🛢️ Smoky Butte 160-100-6 SWD 1

Hunt Oil Company · Divide County, North Dakota County, ND · File #File Number 42606 · Generated 2026-02-13 12:33

API: 3302301730
Target Formation: Dakota Group (Inya Kara Sandstone injection zone)
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit file contains contemporaneous documentation that fully explains and justifies the permit issuance. The Industrial Commission Order No. 35120 (December 22, 2025) provides explicit regulatory authorization conditioned on compliance with the injection permit and NDAC Chapter 43-02-05. The Well Fracture Analysis (December 31, 2025) establishes the technical basis for maximum injection pressure (1,326 psi) derived from formation geomechanics. Six UIC stipulations govern construction, environmental protection, and operational safety. The groundwater survey (September 15, 2025) demonstrates absence of shallow aquifer risk within the area of review. The Dike Variance Request and associated engineered controls package justifies the non-routine containment design by substituting automated monitoring and redundant safeguards for standard earthen dikes. Together, these materials establish the regulatory, technical, and operational framework that conditions the permit approval as of the January 1, 2026 dirt work date.

🔍 Permit Cycle Signals (5)

Industrial Commission Order No. 35120 issued December 22, 2025, authorizing Hunt Oil to dispose of Class II fluids into Dakota Group via SWD well. Order conditions approval on operator compliance with injection permit and NDAC Chapter 43-02-05.

Direct

📄 ORDER OF THE COMMISSION, Case No. 32365, Order No. 35120, dated December 22, 2025
📅 2025-12-22 (Exact confidence)

This is the explicit regulatory authorization that conditions all subsequent operations. The order anchors the permit approval and mandates compliance with the injection permit issued by the Oil and Gas Division.

Well Fracture Analysis by UIC Supervisor Jared Thune (dated December 31, 2025) establishes maximum allowable surface injection pressure of 1,326 psi, calculated from Dakota formation fracture gradient (0.67 psi/ft) and upper confining zone fracture pressure (3,680 psi). This engineering constraint directly conditions operational limits on the issued permit.

Supporting

📄 WELL FRACTURE ANALYSIS document, dated December 31, 2025, prepared by Jared Thune, UIC Supervisor
📅 2025-12-31 (Exact confidence)

Fracture pressure analysis is a mandatory technical prerequisite for UIC class II permits and is explicitly referenced in permit conditions. The calculated maximum injection pressure (1,326 psi) is a non-negotiable operational constraint tied to well design and formation geomechanics.

Six UIC-specific stipulations issued with permit (dated January 1, 2026 dirt work date) including: spud notification requirement, confidential status grant (6-month), rat/mouse hole construction and plugging standards, perimeter berm requirement, remote/automatic shutdown devices, and tank level sensor installation. These are operationally binding conditions of permit issuance.

Direct

📄 PERMIT INFORMATION / STIPULATIONS section, Application for Permit for New Well – Vertical Salt Water Disposal, dated January 1, 2026 (Dirt Work Date)
📅 2026-01-01 (Exact confidence)

Stipulations are explicit permit conditions that govern well construction, environmental controls, and operational safety. They restrict operational discretion and are enforceable regulatory requirements.

Groundwater search conducted by KLJ Engineering (dated September 15, 2025) identified one active groundwater well (Eberle Family Rev Trust, Site 16110033CC, stock well at 40 ft depth, 3,835 ft from proposed SWD location) and one well of unknown status (Rude property, 918 ft from SWD). Both are beyond critical distance thresholds; none within 1/4-mile. This demonstrates environmental baseline and supports area-of-review (AOR) determination.

Supporting

📄 Memorandum from Lexee Dirk, KLJ Engineering, dated September 15, 2025; Groundwater Search map and one-mile buffer analysis
📅 2025-09-15 (Exact confidence)

Pre-permit groundwater survey is standard UIC application requirement (NDAC 43-02-05-04). This confirms no shallow aquifer contamination risk within area of review, a key permit approval justification. It is directly referenced in the permit hearing notice.

Dike Variance Request submitted by Hunt Oil demonstrates redundant containment controls (1,592 bbl tank dike capacity + 77,471 bbl perimeter berm, with 159% containment of largest 1,000 bbl tank). Variance approved implicitly through permit issuance; facility design includes guided-wave radar monitoring, electronic level sensors, dual high/low alarms, pressure shutdown systems, and automated personnel notification. This engineering variance and control package conditions the permit.

Supporting

📄 NDIC Dike Variance Request document; Description of Proposed Injection Program section; Operational and Monitoring Controls subsection
📅 Unknown (Missing confidence)

Dike variance is a non-routine permit condition that substitutes engineered controls (automated monitoring, redundant shutdowns, synthetic liners) for full earthen dike. Its acceptance by NDIC (evidenced by permit issuance without objection) is a material condition of approval that justifies deviation from standard setback/dike rules.

