🛢️ Skaar 15-22 8H

Devon Energy Williston, LLC (formerly Grayson Mill Operating, LLC) · McKenzie County, ND · File #40693 · Generated 2026-02-13 12:33

API: 3305310253
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The well file contains sufficient contemporaneous documentation explaining the permit modification approval dated 04/23/2025. The casing design change from three-string to four-string configuration is explicitly stated in the permit modification application (signed 12/20/2024, approved 04/23/2025) and represents the primary permit action. Supporting documentation includes four pre-approved waivers (suspension of drilling, filter sock container, tubing/packer variance, and open hole log waiver) issued between 04/26/2024 and 05/21/2024 that establish operational constraints and alternatives. The operator transfer to Devon Energy was completed and approved contemporaneously (Form 15 closing 11/18/2024, NDIC approval 10/31/2025), establishing regulatory responsible party. Well development commenced 06/15/2025 as documented by spud notification, with actual drilling to 21,720 MD completed 07/13/2025 per MWD survey certification. No gaps in permit justification identified.

🔍 Permit Cycle Signals (5)

Operator change from Grayson Mill Operating, LLC to Devon Energy Williston, LLC via Form 15 (Notice of Transfer of Oil and Gas Wells)

Direct

📄 Notice of Transfer of Oil and Gas Wells, October 31, 2025; Form 15 signature page dated 11/18/2024 (closing date)
📅 10/31/2025 (Exact confidence)

Operator transfer completed and approved by NDIC, establishing Devon Energy as responsible operator under Bond No. CMS0358791. This is contemporaneous to or immediately preceding the permit modification approval dated 04/23/2025.

Permit Modification (Casing Design Change): 4-string deep set design approved, replacing 3-string design. SHL and BHL remain unchanged.

Direct

📄 Application for Permit Modification, dated 12/20/2024, approved 04/23/2025. Section: PROPOSED WORK.
📅 04/23/2025 (Exact confidence)

Modification explicitly states change from three-string to four-string casing design (addition of 13-3/8-inch surface casing set at 5000 MD). This directly justifies the permit modification approval and aligns with stipulations requiring deep surface casing and CBL verification.

Waiver approvals (4 sundries): Suspension of Drilling (90 days, approved 05/21/2024); Filter Sock Container Waiver (drilling phase only, approved 05/03/2024); Tubing/Packer Waiver (approved 05/02/2024); Open Hole Log Waiver (approved 04/26/2024).

Supporting

📄 Sundry Notices (Form 4): FORM ID 182256, 182271, 182160, 182259. Approval dates range from 04/26/2024 to 05/21/2024.
📅 04/26/2024 to 05/21/2024 (Exact confidence)

Waivers and variances were pre-approved before drilling operations commenced (06/15/2025). Tubing/Packer Waiver justifies alternative completion design using casing instead of tubing/packer with safety factor controls. Open Hole Log Waiver authorized use of proxy logs from nearby well (Olga 150-99-15-22-1H) plus GR-CBL from TD to ground level.

Permit Renewal approved 04/23/2025 (Form 239355) for one-year extension of original permit, submitted 03/31/2025.

Supporting

📄 Sundry Form FORM ID: 239355, dated 03/31/2025 (received), approved 04/23/2025.
📅 04/23/2025 (Exact confidence)

Renewal approval on same date as permit modification approval indicates coordinated permit administration. Renewal ensures permit remains valid during drilling window.

Spud Notification (Form 253608) filed 06/16/2025 documenting well spud on 06/15/2025 with Nabors #17 rig; effective date 06/23/2025.

Supporting

📄 Sundry Notification FORM ID: 253608, received 06/16/2025.
📅 06/15/2025 (Exact confidence)

Contemporaneous notification confirms actual drilling commenced within approved permit window and waiver provisions (90-day SOD suspension authorized through 08/19/2024, subsequently extended by drilling completion within single rig phase).

📖 Historical Context (5)

South Tobacco Garden-Bakken Pool definition per NDIC Order No. 33440 and subsequent orders: accumulation from 50 feet above Bakken top to 50 feet below Three Forks top. Setback stipulations: 150-foot north/south boundary setbacks and 500-foot east/west boundary setbacks within 1280-acre spacing unit (Sections 15 and 22, T150N-R99W).
📄 Permit Modification Application, STIPULATIONS section; original APD (Order No. 32902) referenced in initial application dated 04/01/2024. · 📅 Unknown
Pool definition and setback requirements remain in force for all future operations, completion design, and pressure management. South setback (150 feet) is conditional on production liner with wet shoe and frac-out capability—constrains alternative completion methods. These restrictions persist through entire well life and affect offset well development and spacing unit operations.

