Texas RRC Compliance

The RRC's Operational Reach

The Texas Railroad Commission regulates far more than drilling permits and production reports. Through its Statewide Rules, the RRC sets operational requirements for well integrity, spill prevention and reporting, produced water disposal, waste management, secondary containment, pipeline safety, and site remediation. An operator can have every form filed on time and still be in violation of the Statewide Rules based on field conditions at their facilities.

RRC field inspectors operate on an unannounced basis. When they arrive at a facility, they are evaluating the physical condition of your operation against the applicable Statewide Rules, not reviewing your filing history. Gaps between what your paperwork says and what exists in the field are the most common source of citations and enforcement actions.

Tektite's RRC compliance work focuses on that gap. We audit your facilities against current Statewide Rule requirements, identify conditions that would constitute violations under RRC inspection protocols, and help you correct them before an inspector does.

What RRC Field Compliance Covers

Statewide Rule Audits

The RRC's Statewide Rules govern a wide range of operational conditions that are evaluated by inspectors in the field. Key rules that generate the most violations for Texas operators include Rule 8 (E&P waste management and disposal), Rule 13 (well casing and cement requirements), Rule 14 (plugging of wells), Rule 78 (oil and gas pipeline standards), and Rule 91 (oil spill reporting). Tektite conducts facility audits against these rules to identify non-compliant conditions before they become citations.

Spill Reporting Compliance

RRC Statewide Rule 91 requires immediate verbal notification to the RRC district office for spills of crude oil over five barrels, or any spill that reaches a watercourse regardless of volume. A written Form H-8 report must follow within 10 days. These timelines are strict, and failures to report — or reports with incomplete information — are independently citable violations on top of the spill itself.

Tektite maintains spill response and reporting procedures for our clients that satisfy both RRC Rule 91 and EPA notification requirements simultaneously, so that a spill event triggers the right calls to the right agencies within the required timeframes.

Notice of Violation Response

A Notice of Violation (NOV) from the RRC is the formal start of an enforcement proceeding. The operator must respond within the specified timeframe — typically 20 days — with a corrective action plan or a request for a hearing. How that response is written and what commitments it contains affects both the penalty outcome and the timeline for resolving the violation.

Tektite assists operators in preparing NOV responses that are accurate, specific, and defensible. We identify the root cause of each cited condition, document the corrective actions taken or planned, and communicate with RRC district staff on your behalf. Where violations have cascading effects (a spill that also triggered an SPCC plan deficiency, for example), we coordinate the response across all cited items.

Notice of Responsibility and Site Remediation

A Notice of Responsibility (NOR) is issued when the RRC requires an operator to assess and remediate a contaminated site. NOR response is more complex than an NOV — it involves site assessment, remediation planning, RRC-required reporting milestones, and eventual closure verification. Operators who do not respond to an NOR within required timeframes can have their Certificate of Compliance severed and face escalating penalties.

Tektite manages NOR response from initial assessment through closure, coordinating the environmental fieldwork, RRC documentation, and remediation contractor oversight required to move the site to a regulatory no-further-action determination.

RRC Inspection Readiness

RRC inspections are unannounced. An operator whose field personnel do not know what inspectors look for, where documentation is kept, or how to respond during an inspection is at a significant disadvantage. Tektite prepares operators for RRC field inspections by auditing the facility conditions inspectors evaluate, training field personnel on inspection protocols, and confirming that required records are current, accessible, and organized.