{"operation":"document","citation":"PI-18-0015","title":"Pacific Energy and Mining Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-08-15","effective_on":null,"summary":"PI-18-0015 response to Pacific Energy and Mining Company concerning 192.5.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0015","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/72116/pages-pacific-energy-and-mining-company-pi-18-0015-08-16-2019-part-1925.pdf","body":"<<<PAGE 1>>>\n\nU.S . Department\nofTransportation\nPipeline and Hazardous Materials\nS afety Administration\n1200 New Jersey Avenue SE\nWashington DC 20590\nAUG 1 S 2 0 19\nMr. Dan Green\nConsultant\nPacific Energy and Mining Company\n3550 Barron Way #13A\nP.O. Box 18148\nReno, Nevada 89511\nDear Mr. Green:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated July 6,\n2018, you requested an interpretation on the applicability of Title 49 Code of Federal\nRegulations (CFR) Part 192 to your Greentown Pipeline Gathering System (Gathering System).\nSpecifically, you requested \"clarification and interpretation of Title 49 CFR § 192.5 applicability\nto [the] Greentown Pipeline Gathering System,\" and if the Gathering System is exempt from 49\nCFR Part 192 regulations pursuant to 49 CFR § 192.l(b)(4)(ii).\nFor background purposes, you stated that the Gathering System was built in 2008 by Delta\nPetroleum Corporation, and that it was not regulated until October 2013. You stated that the\nUtah Division of Public Utilities began to regulate the Gathering System in October 2013 after\nthey conducted what you described as a \"courtesy inspection.\" You stated that the Utah Division\nof Public Utilities Safety Engineer concluded his inspection of the line as follows:\n\"Review of the submitted documents on September 13, 2013 did not demonstrate using\nsound engineering principles that the endpoint of gathering extended beyond the\nprocessing plant. My field visit on September 19, 2013 also confirmed the/act that the\nendpoint of this gathering system is the outlet of the processing plant. Utah Pipeline\nSafely considers 22 miles of 16-inch steel pipeline from the processing plant to the\nNorthwest Tie-in as Intrastate Transmission Pipeline. \"\nYou described the Gathering Systems as consisting of 26 miles of 6-inch diameter line operated\nat an MAOP of750 psig, and 21.19 miles of 16-inch diameter line operated at a maximum\npressure of 750 psig.1\nFurthermore, you stated gas is transported from production wells in the 6-inch diameter line to a\nplant where it is dehydrated and compressed. The gas is then transported in the 16-inch diameter\nline to a second facility upstream of the Northwest Pipeline interconnect, where the gas is routed\n1 Information provided by email from Mr. Tariq Ahmad to Asebe Tewabe (PHMSA), dated March 5, 2019 (stating\noperating pressures for both the 6-inch and 16-inch pipelines).\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the fonn 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\nto a filtration plant prior to being transferred to the Northwest Pipeline interstate transmission\nline. 2 You asked whether the entire Gathering System is an unregulated onshore gathering line\n(both the 6-inch diameter pipeline and the 16-inch diameter pipeline) due to the presence of a\nfiltration plant downstream of where the gas is dehydrated and compressed and upstream of the\nconnection to the Northwest Pipeline, a PHMSA-regulated interstate transmission line.\nIn addition, on August 13, 2018, you provided additional information by email (see footnote #2).