🛢️ Clifford Bakke 26-35 6TFH

Devon Energy Williston, L.L.C / Grayson Mill Operating, LLC · Mountrail County, ND · File #41529 · Generated 2026-02-13 12:33

API: 3306105475
Target Formation: Three Forks First Bench (B1) / Bakken Formation
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval (Dirt Work Date 04/01/2025) is clearly explained by a coherent set of contemporaneous waivers and stipulations received and approved between 03/18/2025 and 03/21/2025. The three critical operational waivers (Suspension of Drilling, Filter Sock exemption, and Tubing/Packer variance) establish a compliant drilling and completion framework tied to specific technical conditions. The Open Hole Log waiver reduces characterization burden based on offset well proxim. The APD stipulations (Commission Order No. 33092) set spatial boundaries for lateral placement. All waiver submittals are dated 03/18/2025 (received same day) and were approved within 3 days, indicating regulator review accepted operator justifications without modification. The permit approval date (04/01/2025) follows the final waiver approval (03/21/2025) by 11 days, allowing time for permit issuance. No gaps in permit-cycle documentation.

🔍 Permit Cycle Signals (5)

Suspension of Drilling (SOD) — 90-day waiver to NDAC 43-02-03-55 approved to allow phased drilling strategy using smaller rig for surface casing followed by larger rotary rig for lateral completion within 90-day window.

Direct

📄 Sundry Form ID 237048, approved 03/19/2025
📅 03/19/2025 (Exact confidence)

This is a non-routine operational waiver that directly conditions the drilling sequence and timing. The approval explicitly requires call-ins after spudding with smaller rig, after plug bump, and when conventional rig returns. Failure to complete drilling within 90 days triggers mandatory plug and abandon. This waiver is essential to the drilling execution plan and directly justifies the April 1, 2025 dirt work approval date by establishing the phased approach.

Filter Sock Container Waiver — NDAC 43-02-03-19.2 waiver approved to exempt operator from maintaining on-site leakproof filter media container during drilling phase only, justified on basis that Devon Energy does not use filter media during drilling.

Direct

📄 Sundry Form ID 237043, approved 03/21/2025
📅 03/21/2025 (Exact confidence)

Waiver modifies standard drilling-phase environmental compliance requirement. Explicitly limited to drilling phase only, implying filter containment requirements resume during completion/flowback. Reviewer (Dan Kuchar, ENGINEER TECH) approved without condition, indicating operator assertion of no-filter-media operations was accepted.

Open Hole Log Waiver — NDAC 43-02-03-31 waiver approved to waive requirement for full open-hole logs on target formation. Justification: offsetting well Strobeck 27-34 2H (within 1 mile) contains sufficient open logs to establish formation tops; operator will conduct GR-CBL log from TD to surface.

Direct

📄 Sundry Form ID 237016, approved 03/18/2025
📅 03/18/2025 (Exact confidence)

Geological waiver reduces subsurface characterization requirements by relying on offset well data and partial logging. Reviewer (Ross Edison, Geologist) approved, indicating offset well Strobeck 27-34 2H log data was deemed sufficient substitute. This waiver is specific to well geometry and offset proximity.

Tubing/Packer Waiver (Flowback Design) — NDAC 43-02-03-21 variance approved to allow flowback without tubing/packer configuration. Operator (Grayson Mill) provided technical assurances: new #29 and 32# surface casing with 11,220 psi API burst rating; safety factor 0.85 of API burst; damage detection during completion ops; 300# gauge on surface casing during flowback; production equipment installation as soon as possible post-flowback.

Direct

📄 Sundry Form ID 237054, approved 03/18/2025 (effective 03/18/2025); Approximate Start Date: 10/31/2025
📅 03/18/2025 (Exact confidence)

Completion engineering waiver is tied to specific casing design and operating parameters. Conditions completion flowback strategy using surface casing integrity as primary pressure boundary instead of tubing/packer isolation. Reviewer (Stephen Fried, Petroleum Engineer) approved. This waiver is non-routine and imposes monitoring/operational discipline (gauge installation, rapid equipment installation post-flowback).

APD Stipulation — Commission Order No. 33092: Well bore isolation by cement required; all portions not isolated by cement must maintain 150° setback from north/south boundaries and 500' setback from east/west boundaries within 1280-acre spacing unit (Sections 26 & 35, T155N, R92W). South setback based on production liner cemented in lateral with wet shoe and frac-out capability.

Direct

📄 Application for Permit for New Well — Horizontal, Stipulations section, page 1 of 10
📅 04/01/2025 (Exact confidence)

Setback stipulation is standard for horizontal wells in defined spacing unit but the specific reference to Commission Order No. 33092 and wet-shoe/frac-out design indicates regulator-imposed boundary protection tied to this particular well geometry and lateral placement. Directly conditions drilling trajectory within spatial unit.

📖 Historical Context (4)

Operator change during permitting cycle: Initial permit filed under Devon Energy Williston, L.L.C (address 333 W Sheridan Ave, Oklahoma City OK); Tubing/Packer Waiver (237054) submitted by Devon but approved under Grayson Mill Operating, LLC name; well planning documents show Grayson Mill as operator; November 25, 2024 letter from Grayson Mill to NDIC regarding backbuild order waiver for multiple wells including Clifford Bakke 26-35 variants.
📄 Sundry Forms 237043, 237048, 237016 (Devon Energy); Form 237054 (Devon submitter, Grayson Mill operator); APD signature block (Grayson Mill); November 25, 2024 letter (Grayson Mill) · 📅 Between 03/18/2025 and 04/01/2025
Operator assignment during active permitting cycle may affect liability, bonding, and compliance responsibilities post-drilling. Grayson Mill becomes responsible for all operational and environmental obligations. Grayson Mill is already operating multiple adjacent wells in same spacing unit (Clifford Bakke 26-35 1-H, #2H, #3H, #4H; Strobeck 27-34 variants) per 1-mile radius map. This consolidated operator status reduces inter-operator coordination risk but centralizes performance accountability.

