{"operation":"document","citation":"PI-14-0022","title":"Caelus Energy Alaska LLC — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-03-11","effective_on":null,"summary":"PI-14-0022 response to Caelus Energy Alaska LLC concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-14-0022.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-14-0022.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-14-0022","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2015/Caelus_Energy_Alaska_PI_14_0022_12_15_2014_Part_195.1.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nMAP. l 1 2015\nMr. J. Patrick Foley\nSenior Vice President\nCaelus Energy Alaska LLC\n3700 Centerpoint Drive, Suite 500\nAnchorage, AL 99503\nDear Mr. Foley:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nDecember 5, 2014, Caelus Energy Alaska LLC (Caelus) requested an interpretation ofthe\napplicability of the hazardous liquid pipeline safety regulations to a 2-inch diesel fuel line that\nCaelus operates in connection with the Oooguruk oil field offshore of the North Slope of Alaska.\nYou stated that 49 CFR 195.1 (b)( 5) exempts certain offshore pipelines from PHMSA regulation\nwhere the pipeline is located in state waters upstream from the farthest downstream facility\nwhere produced hydrocarbons are first processed and requested PHMSA's interpretation whether\nthis exemption is applicable to Caelus' 2-inch diesel line.\nYou stated Caelus has constructed a gravel island in the shallow waters of the Beaufort Sea on\nwhich it operates a drill site and production equipment. The island is located in state waters near\na state-owned island known as Thetis Island. and the coastline within Harrison Bay. Caelus also\noperates an onshore tie-in pad which provides an onshore base of operations and logistical\nsupport for the offshore production operati<ms. Caelus does not own and operate its own\nprocessing facilities on the island but instead, contracts to have its produced f1uids processed\nonshore at the Kuparuk River Unit (KRU) processing facilities.\nYou stated that the 2-inch diameter diesel pipeline is bundled with three other pipelines including\nthe crude oil pipelines inside a 16-inch outer diameter conductor pipe. This pipe-within-a-pipe is\nencased in concrete. Unlike the crude oil pipeline that transports crude from the production\nfacilities on the gravel island to the KRU processing facilities. the diesel line transports diesel\nfuel in the opposite direction out to the production facility on the gravel island to power the drill\nrig and carries base oil used to make drilling mud.\nYou noted that the regulatory exemption established in§ 195.l(h)(5) applies to pipelines that:\n(i) transport hazardous liquid or carbon dioxide; (ii) are situated offshore in state waters: and\n(iii) are located upstream of the outlet flange of the farthest downstream facility. You pointed\nout that the diesel pipeline is located upstream of the KRU facility and expressed the vie\\v that\nbecause Caelus' diesel line meets these criteria it should qualify for the exemption.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nSection 195.1(b)(5) states, in relevant part:\n§ 195.1 Which pipelines are covered by this Part?\n(a) ...\n(b) Excepted. This Part does not apply to any of the following:\n(1) ...\n(5) Transportation of hazardous liquid or carbon dioxide in an\noffshore pipeline in state waters where the pipeline is located\nupstream from the outlet ±1ange of the following farthest\ndownstream facility: The facility where hydrocarbons or carbon\ndioxide are produced or the facility where produced hydrocarbons\nor carbon dioxide are first separated, dehydrated, or otherwise\nprocessed;\nBased on the information you provided, Caelus' conclusion that the exemption in§ 195.1(b)(5)\napplies to its 2-inch diesel line appears to be incorrect. In this case, the diesel pipeline is not\ntransporting produced liquids downstream for processing, but is transporting finished diesel fuel\nthat was already in the stream of regulated transportation out to a production facility to be used\nas an energy source for production. The gravel island is not the facility where the diesel fuel was\nproduced. Therefore, the 2-inch diesel pipeline is regulated under § 195.1 (a)(2) because it\ntransports processed petroleum products to the gravel island where they will be consumed.