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both the owner and the operator are in violation of subdivision (a) if evidence of financial responsibility is not established and maintained in accordance with this article. " Title 23 , California Code of Regulations, Chapter 16 — 2711 ( a ) ( 11 ) : "(a) The permit application shall include, but not be limited to, the following information to the extent such information is known to the permit applicant: (11) Documentation to show compliance with state and federal financial responsibility requirements applicable to underground storage tanks containing petroleum . " In this instance, the regulation pertaining to the recordkeeping requirement for the financial responsibility document is retention is CCR 2809 . 1 ( a ) which states : "(a) Owners and operators must maintain evidence of all mechanisms used to demonstrate financial responsibility in accordance with the provisions of this article until the provisions of this article no longer require such maintenance. Such evidence must be maintained at the underground storage tank site or sites or the owner or operator 's place of business. " Again , 7- Eleven makes efforts to ensure the financial responsibility document is on site, but as noted , this is not required . All 7- Eleven Compliance staff have copies of the current document, and those can be sent electronically to anyone upon request . These documents are also maintained and available in the CERS data system as required . For completeness of this letter and your report, a copy of the current financial responsibility document is attached , and one has been delivered to the location for site records . Item 601 : On your inspection report you noted that the hazardous waste was stored onsite longer than 180 days . You noted that the onsite drum had an accumulation start date of 12/ 17/2020 . You requested that the waste be immediately disposed of and send a copy of the manifest to the San Joaquin County EHD within 30 days . Resolution 601 : Belshire Environmental Services Inc . provides Designated Operator ( DO ) services and hazardous waste transportation services for this 7- Eleven site . Belshire is tracking the generator status of this facility as a Very Small Quantity Generator (VSQG ) . The DO inspects the hazardous waste drums each month in order to count the waste . This is completed by measuring the air space in each container and then using a conservative estimate of the weight of the waste in the container to track the onsite accumulation . A conversion table providing weight for inches of waste in the drums is attached . The drum in question contains 110 lbs . of hazardous waste . See attached drum photos . The date on the drum identifies the first deposit date the waste was placed into the drum . Once the drum accumulates 220 lbs . ( 100 kg) the accumulation start date will be placed on the drum label . Once the drum is identified with an accumulation start date the drum must be removed from the site within 180 days or 270 days ( if the waste is transported to a disposal facility greater than 200 miles ) . The waste is sent to a TSDF in Beatty Nevada which is greater than 200 miles . Summary . 7- Eleven, lnc . P.O . Boa 711 — Dallas, Texas 7522 1 -071 1