🛢️ BILLINGSLEY 1-12-13 1H (renamed HERCULES 1-12-13 1H)

Phoenix Operating LLC · Burke County, ND · File #42556 · Generated 2026-02-13 12:33

API: 3301302004
Target Formation: Middle Bakken
Permit Explained: Partially

📋 Permit Cycle Assessment

The well file contains contemporaneous documentation that partially explains the permit approval for BILLINGSLEY 1-12-13 1H, but significant gaps remain. Four waivers/variances submitted 12/15/2025 and approved 12/16–12/24/2025 are directly conditioned on operator submissions: (1) tubing/packer variance justified by specific casing specs and completion design safety factors; (2) filter sock container waiver based on operator affirmation of no filtration use; (3) vertical-section drill cutting samples waiver supported by offset well (3H) sampling plan; (4) open hole log waiver justified by offset well (BRUSVEN 32-1) proximity. All four waivers received geologist or engineer approval. Additionally, an abandoned gas pipeline traversing the pad location was identified by regulator Doug Jackson on 12/9/2025 and mitigated via operator–operator coordination (Phoenix Operating with Steel Reef) confirmed 12/11/2025, with commitment to best-effort locatability and construction-phase precautions. The permit approval date is not explicitly stated in the file; the newest dated documents are the 12/29/2025 cores and samples letter and 12/24/2025 well name change approval. No explicit permit issuance letter with approval date is included in the file. The drilling plan, casing program, and field order information stipulations (setback, pool definition, closed mud system, remote shutoff devices, perimeter berm, spacing unit justification) are routine APD boilerplate and do not differentiate this permit from standard horizontal wells; thus they are not elevated in permit-cycle signals per suppression rules. The file does not explain why the permit was issued on a specific date—only that waivers were approved in the 12 days preceding the 12/24/2025 well-name-change effective date. A standalone permit approval order is absent.

🔍 Permit Cycle Signals (5)

Tubing/Packer Variance (NDAC 43-02-03-21) approved with technical justifications tied to completion design safety factor and casing integrity

Direct

📄 Sundry Form 288097 (Tubing/Packer Waiver) and Proposed Drilling Plan
📅 12/15/2025 (received); 12/16/2025 (approved) (Exact confidence)

Non-routine variance conditioning completion operations. Operator provided six specific engineering assurances: new #29 and 32# casing with 11,220 psi API burst rating, 0.85 API safety factor, immediate damage detection capability, lower pressure exposure during flowback vs. completion, low corrosion/erosion rates, rapid production equipment installation, and 300# gauge installation during flowback. Directly restricts completion methodology.

Filter Sock Container Waiver (NDAC 43-02-03-19.2) approved on basis that operator does not use filter media during drilling

Supporting

📄 Sundry Form 288072 (Filter Sock Container Waiver)
📅 12/15/2025 (received); 12/24/2025 (approved) (Exact confidence)

Operator affirmatively represents no filtration system is deployed. Waiver explicitly limited to drilling phase only. Typical APD boilerplate would require container; this waiver removes that obligation based on operator assertion of non-use.

Drill Cutting Samples Waiver (vertical section only) approved with offsetting sample collection from BILLINGSLEY 1-12-13 3H on same pad

Supporting

📄 Sundry Form 288096 (Drill Cutting Samples Waiver)
📅 12/15/2025 (received); 12/16/2025 (approved) (Exact confidence)

Geologist-approved (Ross Edison) variance to sample collection requirements (NDAC 43-02-03-38.1). Operator requested waiver from Base of Last Salt to planned curve kickoff point in vertical section, with condition that 30-foot samples collected from offset well (3H) on same pad satisfy regulatory sampling objective for formation characterization.

Open Hole Log Waiver approved based on proximity to offset well BRUSVEN 32-1 with sufficient open hole logs and commitment to GR-CBL from TD to ground level

Direct

📄 Sundry Form 288109 (Open Hole Log Waiver)
📅 12/15/2025 (received); 12/15/2025 (approved) (Exact confidence)

Geologist-approved (Ross Edison) waiver to NDIC Rule 43-02-03-31. Offset well BRUSVEN 32-1 (File #12101) within one mile provides sufficient open hole log data to establish formation tops. Partial mitigation through GR-CBL commitment. Non-routine geometry justification.

Abandoned gas pipeline mitigation coordination required due to poly line traversing pad location; line purged, cut, and capped; locatability uncertain; Phoenix committed to best-effort location and coordination with Steel Reef during construction

Direct

📄 Email correspondence dated 12/11/2025 from Tori Siemieniewski (Phoenix Energy) to Doug Jackson (NDIC), and prior inquiry from Jackson dated 12/9/2025; Pad layout plat showing pipeline location
📅 12/09/2025 to 12/11/2025 (Exact confidence)

Infrastructure risk identified during permit review. Regulator (Doug Jackson, Engineering Technician) flagged abandoned gas pipeline running through pad; plat shows approximately 9 feet of cut on south side where pipeline located. Operator response (Phoenix Energy, via Tori Siemieniewski) confirmed pipeline purged, cut, capped on both ends; poly construction renders it unlocatable via standard methods. Operator committed to making all possible attempts to locate during construction and coordinating precautions with Steel Reef (pipeline agent). May result in removal during construction depending on depth. This exchange precedes final permit approval and indicates conditional approval pending mitigation during construction phase.

