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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-04-0103 ([Northern Border Pipeline Company] [Mr. Jose L. de la Fuente])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Northern Border Pipeline Company

Individual Name: Mr. Jose L. de la Fuente

Location State: NE Country: US

View the Interpretation Document

Response text:


Mr. Jose L. de la Fuente
Pipeline Integrity Program Management
Northern Border Pipeline Company
P.O. Box 542500
Omaha, NE 68154-8500

Dear Mr. de la Fuente:

This is in response to your letter of March 23, 2004, in which you request an interpretation of the provisions of the Federal gas pipeline safety regulations at 49 CFR 192.625(b)(1), which requires odorization of gas in a transmission line in a Class 3 or Class 4 location unless "at least 50 percent of the length of the line downstream from that location is in a Class 1 or Class 2 location."

You note that Northern Border Pipeline Company (NBPL) owns only the first 2.7 miles (more than 50% Class 3) of a continuous 86.3 mile pipeline segment serving an underground gas storage facility. The remaining 84 miles of the line is owned by Peoples Gas Light and Coke Company (Peoples) and is predominately Class 1. The question is whether odorization is required in the NBPL portion of this pipeline because more than 50% of the NBPL-owned pipeline is in a Class 3 location.

The odorization requirements of § 192.625 are not dependent on pipeline ownership— which can change— but rather on the configuration and operations of a pipeline segment, which will remain relatively fixed. NBPL would not have to odorize gas in the 2.7 mile segment because it is an integral part of an 86.3 mile line to a gas storage facility. If this line were under a single ownership, it is clear that odorization would not be required, and there is no reason to make odorization dependent on ownership.

Therefore, odorization is not required by § 192.625 if at least 50 percent of the ENTIRE line downstream from a Class 3 or Class 4 location is in a Class 1 or Class 2 location.

If you have any further questions about the pipeline safety regulations, please contact me at (202) 366-4565.


Richard D. Huriaux, P.E.
Manager, Regulations
Office of Pipeline Safety

Regulation Sections

Section Subject
192.625 Odorization of gas