## August 2 8 , 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 typ es of overfill equipment : overfill alarms, flow restrictors, and automated shutoff devices. This information is summarized in this report and includes:  S tate requirement s for overfill operability testing  Estimated c osts to conduct operability testing  Estimated pass rates for overfill equipment testing 

# Sta tes that Conduct or Require Overfill Operability T esting 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 eq uipment, as shown in Table 1 : S tates with Overfill Operability Requirements . The requirements vary among these state s in several aspects:  T esting requirements. While Colorado, Maine , and Montana specificall y 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. Itwas 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 s ynonymousl y.  Who conducts the testing. Most states with overfill testing requirements specify that the test be conducted b y an inspector. In most states, inspectors are contractors that are certified or licensed b y 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 2 8 , 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 W eb site searched were added to Table 2: States without Overfill Operability Testing

/Inspection Requirements . 

# Estimated Costs for Operability T esting 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 Me an Me dian 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 w ere 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 respon ses 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 pri ces for each individual type of overfill equipment because their customers do not ty picall y hire them just to inspect one piece of equipment. Instead, the contractor usuall y

## August 2 8 , 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 b y 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 wor k at the facility and the lower price was used. This assumption was based on input from the respondents indicating they ty pically inspect overfill equipment as part of other work they are hired to do at the facility . Note that some companies also charge fo r 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 rate s 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 8 1 %, and for automatic shutoff devices was 76 %, as is summarized below. Overfill Equipment Pass Rates Pass Rate (% without problems) Equipment Ty pe Me an Me dian Range Overfill Alarm 79% 88% 25% - 95% Flow Restrictors 8 1 % 8 8 % 2 5% - 93% Autom atic Shutoff Devices 76% 85% 25% - 93% Overfill Alarm and Automatic Shutoff Devices estimates are b ased on information provided by staff a t 9 companies. See A ppendix 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 typ e 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 ty

pe s of equipment. The information received on pass rates for overfill alarms and flow restrictors was consistent among eight of the nine respondent s, all characterizing the pass rate in the range of 70%

– 95% , however, one respondent estimated a much lower pass rate of 2 5%. 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 2 8 , 2009 4

interviewed said that whil e problems with flow restrictors are rare, they also are not widel y 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 ty pe of mandate to inspect the overfill equipment for proper operation with some ty

pe 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 likel y 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 2 8 , 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 compli ance 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 mu st include, as applicable, examination, asse ssment, 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 mon i toring 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 conditio n, 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

Op erator 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 inspe ction 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 an d operation. http://oil.cdle.state.co.us/Div%20programs /Regs/Colorado%20Revised%20UST%20 Regs%20Aug08.pdf

ID Inspection required. Inspector Every th ree 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 operati onal; 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 2 8 , 2009 6 Table 1: States with Overfill Operability Re quirements (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 fol lowing 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. Al l 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 sys tems 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 l og recording all tests, ma intenance 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 Inspectio n 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, mu st be inspected for proper operation after installation and before the UST system rece ives 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 therea fter. (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 ensu re 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 speci fications 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 tan k. (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) inspe ctions required in this section. http://www.deq.state.ms.us/newweb/MDEQReg ulations.nsf/3d9fe41da6b657cb86 256d6e00638 e7a/2b4929acd771bdb286256ba5004842a3/$FI LE/UST - 2.pdf

## August 2 8 , 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 ma intenance 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 th e 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 aforem entioned "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 e quipment. 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 eq uipmen t, 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). Th e 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 verific ation that corrosion protection is functional, and release prevention measures. http://www.pacode.com/secure/dat a/025/chapter245/subchapEtoc.ht ml

RI Inspection required. * Ow ner/ 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 W a lk- Through Inspections

... Overfill Alarm: Inspect for proper operation. ”) http://www.dem.ri.gov/pubs/regs/re gs/waste/ust reg07.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 plac e and operational; http://www.scdhec.gov/environmen t/lwm/regs/R.61 - 92_part280.pdf

## August 2 8 , 2009 8 Table 1: States with Overfill Operability Requirements (continued) State Notes Test/Inspecti on 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 device s 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 funct ional condition" required. Owner/

