🛢️ SANDERS 34-27 6H

Devon Energy Williston, LLC · McKenzie County, North Dakota County, ND · File #41620 · Generated 2026-02-13 12:33

API: 3305310525
Target Formation: Middle Bakken
Permit Explained: Partially

📋 Permit Cycle Assessment

The well file contains two direct permit-conditioning signals: (1) the Suspension of Drilling approval (03/19/2025) which directly enabled the two-phase drilling strategy executed (small rig surface hole May 3–May ~8, 2025; main rig lateral drilling August 2–6, 2025); and (2) geologist letter dated 2/25/2025 imposing mandatory cuttings sampling and core collection requirements under ND Century Code §38-08-04. The APD itself (dated 05/15/2025, permit type New Well-Horizontal) anchors to Commission Order No. 33659 and stipulates standard setback geometry (150' N/S, 500' E/W) tied to production-liner cemented-toe design with wet-shoe frac-out capability. The well location plat, well-path design (with KOP at 10,943' MD, curve to 11,730' MD, lateral to 21,700' MD in Middle Bakken), and off-spacing notifications to adjacent operators (Murex Petroleum, Whiting/Chord Energy) per NDIC Orders 31973 and 31848 are documented and contemporaneous. However, no permit review decision letter or drill-approval order letter is present in the file that explicitly states the regulatory rationale for granting the APD on 05/15/2025 or references specific technical submissions (anticollision study, geologic assessment, or detailed completion design) that justified the approval. The geologist report (drilling operations summary dated 08/2025, well completion) is post-spud and therefore reflects actual performance rather than pre-permit justification. Waivers for open-hole logs and tubing/packer are supportive but do not themselves explain the permit grant. Thus, while operational constraints and mandatory submissions are clearly documented, the file lacks explicit pre-permit technical justification or regulatory order articulating why the APD was approved.

🔍 Permit Cycle Signals (4)

Suspension of Drilling (SOD) approval for 90 days—permit operator to drill surface hole with small rig, set casing, then move larger rig onto location to drill to TD within 90-day window.

Direct

📄 Sundry Form FORM ID 236997, dated 03/18/2025, Status: Approved, Effective Date: 03/19/2025
📅 03/19/2025 (Exact confidence)

SOD approval is a non-routine condition that directly enabled the phased drilling sequence executed in the well (surface hole drilled May 3, 2025; lateral drilling completed August 6, 2025). The regulator imposed specific operational constraints: small rig surface hole with freshwater mud, no saltwater in surface casing operations, mandatory plug/mechanical seal placement, and obligation to plug/abandon if main rig did not arrive within 90 days. Field inspector call-in requirements were stipulated.

Open Hole Log Waiver—operator exempted from requirement to run open-hole logs; equivalency justified by offset well (Stallion 33-28 3H, NDIC File #35843, within 1 mile) with existing open logs and formation-top establishment; only gamma-ray/CBL required from TD to surface.

Supporting

📄 Sundry Form FORM ID 236983, dated 03/18/2025, Status: Approved, Effective Date: 03/18/2025
📅 03/18/2025 (Exact confidence)

Non-routine waiver of logging requirement; approved via NDIC #21431. Operator relied on documented proximity of offset well to satisfy formation-definition and risk-assessment criteria, reducing operational burden but placing conditional reliance on offset data integrity.

Tubing/Packer Waiver—variance to NDAC 43-02-03-21; operator (Grayson Mill Operating) granted permission to omit tubing and packer during flowback; casing design and pressure monitoring substituted per stated assurances (API burst rating 11,220 psi; 0.85 safety factor; 300# gauge on surface casing; immediate damage detection capability).

Supporting

📄 Sundry Form FORM ID 237013, dated 03/18/2025, Status: Approved, Effective Date: 03/18/2025; Approximate Start Date: 11/10/2025
📅 03/18/2025 (Exact confidence)

Non-routine completion design waiver conditioned on documented casing strength, low-pressure flowback environment, and real-time monitoring. Indicative of cost-optimization strategy aligned with completion schedule (planned start ~Nov 2025), but no evidence this waiver was exercised or relevant to drilling permit approval timing.

Filter Sock Container Waiver—operator exempted from NDAC 43-02-03-19.2 container requirement for drilling phase only; operator statement that no filter media used during drilling operations.

