A History of the Development of Rule 36
- J.E. Smith (Petro-Management Inc.)
- Document ID
- Society of Petroleum Engineers
- Journal of Petroleum Technology
- Publication Date
- October 1977
- Document Type
- Journal Paper
- 1,227 - 1,234
- 1977. Society of Petroleum Engineers
- 4.1.2 Separation and Treating, 4.1.5 Processing Equipment, 4.2 Pipelines, Flowlines and Risers, 4.2.3 Materials and Corrosion, 1.6 Drilling Operations, 6.2.4 Industrial Hygiene, 4.1.4 Gas Processing, 6.1.5 Human Resources, Competence and Training
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Rule 36 concerns the safe design and operation of oil and gas activities involving hydrogen sulfide. This paper reviews the engineering concepts behind the regulation and how they were applied.
Rule 36, issued by the Railroad Commission of Texas on March 15, 1976, and put into effect on Sept. 1, 1976, is a regulation developed to assure the safe design and operation of oil and gas activities that must handle hydrogen sulfide. The application of the nile has expanded to become an industry guideline for this type of operation.
In developing the regulation, it was necessary to apply certain engineering concepts. This paper reviews these concepts and the manner in which they were applied.
Ensuring the safety of the general public is one of the highest callings of the professional engineer. Insight into the engineering criteria on which Rule 36 was based will assist the engineer in its effective application.
When the Railroad Commission of Texas began developing its regulation for ensuring the public safety, it was determined that the following criteria would be considered: (1) nature and toxicity of hydrogen sulfide, (2) radius of exposure, (3) specifications for materials and equipment, (4) notification and protection of the public, and (5) applicability of the rule.
Smith presents the conditions that would be necessary for a public hazard to exist: (1) there must be a leak; (2) the leak must have volume and concentration that will cause a toxic condition; (3) there must be a weather condition that does not cause dispersion; and (4) there must be a public to be exposed to the gas.
The engineering concepts used to develop Rule 36 are (1) determination of the toxic effect on humans, (2) determination of the H2S concentration in the system, (3) determination of the escape rate, (4) determination of the radius of exposure, (5) determination of the area of exposure, (6) selection of limiting radius, (7) analysis of the phenomena of sulfide stress cracking and hydrogen phenomena of sulfide stress cracking and hydrogen embrittlement, (8) analysis of the criteria for determining susceptibility to sulfide stress cracking, (9) determination of means of H2S detection in atmosphere, (10) determination of requirements for leak detection, and (11) determination of the requirements of contingency planning.
Fig. 1 (from Smith 2) outlines the major H2S areas in Texas. Table 1 (from Smiths) is a general outline of Texas Rule 36.
The following discussion outlines the engineering concepts and how they were used in developing the rule.
Effect on Humans
To ensure that any potentially harmful concentration would be considered, it was necessary to determine the effect of H2S on humans Tables 2 and 3 (tom the API) present data on this effect. Based on these data, the present data on this effect. Based on these data, the 100-ppm H2S concentration was selected as the base line. The 500-ppm H2S concentration was selected as the so-called knock-down limit. The Railroad Commission hearing transcripts further support these selections. Atherton and ANSI Standard 237.2 (1968) describe the limit for effects on humans.
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