical." [IFGC2012.704.2]  Piping, Valves, Regulators, Fuel Controls - Pressure Relief Devices o containers & vessel pressure relief devices per ASME Boiler and Pressure Vessel Code (Section VIII), DOTn 49CR Parts 100-180 [IFGC2012.703.3.3 & 703.3.4], o sized and selected per CGA S-1.1, S-1.2, and S-1.3 [IFGC2012.703.3] o no valves or mechanical restrictions between container and pressure relief devices [IFGC2012.703.3.1] o pressure relief devices protected from debris & environment [IFGC2012.703.3.6] o pressure relief devices readily accessible for inspection [IFGC2012.703.3.7] - Piping design o "Piping and tubing materials shall be 300 series stainless steel or materials listed or approved for hydrogen service and the use intended through the full range of operating conditions to which they will be subjected." [IFGC2012.704.1.2.3] o "Piping passing through concrete or masonry walls shall be protected against differential settlement." [IFGC2012.704.1.2.3.7] o "Underground piping shall not penetrate the outer foundation or basement wall of a building." [IFGC2012.704.1.2.3.4] o "Piping shall not be installed in or through a circulating air duct; clothes chute; chimney or gas vent; ventilating duct; dumbwaiter; or elevator shaft. o Piping shall not be concealed or covered by the surface of any wall, floor or ceiling." [IFGC2012.704.1.2.3.1] o Valves, regulators and piping components shall be listed or approved for hydrogen service, shall be provided with access and shall be designed and constructed to withstand the maximum pressure to which such components will be subjected. [IFGC2012.704.1.2.5] - Joint construction: o "Joints in piping and tubing in hydrogen service shall be listed as complying with ASME B31.3 to include the use of welded, brazed, flared, socket, slip and compression fittings. o Gaskets and sealants used in hydrogen service shall be listed as complying with ASME B31.3.

o Threaded and flanged connections shall not be used in areas other than hydrogen cutoff rooms and outdoors." [IFGC2012.704.1.2.4] o "Brazing alloys shall have a melting point greater than 1,000°F (538°C)." [IFGC2012.704.1.2.4.1] o "Mechanical joints shall maintain electrical continuity through the joint or a bonding jumper shall be installed around the joint." [IFGC2012.704.1.2.4.2] - Indoor gas piping: o "Where piping other than stainless steel piping, stainless steel tubing or black steel is installed through holes or notches in wood studs, joists, rafters or similar members less than 11/2 inches (38 mm) from the nearest edge of the member, the pipe shall be protected by shield plates. Shield plates shall be a minimum of 1/16-inch-thick (1.6 mm) steel, shall cover the area of the pipe where the member is notched or bored and shall extend a minimum of 4 inches (102 mm) above sole plates, below top plates and to each side of a stud, joist or rafter." [IFGC2012.704.1.2.3.5] o "Except for through penetrations, piping located inside of buildings shall be installed in exposed locations and provided with ready access for visual inspection." [IFGC2012.704.1.2.3.2] - Outdoor gas piping: o "Piping installed above ground, outdoors, shall be securely supported and located where it will be protected from physical damage. o Piping passing through an exterior wall of a building shall be encased in a protective pipe sleeve. o The annular space between the piping and the sleeve shall be sealed from the inside such that the sleeve is ventilated to the outdoors. o Where passing through an exterior wall of a building, the piping shall also be protected against corrosion by coating or wrapping with an inert material. o Below-ground piping shall be protected against corrosion." [IFGC2012.704.1.2.3.6] - Shutoff Valves: o Shutoff valves shall be provided on all storage container and tank connections except for pressure relief devices. Shutoff valves shall be provided with ready access. [IFGC2012.704.1.2.5.1]  Labeling & Signage o "Hydrogen piping systems shall be marked in accordance with ANSI A13.1. Markings used for piping systems shall consist of the name of the contents and shall include a direction-of-flow arrow. Markings shall be provided at all of the following locations: 1. At each valve. 2. At wall, floor and ceiling penetrations. 3. At each change of direction. 4. At intervals not exceeding 20 feet (6096 mm)." [IFGC2012.704.1.2.2]

International Fuel Gas Code (IFGC) - Liquified Hydrogen Systems  Components & Systems Certifications o The design of liquefied hydrogen systems shall comply with Chapter 55 of the International Fire Code. [IFGC2012.708.1]

International Fuel Gas Code (IFGC) - additional requirements for indoor hydrogen- generating and refueling operations [IFGC2012.703.1]  Location, Capacity, Siting, & Setbacks o limited to 850 ft2 (79 m2) maximum floor area, [IFGC2012.703.1.1]  Vents & Ventilation o must be vented outdoors, o not exceed 4 SCFM (0.00189 m3/s) H2 generation for each 250 ft2 floor area, o 3 in. (76 mm) minimum cross-sectional area of air openings, o ignition sources (appliance or equipment) not within 12 in. (305 mm) of ceiling. o two permanent vent openings in the same exterior wall: o upper opening within 12 in. (305 mm) of ceiling & o lower opening within 12 in. (305 mm) of the floor; o vent minimum free area of 1/2 ft2 per 1000 ft3 (1 m2 per 610 m3) of garage volume o ventilation louvers & grilles fixed in open position,

o Indoor locations require ventilation per International Mechanical Code (IMC) Section 502.16. [IFGC2012.703.1.2]; ignition sources located below mechanical vent outlets. o Alternately, an approved engineered system is allowed. [IFGC2012.703.1.3]

NFPA 2 Hydrogen Technologies Code - 2011 edition (reference only) Note: NFPA 2 is not specified or invoked by any legal compliance requirement. NFPA requirements may be invoked by a local AHJ at their discretion, but not supported by law. NFPA 2 requirements are for reference only.  Container types & design & storage construction [NFPA 2-2011 7.1.5] designed, fabricated, tested, and marked (stamped) in accordance with either o U.S. Department of Transportation (DOT), o Transport Canada (TC) Transportation of Dangerous Goods Regulations, or o ASME Boiler & Pressure Vessel Code Rules for the Construction of Unfired Pressure Vessels Section VIII (also referenced by NFPA 55 Section 7.1.5.1)  Labeling & Signage [NFPA 2-2011 7.1.6] o containers, cylinders, and tanks marked in accordance with NFPA 704 Standard for the Identification of Hazards of Materials for Emergency Response (also reference by NFPA 55 Section 7.1.8.3.1) o piping systems marked in accordance with ASME A13.1 Scheme for the Identification of Piping Systems or applicable approved codes and standards (also referenced by NFPA 55 Section 7.1.7.4.1);  marking includes name of gas and direction-of-flow arrow;  at each critical process control valve,  at wall, floor, or ceiling penetrations  at a minimum of every 20ft (6.1m) or fraction thereof throughout the piping run.

NFPA 55 Compressed Gases and Cryogenic Fluids Code - 2013 edition Note: NFPA 55 uses "scf" (standard cubic feet) for volumetric limits, and a conversion rate of 1 scf = 0.02832 "Nm3" (Normal cubic meter). A "standard" cubic foot is measured at 60°F, while a "normal" cubic meter is measured at 0°C; both are measured relative to 1 atmosphere of pressure. NFPA 55 addresses flammable hydrogen gas storage requirements by location and quantity stored.

