Hydrogen Sulfide (H2S) - Q & A

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Regulation and Jurisdiction of H2S Activities
8. What training is provided for the
people who work on H2S wells
!acts Relating to H2S ". What should I do if I smell H2S
#. What is H2S Who $an I $all for Help
2. What are the effects
#%. $an odors &e completel'
eliminated
(. How does H2S occur in oil and gas wells ##. How much odor is allowed
). What is &eing done to protect citi*ens in the
locating of H2S oil and gas wells
#2. What value does H2S gas have
+. What is &eing done to protect citi*ens when
drilling the H2S well
#(. How is waste H2S gas disposed of
,. What is &eing done to protect citi*ens when
producing the H2S well
#). How are gas transmission pipelines
regulated
-. What is &eing done to protect citi*ens when
servicing the H2S well
#+. Who regulates air emissions.
R/012A3I45 A56 J1RIS6I$3I45 4! H2S A$3I7I3I/S
Activities that do or could produce h'drogen sulfide 8H2S9 as a result of oil and gas
production or e:ploration; are regulated &' the 6epartment of /nvironmental <ualit'
86/<9 and the =ichigan >u&lic Service $ommission as follows.
3he 4ffice of 0eological Surve' of the 6/< regulates the drilling; production and
transportation through flow lines from the well to surface facilities.
3he Air <ualit' 6ivision of the 6/< issues permits on some of the e?uipment
associated with wells and processing facilities such as storage tanks; flares and other
fuel &urning e?uipment; depending on the amount of emissions e:pected to &e
discharged.
3he =ichigan >u&lic Service $ommission regulates common carrier pipelines which
transport gas and oil from several wells of diverse ownership.
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FACTS RELATING TO H2S
1. What is H2S?
H'drogen Sulfide is a colorless; transparent gas with a characteristic of a rotten@egg
odor at low concentrations and not detecta&le &' odor at high concentrations.
$hemical s'm&ol. H2S
Specific 0ravit'. #.#"2 8heavier than air9
/:plosive limits. 2ower. )A ; 1pper. ))A volume in air
Ignition 3emperature. +%%o !
Solu&ilit' in water. 2." volumes of gas ; per volume of water at 2%o $
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2. What are the effects?
3his information e:cerpted from the American 5ational Standards Institute standard.
B(-.2@#"-2 Accepta&le $oncentrations of H'drogen Sulfide.
H'drogen Sulfide is an e:tremel' to:ic and irritating gas. !ree h'drogen sulfide in the
&lood reduces its o:'gen@carr'ing capacit'; there&' depressing the nervous s'stem.
H'drogen sulfide is o:idi*ed ?uite rapidl' to sulfates in the &od'; therefore no
permanent aftereffects occur in cases of recover' from acute e:posures unless o:'gen
deprivation of the nervous s'stem is prolonged. 3here is no evidence that repeated
e:posures to h'drogen sulfide result in accumulative or s'stemic poisoning. /ffects
such as e'e irritation; respirator' tract irritation; slow pulse rate; lassitude; digestive
distur&ances; and cold sweats ma' occur &ut these s'mptoms disappear in a relativel'
short time after removal from the e:posure.
4dors &ecome detecta&le in concentrations as low as .%%8 parts per million 8ppm9
8$alifornia studies9 &ut the sense of smell is lost after 2@#+ minutes at #%% ppm.
Physiological response:
#% ppm Ceginning e'e irritation
+%@#%% ppm
Slight conDunctivitis and respirator' tract irritation after # hour
e:posure
#%% ppm
$oughing; e'e irritation; loss of sense of smell after 2@#+ minutes.
Altered respiration; pain in the e'es and drowsiness after #+@(%
minutes followed &' throat irritation after # hour. Several hours
e:posure results in gradual increase in severit' of these s'mptoms and
death ma' occur within the ne:t )8 hours.
2%%@(%% ppm
=arked conDunctivitis and respirator' tract irritation after # hour of
e:posure
+%%@-%% ppm 2oss of consciousness and possi&l' death in (% minutes to # hour.
-%%@#%%% ppm Rapid unconsciousness; cessation of respiration and death.
#%%%@2%%%
ppm
1nconsciousness at once; with earl' cessation of respiration and death
in a few minutes. 6eath ma' occur even if individual is removed to
fresh air at once.
3o avoid discomfort; the 88 hour9 time weighted average concentration of h'drogen
sulfide shall not e:ceed #% ppm.
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3. How does H2S occur in oil and gas wells?
H'drogen Sulfide is a naturall' occurring gas mi:ed with natural gas or dissolved in the
oil or &rine and released upon e:posure to atmospheric conditions. 4f the #%;,+2
produci&le oil wells in =ichiganE #;(,% wells had H2S levels e:ceeding (%% ppm.
