From: Peridas, George-->
Sent: Monday, April 17, 2023 10:25 PM
To: Lina Velasco <[email protected]>
Subject: Re: Hydrogen Project in Richmond
Attachment 8
This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.
Hi Lina,
Thanks for getting in touch. Let me gather the relevant experts from our end, and I will endeavor to get you answers to as many of the questions below as possible.
Will be in touch.
George Peridas, Ph.D.
Director, Carbon Management Partnerships
Lawrence Livermore National Laboratory
Ill■ Lawrence Liven � Natinn�I I ahnrn
Administrative contact
Kelly Johnson:
From: Lina Velasco <Lina [email protected]>
Date: Monday, April 17, 2023 at 9:12 PM
To: Peridas, George�
Subject: Hydrogen Project in Richmond
Hi Mr. Peridas
The City of Richmond is reviewing a Hydrogen production project, Raven SR in Richmond, Ca and we have received comments and concerns from the public regarding the safety, climate, and health impacts. We're wondering if you can assist us by providing your thoughts regarding the following questions:
Dangers of hydrogen
1 2
• Some people in Richmond are concerned with both the dangers of transporƟng and storing hydrogen and the dangers of the manufacturing process. They remember the crude plant fire that occurred at the Richmond Chevron refinery in 2012 and the hundreds of people who went to the hospital. Can you explain how dangerous is the manufacturing process that Raven SR proposes? How likely is the facility to explode? How toxic would it be if it exploded?
• How should the city look at the dangers posed by hydrogen itself? Are the hydrogen tube trailers dangerous compared to transporƟng gasoline or chemicals? Is it dangerous if a vehicle has an accident? Is it dangerous to store? Climate Impact
• How useful would hydrogen with a carbon intensity of 2.6 gCO2e/mj be for miƟgaƟng climate change? Might the supposed climate benefit be eliminated by fugiƟve hydrogen leakage? • Roughly what percentage of the hydrogen would it have to leak to totally remove the climate benefit? Health Impact
• Would you be willing to review the HRA and tell us if you believe that Raven SR would reduce the health risk of air polluƟon? Here is the summary of the HRA in its own words:
“The proposed Project provides an overall reducƟon of cancer risk, chronic hazard index, acute hazard index, and parƟculate maƩer concentraƟons as compared to the porƟons of the exisƟng landfill flare operaƟon it would be replacing.”[1]
[1] Project 1690025248 HRA Richmond Planning and Building Service Department Richmond, California. https://www.ci.richmond.ca.us/DocumentCenter/View/64961/Raven-SR-Project Updated-ISMND 030923-PLN21-282 OCR w- ERRATA1
We’
re looking to wrap us the project review in the next couple of weeks, so a quick reply is appreciated.
Thanks,
Lina
Lina Velasco
She/her/hers
Community Development Director
City of Richmond
450 Civic Center Plaza
Richmond, Ca 94804
(510) 620-6841
Attachment 8
Dangers of hydrogen
Some people in Richmond are concerned with both the dangers of transporting and storing hydrogen and the dangers of the manufacturing process. They remember the crude plant fire that occurred at the Richmond Chevron refinery in 2012 and the hundreds of people who went to the hospital. Can you explain how dangerous is the manufacturing process that Raven SR proposes? How likely is the facility to explode? How toxic would it be if it exploded?
According to the U.S. Department of Energy’s Hydrogen and Fuel Cells Technologies Office:
“By their nature, all fuels have some degree of danger associated with them. The safe use of any fuel focuses on preventing situations where the three combustion factors—ignition source (spark or heat), oxidant (air), and fuel—are present. With a thorough understanding of fuel properties, we can design fuel systems with appropriate engineering controls and establish guidelines to enable the safe handling and use of a fuel.
A number of hydrogen's properties make it safer to handle and use than the fuels commonly used today. For example, hydrogen is non-toxic. In addition, because hydrogen is much lighter than air, it dissipates rapidly when it is released, allowing for relatively rapid dispersal of the fuel in case of a leak.
Some of hydrogen's properties require additional engineering controls to enable its safe use.