 Definitions Definitions (Chapter 3) - Important definitions: o Control Areas - A building or portion of a building within which hazardous materials are allowed to be stored, dispensed, used, or handled in quantities not exceeding the maximum allowable quantities (MAQ). [NFPA55-2013 3.3.6.1] o Maximum Allowable Quantity per Control Area (MAQ) - A threshold quantity of hazardous material in a specific hazard class that once exceeded requires the application of additional administrative procedures, construction features, or engineering controls. [NFPA55-2013 3.3.66] o Bulk Hydrogen Compressed Gas System. - An assembly of equipment that consists of, but is not limited to, storage containers, pressure regulators, pressure relief devices, compressors, manifolds, and piping, with a storage capacity of more than 5000 scf (141.6 Nm3) of compressed hydrogen gas and that terminates at the source valve. [NFPA55-2013 3.3.93.2] o Bulk Liquefied Hydrogen System. - An assembly of equipment that consists of, but is not limited to, storage containers, pressure regulators, pressure relief devices, vaporizers, liquid pumps, compressors, manifolds, and piping, with a storage capacity of more than 39.7 gal (150 L) of liquefied hydrogen that terminates at the source valve. [NFPA55-2013 3.3.93.4]

Hazardous Materials - General Provisions o Emergency plan required when exceeding MAQ (max allowable quantity), or when required by AHJ. [NFPA55-2013 4.2.1.1] o Emergency plan details (MSDS, emergency procedures, emergency contact info, hazard identification labeling, etc.) [NFPA55-2013 4.2.1.2]

o Potential electrical ignition sources shall be listed or approved for use with the hazardous material (NRTL listed, and class) [NFPA55-2013 4.9.3]

Chapter 6 Building-Related Controls - defines Control Areas inside a building, defines the construction of gas rooms Chapter 7 Compressed Gases - Non-Bulk Storage: <5000 scf (standard cubic feet) stored Chapter 8 Cryogenic Fluids - Non-Bulk Liquified Hydrogen <39.7 gal (150 L) stored Chapter 10 Bulk Hydrogen Compressed Gas Storage: ≥5000 scf, or exceeding MAQ per control area. Chapter 11 Bulk Liquified Hydrogen Systems ≥39.7 gal (150 L) stored Chapter 12 Gas Generation Systems - includes electrolyzers and catalytic reforming hydrogen generators

o Table 6.2.1 defines the MAQ derating for control areas for floor levels above grade plane, limits number of control areas per floor based on the Fire Resistance Rating for Fire Barriers o Table 6.5 requires a detached building for bulk hydrogen compressed gas systems that exceed 15,000 scf (425Nm3)

 Piping, Valves, Regulators, Fuel Controls Non-Bulk Storage: o Piping per ANSI/ASME B31.3, Process Piping, or other approved standard [NFPA55-2013 7.3.1.3] Bulk Storage: o Piping, tubing, valves, and fittings shall be designed and installed in accordance with ASME B31.12, Hydrogen Piping and Pipelines, NFPA 55 Section 7.3.1.3, and IFC Sections 704.1.2.3, 704.1.2.4, and 704.1.2.5. o Cast-iron pipe, valves, and fittings shall not be used. [NFPA55-2013 10.2.2] o Prior to initial operation, all piping inspected & pressure tested per ASME B31.12, Hydrogen Piping and Pipelines, and IFC Section 705. [NFPA55-2013 10.2.2.1]

 Labeling & Signage Non-Bulk Storage: o No Smoking with 25ft (7.6m) of outdoor storage areas, dispensing areas, or open use areas [NFPA55- 2013 4.9.1]; o No Smoking signs required [NFPA55-2013 4.10.3] . Bulk Storage: o Permanent placard for area: [NFPA55-2013 10.2.1.2] "HYDROGEN - FLAMMABLE GAS - NO SMOKING - NO OPEN FLAMES" o cylinders, containers, & tanks marked per NFPA 704 [NPFA55-2013 7.1.8.3.1]

NPFA 704 - hydrogen gas

NFPA 704 - methane gas

NFPA 55 Compressed Gases and Cryogenic Fluids Code - additional requirements for hydrogen-generating and refueling operations

 Definitions o applies to systems rated from greater than 0.08 lbs/hr (36 g/hr) to less than 55 lbs/hr (25 kg/hr). [NFPA55- 2013 12.3.2.2]  Components & Systems Certifications o Fuel processing equipment integrated into a listed fuel cell power system are installed per NFPA 853. [NFPA55-2013 12.3.2.3] o Safety related controls per NFPA79 Electrical Standard for Industrial Machinery. [NFPA55-2013 12.3.2.4. (8)] o Electrolyzers tested and approved to ISO/DIS 22734 Hydrogen Generators Using Water Electrolysis Process. [NFPA55-2013 12.3.2.7.1]  Location, Capacity, Siting, & Setbacks o footing per ASCE/SEI 7 Minimum Design Loads for Buildings and Other Structures. [NFPA55-2013 12.3.2.4.(1)] o protected from environment & unauthorized access (Fire Dept. access required). o setbacks per Table 10.3.2.1(a), Table 10.3.2.1(b), or Table 10.3.2.1(c). [NFPA55-2013 12.3.2.4.(2) & (6)] - Rooftop & penthouse installation: o Hydrogen reformers or gasifiers are prohibited from rooftop or penthouse installation of occupied structures, unless listing or approval is specific for rooftop installations. [NPFA55-2013 12.3.2.5.1.1 & 12.3.2.5.1.2] o roofing material under and within 12 inches (305 mm) horizontally of a fuel cell power components or system shall be Class A rating or noncombustible per building code. [NFPA55-2013 12.3.2.5.3] - Outdoor installation: o see ventilation requirements… - Indoor installation: o room separated from remainder of building by 1-hour fire resistance rated floor, wall, and ceiling per ASTM E119 Standard Test Methods for Fire Tests of Building Construction and Materials. or UL 263 Fire Tests of Building Construction & Materials. [NFPA55-2013 12.3.2.8.3.3] o Openings between indoor use and other occupied spaces require protection by fire doors & dampers per NFPA90A Standard for Installation of Air-Conditioning and Ventilation Systems, installed per NFPA80 Standard for Fire Doors and Other Opening Protectives, and require egress per NFPA101 Life Safety Code. [NFPA55-2013 12.3.2.8.3.5. through 12.3.2.8.3.8] o fire-rated separation is not required if hydrogen generating & storage does not exceed 400 scf (11.33 Nm3) [NFPA55-2013 12.3.2.4.(7)] o Clearances from other combustible materials per NFPA31 Standard for the Installation of Oil-Burning Equipment, NFPA54 National Fuel Gas Code, or NFPA58 Liquified Petroleum Gas Code. [NFPA55-2013 12.3.2.8.7.3]

 Piping, Valves, Regulators, Fuel Controls o Installed per ANSI/ASME B31.3 Process Piping. [NFPA55-2013 12.3.2.8.4.2] o accessible shutoff valve in the reformer fuel piping, located within 6 ft (1.8 m) of the fuel storage, [NFPA55- 2013 12.3.2.8.4.3] o unless the power system is installed in a room with a 1-hour fire resistance rating; else a second accessible shutoff valve located within 6 ft (1.8 m) of the power system is required, [NFPA55-2013 12.3.2.8.4.4] o unless the power system is installed in a room with a 1-hour fire resistance rating; then the valve shall be located outside of the room. [NFPA55-2013 12.3.2.8.4.5] o Reformer systems using flammable liquid fuel, installed indoors, must: [NFPA55-2013 12.3.2.8.7.3] . contain less than 5 gal (0.019m3) liquid fuel during all modes of operation, standby, and shutdown, . store bulk quantities of fuel outside, . indoor fuel piping requires solid tubing or piping, all-welded, soldered, or brazed up through the reformer enclosure, . leak detection and automatic isolation of the indoor fuel piping to the outdoor bulk fuel supply, . outdoor bulk supplies require an automatic isolation valve at the tank if located at a higher elevation than the reformer. . requires an automatic shutoff valve outside the building using a gas detection system that will close the valve above 25% LFL concentration. [NFPA55-2013 12.3.2.8.4.6] . combustible gas detector installed per NFPA853 8.1.5.4 through 8.1.5.8 (unless fuel is odorized and fuel gas system is listed for indoor use). [NFPA55-2013 12.3.2.8.8.1]  Vents & Ventilation o prevent building air from being exposed to hazardous & toxic atmosphere in excess of OSHA limits [NFPA55-2013 12.3.2.8.2.1, 12.3.2.8.3.2] - Outdoor installation: o exhaust outlets from reformer fuel-bearing components located at least 50 ft (15 m) from HVAC air intakes, windows, doors, and other building openings, and not directed onto walkways or other pedestrian paths. [NFPA55-2013 12.3.2.8.2.2] - Indoor installation: o ventilation & exhaust must be negative or neutral pressure (with respect to the surrounding building) in the room where a reformer is use. [NFPA55-2013 12.3.2.8.5.3] o Natural ventilation may be use if verified safe. [NFPA55-2013 12.3.2.8.5.5] Mechanical ventilation, if used, requires a control interlock to shut down the system safely if ventilation fails. [NFPA55-2013 12.3.2.8.5.4]  Fire & Emergency Response o Fire protection requirements per NFPA 853, o Carbon Monoxide detector installed in the reformer enclosure, the reformer exhaust, or the room it's in. [NFPA55-2013 12.3.2.8.6] o For indoor installations if used without ventilation air from the outside, a limit control or method is required to prevent ambient oxygen levels from dropping below 18% by volume. [NFPA55-2013 12.3.2.8.7.3]

of 44 version: 5May2014 Fuel Cell Power Electrical Generators - Implementation Guide For Telecom Providers Fuel: Flammable Liquids - Methanol