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4. What is being done to protect citizens in the locating of H2S oil and gas wells?
>ermits are reviewed for the pro&a&ilit' of encountering H2S gas &ased on
knowledge of the rock formations from other wells.
Wells ma' &e no closer than (%% feet to e:isting occupied structures or pu&lic
recreation areas.
Surface facilities 8vessels for treating and storage of oil and gas; with associated
piping and flares9 must &e at least ,%% feet from e:isting occupied structures or
pu&lic recreation areas;
When a well contains (%% ppm or more of h'drogen sulfide; surface facilities or
associated flare stacks ma' not &e located in areas which have &een *oned
residential &efore
Januar' 8; #""(.
>rior to issuance of the permit to drill and operate; a contingenc' plan must &e prepared
&' the applicant which provides an organi*ed plan of action for alerting and protecting
personnel at an H2S well site and the pu&lic. 3his plan identifies.
$ircumstances that activate the plan.
Initial procedures to &e followed to account for all staff; restrict access and notif'
the general pu&lic; pu&lic authorities and safet' agencies.
>rocedures for evacuating the pu&lic.
>rocedures for &urning an' gas released from the well.
A map showing within #(%% feet of the well the following information.
@All occupied structures; pu&lic recreation areas; roads and railroads
@5ames; telephone num&ers and address for residents; &usinesses; schools
churches; hospitals; offices and pu&lic camping or gathering areas.
/mergenc' telephone num&ers including permittee; drilling contractor;
emergenc' preparedness coordinator; am&ulance; hospital; fire department; 6/<;
and the >ollution /mergenc' Alert S'stem 8>/AS9.
3he permittee must under all circumstances notif' the local emergenc' preparedness
coordinator; &' certified letter not less than 2) hour &efore commencing to drill an H2S
well.
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5. What is being done to protect citizens when drilling the H2S well?
3he following safet' features are re?uired.
3he drilling rig must contain wind direction indicators; h'drogen sulfide
detection monitors 8with an audi&le alarm at 2% ppm9; emergenc' escape
&reathing apparatus.
All free gas separated from the drilling fluid must &e flared and tested for H2S.
>roper drilling fluids must &e used to prevent formation fluids or gases from
escaping from the well.
Clowout preventers must &e in place and tested; and &e capa&le of immediatel'
closing in the well even if drilling pipe is in the well.
=ultiple; concentric strings of casing must &e cemented in place to protect fresh
waters and confine fluids or gases to within the well &ore.
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6. What is being done to protect citizens when producing the H2S well?
Warning signs must &e posted at the well and markers placed along the flow line.
An' vents to the atmosphere must &e at least #% feet a&ove the tank top or 2% feet
a&ove the ground. 7enting ma' &e prohi&ited if it results in a verified chronic
nuisance odor.
When storage vessels release more than +%%% cu&ic feet of vapors in 2) hours;
the' must &e e?uipped to conve' those gasses to an incinerator; flare or vapor
recover' s'stem; the site must &e fenced and warning signs posted. /mergenc'
relief valves on these wells must &e routed to an incinerator or flare.
Incinerators or flares must &e designed and e?uipped to prevent the release of
un&urned gas to the atmosphere.
Wells which produce unattended with pressures greater than #%% psig must &e
e?uipped with high@low pressure shut@in s'stems.
7apor return lines are re?uired on truck loading facilities.
All flow lines to first point of sale are re?uired to &e marked to denote the presence of a
&uried line containing h'drogen sulfide; the ownerFs name and emergenc' num&er.
!low lines or facilit' piping for wells permitted after Sept. 2%; #"", are to &e
pressure tested ever' twelve months or visuall' inspected ever' three months.
A&ove ground lines are to &e protected from accidental damage.
40S 84ffice of 0eological Surve'9 staff inspect production facilities two to four times
per 'ear. !acilities known to have a histor' of pro&lems are inspected more fre?uentl'.
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. What is being done to protect citizens when ser!icing the H2S well?
3he same safet' e?uipment as re?uired for drilling; must &e installed whenever
servicing re?uires removing the seal on the innermost well casing. A revised
contingenc' plan is re?uired.
!ield staff can re?uire updating of contingenc' plans whenever significant
changes are noted or a significant action such as well servicing is proposed.
We have recentl' issued a clarification to the e:isting rules which re?uires all gas
produced or discharged during an' servicing operation is flared or otherwise
properl' controlled.
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". What training is pro!ided for the people who wor# on H2S wells?
A permittee of a well is re?uired &' law to ensure that all emplo'ees; including drilling
contractors or other independent contractors; who are involved in drilling; completing;
testing; producing; repair; workover or servicing on an H2S well have &een trained
regarding.
3he properties and effects of H2S.
/ffects of H2S on materials.
/mergenc' escape procedures.
2ocation and use of safet' e?uipment; &riefing areas; detection and warning
s'stems.