Core and sample preservation requirement — State Geologist letter dated 01/27/2025 mandates collection and shipment of drill cuttings and any cores to ND Core & Sample Library per NDCC 38-08-04 and NDAC 43-02-03-38.1. Samples at 30° max intervals (vertical/build) and 200' max intervals (horizontal). Cores to be boxed and shipped within 180 days of drilling completion. Civil penalty for non-compliance up to $12,500 per offense, each day a separate offense.
📄 Letter from ND Geological Survey, dated 01/27/2025, signed by Mark F. Bohrer (Assistant Director), Edward C. Murphy (State Geologist) · 📅 01/27/2025
Mandatory state geological archive requirement persists through and beyond drilling completion. Operator must budget and schedule sampling logistics, packaging, and prepaid shipping to Grand Forks within strict timelines. Non-compliance exposure is significant (daily penalties). This obligation is independent of permit approval and continues through production; failure to comply during drilling or post-well-completion phases triggers separate enforcement.

Backbuild Order and Offset Notification — November 25, 2024 letter from Grayson Mill to NDIC regarding Clifford Bakke 26-35 5H, 6TFH, 7TFH, XE 1H, XW 1H (multiple laterals from same pad) proposing to enter Bakken Petroleum System outside target spacing unit. Invokes NDIC Order 31848 offset notification requirement; operator asserts it is also operator of adjacent spacing unit, thus no external notification required.
📄 November 25, 2024 letter from Grayson Mill Operating, LLC to Todd Holweger (NDIC Permit Manager), signed by Tori Siemieniewski (Regulatory Supervisor) · 📅 11/25/2024
Indicates multi-lateral development strategy from single pad (Clifford Bakke PAD) with potential for some wellbores to exit target spacing unit and traverse adjacent units. Grayson Mill's claim of self-ownership of adjacent unit (Section 35, T155N, R92W) eliminates external offset notification burden but creates internal compliance obligation to ensure all laterals from pad respect spacing rules and setbacks within owned acreage. This forward-planning document pre-dates permit approval and signals operator's intent to maximize drainage from single pad infrastructure. Relevant to future drilling sequences and potential multi-well completion/flowback staging.

Well name change from 'Clifford Bakke 25-36 6TFH' to 'Clifford Bakke 26-35 6TFH' — Sundry Form 228109 approved 02/05/2025, submitted 01/22/2025. Change reflects corrected legal location nomenclature (section and quarter-quarter designation).
📄 Sundry Form ID 228109, approved 02/05/2025 · 📅 02/05/2025
Name change indicates initial filing error in legal description that was corrected before final permit issuance. Correct legal location (NE NW Section 26, T155N, R92W) is critical for spacing unit definition, royalty accounting, and regulatory tracking. Corrected nomenclature is reflected in all subsequent permit documents (APD, all waivers, and well planning). No future operational impact but confirms proper identification in permanent well file.

🔧 Operator Pattern

Grayson Mill Operating, LLC operates a cluster of horizontal wells in the Alger-Bakken Pool, Mountrail County, with multiple laterals from shared pad infrastructure. Well naming conventions (Clifford Bakke 26-35 1-H, #2H, #3H, #4H; Strobeck 27-34 2H, 3TFH, 4H, 5TFH) indicate multi-well pads with staggered orientations and formations. Operator proactively seeks waivers (logging, tubing/packer, phased drilling) to optimize development economics and operational efficiency. Compliance posture is structured: provides detailed technical justifications for waivers, maintains clear communication with NDIC (November 2024 backbuild order letter pre-dates final permit approval), and consolidates regulatory responsibility (single operator manages multiple adjacent wells reducing inter-company coordination risk).
1-mile radius map lists 13 active or permitted wells within search area; Grayson Mill operates 8 of them in same field. Well planning documents (Prototype Well Planning LLC, dated 11/22/2024) show detailed directional models for 6TFH variant with design target in Section 26 and planned lateral trajectory through Section 35 (adjacent spacing unit). November 2024 proactive offset letter indicates forward compliance planning. Phased drilling waiver (SOD) suggests financial optimization (smaller rig for casing, avoid rig standby costs). Tubing/packer variance with robust casing design assurances reflects engineering discipline. Filter sock waiver follows operator assertion of no-filter-media operations (operational cost reduction). Open hole log waiver leverages offset data (Strobeck 27-34 2H) and reduces CapEx.

Confidence: High
All critical permit-cycle signals are contemporaneously documented with exact dates (03/18–03/21/2025 waiver approvals; 04/01/2025 permit issuance). Regulatory reviewer signatures and titles are legible (Dan Kuchar, Engineer Tech; Ross Edison, Geologist; Stephen Fried, Petroleum Engineer). No conflicting or missing approvals in the waiver record. Historical context documents (cores/samples letter, backbuild order notification, well name change) are clearly dated and signed by authorized state/operator personnel. Well identification is consistent across all documents (API 3306105475, File 41529, legal location NE NW Sec 26 T155N R92W). Operator name transition (Devon to Grayson Mill) is visible across document sequence but does not obscure the permit logic. One minor inconsistency: APD title page shows 'CLIFFORD BAKKE 25-36 6TFH' (pre-correction name) but all stipulations and waiver signatures reflect corrected '26-35' nomenclature, indicating APD may have been finalized before 02/05/2025 name-change approval took effect, but this does not affect permit cycle assessment.