File #42728 | Phoenix Operating LLC | Divide County
API
3302301772
Target Formation
Middle Bakken
Permit Explained
Partially
Permit Cycle Assessment
Permit approval (2026-02-20) is partially explained by contemporaneous documentation. The production liner design with wet shoe and frac-out capability directly justifies the non-standard 150'/1220' setback condition. Backbuild Order waiver notification to adjacent operator (Phoenix Energy) and directional survey completion satisfy pre-approval requirements. Diesel stimulation restrictions are documented in the drilling plan. However, no regulator-issued order letter or explicit stipulation document pre-dating the permit approval date addresses the underlying regulatory rationale for this specific permit issuance. The permit conditions are internally consistent with the directional design and spacing geometry, but the file lacks a covering letter or permit justification from the NDIC Petroleum Engineer (Nathaniel Erbele) explaining why this particular well configuration was approved on 2026-02-20.
Permit Cycle Signals (4)
Commission Order No. 34436 issued as condition of approval; setback stipulation tied to production liner design with cemented wet shoe and ability to frac out toe (2026-02-20)
Non-routine setback condition (150' north/south, 1220' east/west) is explicitly conditioned on specific liner completion architecture (wet shoe with frac-out capability). This geotechnical constraint directly justifies the permit geometry and is not standard boilerplate.
Backbuild Order waiver requirement satisfied; operator notified adjacent spacing unit operator (Phoenix Energy) per NDIC Order 31848 requirements (2026-01-28)
Well trajectory crosses into adjacent spacing unit; operator fulfilled mandatory inter-operator notification and trajectory disclosure requirements prior to permit approval. This regulatory clearance conditioned the permit issuance.
Directional survey plan and anticollision assessment completed; maximum legal coordinates defined (200' south / 2696' west at 7" casing; 15454' north / 2704' west at TD) (2026-01-28)
Anticollision survey and well geometry definition are pre-requisite technical submissions required for horizontal permit approval. Survey identifies planned BH location and verifies clearance against offset wellbores.
Diesel-based compound restriction imposed on hydraulic stimulation; operator commits to exclude specified CAS Registry Numbers (68334-30-5, 68476-34-6, 68476-30-2, 68476-31-3, 8008-20-6) (2026-01-29)
Non-routine stipulation on stimulation fluid chemistry restricts operator discretion. This appears to condition permit issuance and differentiates this well from routine completions.
Historical Non-Routine Signals (4)
North Dakota Century Code Section 38-08-04 / NDAC 43-02-03-38.1 core and sample submission mandates; samples from Base of Last Charles Salt at 30' max intervals (vertical/build), 200' max intervals (horizontal); delivery to ND Geological Survey within 30 days of drilling completion (2026-02-23)
Operational obligation persisting through drilling and post-drilling phases. Non-compliance incurs civil penalty up to $12,500 per offense per day. Affects wellsite logistics, sample handling protocols, and post-drilling reporting timeline.
Closed mud system with no cuttings pit required; drill cuttings disposal contracted to Smoky Butte Environmental LLC (13310 94th St NW, Fortuna, ND 58844) (2026-02-20)
Operational constraint on drilling execution. Closed-loop system and licensed facility disposal are non-negotiable; affects pad design, rig logistics, and cuttings management costs throughout drilling phase.
Leak-proof filter sock container requirement effective June 1, 2014 (NDAC 43-02-03-19.2); container must be maintained from spud through completion and flow-back phases (2014-06-01)
Standing regulatory requirement affecting well site operations from spud through abandonment of filtration operations. Violation incurs NDAC 33.1-20-02.1-01 solid waste transport permit sanctions.
Hydraulic stimulation survey and certified submission requirement: survey frequency 100 feet vertical, 30 feet in curve, 90 feet in lateral; certified surveys to certsurvey@nd.gov (2026-02-20)
Post-drilling operational and reporting obligation. Survey frequency and digital submission format are mandatory; non-compliance may delay well completion and regulatory release.
Historical Operator Profile
Total Wells:N/A
Active Wells:N/A
Notable Patterns:None identified
Confidence Assessment
Level: Medium Rationale: File contains complete permit approval documentation, directional survey, drilling plan, and regulatory correspondence. Permit conditions are clearly stated and traceable to supporting technical submissions (directional design, backbuild notification, stimulation restrictions). However, the file lacks an explicit regulator-issued order or letter written between the permit application date (2026-01-29) and approval date (2026-02-20) that articulates the NDIC's approval rationale. The wet shoe setback condition is explained by reference to Commission Order No. 34436, but that order document itself is not present in the file. Core/sample and filter sock requirements post-date or pre-date the permit cycle and are regulatory standing mandates rather than permit-specific justifications. The permit-cycle signals are inferred from contextual alignment rather than explicit contemporaneous justification.