The process for obtaining a permit for vessels requires strong attention to detail.

The pipeline is full of water, pressurized, held and monitored, and passed all the tests. Now release the water and get ready to fill that pipeline with natural gas. Wait!  Is a permit needed to discharge all that water?

The simple answer is yes, a permit is required to discharge water used to test the integrity of certain vessels. A vessel may be defined as a pipeline, tank, or similar device used to store, transport, or contain a liquid or gaseous material.

In some states, like Oklahoma, discharges of test water from oil and gas pipelines require a permit from the Oklahoma Corporation Commission, while discharges from vessels not associated with oil and gas are regulated by the Oklahoma Department of Environmental Quality. In Texas, you may need a multiple permits from the Railroad Commission and the Texas Commission on Environmental Quality.

Each agency may require different information to complete the permit application, but in general the following is required:

  1. Operator name, address, telephone, and contact person.
  2. Description of vessel tested, including location, dimensions, intended use, and materials of construction.
  3. Description of any chemical added to the test water.
  4. Source of test water (municipal, water well, surface water, etc.)
  5. Dates of commencement and completion of test.
  6. Estimate of volume discharged and discharge rate.
  7. Description of discharge location.
  8. Map indicating location of vessel, fill point, discharge point, and nearest surface water.
  9. Best Management Practices to prevent erosion and remove suspended solids, oil and grease, and other pollutants.
  10. Permit fee.

While this is not an exhaustive list, it does indicate the time and attention to detail required when submitting a complete permit application to the appropriate permitting agency. Most often, an applicant will not provide the appropriate detail for the application, increasing the time to receive a permit. Pay attention to the detail, read all the instructions, and contact RS&H with questions.

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Elizabeth High

Elizabeth High

Environmental Specialist II at RS&H, Inc.

Liz is as an environmental specialist and Geographic Information System (GIS) analyst in the San Antonio office. She has over six years of experience in environmental compliance consulting and permitting with an emphasis on GIS and spatial analysis.

Contact Liz: Elizabeth.High@rsandh.com

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