Statewide Rule 36: Operations in Hydrogen Sulfide Areas. Statewide Rule 32: Flaring/Venting of Produced Gas. May 5, 2015

Transcription

1 : Operations in Hydrogen Sulfide Areas Statewide Rule 32: Flaring/Venting of Produced Gas May 5, 2015 Travis Baer Engineering Specialist Phone: (x23) 1

2 RRC Mission Our mission is to serve Texas by our stewardship of natural resources and the environment, our concern for personal and community safety, and our support of enhanced development and economic vitality for the benefit of Texans. 2

3 Session Description Part 1 Discussion of the Statewide Rule 36 including general requirements, H-9 Certificate of Compliance, radius of exposure, safety issues, and contingency plans. Part 2 Discussion of Statewide Rule 32 regarding flaring and venting rule exemptions and authorizations, as well as other flaring info and statistics.

4 H2S What is H2S? Colorless gas with a flame that is practically invisible Heavier that air Soluble in oil and water Dangerous to health Sewer gas, stink damp, sour crude, rotten-egg gas 4

5 H2S Where do you find H2S? Variety of natural and industrial settings Natural gas and petroleum Most H2S obtained as by-product Can be recovered from natural gas and refining operations and converted to sulfuric acid or high quality Sulfur 5

6 Texas Administrative Code (TAC) Title 16, Part 1, Chapter Oil, Gas, or Geothermal Resource Operation in Hydrogen Sulfide Areas 6

7 Introduction Designed to protect public from hazards of hydrogen sulfide gas (H2S) Education and training are the best defenses Industry must protect themselves, public Denver City H2S tragedy, February

8 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

9 General Provisions Testing to determine H2S concentration in operation/system color metric tubes (Storage Tanks Only) Tutweiler (titration method) Lead-acetate method (ASTM D4084) 9

10 General Provisions Done at random sites/wells The well must be in production a minimum of 24 hours prior to the test. Must be performed onsite. Samples cannot be taken into a lab. May include: well tubing or casing portable well tester treater or other vessel with fluid/gas gas sales meter (upstream of a scrubber) 10

11 Form H-9 Certificate of Compliance required: H2S concentration is 100 ppm or greater in system/operation Producing/injection in designated H2S field Drilling into known H2S field near a public area Drilling into a wildcat field (H2S) NOTE: A field is designated as sour when an operator files a Production H-9 indicating 100 ppm or greater H2S concentration. 11

12 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 12

13 Radius of Exposure (ROE) 500 ppm ROE distance from release to where H2S concentration in air will dilute to 500 ppm Identifies public roads within the ROE public roads are tax supported or any road used for public access/use 13

14 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

15 Warning & Marker Provision All new signs shall state Caution and Poison Gas with yellow and black contrast

16 Warning & marker provision Signs must be of sufficient size Signs must be posted: at well or facility within city limits or close proximity to public at public road crossings along a line when located within public area along a road at frequent intervals to avoid accidental excavation 16

17 Warning & Marker Provision Examples

18 Security Facilities shall be fenced and locked when located within ¼ mile of a public area for tank facilities within city/town limits The fencing provision will be considered satisfied where the fencing structure is a deterrent to public access. Specific fencing requirements required on case-bycase basis District Office makes this determination 18

19 Materials & Equipment Manufactured to satisfy NACE MR and API RP-14E requirements Materials not susceptible to H2S stress cracking may be used fiberglass, plastics when used for applicable industry standard, specifications or recommended practices Other materials may be used Commission must approve case-by-case 19

20 Materials & Equipment Existing facilities shall be in compliance providing there has been no H2S stress related failure RRC shall be notified of a failure resulting from H2S stress cracking notified in writing compliance of system will be determined 20

21 Control and safety equipment Operators subject to this provision include: 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 100 ppm ROE is 3,000 ft. or greater Operators subject to this provision shall: install and maintain devices and safety procedures to prevent the undetected release of H2S gas 21

22 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 100 ppm ROE is 3,000 ft. or greater 22

23 Contingency plan Instructions/procedures for alerting public/safety personnel of emergency Procedures for requesting assistance to remove public Call list supervisory personnel, sheriff, DPS, ambulance, fire department, doctors, RRC District Office, etc. 23

24 Contingency plan* Plat detailing area of exposure Names & telephone numbers of responsible parties Provisions for advance briefing of the public RRC District Office phone number *Refer to SWR 36 Contingency Plan Provisions for a complete list of requirements. 24

25 Injection of H2S Gas Injection of fluids containing H2S is not allowed unless: approved by Commission after public hearing approved by District Office Contingency plan and control and safety equipment required Injection of sour produced water is not H2S injection 25

