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Home My WebLink AboutO 153Other Order 153 1. May 7, 2019 Enforcement action Missing Meter Performance Reports 2. May 17, 2019 Hilcorp request for informal review 3. May 20, 2019 AOGCC scheduling of informal review 4. June 6, 2019 Informal review sign in sheet 5. ---------------- CONFIDENTIAL information held in secure storage 6. June 21, 2019 Hilcorp follow up from informal review STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage Alaska 99501 Re: Missing Meter Performance Reports ) Other Order No. 153 Custody Transfer Meters ) Docket OTH-19-015 Granite Point Unit ) Trading Bay Unit ) June 12, 2019 DECISION AND ORDER On May 7, 2019 the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to Hilcorp Alaska, LLC (Hilcorp) regarding Granite Point Unit and Trading Bay Unit oil custody transfer meters based on Hilcorp's failure to submit required meter performance reports. The Notice proposed specific corrective actions and a $30,000 civil penalty under AS 31.05.150(a). Hilcorp requested an informal review. That review was held June 6, 2019. Summary of Proposed Enforcement Action: The Notice identified violations by Hilcorp of (1) Conditional approval letter for the changes and upgrades to Granite Point Unit custody transfer oil measurement equipment dated February 7, 2019; and (2) Conditional approval letter for the changes and upgrades to Trading Bay Unit custody transfer oil measurement equipment also dated February 7, 2019. The Notice proposed civil penalties of $30,000 - as follows: - $15,000 for the initial violation — failure to provide meter performance report as specified in Granite Point Unit condition of approval 21; and - $15,000 for the initial violation — failure to provide meter performance report as specified in Trading Bay Unit condition of approval 21 The Notice also proposed that Hilcorp submit the required information and describe how it will prevent recurrence of this violation. Violation - Failure to Submit Required Custodv Transfer Meter Performance Reports; Changes to the custody transfer oil measurement equipment for Hilcorp's Granite Point and Trading Bay Units were conditionally approved by AOGCC on February 7, 2019. Requirements imposed included the meter prove frequency, notification to AOGCC for opportunity to witness meter proves, required actions before making changes to the custody transfer measurement equipment, and reporting obligations following proves. Hilcorp recommenced flow through oil custody transfer measurement systems at the Granite Point Unit Tank Farm and Trading Bay Unit Production Facility after completing modifications to the 'AOGCC Docket OTH-18-042, Granite Point Unit; AOGCC Docket OTH-18-044, Trading Bay Unit. Meter changes and upgrades are designed for the Cross Inlet Pipeline Extension Project by providing two sizes of custody transfer meters at each production facility to allow for variable flow rates. Other Order 153 June 12, 2019 Page 2 of 4 meters. An AOGCC Inspector witnessed functional checks and initial meter proves at the Trading Bay Unit Production Facility on March 1, 2019 and at the Granite Point Unit Tank Farm on March 2, 2019. On April 1, 2019 and May 1, 2019 Hilcorp performed required monthly meter proves at both locations — AOGCC waived its right to witness these proves. Condition 21 of each approval letter requires that Hilcorp "Provide results of each meter proved within 7 days following completion of monthly meter proves, including i. Prove reports ii. Batch summaries iii. Current meter factor control charts — as described in API MPMS 13.2 — with the following fixed control limits that are used to determine when to initiate recalibration of instruments, inspections, adjustments, cleaning, or repairing of mechanical equipment, or audits of the measurement system: 1. +/--0.25% meter factor deviation between consecutive proves 2. +/--0.50% meter factor deviation between current and