OSHA (29CFR1910): Subpart H - Hazardous Materials Methanol

29CFR1910.106 Flammable Liquids  Definitions o Flammable Liquid - flashpoint at or below 199.4°F (93°C) [29CFR1910.106(a)(19)] Methanol (from MSDS): flashpoint = 51.8°F (11°C), boiling point = 148.5°F (64.7°C) o Methanol is defined as Category 2 Flammable Liquid: Packing Group II: flashpoint below 73.4°F (23°C), and having a boiling point above 95°F (35°C), Hazard Class 3 flammable liquid, UN1230 identification number, [per 49CFR173.121] o "Atmospheric tank…operate at pressures for atmospheric through 0.5 psi." [29CFR1910.106(a)(2)] Flammable liquid (fuel storage) for methanol reformers is stored in an atmospheric tank.  Location, Capacity, Siting, & Setbacks - Outdoor storage, aboveground o "The distance between any two flammable liquid storage tanks shall not be less than 3 feet." [29CFR1910.106(b)(2)(ii)(a)] o "…the distance between any two adjacent tanks shall not be less than one-sixth the sum of their diameters. When the diameter of one tank is less than one-half the diameter of the adjacent tank, the distance between the two tanks shall not be less than one-half the diameter of the smaller tank." [29CFR1910.106(b)(2)(ii)(b)] o See 29CFR1910.106(b)(2)(ii)(f) for further requirements when locating flammable liquid near liquefied petroleum gas (e.g.; LNG, butane fluid, etc.). o See 29CFR1910.106(b)(2)(vii) for further requirements for drainage, dikes, & walls for fluid containment of aboveground tanks. Drainage, dikes, or walls are required to contain the full capacity of the storage tank, prevent a leak from causing damage if the spilled fluid ignites. o "No aboveground vertical storage tank containing a flammable liquid shall be located so that the allowable liquid level within the tank is below the established maximum flood stage, unless the tank is provided with a guiding structure such as described in (m), (n), and (o) of this subdivision." [29CFR1910.106(b)(5)(vi)(a)] o Flood Areas: see all sections under 29CFR1910.106(b)(5)(vi) for location requirements & restrictions for storage in flood areas. - Outdoor storage, underground o See all sections under 29CFR1910.106(b)(3) for location requirements & restrictions for underground tanks. o "…The distance from any part of a tank storing Category… 2 flammable liquids…to the nearest wall of any basement or pit shall be not less than 1 foot, and to any property line that may be built upon, not less than 3 feet." [29CFR1910.106(b)(3)(i)] - Indoor storage o "Location." Tanks shall not be permitted inside of buildings except as provided in paragraphs (e), (g), (h), or (i) of this section." i.e.; restricted except for (e) Industrial Plants, (g) Service Stations, (h) Processing Plants, (i) Refineries, Chemical Plants, Distilleries. [29CFR1910.106(b)(4)(i)] o See all sections under 29CFR1910.106(b)(4) for venting indoor tank locations that are allowed.  Container types & design & storage construction - Storage: o "flammable liquids shall be stored in a tank or in a container that complies with paragraph (d)(2) of this section." [29CFR1910.106(a)(32)] - Construction: o "Only approved containers and portable tanks shall be used. Metal containers and portable tanks meeting the requirements of and containing products authorized by chapter I, title 49 of the Code of Federal Regulations (regulations issued by the Hazardous Materials Regulations Board, Department of Transportation), shall be deemed to be acceptable." [29CFR1910.106(d)(2)(i)] o Tanks may be built of materials other than steel for installation underground or if required by the properties of the liquid stored. Tanks located above ground or inside buildings shall be of noncombustible construction. [29CFR1910.106(b)(1)(i)]

o Tanks at atmospheric pressure must follow good standards of design; steel tanks may use these standards: [29CFR1910.106(b)(1)(iii)] . Underwriters' Laboratories, Inc., (UL) Subject No. 142, Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids, 1968; or . UL Subject No. 58, Standard for Steel Underground Tanks for Flammable and Combustible Liquids, Fifth Edition, December 1961; or . UL Subject No. 80, Standard for Steel Inside Tanks for Oil-Burner Fuel, September 1963. . American Petroleum Institute Standards No. 650, Welded Steel Tanks for Oil Storage, Third Edition, 1966. o Tanks at low pressure (0.5 to 15 psig) may be used as tanks at atmospheric pressure, must follow good standards of design, and low pressure tanks may use these standards: [29CFR1910.106(b)(1)(iv)] . American Petroleum Institute Standard No. 620. Recommended Rules for the Design and Construction of Large, Welded, Low-Pressure Storage Tanks, Third Edition, 1966. . The principles of the Code for Unfired Pressure Vessels, Section VIII of the ASME Boiler and Pressure Vessels Code, 1968. o Pressure vessels may be used as tanks at atmospheric pressure. Pressure vessels shall be built in accordance with: [29CFR1910.106(b)(1)(v)] . The Code for Unfired Pressure Vessels, Section VIII of the ASME Boiler and Pressure Vessel Code 1968. o "Tank supports shall be installed on firm foundations. Tank supports shall be of concrete, masonry, or protected steel. Single wood timber supports (not cribbing) laid horizontally may be used for outside aboveground tanks if not more than 12 inches high at their lowest point." [29CFR1910.106(b)(5)(i)] o "Fire resistance. Steel supports or exposed piling shall be protected by materials having a fire resistance rating of not less than 2 hours, except that steel saddles need not be protected if less than 12 inches high at their lowest point. Water spray protection or its equivalent may be used in lieu of fire-resistive materials to protect supports." [29CFR1910.106(b)(5)(ii)]  Vents & Ventilation o "Atmospheric storage tanks shall be adequately vented to prevent the development of vacuum or pressure sufficient to distort the roof of a cone roof tank or exceeding the design pressure in the case of other atmospheric tanks, as a result of filling or emptying, and atmospheric temperature changes." [29CFR1910.106(b)(2)(iv)] o Normal vents shall be sized either in accordance with: . The American Petroleum Institute Standard 2000 (1968), Venting Atmospheric and Low-Pressure Storage Tanks…[29CFR1910.106(b)(2)(iv)(b)(1)] or . other accepted standard [29CFR1910.106(b)(2)(iv)(b)(2)]; or . shall be at least as large as the filling or withdrawal connection, whichever is larger but in no case less than 1 1/4 inch nominal inside diameter." [29CFR1910.106(b)(2)(iv)(b)(3)] o "…Tanks and pressure vessels storing Category 2 flammable …shall be equipped with venting devices which shall be normally closed except when venting under pressure or vacuum conditions, or with approved flame arresters." [29CFR1910.106(b)(2)(iv)(f)(1)] o "Exemption: …outside aboveground atmospheric tanks under 1,000 gallons capacity containing other than Category 1 flammable liquids may have open vents. (See paragraph (b)(2)(vi)(b) of this section." [29CFR1910.106(b)(2)(iv)(f)(2)] o "Flame arresters or venting devices required in paragraph (b)(2)(iv)(f) of this section may be omitted for Category 2 flammable liquids… where conditions are such that their use may, in case of obstruction, result in tank damage. [29CFR1910.106(b)(2)(iv)(g)] o "Where vent pipe outlets for tanks storing Category 1 or 2 flammable liquids…are adjacent to buildings or public ways, they shall be located so that the vapors are released at a safe point outside of buildings and not less than 12 feet above the adjacent ground level. In order to aid their dispersion, vapors shall be discharged upward or horizontally away from closely adjacent walls. Vent outlets shall be located so that flammable vapors will not be trapped by eaves or other obstructions and shall be at least 5 feet from building openings." [29CFR1910.106(b)(2)(vi)(b)]

29CFR1926.152 Flammable Liquids (Safety & Health Regulations for Construction)  Container types & design & storage construction - Indoor Storage: o "No more than 25 gallons of flammable liquids shall be stored in a room outside of an approved storage cabinet." [29CFR1926.152(b)(1)] o "Quantities of flammable liquid in excess of 25 gallons shall be stored in an acceptable or approved cabinet…" [29CFR1926.152(b)(2)] . Requirements for "approved cabinet" under 29CFR1926.152(b)(2) subsections. o "Not more than 60 gallons of Category 1, 2 and/or 3 flammable liquids…shall be stored in any one storage cabinet. Not more than three such cabinets may be located in a single storage area…" [29CFR1926.152(b)(3)] o Additional storage is allowed in an "inside storage room" under 29CFR1926.152(b)(4) subsections

