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Home My WebLink AboutO 219Other Order 219 Docket Number: OTH-25-018 1. May 19, 2022 Background Information from OTH Order 193 2. April 3, 2025 AOGCC notice of proposed enforcement action 3. April 17, 2025 Hilcorp response to notice of enforcement 4. May 16, 2025 Hilcorp civil penalty payment STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage Alaska 99501 Re: Failure to follow conditions of approval of Other Order 193 ) ) ) ) ) ) Docket Number: OTH-25-018 Other Order 219 Cook Inlet Offshore Platform Well P&As May 12, 2025 DECISION AND ORDER On April 3, 2025, the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to Hilcorp Alaska, LLC (Hilcorp). The Notice was sent via certified mail and was delivered and signed for on April 11, 2025. The Notice proposed a $49,000 civil penalty under AS 31.05.150(a). The Notice also requested Hilcorp provide a written response describing the steps that have been taken to ensure all conditions of approval in Other Order 193 (OO193) are met in 2025 and beyond. SUMMARY OF PROPOSED ENFORCEMENT ACTION: Hilcorp failed to comply with the OO193, condition of approval number 6 by missing the December 1, 2024, deadline for its annual meeting with AOGCC to discuss Hilcorp’s Cook Inlet P&A activities and further described in the Notice of Proposed Enforcement issued. For this violation, the AOGCC proposed to impose a civil penalty on Hilcorp under AS 31.05.150 in the amount of $49,000 ($10,000 for the initial violation plus $500 per day for each of the seventy-eight days that the meeting was late, using the first potential date that Hilcorp requested for the meeting, February 17, 2025). In addition, Hilcorp was requested to provide AOGCC with a written response within 14 days, describing the steps that have been or will be taken to ensure all conditions of approval in OO193 are met in 2025 and beyond, pursuant to 20 AAC 25.300. FINDINGS AND CONCLUSIONS: On April 17, 2025, Hilcorp Alaska, LLC responded to the Notice of Proposed Enforcement and acknowledged missing the deadline for the meeting with AOGCC. Hilcorp submitted actions addressing each condition of approval of OO193 to ensure all conditions of approval are complied with in the future. Hilcorp’s response was submitted within the 14-day deadline. Hilcorp did not dispute failing to comply with OO193 condition of approval number 6 by missing the December 1, 2024, deadline for meeting with the AOGCC, as described in the April 3, 2025, Notice. Other Order 219 May 12, 2025 Page 2 of 2 The AOGCC finds that Hilcorp committed the violation as initially alleged in the Notice and that the proposed $49,000 penalty is appropriate under 31.05.150(g). NOW THEREFORE IT IS ORDERED THAT: Hilcorp Alaska, LLC is assessed a civil penalty in the amount of $49,000 for the violation detailed within this Order. If this Order is not appealed, the fine must be paid within 30 days of issuance. If appealed, the fine will be held in abeyance until the appeal process is complete. As an Operator involved in an enforcement action, Hilcorp Alaska, LLC is required to preserve documents concerning the above action until after resolution of the proceeding. DONE at Anchorage, Alaska and Dated May 12, 2025. Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE 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 part 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. Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.05.12 12:30:25 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.05.12 13:42:03 -08'00' From:Coldiron, Samantha J (OGC) To:AOGCC_Public_Notices Subject:[AOGCC_Public_Notices] Other Order 219 (Hilcorp) Date:Monday, May 12, 2025 1:51:28 PM Attachments:OTHER219.pdf Failure to follow conditions of approval of Other Order 193 Samantha Coldiron AOGCC Special Assistant Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, AK 99501 (907) 793-1223 __________________________________ List Name: AOGCC_Public_Notices@list.state.ak.us You subscribed as: samantha.coldiron@alaska.gov Unsubscribe at: https://list.state.ak.us/mailman/options/aogcc_public_notices/samantha.coldiron%40alaska.go v 4 May 16, 2025 Commissioner Jessie Chmielowski Commissioner Gregory