Document 4awwRgEnRxxQzvJGL3n1xO7ga

Hydrocarbons as refrigerant in large heat pumps for district heating in Norway - Safety aspects, standards, and regulations Erlend Balstad, Steinar van der Meer Efficient, environmentally friendly and safe utilization of energy NORSI< ENERGI Report Client: Project name: Title.: Your ref: Created by: Controlled by: Status: Hafslund Oslo Celsio AS Regelverkskrav for bruk av hydrokarboner som kuldemedier Hydrocarbons as refrigerant in large heat pumps for district heating in Norway Oyvind Nilsen, Monica Hayskjold Erlend Balstad, Steinar van der Meer Marthe H. Bjorn s Final edition Summary and conclusion Due to environmental challenges regarding synthetic refrigerants and national and international legislations limit the use of synthetic refrigerants, use of natural refrigerants has become more common in heat pump and refrigeration applications. Hydrocarbons are considered as promising natural refrigerants for future development of heat pumps due to their favorable thermodynamic and environmental properties. Hydrocarbons are however extremely flammable and not without challenges regarding safety. Due to their high flammability, use of hydrocarbons in heat pumps is regulated by several national regulations, and European directives and standards. The purpose of this report is to highlight some of the most important challenges and limitations regarding the use of hydrocarbons as refrigerant in large heat pumps, for district heating applications in densely populated areas. It is assumed that the reader of this document is familiar with the general and specific content of relevant acts, regulations and standards. All heat pump systems with hydrocarbon refrigerants are regulated by: Act relating to the prevention of fire, explosion and accidents involving hazardous substances and the fire service / Brann og eksplosjonsvernloven /1/ (Act related to fire and explosions) Regulations of 8 June 2009 relating to the handling of flammable, reactive and pressurized substances including requisite equipment and installations / Forskrift om handtering av farlig stoff /3/ (Regulations regarding handling of hazardous substances) Directive 2014/68/EU -- Pressure Equipment Directive (PED) / Forskrift om trykkpAkjent utstyr /5/ Directive 2006/42/EC-- Machinery Directive / Forskrift om maskiner /6/ Directive 99/92/EC -- Minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres / Forskrift om helse og sikkerhet i eksplosjonsfarlige atmosf rer /7/ Directive 2014/34/EU -- Equipment and protective systems intended for use in potentially explosive atmospheres / Forskrift om utstyr og sikkerhetssystem til bruk i eksplosjonsfarlig omr5cle /8/ EN 378:2016 Part 1-4 Refrigerating systems and heat pumps - Safety and environmental requirements /13/ Efficient, environmentally friendly and safe utilization of energy MAIN OFFICE Hoffsveien 13 P.O. Box 27 Sk0yen N - 0212 Oslo Phone: 22 06 18 00 OFFICE GJOVIK Strandgt. 13 A N - 2815 GjOvik OFFICE BERGEN Damsgkdsveien 131 N - 5160 LakseAg Organization no. 945 469 277 VAT Acct.no. 7034 05 00014 l @energi.no www.energi.no Dok Id: 36807-13, rev. 2 Date: 10.09.2023 Page 2 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway All systems handling flammable substance must according to Act related to fire and explosions (Section 3.2.1) 26 be safe and suitable for the intended use. According to Regulations regarding handling of hazardous substances(Section 3.2.3) it is mandatory to perform a risk assessment ( 14) and equipment used to handle hazardous substances must be in compliance with recognized norms ( 8). The purpose of both the act and regulation is to protect life, health, environment, and material values. According to Regulations regarding handling of hazardous substances 16 "Land use limitations must be established around equipment and installations where this is necessary, according to 14 (Risk assessment) to safeguard the adjacent area in a satisfactory manner." The limitation of land use (Act related to fire and explosions 20) is set according to the Act of July 2023 regarding planning and construction case processing / The Plan and Building Act (Section 3.2.2). According to The Plan and Building Act 20-6 "Measures sufficiently covered by another act are except from the obligation to apply to the Ministry of Local Government and Regional Development. Which measures are exempt from the duty to apply and to which extent, is decided by the Ministry of Local Government and Regional Development." Depending on the amount of refrigerant charge the system might also be regulated by Directive 2012/18/EU - Seveso III Directive / Storulykkeforskriften (Section 3.1.1). In these cases, there are also more requirements defined in Regulations regarding handling of hazardous substances, most notably 9 and 17. For heat pumps with over 10 000 kg of flammable refrigerant (lower-tier according to the Seveso III Directive) the risk assessment must be in the form of a QRA (Quantitative Risk Assessment) which defines risk contours as described in section 3.1.1. Norsk Energi recommends that a QRA also is considered for smaller refrigerant charge rates. Depending on the amount of refrigerant and conditions on the site, the risk contours may extend out of the enterprises property and impose land use restrictions to nearby properties. Land use restrictions are set by the authorities. As a result, this restricts where such enterprises and large heat pump installations can be located, especially for densely populated areas. For hydrocarbon heat pumps, with a heating capacity of 5-30 MW it is estimated large refrigerant charges rates in the range of 2 000 - 20 000 kg. To summarize, there are five important limits of refrigerant charge which has implications for choice of technical solution, required safety measures and relevant acts and regulations: 1. Refrigerant charge <= 5,0 kg Heat pumps below 5,0 kg per independent refrigerant circuit (R290/Propane) can be placed in a ventilated enclosure as described in EN378 Part 1 (Section 3.1.6). This reduces the technical requirements of the machinery room. For such systems the machinery room is not considered as a potential hazardous sone during normal operation. 2. Refrigerant charge > 5,0 kg and < 400 liters Systems with more than 5,0 kg of refrigerant per independent circuit can according to EN378 Part 1 be located either in a machinery room or in open air given that the location is access restricted (supervised or authorized access) and meet the requirements of EN378 Part 3, section 5.1 - 5.14. Given that the risk assessment according to Regulations regarding handling of hazardous substances 14 finds it acceptable for the specific project or system, EN 378 has no limit on refrigerant charge for heat pumps placed in open air or approved machinery room with authorized access. The 400-liter limit is the value where notification to Directorate for Civil Protection (DSB) for flammable gases categories 1 and 2 is required according to Regulations regarding handling of hazardous substances 12. Depending on the refrigerant this amounts to approximately 200 kg. Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 3 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway Regulations regarding handling of hazardous substances 15 requires efficient ventilation. Pressure relief surfaces are also required for potential EX-zones, protecting the building construction and leading potential pressure built up in a safe direction. This restricts where such systems can be located. 3. Refrigerant charge > 400 liters and < 10 000 kg Systems combined or alone containing more than 400 liters, but less than 10 000 kg of flammable gas is not regulated by the Seveso III directive, but it is required to notify DSB according to Regulations regarding handling of hazardous substances 12. Norsk Energi recommends that a quantitative risk assessment (QRA) is considered for such systems and must be conducted by competent personnel. It is possible that risk contours defined in the QRA may trigger land use restrictions, even to neighboring properties. 4. Refrigerant charge > 10 000 kg and < 50 000 kg (lower-tier for Seveso III Directive) The Seveso III Directive lays down rules for the prevention of major accidents which involve dangerous substances, and the limitation of their consequences. It is implemented in the Norwegian legal system by the regulation "Seveso III Directive". Based on the amount of dangerous substances present on a site lower-tier and upper-tier establishments are defined. It is also worth noting that the amount of dangerous substances is summarized across its classifications and systems. For flammable gases, the lower- and upper-tier limits are 10 and 50 tonnes, respectively. This means that a heat pump with flammable refrigerants will be subject to this directive for total charges of 10 tonnes or potentially less, depending on the amounts of flammable materials already on the site. Such systems are obligated to send a report to the DSB according to "Seveso III Directive" 6, but does not have to generate a safety report as described in 9. In Norway, an establishment which is subject to the requirements of this directive will have to apply for consent from the Norwegian Directorate for Civil Protection (DSB) according to Regulations regarding handling of hazardous substances, 17. In this process, several documents need to be produced, including a QRA (Quantitative Risk Assessment) and involvement of the municipality for land-use planning and possible restrictions for surrounding areas. The whole application process may take 3-6 months or even longer depending on the complexity of the establishment. Such systems covered by the Directive 2012/18/EU - Seveso III Directive (see chapter 3.1.1) has according to Act related to fire and explosions 23 and 24 a duty to inform nearby population and an obligation to gather and take into account statements from nearby population, regarding localization and planned emergency preparedness- and safety measures. 5. Refrigerant charge > 50 000 kg (upper-tier for Seveso III Directive) For charge rates of flammable refrigerants above 50 tonnes, the establishment is defined as upper-tier (In Norway: 9 Sikkerhetsrapport i Storulykkeforskriften). The requirements for upper-tier establishments are increased over the lower-tier establishments. Some of the additional requirements are the need to produce a safety report, stricter requirements for information to public as well as more stringent follow-up form the authorities (more frequent inspections). Concluding remarks There are no national or international regulations or standards that directly forbids the use of large amounts of hydrocarbons as a refrigerant for heat pumps in Norway. However, international directives and national acts and regulations set requirements of, and limits where such systems can be located depending on the risk assessment. National regulations requires pressure relief surfaces for building/room classified as EX-zones and requires equipment in general to be safe and in compliance with recognized norm (e.g. EN 378). Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 4 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway For systems below ground the risk of a building collapse may be increased and pressure relief surfaces difficult to place due to the lack of windows and walls to open areas. National regulations require pressure relief surfaces if a room I classified as containing an explosion hazard. However, EN 378 has no specific requirements for pressure relief surfaces to protect the building construction in the event of an explosion. The national requirement for pressure relief surfaces of machinery rooms is therefore not fulfilled by meeting the requirements of EN 378 alone. With increased amount of refrigerant, the responsibility of the district heating company increases, both in terms of requirements from local and national authorities, quality of the risk assessment and a general responsibility to make sure that the plant is safe and does not pose an unacceptable risk to either life, health, environment or material values. For systems with over 10 000 kg of flammable refrigerant a QRA is required, but Norsk Energi recommend considering av QRA also for smaller systems, especially in densely populated areas. The QRA is likely to result in large zones which might limit the land use also for nearby properties. In densely populated areas this limits the suitable locations for such systems. For heat pump applications, refrigerant charge rates of several tonnes of hydrocarbons are not common today. It is therefore unknown to Norsk Energi to which extent relevant standards and regulations have considered such systems. Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 5 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway Content HYDROCARBONS AS REFRIGERANT IN LARGE HEAT PUMPS FOR DISTRICT HEATING IN NORWAY.......................................0 1 INTRODUCTION ...........................................................................................................................................................7 1.1 Background ................................................................................................................................................................7 1.2 Purpose ......................................................................................................................................................................7 1.3 Prerequisites ..............................................................................................................................................................7 1.4 Abbreviations .............................................................................................................................................................8 2 GENERAL INFORMATION ABOUT SELECTED NATURAL REFRIGERANTS ........................................................................8 2.1 Technical data /table..................................................................................................................................................8 2.2 Expected hydrocarbon charge rates for large high temperature heat pumps for district heating applications. ......9 3 RELEVANT LAWS, REGULATIONS, AND STANDARDS....................................................................................................9 3.1 European directives and standards............................................................................................................................9 3.1.1 Directive 2012/18/EU - Seveso III Directive / Storulykkeforskriften ................................................................9 3.1.2 Directive 2014/68/EU - Pressure Equipment Directive (PED) / Forskrift om trykkpkjent utstyr ..................12 3.1.3 Directive 2006/42/EC - Machinery Directive / Forskrift om maskiner ...........................................................12 3.1.4 Directive 99/92/EC - Minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres / Forskrift om helse og sikkerhet i eksplosjonsfarlige atmosfrer .......12 3.1.5 Directive 2014/34/EU - Equipment and protective systems intended for use in potentially explosive atmospheres / Forskrift om utstyr og sikkerhetssystem til bruk i eksplosjonsfarlig omrde ...........................................12 3.1.6 EN 378:2016 Part 1-4 Refrigerating systems and heat pumps - Safety and environmental requirements.....12 3.2 National laws, regulations, and standards in Norway..............................................................................................13 3.2.1 Act relating to the prevention of fire, explosion and accidents involving hazardous substances and the fire service / Brann- og eksplosjonsvernloven ........................................................................................................................13 3.2.2 Act of July 2023 regarding planning and construction case processing / The Plan and Building Act..............14 3.2.3 Regulations of 8 June 2009 relating to the handling of flammable, reactive and pressurized substances including requisite equipment and installations / Forskrift om hndtering av farlig stoff ...............................................14 4 IMPORTANT SAFETY ASPECTS FOR HEAT PUMPS WITH LARGE HYDROCARBON CHARGE RATES IN NORWAY ...........15 4.1 Defined limits of flammable refrigerant charge rates in different laws, regulations and standards.......................16 4.2 Situation 1: Systems not subject to the Seveso III Directive ....................................................................................16 4.2.1 Case 1a: Refrigerant charge rate < 400 liters ..................................................................................................16 4.2.2 Case 1b: Refrigerant charge rate > 400 liter and < 10 000 kg .........................................................................16 4.3 Situation 2: Systems subject to the Seveso III Directive...........................................................................................16 4.3.1 Case 2a: Refrigerant charge rate > 10 000 kg and < 50 000 kg........................................................................17 4.3.2 Case 2b: Refrigerant charge rate > 50 000 kg..................................................................................................17 5 REFERENCES ..............................................................................................................................................................18 Document revision Rev. no 02 01 00 Date Sept 10th, 2023 Aug 28th, 2023 Aug 17th, 2023 Change Performed by Names of Acts and regulations translated to English yvind Nilsen Updated info related to storage below ground as clarified by DSB and emphasis of consequences of explosion below ground. Initial version. Erlend Balstad/Steinar van der Meer Erlend Balstad/Steinar van der Meer Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 6 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway 1 Introduction 1.1 Background Due to environmental challenges regarding synthetic refrigerants and national and international legislations limiting the use of synthetic refrigerants, use of natural refrigerants has become more common in heat pump and refrigeration applications. The current F-gas legislations in the EU limits use of fluorinated greenhouse gases (HFCs) sold in the EU, due to their contribution to global warming. Alternatives to HFCs are HFOs, modern synthetic refrigerants with low global warming potential (GWP). However, the HFOs are known to degrade in the atmosphere. Some common synthetic refrigerants degrades into trifluoracetic acid (TFA), a known polyfluoroalkyl substance (PFAS) and hydrofluoric acid (HF). The long-term environmental and human health effects of TFA and HF are uncertain but linked to environmental- and human health challenges. Due to the uncertain long-term effect and possible detrimental effects on environmental and human health, the European Chemicals Agency (ECHA) has proposed to forbid PFAS chemicals. This is also impacting synthetic refrigerants with low GWP from 2026/2027. 1.2 Purpose Ammonia (R717) and hydrocarbons (HC) are common natural refrigerants. Hydrocarbons have been used as working fluids in heat pump and refrigeration cycles since the early developments in heat pump technology due to their good thermophysical properties. Hydrocarbons have favorable heat transfer properties resulting in efficient heat exchange. Hydrocarbons are considered a promising choice of working fluid for future development in high temperature heat pumps due to their good thermodynamical- and environmental properties, zero ODP and low GWP. Hydrocarbons are however extremely flammable and hence not without challenges regarding safety. Due to their high flammability, use of hydrocarbons in heat pumps are regulated by several national and international laws, regulations, and standards. Such national and international laws, regulations and standards restrict the use of flammable refrigerants for some applications. The purpose of this report is to highlight some of the most important challenges and limitations regarding use of hydrocarbons as refrigerant in large heat pumps, for district heating applications in densely populated areas. 