HSE and the New Energy Industries

Health & Safety ExecutiveThose who create risks are responsible for managing them.

HSE is an independent regulator working in partnership to enable the safe introduction and expansion of new energy industries. Building on the work HSE has already made to the Government Energy review in 2006, HSE is examining the most effective way it can enable and support the introduction of emerging energy technologies. This includes helping operators understand and control the potential associated risks that might be created during installation and operation. The original work identified six parts to the new energy agenda including:
  1. Natural Gas Storage: replacing occurring reserves with imported gas stored in natural strata or purpose designed and constructed underground facilities. Also the importation, storage and regassification of LNG.
  2. Carbon Capture and Storage: removing carbon from the power generation process in the form of carbon dioxide and transporting it in its dense (liquid) phase to be stored permanently in deep geological strata.
  3. Renewable Energy: the range of renewable energy resources including biofuels, wave and tidal, and wind generation (on and offshore).
  4. Distributed Generation: increasing power generation close to the end user, including the development and proliferation of hydrogen cells
  5. Cleaner Coal Technology: the refinement and development of mature cleaner coal combustion techniques and energy abstraction from coal seams without mining.
  6. New Nuclear Power Stations: For more details of HSE’s New Nuclear Programme see webpage http://www.hse.gov.uk/newreactors/index.htm
The law requires that those that create risks manage those risks. This means that first and foremost, operators must satisfy themselves that their activities do not pose a risk to workers and the public. HSE's new Emerging Energy Technologies Programme will address the first five new energy technologies. This is an important emerging regulatory and policy area because of the novelty, scale and diversity of the hazards presented by the energy programme and gaps in regulatory application. The main agenda is being driven forward by DECC. HSE, together with the Environment Agency and SEPA, have an active partnership with DECC to achieve their aim of responsible regulation of the emerging energy sectors.

HSE has started to introduce major policy or regulatory change as it identifies the hazards and risks associated with new technologies.

Natural Gas Storage

The COMAH Competent Authority (comprising the Health and Safety Executive, Environment Agency and the Scottish Environmental Protection Agency) has recently concluded that the on-shore storage of natural gas in underground natural strata, such as depleted reservoirs, is subject to the Control of Major Accident Hazards Regulations (COMAH).The decision follows an announcement by the European Commission in October 2008 that it expects Member States to apply the Seveso II Directive to such storage sites to ensure that equivalent regulatory requirements apply across the European Union. Underground storage sites will come within the scope of COMAH if the quantity of natural gas stored meets or exceeds the thresholds in the Regulations i.e. 50 tonnes (lower tier) and 200 tonnes (top tier). In practice, all sites are likely to be top tier sites.
Previous research had indicated that the hazards and risks from on-shore storage in natural strata and purpose built facilities ie salt cavities were similar. The decision means that the same regulatory regime applies to storage in man-made (salt) caverns and natural strata. HSE has already contacted relevant industry groups and is contacting sites affected by this decision and has developed guidance for dutyholders on the application of COMAH to these sites.
The Offshore Installations (Safety Case) Regulations were introduced following the Piper Alpha disaster and have played a key role in ensuring safety for those who work offshore. However this legislation only applies to the extraction of oil and gas but not to storage alone. In late 2009 HSE will consult on changes to this legislation which will ensure that this regime covers both extraction and storage offshore, ensuring effective regulation to enable the safe development and operation of new offshore gas storage facilities.

Carbon Capture and Storage

Initial research by HSE has indicated that carbon dioxide in large volumes has the potential to create a major accident. HSE is involved in research with others to better understand the hazards and risks, particularly when carbon dioxide in its dense phase is being transported or stored.

HSE is working closely with DECC and operators in the recently announced pilots to enable the safe introduction of this new technology. A public consultation on proposed amendments to the Pipelines Safety Regulations, including carbon dioxide for Carbon Capture and Storage, will be launched in the autumn 2009.

Renewable Energy – Biomethane

HSE is working with DECC on the development of good practice guidance for the introduction and use of this technology. It is also working with operators who are piloting this emerging technology.

The Gas Safety (Management) Regulations ensure the safe operation and distribution of the UK’s gas supply, protecting both public and workers. In addition this legislation also ensures the quality of the UK’s gas supply ensuring that industrial and domestic equipment operates safely and reliably. HSE in partnership with DECC is considering whether certain statutory requirements for the quality of gas in the grid - concerning oxygen and hydrogen content - might be adjusted in order to help biomethane injection.

The new energy industry and associated technologies create new risks and introduce known risks but in different forms. The law requires that those that create the risks manage those risks. This means that first and foremost, operators must satisfy themselves that their activities do not pose a risk to workers or those affected by them. The operators should identify potential safety threats and implement systems to manage these. HSE is actively engaging with relevant stakeholders to further increase awareness of the key principles that guide safety from work related activities, as well as ensuring they have an opportunity to input into the development of a framework which proportionately regulates these activities.

Moira Wilson,
Health & Safety Executive,
HID S13, Gas & Pipelines,
Redgrave Court,
Merton Road,
Bootle,
Merseyside,
L20 7HS.

www.hse.gov.uk/gas
www.hse.gov.uk/pipelines