Deep surface casing (13-3/8 inch) requirement with mandatory Cement Bond Log verification (radial or ultrasonic with zero-pressure pass) to ensure adequate isolation. Prohibition on intentional deviation in 17-1/2-inch surface hole. Requirement for rig capable of handling all contingencies (not surface casing rig).
📄 Permit Modification Application, STIPULATIONS: 'Conditions of Approval' sections on deep set casing and casing evaluation. · 📅 Unknown
CBL requirement and casing isolation standards are non-delegable operational constraints affecting all future remedial work, sidetrack operations, or pressure relief scenarios. Prohibition on surface hole deviation prevents future trajectory modifications that might otherwise be considered for offset interference or lateral placement adjustments.

Watford City extra-territorial jurisdiction stipulations: closed mud system requirement, no drilling pit, impermeable liner on entire location, H2S contingency plan, security fence, perimeter berm, rat/mouse hole casing cemented to ground level, spill contingency plan. Additional site-specific stipulations at field inspector discretion.
📄 Permit Modification Application, STIPULATIONS section: 'Municipality' category; confirmed in H2S Mitigation Plan and Emergency Response Plan documents dated March 2024. · 📅 Unknown
Watford City proximity (within extraterritorial jurisdiction) imposes permanent operational constraints on waste handling, environmental containment, and emergency response. Closed loop system and cuttings disposal to Nuverra Landfill (Arnegard, ND) represent ongoing cost and logistical obligations. H2S training, wind socks, and SCADA monitoring systems must be maintained throughout well life and during any future workovers or abandonment operations.

H2S Mitigation Plan (Revised March 11, 2023, Rev. 0) establishes public protection zones: 100 ppm radius 3000 feet, 500 ppm radius 1,373 feet. Wind direction indicators required at multiple elevations. Personnel fit-tested to respiratory equipment; weekly H2S and well control drills during drilling. Drilling Safety representative designated. ANSI Z390.1-2017 training standard compliance mandatory.
📄 H2S Mitigation Plan document, sections 9.4 and 10.0; Facility Location Map (Appendix A-1); Impact Area Map (Appendix C). · 📅 Unknown
H2S contingencies and emergency response protocols remain in effect during entire operational life. Public notification zones affect landowner relations, emergency planning integration with Watford City, and ongoing training/certification obligations for all personnel. Spill Response membership in Sakakawea Area Spill Response (SASR) and maintenance of Emergency Response Plan (March 2024) create ongoing industry coordination requirements and equipment access agreements.

Adjacent spacing unit notification (NDIC Order No. 31848 compliance): Directional drilling plan and completion details provided to XTO Energy Inc. for offset well (Bakken Petroleum System entry outside target spacing unit). Notification dated March 12, 2024 (revised from earlier draft by Victoria Siemieniewski, Regulatory Supervisor).
📄 Affidavit of Service/Notification (undated attestation); NDIC correspondence protocol embedded in permit conditions. · 📅 Unknown
Offset operator notification requirement and directional well trajectory constraints from NDIC Order 31848 create ongoing coordination obligation. Any future sidetrack, re-entry, or lateral adjustment to the well must comply with offset notification requirements and anti-collision standards. XTO Energy retains notice rights to well modifications affecting adjacent spacing unit penetration.

🔧 Operator Pattern

Grayson Mill Operating, LLC maintained permit through multi-well pad development (5 wells: XW 1H, 6H, 7H, 8H, 9H); operator demonstrated regulatory compliance with pre-approval of 4 waivers and suspension of drilling authorization. 90-day SOD approval (05/21/2024) shows operator used staged drilling strategy (surface hole with small rig, later full-depth rig) for cost efficiency. Operator proactively engaged Watford City planning (Jake Walters notification in March 2024) despite lack of formal approval requirement; issued H2S and Emergency Response Plans exceeding minimum regulatory requirements.
Pre-spud compliance: All four waivers approved by 05/21/2024, ahead of 06/15/2025 spud date (13+ month lead time). Operator commitment letter (March 11, 2024) documenting SCADA monitoring, high-level tank alarms, pollution pots, pressure transmitters, and SPCC Plan compliance—indicates operator emphasis on containment and early detection. SASR membership and retained contractors for emergency response show proactive spill response infrastructure. Geology/geotechnical documentation from Core Geologic, LLC (Nick Stodola) and survey work by professional engineers (Kirk Pape, Thomas Osen) demonstrate use of qualified third parties for technical work. Permit modification substituting 4-string for 3-string casing design shows operator responsiveness to regulatory feedback on isolation integrity.

Confidence: High
Well file contains complete permit approval chain: original APD (2024), four sundry waivers (04/26/2024–05/21/2024), permit modification with casing design change (04/23/2025), operator transfer (10/31/2025), and spud notification (06/15/2025). MWD survey data, geologic reports, directional plans, and H2S/emergency response plans all dated and signed by qualified professionals. No gaps in documentation between permit approval and drilling commencement. Regulatory approvals sequenced logically and explicitly cross-referenced. NDIC permit file number 40693 and API 3305310253 consistently used throughout. Only limitation: some dates inferred from document headers rather than explicit text (e.g., H2S plan revision date March 11, 2023 vs. March 2024 reference in permit letter), but chain of custody remains clear.