Wilson Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501 Re: Docket Number: OTH-25-018 Other Order 219 Failure to follow conditions of approval of Other Order 193 Dear Commissioners Chmielowski and Wilson: Please find enclosed payment of civil penalty per Docket Number: OTH-25-018, Other Order 219. Sincerely, HILCORP ALASKA, LLC Dan Marlowe Area Operations Manager Cook Inlet Offshore DEM/JLL Enclosure: Check Number 42042771 Hilcorp Alaska, LLC Post Office Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive Suite 1400 Anchorage, AK 99503 Phone: 907/777-8300 Digitally signed by Dan Marlowe (1267) DN: cn=Dan Marlowe (1267) Date: 2025.05.16 14:12:05 - 08'00' Dan Marlowe (1267) 3 04/17/2025 Commissioners –Jessie Chmielowski and Greg Wilson Alaska Oil and Gas Conservation Commission 333 West 7th Avenue Anchorage, Alaska 99501 Subject: Response to Docket Number: OTH-25-018, Notice of Enforcement –Failure to follow conditions of approval Other Order 193 Dear Commissioner Chmielowski and Commissioner Wilson, Hilcorp has reviewed the April 3, 2025 Notice of Proposed Enforcement for failure to follow condition #6 of Other Order 193 (OO 193). Hilcorp acknowledges the late timing of a formal review per OO 193 and submits the following points for your consideration: Background Since the issuance of OO-193 in 2022, Hilcorp has completed P&A activities on the Dillon platform, the subsea Well CI-17489-1A and, most recently, abandonment of the MGS Oil Pool on three wells on the Baker platform in 2024. During and after the 2024 Cook Inlet P&A season, Hilcorp engaged in multiple discussions with the AOGCC on the topic of Cook Inlet P&A activity. These meetings included an October 16th meeting in which the following topics were discussed: x Comparison of P&A operations at specific wells at Dillon and Baker x 2024 P&A project challenges at Dillon, Baker and Middle Ground Shoal x Lessons learned and application of learnings to future P&A programs x 2025 P&A approach and strategy Although this meeting occurred prior to Hilcorp’s submission of its 2024 annual P&A report (submitted November 15, 2024), the discussion that occurred covered much of the substance and content of the 2024 annual P&A report, as required by OO 193 Condition #6. Hilcorp Alaska, LLC Dan Marlowe, CIO Operations Manager 3800 Centerpoint Dr, Suite 1400 Anchorage, Alaska 99503 By Samantha Coldiron at 7:54 am, Apr 18, 2025 On January 21st, the AOGCC notified Hilcorp of the outstanding formal review required per OO 193. Hilcorp immediately agreed to schedule a formal review. Hilcorp reached out on February 6, 2025, to schedule the review with the AOGCC and the review was held on February 19, 2025. Causes of the Oversight Inadequate review of OO-193 conditions of approval resulting in failure to provide required formal review following the 2024 Annual Cook Inlet P&A Report. Contributing Factors Discussions preceding submission of the November 15th report, particularly the October 16th meeting, were incorrectly assumed to have met the requirement of Condition #6, as these discussions covered much of the substance and content of the 2024 annual P&A report. Actions to Ensure OO-193 Conditions of Approval are Met The April 3, 2025 Notice of Proposed Enforcement requests a description of the steps taken to ensure all conditions of OO 193 are met in 2025 and beyond. Existing and new steps being taken are included below: OO-193 Condition 1: “Wells on the Dillon, Baker and Spurr platforms will be P&A’d in 2022, 2023 and 2024 respectively.” Since the issuance of OO-193, Hilcorp has modified the original timeline and prioritization described in Condition 1. Changes are captured in the annual P&A plan updates and discussion with AOGCC per OO-193 Condition 5 & Condition 6. Compliance with Condition 1 of OO-193 will continue to be met by following the plans for abandonment as updated in the prior year’s annual update. On November 28, 2023, Hilcorp met with the AOGCC to discuss the upcoming 2024 Cook Inlet P&A program including plans to abandon wells in the MGS Oil Pool on the Baker platform. In 2024, twelve sundry programs were submitted for reservoir abandonment of the MGS Oil Pool on the Baker platform. Two remaining injection wells, MGS ST 17595 16 & MGS