The URL can be used to link to this page

Home My WebLink AboutO 186Other Order 186 Docket No: OTH-21-013 1. April 21, 2021 Letter to Emerald House LLC regarding the investigation of Umiat 18 plug and abandonment operations 2. June 10, 2021 Notification of proposed enforcement action per 20 AAC 25.535 (b)(1) and 20 AAC 25.353 (b)(2) 3. July 06, 2021 AOGCC granting Emerald House LLC permission to re-enter Umiat 18 with the purpose of completing plug and abandonment operations ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage Alaska 99501 Re: Compliance with Sundry 321-114 Umiat 10 (PTD 2130140) Umiat 18 Other Order 186 Docket Number:OTH-21-013 August 19, 2021 DECISION AND ORDER On June 10, 2021 the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to Emerald House LLC (Emerald House) for violating the provisions of 20 AAC 25.507 (Change of an approved program) by failing to perform operations in accordance with conditionally approved Sundry 321-114. Emerald House was granted approval to re-enter Umiat-18 to complete plug and abandonment operations and clear the location. The Notice proposed a specific corrective action and a $40,000 civil penalty under AS 31.05.150(a). Summary of Proposed Enforcement Action: The Notice proposed a civil penalty for violating four approval conditions while performing abandonment operations. The Notice also proposed that Emerald House submit a detailed written explanation that describes how recurrence of this violation will be prevented in future operations. Violation - Failure to Comply with Sundry Approval Conditions: On March 15, 2021 the AOGCC conditionally approved Sundry 321-114, authorizing Emerald House to re-enter Umiat-18 to complete plug and abandonment operations and clear the location. By letter dated April 21, 2021 AOGCC notified Emerald House of an investigation to determine if the completed abandonment operations at Umiat-18 comported with the requirements of the conditionally approved Sundry, focusing on the following conditions of approval: - Cementing program to be approved by AOGCC before commencing cementing operations; - Cement chemical injection line before pumping cement plugs into the tubing and tubing - casing annulus; - Submit daily reports to AOGCC once operations commence; - Reservoir cement plug verification before placing the surface cement plug, as required in 20 AAC 25.112(g) and as described in the proposed procedure of Sundry 321-114. Emerald House neither requested informal review nor a public hearing regarding the notice of proposed enforcement. By letter dated June 30, 2021 Emerald House acknowledged receipt of the Notice and stated: "Emerald House management conducted an internal review of the Umiat-18 field work. The elements if noncompliance revealed by that assessment did not materially differ from those cited by the AOGCC in items 1 through 4 on page 2 of 3. In that regard, we concur with the Commission's findings that Emerald House did violate the provisions of 20 AAC 25.507 ("Change of an approved program") while performing abandonment operations at Umiat-18 and in accordance with that determination enclose herewith the civil penalty of $40,000.00." Other Order 186 August 19, 2021 Page 2 of 3 Mitigating Circumstances: The factors in AS 31.05.150(g) were considered in determining the appropriate penalty. Emerald House's lack of good faith in its attempts to comply with the imposed conditions, the potential seriousness of the violation, and need to deter similar behavior in future operations are the factors which most heavily influence AOGCC's decision and the penalty being assessed. AOGCC's conditions of approval were clearly written. Regulation 20 AAC 25.507 is clear about requirements for making changes to approved permits. Verbal discussions occurred with Emerald House representatives responsible for plug and abandonment operations at Umiat-18 through the work planning and implementation. Mitigating circumstances include no injury to the public or the environment by the unapproved changes, and no history of noncompliance by Emerald House. Further, AOGCC has not imposed per -day assessments for the violations, which reduced the