Sample Letter to WVDEP Regarding Hydrostatic Testing Rules

April 25, 2017

Division of Water and Waste Management
​Attention: Mylinda Maddox
57th Street SE
Charleston, WV 25304-2345
Re: Permit WV0113069: Hydrostatic Test Water
Ms. Maddox,
I respectfully submit the following comments on Permit WV0113069: Hydrostatic Test Water for your consideration:
The permit does not impose limitations on pollutants because they have not previously been perceived to be a problem. WVDEP needs to impose limitations of pollutants in the discharge water so that they will not be a future problem. WVDEP needs to Protect our Water.
There are no requirements limiting discharges within Zones of Critical and Peripheral Concern. WVDEP should prohibit discharges within source water protection areas.
There are no requirements limiting discharges in Karst terrain. Request WVDEP prohibit discharges in Karst terrain. Karst Terrain is very fragile and should be treated as such.
There are no requirements limiting discharges into Tier 3 streams. I request that the WVDEP prohibit discharges to Tier 3 streams. Our water is extremely important to our lives.
There are currently no requirements to disclose the additives used in the hydrostatic test water. WVDEP must require any permittee to list the additives to the hydrostatic testing water in order to better Protect Our Water.
The permit requires the permittee to discharge hydrostatic test water back to the original water source unless it is impractical. WVDEP should always prohibit out-of-basin transfers. Any discharge of water should be tested for hazardous substances before being returned to to any water basin.
With the massive buildout of new pipelines currently in progress, the general permit would cover 60 permits. We request WVDEP issue individual permits for larger pipelines with an opportunity for public comments.
WVDEP’s first mission should be to “Protect our Water” and not just “Say YES” to industry, as suggested by Governor Justice. That is your legal and moral responsibility.

Sincerely,

[author's name removed to protect privacy]