Railroad Commission of Texas SWR 36: HYDROGEN SULFIDE (H2S) Travis Baer, EIT Engineering Specialist San Antonio Distric

1. Railroad Commission of TexasSWR 36: HYDROGEN SULFIDE (H2S)Travis Baer, EITEngineering SpecialistSan Antonio District Office - Oil and Gas Division

2. TITLE 16 ECONOMIC REGULATION PART 1: RAILROAD COMMISSION OF TEXAS CHAPTER 3: OIL & GAS DIVISION Rule §3.36: Oil, Gas, or Geothermal Resource Operations in Hydrogen Sulfide Areas

3. 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.

4. WHY STATE WIDE RULE 36 EXISTS TODAY • Denver City remembers H2S tragedy • Posted: September 15, 2010 - 12:27am • AVALANCHE-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.

5. Who must comply with Statewide Rule 36? • Any operator who conducts operations including exploration (drilling), production, and transportation of hydrocarbon fluids that contain hydrogen sulfide gas with 100 ppm or greater concentration; this includes drilling, work overs, producing, injecting, gathering, processing, transporting and storage of fluids associated with field production operations, and transportation and handling of fluids and gas which contain hydrogen sulfide as a constituent of the gas.

6. Exemptions from Statewide Rule 36 • Operations involving gathering, storing and transporting of stabilized liquid hydrocarbons (crude oil stored at atmospheric conditions) • Refining, Petrochemical and Chemical Plants • Operations where the concentration of H2S in a system or operation is less than 100 ppm

7. General Provisions • Testing • Each operator shall determine the H2S concentration in the operation or system. • Testing for H2S gas shall be made using those methods accepted by the RRC. Accepted methods are: • Color Metric Tubes •  Tutweiler (titration method) •  Gas Chromatograph (gas analyzer utilized by gatherer) • Note: Advances in technology allows for industry and RRC to periodically evaluate and approve new methods in testing.

8. General Provisions • Testing should be done at random sites/wells to determine the highest H2S concentration in a given operation or system. • All tests must be performed onsite and may include any of the below providing free gas is available: • Well tubing or casing • Portable well tester • Treater or other vessel with fluid/gas  • Gas sales meter  • Production tank – must be producing into tank with approx. ¾ full. Color metric tubes at 1ft above oil.

9. Form H-9 Certificate of Compliance • Required if: • Hydrogen sulfide concentration is 100 ppm or greater in a system/operation •  If producing/injecting (perforations) are in a designated H2S field (website) • Drilling into a known H2S field, near the public or possibly a wildcat field designation. Contact local District Office • **A field is designated as sour when an operator files a production H-9 indicating 100 ppm or greater H2S concentration.

10. Calculation based on H2S concentration and 24 hour release volume of gas determines the distance a release of H2S gas may go under the most stable conditions (Pasquill-Gifford Equation) Rule 36 identifies two Radius of exposures that identify potential danger to the public and may require additional compliance The 100 ppm ROE is the distance from a release to where the H2S concentration in the air will dilute to 100 ppm. This distance should identify if there are any public areas (dwelling, business, school, city or any area that can be expected to be populated) with in the ROE Radius of Exposure (ROE)

11. The 500 ppm ROE is the distance from a release to where the H2S concentration in the air will dilute to 500 ppm. This distance should identify if there are any public roads within the ROE. Public roads are tax supported roads or any road used for public access or use. Radius of Exposure (ROE) (cont.)

12. 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’

13. Warning and Marker Provision All new signs shall state “Caution” and “Poison Gas” with yellow and black contrast

14. Warning and Marker Provision (cont.) Signs: are to be sufficient size to be readable at reasonable distance Posted at any well or fixed facility within a city limits or in close proximity to the public Posted at facilities and at lease entrance. Posted at public road crossings along with information identifying the operator and emergency phone number Posted along a line when located within a public area or along a road at frequent enough intervals to help avoid accidental excavation

15. Warning and Marker Provision (cont.) Examples of acceptable existing signs if they indicate the presence of a potential hazard

16. Security • Facilities and wells shall be fenced and • locked to deter the public from access when located within ¼ mile of a public area (dwelling, business, city or any place public may gather) • Fencing when within a city limits or close proximity to the public shall be chain link, locked and is a deterrent to the public • Specific fencing requirements may be required on a case-by-case basis by the district office

17. Materials and Equipment Materials used in construction, modification of facilities, pipelines, drilling or workover operations shall be manufactured to satisfy the requirements of the latest editions of NACE MR-01-75 and API RP-14E. Other materials which are not susceptible to hydrogen sulfide stress cracking may be used such as fiberglass and plastics providing they are used for applicable industry standard, specifications or recommended practices.

