August 28, 2009 1

TO 3003, Task 2, Subtask e (Other Analyses as Needed) 

Technical Directive Document No. 21 – Overfill Testing

Introduction

As part of revising the 40 CFR Part 280 regulations, EPA is evaluating whether to require 

periodic operability testing for overfill equipment. As a result, EPA needs information on 

several aspects of overfill operability testing for each of three different types of overfill 

equipment: overfill alarms, flow restrictors, and automated shutoff devices. This information is 

summarized in this report and includes:

 State requirements for overfill operability testing

 Estimated costs to conduct operability testing

 Estimated pass rates for overfill equipment testing

States that Conduct or Require Overfill Operability Testing

Summary of Findings

Tables 1 and 2 present information on state requirements for operability testing or inspections for 

UST overfill equipment for all U.S. states and territories. Seventeen states were identified that 

require operability testing or inspection of overfill equipment, as shown in Table 1: States with 

Overfill Operability Requirements. The requirements vary among these states in several aspects:

 Testing requirements. While Colorado, Maine, and Montana specifically require overfill 

operability testing, the other states listed in Table 1 require inspections of overfill 

equipment, but do not specify that operability testing be conducted as part of the 

inspection. It was assumed that operability testing would occur during an overfill 

equipment inspection, therefore, Table 1 includes all states that require either testing or 

inspection of overfill equipment. Throughout the remainder of this document, the terms 

“testing” and “inspection” of overfill equipment are used synonymously. 

 Who conducts the testing. Most states with overfill testing requirements specify that the 

test be conducted by an inspector. In most states, inspectors are contractors that are 

certified or licensed by the state to conduct the testing. In other states, the requirements 

specify that owner/operators are responsible for conducting the testing. California and 

Wyoming allow both options, where either certified contractors or owner/operators 

conduct the testing. Colorado specifies that the operator must be Class A or B, whereas 

South Carolina requires Class B. 

 Frequency of testing. The frequency of overfill equipment testing required by the states 

listed in Table 1 ranges from monthly to every three years.

No information was found on overfill operability testing or inspection requirements for the 

remaining states or for the U.S. territories, as is summarized in Table 2: States without Overfill 

Operability Testing Requirements.
August 28, 2009 2

Method

To collect the state requirements information, each state’s Web site and online regulations that 

govern USTs were reviewed to identify rules or policies for overfill equipment testing. If 

information on overfill operability testing was not identified, the regulations were searched for 

the words “overfill,” “operability,” “test,” “inspect,” “alarm,” and “automatic.” For states where 

overfill testing or inspection information was identified, text excerpts of the state’s regulatory

requirements was added to Table 1: States with Overfill Operability Testing/Inspection 

Requirements. The “Notes” column in Table 1 distinguishes whether the regulation specifically

requires operability testing, or requires that the equipment be inspected or maintained. If 

information was not identified on overfill equipment testing or inspection using these searches, 

the state and a citation for the Web site searched were added to Table 2: States without Overfill 

Operability Testing/Inspection Requirements.

Estimated Costs for Operability Testing

Summary of Findings

The mean cost to conduct overfill equipment testing on UST overfill equipment was $214 per 

tank, as shown in the table below. This cost includes testing all overfill equipment for a tank. 

Respondents were not able to break down costs for each individual piece of equipment (i.e., they

could not provide a price for just inspecting an overfill alarm).

Overfill Equipment Testing Costs

Mean Median Range

Cost ($) per tank $214 $150 $75 - $375

Based on information provided by staff at 8 companies.

See Appendix for details.

Method

Estimated costs charged by contractors to conduct overfill equipment testing were collected

through telephone interviews with nine companies who conduct UST overfill equipment testing 

or inspections. These companies were identified through information received from UST 

program contacts in Mississippi, Maine, and Wisconsin. Two additional companies’ contact 

information was received from the Petroleum Equipment Institute. The companies contacted and 

their responses are included in the Appendix.

The responses included several different methods for pricing overfill equipment testing. Some 

companies price on a per tank basis, others on a per facility basis, and others scale costs 

depending on what other work they have been hired to do at the facility. Respondents were not 

able to provide prices for each individual type of overfill equipment because their customers do 

not typically hire them just to inspect one piece of equipment. Instead, the contractor usually 
August 28, 2009 3

would be hired to inspect the overfill system for a tank, possibly including multiple overfill 

devices, and therefore, they price the work on a per tank basis.

