Rule 32 Pack & rrc_rule32 Skill
This page documents the RRC oil & gas vertical — one of the five packs installed on AEGIS. The mechanisms (packs, skills, routers, HITL rules) are domain-neutral.
The rule_32 pack and the rrc_rule32 skill cover Form R-32 filings for flaring and venting exceptions under Texas Administrative Code 16 TAC 3.32. A user reaches this capability in a general-mode conversation through the flaring router — which carries a watch/file pair: monitoring questions go to flaring_watch (see Flaring Pack), and preparing an application goes to rrc_rule32. There is no dedicated “Rule 32 agent” to pick anymore.
How it is reached
| Mechanism | Value |
|---|---|
| Pack | rule_32 (packs/rule_32/manifest.yaml) |
| Skill key | rrc_rule32 |
| Router | flaring → rrc_rule32 (filing) / flaring_watch (monitoring) |
| Compliance domain | rule_32 |
| Entity types | Well |
The effective LLM model is tenant-configured via Platform Settings (box default anthropic/claude-sonnet-5).
Regulatory Context
Rule 32 (16 TAC 3.32) governs the flaring and venting of natural gas in Texas. The pack’s assessment recipe resolves thresholds from rule_versions for SWR_32:
| Parameter | Default |
|---|---|
Renewal notice window (renewal_notice_days) | 30 days |
Volume warning fraction (volume_warning_fraction) | 0.80 of the authorized period cap |
| Disposition Code 10 | Flared gas |
| Disposition Code 11 | Vented gas |
Operators file a Form R-32 to obtain authorization for flaring or venting. The skill also tracks federal EPA requirements that overlap with the state rule.
Unlike Rule 37 (well placement), Rule 32 addresses what happens to natural gas that cannot be captured, processed, or sold. Flaring (burning) is preferred over venting (releasing unburned) because venting releases methane, a potent greenhouse gas.
Skills in the pack
The rule_32 pack declares ten skills. Some are code-backed (orchestration.skills.rule32.*); rule32_gas_composition, rule32_emissions, and rule32_readiness_check are declarative descriptors (context_table, emissions_calc, readiness_check).
| Skill key | Item | Purpose |
|---|---|---|
rule32_exception_type | Exception Type Determination | Classify emergency / initial / extension / permanent; determine applicable R-32 provisions |
rule32_auth_review | Current Authorization Review | Query existing R-32 authorizations; show history, volumes, durations; flag expirations |
rule32_volume_analysis | Flaring Volume Analysis | Pull production/flaring data; compute current volumes vs. authorized limits; project when limits are reached |
rule32_gas_composition | Gas Composition Analysis | Compile H2S, BTU, CO2, N2, NGL data; flag against pipeline/R-32 requirements |
rule32_pipeline_assessment | Pipeline Availability Assessment | Research gathering infrastructure; document proximity, capacity, connection timeline |
rule32_economic_analysis | Economic Feasibility Analysis | Draft capture-alternative economics (pipeline, compression, reinjection, on-site use) |
rule32_form_r32 | Form R-32 Population | Pre-fill R-32 fields from entity data and analysis results |
rule32_emissions | Emissions Impact Estimate | Calculate CO2e using EPA factors; generate ESG/GHGRP reporting data |
rule32_timeline | Compliance Timeline | Compute the R-32 deadline calendar (authorization duration, extension windows, CFO triggers) |
rule32_readiness_check | Filing Readiness Check | Validate required R-32 fields and supporting-documentation completeness |
Checklist & assessment
The pack’s checklist template defines these ten items (indices 0–9) with min_required_items 0, 1, 2, 4, 6, 8, 9. The assessment recipe runs a deadline_window check against the authorization’s expiration date (renewal_notice_days) and a cumulative_limit check summing flared volume_mcf against the period cap (authorized_volume_mcf, not the Mcf/day cap — comparing a multi-day total against a daily cap would fabricate violations). Auth-only rows with no governing well are stamped as FlaringAuthorization and named by authorization_number (INT-1 parity).
HITL Checkpoints
HITL travels with the rrc_rule32 skill as a seeded require_hitl rule:
| Rule key | Checkpoint | Trigger |
|---|---|---|
skill:rrc_rule32:pre_filing | pre_filing | R-32 filing assembly, before RRC submission |
There is intentionally no emissions HITL rule for rrc_rule32 — emissions is a
model-supplied calculation (rule32_emissions), not a filing gate. The single gate is
pre_filing on filing assembly. The approval_node is fail-closed and pauses
(awaiting_hitl) rather than proceed unreviewed.
Skill-scoped tools
Once rrc_rule32 is loaded, its code-block tools become available — notably rule32_filing_assembly (the HITL-gated mutation). The read-only flaring_watch skill reuses these code-block implementations under the distinct tool names flaring_volume_status and emissions_screening.
Known open regression: the Rule 32 filing path can 500 on the 25-superstep recursion limit
after the sonnet-5 model bump (docs/specs/R40b-rule32-filing-recursion-500.md).
Related Forms and Regulations
| Form | Full Name | Purpose |
|---|---|---|
| R-32 | Application for Exception to Statewide Rule 32 | Primary application for flaring/venting authorization |
| PR | Monthly Production Report | Monthly filing that includes gas disposition (flared, vented, sold) — its own form_pr pack |
| Rule | Scope | Relevance |
|---|---|---|
| OOOOb | New and modified sources after Nov 15, 2021 | Methane emission limits — the separate epa_oooob pack (the fifth installed pack) |
| GHGRP Subpart W | Facilities exceeding 25,000 MT CO2e/year | Annual greenhouse-gas reporting for petroleum and natural gas systems |
Disposition Codes
| Code | Meaning | Regulatory Impact |
|---|---|---|
| 10 | Flared (burned) | Requires R-32 authorization above de minimis levels |
| 11 | Vented (released unburned) | Most scrutinized — direct methane emission |
Example Interaction
In a general conversation:
“We need to file a flaring exception for the Howard Unit wells. We’ve been flaring since completion and the pipeline connection isn’t ready.”
The agent pulls the flaring router, disambiguates to rrc_rule32 (filing, not monitoring), loads the skill, and then reviews authorizations and volumes, assesses gas composition and pipeline availability, estimates CO2e, assembles the R-32 package, and pauses at the pre_filing HITL checkpoint.