ST 17596 17, are planned to be left open to the MGS Oil Pool for fluids disposal under AIO 7.004 until the conclusion of P&A activity. Of the twelve well reservoir abandonments submitted, seven sundries were approved and three wells’ MGS oil pool abandonments were completed fully with witnessed mechanical integrity tests (MITs) and top of cement tags on 10/8/25. These abandonment programs mimicked recent reservoir abandonments on the Dillon platform. Within the planned work, the abandonment plugging requirements of 20 AAC 25.112 were to be met by isolating the MGS oil pool production strata from other hydrocarbon or freshwater strata within the wells. Individual zones (formerly individual oil pools) within the MGS Oil Pool were not specifically targeted for isolation from each other. Of the five abandonment sundries which were not approved, two were denied by the AOGCC on the basis of the potential for communication between intervals of the MGS Oil Pool below proposed abandonment plugs. On 3/21/25, the AOGCC clarified the requirements for MGS Oil Pool abandonment to include isolation of three continuous intervals within the MGS Oil Pool strata. Based on this interpretation, three of the remaining unapproved well abandonment sundries would meet the AOGCC’s criteria. Hilcorp will work with the AOGCC to determine a path forward for the remaining two wells which have historic plugs & fill within the three intervals of the MGS Oil Pool. Table 1 below includes a summary of the current status of the nine remaining Baker wells awaiting P&A in the MGS Oil Pool. Remaining Baker Wells Requiring P&A of the MGS Oil Pool Well Name Reservoir P&A Sundry MGS Oil Pool Abandonment Remaining Steps MGS ST 17595 5 Approved Work Complete. Needs witnessed tag & MIT MGS ST 17595 6 Submitted - Not Approved Need resubmission of abandonment sundry. MGS BCD and EFG zones separated by CIBP and below fill and CMT retainer. MGS ST 17595 11 Approved Work mostly complete. Needs modified abandonment sundry to include Slickline diagnostics or CTU cleanout of SS and potential cementing up the short string followed by, tags & MIT. MGS ST 17595 13 Submitted - Not Approved Need resubmission of reservoir abandonment sundry. Lower “G” zones below the MGS Oil Pool defined by CO 44. Currently separated from upper zones by two drillable BPs and ~1000’ of fill. MGS ST 17595 20 Submitted - Not Approved Requires approval of original reservoir abandonment sundry MGS ST 17595 23 Approved Requires SL fishing of stuck CIBP then resume reservoir abandonment. MGS ST 17595 28 Approved Approved, reservoir abandonment not started. MGS ST 17595 29 Submitted - Not Approved Requires approval of original reservoir abandonment sundry MGS ST 17595 30 Submitted - Not Approved Requires approval of original reservoir abandonment sundry Table 1:Summary of Remaining Baker MGS Oil Pool P&A Hilcorp is committed to completing the nine remaining Baker wells in a timely and effective manner. Eight of the remaining wells require cementing. Mobilizing cementing equipment and personnel to the lighthoused Baker platform requires significant resources and logistical complexity. Hilcorp will work to confirm path forward for the remaining five abandonment sundries prior to mobilizing for platform cementing. OO-193 Condition 2: “Well P&A activity will begin at the Dillon platform immediately….” Well P&A activity on the Dillon platform was completed in 2023 satisfying this condition. OO-193 Condition 3: “Spurr 05RD3 must have a tree and pressure monitoring equipment installed not later than June 15,2022” Tree and pressure monitoring equipment were installed on Spurr platform well 05-RD3 satisfying this condition. OO-193 Condition 4: Pressure monitoring checks are required on all Spurr wellheads on a monthly basis until the wells at Spurr are P&A’d. AOGCC is to be given an opportunity to witness the platform checks. Results of the monthly checks to be sent to the AOGCC in an Excel table. Pressure monitoring checks are conducted monthly on all wellheads on the Spurr platform. Wellhead pressures are provided to the AOGCC monthly as part of monthly TIO reporting which satisfies this condition. OO-193 Conditions 5 & 6:“No later than November 15th each year Hilcorp