To estimate a mean cost per tank among the companies contacted, any price per facility estimates 

were converted to price per tank estimates based on the average number of tanks per facility

reported by the respondent. When facilities provided variable pricing for an overfill equipment 

inspection as a stand-alone job versus as part of other work they are doing at the facility, it was 

assumed that they would also be doing other work at the facility and the lower price was used. 

This assumption was based on input from the respondents indicating they typically inspect 

overfill equipment as part of other work they are hired to do at the facility. Note that some 

companies also charge for travel to the facility. As travel costs are highly variable, they were not 

included in the testing cost estimates.

Estimated Overfill Equipment Pass Rates

Summary of Findings

The pass rates presented below indicate the percent of equipment inspections where no problems 

were detected. The mean pass rate for overfill alarms was 79%, for flow restrictors was 81%, and 

for automatic shutoff devices was 76%, as is summarized below.

Overfill Equipment Pass Rates

Pass Rate 

(% without problems)

Equipment Type Mean Median Range

Overfill Alarm 79% 88% 25% - 95%

Flow Restrictors 81% 88% 25% - 93%

Automatic Shutoff Devices 76% 85% 25% - 93%

Overfill Alarm and Automatic Shutoff Devices estimates are based on information provided by staff

at 9 companies. See Appendix for details.

Respondents generally found it difficult to estimate pass rates for overfill equipment and stressed 

they were providing rough estimates based on their judgment and experience. One company

could not estimate rates for each type of equipment and instead provided an overall overfill 

system pass rate of 90 – 95% which encompassed all three types of equipment. The midpoint of 

this range was used in calculating the mean and median values shown above, and was applied to 

each of the three types of equipment. 

The information received on pass rates for overfill alarms and flow restrictors was consistent 

among eight of the nine respondents, all characterizing the pass rate in the range of 70% – 95%, 

however, one respondent estimated a much lower pass rate of 25%. Similarly, for automatic shut 

off devices, seven of the nine respondents estimated a pass rate of >75%, while one respondent 

estimated 50%, and another respondent estimated a 25% pass rate. Two of the companies 
August 28, 2009 4

interviewed said that while problems with flow restrictors are rare, they also are not widely used. 

One respondent provided additional input on overfill equipment pass rates, stating, “... many of 

the larger owner/operators such as the major oil companies are getting out of the retail market. 

These companies have typically been very proactive about inspecting and maintaining their 

overfill equipment and ... [this maintenance] has kept the number of issues associated with 

overfill equipment problems down... Once the "new owners" step in, it is our experience and we 

feel that unless there is some type of mandate to inspect the overfill equipment for proper 

operation with some type of frequency and this is in writing, there will be very little, if any, 

proactive inspection work such as what has been done by the major oil companies to keep their 

sites functioning properly and most likely we would expect to see this equipment eventually not 

perform as designed over time and go into disrepair.” 

Method

The information on equipment pass rates was collected during the same telephone interview with 

staff at the nine companies, as described above. 
August 28, 2009 5

Table 1: States with Overfill Operability Testing/Inspection Requirements

State Notes Test/Inspection 

Conductor

Frequency

of Testing Text Source

AK Inspection 

required. Inspector Every three years

18 AAC 78.017. Operations inspection. (a) Except as provided in (b) and (c) of this 

section, the owner or operator of a UST system shall have each UST inspected at least 

every three years to determine compliance with the release detection, spill and 

overfill prevention, and corrosion protection requirements of this chapter. Each 

inspection must be performed by an inspector who is certified under 18 AAC 78.410 and 

must include, as applicable, examination, assessment, testing, and documentation of the 

following for the UST system inspected: (1) equipment; (2) procedures; (3) operations; 

(4) maintenance; (5) recordkeeping.

http://www.dec.state.ak.us/REGULATION

S/pdfs/18%20AAC%2078.pdf

CA

Requires 

certification 

of operability 

of monitoring 

equipment, 

including 

tank 

overfill/high 

level 

sensors.

Designated 

operator or 

contractor Annually

§ 2638. Annual Certification of Monitoring Equipment.

