Tier II Reporting-The Clock is Ticking

If your business stores hazardous materials than it’s that time of year again to conduct your Tier II Reporting to TCEQ, which is required by the Right to Know Act. The clock is ticking as one has 10 days to meet the March 1st reporting deadline. The TCEQ has modified their reporting system away from the EPA Tier II submit software to a new online reporting system through STEERS. If you did not attend one of their day long training sessions or have time to absorb the 216 Page Tier II User Guide chances are you will struggle this year getting the reports completed and in on time. A valid customer number (CN), regulated entity number (RN), and TXT2 number will be required. All RN’s must also have a valid address. A general description of the location used commonly for well sites will not suffice. Be sure to update the locations with Central Registry before starting the reporting process. Below I’ve outlined the process for you. Please keep in mind this is a very simple version of the 216 page user guide just to give you an idea.

• Open a STEERS Account if you don’t already have one.
• Request Tier II Core Data and Tier II Reporting Access & specific Tier II accounts. Sign STEERS Participation Agreement (SPA).
• Register the owner/operator as well as the Tier II Facilities through the Tier II Core Data Program. This needs to be done with those that have existing CN, RN, TXT2 numbers and those that need new ones created.
• Complete and submit reporting information through the Tier II Reporting application.
• Request either XML or PDF copies of the reports to be downloaded from TCEQ’s FTP web site. Send copies to appropriate Fire Departments and LEPCs.

One can always request assistance from the Tier II reporting program at Tier2Help@tceq.texas.gov or 512-239-5060. Tier II staff have been extremely helpful answering my questions and fixing things on their end, however, they are also overwhelmed. They are experiencing very high call and email volumes and it may take a while for them to get back with you to resolve any questions or issues. Luckily I have some direct contacts that have expedited my requests. If you are needing assistance with the new Tier II Reporting process please reach out to me at 941-704-8884 or vmooney@vmenvironmentalconsulting.com. I would be happy to assist in meeting the reporting deadline.