Tier II Chemical Reporting for Texas Oil & Gas Facilities
Updated March 2026 · 9 min read
Tier II chemical inventory reporting is a federal requirement under the Emergency Planning and Community Right-to-Know Act (EPCRA) that affects many Texas oil and gas facilities. If your facility stores hazardous chemicals above certain threshold quantities, you must file annual Tier II reports with TCEQ, your Local Emergency Planning Committee (LEPC), and the local fire department.
This guide explains who needs to file, what to report, and how to stay in compliance.
What Is Tier II Reporting?
Tier II reporting, required under EPCRA Section 312, is designed to provide emergency responders and the public with information about hazardous chemicals stored at facilities in their communities. The report identifies the types and quantities of hazardous chemicals present, their physical and health hazards, and their storage locations within the facility.
In Texas, TCEQ is the designated agency for receiving Tier II reports at the state level. This is separate from (but related to) EPCRA Section 302 emergency planning notifications and Section 304 emergency release notifications.
Who Must File?
Your facility must file Tier II reports if you store or use any hazardous chemical that requires a Safety Data Sheet (SDS) under OSHA's Hazard Communication standard AND the chemical is present at your facility at or above the following thresholds at any point during the calendar year:
- 10,000 pounds for most hazardous chemicals
- 500 pounds or the Threshold Planning Quantity (TPQ) (whichever is lower) for Extremely Hazardous Substances (EHS) listed under EPCRA Section 302
Common Oil & Gas Chemicals That Trigger Tier II
Many chemicals routinely present at oil and gas facilities exceed Tier II thresholds:
- Crude oil: Classified as flammable — a single 500-barrel tank holds approximately 150,000 pounds
- Natural gas and condensate: Flammable gases and liquids present in significant quantities
- Methanol: Commonly used for hydrate prevention and often stored above 10,000 pounds
- Diesel fuel: Used to power pumps, generators, and equipment
- Hydrogen sulfide (H2S): An EHS with a very low TPQ of 500 pounds — sour operations easily exceed this
- Sulfuric acid, hydrochloric acid: Used in well stimulation and treatment operations
Filing Deadline
Tier II reports are due annually by March 1, covering chemicals present at the facility during the previous calendar year. For example, the March 1, 2026 report covers chemicals present during calendar year 2025.
Where to File
You must submit Tier II reports to three recipients:
- TCEQ: File electronically through TCEQ's Tier II online reporting system
- Local Emergency Planning Committee (LEPC): Submit to the LEPC for the county where your facility is located
- Local fire department: Submit to the fire department that has jurisdiction over your facility
Many operators use EPA's Tier2 Submit software to prepare their reports, which can then be submitted electronically to TCEQ and printed for LEPC and fire department submission.
What to Include in the Report
Each Tier II report must include: the facility name, address, and contact information; the name and SDS reference for each reportable chemical; the maximum amount present at any time during the year; the average daily amount; the number of days present; the storage type and conditions (pressure, temperature); and the specific location of each chemical within the facility (building, tank, or area).
Multi-Site Considerations
Operators with multiple facilities face additional complexity. Each facility location must have its own Tier II report — you cannot aggregate chemicals across sites. For oil and gas operators with dozens or hundreds of well sites, tank batteries, and facilities, determining which sites exceed thresholds requires careful tracking of chemical inventories across all locations.
Penalties for Noncompliance
Failure to file Tier II reports can result in penalties from both federal and state agencies. EPA can assess penalties up to $69,733 per day per violation under EPCRA. TCEQ can assess additional state penalties. Beyond the financial penalties, failure to file Tier II reports means that local emergency responders may not have critical safety information about your facility — creating significant liability in the event of an emergency.
Automate Your Chemical Tracking
Tracking chemical inventories across multiple oil and gas facilities is a significant undertaking. CompliantIntel helps operators track chemical inventories, identify Tier II reporting obligations, and meet the March 1 deadline — along with every other compliance obligation.