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🛢️ MARY 25-36-1-12 3H
Phoenix Operating LLC · McKenzie County, ND · File #42618 · Generated 2026-02-13 12:33
- API
- 3305310756
- Target Formation
- Middle Bakken
- Permit Explained
- Yes
📋 Permit Cycle Assessment
The well file contains sufficient contemporaneous documentation to explain the 02/01/2026 permit approval. NDIC approval is directly conditioned by (1) Open Hole Log Waiver (01/09/2026) justified by offset well formation tops and GR-CBL contingency, (2) State Geologist cores/samples order (01/12/2026) establishing non-negotiable drilling-phase deliverables, (3) anti-collision engineering report (01/05/2026) demonstrating separation analysis and 30' survey protocol to mitigate lateral geometry risk, (4) Commission Order No. 34508 setback stipulation tied to production liner wet-shoe design, and (5) surface geology clearance (01/05/2026) from NDGS confirming no major landslide risk. No permit-cycle gap exists. All signals are time-bound to the approval anchor and directly justify or constrain issuance.
🔍 Permit Cycle Signals (5)
📄 Sundry Form 292057, Page 1-2; Reviewer: Ross Edison, NDIC Geologist
📅 2026-01-09 (Exact confidence)
Waiver explicitly conditions permit approval. NDIC Rule 43-02-03-31 requires open hole logs; waiver justified by offsetting well (Twin Tanks 36-32, NDIC #8167) having sufficient formation tops established. GR-CBL planned from TD to ground level. Establishes non-routine path to approval.
📄 State Geologist letter signed by Ross Edison (Oil & Gas Division); references NDCC 38-08-04 and NDAC 43-02-03-38.1
📅 2026-01-12 (Exact confidence)
Regulator-issued order specifying mandatory drilling-phase deliverables: drill cuttings sampling (30' vertical/200' horizontal intervals), core preservation, and submittal timelines (30 days for samples, 180 days for cores). Civil penalty authority (up to $12,500/day) conditions compliance. Non-routine technical requirement tied to permit.
📄 Phoenix letter to Todd Holweger (NDIC) signed by Tyree Abshire, VP Drilling; Taktikal Directional anticollision report (multiple pages with separation factor analysis)
📅 2026-01-05 (Exact confidence)
Pre-permit submission justifying lateral geometry. Anticollision analysis shows separation factors and 30' survey intervals during build/curve sections to mitigate collision risk with nearby dry wells (Twin Tanks 36-32, Carmona 31-1H, Ahel Et Al Grassy Butte, Woody Watson 1). Supports non-standard setback geometry approval.
📄 APD Form, Stipulations section; Bakken Setback Summary references production liner + wet shoe fracture-out capability
📅 Unknown (Missing confidence)
Permit explicitly conditions setback geometry (150' north/south, 500' east/west) on production liner cemented with wet shoe. South setback justified by shoe-frac design. Conditions tied to well design, not generic boilerplate.
📄 Email chain between Todd Holweger (NDIC) and Fred Anderson (NDGS Surface Geology Section), 01/05/2026; no major concerns noted in aerial review
📅 2026-01-05 (Exact confidence)
Regulator-initiated surface geology screening. Permit approval implicitly conditioned on geologic clearance. Email indicates operator concern regarding landslide risk adjacent to eastern pad edge; NDGS review permitted approval to proceed.
📖 Historical Context (5)
Backbuild Order Waiver Request — Filed 12/31/2025 (pre-permit)
📄 Phoenix letter to Todd Holweger re: 'Mary Pad (Mary 25-36-1-12 1H, 2H, 3H, 4H) — Backbuild Order Waiver'; signed by Tori Siemieniewski, Director Bakken Regulatory · 📅 2025-12-31
Well lateral planned to enter Bakken outside target spacing unit (DSU = Sections 25, 36, 1, 12 spanning two townships). Operator filed Case #32125 (September 2025) for 3-mile spacing unit; approval status unknown at filing. Pending spacing case introduces regulatory uncertainty for future appraisal and development decisions. If spacing unit is denied or modified, lateral drilling operations and reserves assigned to unit may be constrained.