Safe Transportation of Methanol - Identified by 49CFR172.101 Hazardous Materials Table (2) (8) (9) Hazardous (3) (7) Packaging Quantity limitations (1) materials (4) (6) Hazard (5) Special (§173.***) (see §§173.27 and 175.75) Symb descriptions Identification Label class or PG provisions ols and proper Numbers Codes Non- Passenger Cargo aircraft Division (§172.102) Exceptions Bulk shipping bulk aircraft/rail only names IB2, T7, + I Methanol 3 UN1230 II 3, 6.1 150 202 242 1 Liter 60 Liters TP2 (1) Symbol "+ " : the material is known to pose a risk to humans (1) Symbol "I" : The letter “I” identifies proper shipping names which are appropriate for describing materials in international transportation. An alternate proper shipping name may be selected when only domestic transportation is involved (i.e.; must call it "Methanol", not "Methyl Alcohol") (2) "Methanol" proper shipping name (3) Hazard class or Division "3" : flammable liquid per 49CFR173.120(a) definitions (4) Identification Numbers : United Nations (international) material designation for shipping identification number (5) PG :Packing Group II - flashpoint below 73.4°F (23°C), and having a boiling point above 95°F (35°C) per 49CFR173.121(a)(1). (6) Label Codes : Flammable Liquid [see 49CFR172.419 for labeling], Poison [see 49CFR172.430 for labeling] (7) Special provisions : IB2 = special provision for Intermediate Bulk Container (IBC); T7 = special provision for UN or IM Specification portable tanks; TP2 = special provision for UN or IM Specification portable tanks. (8) Packaging : Exceptions [49CFR173.150] = inner packaging not over 1.0 Liter (0.3 gallons) net capacity each… Non-bulk [49CFR173.202] = Non-bulk packagings for liquid hazardous materials in Packing Group II. Non-bulk packaging: liquid capacity does not exceed 119 gallons (450L) [49CFR171.8] Bulk [49CFR173.242] = Bulk packagings for certain medium hazard liquids and solids, including solids with dual hazards. Defines requirements for (a) Rail cars (see specification for details), (b) Cargo tanks (see specification for details), and (c) Portable tanks. DOT Specification 51, 56, 57 and 60 portable tanks; Specification IM 101, IM 102, and UN portable tanks; and marine portable tanks conforming to 46 CFR part 64 are authorized. (9) Quantity limitations : limit of 1 Liter for passenger aircraft or passenger rail, limit of 60 Liters for cargo aircraft.

 Label specifications: [49CFR172.407] o "Durability.

. Each label, whether printed on or affixed to a package, must be durable and weather resistant. A label on a package must be able to withstand, without deterioration or a substantial change in color, a 30-day exposure to conditions incident to transportation that reasonably could be expected to be encountered by the labeled package." o "Design. . Except for size and color, the printing, inner border, and symbol on each label must be as shown in §§172.411 through 172.448 of this subpart, as appropriate." "The dotted line border shown on each label is not part of the label specification, except when used as an alternative for the solid line outer border to meet the requirements of §172.406(d) of this subpart." o "Size. . Each diamond (square-on-point) label …must be at least 100 mm (3.9 inches) on each side with each side having a solid line inner border 5.0 to 6.3 mm (0.2 to 0.25 inches) from the edge." . "…the hazard class number, or division number, as appropriate, must be at least 6.3 mm (0.25 inches) and not greater than 12.7 mm (0.5 inches)." . "When text indicating a hazard is displayed on a label, the label name must be shown in letters measuring at least 7.6 mm (0.3 inches) in height." o "Color. . …(2) The symbol, text, numbers, and border must be shown in black on a label except that— . White may be used on a label with a one color background of green, red or blue."  Fuel Transportation & Site Refueling o "Areas in which flammable liquids are transferred at one time, in quantities greater than 5 gallons from one tank or container to another tank or container, shall be separated from other operations by 25-feet distance or by construction having a fire resistance of at least 1 hour. Drainage or other means shall be provided to control spills. Adequate natural or mechanical ventilation shall be provided to maintain the concentration of flammable vapor at or below 10 percent of the lower flammable limit." [29CFR1926.152(e) (1)] o "Transfer of Category 1, 2, or 3 flammable liquids from one container to another shall be done only when containers are electrically interconnected (bonded)." [29CFR1926.152(e)(2)] o " Dispensing devices and nozzles for Category 1, 2, or 3 flammable liquids shall be of an approved type. [29CFR1926.152(e)(5)] o "Category 1, 2, or 3 flammable liquids shall be kept in closed containers when not actually in use." [29CFR1926.152(f)(1)] o "The tank trucks shall comply with the requirements covered in the Standard for Tank Vehicles for Flammable and Combustible Liquids, NFPA No. 385-1966." [29CFR1926.152(g)(2)] o "The dispensing hose shall be an approved type." [29CFR1926.152(g)(3)] o "The dispensing nozzle shall be an approved automatic-closing type without a latch-open device." [29CFR1926.152(g)(4)]  Fire & Emergency Response - Indoor: o "At least one portable fire extinguisher, having a rating of not less than 20-B units, shall be located outside of, but not more than 10 feet from, the door opening into any room used for storage of more than 60 gallons of flammable liquids." [29CFR1926.152(d)(1)] - Outdoor: o "At least one portable fire extinguisher having a rating of not less than 20-B units shall be located not less than 25 feet, nor more than 75 feet, from any flammable liquid storage area located outside." [29CFR1926.152(d)(2)]

Hazardous Substances - Reportable Quantity (RQ) - Methanol

Table 1 to Appendix A Methanol = 5000lbs (2270kg) [49CFR172.101]. See also Table 302.4 List of Hazardous Substances and Reportable Quantities. [40CFR302.4] At a specific gravity of 0.8822 for 70% methanol & 30% water, this is ~680 gallons (2573 Liters) at 68°F (20°C) At a specific gravity of 0.792 for 100% methanol, this is ~758 gallons (2866 Liters) at 68°F (20°C)

For Flammable Liquids:

International Fire Code (IFC)- methanol & other flammable liquids: referenced sections: IFC: 2012: Chapter 50 - Hazardous Materials - General Provisions o Section 5001.2 Material classification o Section 5001.3 Performance-based design alternative, specifically, o Section 5001.3.3 Performance requirements o Section 5001.5.1 Hazardous Materials Management Plan (HMMP) o Section 5001.5.2 Hazardous Materials Inventory Statement (HMIS) o Section 5003.1.1 Maximum Allowable Quantity (MAQ) per Control Area Chapter 57 - Flammable and Combustible Liquids

 Definitions IFC(all editions) [Section 202]: o Flammable Liquid - Class IB: (e.g.; methanol): flashpoint below 73°F (23°C), and having a boiling point at or above 1--°F (30°C); does not include cryogenic fluids (like liquefied hydrogen) o Combustible Liquid: "A liquid having a closed cup flash point at or above 100°F (38°C)." o Explosive: "The term "Explosive" includes any material determined to be within the scope of USC Title 18: Chapter 40 and also includes any material classified as an explosive other than consumer fireworks, 1.4G by the hazardous materials regulations of DOTn 49 CFR Parts 100-185." Methanol is a Class IB flammable liquid; it is not a combustible liquid , it is not an explosive.

