Frequent Questions

What conditions would apply to storage of emission-comparable fuel (ECF)?

Emission-comparable fuel (ECF) must be stored in tanks, tank cars, or tank trucks. These tank systems, tank cars, and tank trucks would be excluded from hazardous waste regulation if they meet conditions similar to those which apply to fuel oil (the product most analogous to ECF), along with additional conditions necessary to minimize the potential for releases to the environment accounting for the differences between ECF and fuel oil. These include:

1. certain provisions of the Spill Prevention, Control, and Countermeasures (SPCC) requirements applicable to oils under §§112.2, 112.5, 112.7, and 112.8;
2. secondary containment and leak detection requirements for tank systems, including use of liners, vaults, or double-walled tanks;
3. preparedness and prevention, emergency procedures, and response to release provisions adopted from requirements applicable to tank systems that store hazardous waste, and
4.fugitive air emission technical controls adopted from Subpart EEEE, Part 63, for organic liquids distribution (which would apply not only to any hazardous air pollutants among the oxygenates and hydrocarbons, but also would apply to the 11 oxygenates for which there would be no specification in this proposed rule and which are hazardous constituents under Resource Conservation and Recovery Act having significant vapor pressure but which are not hazardous air pollutants under the Clean Air Act).

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