🛢️ Willow Gray 2-11-14-23 5H

Phoenix Operating LLC · Divide County, North Dakota County, ND · File #42043 · Generated 2026-02-13 12:33

API: 3302301640
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The well file contains substantial contemporaneous documentation explaining the permit approval (dated 05/15/2025, effective 05/15/2025). The primary permit-cycle signals are: (1) Pool definition and setback stipulation (Commission Order 33781) establishing structural constraints on lateral placement and wellbore isolation distance from boundaries, with south setback conditioned on wet shoe design; (2) Tubing/packer waiver (06/24/2025) pre-approving alternative completion methodology based on casing strength and monitoring assurances, indicating non-standard flowback procedures; (3) Filter media and open hole log waivers (06/24–25/2025) documenting drilling fluid system (OBM, no filtration) and logging offset-well strategy. Drill cutting sample waiver (06/24/2025, Form 255444) permits sampling from offset vertical section rather than this well's vertical portion. These three operational waivers collectively document a routine Bakken pad development within established field orders, with non-routine completion design (production liner with wet shoe, tubing/packer waiver) requiring pre-approval. The geological summary confirms drilling stayed 100% in zone (Middle Bakken C and D facies), tracking the C/D contact as planned via Starsteer software with 8-foot target window, supporting the regulatory basis for setback compliance. No contemporaneous permitting issue, environmental constraint, or engineering waiver appears to have been unresolved at spud or TD. The well is currently waiting for completion operations.

🔍 Permit Cycle Signals (5)

Setback Compliance Stipulation — 150' north/south, 500' east/west boundaries within 2560-acre spacing unit (Sections 2, 11, 14, 23, T159N, R98W). South setback premised on production liner cemented in lateral with wet shoe and ability to frac out shoe.

Direct

📄 Permit Form (Page 1 of 10) — STIPULATIONS section
📅 2025-05-15 (Exact confidence)

Directly conditions permit approval on specific wellbore geometry constraint tied to casing design and completion mechanics. South setback depends on wet shoe assumption—a non-routine engineering condition.

Commission Order No. 33781 — Pool definition for Big Stone-Bakken Pool: 50 feet above Bakken top to 50 feet below Three Forks top. Well required to remain within this interval.

Direct

📄 Permit Form (Page 1 of 10) — STIPULATIONS / NDIC Field Order Info
📅 Unknown (Missing confidence)

Regulatory pool definition establishes vertical drilling target window. Directly explains why geological summary confirms 100% drilling in zone; constrains completion and production risk assessment.

Tubing/Packer Waiver (Form ID 255494) — Operator requested variance to NDAC 43-02-03-21 regarding tubing/packer requirement. Approved 06/24/2025. Operator provided engineering assurances: (1) new 29# and 32# surface casing with 11,220 psi API burst; (2) safety factor 0.85 on API burst for completion pressures; (3) casing damage detection via monitoring; (4) low corrosion/erosion from completion and formation fluids; (5) 300# gauge on surface casing during flowback; (6) early production equipment installation.

Direct

📄 Sundry Form 255494 (Tubing/Packer Waiver) — Approved 06/24/2025, Effective 06/24/2025
📅 2025-06-24 (Exact confidence)

Non-routine waiver of production tubing/packer requirement directly tied to permit approval. Waiver conditioned on specific casing design and completion fluid properties. Flowback period (between drilling completion and production tie-in) identified as operational risk window requiring pressure monitoring. Indicates well will remain in flowback state during early post-TD phase.

Filter Sock Container Waiver (Form ID 255470) — Operator requested exemption from NDAC 43-02-03-19.2 requirement to maintain filter media container. Approved 06/25/2025. Basis: operator does not use filter media during drilling.

Supporting

📄 Sundry Form 255470 (Filter Sock Container Waiver) — Approved 06/25/2025, Effective 06/25/2025
📅 2025-06-25 (Exact confidence)

Operational waiver indicating use of oil-based mud (OBM) system without filtration. Consistent with permit boilerplate requirement for closed mud system. Waiver drilling phase only; does not extend to completion or flowback phases.

