Most advice about "common violations" is educated guesswork. This list is not. We analyzed the Railroad Commission of Texas's own inspection records, more than 400,000 violations statewide from August 2015 through September 2026, and pulled out the 100,376 recorded in the Permian Basin districts (08, 8A, and 7C). These are the five rules Permian operators are actually cited for most, why each happens, and what it takes to avoid it.
What are the most common RRC violations in the Permian?
Five rules account for two-thirds of all Permian violations in the RRC data:
| Rank | Rule | Violation | Violations | Share of Permian total |
|---|---|---|---|---|
| 1 | SWR 3.8(d)(1) and 4.103(a) | Unpermitted disposal of oil and gas wastes | 29,527 | 29.4% |
| 2 | SWR 3.14(b)(2) | Inactive unplugged well | 10,658 | 10.6% |
| 3 | SWR 3.3(2) | Well sign | 9,738 | 9.7% |
| 4 | SWR 3.91(d)(1) | Remediation of soil | 8,497 | 8.5% |
| 5 | SWR 3.13(a)(6)(A) | Surface control of well | 8,436 | 8.4% |
1. Unpermitted disposal of oil and gas wastes (Rule 8, now 16 TAC 4.103)
By a wide margin, this is the Permian's most-cited violation: nearly three in ten. The RRC's waste rules prohibit disposing of oil and gas wastes without authorization. That prohibition sat in Statewide Rule 8 until July 1, 2025, when the RRC replaced Rule 8 with new waste rules in 16 TAC Chapter 4, Subchapter A; it is now 4.103(a), and the counts above include citations under both numbers. In the field it usually means produced water, oil, or other fluids released or left standing on the ground, waste in an unpermitted pit, or waste handled outside an authorized disposal method. With the volumes of produced water the Permian moves every day, small leaks and poor housekeeping add up quickly. It is also where most of the serious cases sit: statewide, about 84 percent of violations the RRC classified as major fell under the waste rules.
How to avoid it: treat waste handling as a program, not a cleanup task. Inspect transfer points, tank batteries, and flowlines for leaks on a schedule, clean up releases promptly, and confirm every waste stream goes to an authorized disposal method with records to prove it. Under the 2025 rules that means a Waste Profile Form for each stream before it moves and a manifest for off-lease hauling; our guide to characterizing oilfield waste covers both.
2. Inactive unplugged wells (Statewide Rule 14)
Rule 14 governs when inactive wells must be plugged, and wells that sit idle past the allowed period without being plugged or covered by a plugging extension are the second most-cited violation. The failure is usually one of tracking: wells drift into inactive status on a large lease portfolio, and nobody owns the decision to plug or extend.
How to avoid it: keep a current inventory of inactive wells, and for each one either schedule plugging or keep the required plugging extension current before the deadline passes.
3. Well signs (Statewide Rule 3)
Rule 3 requires identification signs at lease entrances, at each well, and at tank batteries. It is the simplest rule on this list, yet signage provisions together make up 16.8 percent of Permian violations, and 27.6 percent statewide, the largest single category in the state. Signs go missing, fade, get damaged, or fall out of date when a lease or operator changes.
How to avoid it: make a sign check part of every routine lease visit, and update signs immediately after any change in operator or lease identification.
4. Soil remediation after spills (Statewide Rule 91)
Rule 91 sets the cleanup standard for crude oil spills, and failing to remediate impacted soil is cited in the Permian at roughly two and a half times the statewide rate (8.5 percent versus 3.4 percent). The pattern is a spill that was contained but never taken to documented closure: free oil removed, but contaminated soil left above the 1 percent TPH cleanup level, or no sampling to prove it was met.
How to avoid it: close every release with sampling and documentation, not just a visual cleanup. Our post-spill sampling protocol covers how to take a site to defensible closure.
5. Surface control of wells (Statewide Rule 13)
Rule 13 includes requirements for the surface control equipment on a well, the wellhead assembly that keeps the well under control at the surface. Missing, damaged, or poorly maintained wellhead components are the fifth most-cited Permian violation.
How to avoid it: include wellhead condition in routine inspections, and repair leaking or damaged surface equipment promptly rather than waiting for the next scheduled workover.
What else shows up in the Permian data?
Just outside the top five, injection wells stand out. Violations of injection permit conditions under Statewide Rule 46 make up 6.9 percent of Permian violations, about double the statewide share, which fits the basin's heavy saltwater disposal activity. Tracking every permit condition, mechanical integrity test, and injection report for each disposal well is the fix. Notably, paperwork filings such as the P-5 Organization Report do not appear in the inspection data at all; they are enforced administratively rather than through field inspections, so they are a separate risk to manage.
The federal violations enforced alongside
The RRC data covers only the Commission's own Statewide Rules. Permian operators also answer to the EPA, and the most common federal failures are enforced separately and do not appear in the numbers above:
- LDAR under NSPS Quad O: inconsistent or poorly documented leak detection and repair programs, including missed repair deadlines and incomplete logs. See how to build a compliant LDAR program.
- SPCC plans (40 CFR Part 112): plans that no longer match the facility after a change, missed inspections, and missing PE re-certification. See our SPCC self-audit guide.
- RCRA waste characterization: treating a waste stream as exempt E&P waste when it is actually hazardous, which cascades into labeling, manifest, and accumulation violations. See the RCRA E&P exemption guide.
The common thread: these are avoidable
The data makes the point plainly. Of more than 400,000 violations statewide, only 244 were classified as major. The rest are signs, fluids on the ground, idle wells, unfinished cleanups, and wellhead upkeep: failures of routine, not engineering. And the Permian is already moving the right way: even as RRC inspections there roughly tripled since 2016, the share finding a violation fell to about 4 percent in 2025, half the statewide rate. That is good news, because the fix is systematic rather than heroic: a regular lease inspection covering the rules that actually get cited, records that prove the work was done, and a periodic self-audit that catches the gap before an inspector does.
How Tektite helps
Tektite provides RRC compliance for Texas operators: auditing leases against the Statewide Rules that generate the most violations, from waste housekeeping and signage to inactive-well plugging and injection permit conditions, and coordinating the RRC obligations with the EPA requirements enforced alongside them. If you want to know which of these you are exposed to before an inspector tells you, a focused review is the place to start.
Related reading
Frequently Asked Questions
What are the most common RRC violations in the Permian Basin?
In RRC inspection records for Districts 08, 8A, and 7C from August 2015 through September 2026, the five most-cited rules were unpermitted disposal of oil and gas wastes (29.4 percent of violations), inactive unplugged wells (10.6 percent), well signs (9.7 percent), soil remediation after spills (8.5 percent), and surface control of wells (8.4 percent).
Are most RRC violations serious?
No. Of more than 400,000 violations statewide in RRC inspection data since 2015, only 244 were classified as major. Most violations are housekeeping and upkeep failures, such as missing signs, fluids on the ground, and inactive wells left unplugged, which is exactly why they are preventable with a routine inspection program.
How much are fines for RRC and EPA violations?
RRC penalties vary widely, and the Commission assesses millions of dollars in fines across operators each year. Federal Quad O non-compliance can exceed tens of thousands of dollars per day, per component. Often the bigger cost is not the fine but a shut-in order that halts production.
How do operators avoid these violations?
Because most are routine upkeep failures, a periodic lease inspection covering signage, waste housekeeping, inactive-well status, spill cleanup, and wellhead condition prevents most of them. Structured RRC compliance support closes the gaps a busy operations team tends to miss.
