26 Miss. Code. R. 2-1.66 - OPERATIONS INVOLVING HYDROGEN SULFIDE

Preventative measures shall be taken to control the effects of hydrogen sulfide (H₂S) at all operations where H₂S concentrations in the gas stream are equal to 100 ppm or more. Such operations shall include, but may not be limited to drilling, working over, testing, producing, gathering, metering, processing, storing, transporting, and injecting.

(1) Definitions. In addition to the definitions set forth in State Oil and Gas Board Order No. 201-51, Rule 2, unless the context otherwise requires, the following words shall have the meanings indicated when used within this rule.

(a) Radius of exposure: That radius constructed with the point of escape as its starting point and its length calculated as provided for in Paragraph (10)(b).

(b) Area of exposure: The area within a circle constructed with the point of escape as its center and the radius of exposure as its radius.

(c) Public area: Shall include but not be limited to a dwelling, place of business, church, school, hospital, school bus stop, government building, a public road, all or any portion of a park, city, town, village, or other similar area that can expect to be populated.

(d) Public road: Any federal, state, county, or municipal street or road owned or maintained for public access or use.

(e) Sulfide stress cracking: The cracking phenomenon which is the result of corrosive action of hydrogen sulfide on susceptible metals under stress.

(f) Facility modification: Any change in the operation, such as an increase in throughput, in excess of the currently permitted capacity; or any change that would increase the radius of exposure.

(g) Public infringement: A public area and/or a public road has been established within an area of exposure to the degree that such infringement would change the applicable requirements of this rule to those operations responsible for creating the area of exposure.

(h) Contingency plan: A written document that shall provide an organized plan of action for alerting and protecting the public within an area of exposure following the accidental release of a potentially hazardous volume of hydrogen sulfide.

(i) Civil authorities shall include but not be limited to the following agencies:

Governor, Assistant to Governor, local Government Emergency Management/Civil Defense agency, Mississippi Adjutant General, Mississippi National Guard, Mississippi Emergency Management Agency, Bureau of Pollution Control, Red Cross, Mississippi State Department of Health, Department of Public Safety, and such other agencies as in the discretion of the Supervisor of Oil and Gas deems advisable.

(2) Operator Responsibility.

(a) It shall be the responsibility of each operator to conduct operations in accordance with Paragraph (3) through (8) below. Paragraph (9) requires each operator to file a Certificate Of Compliance For Hydrogen Sulfide Operations (Certificate) for each operation that handles or could reasonably be expected to encounter sour oil and/or gas.

(b) Exemptions to Paragraph (3) through (8) may be obtained by filing a Certificate with the Supervisor as directed under Paragraph (10) below.

(c) Variances to or waivers from the specifications of this rule may be granted by the Supervisor upon showing a good cause by the operator.

(3) Safety Program.

A safety program shall be established and maintained to promote safety procedures. All personnel that are assigned, contracted, or employed shall be instructed as to hazards of H₂S, including physiological responses and the application of first aid to victims of H₂S exposure.

(4) Equipment and Materials.

All equipment and materials that will be exposed, or can reasonably be expected to be exposed to H₂S, shall be designed and maintained in accordance with specifications evolved through technology of the latest state-of-the-art to resist damage caused by hydrogen sulfide stress cracking, embrittlement, or corrosion.

(5) Warning Systems.

(a) Warning signs.

1. For above-ground and fixed surface facilities, the operator shall post, where permitted by law, clearly visible warning signs on public streets or roads which provide direct access to facilities.

2. On offshore facilities, the operator shall display clearly visible warning signs on at least two sides of the rig and at points of access to the rig or platform.

3. In populated areas such as townsites and cities where the use of signs is not considered to be acceptable, an alternate warning plan may be approved upon written request to the Supervisor.

(b) Monitors and Alarms.

1. Unless otherwise approved by the Supervisor, each drilling, workover, test, or plant facility shall have an H₂S monitoring system which activates visible alarms when the concentration of H₂S exceeds 10 parts per million (ppm) in air and audible alarms when the concentration of H₂S exceeds 20 parts per million (ppm) in the air. This system shall be capable of sensing a minimum of 5 ppm in the air.