Specifically, hydrogen has a wide range of flammable concentrations in air and lower ignition energy than gasoline or natural gas, which means it can ignite more easily. Consequently, adequate ventilation and leak detection are important elements in the design of safe hydrogen systems. Because hydrogen burns with a nearly invisible flame, special flame detectors are required.
In addition, some metals can become brittle when exposed to hydrogen, so selecting appropriate materials is important to the design of safe hydrogen systems. In addition to designing safety features into hydrogen systems, training in safe hydrogen handling practices is a key element for ensuring the safe use of hydrogen. In addition, testing of hydrogen systems—tank leak tests, garage leak simulations, and hydrogen tank drop tests—shows that hydrogen can be produced, stored, and dispensed safely.”1
To summarize, hydrogen is a non-toxic, light gas that diffuses fast, which results in a narrow window for the right hydrogen-air mixture to result in a fire/explosion. As with any fuel, proper engineering and prevention is required for safe handling.
Hydrogen production via steam methane reforming has been being used in petroleum refineries for many decades now, as hydrogen is needed to treat/upgrade fossil feedstock and byproducts. Steam methane reforming is a mature production process, currently responsible for 95% of hydrogen production in the United States. SMR hydrogen is produced at the 130 oil refineries in the United States, and at more than 200 other facilities across the United States.2 1 https://www.energy.gov/eere/fuelcells/safe-use-hydrogen 2 https://www.energy.gov/eere/fuelcells/hydrogen-production-natural-gas-reforming Attachment 8
Further information of past use of hydrogen in the economy as well as related safety standards can be found in a report by the U.S. Department of Energy Office of Scientific and Technical Information.3 The report states that:
“It is important to note that similar codes are used for different fuel sources, such as natural gas and gasoline. Although the risk of a severe accident is not 0 in any of these applications, society and governing officials accept a reasonable level of risk with these types of facilities. Specific to hydrogen, the codes and standards were developed so that the risk associated with a hydrogen system is the same or lower than that of a gasoline refueling station. This ensures that undue risk is not being undertaken by the public when in close proximity to a hydrogen generation facility or hydrogen fueling system.”
The safety record of that process should be indicative of the likely safety of the Raven SR operations, as the only thing that appears to be different is the feedstock: it would be bio-derived instead of natural gas. Since many accidents take place due to human error or omission, an assessment on the safety record of the developer will be an important factor to consider in assessing project safety.
The 2012 fire at Chevron’s Richmond refinery has been documented in an investigation report by the U.S. Chemical Safety and Hazard Investigation Board.4 The incident was caused by a failed steel piping component that had worn down due to corrosion linked to the sulfur content of the fuel it transported:
light gas oil. This is known as sulfidic corrosion. Failure by the operator to inspect, detect and replace such worn components resulted in the accident, despite prior recommendations by Chevron employees to do so.
We view the accident as an indication of what can happen when proper engineering procedures are not followed, but not indicative of the dangers posed by hydrogen or the Raven SR project itself. Light gas oil is a very different substance to hydrogen with wholly different properties and possible health effects from the toxicity of its combustion vapors.
How should the city look at the dangers posed by hydrogen itself? Are the hydrogen tube trailers dangerous compared to transporting gasoline or chemicals? Is it dangerous if a vehicle has an accident? Is it dangerous to store?
Any form of energy carrier or fuel, such as gasoline, battery, hydrogen, natural gas containing similar amount of energy pose a safety concern. However, the type of hazard is quite different. Gases such as natural gas and hydrogen have a narrow time window in the fire hazard condition (this on whether the leak takes place in confined space/open space and/or the rate of leak). Liquid fuels such as gasoline have to evaporate to become explosive, but will likely burn for a longer time than gas. Batteries will keep burning until completely discharged and/or metals (such as lithium) are completely oxidized, potentially for days.
3 https://www.osti.gov/servlets/purl/1870559
4 https://www.csb.gov/file.aspx?DocumentId=5917
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We are under the impression that fire departments already have training for how to deal with fire hazards from various types of cars such battery electric vehicles and fuel cell electric vehicles. The City may want to consult with them.