proposed penalty. Findings and Conclusions: Despite admitting that it did violate the provisions of 20 AAC 25.507 ("Change of an approved program") while performing abandonment operations at Umiat-18, and paying the civil penalty, Emerald House requested that AOGCC reconsider the amount of the penalty. The basis for this request is based on unspecified impacts of COVID-19 affecting their ability to comply, dual permitting by state and federal agencies, communication challenges because of the remote well location, and other unspecified "hurdles". Emerald House's argument suggests that a technical success for the plug and abandonment operations should somehow overshadow compliance with clear and specific regulatory requirements, including conditions of the Sundry approval. The AOGCC finds that Emerald House violated 20 AAC 25.507 at Umiat-18 by failing to obtain prior approval for changes to the approval conditions attached to Sundry 321-114. Emerald House has not disputed the findings in the Notice and has paid the civil penalty proposed by AOGCC. Emerald House has not provided any factual information that would warrant changing the penalty amount. The request to reconsider the penalty amount is rejected. Now Therefore It Is Ordered That: Emerald House is assessed a civil penalty in the amount of$40,000 for violating 20 AAC 25.507 for failing to comply with the approval conditions in Sundry 321-114. Within 10 days of the date of AOGCC's final decision, Emerald House shall provide a detailed written explanation that describes how it intends to prevent recurrence of this violation. As an Operator involved in an enforcement action, Emerald House is required to preserve documents concerning the above action until after resolution of the proceeding. Done at Anchorage, Alaska and Dated August 19, 2021 Digitaly vgnetl by Jeremy Jeremy g Jessie L. Digitally signed by Jessie L. Chmielowski Dan Dyn,[ysiqnm Wwo Date: 2021.08.19 Price Date: 2021.08.19 ChmielowSkI Seamount 11 mxto .is ixmmx 111, 111.08.1112.1.11 13,0931.08'p0 12:06:22-08'00 ea Jeremy M. Price Jessie L. Chmielowski Daniel T. Seamount, Jr. Chair, Commissioner Commissioner Commissioner cc: AOGCC Inspectors Phoebe Brooks (AOGCC) Other Order 186 August 19, 2021 Page 3 of 3 As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in pan within 10 days after it is filed. Failure to act on it within 10-days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. From: Carlisle, Samantha I (CED) To: AOGCC Public Notices Subject: Other Order 186 (Emerald House) Date: Thursday, August 19, 2021 2:34:00 PM Attachments: OtherlWodf Compliance with Sundry 321-114 Umjat 10 (PTD 2130140) Umiat 18 Docket Number: OTH-21-013 Samantha Carlisle Executive Secretary Ili Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 From: Carlisle Samantha ) (CED) To: "er"k oostad@)amail.mm" Subject: Other Order 186 Date: Thursday, August 19, 2021 2:36:00 PM Attachments: Other186.odf Please see attached Samantha Carlisle Executive Secretary III Alaska Oil and Gas Conservation Commission 333 West 71h Avenue Anchorage, AK 99501 (907) 793-1223 From: Carlisle Samantha ] (CED1 To: Inspectors(AOGCC.1nsoectorsCalalaska.aov); Brooks, Phoebe L (CED) Subject: Other Order 186 (Emerald House) Date: Thursday, August 19, 2021 2:35:00 PM Attachments: Other186 odf Samantha Carlisle Executive Secretary III Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907)793-1223 Bernie Karl Gordon Severson Richard Wagner K&K Recycling tnc. 3201 Westmar Cir. P.O. Box 60868 P.O. Box 58055 Anchorage, AK 99508-4336 Fairbanks, AK 99706 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 �Xt ��\ INDEXES Emerald House, LLC P.O. Box 112212, Anchorage, Alaska 99511-2212 June 30, 2021 Mr. Jeremy M. Price Chair, Commissioner RECEIVED Alaska Oil & Gas Conservation Commission 333 West Seventh Avenue JUL 0 6 2021 Anchorage, Alaska 99501-1433 AOGCC Re: Docket #: OTH-21-013 Compliance w/Sundry 321-114 Umiat-18 (PTD 2130140) Commissioner Price (Chair): On March 15, 2021, the Alaska Oil & Gas Conservation Commission ("AOGCC") conditionally approved Sundry 321-114, authorizing Emerald House LLC ("Emerald House") to re-enter Umiat-18 with the