Other Order 109 May 3, 2016 Page 5 of 7 Table 1 - Hilcorp Noncompliance History Date Non-Compliance Location AOGCC Comments Action6 April 2012 Missing SVS tests; Failure Westside No action taken Numerous efforts by AOGCC to obtain SVS test to notify AOGCC for test results for IRU, PCU, LRU, Stump Lake; some witness missing SVS tests between 5/201 1 and 2/2012; some failure to notify AOGCC for opportunity to witness (previous operator responsible for some tests) 5/8/2012 Missing Kill Line Valve Swanson River 21-22 BOPE test; Inspector observed missing kill line valve (Aurora Rig 1) at inlet to stack 1 installed; 2 required) 9/17/2012 Choke Manifold Valves Swanson River 21-25 Conective Rig crew performing choke manifold test greased and cheated closed during (Aurora Rig 1) actions had to cheat choke manifold valves closed to pass BOPE test pressure test 10/2/2012 Notice of Meter Happy Valley Corrective AOGCC has not received notice of meter calibration Calibrations actions for Happy Valley custody transfer meter for at least as long as Hilcorp has been responsible for the meter; schedule provided 10/9/12 10/18/2012 Incorrect BOPE Test Soldotna Ck 44-33 See 10/23/12 When ?nally tested BOPE after use (1 0/1 8/ 12), tested Pressure (Doyon Rig 1) enforcement to wrong pressure (4000psi instead of Failure to notify of changes Civil Penalty; Hilcorp failed to follow well drilling procedures to approved permit Corrective approved in PTD by failed to notify 0 [23 [2012 Soldotna Ck 44-33 Actions (Other AOGCC of changes to well plan; failed to maintain (Doyon Rig 1) Order 80) well in overbalanced condition; lack of change Well control; Failure to test Hilcorp failed to test BOPE used in well control BOPE after use operations prior to ?rst wellbore entry following use 10/26/2012 Failure to Test BOPE Granite Pt 32-I3RD Denied request Test due 10/26/ 12, started running completion within 7 days (crane workover) for delaying 1500hrs on 10/26 without making any attempt to get BOPE test test extension (working daylight hours only); landed pipe high, had to trip pipe; west extension 10/27/ 12 10/31/2012 Improper gauge on IA Trading Bay Unit 0- none Hilcorp self-reported that gauge was pegged out; 45 2000psi alarm set, lO?si gauge; well SI by Hilcorp 6 NOV Notice of Violation; no ?nancial penalty; corrective actions only Other Order 109 May 3, 2016 Page 6 of 7 Date Non-Compliance Location AOGCC Comments Action6 1 1/29/2012 Missing well control Happy Valley B-I6 NOV Missing top drive valve(s) on 10/ 10/12 and again equipment (Aurora Rig 1) 11/18/12: reviewing Hilcorp response rec?d 12/11/12 1 1/29/2012 Incorrect BOPE test Granite Point #50 NOV Sundry 312-439 required BOPE rams, valves to test to pressure (Schlumberger CT 2) 4500psi; Hilcorp tested to 350_Opsi 1216/2012 Conduct of operations Trading Bay Unit 0- NOV Violation found 1 1/7/ 12 as part of rig inspection/ and 32 (Williams Rig 404) BOPE test witness; hazardous conditions; wellbore ?uids on deck; equipment placement; lack of winterization; reviewing Hilcorp response rec?d 12/21/12 12/16/2012 Winterization; Conduct of Trading Bay Unit Ordered ops Inspector arrived 12/1 5/ 12 for BOPE test; unable to Operations 32 (Williams Rig 404) shut down on test due to ?uids covering stack well cellar (similar to Rig 404 until issued noted in 12/6/ 12 returned 12/16/12 to corrective test BOPE - unable to test BOPE (frozen choke i actions manifold, top drive valves, floor safety valves, choke implemented and kill lines along with everything else not in heated enclosure. Rig ops allowed to restart 12/31/12 alter corrective actions, inspection and passing BOPE test [2/16/2012 Commence production w/o Nikolaevsk Unit (Red Corrective 12/18/ 12 Hilcorp contacts AOGCC with notice of approved LACT meter pad) actions SVS testing; AOGCC determined by questioning status that well commenced production 12/16/12; application for LACT meter rec?d 1/9/ 12 4/11/2013 Defeated SVS Sterling 43-09X SVS found defeated 3/ 15/ 13 during AOGCC inspection: well was 81 without testing 9/30/2013 Defeated SVS Swanson River Field NOV SVS found defeated 9/2/13 during AOGCC KGSF #1 inspection; needle valve on actuator blocked 1/14/2014 Defeated SVS Swanson River Field NOV SVS on 3 rod pump wells found defeated during Missing Annulus Gauges SCU SCU 12/9/ 13 AOGCC inSpection; found SCU 24A-09 w/o SCU 41A-08 the req?d pressure gauge to monitor outer annulus 4/22/2014 Defeated SVS Ninilchik Unit Corrective found by AOGCC Inspectors 4/ 15/ 14 and Ninilchik Unit FC-S actions 4/16/14; Hilcorp reported on 4/21/14; Inspector required back in service before departing 3/29/2014 Failure to Test BOPE Trading Bay Unit G- NOV Rig exceeded allowed 7days between BOPE tests 11 (Moncla Rig 301) without AOGCC approval Other Order 109 May 3. 2016 Page 7 of 7 Date Non-Compliance Location AOGCC Comments Action? 10/31/2014 Failure to Test Required Ninilchik Unit Paxton Corrective No enforcement; reported by Hiicorp; approved Well Control Equipment 7 Paxton 8 actions sundry required testing despite wells being isolated from the formation 1/5/2015 Workover Safety Concerns Hilcorp Cook Inlet Meeting 1/9/15; List of concerns provided to Hilcorp addressing and Kenai Peninsula Corrective suitability of equipment and procedures; unsafe Rig Workovers actions working conditions associated with rig workovers; onshore and offshore Cook Inlet 1/7/2015 Casing Valves lnaccessible Ninilchik Unit Paxton Meeting 1/9/15; Frozen well cellar found by Inspector 1/7/15; operator 8 Corrective instructed to thaw cellar; no action taken per Hilcorp actions 15 - ?operator unclear about req?d action?); AOGCC De?ciency Report created to track corrective actions identi?ed during inspections 2/4/2015 Defeated SVS Unit NOV SSV found defeated during 1/23/15 AOGCC inspection 11/22/201 5 Failure to Obtain Approval Kenai Gas Field KDU NOV Operating without required competent tubing and for Continued Production 1 packer; no AOGCC approval (20 AAC 25.200); discovered as part of well review; well shut in 9/4/2015 Rig Operations with Failed Milne Pt Unit F-96 Notice of AOGCC Docket 0TH 15?024; Notice sent 1 1/25/ 15; Gas Detection System Proposed informal review held 2/18/16; Final Decision pending Enforcement (Civil Penalty) 10/1/2015 Failure to follow approved All Hilcorp?operated Shut down well AOGCC-ordered suspension of all rig workover procedures/good oilfield rigs performing workover operations; corrective actions required; conditional practices workovers operations approval for restart 10/21/15