Operator Annual (10) SYSTEM MAINTENANCE. (a) All system equipment and components shall be ma intained to function to the manufacturer’s original specifications and shall be ma intained to be leak −free. (d) Leak detection, fi ll 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- BST Comm10 - Wh atW isconsinTankOwnersNeedT oKnowAboutTheRevisedComm10.p df http://www.pei.org/Portals/0/reso urc 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 i nspection for the entire facility. An annual inspection is to be conducted either by the owner, the operator, or a qualified consultant. The ins pector shall meet all of the qualifications as a CP tester if he or she inspects a CP sy stem. This inspection sh all: (iv) document that all Automatic Tank Gauges (ATG), interstitial monitoring sy

stems, vapor monitoring sy stems, or other automatic systems are properly calibrated and functioning. This includes a check to determine if probes are clean and are the prope r 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 tan k and that the overfill alarm activates at 90 percent of th e 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 shu toff 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 bal l float valve activates at 90% of the tank capacity or at least 30 minutes before the tank will be overfilled.

## August 2 8 , 2009 9 Table 2 : States with out 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

D E 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 A

TGs inspected by

a certified technician once every twelve (12) months as part of a preventive Ma intenance program to minimize in service failures. Any equipment ma lfunctions 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 operatio n 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 informatio n found http://search.legis.state.ia.us/ IL No information found http://www.state.il.us/osfm/PetroChemSaf/Current170code9 2008.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 - 09E 3 -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 2 8 , 2009 10 T able 2: States without Overfill Operability Testing Requirements (continued) State Notes Text Source MI No information found http://www.michigan.gov/documents/deq/deq - std - M USTR_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 sy

stems 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 n ew and replacement overfill protection devices shall be installed to allow access for inspection of proper operation. Env-Wm 1401.29 Release Detection for Tanks W ithout Secondary Containment and Leak Monitoring. (g) equipment and devices shall be maintain ed 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-wm 1400.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 htt p://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 - B8CC 85FC783D170B/0/ControlTanquesSoterrados.pdf SD No information found http://legis.state.sd.us/rules/Disp layRule.aspx?Rule=74:56:01 TN No information found* http://www.state.tn.us/environment/ust/act_rules.shtml https://www.tennesseeanyt im e.org/osbr/ustmanual.pdf

## August 2 8 , 2009 11 Table 2: States without Overfill Operability Testing Requirements (continued) State Notes Text Source UT No information found http://www.undergroundta nks.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 relate d to overfill protection equipment: • A qualified U ST 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 bal l float valve activates at 90% of the tank capacity or at least 30 minutes before the tank will be overfilled.

## August 2 8 , 2009 12

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

pe 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, W I 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, W I 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 Wa yne Parrish, 601 - 948 -2042 Jackson, MS $150 - $350/tank Crompco, LLC Ed Kubinsky, 610 -276 - 5914 Plymouth Meeting, PA Wecharge $150 for an overfill veri fication 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 2 8 , 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 Hattiesbu rg, MS 25% pass rate applies to all types of overfill equipment. >75%, “most” Protanic, Inc. Frank Grebus, 262 - 268 - 1150 Saukville, W I

85 - 90% Oil Equipment Company Inc.

Kathy Kwiatkowski, 608 - 249 - 2881 Madison, W I 85% W. Two Plus Inc.

Tim Herdman, 817 - 5 72 - 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

Wa yne 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 Lew iston, ME Overfill alarms are the most problematic.

## August 2 8 , 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% p ass rate applies to all types of overfill equipment. >75 %, “most” Protanic, Inc. Frank Grebus, 262 - 268 - 1150 Saukville, W I

75% Oil Equipment Company Inc.

Kathy Kwiatkowski, 608 - 249 - 2881 Madison, W I

99% W. Two Plus Inc.

Tim Herdman, 817 - 572 - 9424 Kenned ale, 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

Wa yne 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 encompas s all 3 forms of overfill equipment

. 85% Simard & Sons

Michael Simard, 207 - 783 - 0297 Lewiston, ME

## August 2 8 , 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, W I

50% Oil Equipment Company Inc.

Kathy Kwiatkowski, 608 - 249 - 2881 Madison, W I

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

Wa yne Parrish, 601 - 948 -204 2 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