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Chairman David Porter
Commissioner Christi Craddick
Commissioner Ryan SittonApril 2016
Railroad Commission of Texas
Rule §3.36: Oil, Gas, or Geothermal Resource Operations in Hydrogen Sulfide Areas
Wesley Dresch – H2S CoordinatorTravis Baer, P. E. –Engineering Specialist
Field Operations – San Antonio District Office
Introduction
• Statewide Rule 36 is designed to help protect the public from the hazards of hydrogen sulfide gas (H2S) in oil and gas operations.
• The Railroad Commission (RRC) believes that education and training in H2S safety and equipment are the best defenses against the hazards of H2S and that industry must be able to protect themselves if they are to help protect the public.
Why Statewide Rule 36 Exists Today
Denver City remembers H2S tragedyPosted: September 15, 2010 - 12:27amAVALANCHE-JOURNAL
DENVER CITY — Thirty-five years ago on the morning of Feb. 2, 1975, a city of about 4,100 people awoke to the biggest oil field-related tragedy it had ever experienced.A very small leak of hydrogen sulfide (H2S) — a poisonous, pungent gas — took the lives of nine people when an experimental gas injection-well pipe connection ruptured.
Characteristics of H2S Gas
• Boiling Point: -76°F (-60°C)
• Specific Gravity: 1.9 (heavierthan air)
• Ignition temp: 500°F (260°C)
• Explosive at mixtures between 4.3% - 46%.
• Combustion byproduct is toxic Sulfur Dioxide (SO2)
• Corrosive to high-carbon steel
Physical Effects of Hydrogen Suflide
PHYSICAL EFFECTS OF HYDROGEN SULFIDECONCENTRATION
Percent (%) PPM Grains/100 std. ft3 * Physical Effects
0.001 10 0.65Obvious and unpleasant odor. Safe for 8-hour exposure.
0.01 100 6.48Kills smell in 3 to 15 minutes; may sting eyes and throat.
0.02 200 12.96 Kills smell shortly; stings eyes and throat.
0.05 500 32.96Dizziness; breathing ceases in a few minutes; need prompt respiration
0.07 700 45.36Unconcious quickly; death will result if not rescued promptly.
0.10 1000 64.8Unconscious at once, followed by death within minutes.
* At 15.00 psia and 60°F
Toxicity of Various Gases
Railroad Commission Compliance
Compliance requirements
• Exploration, production and transportation of hydrocarbon fluids that contain hydrogen sulfide gas– 100 ppm or greater concentration
• Exceptions:– gathering, storing and transporting stabilized liquid
hydrocarbons (atmospheric pressure)– refining, petrochemical and chemical plants– operations where concentration of H2S is less than
100 ppm
8
Radius of Exposure (ROE)
SWR 36 identifies two ROEs that identify potential danger, may require additional compliance.
• 100 ppm ROE – distance from release to where H2S concentration in air will dilute to 100 ppm.
Identifies public areas within the ROE
• 500 ppm ROE – distance from release to where H2S concentration in air will dilute to 500 ppm
Identifies public roads within the ROE
Compliance Requirements Based on ROE
Case 1: 100 ppm ROE is < 50’
Case 2: 100 ppm ROE ≥ 50’ but < 3,000’ & No Public Area
Case 3:• 100 ppm ROE ≥ 50’ &
Public Area; or• 500 ppm ROE contains
Public Road; or• 100 ppm ROE ≥ 3,000’
*Requirements for Districts 5 & 6 only. **Requirements for drilling and workover operations
Testing for H2S
• Multiple sample points
– Wellhead, test separator (for ROE)
– Storage Tanks
• Test Methods
– Gas chromatography, Tutwiler
– Colorimetric tubes*
Image Source: “Figure 1” Federal Register § 60.5408
Proper Warning Marker
All new signs shall state “Caution” and “Poison Gas” with yellow and black contrast.
