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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #15-0246 ([Petroleum Transport, Inc.] [Roger Kirk])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Petroleum Transport, Inc.

Individual Name: Roger Kirk

Location State: MI Country: US

View the Interpretation Document

Response text:

May 10, 2016

Mr. Roger Kirk
Petroleum Transport, Inc.
4967 Crooks Rd., Suite 201
Troy, MI 48098

Reference No. 15-0246

Dear Mr. Kirk:

This is in response to your December 21, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask for clarification of the correct test markings for a tank trailer hauling UN 1987, Alcohols, n.o.s., 3, II.  You provide a Safety Data Sheet for the mixture, which contains 60-100 percent weight Ethyl Alcohol, 1-5 percent weight Natural Gasoline and 0.1-1 percent weight Benzene. You also state that the trailer is marked with K-EPA-27, but the Ohio Public Utilities Commission cited this as incorrect.  

In accordance with 49 CFR 180.407(h)(2), cargo tanks used to transport petroleum distillate fuels that are equipped with vapor collection equipment may be leak tested in accordance with the Environmental Protection Agency’s “Method 27 – Determination of Vapor Tightness of Gasoline Delivery Tank Using Pressure-Vacuum Test” as set forth in Appendix A to 40 CFR part 60.  In a final rule under Docket No. RSPA–98–3554 (HM-213; April 18, 2003), the Research and Special Programs Administration, predecessor to the Pipeline and Hazardous Materials Safety Administration, clarified that the EPA 27 test method may be used only for petroleum fuel service.  It is the opinion of this Office that the material you describe may be used in blending with gasoline but is not, on its own, a petroleum distillate fuel.  As such, the tank trailer may not be leak tested using the EPA Method 27 and marked with K-EPA-27.

I hope this satisfies your inquiry.  Please contact this office if you need further assistance.


Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks