General Maintenance and Integrity Considerations

The US Occupational Safety and Health Administration (OSHA) Standard 1910.119 describes requirements for a mechanical integrity program that should be implemented for all hydrogen systems. These programs generally involve:

• Proper design, testing, and commissioning
• Use of fail-safe features
• Preventative maintenance plan
• Written procedures
• Training for maintenance, calibration, testing, and inspection personnel
• Calibration, Testing and Inspection - The types and frequency should be consistent with applicable manufacturers’ recommendations and adjusted as indicated by operating experience
• Correcting deficiencies that are outside acceptable limits
• Documentation – Each calibration, inspection, and test should be recorded

Additional general considerations:

• During the design phase, project participants should ensure the appropriate safeguards and safety-related maintenance requirements are included in the design.
• Chronic maintenance issues may be the result of design flaws that should be corrected
• Any changes other than replacements in kind should be done through a formal Management of Change process. See Management of Change
• Workers must have the right tools and training as well as sufficient time and budget to perform needed maintenance activities

Maintenance planning should be started during the design phase to:

• help ensure that needed safety features for maintenance are included in the facility
• help with design choices by balancing initial cost of equipment with ongoing maintenance costs

A complete set of maintenance plans should be drafted before the system is started. The drafts should be improved as operating experience dictates. Elements of the plan include:

• A list of equipment (See Note below.) in the facility.
• Priority grouping of equipment (high, medium, and low) based on importance to the process, safety, operability, and other key criteria. Although it is difficult to do, facility managers should balance the risk of equipment failure with the cost of maintenance. If the failure consequence of a component is minimal, inspection and maintenance need not be as frequent as those for equipment whose failure could lead to injury or shutdown.
• The required maintenance activities, manpower requirements, and timing for each component should be based on the manufacturer’s recommendations, history, and good engineering judgment.
• A master maintenance schedule starting with the activities to be performed on the high-priority components. The schedule should ensure that the high-priority components receive the greatest attention before something goes wrong (preventive maintenance). It may be possible to deal with the low-priority components using in a reactive approach.
• The plan should be documented and communicated to the workers who will be performing the maintenance.

Along with the maintenance plan for each piece of equipment, the results of inspection and maintenance should be documented and include a description of any needed follow-up activity and the next scheduled inspection/maintenance activity.

All maintenance should be systematically recorded to show:

• What was done
• By whom
• When it was completed

Any incident involving maintenance should be investigated following the procedures for the facility. Consider reporting “near misses” and incidents to the H2tools Lessons Learned Database.

Note: As used in this section, “equipment” is an all-inclusive term that includes piping, instruments, and controls as well as those hydrogen system components commonly known as equipment.