Department of Transportation Electromagnetic Interference Environmental Protection Agency Emergency Response Planning Guide Federal Register Hazardous Waste Operations and Emer- gency R
Standards
The standards outlined herein include provisions that are integral to this document It is important to note that all standards may be revised, and users should consider utilizing the latest editions of the referenced standards.
1 Threshold Limit Values and Biological Exposure
Chemical Plant and Petroleum Rejìn- ing Piping
Liquid Petroleum Transportation Pip- ing Systems
Gas Transmission and Distribution Piping Systems
Standard for Gas Detector Tube Units-Short Term Type for Toxic Gases and Vapors in Working Envi- ronments
Bulletin on the Generic Hazardous Chemical Category List and Inven- tory for the Oil and Gas Exploration
Bulletin on Management of Natu- rally Occurring Radioactive Materi- als (NORM) in Oil and Gas Production
Well Abandonment and Inactive Well Practices for US Exploration and Production Operations
Release Reporting for the Oil and Gas Exploration and Production In- dustry as Required by the CWA, CERCLA and SARA ùùtle Ill
Recommended Practice for Setting, Maintenance, Inspection Operation, and Repair of Tanks in Production Service
Recommended Practice for Analysis, Design, Installation, and Testing of Basic Surface Safety Systems for Offshore Production Plarfonns Recommended Practice for Drilling and Drill Stem Testing Operations Involving Hydrogen Sulfide
'Recommended Practice for Class$- cation of Locations for Electrical In- stallations at Petroleum Facilities Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Re- pair, and Alteration
Inspection of Pressure Relieving Devices
Management of Process Hazarh Welding of Pipelines and Related Facilities
Guidelines f o r Work in Inert Con- jìned Spaces in the Petroleum In- dusợty
'American Conference of Governmental industrial Hygienists, 1330 Kem- per Drive, Cincinnati, OH 45240
2American National Standards Institute, 1430 Broadway, New York, N.Y
3Amer¡can Petroleum institute, Publications & Dismbution Section, 1220 L Street NW, Washington, D.C 20005
4American Society of Mechanical Engineers, 22 Law Drive, Box 2300, Faifield, NJ 07007-2300
Provided by IHS under license with API
No reproduction or networking permitted without license from IHS
Health Assessment Docu- ment for Hydrogen Sulfide
Performance Requirements for Hydrogen Sulfide Detec- tion Instruments
Installation, Operation, and Maintenance of Hydrogen Sulfide Detection Instru- ments
Standard Material Require- ments Sulfide Stress Crack- ing Resistant Metallic Mate- rials for Oilfìeld Equipment
Hazardous Materials Emer- gency Planning Guide
27 Technical Guidance for Hazards Analysis, Emer- gency Planning for Extremely HazardousSubstances
Purged and Pressurized En- closures for Electrical Equip- ment in Hazardous (Classi- fied) Locations
Criteria for a Recommended Standard for Occupational Exposure to Sulfur Dioxide
Criteria for a Recommended Standard for Occupational Exposure to Hydrogen Sul- fide (GPO No 017-033-
NIOSH Pocket Guide to Chemical Hazards
SEnvi~mmental Protection Agency, available from U.S Government Print- ing office, Washington, D.C 20402
%strument Society of America, Box 12277, Research Triangle park NC
'National Association of Corrosion Engineers, NACE International Box
8National Response Team, National Oil and Hazardous Substances
Contingency Plan GWDFü12,2100 Second Street SW, Washington, D.C
%ational Fire Protection Association 60 Batterymarch wrk, Quincy, MA
02264 iwational Institute for Occupational Safety and Health (U.S Departmait of
Health Education, and Welfare), available from US Government Pnnting office, Washington, D.C 20402
33 Report 85-5 Review of Ambient Hydro- gen Sulfide Standards in Canada.
Regulations
The following regulations ate referenced in this standard All regulations are subject to revision, and users should de- termine the latest version to ensure compliance
Emergency Evacuation Plans for Manned OCS Facilities Emergency Evacuation Plans for Manned OCS Facilities
Contingency Plans and Emergency Procedures
Designation, Reportable Quantities, and Notijcation Emergency Planning and Notijication
Hazardous Chemical Report- ing: Community Right-to-
Oil, Gas, and Sulphur Opera- tions in the Outer Continen- tal Shelf
Oil, Gas, and Sulphur Operations in the Outer Con- tinental Shelf;
Safety Requirements for Drilling Operations in a Hy- drogen Sulfide Environment, Outer Continental Shelf (February 1976)
11Petroleum Association for Conservation of the Canadian Environment,
12002-275 Slater Street, Ottawa, Ontario, Canada LIFSH9
~ZBureau of Mines, U.S Department of Interior, available from U.S Gov- ernment Pnnting office, Washington, D.C 20402
Woast Guard, US Department of Transportation, available from U.S
14U.S Department of Transportation, available from U.S Government Ainting office, Washington, D.C 20402 lsMinerals Management Service, U.S Department of Intenor 381 Elden
S w t , Hemdon, VA 22070-4817 Available from U.S Government Rinting office Washington, D.C 20402
RECOMMENDED PRACTICES FOR OIL AND GAS PRODUCING AND GAS PROCESSING PLANT OPERATIONS INVOLVING HYDROGEN SULFIDE 3
Safety Requirements for Drilling Operations in a Hy- drogen Sulfide Environment, Outer Continental She& (July 1,1982)
Employee Emergency Plan and Fire Prevention Plans
Process Safe0 Management of Highly Hazardous Chem- icals
Hazardous Waste Opera- tions and Emergency Re- sponse
Hazardous Waste Opera- tions and Emergency Re- sponse
Toxic and Hazardous Sub- stunces (Air Contaminants)
Other References
56 Poda, George A., “Hydrogen Sulfide Can Be Han- dled Safely”, Archives of Environmental Health, Vol
57 Ronk, Richard and White, M K., “Hydrogen Sulfide and the Probabilities of Inhalation Through a Tym- panic Membrane Defect”, Journal of Occupational Medicine, Vol 25, No 5,337-340, May 1985
The "Synopsis of Boiler & Pressure Vessel Laws, Rules, and Regulations" provides a comprehensive overview of the legal framework governing boiler and pressure vessel operations across various states, cities, counties, and provinces in the United States and Canada This essential resource is available from the Uniform Boiler and Pressure Vessel Laws Society, located at P.O Box 1521, Oceanside, New York, NY.