\nPlease note that this response to your December 5, 2014, request reflects PHMSA's initial\ndetermination of the applicability of the Part 195 regulations based on the limited information in\nyour description of the facilities in your letter and is subject to further consideration if any\nadditional information about the facility would be relevant to this determination.\nIfwe can be offurther assistance, please contact Tewabe Asebe ofmy staff at 202-366-5523.\nSincerely,\n;///Gjv\n~~Q;Y{}\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nJ. Patrick Foley\nSVP, Caelus Natural Resources Alaska, LLC\npat.foley@caelusenergy.com\nDirect: 907-343-2110\nDecember 5, 2014\nJeffrey Wiese, Associate Administrator\nc/o Office of Pipeline Safety (PHP-30)\nPHMSA, U.S. Dept. of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nRe: Request for Written Regulatory Interpretation under 49 C.F.R. § 190.11\nDear Mr. Wiese:\nWe are writing to request a written regulatory interpretation pursuant to 49 C.F.R. § 190.11.\nCaelus Energy Alaska LLC. (“Caelus”) seeks an interpretation of the Pipeline and Hazardous\nMaterials Safety Administration (“PHMSA”) regulation at 49 C.F.R. § 195.1(b)(5) as it applies\nto a 2-inch diesel fuel line Caelus operates in connection with the Oooguruk oil field offshore of\nthe North Slope of Alaska.\nThe provisions of 49 C.F.R. § 195.1(b)(5) specify that certain offshore pipelines are exempt from\nPHMSA jurisdiction where the pipeline is located in state waters “upstream from” the “farthest\ndownstream facility”:\nTransportation of hazardous liquid or carbon dioxide in an offshore\npipeline in state waters where the pipeline is located upstream from\nthe outlet flange of the following farthest downstream facility: The\nfacility where hydrocarbons or carbon dioxide are produced or the\nfacility where produced hydrocarbons or carbon dioxide are first\nseparated, dehydrated, or otherwise processed.\nThrough this request, for the reasons detailed below, Caelus seeks PHMSA’s concurrence that\nthe above exemption is applicable to Caelus’ 2-inch diesel line.\nI. FACTUAL CONTEXT\nThe State of Alaska oil and gas leases comprising the Oooguruk oil field include both onshore\nand offshore lands. Caelus operates a gravel island in the shallow waters of the Beaufort Sea\nfrom which it operates a drill site and production equipment. The island is located in state waters\nbetween a State-owned island known as Thetis Island and the coastline, within Harrison Bay.\nCaelus also operates an onshore tie-in pad (the “OTP”) which provides an onshore base of\n3700 Centerpoint Drive, Suite 500 • Anchorage, Alaska 99503 • Main Line: 907-277-2700 • Fax: 907-343-2190 • www.caelusenergy.com\n\n<<<PAGE 4>>>\n\nOffice of Pipeline Safety\nDecember 5, 2014\nPage 2\noperations and logistical support for the offshore production operations. Caelus does not own\nand operate its own processing facilities and instead contracts to have its produced fluids\nprocessed at the Kuparuk River Unit (“KRU”) processing facilities.\nCrude oil is produced from wells drilled from the offshore gravel island. The produced fluids are\ntransported via a production pipeline to the OTP where they are transferred to KRU pipelines\nand transported to the KRU central processing facilities (“CPF”). Once delivered to the KRU\nCPF, the fluids are processed to separate the oil component and create sales quality crude oil for\nsubsequent transport through the Trans-Alaska Pipeline System.