🛢️ Gail Arnold 33-28-21 2H

Phoenix Operating LLC · Divide County County, ND · File #42015 · Generated 2026-02-13 12:33

API: 33-023-01632
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The well file contains contemporaneous documentation that directly explains and justifies the permit action. Five regulatory stipulations and waivers, all approved or effective between 06-18-2025 and 06-19-2025 (prior to spud 09-29-2025), establish the operational and technical conditions under which the permit was granted. These include: (1) filter sock container waiver eliminating a drilling-phase requirement based on operational practice; (2) drill cutting samples waiver reducing vertical section sampling obligations while redirecting to offset well; (3) open hole log waiver justified by adequate offset well formation top control; (4) tubing/packer variance with explicit technical safety assurances; and (5) Commission Order–based setback and pool definition stipulations. The directionality plan, anticollision study, and formation tops data in the geological summary all align with the setback and spacing unit requirements established in the permit stipulations. The well was spud on 09-29-2025 and completed on 11-04-2025 in compliance with all documented conditions. The permit cycle is fully documented.

🔍 Permit Cycle Signals (5)

Filter Sock Container Waiver (NDAC 43-02-03-19.2) - Operator does not use filter media during drilling and requested exemption from maintaining container requirement.

Direct

📄 Well Sundry Form 254330, Page 2
📅 06-19-2025 (Exact confidence)

Waiver directly conditions drilling phase operations; approved effective 06-19-2025, prior to spud on 09-29-2025.

Drill Cutting Samples Waiver (NDAC 43-02-03-38.1) - Operator waived collection of 30-foot samples in vertical section from Base of Last Salt to planned KOP; samples to be collected from offset well Gail Arnold 33-28-21 1H on same pad. Collection resumes in curve and lateral.

Direct

📄 Well Sundry Form 254319, Page 2
📅 06-19-2025 (Exact confidence)

Waiver materially reduces sampling obligation but establishes offset well offset sampling requirement; directly conditions drilling operations.

Open Hole Log Waiver (NDIC Rule 43-02-03-31) - Operator waived open hole logs, citing sufficient formation top control from offset well MOE TRUST 33-28-160-98H 1BP (File #23601) within 1 mile. Only GR-CBL to be run from TD to ground level.

Direct

📄 Well Sundry Form 254296, Page 2
📅 06-19-2025 (Exact confidence)

Waiver explicitly justified by offset well data adequacy; structures logging phase and reduces technical requirements.

Tubing/Packer Variance (NDAC 43-02-03-21) - Operator requested variance to omit tubing and packer, providing technical assurances on casing integrity, safety factor (0.85 API burst rating), pressure monitoring, corrosion/erosion rates, and 300# gauge installation during flowback. Approved 06-18-2025.

Direct

📄 Well Sundry Form 254341, Pages 1–2
📅 06-18-2025 (Exact confidence)

Variance directly conditions completion design and post-drilling operations; conditions safety requirements and operational protocol during flowback phase starting ~01-02-2026.

Setback Stipulation and Bakken Pool Definition - Permit grants approval under Commission Order No. 34436 with condition that all non-cemented wellbore portions maintain 150-foot setback from north/south boundaries and 1,220-foot setback from east/west boundaries within 1,920-acre spacing unit (Sections 21, 28, 33). North setback based on production liner with wet shoe and frac-out capability.

Direct

📄 Application for Permit for New Well – Horizontal, Page 1 (Stipulations section)
📅 09-01-2025 (Inferred confidence)

Stipulation directly justifies well geometry and trajectory design; defines spacing unit and establishes lateral cement/isolation requirements that condition drilling operations.

📖 Historical Context (4)

Five-well pad configuration (Gail Arnold 33-28-21 1H through 5H-LL plus SWD) - Well file documents five additional wells on the same pad, all targeting Middle Bakken and entering adjacent spacing units. Anticollision study demonstrates well separation factors >1.7 from nearest offset (MOE TRUST 33-28-160-98H 1BP).
📄 Anticollision Report, Summary section; Well Location Plat; Directional planning report · 📅 Unknown
Establishes long-term operational constraint: all five wells on pad share infrastructure, sampling, and access; any abandonment, workovers, or interventions on 33-28-21 2H may be coordinated with pad operations. Anticollision clearances must be maintained if offset wells are later developed or re-entered.

Production liner with wet shoe and frac-out capability - Intermediate casing (7-inch) set at 9,797.7' MD; completion design includes wet shoe sub with ability to frac out toe. Design documented in permit stipulation and casing diagram.
📄 Permit Stipulations (Bakken Setback Summary); Casing Design Schematic · 📅 Unknown
Commits operator to specific completion methodology; affects future production string design, perforation placement, and flowback operations. Wet shoe design must be validated during completion operations scheduled ~01-02-2026.

Offset well data dependency for formation control - Operator's logging waiver explicitly relies on MOE TRUST 33-28-160-98H 1BP (File #23601) for formation top control. No open hole logs run on 33-28-21 2H itself; only GR-CBL.
📄 Well Sundry Form 254296; Geological Summary · 📅 Unknown
Creates forward dependency: any reinterpretation of formation tops in offset well or any change in offset well status/availability could necessitate re-evaluation of 33-28-21 2H formation identification and landing target accuracy. GR-CBL data alone insufficient for independent formation correlation.

Bakken Pool definition within 1,920-acre spacing unit - Commission Order defines Bakken accumulation as interval 50 feet above top of Bakken Formation to 100 feet below top of Three Forks Formation. Pool extends across Sections 21, 28, 33 (T160N R98W).
📄 Permit Stipulations (NDIC Field Order Info) · 📅 Unknown
Establishes regulatory pool boundaries affecting future drilling rights, offset well spacing, and unitization. Operator's obligations to offset operators in adjacent spacing units remain conditional on production within defined pool interval.

🔧 Operator Pattern

Phoenix Operating LLC demonstrates compliance with waiver submission and technical justification protocols. All three waivers (filter sock, drill cuttings, open hole logs) were requested pre-spud and approved within 1–2 days. Operator provided specific technical rationales tied to pad strategy (reliance on offset well sampling/logging) and operational practice (no filter media use). Tubing/packer variance submitted with detailed safety engineering (casing burst rating calculations, pressure monitoring protocol). No evidence of regulatory violations or non-compliance in file.
Sundry notices filed 06-18-2025; all approved 06-18–06-19-2025. Well spud 09-29-2025 and drilled to TD 11-04-2025 within 6.92 days, achieving 100% stratigraphic placement in Middle Bakken C/D facies. Geosteering executed with real-time gamma ray correlation and StarSteer software; MWD tool malfunction noted after 24,840' MD but did not impede TD achievement. Well constructed per permit stipulations (landing target 9,441' TVD achieved at 9,438.23' TVD; intermediate casing set 9,797.7' MD as required).

Confidence: High
Well file contains complete and internally consistent permit documentation, regulatory approvals, technical submissions (directional plan, anticollision study, formation tops, mud/casing records, MWD surveys), and post-drilling geological summary. All dates are explicitly stated or clearly inferred from document headers and review stamps. No material gaps in permit-cycle chain of custody from approval (06-18–06-19-2025) through spud (09-29-2025) and TD (11-04-2025). Waivers and stipulations directly tied to observed well design and execution. File marked CONFIDENTIAL but content was public prior to confidential designation per file header. Only minor OCR artifacts (scattered character/word distortions in drilling summary text) do not affect regulatory signal extraction.