Open Hole Log Waiver (Form ID 255343) — Operator requested waiver of open hole log requirement (NDIC Rule 43-02-03-31). Approved 06/24/2025. Basis: offsetting well (Willow Gray 2-11-14-23 3H) within 1 mile will have open logs; formation tops established by offset; GR-CBL (gamma ray/cement bond log) to be run from TD to surface.

Supporting

📄 Sundry Form 255343 (Open Hole Log Waiver) — Approved 06/24/2025, Effective 06/24/2025
📅 2025-06-24 (Exact confidence)

Geological characterization waiver justified by offset well proximity and supplemental GR-CBL coverage. Reduces pre-completion logging burden but preserves cement integrity verification via casing-mounted log. Drilling-phase signal with post-drilling verification requirement.

📖 Historical Context (4)

Six-well pad development on 2560-acre spacing unit (Sections 2, 11, 14, 23, T159N–160N, R98W). Willow Gray 2-11-14-23 5H is the fifth well on Woods-Willow Gray pad. Pre-existing wells on pad: Willow Gray 2-11-14-23 1H-LL, 2H, 3H, 4H; Woods 35-26-23 1H-LL, 2H, 3H, 4H, 5H (all on surface location SE SW Sec. 35, T160N, R98W). Off-spacing wells (Woods 35-26-23 series) require backbuild notification per Orders 31973 and 31848.
📄 Affidavit of Surface Damage Agreement (dated 05/13/2025); Permit directional plan; Backbuild waiver letter dated 05/15/2025. · 📅 Unknown
Multi-well pad configuration and off-spacing drilling (Woods wells bottom-hole location in SESE Sec. 23, T159N, R98W, outside the T160N, R98W spacing unit) creates permanent inter-well interference and cumulative completion/production risk profile. Off-spacing wells require ongoing regulatory notification if operations impact the on-spacing unit. Backbuild waiver (Phoenix Energy as operator of adjacent spacing unit) establishes operator obligations regarding directional communication and compliance monitoring. Well geometry and lateral positions on shared pad remain constraints on future workover, sidetrack, or abandonment operations.

Wet shoe completion design with ability to frac out toe (Form ID 255494 Tubing/Packer Waiver). Casing: 9 5/8" surface @ 2,099.4'; 7" intermediate @ 10,101.76'; 6" production liner @ 30,844' MD (lateral shoe). Surface casing API burst 11,220 psi; completion safety factor 0.85. Flowback period identified as operational risk requiring 300# pressure gauge on surface casing and immediate production equipment installation post-flowback.
📄 Tubing/Packer Waiver (Form 255494); Well schematic dated 03/24/2025; Geological summary (TD 10/06/2025). · 📅 Unknown
Wet shoe design (ability to frac out toe plug after liner set) is non-standard for vertical casing but operationally accepted for horizontal laterals. Once production liner is cemented and shoe fractured, well depends on formation permeability near horizontal section for initial productivity. Casing design and safety factor directly impact maximum allowable injection/production pressures and inform future completion re-entry, stimulation design, and abandonment procedures. Flowback period (post-TD to first production tie-in) remains a pressure-control critical phase. Well pressure history, casing condition assessment, and monitoring logs from flowback are prerequisites for long-term production operations or future interventions.

Oil-based mud (OBM) system for vertical and curve sections; brine for lateral (Mud Record, 09/27–10/05/2025). Mud weight 10.0–10.2 lb/gal; oil/water ratio 0 to 69/31 (OBM predominant in curve/lateral). Filter media waiver granted (drilling phase only) because no filtration used. No cuttings pit; closed mud system required by permit.
📄 Mud Record (drilling fluid log, 09/27–10/05/2025); Filter Sock Container Waiver (Form 255470, approved 06/25/2025); Permit boilerplate (Closed mud system with no cuttings pit). · 📅 Unknown
OBM/brine system and closed mud design establish baseline waste disposal and environmental compliance obligations. Recovered drill solids and mud returns must be managed per NDAC 43-02-03-19.2 (waste disposal in authorized facilities). Closed system constrains surface facility configuration and re-entry procedures (well must remain isolated until production equipment installed). Fluorescence data in cuttings descriptions (bright yellow fluorescence from 14,200' MD onward) indicates oil-charged formation; OBM system appropriate for seepage management but creates baseline contamination baseline for any future openhole interventions. Abandonment plugging design must account for OBM residue in vertical and curve sections.