59 Pasquill, E, Atmospheric Difusion, Second Edition,
John Wiley & Sons, New York, NY, 1947
60 Slade, D H., Metrology and Atomic Energy NTIS-
TID 241 90 ( 1968), National Technical Infomation Service (NTIS), U.S Department of Commerce, Spnngfieid, VA 22 161
61 Wilson, D J., “Release and Dispersion of Gas from
Wccupational Safety & Health Administration (U.S Department of
Labor), available from U.S Government Pnnting Office, Washington, D.C
Pipeline Ruptures”, Department of Mechanical Engi- neering, University of Alberta, Edmonton, Canada
62 Jann, P R., “Evaluation of Sheltering in Piace’:
Journal of Loss Prevention in the Process Industv,
63 MacFarlane, D R and Ewing, T E, “Acute Health Effects From Accidental Releases of High Toxic Hazard Chemicals”, Journal of Loss Prevention in the Process Industry, Vol 3, No 1 , January 1990, pp
64 Wilson, D J., “Stay indoors or Evacuate to Avoid Exposure to Toxic Gas?”, Emergency Preparedness Digest, Ottawa, Canada, January-March 1987, pp 19-
Davies, P C and Purdy, G conducted a study titled “Toxic Gas Risk Assessments - The Effects of Being Indoors,” published in 1986 by the North Western Branch of the Institution of Chemical Engineers This research, associated with the Health and Safety Executive's Major Hazards Assessment Unit, highlights the risks posed by toxic gases in indoor environments.
66 Glickman, T.S and Ujrhara, A M., “Protective Ac- tion Decision Making in Toxic Vapor Cloud Emer- gencies”, Center for Risk Management, Resources for the Future, Washington, D C 20036
In the study by Wilson (1988), titled “Variation of Indoor Shelter Effectiveness Caused by Air Leakage Variability of Houses in Canada and the USA,” presented at the US EPA/FEMA Conference, the impact of air leakage on the effectiveness of indoor shelters during chemical release emergencies was analyzed The research highlights the importance of understanding how variations in house construction can influence shelter performance, emphasizing the potential of in-place sheltering as an alternative to evacuation in emergency situations.
Bibliography
The following publications contain information related to
Recommended Practice for Design and Installation of Electrical Systems for Ofshore Production Platforms
Recommended Practices for Occupa- tional Safety f o r Oil and Gas Well Drilling and Servicing Operations Recommended Standard for Occupational Exposure to
Hydrogen Sulfide, National Institute for
Texas Railroad Commission Rule 36: Oil, Gas, and
Geothermal Resources Operations in Hydrogen Suljide Areas, Texas Railroad
Public Health Service Publication 999-AP-26, Workbook on Atmospheric Dispersion Estimates,
D Bruce Tanner, available from U.S Department of Health, Education, and Welfare, Cincinnati, OH this subject:
Provided by IHS under license with API
No reproduction or networking permitted without license from IHS
GPA 21 45-85 Physical Constants of Paraffin Hydro- carbons and Other Components of Nat- ural Gar, available from Gas Processors Association, 6526 E 60th Street, Tulsa,
Acronyms and Abbreviations
Enclosed Facilities and Confined Space Entry
Refer to 29 Code of Federal Regulations Part 1 9 1 O 146 for
OSHA’s confined space entry regulations Refer to Section
1 2, “Operations Involving Enclosed Facilities”, for some topics that may be used in training personnel for enclosed fa- cilities work Refer to Pars 9.17 and 9.18 for further precau-
PRACTICE 55 tionary information on entry into confined spaces (including vessels) and enclosed facilities
Individuals with recognized physiological or psychological conditions that hinder normal breathing should not be assigned to roles that may expose them to hydrogen sulfide or sulfur dioxide This is particularly important if the use of breathing equipment or exposure could exacerbate their respiratory issues For more information, refer to OSHA’s Respiratory Protection Standard.
(29 Code of Federal Regulations Part 191 O i 34)
Personnel assigned to tasks involving the use of breathing equipment must undergo regular evaluations to assess their physiological and psychological fitness for this equipment, in accordance with 29 Code of Federal Regulations Part 1910.134 and ANSI 288.2.
Perforated Eardrums
The medical community is divided on whether individuals with a perforated eardrum can be at risk of toxic substance exposure through the ear, even when using effective breathing apparatus For more details, see Appendix A.
Introduction
Section 6 highlights the importance of personal protective equipment (PPE) in oil and gas operations, particularly in environments where hydrogen sulfide levels may exceed 10 ppm or sulfur dioxide levels may surpass 2 ppm It emphasizes that merely having PPE is insufficient; comprehensive training for personnel on the selection, usage, inspection, and maintenance of this equipment is crucial for ensuring safety in these hazardous conditions.
Stationary Hydrogen Sulfide Monitoring Systems
Stationary hydrogen sulfide atmospheric monitoring systems in oil and gas operations must feature visual or audible alarms that are easily noticeable throughout the work area Daily checks of direct current (DC) system batteries are essential unless an automatic low voltage alarm is in place Relevant guidelines can be found in the Instrument Society of America publications, ISA-S12.15 Part I and ISA-RP12.15.
Part II, contain equipment performance requirements and
In the article, Poda (1966) discusses the safe handling of hydrogen sulfide, emphasizing its environmental health implications Meanwhile, Ronk and White explore the risks associated with inhaling hydrogen sulfide through a tympanic membrane defect, highlighting the potential dangers of exposure Both studies contribute valuable insights into the safety measures and health risks related to hydrogen sulfide.
OccuporioMI Medicine, Vol 25, No 5,337-340, May 1985 `,,```,,,,````-`-`,,`,,`,`,,` -
For optimal operations in oil and gas production and gas processing plants involving hydrogen sulfide, it is essential to follow nine key recommendations for the installation, operation, and maintenance of monitoring and detection instruments For further information on the evaluation and selection of hydrogen sulfide monitoring equipment, please refer to Section 10.
Portable Detection Equipment
Portable hydrogen sulfide detection instruments must be available if atmospheric concentrations of hydrogen sulfide reach or exceed the levels specified in Par 6.1 For detailed information on the evaluation, selection, maintenance, and use of these detection devices, refer to Section 10 In cases where hydrogen sulfide concentrations may surpass the measurement range of the current detection instruments, a pump and colorimetric indicator tube detector, along with a supply of detector tubes, should be on hand to obtain instantaneous "grab" samples for assessing hydrogen sulfide levels in enclosed facilities, storage tanks, and vessels.
In situations where sulfur dioxide levels may reach or exceed the limits set in Par 6.1, such as during flaring or other operations, it is essential to have portable sulfur dioxide detection instruments or length-of-stain detectors available, along with a supply of detector tubes These tools are necessary for measuring sulfur dioxide concentrations and monitoring areas affected by sulfur dioxide gas when burning fluids containing hydrogen sulfide Additionally, personnel must wear appropriate personal breathing equipment, as outlined in Par 6.4, unless it has been confirmed that the atmosphere in the work area is safe.
Breathing (Respiratory Protection) Equipment
Face Piece Restrictions
Full face piece breathing equipment that complies with Par 6.4 is essential when the atmosphere contains more than 10 ppm of hydrogen sulfide or 2 ppm of sulfur dioxide Personnel must avoid wearing eyeglasses with temple bars that penetrate the sealing edge of the face piece However, approved adapters allow for the installation of corrective prescription lenses within the breathing apparatus face piece.
As of now, the U.S Department of Labor (OSHA) prohibits the use of contact lenses while wearing respirator breathing equipment, as stated in 29 Code of Federal Regulations Part 1910.134(e)(5)(ii) OSHA has conducted investigations regarding this restriction and released a field memorandum on February 8.
1989, Thomas Shepich, Director, Directorate of Compliance
Programs) stating their intent to modify the rule and issuing an interim enforcement policy as follows: a Violations of the Respiratory Protection Standard (29
The use of gas permeable and soft contact lenses, as outlined in the Code of Federal Regulations Part 1910.134, must be documented in case files and classified as de minimis, with no citations issued Additionally, any evidence of negative effects related to wearing contact lenses while using respirator breathing equipment should be reported to the U.S Department of Labor (DOL).
Occupational Safety and Health Administration (OSHA),
Directorate for Compliance Programs, Washington, D C
20210 Benefits associated with the use of contact lenses with respirator breathing equipment would be useful to
OSHA The issue of use of non-gas-penneable hard contact lenses will be resolved in OSHA's revision of 29 Code of
Note: Companies should review available information and provide em- pioyee guidance regarding the use of contact lenses under respirator breath- ing equipment
Personnel must ensure that facial hair does not interfere with the proper sealing of face masks Before using assigned or randomly selected equipment, individuals should confirm that a secure face seal can be achieved If a satisfactory seal cannot be obtained, appropriate equipment must be provided, or the individual will be disqualified from working in hazardous conditions.
Air Supply
Breathing air quality shall meet requirements set forth in OSHA's Respiratory Protection Standard, 29 Code of Fed- eral Regulations Part 191 O 134, and shall at least meet Grade
D requirements as described in ANSI CGA G-7.1.
Compressors
Air breathing air compressors must comply with the standards outlined in 29 CFR Part 1910.134 of OSHA's Respiratory Protection Standard Additionally, the intake for these compressors should be situated in a contaminant-free area that is unclassified according to API RP500, Section B.
Inlet air for such compressors shall be monitored when con- ditions arise which permit possible contamination of the inlet air by toxic, flammable, or combustible gases.
