🛢️ DANNY NOONAN 28-21-16 2H

Phoenix Operating LLC · Divide County, ND · File #42676 · Generated 2026-02-13 12:33

API: 3302301754
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval (File No. 42676, issued 2026-02-02) is supported by explicit regulatory conditions and operational documentation. Commission Order No. 33956 provides approval authority and establishes setback requirements conditioned on well geometry (wet shoe, frac-out capability). The Proposed Drilling Plan specifies casing, cementing, mud system, and stimulation controls consistent with permit stipulations. The backbuild order waiver letter (2026-01-28) contemporaneously satisfies NDIC Order No. 31848 notification requirements for cross-spacing-unit drilling. Pool definition and setback stipulations are directly tied to well trajectory and anticollision strategy. No material gaps exist between permit issuance and supporting technical/regulatory documentation.

🔍 Permit Cycle Signals (5)

Commission Order No. 33956 approval to drill conditional on 150' setback (north/south) and 500' setback (east/west) within 1920-acre spacing unit (Sections 16, 21, 28, T162N, R95W); north setback based on production liner cemented in lateral with wet shoe and frac-out capability.

Direct

📄 Permit APD, STIPULATIONS section, NDIC Field Order Info / Conditions of Approval
📅 2026-02-02 (Exact confidence)

Setbacks are tied to specific well geometry (wet shoe, frac-out design) and casing design, indicating non-routine anticollision/pressure control considerations that condition the permit approval.

Noonan-Bakken Pool definition: accumulation interval from 50 feet above top of Bakken Formation to 50 feet below top of Three Forks Formation (per NDIC Field Order).

Direct

📄 Permit APD, STIPULATIONS section, NDIC Field Order Info
📅 2026-02-02 (Exact confidence)

Pool definition is explicit in permit stipulation and directly bounds the well's target zone; required for regulatory compliance and spacing unit confirmation.

Production liner with wet shoe and frac-out capability required; intermediate casing (7 inch) set at 9098' MD with cement top at 3716' TVD; all WOC times adequate to achieve 500 psi compressive strength at casing shoe prior to drilling out.

Supporting

📄 Proposed Drilling Plan, Casing Program and Cementing Program sections; Permit APD Conditions of Approval
📅 Unknown (Missing confidence)

Casing and cementing design (wet shoe, frac-out, cement top specification, WOC requirements) is specified in detail and directly referenced in permit setback stipulation; these are non-routine controls tied to well geometry and pressure management.

Closed mud system with no cuttings pit required; all drill cuttings to be hauled to licensed disposal facility (Smoky Butte Environmental LLC, Fortuna, ND); no diesel-based compounds permitted in hydraulic stimulation (specific CAS Registry Numbers prohibited).

Direct

📄 Permit APD, STIPULATIONS (Permit Review Policy); Proposed Drilling Plan, Section 4 (Disposal of Drill Cuttings) and Section 5 (Stimulation)
📅 2026-02-02 (Exact confidence)

Closed mud system and stimulation fluid restrictions are permit conditions tied to environmental protection and regulatory compliance; diesel fuel ban is explicit permit requirement.

Backbuild order waiver letter (dated 2026-01-28) submitted by Phoenix Operating LLC to North Dakota Industrial Commission addressing NDIC Order No. 31848 requirements: operator notified adjacent spacing unit operator (Phoenix Energy) of directional plan, drilling commencement date, and contact information; wells proposed to enter Bakken outside target spacing unit.

Supporting

📄 Letter from Meaghan Coughlan (Phoenix Operating LLC) to Todd Holweger (NDIC), January 28, 2026, re: DANNY NOONAN Pad Backbuild Order Waiver
📅 2026-01-28 (Exact confidence)

Backbuild waiver submission is contemporaneous to permit approval and directly addresses regulatory requirement (NDIC Order 31848) for cross-unit drilling notification; indicates well trajectory enters adjacent spacing unit and satisfies notification obligation.

📖 Historical Context (2)

Cores and samples submission requirement (ND Century Code § 38-08-04, ND Administrative Code § 43-02-03-38.1): operator must collect sample cuttings at 30' intervals (vertical/build) and 200' intervals (horizontal) beginning at Base of Last Charles Salt; submit to State Geologist within 30 days of completion; cores within 180 days. Civil penalty up to $12,500 per violation per day applies.
📄 Letter from Ross Edison, Geologist, ND Dept. of Mineral Resources, dated 2026-02-02, re: CORES AND SAMPLES · 📅 Unknown
Sampling obligation is statutorily mandated and persists through and beyond drilling completion; non-compliance triggers significant civil penalties. Operator must maintain compliance documentation and sample shipment records throughout well lifecycle.

Filter socks and filtration media disposal requirement (ND Administrative Code § 43-02-03-19.2, effective 2014-06-01): operator must maintain leak-proof, covered container on well site during drilling, cleanout, completion, and flow-back whenever filtration operations conducted. Container must be placarded for filters only. Used filters must be disposed of in authorized facility per state/federal requirements. Waiver available via Form 4 Sundry Notice if no filtration system used.
📄 Letter from Mark F. Bohrer, Assistant Director, ND Oil and Gas Division, dated 2025-05-30, re: Filter Socks and Other Filter Media · 📅 Unknown
Filter disposal obligation is regulatory requirement that extends from spudding through completion/flow-back phases. Operator must maintain container compliance and manage disposal chain-of-custody. Failure to comply exposes operator to enforcement action under ND Administrative Code § 33.1-20-02.1-01 (solid waste transport permit requirements).

🔧 Operator Pattern

Phoenix Operating LLC operates multi-well pads with coordinated spacing unit strategy; demonstrates regulatory engagement (backbuild waiver submission) and multi-well pad design (5 planned wellbores from single pad location in SWSE Sec. 28).
DANNY NOONAN pad design includes 1H, 2H, 3H, 4H, 5H wellbores planned from single location; backbuild waiver letter references coordination with adjacent operator (Phoenix Energy) and compliance with NDIC Order 31848; well spacing footage table in plat shows coordinated FNL/FEL progression across five wellbores.

Confidence: High
Permit file contains complete regulatory chain (Commission Order 33956, Field Order stipulations, contemporaneous backbuild waiver letter, detailed Proposed Drilling Plan with casing/cementing/mud specifications, and post-permit regulatory guidance letters on cores/samples and filter disposal). Well geometry, setback conditions, and casing design are internally consistent across APD stipulations and drilling plan. Backbuild waiver letter dated 2026-01-28 is temporally proximate to permit approval (2026-02-02) and explicitly addresses NDIC Order 31848 requirements. No material conflicts or missing explanatory documents identified. OCR quality is adequate for regulatory language extraction.