baseline proves" Reports from meter proves and transmitter calibration checks were provided to the AOGCC Inspector on March 5, 2019 — no meter factor control charts were included in Hilcorp's submittal. Also, no results were provided for the meters proved on April 1 and May 1, 2019. By email dated May 16, 2019 Hilcorp provided copies of the reports required in the two conditional approval letters. By letter dated May 17, 2019 Hilcorp acknowledged receipt of the Notice and requested an informal review of the matter. The informal review was held June 6, 2019 during which time Hilcorp asked several clarifying questions and provided verbal assurance that corrective actions have been implemented. Mitigating Circumstances: The factors in AS 31.05.150(g) were considered in determining the appropriate penalty. Hilcorp's lack of good faith in its attempts to comply with the imposed conditions, its history of regulatory noncompliance and need to deter similar behavior are the factors which most heavily influence AOGCC's decision and the penalty being assessed: - The failure to submit information related to meter performance — specifically the meter factor control charts — cannot be characterized as a good faith attempt to comply with the AOGCC's conditional approval letters. - Acceptance of arguments that the conditions of approval are new provisions to Hilcorp operations personnel responsible for overseeing the custody transfer meters at Granite Point and Trading Bay Units would essentially encourage personnel not to familiarize themselves with the requirements of applicable orders and regulations. There is nothing ambiguous about the approval conditions requiring submittal of meter prove results, and the requirements are consistent with the industry recognized practices found in API Manual of Petroleum Measurement Standards.2 - The absence of equipment performance tracking information such as the required meter factor control charts compromises the ability of AOGCC to make informed, fact -based decisions about how frequently to witness meter proves. - Hilcorp's history of noncompliance in Alaska is well documented through various AOGCC enforcement actions. While improvements in Hilcorp's compliance can be shown in the past 2 years, the recurrence of failing to account for approval conditions I Incorporated by reference into AOGCC regulations at 20 AAC 25.228 Other Order 153 June 12, 2019 Page 3 of 4 imposed by AOGCC calls into question the effectiveness of corrective actions implemented in responses to past enforcement actions. Mitigating circumstances considered in the assessment of the proposed civil penalty include Hilcorp's partial submittal of information requested by the AOGCC Inspector who witnessed meter proves on March 1-2, 2019, Hilcorp's urgency in providing the missing information to AOGCC after receiving the Notice, the demonstrated good performance of the meters as shown in their respective meter factor control charts, and no injury to the public. Further, AOGCC has used its discretion in significantly reducing the penalty by not invoking per -day or per -month assessments for the violations. Findings and Conclusions: The AOGCC finds that Hilcorp violated the February 7, 2019 conditional approval letters for changes to oil custody transfer meters at Granite Point Unit and Trading Bay Unit. Mitigating circumstances outlined above were considered in the Notice and the AOGCC assessment as to the appropriate civil penalty. Hilcorp has neither disputed the findings in the Notice nor the penalty proposed by AOGCC. Since receiving the Notice, Hilcorp has provided results of each meter prove as required in the conditional approval letters. Now Therefore It Is Ordered That: Hilcorp is assessed a civil penalty in the amount of $30,000 for violating the February 7, 2019 conditional approval letters for the changes and upgrades to Granite Point Unit and Trading Bay Unit custody transfer oil measurement equipment. If