File #42016 | Phoenix Operating LLC | Divide County
API
3302301633
Target Formation
Middle Bakken
Permit Explained
Yes
Permit Cycle Assessment
The permit approval dated 06/16/2025 is directly justified by four pre-approval waivers (06/18-06/19/2025, approved within 24-48 hours of permit date) that condition operational execution. The tubing/packer variance and open-hole log waiver specifically enable the well to proceed without standard completion and logging requirements by relying on offset well data and casing design assurances. The drill-cuttings sample waiver eliminates data collection burden by redirecting sampling obligation to the adjacent Gail Arnold 33-28-21 1H on the same pad. The anticollision report (05/24/2025) pre-dates permit approval and documents separation factor clearance (with Level 3 warnings acknowledged but not remediated). The 150/500-foot setback stipulation is conditioned on wet-shoe completion design, directly tied to the tubing/packer variance approved concurrently. All four waivers are internally consistent with a pad-drilling strategy that consolidates sample collection and leverages offset well control to reduce well-specific obligations. The permit approval is fully explained by these contemporaneous and preceding regulatory instruments.
Permit Cycle Signals (4)
Permit approved by NDIC with stipulated 150' setback (north/south) and 500' setback (east/west) within 1920-acre spacing unit, conditioned on production liner cemented in lateral with wet shoe and ability to frac out shoe. (2025-06-16)
Setback geometry is explicitly tied to completion design (wet shoe/frac-out capability). Non-routine because north setback is conditioned on specific completion method, indicating directional/spacing risk mitigation.
Four waivers approved pre-permit (dated 06/18-06/19/2025): (1) Filter sock container waiver for drilling phase only; (2) Drill cutting samples waiver for vertical section (samples to be collected from offset well Gail Arnold 33-28-21 1H); (3) Open hole log waiver (justified by offset well MOE TRUST 33-28-160-98H 1BP within 1 mile, with GR-CBL planned); (4) Tubing/packer variance with specified safety factor and casing design assurances. (2025-06-18)
Waivers directly condition permit execution: samples waiver eliminates vertical data collection in this well (relies on pad offset); log waiver eliminates open hole logging requirement based on offset well control. Tubing/packer variance explicitly justifies flowback without tubing/packer.
Anticollision report dated 05/24/2025 evaluated minimum separation factors against 9 offset wellbores (including MOE TRUST 33-28-160-98H 1BP and W NYSTUEN 159-98-15-9-4-2H3). Report flagged Level 3 warning levels on multiple well comparisons but did not trigger design modification; closest center-to-center separation 1.393 usft (separation factor threshold warning). (2025-05-24)
Anticollision clearance is pre-approval finding that conditions permit issuance. Level 3 warnings on separation factors indicate lateral trajectory carries collision risk but was approved as designed without modification.
State Geologist letter (dated 06/23/2025) mandates core/sample preservation and submission within regulatory timeframes: samples at 30' intervals (vertical/build) and 200' intervals (lateral), boxed within 30 days of drilling completion; cores within 180 days. Operator must collect samples from Base of Last Charles Salt downward. (2025-06-23)
Regulatory mandate dated after permit approval (06/16) but prior to spud (09/29). Establishes enforceable sample collection and submission obligations. Cross-references approved waiver for vertical section samples (which exempts this well from collecting its own vertical samples).
Historical Non-Routine Signals (3)
Well is part of five-well pad (Gail Arnold 33-28-21 1H, 2H, 3H, 4H, 5H-LL) with shared sample collection obligation redirected to well 1H; offset well MOE TRUST 33-28-160-98H 1BP within 1 mile provides open-hole log data and formation top calibration; directional data integration across pad demonstrates coordinated spacing-unit design. (N/A)
Multi-well pad obligation persists through drilling and completion phases. Sample submission deadline (30 days post-drilling completion per State Geologist letter) applies to Gail Arnold 33-28-21 1H on behalf of the 3H. Offset well formation top control (Mission Canyon at 8,257' TVD, Lodgepole at 8,908' TVD per actual drilling report) becomes baseline for 3H geosteering and completion placement decisions. Anticollision level 3 warnings on multiple offsets constrain future re-entry or workover operations.
Tubing/packer variance approved with operational constraints: maximum pressure limited to 85% API burst rating (11,220 psi burst × 0.85 = 9,537 psi operational ceiling); 300# gauge required on surface casing during flowback; casing exposure to completion-phase pressures is design-limiting factor. (N/A)
Pressure management protocol persists through completion and flowback operations. 300# gauge monitoring requirement is ongoing operational constraint. Damage-detection monitoring during completion operations and post-completion equipment installation 'as soon as possible' are non-discretionary post-drilling obligations tied to casing integrity assurance.
Bakken-specific drilling restrictions per permit language: any changes to casing point, Total Depth lengthening, or completion technique modifications within Bakken-Three Forks Petroleum System require prior NDIC approval (per operator assertions, permit page 9). Operator acknowledged in permit approval that changes are not discretionary. (N/A)
Change-control protocol is binding through well completion and production phases. Any deviation in lateral landing depth (currently planned 9,455' TVD, 38 feet into Middle Bakken per drilling report) or completion interval extent (currently 9,855–25,313' MD per permit) requires regulator pre-approval. Geosteering-driven depth adjustments made during drilling (landing target adjusted from 9,444' to 9,448' TVD) were within executed drilling plan; future modifications would require waiver.
Historical Operator Profile
Total Wells:N/A
Active Wells:N/A
Notable Patterns:None identified
Confidence Assessment
Level: High Rationale: Well file contains complete permit chain: (1) permit application submitted 06/03/2025, approved 06/16/2025 by NDIC Petroleum Engineer; (2) four waivers submitted 06/18/2025 and approved 06/18-06/19/2025 by State Geologist and NDIC technical staff; (3) anticollision report dated 05/24/2025 predates permit; (4) State Geologist mandate letter dated 06/23/2025 post-dates permit but within pre-spud window (spud 09/29/2025). All dates are exact and documentable. Drilling report (10/22/2025 TD) confirms execution within planned design. Setback stipulation is non-routine and explicitly tied to completion design (wet shoe). Waivers are substantive and condition permit execution (not routine APD boilerplate). No conflicting or missing documentation detected. Well file is internally consistent: anticollision warnings acknowledged, offset well data cross-referenced in waivers and drilling operations, tubing/packer variance directly enabled by permit approval sequence.