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Kilgore contractors work the oldest field in East Texas. What does that mean for insurance?

Updated . Sources for every claim are listed at the end.

The short version

  • Gregg County is RRC District 6. The Railroad Commission's Kilgore office moved to 100 Bane Blvd. in Henderson in June 2024, so Kilgore no longer hosts the district office.
  • Kilgore was the center of the 1930s East Texas Field boom, where one city block held 44 wells.
  • The East Texas Field has reinjected produced salt water since 1938, so water hauling, disposal and pollution coverage are everyday issues here.
  • Gregg County also produces deeper gas from Cotton Valley and Travis Peak fields, which brings different MSAs and different well risks.
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Kilgore and the RRC: the office moved

Kilgore is in Gregg County, which the Railroad Commission places in District 6. Neighboring Rusk County is also District 6.

For years, the RRC's East Texas district office was known as the Kilgore office. On June 6, 2024, the RRC announced that the office had moved to 100 Bane Blvd., Henderson, Texas 75652. That office now serves both District 5 and District 6, and its county list includes Gregg, Rusk, Smith, Upshur, Panola, Harrison and many more.

If old paperwork, permits or MSA notice clauses still point to a Kilgore address for the RRC, update them.

For state roads, Gregg and Rusk are in TxDOT's Tyler district.

Kilgore at a glance
ItemDetail
CountyGregg (Rusk adjoins to the south)
RRC districtDistrict 6
RRC office100 Bane Blvd., Henderson (moved June 2024)
TxDOT districtTyler

The East Texas Field: old wells, close quarters

The East Texas Field was discovered with the Bradford No. 3 well in Rusk County in 1930. It covers about 140,000 acres across central Gregg, western Rusk, southern Upshur, southeastern Smith and northeastern Cherokee counties, and the Texas State Historical Association calls it "the largest and most prolific oil reservoir in the contiguous United States." The oil comes from the Woodbine sands.

Kilgore was the center of the boom. Wells were drilled in the yards of homes, and one city block contained 44 wells.

What that history means for a contractor today:

  • Old wellbores and equipment. Workover and plugging work on decades-old wells carries its own surprises. Read who takes loss of hole and underground damage in the MSA.
  • Work near homes and businesses. Locations in and near town put third-party property and bodily injury closer to your crews. Your GL limits and the operator's additional insured requirements matter more.

See well servicing insurance.

Produced water and pressure maintenance

By 1938, East Texas Field operators began a pressure maintenance program that reinjected produced salt water into the aquifer. Reinjection was later credited with preserving the field's strong water drive.

That makes produced water a constant in Kilgore work: hauling it, piping it, and disposing of it.

  • Waste hauler permit. Transporting non-hazardous oil and gas waste for hire off a lease requires an RRC waste hauler permit.
  • Pollution on the truck. A spill from a vacuum truck on a county road is an auto pollution question, not just a GL one. Ask whether your auto policy, a pollution endorsement or a separate policy picks it up.
  • Pollution at the site. Contractors pollution liability covers pollution from your operations at the job site. Salt water is a pollutant for insurance purposes.

See water hauling insurance and do I need pollution coverage to haul produced water.

Which policy answers a pollution loss

Pollution coverage by policy and scenarioMatrix of five pollution scenarios against four policy setups: GL with standard pollution exclusion, GL with time-element buyback, Contractors pollution liability, Auto with CA 99 48. A standard GL pollution exclusion answers none of them. Contractors pollution liability answers most on-site losses. Auto with CA 99 48 answers in-transit spills. Loading and unloading is a gray area.ScenarioGL, standardpollution exclusionGL withtime-element buybackContractorspollution liabilityAuto withCA 99 48Hose or line fails on location,found and reported right awayNoNarrowUsuallyNoSlow leak at the job,found weeks laterNoNoUsuallyNoTruck rolls over in transit,load of produced water spillsNoNoRead wordingUsuallySpill while loading orunloading at an SWDNoRead wordingRead wordingRead wordingRegulator orders cleanup,nobody suesNoNarrowUsuallyRead wording
General patterns, not a promise of coverage: the policy wording, reporting deadlines and endorsements decide every claim. The gray areas (loading and unloading especially) are where contractors get caught between their GL and auto policies, so get the answer in writing before the work starts.

Deeper gas in Gregg County

Gregg County is not only the old oil field. The RRC's January 2025 District 6 lease and well listing shows Gregg County gas wells in fields such as Willow Springs (Cotton Valley), Willow Springs (Travis Peak), Oak Hill (Cotton Valley), White Oak (Cotton Valley Sand) and Gladewater (Haynesville). Gregg is also on the RRC's list of Haynesville/Bossier counties.

Deeper gas wells bring different contracts. Read the MSA for:

  • who takes loss of hole, underground damage and well control costs,
  • whether your in-hole tools are covered by the operator or left with you,
  • and whether the limits you agreed to carry for the operator match what you have. Under Texas Chapter 127, mutual indemnity is limited to those agreed limits.

See do service contractors need control of well insurance and Texas oilfield anti-indemnity act.

Ice, storms and what to send us

FEMA records show Gregg County designated in the February 2021 severe winter storm disaster (DR-4586), the Hurricane Beryl disaster in July 2024 (DR-4798), and the March 2016 severe storms, tornadoes and flooding disaster (DR-4266). Ice and wind are as much a Kilgore exposure as flood.

Check freeze coverage on pumps, tanks and lines, comprehensive on parked trucks, and how your floater handles equipment on location.

What to send us: the insurance and indemnity sections of each MSA, your current certificates, your auto schedule, and any ISNetworld or Avetta rejection notice. Tell us whether you haul water and whether you work shallow oil wells, deeper gas wells, or both. Your attorney reviews the contract. A licensed insurance specialist will go over what we find.

Common questions

Is the RRC district office still in Kilgore?

No. The RRC announced on June 6, 2024 that the office moved to 100 Bane Blvd. in Henderson. It serves Districts 5 and 6.

Which RRC district covers Kilgore?

Gregg County and neighboring Rusk County are both RRC District 6.

Do I need pollution coverage to haul salt water around Kilgore?

Produced water is a pollutant for insurance purposes. If you haul it, you need pollution coverage that applies to the load in transit, and an RRC waste hauler permit if you haul for hire.

Does working old East Texas Field wells change my MSA review?

It can. Look closely at who takes loss of hole and underground damage, and at additional insured and GL limits when locations are close to homes and businesses.

Sources

  1. Railroad Commission of Texas: Kilgore office new location (June 6, 2024). Office moved to 100 Bane Blvd., Henderson; District 5 and 6 county list.
  2. Railroad Commission of Texas: Oil and gas counties by district. Gregg and Rusk in District 6, Henderson office.
  3. Texas State Historical Association: East Texas Oilfield. Discovery, extent, Woodbine sands, Kilgore boom, 44 wells in one block, 1938 salt water reinjection.
  4. Railroad Commission of Texas: District 6 oil leases and gas wells (January 2025). Gregg County fields including Willow Springs (Cotton Valley, Travis Peak) and Gladewater (Haynesville).
  5. Railroad Commission of Texas: Haynesville/Bossier Shale. Gregg on the affected county list.
  6. Railroad Commission of Texas: Oil and gas waste haulers. Waste hauler permit requirement.
  7. FEMA: Texas Severe Winter Storms (DR-4586-TX). February 11 to 21, 2021.
  8. OpenFEMA: Disaster Declarations Summaries. Gregg County designated under DR-4586, DR-4798 and DR-4266.

This page explains insurance, not law. Have your attorney review indemnity and contract language; our job is making the insurance match it.

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