Is Your Company Tier II compliant?
There are many independent oil and gas operators that may have never even heard of Tier II. Tier II is an annual report that is required to be submitted to the EPA. It is a federal requirement that each individual state must adhere to and act as a collecting agency on behalf of the EPA. It entails reporting not only at the federal, state and municipal levels, but also to local LEPCs and fire departments.
Each company, be it oil and gas, or any other commercial endeavor, must report any chemicals stored that exceed, in the weight measured in pounds, a guideline threshold. You can read more about the rules by following this link below:
It can be confusing and overwhelming if a company is not familiar and adept at observing and filing the proper TIER II documentation required by these rules. Also it must be reported through the EPA TIER II software reporting system.
STATE SPECIFIC REPORTING OF TIER II SITES
In Texas a new rule has been passed by the Texas Commission on Environmental Quality, TCEQ, that states any corporation or commercial entity must now also register each reportable facility (RN) and have a identification number assigned to that facility. In order to be able to do this you must first sign up and obtain specific “CN” – or customer numbers and “RE” – registered site numbers. This allows the TCEQ to map the location of the chemicals being stored. Which once again opens your organization up to state and federal scrutiny. If your Regulatory or HSE departments miss this mandate, it can place your company at risk for fines and other headaches that can be costly. The deadline for compliance is March 1, 2019.
If you and your organization would like more information or help in bringing your company into compliance, please contact Oil and Gas Regulatory Classes™ at 817-381-8129.