🛢️ DANNY NOONAN 28-21-16 5H

Phoenix Operating LLC · Divide County, ND · File #42678 · Generated 2026-02-13 12:33

API: 3302301756
Target Formation: Middle Bakken
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit issued 2/2/2026 (File No. 42678, API 3302301756) is justified by contemporaneous regulatory documentation that establishes three categories of condition: (1) Setback geometry (150' N/S, 500' E/W) conditioned on production liner cement design with wet shoe fracout capability—operationalized in the Proposed Drilling Plan and directly referenced by Commission Order No. 34326. (2) Cores and samples collection protocol mandated by geologist letter same date as permit, establishing drilling-phase compliance obligations. (3) Backbuild waiver requirement (Order 31848) satisfied by inter-operator notification letter (1/28/2026) confirming adjacent operator awareness. The permit approves a horizontal well with non-routine geometry (backbuild trajectory exiting target spacing unit) conditioned on specific liner completion architecture and coring requirements. All material conditions are explained by pre- or contemporaneous permit-cycle documentation.

🔍 Permit Cycle Signals (5)

Commission Order No. 34326 approves drilling conditional on 150' north/south setback and 500' east/west setback from spacing unit boundaries; north setback premised on production liner cemented in lateral with wet shoe and ability to frac out shoe

Direct

📄 Application for Permit for New Well - Horizontal, Stipulations section
📅 2026-02-02 (Exact confidence)

Setback conditions directly tied to well geometry (production liner design and frac-out capability). Non-routine condition justifying specific completion architecture.

North Dakota Geological Survey cores and samples letter (2/2/2026) establishes mandatory collection protocol: sample cuttings from Base of Last Charles Salt at 30' intervals (vertical/build) and 200' intervals (horizontal); submission within 30 days of drilling completion; cores within 180 days. Violation penalty up to $12,500 per day.

Direct

📄 CORES AND SAMPLES letter from Ross Edison, Geologist, dated 2/2/2026
📅 2026-02-02 (Exact confidence)

Permit-conditioned geologist-issued directive tied to drilling operations. Establishes compliance obligation during drilling phase (pre-completion).

Well trajectory enters Bakken Petroleum System outside target spacing unit; backbuild waiver required per NDIC Order 31848. Operator (Phoenix Operating) notified adjacent operator (Phoenix Energy) per regulatory requirement. Letter dated 1/28/2026 confirms compliance with inter-operator notification.

Supporting

📄 Letter from Meaghan Coughlan, Phoenix Operating, dated January 28, 2026, subject: Backbuild Order Waiver
📅 2026-01-28 (Exact confidence)

Backbuild geometry creates regulatory obligation under Order 31848. Adjacent operator notification is prerequisite to permit compliance. Letter confirms satisfaction of inter-operator communication requirement.

Proposed casing program specifies production liner (4.5") set at 8054'–24532' MD with tail cement (Class G/POZ, 3% Barite, 0.5% FL, 0.5% Viscosifier, 1.18% Retarder) topped to liner top. Wet shoe with fracout capability explicitly documented in drilling plan.

Supporting

📄 Proposed Drilling Plan, Section 2 (Cementing Program) and well schematic
📅 Unknown (Missing confidence)

Directly supports setback condition in permit. Liner design and cementing schedule operationalize the structural condition imposed by Commission Order No. 34326.

Closed mud system with no cuttings pit required. Drill cuttings collected in metal containers and hauled to licensed disposal facility (Smoky Butte Environmental LLC, Fortuna, ND). Disposal protocol aligns with NDAC 43-02-03-19.2 waste management requirement.

Direct

📄 Application Stipulations (Permit Review Policy) and Proposed Drilling Plan, Section 4
📅 2026-02-02 (Exact confidence)

Standard condition but operationalized via specific disposal contractor and closed-loop system architecture. Ties to state waste management code.

📖 Historical Context (3)

Well design includes four additional horizontal laterals from same pad (DANNY NOONAN 28-21-16 1H, 2H, 3H, 4H) proposed to same target (Middle Bakken). Multi-well pad geometry documented in directional survey, well proximity map, and pad layout drawings.
📄 Well Location Plat, Surface Hole Footage Table, Well Proximity Map (TOPO C) · 📅 Unknown
Pad design constrains future drilling sequencing, rig logistics, and pressure management during completion. Backbuild geometry on 5H increases complexity of offset well isolation. Forward operational impact on cement integrity verification, frac staging, and interference mitigation.

Noonan-Bakken Pool defined as interval 50 feet above top of Bakken Formation to 50 feet below top of Three Forks Formation. Pool definition establishes regulatory spacing and pooling obligation for all future development in designated pool area.
📄 Application Stipulations, NDIC Field Order Info · 📅 2026-02-02
Pool definition is permanent regulatory geography. Affects future offset well spacing, drilling order, and any drilling unit modifications. Constrains operator's ability to drill additional wells in pool without conforming to defined interval.

Filter socks and filtration media disposal requirement: leak-proof, covered containers required on-site from spud through completion. Disposal via authorized facility. Applies to all wells drilled in North Dakota per NDAC 43-02-03-19.2 (effective 6/1/2014). Failure to comply creates civil penalty risk up to $12,500/day per statute 38-08-16.
📄 Filter Socks and Other Filter Media letter dated May 30, 2025, from Mark F. Bohrer, Assistant Director · 📅 2025-05-30
Standing waste management obligation for entire well lifecycle (drilling, completion, flowback). Non-compliance risk persists through abandonment. Operator must maintain documented disposal records.

🔧 Operator Pattern

Phoenix Operating LLC operates multi-well pad development in Bakken. Backbuild waiver letter (1/28/2026) indicates intentional use of adjacent-spacing-unit entry to optimize drainage from single pad location. Operator (Phoenix Operating) and adjacent operator (Phoenix Energy, same parent or affiliate) coordinate trajectory planning.
Backbuild waiver letter explicitly names Phoenix Energy as operator of adjacent spacing unit and confirms 'no additional notification is necessary,' suggesting pre-existing operational relationship or common ownership. Four additional wells (1H–4H) proposed from same pad with same target indicate standardized multi-well pad strategy.

Confidence: High
Permit file contains explicit regulatory orders (Commission Order No. 34326), geologist-issued drilling instructions (cores/samples), contemporaneous waiver documentation (backbuild notice), and detailed drilling/completion plans that operationalize all material permit conditions. Permit approval date (2/2/2026) is anchored to firm regulatory documents. No contradictions or unexplained approvals detected. Backbuild geometry is non-routine and fully justified by pre-permit waiver coordination. Historical constraints (pool definition, waste management, multi-well sequencing) are documented and persistent.