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To substantiate this statement, enclosed are copies of manifests showing the disposal of used lubricating oil by both the Can Plant and Cannery. Notwithstanding the above, consolidation of waste oils from the Can Plant and Cannery does not constitute transportation of hazardous waste to an unpermitted facility. The term "generator" is defined at 22 CCR §66260.10 as "any persons by site, whose act or process produces hazardous waste identified or listed. . . or whose act first causes a hazardous waste to become subject to regulation." Although the Can Plant and Cannery have different addresses and have different managers, both are Pacific Coast Producers owned and operated facilities. Consequently, the "generator" of hazardous waste is Pacific Coast Producers. The term "site" is defined as "the land or water area where any facility or activity [subject to regulation] is physically located or conducted, including adjacent land used in connection with the facility or activity." In fact, the parcels may be separated by a public road, and crossing that road does not constitute transportation to a facility. Pacific Coast Producers owns the two contiguous parcels on which the Cannery and Can Manufacturing activities which generate hazardous wastes occur. For purposes of hazardous waste control laws, the hazardous waste generated by the activities on PCP's two contiguous parcels constitutes one "site". This interpretation is confirmed by Mr. Tim Beckwith, Chief, Hazardous Waste Generator Information Unit, DTSC [(916) 324-05911. For your information, PCP has made an effort to improve and simplify its hazardous waste management. This effort includes elimination of duplicate EPA ID Numbers for these facilities and the creation of a centralized hazardous waste storage area, except for satellite or temporary accumulation. ITEM #6 Decontamination Equipment The regulation upon which your office bases this alleged violation [22 CCR §66265.321 requires certain types of emergency equipment unless it can be shown to DTSC that none of the hazards posed by the waste handled at the facility would require a particular kind of equipment. As dictated by the character of the wastes handled at our facility, the waste storage and handling room is equipped with an internal and external alarm, a communication system, fire extinguishing equipment, 2 hour fire walls, and explosion proof lighting.