Progress: Addressed, Not Adequately
DOT Relevance: 172 Subpart G
This key area pertains to the provision of appropriate information needed by first responders to potential emergencies (e.g., accidents) involving cryogenic liquid hydrogen, which may be part of a central-production hydrogen fueling infrastructure. The emergency response information must be applicable to liquid hydrogen tank truck transportation from the production plant to fueling stations, including liquid hydrogen loading and (especially) unloading operations.
This key area will be critical if hydrogen fueling infrastructures evolve that utilize hydrogen transported as a cryogenic liquid from central production plants to fueling stations. This key area is also obviously critical to infrastructures supporting vehicles that have liquid hydrogen fuel tanks. At the present time, during this pre-commercialization demonstration phase, a significant portion of hydrogen fueling stations do indeed receive and store liquid hydrogen. However, various DOE-sponsored source-to-wheels studies and the National Academies Review conclude that a fueling infrastructure involving hydrogen liquefaction is not viable, primarily because the liquefaction process is so energy intensive (requiring 30 to 40% of hydrogens heating value).
It is not possible to foresee how soon the goal of renewable-energy-based and low-greenhouse-gas-emissions hydrogen production, either distributed onsite at fueling stations or centralized with pipeline delivery, will be realized. If this infrastructure goal is reached at the same time as hydrogen-fueled vehicles become a commercial reality, then the need for enhanced cryogenic hydrogen emergency response information is less critical. This is because current emergency response resources, which support liquid hydrogen transportation for industrial applications, will probably suffice to support the needs of controlled-access technology demonstrations. If, however, hydrogen vehicle commercialization evolves with liquid hydrogen delivery, then the need to refine cryogenic hydrogen emergency response information is critical. This is because current emergency response resources are aimed at industrial applications with controlled access and trained personnel. Liquid hydrogen delivery to public-access fueling stations will involve a different set of circumstances and require different emergency response resources.
Progress toward providing the technical basis needed for developing emergency response information applicable to cryogenic hydrogen transportation as part of a hydrogen vehicle fueling infrastructure is rated as Addressed, Not Adequately. This is because currently available resources (e.g., the DOT Emergency Responders Guidebook) are adequate to support the cryogenic hydrogen transportation required for delivery to controlled-access fueling stations supporting technology demonstration projects. In addition, new emergency response resources being developed specifically for hydrogen vehicle and infrastructure applications (e.g., CaFCP Emergency Responders Guide, DOT-FTA Hydrogen Bus Design Guidelines, etc.) usually have sections that address cryogenic hydrogen safety practice and/or emergency response.
However, if a fully commercialized hydrogen vehicle fueling infrastructure evolves that includes cryogenic hydrogen delivery and fuel storage, then new and different emergency response resources will be required to address the substantial increase in cryogenic hydrogen transportation (by highway truck and possibly also by railroad and/or marine vessel) and the substantial implications of unloading liquid hydrogen at public-access fueling stations.
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.
Work to update emergency response information resources supporting cryogenic hydrogen transportation should proceed in parallel with work to update other 49 CFR regulations pertaining to hydrogen vehicle cryogenic hydrogen packaging and transportation. Particular emphasis should be given to the implications of high-volume hydrogen delivery and unloading in an open public-access environment. If and when it appears that liquid hydrogen transportation may be an element of the hydrogen fueling infrastructure supporting fully commercialized hydrogen vehicle operations, then work to characterize the new requirements and develop appropriate emergency response resources should be substantially accelerated.
One reason for prioritizing cryogenic hydrogen transportation emergency response resource development is the fact that there has already been one noteworthy mishap involving cryogenic hydrogen truck delivery to a fuel cell test facility, and there have been more serious incidents involving analogous cryogenic tank trucks transporting LNG vehicle fuel.