shall provide a report……Hilcorp shall meet with the AOGCC no later than December 1st each year to discuss the report….” A Compliance Task Management (CTM) Task has been generated for CIO Operations Engineer, Well Integrity Engineer, Well Integrity Manager and Operations Manager. The task describes the specific required content of the OO 193 report as well as the distinct requirement for a formal review of the report to occur after the report is submitted. Hilcorp remains committed to full compliance with AOGCC regulations and value our ongoing working relationship with the AOGCC. Please let us know if further documentation or clarification would be helpful. If you have any questions, please contact me at (907)283-1329 or Wyatt Rivard at (907)777-8547. Sincerely, Dan Marlowe CIO Operations Manger CC Bryan McLellan Digitally signed by Dan Marlowe (1267) DN: cn=Dan Marlowe (1267) Date: 2025.04.17 15:58:48 - 08'00' Dan Marlowe (1267) 2 Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.aogcc.alaska.gov April 3, 2025 CERTIFIED MAIL – RETURN RECEIPT REQUESTED 7018 0680 0002 2052 9808 Mr. Dan Marlow Hilcorp Alaska, LLC P.O. Box 244027 Anchorage, AK 99524-4027 Re: Docket Number: OTH-25-018 Notice of Proposed Enforcement – Failure to follow conditions of approval Other Order 193 Cook Inlet Offshore Platform Well P&As Dear Mr. Marlow: Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby notifies Hilcorp Alaska LLC (Hilcorp) of a proposed enforcement action. Nature of the Apparent Violation or Noncompliance (20 AAC 25.535(b)(1)). Hilcorp failed to comply with Other Order (OO) 193, condition of Approval number 6 in the calendar year 2024. Basis for Finding the Violation or Noncompliance (20 AAC 25.535(b)(2)). On May 19, 2022, the AOGCC issued OO 193, conditionally granting Hilcorp Alaska, LLC’s (Hilcorp’s) request to delay the previously ordered plugging and abandonment (P&A) of Spurr platform wells until after the wells on Dillon and Baker were plugged and abandoned. The rationale was based on perceived risk, with Dillon and Baker platforms and wells having a higher risk than the wells at Spurr platform. x OO 193 condition of approval number 5 requires an annual report to the AOGCC, no later than November 15th of each year, on the P&A activities that were completed during the previous summer and the plans for the next year’s open water season. Hilcorp timely submitted the report on November 15, 2024. x OO 193 condition of approval number 6 requires that Hilcorp meet with the AOGCC no later than December 1st of each year to discuss the report required in condition of approval Docket Number: OTH-25-018 April 3, 2025 Page 2 of 3 number 5 above. Hilcorp did not attempt to schedule a meeting with the AOGCC by the December 1, 2024 deadline. x Hilcorp sent an email to the AOGCC on February 6, 2025, requesting the meeting and offering potential meeting dates between February 17 and 21, 2025. February 17, 2025, is seventy-eight days after the meeting was due. x The meeting was held at the AOGCC office on February 19, 2025. Failing to meet with the AOGCC by December 1st of each year to discuss the annual Cook Inlet P&A report submitted by November 15th of each year is a violation of OO 193, condition of approval number 6. Proposed Action (20 AAC 25.535(b)(3)). For this violation, the AOGCC intends to impose a civil penalty on Hilcorp under AS 31.05.150 in the amount of $49,000 1 ($10,000 for the initial violation plus $500 per day for each of the seventy-eight days that the meeting was late, using the first potential date that Hilcorp requested for the meeting, February 17, 2025). In addition, within fourteen days of receipt of this letter (next business day if the due date falls on a weekend), Hilcorp is requested to provide AOGCC with a written response describing the steps that have been or will be taken to ensure all conditions of approval in OO 193 are met in 2025 and beyond. The information request is made pursuant to 20 AAC 25.300. Failure to comply with this request will be an additional 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 – Hilcorp 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 Hilcorp an opportunity to submit documentary material and make a written or oral