Hilcorp chooses not to appeal this Order 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. In addition to the civil penalty, within 10 days of the date of the AOGCC's final decision, Hilcorp 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, Hilcorp is required to preserve documents concerning the above action until after resolution of the proceeding. Done at Anchorage, Alaska and Dated June 12, 2019. Jessie L. Chmielowski Daniel T. Seamount, Jr. Commissioner Commissioner cc: AOGCC Inspectors Phoebe Brooks (AOGCC) Other Order 153 June 12, 2019 Page 4 of 4 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. Carlisle, Samantha J (CED) From: Colombie, Jody J (CED) <jody.colombie@alaska.gov> Sent: Thursday, June 13, 2019 8:16 AM To: AOGCC Public Notices Subject: [AOGCC_Public_Notices] oth153 (Hilcorp) Attachments: othl 53.pdf Please see attached. Re: Missing Meter Performance Reports ) Other Order No. 153 Custody Transfer Meters ) Docket OTH-19-015 Granite Point Unit ) Trading Bay Unit ) June 12, 2019 .1odv.L Colornhie Special <<tssisturn Alaska Oil and Gas Conservation Commission 333 i1/est ''Avemae Anchorage, .AK 99.501 (907) 793-1221 Direct (90" ) 2?6-?512 Fax List Name: AOGCC—Public—Notices@list.state.ak.us You subscribed as: samantha.carlisle@alaska.gov Unsubscribe at: http:Hlist.state.ak.us/mailman/options/aogcc_public_notices/samantha.carlisle%40alaska.gov Bernie Karl K&K Recycling Inc. P.O. Box 58055 Fairbanks, AK 99711 George Vaught, Jr. P.O. Box 13557 Denver, CO 80201-3557 Gordon Severson 3201 Westmar Cir. Anchorage, AK 99508-4336 Darwin Waldsmith P.O. Box 39309 Ninilchik, AK 99639 Penny Vadla 399 W. Riverview Ave. Soldotna, AK 99669-7714 Richard Wagner P.O. Box 60868 Fairbanks, AK 99706 icd �I►z��Cr HARVEST ALASKA July 12, 2019 Commissioner Jessie L. Chmielowski Alaska Oil and Gas Conservation Commission 333 West 7h Avenue Anchorage, AK 99501-3572 RE: Docket No.: OTH-19-015 Missing Meter Performance Reports Granite Point Unit Trading Bay Unit Dear Commissioner Chmielowski: Post Office Box 244027 Anchorage, AK 99524 3800 Centerpoint Dr. Suite 1400 Anchorage, AK 99503 I-CEIVED ,JUL 12 2019 AOGCC Attached please find payment of $30,000 for assessed penalty pursuant to Decision and Order dated June 12, 2019 for the above referenced matter. Please feel free to contact me directly at (907) 777-8336. Sincer y �p Richard Novcaski Vice President, Harvest Alaska Enclosure Harvest Alaska, LLC P O Box 61229 Houston TX 77208-1229 PAY Thirty Thousand Dollars and Zero Cents To STATE OF ALASKA THE ORDER AOGCC OF 333 WEST 7TH AVE ANCHORAGE AK 99501-3539 AMEGY BANK 1131 Void After 90 Days Check No Check Date Check Amount 0072009719 6/28/2019 ""*"`$30,000.00 Authorized Signature „°007 2009719115 1: 113 i 105861: 04444080 20,15 101 June 21, 2019 Hilcorp Alaska, LLC Post Office Box 244027 Anchorage, AK 99524-4027 3800 Centerpoint Drive Suite 100 Anchorage, AK 99503 RECEIVED Jessie L. Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission JUN 2 1 2013 333 West Seventh Avenue /� Anchorage, AK 99501-3572 AOGCC Re: Docket Number: OTH-19-015 Missing Meter Performance Reports Granite Point Unit Trading Bay Unit Dear Commissioner Chmielowski: Hilcorp is in receipt of the Commission Decision and Order dated June 12, 2019 regarding the above referenced enforcement action. Pursuant to Order, below is a written explanation that describes preventative measures now in place to prevent recurrence of this violation. A single point of contact has been established for future submittal of monthly reports to AOGCC to ensure consistent and complete reporting. We also believe that this change will help to facilitate clear communications and expectations between Hilcorp and AOGCC. Internal processes have been updated and communicated. A clear internal process now exists to ensure the timely and complete delivery of monthly reports and information to AOGCC. This process includes how field operators provide meter information