1.3 Prerequisites It is assumed that the reader of this document is familiar with the general and specific content of: EN 378:2016 Part 1-4 Refrigerating systems and heat pumps - Safety and environmental requirements. /13/ National and international laws and regulations regarding heat pumps and use of flammable gasses. For instance, but not limited to: o Act 14 June 2002 relating to the prevention of fire, explosion and accidents involving hazardous substances and the fire service / Brann og eksplosjonsvernloven /1/ (Act related to fire and explosions) o Regulations of 8 June 2009 relating to the handling of flammable, reactive and pressurized substances including requisite equipment and installations / Forskrift om hndtering av farlig stoff /3/ (Regulations regarding handling of hazardous substances) o Directive 2012/18/EU - Seveso III Directive / Storulykkeforskriften /4/ o Directive 2014/68/EU - Pressure Equipment Directive (PED) / Forskrift om trykkpkjent utstyr /5/ o Directive 2006/42/EC - Machinery Directive / Forskrift om maskiner /6/ o Directive 99/92/EC - Minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres / Forskrift om helse og sikkerhet i eksplosjonsfarlige atmosfrer /7/ Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 7 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway o Directive 2014/34/EU - Equipment and protective systems intended for use in potentially explosive atmospheres / Forskrift om utstyr og sikkerhetssystem til bruk i eksplosjonsfarlig omrde /8/ 1.4 Abbreviations DSB - Norwegian Directorate for Civil Protection EEC - European Economic Community EU - European Union GHS - Globally Harmonized System of Classification and Labelling of Chemicals GWP - Global warming potential HC - Hydrocarbon HF - Hydrofluoric acid HFO - Hydrofluoroolefins LFL - Lower flammability limit ODP - Ozone depletion potential PED - Pressure Equipment Directive PFAS- Polyfluoroalkyl substance QRA - Quantitative Risk Assessment TFA - Trifluoracetic acid 2 General information about selected natural refrigerants 2.1 Technical data /table Table 1: Technical data for some common refrigerants. Refrigerant Propane Natural Abbreviation refrigerant Yes R290 ISO 817 Classification /13/ A3 N-Butane Yes R600 A3 Isobutane Yes R600a A3 N-Pentane Yes R601 A3 Iso-pentane Yes R601a A3 Ammonia Yes R717 B2L LFL kg/m /13/ 0,038 0,038 0,043 0,035 0,038 0,116 Flammable (GHS) Extremely Flammable (Category 1) Extremely Flammable (Category 1) Extremely Flammable (Category 1) Extremely Flammable (Category 1) Extremely Flammable (Category 1) Flammable (Category 2) Toxic No No No No No Yes GWP 100 year /12/ 0.02 /12/ PFAS No 0.006 No /12/ 3 /13/ No 5 /13/ No 5 /13/ No 0 /13/ No Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 8 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway 2.2 Expected hydrocarbon charge rates for large high temperature heat pumps for district heating applications. Use of hydrocarbons for large high temperature heat pumps are not common today for district heating applications, but it may become more common in the future due to the transition towards more sustainable and environmentally friendly refrigerants. It is estimated that hydrocarbon based high temperature heat pumps with a heat capacity of 5 to 30 MW could require as much as 2 - 20 tonnes of refrigerant. In these specific cases the estimated refrigerant charge rates are given for; ISO-butane, N-butane, ISO-pentane and N-Pentane only, but it is assumed that the refrigerant charge rates would be comparable for other hydrocarbons. Table 2: Estimated refrigerant charge rates for high temperature heat pumps using butane, R600 and R600a. Heat capacity 5 MW 10 MW 30 MW Inlet / outlet temperature evaporator 6/2C 6/2C 6/2C Inlet / outlet condenser 60/90-100C 60/90-100C 60/90-100C Estimated refrigerant charge rate ISO-butane R600a kg 2,000 - 4,000 5,000 - 7,000 15,000 - 20,000 Estimated refrigerant charge rate N-butane R600 kg 2,000 - 3,000 5,000 - 7,000 15,000 - 20,000 Table 3: Estimated refrigerant charge rates for high temperature heat pumps using pentane, R601 and R601a. Heat capacity 5 MW 10 MW 30 MW Inlet / outlet temperature evaporator 40/30C 40/30C 40/30C Inlet / outlet condenser 90/125C 90/125C 90/125C Estimated refrigerant charge rate ISO-pentane R601a kg 3,000 - 5,000 6,000 - 9,000 15,000 - 20,000 Estimated refrigerant charge rate N-pentane R601 kg 3,000 - 5,000 6,000 - 9,000 15,000 - 20,000 3 Relevant laws, regulations, and standards 3.1 European directives and standards The directives below are legislation that is valid in the entire EU/EEC area and are implemented by the respective member states through their national legislation. The aim for these directives is to have a common set of rules in the Union so that the requirements does not differ between the member states. For the product directives, like the PED and Machinery Directive, the manufacturer of the relevant products has the responsibility to document conformance with these directives and will need to provide a Declaration of Conformity and affix the CE mark before placing on the market or handing over to a customer. 3.1.1 Directive 2012/18/EU - Seveso III Directive / Storulykkeforskriften The Seveso III Directive lays down rules for the prevention of major accidents which involve dangerous substances, and the limitation of their consequences. It is implemented in the Norwegian legal system by the regulation Storulykkeforskriften. Based on the amount of dangerous substances present on a site, with qualifying quantities listed in Annex I, lower-tier and upper-tier establishments are defined. It is also worth noting that the amount of dangerous substances is summarized across its classifications and systems. Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 9 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway For flammable gases, the lower- and upper-tier limits are 10 and 50 tonnes, respectively. This means that a heat pump with flammable refrigerants will be subject to this directive for total charges of 10 tonnes or potentially less, depending on the amounts of flammable materials already on the site. Some of the major requirements of the directive are: In Norway: Apply for consent from the Directorate for Civil Protection (DSB) as described below A notification or safety report to authorities for lower-tier and upper-tier establishments, respectively A major-accident prevention policy Emergency plans Information to the public A safety management system proportionate to the hazards, industrial activities and complexity of the organization, addressing: o organization and personnel -- the roles and responsibilities of personnel involved in the management of major hazards o identification and evaluation of major hazards -- adoption and implementation of procedures for systematically identifying major hazards o operational control -- adoption and implementation of procedures and instructions for safe operation o management of change -- adoption and implementation of procedures for planning modifications o planning for emergencies -- adoption and implementation of procedures to identify foreseeable emergencies o monitoring performance -- adoption and implementation of procedures for the ongoing assessment of compliance o audit and review -- adoption and implementation of procedures for periodic systematic assessment In Norway, an establishment which is subject to the requirements of this directive will have to apply for consent from the Norwegian Directorate for Civil Protection (DSB) according to Regulations regarding handling of hazardous substances, 17 (Section 3.2.3). In this process, several of the below documents need to be produced, including a QRA (Quantitative Risk Assessment) and involvement of the municipality for land-use planning and possible restrictions for surrounding areas. The national authorities have developed detailed guidelines/10/ for how to produce QRAs, and what is considered acceptable risks/11/ for the surrounding environment and the public. Based on these guidelines the authorities may approve or reject plans based on the risk levels identified. The whole application process may take 3-6 months or even longer depending on the complexity of the establishment. The criteria for acceptable risk (individual risk - probability of a fatality) are as follows (Figure 1): Upper level of 10-5 for individual risk to people located outside an establishment handling hazardous substances. The level of individual risk should be further reduced to 10-6 or lower for individuals residing in regular residential areas, and to 10-7 or lower for particularly vulnerable segments of the population. Lower level of 10-8 for accidents (negligible risk for isolated, identified accident events). Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 10 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway Outer zone Risk contour 1 x 107 Risk contour 1 x 106 Inner zone Risk contour 1 x 10 Figure 1: Illustration of the zones requiring special consideration around an establishment with the depiction of risk contours that delimit the zones /11/. Based on these criteria, 3 zones shall be defined for land-use planning: inner zone, middle zone and outer zone as depicted in Table 4. Consideration Consideration zones for Provisions for the consideration zones (objects and activities zones hazardous substance facilities accepted in the zone) Inner zone Up to risk contour (probability This is primarily the facility's own area. Additionally, areas of a fatality higher than) 10-5 such as agricultural and forestry areas can be included in the inner zone. Only brief passing by third parties (such as hiking trails, etc.). Middle zone From risk contour 10-5 to 10-6 Public roads, railways, docks, and similar areas. Permanent workplaces within industrial and office activities can also be located here. There should be no overnight stays or residences in this zone. Scattered residential development may be accepted in specific cases. Outer zone From risk contour 10-6 to 10-7 Areas designated for residential and other general population use can be included in the outer zone, including shops and small accommodations. Outside outer Outside the outer zone there Schools, kindergartens, nursing homes, hospitals, and zone are no special considerations. similar institutions, shopping centers, hotels, or large public venues must be located outside the outer zone. Table 4: The consideration zones for hazardous substance facilities /11/. Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 11 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway 3.1.2 Directive 2014/68/EU - Pressure Equipment Directive (PED) / Forskrift om trykkpkjent utstyr This directive applies to equipment with risks related to pressure, and the responsibility of compliance lies on the manufacturer of the pressure equipment and assemblies. The risk categories will increase with increasing charge rates and heat pumps with a charge rate of flammable refrigerants in the order of around 100 kg (depending on the specific refrigerant and design pressure) will end up in the highest category. For charges above this threshold the requirements are generally the same. 3.1.3 Directive 2006/42/EC - Machinery Directive / Forskrift om maskiner This directive applies to equipment with machinery risks, and the responsibility of compliance lies on the manufacturer of the machinery. All heat pumps will need to comply with this directive regardless of the refrigerant charge and should not impose significant challenges in this regard. 3.1.4 Directive 99/92/EC - Minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres / Forskrift om helse og sikkerhet i eksplosjonsfarlige atmosfrer This directive applies to areas where explosive atmospheres may exist, and the responsibility of compliance lies on the establishment where the explosive atmospheres exist. If explosive atmospheres may exist, an explosion protection document shall be produces and EX-zones shall be defined. Within EX-zones, measures shall be implemented to avoid ignition of explosive atmospheres. 3.1.5 Directive 2014/34/EU - Equipment and protective systems intended for use in potentially explosive atmospheres / Forskrift om utstyr og sikkerhetssystem til bruk i eksplosjonsfarlig omrde This directive applies to equipment for use in potentially explosive atmospheres, and the responsibility of compliance lies on the manufacturer of the machinery. Parts of heat pumps may need to comply with this directive if explosive atmospheres are present and EX-zones are defined according to Directive 99/92/EC. 3.1.6 EN 378:2016 Part 1-4 Refrigerating systems and heat pumps - Safety and environmental requirements EN 378:2016 /13/ /13/is a European standard which specifies safety and environmental requirements for refrigerating systems and heat pumps, including but not limited to requirements of the machine (heat pump unit), machinery room, ventilation, service, maintenance, and reuse. Part 2 of the standard is harmonized with the Pressure Equipment Directive and the Machinery Directive, giving presumption of conformity with