This meeting allows a broad array of stakeholder experts to discuss a few key issues and provide feedback to CDOs, SDOs, and regulators to advance a number of activities. The key areas for discussion at the meeting are the California Hydrogen Fuel Quality Specifications, industry feedback to DOT on the Gap Analysis report, as well as other issues identified, hydrogen proposals for next week’s ICC hearings, and accreditation of personnel certification programs. These forums are meant to generate honest discussion and identify any issues and concerns early in the process, as well as provide support for developing efforts. We welcome your input and look forward to active discussion.

1. The proposed Draft Regulation (i.e., Article 8 of the California Code of Regulations) developed by the Division of Measurement Standards that has been published for review and comment by all interested parties (70Kb PDF)
   
2. Copy of the letter that DMS has disseminated to all interested stakeholders to solicit their input and comments (385Kb PDF)

The effectiveness of cleaning procedures for sampling equipment and containers shall be confirmed by analysing ultra high purity hydrogen. The determined concentration of each contaminant measured shall be equal or less than one fifth (1/5) of the specified limit in Section 4181.

• Report highlight
  
• Critical safety and codes and standards needs and R&D needs
  
• Consensus priority needs
  
• Role for the Coordinating Committee to facilitate addressing priority needs

1. Issue Number 1: There is the challenge of drawing and shipping small quantities of hydrogen from various fueling stations and sending the samples to analytical laboratories for fuel quality testing. Existing shipping procedures are recognized as difficult to implement. The ASTM team that is developing hydrogen sampling standards is making progress with standard analytical methods, but getting small quantities shipped through common carriers is very difficult. The quantities allowed to be shipped are small with a maximum pressure during shipment of 500 PSIG.
   
   Hydrogen suppliers believe that industry should be able to put a sample cylinder in a car and carry it to a sampling site. Industry should be able to ship the samples via common carrier. If DOT exemptions or CFR rules allow either of these forms of transport, they are not well understood and NHA would be interested in helping DOT to disseminate that information. Otherwise, DOT may need to establish new exemptions - special permits and CFR rules to make it easier to ship small quantities of hydrogen to support fuel quality testing.
   
   At present, composite tanks in passenger cars are not approved for ground storage or for commercial transport of gases. Therefore, it is not possible to use 350bar and 700 bar composite storage vessels to take samples for hydrogen fuel quality testing at stations without using pressure-reducing valves because DOT exemptions for their transport are lacking.
   
   DOT responded that there are approved cylinders, and other cylinders can be used with special exemptions. It is also possible to petition the HazMat office for a rule change, if necessary.
   
   Sondra Ullman asked whether an exemption is possible as a ‘material of trade.’ DOT said this is a possibility as well. 49 CFR 173.6 B5 covers cylinders. Approved packaging is required. Sondra agreed to get this information to Karen for the final report.
   
   ASME has a task force working on bulk storage for hydrogen.
   
   DOT will require a special permit for high-pressure transport. DOT recently updated their rule-making based on ISO 11119 for composite tanks.
   
   Jim Ohi noted it is not clear that the samples need to be transported, or tested, at the working pressure.
   
   There is a need to gain industry consensus on the suitability of composite storage cylinders for ground storage and commercial transport, as well as clearer requirements on the pressures for samples, as required in the hydrogen fuel quality specifications (and future California regulations).
   
   
2. Issue Number 2:The second issue is cited in DOT’s Gap Analysis report as area 16.11, Odorization of Gas, which has a DOT criticality rating of high, and is considered in the DOT report to be not addressed. Subpart L of 49 CFR 192 states that “a combustible gas in a distribution line must contain a natural odorant or be odorized so that at a concentration in air of one-fifth of the lower explosive limit, the gas is readily detectable by a person with a normal sense of smell.”
   
   A natural odorant compatible with hydrogen use in fuel cells has not been identified and validated, and equipment and processes to remove odorants at each point of use are not practical. In addition, the issue of detection must apply to both gaseous and liquid hydrogen. Industry must either find a workable odorant or come forward with alternatives to current odorant requirements that preserve the level of safety intended by the regulation. For example, the regulation might be amended to include other methods leak detection. The NHA would like to work with DOT to address this topic.
   
   Bill Chernicoff noted that odorization may not be required until 2010-2012.
   
   Jim Ohi noted the CFR statement is based on the Lower Explosive Limit, rather than the Lower Flammability Limit, which may be more appropriate for hydrogen.
   
   Chris Sloane noted that consideration must be given to the amount of odorant that would be required to meet the eventual requirement, assuming a suitable odorant could be identified.
   
   Karen Hall reiterated that this issue is multi-faceted. Consideration should be given to research to identify a suitable odorant, as well as mechanisms to revise the regulation in order to meet the true intent – safety by detection.
   
   
3. Issue Number 3: The third issue is training. Area 20 of the DOT Gap Analysis report describes 49 CFR 172.700-172.704 regulations pertaining to training requirements. NHA is supportive of efforts to provide safety training.
   
   Training certification in hydrogen safety is required in areas where training certification is required for other fuels; for example, pipeline maintenance. In other areas, such as vehicle refueling, NHA will enthusiastically work with industry, DOT and other regulators to ensure education in safe hydrogen practices is available and disseminated broadly.
   
   The hydrogen industry recognizes that perceptions can lead to false impressions, and are concerned that any program that requires “special training” and certification for hydrogen and not other fuels, such as gasoline and natural gas, may lead to a misperception that hydrogen is somehow less safe than other fuels. Therefore, NHA wants to ensure that these misperceptions cannot occur by discouraging efforts to require certification for hydrogen where it isn’t required for other fuels. NHA would want to work with industry and regulators to ensure hydrogen safety training is available and adequate, yet does not constitute unusual requirements for hydrogen use.
   