(a) All monitoring equipment used to satisfy the requirements of this article shall be 

installed, calibrated, operated and maintained in accordance with manufacturer's 

instructions, and certified every 12 months for operability, proper operating condition, 

and proper calibration. Written records shall be maintained as required in section 2712. 

(b) Persons performing installation, repair, maintenance, calibration, or annual 

certification of monitoring equipment shall meet the requirements set forth in section 

2715, subdivision (i).

(c) Annual monitoring equipment certification shall be made on a "Monitoring System 

Certification" form (see Appendix VI).

(d) UST owners and operators shall submit a completed "Monitoring System 

Certification" form to the local agency within 30 days after completion of the inspection.

(e) The UST owner or operator shall notify the local agency at least 48 hours prior to 

conducting the installation, repair, replacement, calibration, or certification of monitoring 

equipment unless the notification requirement is waived by the local agency.

http://www.swrcb.ca.gov/ust/regulatory/do

cs/ccr_title23div3chapt16.pdf

CO Testing 

required.

Class A or B 

Operator Annually

2-7-9 Annual Operational Compliance Inspections.

(a) The designated Class A or B operator(s) shall perform an annual operational 

compliance inspection of all UST systems for which they are designated. The annual 

operational compliance inspection shall include, but is not limited to, the following: .... (3) 

Conducting functionality testing on all line leak detectors, sump sensors and 

overfill prevention equipment in accordance with manufacturers specifications to 

ensure proper installation and operation.

http://oil.cdle.state.co.us/Div%20programs

/Regs/Colorado%20Revised%20UST%20

Regs%20Aug08.pdf

ID Inspection 

required. Inspector Every three years

03. Inspections. All inspections shall be done in accordance with the provisions of 

Section 39-108, Idaho Code. At a minimum, an on-site inspection must assess 

compliance with the following: (4-2-08)...

c. Overfill prevention in place and operational;

http://adm.idaho.gov/adminrules/rules/ida

pa58/0107.pdf 

http://www.deq.state.id.us/waste/prog_iss

ues/ust_lust/ust_rules_state_fs.pdf
August 28, 2009 6

Table 1: States with Overfill Operability Requirements (continued)

State Notes Test/Inspection 

Conductor

Frequency

of Testing Text Source

MA Inspection 

required. Inspector Every three years

(P) Third-party Inspections. (1) Prior to August 8, 2010, and at a minimum once 

every three years thereafter the owner/operator of every underground storage tank 

shall at his/her expense cause said tank(s) and related piping to be inspected by a 

third-party inspector, as defined in 527 CMR 9.02...

(4) Third-party inspectors shall conduct an inspection of the following underground 

storage tank system components in accordance with the equipment manufacturers 

inspection/testing instructions and sound industry practices:...(b) Overfill prevention 

in place and operational.

http://www.mass.gov/Ador/docs/dor/UST/Regula

tions/CMR-503-2.pdf 

ME Testing 

required.

Contractor or 

Inspector Annually

(7) Overfill and spill prevention: (b) Operation, maintenance and testing of overfill 

and spill prevention equipment. All overfill and spill prevention equipment must 

be maintained to properly operate at all times while the facility is in operation, 

and in accordance with the requirements of this rule. Overfill and spill 

prevention alarms and shutoff systems must be tested at least annually and 

recalibrated, if necessary, in accordance with manufacturer's instructions. 

Testing and recalibration must be conducted by a Maine certified underground oil 

tank installer, or inspector who is also certified by the manufacturer of the equipment, 

if such manufacturer certification is available. Repairs of automatic overfill and spill 

prevention alarm and shutoff systems must be done by a Maine certified 

underground oil storage tank installer, within 30 days. A log recording all tests, 

maintenance and repairs must be maintained by the owner in accordance with 

section 5(D)(19).

http://www.maine.gov/sos/cec/rules/06/096/096c

691.doc 

MS Inspection 

required. Contractor Annually

Subpart C—General Operating Requirements, § 280.30 Operation and maintenance 

of spill and overfill prevention equipment.(d) Overfill prevention equipment 

(including any tight-fill adapters that may be in use) must be inspected and 

proper operation ensured in accordance with the following requirements:(1) 