statement. If Hilcorp 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 11th day after it was issued. If such a request is timely filed, the AOGCC will hold its decision in abeyance and schedule a hearing. If Hilcorp does not concur in the proposed action described herein, and the AOGCC finds that Hilcorp 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 1 AS 31.05.150(g) requires AOGCC to consider nine criteria in setting the amount of a civil penalty. Docket Number: OTH-25-018 April 3, 2025 Page 3 of 3 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 Hilcorp 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. Questions regarding this letter should be directed to Bryan McLellan at bryan.mclellan@alaska.gov. Sincerely, Jessie L. Chmielowski Gregory C. Wilson Commissioner Commissioner cc: Phoebe Brooks Jim Regg Bryan McLellan Gregory C. Wilson Digitally signed by Gregory C. Wilson Date: 2025.04.03 14:57:33 -08'00'Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2025.04.03 15:42:25 -08'00' 1 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West 7th Avenue Anchorage, Alaska 99501 Re: Hilcorp’s request to reprioritize the plugging and abandonment plans for wells on the Baker, Dillon, and Spurr platforms in the Cook Inlet Offshore. ) ) ) ) ) ) ) Docket Number: OTH-22-005 Other Order 193 Hilcorp Alaska, LLC Cook Inlet Offshore platform well P&As May 19, 2022 DECISION AND ORDER By email dated December 30, 2021, Hilcorp Alaska, LLC (Hilcorp) requested approval from the Alaska Oil and Gas Conservation Commission (AOGCC) to delay the plugging and abandonment (P&A) of offshore wells on the Spurr platform in Cook Inlet (CI) and proposed to P&A wells on the Dillon and Baker platforms which Hilcorp considered to be higher priority. On January 6, 2022, the AOGCC asked forinformation to support Hilcorp’s request. Hilcorp provided supporting information on January 11, 2022. Because the P&A of all wells on three platforms in CI is a matter of public interest, on its own motion, AOGCC set a public hearing to discuss Hilcorp’s P&A plans for wells on the Baker, Dillon, and Spurr platforms. Pursuant to 20 AAC 25.540, the AOGCC scheduled a public hearing on March 29, 2022. On February 10, 2022, the AOGCC published notice of that hearing on the State of Alaska’s Online Public Notice website and the AOGCC’s website, electronically transmitted the notice to all persons on the AOGCC’s email distribution list and mailed copies of the notice to all persons on the AOGCC’s mailing distribution list. On February 13, 2022 the notice was published in the Anchorage Daily News. On March 29, 2022, the AOGCC held the hearing. FINDINGS: 1. Hilcorp performed an assessment of the long-term shut in wells on the Dillon, Baker and Spurr platforms in CI that included subsurface and surface risk factors. Based on the assessment, Hilcorp proposes to P&A wells on the Dillon, Baker and Spurr platforms in 2022, 2023 and 2024, respectively. 2. Dillon platform is considered to have the highest subsurface risk, and thus be the highest priority candidate for P&A operations, since most of its wells do not have any downhole cement plugs. In contrast, the wells on the Spurr platform are lower priority since all have at least one cement plug between the reservoir and the surface. 3. Hilcorp performed a structural assessment of the platforms in November 2021, including the condition of leg and tidal zone, jacket stresses, cathodic protection, power supply and pipelines. Based on this assessment, Dillon platform is considered to be the highest priority for well abandonment followed by Baker platform and then Spurr platform. Other Order 193 May 19, 2022 Page 2 of 3 4. Production and injection operations ceased on the Dillon, Baker and Spurr platforms in 2002, 2014 1, and 1992, respectively. 5. In 2009, based on information provided by the operator, AOGCC determined that the wells on the Spurr platform had no further utility. Marathon, the operator at the time, planned to P&A the wells by 2013. Before the wells were P&A’d, the asset was purchased by Hilcorp which requested an extension to re-evaluate the platform for potential startup. In 2017, Hilcorp’s applications for well suspension renewals were denied by the AOGCC for a lack of future utility. The AOGCC approved limited well suspension sundries on the conditions that a timeline was set for well P&As and Hilcorp submit a yearly progress report. Hilcorp has taken four years to get the Spurr platform in a condition to support the well P&A campaign. Well P&As on the Spurr platform were planned to start in 2021 but were delayed again due to crane malfunction. 