UNITED TATE E VIRONM ~NTAL PROTECTIO AGE C

HE ION 8 2011 UG 29 : IB

1595 WY KOOP TREET

D R1 0 80202-1129

Phone 800-227-8917

bttp://www.epa.go /region08

00 KET 0.: -08-2011-0027

IN THE MATTER OF';

L: P TTED HAWK D V tLOP iNT,

AND

:HD OIL & GAS, LL

Respondent

)

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)

)

)

)

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R ER ,RA TI ~JL

OF AN ELECTRO JC

rOiNS,F,NT AG REE

FINAL ORDER

Pur uant to 40 C.F.R. §22.13(b) and 22.18, of EPA S onsolidated Rul s of Practic , the

'on 'ent Agr emenl resolving thi matter is her by approved an incorporated by r fercnce into

this -inalOrder. Th R pondent is hereby OR RED to comply with all ofth' terms o1'th

'ol1"cnl Agreem nt clTcctive imm uiatcly up n r ccipt by R>sp nd 'nt orthis 'on~ nt

Agr m nt and final rder.

This court will accept the lectronic filing ofthe Consent Agreement in tlli matter at tIus

time. however the Parties are to file the original Consent Agreement witbin seven days of

i suanCl: rthi. OnJ r.

The Pani arc hereby ORDERED to comply with all ofthe terms of this Order,

effective immediately upon receipt by Partie ofthi Order.

.'0 ORO RED THI eYCr~ Da of Clu-guafEIyana R. • 11

Regional Judicial Officer

,2011
UNITED STATES

ENVIRONMENTAL I'ROTECTION AGEN<NII AUG 29 PII 3: \8

REGION 8

Docket NO.-CAA=08-20l J-0027

In the Mauer of:

SParrED HAWK DEVELDPMI'NT. LLC )

& )

SHD OIL & GAS, LLC )

)

Respondent.

ADMINISTRATIVE COMPLAJNT

AND CONSENT AGREEMENT

AUTlJORITY

The United States Environmental Protection Agency, Region 8 (EPA or Complainant) is issuing

Ihis AdminiSlmlive Complaint and Consent Agreement (Agreement) to Spotted Hawk Development,

LLC and SHD Oil & Oas, LLC (Respondents) pursuant to Sections 113(a)(3) and 113(d)(I) ofthe Clean

Air Aet(CAA Orlhe Act), 42 U.S.C. § 7413(a)(3) and § 7413(d)(I). The AdministralOr ofthe EI'A hns

the authority 10 enter into this Agreement and that authority has been property delegated to the

undersigned EPA official.

A. STATUTORY AND REGULATORY BACKGROUND

I. On June 19. 1978. EPA promulgated the Prevention or Significant DClcrionllion (PSD) regulations

pursuant to Subtitle I. Part C oflhe Act. 43 Fed. Reg. 26403. EPA revised the PSD regulations 00

several occasions including August 7, 1980 (45 Fed. Reg. 52676) and December 31,2002 (67 Fed. Reg.

80186). '!'hese regulations are codified at 40 C.F.R. Part 52.

2. Tenns used in this Agreemcnll.hat are defined in the Act or in regulations promulgated pursuant to the

Act shall have the meanings assign.ed to them therein, unless otherwise provided in this Agreement.

3. The emission sources to which lhis Agreement relates arc in "'ndian COWltry" as defined 3t 18 U.S.C.

§ 1151. The locations of the emission sources are identified in Appendix A.

4. Section 165(a) ofthe Act. 42 U.S,C. § 7475(a), and the PSD regulations implementing Part C at 40

C,F.R. § 52.21 (a)(2Xiii), prohibit a major stationary source from commencing construction or major

modification of a major stationary source without a penniI which states that the majorstationary source

or modjfication would meet the requirements of40 C.F.R. § 52.210) through tr).

5. 40 C.F.R. § 52.21 (b)(5) defines a "stationary source" as, any building, structure, facility or installation

which emits or may emit a regulated PSD pollutant.

