SecProbe.io

December 1 1, 2012

Via E -Mail
Mr. Elijio Serrano
Chief Financial  Officer
Tetra Technologies, Inc.
24955 Interstate 45 North
The Woodlands, Texas  77380

Re: Tetra Technologies, Inc.
 Form 10-K for the Fiscal Year ended December 31, 201 1
Filed February 29, 2012
File No. 001-13455

Dear  Mr. Serrano :

We have reviewed your filing an d 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 appropriate, please tell us why in your response.

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

Form 10 -K for the Fiscal Year ended December 31, 2011

Financial Statements

Note B - Summary of Significant Accounting Policies, page F -8

Repair Costs and Insurance Recoveries, page F -15

1. We note your disclos ure stating " Hurricane damage repair efforts consist of the repair of
damaged facilities and equipment, well intervention, abandonment, decommissioning,
and debris removal associated with the destroyed offshore platforms, construction of
replacement platfo rms and facilities, and redrilling of destroyed wells. "  It appears the
activities you associate with the phrase "repair efforts"  would be more appropriately
characterized as "assessment and response efforts ," as repair s generally  have the quality

Mr. Elijio Serrano
Tetra Technologies, Inc.
December 11, 2012
Page 2

 of resto ring utility to an asset , and several of the activities that you mention are not
clearly consistent with this outcome .  Please  modify your policy note to clarify how you
determine  whether  costs associated with structures damaged by hurricanes are within th e
scope of FASB ASC 410 -20 (capitalized  and classified as asset retirement obligations ) or
FASB ASC 450  (expensed and classified as loss contingencies ).  It should  also be clear
how you determine the classification of costs associated with repairs to structures
damaged by hurricanes as either period expense or asset retirement obligations.   Please
modify disclosures elsewhere in your filing as necessary to clarify the extent to which
costs and charges associated with your hurricane damage assessment and response efforts
represent recognition of loss, construction of new assets, and repairs.

Note J - Commitments and Contingencies, page F -28

2. We note your disclosure that management does not reasonably expect the outcome of
lawsuits or other proceedings to have a material adverse impact on the financial
statements.   Please revise your disclosure to clarify whether it is reasonabl y possib le that
a material loss exceeding amounts already recognized may ha ve been incurred, and if so
either disclose an estimate of the additional loss or range of loss, or state that such an
estimate cannot be made  to comply with FASB ASC 450 -20-50-4.

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 compa ny 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.

 In responding to our comments, please provide  a written statement from the co mpany
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.

Mr. Elijio Serrano
Tetra Technologies, Inc.
December 11, 2012
Page 3

 You may contact John Cannarella, Staff Accountant, at (202) 551 -3337 or Kimberly
Calder, Assistant Chief Accountant at (202) 551 -3701 if you have any questions  regarding
comments on the financial statements and related matters.   Please contact me at (202) 551 -3686
with any other questions.

        Sincerely,

        /s/ Karl Hiller

        Karl Hiller
        Branch Chief