(i) As a minimum, H₂S sensors for onshore drilling and workover rigs shall be located at the rig floor, bell nipple, shale shaker, and mud pits; for offshore drilling and workover rigs, the sensors shall be located at the rig floor, bell nipple, shale shaker, mud pits, and living quarters.

(ii) For drilling operations, this monitor and alarm system shall be on site and operational prior to penetrating the H₂S bearing zone in accordance with the time specified in the contingency plan and approved by the Supervisor. Said equipment shall be on site and operational prior to commencing all other operations involving H₂S.

2. As approved by the Supervisor, the operator of each gathering system, production well, and injection well shall install and maintain in operable condition safety devices to include automatic shut-down devices designed to prevent the undetected continuing escape of hydrogen sulfide.

3. The operator of each unplugged inactive well shall establish safety procedures, as approved by the Supervisor, which are designed to prevent the undetected continuing escape of hydrogen sulfide.

(c) Wind Direction Equipment. Wind direction equipment shall be installed at prominent locations on or near the drilling, workover, test, or plant facility to indicate the wind direction at all times and the safe upwind areas in the event H₂S becomes present in the atmosphere.

(d) Danger Signals.

1. Danger signals consisting of signs and flags shall be displayed in a manner visible to all traffic approaching the facility. All signals shall be illuminated under conditions of limited visibility when in use. If illumination is not feasible, signals must be constructed of reflective material or covered with reflective paint so they will be readily visible from other light sources such as automobiles. Danger signals shall be displayed to indicate the following operational conditions and requirements:

(i) Possible danger - green - When the concentration of H₂S is less than 10 ppm in air;

(ii) Moderate danger - yellow - When the concentration of H₂S reaches 10 ppm in air. If the concentration of H₂S reaches 20 ppm in air, breathing apparatus shall be worn by all personnel and all nonessential personnel shall proceed to the safe briefing areas;

(iii) Extreme danger - red - When the concentration of H₂S reaches 50 ppm in air. All nonessential personnel shall be evacuated, immediate notification shall be given to local civil authorities, and traffic in the immediate vicinity of the facility shall be diverted. The State Oil and Gas Board and other appropriate governmental agencies shall be notified as soon as possible when conditions of extreme danger exist.

(6) Training Requirements.

(a) Each operator whose operations are subject to this rule shall provide training of personnel responsible for his operations. An attendance list of these training sessions shall be maintained by the operator.

(b) The training of personnel shall include the following elements:

1. Safety precautions;

2. Operation of safety equipment and life support systems;

3. Corrective action and shutdown procedures;

4. Effect on metal components of the system.

(7) Personnel Safety Equipment.

(a) Breathing apparatus shall be provided and be readily accessible. A minimum requirement shall be to provide self-contained breathing equipment for all personnel that could be exposed to H₂S concentrations in excess of 10 parts per million (ppm) in air.

(b) Where H₂S concentrations reach 20 ppm in air, a system of breathing air manifolds, hoses, and masks shall be provided. A rechargeable cascade air bottle system shall be provided to refill individual bottles of breathing air. Additional equipment such as a first aid kit, nose cups, ear plugs, spectacle kits, portable H₂S detectors, retrieval ropes and harnesses, chalk boards, note pads, bull horns, flashing lights, resuscitators, and a litter shall also be available.

(c) For drilling operations, the equipment specified in Paragraphs (7)(a) and (7)(b) shall be on site and operational prior to penetrating the H₂S bearing zone in accordance with the time specified in the contingency plan and approved by the Supervisor. Said equipment shall be on site and operational prior to commencing all other operations involving H₂S.

(d) Explosion-proof ventilation devices shall be provided in critical work areas of the drilling, workover, test, or plant facility and be multidirectional and capable of dispersing H₂S vapors.

(e) If H₂S is detected, frequent inspections of all areas of poor ventilation shall be made with an H₂S detector instrument, and personal H₂S detectors shall be made available to personnel.

(8) Contingency Plan.

(a) Operations that handle gas containing 100 ppm H₂S or more in the gas stream must formulate a contingency plan unless exempted under Paragraph (10). Unless otherwise approved, a contingency plan should be filed (in triplicate) with the Supervisor within 30 days of the approval of the drilling permit application.