Frequency.(i) Overfill prevention equipment installed on or after October 1, 2008, 

must be inspected for proper operation after installation and before the UST system 

receives any delivery of regulated substances and at least once every 12 months 

thereafter.(ii) Overfill prevention equipment installed before October 1, 2008, must be 

inspected for proper operation by October 1, 2009, and at least once every 12 

months thereafter.(iii) Overfill prevention equipment must be inspected whenever it is 

suspected, by visual evidence or other means, that the proper operation of the 

overfill prevention equipment may be in question.(2) Criteria. At a minimum, the 

inspection must ensure that the overfill prevention equipment:(i) Is properly installed; 

and(ii) Is properly functioning in accordance with the manufacturer’s specifications 

and any applicable code of practice listed in §280.13.Note: In the absence of 

manufacturer’s specifications or an applicable industry code or recommended 

practice, the inspection may be accomplished by removal of the equipment from the 

tank, visual examination and confirmation that the overfill device is installed at the 

correct height within the tank.(3) Records. A written record documenting the 

inspection of the overfill prevention equipment must be maintained (in accordance 

with §280.35) to demonstrate compliance with this section. These records must 

provide the results of the last two (2) inspections required in this section.

http://www.deq.state.ms.us/newweb/MDEQReg

ulations.nsf/3d9fe41da6b657cb86256d6e00638

e7a/2b4929acd771bdb286256ba5004842a3/$FI

LE/UST-2.pdf
August 28, 2009 7

Table 1: States with Overfill Operability Requirements (continued)

State Notes Test/Inspection 

Conductor

Frequency

of Testing Text Source

MT Testing 

required. Inspector Every three years

17.56.309 REQUIREMENTS FOR COMPLIANCE INSPECTIONS (1) The owner or operator 

of an underground storage tank system shall have all active underground storage tank 

systems at an individual facility inspected by a licensed compliance inspector, certified 

under this chapter, at least every three years for compliance with the operation and 

maintenance requirements of Title 75, chapter 11, part 5, MCA, and the rules adopted 

thereunder. Inspections must be completed at least 90 days before the expiration date of 

the operating permit issued pursuant to ARM 17.56.308.

(a) The inspection must include examination, assessment and documentation of compliance 

with all tank operation and maintenance requirements under 75-11-509, MCA, and rules 

adopted thereunder. The aforementioned "operation and maintenance requirements" are 

those requirements in ARM Title 17, chapter 56, subchapters 2, 3, and 4 that address the 

following categories:

(i) release prevention and detection;

(ii) spill and overfill prevention;

http://www.deq.mt.gov/dir/legal/Ch

apters/Ch56-03.pdf

NY Inspection 

required.

Owner/

Operator Monthly

§598.6 Underground Storage Systems - Testing And Inspection

(a) Testing and inspections of ancillary equipment. Beginning one (1) year from the effective 

date of these regulations, the owner and operator must inspect ancillary equipment as 

follows:

(1) Monthly inspection must be made of vents, pressure relief devices, gauges, 

alarms, overfill prevention equipment, cathodic protection monitoring equipment, other 

monitoring equipment, warning alarms and safety systems. Equipment must be visually 

inspected for cleanliness, leakage, corrosion, and operability;

http://www.dec.ny.gov/regs/4448.ht

ml#15601

OH Inspection 

required.

Owner/

Operator Annually

Operating requirements for UST systems. (B) Operation of spill and overfill prevention 

control. (4) Owners and operators shall inspect all spill and overfill prevention 

equipment annually for proper operation and evidence of deterioration.

http://www.com.state.oh.us/SFM/p

ub/bust_1301_7-9.pdf

PA Inspection 

required. Inspector Every three years

§ 245.411. Inspection frequency.