essential safety requirements of these directives when the respective parts of the standards are satisfied. EN 378:2016 Part 1, Basic requirements, definitions, classification, and selection criteria, o Determines the refrigerant charge rate limit based on the location of the heat pump and access category. Which for heat pumps with A3 refrigerants in location category III (Outdoor or in approved machinery room) is 5 kg, 10 kg, or unlimited, dependent of access category a (General access), b (supervised access) or c (Authorized access). The heat pump unit shall meet the requirements in EN 378 Part 2 and the location of the heat pump shall meet the requirements of EN 378 Part 3. EN 378 Part 2, Determines requirements for design, construction, testing and documentation. o In particular section 6.2.14 Protection against fire- and explosions is applicable to heat pumps with hydrocarbon refrigerants. Potential EX-zones and extents of zones shall be determined according to EN 60079-10-1: "Explosive atmospheres - Part 10-1: Classification of areas Explosive gas atmospheres" /14/. Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 12 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway EN 378 Part 3, Determines requirement for installation site and personal protection. o In general a machinery room for refrigeration equipment shall meet the requirements of section 5.1-5.14. A risk assessment shall also be performed, and determines if the heat pump needs to be placed in a separate machinery room. A gas detector shall be installed in each machinery room. For systems below ground using A3 refrigerants with a refrigerant charge larger than 26 x LFL (app. 1 kg propane) it shall be used an extra gas detector. o Section 5.1 to 5.13 specifies requirements for access, ventilation, combustion equipment, use of open flame, Lighting and building construction of the machinery room. Including fire resistance of walls, door, openings. o 5.14 Determines specific requirements of machinery rooms for A2L, A2, A3, B2L, B2 and B3 refrigerants. 5.14 is therefore applicable for both ammonia and hydrocarbon refrigerants. 5.14 Also specifies additional requirements for R717 (Ammonia). o The standard has no specific requirements for pressure relief surfaces and tolerated maximum over pressure to protect the building construction in the event of an explosion. EN 378 Part 4, Determines requirements for; Operation, maintenance, repair and recovery. o Annex E gives informative guidelines for repairs of equipment using flammable refrigerants. EN 378 sets few additional requirements for machinery rooms with hydrocarbon refrigerants compared to refrigerants in general. The most important additional requirements set by the standard are; more strict limit of refrigerant charge, more comprehensive ventilation system and requires that potential hazardous sones shall be classified according to EN 60079-10-1. A refrigerant leakage would for a highly flammable refrigerant result in a larger and more hazardous sone according to EN 60079-10-1 due to a low LFL. Use of hydrocarbons as refrigerants therefore requires a more comprehensive ventilation system and measures to eliminate potential sources of ignition. This includes avoiding open flame, hot surfaces and mechanical or electrical components which could create sparks. The classification of the according to EN 60079-10-1 machinery room is likely to conclude that equipment in parts of- or the machinery room as a whole need to be rated for use in explosive gas atmospheres. The standard has several specific sections for ammonia (R717), but in comparison few specific sections regarding hydrocarbons. The current version of EN 378 is from 2016 and under revision. It is unknown to Norsk Energi to which extent the current version of EN 378 have considered heat pumps with several tones of hydrocarbons, due to such systems not being frequently considered until recently. It is assumed that it is not unlikely that future versions of EN 378 could have more specific requirements for use large quantities of flammable refrigerant, due to the development of high temperature heat pumps with large quantities of hydrocarbon charge rates. It is also worth mentioning that section 5.14.2.1 states that "The machinery room shall be located in accordance with local and national regulations. And that "Requirements may depend on the amount of charge of the refrigeration system". 3.2 National laws, regulations, and standards in Norway 3.2.1 Act relating to the prevention of fire, explosion and accidents involving hazardous substances and the fire service / Brann- og eksplosjonsvernloven Act related to fire and explosions /1/ is applicable for use of flammable refrigerants in heat pump installations in Norway. The act ( 13) specifies that the municipality shall perform inspections of enterprises where fire could result in loss of several lives or extensive damages to human health, environment, or material values. According to 20 the enterprise has a duty to make sure that hazardous substances are handled in way the ensure safety of humans, environment and surroundings. Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 13 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway According to 20, the risk shall be reduced through technical and or organizational measures and reduced to a reasonable level. The measures might include area restrictions set according to the act of July 2023 regarding planning and construction case processing (3.2.2). The cost of such measures should be covered by the enterprise. 21 - specifies the enterprise's emergency preparedness duty 23 - enterprises covered by the Directive 2012/18/EU - Seveso III Directive (section 3.1.1) duty to inform nearby population. 24 - enterprises covered by the Directive 2012/18/EU - Seveso III Directive obligation to gather and take into account statements from nearby population regarding localization and planned emergency preparedness- and safety measures. 3.2.2 Act of July 2023 regarding planning and construction case processing / The Plan and Building Act The Plan and Building Act/2/ regulates area- and construction planning in Norway. As stated in 30-2 the municipality has the right to forbid or set specific requirements for enterprises in connection to residential areas which could impose a hazard or particular disadvantage. Large risk contour sones from the QRA could be considered to impose a particular disadvantage. This includes requirements for location of buildings and enterprises. 20-6, Measures sufficiently covered by another act are except from the obligation to apply to the Ministry of Local Government and Regional Development. Which measures are exempt from the duty to apply and to which extent, is decided by the Ministry of Local Government and Regional Development. 