18. Materials and Equipment (cont.) Other materials may also be used as a result in technology or as a result of control of the operating conditions that remove the conditions for hydrogen sulfide stress cracking. The Commission must approve this on a case-by-case basis.

19. Materials and Equipment (cont.) • Existing facilities including drilling and workover operations prior to this section shall be in compliance providing there has been no hydrogen sulfide stress related failure. • The RRC shall be notified in writing in the event of a failure as a result of hydrogen sulfide stress racking and the compliance of the system will be determined.

20. Control and Safety Equipment Operators subject to this provision shall install devices, maintain them and design safety procedures to prevent the undetected release of H2S gas.

21. Control and Safety Equipment (cont.) Operators subject to this provision are those whose operations include one of the following: The 100 ppm ROE is in excess of 50 ftand includes any part of a public area (dwelling, city, business, etc.) The 500 ppm ROE is greater than 50ft and includes any part of a public road (public access or use) The 100 ppm ROE is 3,000 ftor greater

22. Contingency Plan Provision • The contingency plan is an organized • plan of action for alerting, responding and protecting the public following the release of a potentially hazardous volume of hydrogen sulfide gas. • Required for any operation which includes the following • The 100 ppm ROE includes a public area • The 500 ppm ROE includes a public road • The 100 ppm ROE is 3,000ft or greater

23. Contingency Plan Provision (cont.) • Contingency plan • shall contain the following: • Instructions/procedures for alerting the public and public safety personnel of the emergency • Procedures for requesting assistance to remove the public from an area of exposure • Call list to include: local supervisory personnel, county sheriff, DPS, ambulance service, fire department, doctors, contractors, RRC district office, other public agencies

24. Contingency Plan Provision (cont.) • Plat detailing the area of exposure including • private dwellings and other public areas • Names and telephone numbers of all responsible parties of the possibly occupied public areas • Provisions for advance briefing of the public within the ROE to include hazards of H2S, the reason for the plan, the operations possible source of release, emergency information for the public to call, and how the public will be notified in the event of a release of H2S gas • Shall contain the RRC District Office phone number. • The RRC must be notified immediately if the plan is activated or 12 hours in advance of an intentional release of potentially hazardous volume of H2S gas. • Please see Rule 36 “Contingency Plan Provision” for a complete list.

25. Injection of Hydrogen Sulfide Gas • The injection of fluids containing hydrogen sulfide is not • allowed unless first approved by the Commission after a • public hearing or approved by the District Office. • A Commission hearing is required if these conditions exist: • If the 100 ppm ROE is greater than 50 ft and includes a public area • If the 500 ppm ROE is greater than 50 ft and includes a public road • If the hydrogen sulfide content of the gas has been increased by a processing plant • If the 100 ROE is 3,000 ft or greater • ** Approval must be obtained by the District Office if none of the above conditions exist. • ** Contingency plan and Control and Safety Equipment required. • **It is advisable to contact the District office for information and guidance regarding the proper permitting requirements if injection of H2S gas is being considered. • **Injection of sour produced water is not H2S injection.

26. Training Requirements Each operator with operations with 100 ppm or greater H2S gas shall train its employees working in potentially affected areas in H2S safety. Each operator shall also require all service companies working in H2S affected areas to utilize only those company personnel who have been trained in H2S safety.

27. Training Requirements (cont.) Training shall include the following: Hazards and characteristics of hydrogen sulfide Safety precautions Operations of safety and life support equipment; On-site supervisory personnel shall be additionally trained in the following: Effects of H2S on metal components Corrective action and shutdown procedures for production, drilling, blowout prevention and well control Full knowledge of the contingency plan if required **Training documentation shall be provided to RRC upon request.

28. Accident Notification The “Operator” is responsible for making immediate notification to the RRC District Office for the following: Accidental release of H2S gas that may present a hazard In the event of activation of the contingency plan Any incident/accident involving H2S gas ** A written report by the operator shall be furnished to the RRC District Office within 10 days of these conditions. The report shall give a description of the incident and if applicable what could be done to prevent the occurrence from happening again.

29. Drilling and WorkOver Provisions • Categorized as four different conditions: • Infield drilling/workover  • Drilling into known H2S zone • Wildcat drilling • Drilling or workover operations where the 100 ppm ROE includes a public area or 500 ppm ROE includes a public road.

