The following white paper, written by reader Lionel Milberger, proves the Railroad Commission’s rule SWR 36 is not protecting the public from deadly H2S Gas.
EDIT: duh! It’s H2S. I had a dyslexic moment.
26 April 2009
REV = 0, 26 April 2009
WHAT’S WRONG With Texas’s SWR 36, used by the Railroad Commission?
1. GENERAL: This rule has to do with H2S in Texas and it governs the RRC’s activities with O&G operators regarding this gas.
a. The Rule does not prevent, prohibit nor limit the emission of H2S to the air in any quantities what-so-ever.
b. Basically, an operator (or it’s operation) comes under the provisions of this rule if there is a concentration of H2S in any of it’s flow-stream/s wherein the concentration exceeds 100 ppm.
c. The rule clearly states that each operator will test for H2S in the flow-stream. However, this provision is contained in SWR 36. If an operator or operation is not under this rule, then there is no requirement for such testing! The rule clearly states that there are four (4) methods to use for testing for H2S in gaseous streams.
1. ASTM Standard D-2385-66. This spec. was withdrawn in 1995—not replaced and is obsolete.
2. GPA (Gas Processors Association) Publication 2265-68. This spec., although still active, is almost a verbatim copy of the above withdrawn and obsolete ASTM Standard.
3. GPA Plant Operation Test Manual C-1. This C-1 document is NOT a spec.; but, is only some recommendations for information use only.
4. Other procedures approved by the commission. According to at least two high level employees of the RRC, there are no other approved procedures or methods.
d. Test of vapor accumulation in storage tanks may be made with industry accepted colormetric tubes. Notice the word “may”. Also, these tubes are known to not include H2S that is dissolved in water vapors.
e. Because of 2(c) above, an operator or operation is under SWR 36 only if the operator wants to put himself or facility under the rule.
f. If an operator or facility is under SWR 36 there are only about four (4) things that the operator must do:
i. Notify the sheriff.
ii. Write a simple evacuation plan.
iii. Put up some signs.
iv. Make some rudimentary hand calculations and submit an H-9 form to the RRC.
g. The rule clearly states that NACE MR-01-75 is applicable and must be used during the selection of materials to meet satisfactory performance for H2S environments (SSC conditions). Since many wells or facilities conditions can be significantly below 100 ppm H2S, wherein NACE MR-01-75 is applicable, the Rule is sorely lacking. Again, this requirement applied ONLY if you or your facility is under SWR 36—and you are under it only if you want your self to be under it.
h. The rule makes no mention about additional needs for material/component selection regarding other corrosive conditions that may exist in a well or facility—whether or not the facility if under Rule 36.
i. There are NO punitive provisions included in the Rule for non-compliance.
j. The Rule does almost NOTHING to protect the public from the harmful effects of H2S.
k. In short—it’s a JOKE!
SURVEY of ACCIDENTAL and INTENTIONAL HYDROGEN SULFIDE (H2S) RELEASES CAUSING EVACUATIONS and/or INJURY
in Manistee and Mason Counties
from 1980 to 2002
Introduction added 2001
Amended June 2003