Supporting

📄 Sundry Form FORM ID 236989, dated 03/18/2025, Status: Approved, Effective Date: 03/21/2025
📅 03/21/2025 (Exact confidence)

Routine waiver based on drilling fluid selection (no filtration system). Does not explain permit approval; included for completeness as time-bound operational constraint.

📖 Historical Context (3)

Offset well Stallion 33-28 3H (NDIC File #35843) used as basis for open-hole log waiver; formation-top data from offset incorporated into Sanders 34-27 6H geologic prognosis.
📄 Sundry Form FORM ID 236983 (Open Hole Log Waiver); Well Location Plat and Coordinate Table (showing Stallion 33-28 wells in proximity); Formation Tops table (Sanders 34-27 6H) showing prognosed tops aligned with offset data. · 📅 Unknown
Validity of formation-top predictions and drilling safety depend on offset-data accuracy. Any reinterpretation or revision to Stallion 33-28 3H geologic model would require reassessment of Sanders 34-27 6H drilling hazards and potential drilling-restriction review.

Well operates off-spacing unit boundary into adjacent spacing units (NDIC Orders 31973, 31848 triggered); operator notified adjacent operators (Murex Petroleum, Whiting/Chord Energy) per regulatory requirement; wellbore lateral enters SE 27 from surface location in SE 33.
📄 Affidavit by Victoria Siemieniewski dated 01/17/2025 (signed 01/17/2025); Well Location Plat sheets showing SHL in SESE 33, T151N, R101W and BHL projected to SESE 27, T151N, R101W. · 📅 Unknown
Off-spacing drilling creates standing obligation to maintain directional control and well-bore isolation as drilled. Any wellbore deviation or casing failure affecting adjacent acreage could trigger liability or re-certification requirements. Adjacent operators retain potential development or enforcement rights under NDIC orders.

Samples and cores mandatory collection per ND Century Code §38-08-04: drill cuttings at 30' intervals (vertical/build) and 200' intervals (lateral); submission to State Geologist within 30 days of drilling completion; cores (if cut) within 180 days.
📄 Letter dated 2/25/2025 from Ross Edison, Geologist, NDIC Oil & Gas Division, captioned 'CORES AND SAMPLES' · 📅 Unknown
Operator remains liable for compliance with ND Century Code §38-08-16 (civil penalty up to $12,500 per violation, each day a separate offense). Non-submission or late submission carries enforceable penalty exposure. Samples are public record (upon request, post-confidential period lift) and inform state subsurface database and geologic assessment.

🔧 Operator Pattern

Devon Energy Williston, LLC structured phased drilling strategy (small-rig surface section, main-rig lateral section) to optimize rig-scheduling and cost efficiency. Operator sought and obtained regulatory waivers for non-standard completion design (tubing/packer exemption), logging (offset-well equivalency), and filter management (no-filtration statement). Operator complied with off-spacing notification and surface-damage settlement requirements.
Suspension of Drilling request (03/18/2025, approved 03/19/2025) explicitly cited cost and time savings; phased drilling executed as approved (spud 05/03/2025, surface hole ~5 days, curve/lateral drilling 08/02–08/06/2025). Tubing/Packer Waiver (03/18/2025, approved 03/18/2025) submitted with engineering justification. Affidavit of Surface Damage Agreement (02/10/2025) and off-spacing notifications (01/17/2025) demonstrate operator operational-risk management and regulatory compliance discipline.

Confidence: Medium
The file contains comprehensive drilling operations documentation (geologist report, cuttings logs, formation samples), well-design plans (location plat, well-path sections, casing design), regulatory submissions (Sundry Notices, waivers, off-spacing affidavits), and standard APD boilerplate. The Suspension of Drilling approval and geologist-imposed sampling requirements are clearly documented and time-bound. However, the file does NOT contain an explicit permit-approval letter from the NDIC articulating the technical or regulatory basis for granting the APD on 05/15/2025. The geologist report is post-spud (operations summary completed 08/28/2025 after drilling finished 08/06/2025) and therefore documents actual results rather than pre-permit justification. Open-hole log and tubing/packer waivers are pre-permit but are supportive conditions, not explanations of the permit grant itself. The absence of a decision letter or drill-order rationale, combined with post-spud reporting, limits confidence in fully explaining the permit-cycle approval logic; all essential operational constraints are documented, but the regulator's explicit findings are missing.