🛢️ Gail Arnold 33-28-21 1H

Phoenix Operating LLC · Divide County, ND · File #42014 · Generated 2026-02-13 12:33

API: 3302301631
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval for Gail Arnold 33-28-21 1H (File 42014, issued 09-04-2025 effective date per casing waiver, with principal drilling permit dated prior to spud on 09-19-2025) is clearly justified by contemporaneous technical and regulatory documentation. Five direct regulatory waivers and supporting analyses explain the permit conditions: (1) larger-diameter surface casing (13 3/8" vs. 9 5/8") was approved by engineering review on 09-04-2025 prior to construction; (2) filter sock waiver and tubing/packer variance were approved pre-drilling with specific phase limitations and safety factors; (3) open hole log waiver was justified by offset well data and contemporaneous GR-CBL requirement; (4) anticollision analysis dated 24 May 2025 (pre-permit) certified compliance with NDIC spacing, setback, and collision-avoidance rules via ISCWSA error modeling. All waivers and modifications tie directly to the 09-04-2025 through 09-19-2025 permit window and reflect operator submissions dated June–September 2025.

🔍 Permit Cycle Signals (5)

Casing design revision approved via waiver (FORM ID: 268020) - change from 9 5/8" to 13 3/8" surface casing

Direct

📄 Sundry Form 268020, Reviewer: Emma Neigum, evneigum@nd.gov
📅 09-04-2025 (Exact confidence)

Direct modification to permitted casing design executed before spud; demonstrates operator-initiated design adaptation in response to site/engineering requirements

Filter sock container waiver approved (FORM ID: 254329) - exemption from NDAC 43-02-03-19.2 for drilling phase only

Direct

📄 Sundry Form 254329, Reviewer: Dan Kuchar, djkuchar@nd.gov, Effective: 06-19-2025
📅 06-18-2025 (Exact confidence)

Operator requested and received phase-specific waiver conditioning drilling operations; establishes operational constraint for completion/flowback phases

Open hole log waiver approved (FORM ID: 254294) - exemption from NDIC Rule 43-02-03-31 based on offset well correlation

Direct

📄 Sundry Form 254294, Reviewer: Ross Edison, rossedison@nd.gov, Effective: 06-19-2025
📅 06-18-2025 (Exact confidence)

Waiver justified by proximity to MOE TRUST 33-28-160-98H 1BP (File #23601, within 1 mile) with sufficient open logs; GR-CBL run from TD to ground level required as compensatory measure

Tubing/packer waiver approved (FORM ID: 254340) - variance to NDAC 43-02-03-21 with seven engineering assurances provided

Direct

📄 Sundry Form 254340, Reviewer: Stephen Fried, sjfried@nd.gov, Effective: 06-18-2025; Approximate Start Date: 01-01-2026
📅 06-18-2025 (Exact confidence)

Comprehensive waiver for completion phase conditioning well integrity management; casing burst rating 11,220 psi with 0.85 safety factor; 300# gauge mandated during flowback

Anticollision analysis completed and certified (COMPASS Report, dated 24 May 2025, TAKTIKAL DIRECTIONAL)

Supporting

📄 Anticollision Report spanning 30+ pages with detailed separation analysis; Survey Calculation Method: Minimum Curvature; ISCWSA Error Model applied at 2.00 sigma
📅 2025-05-24 (Exact confidence)

Pre-drilling technical justification: minimum separation achieved vs. MOE TRUST 33-28-160-98H 1BP (1,295.43 usft at closest approach, separation factor 72.983); vs. W NYSTUEN 159-98-15-9-4-2H3 (min sep 1,513.40 usft, SF 7.474); vs. pad wells (59.97–119.94 usft, all SF >2.8)

📖 Historical Context (5)

Cores and samples collection mandate (Letter dated 06-23-2025 from State Geologist Mark F. Bohrer) - North Dakota Century Code 38-08-04 compliance
📄 Letter from ND Geological Survey, addressed to Karlyn Linarte (Phoenix Operating), Well File No. 42014 · 📅 2025-06-23
Operator obligation persisting through completion: samples must be collected from Base of Last Charles Salt at 30' max intervals (vertical/build) and 200' max intervals (lateral); boxed and shipped to ND Geological Survey within 30 days of drilling completion. Non-compliance carries civil penalty up to $12,500 per violation per day.

NDIC Order No. 34436 spacing unit and setback restrictions - 1920-acre spacing unit (Sections 21, 28, 33, T160N R98W) with conditional 150' FSL/FNL and 500' FEL/FWL boundaries
📄 APD Permit Application Stipulations page, NDIC Field Order Info category · 📅 Unknown | Relative to permit issuance
Setback constraints conditioning all future lateral extensions and pad development; north setback based on production liner with wet shoe and frac-out capability; Bakken pool defined as interval 50 ft above top to 100 ft below top of Three Forks Formation

Operational constraint: closed mud system with no cuttings pit (APD Stipulation)
📄 APD Permit Application, Permit Review Policy category · 📅 Unknown | Relative to permit issuance
Environmental/operational requirement persisting through drilling and completion phases; affects waste management and site infrastructure planning

Mandatory pre-construction notification to NDIC Field Inspector Gunther Harms (701-770-2564) prior to location construction
📄 APD Permit Application Stipulations, Construction Commencement Notification · 📅 Unknown | Relative to permit issuance
Operational gate for location development; non-compliance may trigger enforcement action or construction halt

Planned pad development: multi-well pad configuration (Gail Arnold 33-28-21 1H through 5H-LL plus 1 SWD) from single surface location in SESW Section 33 with directional/lateral drilling into Sections 28 and 21
📄 Location Plat, Directional Plan (COMPASS 5000.15), Anticollision Report; Notarized Affidavit dated June 2025 (Meaghan Coughlan, Phoenix Operating) · 📅 2025-05-23 to 2025-06-04
Future drilling commitment: planned wells 2H–5H and SWD require same spacing/setback compliance and anticollision clearance; tubing/packer waiver and casing design extend to completion of all pad wells; operator notification to PetroHunt and Whiting (Chord Energy) of adjacent-unit trajectory impacts establishes future coordination obligation

🔧 Operator Pattern

Phoenix Operating LLC demonstrates routine pre-drilling regulatory compliance and proactive waiver management. Operator submitted engineering modifications (casing revision) and operational waivers (filter sock, open hole logs, tubing/packer) in advance of spud, with all approvals granted by NDIC reviewers within 1–2 weeks of submission. Directional and anticollision work products (COMPASS, TAKTIKAL) are professional-grade and contemporaneous with permit cycle.
Casing waiver submitted 09-04-2025, approved same day; filter sock, open hole, tubing/packer waivers submitted 06-18-2025, approved 06-19-2025; anticollision report dated 24 May 2025 (26 days pre-spud); drilling commenced on schedule 09-19-2025 per spud notification; geological report and MWD surveys completed post-drilling in professional format (well summaries, sample descriptions, formation tops all archived); multi-well pad plan indicates staged development strategy with single operator control across Section 33 and extensions into Sections 21, 28.

Confidence: High
Well file contains complete permit approval chain: dated waiver applications (FORM IDs 254329, 254294, 254340, 268020) with clear approver names and effective dates; pre-spud anticollision and directional engineering (COMPASS, TAKTIKAL, dated May 2025); post-spud geological summary, MWD surveys, and cuttings logs (all dated September 2025); contemporaneous regulatory letters (core/sample mandate 06-23-2025). All signals are time-bound to permit window June–September 2025 or structurally persistent. No contradictions or missing critical dates in permit-cycle chain. Operator compliance profile consistent across all submissions.