Breathing Equipment Use
Personnel shall use breathing equipment prior to entering an area where OSHA ACCs and PELS for hydrogen sulfide and sulfur dioxide, respectively, are exceeded (refer to Par
4.1, Appendices A and B, and 29 Code of Federal Regula- tions Part 191O.IOO0, Subpart Z, Table Z.1) until either the area is made or tested safe or they return to a safe area
Breathing equipment shall be put on in a safe area prior to either beginning a rescue operation or entering a hazardous environment.
Standby Rescue Personnel
In environments where hydrogen sulfide or sulfur dioxide levels are classified as immediately dangerous to life or health (IDLH), it is essential to have a trained standby rescue personnel equipped with suitable rescue gear, including appropriate breathing apparatus, to ensure safety in the working breathing zone.
Rescue Equipment
In environments where hydrogen sulfide, sulfur dioxide, or oxygen levels pose an immediate danger to life or health (IDLH), it is essential to provide suitable rescue equipment, such as appropriate breathing apparatus, lifelines, and harnesses The specific types of rescue equipment required will vary based on the nature of the job and the work being conducted It is crucial to consult with qualified health and safety professionals to identify the necessary rescue equipment tailored to the specific job and work conditions.
Wind Direction Indicators
Consideration should be given to locating windsocks, streamers, flags, or other suitable devices for indicating wind
For optimal safety in oil and gas operations involving hydrogen sulfide, it is essential to ensure that warning devices are clearly visible to all personnel approaching the work site.
Note: Regulatory requirements for wind direction indicators shall be ob-
Warning Signs
Legible warning signs, such as “HYDROGEN SULFIDE
SHOWS THE AREA TO BE SAFE” or “RESPIRATORY
"Prominently display 'BEYOND THIS POINT' signs at key locations, such as entrance points, in facilities that process or handle fluids containing hydrogen sulfide, as outlined in Paragraph 4.1 for applicability."
Note: Regulatory requirements for sign posting shall be observed
OPERATIONS-ENTER ONLY WHEN MONITORING
PROTECTION EQUIPMENT MUST BE WORN BE-
Operators must assess both current and future operations involving hydrogen sulfide and sulfur dioxide to ascertain the necessity for contingency plans, emergency procedures, and training This evaluation will pinpoint potential emergencies and their effects on personnel and the public If a contingency plan is deemed necessary, it must comply with all relevant local, state, and federal regulations concerning notifications, precautions, evacuations, and other requirements, as outlined in the 40 Code of Federal Regulations.
Pari 264, Subpart D; 29 Code of Federal Regulations Part
1910.120; and 29 Code ofFederalReguZations Part 1910.38 for EPA and OSHA requirements, respectively, for contin- gency plans and emergency procedures).
Scope
A contingency plan must include emergency response procedures that outline a structured immediate action plan for alerting and safeguarding both personnel and the public These plans should be tailored to the specific operations of the facility and take into account the potential severity and extent of atmospheric concentrations of hydrogen sulfide and sulfur dioxide Additionally, it is essential to consider the dispersion characteristics of these gases in the development of effective contingency plans.
(refer to Appendix C or other recognized dispersion mod- elling techniques) Contingency plans should contain provi- sions for all applicable items listed in this section (Refer to
Hazardous Materials Emergency Planning Guide, NRT- I , and Technical Guidance For Hazar& Analysis In addition to the contingency plan, Sections 302 and 303 of the Superfund
Amendments and Reauthorization Act of 1986 (SARA Title
A facility operator may be required to appoint an emergency coordinator to collaborate with the local emergency planning committee (LEPC) in creating an effective emergency response plan, as outlined in 40 Code of Federal Regulations Part.
Availability of Plan
The contingency plan shall be available to all personnel responsible for implementation, regardless of their noma1 location assignment
Contingency plans should contain, but not be limited to, information on the following subjects, as appropriate: a Emergency Procedures:
1 Responsibilities of personnel (refer to Par 7.5)
2 Immediate action plan (refer to Par 7.6)
3 Telephone numbers and communication methods (re- fer to Par 7.7)
4 Locations of nearby residences, businesses, parks, schools, churches, roads, medical facilities, etc
5 Evacuation routes and road block locations
6 Safety equipment and supplies available (e.g., number and location of breathing equipment) b Characteristics of Hydrogen Sulfide and Sulfur Dioxide:
1 Refer to Appendix A for hydrogen sulfide characteris- tics
2 Refer to Appendix B for sulfur dioxide characteristics
3 Wells, tank batteries, gas conditioning facilities, flow- lines
1 Responsibilities and duties of essential personnel
2 On-site or classroom (tabletop) drills
3 Informing nearby residents on protective measures in emergency situations, as appropriate
5 Briefing of public officials on issues such as evacua- tion or shelter-in-place20 plans c Facility Description, Maps, and Drawings: d Training and Drills (refer to Par 7.8):
Responsibilities of Personnel
The contingency plan will define the roles and responsibilities of all key personnel It is crucial to restrict access to areas contaminated by hydrogen sulfide, particularly when atmospheric concentrations exceed 10 ppm, to ensure the safety of visitors and non-essential personnel.
Shelter-in-place is a safety strategy designed to protect the public by instructing residents to remain indoors until emergency responders arrive or the emergency situation has concluded.
