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Application for a Permit to Discharge of Hydrostatic Test Water to Land Surface

Permit application for the discharge to land surface of hydrostatic test water used to test the integrity of natural gas, crude oil, or other pipelines or vessels under the jurisdiction of the Railroad Commission of Texas (RRC).

Note: As of January 15, 2021, any discharge of oil and gas hydrostatic test water to surface waters is under the jurisdiction of the Texas Commission on Environmental Quality (TCEQ). You can read more about these changes at our discharge information page.

The RRC will only issue permits authorizing discharge to land surface. If you will be discharging HT wastewater to surface waters, do not use this application. Visit the TCEQ website for information about hydrostatic test water discharges to surface water:  https://www.tceq.texas.gov/assistance/industry/oil-and-gas/oil-and-gas-wastewater-permits   

 

To ensure the efficient processing of your application, please read the Hydrostatic Test Discharge Permit Application Frequently Asked Questions and Permit Processing Time Savers as part of the preparation of your permit application.

An operator must apply for a "minor permit" to discharge hydrostatic test water to land surface. The operator must file a written application containing the following:

  1. Operator name, address, telephone number, and contact person. Note that unless otherwise specified in an application, the permit and correspondence will only be mailed to the operator’s P-5 address.

  2. Description of the pipeline or tank to be tested. Include information such as the location, dimensions, materials of construction, intended use, whether the pipeline or tank to be tested has been in service, for how long, and what type of service. Also, include whether a pipeline is a transmission line or a gathering line.

  3. Indicate whether the pipeline or tank to be tested has or will contain fluids with H2S concentrations of 100 ppm or greater.

  4. Identify the source of the water to be used for the test. (Should be a good quality water source such as a municipal water supply, drinking water well, irrigation well, clean source of surface water, etc.) Note: The use of surface waters may require a temporary water use permit from the Texas Commission on Environmental Quality (TCEQ). Contact the appropriate TCEQ district office for more information.

  5. Description of any chemicals to be added to the test water, the purpose for using the chemicals, and the concentrations to be used. Provide product literature and material safety data sheets.

  6. Projected dates for commencement and completion of the test and for commencement and completion of the discharge. Any permit issued will require notification of the Railroad Commission Pipeline Safety Office as soon as practical after any failure during testing.

  7. Estimation of the total volume of test water to be discharged in gallons and discharge rate in gallons per minute.

  8. Description of the location of the discharge point by latitude-longitude coordinates, by distance and direction from nearest post office or town.

  9. Include a topographic map clearly depicting the pipeline or tank, the fill point, the discharge point, and the nearest body of surface water. No hydrostatic test water may be discharged within 5 miles of a drinking water supply intake.

  10. Description of how the test water will be settled, filtered, or otherwise treated to prevent erosion and remove suspended solids, oil and grease, and other pollutants. (Any permit issued may require the permittee to sample and analyze the water being discharged and submit the results along with pictures of the treatment system and discharge.)

  11. Describe how test water will be stored prior to and after the testing is completed:

  • Will frac tank(s), vacuum or water truck(s) be used to fill or store the test water prior to filling the test pipe or tank(s)?
  • After hydrostatic testing is completed, will the test water be stored or staged in frac tank(s) prior to discharge?
  • Provide drawings, showing dimensions, any oil retention structures, (i.e. special piping, baffles, weirs, etc.) inside pits or tanks to minimize turbulence, control oil carry over and control water level, etc.

Note: Hydrostatic test water may require analytical testing prior to discharge. Analytical testing will be required if test water is stored in any pits, in frac tanks, or in trucks that have previously hauled waste. If the test water exceeds the limitations in Table 1 below, it is considered a hazardous waste by the U.S. Environmental Protection Agency (EPA) and must be handled, treated and disposed of in accordance with those regulations.

Table 1:  Hydrostatic Test Discharge Requirements
PARAMETER LIMITATIONS
Benzene (discharge to surface) 0.5 mg/L
Benzene (discharge to surface water) 0.05 mg/L
Oil & Grease 15 mg/L
Chemical Oxygen Demand Report
Electrical Conductivity Report
Total Suspended Solids Report
  1. If the test water will be allowed to drain across private property, include a statement that the landowner(s) have been notified of the proposed discharge and have not objected.

  2. If testing a used pipeline or tank, a concise description should be given on how the pipeline or tank will be cleaned prior to testing. (Any permit issued may contain limitations on the levels of benzene, oil and grease, or other parameters that may be present in the water to be discharged as shown in Table 1 above). At a minimum for a used pipeline, a volume of water equal to 300 linear feet of the pipeline, or 1000 gallons, whichever is greater, must be pigged through the line prior to filling for the test. This flush water may not be discharged under this permit and must be collected and disposed of properly.

  3. Include a signed statement certifying that no test water will reach surface waters of the state. Note that dry creeks, ponds, canals and ditches are considered surface waters.

  4. You must certify the application as follows:

"I certify that I am authorized to make this application, that this application was prepared by me or under my supervision and direction, and that the data and facts stated herein are true, correct, and complete to the best of my knowledge."

The application must be signed by the representative for the operator who is responsible for ensuring that the hydrostatic test water is disposed of in a proper manner.

Mail the original application, including all attachments to:

Railroad Commission of Texas 
Technical Permitting 
P.O. Box 12967 
Austin, Texas 78711-2967

Before any permit will be issued, the operator must have an active Organization Report (Form P-5) on file with the Austin Office of the Commission. For questions concerning the Form P-5 call the P-5 Department at 512-463-6772.



Commissioners