6. 40 C.F.R. § 52.21(b)(1 )(iXb) defines a "major stationary source" as, among o'her things, any sta,ionlU)'

source that emits, or hos the potential to emit, 250 Ions JX:r year or more orany rcgultncd PSD pollutant.
7. On July 1,2011, EPA promulgated final rules titled "Review of New Sources and Modifications in

Indian Country." (Tril"'l Minor NSR Rule) 76 Fed. Reg. 38748·808 (July 1,2011) (10 be codified at 40

C.F.R. Parts 49 and 5J). Tbe final rules are effective on Augu5I 30. 20 JI. 76 Fed. Reg. al 38748. Once

cffcctiv~. the rules allow, among other things. lor a synLhetic minor source pemlit to be issued to un

otherwise major source that has taken a restriction. enforceable as a legal and practical matter. so that the

source's potcntial to emit is less than the amounts for major sources.

8. This proceeding is governed by the Consolidatcd Rules of Practice Governing the AdminisLratjve

Assessment ofCivil Penalties. and the Revocation, Tennination or Suspension of Permits (Consolidatcd

RuIL'S) set fortb al40 C,F.R. Part 22. Tbe U.S. Department ofJuslice bas concurred witb EPA Region

8's requcst for authorization to commence all administrative enforcement action in this matter.

9. 'Ibis Agreement is voluntarily entered into by the EPA and the Respondent for the purpose of

simultaneously commencing and concluding this matter, as authori7..ed by 40 C.f.R. § 22.13(b), and

exccoted porsoant to 40 C.F.R. § 22.18(b)(2) and (3) oftbe Consolidated Rules.

U. INTRODUCTORY PROVISIONS

I. This Agreement uddresscs a unique situation in that the Respondent is unable to obtain an effective

synlhetic minor source permit from EPA prior to commencing conslnlction because, pursuant to the new

TribaJ Minor NSR Rule, Ule authority to issue such permits hegins August 3D, 2011,

2. This Agreement is entered into by EPA and Respondent to settle alleged violations and allow

ReSpOndents to comply as ex.peditiously as possible with !.he requirements ofthe CAA, sp<..-cifically PSD,

of certain Bakken FonnaLion Oil and Gas Emission Sources (emission sources) owned and/or operated

by Respondent. located within the exterior boundaries ofthe Fort Berthold Indian Reservation in Norol

Dakota as described in Appendix A.

3. Respondent admits the jurisdiction!Ll allegations in this Agreement but docs nol admit lhe specific

factual allegalions or legal conclusions made by lhc Complainanl herein.

4. Respondent waives its rights to u hearing before <lny tribunal and to contest any issue of law or fact set

forth in Ihis Agreement.

5. Complainant asserts that scttlement oftltis maller is in the public interest. Complainant and Respondcnt

a.gree that resolving this matter without f\lrthcr litigation and without adjudication of any issue of fact or

law is appropriate.

6. This Agrt:t:mcnl, which includes Appendices A and B, upon incorporation into a Final Order, applics 10

and is binding upon EllA and upon Respondent, and Respondent's officers, directors, employees, agents,

Successors and assigns.

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7. Tltis Agrccmem contains all terms of the settlement agreed to by the EPA and Respondent.

C. ALLEGED VIOLATIONS

I. Respondent is II limited liability corporation and therefore a uperson" as defined in section 302(c) of the

CAA. 42 U.S.C. § 7602(e).

2. Respondent owns and/or operates Lhe emission sources described in Appendix A.

J. Complainant alleges that Respondent violated Lhc CAA by construcling each oflhe major stationary

sources identified in Appendix A, Table A~I without first Obtaining a PSO permit pursuant to 40 C.F'.R.

§ 52.21.

O. REQUIREMENTS UNIJER TIns AGREEMENT

The EPA and Respondent. by their undersigned representatives, hcreby consent and agree as follows:

I. Jlennitting

n. Within one year ofthc effective date of this Agreement for all Existing Emission Sources listed

in Appendix A, Table A-I, Respondent shall submit to EPA a complete synthetic minor source

permit application under EPA's Tribal Minor NSR Rule. IfRespondent determines thai 3n

emission source was incorrectly included in Appendix A, Table A-I, it may notify EPA ofthat

fact by October (4.2011. In this circumstance, Paragraph F.13 below shall apply.

b. By October I, 20 II. Respondeot shall submit to EPA a complete synthetic minor source pennit

application fOf New Emission Sources listed in Appendix A, Table A-2 that will commence:

construction during the period staning August 3),2011, and ending December 31, 2011.