(a) Inspection of tanks. Underground storage tank owners or operators shall have their 

underground storage tank facility inspected by a certified inspector at the frequency 

established in subsections (b)—(d). The inspection must include, but not be limited to, 

release detection, assessment of the underground storage tank system and ancillary 

equipment, operation of overfill and spill prevention equipment where practicable, 

corrosion protection testing, or verification that corrosion protection is functional, and 

release prevention measures.

http://www.pacode.com/secure/dat

a/025/chapter245/subchapEtoc.ht

ml

RI Inspection 

required.*

Owner/ Operator Bi-annual

8.03 Facility Compliance - Environmental Results Program: The Environmental Results 

Program (ERP) is a mandatory, bi-annual facility compliance inspection program. (Includes 

section on overfill inspection. Also includes “Periodic Walk-Through Inspections...Overfill 

Alarm: Inspect for proper operation.”)

http://www.dem.ri.gov/pubs/regs/re

gs/waste/ustreg07.pdf

http://www.dem.ri.gov/programs/be

nviron/assist/usterp/pdf/ustwb04.p

df

SC Inspection 

required.

Class B 

Operator Monthly (e) Once each month, Class B Operators shall validate that: (6) Spill, overfill, and 

corrosion protection systems are in place and operational;

http://www.scdhec.gov/environmen

t/lwm/regs/R.61-92_part280.pdf
August 28, 2009 8

Table 1: States with Overfill Operability Requirements (continued)

State Notes Test/Inspection 

Conductor

Frequency of 

Testing Text Source

TX Inspection 

required.

Owner/

Operator

“Manufacturers 

specification”

(a) General spill and overfill control requirements. (6) The owner or operator shall 

assure that all spill and overfill prevention devices installed pursuant to subsection 

(b) of this section are maintained in good operating condition, and that such 

devices are inspected and serviced in accordance with the manufacturers' 

specifications.

http://info.sos.state.tx.us/pls/pub/rea

dtac$ext.TacPage?sl=R&app=9&p_

dir=&p_rloc=&p_tloc=&p_ploc=&pg

=1&p_tac=&ti=30&pt=1&ch=334&rl

=51

WI

"Maintained in a 

functional 

condition" 

required.

Owner/

Operator Annual

(10) SYSTEM MAINTENANCE. (a) All system equipment and components shall be 

maintained to function to the manufacturer’s original specifications and shall be 

maintained to be leak−free. (d) Leak detection, fill and overfill prevention equipment shall 

be maintained in a functional condition.

http://www.legis.state.wi.us/rsb/cod

e/comm/comm010.pdf

http://commerce.wi.gov/er/pdf/bst/C

ommCodes10_5_2_48/ER-BSTComm10-

WhatWisconsinTankOwnersNeedT

oKnowAboutTheRevisedComm10.p

df

http://www.pei.org/Portals/0/resourc

es/documents/RP900%20Appendix

%20B.pdf

WY

Inspection 

required. 

"Storage tank 

system" 

includes USTs.

Owner/

Operator or 

contractor

Annually

(e) Operator’s Annual Inspection. Storage tank system owners and/or operators shall 

provide an annual report of inspection for the entire facility. An annual inspection is to be 

conducted either by the owner, the operator, or a qualified consultant. The inspector shall 

meet all of the qualifications as a CP tester if he or she inspects a CP system. This 

inspection shall: (iv) document that all Automatic Tank Gauges (ATG), interstitial 

monitoring systems, vapor monitoring systems, or other automatic systems are 

properly calibrated and functioning. This includes a check to determine if probes are 

clean and are the proper ones for the regulated substance being stored.

http://deq.state.wy.us/shwd/stp/STP

Downloads/Chapter_17.pdf

* Rhode Island’s Environmental Results Program for USTs includes several Best Management Practices related to overfill protection equipment: 

• A qualified UST contractor should check your overfill alarm annually to make sure it is set at the proper height in the tank and that the overfill alarm activates at 90 percent of the tank 

capacity. The UST contractor should trip the alarm manually to make sure that it is functioning properly.

• A qualified UST contractor should check your automatic shutoff device to make sure that it is functioning properly and that the automatic shutoff device activates at 95% of the tank 

capacity or before the fittings at the top of the tank are exposed to fuel.