objective to complete plug and abandonment operations and clear the location. Plug and abandonment operations were completed by Emerald House on April 2, 2021. By letter dated April 21, 2021, the AOGCC notified Emerald House of an investigation to determine if the abandonment operations at Umiat-18 comported with the requirements of the conditionally approved Sundry or had Emerald House violated the provisions of 20 AAC 25.507 ("Change of an approved program"), while performing abandonment operations at Umiat-18. By letter dated June 10, 2021, AOGCC notified Emerald House of a proposed enforcement action that included the intent to impose a civil penalty on Emerald House under AS 31.05.150(a) in the amount of $40,000 for failing to comply with the conditions imposed by Sundry approval 321-114. After receiving the AOGCC letter dated June loth, Emerald House management conducted an internal review of the Umiat-18 field work. The elements of noncompliance revealed by that assessment, did not materially differ from those cited by the AOGCC in items 1 through 4 on page 2 of 3. In that regard, we concur with the Commission's finding that Emerald House did violate the provisions of 20 AAC 25.507 ("Change of an approved program") while performing abandonment operations at Umiat-18 and in accordance with that determination enclose herewith the civil penalty of $40,000.00. Following on that submittal, we would respectfully request that the Commission reconsider the amount of that penalty. From our perspective, the deviations from the conditions of approval imposed by Sundry 321-114 were largely the result of some initial confusion on the part of the field team given the federal & state duopoly in NPRA, coupled with the Erik Opstad VPimerald House (907) 244-5210 Page 2 of 2 unprecedented impact of required COVID-19 protocol compliance and a number of communication challenges posed by the Umiat-18 site itself that included; limited snow trail access, no cell phone coverage, poor satellite links, no line of sight radio tie in due to terrain issues, weather imposed access constraints, plus a host of other minor hurdles that made this site uniquely challenging. My takeaway was that everyone working on the program from the state & federal agencies through Emerald House with its vendors, were doing their best to get the job done under daunting conditions. Given the acknowledged deviations from the Sundry COA's, in hindsight that effort needed some improvement in several largely procedural areas, but the abandonment program was a technical success and achieved those results with no adverse environmental or personnel safety impacts whatsoever! At the end of the day, the abandonment of Umiat-18 was fully approved by the AOGCC and separately by BLM without comment. Although somewhat imperfect in its procedural execution, it is hard for us to see given the extenuating circumstances and positive outcome how a $40,000 penalty is warranted, and again, respectfully ask the Commission to reconsider the amount of the imposed penalty. We appreciate your forbearance in the matter. Sincerely, Emerald House, LLC Erik Opstad Vice President (907)244-5210 Emerald House, LLC P.O. Box 112212, Anchorage, Alaska 99511-2212 June 30, 2021 Mr. Jeremy M. Price Chair, Commissioner RECEIVE® Alaska Oil & Gas Conservation Commission 333 West Seventh Avenue JUL 0 6 2021 Anchorage, Alaska 99501-1433 AOGCC Re: Docket #: OTH-21-013 Compliance w/Sundry 321-114 Umiat-18 (PTD 2130140) Commissioner Price (Chair): On March 15, 2021, the Alaska Oil & Gas Conservation Commission ("AOGCC") conditionally approved Sundry 321-114, authorizing Emerald House LLC ("Emerald House") to re-enter Umiat-18 with the objective to complete plug and abandonment operations and clear the location. Plug and abandonment operations were completed by Emerald House on April 2, 2021. By letter dated April 21, 2021, the AOGCC notified Emerald House of an investigation to determine if the abandonment operations at Umiat-18 comported with the requirements of the conditionally approved Sundry or had Emerald House violated the provisions of 20 AAC 25.507 ("Change of an approved program"), while