The contingency plan must be approved by the Supervisor prior to commencing the following operations;

1. Penetrating the H₂S bearing zone during drilling operations.

2. Working over or recompleting a well in an H₂S bearing zone;

3. Testing or putting on permanent production a well that is completed in an H₂S bearing zone;

4. Producing hydrocarbons bearing H₂S into a pipeline or gathering system;

5. Starting up a plant or facility that will remove H₂S from production;

6. Implementing any modification to an existing operation or facility which increases the radius of exposure in a public area or results in a change of the applicable requirements of this rule.

(b) A contingency plan shall include a plat or aerial photograph covering the area of exposure or an area having a radius of one mile, whichever is greater. The plat shall include the location of the well, plant, or corridor showing all good roads, residences, public areas and places, areas of low elevation where H₂S might accumulate, the direction of prevailing winds, oil and gas wells, separators, heaters, corridors of gathering or pipeline systems, pumping stations, plants, refineries, transformer stations, and other manmade structures or features that may be of importance. An index list of houses and places of business with telephone numbers and names and numbers of residents and employees as well as the identification of residents needing assistance in evacuation shall accompany the plan. This index list shall be limited to those houses and places of business located within a radius of one mile. The radius about the well, plant, or corridor may be extended beyond one mile if deemed necessary by the operator, or at the request of the Supervisor. The plan shall also include:

1. Information about the safety program established in Paragraph (3), the training requirements in Paragraph (6), the personnel safety equipment required in Paragraph (7), the location of briefing areas, and responsibilities of personnel during different operational conditions;

2. A description of the warning systems required in Paragraph (5) to include number, location, and detection limits of all monitors as well as the schedules for calibrating and testing said systems;

3. For drilling operations, a specification of the time at which the warning systems required in Paragraph (5) and the personnel safety equipment required in Paragraph (7) will be on site and operational;

4. Procedures to evacuate residences, businesses, and public places;

5. Procedures to divert traffic in the immediate vicinity and to notify the local civil authorities, the State Oil and Gas Board, and other appropriate governmental agencies;

6. Procedures to evacuate non-essential personnel from the well and/or facility in the event attempts to control the well and/or facility are unsuccessful;

7. A list including names, addresses, and telephone numbers of the closest hospitals, ambulance services, medical personnel, and other individuals or facilities that could assist in the event of an emergency;

8. The name, address, and telephone number of the individual in charge of administering the plan;

9. Any other information that the operator deems appropriate;

10. Other information deemed necessary by the Supervisor.

(c) A new or amended contingency plan shall be filed with the Supervisor when any significant change in public exposure caused by public infringement of an existing radius of exposure requires such changes to be made. Otherwise, the contingency plan for each facility shall be reviewed and updated on an annual basis. Any updates, revisions, and/or amendments to a contingency plan shall be submitted to the Supervisor within 30 days of the plan's anniversary date or within 30 days of the date an operator becomes aware of the public infringement, as applicable. If there are no changes, an annual statement of review shall be filed with the Supervisor.

(d) The filing requirement may be waived if a current plan has previously been submitted and is in compliance with the requirements set forth herein. Plans filed prior to the effective date of this rule must be reviewed and modified, if necessary, to obtain compliance with this Paragraph within 180 days of said effective date.

(e) Unless previously provided, copies of the approved contingency plan shall be provided to local civil authorities prior to commencing any one of the operations set forth in Paragraph (8)(a) and be readily available at the drilling, workover, test, or plant facility.

(9) Certificate Of Compliance For Hydrogen Sulfide Operations.

(a) A Certificate shall be filed in triplicate with the Supervisor for each facility or operation subject to any requirement of this rule.

(b) The Certificate shall certify that the operator has complied, or will comply, with the applicable requirements of this rule.

(c) For drilling operations, the Certificate shall be filed with the Supervisor as a part of the application to drill. For facilities involving other types of H₂S operation, as set forth in Paragraph (8)(a), the Certificate shall be filed with and approval granted by the Supervisor prior to commencing those operations.