Directional survey data (MWD surveys, SHL 410' FSL & 2277' FWL Sec. 35 to BHL 190' FSL & 1056' FEL Sec. 23) shows wellbore trajectory compliance with 150'/500' setback stipulation. Final TVD 9,808.7'; vertical section drop 89.1° (within 89°–90° horizontal range). Lateral length 21,441.85' (vertical section). Formation landing Middle Bakken C/D contact between 9,497'–9,809' TVD; well remained in zone throughout lateral (100% compliance per geological summary).
📄 MWD Surveys (344 survey stations from spud to PTB 30,844' MD); Geological Summary (landing target 9,486' TVD, adjusted to 9,497' TVD based on Lodgepole markers); Planning Report (Taktikal Directional, 03/24/2025). · 📅 Unknown
Achieved wellbore geometry establishes baseline for setback compliance verification and inter-well spacing justification. Actual survey data and formation top picks are permanent records required for any future offset well drilling, spacing unit re-evaluation, or regulatory audit. Lateral azimuth and inclination (approaching 90° in lower lateral) may impact proppant placement, production performance, and future re-entry sidetrack options. Formation landing in C facies (not B or D) defines the reserve base and guides stimulation design and production forecasting. Survey accuracy (Dogleg Severity values, positional uncertainty) affects confidence in setback compliance and future drilling risk assessments.

🔧 Operator Pattern

Phoenix Operating LLC operates multi-well horizontal pads in Divide/Williams County, North Dakota Bakken field, with coordinated off-spacing drilling strategy using shared surface locations. Operator routinely files pre-drill waivers for operational standardization (tubing/packer, filtration, logging), supported by engineering analysis and offset-well data. Regulatory compliance is proactive: backbuild notification, surface use agreements, directional planning documentation submitted well in advance of spud. Typical pad configuration: 6–10 horizontal wells per surface location, Bakken/Three Forks targeting, wet-shoe liner completions, OBM drilling systems.
Willow Gray 2-11-14-23 pad hosts 6 planned wells (four on-spacing Willow Gray wells + two Woods off-spacing wells from this location); Woods 35-26-23 off-spacing wells require backbuild notification (Letter 05/15/2025); pre-spud waiver suite filed 06/24–25/2025 (tubing/packer, filtration, logging); directional plan finalized 03/24/2025; surface use agreement affidavit 05/13/2025; all standard Bakken completion design (wet shoe, OBM, closed mud, 11,220 psi casing burst). No post-spud modifications, emergency waivers, or compliance violations noted in file.

Confidence: High
Complete well file with spud (08/05/2025) and TD (10/06/2025) documentation, comprehensive permit stipulations and pre-spud waivers (all dated and approved), detailed drilling records (MWD surveys 344 stations, cuttings descriptions, mud logs, bit record), and geological summary confirming 100% zone compliance. Regulatory approvals are explicit and time-stamped (Filter waiver 06/25/2025, Tubing/Packer waiver 06/24/2025, Open Hole Log waiver 06/24/2025, Drill Cutting Sample waiver 06/24/2025). Permit approval anchored to 05/15/2025 with clear stipulation basis (Order 33781, setback/pool definitions). No ambiguity in permit-cycle signals: setback geometry, completion design waiver, and operational waivers all directly pre-condition approval. Historical context is robust: six-well pad development, off-spacing strategy, standard Bakken completion methodology, and continuous regulatory documentation. Only minor gap: Commission Order No. 33781 date not stated in permit, but order number and pool definition are explicit.