and how the meter information is assembled and distributed. At the informal hearing between Hilcorp and AOGCC on June 6, 2019, it was confirmed that all required reports have been received by AOGCC. Several outstanding questions were identified for follow up. We will meet with AOGCC to follow up and address remaining items from the June 6, 2019 informal hearing. Should you have any additional questions, please contact Richard Novcaski 777-8455. Sincerely, David Wil ns Senior Vice President Hilcorp Alaska, LLC 5 CONFIDENTIAL information held in secure storage STATE OF ALASKA OIL AND GAS CONSERVATION COMMISSION SUBJECT: Car tc�, r4Ti�d.,a— DATE: 6 1j NAME AFFILIATION 0 THE STATE 01ALASKA May 20, 2019 GOVERNOR MIKE DUNLEAVY CERTIFIED MAIL — RETURN RECEIPT REQUESTED 7015 0640 0006 0779 5227 Mr. David Wilkins Senior Vice President Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: OTH-19-015 Informal Review Missing Meter Performance Reports Granite Point Unit Trading Bay Unit Dear Mr. Wilkins: Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 v .aogcc.olaska.gov As part of the informal review process, Hilcorp Alaska, LLC (Hilcorp) has the opportunity to submit documentary material and make written and oral statements regarding the Notice of Proposed Enforcement Action for Docket Number OTH-19-015, Missing Meter Performance Reports, Granite Point Unit, Trading Bay Unit. There will be no formal record kept of the review and the review will not involve the presence of counsel, either for the AOGCC or the operator. The informal review is scheduled for June 6, 2019 at 10:00 am in the AOGCC's Anchorage office located at 333 West 7a' Avenue. Copies of all written submissions and summaries of any oral statements planned by Hilcorp should be provided to the AOGCC no later than June 3, 2019. Sincerely, n Gn Je sie L. Chmielowski Commissioner 17- 171 ru Lr) or r C3 C3 `0 O M O U.S. Postal Service" CERTIFIED MAIL® RECEIPT Domestic Mail Only O Mr. David Wilkins 1-_I Senior Vice President Ln Hilcorp Alaska, LLC C3 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 ■ Complete items 1, 2, and 3. X ■ Print your name and address on the reverse so that we can retulp the card to you. & ■ Attach this card to the back of the maiipiece, or on the front if space permits. Mr. David Wilkins Senior Vice President Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 L 3. 9590 9402 3704 7335 2702 50 7015 -11 0-640 0006 0779 5227 PS Form 3811, July 2015 PSN 7530-02-000-9053 @Agent ❑ Addre by (Printed Name) C. Qate ot,D1l r c l ddress different from Item 17 0 Yes . _ g delivery address belpw: 0 No r MAY 2 3 ?ntg Restricted Delivery 0 gerdfied Mail Restricted Delivery ❑ Collect on Delivery ❑ Collect on Delivery Restricted Delivery Nall Nail Restricted Delivery ❑Priority Mail Express® E3 Registered Malll" ❑ Registered Mail Restricted Delivery ❑ Return Recelpt for Merchandise ❑ Signature Con irmattarm ❑ Signature Confirmation Restricted Delivery Domestic Return Receipt z May 17, 2019 Hilcorp Alaska, LLC Post Office Box 244027 Anchorage, AK 99524-4027 3800 Centerpolnt Drive Suite 100 Anchorage, AK 99503 RECEI'6ED MAY 17 9019 Jessie L. Chmielowski, Commissioner r Alaska Oil and Gas Conservation Commission p®GCC 333 West Seventh Avenue Anchorage, AK 99501-3572 Re: Docket Number:OTH-19-015 Missing Meter Performance Reports Granite Point Unit Trading Bay Unit Dear Commissioner Chmielowski: We are in receipt of the Commission's Notice of Proposed Enforcement Action dated May 7, 2019, concerning the provisions required under the AOGCC conditional approval letters dated February 7, 2019. Pursuant to the Commissioner's Notice and 20 AAC 25.535(c), Hilcorp Alaska hereby requests an informal review of the matter. Please note that on May 17th, Harvest Alaska provided Mr. James Regg the April and May proving documentation requested and indicated that Harvest Alaska would provide the State with monthly documentation going forward as part of its