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Fax: (818) 772-1926 <br /> Email: TStanford(a)tresolutions.com <br /> 2.4 Facility Locations <br /> Figure 1 provides an overview of the BNSF facilities. Additional details regarding the general <br /> facility operations are provided in Table 2. <br /> 3.0 Requested Variance <br /> The requested variance would waive certain provisions of Chapter 6.5, H&SC and Title 22, <br /> CCR), that would otherwise require BNSF to comply with various generator requirements <br /> relating to transportation, manifesting, storage, and disposal of hazardous waste. The <br /> hazardous wastes that are the subject of this variance application are fully regulated under <br /> H&SC Section 25100, Division 20, et seq., and California Code of Regulations, Title 22, Division <br /> 4.5. <br /> California State Hazardous Waste Control Law (HWCL) pertaining to the management of used <br /> oil is generally more stringent than Federal used oil regulations. Under federal regulations, <br /> used oil is not a listed hazardous waste, but is presumed to be recycled and is required to be <br /> managed in accordance with the requirements specified in 40 Code of Federal Regulations <br /> (CFR) Part 279 (Standards for the Management of Used Oil). Under California HWCL, used oil <br /> is to be managed as a hazardous waste in accordance with the provisions specified in Article 13 <br /> commencing with H&SC Section 25250.1 until it has been shown to meet the recycled oil <br /> specifications pursuant to H&SC 25250.1(b) or is excluded from regulation as a hazardous <br /> waste pursuant to H&SC 25143.2. <br /> This variance application is submitted pursuant to H&SC Section 25143, which authorizes the <br /> Department of Toxic Substances Control (DTSC) to issue variances from the laws and <br /> regulations specified above. The hazardous waste that would be subject to this variance is <br /> used oil generated during maintenance of locomotives, rail-bound and off-road vehicles. <br /> 3.1 Conditions Required for Variance <br /> The following sections provide a general overview of the conditions that would be required for <br /> issuing a variance under the provisions of H&SC Section 25143. Where applicable, a narrative <br /> response to the conditions is provided and is intended to enhance the understanding of the <br /> potential basis for and potential conditions of the variance. <br /> 3.1.1 Exemption from Federal Hazardous Waste Regulations <br /> Historical sampling and analysis of BNSF's used oil demonstrates that it is solely a non-RCRA <br /> hazardous waste and is exempt from, or not otherwise regulated pursuant to the Federal act. <br /> 3.1.2 Suggested Department Findings <br /> The objective of the application is to provide relevant information to the Department in order to <br /> support the determination that a variance from specific statutory and regulatory requirements <br /> Hazardous Waste Variance Application 6 July 29, 2014 <br /> BNSF Railway <br /> TRC Project No. 211983 <br />