9VAC25-580-50(3)(a)(2) only requires a tank owner to install and operate one form of overfill prevention equipment, but DEQ is mandating that all equipment needs to be tested if more than one is installed. This makes sense if the 2 forms are a ball float and a flapper valve on a drop tube due to compatibility issues, but there is no rational for testing both an electronic overfill alarm and a mechanical flapper valve on a drop tube. Only the primary equipment should need to be tested. There are no compatibility issues with an overfill alarm and the flapper valve on a drop tube.

This requirement to test all equipment punishes the tank owner that went over and above the regulations by installing a primary method at 90% and a secondary method at 95%. The cost to remove a single drop tube that is seized due to ethanol is ~ $4000. This is a significant financial impact for equipment that is not even required. This incentivises tank owners to just meet the bare minimum of the regulations and not to go over and above for additional protection.