\nCaelus operates a bundle of four pipelines between the OTP and the offshore island. The\nproduced fluids pipeline is 12 inches in diameter inside of a 16-inch outer diameter conductor\npipe. Bundled with this produced fluid pipeline are three other smaller lines: an 8-inch diameter\nwater injection line (which is encased in concrete), a 6-inch diameter gas injection line, and the\n2-inch diameter diesel line that is at issue in this request. The diesel line is used to batch-\ntransport diesel and mineral oil products from the OTP to the offshore drill site. All four lines\nare bundled together in a robust special webstrapping material and secured externally with a\nseries of locking turnbuckles. Internally, the four bundled lines are buffered and protected by\nhigh strength polymers to eliminate friction and ensure pipeline integrity.\nThe bundled lines traverse approximately 8 miles between the OTP and the offshore island drill\nsite. Approximatley 2.5 miles are onshore and the remaining 5.5 miles are offshore. See\nattached map marked “Figure 1”. The bundle is buried in a trench 6 feet below the sea floor.\nThe trench was backfilled with protective and native material to prevent damage to the bundled\npipelines.\nThe produced fluids line carries a combined stream of oil, gas, and water from the offshore\nproduction site to the OTP for transfer and processing. The gas injection line and water line\ncarry natural gas and water respectively, which are injected for enhanced oil recovery. The\ndiesel line delivers fuel to power the drill rig and for use as a freeze-protection fluid and carries\nbase oil used to make drilling fluids. The pipelines were constructed in early 2007 and put into\nservice later that year.\nII. PHMSA JURISDICTIONAL EXEMPTION\nAs addressed in Subsection II.A below, Caelus’ diesel pipeline qualifies for the PHMSA\njurisdictional exemption established in 49 C.F.R. § 195.1(b)(5). In addition, while not\ncontrolling of the correct interpretation, as addressed in Subsection II.B below, application of a\njurisdictional exemption in this instance nevertheless ensures continued safe pipeline operations\nin a protective environment and is consistent with other public policies underlying PHMSA’s\nregulations.\n77681075.3 0081965-00002\n\n<<<PAGE 5>>>\n\nOffice of Pipeline Safety\nDecember 5, 2014\nPage 3\nA. Caelus’ Diesel Pipeline Qualifies For A Jurisdictional Exemption\nThe regulatory exemption established in 49 C.F.R. § 195.1(b)(5) applies to pipelines that: (i)\ntransport hazardous liquid or carbon dioxide; (ii) are situated offshore in state waters; and (iii)\nare located upstream of the outlet flange of the farthest downstream facility. The subject pipeline\ntransports diesel, which qualifies as a “hazardous liquid.” Moreover, the subject pipeline is\nlocated offshore entirely within state (State of Alaska) waters.1 Accordingly, application of the\njurisdictional exemption in this instance turns on whether the pipeline is located “upstream” of\nthe farthest downstream facility.\nThe term “upstream” is not defined in PHMSA’s regulations. Generally, in the oil and gas\nindustry, major operations are divided into upstream and downstream components. See generally\nPatrick H. Martin and Bruce M. Kramer, Williams & Meyers, Manual of Oil and Gas Terms,\n“downstream” and “upstream”. “Upstream” refers to operations before a point of reference or\ncloser to the source (a given reservoir), particularly exploration and production operations.