SecProbe.io

Mail Stop 3561
        September 13, 2007

Joseph M. Abell
Senior VP and CFO
TETRA Technologies, Inc.
25025 Interstate 45 North, Suite 600
The Woodlands, TX 77380

Re: TETRA Technologies, Inc.
 Form 10-K for the year ended December 31, 2006
Filed March 1, 2007
 File No. 1-13455

Dear Mr. Abell:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with more information so we may
better understand your disclosure.  After re viewing this information, we may raise
additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Contractual Obligations and Other Commitments, page 40

1. In future filings please revise the tabu lar disclosure to include the estimated
interest payments on long-term debt in the table or as a supplemental footnote.
See Item 303 (a)(5)(ii) of Regulation S- K and Section IV of SEC Release 33-
8350.

Joseph M. Abell
TETRA Technologies, Inc.
September 13, 2007 Page 2
Consolidated Balance Sheets, page F-4

2. If you continue to present restricted cas h please include a policy note disclosing
the nature of the restriction and intended  purpose for the funds.  We notice there is
relatively little change in the balances pr esented.  If the funds are not intended to
be used in the near term we would e xpect them to be excluded from current
assets.  See footnote 1 in paragr aph 6 of Chapter 3 in ARB 43.

Consolidated Statement of Operations, page F-6

3. Please tell us whether your rental revenues exceeded 10%  of total revenues.  See
Regulation S-X Rule 5-03.01.
Notes to Consolidated Financial Statements, page F-9
Gas Balancing, page F-12

4. If the receivable is recorded under the en titlement method please disclose if it is
valued at the lower of: (a ) the price in effect at the time of production, ( b) current
market price, or ( c) if applicable, contract price.

Environmental Liabilities, page F-14

5. You disclose that you accrue loss estima tes when both criteria in paragraph 8 of
SFAS No. 5 are met.  You do not address your  policy with respect to disclosure of
losses in excess of amounts recorded when  there is a reasonably possibility that
additional loss may have been incurre d.  See paragraphs 13 through 16 of SOP
94-6.   Please expand your policy to include this as well as disclose the underlying judgments and assumptions considered  by management when assessing the
measurement and recognition of reco rded and unrecorded environmental
remediation liabilities.  See the bullet points in Question 2 to SAB Topic 5Y.
Please include an example of your re vised disclosures in your response.

Revenue Recognition, page F-14

6. We note that you recognize revenues ba sed upon the percentage of completion
method.  Please provide the disclosure s required by Regulation S-X Rule 5-
02.3(c).

Note D – Acquisitions and Dispositions, page F-18

7. We note that you have not provided pro fo rma information with respect to your
acquisitions that you closed in the most rece nt fiscal year.  Please confirm to us

Joseph M. Abell
TETRA Technologies, Inc.
September 13, 2007 Page 3
that the pro forma results of operations for 2006 would not have been materially
different from actual historical results of operations.  See SFAS 141 paragraph 54.

 As appropriate, please amend your filing and respond to these comments within
ten business days or tell us when you will re spond.  You may wish to provide us with
marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comm ents after reviewing your amendment and
responses to our comments.

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a 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 comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 If you have any questions, please call me at (202) 551-3841.

       S i n c e r e l y ,

       M i c h a e l  M o r a n
       B r a n c h  C h i e f