🛢️ Clifford Bakke 26-35 7TFH

DEVON ENERGY WILLISTON, L.L.C (Grayson Mill Operating, LLC) · Mountrail County, ND · File #41528 · Generated 2026-02-13 12:33

API: 3306105474
Target Formation: Three Forks First Bench (B1)
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval issued 04/01/2025 is directly explained by a coherent set of contemporaneous waivers and conditions filed 03/18–03/27/2025. Three critical operational waivers condition the approval: (1) Tubing/Packer Waiver (04/01/2025 effective) substitutes casing integrity and pressure monitoring for standard tubing/packer, justified by new surface casing specs and low corrosion rates; (2) Filter Sock Container Waiver (03/21/2025 effective) exempts operator from container requirement because no filter media is used in drilling operations; (3) Suspension of Drilling Waiver (03/19/2025 effective) authorizes phased drilling (small rig surface hole + conventional rig to TD within 90 days) with casing-wear constraints. A supporting Open Hole Log Waiver (03/18/2025) reduces logging burden based on offset well data. The permit stipulates setback geometry (150°/500') keyed to a production liner with wet-shoe completion design. All waivers and field orders pre-date or align with the 04/01/2025 permit effective date and explain specific drilling, completion, and operational departures from standard practice. The well name was formally changed from Clifford Bakke 25-36 7TFH to Clifford Bakke 26-35 7TFH (02/05/2025), aligning well identifier before permit issuance.

🔍 Permit Cycle Signals (5)

Tubing/Packer Waiver approval under NDAC 43-02-03-21 conditioned on casing integrity assurances and pressure monitoring during flowback.

Direct

📄 SUNDRY FORM FILE NUMBER 41528, FORM ID 237056
📅 2025-04-01 (Exact confidence)

Waiver directly conditions well completion design. Approval permits omission of tubing/packer requirement by substituting new #29 and 32# surface casing with API burst rating of 11,220 psi and 0.85 safety factor. Requires 300# gauge on surface casing during flowback and immediate detection of casing damage via monitoring. This is non-routine and directly justifies departure from standard completion stipulations.

Filter Sock Container Waiver approved under NDAC 43-02-03-19.2 for drilling phase only, exempting operator from maintaining on-site container since no filter media is used during drilling.

Direct

📄 SUNDRY FORM FILE NUMBER 41528, FORM ID 237047
📅 2025-03-21 (Exact confidence)

Waiver explicitly tied to operator's process design: Devon Energy does not utilize filter media during drilling. This is a non-routine exemption from environmental containment requirement and conditions the permit approval.

Suspension of Drilling (SOD) approval for 90 days under NDAC 43-02-03-55 permitting phased drilling strategy: initial surface hole with small rig and freshwater mud (3-5 days), followed by conventional rotary rig mobilization within 90-day window for drilling to TD.

Direct

📄 SUNDRY FORM FILE NUMBER 41528, FORM ID 237050
📅 2025-03-19 (Exact confidence)

Conditional approval with field inspector notification requirements and plug-and-abandon obligation if well not drilled within 90 days. Reviewer comment warns against intentional deviation of surface hole due to casing wear risk during vertical/curve sections. This operational window and casing-wear constraint directly condition well execution and drilling sequencing.

Open Hole Log Waiver approved under DMR Rule 43-02-03-31 based on availability of open logs from offsetting well (Storbeck 27-34 2H, NDIC File #17165) within one mile, substituting GR-CBL log from TD to ground level.

Supporting

📄 SUNDRY FORM FILE NUMBER 41528, FORM ID 237024
📅 2025-03-18 (Exact confidence)

Waiver justified by regional geological context (offsetting well's open logs sufficient to establish formation tops). Geologist approval indicates reduced logging burden is acceptable given nearby offset data. This conditions the well's logging obligations.

Permit approval issued 04/01/2025 with setback stipulations per Commission Order No. 33092: 150° setback from north/south boundaries, 500' setback from east/west boundaries within 1,280-acre spacing unit (Sections 26 & 35). Production liner cemented in lateral with wet shoe capability.

Direct

📄 APPLICATION FOR PERMIT FOR NEW WELL - HORIZONTAL, Page 1 of 10
📅 2025-04-01 (Exact confidence)

Setback geometry directly tied to well path design (south setback based on production liner with wet shoe frac-out capability). This is the anchoring permit approval date and core structural condition.

📖 Historical Context (2)

State Geologist cores and samples requirement (ND Century Code § 38-08-04, NDAC 43-02-03-38.1) mandating sample collection from Base of Last Charles Salt at 30° intervals (vertical/build sections) and 200' intervals (horizontal sections), with submission to ND Geological Survey Core Library within 30 days of drilling completion and core submission within 180 days.
📄 Letter from ND Department of Mineral Resources, dated 1/27/2025, signed by Mark F. Bohrer (Assistant Director) · 📅 2025-01-27
This obligation persists through and beyond well completion. Non-compliance triggers civil penalties up to $12,500 per violation per day. The requirement is independent of permit approval and remains operative for all drilling, cuttings collection, and core handling throughout the well's lifecycle until samples/cores are delivered to the state library.

Backbuild Order Waiver Notification requirement (NDIC Order 31848) obligating operator to notify adjacent spacing unit operator of directional drilling plan, trajectory, formation tops, casing/cementing details, and drilling commencement date when wellbore traverses adjacent spacing units.
📄 Letter from Grayson Mill Operating, LLC to Todd Holweger, NDIC, dated 11/25/2024, re: Backbuild Order Waiver · 📅 2024-11-25
Operator notes Grayson Mill is operator of both the subject and adjacent spacing units, making internal coordination requirement moot. However, the regulatory obligation to comply with Order 31848 notification protocols persists if spacing unit operatorship changes. The letter establishes that Grayson Mill is aware of and committed to responsible cross-unit coordination, which remains binding on future drilling and completion operations.

🔧 Operator Pattern

Grayson Mill/Devon Energy demonstrates systematic use of operationally-tailored waivers and phased drilling strategies to optimize cost and schedule, with documented compliance framework for regulatory notification and environmental obligation (cores, samples, casing wear prevention).
Multiple waivers (tubing/packer, filter sock, SOD, open hole logs) approved within two-week window (03/18–03/27/2025) indicate pre-coordinated regulatory strategy. Well name change (01/22/2025) and backbuild notification (11/25/2024) predate permit issuance, showing advance planning. Suspension of Drilling waiver explicitly frames phased drilling as cost/time optimization with understood 90-day window and plug/abandon contingency. Filter sock waiver tied to operator's proprietary process design (no filter media). Operator maintains multi-well pad development (Clifford Bakke 26-35 1-H, #2H, #3H, #4H, 5H, 6TFH documented in vicinity) with coordinated directional drilling from common location.

Confidence: High
Permit approval date (04/01/2025) is clearly stated in the APD. All subordinate waivers carry explicit approval dates and effective dates within 03/18–04/01/2025 window. Waiver justifications are detailed and operator-specific (casing specs, no-filter-media process, phased rig strategy). Reviewer signatures (Dan Kuchar, Stephen Fried, Ross Edison) and contact information (sjfried@nd.gov, djkuchar@nd.gov, rossedison@nd.gov) are present. The permit APD document is complete with stipulations, field orders, and design drawings (trajectory, pad layout, cross-sections). No material gaps in documentation logic or temporal alignment exist. OCR quality is generally sound for critical fields (dates, permit numbers, well name, operator, setback terms). The permit file contains original source documents (Sundry Forms, letters, technical drawings) not summaries.