🛢️ ORVILLE 4-9 7H

Devon Energy Williston, L.L.C. (Grayson Mill Operating filing agent) · Williams County, ND · File #41531 · Generated 2026-02-13 12:33

API: 3310506410
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The well file contains explicit permit-cycle documentation that justifies and conditions the New Well permit and all associated sundry approvals. The permit approval (Dirt Work Date 05/01/2025) is grounded in three regulatory mechanisms: (1) Suspension of Drilling authorization under NDAC 43-02-03-55, contingent on 90-day rig sequencing and mandatory P&A if re-mobilization fails; (2) Waiver and variance approvals (filter sock container, tubing/packer, open hole logs) each submitted as Sundry Notices with specific technical or operational justifications, all approved by NDIC engineer and geologist reviewers between 01/29/2025 and 02/05/2025; and (3) Setback stipulations and pool definitions from Commission Order No. 32450 establishing drilling unit geometry and casing isolation requirements. The tubing/packer variance is the most risk-sensitive approval—conditioned on seven specific design and monitoring parameters (casing burst rating, safety factor, pressure gauge, fluid corrosion properties, real-time damage detection, and early equipment installation). The open hole log waiver and filter sock waiver are justified by offset data and operational design (no filtration in use), respectively. No material gaps exist between permit issuance and pre-permit technical submissions; all sundry notices predate or match the permit effective dates. The 90-day SOD condition creates a future compliance obligation: re-drilling must begin before 90 days post-spud or automatic P&A is triggered.

🔍 Permit Cycle Signals (5)

Suspension of Drilling (SOD) approval conditioned on staged completion strategy: surface casing set by small rig in 3–5 days, with larger rotary rig to return within 90 days to drill to TD per approved casing plan.

Direct

📄 Sundry Form 229346, DESCRIPTION section; APD stipulations reference NDAC 43-02-03-55
📅 03/07/2025 (Exact confidence)

Approval is contingent on rig sequencing and 90-day re-mobilization deadline. Non-compliance triggers automatic P&A obligation. This is the direct trigger for the permit condition.

Reviewer directive: No intentional deviation of surface hole; monitor for casing wear during vertical and curve portions. Field inspector notification required when plug is bumped and when conventional rig returns to location.

Direct

📄 Sundry Form 229346, REVIEWER COMMENTS section (Dan Kuchar, ENGINEER TECH)
📅 01/29/2025 (Exact confidence)

Engineer-level restriction on wellbore geometry (no intentional deviation in surface hole) tied to casing wear risk during build section. This condition modifies standard APD drilling plan.

Filter Sock Container Waiver (NDAC 43-02-03-19.2): Operator states no filter media used during drilling; waiver granted for drilling phase only.

Direct

📄 Sundry Form 229307, DESCRIPTION and ADDITIONAL SUNDRY DATA sections
📅 02/05/2025 (Exact confidence)

Waiver is explicit to drilling phase only, preserving filter container requirement for completion and flowback. Justification is operational (no filtration system in use), not technical risk mitigation.

Tubing/Packer Variance (NDAC 43-02-03-21): Approval based on 7 technical assurances including new casing with 11,220 psi burst rating, 0.85 safety factor on API burst, casing damage monitoring, low corrosion fluids, and 300# gauge during flowback.

Direct

📄 Sundry Form 229367, DESCRIPTION section; approved by Stephen Fried, Petroleum Engineer
📅 01/30/2025 (Exact confidence)

Variance permits production casing to be left uninsulated and unpacked during flowback period (typical requirement is tubing + packer installation before first production). Approval is conditioned on specific pressure rating, monitoring, and fluid chemistry assurances. Start date June 1, 2025 aligns with production timeline.

Open Hole Log Waiver (NDAC 43-02-03-31): Offset well (ORVILLE 4-9 1-H, NDIC File #21007) within 1 mile provides sufficient formation tops data. GR-CBL log from TD to ground level will be run.

Direct

📄 Sundry Form 229276, DESCRIPTION section; approved by Ross Edison, Geologist (01/30/2025)
📅 01/30/2025 (Exact confidence)

Waiver substitutes offset well correlation for conventional open hole suite. Geologist acceptance is based on proximity and existing petrophysical coverage, reducing drilling time and operational risk.

📖 Historical Context (5)

Cores and Samples requirement (letter from Ross Edison, Geologist, 01/27/2025): All cores and samples must be collected per NDCC 38-08-04 and NDAC 43-02-03-38.1. Samples at 30' max intervals (vertical/build) and 200' max (horizontal); shipment to ND Geological Survey Core Library within 30 days of drilling completion. Cores within 180 days. Civil penalty up to $12,500 per day for non-compliance.
📄 Letter from Ross Edison, Geological Survey, dated 01/27/2025 · 📅 Unknown
This is a post-drilling obligation that persists through completion and production phases. Non-compliance triggers daily civil penalties under NDCC 38-08-16. Operator must plan logistics for core preservation and timely shipment to Grand Forks facility. The sampling interval (30' in build, 200' in lateral) is standard but mandatory and affects drilling operations planning.