Warning & Marker Provision
Signs must be posted:
• at well or facility within city limits or close proximity to public;
• at public road crossings;
• along a sour gas pipeline when located within public area; and
• along a road at frequent intervals to avoid accidental excavation
Warning & Marker Provision
Training
• Operations with 100 ppm or greater H2S shall train employees working in potentially affected areas in H2S safety
• Operators shall require service companies in H2S affected areas to utilize only personnel trained in H2S safety
• Training MUST be done on an annual basis
Photo source: www.mastery.com(1)
• Training SHALL include:• hazards and characteristics of
H2S safety precautions• operations of safety and life
support equipment
• Additional training for on-site supervisory personnel:• effects of H2S on metal
components• corrective action and shutdown
procedures• full knowledge of contingency
plan
Training
Photo source: http://greatervisionltd.net (2)
Accident Notification
• Operator is responsible for notifying RRC District Office:• accidental release of H2S gas that may present a hazard• activation of contingency plan• incident/accident involving H2S gas
• A written report shall be furnished to the RRC District Office within 10 days of these conditions.
Contingency Plan
• Contingency Plan - Plan of action for alerting, responding and protecting the public following release of potentially hazardous volume of H2S gas
• Required for any operations where:• 100 ppm ROE is in excess of 50 ft., includes any public
area; • 500 ppm ROE is greater than 50 ft., includes any public
road; OR• 100 ppm ROE is 3,000 ft. or greater
• Instructions/procedures for alerting public/safety personnel of emergency
• Plat detailing area of exposure
• Procedures for requesting assistance to remove public
• List of responsible parties
• Call list– supervisory personnel, sheriff, DPS, ambulance, fire department,
doctors, RRC District Office, other regulatory agencies (OSHA, TCEQ, etc.)
• Provisions for advance briefing of the public
Contingency Plan
Form H-9 Certificate of Compliance
• Certified operator has or will comply with the provisions of SWR-36
• H-9’s are not transferable, each operator must test each lease/gas well or system and file H-9
– in triplicate with the District Office;
– 30 days prior to commencement of drilling;
– within 30 days after P-4 certificate of transfer
• New/amended H-9 filed if change in public exposure
• Signed by a person trained, experienced and qualified to make the certification
Additional Information
H2S Information on Our Website:
•H2S Field Data:
http://www.rrc.texas.gov/oil-gas/research-and-statistics/field-data/h2s/
•Hydrogen Sulfide Safety Manual:
http://www.rrc.texas.gov/oil-gas/publications-and-notices/publications/swr36index/
•H-9 Certificate of Compliance Filings:
https://rrcsearch3.neubus.com/esd3-rrc/index.php?_module_=esd&_action_=keysearch&profile=53
RRC District Office H2S Coordinators
• San Antonio (01/02), Wesley Dresch* (210) 227-1313
• Houston (03), Pete Fisher (713) 869-5001
• Corpus Christi (04), Rick Silguero (361) 242-3113
• Kilgore (05/06), Ronny Russell (903) 984-3026
• Abilene (7B), Sam Birdwell** (325) 677-3545
• San Angelo (7C), Bill Spraggins (325) 657-7450
• Midland (08/8A), Tom Fouts (432) 684-5581
• Wichita Falls (09), Kim Peterson (940) 723-2153
• Pampa (10), Alan Leach (806) 665-1653
*State Coordinator for Districts 1, 2, 3, 4, 5, & 6
**State Coordinator for Districts 7B, 7C, 8/8A, 9 & 10
21
RRC Oil & Gas District Offices
Areas of Major Sour Gas Production
San Andres
Fusselman
Smackover
Edwards
Questions?
Wesley DreschHydrogen Sulfide Safety CoordinatorEmail: [email protected]
Phone: (210) 227-1313 (ext.25)
Travis Baer, P.E.Oil & Gas Division – San Antonio District Office
Email: [email protected]: (210) 227-1313 (ext.23)