The Energy Marketers of America is preparing to meet with EPA regarding a 2024 regulatory change to the Method 27 test standards that affects cargo tank owners and operators picking up fuel at gasoline distribution facilities. If the rule is not revised, cargo tanks would be required to be certified as passing a 0.5-inch test in order to load gasoline at distribution facilities.

To help inform these discussions, please take a moment to respond to the following questions:

Question Title

* 1. Do you have MC-306 specification cargo tanks in active service? If so, approximately how many?

Question Title

* 2. To what standard are your MC 306 cargo tanks currently certified?

Question Title

* 3. To what standard are your DOT 406 cargo tanks currently certified?

Question Title

* 4. If your cargo tanks are currently certified to 3 inches, would certification to a 1-inch standard present operational or technical challenges? Specify type of cargo tanks.

T