\nYou assert that the Gathering System is an onshore rural gathering line exempt from PHMSA's\nregulations. Your assertion can be summarized as follows: (1) the entire Gathering System is\nlocated in a Class I location, as defined by 49 CFR § 192.5, and onshore gathering lines in Class\nI locations are unregulated gathering lines under 49 CFR § 192.8(b); (2) both the 6-inch\ndiameter line and the 16-inch diameter line are gathering lines, as defined by 49 CFR § 192.3;\nand (3) the 6-inch diameter line and the 16~inch diameter line are gathering lines because there\nare three separate points along the Gathering System where the gas is treated before it reaches\nthe end point of gathering and ready for consumer consumption. You describe the three\ntreatment locations as follows: (i) the wellhead where the gas is separated to remove water and\noil; (ii) a facility where the gas is compressed, dehydrated and refrigerated (Processing Plant);\nand (iii) a filtration plant where the gas is treated to remove impurities, and the quality of gas is\nmeasured and the 16-inch diameter line is connected to the Northwest Pipeline, PHMSA-\nregulated interstate transmission pipeline. Finally, you stated that only after the gas is treated\nand measured at the filtration facility it is fit for consumer consumption.\nPursuant to 49 U.S.C. 60101 et seq., PHMSA prescribes and enforces standards and regulations\nthat apply to the gathering, transmission, and distribution of gas by pipeline. A gathering line is\ndefined in Part 192 as \"a pipeline that transports gas from a current production facility to a\ntransmission line or main\" per 49 CFR § 192.3. That same section defines a transmission line as\n\"a pipeline, other than a gathering line that: (1) Transports gas from a gathering line or storage\nfacility to a distribution center, storage facility, or large vohyne customer that is not downstream\nfrom a distribution center; (2) operates at a hoop stress of20 percent or more of SMYS; or (3)\ntransports gas within a storage field.\"\nOn March 15, 2006, PHMSA issued a Final Rule that defined a \"regulated gathering line\" and set\nforth the requirements that apply to regulated gathering lines (71 FR 13289). The rule adopted\nAPI RP 80 with certain limitations. Section 192.8 now provides as follows:\n§ 192.8 How are onshore gathering lines and regulated onshore gathering lines\ndetermined?\n(a) An operator must use API RP 80 (incorporated by reference, see§ 192.7), to\ndetermine if an onshore pipeline ( or part of a connected series of pipelines) is an onshore\ngathering line. The determination is subject to the limitations listed below. After making\n2 On the March 5, 2019, email, Mr. Tariq Ahmad described the filtration plant removes liquid hydrocarbons and\nwater. In the August 13, 2018, email, Mr. Ahmad described the hydrocarbons as heavier gaseous hydrocarbons\n(ethane, propane, butane, isobutane, pentanes and even higher molecular weight hydrocarbons) that are collectively\nreferred to as Natural Gas Liquids.\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\n3\nthis determination, an operator must determine if the onshore gathering line is a regulated\nonshore gathering line under paragraph (b) of this section.\n(1) The beginning of gathering, under section 2.2(a)(l) of API RP 80, may not extend\nbeyond the furthermost downstream point in a production operation as defined in\nsection 2.3 of API RP 80. This furthermost downstream point does not include\nequipment that can be used in either production or transportation, such as separators\nor dehydrators, unless that equipment is involved in the processes of \"production and\npreparation for transportation or delivery of hydrocarbon gas\" within the meaning of\n\"production operation.\"\n(2) The endpoint of gathering, under section 2.2(a)(l)(A) of API RP 80, may not\nextend beyond the first downstream natural gas processing plant,· unless the operator\ncan demonstrate, using sound engineering principles, that gathering extends to a\nfurther downstream plant.\n(3) If the endpoint of gathering, under section 2.2(a)(l)(C) of API RP 80, is\ndetermined by the commingling of gas from separate production fields, the fields may\nnot be more than 50 miles from each other, unless the Administrator finds a longer\nseparation distance is justified in a particular case (see 49 CFR § 190.9).