performing abandonment operations at Umiat-18. By letter dated June 10, 2021, AOGCC notified Emerald House of a proposed enforcement action that included the intent to impose a civil penalty on Emerald House under AS 31.05.150(a) in the amount of $40,000 for failing to comply with the conditions imposed by Sundry approval 321-114. After receiving the AOGCC letter dated June loth, Emerald House management conducted an internal review of the Umiat-18 field work. The elements of noncompliance revealed by that assessment, did not materially differ from those cited by the AOGCC in items 1 through 4 on page 2 of 3. In that regard, we concur with the Commission's finding that Emerald House did violate the provisions of 20 AAC 25.507 ("Change of an approved program") while performing abandonment operations at Umiat-18 and in accordance with that determination enclose herewith the civil penalty of $40,000.00. Following on that submittal, we would respectfully request that the Commission reconsider the amount of that penalty. From our perspective, the deviations from the conditions of approval imposed by Sundry 321-114 were largely the result of some initial confusion on the part of the field team given the federal & state duopoly in NPRA, coupled with the Enk OVstad VP Lmerald House (907) 2445210 Page 2 of 2 unprecedented impact of required COVID-19 protocol compliance and a number of communication challenges posed by the Umiat-18 site itself that included; limited snow trail access, no cell phone coverage, poor satellite links, no line of sight radio tie in due to terrain issues, weather imposed access constraints, plus a host of other minor hurdles that made this site uniquely challenging. My takeaway was that everyone working on the program from the state & federal agencies through Emerald House with its vendors, were doing their best to get the job done under daunting conditions. Given the acknowledged deviations from the Sundry COA's, in hindsight that effort needed some improvement in several largely procedural areas, but the abandonment program was a technical success and achieved those results with no adverse environmental or personnel safety impacts whatsoever! At the end of the day, the abandonment of Umiat-18 was fully approved by the AOGCC and separately by BLM without comment. Although somewhat imperfect in its procedural execution, it is hard for us to see given the extenuating circumstances and positive outcome how a $40,000 penalty is warranted, and again, respectfully ask the Commission to reconsider the amount of the imposed penalty. We appreciate your forbearance in the matter. Sincerely, Emerald House, LLC Erik Opstad Vice President (907)244-5210 7[ 6758 ELKO International LLC 3500 Taiga Drive Anchorage, Alaska 99516-2886 +1 907 2 10 1 +1 907 02 8937 EIN # PAY TO THE State of Alaska - AOGCC ORDER OF — Forty Thousand and fate o Alaska A G 333 West 7th Avenue Anchorage, Alaska 99501-3572 MEMO Violation or Non -Compliance (20 AAC 25.535(b)(1)) NORTHRIM BANK P.O. Box 241489 Anchorage, AK 99503 89-9311252 119006758iP is L 25 2009341:7100075030iP ELKO International LLC 7/2/2021 State of Alaska - AOGCC Violation or Non -Compliance (20 AAC 25.535(b)(1)) RECE�vED �UL 0 6 2021 p OOGGG Northrim Checking Violation or Non -Compliance (20 AAC 25.535(b)( 7/2/2021 $ **40,000.00 3 x DOLLARS 8 6758 40,000.00 40,000.00 THE STATE °fALASKA GOVLRNOR MIKE DUNLEAVY June 10, 2021 Mr. Erik Opstad Emerald House, LLC P.O. Box 112212 Anchorage, AK 99511-2212 Re: Docket Number:OTH-21-013 Compliance with Sundry 321-114 Umiat 18 (PTD 2130140) Alaska Oil and Gas Conservation Commission 333 Wesi Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279, 1433 Fax: 907.276.7542 www.00gcc.a[aska.gov Dear Mr. Opstad: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby notifies Emerald House LLC (Emerald House) of a proposed enforcement action. Nature of the Apparent Violation or Noncompliance (20 AAC 25.535(b)(1)). Emerald House has violated the provisions of 20 AAC 25.507 ("Change of an approved program") while performing abandonment operations at Umiat 18. Basis for Finding the Violation or Noncompliance (20 AAC 25.535(b)(2)). Exploration