30. Infield Drilling and WorkOvers Drilling or workovers on existing leases with production form H-9 filed shall comply with the following requirements if applicable. Form H-9 for drilling is not required if a production H-9 is on file. Protective breathing equipment (SCBA) shall be maintained at two or more locations 

31. Infield Drilling and Workovers (cont.) Wind indicators and H2S signs posted on site Automatic H2S sensors/alarms to warn of H2S gas Personnel trained in H2S and safety equipment **Compliance depth for drilling is minimum 1000ft above known H2S zone. **Compliance for workovers is when a rig moves in to rig up.

32. Drilling Into Known H2S Zones • Drilling into known H2S fields/zones require the following: • File form H-9 for drilling with the RRC District Office at least 30 days prior to drilling. A waiver to the 30 day waiting period may be requested in writing to the District Office. • Protective breathing equipment (SCBA) shall be maintained at two or more locations.

33. Drilling Into Known H2S Zones (cont.) • Wind indicators to be visible from any site • H2S signs posted at entrance of location • Automatic audible H2S sensors/alarms to warn of H2S gas • Personnel trained in H2S and safety equipment • **Compliance depth for drilling is minimum 1,000 ft above known H2S zone.

34. The “Wildcat” designation may require the operator • to comply if the RRC District Office determines the conditions warrant compliance. Requirements vary by district. Call RRC District Office for their specific requirements. • Requirements may include: • File Form H-9 for Drilling with the RRC District Office at least 30 days prior to drilling. A waiver to the 30 day waiting period may be requested in writing to the District Office. Wildcat Drilling Provision

35. Assume a 3,000ft ROE on Form H-9 File a Contingency Plan with the RRC District Office “Full compliance” under this condition requires the following in addition to other requirements outlined under infield drilling and workovers: Maintain sufficient breathing equipment (cascade system) to provide for well control operations Wildcat Drilling Provision (cont.)

36. Wildcat Drilling Provision (cont.) • Minimum three audible H2S monitors/sensors (rig floor, bell nipple, pits); • Provide a method of igniting the gas in event of uncontrollable emergency • Install a choke manifold, mud-gas separator, flare line and method for lighting the flare

37. Wildcat Drilling Provision (cont.) • Secondary remote control of blowout prevention and choke equipment located a safe distance from well • Drill Stem Test of H2S zone only during daylight hours RRC District Office to be notified before test • BOP and well control systems to be pressure tested at or near compliance depth. Notify RRC District Office four hours prior to test

38. Drilling or Workover Operations when 100ppm ROE includes a public area or 500 ROE includes a road Requirements may include: Call RRC District Office File Form H-9 for Drilling with the RRC District Office at least 30 days prior to drilling/workover File a Contingency Plan with the RRC District Office This condition is full compliance and has the same requirements as “Wildcat” Drilling.

39. Reports Required • Form H-9 Certificate of Compliance: • Operator is certifying that they have or will • comply with the provisions that apply: • H-9’s are not transferable and each operator must test each lease/gas well or system and file H-9 • File in triplicate (one original and two copies) with the District Office • File 30 days prior to commencement of drilling; • File within 30 days after P-4 certificate of transfer; • A new or amended H-9 shall be filed if there is a change in public exposure • Shall be signed by a person trained, experienced and qualified to make the certification

40. Reports Required (cont.) • Completion Report: • Shall report on the initial completion report for oil well and gas well gas the H2S concentration when completed either in a designated H2S field or the H2S is 100 ppm or greater • Shall file a Drilling H-9 or provide a copy of a certified copy of a production H-9 when submitting a drilling application that requires one to be filed

41. Railroad Commission District Office H2S Coordinators • San Antonio (01/02), Wesley Dresch (SW-S) (210) 227-1313 • Houston (03), Vacant (713) 869-5001 • Corpus Christi (04), Rick Silguero (361) 242-3113 • Kilgore (05/06), Ronny Russell (903) 984-3026 • Abilene (7B), Sam Birdwell (SW-N) (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

42. Additional Information H2S Information: • H2S Field Data: http://www.rrc.state.tx.us/data/fielddata/h2s/index.php • Hydrogen Sulfide Safety Manual: http://www.rrc.state.tx.us/forms/publications/swr36/index.php • Travis Baer, San Antonio District Office • (210) 227-1313 (ext. 23) • travis.baer@rrc.state.tx.us • Railroad Commission of Texas • 1701 N Congress Ave • Austin, Texas 78711-2967 • (512) 463-6830 (Office) Answering Service 24/7/365 • (512) 463-7328 (FAX)