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Pacific Gas and Electric Company Environmental Services <br />P.O. Box 7640 <br />March 31, 2006 San Francisco, CA 94120 <br />415/973-7000 <br />Direct Dial 41b/.973- <br />Telecopy 415/973-9201 <br />Department of Toxic Substances Control <br />Program Data Management Section <br />Consolidation Site Annual Notification <br />1001 I Street <br />P.O. Box 806 <br />Sacramento, CA 95812-0806 <br />nFC on <br />MAR P ' 2006 <br />SRt 0ACI.,iN COUNTY <br />ENVtRONiV1ENTAL HEALTH DEPT. <br />Re: Pacific Gas & Electric Company's 2006 Remote Waste / <br />Consolidation Site Annual Notification. <br />Ladies / Gentlemen: <br />Pacific Gas & Electric Company (PG&E) is submitting this annual notification to <br />operate under the Health & Safety Code provisions allowing small quantities of <br />hazardous waste to be transported without a uniform hazardous waste manifest from a <br />remote location to a consolidation site. These remote sites are located within PG&E's <br />operational territory, which includes most of northern and central California and parts <br />of southeastern California. <br />Attached are tables which list PG&E's consolidation facilities, including addresses and <br />EPA identification numbers (Tables 1-3). Table 4 provides a general description of <br />PG&E's remote sites. For some of these remote sites, PG&E previously obtained and <br />will maintain the EPA identification numbers to properly handle occasional <br />maintenance projects that generate large quantities of waste. Table 5 lists the typical <br />hazardous wastes that may be generated at the remote sites. <br />In order to demonstrate eligibility for generator consolidation of remotely collected <br />wastes, generators are required to provide the basis for determining that a hazardous <br />waste permit is not required under the federal Resource Conservation and Recovery Act <br />(RCRA) and the federal regulations adopted under RCRA (Title 40, Code of Federal <br />Regulations). The following best describe the operation of PG&E's onsite <br />consolidation sites: <br />• The hazardous wastes being consolidated are not hazardous waste under federal law <br />although the wastes are regulated as hazardous waste under California state law. <br />• The hazardous wastes are hazardous waste under federal law, but transportation to <br />and accumulation at the consolidation site of the wastes is not subject to permitting <br />requirements under federal law because RCRA does not subject these wastes to <br />permitting requirements. <br />