6. Suspension sundries for wells on the Spurr platform expired on December 31, 2021. 7. Hilcorp states that the cranes and helidecks on the Dillon and Baker platforms are operational and do not need additional integrity inspections. 8. Well 05RD3 on the Spurr platform does not have a tree or pressure monitoring equipment. 9. Potential undeveloped hydrocarbon resources near the Dillon, Baker and Spurr platforms could be accessed and drilled from the open well slots on other nearby platforms. CONCLUSIONS: 1. The P&A of wells with no future utility is required per 20 AAC 25.105. 2. P&A operations on wells on Dillon, Baker and Spurr platforms are appropriately ordered in accordance with the ranking of surface and subsurface risks. 3. Due to delays in the P&A of wells on the Spurr platform, it is appropriate to set dates by which wells on Dillon, Baker and Spurr platforms will be P&A’d. 4. Suspension sundries for wells on the Spurr platform expired on December 31, 2021 and will not be renewed because the wells have no future utility. 5. P&A of the existing wells on Dillon, Baker and Spurr platforms still allows for development of future hydrocarbon resources via the open well slots on the nearby platforms. NOW THEREFORE IT IS ORDERED: Hilcorp’s request to reprioritize the P&A plans for wells on the Baker, Dillon, and Spurr platforms in the Cook Inlet Offshore is GRANTED per the following conditions: 1. Wells on the Dillon, Baker and Spurr platforms will be P&A’d in 2022, 2023 and 2024, respectively. 1 2014 is when all production from the Baker platform ceased, oil production ceased in 2003. Other Order 193 May 19, 2022 Page 3 of 3 2. Well P&A activity will begin at Dillon platform immediately and is to be completed by the end of the ice-free season. If for some reason P&A activity cannot begin on Dillon platform, then P&A activity at Baker will take place according to this timeline. 3. Spurr 05RD3 must have a tree and pressure monitoring equipment installed not later than June 15, 2022. 4. Pressure monitoring checks are required on all Spurr wellheads on a monthly basis until the wells at Spurr are P&A’d. AOGCC is to be given an opportunity to witness the monthly platform checks. Results of the monthly checks to be sent to the AOGCC in an Excel table. 5. No later than November 15 th of each year, Hilcorp shall provide a report to the AOGCC on the P&A activities that were completed during the previous summer and the plans for the next year’s open water season. The report shall include, but not be limited to, the following information: a. A well-by-well discussion of how the P&A of each well went and how this compared to what was anticipated; b. A discussion of challenges and lessons learned during the P&A operations; c. A discussion of how these lessons learned will be applied to the future P&A programs; and d. A discussion on whether or not the P&A scheduled ordered in 1 above needs to be adjusted and why. e. An update on the maintenance, functionality and integrity of equipment on the Spurr platform to ensure that it will be in a condition to P&A wells in 2024. 6. Hilcorp shall meet with the AOGCC no later than December 1 st each year to discuss the report required in 5 above. DONE at Anchorage, Alaska and dated May 19, 2022. Jeremy M. Price Daniel T. Seamount, Jr. Jessie L. Chmielowski Commissioner, Chair Commissioner Commissioner RECONSIDERATION AND APPEAL NOTICE 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 part 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 recon- sideration 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. Dan Seamount Digitally signed by Dan Seamount Date: 2022.05.19 10:28:54 -08'00' Jessie L. Chmielowski Digitally signed by Jessie L. Chmielowski Date: 2022.05.19 11:41:29 -08'00' Jeremy Price Digitally signed by Jeremy Price Date: 2022.05.19 12:46:26 -08'00'