SOP FB-08 (Revised MAR 2014) STANDARD OPERATING PROCEDURES-FLOWBACK Hydrogen Sulfide Operations Section 1.0 Introduction and Background Rockwater Energy Solutions, Inc. (and all its affiliated and subsidiary companies, hereinafter collectively referred to as Rockwater ) is committed to providing its employees a safe working environment and avoiding injury to our contractors, customers, and neighbors. As part of our overall commitment to safety, Rockwater seeks to prevent acts or conditions that could result in injury and/or illness to any employee, customer, contractor, neighbor, and/or the environment. In an effort to prevent potentially harmful acts or conditions, Rockwater has developed this Standard Operating Procedure (SOP). This SOP will discuss steps to be taken to promote a safe process, as well as a list of potential hazards that should be identified and remediated prior to commencing these activities. This SOP will be reviewed and revised on an ongoing basis to keep pace with best oilfield practices. This SOP will be a part of the training provided to all affected employees when they begin their employment with Rockwater and any time the plan is changed. This SOP will also be reviewed with an employee if his/her responsibilities change under the plan. A written copy of this plan will remain in the regional Safety Office, and will be available for employee review. The Vice-President of Health Safety and Environment, or his agents, may be contacted by any employee if he/she needs additional information about this SOP. This SOP has been developed to assist affected employees with the operational steps that may be used to complete the task safely. It must be noted, however, that the experience and background of a trained flowback operator is essential to the success of any project or task. Nothing contained in this SOP is a substitute for each employee s individual judgment in any given situation. In the event that any employee believes that any task outlined in any SOP cannot be completed safely, then that employee should immediately halt the performance of such task and notify their direct supervisor. In addition to this SOP, the policies and procedures of each operating company will be strictly observed by Rockwater personnel. Section 2.0 Background and Process Steps, Hydrogen Sulfide Operations Hydrogen Sulfide (H 2 S) is a colorless, flammable, toxic gas that is the result of the decomposition of organic material. Although H 2 S gas has an odor similar to rotten eggs, this gas will rapidly deaden the sense of smell. H 2 S gas is heavier than air, so it will tend to pool in low lying areas or on the ground. But the biggest hazard associated with H 2 S gas is that it is toxic to humans and can have fatal effects very quickly. The purpose of this SOP is to provide information and guidance for safe operations in H 2 S situations. This SOP has incorporated information from the American Petroleum Institute s Recommended Practice 49 Practices for Drilling and Well Servicing Operations Involving Hydrogen Sulfide, as well as other industryrecognized best practices. As part of the pre-job hazard evaluation process, Rockwater will evaluate (or work with the operating company during their evaluation) the site for the presence of H 2 S gas. The measurements will be conducted with an appropriate gas meter, calibrated to detect H 2 S. Please
note that typical gas meters are calibrated to detect H 2 S gas in parts per million (ppm). The standard calibration point on a personal gas meter for H 2 S is typically 10 ppm, and the effective range of the meter is typically up to 100 ppm. Unprotected exposure to H 2 S gas over the 10 ppm reading should be avoided at all costs. All sites will be rated based on the following criteria: No Hazard o H 2 S not present Condition 1/Low Hazard o H 2 S detected, but below 10 ppm Condition 2/Medium Hazard o H 2 S detected between 10 ppm and 30 ppm Condition 3/High Hazard o H 2 S detected above 30 ppm Typically, the placement of warning flags/lights/alarms/signs indicating H 2 S conditions is the responsibility of the operating company. This matter should be discussed with the operating company prior to mobilizing Rockwater personnel or equipment to the jobsite. In the unlikely event that the operating company does not place H 2 S warning flags, Rockwater will use the following system: Condition 1, green flag Condition 2, yellow flag with visual and audio alarms connected to fixed location air monitoring devices Condition 3, red flag with visual and audio alarms connected to fixed location air monitoring devices Fixed location monitoring equipment should be in place and used whenever the potential for H 2 S gas is present, and should be placed in all areas of potential accumulation, especially any living quarters onsite. All Rockwater employees working on any project with the potential for the presence of H 2 S gas must wear portable monitoring equipment at all times. As part of the pre-project hazard evaluation, two muster points should also be identified. These two locations should be 180 o from each other, and clearly identified during the daily job safety analysis (JSA) briefing. The muster points should be near wind socks, and the JSA briefing should include daily reminders to check wind direction prior to any site evacuation, then rapidly move to the upwind muster point. TRAINING: Prior to the commencement of onsite activities, all potentially affected employees must be trained on H 2 S hazards, in compliance with OSHA requirements. This course should include:
Identification of the characteristics, sources, and hazards of Hydrogen Sulfide. Proper use of the Hydrogen Sulfide detection methods used on the site. Recognition of, and proper response to, Hydrogen Sulfide warnings at the workplace. Symptoms of Hydrogen Sulfide exposure. Proper rescue techniques and first-aid procedures to be used in a Hydrogen Sulfide exposure. Proper use and maintenance of personal protective equipment. Demonstrated proficiency in using PPE should be required. Worker awareness and understanding of workplace practices and maintenance procedures to protect personnel from exposure to hydrogen sulfide. Wind direction awareness and routes of egress. Confined space and enclosed facility entry procedures. Locations and use of safety equipment. Locations of safe briefing areas. Use and operation of all Hydrogen Sulfide monitoring systems. Emergency response procedures, corrective action, and shutdown procedures. Effects of Hydrogen Sulfide on the components of the Hydrogen Sulfide handling system. The importance of drilling fluid treating plans prior to encountering Hydrogen Sulfide. In addition, should any employee have to potential to use a supplied air source, additional training and testing will be required. The additional requirements include (at a minimum): Respiratory Protection training, including supplied air usage Medical evaluation for respiratory protection Assignment of personal respirator/mask Qualitative fit testing for personal respirator/mask SUPPLIED AIR AND H 2 S OPERATIONS: In the event that the onsite H 2 S readings should exceed 20 ppm, Rockwater personnel will utilize an appropriate supplied air system for respiratory protection. A typical supplied air option includes the use of a central air pump, staged upwind of the jobsite. Three air lines should be rigged up that run to the separator, water tanks, and oil tanks. Each employee should wear 30 minute escape packs in addition to the supplied air. Should the onsite H 2 S readings ever exceed 200 ppm, a third party contractor that specializes in high H 2 S situations will be brought in to assist Rockwater field personnel with the completion of the project. Section 3.0 Potential Hazards Any time that flowback operations are in progress, the following potential hazards must be considered and mitigated: Latent natural gas
Wind direction Ignition sources within 100 feet of the wellhead and/or frac tanks Pressure Line of fire/body placement/grease valve placement Hydrogen Sulfide (H 2 S) Stored energy Overhead work or suspended loads Section 4.0 Other Safety Items In addition to the above potential hazards, the following items should be discussed and implemented during the pre-project tailgate safety meeting and JSA process, prior to commencement of onsite activities: All possible flammable gas or liquid sources are to be identified and controlled or remediated. All possible ignition sources are to be identified and controlled or remediated. Environmental controls; o Erosion and Sedimentation (E&S) controls in place? o E&S controls appropriately located? o E&S controls adequate for situation? Ensure that safety equipment and personal protective equipment (PPE) is onsite and available and properly utilized when necessary or otherwise required pursuant to this SOP or the operating company s policies and procedures. Access signs or tape (as required) are available. Non-sparking tools for potential leaks are available. Potential communication issues should be identified and resolved; o Among Rockwater employees. o Between Rockwater and other contractors onsite. Strategies for limiting site access should be discusses and implemented, if possible. Rally points for and routes for emergency evacuations should be identified. o Identify a secondary rally point, along with a secondary evacuation route. Grounding and bonding of tanks and equipment must be completed. Appropriate actions on/around tanks must be discussed. Spill/leak cleanup procedures must be reviewed. Containment requirements must be reviewed. Reporting requirements and procedures must be reviewed. Discuss that the integrity of lines is not guaranteed, and can be negatively impacted by o Pressure; o Vibration; o Torque; or o Binds. Record-keeping and project log requirements should be reviewed. Water for pressure testing, purging requirements and processes must be identified. A minimum of two workers must be present onsite at all times.
SOP In-Field Checklist, H 2 S Operations Evaluate site for presence of H 2 S gas with following criteria: No Hazard (H 2 S not present) Condition 1/Low Hazard (H 2 S detected, but below 10 ppm) Condition 2/Medium Hazard (H 2 S detected between 10 ppm and 30 ppm) Condition 3/High Hazard (H 2 S detected above 30 ppm) Ensure operating company places warning flags/lights/alarms/signs indicating H 2 S conditions If H 2 S may be present, Rockwater employees must wear meters at all times Ensure daily that meters are fully charged and calibrated Identify two muster points/evacuation routes (should be 180 o from each other) Ensure/confirm all employees are trained (and current) on H 2 S hazards In the event that supplied air may be needed, ensure employees are trained and current