📖 Historical Context (6)

1920-acre spacing unit justification conditional: well must be drilled with another well complying with 1220-foot setback
📄 APD Stipulations section (Commission Order No. 33922) · 📅 05/01/2025 (Dirt Work Date on APD)
Spacing unit approval is contingent on multi-well pad development. If the companion well (1220-foot setback) is not drilled or is abandoned, this well's spacing unit approval may be jeopardized. Operator must maintain compliance through drilling of both wells or seek reconsideration.

Production liner cemented in lateral with wet shoe and ability to frac out toe; south setback (150 feet) justified by this completion design
📄 APD Stipulations, Casing/Cement category and Proposed Drilling Plan (Section 5) · 📅 05/01/2025 (Dirt Work Date); confirmed in drilling plan
Completion design is locked into permit stipulations. Any deviation from wet shoe design, frac-out shoe capability, or lateral cement placement will require amendment. This constrains future operational flexibility and must be maintained through completion.

Cores and samples requirement: all cores and cuttings from Base of Last Charles Salt onward must be submitted to ND Geological Survey within 30 days (samples) to 180 days (cores)
📄 Letter from Ross Edison (Geologist), dated 12/29/2025, referencing NDCC § 38-08-04 and NDAC § 43-02-03-38.1 · 📅 12/29/2025
Statutory obligation persisting beyond drilling. Operator bears civil penalty liability up to $12,500 per day of violation. Samples must meet format and depth interval specifications (30° max vertical, 200° max lateral). Core library shipment address and timing are binding.

Closed mud system with cuttings disposal via licensed facility (Smoky Butte Environmental LLC, Fortuna, ND)
📄 Proposed Drilling Plan, Section 4 · 📅 05/01/2025 (Dirt Work Date on APD)
Environmental compliance obligation. All cuttings collected in metal containers and hauled to specific licensed facility. Changes in disposal vendor require NDIC notice/approval and regulatory compliance with solid waste permits (ND Dept. of Environmental Quality, Division of Waste Management).

No diesel-based compounds in hydraulic stimulation; specific CAS Registry Numbers prohibited (68334-30-5, 68476-34-6, 68476-30-2, 68476-31-3, 8008-20-6)
📄 Proposed Drilling Plan, Section 5 · 📅 05/01/2025 (Dirt Work Date on APD)
Stimulation design constraint. Operator must source frac fluids from approved additives list excluding diesel-based products. Non-compliance creates permitting violation and potential enforcement exposure.

Operator profile: Phoenix Operating LLC has deployed multiple wells on Billingsley Pad (1H, 2TFH, 3H, 5H, 7H) in coordinated multi-well development with shared infrastructure
📄 Pad layout plats, well proximity maps, directional plans, and construction coordination emails · 📅 Spanning 05/01/2025 (Dirt Work) to 12/11/2025 (infrastructure coordination)
Operational efficiency and risk-sharing structure. Multi-well pad reduces surface footprint and environmental impact but requires coordinated completion scheduling, shared facilities (containment, flare, injection lines), and inter-well spacing compliance. Any delay or abandonment of companion wells affects justification of 1920-acre spacing unit.

🔧 Operator Pattern

Phoenix Operating LLC (and related entity Phoenix Energy) operates multi-well horizontal pad development in Bakken Formation with emphasis on environmental stewardship, regulatory coordination, and infrastructure risk mitigation.
File contains: (1) proactive backbuild order notification (11/13/2025 letter to Todd Holweger) disclosing that wells enter target spacing unit outside adjacent unit, with offer to provide detailed trajectory and contact info; (2) responsive infrastructure coordination with Steel Reef pipeline operator (12/11/2025) regarding abandoned gas line purging, cutting, capping, and best-effort locatability; (3) waiver submissions supported by technical justifications (tubing/packer safety factors, casing ratings, completion design rationale); (4) offset-well integration strategy (Billingsley 3H samples waiver referencing pad-mate drilling); (5) commitment to core and sample submission within statutory deadlines; (6) closed mud system deployment with pre-identified licensed disposal facility. Operator demonstrates regulatory engagement (Meaghan Coughlan, Regulatory Specialist; Tori Siemieniewski, Bakken Regulatory Director) and third-party coordination (Steel Reef, Mike Pirie). No enforcement history evident in file.

Confidence: Medium
Permit approval date is not explicitly stated in the file. The most recent dated documents are the 12/29/2025 cores and samples letter and the 12/24/2025 well-name-change effective date; no standalone permit issuance letter is present. The APD lists a Dirt Work Date of 05/01/2025 but does not include an explicit Permit Approval Date. Waivers were received and approved in the 12 days prior to 12/24/2025, suggesting the permit may have been approved on or near 12/24/2025, but this is inferred, not stated. The file contains comprehensive technical and regulatory justifications for non-routine waivers and infrastructure mitigation, but the temporal anchor of the permit approval itself is ambiguous. Infrastructure coordination regarding the abandoned pipeline was completed 12/11/2025, which predates the inferred approval date and is consistent with permit-cycle timing. Historical context is well-documented and confidence in ongoing constraints is high. Overall confidence in permit-cycle intelligence is medium because the permit anchor date is missing and the primary justification documents (waivers, drilling plan, field order) predate the likely approval window by weeks or months.