Provided by IHS under license with API
No reproduction or networking permitted without license from IHS
12 API RECOMMENDEC tion of sulfur dioxide exceeding 2 ppm in the atmosphere
(refer to Par 4 I and Appendices A and B).
Immediate Action Plan
An effective contingency plan must include a concise "Immediate Action Plan" for designated personnel to follow upon receiving notification of a potential hydrogen sulfide or sulfur dioxide discharge This plan is crucial for ensuring the safety of both personnel and the general public, and it should encompass essential measures such as alerting and accounting for all facility personnel.
1 Move away from the hydrogen sulfide or sulfur diox- ide source and get out of the affected area
2 Don proper personal breathing equipment
5 Proceed to the designated emergency assembly area
To ensure the safety of on-site personnel, it is crucial to take immediate action to control any current or potential discharges of hydrogen sulfide or sulfur dioxide and eliminate possible ignition sources If emergency shutdown procedures are necessary, they should be initiated promptly In situations where timely action cannot prevent exposure to hazardous concentrations of these gases, it is essential to alert the public, either directly or through government agencies, about potential exposure levels exceeding 30 ppm of hydrogen sulfide or 1021 ppm of sulfur dioxide Evacuation operations should then be initiated, and the designated supervisor on the call list must be contacted to inform them of the circumstances and any immediate assistance required.
Supervisors must ensure that all relevant personnel, including public officials, are notified as per the call list They should provide recommendations to public officials for blocking unauthorized access to unsafe areas and assist as needed Additionally, supervisors should advise on the evacuation of the public and offer appropriate support It is also essential to notify state and local officials, as well as the National Response Center, to fulfill release reporting requirements.
The Emergency Response Planning Guide Level 2 (ERpG-2) outlines critical safety measures regarding airborne concentrations of hazardous substances Specifically, the E m - 2 value represents the maximum airborne concentration that individuals can be exposed to for up to one hour without suffering irreversible health effects or impairments Compliance with regulatory requirements, such as those outlined in 40 Code of Federal Regulations Parts 302 and 355, is essential Additionally, it is crucial to monitor ambient air quality in the exposure area after implementing abatement measures to ensure safe re-entry.
Note: This sequence (Par 7.6) should be altered to fit the prevailing situa- tion Certain actions, especially those dealing with the public, should be co- ordinated with public officials.
Emergency Telephone Lists
Respiratory Problems
Individuals with recognized physiological or psychological conditions that hinder normal breathing should not be assigned to roles that may expose them to hydrogen sulfide or sulfur dioxide This is particularly important if the use of breathing equipment or exposure could exacerbate their respiratory issues For more information, consult OSHA’s Respiratory Protection Standard.
(29 Code of Federal Regulations Part 191 O i 34)
Personnel assigned to tasks involving the use of breathing equipment must undergo regular evaluations to assess their physiological and psychological fitness for this equipment, in accordance with 29 Code of Federal Regulations Part 1910.134 and ANSI 288.2.
The medical community is divided on whether individuals with a perforated eardrum can be at risk of toxic substance exposure through the ear, even when using effective breathing apparatus For more details, see Appendix A.
Section 6 discusses some personnel protective equipment that can be used in oil and gas well producing and gas pro- cessing plant operations where the work atmosphere concen- tration of hydrogen sulfide could exceed 10 ppm or sulfur dioxide atmospheric concentration could exceed 2 ppm (re- fer to Par 4.1 and Appendices A and B) Having personnel protective equipment available is not enough; training per- sonnel in the selection, use, inspection, and maintenance of the equipment is essential
6.2 STATIONARY HYDROGEN SULFIDE MONITORING SYSTEMS
Stationary hydrogen sulfide atmospheric monitoring systems in oil and gas operations must feature visual or audible alarms that are easily noticeable throughout the work area Daily checks of direct current (DC) system batteries are essential unless an automatic low voltage alarm is in place Relevant guidelines can be found in the Instrument Society of America publications, ISA-S12.15 Part I and ISA-RP12.15.
Part II, contain equipment performance requirements and
In the article, Poda (1966) discusses the safe handling of hydrogen sulfide, emphasizing its environmental health implications In contrast, Ronk and White examine the risks associated with inhaling hydrogen sulfide through a tympanic membrane defect, highlighting the potential dangers of exposure Both studies contribute valuable insights into the safety and health risks related to hydrogen sulfide.
OccuporioMI Medicine, Vol 25, No 5,337-340, May 1985 `,,```,,,,````-`-`,,`,,`,`,,` -
This article outlines nine essential recommendations for the installation, operation, and maintenance of hydrogen sulfide monitoring and detection instruments in oil and gas production and gas processing plants For further information on evaluating and selecting appropriate hydrogen sulfide monitoring equipment, please refer to Section 10.
Portable hydrogen sulfide detection instruments must be available if atmospheric concentrations reach or exceed the levels specified in Par 6.1 For details on the evaluation, selection, maintenance, and use of these detection devices, refer to Section 10 In cases where hydrogen sulfide concentrations may surpass the measurement range of the current instruments, a pump and colorimetric indicator tube detector, along with a supply of detector tubes, should be on hand to obtain instantaneous "grab" samples for measuring hydrogen sulfide levels in enclosed facilities, storage tanks, and vessels.