📖 Historical Context (4)

Six source wells identified as future feedstock for the SWD facility: Alexandria 161-100-33-21H-2, Alexandria 161-100-33-21H-3, Alexandria 161-100-34-22H-1, Sioux Trail 160-101-1-13H-3, Smoky Butte 160-100-6-18H-1, and Smoky Butte 160-100-6-18H-2. All listed as 'Permitted/Not yet drilled.' Facility capacity is 300 bbls/day. No third-party disposal planned.
📄 Description of Proposed Injection Program section; SOURCE WELLS table · 📅 Unknown
This establishes the operational dependency structure of the SWD facility. Future drilling of these source wells must be coordinated with SWD operations. Any delay, abandonment, or modification to these wells affects injection volumes and facility utilization. The 'no third-party disposal' constraint limits operational flexibility and revenue potential, and creates exclusive reliance on Hunt Oil's own production within the pad.

Surface ownership limited to Robert & Shanna Rude (0.25-mile radius). Well location surface agreement executed. Divide County road approach permit issued September 25, 2025 (Permit #09/25/153) for new field access; 183-foot access road via 90th St NW with 24-inch CMP culvert.
📄 SURFACE OWNERSHIP AND MAP; AFFIDAVIT OF MAILING (dated September 30, 2025); Divide County Approach Permit dated October 5, 2025 · 📅 Unknown
Surface rights and access agreements are binding long-term constraints. The executed surface agreement with Rude secures location viability and protects against surface use disputes. The county road approach permit creates a permanent access obligation and cost responsibility (road maintenance invoiced at county rates—$130–$180/hour for equipment). Any future modifications to access or facility boundary require new permits and renewed coordination with Rude.

Environmental assessment program (standard Hunt procedure per testimony in Drilling Operations Plan) includes: Waters of the U.S. and wetland protection, stormwater pollution prevention, threatened & endangered species avoidance (USFWS coordination), federal/state land easement reviews, eagle/raptor/migratory bird habitat protection, floodplain assessment, historic landslide identification, and cultural resources evaluation. No surficial aquifer occurs within 4 miles; nearest is ~4 miles southeast.
📄 Environmental Assessment Process and Environmental Control Measures sections of the Drilling Operations Plan and injection program description · 📅 Unknown
Environmental compliance obligations persist throughout the life of the facility. The documented environmental baseline (no surficial aquifer within critical distance; no wetlands or endangered species identified on the site maps) creates a record against which future environmental claims or enforcement actions will be measured. The commitment to ongoing coordination with USFWS and implementation of emergency response drills establishes a persistent operational obligation. Any detection of listed species or habitat degradation triggers immediate shutdown requirements, creating operational risk.

Well design and completion specifications include: 7-inch 32# P-110 long-string casing with float collar at 5,263 MD; perforations in Inya Kara (4,650–5,108 MD) with nickel-coated retrievable packer set 25–50 feet above top perforation; 4.5-inch 11.60# J-55 IPC injection tubing with epoxy internal coating (P70, 10–20 mil); mechanical integrity test to 1,000 psi (NDIC-witnessed); acid stimulation planned; step-rate test 1–2 weeks post-completion.
📄 Smoky Butte 160-100-6 SWD 1 Completion Procedure (AFE document); Well design schematic; Tubular Program and Specs; Formation Information summary; Petrosmith Coating technical specification (P70 epoxy) · 📅 Unknown
The well design establishes the mechanical and geochemical parameters within which all future injections must operate. The retrievable packer design creates a maintenance requirement (packer must be retrievable for future well workover). The epoxy-coated tubing imposes corrosion-control obligations tied to fluid chemistry (specific gravity 1.18, high chloride content 202,000 mg/L in source fluid). The mechanical integrity test baseline (1,000 psi) becomes the reference point for future pressure decline or mechanical failure assessment. Acid stimulation and step-rate testing create a baseline injectivity profile that governs pressure management going forward.

🔧 Operator Pattern

Hunt Oil Company demonstrates systematic pre-development environmental and technical due diligence. The file shows documented coordination with external specialists (KLJ Engineering, Braun Intertec, Eurofins laboratory, directional drilling contractors), adherence to engineered controls exceeding minimum regulatory standards (redundant tank monitoring, automated alarms, pressure shutdown systems), and proactive stakeholder engagement (surface owner communication, county road coordination, USFWS notification).
Groundwater survey commissioned 60+ days pre-hearing (September 15, 2025); environmental assessment integrated into development package; water chemistry analysis (Braun Intertec, Eurofins) completed pre-permit; surface owner mailed notice via FedEx with proof-of-delivery (September 30, 2025); Divide County approach permit obtained before permit issuance; directional survey and anticollision analysis completed; dike variance submitted with detailed engineering drawings and pressure ratings; emergency response procedures documented with annual third-party training coordination.

Confidence: High
Permit approval date is unambiguous (December 22, 2025, Industrial Commission Order; January 1, 2026, dirt work date). All contemporaneous documents (fracture analysis, stipulations, groundwater survey, environmental assessments, surface agreements, completion procedures) are dated within 4 months of permit issuance and directly address permit prerequisites or conditions. No material dates are missing. The file contains complete regulatory chain: permit application → hearing (November 20, 2025) → commission order (December 22, 2025) → technical stipulations and fracture analysis (December 31, 2025) → permit conditions (January 1, 2026 effective). Historical context (source well identities, surface ownership, design specifications, environmental baseline) is clearly separated from permit-cycle signals and does not obscure the permit explanation. No contradictions detected between regulatory findings and supporting technical documentation.