\nDownstream refers to operations after a given point of reference, often used to describe post-\nproduction processes such as refining and processing. Id. Accordingly, operationally,\n“upstream” means toward the source and away from “downstream” processing. Directionally, in\nterms of movement of a material rather than a process, “upstream” means to move against the\ncurrent (i.e., in the opposite direction from the natural flow of a stream of water or other\nsubstance). The term “farthest downstream facility” is defined specifically in 49 C.F.R. §\n195.1(b)(5) as the “facility where hydrocarbons or carbon dioxide are produced or the facility\nwhere produced hydrocarbons or carbon dioxide are first separated, dehydrated, or otherwise\nprocessed.”\nIn the present instance, Caelus’ 2-inch diesel pipeline transports diesel and base oil for drilling\nmuds from the OTP, where produced hydrocarbons are transferred prior to processing, upstream\nfrom the manmade gravel island drilling platform located in offshore state waters. In this\nconfiguration, the “farthest downstream facility” located in the production process is, as a factual\nmatter, the KRU CPF, the facility where produced hydrocarbons are first separated, dehydrated\nand processed. Accordingly, if viewed operationally, the diesel pipeline is located “upstream” in\nthe production process from the KRU facility (the “furthest downstream facility”). Similarly, if\nviewed directionally, the diesel flows “upstream” against the current of the produced oil toward\nthe production source. Accordingly, although the term “upstream” is undefined and the “farthest\ndownstream facility” definition provides alternative choices, under all applications of these terms\n1 The limit of state waters in this area was determined to be three miles from the coastline\nand three miles from offshore islands by the U.S. Supreme Court in United States v. Alaska, No.\n84 Original, 521 U.S. 1 (see discussion in Michael W. Reed, Shore and Sea Boundaries, Volume\n3 at pp. 144-151). Because Thetis Island is less than 6 miles from the coastline, the entire area\nbetween the coastline and Thetis Island is state water.\n77681075.3 0081965-00002\n\n<<<PAGE 6>>>\n\nOffice of Pipeline Safety\nDecember 5, 2014\nPage 4\nto the Oooguruk facilities, Caelus’ diesel line transports a hazardous liquid, offshore in state\nwaters, through a pipeline that is located upstream of the farthest downstream facility. As such,\nCaelus’ diesel line meets all of the criteria for the jurisdictional exemption provided in 49 C.F.R.\n§ 195.1(b)(5).\nB. The Diesel Pipeline Is Safely Designed And Operated In A Low Risk And Remote\nEnvironment\nAlthough the relevant analysis provided in Section II.A is controlling, given PHMSA’s mission\nto protect people and the environment from the risks of hazardous materials transportation, it\nbears emphasis that the diesel pipeline at issue here is designed and operated for maximum\nsafety, and is located in a very remote location where the potential for human exposure\ngeographically constrained and the need for public awareness is very limited.\n1. Safe pipeline design and operation\nCaelus’ diesel pipeline is buried in a 6-foot deep trench beneath the seafloor which is backfilled\nwith protective and native material. Other safety features include an anode bracelet system that\nprovides cathodic protection and a fiber optic cable installed in the bundle that detects movement\nand temperature changes that would indicate leaks.\nCaelus’ operating and inspection practices further ensure the safety and integrity of the pipeline.\nIt is used intermittently to deliver diesel to the offshore gravel island drill site and is pressure\ntested after each batch transfer of diesel. The small sections of pipeline at either end that are\naboveground to connect with other facilities are marked and protected with barriers to prevent\naccidental vehicle collisions. The cathodic protection system is inspected annually at the\nexposed ends of the pipeline. In addition, annual bathymetric surveys are completed along the\nlength of the pipeline to check for scour by ocean currents or ice.\nThe pipeline has a track record of safe operations. It has been in service since 2007 with no\nreported incidents of any kind.