A Case Study for Implementation
Lessons Learned from Clean Air Now’s Hydrogen Permitting Process

By James J. Provenzano, Executive Director, Clean Air Now!

When the National Hydrogen Association invited me to speak at its Safety, Codes, and Standards Workshop this past July, I was concerned with my capacity to contribute to the discussion. Not only am I not an engineer (a frustrated one, I could argue), but I am also not an engineer who has expertise with hydrogen systems. My knowledge of codes and standards for hydrogen was pretty much limited to the fact that the industry is in need of some. I applaud the NHA’s and Canadian Hydrogen Association’s strong efforts to rectify this situation.

What I could bring to the table was the experience of Clean Air Now in obtaining permits for our Solar-Powered Hydrogen Generating and Dispensing Facility, located at Xerox Corporation in El Segundo, California (U.S.A.). Conveying the issues I faced as a manager and highlighting the political and practical implications of dealing with regulatory and permitting agencies, I hoped would make it a little easier for the next person going down the same path.

From the very beginning of our project, one of our objectives, and guiding principles, was to ensure all parties felt safe with the hydrogen energy technologies that we were implementing. Working with Michael Kerr, Tom Halvorson, and the rest of the gang from Praxair, and then with Matthew Fairlie of Stuart Energy Systems/Electrolyser Corporation, one of the first parameters determined was to design the facility using industry standards and apply accepted practices to all the systems. We wanted to adhere to this game plan as much as possible. Since the U.S. Department of Defense funded our project as a “technology deployment” project, using conventional wisdom and practices in the design and construction also satisfied the philosophy behind the project.

If there were shortcomings to this approach, then our experience would flesh them out and we would make recommended upgrades to any subsequent facility. By staying within industry standards, we had some cushion for explanation in the permitting process, hopefully satisfying any objections to design by the authorities. This was not a time for trying something untested unless there was a blatant lack of direction given by the codes and standards used and it was clear that we had devised a “better” approach.

The hydrogen dispensing station doesn’t look all that different from a gasoline station, except for the solar photovoltaic panels at far right, which provide the power to the electrolyzer to separate water into its hydrogen and oxygen components. [Closer shots of the PV panels appear below.]

As a side note, one of the items that is a candidate for improvement that stands out in my mind, and is of a very practical nature when dealing with the public, is the industry standard CGA350 gas line connector used for recharging the trucks with hydrogen. A quick release setup with an integral grounding provision, as is now used with natural gas recharging, needs to be standardized for hydrogen gas use.

We attempted to make the system as “idiot-proof” as possible with current codes and standards. (If hydrogen is to move to wide public acceptance, it is obvious that we need to think about ease-of-use for hydrogen systems now.) For instance, we had to rig our own grounding system for recharging the trucks, as there was no known standard or practice besides using an insecure alligator clamp. Our system employs a safer approach where grounding of the vehicle to the fueling station needs to be completed before the fueling port door on the truck can be opened. This is just one example of ingenuity used during the planning and installation phases of the project that dealt with the deficiency in the codes and standards for hydrogen. This was also a situation where we felt we could improve the safety of the facility.

If I were asked what was the single most important factor in CAN getting permitted, I would have to say it was getting a third and objective party to perform code compliance and safety and failure-mode assessments on all the systems. This is especially true for budding technologies and integrated facilities that have very little record of accomplishment and are not well-known by local permitting agencies and fire marshals.


CAN hired the Energy Technology Engineering Center (ETEC) of Canoga Park, California, to perform the assessments. Kevin Knudsen and Mike McDowell of Rocketdyne’s ETEC installation were invaluable to CAN and the project partners. (Their reports are available to the public and are a great source of a real-life hydrogen energy systems’ evaluation for code applicability and compliance.) Our only mistake was not getting ETEC involved earlier, during the design phase of the project. Instead, they came in after the majority of construction was completed, forcing us to make more costly retrofit changes to rectify the found deficiencies. After ETEC gave the facility “safe to operate” ratings, the El Segundo Fire Marshal signed off, and the Building Department issued the final inspection permit.

The codes and standards applied by ETEC to perform the safety and failure mode assessments include:

We kept the review objective and meaningful by giving ETEC full purview of the facility’s operability and safety worthiness. If they were not happy with anything, we were not happy. ETEC had to be satisfied before we would go for final inspection. This meant implementing provisions that went “beyond” the recommendations of the codes and standards. We made the City of El Segundo, Xerox, and all the partners quite aware of this fact. Even though the city and Xerox were somewhat knowledgeable about, and had some previous experience with, hydrogen (i.e., cooling gas in a local power plant and use in Xerox’s microelectronics lab), having ETEC provide failure-mode analysis and safety assessment documents provided a level of comfort that, I feel, created the atmosphere of good faith among all the parties that enabled us to break new ground.


All the parties were kept informed, coordinated, and involved early and often. Matrix Engineers & Contractors, Inc., which performed the facility construction and installation, submitted the blueprints to the city and informed the El Segundo Fire Department of our project scope and intent immediately after the plans were delivered. We stayed abreast of the internal progress of the permitting process, responding to all concerns and questions. We were fortunate to be able to build on Xerox’s excellent reputation with the city and use their Environmental, Health, and Safety Department’s expertise. All this facilitated important dialogue.

By bringing the permitting and regulatory agencies “along for the ride,” I feel we made them an integral part of the process, giving them a participatory and “ownership” role rather than just a peremptory role. They truly were exited about the project and felt they were contributing to the advancement of clean and renewable energy technology.

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