🛢️ DC GUNNER 6-7-18-19 4H

Phoenix Operating LLC · Williams County, ND · File #42732 · Generated 2026-04-04 15:56

API: 3310506802
Target Formation: Bakken / Three Forks Petroleum System
Permit Explained: Yes

📋 Permit Cycle Assessment

The permit approval (dated 2026-02-25) is directly justified by Commission Order No. 34678, which conditions approval on specific setback distances (150' north/south, 500' east/west) tied to a wet shoe production liner design with frac-out capability. Pre-permit anticollision analysis (dated 2/16/2026) documents compliance with offset well spacing constraints and identifies Level 3 separation warnings that support the regulatory setback framework. A backbuild waiver letter (dated 2/17/2026) satisfies Order 31848 requirements for off-spacing drilling into an adjacent unit. The permit contains complete well geometry, casing design, cementing specifications, and directional survey data consistent with horizontal Bakken drilling. All material permit conditions are anchored to regulator-issued orders or operator pre-approval submissions.

🔍 Permit Cycle Signals (4)

Commission Order No. 34678 conditioning approval – setback requirements tied to production liner cemented in lateral with wet shoe and ability to frac out shoe

Direct

📄 Permit page 1, Stipulations section
📅 2025-05-30 (Inferred confidence)

Order 34678 is the direct regulatory basis for permit approval. South setback (150') is explicitly conditioned on wet shoe design with frac-out capability—a non-routine completion constraint that differentiates this approval.

Anticollision analysis required and completed – separation factors evaluated against multiple offset wells (DC GUNNER 1 SWD, 1H-LL, 2H, 3H, 5H; PEDERSON 1-18-19H) with Level 3 warnings triggered on at least two offsets

Supporting

📄 Anticollision Report dated 2/16/2026; Permit page 8 operator assertion regarding wells within 500' and anti-collision concerns
📅 2026-02-16 (Exact confidence)

Anticollision analysis directly justifies lateral trajectory geometry and setback compliance. Level 3 warnings on DC GUNNER 1 SWD (0.896 SF) and PEDERSON 1-18-19H (0.896 ES/SF) indicate tight spatial constraints that support the Commission's setback conditions.

Backbuild/off-spacing waiver letter (Feb 17, 2026) – wells proposed to enter Bakken Petroleum System outside target spacing unit; Phoenix Energy holds majority working interest in adjacent unit; Order 31848 notification satisfied

Supporting

📄 Phoenix Energy letter dated February 17th, 2026, subject DC GUNNER Pad Backbuild Order Waiver
📅 2026-02-17 (Exact confidence)

Demonstrates operator pre-approval coordination on cross-unit drilling intent. Satisfies NDIC Order 31848 notification requirement for adjacent spacing unit operations. Supports permit approval of the 4H well trajectory that extends into adjacent sections.

Pool definition and formation interval specified in permit – Little Muddy-Bakken Pool defined from 50' above Bakken top to 50' below Three Forks top; completion interval 9905–30659 MD

Direct

📄 Permit page 1, Stipulations section; Permit page 5, Completion Intervals
📅 2026-02-25 (Exact confidence)

Pool definition and completion interval specificity tie the permit approval to regulatory formation boundaries and prevent unauthorized zone drilling. Standard but required for Bakken development approval.

📖 Historical Context (4)

Filter sock disposal requirement (NDIC letter dated 5/30/2025, effective 6/1/2014) – covered leak-proof container with placard mandatory on-site from spud through flow-back
📄 NDIC Oil and Gas Division letter dated May 30, 2025; Permit page 2 conditions; Permit page 9 operator assertions · 📅 2014-06-01
Standing NDIC requirement across all North Dakota wells. Persists as forward operational obligation throughout drilling, completion, and flow-back phases. Non-compliance triggers waste disposal violations under NDAC 43-02-03-19.2.

Closed mud system with no cuttings pit requirement; drill cuttings disposal to licensed facility (13 Mile Landfill, Williston)
📄 Permit page 1, Stipulations; Proposed Drilling Plan page 1, section 4 Disposal of Drill Cuttings · 📅 2026-02-25
Operational constraint throughout drilling phase. Drilling mud program specifies fresh water (0–1944'), 70/30 invert (1944–9905'), brine water (9905–30659'). All cuttings must be containerized and transported to 13 Mile Landfill. Affects rig logistics and cost; violation would result in regulatory enforcement.

Conductor setting restriction – conductor may only be set on permitted wells; rat/mouse holes must be cased, cemented to ground level, and plugged/cut 4' below grade after rig operations
📄 Permit page 1–2, Conditions of Approval · 📅 2026-02-25
Groundwater protection requirement that constrains near-surface drilling operations and post-drilling reclamation timeline. Applies to all rat and mouse holes on this well site indefinitely.

Perimeter berm requirement; 2' berm above pad edge; primary containment 10,593 BBL within steel wall; secondary containment 71,510 BBL with earthen berm
📄 Permit page 2, Conditions of Approval; Pad Layout and Containment schematic · 📅 2026-02-25
Environmental containment design is fixed as part of approved production facility. Supports spill prevention throughout well life and constrains pad layout for any future tie-in or maintenance operations.

🔧 Operator Pattern

Phoenix Operating LLC coordinated off-spacing drilling across multi-well pad development with internal working interest coordination (Phoenix Energy holds majority in adjacent unit). Pre-permit compliance submissions included directional survey data, anticollision analysis, and regulatory notification letters.
Backbuild waiver letter (Feb 17, 2026) demonstrates proactive Order 31848 notification; anticollision report completed 9 days prior to permit approval; all operator assertions on permit form completed with consistent contact information and early field notification protocols identified.

Confidence: High
Permit document is complete with exact approval date (2/25/2026), explicit regulatory conditioning (Order 34678), contemporaneous pre-permit submittals (anticollision 2/16/2026, backbuild waiver 2/17/2026), and detailed well geometry/drilling/completion specifications. No missing critical dates or unexplained regulatory references. Anticollision analysis clearly supports setback geometry. Filter sock and mud disposal requirements are documented in historical NDIC guidance and incorporated into permit conditions.