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F1Pack Gas and <br />Electric Company.. <br />WE DELIVER ENERGY." <br />October 19, 2009 <br />Department of Toxic Substances Control <br />Program Data Management Section <br />Consolidation Site Annual Notification <br />1001 1 Street <br />Sacramento, CA 95812-0806 <br />aI�.I UcK0-mu/l i2d • C<( <br />a.Ih.;ni%use P -MIS <br />1001F. MD M N <br />h36i Jost- <br />SDa t'U� <br />IVSD <br />NOV 10 2009 <br />ENVIRONMENTAL HEALTH <br />DEPARTMENT <br />Re: Pacific Gas & Electric Company's <br />2009 Remote Waste/Consolidation Site Annual Notification - Revision <br />Ladies and Gentlemen: <br />Pacific Gas & Electric Company (PG&E) is submitting this revision to the annual notification <br />to operate under the Health & Safety Code provisions allowing small quantities of hazardous <br />waste to be transported without a uniform hazardous waste manifest from a remote location <br />to a consolidation site. These remote sites are located within PG&E's operational territory, <br />which includes most of northern and central California and parts of southeastern California. <br />Attached are tables which list PG&E's consolidation facilities, including addresses and EPA <br />identification numbers (Tables 1-3 Updated). Table 4 (updated) provides a general <br />description of PG&E's remote sites. For some of these remote sites, PG&E previously <br />obtained and will maintain the EPA identification numbers to properly handle occasional <br />maintenance projects that generate large quantities of waste. Table 5 (Updated) lists the <br />typical hazardous wastes that may be generated at the remote sites. Table 5 has been <br />revised to include some small quantities (< 220 lbs per month) of some RCRA waste <br />streams. <br />In order to demonstrate eligibility for generator consolidation of remotely collected wastes; <br />generators are required to provide the basis for determining that a hazardous waste permit is <br />not required under the federal Resource Conservation and Recovery Act (RCRA) and the <br />federal regulations adopted under RCRA (Title 40, Code of Federal Regulations). The <br />following best describe the operation of PG&E's onsite 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 and <br />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 />