Rule 32 Flaring Exception Agent
The Rule 32 agent specializes in preparing flaring and venting exception applications for the Texas Railroad Commission (RRC). It handles volume calculations, gas analysis, emissions estimates, and Form R-32 assembly.
What Is Rule 32?
Rule 32 (formally 16 TAC 3.32) regulates the flaring and venting of natural gas in Texas. Under this rule, operators who need to flare (burn) or vent gas must obtain authorization from the RRC by filing a Form R-32.
Key aspects of Rule 32:
- Initial exception duration — A flaring exception can be granted for up to 180 days.
- Renewal — Exceptions can be renewed, but you must demonstrate ongoing justification.
- Disposition codes — Code 10 is used for flared gas; Code 11 is used for vented gas.
- Volume tracking — Operators must track and report monthly flaring volumes on Form PR.
What the Agent Does
The Rule 32 agent helps you through four main steps:
1. Flaring Volume Calculation
The agent calculates your current flaring volumes and compares them against:
- Your R-32 authorized maximum
- Regulatory thresholds
- The 180-day cumulative limit
It shows how much of your authorization you have used and how many days remain.
2. Gas Analysis
The agent evaluates the composition of the gas being flared to determine:
- BTU content (heating value)
- Whether the gas is pipeline-quality
- Key component percentages
This analysis is important because the RRC considers whether the gas could reasonably be captured and sold rather than flared.
3. Emissions Estimation
The agent calculates CO2-equivalent (CO2e) emissions from the flaring, using EPA emission factors. This includes:
- Total emissions in metric tons of CO2e
- Assessment of EPA OOOOb applicability (for wells drilled after November 15, 2021)
- GHGRP Subpart W reporting obligations
4. Form R-32 Assembly
The agent compiles everything into a complete Form R-32 application package, including:
- Pre-populated form fields (operator, well, lease, current volumes)
- Volume data and authorization request details
- Emissions calculations and regulatory citations
- Required attachments and supporting documentation
Example Prompts
Here are effective ways to work with the Rule 32 agent:
“File a Rule 32 flaring exception for the Mitchell Ranch lease”
“Our R-32 authorization for Howard Unit A-1H expires next month. Start a renewal.”
“Calculate emissions for Davis Ranch 1H — we are currently flaring 215 MCF per day”
“What are the Form PR reporting requirements for our active flaring authorizations?”
“Is our well drilled in 2022 subject to EPA OOOOb methane rules?”
What to Expect
When you ask the Rule 32 agent to prepare a filing:
- The agent identifies the well or lease and checks for existing R-32 authorizations.
- Status messages appear as the agent calculates volumes, analyzes gas data, and estimates emissions.
- The agent presents the assembled Form R-32 package with all data and analysis.
- A HITL banner appears indicating the filing is ready for review.
- Click Review to go to the filing queue.
The Rule 32 agent requires two human review checkpoints: a Pre-Filing Review of the complete R-32 package and an Emissions Review of the EPA emissions calculations. Both must be approved before submission.
Key Outputs
| Output | Description |
|---|---|
| Form R-32 Data | All fields for the flaring exception application |
| Volume Analysis | Current vs. authorized volumes with utilization percentage |
| Gas Composition | BTU content, component analysis, pipeline-quality assessment |
| Emissions Report | CO2e calculations using EPA factors |
| OOOOb Assessment | Whether EPA methane rules apply to this well |
| Attachments Checklist | Required documents and their status |
Important Thresholds
The agent monitors and alerts on these key thresholds:
| Threshold | Significance |
|---|---|
| 80% of authorized volume | Warning level — approaching the permitted limit |
| 150 of 180 days | Warning level — approaching the cumulative day limit |
| 60 days without infrastructure plan | The RRC expects operators to have gas capture plans within this timeframe |
| Wells drilled after Nov 15, 2021 | Subject to EPA OOOOb methane emission standards |
Tips
- Include the current daily flaring volume in MCF when requesting a filing to speed up the agent’s work.
- If you have an existing R-32 authorization number, provide it so the agent can pull the relevant details.
- For renewals, start the process at least 30 days before your current authorization expires.
- Pay special attention to the emissions review — EPA compliance is a separate obligation from RRC compliance.