Inspectioneering
Inspectioneering Journal

Texas Storage Tank Owners: Are You Prepared for SB 900?

By Earl Crochet, Owner at Crochet Midstream Consulting, and John Evans, Business Segment Director – Oil & Gas at HUVRdata. This article appears in the September/October 2022 issue of Inspectioneering Journal.
18 Likes

Introduction

In August 2017, Hurricane Harvey hit Texas with over 40 inches of rain in a matter of days, causing massive flooding. The local impact was felt by most people and industries, including owner/operators of aboveground storage tanks (ASTs). In fact, multiple ASTs failed for various reasons that include flooding, lack of containment, and loss of power. These failures resulted in environmental contamination and injuries to the community and first responders who were exposed to the various substances released.

Fast forward to March 2019, a major incident occurred at a tank farm in Deer Park, Texas. Multiple tanks caught fire and burned for days. Locals were forced to shelter in place, and ultimately the Houston ship channel was forced to shut down due to a spill related to the incident.

The upshot to this is that the Texas legislature unanimously passed Senate Bill 900 (SB 900) which mandates that ASTs with a capacity of over 21,000 gallons must protect the ground and surface water of Texas “by adopting requirements for the design, construction, operation, and maintenance of storage vessels, with the objective of protecting groundwater and surface water resources in the event of accidents and natural disasters.” This legislation goes into effect in September 2023 and falls under the umbrella of the Texas Commission on Environmental Quality (TCEQ). While there are states that do not regulate their ASTs in this way, conventional wisdom says that they will end up in the same place as Texas.

What Does SB 900 Mandate?

Once in effect, AST owners must comply with:

  • American Petroleum Institute (API) Standard 653 “Tank Inspection, Repair, Alteration, and Reconstruction” for inspection requirements and frequency
  • API Standard 2350 “Overfill Prevention for Storage Tanks in Petroleum Facilities” for overfill prevention systems (including assessment protocols)
  • National Fire Protection Association (NFPA)-30 “Flammable and Combustible Liquids Code” or API Standard 2001 “Fire Protection in Refineries” regarding fire suppression for products with a flashpoint of over 100°F
  • New tanks must also comply with API Standard 650 “Welded Tanks for Oil Storage” and NFPA-30 location standards

These new regulations will impact an estimated 36,000 currently unregulated tanks in Texas, many of which have not been the subject of review, and thus may require a host of interventions. Asset owners have until September 1, 2027, to register their tanks and be in compliance with all parts of SB 900—including inspecting their tanks—no later than September 1, 2037.

SB 900 mandates that employees of TCEQ “shall conduct on-site inspections of the registered/certified facilities at least once every five years to determine compliance.” While the exact amount of fines for non-compliance is not known, you can expect them to be significant. For example, for assets regulated by the Federal Pipeline and Hazardous Materials Administration (PHMSA), the maximum fine is over $200,000 per day per violation with a limit per day for a related series of violations set at $2,000,000.

This content is available to registered users and subscribers

Register today to unlock this article for free.

Create your free account and get access to:

  • Unlock one premium article of your choosing per month
  • Exclusive online content, videos, and downloads
  • Insightful and actionable webinars
GET STARTED
Interested in unlimited access? VIEW OUR SUBSCRIPTION OPTIONS

Current subscribers and registered users can log in now.


Comments and Discussion

Posted by Peter Gbaraneh Awi on November 14, 2022
Good one. Peter Gbaraneh Awi API Tank inspector Log in or register to read the rest of this comment.

Add a Comment

Please log in or register to participate in comments and discussions.


Inspectioneering Journal

Explore over 20 years of articles written by our team of subject matter experts.

Company Directory

Find relevant products, services, and technologies.

Talent Solutions

Discover job opportunities that match your skillset.

Case Studies

Learn from the experience of others in the industry.

Integripedia

Inspectioneering's index of mechanical integrity topics – built by you.

Industry News

Stay up-to-date with the latest inspection and asset integrity management news.

Blog

Read short articles and insights authored by industry experts.

Expert Interviews

Inspectioneering's archive of interviews with industry subject matter experts.

Event Calendar

Find upcoming conferences, training sessions, online events, and more.

Downloads

Downloadable eBooks, Asset Intelligence Reports, checklists, white papers, and more.

Videos & Webinars

Watch educational and informative videos directly related to your profession.

Acronyms

Commonly used asset integrity management and inspection acronyms.