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
Lionel Milberger
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.
2. SHORTCOMMINGS:
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 was withdrawn in 1995—not replaced and is obsolete.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 This spec., although still active, is almost a verbatim copy of the above withdrawn and obsolete ASTM Standard.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!
Additional resources:
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
Dana Schindler
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Your “article” contains some fact but it disregards some other points that are applicable and contradict your arguement.
The first thing, operators in Texas don’t get to choose whether or not SWR 36 applies to them. They fall under the rule if they have gas that has greater than 100 ppm H2S. Period.
If your production falls under SWR36 then there are safety precautions that must be taken as a result. These precautions protect the workers on the location and keep the public safer as well. The greatest way to protect the public is to contain the gas properly and with equiment suited to that purpose, hence the NACE standards.
Your writing unfairly criticies the RRC for some things that are not it’s responsibility. The TCEQ is responsible for emissions to air, not the RRC.
I have read many of your posts and I think you are trying to make statements without complete (or correct) information. It seems to me that you and your readers would be better served by a more thorough understanding of the rules, there applicability, and the realities of safely producing oil and gas. Also, I think it would serve you well to become better informed about surface and mineral owner’s rights – Texas has a long proven record of what these rights are (in Texas).
I realize mine may not be a popular position on your website, but it is hard to read erroneous things that have real-world consequences to people without saying something.
Thanks Jeff. I will send your comments on to the author of the paper I posted. We do know that the TCEQ regulates emissions but this paper deals with the statewide rule and that is the RRC.
I think I’m pretty well versed in surface and mineral right but thanks.
Oh Jeff, you uninformed person! The SWR 36 clearly requires testing, but that testing requirement is in SWR36——AND you are not under SWR36 until the testing has been done. So, you test if you want to (or report such results if you want to). So, like said above, you are not under SWR 36 unless you want to be put under it.
Further, the original SWR36 (in effect in 1975) pervented emissions to the air of H2S. After nine people died from H2S, the SWR36 was changed and that prevention of emissions to the air was REMOVED. And on and on it goes.
Further Jeff–the TCEQ has little or nothing to do with emissions from drill sites in Tx. And that’s the way that the O&G folks want it to be–so the RRC complies!
Actually, SWR 36 compliance for a new well to receive a W-1 permit is based on depth (zone) and the Geo-location of known H2S fields. Some wells must file an H-9 with measured results of expected PPM prior to drilling which allows for using a near by location data, use you own judgement with this scenario.
It is strange that Amine plants must be constructed in areas to remove the sulfur before sending the treated product downline. Looking at H-9’s on file of wells within the areas amine plants are constructed, shows in many documents with PPM’s in minimum ranges.