c. rly November 1,20 II, Respondent shall submilto EPA a complete synthetic minor source

pennit application for New Emission Sources listed in Appendix A. Table A·] that will

commence construction during the pcriod starting January I, 2012, and ending Mlirch 31,2012.

d. By January 1,2012. Respondent shall submit to EPA a complete synthetic minor source pennil

application for New Emission Sources listed in Appendix A, Table A·4 that will commence

construction during the period starting April 1, 2012, and ending June 30, 2012.

e. Any emission SQurces ror which construction will comm~ncc Ilncr June 3U. 2012. ure 110t ~ubjcct

to this Agreement and Re)']>Ondcnt Olust obtain an clr~ctiw. Synthc,lic minQr source pennit from

E1)A or comply with lhl: provisions of40 C.F.R. § 52.21 prior 10 commencing construction.

r. Inclusion nfoll emission source listed in Appendix A. Table 1\.2, A·J or A·4 does not predudc

Respondcnt from commencing conslructjon of lh.'ll emission source nficr the dale spi."Cifi«1 in lhe

relevant 1'1Irngmph D.l.b.o. and d above However. all sueh emission sources must commencc

construction prior to June 30, 2012.

g. if those emission sources listed in Appendix A, Tables A·2, A·3, and/or A·4 do not commenCe

)
constnlction by June 30, 2012, then they nre therefore not subject to Section Dof this

Agreement.

2. Control Requirements

a. For all Existing Emission Sources listed in Appendix A, Table A-I, the Respondent shall comply

with lhe requirements of Appendix 13 by no later than December I, 20 II.

b. For all New Emission Sources listed in Appendix A, Tables A-2. A-3, and A4 the Respondent

shall comply with Lhe requirementS orAppendix B upon stan-up or production. Emission

sources that receive an effective synthetic minor source penniL before commencing construction

are not subject to the requirements of this Agreement.

3. Notification

Respondent shall nOli ry the EPA on the last business day of each month of all of the emission

sources subject to this Agreement that COmmence construction i.n the previous month. Respondent shall

also notify the EPA whether those emission sources are meeting the control requirements as required by

Appendix Band whether they have received an effective synthetic minor Source pennit. This notice

shall also include n Iis( of emissions sources that are removing a 98% control device and using a 90%

control device as outlined in Appendix B.

Unless otherwise specified herein, whenever Respondent's notification, submissions, or

communication are required by this Agreemenl, they shall be made electronically or mailed to the

following:

Cynthia J. Reynolds. Director

U.. EPA Region 8 (8ENF.Al)

Air & Toxics Technical Enforcement Program

1595 Wynkoop Sl.

Denver, CO 80208-1129

revnolds.cvnthia(Q);cpa.gov

E. CIVIL PENALTY

1. Pursuant to an analysis of the facts and circumstances ofthis case with the statutory factors described in

seclion 113(d)(J)(B) of the CM, 43 U.S.C. §7413(d)(1 )(B), EPA has detcrmined that an appropriate

civil penalty to settle this action is the amount of $3.000 per emission source listed in Appendix A ror a

lotal of $15,000.

2. Rcspondcnl consents to the issuance of a rinal Order and consents for the purpose ofsettlement to lhe

payment of the civiJ penaJty in the manner described below in this paragraph:

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8. Payment is due within 90 calendar days from tJle date oftile Final Order, to be issued by the

EPA's Regional JlIdicial Officer, that adopts this Administrative Camplaim and Consent

Agreement. If the due dale falls on a weekend or legal federal holiday, then the due date

becomes the next business duy. The date the payment is made is considered to be the date

processed by the Bank described below. Payments received by t 1:00 AM are processed on the

nexl business duy.

b. The paymern shaU be made by remitting a cashier's or certified check, including the nwne nnd

docket number ofthis case, for the calculutcd amount, payable to "Treasurer. United States of

America;' to:

CHECK PAYMENT:

US Environmental Protection Agency

Fines and Penalties

Cincinnati Finance Cenler

PO Box 979077

SI. Louis, MO 63197-9000

OVERNIGHT MAIL:

U,S, Bank

1005 Convention Plaza

Mail Station SL-MO-C2GL

I. Louis. MO 63101

Contact: Natalie Pe~rson

314-418-4087

WIRE TRANSFER:

Wire Transfers should be directed to the Federal Reserve Bank of New York

Fcdeml Reserve Bank of New York

ABA =021030004

Account =68010727

SWIFT address = FRNYUS33

33 Liberty Street

New York, Y 10045

Field Tug 4200 oflhe Fcdwire message should read AD 6801727 Environmental Protection

Agency

ACH (also known as REX or remittance express):

Automated Clearinghouse (ACH) for receiving US currency

I'NC Bank

808 17- Street, NW

Washington, DC 20074

5
Contael B Jesse White 301-887-6548

ABA 051 036706, Trdnsaetion Code 22- checking

Environmental Protection Agency. Account 31 0006, CTX Formut

ON-LINE PAYMENT:

There is now an On Line Payment Option. aVtlilable through the Dept. ofTreaslJry. This payment option

can bl.: accessed from the information belov.::

WWW.ooy.gov

Entersfo 1.1 in the search field. Open form and complete required fields.

A copy ofthe check, or wire transfer, shall be sent simultaneously to:

Alexis North (8ENF-AT)

U.S. E['A Region 8

Technical Enforcement Program

1595 Wynkoop SI.

Denver, CO 80202-1129

und Tina Artemis

Regional Hearing Clerk (8Re)

U.S. EPA Region 8

1595 Wynkoop Sl.

Denver, CO 80202-1129

c. Payment of the penally in this manner does not relieve Respondent of its obligation to comply

with the requirements orlhe eAA and its regulations.

11. GENERAL PROVISIONS

1. The emissions controls required in Appendix: 13 under this Agreement shall be considered "federally

enforceable" :md, as applicable, "legally and practicably enforceable" for purposes ofcalculating the

potential 10 emit for the emission sources covcrt.-d under this Agreement.

2. Failure by Respondent to timely apply for, and ultimately obtain, Ihe synthetic minor pcrmjl for any

emission source identified in this Agreement or to comply with the requirements of eetion D and

Appendix Bsha.ll render llllY release or satisfuction ortiabilily afforded under this Agreement null and

void as to thai source.

J. Nothing in Ihis Agreement shall be construed as n waiver by lhe EPA or any other fc..-dcraJ entity of ilS

authority 10 seek costs or any appropriate penalty associated with any collection action instituted as a

result ofRespondent's failure to perform pursuuJlt to the temlS oflhis Agreement.

4. Once Ihe Respondenl has received a synthclic minorsource pennil from EI'A for the cmission source

identified in Appcndi.x A, and that permit has become effective, the terms oflhat permit supersede lhis

Agreement.

5. For all Existing Emission Sources listed in Appendix A, Table A·l, Respondent's submission ofa

complete synthetic minor source permit application will constitute compliance with the relevant CAA

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provisions during the period ofthis Agreement,

6. Por all New Emission Sources listed in Appendix A, Tables A-2, A-3, and A-4, compliance with the

relevant CAA provisions requires that Respondent; a)obtains an effective synthetic minor source permit~

b) is subjecl to an EPA approved Federallmplemcnlation Plan which allows for u permit by rule; or c)

complies with a new I:PA applicable CAA regulation that removes them from P Dapplicability

7, Notwithstanding the terms of this Agreement, the Respondent must meet any other applicable

requirements orthe Act or its implementing regulations,

8. Respondent agrees that lor any emission source opermed without the controls required by this

Agreement, except lor instances ofmalfunction, Resporldent is in violation ofthis Agreement

Malfunction shall be dcllned as any sudden, infrequent, and nol reasonably preventable failure of air

pollution control equipment. process equipment, or a proct:Ss to operate in a normal or usual manner,

caused by circwnstanccs entircly beyond the control orthe owner or operator, but shall not include

failures that are caused in whole or in part by poor maintenance or careless operation.

9, Respondent agrees that any emission source whose IIctual emissions have exceeded 250 tons per year is

not covered by this Agreemcnt. including any emission source listcd by the Respondent in Appendix A,

10. Each undersigned representative ofthe EPA and Respondents (parties) to this Agreement certifies that

he or she is fully authorized by the Party represented to bind the Party to the terms and conditions of this

Agreement and to execute and legally bind that Parry to this Agreement.

11. The Panics agree to submit this Agreement to the Regional Judicial Officer, with a request that it be

incorporuled into a Pinal Order.

12. The tenus, conditions, and compliance requirements orthis Agreement mllY not be modified or amended

except upon the wrilten agreement afboth parties, and approval ofa Regional Judicial Omcer.