Note: Methanol is defined as a Class I Group D flammable vapor per National Electric Code [NFPA70-2014 500.6] for relevance, see Table 5703.1.1 Class I Electrical Equipment Locations o Toxic: "A chemical falling within any of the following categories: 1. median lethal dose (LD50) > 50 milligrams per kilogram, < 500 milligrams per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each. 2. median lethal dose (LD50) > 200 milligrams per kilogram & < 1,000 milligrams per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between 2 and 3 kilograms each. 3. median lethal concentration (LC50) in air > 200 parts per million & < 2,000 parts per million by volume of gas or vapor, or > 2 milligrams per liter & < 20 milligrams per liter of mist, fume or dust, when administered by continuous inhalation for 1 hour (or less if death occurs within 1 hour) to albino rats weighing between 200 and 300 grams each." Methanol (from MSDS); 100% concentration; diluted concentrations with water have higher median lethal dose & concentrations: 1. LD50/oral/rat: >1100 mg/kg 2. LD50/dermal/rabbit: >17000 mg/kg 3. LC50/inhalation/4hr/rat: >128 mg/liter/4hr Methanol (including methanol-water mixtures) is not classified as Toxic o Container: "A vessel of 60 gallons (227 L) or less in capacity used for transporting or storing hazardous materials. Pipes, piping systems, engines and engine fuel tanks are not considered to be containers." o Tank: "A vessel containing more than 60 gallons (227 L)." Capacity of 60 gallons or less is a 'container', over 60 gallons is a 'tank'. o Control Area: "Spaces within a building where quantities of hazardous materials not exceeding the maximum allowable quantities per control area are stored, dispensed, used or handled…" o Outdoor control area. "An outdoor area that contains hazardous materials in amounts not exceeding the maximum allowable quantities of Table 5003.1.1(3) or Table 5003.1.1(4)." Per Table 5003.1.1(3) & Table 5003.1.1(4), methanol does not have a MAQ for outdoor control areas (no 'flammable liquid' listed under 'MATERIAL'). o Closed System: "The use of a solid or liquid hazardous material involving a closed vessel or system that remains closed during normal operations where vapors emitted by the product are not liberated outside of the vessel or system and the product is not exposed to the atmosphere during normal operations; and all uses of compressed gases. Examples of closed systems for solids and liquids include product conveyed through a piping system into a closed vessel, system or piece of equipment."

o Open System: "The use of a solid or liquid hazardous material involving a vessel or system that is continuously open to the atmosphere during normal operations and where vapors are liberated, or the product is exposed to the atmosphere during normal operations. Examples of open systems for solids and liquids include dispensing from or into open beakers or containers, dip tank and plating tank operations." A methanol tank vented to the atmosphere through a flame arrestor may be classified as a Closed System.

 Components & Systems Certifications o "An operational permit is required: 2. To store, handle or use Class I liquids in excess of 5 gallons (19 L) in a building or in excess of 10 gallons (37.9 L) outside of a building…" [IFC2012 105.6.16] o Electrical equipment must be Class I Division 1 or 2 depending on proximity to indoor or outdoor storage per Table 5703.1.1 Class I Electrical Equipment Locations unless amended by AHJ. [IFC2012 5703.1]  Location, Capacity, Siting, & Setbacks o Spill control: If MAQ is exceeded, or if individual capacity storage of more than 55 gallons (208 L), or multiple storage vessels exceeding 1000 gallons (3785 L): [IFC2012 5703.4] "1. Liquid-tight sloped or recessed floors in indoor locations or similar areas in outdoor locations. 2. Liquid-tight floors in indoor locations or similar areas in outdoor locations provided with liquid-tight raised or recessed sills or dikes. 3. Sumps and collection systems. 4. Other approved engineered systems." [IFC2012 5004.2.1] - Fuel Storage: o See IFC2012 5704.2.9.1 through 5704.2.9.7.10 for above-ground tank storage detailed requirements. o See IFC2012 5704.2.11.1 through 5704.2.11.5.2 for underground tank storage detailed requirements. o Vaults are approved for above or below grade; shall be listed in accordance with UL 2245 NRTL certified or approved for liquid tightness, drain to a sump, wind & seismic resistant per IBC, resistant to hydrostatic & soil loads for below grade. Floor and walls of the vault shall be reinforced concrete at least 6 inches (152 mm) thick, roof made of noncombustible material weaker than the walls of the vault (to allow a pressure burst upward). [IFC2012 5704.2.8] o Storage inside buildings for containers & portable tanks (not exceeding 60 gallons) per IFC2012 5704.3.3 - Exception: liquid in fuel tanks of portable or stationary engines. Indoor MAQ: Maximum Allowable Quantity [MAQ] per Control Area of Hazardous Materials Posing a Physical Hazard [IFC2012 Table 5003.1.1(1)] o Storage & Use-Closed Systems - restricts MAQ of Flammable Liquid (Class IB) to 120 gallons per control area, Use-Open Systems - restricts MAQ to 30 gallons per control area, or control area is classified as Occupancy Group H-2 or H-3 (fire suppression required). o Maximum quantities increased by 100% if an approved sprinkler system is in place.  resulting limit: Flammable Liquid (Class IB) to 240 gallons per control area. [note d] o Maximum quantities increased by 100% if stored in approved gas cabinet or storage cabinet.  resulting limit: Flammable Liquid (Class IB) to 240 gallons per control area. [note e] o If both an approved gas cabinet and approved sprinkler system are used, the 100% increase in MAQ is applied accumulatively.  resulting limit: Flammable Liquid (Class IB) to 480 gallons per control area. [note d & e]. Outdoor MAQ: o not defined (no limit criteria)  Container types & design & storage construction o "The design, fabrication and construction of tanks shall comply with NFPA 30. Each tank shall bear a permanent nameplate or marking indicating the standard used as the basis of design." [IFC2012 5704.2.7] Storage Cabinet (may be used for containers & portable tanks under 60 gallons; total storage of 120 gallons maximum per cabinet): o see IFC2012 5704.3.2 for construction of storage cabinet for liquid fuel.  Piping, Valves, Regulators, Fuel Controls (including pressure relief devices) o Piping designed and fabricated per ASME B31.1 (power), B31.3 (process), B31.4 (pipeline transport), B31.9 (building services), and per NFPA 30 Chapter 27. [IFC2012 5703.6]

o Piping pressure tested (unless tested per ASME B31.9) hydrostatically to 150% or pneumatically at 110% of maximum anticipated pressure, but not less than 5 psig (34.47kPa) at the highest point of the system; for 10 minutes minimum; allow sufficient duration to inspect all tubing & joints. [IFC2012 5703.6.3] o Piping must be mechanically supported and protected from damage, including corrosion and galvanic action; supports protected against exposure to fire. [IFC2012 5703.6.5 & IFC2012 5703.6.5] Piping, valves, and fittings must be protected from vehicular damage. [IFC2012 5703.6.4] o Flexible joints required for underground piping where piping connects to underground tanks, termination at pump islands & vent risers, and at points of differential movement. [IFC2012 5703.6.9] o Pipe Joints: [IFC2012 5703.10] . "Joints shall be liquid tight and shall be welded, flanged or threaded except that listed flexible connectors are allowed in accordance with Section 5703.6.9. Threaded or flanged joints shall fit tightly by using approved methods and materials for the type of joint. Joints in piping systems used for Class I liquids shall be welded when located in concealed spaces within buildings." . Nonmetallic joints shall be approved and shall be installed in accordance with the manufacturer’s instructions. . Pipe joints that are dependent on the friction characteristics or resiliency of combustible materials for liquid tightness of piping shall not be used in buildings. Piping shall be secured to prevent disengagement at the fitting." o Pipe and tube bending per ASME B31.9. [IFC2012 5703.6.11] o "Vaults shall be provided with approved vapor and liquid detection systems and equipped with on-site audible and visual warning devices with battery backup. Vapor detection systems shall sound an alarm when the system detects vapors that reach or exceed 25 percent of the lower explosive limit (LEL) of the liquid stored. Vapor detectors shall be located no higher than 12 inches (305 mm) above the lowest point in the vault. Liquid detection systems shall sound an alarm upon detection of any liquid, including water. Liquid detectors shall be located in accordance with the manufacturer’s instructions. Activation of either vapor or liquid detection systems shall cause a signal to be sounded at an approved, constantly attended location within the facility serving the tanks or at an approved location. Activation of vapor detection systems shall also shut off dispenser pumps." [IFC2012 5704.2.8.11]  Vents & Ventilation o "Listed or approved flame arresters or pressure-vacuum (PV) vents that remain closed unless venting under pressure or vacuum conditions - shall be installed in normal vents of tanks containing Class IB… liquids." [IFC2012 5703.6.9] o "Tanks and pressure vessels storing Class IB or IC liquids shall be equipped with venting devices which shall be normally closed except when venting under pressure or vacuum conditions, or with listed flame arresters. The vents shall be installed and maintained in accordance with Section 21.4.3 of NFPA 30 or API 2000." [IFC2012 5704.2.7.3.6] o "Vent pipe outlets for tanks storing Class I, II or IIIA liquids shall be located such that the vapors are released at a safe point outside of buildings and not less than 12 feet (3658 mm) above the finished ground level. Vapors shall be discharged upward or horizontally away from adjacent walls to assist in vapor dispersion. Vent outlets shall be located such that flammable vapors will not be trapped by eaves or other obstructions and shall be at least 5 feet (1524 mm) from building openings or lot lines of properties that can be built upon..." [IFC2012 5704.2.7.3.3] o "Stationary, above-ground tanks shall be equipped with additional venting that will relieve excessive internal pressure caused by exposure to fires. Emergency vents for Class I, II and IIIA liquids shall not discharge inside buildings. The venting shall be installed and maintained in accordance with Section 22.7 of NFPA 30." [IFC2012 5704.2.7.4] o "Vaults that contain tanks of Class I liquids shall be provided with an exhaust ventilation system installed in accordance with IFC2012 5004.3. The ventilation system shall operate continuously or be designed to operate upon activation of the vapor or liquid detection system. The system shall provide ventilation at a rate of not less than 1 cubic foot per minute (cfm) per square foot of floor area [0.00508 m3/(s · m2)], but not less than 150 cfm (4 m3/min). The exhaust system shall be designed to provide air movement across all parts of the vault floor. Supply and exhaust ducts shall extend to within 3 inches (76 mm), but not more than 12 inches (305 mm), of the floor. The exhaust system shall be installed in accordance with the International Mechanical Code." [IFC2012 5704.2.8.9]

