Does each well pad need its own Tier II report?

Generally yes, if it holds hazardous chemicals above thresholds. Separate, non-contiguous sites are typically separate facilities, including unmanned sites.

How should crude oil be reported?

Crude oil is a mixture. It can be reported as a whole or by its hazardous components, and its components need to be identified correctly from the SDS. Some states have specific guidance for crude and condensate, so check your state's rules.

Does natural gas in our pipelines count?

Gas actually moving through transmission or distribution pipeline transport is exempt. That exemption doesn't reach the facility itself, though: on-site process piping and equipment are still reportable, along with anything in storage tanks -- it's specifically transportation that's excluded, not everything with "pipe" in the name.

What about hydrogen sulfide?

Hydrogen sulfide is an extremely hazardous substance with a much lower threshold than most chemicals. How H₂S in sour crude or gas should be accounted for depends on the product and your state's guidance.

Do drilling chemicals count if they're only on site for a few weeks?

Yes. Tier II reports the maximum amount present at any time during the year, so temporarily staged chemicals count if they exceed thresholds.

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Oil and gas

Tier II reporting for oil and gas, one site at a time and all at once

Oil and gas operators report more facilities than almost anyone: well pads, tank batteries, compressor stations and gas plants, many of them unmanned. Each one needs accurate hydrocarbon and chemical quantities, and petroleum SDSs are some of the hardest to read. NeoTech handles all of it across your whole portfolio.

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Where the chemicals are in oil and gas operations

Production sites and tank batteries

Crude oil and condensate in storage tanks
Natural gas liquids and propane
Produced water in tanks

Treating and processing

Methanol for hydrate control
Glycol for gas dehydration
Amines for gas sweetening
Hydrogen sulfide scavengers
Corrosion, scale and paraffin inhibitors

Drilling and completions

Drilling fluid additives, acids and completion chemicals, often staged temporarily

Equipment and support

Compressor and engine lube oil
Diesel for generators and equipment
Lead-acid batteries for site power and controls

Four places oil and gas reports go wrong

Losing count of facilities

Separate, non-contiguous sites are usually separate facilities, and each is checked against thresholds on its own. A portfolio can mean hundreds of reports.

Misreading petroleum SDSs

Crude oil and condensate are complex mixtures with components such as benzene that carry their own classifications. Getting the components right changes what's reported.

Forgetting temporary chemicals

Drilling and completion chemicals staged for a few weeks still count if they exceed thresholds while on site.

Assuming everything in a pipe is exempt

Pipeline transportation is exempt from Tier II, but storage tanks and chemicals at the site are not.

How NeoTech handles it

Built for large portfolios. Set up each site once and track status and deadlines across every facility.

State requirements, checked for you. Oil-producing states often have their own requirements for how sites are identified and reported. NeoTech checks each site against its state's rules.

Petroleum SDS extraction. NeoTech's AI extracts and indexes hazard data from SDSs, including complex petroleum substances and their components.

Totals combined by chemical. Inventory is combined by CAS number across products and locations within each facility, then compared against the correct threshold, including lower thresholds for extremely hazardous substances like hydrogen sulfide.

Deadlines on the calendar. Reminders for Section 302 notifications, Section 311 SDS submissions and the March 1 Tier II deadline.

Reports in your state's format. Submission-ready .t2s packages for Tier2 Submit, E-Plan exports and more.

Or let us file for you. NeoTech can submit on your behalf to the SERC, LEPC and fire department.

State rules

Tier II requirements differ by state. See our state guides below, or browse every state we cover.

See every state's Tier II requirements →

Frequently asked questions

Does each well pad need its own Tier II report?: Generally yes, if it holds hazardous chemicals above thresholds. Separate, non-contiguous sites are typically separate facilities, including unmanned sites.
How should crude oil be reported?: Crude oil is a mixture. It can be reported as a whole or by its hazardous components, and its components need to be identified correctly from the SDS. Some states have specific guidance for crude and condensate, so check your state's rules.
Does natural gas in our pipelines count?: Gas actually moving through transmission or distribution pipeline transport is exempt. That exemption doesn't reach the facility itself, though: on-site process piping and equipment are still reportable, along with anything in storage tanks -- it's specifically transportation that's excluded, not everything with "pipe" in the name.
What about hydrogen sulfide?: Hydrogen sulfide is an extremely hazardous substance with a much lower threshold than most chemicals. How H₂S in sour crude or gas should be accounted for depends on the product and your state's guidance.
Do drilling chemicals count if they're only on site for a few weeks?: Yes. Tier II reports the maximum amount present at any time during the year, so temporarily staged chemicals count if they exceed thresholds.

Hundreds of sites, one reporting process

Tell us about your operations and we'll show you how NeoTech takes every site from inventory to filed report.

Talk to us about your sites