Rule 32 Agent

The Rule 32 Flaring Exception Agent handles Form R-32 filings for flaring and venting exceptions under Texas Administrative Code 16 TAC 3.32. It assists operators in preparing applications to the Railroad Commission of Texas (RRC) for authorization to flare or vent natural gas.

Configuration

Property	Value
Agent ID	`rule32-agent`
Agent Type	`rule_32`
Primary Model	gpt-4o
Fallback Model	gpt-4o-mini
YAML File	`agents/rule32-agent.yaml`

Regulatory Context

Rule 32 (16 TAC 3.32) governs the flaring and venting of natural gas in Texas. Key regulatory parameters:

Parameter	Value
Initial exception maximum duration	180 days
Renewal	Requires justification for extension
Infrastructure connection deadline	60 days (flagged if no plan)
Disposition Code 10	Flared gas
Disposition Code 11	Vented gas

Operators must file a Form R-32 to obtain authorization for any flaring or venting activity. The agent also tracks federal EPA requirements that overlap with state flaring rules.

Unlike Rule 37 (which deals with 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

The Rule 32 agent has access to four skills:

Skill ID	Name	Purpose
`flaring-volume-calc`	Flaring Volume Calculation	Calculate current and projected flaring volumes against Rule 32 thresholds and R-32 authorization limits. Assesses whether the operator is within permitted volume caps.
`gas-analysis`	Gas Composition Analysis	Analyze gas composition data, BTU content, and determine whether the gas is pipeline-quality or requires processing. Evaluates the technical basis for flaring.
`rule32-filing-assembly`	Rule 32 Filing Assembly	Assemble the complete Form R-32 application package, including volume data, gas analysis reports, infrastructure plans, and justification narrative.
`emissions-estimate`	Emissions Estimate	Calculate CO2-equivalent emissions using EPA emission factors for OOOOb and GHGRP Subpart W reporting. Quantifies the environmental impact of the proposed flaring.

Workflow

When a user initiates a Rule 32 flaring exception filing, the agent follows this workflow:

Identify the well/lease — gather the entity information, current flaring volumes, and existing authorization status
Assess flaring volumes — call flaring-volume-calc to analyze current volumes against R-32 thresholds and authorized limits
Evaluate gas composition — call gas-analysis to determine if the gas is pipeline-quality and assess the technical basis for flaring
Estimate emissions — call emissions-estimate to quantify CO2e impact and assess EPA OOOOb/c applicability
Assemble filing package — call rule32-filing-assembly to compile the Form R-32 application with supporting documentation
Present for review — present the draft for human review before HITL approval

HITL Checkpoints

The Rule 32 agent has two mandatory HITL checkpoints:

Checkpoint	Required	Reviewer Strategy	Description
`pre_filing`	Yes	`named_individual`	Review the assembled R-32 package before RRC submission. A specific named reviewer must approve.
`emissions_review`	Yes	`role_based`	Review EPA emissions calculations for OOOOb/GHGRP compliance. Any user with the appropriate environmental compliance role can approve.

Both checkpoints are required — the agent will not proceed to filing submission without explicit human approval.

The emissions_review checkpoint exists because EPA emission calculations have federal regulatory implications beyond the state-level RRC filing. Errors in these calculations can expose operators to federal enforcement actions under OOOOb/c and GHGRP Subpart W.

Budget

Limit	Per Execution	Per Day
Tokens	150,000	2,000,000
Cost (USD)	$10.00	$100.00

System Prompt

The agent’s system prompt establishes:

Expert identity in RRC gas flaring and venting regulations under 16 TAC 3.32
Available tools and their purposes
The 6-step R-32 filing workflow
HITL approval requirements
Rules including the 180-day initial exception maximum
Disposition code tracking (Code 10 = flared, Code 11 = vented)
EPA OOOOb/c applicability assessment based on well drilling date
60-day infrastructure connection plan flagging

Metadata


metadata:
  domain: oil_and_gas
  jurisdiction: texas
  regulator: rrc
  primary_rule: "16 TAC §3.32"
  primary_forms:
    - R-32      # Application for flaring/venting exception
    - PR        # Monthly Production Report (includes flaring volumes)
  epa_rules:
    - OOOOb     # EPA methane emission standards (new sources)
    - OOOOc     # EPA methane emission standards (existing sources)
    - GHGRP Subpart W  # Greenhouse gas reporting for petroleum systems

RRC Forms

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)

EPA Regulatory Overlap

Rule	Scope	Relevance
OOOOb	New and modified sources after Nov 15, 2021	Methane emission limits for oil and gas operations
OOOOc	Existing sources	Retroactive methane emission standards
GHGRP Subpart W	Facilities exceeding 25,000 MT CO2e/year	Annual greenhouse gas reporting for petroleum and natural gas systems

The agent automatically checks whether a well was drilled after November 15, 2021 to determine EPA OOOOb applicability. Wells drilled before this date may still be subject to OOOOc requirements.

Key Concepts

Disposition Codes

The RRC uses disposition codes on Form PR to classify how gas was handled:

Code	Meaning	Regulatory Impact
10	Flared (burned)	Requires R-32 authorization if above de minimis levels
11	Vented (released unburned)	Most scrutinized — direct methane emission, EPA OOOOb focus

Authorization Lifecycle


No authorization → File R-32 → Initial approval (up to 180 days)
  → Monitor volumes against authorized maximum
  → Approaching expiration → File renewal with justification
  → Infrastructure connected → Authorization no longer needed

Example Interaction

A typical Rule 32 workflow:

“We need to file a flaring exception for the Howard Unit wells. We’ve been flaring since the completion and the 60-day mark is approaching without pipeline connection.”

The agent would then:

Look up the Howard Unit wells and current flaring data from the knowledge graph
Calculate total flared volumes and compare against any existing authorization limits
Analyze gas composition to determine if the gas could be captured
Estimate CO2e emissions for the filing period
Assemble the R-32 application with infrastructure timeline and justification
Present for HITL review at both the pre_filing and emissions_review checkpoints