For Texas operators, an approved drilling permit is the beginning of regulatory engagement, not the end of it. The Railroad Commission of Texas (RRC) governs your operation from spud to plugging through its Statewide Rules, and those rules, not the permit, are where most citations come from. This guide covers what the RRC actually regulates, the key Statewide Rules that apply to your wells, and how they interact with the EPA and OSHA.
What is the Texas Railroad Commission (RRC)?
The RRC is the state agency with primary regulatory jurisdiction over the oil and gas industry in Texas. Despite the name, it no longer regulates railroads. Its authority covers exploration, drilling, production, and the intrastate pipelines that move the product, plus natural gas utilities, the LP-gas industry, and coal and uranium surface mining. Its Oil and Gas Division is specifically charged with protecting groundwater from drilling, production, and injection activities.
Just as important is what the RRC does not regulate: it has no jurisdiction over railroads, roads, oil and gas leases and agreements, pipeline easements, or royalty payments. Those are private or other-agency matters.
What are the key RRC Statewide Rules?
The Statewide Rules are codified in Title 16, Chapter 3 of the Texas Administrative Code. They govern the physical conduct of operations, and RRC field inspectors evaluate your facilities against them regardless of what your paperwork says. The table below is the short list operators encounter most.
| Statewide Rule | Governs | What it means for operators |
|---|---|---|
| Rule 8 (16 TAC 3.8) | Water protection | Handling and disposal of oil and gas waste; prohibits pollution of surface and subsurface water |
| Rule 13 (3.13) | Casing, cementing, well control | Well construction and mechanical integrity standards |
| Rule 14 (3.14) | Well plugging | Requirements and timelines for plugging inactive and abandoned wells |
| Rule 32 (3.32) | Flaring and venting | A permit (exception) is required to flare gas beyond a limited post-completion window |
| Rules 37 & 38 (3.37, 3.38) | Well spacing and density | Minimum spacing from lease lines and other wells; number of wells per unit |
| Rules 9 & 46 (3.9, 3.46) | Injection and disposal wells | Permitting and integrity for Class II saltwater disposal and enhanced-recovery injection |
| Rule 91 (3.91) | Spill reporting and cleanup | Reporting thresholds and remediation for crude oil and produced-water spills |
How do RRC rules interact with the EPA and OSHA?
The RRC is not the only agency at the table, and satisfying its rules does not satisfy the others. Air quality is the clearest example: the EPA's New Source Performance Standards (NSPS OOOO, OOOOa, and the newer OOOOb/OOOOc) impose methane and VOC controls and a Leak Detection and Repair program, while the RRC's Rule 32 governs flaring and venting. Both apply, and a single failure can draw penalties from both agencies. OSHA adds a third layer through the Process Safety Management standard, so one event such as a wellhead failure can breach RRC well-integrity rules, EPA emissions limits, and OSHA standards at the same time.
| Compliance area | Texas RRC (Statewide Rule 32) | U.S. EPA (NSPS OOOOa/b/c) |
|---|---|---|
| Primary focus | Preventing waste of natural resources; authorizing flaring and venting | Reducing methane and VOC emissions |
| Key requirement | Permit (exception) to flare beyond a limited post-completion period | LDAR program with set monitoring frequencies (e.g. semi-annual at well sites) |
| Reporting | Monthly production reports (Form PR) with flared and vented volumes | Annual reports detailing LDAR results and component-level repairs |
| Enforcement | Lease-level shut-in orders and administrative penalties | Per-day federal fines and potential consent decrees |
One newer wrinkle: the EPA granted the RRC primacy over Class VI injection wells, making the RRC the permitting authority for geologic carbon dioxide storage in Texas. That matters for operators entering carbon capture and storage, but for conventional production the day-to-day rules above are what govern.
Produced water and Class II injection wells
Disposing of produced water and oilfield waste is one of the most persistent RRC obligations. Disposal into Class II injection wells is permitted and enforced by the RRC under its UIC program, and the integrity of those wells is paramount: they require mechanical integrity testing, continuous monitoring, and accurate reporting. A failed test can trigger an RRC shut-in that halts production across a field. This sits alongside the EPA's SPCC rule for oil storage, so operators are managing two distinct water-and-waste programs at once.
| Program | Agency | Objective | Key steps |
|---|---|---|---|
| SPCC plan | U.S. EPA | Prevent oil spills from reaching navigable waters | Determine applicability by storage capacity, design secondary containment, document inspections and training, obtain PE certification |
| Class II UIC well | Texas RRC | Protect underground sources of drinking water | Permit before injection (Form H-1), establish mechanical integrity, perform periodic MITs, monitor pressure and volume, submit reports (Form H-10) |
How Tektite helps with RRC compliance
Most RRC citations come from the gap between what the paperwork says and what an inspector finds in the field. Tektite provides RRC compliance for Texas operators: auditing facilities against the Statewide Rules, keeping wells inspection-ready, and coordinating the RRC obligations with your parallel EPA and OSHA requirements so nothing falls between agencies. If you have received a notice or want to know where you stand before an inspection, a focused review is the place to start.
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Frequently Asked Questions
What does the Texas Railroad Commission regulate?
The RRC has primary jurisdiction over oil and gas exploration, drilling, and production in Texas, along with intrastate pipelines, natural gas utilities, the LP-gas industry, and coal and uranium surface mining. It does not regulate railroads, oil and gas leases, easements, or royalty payments.
What are the key RRC Statewide Rules for operators?
The Statewide Rules live in Title 16, Chapter 3 of the Texas Administrative Code. The ones operators deal with most are Rule 8 (water protection), Rule 13 (casing and cementing), Rule 14 (plugging), Rule 32 (flaring and venting), Rules 37 and 38 (spacing and density), Rules 9 and 46 (injection and disposal wells), and Rule 91 (spill reporting and cleanup).
What is the difference between the RRC and TCEQ?
The RRC regulates oil and gas exploration and production and the waste, injection, and spills that come with it. TCEQ handles air permitting and broader environmental media. The two jurisdictions overlap, and many oilfield activities answer to both agencies at once, so satisfying one does not satisfy the other. Our RRC compliance work maps both.
Does having an RRC drilling permit mean I am fully compliant?
No. A drilling permit (Form W-1) is the start of regulatory engagement, not the end. Compliance with the Statewide Rules, plus separate federal EPA and OSHA obligations, continues for the entire life of the well.