• A qualified UST contractor should check your ball float valve to make sure that it is functioning properly and that the ball float valve activates at 90% of the tank capacity or at least 30 

minutes before the tank will be overfilled.
August 28, 2009 9

Table 2: States without Overfill Operability Testing/Inspection Requirements

State Notes Text Source

AL No information 

found http://www.adem.state.al.us/regulations/Div6b/Div6VolIIeff42508.pdf

AR No information 

found http://www.adeq.state.ar.us/regs/files/reg12_final_071015.pdf

AS No information 

found http://asepa.gov/_library/documents/legal/asactitle24ch7storagetanksnew.pdf

AZ No information 

found http://www.azsos.gov/PUBLIC_SERVICES/Title_18/18-12.pdf

CT No information 

found http://www.ct.gov/dep/lib/dep/regulations/22a/22a-449(d)-1through113.pdf

DC No information 

found http://dchealth.dc.gov/DOH/cwp/view,A,1374,Q,585833,dohNav_GID,1813.asp 

DE

Requires inspection 

and verification of 

ATG equipment, 

which may or may 

not include overfill 

prevention 

equipment.

1.9.5.3 Owners and Operators shall 

have all ATGs inspected by a certified 

technician once every twelve (12) 

months as part of a preventive 

Maintenance program to minimize inservice failures. Any equipment 

malfunctions identified as a result of the 

inspection shall be rectified immediately. 

The inspection shall at a minimum include: 

1.9.5.3.1 Inspection of the ATG console 

for printer operation if so equipped; and 

1.9.5.3.2 Verification of the system setup 

values and battery backup; and 1.9.5.3.3 

Verification of the test programming; and 

1.9.5.3.4 Verification of the operability of 

all warning and alarm indicator lights and 

audible alarms;...

http://regulations.delaware.gov/AdminCode/title7/1000/1300/1351.pdf

FL No information 

found http://www.dep.state.fl.us/legal/Rules/waste/62-761.pdf

GA No information 

found http://rules.sos.state.ga.us/docs/391/3/15/05.pdf

GU No information 

found http://node.guamepa.net/regs/index.html

HI No information 

found http://hawaii.gov/health/environmental/waste/ust/pdf/ustrules.pdf

IA No information 

found http://search.legis.state.ia.us/

IL No information 

found http://www.state.il.us/osfm/PetroChemSaf/Current170code92008.pdf 

IN No information 

found http://www.in.gov/legislative/iac/T03290/A00090.PDF

KS No information 

found http://www.kdheks.gov/tanks/download/KSA_65-34.pdf

KY No information 

found

http://www.waste.ky.gov/EPPCInternet/Templates/MainTemplate_file.aspx?NRMODE=Published&NRORIGIN

ALURL=/branches/ust/RegulationsStatutesFormsandOutlines.htm&NRNODEGUID={C6C526DC-09E3-43A5-

8B0E-486D5D601181}&NRCACHEHINT=NoModifyGuest#A

LA No information 

found http://www.deq.louisiana.gov/portal/LinkClick.aspx?link=UndergroundStorageTank%2f33v11.doc&tabid=2676 

MD No information 

found http://www.dsd.state.md.us/comar/subtitle_chapters/26_Chapters.htm#Subtitle10
August 28, 2009 10

Table 2: States without Overfill Operability Testing Requirements (continued)

State Notes Text Source

MI No information found http://www.michigan.gov/documents/deq/deq-std-MUSTR_250513_7.pdf

MN No information found https://www.revisor.leg.state.mn.us/rules/?id=7150

MO No information found http://www.sos.mo.gov/adrules/csr/current/10csr/10c20-10.pdf 

MP No information found http://deq.gov.mp/artdoc/Sec7art45ID101.pdf

NC No information found http://wastenot.enr.state.nc.us/Laws.htm

ND No information found http://www.legis.nd.gov/information/acdata/pdf/33-24-08.pdf

NE

Does not specify 

what is included in a 

"monitoring system."

002. Periodic spot checks of tank 

monitoring systems shall be conducted 

by State Fire Marshal personnel.

002.01. Inspections shall cover 

monitoring systems and inventory 

control procedures....

http://www.sfm.state.ne.us/regulations/pdf/title159.pdf

NH

Requires overfill 

protection devices be 

installed to allow 

access for inspection, 

does not state a 

requirement for 

inspections.

(i) All new and replacement overfill 

protection devices shall be installed to 

allow access for inspection of proper 

operation.