26 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 26

27 Training 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 27

28 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. 28

29 Drilling and workover provisions Infield drilling and workovers Drilling into known H2S zone Wildcat drilling Drilling or workover 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 29

30 Infield drilling and workovers Requirements for drilling or workovers on leases with Production Form H-9 filed: protective breathing equipment (SCBA) maintained at two or more locations wind indicators and H2S signs on site automatic H2S sensors/alarms personnel trained in H2S and safety equipment 30

31 Infield drilling and workovers Minimum compliance depth for drilling: 1,000 feet above known H2S zone Compliance for workovers is when a rig moves in to rig up 31

32 Drilling into known H2S zone File Form H-9 with District Office at least 30 days prior to drilling waiver may be requested in writing to DO Protective breathing equipment (SCBA) shall be maintained at two or more locations 32

33 Drilling into known H2S zone Visible wind indicators H2S signs posted at entrance Automatic, audible H2S sensors/alarms Personnel trained in H2S and safety equipment Compliance depth for drilling: 1,000 ft. above known H2S zone 33

34 Wildcat drilling Wildcat designation may require operator to comply if District Office determines conditions warrant compliance. Call District Office for specific requirements Requirements vary by District Office. 34

35 Wildcat drilling Full compliance requires: infield drilling and workover requirements sufficient breathing equipment minimum 3 audible H2S sensors method of igniting gas in event of emergency choke manifold, mud-gas separator, flare line and method for lighting the flare 35

36 Wildcat drilling Full compliance requires: secondary remote control of blowout prevention and choke equipment located a safe distance from well Drill Stem Test of H2S zone during daylight hours RRC DO notified before test BOP and well control systems pressure tested at or near compliance depth RRC DO notified 4 hours prior 36

37 Drilling or workover operations When 100 ppm ROE includes public area or 500 ROE includes a road: call RRC District Office file Form H-9 for Drilling with the RRC DO 30 days prior file Contingency Plan with RRC DO Full compliance/same requirements as Wildcat drilling 37

38 Form H-9 Certificate of Compliance Certified operator has or will comply with the provisions H-9 s are not transferable, each operator must test each lease/gas well or system and file H-9 file in triplicate with the District Office file 30 days prior to commencement of drilling; file 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 38

39 Completion report required 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 Form H-9 or provide a copy of a certified copy of a Production Form H-9 when submitting a drilling application that requires one to be filed 39

40 RRC District Office H2S Coordinators San Antonio (01/02), Wesley Dresch* (210) Houston (03), Pete Fisher (713) Corpus Christi (04), Rick Silguero (361) Kilgore (05/06), Ronny Russell (903) Abilene (7B), Sam Birdwell** (325) San Angelo (7C), Bill Spraggins (325) Midland (08/8A), Tom Fouts (432) Wichita Falls (09), Kim Peterson (940) Pampa (10), Alan Leach (806) *State Coordinator for Districts 1, 2, 3, 4, 5, & 6 **State Coordinator for Districts 7B, 7C, 8/8A, 9 & 10 40

41 H2S Information:

42 Statewide Rule 32 Texas Administrative Code (TAC) Title 16, Part 1, Chapter Gas Well Gas and Casinghead Gas Shall Be Utilized for Legal Purposes 42

43 Session Description Exemptions from the rule When does SWR 32 not apply? No metering required! Authorized Flaring and Venting (PBR) Flaring without a permit under special conditions. Meter all gas and report on Production Report. Flaring Exceptions (permits) What is required for an exception and what does it do for an operator? Other Information and statistics 43

44 Statewide Rule 32 Introduction Gas must be used for lease operations or sold if it can be readily measured by devices (meters) routinely used in the operations of oil wells, gas wells, gas gathering systems or gas plants. 44

45 Statewide Rule 32 Exemptions Tank vapors from: crude oil storage tanks gas well condensate storage tanks salt water storage tanks Fugitive emissions of gas Amine treater, glycol dehydrator flash tank, and/or reboiler emissions Blowdown gas from gas handling equipment for construction, maintenance or repair 45

46 Statewide Rule 32 Exemptions Gas purged from compressor cylinders or other gas handling equipment for startup Gas released: at a well site during drilling operations prior to the completion date of the well must be separated from drilling fluids using a mud-gas separator, or muddegasser During completion or re-completion (hydraulic fracturing) 46

47 Statewide Rule 32 Exemptions from the rule When does SWR 32 not apply? No metering required! Authorized Flaring and Venting (PBR) Flaring without a permit under special conditions. Meter all gas and report on Production Report. Flaring Exceptions (permits) What is required for an exception and what does it do for an operator? Other Information and statistics 47

