Part 1: Hydrogen, Apophenia and Apoplexy

The Department of Business, Energy & Industrial Strategy (BEIS) tasked engineering consultants ARUP+ with conducting a Quantitative Risk Assessment (QRA), to assess the viability of safe domestic hydrogen. In the words of the resulting report the purpose of the safety assessment was to:  

"...

− Determine if the safety risks of conveying hydrogen inside residential and commercial buildings can be minimised such that they are no greater than the accepted risk level associated with the current use of natural gas

− Identify any associated safety mitigation and risk reduction measures to control and manage the safety risk of conveying hydrogen to the accepted level

− Enable a safety annex to be produced to support the Safety Case submission required by the Gas Distribution Network Operator (GDNO) for any proposed community trial

− Provide the evidence to support wider commercial/business and/or policy decision-making around widespread conversion of the natural gas network to hydrogen.

..."

Safety Assessment Conclusions Report incorporating Quantitative Risk Assessment, Hy4Heat Workpack 7, ARUP+

Discrediting a QRA

I became aware of the QRA report when I saw that people were being vilified in comments to a post; one for supporting the QRA and the other for simply being a known advocate of hydrogen applications. I couldn’t abide that, said as much, and a number of threads unravelled. 

I am not going to rehearse those conversations in any detail here, but as a result of those exchanges, I read QRA and related materials. This put me in possession of the facts. Soon it became obvious that the safety assessment was being misrepresented and, across a number of subsequent posts, the majority of comments were substantially wrong.  

I then set about defending the thrust of the document against hopelessly misguided and often overwrought comments. It wasn’t just a matter of differing opinion on the merits, but a collective apophenia, making connections that don’t exist whilst being unwilling, or perhaps unable, to read or see what is actually there. 

There was a clamour for transparency and groundless insinuations were made that the study was somehow ethically compromised. Yet despite the QRA document being in the public domain, those who were making various demands and non-specific accusations, refused to look at it.  

Certainly, some downloaded it and as evidenced by some of the conversations, had performed perfunctory keyword searches, but when I attempted to engage them on the detail, it was obvious that they did not understand the context or the broader case. Although there was little sign that any of my correspondents had actually read the document, this did not stop them imagining how appalled they would be, if only they had.  

Some were dismissive, for example by claiming the 144 paged document was ‘flimsy’, without bothering to be sufficiently acquainted with the content to elaborate.  Another individual repeatedly made oblique references to ‘page 80’, seemingly hoping that someone who understood his point better than him, might be triggered to run with it.  

One person was particularly indignant that hydrogen trials had been ‘conducted in people's homes’ for the QRA and, if I remember correctly, the fact this wasn’t true didn’t stop the comment being ‘liked’ by other non-readers. I was curious to see where this came from and it didn’t take me long to find that he had misread page 2, which I suppose, having got that far was a distinction of a sort. 

I felt obliged to make numerous corrections of the most basic type, about what people claimed was in the document, as well as what was supposedly left out. I wasn’t shocked at the lack of comprehension, because after all, the conversation had been taken over by tribalism. What did surprise me was that no matter how simply put, the capacity to understand the issues just wasn’t there, it was if there was a cognitive blockage keeping these individuals closed off from reason.

So in the end no amount of explanation mattered, because the dominant objection was not about any conclusion the report might have drawn, but the fact that the assessment had been conducted at all. 

Mostly, they preferred to assume that evidence for the safe use of hydrogen in homes, simply could not exist. From that perspective, anything to the contrary had to be wrong, and anybody saying anything positive about hydrogen safety, were somehow foolish, conflicted or both.

Safety Equivalence

What people seemed to be most upset about, was the report’s claim that hydrogen could be made as safe as natural gas (which is 70-90% methane), albeit with some additional mitigations. The response to this might be characterised as,

‘Aha! So you need additional mitigations to make it as safe!’ Ergo ‘it’s less safe’. 

This is not true. Don’t misunderstand me, of course I can see why it seems to makes sense, it’s just that I also know why it doesn’t. To appreciate that we need to be equipped with some basics about risk.

Risk

Risk is a two-dimensional concept with components of severity and likelihood. In practice, this may mean that two events can be considered to have equivalent risk, even when have different impacts and probabilities. For example, an unlikely event with moderate impact might have the same risk rating as a likely event, with negligible impact. This is an important concept because for risks to be comparable there has to be a certain fungibility.

The concept of ALARP (As Low As Reasonably Practicable) is a way of understanding the cost-benefit of a mitigation. We all tolerate some risk in order to live our lives but for groups and populations a formal approach to risk is needed. We do not have the ability or resources to eliminate all risk so the ALARP principle brings focus to those that are most significant.

Drivers

The main driver for the ARUP+ QRA report, is to determine the safety of hydrogen in the domestic environment, insofar as it relates to flammability. This is quite correct but it is important to keep the bigger context in mind. The energy-transition encompasses the displacement of carbon based fuels with cleaner alternatives which is both a risk mitigation and net-benefit. 

The major motivation for transitioning from natural gas to hydrogen i.e., to eliminate carbon content as a mitigation for climate risk, is necessarily beyond the scope of the report. Yet at some point everything we understand about domestic risks must be put in the global context.

The costs are unavoidable we just get to choose whether they will be for mitigations or the failure to mitigate. Assuming existential threats are unacceptable to us, the cost of mitigation must be balanced against the benefits of the energy transition. Only then can we come close to understanding the cost-benefit.  

Can domestic hydrogen ever be at ALARP levels of risk? Maybe, maybe not, but we must remember that it is a standard that domestic natural gas has never come close to achieving.  

Next - Part 2: Hydrogen, Agendas and Anxiety

Department for Business, Energy and Industrial Strategy (BEIS),  Mark Neller, Dr Angela Needle FEI, Jon Saltmarsh, Cadent Gas Limited, Hello Hydrogen