In situations where sulfur dioxide levels may reach or exceed the limits set in Par 6.1, such as during flaring or operations that generate sulfur dioxide, it is essential to have portable detection instruments or length-of-stain detectors, along with a supply of detector tubes, to monitor sulfur dioxide concentrations in affected areas Additionally, personnel must use appropriate personal breathing equipment, as outlined in Par 6.4, unless it is confirmed that the atmosphere in the work area is safe.
Site specific contingency plans shall be prepared to spec- ify the quantity and location of breathing equipment to be available Respirators shall meet the requirements of
OSHA's Respiratory Protection Standard (refer to 29 Code of Federal Regulations Part i 9 1 O 134) and be approved un- der procedures outlined in ANSI 288.2 All breathing air cylinders shall meet U.S Department of Transportation
(DOT) or other appropriate regulatory requirements (refer to
30 Code of Federal Regulations, Part 19 1 O 134, Chapter 1,
Subchapter B, Part II, Subpart H, Par 1 1.80 and 49 Code of
Federal Regulations Part 178, Subpart C) The following types of breathing equipment with full face piece meet these
A gas detection instrument is a combination of electrical, mechanical, and chemical components designed to continuously sense and respond to the presence of hazardous gases, such as hydrogen sulfide or sulfur dioxide, in the atmosphere One effective type of detector is a pump and colorimetric indicator tube system, which uses a pump to draw a known volume of air through a detector tube containing chemical reagents that indicate the concentration of these gases The length of the color band formed in the tube provides an immediate quantitative measure of the specific chemical present It is essential to use appropriate respiratory protection when atmospheric concentrations exceed 10 ppm for hydrogen sulfide or 2 ppm for sulfur dioxide Recommended equipment includes self-contained, positive-pressure breathing apparatus for any concentration of these gases, air-line breathing equipment with a self-contained unit rated for at least fifteen minutes, and air-line systems with auxiliary supplies for emergency escape.
1 Personnel assigned job-related tasks requiring routine use of breathing equipment shall have a periodic review to determine their physiological and psychological adequacy for use of this equipment (refer to ANSI Z 88.2 and
29 Code of Federal Regulations part 191 O 134)
2 Positive-pressmlpressure-demand, air-line or self-contained breathing apparatus, as appropriate, with full face piece shall be worn by personnel ex- posed to atmospheres containing concentrations of hydrogen sulfide or sul- fur dioxide above OSHA's ACCs and PELS for air contaminants (refer to 29
Code of Federal Regulations part 191 O loOO
Gas mask canister type breathing and demand type (negative pressure) equipment must not be utilized in oil and gas production or processing facilities where there is a potential for exposure to hydrogen sulfide or sulfur dioxide.
Storage and Maintenance
Personal breathing equipment must be strategically positioned for quick and easy access by essential personnel, who are responsible for ensuring safe operations and managing hazardous conditions related to hydrogen sulfide or sulfur dioxide Additional equipment may be necessary based on site-specific contingency plans It is crucial that breathing equipment is maintained and stored in a clean, sanitary location, in compliance with OSHA's Respiratory Protection Standard as outlined in the 29 Code of Federal Regulations.
All breathing equipment must be checked before and after each use, with monthly inspections to ensure satisfactory maintenance, as outlined in Part 1910.134 of the 29 Code of Federal Regulations Records of these inspections, including dates and findings, should be kept for at least twelve months, or longer if required by company policy Any equipment identified as needing repair must be addressed promptly.
Provided by IHS under license with API
No reproduction or networking permitted without license from IHS
Proper storage, maintenance, handling, and inspection of personal breathing equipment are crucial for ensuring its integrity Personnel assigned to this equipment must receive instruction on its proper maintenance, or alternative measures should be implemented to guarantee its reliability It is essential to adhere to the recommendations provided by NIOSH, OSHA, and the equipment manufacturer.
Full face piece breathing equipment that complies with Par 6.4 is essential in work areas where hydrogen sulfide concentrations exceed 10 ppm or sulfur dioxide levels exceed 2 ppm Personnel must avoid wearing eyeglasses with temple bars that penetrate the sealing edge of the face piece However, approved adapters allow for the installation of corrective prescription lenses within the breathing apparatus face piece.
As of now, the U.S Department of Labor (OSHA) prohibits the use of contact lenses while wearing respirator breathing equipment, as outlined in 29 Code of Federal Regulations Part 1910.134(e)(5)(ii) OSHA has conducted investigations regarding this restriction and issued a field memorandum on February 8.
1989, Thomas Shepich, Director, Directorate of Compliance
Programs) stating their intent to modify the rule and issuing an interim enforcement policy as follows: a Violations of the Respiratory Protection Standard (29
The use of gas permeable and soft contact lenses, as outlined in the Code of Federal Regulations Part 1910.134, must be documented in case files and classified as de minimis, with no citations issued Additionally, any evidence of negative effects related to wearing contact lenses while using respirator breathing equipment should be submitted to the U.S Department of Labor (DOL).
Occupational Safety and Health Administration (OSHA),
Directorate for Compliance Programs, Washington, D C
20210 Benefits associated with the use of contact lenses with respirator breathing equipment would be useful to
OSHA The issue of use of non-gas-penneable hard contact lenses will be resolved in OSHA's revision of 29 Code of
Note: Companies should review available information and provide em- pioyee guidance regarding the use of contact lenses under respirator breath- ing equipment
Personnel must ensure that facial hair does not interfere with the proper sealing of face masks Before using any assigned or randomly selected equipment, individuals should confirm that a secure face seal can be achieved If a satisfactory seal cannot be obtained, appropriate equipment must be provided, or the individual will be disqualified from working in areas with potential hazardous conditions.