\n(4) The endpoint of gathering, under section 2.2(a)(l)(D) of API RP 80, may not\nextend beyond the furthermost downstream compressor used to increase gathering\nline pressure for delivery to another pipeline. ·\nBased on the information provided, the 26-miles of 6-inch diameter pipeline meets the definition\nof a gathering line because it transports gas from a production facility (the wellhead), and is\nupstream from the Processing Plant, where the 16-inch pipeline originates. Further, the 6-inch\ndiameter gathering line is located within a Class 1 location, and is therefore an unregulated rural\nonshore gas gathering line exempt from Part 192.\nHowever, pursuant to 49 CFR § 192.8(a)(2), the endpoint of onshore gas gathering for the\nGathering System is the outlet flange of the Processing Plant where the 21.19-miles of 16-inch\ndiameter pipeline connects. As you described the treatment processes, the gas is processed at the\nwellhead and the Processing Plant. The treatment conducted at the filtration plant removes water\nand separates heavier hydrocarbons. There are no sound engineering principles that require the\nfiltration plant to be located 21.19 miles downstream of the Processing Plant, and you have\nprovided no justification to the contrary. In addition, the product that is transported in the 16-\ninch diameter pipeline could be injected into the Northwest Pipeline without first going through\nthe filtration plant. Unless the gas is transported to an LNG facility, almost all natural gas is\ntransported with some heavier hydrocarbons.\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 fonn 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 4>>>\n\n4\nPHMSA agrees with the September 13, 2013, conclusion of the Utah Division of Public Utilities\nthat treatment for transportation of gas by pipeline is completed at the Processing Plant.\nTherefore, the 16-inch diameter pipeline is regulated as an intrastate transmission line under 49\nCFR Part 192.\nIfwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\no . Gale\nDirector, Office of Standards\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 fonn 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 5>>>\n\nJuly 6,2018\nMr. Alan Mayberry\nAssociate Administrator\nU.S. Department of Transportation,\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDear Mr. Mayberry:\nPlease find attached a \"Request for Interpretation of Title 49 CFR 192.\nIf you have any questions, please feel free to call me at 775-636-3132\nSincerely,\nFor Pacific Energy and ining Company\nc1\nDan Green\nConsultant\n3550 Barron Way#13A, P0Box 18148, Reno, Nevada 89511¯ PH775 852 7444¯ FAX 775 333 0225\nwww.pemc.us\n\n<<<PAGE 6>>>\n\nPAcW1C ENERGY & 11116 CO\nJUL13 ?Th\nJuly 6, 2018\nMr. Alan Mayberry\nAssociate Administrator\nU.S. Department of Transportation,\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nRIE: Request for Interpretation of Title 49 CFR 192\nDear P}{MSA- Office of Pipeline Safety\nPacific Energy and Mining Company (\"PEMC\") hereby requests Pipeline and Hazardous Materials\nSafety Administration (PHMSA) for a review, clarification and interpretation of Title 49 CFR 192.5\napplicability to Greentown Pipeline Gathering System (\"Gathering Line\") mistakenly referred to as\nthe Paradox Pipeline (OPID 39040).\nOur request is based upon the following:\n¯ Greentown Pipeline Gathering System (\"Gathering Line\") operated from 2008 to 2013\nwithout regulation.\n¯ State of Utah unilateral determination to regulate the Gathering Line by the Department of\nCommerce, Division of Public Utilities (\"Division\") email 9/23/2013.1\n¯ On September 13, 32013, PEMC had informed the Division that the Gathering Line is not\nsubject to regulation.\n¯ Agreement with PEMC' s determination of its Exemption from regulation under Title 49,\nPart 192- Transportation of natural and other gas by pipeline: minimum federal standards.