3.2.3 Regulations of 8 June 2009 relating to the handling of flammable, reactive and pressurized substances including requisite equipment and installations / Forskrift om hndtering av farlig stoff Regulations regarding handling of hazardous substances/3/ applies for use of flammable and toxic substances as refrigerants in Norway. Anyone handling hazardous substances is responsible for the requirements of the regulation being fulfilled. Some important paragraphs in the regulation applicable to heat pumps is summarized below: 5 - Determines that "Flammable gas Categories 1 and 2 must not be stored in a basement or other room below ground or in an attic". It is however clarified by DSB /16/ that heat pumps below ground are considered acceptable when they are designed according to EN 378 (it should be noted that the letter indicates that the pressure relief surface requirements from the standard is deemed acceptable, but the standard does not cover pressure relief requirements of the building construction). 8 - Determines that "Anyone designing, constructing, manufacturing, installing, altering, repairing, maintaining or inspecting equipment and installations must ensure their work is carried out with skilled workmanship and in accordance with recognized norms in order to attain sufficient safety under all foreseeable operating conditions". 9 - "The owner and user must make sure equipment and installations are subject to systematic inspections to ensure they are in a satisfactory technical condition." "The systematic inspection of the state of equipment and installations must be conducted by an independent inspector if the enterprise requires consent pursuant to Section 17, or the equipment and installations represent a high potential risk". 12 - "Anyone storing hazardous substances in an installation or transporting hazardous substances in a pipeline in a quantity equal to or greater than the quantities stipulated in Appendix 2, must notify the Directorate for Civil Protection and Emergency Planning" (DSB). For flammable refrigerants, the quantity stipulated in Appendix 2 is 400 liters. Depending on the refrigerant this amounts to approximately 200 kg. Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 14 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway 14 - Risk assessment. "The owner or user of equipment and installations employed in the handling of hazardous substances and enterprises that handle hazardous substances must ensure that the risk is reduced to a level that can reasonably be achieved." "The enterprise must survey hazards and problems relating to the handling of hazardous substances and assess the risk on the basis of this. The assessment must include company-internal as well as external issues as well as malicious attacks." 15 Describes mandatory preventive measures and technical solutions. Some of the mandatory requirements for using flammable refrigerants are: o "a) A building where hazardous substances are handled must have efficient ventilation that safeguards against fires, explosions, and other accidents. " o "b) A building or room that is classified as containing an explosion hazard must have one or several safety panels that is weaker than the rest of the construction, and which will act as pressure relief if an explosion were to occur in the building. The relieved pressure must be led away in a safe direction. " o "g) Systems for process safety, emergency shutdown and emergency power, adapted to the complexity of the activity, must be installed if this is necessary to prevent abnormal conditions from developing into hazard situations. " 16 Land use limitations Land use limitations must be established around equipment and installations where this is necessary according to 14 to safeguard the adjacent area in a satisfactory manner. 17 Consent from DSB. "Enterprises covered by the Regulations of June 3rd 2016 relating to measures to prevent and limit the consequences of major accidents involving hazardous chemicals (the Major-Accident Hazards Regulations "..." must obtain consent from the Directorate for Civil Protection and Emergency Planning in reasonable time before the handling of hazardous substances is commenced. If a new installation is being built as mentioned in Subsection 1, consent must be obtained in reasonable time before the construction is commenced." For hydrocarbons and ammonia as refrigerant this impacts operations with more than 10 000 kg or 50 000 kg refrigerant charge rates respectively. 19 Emergency preparedness obligations "Enterprises that handle hazardous substances must prepare an emergency response plan and establish a sufficient internal preparedness and response organization, with plans for alarms and emergency duties. The emergency plan must be updated regularly and describe roles and responsibilities and the distribution of resources during the response to accidents and other undesirable incidents. The emergency response plan must include instructions for raising the alarm, escape, rescue and firefighting. Enterprises with a duty to notify the Directorate according to Section 12 must coordinate their emergency response plan with public emergency response plans, so that cooperation can be established with the relevant local authorities." 4 Important safety aspects for heat pumps with large hydrocarbon charge rates in Norway The risks involving the use of heat pumps with flammable refrigerant are primarily related to the risk of leakage of the refrigerants and subsequently ignition with the consequence of explosion and/or fire. An explosion may lead to loss of life, collapse or critical damage to buildings as well as financial loss. For systems below ground the risk of a building collapse may be increased and pressure relief surfaces difficult to place due to the lack of windows and walls to open areas. Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 15 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway Common for all the cases below is the need to perform a risk assessment and identifying and implementing mitigating measures to keep the risk within acceptable limits. In general, the risk will increase with increasing amounts of flammable material and inversely with the distance to populated areas but is also highly dependent on each establishments design as well as the mitigating measures. 