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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-78-004 ([Cities Service Gas Company] [Mr. Richard H. Ruth])

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

Interpretation Response Details

Response Publish Date:

Company Name: Cities Service Gas Company

Individual Name: Mr. Richard H. Ruth

Location State: OK Country: US

View the Interpretation Document

Response text:

Mr. Richard H. Ruth

Cities Service Gas Company

P.O. Box 25128

Oklahoma City, Oklahoma 73125

Dear Mr. Ruth:

This refers to your letter of January 4, 1978, asking whether Cities Service's Cleveland 4-inch natural gas pipeline was required by the Department's gas pipeline safety regulations (49 CFR Part 192) to be odorized on February 27, 1976, and whether those regulations require odorization of the line at the present time.

The odorization requirements of Part 192 (in effect since June 4, 1975) are contained in Section 192.625. The applicability of those requirements to the Cleveland 4-inch line depends on whether the line is classified under Part 192 as a "distribution line" or a "transmission line."

As defined in Section 192.3, a "distribution line" is "a pipeline other than a gathering line or transmission line." A "transmission line" is defined, in pertinent part, as "a pipeline, other than a gathering line, that...[t]ransports gas from a gathering line or storage facility...." Also, a "gathering line" is "a pipeline that transports gas from a current production facility to a transmission line or main."

Under these definitions, a pipeline is classified according to its function in the transportation of gas. It appears from the information submitted that the primary function of the Cleveland 4-inch line is to transport gas to the City of Cleveland's distribution system. It further appears that the gas being delivered is supplied by a series of interconnected pipelines running from certain gathering fields in Oklahoma. Given these circumstances, we find that the Cleveland 4-inch line is properly classified under the above definitions as a "transmission line."

Under the provisions of Section 192.625, gas in transmission lines was not required to be odorized until January 1, 1977, except for gas in transmission lines in States where odorization
was required by the interim standards of Part 190 (see §192.625(g)). Since Oklahoma is not such a State, odorization was not required for gas in the Cleveland 4-inch line on February 27, 1976.

We are unable to determine whether, at the present time, gas in the Cleveland 4-inch line must be odorized. This question is answered by applying the provisions of Section 192.625(b); and your letter does not contain the information needed to apply this Section to the Cleveland line. Specifically, information is needed as to the Class locations along the pipeline, as defined by Section 192.5, and their lengths and relative positions. Under Section 192.5, a pipeline's Class location is defined in terms of the number of "buildings intended for human occupancy" within 220 yards on each side of the line. While we would be happy to offer any additional assistance you consider necessary, it should not be difficult to decide whether the Cleveland line must be odorized once the requisite information is obtained.

We are enclosing your letter, Exhibits A and B attached thereto, and a copy of 49 CFR Part 192 as you have requested.


Cesar DeLeon

Acting Director

Office of Pipeline

Safety Operations


Regulation Sections

Section Subject
192.625 Odorization of gas