\nBack&ound\n1. Gathering Line was built in 2008 by Delta Petroleum Corporation. Gathering Line was built\non a right-of-way issued by the United Stated Department of the Interior, Bureau of Land\nManagement as the Greentown Pipeline Gathering System. Both the 6-inch and the 16-inch\n1 This determination was made after Pacific Energy & Mining Company (PEMC) asked PHMSA for\nconformance of existing laws in pertaining to safe operation of the Gathering Line by email & phone\nrequesting a courtesy inspection ofthe Gathering Line.\n3550 Barron Way #13A, P0 Box 18148, Reno, Nevada 89511¯ PH 775 852 7444¯ FAX 775 333 0225\nwww.pemc.us\n\n<<<PAGE 7>>>\n\nPHMSA\nRequest for Interpretation of Title 49 CFR 192\nJuly 6, 2018\nPage 2 of 6\ngathering lines are built on Right-of-Way UTU-83457 issued by the United States\nDepartment ofthe Interior, Bureau ofLand Management.\n\"On February 1, 2008, right-of-way UTU-83457 was issued to Delta Petroleum\nCorporation for the Greentown natural gas pipeline gathering system on public lands\nin Grand County, Utah.\"\nSee Approval ofAssignment dated February 3, 2012 page 1, J1 Exhibit 1.\nThe Gathering Line consists of 26 miles of 6-inch line and 21.19 miles of 16-inch line. See\n2. Exhibit 2.\n3. Gas is transported from Wells in the 6-inch line to a plant where it is dehydrated and\ncompressed. (First facility.)\n4. Gas is transported in the 16-inch Gathering Line from \"First Facility\" to the second facility\nup stream of the Northwest Pipeline interconnect, where it is run through a filtration plant, tested for\nquality and finally transferred to Northwest Pipeline through a sales meter upstream of Northwest\nPipeline valve connecting the processed gas to Northwest Pipeline interstate transmission line.\n5. Delta Petroleum Corporation placed the Gathering Line in operation during 2008.\n6. Delta Petroleum Corporation designed and built the Processing Facility to handle 25 million\ncubic feet of natural gas.\n7. The initial production from the processing plant was approximately 1 million cubic feet of\nnatural gas per day.\n8. Construction of the Gas Gathering Line included the installation of a block valve in order to\naccept gas from other operators in the area.\n9. Gathering Line is to gather gas from all operators within the vicinity of the Gathering Line,\nall in order to prevent multiple Gathering lines being built.\n10. During 2010 PEMC acquired the Greentown Oil Field and the Gathering System.\n11. PEMC dismantled the 25 million cubic feet per day processing plant and installed a\nequipment to process 500,000 cubic feet of gas per day. (Decrease by a factor of 50).\n12. regulated.\nFrom inception of production in 2008 until October 2013 the Gathering Line was not\n13. During 2013 PEMC requested a courtesy review of the Gathering Line for safe operations.\nThis review was not for establishing jurisdiction or an agreement allowing the Gathering Line to be\nclassified as a Transmission Line.\n2\n\n<<<PAGE 8>>>\n\nPHIMSA\nRequest for Interpretation of Title 49 CFR 192\nJuly 6, 2018\nPage 3 of 6\n14. After a courtesy inspection by the Division, the Division decided to regulate the Gathering\nSystem as a Transportation Line.\n15. One ofthe conditions ofthe permit was that the Gathering Line would be required to\ntransport natural gas to the Second Facility from gas fields owned and operated by others. This was\ndone in order to decrease the necessity to build additional pipelines on public lands.\n16. As in other gas fields in the State of Utah, natural gas is owned by the operator of the wells\nuntil it is transferred to the natural gas buyer downstream of the natural gas sales meter. The gas is\nthen transported in the Interstate Pipeline for delivery to an end user, i.e. consumer. In this case the\nownership ofthe gas is transferred after the Second Facility.\n17. On September 16, 2013, Utah Division of Public Utilities (\"Division\") requested that its\ninspector be allowed to inspect the Pipeline. Pacific agreed to a courtesy inspection.