← Back to Daily Permits
🛢️ MARY 25-36-1-12 2H
Phoenix Operating LLC · McKenzie County, ND · File #42617 · Generated 2026-02-13 12:33
- API
- 3305310755
- Target Formation
- Middle Bakken
- Permit Explained
- Yes
📋 Permit Cycle Assessment
The permit approval (effective 02/01/2026) is contemporaneously explained by five convergent regulatory signals: (1) Commission Order 34508 establishing spacing unit geometry and setback requirements, (2) open hole log waiver (01/09/2026) justified by offsetting well data, (3) mandatory cores and samples collection regime (01/12/2026) conditioning drilling operations, (4) anti-collision study demonstrating separation compliance with four offset wells, and (5) surface geology clearance confirming no landslide risk at the proposed location. These signals collectively establish both the regulatory framework (spacing, setbacks, pool definition) and the site-specific operational constraints (logging waiver, core collection, anti-collision steering) that condition this horizontal drilling permit. The permit documentation contains no gaps or unexplained approvals; all major decisions are anchored to dated regulatory orders or technical submissions contemporaneous with the permit cycle.
🔍 Permit Cycle Signals (5)
📄 Sundry Form (File 292049), p. 1-2; signed by Ross Edison (Geologist)
📅 01/09/2026 (Exact confidence)
Waiver conditions the drilling program. Operator cites offsetting well (MARY 25-36-1-12 — File #8167) with sufficient open hole logs within one mile to establish formation tops, and commits to running GR-CBL from TD to ground level. This is a non-routine waiver directly justifying the permit approval.
📄 Cores and Samples Letter, signed by Ross Edison with Mark F. Bohrer, Nathan D. Anderson, Edward C. Murphy (State officials)
📅 01/12/2026 (Exact confidence)
Regulatory mandate conditioning drilling execution. Operator must collect sample cuttings no lower than Base of Last Charles Salt at specified intervals (30' max vertical/build, 200' max horizontal), deliver to State within 30 days. Cores to State within 180 days. Non-compliance incurs civil penalty up to $12,500 per day. This is a direct condition on the drilling permit.
📄 APPLICATION FOR PERMIT FOR NEW WELL — HORIZONTAL, STIPULATIONS section
📅 02/01/2026 (Inferred confidence)
Permit explicitly references Commission Order No. 34508, which establishes a 2,560-acre spacing unit (Sections 25 & 36, T147N R99W, plus Sections 1 & 12, T146N R99W) and specifies setback geometry: 150' from north/south boundaries, 1,220' from east/west boundaries. Pool definition runs from 100 ft above Bakken top to above Birdbear top. These are structural conditions tied to non-routine lateral geometry and multi-well pad configuration.
📄 Phoenix letter to Todd Holweger; Anticollision Report section with Separation Factor Plot and Closest Approach analysis
📅 01/05/2026 (Exact confidence)
Anti-collision analysis demonstrates compliance with regulatory risk mitigation for four existing offset wells (Twin Tanks 36-32 File #8167; Carmona 31-1H File #16161; Ahel Et Al Grassy Butte File #12772; Woody Watson 1 File #8881). Operator commits to well steering, 30' surveys during build/curve/drop, and nearest wellbore positioning. Separation factors range 0.92–4.84. This analysis directly supports permit approval by addressing collision risk in a high-density pad.
📄 Email from fjanderson@nd.gov to Todd Holweger, January 5, 2026, 1:08 PM
📅 01/05/2026 (Exact confidence)
Permit Manager requested geotechnical review due to proximity of proposed landslide adjacent to eastern pad edge. Surface Geology Section Manager (Fred Anderson) reviewed plat and recent aerial imagery and confirmed 'no major concerns.' This geotechnical clearance is a condition of approval for this specific location geometry.
📖 Historical Context (5)
Stormwater Pollution Prevention Program (SWPPP) Guidance Document (Revision 0, dated 6/6/2025)
📄 Phoenix SWPPP Guidance Document, comprehensive operational and BMP manual · 📅 06/06/2025
This forward-looking operational standard persists through the well's construction, drilling, completion, and production life cycles. It mandates 14-day inspections during active construction, erosion controls, sediment basins, stormwater discharge monitoring, and final stabilization (70% perennial vegetation) before permit closure. Non-compliance triggers annual re-evaluation and potential revision. The document is binding on all Phoenix sites in North Dakota and Montana and will govern ongoing site management beyond spud.