Env-Wm 1401.29 Release Detection for 

Tanks Without Secondary Containment 

and Leak Monitoring. (g) equipment and 

devices shall be maintained in good 

working order at all times to continuously 

perform their original design function and 

shall be inspected and tested annually in 

accordance with the manufacturer’s 

requirements for proper operation.

http://des.nh.gov/organization/commissioner/legal/rules/documents/env-wm1400.pdf

NJ No information found http://www.state.nj.us/dep/srp/regs/ust/ustrule.pdf

NM No information found http://www.nmcpr.state.nm.us/nmac/_title20/T20C005.htm

NV No information found http://ndep.nv.gov/BCA/ust_home.htm

OK No information found http://www.occeweb.com/Divisions/PST/Forms/Rules/Chapter25.pdf

OR No information found http://arcweb.sos.state.or.us/rules/OARs_300/OAR_340/340_150.html

PR No information found http://www.gobierno.pr/NR/rdonlyres/667951D6-B109-4D68-B8CC85FC783D170B/0/ControlTanquesSoterrados.pdf

SD No information found http://legis.state.sd.us/rules/DisplayRule.aspx?Rule=74:56:01

TN No information 

found*

http://www.state.tn.us/environment/ust/act_rules.shtml

https://www.tennesseeanytime.org/osbr/ustmanual.pdf
August 28, 2009 11

Table 2: States without Overfill Operability Testing Requirements (continued)

State Notes Text Source

UT No information found http://www.undergroundtanks.utah.gov/docs/R311_81808.pdf

VA No information found http://www.deq.state.va.us/export/sites/default/tanks/pdf/usttech.pdf

VI No information found http://dpnr.gov.vi/dep/waste.htm 

VT No information found* http://www.anr.state.vt.us/dec/wastediv/ust/regs/fullUSTregs.pdf

http://www.anr.state.vt.us/dec/wastediv/ust/erp/Chapter_4.3.pdf

WA No information found http://www.ecy.wa.gov/PROGRAMS/tcp/ust-lust/tanks.html

WV No information found

http://www.legis.state.wv.us/WVCODE/22/code/WVC%2022%20%20-%2017%20%20-%20%20%206%20%20.htm

http://www.wvdep.org/item.cfm?ssid=13&ss1id=729

* Tennessee and Vermont have an Environmental Results Program for USTs that includes several Best Management Practices related to overfill protection equipment: 

• A qualified UST contractor should check your overfill alarm annually to make sure it is set at the proper height in the tank and that the overfill alarm activates at 90 percent of the tank capacity. 

The UST contractor should trip the alarm manually to make sure that it is functioning properly.

• A qualified UST contractor should check your automatic shutoff device to make sure that it is functioning properly and that the automatic shutoff device activates at 95% of the tank capacity or 

before the fittings at the top of the tank are exposed to fuel.

• A qualified UST contractor should check your ball float valve to make sure that it is functioning properly and that the ball float valve activates at 90% of the tank capacity or at least 30 minutes 

before the tank will be overfilled.
August 28, 2009 12

Appendix: Information Collected on Operability Testing for Overfill Equipment, by Equipment Type

Data Source

Costs

Overfill operability testing 

cost ($)

Company Name; 

Contact Name and Phone City, State Notes

$300 / facility

(average of a facility with three 

tanks)

UST Services, Inc.

Gary Richards, 601-606-0621 Hattiesburg, MS The visit costs $300 + the amount of miles x $1.50

$250 - $350 / tank Protanic, Inc.

Frank Grebus, 262-268-1150 Saukville, WI

Factors for cost include how many tanks the facility has 

and whether other tests are being conducted.

$75/ tank Oil Equipment Company Inc.

Kathy Kwiatkowski, 608-249-2881 Madison, WI

The cost of inspecting one tank for overfill testing is $75. 

If there are problems and it takes a while, a fee per hour 

will be added.

$150/ tank

$400 is average / facility

W. Two Plus Inc.

Tim Herdman, 817-572-9424 Kennedale, TX

$375/ tank, $600 minimum per 

facility

Northwest Pump

Steve Fletcher, 503-807-7644 Portland, OR

Declined to provide cost 

information

Gaftek, LLC

Reginald Faulkingham, 888-485-5731 Bucksport, ME

$350/tank Performance Oil Equipment

Wayne Parrish, 601-948-2042 Jackson, MS

$150 - $350/tank Crompco, LLC

Ed Kubinsky, 610-276-5914

Plymouth Meeting, 

PA

We charge $150 for an overfill verification at a facility if 

we are performing other services at the site. If we come 

out to perform an overfill verification alone it would be 

about $350.