 Labeling & Signage o Hazard identification signs. "Unless otherwise exempted by the fire code official, visible hazard identification signs as specified in NFPA 704 for the specific material contained shall be placed on stationary containers and above-ground tanks and at entrances to locations where hazardous materials are stored, dispensed, used or handled in quantities requiring a permit and at specific entrances and locations designated by the fire code official." [IFC2012 5003.5] o Tanks more than 100 gallons (379 L) permanently installed or mounted and used for Class I…liquid require identification and warning placard per NFPA 704 (underground tanks exempted). [IFC2012 5704.2.3]

NPFA 704 - Methanol

o No Smoking signs: "Smoking shall be prohibited and "No Smoking” signs provided as follows…" "2. Within 25 feet (7620 mm) of outdoor storage, dispensing or open use areas…" "4. In rooms or areas where flammable or combustible hazardous materials are stored, dispensed or used." [IFC2012 5003.7.1]

o "Warning signs shall be of a durable material. Signs warning of the hazard of flammable liquids shall have white lettering on a red background and shall read: DANGER—FLAMMABLE LIQUIDS. Letters shall not 1 be less than 3 inches (76 mm) in height and /2 inch (12.7 mm) in stroke. [IFC2012 5703.5.1]

o Piping labeled per ASME A13.1; locations as required by fire code official. [IFC2012 5703.5.2] o "A permanent sign shall be provided at the fill point for the tank, documenting the filling procedure and the tank calibration chart. Exception: Where climatic conditions are such that the sign may be obscured by ice or snow, or weathered beyond readability or otherwise impaired, said procedures and chart shall be located in the office window, lock box or other area accessible to the person filling the tank." IFC2012 5704.2.9.7.6.1]

 Fuel Transportation & Site Refueling o "Filling, emptying and vapor recovery connections to tanks containing Class I, II or IIIA liquids shall be located outside of buildings in accordance with Section 5704.2.7.5.6 at a location free from sources of ignition and not less than 5 feet (1524 mm) away from building openings or lot lines of property that can be built upon. Such openings shall be properly identified and provided with a liquid-tight cap which shall be closed when not in use." [IFC2012 5704.2.7.5.2] o "Filling, withdrawal and vapor-recovery connections for Class I, II and IIIA liquids which are made and broken shall be located outside of buildings, not more than 5 feet (1524 mm) above the finished ground level, in an approved location in close proximity to the parked delivery vehicle…." [IFC2012 5704.2.7.5.6] o "An approved means or method in accordance with Section 5704.2.9.7.6 shall be provided to prevent the overfill of all Class I, II and IIIA liquid storage tanks." [IFC2012 5704.2.7.5.8] o "Protected above-ground tanks shall not be filled in excess of 95 percent of their capacity. An overfill prevention system shall be provided for each tank. During tank-filling operations, the system shall comply with one of the following: 1. The system shall: 1.1. Provide an independent means of notifying the person filling the tank that the fluid level has reached 90 percent of tank capacity by providing an audible or visual alarm signal, providing a tank level gauge marked at 90 percent of tank capacity, or other approved means; and 1.2. Automatically shut off the flow of fuel to the tank when the quantity of liquid in the tank reaches 95

percent of tank capacity. For rigid hose fuel-delivery systems, an approved means shall be provided to empty the fill hose into the tank after the automatic shutoff device is activated. 2. The system shall reduce the flow rate to not more than 15 gallons per minute (0.95 L/s) so that at the reduced flow rate, the tank will not overfill for 30 minutes, and automatically shut off flow into the tank so that none of the fittings on the top of the tank are exposed to product because of overfilling." [IFC2012 5704.2.9.7.6]

 Fire & Emergency Response o Performance requirements (for Performance-based design alternative) - if chosen by mfg. [IFC2012 5001.3.3] o Hazardous Materials Management Plan (HMMP) - if required by AHJ [IFC2012 5001.5.1] o Hazardous Materials Inventory Statement (HMIS) - if required by AHJ [IFC2012 5001.5.2] o Fire Suppression - if required: [IFC2012 5705.3.7.3] Group H-2 or H-3 areas for flammable & combustible liquids o Fire protection for the storage, use, dispensing, mixing, handling, and on-site transportation of flammable liquids per IFC Chapters 9 & 57. o "When required by the fire code official, foam fire protection shall be provided for above-ground tanks, other than pressure tanks operating at or above 1 pound per square inch gauge (psig) (6.89 kPa) . when such tank, or group of tanks spaced less than 50 feet (15 240 mm) apart measured shell to shell, . has a liquid surface area in excess of 1,500 square feet (139 m2), . and is in accordance with one of the following: 1. Used for the storage of Class I or II liquids. … 4. Considered by the fire code official as posing an unusual exposure hazard because of topographical conditions; nature of occupancy, proximity on the same or adjoining property, and height and character of liquids to be stored; degree of private fire protection to be provided; and facilities of the fire department to cope with flammable liquid fires." [IFC2012 5704.2.9.2.1] o "Where foam fire protection is required, it shall be installed in accordance with NFPA 11." [IFC2012 5704.2.9.2.1] o "Where foam fire protection is required, foam-producing materials shall be stored on the premises. Exception: Storage of foam-producing materials off the premises is allowed as follows: 1. Such materials stored off the premises shall be of the proper type suitable for use with the equipment at the installation where required. 2. Such materials shall be readily available at the storage location at all times. 3. Adequate loading and transportation facilities shall be provided. 4. The time required to deliver such materials to the required location in the event of fire shall be consistent with the hazards and fire scenarios for which the foam supply is intended. 5. At the time of a fire, these off-premises supplies shall be accumulated in sufficient quantities before placing the equipment in operation to ensure foam production at an adequate rate without interruption until extinguishment is accomplished." [IFC2012 5704.2.9.2.2.1]

International Fuel Gas Code (IFGC) - Liquid Fuel  Components & Systems Certifications Liquid-fueled fuel cell power systems, including methanol & LP are outside the scope of IFGC: "This code shall not apply to the following:… 7. Integrated chemical plants or portions of such plants where flammable or combustible liquids or gases are produced by, or used in, chemical reactions…. 8. LP-gas installations at utility gas plants… 9. Liquefied natural gas (LNG) installations…" [IFGC2012.101.2.4]

NFPA 30 Flammable & Combustible Liquids Code - 2012 edition NFPA 30 addresses flammable methanol/water mixture storage requirements by location and quantity stored. NFPA 30 has different requirements & capacity limits for use in a process, i.e.; reformation (Chapter 17) vs. for bulk storage (Chapters 10-16). reformer fuel mix: Methanol/water blend, 60-70% (by weight) methanol to water, and has a flash point under 70°F. Pure methanol and methanol/water blend as described above are Flammable Class IB liquids per Section 4.3.1

