File #42727 | Firebird Services, LLC | McKenzie County
API
3305310759
Target Formation
Dakota Group (Inyan Kara Formation)
Permit Explained
Yes
Permit Cycle Assessment
The permit approval on 02/20/2026 is directly explained by Industrial Commission Order 35406 issued 02/09/2026, which authorized injection of Class II fluids into the Dakota Group subject to compliance with all permit stipulations and NDAC Chapter 43-02-05. The approval is conditioned on: (1) a tank dike variance approved contingent on as-built documentation; (2) injection pressure limited to 1,000 psi based on fracture gradient analysis of the Mowry Formation confining zone (calculated maximum 1,628.61 psi); (3) pre-drill freshwater baseline sampling of three wells within the 1-mile area-of-review completed 12/03/2025; and (4) anticollision analysis completed 11/21/2025 confirming no corrective action required for 11 offset wells. The permit imposes a completion deadline of 02/20/2027 and requires pre-spud notification to NDIC Field Inspector. All contemporaneous documentation supporting regulatory findings (Dakota Group exempted aquifer status, confining zone integrity, no conflicting wellbores) is present in the file.
Permit Cycle Signals (5)
UIC Order 35406 issued by Industrial Commission on 02/09/2026, conditioning permit approval on compliance with all injection well permit provisions and NDAC Chapter 43-02-05 requirements. (2026-02-09)
This is the formal regulatory authorization that directly conditions and frames the permit issued 02/20/2026. It establishes legal nexus between application approval and compliance obligations.
Tank dike variance approved contingent on submission of as-built site schematic after facility construction completion. Variance was requested because tank dike dimensions insufficient to contain largest tank plus one day's fluid throughput. (2026-02-20)
Non-routine waiver tied to specific design constraint. Condition explicitly tied to permit approval and requires post-construction documentation.
Maximum injection pressure calculated at 1,628.61 psi based on fracture gradient analysis of Mowry Formation upper confining zone (0.8 psi/ft gradient, depth 5,131' TVD). Permitted maximum allowable surface injection pressure set at 1,000 psi per UIC pressure test requirements. (2026-01-23)
Technical basis for injection pressure limit is documented with geologic formation analysis. Supports mechanical integrity and confinement requirements stated in permit conditions.
Freshwater well baseline sampling completed 12/03/2025 for three wells within 1-mile AOR. Two wells (Bryce and Doug) sampled; one well (14910208CCB) noted winterized/non-operational. Analytical results received 12/08/2025 from Pace Analytical Services. (2025-12-03)
Pre-permit environmental baseline establishes condition of freshwater resources prior to injection operations. Required by NDAC 43-02-05 area-of-review documentation. Supports permit finding that Dakota Group is exempted aquifer and injection will not impact USDW.
Anticollision modeling completed 11/21/2025 with analysis of 11 offset wells. No corrective action required; existing CROSSBOW 1-7-6H wellbore located >0.25 miles from injection interval per Appendix B. Minimum separation factors range 1.5–7.9 across all offsets. (2025-11-21)
Anticollision analysis addresses API/regulatory requirement for well spacing and confinement integrity. Clears technical path for directional well drilling from pad location.
Historical Non-Routine Signals (4)
Phoenix Operating LLC identified as operator of co-located oil wells on same pad (RIDE THE LIGHTNING FED 18-19-30-31 1HF, 2HF, 3HF, 4HF, 5HF) with multiple wells in active or submitted status. SWD facility is co-located within same berms as oil production facilities. (N/A)
Co-location creates ongoing operational interdependence and shared facility/containment infrastructure. Future modifications to oil well operations or SWD injection rates must account for shared pad constraints and tank capacity interactions (6,919 BBLS primary containment; 58,519 BBLS with earthen berm secondary containment).
Injection fluid source designated as produced water from on-pad oil wells with no third-party volumes currently planned. Representative water sample from Ian Quicksilver well analyzed 12/11/2025 showing Class II fluid characteristics. Operator retains option to receive third-party volumes. (N/A)
Fluid source limitation is not structurally enforceable beyond current statement of intent. Any future acceptance of third-party disposal water or off-pad sources requires amendment to injection program and geotechnical re-evaluation, particularly if fluid chemistry differs from baseline (Bryce/Doug freshwater well samples or Ian Quicksilver produced water profile).
SPCC (Spill Prevention, Control, and Countermeasure) Plan implementation required within six months of commissioning per EPA regulations. Facility equipped with 24-hour SCADA remote monitoring with tank high-level alarms, separator alarms, Emergency Shut Down Valve (ESDV) activation, tubing pressure, vibration monitoring, and low/high flow alarms. (N/A)
SPCC plan submission and annual SCADA/personnel training are enforceable post-approval operational obligations. System failures or alarm bypass events trigger reporting and corrective action requirements under EPA and NDIC oversight.
Permit expiration deadline of 02/20/2027 if well is not completed as saltwater disposal well. Completion requires perforation, packer setting, minimum internal tubing test (MIT) to 1,000 psi, and injection initiation within one year of approval. (N/A)
One-year completion mandate creates hard deadline for drilling, completion, and initial injection operations. Non-completion triggers permit lapse with requirement for reapplication if operations delayed beyond 02/20/2027.
Historical Operator Profile
Total Wells:N/A
Active Wells:N/A
Notable Patterns:None identified
Confidence Assessment
Level: High Rationale: Well file contains complete permit issuance documentation (02/20/2026 approval by UIC Supervisor Jared Thune), formal Industrial Commission Order 35406 (02/09/2026), comprehensive UIC plan with geologic formation analysis, anticollision reports, freshwater baseline sampling with laboratory certifications, approach permit approval, and all area-of-review notifications with proof of certified mail delivery. All permit-cycle signals are directly supported by dated regulatory documents or technical submittals explicitly referenced in permit conditions. No material gaps or inconsistencies between permit language and supporting documentation. Historical context signals are corroborated by multiple sections of the file showing co-location arrangements, fluid source documentation, and operational procedures.