Hydrogen Sulfide (H2S) Compliance
& RRC Form H-9

Hydrogen sulfide (H2S) exposure is one of the greatest health and safety risks encountered in the oil and gas industry. The Railroad Commission of Texas (RRC) requires operators to protect the general public from the harmful effects of H2S. Statewide Rule 36 (SWR 36) applies to many common oil and gas activities and operations such as drilling, workovers, production, storage, injection, and transportation of hydrocarbon fluids that contain H2S as a constituent. These requirements typically apply to operations where the concentration of H2S is equal to or greater than 100 parts per million (ppm). SWR 36 requires different compliance levels based on the risk of H2S exposure that the general public bears. This risk (and the required level of compliance) is determined based on the 100 ppm and 500 ppm Radius of Exposure (ROE) calculations.

 

 

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Certificate of Compliance Statewide Rule 36 (RRC Form H-9)

Sport Environmental's environmental experts have understand the intricacies of H2S compliance and frequently assist clients with RRC Form H-9 filings for purposes of compliance with SWR 36 . Many clients also choose to have Sport Environmental provide air permitting services or Tier II documentation when H2S compliance services are requested because our environmental experts are able to collect data in the field that can be used for multiple environmental filings in a single visit.

In cases where ROE calculations indicate the need for a Contingency Plan, Sport Environmental can help guide you prepare one that is specific to your facility.

  Did you know?  In Texas, the RRC and TCEQ have different definitions of "sour gas". Natural gas associated with oil and gas production that contains 100 or more parts per million (ppm) hydrogen sulfide is considered sour by the RRC. In contrast, TCEQ considers gas to be sour if it contains just 24 ppm or more hydrogen sulfide. Sport Environmental helps our clients comply with regulations and understand key differences that impact compliance needs. For example, if you have a facility that is considered "sweet" by the RRC at 50 ppm H2S, that same facility will require an air permit in Texas since the TCEQ would consider it a sour site.

Did you know? In Texas, the RRC and TCEQ have different definitions of "sour gas". Natural gas associated with oil and gas production that contains 100 or more parts per million (ppm) hydrogen sulfide is considered sour by the RRC. In contrast, TCEQ considers gas to be sour if it contains just 24 ppm or more hydrogen sulfide. Sport Environmental helps our clients comply with regulations and understand key differences that impact compliance needs. For example, if you have a facility that is considered "sweet" by the RRC at 50 ppm H2S, that same facility will require an air permit in Texas since the TCEQ would consider it a sour site.

H2S Safety-Trained field Staff

Let Sport Environmental handle your RRC Form H-9 and other H2S compliance needs. Our field team is up-to-date on hydrogen sulfide safety training and other oil field safety training (e.g., Basic Orientation Plus and Safeland USA). We also communicate with your health and safety team to ensure safe and efficient hydrogen sulfide sampling.