 Definitions o Flammable Liquid: Any liquid that has a closed-cup flash point below 100°F (37.8°C)…and a Reid vapor pressure <40psi (276kPa) at 100°F (37.8°C). [NPFA30-2012 3.3.33.2] o Classification of Liquids (Chapter 4): (1) Class IB Liquid - Any liquid that has a flash point below 73°F (22.8°C) and a boiling point at or above 100°F (37.8°C).. [NPFA30-2012 4.3.1] o Containers & Tanks:  Containers: vessel for use or storage not to exceed 119 gallons (450 L). [NPFA30-2012 Section 3.3.12]  Intermediate Bulk Containers (IBC): closed vessel, not to exceed 793 gallons (3000 L), intended for storage or transport per CFR49 Parts 100-199 (DOT) or Part 6 UN Recommendations on the Transport of Dangerous Goods. [NPFA30-2012 3.3.12.4]  Rigid nonmetallic intermediate bulk containers & composite IBCs:  have a plastic vessel that serves as the primary liquid-holding component, enclosed in or encased by an outer structure of steel cage, a single-wall metal or plastic enclosure, a double wall of foamed or solid plastic, or a paperboard enclosure; also denotes an all- plastic single-wall IBC that might or might not have a separate plastic base and for which the containment vessel also serves as the support structure. U.S. Department of Transportation (DOT) describes these as "composite IBCs".  IBCs that have an outer liquid-tight metal structure are considered to be metal IBCs or metal portable tanks by DOT. [NPFA30-2012 A.9.4.1(5)]  Atmospheric Tank: storage tank designed for atmospheric to 1.0 psi (6.9 kPa) gauge pressure measure at the top of the tank. [NPFA30-2012 3.3.51.2]  Low-Pressure Tank: storage tank designed for pressures from 1.0 psi (6.9 kPa) to 15 psi (103 kPa) gauge pressure measured at the top of the tank. [NPFA30-2012 3.3.51.3]  Pressure Vessel: tank designed to operate above 15 psi (100kPa). [NPFA30-2012 21.4.2.3.1]  Portable Tank: storage tank over 60 gallons (230 L), not intended for fixed installations. [NPFA30- 2012 3.3.51.4]  Storage Tank: vessel for fixed installation, not used for processing, exceeds 60 gallons (230 L) capacity. [NPFA30-2012 3.3.51.6]  Secondary Containment Tank: tank with inner and outer walls with a means of leak detection in the space between. [NPFA30-2012 3.3.51.5] o Vault: an enclosure with a floor, 4 walls, and a top used only for containing a liquid Storage Tank. [NPFA30-2012 3.3.59] o Process or Processing: an integrated sequence of operations, including physical and or chemical operations, involving (but not limited to) preparation, separation, purification, or change in state, energy content, or composition. [NFPA30-2012 3.3.45 & A.3.3.45]  Components & Systems Certifications o Electrical equipment must be Class I Division 1 or 2, Zone 1 or 2 depending on proximity to indoor or outdoor storage per Table 7.3.3 Electrical Area Classifications unless amended by AHJ. [NFPA30-2012 7.3.3 - 7.3.6]

o Electrical equipment for Class I Division 1 or 2, or Zone 1 or 2 locations (classified area) may allow ordinary electrical equipment in a room or enclosure if maintained at a positive pressure relative to the classified area. [NFPA30-2012 7.3.7] - Pressure Testing requirement: . test per ASME B31, Code for Pressure Piping, all piping shall be tested before being covered, enclosed, or placed in use. [NFPA30-2012 27.7.1] . hydrostatic testing to 150 percent of the maximum anticipated pressure of the system or pneumatically to 110 percent of the maximum anticipated pressure of the system; maintain test pressure while a complete visual inspection of all joints and connections is conducted. [NFPA30- 2012 27.7.1.1] . test pressure no less than a gauge pressure of 5 psi (35 kPa) measured at the highest point of the system, and the test pressure be maintained not less than 10 minutes duration. [NFPA30-2012 27.7.1.2]

 Location, Capacity, Siting, & Setbacks o basement storage for Class I liquids prohibited. [NFPA30-2012 9.3.6] o for stable liquid, not over 2.5psi emergency relief pressure: o Table 17.4.3 Location of Process Vessels with Respect to Property Lines, Public Ways, and the Nearest Important Building on the Same Property….&  275 gallons or less 5 ft (1.5 m) from Property Line (present & future)  276-750 gallons 10 ft (3 m)  751-12,000 gallons 15 ft (4.5 m)  12,0001-30,000 gal 20 ft (6 m)  30,001-50,000 gal 30 ft (9 m)  50,001-100,000 gal 50 ft (15 m)  over 100,000 gal 80 ft (24 m) o Table 22.4.1.1.(a) Location of Aboveground Storage Tanks…. o Table 22.4.1.1.(b) Reference Table (for minimum distance from Property Line…) o Storing near LP-Gas: o 20 ft (6 m) minimum horizontal separation between LP-Gas containers and Class 1 Liquid storage. [NFPA30-2012 22.4.2.4]; o including means to prevent Class 1 liquid from accumulating under LP-Gas containers [NFPA30- 2012 22.4.2.4.1] o LP-Gas outside of diked areas (if used), and at least 3 ft (0.9 m) from centerline of wall of diked areas. [NFPA30-2012 22.4.2.4.2] Indoor MAQ: Maximum Allowable Quantity [MAQ] of Flammable Liquids per Control Area [NFPA30-2012 Table 9.6.1] o - restricts MAQ of Flammable Liquid (Class IB) to 120 gallons per control area, o Maximum quantities increased by 100% if stored in approved flammable liquid storage cabinet or safety cans;  resulting limit: Flammable Liquid (Class IB) to 240 gallons per control area. [Note 1] o Maximum quantities increased by 100% if an approved sprinkler system is in place;  resulting limit: Flammable Liquid (Class IB) to 240 gallons per control area. [Note 2] o If both an approved gas cabinet and approved sprinkler system are used, the 100% increase in MAQ is applied accumulatively;  resulting limit: Flammable Liquid (Class IB) to 480 gallons per control area. [Notes 1 & 2]. o No limit if building has an automatic fire sprinkler system throughout installed per NFPA 13 Standard for the Installation of Sprinkler Systems, and designed per NFPA30-2012 Chapter 16. [Note 4] Outdoor MAQ: o not defined (no limit criteria) o Storage is limited per Table 15.3 Storage Limitations for Outside Storage (per Pile):  Containers: 2200 gallons  Portable Tanks & Metal IBCs: 4400 gallons  Rigid Plastic & Composite IBCs: Not Permitted o Outdoor storage adjacent to a building - for containers, IBCs, or portable tanks: [NFPA30-2012 15.4.1]

 limited to 1100 gallons (4160 L) per pile  the adjacent building wall has an exterior fire resistance rating of 2 hours,  no openings at or above grade on the adjacent building wall that are within 10 ft (3 m) horizontally of the storage, and  no openings below grade on the adjacent building wall that are within 50 ft (15 m) horizontally of the storage,  may be waived by AHJ if the building is one story, is of noncombustible or fire-resistive construction, and devoted principally to liquid storage. [NFPA30-2012 15.4.2]  may exceed 1100 gallons (4160 L) if stored at least 5 ft between piles, 50 ft from property lines, and 10 ft from Street, Alley, or Public Way. [NFPA30-2012 15.4.4]  Container types & design & storage construction o For fixed tanks that exceed 60 gallons (230 L), or portable tanks that exceed 660 gallons (2500 L), or IBC that exceed 793 gallons (3000 L) capacity: [NFPA30-2012 21.1] . of any shape, size, or type consistent with recognized engineering standards, [NFPA30-2012 21.3.2] . made of steel or other noncombustible material, [NFPA30-2012 21.4.1] . made of compatible materials to what's being stored, [NFPA30-2012 21.4.1.1] . tanks may have combustible linings, [NFPA30-2012 21.4.1.4] . designed and constructed per recognized engineering standards, including the following (design standards for atmospheric tanks): [NFPA30-2012 21.4.2.1.1] o API Specification 12B, Bolted Tanks for Storage of Production Liquids o API Specification 12D, FieldWelded Tanks for Storage of Production Liquids o API Specification 12F, Shop Welded Tanks for Storage of Production Liquids o API Standard 650, Welded Steel Tanks for Oil Storage o UL 58, Standard for Steel Underground Tanks for Flammable and Combustible Liquids o ANSI/UL 80, Standard for Steel Tanks for Oil-Burner Fuels and Other Combustible Liquids o ANSI/UL 142, Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids o UL 1316, Standard for Glass-Fiber Reinforced Plastic Underground Storage Tanks for Petroleum Products, Alcohols, and Alcohol-Gasoline Mixtures o ANSI/UL 1746, Standard for External Corrosion Protection Systems for Steel Underground Storage Tanks o UL2080, Standard for Fire Resistant Tanks for Flammable and Combustible Liquids o ANSI/UL 2085, Standard for Protected Aboveground Tanks for Flammable and Combustible Liquids . low-pressure tanks (1.0 - 15 psi) o API 620, Recommended Rules for the Design and Construction of Large, Welded, Low- Pressure Storage Tanks o ASME Code for Unfired Pressure Vessels, Section VIII, Division 1 o For drums or other containers not exceeding 119 gallons (450 L), or portable tanks not exceeding 660 gallons (2500 L), or IBC not exceeding 793 gallons (3000L) capacity: [NFPA30-2012 9.1.1] Approved containers, IBC, and portable tanks: [NFPA30-2012 9.4.1] . Metal: US DOT Title 49CFR Parts 100-199 or Part 6 of UN Recommendations on the Transport of Dangerous Goods. . Plastic: US DOT Title 49CFR Parts 100-199 or Part 6 of UN Recommendations on the Transport of Dangerous Goods. . Fiber Drums: National Motor Freight Classification (NMFC) Items 294 & 296, or Uniform Freight Classification (UFC) Rule 51 for types 2A, 3A, 3B-H, 3B-L, or 4A. o For rigid nonmetallic intermediate bulk containers . must be listed and labeled for fire performance. [NPFA30-2012 9.4.1.1] . US DOT Title 49CFR Parts 100-199 or Part 6 of UN Recommendations on the Transport of Dangerous Goods, for Classes 31H1, 31H2, and 31HZ1 . National Motor Freight Classification (NMFC), or the International Safe Transit Association for liquids that are not classified as hazardous by the US DOT Title 49CFR Parts 100-199 or Part 6 of UN Recommendations on the Transport of Dangerous Goods. [NPFA30-2012 9.4.1(5)] o Maximum allowable size for Containers, IBCs, and Portable Tanks - for Class 1B per Table 9.4.3; . Metal drums (e.g.; UN 1A1/1A2): 119 gallons (450 L)

