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As concerned citizens, we are troubled that the Trans-Pecos Pipeline system has not been thoroughly tested for leaks, or other failures, before burial in the ground. Energy Transfer Partners repeatedly promised at public meetings, and in writing, that 100% of the system welds would be inspected, and that the system would be thoroughly pressure tested at 1.1 to 1.5 times its maximum allowable operating pressure of 1,440psi.

Hydrostatic testing, which Energy Transfer Partners, and its contractor committed to perform, involves filling the pipeline system with pressurized water, potentially laced with chemicals, and testing for leaks or related failures. We have not seen any evidence of hydrostatic testing being performed before the pipe was buried and, after significant research, found permits for disposing waste water were just filed last week. This means they were either filed late, or that ETP may run much less effective tests after most of the pipe is buried. Either way, as this is a high-pressure gas pipeline with a 1/4 mile blast radius, we are very concerned.

Filling the entire 42”-diameter, 148-mile long pipeline system, just one time, requires 54 million gallons of water (54,000,000 gallons). In most cases, the water is treated with an oxygen-reducing chemical, and chemical corrosion inhibitors. Sometimes dyes are added, to make identification of leaks easier. In addition to the chemical additives, the hydrostatic testing water picks up more contaminants as it runs through the pipeline, including residual oils, lubricants, surface treatments, and metallic debris from welding and grinding operations. The water used in hydrostatic testing is thus contaminated, and considered hazardous waste, requiring permits for disposal. In this case, surface disposal is being used, which simply means dumping the contaminated water onto the surface of the soil, and relying on the ground itself to filter contaminants out of the water, before it reaches the groundwater sources, like our aquifer.

Hydrostatic testing involves filling the pipeline with water, under 1,440psi to 2,160psi of pressure, and detecting failures or leaks in the system, before it goes into service. This can be done in “sections,” while the pipeline is still exposed in welded “strings,” alongside the trench, and it can also be done after the pipeline is buried, although that makes identification of leaks and failures much more time-consuming and difficult, and requires excavating the pipeline to repair a failure. The activity is highly “visible,” requiring tanker trucks of water, high-pressure pumps, hoses, and significant activity on the right-of-way during testing.

Observers along the route have been monitoring construction. Among many anomalies, they were never able to observe hydrostatic testing activities, expected to be conducted along the construction spreads as the welded pipeline segments were completed. Now, much of the system is in the ground, buried. While hydrostatic testing is certainly still possible, any leaks in the system become difficult to locate, and repair after the pipeline is buried in the trench.

Additional investigation led to querying the Railroad Commission of Texas (RCT), as disposal of hydrostatic testing water, which is contaminated, requires a permit from the agency. Initially, no evidence of any permits, either in application form, pending, or issued showed up in the RCT’s publicly accessible database.

Beginning December 6, 2016, after being unable to locate any evidence of application, pending, or issued permits, BBCA’s research team contacted the Midland, District 8 RCT office, to inquire about the required disposal permits. RCT staffers were polite, and courteous, but were unable to locate any evidence of disposal permits at the local office level. After several referrals, a Midland office staffer provided a contact to one of RCT’s staff in Austin, in the division responsible for issuance of “Minor Permits,” under which the hydrostatic test water disposal permit falls. The Austin office staffer provided interesting insights:

He had recently issued two permits for Pumpco, the construction contractor for Trans-Pecos Pipeline, LLC; one permit authorizing surface disposal of 27,000 gallons of hydrostatic test water, and a second permit authorizing surface disposal of 1.6 million gallons of hydrostatic test water. Both permits were issued within the last working week. The RCT staffer indicated that often, “permit applications are the last thing on the contractor’s mind,” and often fall into last-minute, sometimes after-the-fact requests – he was unable to comment as to whether Pumpco had performed any, or all of the hydrostatic testing, or whether the surface disposal for either of the permits had taken place. Due to backlog, and inefficiencies in RCT’s systems, it may be several months before the permits appear in RCT’s electronic, on-line database, available to the public.

All we as citizens know for certain, is that there were two permits allowing surface disposal of 27,000 gallons, and 1.6 million gallons of contaminated water, issued by RCT for this project.

These HT Discharge permits are site-specific, and allow HT discharge only in the place specified by the permit, as issued, i.e. we would likely notice the discharge of 1.6 million gallons along the route, especially in an arid region like the Big Bend. When copies of the permits become available, we would know for certain where these surface discharges occurred.

Recall that filling the entire Trans-Pecos Pipeline system from end-to-end requires at least 54-million gallons of water, which the HT permits account for only about 1.6-million gallons. While it is possible to use a technique sometimes called “jumping,” or “shuttling” – testing the line segment-by-segment, and moving the water from one construction spread to an adjacent downstream spread, the difference between 54-million gallons (just for a complete, one-time end-to-end test) and 1.6-million gallons is significant (1.6-million gallons is about 2% of the water required to completely fill the pipeline).

For those who’ve been following the Trans-Pecos Pipeline project, recall that the company’s lead representative, Energy Transfer Partners, LP, and the construction contractor, Pumpco, indicated that 100% inspection of all welds, and complete hydrostatic testing of the system would be performed. These commitments were made in multiple public meetings, and on the company’s informational web site for the project (http://www.transpecospipelinefacts.com/safety.html…). All we have as citizens is the word of the company and contractor representatives.

In this environment, it is highly likely that observers along the route would have noticed hydrostatic testing activity, and consequent discharge of large volumes of hydrostatic test water if it had already occurred. As the system nears completion, and if you are an observer, be on the look out for evidence of testing, and re-excavation of portions of the system, which will require discharge of significant volumes of water, and activity to repair any leak or failure that is detected. If you are able to observe this activity, without trespassing, feel free to notify info@bigbendconservationalliance.org by email.

Related to this research, in conducting the search for the HT Discharge permits, it appears that Trans-Pecos Pipeline, LLC’s T4 Operating Permit, T09352 is no longer available in the RCT’s database, nor does it appear in the RCT’s GIS Viewer (mapping system). Texas Public Information Act / Open Records requests were filed on December 8, 2016, for copies of the HT Discharge permits, and a copy of the valid T4 operating permit. At this late stage, it is curious that the T4 Operating Permit, which is required for the operation of the pipeline, as well as the legal aspects of eminent domain condemnation, used in 39 cases to obtain easement for the project by force of the court, is absent from the RCT’s public records.