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Cindy Vo [EH] From: Phillips, Edward P <Edward.Phillips@BNSF.com> Sent: Tuesday, May 12, 2015 2:07 PM To: Cindy Vo [EH] Cc: Blackshire, Marisa; Clift, Michael E; Fiffick, Laura Subject: RE: Return to Compliance: Hazardous Waste Inspection for 801 Diamond Street Facility on 6/27/2013 Attachments: 0000000122.0000002255.transmittal.55686674.Calwa_Sept_2014_HazMatShed jpg; CUPA RTC 051215.pdf Hello Ms. Vo, Thank you for your email. I must say that I am a little confused by the generator status information you mentioned in your email. The manifest dated January 10, 2012 was for waste accumulated over the previous 180 days. Once that waste left the facility, there was no waste on site. The next manifest, dated July 2, 2012, was for 50 gallons of used oil. The final manifest dated July 6, 2012, was for 400 pounds of oil debris and 330 gallons of oily water. This last manifest was an episodic generation due to an emergency release from a locomotive, and not from any routine or fixed waste stream practices located at the facility. The routine waste stream between January 10 and July 2 generated an average waste of 62 pounds per month (50 gallons X 7.45 pounds/6 months). I am unaware of any DTSC or EPA guidance that uses an average to determine generator status. The guidance that I have found states that a facility's generator status can change from month to month, which means that if the episodic generation on July 6 is excluded, then the facility generates less than 220 pounds of hazardous waste per month. If the episodic generation on July 6 is included, then the facility's generator status changed only for the month of July. Obviously, complying with changing requirements from month to month isn't always practical. That is why BNSF has decided to conduct weekly inspections of its hazardous waste and to follow the other requirements for SQG at all its CESQG facilities, including this one. We have installed threaded funnels on the used oil drums and latching lids on the aerosol cans and drained used oil filters drums. We are also ensuring that the hazardous waste labels are completely filled out, including accumulation start date and physical state and hazardous properties (see attached photograph). Based upon our status as a CESQG, I am not sure that I need to submit the RTC, however, I have completed it and attached it for your review should you still require it. I hope this resolves the outstanding issues for this inspection. Please do not hesitate to contact me at 909-266-3518 should you have any questions or like to discuss this matter further. Sincerely, 10411 ^ From: Cindy Vo [EH] [mailto:cvo@sicehd.com] Sent: Wednesday, April 29, 2015 9:33 AM To: Phillips, Edward P Subject: Return to Compliance: Hazardous Waste Inspection for 801 Diamond Street Facility on 6/27/2013 Good Morning Edward Phillips, Thank you for submitting your statement for the hazardous waste inspection conducted on 6/27/2013 by Jeffrey Wong. Based on the amount, an average of approximately 167kg/month, this facility generated in 2012, it is not classified as a Conditionally Exempt Small Quantity Generator (CESQG). Thus, the CESQG regulations does not apply to this facility. See attachments 1,2, and 3 for manifests of hazardous waste generated in 2012 at this facility.