Articles

Are you managing hydrostatic test water correctly? 

 

October 10, 2024

 

In the oil and gas industry, the integrity of pipeline systems is paramount. One common method used to check this integrity is hydrostatic testing. This process involves filling the pipeline with water under pressure to test for leaks. While essential for safety and operational efficiency, it generates a significant amount of wastewater. The question is, are you managing this wastewater correctly?

 

Understanding hydrostatic test wastewater

 

The management of hydrostatic test wastewater is a critical environmental concern. If not handled properly, it can lead to contamination of soil and water bodies, posing risks to both the environment and public health.

 

Navigating regulatory exemptions (or lack thereof)

 

In the United States, the oil and gas exploration and production (E&P) exemption under the Resource Conservation and Recovery Act (RCRA) exempts certain wastes generated during oil and gas E&P activities from being classified as hazardous waste. However, does hydrostatic test wastewater fall under this exemption? The answer is not straightforward and can depend on several factors, including the source of the test water, the additives used, and the potential contaminants present. As such, it's best to treat each situation separately and perform an applicability determination for each project. Also, don't forget to check for any state-specific waste management regulations!

 

Chlorine content and NPDES

 

An important consideration in managing hydrostatic test wastewater is the chlorine content of the test water. Chlorinated water can cause issues and potentially trigger applicability for a National Pollutant Discharge Elimination System (NPDES) wastewater permit. Therefore, it’s crucial to test the water for chlorine content before discharge evaluate accordingly.

 

Best practices for managing hydrostatic test wastewater

 

Regardless of whether the wastewater meets the E&P exemption, responsible management is crucial. Here are some best practices:

 

  • Use techniques such to minimize the amount of waste generated during pipeline hydrostatic tests.
  • If feasible, treat the wastewater on-site to remove contaminants before discharge.
  • If on-site treatment is not possible, ensure that the wastewater is transported to a permitted treatment or disposal facility.
  • Talk to different waste disposal and recycling facilities and look into potentially reusing water for testing if legally and economically feasible.
  • If diesel or other items are used to clean the pipeline to prepare for, or in conjunction with testing, all RCRA hazardous waste considerations should be considered.

 

If we do our best to abide by these practices, we can ensure that our operations are not only efficient but also present a significant waste reduction opportunity.

 

The path forward

 

Managing hydrostatic test wastewater correctly is more than just an engineering problem. It’s a waste reduction opportunity that requires us to balance operational efficiency with environmental responsibility. As we continue to advance in the oil and gas industry, let’s strive not just for operational success, but also for waste reduction.

 

So, I leave you with this question: How are you managing your hydrostatic test wastewater, and what steps are you taking towards waste reduction in your operations?

 

Bonus tip: don't forget to set up secondary containments and drip pans if you're using air compressors, generators, light plants, frac tanks, mobile fuel tanks, etc. and to keep a spill kit handy. Do you have 1,320 gallons or greater of oil onsite? You may need to have an SPCC Plan.