Surface Use Agreement and Easement Affidavit (Whitney Stephenson, 12/19/2024): Devon Energy has obtained surface agreement for Borsheim South Pad. Landowner aware of off-spacing drilling from Section 33 (EASW½ and SESW½, T155N, R101W). Agreement covers multiple wells including ORVILLE 4-9 7H.
📄 Affidavit of Surface Use Agreement and Easement, executed 12/19/2024 · 📅 Unknown
Surface rights and easement terms are binding throughout the well's lifecycle. Any dispute with landowner regarding surface restoration, access, or use restrictions during production will be governed by this agreement. The affidavit establishes the operator's right to multi-well development off-spacing; disputes could affect future pad development or delay abandonment obligations.

Best Management Practices (BMP) Letter (01/02/2025): Devon commits to specific environmental and operational controls including: one access road via 54th St NW with defined truck route minimizing traffic to Williston; existing oil and water pipelines for off-pad transport (gas to ONEOK per existing dedication); stormwater management with 6-inch 24-hour capacity moat and perimeter berms; closed-loop drilling system with cuttings hauled to Secure Energy 13-Mile Landfill; SPCC plan within 6 months of first oil production; BOPP and Drilling SPCC during drilling/completion phases.
📄 BMP Letter from Tori Siemieniewski, Devon, dated 01/02/2025; H2S Mitigation Plan; Emergency Response Plan (both Revised 01/02/2025) · 📅 Unknown
These commitments create enforceable operational and environmental management obligations that persist throughout drilling, completion, production, and eventual abandonment. Closure of the moat valve and SPCC compliance are ongoing. Non-compliance with H2S and emergency procedures during drilling and flowback is subject to BLM Onshore Order #6 and ANSI Z390.1-2017 standards. Truck route and road maintenance coordination with Williams County is ongoing.

H2S Mitigation Plan and Emergency Response Plan (Rev. 0, 01/02/2025): Plan addresses drilling and completion hazards for Bakken H2S exposure. Requires H2S training per API RP 49 and ANSI Z390.1-2017; weekly drills during drilling; respiratory fit testing; HAZWOPER training for offensive responders; warning signs, windsocks, and evacuation protocols. Plan applies to all Borsheim South Pad wells.
📄 H2S Mitigation Plan and Emergency Response Plan, both revised 01/02/2025, submitted to BLM/NDIC · 📅 Unknown
H2S safety obligations persist during drilling and flowback phases and establish baseline for personnel safety and emergency response. Weekly drill records are required. Non-compliance with H2S training and BOP/well control procedures during drilling operations is a federal and state violation. Contingencies for emergency evacuation and medical response remain operationally critical during production if H2S is encountered.

Backbuild Order Waiver notification (01/02/2024, pre-APD): Devon notified NDIC that wells on Borsheim South Pad will horizontally drill outside their target spacing units per NDIC Orders 31973 and 31848. Devon self-certified as operator of adjacent spacing units, negating need for third-party operator notification. Wells included ORVILLE 4-9 7H.
📄 Backbuild Order Waiver letter from Tori Siemieniewski, Devon, dated 01/02/2024 (note: year appears to be 2024 but context suggests early 2025 pre-submission) · 📅 Unknown
Off-spacing drilling creates ongoing obligation to monitor well performance in adjacent spacing units and comply with NDIC Orders 31973 and 31848 requirements. Any disputes with leaseholders in adjacent units or changes to spacing unit boundaries could trigger re-evaluation of well geometry and liability for production allocation. This establishes the well's off-spacing status as a structural attribute, not a one-time compliance event.

🔧 Operator Pattern

Devon Energy (operator via Grayson Mill Operating filing entity) demonstrates staged regulatory engagement: early notification of off-spacing drilling status (01/02/2024), coordinated surface rights and easement execution (12/19/2024), contemporaneous submission of all five sundry notices and supporting technical documents (01/29/2025–01/30/2025), and proactive Best Management Practices, H2S, and Emergency Response planning aligned with Williston city zoning coordination (01/02/2025). All submissions are technically detailed and address regulator concerns prospectively (casing burst rating, damage monitoring, offset log correlation, surface drainage). Operator self-certified as adjacent-unit operator, reducing third-party notification burden.
Backbuild Order Waiver (01/02/2024), Surface Use Affidavit (12/19/2024), Cores/Samples directive (01/27/2025), five Sundry Notices with reviewer approvals (01/29/2025–02/05/2025), BMP/H2S/ERP letters (01/02/2025). All documents are executed or approved by named regulatory supervisors (Tori Siemieniewski, Whitney Stephenson, Dan Kuchar, Stephen Fried, Ross Edison). No evidence of enforcement actions, late submissions, or incomplete filings.

Confidence: High
Permit approval date is explicit (03/07/2025 for suspension of drilling; 02/05/2025 for filter sock waiver; 01/30/2025 for tubing/packer and open hole log waivers). Contemporaneous sundry notices and waiver justifications are present. APD documents, wellbore design, and regulatory correspondence are complete and internally consistent. No missing permit-cycle dates.