Risk Assessment Challenges for HRS Projects – Our Experiences

In Australia, energy operators are in various project stages in the development of facilities generating, storing and dispensing hydrogen. From a process safety viewpoint, careful consideration of the hydrogen process and storage conditions is required. The same level of risk assessment rigour that is applied to a traditional energy production facility equally applies to new energy facilities. In particular, there are several process safety challenges that apply to a Hydrogen Refuelling Station (HRS). Of note, the management of interfaces between the Person Conducting a Business or Undertaking (PCBU), i.e. the owner/operator of the HRS and vendors designing manufacturing and supplying the packages requires particular attention. Our experience has shown that the HRS process design is relatively complex with various vendor package interfaces that individually have undergone their own risk review process but not in totality. Likewise, the level of process safety assessments varies between the PCBU and the vendor necessitating harmonization to ensure the risks meet operator as well as regulatory risk regimes.

• This paper outlines the challenges that may occur in a project to develop a HRS, including:
• Legislative (health and safety) requirements on the PCBU and equipment designer/manufacturer.
• State stakeholders, requirements and guidance.
• Changes in HRS technology and development of standards over the life of the project.
• Clarity on key design deliverables and management of documentation.
• Identification of Work Health and Safety (WHS) hazards and issues relating to conduct of Hazard and Operability (HAZOP) studies on vendor packages.
• Assessment of risks and potential conflicts with vendor risk assessments, including Safety Integrity Level (SIL) allocation and verification.
• Tips are provided to address these challenges in delivering a HRS in Australia.