Stormwater Pollution Prevention Program (SWPPP) Guidance Document — Revision 0, 06/06/2025
📄 Phoenix-issued SWPPP Guidance (16 pages + appendices); covers well pad, access road, containment, erosion controls, discharge protocols, inspection schedules · 📅 2025-06-06
Forward-looking environmental compliance obligation. 14-day inspection frequency during active construction, 30-day under stabilized/drought conditions. Sediment basin cleaning, erosion control maintenance, and dewatering discharge procedures are ongoing until final stabilization (≥70% perennial vegetation). Failure to comply with SWPPP triggers NDDEQ reporting and penalty risk (civil penalty up to $12,500/day per NDCC 38-08-16). Controls persist through drilling, completion, and reclamation phases.
Filter Sock and Filter Media Containment Requirement (NDAC 43-02-03-19.2) — Industry Notice, 05/30/2025
📄 North Dakota Department of Mineral Resources letter dated 05/30/2025; effective 06/01/2014 · 📅 2025-05-30
Mandatory onsite leakproof container (with lid and placard) required from spud through flowback. Used filter socks must be stored and disposed at authorized facility. Non-compliance subjects operator to waste classification penalties. Requirement persists during entire well life cycle.
Multi-Well Pad Emergency Response Plan (ERP) — Revision status unclear (covers MARY 1 SWD, 1H, 2H, 3H, 4H)
📄 Phoenix Emergency Response Plan cover page; no revision date visible; references Well Site ERP for McKenzie County · 📅 Unknown
ERP establishes spill response protocols, personnel notification hierarchy, and equipment deployment for multi-well pad. Plan must be maintained and updated if operational changes occur (e.g., staffing, contractor changes, equipment upgrades). Non-compliance with emergency preparedness can result in regulatory action and civil liability in event of release.
Soil Compaction and Geotechnical Monitoring (Slope Stability) — Operator Committed Measure, 01/05/2026
📄 Phoenix letter to NDIC (01/05/2026) re: 'Proposed well pad location — Best Management Practices'; references Standard Proctor testing and soil compaction testing at 2-foot intervals in fill to subgrade · 📅 2026-01-05
Operator commitment to compaction testing and potential hydroseeding/overseeding for erosion control ties to landslide risk mitigation. If testing reveals inadequate compaction or instability, operational pause and remediation required. Ongoing compliance with submitted commitments is binding—failure to perform subjects operator to permit non-compliance findings.
🔧 Operator Pattern
Phoenix Operating LLC demonstrates proactive regulatory engagement and environmental stewardship through pre-submission technical coordination, third-party engineering support, and adoption of industry best practices exceeding minimum regulatory thresholds.
Phoenix filed anticollision reports, backbuild waiver justification, and pad design (including geotechnical mitigation) prior to permit issuance. Operator voluntarily implemented SWPPP guidance (06/06/2025) despite North Dakota exemption from federal stormwater permitting. Emergency Response Plan and spill containment architecture reference external consortium membership (Sakakawea Area Spill Response, SASR) and annual employee training. 24-hour SCADA monitoring and high-level tank alarms document operational rigor beyond permit stipulations. No evidence of prior violations or enforcement actions in file; regulatory correspondence tone is collaborative and detailed.
Confidence: High
File contains explicit permit approval date (02/01/2026), signed regulatory orders and waivers with specific effective dates, third-party directional survey/anticollision analysis with named practitioners, and contemporaneous inter-agency correspondence (NDIC–NDGS). Open Hole Log Waiver and Cores/Samples order are dated within 14 days of permit issuance and explicitly condition approval. Anti-collision report output dated 12/06/2025 (pre-permit), with narrative justification in 01/05/2026 letter. No contradictions or missing justifications detected. Operator's commitments (SWPPP, ERP, stormwater discharge, geotechnical monitoring) are documented in writing and traceable to specific personnel and dates. All date inferences are marked 'Unknown' or 'Missing' where actual dates are absent; no speculative dates are asserted.