SecProbe.io

December 12, 2012

Via E -mail
Mr. Richard A. Hubbell
President and Chief Executive Officer
RPC, Inc.
2801 Buford Highway, Suite 520
Atlanta, Georgia 30329

 Re: RPC, Inc.
  Form 10-K for the Fiscal Year Ended December 31, 2011
Filed February 29, 2012
  File No.  1-8726

Dear Mr.  Hubbell:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten  business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appr opriate, please tell us why in your response.

 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.

Form 10 -K

Risk Factors, page 9

Our Operations may be adversely affected if we are unable to comply with regulatory and
environmental laws, page 10

1. You disclose on page 3 that pressure pumping accounted for 55% of 2011 revenues, and
that pressure pumping services include hydraulic fracturing to stimulate pro duction.  We
also note the risks you identify under the risk factor captioned “Our business has potential
liability….”  In this risk factor, you disclose that regulations curtailing exploration and
development of oil and gas fields would adversely affect y our operations by limiting
demand for your services, and also that you have the potential for environmental
liabilities.  Please add a new risk factor to disclose in necessary detail the regulatory,
financial, and/or operational risks posed to you by your provision of hydraulic fracturing

Mr. Richard A. Hubbell
RPC, Inc.
December 12, 2012
Page 2

 services, including the risks posed to you by regulations that have been adopted by states
in which you operate and/or by the federal government.

Closing Comments

We urge all persons who are responsible for the accuracy  and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts rel ating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for  the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comm ents as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

 Please contact Kevin Dougherty  at (202) 551 -3271 or in his absence, Timothy S.
Levenberg  at (202) 551 -3237 with any questions.

        Sincerely,

        /s/H. Roger Schwall

        H. Roger Schwall
        Assistant Director