\n2. Remote and low risk environment\nThe pipeline is also located in a very low risk environment. There are no nearby communities,\nresidents, or inhabitants other than the small isolated oil field camps for oil field employees at\neither end of the line. At its closest point, the nearest Alaska Native village (Nuiqsut) is\napproximately 25 miles inland and southwest from the nearest portion of the pipeline.\nAccordingly, although in the broadest possible sense, the pipeline resides within an expansive\nsubsistence use area of the Beaufort Sea offshore, the location of the pipeline is remote, very\nsmall in scale and at all times inaccessible to the public. Indeed, there is virtually no “public” in\nthe area to educate—no affected municipalities, school districts, businesses or residents.\n77681075.3 0081965-00002\n\n<<<PAGE 7>>>\n\nOffice of Pipeline Safety\nDecember 5, 2014\nPage 5\nThe location of the pipeline in a buried offshore trench in shallow water is an additional very\nsignificant source of separation between the pipeline and human or animal activities, and\nassociated reduced risk. The depth of the buried bundle protects the pipelines from contact with\nvessels, anchors, and grounded sea ice which could damage the pipelines. Moreover, the shallow\nwater depths of less than six feet prevent large vessels from navigating the area during the open\nwater season, and the presence of ice prevents all navigation for approximately nine months of\nthe year. Caelus estimates that 99% of the vessel traffic in the area during the brief open water\nseason are Caelus vessels related to its oilfield operations.\nFinally, offshore excavation activities in the vicinity of the pipeline could occur only after\nextended federal and state public notice and permitting processes (i.e., at a minimum, pursuant to\na state right-of-way grant, a federal Clean Water Act § 404 permit from the U.S. Army Corps of\nEngineers, and a federal ocean dumping permit from the U.S. EPA, along with NEPA\nenvironmental impact analysis). These processes ensure beyond any question that no\nunanticipated activities that may be incompatible with the pipeline presence and use could occur,\nand that no excavation that might damage or compromise the existing pipeline could be\nproposed, approved or initiated without establishing appropriate measures for mitigation and\nprotection. Because the pipeline is part of oilfield operations, it is further subject to other state\nand federal safety regulations, including reporting requirements, emergency response, integrity\nprotection, and leak detection requirements (see generally AS 46.04.030; 11 AAC 75.005 – 11\nAAC 75).\nIn sum, Caelus’ diesel pipeline has been constructed in an extremely remote location, in a\nconfiguration that presents an exceptionally low risk to a very small number of humans or to the\nenvironment. Moreover, the design of the pipeline, corrosion prevention system, and leak\ndetection measures provide additional specific and important protections for humans and the\nenvironment.\nIII. REQUEST FOR FORMAL INTERPRETATION\nFor the reasons stated above, pursuant to 49 C.F.R. § 190.11, Caelus requests a formal written\ninterpretation from PHMSA confirming that, based upon the facts presented above, Caelus’ 2-\ninch diesel line operated in connection with the Oooguruk oil field offshore of the North Slope of\n77681075.3 0081965-00002\n\n<<<PAGE 8>>>\n\nSincerely,\nJ. Patrick Foley\nSenior VP\nCC:\nJohn Hellen, Caelus\nJeffrey W. Leppo, Stoel Rives\n77681075.3 0081965-00002\n\n<<<PAGE 9>>>\n\nK U P A R U K R I V E R U N I T\nMILNE POINT\nUNIT\n! (\nDSD-1H\nDS-1A\nDS-1G\nDS-1R\nDS-1Q\nDS-3S\nDS-3C\nDS-3N\nDS-3K\nCPF 3\nDS-3J\nDS-3B\nDS-3F\nDS-3A\nDS-3L\nDS 3M\nDS-3H\nDS-3G\nCPF 1\nDS-2Z\nDS-2X\nDS-2W\nDS-2U\nDS-2V\nDS-2T\nDS 2A\nMINE\nSITE C\nMINE\nSITE F\nUGNU\nMINE SITE E\nDS-3Q\nDEWLINE\nSITE\nOLIKTOK