   The NHA is therefore interested in working with DOT to understand the training requirements in 49 CFR, and determine how best to meet them.
   
   The DOT representatives stated they are working with the National Association of State Fire Marshals with respect to LNG, which will carry over to hydrogen. Currently, there are regulations at DOT for validating hydrogen pipelines. It is important to note which requirements apply to transmission pipelines versus distribution pipelines. CFR 49 applies to piping into homes (i.e., distribution). Transport by truck, or other methods, does not require odorization. The NHA can find the specific requirements for distribution lines on the DOT website at www.dot.gov, under ‘Hazardous Materials & Safety Administration.’
   
   Input from fuel cell manufacturers indicated t he following issues, identified in the DOT Gap Analysis report, which may adversely impact the hydrogen and fuel cell industry:
   
   (1) Investigation of Failures (16.7) – The solution is to generate a risk assessment tool with SNL and NREL. This tool is envisioned to be incorporated into the language of 49 CFR 192.
   
   (2) Compressor Stations: Gas Detection (17.9) - The solution is to adopt standards for gas detection and incorporated into the language of 49 CFR 192.
   
   (3) Odorization of Gas (16.11) – The solution is to require an appropriate odorant at an appropriate concentration for hydrogen distribution pipelines. When this is decided upon, the requirement should be incorporated into the language of 49 CFR 192. The specialty gas companies have objected to odorizing transmission pipelines. Members of the fuel cell industry are also on record against requirements for odorants at this point in time.

1. Effects of non-hydrogen constituents in a fuel grade hydrogen on the containment materials.
   
   
2. Effects of pressure and temperature on hydrogen embrittlement and hydrogen attack on containment materials.
   
   
3. Effects of pressure and temperature on composite reinforced pipe.
   
   
4. Effects of a fuel grade hydrogen on plastic pipe materials.
   
   
5. Fatigue crack growth in hydrogen.
   
   
6. Test methods for qualifying materials for piping, pipelines and storage containers.

The above activities all support ongoing efforts to develop codes and standards.

In addition to the above-mentioned items in the draft report, participants of the In-Person meeting suggested the addition of the following issues:

1. Portable power applications, including transporting and refueling,
   
   
2. Small refueling products, such as mobile refuelers.

6.0 ACCREDITATION OF CERTIFICATION PROGRAMS/PROCESSES FOR TRAINING PERSONNEL
INVOLVED IN INSPECTING HYDROGEN FUELING STATIONS, ETC.
Dr. Roy Swift of ASNI presented an overview of the ANSI system for accreditation, available here:

Increasing the Credibility and Quality of Certification through Accreditation (331Kb PDF)

The objective is validation of knowledge, skills and training – independent verification of competency – like a certificate program.

ANSI/ISO/IEC 17024 sets the bar to ensure individuals who should pass do pass, and who should fail do fail. The certification is time-limited and can be revoked. The standard covers policy and procedures of the certification body.

Discussion of Pros/Cons of Accreditation
Accreditation makes sense when industry has a need to ensure people are competent in an area. Accreditation is used to ensure a training program passes who should pass, and fails who should fail.

In the case of a program for hydrogen, the hydrogen industry is not asking for such a program, as the knowledge base upon which to build such a program is still in flux. CSA America is moving forward with personnel certification for hydrogen safety expertise:

CSA Certification Proposal (149Kb PDF)

The hydrogen industry, as represented at this In-Person meeting and the membership of the National Hydrogen Association, is not in favor of this at this time.

The discussion after Dr. Swift’s presentation led to the conclusion that Certification should come from Industry. People vote with their feet – if employers don’t want it, and committee representation isn’t diverse, it may not happen. Industry should continue to indicate these positions to CSA America.


7.0 WRAP-UP AND NEXT MEETING
Russ Hewett polled participants on whether they planned to attend the USFCC 2006 Fuel Cell Seminar in Hawaii in November, which would present an opportunity for the next In-Person meeting. Most participants indicated they did not plan to attend. Russ proposed an alternative opportunity. The DOE Codes & Standards Tech Team is meeting on January 10 at Sandia/Livermore. It would be possible to hold an In-Person meeting in conjunction with that meeting (i.e., January 11). The meeting would provide an opportunity to focus on the hydrogen fuel quality work, with more direct participation from the hydrogen suppliers who would be attending the Tech Team meeting. There was general agreement that this would be preferable. The “problem,” however, is that the In-Person meeting might not be timely – with respect to the schedule that the California DMS is operating on to develop the standard as mandated by the California legislature. The issue of the next In-Person meeting will be discussed again at the October meeting.

The October meeting of the Coordinating Committee will be a teleconference meeting as follows:

DATE: October 4th (First Wednesday)
TIME: 3:00 – 4:30 pm EDT
2:00 – 3:30 pm CDT
1:00 – 2:30 pm MDT
Noon – 1:30 pm PDT

The call-in number and passcode may be found in the Members Only section of this site.

The agenda will be disseminated with the Final Announcement.

If there are items you would like to have on the agenda, please contact any one of the following:

• Karen Hall
• Sondra Ullman
• Robert Wichert
• Jim Ohi
• Russ Hewett

GUEST PARTICIPANTS (Participating by Teleconferencing)
(1) Jim Merrit (DOT/Pipeline Safety)
(2)Dave Smith (BP)
(3)Jim Simmick (BP)
(4) Rick Paul (BP)
(5) Gary Nakarada