Saltwater Spill Cleanup in Texas (Produced Water)

Texas has no numeric cleanup rule for produced water the way Statewide Rule 91 sets 1% TPH for crude oil. Saltwater spills are handled case by case with the Railroad Commission (RRC) district office under the agency's water pollution rule. The working reference is an RRC staff field guide that was released as a draft and never formally adopted.

In practice, stop the source and recover free water right away, notify the district office, sample for chloride and electrical conductivity (EC) with background samples, and delineate to background or 3,000 mg/kg chloride. Then pick a remedy based on groundwater risk and land use: amend, flush, or dig out and replace. This is a plain-language summary, not legal advice. The district office and the surface owner have the final say on your site.

Reporting: what the rules say, and the gray area

Statewide Rule 20 requires immediate notice to the district office of any fire, leak, spill or break, followed by a letter describing the event and the volume of "crude oil, gas, geothermal resources, other well liquids, or associated products lost" (16 TAC §3.20). The RRC's accident reporting page repeats the Rule 20 notice requirement.

Saltwater is different from oil in two ways. First, Form H-8, the oil-loss report, is not used for saltwater. The RRC's reporting instructions say so directly (RRC Section I). Second, the RRC's draft field guide for produced water says Rule 20(a) does not specifically address produced water, so notice is voluntary. It still encourages operators to notify the RRC right away of significant spills, meaning more than 25 barrels or any amount that reaches groundwater or surface water. It also says any water pollution from a produced water spill, of any size, must be cleaned up (RRC draft field guide, reproduced by University Lands).

Reporting from 2023 found the gap is real. An RRC spokesperson said produced water spills must be reported. The District 8 office in Midland said companies only had to report produced water spills over 250 barrels. And the agency had never formally adopted its draft guidelines (Texas Tribune / Inside Climate News). The safe move is to call the district office, write down who you spoke with, and follow what they tell you. The pollution rule itself is not optional. Since July 1, 2025 it has read: no person conducting activities regulated by the RRC may cause or allow pollution of surface or subsurface water in the state (16 TAC §4.101).

The first hours: stop it and pick it up

The draft guide puts initial response on two things: finding and stopping the source, and recovering free fluid. Prompt recovery limits how far the salt spreads. Before the scene changes, note:

• The rate and duration of the release
• Whether the water ran off overland or pooled in one spot
• Whether the soil is sandy, clayey, hard or fractured, and whether it was wet or dry
• Water wells, stock ponds, draws and farm ground nearby

Those notes tell you where the salt went. The guide's examples: a fast release pooling on sandy soil suggests saltwater is soaking down toward groundwater. A slow release spreading across clay suggests limited downward movement at first.

Be careful with fresh water. The guide says flushing can remove salt before the soil is damaged, but it should not be done without thinking about groundwater. Sometimes it is better to leave the salt in shallow soil than push it toward a water supply.

Sampling and the 3,000 mg/kg number

The draft guide recommends:

• Chloride and/or EC to map how far the spill reached, sideways and down
• Chloride, EC, sodium adsorption ratio (SAR) and exchangeable sodium percentage (ESP) to choose a restoration method
• Background samples (chloride, EC, SAR, ESP) from nearby unaffected ground, so the site is judged against its own natural salinity
• BTEX and metals where the location is sensitive

Field test kits may be used for EC and chloride. Delineate to background levels. If background is not known, delineate the soil above 3,000 mg/kg chloride. An EC of 8 mmhos/cm or less is expected not to exceed that much chloride. The guide treats soil at or below 3,000 mg/kg chloride or 8 mmhos/cm EC as generally protective of groundwater. That assumes a complete leaching or runoff pathway with 10-fold dilution in the receiving water, and site conditions can call for a different goal. If EC is measured instead of chloride, the guide gives these EC ranges by effect on plants:

If the spill stayed inside a bermed area that was lined ahead of time with an impermeable liner, and no fluid got past the liner, the guide says soil sampling is not needed.

Cleanup options

Under the draft guide, the operator picks the remedy and is responsible for making it work. The options are:

• No further remedy if sampling shows the soil's salinity and sodium are suitable for how the land is used, and it is protective of groundwater and surface water
• Amendments such as gypsum or organic matter, to restore soil structure and productivity for the intended cover or farm use
• Flushing with fresh water to push salt below the root zone, only where groundwater is not threatened, ideally where soil structure is not badly damaged. A leachate recovery system can collect the water before it reaches groundwater.
• Removal and replacement with clean soil, where salinity is too high for amendments or flushing, or where the landowner approves

The surface owner can be stricter than the RRC. University Lands, which manages Permanent University Fund land in West Texas, requires removal of affected soil over 3,000 ppm chloride. It does not allow blending or soil amendments as remediation, and it expects soil remediation to be finished within one month of the release. It also asks that every spill be reported to its representative, and it will consider other remedies where a site has unique circumstances (University Lands). Read the surface use agreement before choosing a remedy.

Excavated salty soil leaving the lease is oil and gas waste. It needs to be characterized by the generator and moved by a permitted carrier to a facility authorized to take it. Our produced water hauling guide covers the permits and paperwork.

When it reaches water

Where saltwater has soaked into permeable soil over a shallow water table, RRC staff may require monitor wells and groundwater sampling. Produced water is denser than fresh water, so it can sink to the base of a shallow aquifer. The same applies in a stock tank or pond: saltwater sinks, so the guide calls for samples near the surface, mid-depth and at the bottom where the water is deep enough. It also calls for delineating to background or 300 mg/L chloride. Without site-specific data, 300 mg/L chloride can serve as a default cleanup goal for surface water. Cut off the source and berm or trench to keep runoff out of the water.

Crude oil vs. saltwater at a glance

The crude oil side is covered in our Rule 91 spill cleanup guide.

How we help

Simba Services does environmental cleanup and site restoration, runs vac trucks to recover free saltwater, and handles dirt work and soil remediation for excavation and backfill around Midland, Odessa and the Permian Basin. We are open 24/7. When you call, have the lease and GPS location, an estimate of the barrels released, whether the source is stopped, whether it reached a draw or stock tank, whether the district office has been notified, and any surface owner requirements.