I have been looking at different posts and reading statements regarding concerns of H2S and safety.

I have many friends in the area which state the concentrations are very high all up and down the EFS.

So I went looking...at the RRC...man they have a really old and slow system, but with a little persistence and digging I believe I understand.

H-9's are submitted before a well is drilled!!

When the RRC decides a well is going through a known field of known H2S, the RRC, as it reviews the applicants W-1 request for permit to drill, stipulates the location is subject to SWR36.

State Wide Rule 36 states the need for a contingency plan to be created if public or a public road will be within the potential AOE (Area of Exposure). AOE??? the well has not been drilled?? to calculate the AOE, the H2S
PPM has to be known... how can an AOE be calculated since the well has not been drilled???

The RRC allows the applying operator to use a close by well....wait does this sound like a xerox of a xerox of a xerox?? additionally, nothing requires actual testing to be submitted for public access after the well is completed.

Like I stated before, I have friends that are safety techs working in many of the counties of the EFS, some of the sample readings are well into 1,000PPM's many times over. H2S is very dangerous in these ranges. They tell me a well which has H2S and flared has a blueish green flame...oh and smells horrible.

I think we have to much trust and the public should be aware, this is dangerous stuff.
I should state not all wells in the EFS have H2S and H2S is not caused by the drilling process or an operator, it is a natural occurrence.

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Comment by Mark on March 25, 2013 at 5:22pm

I know that H-9's are filed for every completed well if there is H2S in the gas stream based on post frac gas analysis. During the permitting process, the operator will err on the safe side as to indicating that H2S is a possibility.

The variability of H2S in the EF is both interesting and puzzling. I have seen wells with 200-3000 ppm offset by wells with no H2S. Underscores the heterogeneity of the EF not just as to reservoir qualty but also as to geochemical variability and complexity.

Lateral location / target zone is also important - getting horizontal too close to the Buda may cause frac to "grow" into that interval - which is oftentimes sour (different hydrocarbon source than for EF section).

The biggest issue (outside of safety and its nuisance value due to odor and equipment corrosion capabilities) is the need for special handling (i.e. pipelines) to get this gas to processing plant to strip out the sour components and get the residual clean gas put into pipeline for marketing. Many EF wells have been shut in for extended periods as operators wait on sour gas pipeline gathering systems to be laid to the wells in question.

Crude oil / condensate associated with sour gas also tends to carry a sulfur component - which usually mean different trucking options to keep the sour oil from contaminating sweet oil.

Below is a link to the Tx RRC site that has H2S listings for various fields sorted by Districts. Check out Districts 1 & 2 for Eagle Ford fields and reported sour gas info.


Just another nasty by product of O&G operations.

Comment by Dana Pearce on April 8, 2013 at 11:32am

H-9's are filed before the drilling of a well based on nearby activities in order for the RRC to confirm when (at what depth) the monitoring/alarm system will be activated on the rig.  We usually ran the equipment after the surface casing was cemented.  It could be activated a day or two later when we got close to the depth where we encountered the formation containing it.  We usually started monitoring about 350' above the top of that zone - just to be on the safe side.

The RRC does come out and check if the equipment is working properly by the way.


Comment by Mark on April 8, 2013 at 11:39am

Thanks Dana - good info.

I have been involved with EF wells drilled in LaSalle County where we had zero H2S indicators while drilling (mudlogging sensors) but after frac had sour gas. Figure we frac'd and hooked up into fault / fracture system that rooted down into Buda / Georgetown / Edwards et al sour environment.

Comment by Jimmy Wells on April 26, 2013 at 4:10pm

The point of my first post regarding the PPM on the original H-9 prior to drilling and xerox of a xerox is the information posted does not change after the well is fracked or completed. The written copy held at the local district office is placed in a binder and placed on a shelf. Unless the O&G company decides to submit a revised H-9 the original PPM stands for the next well to use.



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