\n18. On September 19, 2013 the Division conducted its courtesy inspection. Thereafter, the\ndivision unilaterally decided, without any legal authority, that it had jurisdiction upon the Gathering\nLine. Division's decision was based upon its logic the gas is processed at the beginning of the\nGathering Line.\n19. The gas gathering line was operated without the jurisdiction of the Division from the year\n2008 until the unilateral decision of the Division as relayed by an email on September 23'\", 2013 by\nJimmy W. Betham, Utah Pipeline Safety Engineer, State of Utah Department of Commerce,\nDivision ofPublic Utilities. (\"Division\"):\n\"Review of the submitted documents on September 13, 2013 did not demonstrate\nusing sound engineering pr1ncip1es that the end point of gathering extended\nbeyond the processing plant. My field visit on September 19, 2013 also\nconfirmed the fact that the end point ofthis j'atherin system is the outlet ofthe\nprocessiniz plant. Utah Pipeline Safely considers 22 miles of 16 inch steel\npipeline from the processing plant to the Northwest Tie-in as Intrastate\nTransmission Pipeline.\"\nThe above statement is contrary to the fact, as prior to transfer to Northwest Pipeline Transmission\nline, gas is treated as it flows thru a filtration plant removing impurities, quality of gas is measured:\ni.e., dew point, water content and BTU, (only after this point the gas is fit for the market) quantity of\ngas is measured thru a meter upstream ofthe Northwest Pipeline valve connecting the pipe to\nNorthwest Pipeline Transmission Line. See defmition of Gathering System.2\n2 Gathering System: The gathering lines, pumps, auxiliary tanks (in the case ofoil), and other equipment used to\nmove oil or gasfrom the well site to the main pipelinefor eventual delivery to the refinery or consumer as the case may be.\nIn the case ofgas, the gathering system includes the processingplant ('ifany) in which the gas is preparedfor market.\nManual ofOil & Gas Terms\nWilliams & Meyers, 3rd\nEdition\n\n<<<PAGE 9>>>\n\nPHMSA\nRequest for Interpretation of Title 49 CFR 192\nJuly 6, 2018\nPage 4 of 6\n20. PEMC has operated the Gathering Line without any incidents, similar to the 6-inch\ngathering lines in the Greentown field, these lines are not regulated by the Division, but are located\non the same right-of-way which specifies \"Greentown natural gas pipeline gathering system.\"\nStatus ofPipeline\nThe Paradox Pipeline operates at a maximum pressure of 750 psi. The closest municipality, Green\nRiver, Utah, from the Northwestern end of the Gathering Line is 13 miles. The closest municipality,\nMoab, Utah, from the southeastern end is 8 miles. In the 660 ft. buffer zone, there are two areas\nwith potential population; 1) at Archview RV campground where there is one residential structure\nand RV camping sites and 2) at Moab Under Canvas there is one camp site. See Exhibit 3.\nBased on Title 49 CFR Part 192- Transportation of Natural Gas, under section § 192.5 (b) (see\nattached flow chart Exhibit 4) the Gathering line is clearly Class 1.\n(a) This section class/les pzpeline locations forpurposes ofthis part. Thefollowing criteria\napply to classifications under this section.\n(1) A \"class location unit\" is an onshore area that extends 220 yards (200 meters)\non either side ofthe centerline ofany continuous 1-mile (1.6 kilometers) ofpipeline.\n(2) Each separate dwelling unit in a mu1tip1e dwelling unit building is counted as a\nseparate building intendedfor human occupancy.\n(b) Except as provided in paragraph (c) ofthis section, pipeline locations are classfled as\nfollows:\n(1) A Class 1 location is:\n(i) An offshore area; or\n(ii) Any class location unit that has 10 or fewer buildings intended for\nhuman occupancy.\n(2) A Class 2 location is any class location unit that has more than 10 but fewer\nthan 46 buildings intendedfor human occupancy.