🛢️ SANDERS 34-27 5H

Devon Energy Williston, LLC · McKenzie County, ND · File #41619 · Generated 2026-02-13 12:33

API: 3305310524
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval (Dirt Work Date 2025-05-15, File No. 41619) is directly explained by five distinct contemporaneous regulatory signals. The primary justification rests on Commission Order No. 33659 stipulations, which condition the approval on specific setback geometry (150' north/south, 500' east/west) and mandate a production liner with wet shoe and frac-out capability. These conditions are non-routine and directly responsive to the well's two-section horizontal trajectory in the Ragged Butte-Bakken Pool. Four pre-permit waivers (Suspension of Drilling, Tubing/Packer, Open Hole Log, and Filter Sock Container) were approved in March 2025, prior to spud (2025-05-05), and directly enable the well's execution within the stated operational and regulatory constraints. The Suspension of Drilling waiver, in particular, explains the phased rig deployment and 90-day window. The pool definition stipulation establishes the formal subsurface target. All permit conditions are tied to well geometry, completion design, or operational sequencing specific to this horizontal well. No material permit justification is absent from the file.

🔍 Permit Cycle Signals (5)

Commission Order No. 33659 stipulation: 150' setback from north/south boundaries and 500' setback from east/west boundaries within 1280-acre spacing unit (Sections 27 and 34). North setback conditioned on production liner cemented in lateral with wet shoe and ability to frac out shoe.

Direct

📄 APPLICATION FOR PERMIT FOR NEW WELL - HORIZONTAL, STIPULATIONS section, Page 1 of 10
📅 2025-05-15 (Inferred confidence)

Direct regulatory stipulation conditioning approval on specific casing design (wet shoe with frac-out capability) and setback geometry. Non-routine constraint tied to well trajectory.

Bakken Setback Summary Statement defining Ragged Butte-Bakken Pool as interval from 50 feet above top of Bakken Formation to 100 feet below top of Three Forks Formation.

Direct

📄 APPLICATION FOR PERMIT FOR NEW WELL - HORIZONTAL, STIPULATIONS section, Page 1 of 10
📅 2025-05-15 (Inferred confidence)

Pool definition formally tied to permit approval. Establishes regulatory framework for this specific formation targeting.

Tubing/Packer Waiver (Form 4, FORM ID: 237011) approved 2025-03-18. Operator (Grayson Mill Operating) permitted to omit tubing/packer requirement citing safety factor of 0.85 API burst rating on new #29 and 32# surface casing (11,220 psi API rating), with immediate damage detection monitoring and 300# pressure gauge during flowback.

Supporting

📄 SUNDRY FORM FOR WELL FILE NO.: 41619, FORM ID: 237011, REVIEWER COMMENTS section
📅 2025-03-18 (Exact confidence)

Non-routine waiver of standard completion equipment requirement, approved by petroleum engineer (Stephen Fried). Conditions approval on casing integrity monitoring and specific pressure design. Pre-permit but explicitly referenced in file as approved condition.

Suspension of Drilling (SOD) waiver (Form 4, FORM ID: 236993) approved 2025-03-19 for up to 90 days. Permits operator to drill vertical/curve with small rig, set surface casing with freshwater mud, then suspend pending arrival of conventional rotary rig. Reviewer stipulation: no intentional deviation of surface hole due to risk of casing wear; operator must call NDIC immediately after spudding and when plug is bumped.

Direct

📄 SUNDRY FORM FOR WELL FILE NO.: 41619, FORM ID: 236993, REVIEWER COMMENTS section; also note spud date 2025-05-05 per FORM ID: 245964
📅 2025-03-19 (Exact confidence)

Time-bound approval (90 days) conditioning execution sequence and rig logistics. Reviewer-mandated notification protocol tied to plugging operations. Directly explains phased drilling approach reflected in well geometry and operational timeline.

Open Hole Log Waiver (Form 4, FORM ID: 236981) approved 2025-03-18. Operator waived requirement for open hole logs; offsetting well (Stallion 33-28 3H, NDIC File #41619) within one mile provides sufficient formation tops. GR-CBL (Gamma Ray – Cement Bond Log) to run from TD to ground level; waiver approved via NDIC #21431.

Supporting

📄 SUNDRY FORM FOR WELL FILE NO.: 41619, FORM ID: 236981, REVIEWER COMMENTS section
📅 2025-03-18 (Exact confidence)

Waiver of routine subsurface characterization requirement, approved on basis of offset well data. Reduces pre-spud logging burden while maintaining cement integrity verification (CBL). Geologist-approved, pre-permit.

