Emergency Response Information: Cryogenic (19.3)
Criticality: High
Progress: Addressed, Not Adequately
Score: 20
DOT Relevance: §172 Subpart G
Description of Key Area
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.
Discussion of Criticality
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
hydrogen’s 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.
Discussion of Progress
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 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.
Recommendations
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.
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