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F1Pacific Gas and su cev/Y)on _/� M 14Electric Company.. aW /��4a.-%hZuf) T�uz r WE DELIVER ENERGY."' t9Gf9f'6E-�,�1 �ZD'MN h3 5 5. 11Cw►�' S� �'�`� 4OUO �5t' I-/, S0Z U� October 19, 2009 IVED NOV 10 2009 Department of Toxic Substances Control Program Data Management Section ENVIRONMENTAL HEALTH Consolidation Site Annual Notification DEPARTMENT 1001 1 Street Sacramento, CA 95812-0806 Re: Pacific Gas & Electric Company's 2009 Remote Waste/Consolidation Site Annual Notification - Revision Ladies and Gentlemen: Pacific Gas & Electric Company (PG&E) is submitting this revision to the annual notification to operate under the Health & Safety Code provisions allowing small quantities of hazardous waste to be transported without a uniform hazardous waste manifest from a remote location to a consolidation site. These remote sites are located within PG&E's operational territory, which includes most of northern and central California and parts of southeastern California. Attached are tables which list PG&E's consolidation facilities, including addresses and EPA identification numbers (Tables 1-3 Updated). Table 4 (updated) provides a general description of PG&E's remote sites. For some of these remote sites, PG&E previously obtained and will maintain the EPA identification numbers to properly handle occasional maintenance projects that generate large quantities of waste. Table 5 (Updated) lists the typical hazardous wastes that may be generated at the remote sites. Table 5 has been revised to include some small quantities (< 220 lbs per month) of some RCRA waste streams. In order to demonstrate eligibility for generator consolidation of remotely collected wastes, generators are required to provide the basis for determining that a hazardous waste permit is not required under the federal Resource Conservation and Recovery Act (RCRA) and the federal regulations adopted under RCRA (Title 40, Code of Federal Regulations). The following best describe the operation of PG&E's onsite consolidation sites: The hazardous wastes being consolidated are not hazardous waste under federal law although the wastes are regulated as hazardous waste under California state law. The hazardous wastes are hazardous waste under federal law, but transportation to and accumulation at the consolidation site of the wastes is not subject to permitting requirements under federal law because RCRA does not subject these wastes to permitting requirements.