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

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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

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RRC Oil & Gas District Offices

Areas of Major Sour Gas Production

San Andres

Fusselman

Smackover

Edwards

Questions?

Wesley DreschHydrogen Sulfide Safety CoordinatorEmail: wesley.dresch@rrc.texas.gov

Phone: (210) 227-1313 (ext.25)

Travis Baer, P.E.Oil & Gas Division – San Antonio District Office

Email: travis.baer@rrc.texas.govPhone: (210) 227-1313 (ext.23)