PROCESS ENGINEERING FOR TANKS & TERMINALS
Overfill Prevention & Compliance Services for Texas SB 900
By September 2027, approximately 36,000 aboveground storage tanks across Texas must be registered under the new Aboveground Storage Vessel Safety (ASVS) Program, established by Texas Senate Bill 900 (SB 900). Full compliance including an out-of-service API 653 inspection is required by September 2037, with inspections to be completed at each tank’s next regularly scheduled maintenance outage following the registration deadline.
Do you know if your tanks are compliant or exempt?
To maximize time and minimize costs, owner-operators should simultaneously plan all other compliance requirements during this planned outage.
Equity Engineering can review your tank inventory and determine applicability, exemption status, and priority compliance gaps. All during one planned outage, our bundled process engineering and compliance services will complete the API 653 inspection; the pressure relief valve (PRV) bench testing and recertification; the pressure/vacuum (P/V) vent sizing revalidation; the EPA AP-42 Chapter 7 VOC emission calculations; and the Spill Prevention, Control, and Countermeasure (SPCC) update.
Start your SB 900 assessment today!
What is Texas Senate Bill 900?
Resulting from a series of chemical fire incidents, the Texas state legislature passed Senate Bill 900 (SB 900), establishing the Aboveground Storage Vessel Safety (ASVS) Program administered by TCEQ under 30 TAC Chapter 338. The program requires atmospheric storage tanks of 21,000 gallons (500 BBL) or more at petroleum refineries, petrochemical plants, and bulk storage terminals to comply with inspection, mechanical integrity documentation, and overfill prevention requirements. While SB 900 itself is a safety and mechanical integrity regulation, the planned outage it mandates also creates the most efficient window to simultaneously address parallel VOC emission compliance obligations under federal and state air quality regulations.
SB 900 Milestone:
Program Effective
Deadline:
August 2023
Required Action:
Understand applicability
SB 900 Milestone:
Registration Deadline
Deadline:
September 2027
Required Action:
API 653 + full documentation required
SB 900 Milestone:
Full Compliance Required
Deadline:
September 2037
Required Action:
All standards met
SB 900 Milestone:
Re-Certification Cycle
Deadline:
Every 10 Years
Required Action:
Ongoing compliance
Equity Engineering – SB 900 Services
Equity Engineering integrates process engineering, API standards expertise, process safety management (PSM), and air emissions compliance under one team — eliminating the need for multiple contractors during your SB 900 outage. We deliver PE-stamped documentation that satisfies SB 900, 40 CFR Part 68, and applicable TCEQ and EPA air quality requirements.
Tank Inspection
Standards: API 653
Every covered tank must be taken out of service and inspected.
Equity Engineering provides:
- Alteration and repair evaluation
- NDE services
- Construction documentation
Registration deadline: September 2027
Overfill Prevention & PSM Documentation
Standards: API 2350 | 40 CFR 68 | NFPA 30
Automated and manual overfill prevention programs are a core SB 900 requirement.
Equity Engineering develops:
- Automated and manual overfill prevention programs
- Process Safety Management (PSM) and Risk Management Plan (RMP) program support
- Independent audits under 40 CFR 68
- Mechanical integrity documentation
- Fire protection compliance per API RP 2001 and NFPA 30
We ensure your records are complete, current, and audit ready.
Pressure/Vacuum Vent Sizing & PRV Recertification
Standards: API 2000 | API RP 2001 | 40 CFR 68
Existing P/V vent calculations must be validated against API 2000 and 40 CFR 68.65. Most facilities have significant documentation gaps in this area; Equity Engineering’s capabilities deliver immediate value.
- Validate existing P/V vent calculations vs. API 2000 and 40 CFR 68.65
- Confirm set pressures and RAGAGEP compliance
- Bench test and recertify PRVs per API RP 2001
- Full documentation for 40 CFR 68.73 mechanical integrity reports
Tank Emissions & SPCC Compliance
Standards: TCEQ 30 TAC Chapter 115 | 40 CFR 112
SB 900 API 653 inspections create the ideal outage window to simultaneously address VOC and air emissions compliance.
Equity Engineering performs:
- EPA AP-42 Chapter 7 emission calculations for working, breathing, and fill loss
- VOC air emissions compliance under TCEQ requirements
- SPCC plan development and updates, per 40 CFR 112
All documentation will be aligned to TCEQ and EPA requirements.
The Risks of Non-Compliance
Non-compliance with SB 900 and the overlapping federal regulations carries serious consequences for any facility storing hazardous materials in aboveground tanks.
- Regulatory Fines: TCEQ and EPA civil penalties can reach $25,000 per day, per violation.
- Forced Shutdown: Regulators may order operations to cease until compliance is demonstrated — an outcome far more costly than proactive engineering.
- Insurance and Liability Exposure: Non-compliant facilities face coverage exclusions, claim denial after incidents, and significantly higher premiums.
- Safety Incidents and Criminal Liability: Unvalidated pressure/vacuum vents and failed PRVs create real overpressure and fire risk. Incidents resulting from documented non-compliance can trigger criminal liability for facility management.
Frequently Asked Questions
When does SB 900 registration need to be completed?
The registration deadline for the Aboveground Storage Vessel Safety Program is September 2027. Full compliance is required by September 2037, with re-certification every 10 years thereafter.
How do I know if my tanks are covered by SB 900?
A tank is covered if it is atmospheric (below 0.5 psig), holds 21,000 gallons or more, and stores a regulated substance. Several categories are exempt, including heated tanks, LPG vessels, and crude oil production tanks. Equity Engineering can perform a full inventory review to confirm your applicability.
What happens if we miss the SB 900 registration deadline?
TCEQ and EPA civil penalties can reach $25,000 per day per violation. Regulators may also order facility shutdowns until compliance is demonstrated. Insurance coverage may be affected as well.
Can Equity Engineering handle all SB 900 compliance work?
Yes. Equity Engineering delivers API 653 inspection, API 2350 overfill prevention, P/V vent sizing, PRV recertification, emissions calculations, and SPCC plan development — all under one team, with PE-stamped deliverables.
What is the “bundled opportunity” approach?
SB 900 requires every covered tank to be taken out of service for an API 653 inspection. Equity Engineering scopes all compliance work (PRV recertification, vent revalidation, emissions calculations, and SPCC updates) to occur during that same planned outage. This reduces the total number of service mobilizations and minimizes equipment downtime.
Recommended Reading
Process Engineering & Safety Expertise
For more than 20 years, Equity Engineering has earned the reputation as consultants who deliver practical solutions that prioritize safety, reliability, and performance. Our multi-disciplinary engineering consulting team combines its extensive experience with state-of-the-art technology to help extend the lifecycle of your existing assets. We are known for our technical leadership and extensive volunteer time to complete objectives for technological development and necessary publication.
- Active members and/or volunteers on 44 API Code Committees or Subcommittees
- Active members and/or volunteers on 20 ASME Code Committees or Subgroups
- Primary authors of WRC 528, WRC 562, WRC 488, WRC 489, and WRC 490
- Lead investigators on API 579, API 571, and API 581
- Active members and/or volunteers on AMPP, ASCE, ISA, MTI, NBIC, IEEE, ISA, and NFPA
- Chairman of API 520 task force for more than 25 years
