SecProbe.io

February 18, 2011
 Via U.S. Mail and Facs imile (281) 364-4398

 Mr. Stuart M. Brightman President & Chief Executive Officer
TETRA Technologies, Inc.
24955 Interstate 45 North The Woodlands, Texas 77380
 Re: TETRA Technologies, Inc.
Form 10-K for Fiscal Year Ended December 31, 2009 Filed March 1, 2010 Forms 10-Q for Fiscal Quarters Ende d March 31, 2010 a nd June 30, 2010
Filed May 10, 2010 a nd August 9, 2010
File No. 1-13455

Dear Mr. Brightman:
We have reviewed your letter dated Oc tober 22, 2010, and we 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 advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease 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 for Fiscal Year Ended December 31, 2009

 Properties, page 24

 Oil and Gas Reserves, page 25

 1. We note your response to comment three in our letter dated September 28, 2010.  Please
confirm that in future filings you will expa nd your disclosure to include the analysis
contained in your response.

Mr. Stuart M. Brightman
TETRA Technologies, Inc. February 18, 2011 Page 2  Form 10-Q for Fiscal Quarter Ended June 30, 2010

 General

 2. We note your response to comments 16 and 17 in our letter dated September 28, 2010.
Please confirm that in future filings you will expand your disclosure to include the
content of your responses.
 Closing Comments

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 Please contact Sirimal R. M ukerjee, Staff Attorney, at (202) 551-3340 or Alexandra M.
Ledbetter, Staff Attorney, at (202) 551-3317 wi th any questions.  If you require further
assistance, you may contact th e undersigned at (202) 551-3740.
         S i n c e r e l y ,

 H. Roger Schwall Assistant Director