procedure. Hilcorp Alaska will submit documentary material in advance of the informal review, and make an oral presentation at the informal review. Should you have any additional questions, please contact Richard Novcaski, Vice President of Harvest Alaska at (907) 777-8455. Sincerely, avid Wilkins Senior Vice President Hilcorp Alaska, LLC il THE STATE May 7, 2019 °fALASKA GOVERNOR MIKE DUNLEAVY CERTIFIED MAIL RETURN RECEIPT REQUESTED 7015 0640 0003 5185 7103 Mr. David Wilkins Senior Vice President Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Re: Docket Number: OTH-19-015 Missing Meter Performance Reports Granite Point Unit Trading Bay Unit Dear Mr. Wilkins: Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www.a ogc c.a laska.gov 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 has violated the provisions of the conditional approval letters for the Granite Point Unit and Trading Bay Unit custody transfer oil measurement equipment. Basis for Finding the Violation or Noncompliance (20 AAC 25.535(b)(2)). Changes to the custody transfer oil measurement equipment for Hilcorp's Granite Point and Trading Bay Units were conditionally approved by AOGCC on February 7, 20191. Requirements imposed include the meter prove frequency, notification to AOGCC for opportunity to witness meter proves, required actions before making changes to the custody transfer measurement equipment, and reporting obligations following proves. Condition 2.f. of each approval letter requires that Hilcorp "provide results of each meter proved within 7 days following completion of monthly meter proves", including prove reports, batch summaries, and current meter factor control charts. Review of the Granite Point Unit and Trading Bay Unit field records reveal that Hilcorp failed to submit meter performance reports as directed in the February 7, 2019 conditional approval. 'AOGCC Docket OTH-18-042, Granite Point Unit; AOGCC Docket OTH-18-044, Trading Bay Unit. Meter changes and upgrades are designed for the Cross Inlet Pipeline Extension Project by providing two sizes of custody transfer meters at each production facility to allow for variable flow rates. Docket Number: OTH-19-015 Page 2 of 3 Proposed Action (20 AAC 25.535(b)(3)). The custody transfer measurement reporting violations at Granite Point Unit and Trading Bay Unit are not isolated events. An AOGCC Notice of Proposed Enforcement was previously issued in 2016 for a similar violation — failing to provide required performance reports for the Ninilchik Unit Bartolowits pad custody transfer meter. Hilcorp's non-compliance history in conducting hydrocarbon development activities in Alaska includes past failures to obtain necessary approvals, failures to install, maintain, and test required well control safety systems, failures to perform required tests, and failure to provide reports. AOGCC has issued 18 non -civil penalty and 7 civil penalty enforcement actions since January 2012 against Hilcorp. Recurring areas of noncompliance, such as Hilcorp's inability to account for specific approval conditions in its regulatory compliance tracking efforts, call into question the assurances that corrective actions implemented in response to past enforcement actions would be effective in mitigating repeat violations. For violating provisions of the February 7, 2019 conditional approval letters for Granite Point Unit and Trading Bay Unit custody transfer measurement systems, the AOGCC intends to impose a civil penalty on Hilcorp under AS 31.05.150(a) in the amount of $30,000.3 In determining the amount of the penalty, AOGCC has considered the criteria in AS 31.05.150(g), with emphasis on the extent to which Hilcorp was acting in good faith in attempting to comply, the extent to which Hilcorp acted in a willful or knowing manner, the extent and seriousness and actual or potential threat to public health or the environment, injury to the public, the need to deter similar behavior by Hilcorp and others similarly situated at the time of the violation or in the future, and Hilcorp's history of compliance issues. In addition to the imposed civil penalty, AOGCC intends to require Hilcorp to provide 1) a detailed written explanation that describes how it intends to prevent recurrence of this violation. Hilcorp is also to provide the required information within 10 days of this order. As an operator involved in an enforcement action you are required to preserve documents concerning the above actions until after resolution of the proceeding. 