{"operation":"document","citation":"PI-78-004","title":"Cities Service Gas Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1978-01-24","effective_on":null,"summary":"PI-78-004 response to Cities Service Gas Company concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-004","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/PI78004.pdf","body":"<<<PAGE 1>>>\n\nJanuary 24, 1978\nMr. Richard H. Ruth\nCities Service Gas Company\nP.O. Box 25128\nOklahoma City, Oklahoma 73125\nDear Mr. Ruth:\nThis refers to your letter of January 4, 1978, asking whether Cities Service's Cleveland 4-inch\nnatural gas pipeline was required by the Department's gas pipeline safety regulations (49 CFR Part\n192) to be odorized on February 27, 1976, and whether those regulations require odorization of\nthe line at the present time.\nThe odorization requirements of Part 192 (in effect since June 4, 1975) are contained in Section\n192.625. The applicability of those requirements to the Cleveland 4-inch line depends on whether\nthe line is classified under Part 192 as a \"distribution line\" or a \"transmission line.\"\nAs defined in Section 192.3, a \"distribution line\" is \"a pipeline other than a gathering line or\ntransmission line.\" A \"transmission line\" is defined, in pertinent part, as \"a pipeline, other than a\ngathering line, that...[t]ransports gas from a gathering line or storage facility....\" Also, a\n\"gathering line\" is \"a pipeline that transports gas from a current production facility to a\ntransmission line or main.\"\nUnder these definitions, a pipeline is classified according to its function in the transportation of\ngas. It appears from the information submitted that the primary function of the Cleveland 4-inch\nline is to transport gas to the City of Cleveland's distribution system. It further appears that the\ngas being delivered is supplied by a series of interconnected pipelines running from certain\ngathering fields in Oklahoma. Given these circumstances, we find that the Cleveland 4-inch line is\nproperly classified under the above definitions as a \"transmission line.\"\nUnder the provisions of Section 192.625, gas in transmission lines was not required to be\nodorized until January 1, 1977, except for gas in transmission lines in States where odorization\nwas required by the interim standards of Part 190 (see §192.625(g)). Since Oklahoma is not such\na State, odorization was not required for gas in the Cleveland 4-inch line on February 27, 1976.\nWe are unable to determine whether, at the present time, gas in the Cleveland 4-inch line must be\nodorized. This question is answered by applying the provisions of Section 192.625(b); and your\nletter does not contain the information needed to apply this Section to the Cleveland line.\nSpecifically, information is needed as to the Class locations along the pipeline, as defined by\nSection 192.5, and their lengths and relative positions. Under Section 192.5, a pipeline's Class\nlocation is defined in terms of the number of \"buildings intended for human occupancy\" within\ndal\\192\\625\\78-01-24\n1\n\n<<<PAGE 2>>>\n\n220 yards on each side of the line. While we would be happy to offer any additional assistance\nyou consider necessary, it should not be difficult to decide whether the Cleveland line must be\nodorized once the requisite information is obtained.\nWe are enclosing your letter, Exhibits A and B attached thereto, and a copy of 49 CFR Part 192\nas you have requested.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\nEnclosures\ndal\\192\\625\\78-01-24\n2\n\n<<<PAGE 3>>>\n\nJanuary 4, 1978\nMr. Cesar DeLeon\nOffice of Pipeline Safety\nDepartment of Transportation\nOperations Division\n2100 Second Street, Southwest\nWashington, D.C. 20590\nRE: Request for Regulatory Ruling\nand Opinion Concerning Department\nof Transportation Ododrization\nRequirements\nDear Mr. De Leon:\nPursuant to our telephone conversation on January 4, 1978, I now forward to you the\ninformation which follows, and request an official ruling and opinion from your office as to the\nfollowing:\n(1) Whether Department of Transportation regulations required odorization of\nnatural gas within Cities Service's Cleveland 4-inch natural gas pipeline as\nof February 27, 1976, and;\n(2) Whether Department of Transportation regulations presently require\nodorization of said gas in said pipeline.\nThe opinion which we request is to be used in civil litigation in the District Court of\nPawnee County, Oklahoma, on January 23, 1978 in the case of Margie Davis v. City of\nCleveland, Oklahoma, and Cities Service Gas Company, No. C-76-146 and No. C-77-190,\nwherein Cities Service Gas Company is charged with negligence in failure to odorize its gas in its\naforesaid Cleveland 4-inch pipeline.\nThe small map attached to this letter and marked as Exhibit A depicts the entire pipeline\nsystem of Cities Service Gas Company. Cities Service's Cleveland 4-inch pipeline in encircled on\nExhibit A in red ink. The large map attached to this letter as Exhibit B is a more detailed map\ndepicting the Cleveland\n4-inch pipeline and other facilities in its vicinity. The Cleveland 4-inch pipeline is marked in\nyellow on Exhibit B.\ndal\\192\\625\\78-01-24\n3\n\n<<<PAGE 4>>>\n\nThe primary purpose of the Cleveland 4-inch pipeline is to transport natural gas from\nCities Service's 16-inch pipeline to a delivery point at the north end of the Cleveland 4-inch line\nfor delivery and sale to the municipal gas distribution system owned by the City of Cleveland,\nOklahoma. This delivery point is referred to as the Cleveland Town Border.\nAt all times pertinent hereto eleven rural domestic farm tap customers received natural gas\nservice from taps located on the Cleveland 4-inch line. In addition, two taps on this line serve oil\ncompanies with natural gas for use in oil pumping engines. Although the natural gas within the\nCleveland 4-inch pipeline itself is not and was not odorized, the natural gas served to the domestic\ncustomers is odorized at the respective taps. Otherwise, the natural gas flowing in the Cleveland\n4-inch pipeline is not odorized, and is delivered to the municipal distribution system in the City of\nCleveland, Oklahoma at the Cleveland Town Border in an unodorized state. After this delivery\nthe natural gas enters facilities owned by the City of Cleveland, and title thereto passes to the\nCity.\nThe total length of the Cleveland 4-inch natural gas pipeline is 30,232 feet. Field surveys\ncurrent as of February 27, 1976 indicate that 14,768 feet of this line had a population of ten or\nless per mile within 660 feet each side of the pipeline, 3,919 feet of this line had a population\nbetween ten and forty-six per mile 660 feet each side of the pipeline, and 11,545 feet of this line\nhaving a population of forty-six or more with no multi-story buildings 660 feet each side of the\npipeline. Presently, 11,200 feet of this pipeline has a population of ten or less per mile within 660\nfeet each side of the pipeline, 5,987 feet of this line has a population between ten and forty-six per\nmile 660 feet each side of the pipeline and 13,045 feet of this line has a population of forty-six or\nmore with no multi-story building 660 feet each side of this pipeline.\nI request that your opinion as to Department of Transportation regulatory requirements\nfor odorization of gas within the Cleveland 4-inch pipeline itself include a determination of\nwhether this line is a distribution line, transmission line, or gathering line within the meaning of\nyour regulations. I further request that you attach this letter and exhibits, to your rules and\nopinion and that you incorporate these by reference into your ruling and opinion.\nI sincerely, appreciate your cooperation in this matter. If you desire any further\ninformation in order to issue your ruling and opinion so as to reach me before January 23, 1978,\nplease feel free to call me collect at 405/236-0601.\nVery truly yours,\nRichard H. Ruth\ndal\\192\\625\\78-01-24\n4","truncated":false,"body_characters":7584}