🛢️ CHARLES 3-10 XW 1H

Devon Energy Williston, L.L.C. (on behalf of Grayson Mill Operating) · Williams County, ND · File #41532 · Generated 2026-02-13 12:33

API: 3310506411
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The well file contains comprehensive contemporaneous documentation explaining and conditioning the permit approval. The permit cycle is anchored to the New Well – Horizontal APD approval (Dirt Work Date: 05/01/2025, File Number 41532). Four subordinate sundry waivers (Forms 4, issued 01/29/2025–01/30/2025) directly justify approval conditions: (1) Suspension of Drilling for 90 days to accommodate staged drilling with small rig followed by conventional rig (cost/schedule optimization, not technical risk); (2) Surface hole drilling restriction (no intentional deviation) due to casing wear risk during build; (3) Filter sock container exemption (no filter media used); and (4) Tubing/packer variance with detailed casing metallurgy and pressure-control justification. An Open Hole Log Waiver (01/30/2025) references nearby offset well data sufficiency. The APD itself cites Commission Order No. 32450 and defines Todd-Bakken Pool with setback stipulations (150' north/south setback based on production liner with wet shoe and frac-out capability). Supporting technical submissions (well location plat with anticollision survey, H2S mitigation plan, emergency response plan, surface use agreement, and cores/samples directive dated 01/27/2025) establish engineering and environmental compliance. All material waivers and conditions are geologist- or engineer-approved, time-stamped, and directly reference regulatory code sections. The permit is fully explained by regulatory action and supporting technical rationale.

🔍 Permit Cycle Signals (5)

Suspension of Drilling (SOD) approval for 90 days to accommodate two-stage drilling with small rig for surface casing, followed by conventional rotary rig for full build-out to TD

Direct

📄 FORM ID 229353, REVIEWER COMMENTS, Pages 1–2
📅 03/07/2025 (Exact confidence)

Regulatory approval conditions the permit on a non-standard drilling sequence: operator explicitly uses small initial rig to set surface casing at pre-approved depth, then moves conventional rig onsite within 90 days to complete drilling and casing plan. This two-phase approach directly justifies the SOD waiver and is tied to cost/time optimization, not technical risk mitigation.

Surface hole drilling restriction: no intentional deviation on surface hole due to risk of severe casing wear during vertical and curve portions

Direct

📄 FORM ID 229353, REVIEWER COMMENTS (Engineer Dan Kuchar), Page 2
📅 03/07/2025 (Exact confidence)

Engineer-issued operational constraint directly conditioning approval. Reflects geological/wellbore geometry risk specific to this well's anticipated trajectory through build section.

Filter Sock Container Waiver (FORM ID 229310) – exemption from NDAC 43-02-03-19.2 filter media storage requirement on basis that operator does not use filter media during drilling

Direct

📄 FORM ID 229310, Pages 1–2; effective date 02/06/2025
📅 02/06/2025 (Exact confidence)

Regulatory waiver approved prior to primary permit approval. Operator declares no filter media consumption during drilling phase, eliminating mandatory container requirement. Waiver scoped to drilling phase only, preserving requirement for completion/flowback if applicable.

Tubing/Packer Waiver (FORM ID 229372) – variance to NDAC 43-02-03-21 casing/packer requirements with technical justification: new #29 and 32# surface casing (API burst 11,220 psi), 0.85 safety factor, real-time damage monitoring, low corrosion/erosion fluids, 300# surface gauge during flowback

Direct

📄 FORM ID 229372, Pages 1–2; effective date 01/30/2025
📅 01/30/2025 (Exact confidence)

Engineer-approved (Petroleum Engineer Stephen Fried) variance conditions completion design on specific casing metallurgy, pressure rating, monitoring protocol, and fluid properties. Waiver tied to flowback operations with approximate start date 06/01/2025. Demonstrates non-routine completion geometry or pressure risk mitigation.

Open Hole Log Waiver (FORM ID 229295) – exemption from DMR Rule 43-02-03-31 open-hole logging requirement based on offset well (Orville 4-9 1-H, NDIC File #21007) within 1 mile with sufficient open logs to establish formation tops; GR-CBL to be run from TD to ground level

Direct

📄 FORM ID 229295, Pages 1–2; effective date 01/30/2025
📅 01/30/2025 (Exact confidence)

Geologist-approved (Ross Edison) waiver justifies omission of full open-hole suite by reference to nearby offset well data sufficiency and fallback GR-CBL plan. Reduces drilling operational complexity and cost.

📖 Historical Context (4)

Pad location offset from target spacing units: well drains from SWSE Sec. 33 (T155N/R101W) surface location but bottom hole location extends into Sec. 3 (T154N/R101W), requiring off-spacing wellbore traversal notification per NDIC Orders 31973 and 31848
📄 Devon letter to Todd Holweger, NDIC Permit Manager, dated January 2, 2024 (Backbuild Order Waiver); Affidavit of Surface Use Agreement (dated 19 December 2024) · 📅 01/02/2024
Off-spacing drilling geometry creates standing obligation for operator to notify adjacent unit operator (here, Devon itself) of trajectory, formation tops, casing design, and cementing details. Multi-well pad architecture (6 wells listed: Orville, Cherrey, Charles 3-10 XW 1H, Borsheim variants) amplifies coordination burden. Well is part of Borsheim South Pad requiring City of Williston SPU permit (issued 07/15/2024) and coordinated road/midstream/stormwater BMPs. Operator committed to Best Management Practices including dust control, produced water/oil piping, stormwater moat/swale design (6-inch 24-hour capacity), SPCC implementation within six months of first production, and closed-loop drilling disposal at Secure Energy Services 13-Mile Landfill.