13. I[the Respondent, pursuant 10 Paragraph O.l.a. above, wishes to amend the list ofcmission sources in

Appendix A. Table A4 1, it shall submit those suggested changes to EPA for approval. If c!JA agrees

with the suggested changes, the Parties will submit an amended Agreement to the Regional Judicial

Officer for incorporation into a revised Final Order,

14. The effective dale ofthis Agreement is the date that the Final Order is signed by the Regional Judicial

Officer.

15. This Agreement, upon incorporation into a Final Order by the Regional Judicisl Omcer and full

satisfaction by the Porties, shall be 8 complete, full and final sculemcnt oflhe violations ulJeged illlhis

Agrecment.

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· Each Party shall b ar its own ost and attorn ys fees in cOlln eLion with all is ues as 0 iated with this

Agreement.

lIED TATE, lNV1RO MENTAL

PR TECTION AGE Y REG rON 8

mplainant.

Date: ~_-"f.--X>_".;...fj_

ate: Au usl 6 2011

Dul: ugusl 26 201 1

PO ED HAWK D'V L PMENT, LL

R p udene

'HDOLL&G LL

Re poodent.

A" LL
APPENDIX A

EMISSION SOURCE INVENTORY

Table A·! Existing Emission Sources (commenced construction by August 30 2010

Source Latitude nnd Section, Well site Casinghead Casinghead Tanksffank TanksITank

Name Longitude Township, completion gas gas control Battery Battery

Range date controlled device control control

or captured device device

install date

Simbn Latatude North 30,150,90 4/5/10 Controlled Treater No

24- 47 deg 46 min flare

30H 40.91 sec North

Longitude West

102 deg 15

minutes 4.08 sec

Table A-2 New Emission'Sources (commencing construction between August 31, 2011 and

December 31 20 III

Source Section, Expected

Identification Township, Commence

Range Construction

Date

Alnha21-IRH 1815091 10/11

Table A-3 New Emission Sources (commencing construction between January 1,2012 and

March 31 2012\

Source Section, Expected

Identification Township, Commence

Rangc Construction

Date

Bela 21-18H 18,150,91 January

2012

Garnma21-18H 18150,91 March 2012

2
-11-

Table A-4 New Emission Sources (commencing construction between April 1,2012 and June 30,

20m

Source Section, Expccted

Identificatian Township. Commence

Range Construction

Datc

Delta 21-18;1 1815091 ADril2012

J
APPENDIX B

EMISSION CONTROL REQUIREMENTS

A. Applicability

·I'hesc requirements apply to existing and new emission sources associated with oil produclion from

the Bakken Formation on the Fon Berthold Indian Reservation in North Dakota llnd largcllhe control

ofca.~inghead gas emissions (a/so known as lrCulcr gus) nnd emissions from ail and produced water

storage tanks (tanks).

n. Control RC(luircmCl1ls

All casinghead gas and lank emissions must be controlled or captured upon start of production. Ifgas

gathering infrastructure is in place, casinghead gns shall be rouled to a gas gathering pipeline as soon

US pruclicable. When a pipeline is nOI available, casinghead gas is required to be routed to a control

system or device in the Control ySlcm List below. The Control System List also applies to emissions

from oil and produced water storage tanks. Capture or control devices shall be opel'lltoo 81 all times

when emissions mu)' be vented to them.

'I'he owner/operator shullllluintain and operate all air pollution control equipment, and all equ iprncnt

employed to contain and collect vapors and transport them 10 the emission control system or device,

in accordance with the manufacturer's recommendations and in a manner consislenl with good air

pollution control practice for minimizing.emissions.

C201rol System List

I. A ground pil narc (including, but not limited IU pil nares, shop built flares or other similar

oilfield lype flares) or other 90% or greater DRE device. If aground pit narc is utilized, a

90% DRE to be 8::isumed. This is considered the minImum level ofcontrol for tank and treater

gas emissions at all times.

2. A vapor recovery unit or oil stabilizer thut is designed and operated to reduce the mass content

of VOC and total hll7..ardous air pollutant (I-IA I) emissions in the vapors vented to the device

by at least 95% by weight.

