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Pacific Gas and <br />& Electric Company <br />375 North Wiget Lane <br />Walnut Creek, CA 94598-2412 <br />Mr. Michael Kith <br />San Joaquin County Public Health Services Department <br />Environmental Health Division <br />304 East Weber Avenue, <br />Stockton, CA 95201-0388 <br />Re: Response to San Joaquin County Environmental Health Inspection <br />Report Dated 9/28/99 <br />October 11, 1999 <br />Dear Mr. Kith, <br />Thank you for allowing PG&E the opportunity to address the issues identified <br />during your recent September 28, 1999 inspection of the McDonald Island Gas <br />Storage Facility. Each issue identified is described below along with PG&E's <br />response thereto. <br />Alleged Notices of Violation <br />1. Facility is not maintained to minimize the release of Hazardous <br />Waste. <br />The cited violation refers to 22 CCR 66265.31 which states "Facilities <br />shall be maintained and operated to minimize the possibility of a fire, <br />explosion, or any unplanned sudden or non -sudden release of hazardous <br />waste constituents to air, soil or surface waters which could threaten <br />human health or the environment." <br />Triethylene Glycol (TEG) - The TEG was contained within a secondary <br />containment structure specifically designed for this purpose and drains <br />into the oily water separator. The effluent from the oily water separator is <br />collected in aboveground storage tanks and is not released to the <br />environment. PG&E has previously provided your office with <br />determinations that the influent to the oily water separator is not a <br />hazardous waste; as such, the OWS is not a hazardous waste treatment <br />unit and is therefore not subject to hazardous waste regulations. A copy <br />of the previous submittal is included in attachment A. <br />