🛢️ PETERSON 22-15-10-3 2H

Phoenix Operating LLC · Williams County, ND · File #42624 · Generated 2026-02-13 12:33

API: 3310506774
Target Formation: Middle Bakken
Permit Explained: Partially

📋 Permit Cycle Assessment

The well file contains permit-cycle documentation but is incomplete and contradictory. The APD (Application for Permit for New Well - Horizontal) with File Number 42624 and API 3310506774 shows approval conditioned on standard setback stipulations (150' north/south, 1220' east/west) tied to production liner design with wet shoe fracability. The intended Dirt Work Date of 04/01/2026 suggests approval timing. However, a critical suspension notice dated 01/14/2026 from the NDIC suspends all five Peterson permits (including 42624) pending a revocation hearing in February 2026, rendering the permit inactive. The contemporaneous pre-permit documentation includes a backbuild order waiver request (01/08/2026) addressing the non-routine geometric constraint (laterals exiting spacing unit boundary) and a State Geologist cores/samples requirement (01/12/2026). The approval date of the APD itself is not explicitly stated in the provided documents. The suspension on 01/14/2026 is the controlling regulatory action overriding the permit condition.

🔍 Permit Cycle Signals (4)

Permit suspension notice issued January 14, 2026 — revocation proceeding initiated by Koda Resources Operating LLC against all five Peterson permits (42623-42627). Hearing scheduled February 2026. Drilling activities prohibited pending Commission decision.

Direct

📄 Letter dated January 14, 2026 from Edd L. Holweger, Sr. Permit Manager, NDIC Oil & Gas Division to Tori Siemieniewski, Phoenix Operating LLC
📅 2026-01-14 (Exact confidence)

This is a regulatory suspension that directly blocks the approved permit from proceeding. The permit approval date cannot be established from the provided documents, but the suspension on 1/14/2026 is the controlling action in the file.

APD (Application for Permit for New Well - Horizontal) issued with Dirt Work Date of 04/01/2026 and standard setback stipulations (150' north/south, 1220' east/west). Setback summary tied to production liner cemented in lateral with wet shoe and ability to frac out shoe.

Supporting

📄 Application for Permit for New Well - Horizontal (APD), Page 1 of 10, File Number 42624
📅 2026-04-01 (Inferred confidence)

Dirt Work Date of 04/01/2026 appears to be the intended permit activation date, but this is contradicted by the suspension notice dated 01/14/2026. The stipulation tying setbacks to liner design and wet shoe fracability justifies non-standard geometry constraints.

Backbuild order waiver request dated January 8, 2026 — operator proposes to drill five Peterson wells from pad in SESE Section 22 with laterals entering Bakken outside target spacing unit. References NDIC Order 31848 notification requirement for adjacent spacing unit operators. States no other operators in proposed unit at time of submission.

Direct

📄 Letter dated January 8, 2026 from Jessica Wentz, Regulatory Specialist, Phoenix Operating LLC to Todd Holweger, NDIC Permit Manager
📅 2026-01-08 (Exact confidence)

Waiver request directly addresses the geometric constraint that defines this permit cycle — laterals crossing spacing unit boundary. This is a non-routine drilling authorization requiring explicit regulator approval prior to drilling.

Cores and samples submission requirement issued 01/12/2026 by State Geologist — operator must collect drill cuttings from Base of Last Charles Salt, submit samples at 30' max intervals (vertical/build) and 200' max intervals (horizontal), and submit to State Core Library within 30 days of drilling completion. Cores to be submitted within 180 days.

Direct

📄 Letter dated 1/12/2026 from Ross Edison, Geologist, ND Geological Survey to Tori Siemieniewski, Phoenix Operating LLC, RE: CORES AND SAMPLES, Well File No. 42624
📅 2026-01-12 (Exact confidence)

Regulator-imposed geologic sampling requirement tied to permit approval. Establishes mandatory data collection and submission protocol that conditions permit execution.

📖 Historical Context (4)

Grenora-Bakken Pool definition: accumulation of oil and gas from 50 feet above top of Bakken Formation to 50 feet below top of Three Forks Formation. Spacing unit: 2560 acres consisting of Sections 3, 10, 15, and 22, Township 159 North, Range 103 West. Commission Order No. 34633 governs setback policy.
📄 APD Stipulations section, page 1 · 📅 Unknown
Pool definition and spacing unit geometry define the regulatory framework that persists across all five Peterson wells in the pad development. Any modification to pool definitions or spacing unit boundaries would require new permit action.

Closed mud system requirement with no cuttings pit; closed-loop disposal of all drill cuttings to licensed facility (Secure Waste Infrastructure USA LLC, Williston, ND). Remote or automatic shutoff devices required on all equipment.
📄 APD Stipulations (Permit Review Policy) and Proposed Drilling Plan, Section 4 · 📅 Unknown
Environmental and safety operational controls persist throughout well execution and must be maintained during drilling, completion, and flowback operations. Failure to maintain closed system violates permit conditions.

Diesel fuel prohibition in hydraulic stimulation — operator commits to exclude Chemical Abstract Service Registry Numbers 68334-30-5, 68476-34-6, 68476-30-2, 68476-31-3, and 8008-20-6 (diesel and kerosene products) from all completions operations.
📄 Proposed Drilling Plan, Section 5 (STIMULATION) · 📅 Unknown
Stimulation design constraint applies to all completion operations on this well and is enforceable through permit compliance audits. Modification of stimulation fluid compositions requires sundry notice approval.

Filter socks and filtration media disposal requirement — operator must maintain leak-proof, covered, placard-identified containers on-site during drilling, clean-out, completion, and flowback operations. Filters must be disposed of at authorized facility per NDAC 43-02-03-19.2 and ND Century Code 33.1-20-02.1-01. Violation subject to civil penalty up to $12,500 per offense, each day a separate offense.
📄 Industry letter dated May 30, 2025 from Mark F. Bohrer, Assistant Director, NDIC Oil & Gas Division, RE: Filter Socks and Other Filter Media · 📅 Unknown
Mandatory waste management protocol applies to all wells drilled in ND after June 1, 2014. Persists through full well lifecycle and is subject to field inspection. Non-compliance exposes operator to significant civil penalties.

🔧 Operator Pattern

Phoenix Operating LLC operates multiple horizontal wells within the Peterson pad development (five wells planned from single SESE Section 22 location). Operator demonstrates proactive regulatory engagement: submitted backbuild order waiver request prior to permit approval, coordinated notification to adjacent spacing unit operators per NDIC Order 31848, and contracted with licensed disposal vendors for cuttings management.
Backbuild waiver letter dated 01/08/2026 demonstrates understanding of Order 31848 spacing unit crossing requirements. Proposed Drilling Plan specifies licensed disposal facility by name and address. Pad-level design shows five wells on single location (Peterson 1H-5H), indicating development strategy consistent with unconventional Bakken development practice.

Confidence: Medium
High confidence in document authenticity and permit identification (File No. 42624, API 3310506774, well name PETERSON 22-15-10-3 2H, Williams County). However, critical structural uncertainty: the permit approval date is not explicitly stated in the provided documents. The APD shows intended Dirt Work Date of 04/01/2026, but this is inferred as activation rather than approval date. The suspension notice dated 01/14/2026 definitively overrides the permit and is the controlling regulatory action. The backbuild waiver request (01/08/2026) and cores/samples requirement (01/12/2026) are contemporaneous pre-permit signals, but without an explicit permit approval date, the temporal sequencing and causal relationship to approval remain ambiguous. Standard APD boilerplate (setbacks, closed mud systems, safety devices, pool definitions) is present but suppressed from primary signals per schema rules.