48 Statewide Rule 32 Gas releases to be flared or vented The Commission may require flaring of releases of gas not readily measured if the Commission determines that flaring is required for safety reasons (e.g. high concentrations of H2S). All gas releases >24 hours duration shall be burned in a flare, if the gas can burn safely All gas releases of <24 hours duration may be vented to the air if not required to be flared for safety reasons (contact District Office for verification) 48

49 Statewide Rule 32 Gas Releases Authorized by Rule Authorized gas releases during production operations must be measured (metered) and be reported on monthly Production Reports. Flaring beyond the limits set in the following scenarios requires an exception (permit) to be granted. Produced gas not to exceed 10 producing days after initial completion, recompletion in another field, or workover in the same field. Gas that must be unloaded from a well may be vented up to 24 hours in one continuous event or up to 72 cumulative hours in one month 49

50 Statewide Rule 32 Gas Releases Authorized by Rule (cont.) Gas from a lease production facility may be released for up to 24 hours in the event of a pipeline or gas plant upset. Gas contained in waste stream from molecular sieve or membrane gas treatment unit, provided at least 85% of inlet gas is recovered and directed to legal use Low pressure separator gas, up to 15 mcfd for gas wells, 50 mcfd for oil leases or commingled points (gas must pass through separator, heater-treater, free-water knockout, or other low-pressure equipment prior to release) 50

51 Statewide Rule 32 Gas Releases from gas gathering system or gas plant May be released for up to 24 hours in the event of a pipeline or gas plant upset. Notify the local District Office as soon as reasonably possible after release begins. If gas plant operator presents information that shows necessity of release is justified beyond 24 hours, operator may continue to flare gas. Operator must file exception request within one business day after first 24 hours of release. 51

52 Statewide Rule 32 Exemptions from the rule When does SWR 32 not apply? No metering required! Authorized Flaring and Venting Flaring without a permit under special conditions. Meter all gas and report on PR. Flaring Exceptions (permits) What is required for an exception and what does it do for an operator? Other Information and statistics 52

53 Statewide Rule 32 Exceptions (a.k.a. Flare Permits ) Exceptions are good for 45 days up to a total of 180 days May be indefinitely approved administratively with adequate justification if less than 50 mcf/day Exceptions for more than 180 days may only be granted through a final order (hearing) signed by the Commission. 53

54 Statewide Rule 32 Exceptions Documentation required for permanent exception cost benefit analysis map showing nearest pipeline capable of accepting gas estimate of gas reserves Fee of $ per gas well, oil lease, or commingled vent/flare point Exception may be sent by fax or , provided a signed original request, accompanied with fee, is received by Commission within 3 business days 54

55 Statewide Rule 32 Exceptions If additional time is requested, operator must re-file within 21 days BEFORE the expiration of existing exception. If re-filed within 21 days, the operator is authorized to continue flaring/venting until final approval or denial of the requested permit extension. If operator files for extension less than 21 days before expiration or after expiration of the permit, continues to flare during processing of request and the request is denied, operator may be subject to administrative penalties 55

56 Statewide Rule 32 Exceptions Not transferable upon a change of operatorship Operator has 90 days to re-file the exception once the P-4 transfer has been approved 56

57 Statewide Rule 32 Exemptions from the rule When does SWR 32 not apply? No metering required! Authorized Flaring and Venting Flaring without a permit under special conditions. Meter all gas and report on PR. Flaring Exceptions (permits) What is required for an exception and what does it do for an operator? Other Information and statistics 57

58 Statewide Rule 32 Additional information An automated system check for permits if flaring is indicated on Production Reports If flaring production is not permitted, operator will automatically be sent a Notice of Violation (30 days), a Notice of Intent to Sever by certified mail (30 days), and then a severance letter, if compliance is not achieved. A permit extension may be denied if no progress is made to eliminate necessity for flaring. 58

59 Statewide Rule 32 January 2014 Notice to Industry unauthorized venting or flaring of gas may constitute waste. SWR 32 prohibits venting or flaring of gas under certain conditions unless authorized by the Commission. Any venting/flaring of casinghead gas or gas well gas not authorized by SWR 32 or by permit may be subject to administrative penalty action. An operator whose application to vent or flare gas is denied in whole or in part has the right to request a hearing before the Commission. 59

60 Flaring Permits FISCAL YEAR FLARE PERMITS ISSUED , , To put these numbers in context, Texas currently has more than 176,000 producing oil wells, so flaring involves just a small fraction of the state s oil wells. 60

61 Statewide Flaring Percentage Approximately 0.8% produced gas is flared/vented on average. 61

62 Flaring Frequently Asked Questions: 62

63 Santos Gonzales, Jr., P. E. Assistant Director, Field Operations Phone: (512) Travis Baer, E.I.T. Engineering Specialist San Antonio District Phone: (210) (x23) 63