Procedural Manual for Operations, Maintenance, and Emergencies (16.1)
Criticality: High
Progress: Addressed, Not Adequately
Score: 20
DOT Relevance: §192.605
Description of Key Area
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.”
Discussion of Criticality
Procedures must be documented and training programs must be
created.
Discussion of Progress
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 DOT’s RITA established the Hydrogen
Executive Leadership Panel (HELP). HELP’s 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.
Recommendations
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.
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