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Continuing Surveillance (16.3)

Criticality: High
Progress: Not Addressed
Score: 40
DOT Relevance: §192.613

Description of Key Area

Continuing surveillance falls under the heading of Operations in Subpart L of 49 CFR 192. Per the code, “each operator shall have a procedure for continuing surveillance of its facilities to determine and take appropriate action concerning changes in class location, failures, leakage history, corrosion, substantial changes in cathodic protection requirements, and other unusual operating and maintenance conditions.”

Discussion of Criticality

A determination of action needed must be defined for changes in operating and maintenance conditions for hydrogen pipe.

Discussion of Progress

ASME B31.12 will incorporate the requirements of ASME B31.8S as mandatory and modify selected sections to adapt this standard to hydrogen use.

Recommendations

Because of the unique characteristics of hydrogen, this section of 49 CFR 192 may need to be changed. Standards for continuing surveillance of hydrogen pipe should be established and incorporated by reference into the federal code. The standard should include guidelines to determine the proper time for pipe replacement, and when reduction in the maximum allowable operating pressure should occur.