Cores and Samples collection mandate (ND Century Code §38-08-04, NDAC §43-02-03-38.1): operator must collect sample drill cuttings from Base of Last Charles Salt at 30-foot maximum intervals (vertical/build) and 200-foot maximum intervals (horizontal); ship washed/dried samples in standard envelopes/boxes to ND Geological Survey Core Library within 30 days of drilling completion; any core must be preserved, boxed, and forwarded within 180 days or obtain Form 4 extension
📄 ND Geological Survey letter (signed by Ross Edison, Geologist) dated 01/27/2025, addressed to Tori Siemieniewski, Devon Energy Williston · 📅 01/27/2025
Standing regulatory obligation tied to drilling operations. Failure to comply incurs civil penalties up to $12,500 per violation per day. Creates post-drilling deliverable timeline (30 days for samples, 180 days for cores) and requires pre-drilling coordination with core library for sample box procurement and shipping logistics. Non-compliance risk extends beyond well completion into data custodianship phase.

H2S Hazard Mitigation Plan (BLM format) and Emergency Response Plan, both effective January 2, 2025 (revised Rev. 0), establish ongoing training, PPE, evacuation, and public protection protocols for Borsheim South Pad (8 wells including Charles 3-10 XW 1H)
📄 H2S Mitigation Plan (Devon Operating, BORSHEIM SOUTH WELL PAD); Emergency Response Plan (January 2025, Rev. 0) · 📅 01/02/2025
Structural commitment to hazard control and personnel safety during all operational phases (drilling, completion, production). H2S plan mandates ANSI Z390.1-2017 training for all site personnel; weekly well-control drills during drilling; fitness testing and respiratory equipment qualification; HAZWOPER certification for emergency responders; wind direction monitoring; warning signage; and designated Drilling Safety representative. Emergency Response Plan defines chain-of-command, evacuation zones, and public notification. Plans remain active throughout well life and are subject to periodic SPCC inspections and annual training.

Backbuild/off-spacing operational commitment: Devon committed to Best Management Practices letter (January 2, 2025) itemizes road routing (Highway 2 → 58th St → 137th Ave → 54th St to pad, ~3 miles total), dust control, piped off-location disposal (produced water/oil via existing lines; gas to ONEOK), stormwater containment (6-inch/24-hour capacity moat), AST synthetic containment (EPA/NDIC compliant), SPCC within six months of first oil, and closed-loop drilling with cuttings disposal at Secure Energy Services 13-Mile Landfill
📄 Devon Energy letter to Todd Holweger, dated January 2, 2025 (BMP Letter) · 📅 01/02/2025
Operator-committed environmental and operational controls persist through production and post-drilling phases. Road dust suppression, stormwater management, spill prevention, and waste disposal all require ongoing compliance monitoring. Proximity to City of Williston (pad ~2–3 miles northwest) creates standing community relations and regulatory oversight obligation. SPCC plan must be prepared and implemented within 6 months of first production, triggering a regulatory approval/inspection gate.

🔧 Operator Pattern

Devon Energy Williston (subsidiary operator identity: Grayson Mill Operating on drilling operations) is a multi-well pad developer in Williams County Todd Field with systematic offset-spacing strategy and proactive regulatory coordination.
Borsheim South Pad demonstrates coordinated, multi-well development: 6 primary wells (Orville, Cherrey, Charles 3-10 XW 1H, Borsheim variants), several confidential extensions (Orville 4-9 3H–5H, NDIC Files 5790–5791), and additional Charles 3-10 variants (3H–5H, Files 5955–5957). All wells utilize off-spacing geometry with surface location in Sec. 33 (T155N/R101W). Operator obtained City SPU permit (July 2024), engaged Best Management Practices consultation, and submitted H2S/Emergency Response Plans in advance of approval. Off-spacing notifications (January 2, 2024) and backbuild waiver requests signal routine operational framework for this operator. Pattern indicates large-scale consolidation drilling with infrastructure leverage (existing produced water/oil lines, ONEOK gas dedication) and community relations strategy (dust control, stormwater, coordinated truck routing).

Confidence: High
The file contains comprehensive, time-stamped regulatory documents with explicit approvals, technical justifications, and geologist/engineer signatures. Permit approval (05/01/2025 Dirt Work Date) is supported by four subordinate sundry waivers (issued 01/29/2025–01/30/2025, all Approved and Effective). All waiver justifications reference specific NDAC code sections, casing metallurgy/pressure ratings, offset well data, or drilling logistics. Pre-permit coordination letters (backbuild waiver, BMP letter, surface use affidavit) are dated January 2, 2024, and January 2, 2025, establishing clear temporal sequence. Supporting technical submissions (well plat, H2S/ERP plans, cores/samples directive) are consistently dated and signed. No conflicting or ambiguous statements; no missing approval dates or unexplained condition reversals. Historical signals are grounded in regulatory statutes (ND Century Code §38-08-04, NDAC §43-02-03-19.2, §43-02-03-21, §43-02-03-31) and NDIC orders (31973, 31848, 32450). Operator (Devon/Grayson Mill) identity is consistent across all documents.