$orrective actions; shut@in procedures; well ignition procedures and how to notif'
off@site pu&lic authorities identified in the contingenc' plan.
$ontents of the permitteeFs contingenc' plan.
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$. What should % do if % s&ell H2S?
Never ener an area o see !here he s"ell is co"ing #ro" or o resc$e
%o!ne% personnel& H2S is e're"ely o'ic in high concenraions&
5otif' personnel who can address the pro&lem as follows.
(HO CAN I CALL FOR HELP)
/mergencies.
If the pro&lem appears that it ma' &e more than Dust odors such as &urning in
'our e'es or nose; immediatel' contact 'our local "##; fire or police department.
=ove awa' from an' well or facilities near 'ou &' going perpendicular to the
wind direction.
4dor complaints.
If it appears onl' to &e an odor pro&lem; either notif' the compan' at the num&er posted
on the well sign; the appropriate 6/< 6istrict office 8on@line 40S telephone director'9.
or the >ollution /mergenc' Alert S'stem 8>/AS9 at telephone #@8%%@2"2@)-%,.
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1'. (an odors be co&pletel) eli&inated?
H'drogen Sulfide can &e detected &' smell at concentrations as low as a few parts per
&illion. !or this reason it is e:tremel' difficult to totall' eliminate all odors all the time.
1pon receiving complaints; the Supervisor of Wells ma' re?uire the permittee to
calculate the predicted concentration of H2S in the air at the closest occupied structure
or pu&lic recreation area and ma' then re?uire appropriate emission control measures.
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11. How &uch odor is allowed?
5o odor threshold has &een legall' esta&lished in =ichigan.
3he Supervisor of Wells ma' find; after the permittee has provided calculations and an'
other testing; that a Gnuisance odorG e:ists. A nuisance odor is defined as an emission of
any gas, vapor, fume, or mist, or combination thereof, from a well or its associated
surface facilities, in whatever quantities, that causes, either alone or in reaction with
other air contaminants, injurious effects to human health or safety; unreasonable
injurious effects to animal life, plant life of significant value, or property; or
unreasonable interference with the comfortable enjoyment of life or property.
5uisance odors are prohi&ited and the Supervisor of Wells ma' take action consistent
with the rules to prevent activities causing them or re?uire changes &e made to prevent
them.
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12. What !alue does H2S gas ha!e?
2arge volumes of gas with high concentrations in sufficient ?uantities of H2S can &e
processed to produce elemental sulfur.
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13. How is waste H2S gas disposed of?
2ow concentrations of H2S can &e removed from the gas stream at the well site.
2ow volumes of free gas can &e &urned.
The *ichigan P$+lic Service Co""ission has ,$ris%icion over na$ral gas
pro%$cion raes an% rans"ission pipelines&
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14. How are gas trans&ission pipelines regulated?
>ipeline operators are regulated under the =ichigan 0as Safet' $ode; #"," >A #,+;
and its rules to ensure that the pu&lic safet' is protected to the e:tent possi&le in the
transportation of gas &' pipeline. 3he statute specificall' e:empts the gathering of gas
in rural locations that lie outside the limits of an incorporated or unincorporated cit';
town; or village. However; gathering lines located in or occup'ing the propert' of
schools; hospitals; churches; parks; or similar pu&lic places are su&Dect to the code.
Also; the commission ma' define other designated residential or commercial area such
as a su&division; &usiness or shopping center; communit' development; or similar
populated area as a non@rural area su&Dect to the code.
5atural gas transmission pipelines are regulated under Act " of >u&lic Acts of #"2";
and re?uire the issuance of a $ertificate of >u&lic $onvenience and 5ecessit' &' the
$ommission prior to construction. However; there are certain circumstances where
pipelines are e:empt from $ommission Durisdiction. If the pipeline is a common carrier
8transporting gas from two or more owners9; the $ommission also has Durisdiction over
its rates; charges and conditions of service.
In addition; under this statute; the >u&lic Service $ommission has the authorit' to
regulate production rates of natural gas from gas wells through the issuance of Well
$onnection >ermits; Allowa&le Withdrawal 4rders and >roration 4rders.
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15. Who regulates air e&issions*
3he Air <ualit' 6ivision does not issue permits for wells; &ut ma' permit some of the
e?uipment associated with wells. Air <ualit' regulations prohi&it release of harmful
?uantities of H2S in an' instance. All sweetening facilities must &e permitted &' the Air
<ualit' 6ivision. A Gsweetening facilit'G treats sour gas to remove sulfur compounds
from the gas. After the compan' has &een issued a permit; and the plant has &een
constructed; Air <ualit' 6istrict staff are involved in inspecting the plant to determine
compliance with its air use permit. 6istrict staff also respond to citi*en complains
regarding gas sweetening plants.