*     Strong evidence indicates that Hilcorp has not adequately prepared its personnel for operations in compliance with AOGCC regulatory requirements. Left unaddressed and uncorrected these and similar violations will be repeated."

*     The order said Hilcorp's failure to comply was the result of either a lack of attention to regulations, or a lack of understanding of "clearly worded expectations."

*     "No explanation was offered for failure to test BOPE as required," the commission said.

*     The bulk of the $115,500 civil penalty, or $75,000, was for "the initial violation -- failure to increase the drilling fluid weight prior to milling the casing window" as required in the permit to drill.

*  The penalty also included $7,500 for each day, Oct. 14 through Oct. 17, 2012, that the blowout prevention equipment went untested after use.