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Regulations, Codes, and Standards Review for Underground Hydrogen Storage

Louie, Melissa S.; Ehrhart, Brian D.

Hydrogen continues to show promise as a viable contributor to achieving energy storage goals such as energy security and decarbonization in the United States. However, many new and expanded hydrogen use applications will require identifying methods of larger-scale storage than the solutions that currently exist for smaller storage applications. One possibility is to store large quantities of gaseous hydrogen below ground level. Underground storage of other fuels such as natural gas is already currently utilized, so much of the infrastructure and basic technologies can be used as a basis for underground hydrogen storage (UHS). A few commercial UHS facilities currently exist in the United States, including salt caverns owned and operated by Air Liquide, Linde, and Conoco Philips, but UHS is still a relatively new concept that has not been widely deployed. It is necessary to understand the safety risks and hazards associated with UHS before its use can be expanded and accepted more broadly. Many of these risks are addressed through regulations, codes, and standards (RCS) issued by governing bodies and organizations with expertise in certain hazards. This report is a review of RCS documents relevant to UHS, with a particular lens on potential technical gaps in existing guidance. These gaps may be specific to the physical properties of hydrogen or due to the different technologies relevant for hydrogen vs. natural gas storage. This is meant to be a high-level review to identify relevant documents and potential gaps. Formally addressing the individual gaps identified here within the codes and standards themselves would involve a more intensive analysis and differ based on the code or standard revision processes of the various publishing organizations. Therefore, presenting specific recommendations for revising the verbiage of the documents for UHS applications is left for future work and other publications.