Cargo Tank Hazardous Material Regulations

[12.08.2005]

When applicable, Section 180.407(h)(2) of Title 49 of the Code of Federal Regulations (CFR) Permits the use of EPA Method 27 Test as an alternative test to the leakage test for specification cargo tanks equipped with vapor collection systems used to transport petroleum distillates. Method 27 Test is the Environmental Protection Agency's (EPA) "Method 27 - Determination of Vapor Tightness of gasoline Delivery Tank using Pressure-Vacuum Test", referenced in Title 40 CFR, Part 60, Appendix A.

The Michigan Department of Environmental Quality (MDEQ), however, has adapted a Vapor Tightness Test into their promulgated rules (R336.2005) that differes from EPA Method 27 Test.

The Pipeline and Hazardous Material Safety Administration (PHMSA) is the agency within the U.S. Department of Transportation (USDOT) that is responsible for issuing hazardous materials regulations and interpretations. It is the position of RSPA that the ONLY Vapor Tightness Test that is allowable under Section 180.407 (h) is the EPA Method 27 Test, as amended. The MDEQ Test DOES NOT Qualify as a substitution leakage test under Title 49. The MDEQ Test is a stand alone, seperate Requirement from Title 49.