well Umiat 18 was drilled and evaluated in 2013. The well was suspended as approved by AOGCC in Sundry 313-225. On March 15, 2021 the AOGCC conditionally approved Sundry 321-114, authorizing Emerald House to re-enter Umiat 18 to complete plug and abandonment operations and clear the location. Plug and abandonment operations were completed by Emerald House on April 2, 2021. By letter dated April 21, 2021 AOGCC notified Emerald House of an investigation to determine if the abandonment operations at Umiat 18 comported with the requirements of the conditionally approved Sundry, focusing on the following conditions of approval: - Cementing program to be approved by AOGCC before commencing cementing operations; - Cement chemical injection line before pumping cement plugs into the tubing and tubing - casing annulus; - Submit daily reports to AOGCC once operations commence; - Reservoir cement plug verification before placing the surface cement plug, as required in 20 AAC 25.112(g) and as described in the proposed procedure of Sundry 321-114. Docket Number: OTH-21-013 Notice of Proposed Enforcement June 10, 2021 Page 2 of 3 Per 20 AAC 25.507 an operator may not undertake a change to an approved program or activity without AOGCC approval. Paragraph (a) of 20 AAC 25.507 further describes the information that must be submitted to AOGCC. To make a change, the well's current condition and proposed change must be provided to AOGCC for review and approval. AOGCC investigation indicates Emerald House failed to comply with the conditions imposed in the approved Sundry 321-114, including the noted changes and obligations in the work procedure inserted by AOGCC. Specifically, Emerald House: 1) Commenced pumping cement into the tubing and tubing -casing annulus in Umiat 18 on March 22, 2021. The cementing procedure was submitted to AOGCC on March 24, 2021. 2) Attempted to pump cement into the 1/4-inch chemical injection line on March 23, 2021 without success. Cement plugs were pumped into the tubing and tubing -casing annulus on March 22, 2021. 3) Submitted summaries of daily operations on March 25 and April 1, 2, and 3, 2021. Plug and abandonment operations were commenced on March 20, 2021. 4) Changed the approved plugging procedure without obtaining AOGCC approval. Two plugs were required in the approved sundry with the integrity of the reservoir plug verified before pumping the surface plug. Cement was instead pumped to surface in both the tubing and tubing -casing annulus, eliminating the required plug tag and pressure test verifications. Proposed Action (20 AAC 25.535(b)(3)). For violating 20 AAC 25.507 the AOGCC intends to impose a civil penalty on Emerald House under AS 31.05.150(a) in the amount of $40,000 for failing to comply with the conditions imposed in Sundry approval 321-114.' In addition to the imposed civil penalty, AOGCC intends to require Emerald House to provide a detailed written explanation that describes how Emerald House intends to prevent recurrence of this violation. Rights and Liabilities (20 AAC 25.535(b)(4)) Within 15 days after receipt of this notification — unless the AOGCC, in its discretion, grants an extension for good cause shown —Emerald House may file with the AOGCC a written response that concurs in whole or in part with the proposed action described herein, requests informal review, or requests a hearing under 20 AAC 25.540. If a timely response is not filed, the proposed action will be deemed accepted by default. If informal review is requested, the AOGCC will provide Emerald House an opportunity to submit documentary material and make a written or oral statement. If Emerald House disagrees with the AOGCC's proposed decision or order after that review, it may file a written request for a hearing within 10 days after the proposed decision or order is issued. If such a request is not filed within that 10-day period, the proposed decision or order will become final on the 111 day after it was issued. If such a request is timely filed, the AOGCC will hold its decision in abeyance and schedule a hearing. ' AS 31.05.150(g) requires AOGCC to consider nine criteria in setting the amount of a civil