We are not aware of any hydrogen explosions caused by hydrogen leaked from fuel cell electric vehicles, despite multiple reports of such vehicles involved in road accidents. In case of emergency, the vehicles are designed to release hydrogen upward so that even if it catches fire, it will only shoot upwards, not horizontally. Also, the currently used onboard hydrogen tanks are designed to (and experimentally confirmed) such that shooting them with an assault rifle will puncture them but not cause an explosion.5
We suggest that the City consider whether the project plans to having on-site hydrogen storage or not.
In future, hydrogen distribution from its production facility to refueling stations will likely to be done with liquid hydrogen tankers, not tube trailers (for economic reasons). However, this requires a large enough market size and supply capacity to justify installation of liquification equipment. We are aware of a few fire incidents of hydrogen tube trailers in California in the past ~5 years, however, no casualties (or serious injuries) have been reported that we are aware of. If this is true, it is likely due to hydrogen’s burning characteristics and safety measure taken in the tube trailers to ensure that any hydrogen released shoots in a vertical direction so the fire will shoot straight up.
Climate Impact
How useful would hydrogen with a carbon intensity of 2.6 gCO2e/MJ be for mitigating climate change? Might the supposed climate benefit be eliminated by fugitive hydrogen leakage? A carbon intensity of 2.6 gCO2e/MJ represents a >97% (i.e. very large) reduction in carbon intensity compared to conventional grey hydrogen from steam methane reforming using natural gas.
In principle, the bio-conversion process proposed for the Raven SR Project could be used to replace the production of conventional CO2-emitting SMR hydrogen. Worldwide, 830 tons of CO2 are emitted to produce 74 million tons of hydrogen each year, representing 2.2% of total CO2 emissions. The United States produces about 10 million tons of hydrogen per year, primarily using the SMR process. So, the technology proposed for the Raven SR Project can have a useful impact on mitigating climate change.
Replacing natural gas with biomethane as the feedstock in the water-gas shift reactor reduces the use of fossil fuel. Replacing fossil-fuel combustion with an energy-efficient approach that uses renewable electricity to supply the process heat required by the water-gas shift reactor also reduces the use of fossil fuel.
Roughly what percentage of the hydrogen would it have to leak to totally remove the climate benefit?
Reports on the potential negative effect of fugitive hydrogen generally assume a 10-20% leak rate and the effect is estimated based on general knowledge of chemistry: in other words, these are not confirmed scientific facts, rather suggestions/propositions. 5 See, for example: https://www.youtube.com/watch?v=jVeagFmmwA0 Attachment 8
For an in-depth assessment of the potential climate good vs. harm of hydrogen, we point the City to a recent analysis by the Rocky Mountain Institute and another by a team of researchers from the United Kingdom. 6,7
The former concluded that:
“The climate benefit from a well-regulated clean hydrogen economy outweighs the impact of any emissions that hydrogen would add to our energy system, especially if we prioritize hydrogen produced from renewables-powered electricity.” The latter concluded that:
“If a global hydrogen economy replaced the current fossil fuel-based energy system and exhibited a leakage rate of 1% then it would produce a climate impact of 0.6% of the current fossil fuel based system. If the leakage rate were 10%, then the climate impact would be 6% of the current system.”
Health Impact
Would you be willing to review the HRA and tell us if you believe that Raven SR would reduce the health risk of air pollution? Here is the summary of the HRA in its own words:
“The proposed Project provides an overall reduction of cancer risk, chronic hazard index, acute hazard index, and particulate matter concentrations as compared to the portions of the existing landfill flare operation it would be replacing.”8
We do not feel qualified to answer the question in the timeline available without a deeper dive into the specifics of the project. However, we recommend that the City consider the nature of the Raven SR feedstocks and process emissions/byproducts compared to the existing landfill operations. 6 https://rmi.org/hydrogen-reality-check-1-hydrogen-is-not-a-significant-warming-risk/ 7 https://www.geos.ed.ac.uk/~dstevens/Presentations/Papers/derwent ijhr06.pdf 8 Project 1690025248 HRA Richmond Planning and Building Service Department Richmond, California. https://www.ci.richmond.ca.us/DocumentCenter/View/64961/Raven-SR-Project Updated - ISMND 030923 -PLN21-282 OCR w -ERRATA1
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