. approved Metal Portable Tanks & IBCs: 793 gallons (3000 L) . approved Plastic or Metal (other than drums): 5.3 gallons (20 L) . Rigid Plastic, Composite IBCs, Fiber Drum: not permitted; except: Plastic Containers are permitted up 60 gallons (230 L) capacity of Class 1B water-miscible liquids. [NPFA30-2012 9.4.3.1]  Piping, Valves, Regulators, Fuel Controls per Chapter 27 o "Pipe, valves, faucets, couplings, flexible connectors, fittings, and other pressure-containing parts shall meet the material specifications and pressure and temperature limitations of ASME B31, Code for Pressure Piping…" [NFPA30-2012 27.4.1] o "Nonmetallic piping shall be built and used within the scope of their approvals or within the scope of UL 971, Standard for Nonmetallic Underground Piping for Flammable Liquids." [NFPA30-2012 27.4.6.2]  Vents & Ventilation o "When a process heats a liquid to a temperature at or above its flashpoint (e.g.; burner)… (1) The process vessel shall be closed to the room in which it is located and vented to the outside of the building…. (3) The process vessel shall be equipped with an excess temperature control set to limit excessive heating of the liquid and the subsequent release of vapors." [NPFA30-2012 17.3.7] o Portable Tank & IBC vents:  portable tanks or IBCs require emergency venting devices installed on top to limit internal pressure under fire exposure to 10 psi (70 kPa) gauge or 30% portable tank bursting pressure. [NFPA30-2012 9.4.2]  total venting capacity not less than specified in NFPA30-2012 22.7.3.2 or 22.7.3.4. [NFPA30- 2012 9.4.2.1]  require at least 1 pressure-actuated vent, opening at not less than 5 psi (35 kPa) gauge pressure, capable of 6000 ft3 (170 m3) of free air per hour at an absolute pressure of 14.7 psi (101 kPa) at 60F (15.6C). [NFPA30-2012 9.4.2.2]  fusible vents if used must activate at or below 300°F (150°C); type that softens to failure at 300°F (150°C) maximum under fire conditions may be permitted for the entire emergency venting requirement. [NFPA30-2012 9.4.2.3] o Tanks vents:  sized to either API Standard 2000, Venting Atmospheric and Low-Pressure Storage Tanks, or another approved standard.  The normal vent shall be at least as large as the largest filling or withdrawal connection, and not less than 1.25 in. (32 mm) nominal inside diameter.  "Tanks and pressure vessels that store Class IB…liquids shall be equipped with venting devices or with listed flame arresters. When used, vent devices shall be closed, except when venting under pressure or vacuum conditions." [NPFA30-2012 21.4.3.9]; waived if - when obstructed - likely to cause damage to tank. [NPFA30-2012 21.4.3.11]  vent not required for interstitial space between primary & secondary containment. [NPFA30-2012 A21.4.3.2]  Labeling & Signage Labeling (Storage Cabinet): o shall be marked - attached to upper portion of cabinet's front door or frame - as follows: "WARNING: FLAMMABLE KEEP FIRE AWAY" uppercase letters, contrasting color to the background, 2.0 inch (50mm) minimum height for "FLAMMABLE", 1.0 inch (25mm) minimum height for "KEEP FIRE AWAY". May use other languages and international symbols (flame in a triangle, burning match in "no" circle). [NFPA30-2012 9.5.5]

 Fuel Transportation & Site Refueling o Class 1 liquids are kept in closed containers or tanks when not actually in use. [NFPA30-2012 18.4.1] o Liquids transferred by inert gas pressure are permitted if all fluid storage & handling is designed for the anticipated pressure, overpressure or pressure-relief devices are provided, and only inert gas is used. [NFPA30-2012 18.4.4] o Areas where liquids are transferred from one container or tank into another require: . separation by distance or fire-resistance construction from other potential ignition sources, . drainage or other spill control, and . natural or mechanical ventilation per NFPA30-2012 17.11. [NFPA30-2012 18.5.6] . mechanical ventilation required for Class 1 liquids dispensed inside a room. [NFPA30-2012 18.6];  shall provide at least 1cfm exhaust air for each sq. ft. of floor area (0.3 m3/min./m2), but not less than 150 cfm (4 m3/min.), [NFPA30-2012 18.6.5]  have an interlocked audible alarm that sounds if ventilation fails. [NFPA30-2012 18.6.5.1]  exhaust air outlet on one side of a room within 12 inches (300 mm) of the floor, and one or more inlets on the other side of the room within 12 inches (300 mm) of the floor. [NFPA30-2012 18.6.1],  and exhaust discharged outside the building unless recirculation is used; recirculation requires continuous monitoring and provide full exhaust to the outside if vapor exceeds 25% LFL. [NFPA30-2012 18.6.3 & 18.6.3.1]  Fire & Emergency Response per Chapter 6 o Hazard analysis exempted: Exemption No. 1: Operations where liquids are used solely for on-site consumption as fuels. [NFPA30-2012 6.4.1] o Fire Protections and Fire Suppression Systems (general requirements) per NFPA30-2012 6.7. o A written emergency action plans is required, including procedures for response to leaks or fire, maintenance, inspections, shutdown and isolation, etc. [NFPA30-2012 6.8.1]

of 44 version: 5May2014 Fuel Cell Power Electrical Generators - Implementation Guide For Telecom Providers By application:

Telecom Use Other compliance requirements: Network Equipment Building Systems (NEBS) - Telcordia Telcordia (formerly Bell Labs, now a part of Ericsson) has created a series of standards for telecom applications that cover construction, performance, reliability, and additional safety requirements.

NEBS compliance criteria is defined by each particular telecom carrier (if required).

FR-2063 defines NEBS equipment. The fuel cell power system is a standby generator; when used at a cell site is considered part of the Outside Plant equipment. A guide to understanding NEBS criteria and document requirements entitled "Roadmap To NEBS Documents" is provided by Telcordia at: http://telecom-info.telcordia.com/ido/PDF/ROADMAP_TO_NEBS_1.i07.pdf  SR-3580 NEBS Criteria Levels: Level 1, Level 2, Level 3  GR-63-CORE Physical Protection  GR-78-CORE Generic Requirements for the Physical Design and Manufacture of Telecommunications Products and Equipment  GR-487-CORE Generic Requirements for Electronic Equipment Cabinets  GR-1089-CORE Electromagnetic Compatibility and Electrical Safety

of 44 version: 5May2014