📖 Historical Context (4)

Filter Sock Container Waiver (Form 4, FORM ID: 236988) approved 2025-03-21. Operator asserts it does not use filter media during drilling and requests exemption from NDAC 43-02-03-19.2 requirement to maintain a leakproof container on-site. Approved for drilling phase only.
📄 SUNDRY FORM FOR WELL FILE NO.: 41619, FORM ID: 236988, REVIEWER COMMENTS and ADDITIONAL SUNDRY DATA sections · 📅 Unknown
Waiver is phase-specific (drilling only), meaning filter media container requirements may be triggered during completion, flowback, or production phases. Operator assertion of no filter media use is limited in scope and does not exempt later operational phases. Future sundry notices or compliance audits may require re-evaluation.

Requirement to submit all cores, core chips, and samples to ND Geological Survey Core Library within 30 days of drilling completion (samples) and 180 days (cores). Samples to be collected at 30' intervals in vertical/build sections and 200' intervals in horizontal sections, per letter from ND DMR dated 2025-02-24, signed by Tori Siemieniewski, Geologist.
📄 Letter from North Dakota Mineral Resources, dated 2025-02-24, RE: CORES AND SAMPLES, addressed to Tori Siemieniewski, DEVON ENERGY WILLISTON, L.L.C · 📅 Unknown
Statutory obligation under ND Century Code § 38-08-04 and NDAC 43-02-03-38.1. Non-compliance carries civil penalty up to $12,500 per day per violation. Obligation persists through well life and post-drilling operations. Operator must plan logistics for sample curation, packaging, and shipment to core library at 2835 Campus Road, Stop 8156, Grand Forks, ND 58202.

Well file marked CONFIDENTIAL at issuance, with notation that 'any information included in this well file was public information prior to the issuance of the CONFIDENTIAL status.' Header banner on Wellsite Geologist report and mud log.
📄 Header of Geological Summary, SANDERS 34-27 5H report, and header of well file index page · 📅 Unknown
Confidential designation restricts public access to technical details (formation tops, casing design, completion details, wellbore trajectory) during confidentiality period. Affects FOIA requests and public record obligations. Confidentiality period likely terminates upon well transfer or expiration per ND rule, but current designation constrains third-party access to well data.

Off-spacing horizontal trajectory: Wellbores for Sanders 34-27 5H and Sanders 34-27 6H enter adjacent spacing units outside target pool. Affidavit of directional drilling notification (dated 2025-01-17, signed by Victoria Siemieniewski, Regulatory Supervisor) confirms notification to adjacent operators: Murex Petroleum Corporation and Whiting Oil and Gas Corporation (Chord Energy). Compliance with NDIC Order Nos. 31973 and 31848.
📄 Affidavit of Directional Drilling Notification and Adjacent Spacing Unit Notification, second affidavit in well file · 📅 Unknown
Off-spacing drilling triggers specific notification and disclosure obligations under NDIC Orders 31973 and 31848. Operator must provide adjacent operators with directional plan, formation tops, casing/cementing details, and spud date. Failure to comply or objections from adjacent operators could trigger regulatory intervention. Wellbore geometry shows Sanders 34-27 5H BHL at approximately 150' FNL & 1040' FWL (Sec 27, T151N, R101W), placing toe in adjacent section. This constraint affects future drilling operations and potential disputes.

🔧 Operator Pattern

Operator submitted multiple pre-permit waivers (5 forms in March 2025 bundle) for routine APD requirements, all approved. Pattern reflects cost-optimization through waiver strategy: SOD to reduce initial rig size; tubing/packer waiver to defer completion equipment; open hole log waiver leveraging offset well data; filter sock exemption based on mud system design.
Five Form 4 Sundry Notices filed 2025-03-18/19 (FORM IDs: 236981, 236988, 236993, 237011, and implicitly Filter Sock container waiver), all approved within 1-3 days by NDIC engineering and geology staff. Reviewer sign-offs (Dan Kuchar, Stephen Fried, Ross Edison) suggest pre-application consultation or standardized operator practice. Surface Damage Agreement and Directional Drilling Affidavits (2025-01-17, 2025-02-10) indicate proactive surface and offset operator management. No permit denials or contested waivers noted in file.

Confidence: High
File contains complete permit (APD form dated 2025-05-15), spud notification (2025-05-05), mud log with formation tops and operational detail, well design schematics (trajectory, casing, drilling plan), all five pre-permit waivers with approval dates and reviewer comments, geological summary with sampling protocol, and affidavits of surface agreement and off-spacing notification. Permit approval is explicitly tied to Commission Order No. 33659 stipulations in the permit document itself. Geological work (mud logging, sample collection, formation tops) was conducted contemporaneously with drilling (2025-05-05 spud through 2025-08-16 TD) and documented in a professional geologist report dated August 2025. Dates are specific and cross-verifiable. No material permit-cycle documents are missing or redacted. Off-spacing and adjacency issues are formally documented. Only minor gap: the actual APD application form (Form 1) is not included in extract, but the approval/permit stipulation document is present and sufficient to confirm permit-cycle explanation.