Breathing air quality shall meet requirements set forth in OSHA's Respiratory Protection Standard, 29 Code of Fed- eral Regulations Part 191 O 134, and shall at least meet Grade
D requirements as described in ANSI CGA G-7.1
Air breathing air compressors must comply with the standards outlined in 29 CFR Part 1910.134 of OSHA's Respiratory Protection Standard Additionally, the intake for these compressors should be situated in a contaminant-free area that is unclassified according to API RP500, Section B.
Inlet air for such compressors shall be monitored when con- ditions arise which permit possible contamination of the inlet air by toxic, flammable, or combustible gases
Personnel shall use breathing equipment prior to entering an area where OSHA ACCs and PELS for hydrogen sulfide and sulfur dioxide, respectively, are exceeded (refer to Par
4.1, Appendices A and B, and 29 Code of Federal Regula- tions Part 191O.IOO0, Subpart Z, Table Z.1) until either the area is made or tested safe or they return to a safe area
Breathing equipment shall be put on in a safe area prior to either beginning a rescue operation or entering a hazardous environment
In environments where hydrogen sulfide or sulfur dioxide levels are classified as immediately dangerous to life or health (IDLH), it is essential to have a trained standby rescue personnel equipped with suitable rescue gear, including appropriate breathing apparatus, readily available in the working breathing zone.
In environments where hydrogen sulfide, sulfur dioxide, or oxygen levels pose an immediate danger to life or health (IDLH), it is essential to provide suitable rescue equipment, such as appropriate breathing apparatus, lifelines, and harnesses The specific types of rescue equipment needed will vary based on the job and work conditions Therefore, it is crucial to consult with qualified health and safety professionals to identify the necessary rescue equipment tailored to the specific site and tasks at hand.
Consideration should be given to locating windsocks, streamers, flags, or other suitable devices for indicating wind
For optimal safety in oil and gas operations involving hydrogen sulfide, it is essential to ensure that warning devices are clearly visible to all personnel approaching the work site.
Note: Regulatory requirements for wind direction indicators shall be ob-
Legible warning signs, such as “HYDROGEN SULFIDE
SHOWS THE AREA TO BE SAFE” or “RESPIRATORY
"Signs stating 'BEYOND THIS POINT' must be clearly displayed at key locations, such as entrance points, in facilities where fluids containing hydrogen sulfide are processed or handled, as outlined in Paragraph 4.1."
Note: Regulatory requirements for sign posting shall be observed
OPERATIONS-ENTER ONLY WHEN MONITORING
PROTECTION EQUIPMENT MUST BE WORN BE-
Introduction
Operators must assess both current and new operations involving hydrogen sulfide and sulfur dioxide to determine the necessity of contingency plans, emergency procedures, and training This evaluation will identify potential emergencies and their effects on personnel and the public If a contingency plan is deemed necessary, it must comply with all relevant local, state, and federal regulations concerning notifications, precautions, evacuations, and other requirements, as outlined in the 40 Code of Federal Regulations.
Pari 264, Subpart D; 29 Code of Federal Regulations Part
1910.120; and 29 Code ofFederalReguZations Part 1910.38 for EPA and OSHA requirements, respectively, for contin- gency plans and emergency procedures)
A contingency plan must include emergency response procedures that outline a structured immediate action plan for alerting and safeguarding both personnel and the public These plans should be tailored to the specific operations of the facility and take into account the potential severity and extent of atmospheric concentrations of hydrogen sulfide and sulfur dioxide Additionally, it is essential to consider the dispersion characteristics of these gases in the development of effective contingency plans.
(refer to Appendix C or other recognized dispersion mod- elling techniques) Contingency plans should contain provi- sions for all applicable items listed in this section (Refer to
Hazardous Materials Emergency Planning Guide, NRT- I , and Technical Guidance For Hazar& Analysis In addition to the contingency plan, Sections 302 and 303 of the Superfund
Amendments and Reauthorization Act of 1986 (SARA Title
A facility operator may be required to designate an emergency coordinator to collaborate with the local emergency planning committee (LEPC) in creating an emergency response plan, as outlined in 40 Code of Federal Regulations Part.
The contingency plan shall be available to all personnel responsible for implementation, regardless of their noma1 location assignment
Contingency plans should contain, but not be limited to, information on the following subjects, as appropriate: a Emergency Procedures:
1 Responsibilities of personnel (refer to Par 7.5)
2 Immediate action plan (refer to Par 7.6)
3 Telephone numbers and communication methods (re- fer to Par 7.7)
4 Locations of nearby residences, businesses, parks, schools, churches, roads, medical facilities, etc
5 Evacuation routes and road block locations
6 Safety equipment and supplies available (e.g., number and location of breathing equipment) b Characteristics of Hydrogen Sulfide and Sulfur Dioxide:
1 Refer to Appendix A for hydrogen sulfide characteris- tics
2 Refer to Appendix B for sulfur dioxide characteristics
3 Wells, tank batteries, gas conditioning facilities, flow- lines
1 Responsibilities and duties of essential personnel
2 On-site or classroom (tabletop) drills
3 Informing nearby residents on protective measures in emergency situations, as appropriate
5 Briefing of public officials on issues such as evacua- tion or shelter-in-place20 plans c Facility Description, Maps, and Drawings: d Training and Drills (refer to Par 7.8):
The contingency plan will define the roles and responsibilities of all key personnel It is crucial to restrict access to areas contaminated by hydrogen sulfide, particularly when atmospheric concentrations exceed 10 ppm, to ensure the safety of visitors and non-essential personnel.
