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attached for reference. SJCEHD also sent an email request for more information on May 18th, 2009 regarding additional missing manifests dated 001941708 —6/28/2007, 001941710—6-28-2007, and 002911091 —9/20/2007, which are also attached for reference. Violation # 45—66265.52 CCR—Contingency Plan incomplete Waste Management believes this finding to be in error. The Hazardous Material storage Compliance Binder was provided to SJCEHD during the inspection for review which contained our approved Contingency Plan. Unfortunately the third party contractor information was filed one tab behind the Contingency Plan. The contractor information was shown to the SJCEHD inspector during the inspection and explained that the information was in the wrong tab. Waste Management believes that the Contingency Plan was complete as the third party contractor information was provided on site during the inspection. The one page that was filed incorrectly has now been placed in the proper location of the binder within the Contingency Plan tab. Contingency Plan has been attached for your reference. Violation #64—66265.192 CCR—Failed to retain on-site required certification for HW tank Waste Management believes this finding to be in error. The tank in question was purchased and installed in July 2008, sometime in August 2008 Waste Management identified that our Small Quantity Generator status was potentially affected by the inclusion of used oil in our generator status calculations. After some confirmatory conversations with the Department, Waste Management determined that the addition of the used oil constituted a generator status change for the facility. The facilities status therefore changed from SQG to LQG,thus requiring the certification of the tank under 22 CCR 66265.192. As Waste Management has many facilities that were potentially affected by this determination, an internal effort at our group level began to identify a qualified contractor to perform these tank tightness tests across the group. After a somewhat lengthy search for a qualified contractor, Waste Management issued an authorization to proceed to Network Environmental Services to perform the certifications for several of our facilities in California. Representatives from NES conducted the integrity assessment on the subject tank on April 15, 2009. The inspection by the department was conducted on May 18th, approximately 30 days after the initial inspection of the tank. Unfortunately, at the time of inspection the certification document had not been finalized and was not available on-site. A copy of the finalized Hazardous Waste Tank Assessment report has been attached for reference. Therefore Waste Management believes that we had met the full intent of the rule by having the inspection completed prior to the Departments inspection but was caught in a time lag between the certification and receiving the documentation