4.1 Defined limits of flammable refrigerant charge rates in different laws, regulations and standards Refrigerant Propane N-Butane Isobutane N-Pentane Isopentane Ammonia NS-EN 378: 1-4 Machinery room No limitation* No limitation* No limitation* No limitation* No limitation* NS-EN 378: 1-4 Ventilated enclosure 4,94 kg (130 * LFL) 4,94 kg 5,59 kg 4,55 kg 4,94 kg Obligated to notify DSB 400 liter 400 liter 400 liter 400 liter 400 liter Seveso III Directive Lower tier limit 10 000 kg 10 000 kg 10 000 kg 10 000 kg 10 000 kg No limitation* 15,08 kg 400 liter 50 000 kg *Refrigerant charge rate might be limited as a result of the risk assessment Seveso III Directive Upper tier limit 50 000 kg 50 000 kg 50 000 kg 50 000 kg 50 000 kg 200 000 kg 4.2 Situation 1: Systems not subject to the Seveso III Directive For cases where the total charges of flammable refrigerants are less than 10 tonnes (including flammable substances already on the site), the risks are primarily regulated by the national legislation Regulations regarding handling of hazardous substances. Central in this regulation is the risk assessment mandated by 14. The requirements for the risk assessment are not very detailed, but there are some guidance material that can be used. It is suggested to use the process from the Norwegian standard NS 5814:2021 - Krav til risikovurderinger /15/. 4.2.1 Case 1a: Refrigerant charge rate < 400 liters The limit for notification to DSB ( 12 in Regulations regarding handling of hazardous substances) is 400 liters for flammable gases, categories 1 and 2, and depending on the refrigerant this amounts to approximately 200 kg. For heat pumps with charges below this limit, there no requirement for notification, but there is still a need to do a risk assessment. 4.2.2 Case 1b: Refrigerant charge rate > 400 liter and < 10 000 kg For these installations a notification to DSB is needed. While the regulations do not specifically require to produce a QRA for establishments not subject to the Seveso III directive, Norsk Energi recommends that this approach is considered for such heat pump installations with flammable refrigerants. This is the most accurate process to determine if the risk is acceptable for the surroundings in a format that the authorities are familiar with. 4.3 Situation 2: Systems subject to the Seveso III Directive For cases where the total charges of flammable refrigerants are more than 10 tonnes (including flammable substances already on the site), the system is both regulated by the national legislation Regulations regarding handling of hazardous substances, and the Seveso III directive. Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 16 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway 4.3.1 Case 2a: Refrigerant charge rate > 10 000 kg and < 50 000 kg For charge rates of flammable refrigerants category 1 or 2 between 10 and 50 tonnes, the establishment is defined as lower-tier (In Norway: 6 Melding i Storulykkeforskriften). This means that an application for consent to DSB is needed as well as satisfying the requirements for lower-tier establishments, including a QRA. 4.3.2 Case 2b: Refrigerant charge rate > 50 000 kg For charge rates of flammable refrigerants category 1 or 2 above 50 tonnes, the establishment is defined as upper-tier (In Norway: 9 Sikkerhetsrapport i Storulykkeforskriften). The requirements for upper-tier establishments are increased over the lower-tier establishments. Some of the additional requirements are the need to produce a safety report, stricter requirements for information to public as well as more stringent followup form the authorities (more frequent inspections). Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 17 of 18 Client: Title: Hafslund Oslo Celsio AS Hydrocarbons as refrigerant in large heat pumps for district heating in Norway 5 References /1/ Lov 14. juni 2002 om vern mot brann, eksplosjon og ulykker med farlig stoff og om brannvesenets redningsoppgaver (brann- og eksplosjonsvernloven) (Act related to fire and explosion) /2/ Lov 27. juni 2008 om planlegging og byggesaksbehandling (plan- og bygningsloven) (The Plan and Building Act) /3/ Forskrift 8. juni 2009 om hndtering av brannfarlig, reaksjonsfarlig og trykksatt stoff samt utstyr og anlegg som benyttes ved hndteringen (forskrift om hndtering av farlig stoff) (Regulations regarding handling of hazardous substances) /4/ Forskrift 3. juni 2016 om tiltak for forebygge og begrense konsekvensene av storulykker i virksomheter der farlige kjemikalier forekommer (storulykkeforskriften) Directive 2012/18/EU - Seveso III Directive /5/ Forskrift 10. oktober 2017 om trykkpkjent utstyr Directive 2014/68/EU - Pressure Equipment Directive (PED) /6/ Forskrift 20. mai 2009 om maskiner (maskinforskriften) Directive 2006/42/EC - Machinery Directive /7/ Forskrift om helse og sikkerhet i eksplosjonsfarlige atmosfrer Directive 99/92/EC - Minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres /8/ Forskrift 29. november 2017 om utstyr og sikkerhetssystem til bruk i eksplosjonsfarlig omrde Regulation of November 29th 2017, regarding the use of equipment and safety systems in explosive areas /9/ Forskrift 19. Juni 2017 om tekniske krav til byggverk (Byggteknisk forskrift) Building Acts and Regulations /10/ Retningslinjer for kvantitative risikovurderinger for anlegg som hndterer farlig stoff, DSB 2021 Guidlines for quantitative risk assessments for facilities that handle hazardous substances /11/ Sikkerheten rundt anlegg som hndterer brannfarlige, reaksjonsfarlige, trykksatte og eksplosjonsfarlige stoffer - Kriterier for akseptabel risiko, DSB 2012 (Norwegian only) Safety near facilities that handle substances that are flammable, reactive, pressurised and explosive - Criteria for acceptable risk /12/ Climate Change 2021: The Physical Science Basis | Climate Change 2021: The Physical Science Basis (ipcc.ch) IPCC, 2021: Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change[Masson-Delmotte, V., P. Zhai, A. Pirani, S.L. Connors, C. Pan, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M.I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T.K. Maycock, T. Waterfield, O. Yeleki, R. Yu, and B. Zhou (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, In press, doi:10.1017/9781009157896. /13/ NS-EN 378-serien for kuldeanlegg og varmepumper (standard.no), Standard Norge 2016 Refrigerating systems and heat pumps - Safety and environmental requirements. /14/ NEK EN IEC 60079-10-1:2021 (standard.no), Standard Norge 2021, Explosive atmospheres - Part 10-1: Classification of areas - Explosive gas atmospheres /15/ NS 5814:2021 - Krav til risikovurderinger (standard.no) /16/ Avklaring om bruk av brannfarlige kuldemedier under terreng, letter from DSB related to flammable refrigerants under ground, ref. 2018/6799/SVBE, Sep 12th 2018 Efficient, environmentally friendly and safe utilization of energy Dok ID: 36807-13, rev. 2 Date: 10.09.2023 Page 18 of 18