I would like to see if you would revisit the requirement to remove the ball floats when they fail and we install another form of overfill protection. Can you consider going with a rule similar to NC that allows you to leave the ball float in as long as the overfill valve is below the ball float. I trust the ball float over an overfill valve any day of the week as the overfill valves are more likely to fail and also drivers tend to bypass the overfill valves. The only time I have seen a ball float fail was when it was stuck in the closed position which that prevented the site from getting a delivery. All of the ball floats we have tested have failed due to the 90% rule, not that anything was wrong with them.

Thanks for your time and consideration