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 Z Other Order 113: "Final Decision and Order, Missing Meter Calibration Reports, Ninilchik Unit Bartolowits Pad"; October 20, 2016 3 Penalty amount arrived at considering each custody transfer oil measurement system as separate initial violations, penalized at $15,000 per violation. Docket Number: OTH-19-015 Page 3 of 3 a request is not filed within that 10 -day period, the proposed decision or order will become final on the l ls' 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 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 other actions the AOGCC may take. AOGCC has granted Hilcorp's request to combine into a single meeting the informal review of several recent notices of proposed enforcement. This proposed action can also be included in the informal review but Hilcorp must notify AOGCC within 10 days if it desires to do so. Sincerely, Je ie L. Chmielowski Commissioner Ul vx fi 9 - 1 ?4, w a Certified Mail Fee "`" r7 $ V7 Extra Services&Fees(cn.d ,,am reeas ❑Return Receipt (hardcopy) $ apPropnefe) 0 ❑Rdum Receipt (elecpanlc) $ OClCertiAed Mall gasMdad eelivx $ PoSlmadc ❑AdultslgnetureRoouim $ Here El do slenetura RaeMded Delivery $ OP ------ S Mr. David Wilkins E3 Senior Vice President � Hilcorp Alaska, LLC r 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 ar;. ■ 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 mailpiece, or on the front if space permits. Mr. David Wilkins Senior Vice President Hilcorp Alaska, ac 3800 Centerporive, Suite 1400 Anchorage, AK503 9590 9402 3704 7335 2702 67 7015 0640 0003 5185 7103 A. Sttura X 0 Agent ❑ Addm B. Received IfirWrinted Name), , I C. Dalai of Qel lddress different from tem l? U Ya: ;r delivery address below„ Q,,tJo MAY 10 2019 3. Service Type ❑ Priority Mail Express® . Postal Service'" ❑ Adult Signature Restricted Delivery ❑ Registered Mall Restricted ❑ Certified Mal® V RTIFIED MAIL° RECEIPT Merchandise ^ ^ 'Delivery Restricted Delivery 0 Signature Confionation'm estic Mail Only Aail Restricted Delivery �m Restricted Delivery elivery information, visit our website at 'T—T Ul vx fi 9 - 1 ?4, w a Certified Mail Fee "`" r7 $ V7 Extra Services&Fees(cn.d ,,am reeas ❑Return Receipt (hardcopy) $ apPropnefe) 0 ❑Rdum Receipt (elecpanlc) $ OClCertiAed Mall gasMdad eelivx $ PoSlmadc ❑AdultslgnetureRoouim $ Here El do slenetura RaeMded Delivery $ OP ------ S Mr. David Wilkins E3 Senior Vice President � Hilcorp Alaska, LLC r 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 ar;. ■ 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 mailpiece, or on the front if space permits. Mr. David Wilkins Senior Vice President Hilcorp Alaska, ac 3800 Centerporive, Suite 1400 Anchorage, AK503 9590 9402 3704 7335 2702 67 7015 0640 0003 5185 7103 A. Sttura X 0 Agent ❑ Addm B. Received IfirWrinted Name), , I C. Dalai of Qel lddress different from tem l? U Ya: ;r delivery address below„ Q,,tJo MAY 10 2019 3. Service Type ❑ Priority Mail Express® D Adult Signature ❑ Registered Manu' ❑ Adult Signature Restricted Delivery ❑ Registered Mall Restricted ❑ Certified Mal® Delivery ❑ Certified Mail Restricted Delivery ❑ Return Receipt for ❑ Collect on Delivery Merchandise ^ ^ 'Delivery Restricted Delivery 0 Signature Confionation'm mail ❑ Signature Confirmation Aail Restricted Delivery �m Restricted Delivery PS Form 3811; July 2015 PSN 7530-02-000-9053 Domestic Return Receipt