Shelter-in-place is a safety measure designed to protect the public by instructing residents to remain indoors until emergency responders arrive or the crisis has passed.
Provided by IHS under license with API
No reproduction or networking permitted without license from IHS
12 API RECOMMENDEC tion of sulfur dioxide exceeding 2 ppm in the atmosphere
(refer to Par 4 I and Appendices A and B)
An effective contingency plan must include a concise "Immediate Action Plan" for designated personnel to follow upon notification of a potential hydrogen sulfide or sulfur dioxide discharge This plan is crucial for ensuring the safety of personnel and the general public, as well as for mitigating the discharge Key provisions of the "Immediate Action Plan" should encompass alerting and accounting for all facility personnel.
1 Move away from the hydrogen sulfide or sulfur diox- ide source and get out of the affected area
2 Don proper personal breathing equipment
5 Proceed to the designated emergency assembly area
To ensure the safety of on-site personnel, it is crucial to take immediate action to control any current or potential discharges of hydrogen sulfide or sulfur dioxide and eliminate possible ignition sources If emergency shutdown procedures are necessary, they should be initiated promptly In cases where timely action cannot prevent exposure to hazardous concentrations of these gases, it is essential to alert the public, either directly or through government agencies, about potential exposure levels exceeding 30 ppm of hydrogen sulfide or 1021 ppm of sulfur dioxide Evacuation operations should then be initiated, and the designated supervisor on the call list must be contacted to inform them of the situation and determine if immediate assistance is required.
Supervisors must ensure that all relevant personnel, including public officials, are notified promptly They should recommend measures to public officials for blocking unauthorized access to unsafe areas and assist in these efforts Additionally, supervisors should advise on the evacuation of the public and provide necessary support It is also essential to notify state and local officials, as well as the National Response Center, to fulfill release reporting requirements.
The Emergency Response Planning Guide Level 2 (ERpG-2) outlines critical safety measures regarding airborne concentrations of hazardous substances Specifically, the E m - 2 value represents the maximum airborne concentration that individuals can be exposed to for up to one hour without experiencing serious health effects Compliance with federal regulations, such as the 40 Code of Federal Regulations Parts 302 and 355, is essential Additionally, it is important to monitor ambient air quality in the exposure area after implementing abatement measures to ensure safety for re-entry.
Note: This sequence (Par 7.6) should be altered to fit the prevailing situa- tion Certain actions, especially those dealing with the public, should be co- ordinated with public officials
A list of emergency telephone numbers should be pre- pared and maintained as a part of the contingency plan, con- sidering the need to contact any of the following: a Emergency Services
4 State and Local Law Enforcement Agencies
7 Other applicable government agencies c Operator and Contractors
3 Applicable service companies b Government Agencies and Contacts d Public
Training and drills are crucial for effective emergency response in oil and gas operations involving hydrogen sulfide or sulfur dioxide It is essential that all personnel designated in the emergency response plan receive the necessary training.
Training must emphasize the significance of each individual's role in executing an effective emergency response Simulated exercises or drills are essential for demonstrating the importance of contingency plans and ensuring they remain up-to-date These exercises can range from tabletop discussions to realistic drills involving equipment deployment, communication testing, and the transport of simulated injured "victims" to hospitals It is crucial to involve public officials in these exercises Following the testing of a plan, it should be revised and retested until those responsible are confident in its operational effectiveness.
I : Hazardous Materiais Emergency Planning Guide
RECOMMENDED PRACTICES FOR OIL AND GAS PRODUCING AND GAS PROCESSING PLANT OPERATIONS INVOLVING HYDROGEN SULFIDE 13
A contingency plan shall be periodically reviewed and up dated any time its provisions or coverage change (refer to
The recommendations in Section 8 are relevant for operations in production and gas processing plants that manage fluids with significant hydrogen sulfide content, aligning with NACE Standard MROI 75 This standard can also serve as a valuable guideline for the design and construction of additional facilities that handle hydrogen sulfide.
Appendix D for information on defining a sour environment
All pressure vessels must be designed and constructed in compliance with the ASME Boiler and Pressure Vessel Code, as outlined in the Synopsis of Boiler and Pressure Vessel Laws, Rules, and Regulations by various states, cities, counties, and provinces.
(United States und Canada)] All piping systems should be designed and constructed in accordance with applicable pro- visions of ANSI B31.3 ANSI B31.4, OR ANSI 831.8
Manufactured equipment must be designed, constructed, tested, and approved to meet or exceed the system requirements for hydrogen sulfide service Additionally, installation should comply with relevant codes and industry standards.
When designing a facility, it is essential to consider various factors such as hydrogen sulfide concentration, atmospheric and operating temperatures, system pressures, pH levels, and water content in fluids Additionally, mechanical stresses on components, changes in physical strength due to corrosion and scale deposits, and specific conditions related to individual processes that may negatively affect the system must also be taken into account.
To minimize internai corrosion, piping and vessels should be designed and installed in such a way that areas of insuffi- cient flow (including dead-end piping) are eliminated