In 2011, Mazzetti-Perkins+Will was one of two winners of the Kaiser Permanente “Small Hospital, Big Idea” Competition (SHBI, for short). One of Kaiser’s goals going into the project was a “near-zero impact on the environment.”
A key element of our design was the combination of energy systems, focused around a set of fuel cells using waste gas from a landfill. The idea behind the design was to eliminate the diesel generators that are currently used for emergency power, and to use instead the unique modular design of fuel cells so that they could power both normal and emergency operations. In addition to using a renewable fuel, as defined by the state of California, emissions from fuel cells are considerably less than emissions from even the best diesel generators. The problem was, codes in effect at the time, and, arguably today, don’t seem to allow this design.
One of the things our SHBI entry included was a regulatory strategy. Much of what was in that design could not be built under then-current regulations. A key element of that strategy was to do the work to change the codes to make this design real.
Kaiser never proceeded with the promised design and construction of this hospital, but we have continued to patiently pursue the modernizing of relevant healthcare codes so as to allow the healthcare industry access to this important technology.
And now, all of a sudden, with all of the attention turning to micro-grids, our idea is suddenly starting to get attention.
We are hearing from a number of our clients and others that they are interested in pursuing the use of fuel cells as emergency sources, and that they are being prevented by the regulatory community.
So, if a healthcare facility wanted to substitute fuel cells for diesel generators, is there a regulatory path NOW to make it happen?
It is important to know that fuel cells are constructed differently and operate differently from diesel generators. So, such a replacement is not a simple one for one change. Fuel cells, first, can’t start up and assume loads as fast as diesel generators can. So, a design with fuel cells would mean they would need to be operating in both normal and emergency states. Many fuel cells generate both heat and electricity. For these units, in an emergency, there would need to be ways to use both. Most fuel cells currently run only on natural gas, and so, on-site fuel storage will be an issue for disaster resilience.
In 2015, NFPA 99 addressed all of these concerns, and was the first national model code to embrace the use of fuel cells as an emergency source for healthcare facilities:
“220.127.116.11.7 Fuel Cell Systems. Fuel cell systems shall be permitted to serve as the alternate source for all or part of an essential electrical system, provided the following conditions apply:
18.104.22.168.7.1 Installation shall comply with NFPA 853, Standard for Installation of Stationary Fuel Cell Power Systems.
22.214.171.124.7.2 N+1 units shall be provided where N units have sufficient capacity to supply the demand load of the portion of the system served.
126.96.36.199.7.3* System shall be able to assume loads within 10 seconds of loss of normal power source.
188.8.131.52.7.4 System shall have a continuing source of fuel supply, together with sufficient on-site fuel storage for the essential system type.
184.108.40.206.7.5 A connection shall be provided for a portable diesel generator to supply life safety and critical portions of the distribution system (if present).”
These requirements are considerably more stringent than similar requirements in other NFPA documents but are reasonable safeguards for deploying this technology.
NFPA intends for 99 to be the document that calls out performance needed for all systems for healthcare. The National Electrical Code, NFPA 70, then, is intended to follow 99, and to detail the technical requirements for achieving these performance needs.
NFPA 70, referring back to NFPA 99, requires that emergency loads in a health facility have a normal and an alternate source of power, where the alternate source of power is:
“(1) Generator(s) driven by some form of prime mover(s) and located on the premises
(2) Another generating unit(s) where the normal source consists of a generating unit(s) located on the premises
(3) An external utility service when the normal source consists of a generating unit(s) located on the premises
(4) A battery system located on the premises.”
Then, Articles 700 and 701 go on to detail some of the more specific requirements for these generators.
Article 700 in the NEC covers “Emergency Systems.” This article (700.12(E)) allows the use of Fuel Cells for these systems so long as it is not “a single fuel cell system.” So, the redundancy requirements of NFPA 99 are met. Further, Article 701, “Legally Required Standby Systems” covers other emergency loads, and it, too, allows the use of fuel cells (701.12(F)) under the same conditions.
The other relevant NFPA regulation is NFPA 110. This document is a standard for Emergency Power systems. It is widely recognized as a standard but not codified in many jurisdictions. Nonetheless, it requires energy converters to be “rotating equipment […] consist[ing] of a generator driven by one of the following prime mover types: (1) Otto cycle (spark ignited) (2) Diesel cycle (3) Gas turbine cycle.” To date, 110 has not kept up with NFPA 99, 70 and emerging practice in explicitly allowing fuel cells. However, 110 does provide (220.127.116.11) that “other types of prime movers and their associated equipment meeting the applicable performance requirements of this standard shall be permitted, if acceptable to the authority having jurisdiction.” That is, locations following NFPA 70 and 99 will comply even with the current versions of NFPA 110. We have recently submitted proposals to the 110 committee to bring that standard into agreement with 99 and 70, but this action is pending.
When Kaiser started its SHBI competition, it intended to change the way hospitals were conceived, planned, and developed. In at least this one aspect, we are on a path to helping make that vision real.