Tier II Reporting

What Tier II Reporting Is

Tier II reporting is an annual federal requirement under the Emergency Planning and Community Right-to-Know Act (EPCRA), specifically Section 312. It is also referred to as SARA Tier II reporting, after the Superfund Amendments and Reauthorization Act (SARA Title III) that created the requirement. Facilities that store hazardous chemicals at or above threshold quantities must submit a Tier II chemical inventory report each year covering the prior calendar year's storage.

The report gives emergency responders and the public information about what chemicals are stored at a facility, in what quantities, and where on site. It is not an emissions report — it is a storage inventory. For oil and gas operations, common reportable chemicals include diesel fuel, crude oil, methanol, treating chemicals, lubricants, and compressed gases.

Tier II Reporting Requirements

Under EPCRA Section 312, Tier II reporting is required for any facility that stores a hazardous chemical at or above the following thresholds at any point during the calendar year:

• Extremely Hazardous Substances (EHS): 500 pounds or the threshold planning quantity (TPQ), whichever is lower.
• All other hazardous chemicals covered by OSHA's Hazard Communication Standard: 10,000 pounds.

Most oil and gas facilities exceed at least one of these thresholds. A single large diesel storage tank, a crude oil production facility, or a location with multiple chemical storage totes can all trigger the requirement. The threshold is based on the maximum quantity stored at any point during the year, not an annual average.

Tier II reports must be submitted to three separate recipients: the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and the local fire department with jurisdiction over the facility. In Texas, TCEQ serves as the SERC and receives reports through the state's online reporting portal.

TCEQ Tier II Reporting in Texas

Texas operators submit their Tier II chemical inventory reports through TCEQ's State of Texas Environmental Electronic Reporting System (STEERS). TCEQ has specific formatting and submission requirements beyond the federal baseline, and it collects the reports on behalf of LEPCs statewide. Facilities must still separately notify their local fire department.

TCEQ also administers a Tier II training program for facilities and local emergency planners. While the training is not universally mandated, it is offered as a resource and certain TCEQ compliance programs reference it. Tektite stays current on TCEQ Tier II requirements and submits reports directly through STEERS on behalf of our clients.

Tier II Reporting Deadline

The Tier II reporting deadline is March 1 each year. Reports cover chemical storage during the prior calendar year (January 1 through December 31). There is no extension process — a report submitted after March 1 is late, regardless of the reason. Late or missing submissions can result in penalties from EPA, TCEQ, or both.

Many operators miss the deadline not because they forget the obligation, but because gathering accurate chemical inventory data across multiple facilities takes more time than anticipated. Tektite builds client reporting timelines that account for data collection, internal review, and submission well ahead of the deadline.

What We Handle

• Chemical Inventory Data Collection: We work with your operations team to identify all reportable chemicals across your facilities and compile the maximum daily storage quantities required for the report.
• Threshold Applicability Review: We confirm which chemicals and facilities trigger the reporting requirement, including chemicals that are often overlooked such as diesel in vehicle tanks or treated produced water.
• TCEQ STEERS Submission: We prepare and submit the Tier II report through TCEQ's online system, covering the state SERC submission requirement.
• LEPC and Fire Department Notification: We coordinate the required notification to your county LEPC and local fire department.
• Multi-Facility Programs: For operators with multiple locations, we manage the reporting program across all facilities under a single coordinated workflow.