Is FIPS 140-2's "Continuous random number generator test" practical? Section 4.9.2 of FIPS PUB 140-2 specifies, amongst other things, a "Continuous random number generator test."  Here are the relavant bits:


  
  If each call to a[n] RNG produces blocks of n bits (where n > 15), [...] Each subsequent generation of an n-bit block shall be compared with the previously generated block. The test shall fail if any two compared n-bit blocks are equal.
  If each call to a[n] RNG produces fewer than 16 bits, [...] (for some n > 15) [...] Each subsequent generation of n bits shall be compared with the 
  previously generated n bits. The test fails if any two compared n-bit sequences are equal.
  


Isn't (n > 15) too small?

I am concerned about their choice of 16 being the minimum for 'n'.  At 16-bits, one would expect to see the test fail, inappropriately, about every 64,000 iterations.  That is rather frequent!  Even an 'n' of 32 will lead to noticeable false positives if the RNG is being used very frequently.

In my specific case, I have a 32-bit TRNG, and would much rather stretch 'n' to 64 to prevent false positives.

Thoughts?
This requirement is a part of the general "continuous tests", and as such it's primary purpose is to detect "flatline" failures (if you can torture that analogy into making sense). Remember that FIPS-140 was originally written with hardware implementations in mind, so the approaches they take for testing sometimes seem odd for software since hardware failures tend to be different from software failures.

I don't think there's a problem, though. You could choose $n = 16$ and potentially have statistical problems, but you don't have to pick something that small. Build your construction to output the size block that you want it to. Eg, modern constructions like CTR_DRBG from SP800-90 output 16 bytes at a time, which is well outside statistical concern.

Also, you're probably not certifying a TRNG, since there are no non-deterministic RNGs that can be certified.