PT\nSTAGING AREA\nOLIKTOK\nDOCK\nDS-3R\nDS-3O\nDS 1Y\nKUPARUK\nBASE\nCAMP\nKOC\nL\nF\nHELMERICKS\nCOLVILLE\nRIVER DELTA\nF\ne\nd\ne\nr\na\nl W\na\nte\nr\ns\nS\nt\nat\ne\nW\nat e\nrs\nKalubik Creek\nH A R R I S O N B A Y\nThetis Island\n5.7 Miles Buried\nSubsea Flowline\n2.4 Miles\nOnshore\nFlowline\nSpy Island\nMilluveach River\nColville River\nMine Site E\nOooguruk Tie-in Pad &\nConnection to Existing Flowline\nOooguruk Drill Site\nT13NR7E T13NR8E T13NR9E\nT14NR8E\nT14NR9E\nT12NR9E\nT12NR7E\nT11NR8E\nT11NR7E\nT12NR10E\nT11NR9E\nT13NR10E\nT11NR10E\nT12NR8E\nT14NR10E\nT13NR6E\n1\n9\n9 8\n3\n8 8\n8\n8 8\n8\n2\n6\n1\n5\n6\n6 6 6\n6\n6\n6\n6\n6\n6\n6\n6\n6 6\n6\n6\n6\n6\n6\n6\n5\n6\n6\n6\n6\n6\n6\n6\n6\n6\n6\n6\n6\n6\n3\n3\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n4\n4\n4\n4\n4\n4\n2\n3\n3\n3\n7\n7\n7\n7\n7\n7\n7\n7\n7\n7\n7\n7\n7\n7 7\n7\n7\n7\n7\n7\n7\n8\n5\n3\n34\n7\n7\n7\n7 5\n2 4\n4 6\n6\n6\n8\n8\n8 8\n8\n6 4\n5\n5\n5\n5\n5\n9\n9\n5\n5 5\n6\n6\n6\n6\n6\n6\n6\n6 5\n5\n9\n9\n9\n9\n9\n9\n9\n9 9\n9\n9\n9\n9\n5\n5\n8\n69\n9 9\n5\n5\n5\n5\n8\n9\n9\n9\n9 9\n6\n6\n6\n6 6\n6\n9\n4\n9\n5\n6\n6 9\n9\n9\n5\n5\n5\n5 7\n7\n7\n7\n7 7\n7\n7\n7\n7\n7 7\n7\n7\n7\n7\n7\n7 7\n7\n7\n7\n7 7\n7\n7\n7\n7 7\n7\n7\n7 7\n7 7\n7\n6 5\n4 4\n4\n3\n4\n4\n4\n4\n4\n4\n4\n4\n4\n4\n4\n4\n4\n4\n4\n8\n8\n8\n8\n8\n8\n8\n8\n8\n8\n8\n8\n8\n8\n8 8\n8\n8\n8\n8\n8 8\n8\n8\n2\n2\n2 2\n3\n3\n3\n3\n3\n3\n3\n3\n3\n3\n3 3 3\n7\n7\n7\n9\n2\n8\n8 8 7 7 9\n8 7\n7\n7\n7\n7\n6\n6 6\n4\n3\n5\n6\n6\n8\n8\n8\n8\n8\n8\n6\n8\n7\n7\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n5\n2\n2\n2\n2\n4\n4\n4\n4\n4\n4\n4\n4\n4\n4\n4\n3\n3\n3\n3\n3\n3\n3\n3\n3\n3\n3\n3\n9\n9\n9\n9\n9\n9\n9\n9\n9\n9\n8\n8\n8\n4\n7\n7\n7\n7\n6\n6\n6\n5\n5\n5\n2\n2\n3\n3\n3\n3\n7\n7\n8\n8\n8\n7\n7 7\n7 7 7\n7\n7\n7 2\n3\n6\n4\n5\n7\n6\n3\n4\n4\n2\n3\n2\n4\n7\n8\n7\n7 8 6\n7\n7\n7 7 7 7\n7\n7\n8\n76\n7\n7\n5\n5\n4\n8\n7\n6\n7\n6\n7 6\n5\n5 3\n4\n2\n4\n4\n2\n3\n6\n7 7 6 7\n7\n7\n5\n4 5\n4\n5\n6\n6\n5\n3\n3 3\n2\n4\n23\n24\n29\n25\n21\n16\n21\n13\n10\n20 27\n30\n26\n16\n27 35\n34\n33\n33\n33\n35 37 38\n40\n45\n42\n38\n39\n36\n46\n45\n43\n41\n44\n45 45\n43\n22\n43\n39\n38\n38\n37\n38\n35 39\n32\n35\n33\n34\n35\n28\n38\n36\n37\n35\n31\n30\n28\n36\n35\n34\n36\n34\n35\n31\n30\n34\n33\n29 37\n36\n39\n36 42 43\n37\n38\n37\n38\n32\n32\n37 37\n34\n35\n36\n36\n36 35\n32\n27\n29\n30\n32\n33\n33\n33\n35\n34\n33\n33\n32\n31\n35\n34\n31\n31\n29\n35\n36\n32\n32\n34\n32\n26\n29 29\n28\n26\n31\n30 29\n26\n30\n28 28\n32 32\n29 29 29\n30\n29\n25\n25 28\n25 31 32\n31\n34\n29\n29\n29\n32\n24\n29\n24\n26\n29\n26\n29\n29\n23\n15\n27\n27\n27\n27\n27\n27\n27\n27\n22\n20\n17\n16\n11 10\n16\n14\n20\n22\n10\n10\n10\n10\n10\n16 20\n15\n22\n18\n13\n17\n16\n14\n23\n22\n12\n13\n14 10\n10\n10\n10\n10\n10\n10 11\n11\n11\n13\n14\n14\n13\n11\n14\n16 15\n15\n15\n15\n18\n18\n17\n14\n17\n19\n18\n19\n18\n21 21\n25\n23\n22\n23\n12\n24\n25\n21\n24\n25\n22\n23\n22\n21\n21 19\n18\n18\n19\n21\n16\n16\n16\n15\n16\n12\n13\n13\n14\n14\n14\n11\n11\n11\n11\n11\n10\n10\n10\n10\n10\n10\n10\n16\n15\n14\n17\n20\n18\n17\n17\n20\n22\n16\n14\n12\n14\n15\n17\n13\n11\n11\n11\n12\n12\n21\n17\n14\n19\n16\n11\n14\n13\n10\n10 12\n11\n10 11 11\n10 10\n10\n12\n12\n11\n11\n11 11\n11\n11\n11\n11\n11\n11\n11\n11\n11\n10\n10\n11\n11\n11\n11\n11\n11\n13\n13\n13 13\n13\n13\n12 12\n12\n12\n12 12\n12\n12\n12\n12\n12\n12\n12\n10\n10\n10\n10\n10\n10\n10\n10\n10\n10\n10\n10\n10\n10\n10\nPROJECT LOCATION MAP\nOooguruk Development Project\n0 5\n2.5 Miles\nFIGURE:\nSCALE:\n1\n¤\nNAD27 State Plane Zone 4 (feet). Umiat Meridian.\nBathymetry in feet, Mean Lower Low Water (MLLW).\nSalt and brackish water marshes provided by NOAA.\n! ( Oooguruk Drill Site Location\nFlowline Route - Onshore\nFlowline Route - Buried Subsea\nKuparuk River and Milne Point Oil & Gas Units\nFederal/State Waters Boundary\nNative Allotment\nSalt & Brackish Water Marshes","truncated":false,"body_characters":22924}