IN THE MATTER OF ALLEGED VIOLATIONS OF THE          CAUSE NO. 1
RULES AND REGULATIONS OF THE
COLORADO OIL AND GAS CONSERVATION                       ORDER NO. 1V-124
COMMISSION BY NERDLIHC COMPANY, INC.,
WELD COUNTY, COLORADO

REPORT OF THE COMMISSION

This cause came on for hearing before the Commission on July 1, 1997, at 8:30 a.m., in Suite 801, The Chancery Building, 1120 Lincoln Street, Denver, after giving Notice of Hearing as required by law, on why Nerdlihc Company, Inc. is in violation of Rule No. 326.b.1., requiring temporarily abandoned wells to be tested for mechanical integrity; Rule No. 319.b,, requiring temporarily abandoned wells to be plug within six (6) months; and Rule No. 210.b., requiring the posting of well signs, of the Oil and Gas Conservation Commission, and why it should not invoke the provisions of §34-60-121 C.R.S., as amended, providing for penalties for violations of the Rules and Regulations of the Commission for certain wells.

FINDINGS

The Commission finds as follows:

1. Nerdlihc Company, Inc. is an interested party in the subject matter of the above referenced hearing.

2. Due notice of the time, place and purpose of the hearing has been given in all respects as required by law.

3. The Commission has jurisdiction over the subject matter embraced in said Notice, and of the parties interested therein, and jurisdiction to promulgate the hereinafter prescribed order.

4. From November 14 to November 30, 1991, the Nerdlich Company drilled the Toedtli #1-10 Well. The well is located 2000' FSL and 1985' FWL in the NE¼SW¼ of Section 10, Township 10 North, Range 57 West, 6th P.M. The Toedtli #1-10 Well was completed and tested on January 11, 1992. The well tested 627 MCFD of gas and 36 bbls of water on a 24 hour test. To date no production has ever been sold from the Toedtli Well and no Form 10 has been filed with the Colorado Oil and Gas Conservation Commission.

5. On September 5, 1996, the Toedtli Well site was inspected be Staff Engineer Binkley. He reported the status of the well as temporarily abandoned and issued Nerdlich Company a unsatisfactory inspection report. A Notice of Alleged Violation (NOAV) was issued to Nerdlich Company, Inc. on September 9, 1997. The NOAV cited Nerdlich for violation of Rule No. 326.b.1., requiring temporarily abandoned wells to be tested for mechanical integrity; Rule No. 319.b,, requiring temporarily abandoned wells to be plug within six (6) months; and Rule No. 210.b., requiring the posting of well signs. The NOAV required Nerdlich to perform a mechanical integrity test by October 12, 1996, or plug the well by March 12, 1997. Nerdlich was also required to close open pits by October 12, 1996. To date Nerdlich Company, Inc. has not complied with the requirements of the NOAV.

6. On April 24, 1997, the Colorado Oil and Gas Conservation Commission received a letter from Lohf, Shaiman & Jacobs, Attorneys at Law, stating that the Nerdlich mineral lease for the Toedtli #1-10 Well "had terminated for violation of the implied duty to market". The letter also stated that certain clients of Lohf et al had "obtained a new oil and gas lease from the current mineral owners" and were interested in assuming responsibility for operation of the Toedtli well.

7. On June 24, 1997, Richard C. Grimmette and Allen Heim, by their attorney, filed with the Commission an Intervention to the staff request for order finding violation, stating that their designee, Intermountain Oil Company, should be recognized as the Operator of the Toedtli well since a Form 10, Form 4’s and a bond were in place.

8. At the time of hearing on July 1, 1997, COGCC staff presented testimony and requested that an order of the Commission be entered finding Nerdlihc Company, Inc. in violation of Rule No. 326.b.1., requiring temporarily abandoned wells to be tested for mechanical integrity; Rule No. 319.b,, requiring temporarily abandoned wells to be plug within six (6) months; and Rule No. 210.b., requiring the posting of well signs and assessing a fine of Nine Thousand Dollars ($9,000) payable within thirty (30) days from the date the order is issued. The fine should be reduced to Four Thousand Five Hundred Dollars ($4,500) if it is paid by July 15, 1997.

ORDER

NOW, THEREFORE, IT IS ORDERED, that Nerdlihc Company, Inc. shall be found in violation of Rule No. 326.b.1., requiring temporarily abandoned wells to be tested for mechanical integrity; Rule No. 319.b,, requiring temporarily abandoned wells to be plug within six (6) months; and Rule No. 210.b., requiring the posting of well signs for the Toedtli #1-10 Well located 2000' FSL and 1985' FWL in the NE¼SW¼ of Section 10, Township 10 North, Range 57 West, 6th P.M

IT IS FURTHER ORDERED, that Nerdlihc Company, Inc. shall be assessed a fine of Nine Thousand Dollars ($9,000) payable within thirty (30) days from the date the order is issued. The fine shall be reduced to Four Thousand Five Hundred Dollars ($4,500) if it is paid by July 15, 1997.

IT IS FURTHER ORDERED, that the provisions contained in the above order shall become effective forthwith.

IT IS FURTHER ORDERED, that the Commission expressly reserves its right, after notice and hearing, to alter, amend or repeal any and/or all of the above orders.

ENTERED this day of July, 1997, as of July 1, 1997.

OIL AND GAS CONSERVATION COMMISSION OF THE STATE OF COLORADO

By Patricia C. Beaver, Secretary

Dated at Suite 801, 1120 Lincoln Street Denver, Colorado 80203 July 3, 1997

(1V#124)