Emergency Response Plan (ERP) for Mary Multi-Well Pad (dated, location: well site document set)
📄 WELL SITE EMERGENCY RESPONSE PLAN (ERP), MARY MULTI-WELL PAD section · 📅 Unknown
ERP establishes protocol for drilling emergencies, blowout prevention (BOPP), spill response, and contact procedures for all four planned wells on the pad. This plan persists through the entire drilling and completion cycle and is activated upon any emergency. Non-compliance with ERP procedures during an incident could expose the operator to regulatory action and civil liability.
Backbuild Order Waiver Request (Phoenix letter dated December 31, 2025, to NDIC)
📄 Phoenix letter, December 31, 2025, Subject: Mary Pad Backbuild Order Waiver · 📅 12/31/2025
Operator proposes to horizontally drill four wells (1H, 2H, 3H, 4H) with laterals exiting the target spacing unit per NDIC Order 31848. This requires notification of adjacent spacing unit operator. Unit to the north is unspaced, but operator has filed pending Case #32125 (heard September 2025). This creates an ongoing regulatory obligation: if the northern spacing unit is subsequently spaced by another operator, the backbuild waiver may be revisited or challenged. The operator must monitor this case outcome and remain responsive to NDIC inquiry.
Closed Mud System Requirement & Cuttings Disposal (APD Stipulation; cuttings route to Select Water Solutions LLC, Armegard ND)
📄 APD Stipulations section: 'Closed mud system with no cuttings pit'; Phoenix letter January 5, 2026: 'drill cuttings will be hauled and disposed of at Select Water Solutions LLC' · 📅 Embedded in APD | 01/05/2026
This is a standing operational constraint throughout the drilling and completion phases. All cuttings must be managed via closed system and transported to an authorized disposal facility. Any deviation (e.g., onsite cuttings pit use) would require a Sundry Notice waiver and constitutes non-compliance if violated. The disposal facility commitment creates contractual and logistical exposure if Select Water Solutions becomes unavailable.
Filter Sock & Filter Media Container Requirement (ND DMR Letter, May 30, 2025, re: NDAC 43-02-03-19.2)
📄 ND DMR letter dated May 30, 2025, from Assistant Director Mark F. Bohrer, re: 'Filter Socks and Other Filter Media — Leak Proof Container Required' · 📅 05/30/2025
Effective June 1, 2014, a leak-proof, covered, placard-marked filter container must remain on the well location from spud through clean-out, completion, and flow-back whenever filtration occurs. Failure to maintain this container exposes the operator to NDAC violations. The obligation persists through the entire drilling and initial production phase.
🔧 Operator Pattern
Phoenix Operating LLC demonstrates systematic regulatory compliance infrastructure and forward-oriented environmental management.
Company has drafted and implemented an enterprise-wide SWPPP Guidance Document (6/6/2025) that voluntarily exceeds regulatory minima; has retained Taktikal Directional for professional anti-collision engineering; has secured membership in Sakakawea Area Spill Response (SASR) for coordinated emergency response; maintains annual SPCC training for oil-handling personnel; and has submitted contemporaneous technical letters (January 5, 2026) addressing landslide review, anti-collision strategy, and well pad stormwater/spill response measures. The backbuild waiver letter (December 31, 2025) signals proactive notification and good-faith engagement with spacing unit obligations. No historical violations or adverse events are noted in the file, suggesting mature operational discipline.
Confidence: High
The file contains dated, regulator-signed documents (NDIC waiver 01/09/2026; State Geologist cores mandate 01/12/2026; Surface Geology clearance 01/05/2026) that explicitly condition the permit. The APD itself references Commission Order 34508 by number and specifies setback geometry, pool definition, closed mud system, and equipment standards. Anti-collision reports with Separation Factor plots and Closest Approach tables provide quantitative justification for lateral geometry. The file exhibits no contradictions, missing dates, or gaps between permit approval (effective 02/01/2026) and pre-permit submissions. Historical context documents (SWPPP, ERP, backbuild waiver, cuttings disposal route, filter container requirement) are complete and dated, allowing clear separation of permit-cycle from forward-looking operational obligations. OCR integrity is high; no instances of unintelligible text or missing critical dates observed.