penalty. Docket Number: OTH-21-013 Notice of Proposed Enforcement June 10,2021 Page 3 of 3 If Emerald House does not concur in the proposed action described herein, and the AOGCC finds that Emerald House violated a provision of AS 31.05, 20 AAC 25, or an AOGCC order, permit or other approval, then the AOGCC may take any action authorized by the applicable law including ordering one or more of the following: (i) corrective action; (ii) suspension or revocation of a permit or other approval; and (iii) imposition of penalties under AS 31.05.150. In taking action after an informal review or hearing, the AOGCC is not limited to ordering the proposed action described herein, as long as Emerald House received reasonable notice and opportunity to be heard with respect to the AOGCC's action. Any action described herein or taken after an informal review or hearing does not limit the action the AOGCC may take under AS 31.05.160. Sincerely, Jeremy DigRal",nW byxmWl� oare::ozi.W0 Price MS�36�W Jeremy M. Price Chair. Commissioner Domestic Mail C For tlelivery intorn M1 `p CerCail Re4� Ln $ U ervices BFees (checkbox, atltly pp ie�e) eNrn FeLaipl maNLOpy) $ ecL 1 O ❑Return Feipt(eleohonl0) E J ❑Certlfletl Mall ResMctetl Delivery E [t• ❑aa $ ❑napnsisa�enm aoarvey$ re )1191( Pa M1 $ TOW Pasta Fens ru $ rr Sene To ra O SYreet endh'p(. Nd., orPBBoz No. M1 THE STATE oALASKA WVICRNO R MIKE, I)l'NLI'.A%'S April 21, 2021 Mr. Erik Opstad Emerald House, LLC P.O. Box 112212 Anchorage, AK 99511-2212 Re: Docket Number:OTH-21-013 Compliance with Sundry 321-114 Umiat 18 (PTD 213014) Dear Mr. Opstad: Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276,7542 www.00gcc.alaska.gov Certified Mail Return Receipt Requested 7018 0680 0002 2052 9433 Plug and Abandonment operations were recently completed on Umiat 18 by Emerald House LLC. The Alaska Oil and Gas Conservation Commission (AOGCC) conditionally approved the Sundry Application (321-114) for the proposed work on March 15, 2021. The following conditions are the focus of AOGCC's investigation: Cementing program to be approved by AOGCC before commencing cementing operations; - Cement chemical injection line before pumping cement plugs into the tubing and IA; - Submit daily reports to AOGCC once operations commence; - Reservoir cement plug verification before placing the surface cement plug, as required in 20 AAC 25.112(g) and as described in the proposed procedure of Sundry 321-114. The All is reviewing whether the abandonment operations at Umiat 18 comported with the requirements of the conditionally approved Sundry. Should you have any questions about this investigation notice, please contact Mr. Bryan McLellan, Senior Petroleum Engineer, at (907) 793-1226 or via email at bryan.mclellan@alaska.gov. Sincerely, JeremyM. 1' 1 I"�'"e"" MeZ M. Prke Price D1e2031NII 1318:11-08W Jeremy M. Price Chair, Commissioner cc: David Wall (Emerald House, LLC) it", J L;tw i (FIFO MAIL' RECEIPT Domestic Mail Only For delivery information, visit our webslte at www.usps.com�. 1 ll1OPostage ail FeEt C3 f1Jices&Eox. and faeaz eP➢mOnatelru RvaiPt $gereipt sPoslmedc C3a Mal Pavaly s Hemlenemre gignature ei s O CO 13 Total Postage and Fees rSent r�-i0,O CA` -----or 6zN'"---"'------%`°0 DX%- ■ Complete items 1, 2, and 3. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mallpiece or on the front if space permits. 1. Article Addressed to: - -- Vie„ ('e ActSe LG� PO fox //2a/2- IIIIIIIIIIIII IIII III IIII III I'IIIII III IIIIII III 9590 9402 4351 8190 1878 67 2. Article Number (Transter from service label) 7018 0680 0002 2052 9433 ❑ Agent D. Is delivery address different from ftem W El&m If YES, enter delivery address below: ❑ No 3. Service Type ❑ Priority Mall Express D Adult Signature ❑ Registered Mi ❑ Adult Signature Restricted Delivery 0 Registered Mail Restricted ❑ CartHletl Mai Del 0 Certified Mail Restricted Delivery ❑ ReturnReceipt for ❑ Collect an Delivery Mercl andlea ❑ Collect on Delivery Restricted Delivery 0 Signature ConBrnatlonTM Ired Mall ❑ Signature Confirmation fired Mall Restricted Delivery Restricted Delivery —r 9500) PS Form 3811, July 2015 PSN 7530-02-000-9053 Off/ - Zi - D Domestic Return Receipt I