Subject of Possible Rule Making: The purpose of this rule making is to make permanent exemptions to the odorization requirements of WAC 480-93-015 for operators of class 1 and 2 renewable natural gas (RNG) transmission facilities (pipelines) with hydrogen sulfide (H2S) present in the gas. These exemptions were added by emergency rule making at WSR 23-23-059. WAC 480-93-015(2) previously required all gas pipeline operators, without exception, to odorize their lines and perform a sniff test to detect odorization. Because H2S is toxic to humans, class 1 and 2 transmission pipelines where H2S is present should be exempt from the odorization and sniff test requirements to prevent injuries that would be incurred by meeting the sniff test requirement.

Reasons Why Rules on this Subject may be Needed and What They Might Accomplish: To meet the odorization requirements of WAC 480-93-015 prior to the emergency rule amendment, operators of class 1 and 2 RNG transmission pipeline facilities were required to put employees at significant risk of injury. Performing a sniff test when H2S is present in the pipeline exposes the tester to a substance that is toxic and hazardous. Exempting odorization of these lines, in addition to exempting the sniff test, is necessary because the addition of odor without confirmation via a sniff test makes the effectiveness of odorization questionable. Additionally, if odorization is not being checked via a sniff test, this may result in under-odorization which could cause leaks to go unnoticed. Unodorized lines are required under WAC to be checked each month via a gas leak survey. The proposed permanent revisions include the requirement that under the exempted circumstances, operators must be able to otherwise demonstrate impurity levels.

Interested parties can participate in the decision to adopt the new rule and formulation of the proposed rule before publication by contacting Kathy Hunter, Acting Executive Director and Secretary, P.O. Box 47250, Olympia, WA 98504-7250, phone 360-701-1612, fax 360-586-1150, website www.utc.wa.gov.