Aboveground Storage Tank 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 validation and documentation; the EPA AP-42 Chapter 7 VOC emission calculations; and the Spill Prevention, Control, and Countermeasure (SPCC) update. 

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	Registration Deadline	Full Compliance Required	Recertification Cycle
Deadline	August 2023	September 2027	September 2037	Every 10 years
Required Action	Understand applicability	Register all covered ASVs with TCEQ	Complete out-of-service API 653 inspection; certify compliance with all ASVS standards	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 
• Tank inspection documentation  

Tank registration deadline: September 2027

Full compliance deadline: September 2037 

Overfill Prevention & PSM Documentation

Standards: API 2350 | 40 CFR 68

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 standing loss and working 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 regulated materials in aboveground tanks. 

• Regulatory Fines: TCEQ civil penalties for SB 900 non-compliance can reach $25,000 per day per violation. Separately, EPA civil penalties for violations of overlapping federal regulations, including 40 CFR Part 68 and applicable air quality rules, can reach $70,117 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.