J. An enclosed combustion device appropriately sized for the site's operating parameters and for

which the manufacturer represelHs will achieve II destruction efficienoy ofalloast 95% ofthe

VOCs with respect to the volumetric now and RTLJ content ofthe sile's wa..c;te gas stream. An

enclosed combustion device is operated including. but not limited to the following:

• This device i:hould be operated widl no visible emissions l:Xl:CPl for periods nOlto

exceed u total of5 minutes during any 2 consecutive hours; Method 22 of40 CFR

Appendix A shall be used to detennine the compliance with this visible emission

provision.

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• Owner/opcrntorshall install nn appropriate, reliable temperalure sensor/transmitter

that indicates continuous ignition ofthe pilot flame on the control device, The

sensor/trllnsmiuer will be connected to Ihe site's Supervisory Control and Data

Acquisition (SCADA) System. The SCADA system will record temperature reading~

at a specified frequency and will be programmed to trigger an alarm iftcmpcmtures

oUl~ide ora pre-programmed range tire detected. For Ille purpose ofthis paragraph,

"continuous" monitoring equipment shall meusurc and record values nt least once

every hour.

4. A utility flare (using an open flame without enclosure) that is designed and operated to reduce

the mass content of VOC and total HAP emissions in the vapors vented 10 Ihe device by at

least 98% by weight. A utility nare is any narc that is designed and operated in accordance

with the requirements of40 C,F.R § 60,18. RequiremclILs of40C.F.R § 60.18 include, but arc

nOllimited to Ihc follOWing:

• Flare shall be designed and operated wilh no visible emissions except for periods not

to cxceed a tOlal of 5 minutes during an)' 2 consecutive hours; Mcthod 22 of 40 eFR

Appendix A shall be used to determine the compliance with this visible emission

provision;

• Flare shall be operated with a l1ame presenl at:ill times;

• An owner/operator has the choice ofadhering to either Ihe heal content speciJications

in paragraph 40 C.F.R. § 60. I8(e)(3)(ii) and Ihe maximum tip velocity specifications

in paragraph (e)(4) or adhering to the requirements in 40 C.f.R, § 60. I8(cX3)(i)j

• Flares used 10 comply with this section shall be steam·assisted, air·llssistcd or

nonassisted;

• Owncrslopel11tors of narcs shall monitor the control devices to cnsure thut thc)' arc

operated <1nd maintained in conformance with their designs;

• The presence ofa narc pilot name shall be monitored using 8 thermocouple or an)'

other equivalcllt deviec to detect the presence of a flame. Continuous checks by an

operator to verify the existence ofa visible nume or 10 verify proper opcmlion orthe

igniter may be used in lieu of a physical device. For the purpose oflhis paragraph.

"continuous" monitoring equipment shall measure and record value..li at least once

every hour.

• For safely and oir pollution control purposes: each narc mUSl be equipped and

operated wilh an automatic ignitor or a continuous buming pilot, which must be

maintained in good working order. '111i5 is required even ifthe flure is used lor

emergency purposes only.

Control devices other Ihan those listed above may be ulilized upon approval from the EPA.

C. Rl.'Cordkecplng Requlrcmcnls

1. Owner/operator shall maintain control device tempcmture logs for Ihrec years.

5
CERTIFICATE OF SERVICE

The undersigned certifies thal the origin;]! of the attached ORDER GRANTINC

~:LECTRONIC FILING OF CONSENT AGREEMENT AND FINAL ORIJER in the

matter ofSPOTTEIJ HAWK IJEVELOPMENT, LLC., and SHIJ OIL & GAS, LLC.;

I)OCKET NO.: CAA-08-2011-0027, was filed with the Regional Ilearing Clerk on August 29.

2011.

Further, lile undersigned certifies that it true and correCI copy of the document was

delivered to Jim Eppers. Enforcement Attomey. U.•. EPA - Region 8, 1595 Wynkoop Street.

Denver, CO 80202-1129. True and correct copics orthe aforementioned documents were

placed in the United States mail on August 29. 2011. to:

Demarco J. Bell. EVP

Sponed Ilawk Development

1650 Tysons Blvd, Ste 900

McLean. Virginia 22102

And cmailcd lo:

E1i1--,lbcLh Whitsel

U. S. Environmental Prolection Agency

Cincinnati Finance Center

26 W. Martin LUlhcr King Drive (MS-0002)

Cincinnati, Ohio 45268

August 29, 2011 J<4a.J~ Tina Artemis

ParalegallRcgional Hearing Clerk