Surface Waste Management Manual

Application for a Permit to Discharge of Hydrostatic Test Water

Permit Application for the Discharge of Hydrostatic Test Water Used to Test the Integrity of Natural Gas, Crude Oil, or Other Pipelines or Vessels Under Jurisdiction of the Railroad Commission of Texas.

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. 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. If the discharged water will reach surface waters of the State, show the route of flow of the test water from the discharge point to the nearest body of surface water.

  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.) Also, a description of how dissolved oxygen will be restored to the test water if it is going to reach any surface water body. No hydrostatic test water may be discharged within 5 miles of a drinking water supply intake.

  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
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. There is a nonrefundable application fee for a permit to discharge oil and gas waste to surface waters of the state. EFFECTIVE MAY 1, 2012, the total application fee will now be $750, in accordance with Senate Bill 1 (82nd Legislature, First Called Session, 2011). Checks or money orders should be made payable to "Railroad Commission of Texas". Please do not send cash through the mail. This fee is an application fee and is not refundable even if your application is returned, withdrawn, or denied. If test water will not be discharged to surface waters, the fee is not required; however, a signed statement must be provided indicating that no test water will reach surface waters of the state. Note, a permit from the U.S. EPA may be required for a discharge to surface waters under the National Pollutant Discharge Elimination System (NPDES). Contact EPA Region 6 in Dallas for more information.

  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 operator’s representative responsible for ensuring that the hydrostatic test water is disposed of in a proper manner must sign the application.

File the application, including all attachments, with the Railroad Commission of Texas, Oil and Gas Division, Technical Permitting Section, P. O. Box 12967, Austin, TX 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.

Last Updated: 4/3/2018 7:36:54 AM