No, see this update from 2014. Page 6
http://ccld.ca.gov/res/pdf/CCUpdateFall2014.pdf
Child Care Center fencing requirements are not required for inflatable or portable wading
pools with sides low enough for children to step out unassisted; however, these pools should be
emptied after each use
As usual, California is vague. The ONLY thing it says is that wading pools have to be emptied after each use. (I am guessing that was your plan) The regs don't say water cannot ever be unattended. They also don't ban wading pools.
I get the overall concern . . . but the analyst can assess the situation and use common sense. If the pool appears freshly filled, it probably is.
I would appeal, especially since it is probably a more serious health/safety violation.