(d) A Certificate shall be filed for existing facilities or operations within 180 days of the effective date of this rule.

(e) A new or amended Certificate shall be required if there is a change in public exposure caused by public infringement of an existing radius of exposure resulting in a change in the applicable provisions of this rule, not described by the existing Certificate. The operator shall file the new or amended certificate within 30 days after an operator becomes aware of such infringement.

(f) A new or amended Certificate shall be required if there is a modification of an existing operation or facility which increases the radius of exposure in a public area or results in a change in the applicable provisions of this rule not described by the existing Certificate. The operator shall file the new or amended Certificate at least 10 days prior to initiating the operation or construction. Approval of the Certificate must be granted by the Supervisor prior to commencing that operation or construction.

(g) Each facility or operation for which a Certificate has been approved shall be recertified by the operator on an annual basis. The recertification shall be filed with the Supervisor within 30 days of the anniversary date of the most recently approved Certificate for that facility or operation.

(10) Rule Exemptions. Exemptions from Paragraphs (3) through (8) may be obtained by filing the Certificate as directed below:

(a) Each operator must determine the hydrogen sulfide concentration in the gaseous mixture in an operation or system.

1. Tests shall be made in accordance with standards as set by American Society for Testing and Methods (ASTM) Standard D-2385-66, or Gas Processors Association (GPA) Plant Operation Test Manual C-1, GPA Publication 2265-68, as revised, or other methods approved by the Supervisor.

2. Tests of vapor accumulation in storage tanks may be made with National Institute of Occupational Safety and Health (NIOSH) approved colormetric tubes.

(b) To obtain an exemption from this rule, the radius of exposure must be determined, except in the cases of storage tanks, using the following Pasquill-Gifford equation, or by other methods satisfactory to the Supervisor:

For determining the radius of exposure:

X={(1.589) (mole fraction H₂S) (Q)} ^(.6258) Where: X=radius of exposure in feet for 100 ppm H₂S concentration

Q = maximum volume determined to be available for escape in standard cubic feet per day

H₂S = mole fraction of hydrogen sulfide in the gaseous mixture available for escape (i.e. for 1% H₂S (volume basis), mole fraction is .01)

(c) The volume used as the escape rate in determining the radius of exposure shall be that specified below, as applicable:

1. The maximum daily volume rate of gas containing hydrogen sulfide handled by that system for which the radius of exposure is calculated.

2. For existing gas wells, the estimated maximum open flow potential shall be used.

3. For new wells drilled in developed areas, the escape rate shall be determined by using the estimated maximum flow potential of adjacent wells in the field.

4. The escape rate used in determining the radius of exposure shall be corrected to standard conditions of 15.025 psia and 60^oF.

(d) For drilling of a well in an area where insufficient data exist to calculate a radius of exposure but where hydrogen sulfide may be expected, then a radius of exposure equal to one-half mile shall be assumed. A lesser-assumed radius may be considered upon written request setting out the justification for same.

(e) Storage tanks which are utilized as part of a production operation and which are operated at or near atmospheric pressure are exempt from Paragraphs (3) and (5) through (8); however, where the vapor accumulation has a hydrogen sulfide concentration in excess of 500 ppm, the storage tanks shall be subject to the following:

1. Storage tanks are exempt from Paragraphs (5), 7b,c,d, and e), and (8) only;

2. A warning sign shall be posted on or within 50 feet of the facility to alert the general public of the potential danger;

3. Fencing, as a security measure, is required when storage tanks are located inside the limits of a townsite or city or where conditions cause the storage tanks to be exposed to the public.

(f) Operations with a radius of exposure less than 50 feet are exempt from Paragraphs (3) through (8) upon filing the Certificate.

(g) Provided no public area is included, operations with a radius of exposure greater than 50 feet and less than one-half mile are exempt from Paragraphs (5)(b) through (8) upon filing the Certificate.

(h) Operations with a radius of exposure that either is greater than 50 feet and includes a public area or is equal to or greater than one-half mile are not eligible for an exemption under this Paragraph.

Notes

26 Miss. Code. R. 2-1.66

MCA Section 53-1-17(3) (1972)