Small Operator Compliance Checklist for Texas Oil & Gas
Updated March 2026 · 10 min read
Running a small oil and gas operation in Texas means wearing many hats — and compliance manager is one of the most important. Unlike large operators with dedicated environmental teams, small operators often rely on one or two people to navigate the full spectrum of TCEQ, RRC, EPA, and OSHA requirements.
This checklist covers the essential compliance obligations every small Texas operator needs to stay on top of. Use it as a starting point, and sign up for CompliantIntel to automate tracking for your specific permits and operations.
TCEQ Compliance Checklist
Air Quality
- Verify you have the correct air authorization — Standard Permit, Permit by Rule (PBR), or New Source Review permit — for every emissions source at your facilities
- Maintain an up-to-date emissions inventory for each facility
- File the Annual Emissions Inventory by March 1 if your facility exceeds reporting thresholds
- Report emissions events to TCEQ within 24 hours and submit follow-up reports within 2 weeks
- Submit semi-annual deviation reports if required by your permit
- Keep records of all equipment inspections, maintenance, and monitoring for at least 5 years
Water Quality
- Ensure any wastewater discharge is covered by a TPDES permit
- Submit monthly Discharge Monitoring Reports (DMRs) on time
- Maintain stormwater pollution prevention plans (SWPPPs) for all applicable facilities
- Conduct required stormwater sampling and inspections
- Report any spill that reaches or threatens waters of the state immediately
Waste Management
- Properly classify all wastes generated at your facilities (exempt vs. non-exempt, hazardous vs. non-hazardous)
- Use licensed waste transporters and maintain manifests
- Close and remediate any inactive pits within required timelines
- Maintain waste disposal records for at least 5 years
RRC Compliance Checklist
- File monthly production reports (Form P-1 for oil, P-2 for gas) by the 15th of the second month following production
- Maintain current Organization Report and update within 30 days of any changes
- Keep all well drilling permits (W-1) current before spudding
- File completion reports (W-2/G-1) within 30 days of completing or reworking a well
- Conduct and document mechanical integrity tests on injection and disposal wells as required
- Submit flaring notifications and obtain authorization under Statewide Rule 32
- Plug inactive wells or file extensions within required timelines
- Maintain financial assurance (bonds) at required levels
EPA/Federal Compliance Checklist
- Submit Tier II chemical inventory reports by March 1 to TCEQ, the LEPC, and local fire departments
- File Toxics Release Inventory (TRI) reports by July 1 if your facility exceeds reporting thresholds
- Maintain Spill Prevention, Control, and Countermeasure (SPCC) plans if you store over 1,320 gallons of oil above ground
- Comply with NSPS OOOO/OOOOa requirements for new and modified equipment (leak detection, pneumatic controllers, storage vessels)
- Monitor and report greenhouse gas emissions if your facility exceeds 25,000 metric tons CO2e annually
OSHA Compliance Checklist
- Maintain and update your written Hazard Communication program and Safety Data Sheets (SDS)
- Conduct H2S training and monitoring where hydrogen sulfide is present
- Ensure fall protection systems are in place for work at heights above 4 feet
- Maintain Process Safety Management (PSM) documentation if handling highly hazardous chemicals above threshold quantities
- Record and report workplace injuries and fatalities per OSHA requirements
- Conduct regular safety meetings and document attendance
Monthly Compliance Tasks
Beyond the annual deadlines, small operators should build these tasks into their monthly routine:
- Review and file RRC production reports
- Submit DMRs for any wastewater discharge permits
- Conduct visual site inspections at all facilities
- Check monitoring equipment calibration
- Review any open compliance items or corrective actions
- Update compliance records and files
Automate Your Compliance Tracking
This checklist covers the basics, but every operation is different. Your specific permit conditions, facility types, and locations determine exactly which requirements apply to you. Trying to track all of this in spreadsheets is a recipe for missed deadlines and violations.
CompliantIntel builds a customized compliance calendar based on your permits and operations, sends automated alerts before deadlines, and tracks your compliance status across TCEQ, RRC, EPA, and OSHA — so nothing falls through the cracks.