Checklist: Is Your Oil & Gas Operation Ready for an EPA or RRC Audit?

For Texas operators, a regulatory inspection is a matter of when, not if. The difference between a routine audit and a six-figure fine is preparation: whether you can produce the right records, in the right condition, on demand. This is a self-assessment checklist. Work through each item, and if you cannot answer yes with accessible documentation to back it up, you have found a gap to close before an inspector does.

What does an inspector check, and who conducts the audit?

Two levels of authority, often overlapping. The Railroad Commission of Texas (RRC) governs day-to-day oil and gas operations and filings, while the EPA retains authority over federal statutes such as the Clean Air Act and the Resource Conservation and Recovery Act (RCRA). OSHA operates on a separate worker-safety track. An audit triggered by one agency can cascade into a multi-agency review, so the checklist below spans every domain an inspector touches: permits, air and emissions, waste, produced water and spills, stormwater, and documentation.

The audit-ready checklist

1. Permits and organizational status

An inspector first verifies your legal standing and core permits. Expired or incomplete foundational documents signal systemic problems immediately.

• RRC Organization Report (P-5): Is your P-5 current, reflecting your current officers and operating status? An outdated P-5 is an instant red flag.
• Air emission permits: Do you keep a master file of all active air permits, with permit number, issue date, and operating conditions retrievable on demand?
• SPCC plan certification: Is your SPCC plan PE-certified, reviewed within the last five years, and on-site? It applies to any facility with over 1,320 gallons of aboveground oil storage and is one of the most frequently cited violations.
• OSHA documentation: Are safety procedures, training records, and incident logs (OSHA 300) maintained and accessible?

2. Air quality and emissions

The EPA aggressively enforces methane and VOC standards under the Clean Air Act. You must be able to prove that monitoring and control equipment works as permitted.

• NSPS Quad O (OOOO/OOOOa/OOOOb/OOOOc): Are your facilities correctly identified under the applicable subpart, with required controls (vapor recovery units, combustors) installed, operational, and inspected on schedule?
• LDAR: Is your Leak Detection and Repair program documented, with inspection schedules, OGI or Method 21 calibration records, leak tags and logs, and proof of timely repairs?
• Flaring and combustion devices: Are combustion efficiency, pilot presence, and flow-rate data logged to prove devices meet permit limits (often 98 percent destruction efficiency)?

3. Waste management

Improper waste characterization and recordkeeping are a primary source of EPA violations.

• RCRA characterization: Has every waste stream been characterized as hazardous or non-hazardous, with lab analysis on file to defend each determination?
• Used oil (40 CFR Part 279): Are containers labeled "Used Oil," stored with secondary containment, and manifested for every off-site shipment?
• NORM: Are procedures for identifying and managing Naturally Occurring Radioactive Material defined, followed, and documented through disposal?

4. Produced water and spills

Produced water is the largest-volume stream, and spills are the most visible failures during an inspection.

• Disposal records: Can you document that produced water is disposed of through permitted injection wells or approved recycling, with mechanical integrity test records for disposal wells?
• Secondary containment: Is containment sized to hold the largest tank plus freeboard, and free of erosion, cracks, or gaps? This is a common RRC Statewide Rule 8 and SPCC citation.
• Spill reporting: Do your procedures meet RRC Rule 91 reporting thresholds and timelines, with a documented chain from discovery to Form H-8?

5. Stormwater

• SWPPP: Do sites requiring stormwater coverage under the Texas Pollutant Discharge Elimination System (TPDES) have a current Stormwater Pollution Prevention Plan on file?
• Inspections: Are the required stormwater inspections completed and documented, including the annual comprehensive inspection?

6. Documentation and recordkeeping

An audit is won or lost on the strength and accessibility of your records. An inspector assumes that an action not documented did not happen.

• Centralized access: Can you produce any requested permit, manifest, inspection log, or training certificate within one hour? A fragmented, paper-based system scattered across field offices is a critical vulnerability.
• Data integrity: Are records complete, legible, protected from alteration, and backed up? Handwritten field tickets full of errors invite scrutiny.
• Retention: Does your retention policy meet or exceed every applicable rule? Most environmental records must be kept 3 to 5 years, and some permit conditions require longer.

How often should you run a self-audit?

Quarterly is the practical standard for staying inspection-ready. Because RRC field inspections are unannounced and the EPA can arrive at any time, a facility that only checks its records once a year is almost always caught with a stale permit, a missed LDAR survey, or a gap in the manifest trail. A short quarterly walk through this checklist keeps small issues from becoming citations.

How Tektite helps

Running this checklist honestly often surfaces gaps that are hard to see from the inside. Tektite provides third-party environmental compliance audits that assess your facilities against the same items an inspector uses, then hand you a prioritized list of what to fix and in what order. If you would rather find the gaps yourself than have an auditor find them for you, that is the place to start.