1.1 Overview of BNSF Facility Operations
<br /> BNSF maintains thirty-one (31) facilities in California that support transportation logistics,
<br /> maintenance of way, and/or maintenance, fueling and repair of locomotives, railcars, rail-bound
<br /> equipment (i.e., equipment that travels exclusively on rail and is used to maintain the tracks),
<br /> and off-road "carts" and tractors. Table 1 presents a summary of the BNSF facilities in
<br /> California that have been issued an EPA Hazardous Waste Generator identification number and
<br /> may generate used oil from maintenance operations.
<br /> In general, the BNSF locations can be classified into one or more of the following categories:
<br /> Mechanical Yard, Switching Yard, or Intermodal Yard. In addition to railcar switching and
<br /> intermodal functions, maintenance and repair of locomotives and railcars is performed at
<br /> certain, but not all, facilities. The degree of maintenance and repair performed includes minor
<br /> maintenance of railcars (e.g., brake shoe replacement and lubrication of bearing housings),
<br /> emergency repairs of locomotives and railcars, and routine maintenance of locomotives (e.g.,
<br /> inspection, mechanical repairs, painting, and lubrication).
<br /> BNSF's primary locomotive maintenance facilities are located in Barstow, Commerce, and
<br /> Richmond, California. These three (3) facilities are classified as Large Quantity Generators of
<br /> hazardous waste, exclusively related to the quantity of used oil generated. The remaining
<br /> twenty-eight (28) BNSF facilities addressed in this document are considered either Small
<br /> Quantity Generators or Conditionally Exempt Small Quantity Generators. Generation of used oil
<br /> at these SQG/CESQG yards are from rail-bound and off-road equipment such as backhoes.
<br /> 1.2 BNSF Used Oil Generation and Storage
<br /> Maintenance and repair of locomotives is performed at the Barstow, Commerce, and Richmond
<br /> facilities on a daily basis. Locomotive maintenance is not performed at any of the other BNSF
<br /> facilities. However, maintenance and repair of off-road equipment, including backhoes, forklifts,
<br /> and traction equipment, is performed periodically at these other locations. In general, removal
<br /> and replacement of engine oil is performed on an as-needed basis. Maintenance of rail-bound
<br /> and off-road equipment occurs on a quarterly or semi-annual basis at a few locations (e.g.,
<br /> Victorville and Needles).
<br /> Used oil generated from the three (3) primary locomotive maintenance facilities (i.e., Barstow,
<br /> Commerce, and Richmond) is stored in above-ground storage tanks equipped with secondary
<br /> containment structures. Used oil generated at all other BNSF locations is stored in 55-gallon
<br /> drums which are also provided with secondary containment. Additional details regarding the
<br /> BNSF facilities that utilize above-ground storage tanks for storage of used oil are provided in
<br /> Sections 1.2.1 through 1.2.3.
<br /> 1.2.1 Barstow Yard
<br /> The Barstow Yard contains a total of thirty-three (33) above-ground storage tanks (ASTs) that
<br /> contain petroleum hydrocarbons (e.g, gasoline, diesel fuel, lube oil, used oil, and journal oil)
<br /> ranging in size from approximately 500-gallons to approximately 2,310,000-gallons. Five of
<br /> these ASTs (A-27, A-28, A-34, A-35, and A-38) contain used oil generated from maintenance-
<br /> related activities or recovered from the wastewater treatment system. The storage capacity of
<br /> Hazardous Waste Variance Application 2 July 29, 2014
<br /> BNSF Railway
<br /> TRC Project No. 211983
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