Progress: Addressed, Not Adequately
DOT Relevance: 192.605
The topic of procedures for operations falls under Subpart L (Operations) of 49 CFR 192. Per the Code, This subpart prescribes minimum requirements for the operation of pipeline facilities.
Procedures must be documented and training programs must be created.
Hydrogen pipeline operations and maintenance requirements have been developed by a number of companies internally but there are not yet any public guidelines.
In 2005, the NASFM and DOTs RITA established the Hydrogen Executive Leadership Panel (HELP). HELPs mission is to bring together emergency responders, government regulators, scientists, consumers and experts from the automotive and energy industries to facilitate a safe and orderly transition to hydrogen and other alternative fuel sources. HELP will focus on issues involved in training, educating, and mobilizing emergency responders to work with government, industry, and community groups to facilitate and ensure hydrogen transport, storage and distribution, and the safety of vehicles and environs.
NREL has plans to establish a condensed version of training related material for code officials and fire marshals.
ASME B31.12 will incorporate by reference ASME B31.8S to address the more comprehensive concept of integrity management and not just maintenance. ASME B31.12 will incorporate by reference ASME B31Q when it is published to address the training, examination, and certification of system operators.
Generally, a complete public specification for operation and maintenance may not be necessary but, at a minimum, best practices should be disseminated. The ongoing efforts related to procedure development should be monitored and appropriate learning considered for incorporation by reference into the federal code.