\n(3) A Class 3 location is:\n(z) Any class location unit that has 46 or more buildings intendedfor human\noccupancy; or\n(ii) An area where the pipeline lies within 100 yards (91 meters) ofeither a\nbuilding or a small, well-defined outside area (such as a playground,\nrecreation area, outdoor theater, or other place ofpublic assembly) that is\noccupied by 20 or more persons on at least 5 days a weekfor 10 weeks in\nany 12-month period (The days and weeks need not be consecutive.)\n\n<<<PAGE 10>>>\n\nPHMSA\nRequest for Interpretation of Title 49 CFR 192\nJuly 6, 2018\nPage 5 of 6\n(4) A Class 4 location is any class location unit where buildings with four or more\nstories above ground are prevalent.\n(c) The length ofClass locations 2, 3, and 4 may be adjusted asfollows:\n(1) A Class 4 location ends 220 yards (200 meters) from the nearest building with\nfour or more stories above ground.\n(2) When a cluster ofbuildings intendedfor human occupancy requires a Class 2 or\n3 location, the class location ends 220 yards (200 meters) from the nearest building\nin the cluster.\nSee Exhibit 3, Google map showing pipeline and locations.\nOn September 13, 2013 Consultant for PEMC sent an email:\nSent: Friday, September 13, 2013 4:51 PM\nSubject: Detailfor Paradox (Natural Gas) Gathering Pzpeline.\nTeriy,\nlam sendinR you a somewhat detailed description ofmy loiic that the Paradox (Natural Gas)\nGatherinii Pipeline does not fall under the scope of49 CFR 192.1,\nunder 192.1(b) (4) (ii) as it is not a regulated onshore gathering line (as determined in 49 CFR\n192.8). The area in which this pipeline runs through is under\ndevelopment and fsignjIcant oil and gas discoveries will be made then this gatheringpijpeline will\nconvey otherproducers'production to the Tie-in ofNorthwest\nPipeline.\nAtpresent there is only one wellproducing, into this line, which is operated by PacfIc Energy &\nMining Company (PEMC). PEMC is currently developing its\nleases and will be conveying gasfrom other wells into this line. Additionally, anotherproducer will\nalso be conveying gas into this gathering line, as shown on\nRegards,\nMobashir Ahmad\nPEMC\n775-742-1032\nSee Exhibit 5.\nThe Gathering Line has operated without any incident for over 10 years. Thus, PEMC'\ns request, as\nstated above to review, clarify, and determine that the Gathering System is not a Transmission Line.\n\n<<<PAGE 11>>>\n\nPHMSA\nRequest for Interpretation of Title 49 CFR 192\nJuly 6, 2018\nPage 6 of 6\nReiuest to exempt PEMC from regulation.\nThe definition by the Department ofEnergy isfor economic purposes; however, it does demonstrate\nthat other government agencies do consider gathering lines andprocessingplants as part ofthe\nsamefacilily.\nGathering System: The gathering lines, pumps, auxiliary tanks (in the case ofoil), and other\nequipment used to move oil or gasfrom the well site to the main pipelinefor eventual delivery to the\nrefinery or consumer as the case may be. In the case ofgas, the gathering system includes the\nprocessingplant (ifany) in which the gas is preparedfor market.\nManual ofOil & Gas Terms\nWilliams & Meyers, 3rd\nEdition\nExhibit 6 shows the right-of-way issued by the United States Department of the Interior Bureau of\nLand Management specifically issued the right-of-way for a gas gathering line. Thus as above\ndeference must be given to the United States Government Department ofthe Interior.\nReQ uested Interpretation\nPacific Energy and Mining Company requests an interpretation that the subject Pipeline is \"Not\nRegulated.\" Pursuant to 49 CFR 192.\nShould there be any questions, please feel free to call me at (775) 636-3132.\nSincerely,\nFor Pacific Energy and Mining Compa y\nRy\nDan Green\nConsultant\nCc: Tariq Ahmad\nEnclosures Exhibit 1\nExhibit 2\nExhibit 3\nExhibit 4\nExhibit 5\nExhibit 6\nAssignment from the BLM\nParadox Pipeline Map\nGoogle Paradox Pipeline Map\nPart 192- Gas Gathering Jurisdiction Flowchart\nAttachment to email dated September 13, 2013\nMemorandum dated January 18, 1980\n6","truncated":false,"body_characters":24876}