$275 / tank Simard & Sons

Michael Simard, 207-783-0297 Lewiston, ME $275 is average rate per tank. A factor to determine cost includes how far away the facility is.
August 28, 2009 13

Data Source

Overfill Alarms Pass Rates

Pass Rate 

(% without problems)

Company Name; 

Contact Name and Phone City, State Notes

25% UST Services, Inc.

Gary Richards, 601-606-0621 Hattiesburg, MS 25% pass rate applies to all types of overfill equipment.

>75%, “most” Protanic, Inc.

Frank Grebus, 262-268-1150 Saukville, WI

85-90% Oil Equipment Company Inc.

Kathy Kwiatkowski, 608-249-2881 Madison, WI

85% W. Two Plus Inc.

Tim Herdman, 817-572-9424 Kennedale, TX

95% Northwest Pump

Steve Fletcher, 503-807-7644 Portland, OR Overfill alarms almost always pass.

90% Gaftek, LLC

Reginald Faulkingham, 888-485-5731 Bucksport, ME

70% Performance Oil Equipment

Wayne Parrish, 601-948-2042 Jackson, MS

90-95% Crompco, LLC

Ed Kubinsky, 610-276-5914

Plymouth Meeting, 

PA

5-10% of the time there is a problem with the overfill 

protection system. This would encompass all 3 forms of 

overfill equipment.

80% Simard & Sons

Michael Simard, 207-783-0297 Lewiston, ME Overfill alarms are the most problematic.
August 28, 2009 14

Data Source

Flow Restrictors Pass Rate

Pass Rate 

(% without problems)

Company Name; 

Contact Name and Phone City, State Notes

25% UST Services, Inc.

Gary Richards, 601-606-0621 Hattiesburg, MS 25% pass rate applies to all types of overfill equipment.

>75%, “most” Protanic, Inc.

Frank Grebus, 262-268-1150 Saukville, WI

75% Oil Equipment Company Inc.

Kathy Kwiatkowski, 608-249-2881 Madison, WI

99% W. Two Plus Inc.

Tim Herdman, 817-572-9424 Kennedale, TX Flow-restrictors generally always work, but they are not used that often.

90% Northwest Pump

Steve Fletcher, 503-807-7644 Portland, OR Generally pass, does not see ball floats that often anymore. 

80-90% Gaftek, LLC

Reginald Faulkingham, 888-485-5731 Bucksport, ME

80% Performance Oil Equipment

Wayne Parrish, 601-948-2042 Jackson, MS

90-95% Crompco, LLC

Ed Kubinsky, 610-276-5914

Plymouth 

Meeting, PA

5-10% of the time there is a problem with the overfill 

protection system. This would encompass all 3 forms of 

overfill equipment.

85% Simard & Sons

Michael Simard, 207-783-0297 Lewiston, ME
August 28, 2009 15

Data Source

Automatic Shutoff Devices Pass Rate

Pass Rate 

(% without problems)

Company Name; 

Contact Name and Phone City, State Notes

25% UST Services, Inc.

Gary Richards, 601-606-0621 Hattiesburg, MS 25% pass rate applies to all types of overfill equipment.

>75%, “most” Protanic, Inc.

Frank Grebus, 262-268-1150 Saukville, WI

50% Oil Equipment Company Inc.

Kathy Kwiatkowski, 608-249-2881 Madison, WI

85% W. Two Plus Inc.

Tim Herdman, 817-572-9424 Kennedale, TX

90% Northwest Pump

Steve Fletcher, 503-807-7644 Portland, OR

80-90% Gaftek, LLC

Reginald Faulkingham, 888-485-5731 Bucksport, ME

80% Performance Oil Equipment

Wayne Parrish, 601-948-2042

Jackson, MS

90-95% Crompco, LLC

Ed Kubinsky, 610-276-5914

Plymouth 

Meeting, PA

5-10% of the time there is a problem with the overfill 

protection system. This would encompass all 3 forms of 

overfill equipment.

90% Simard & Sons

Michael Simard, 207-783-0297 Lewiston, ME

All information collected August 2009