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Cal -ARP Inspection — One violation and several comments were noted. Cal -ARP Violation -Item 648: CCR 2760.9(e) Failed to establish system to address/resolve/document the incident report findings/recommendations. The owner/operator failed to promptly address and resolve the investigation findings and recommendations. The facility had on ammonia release on 09/30/2015. The incident investigation report has twenty corrective actions, and seventeen of these corrective actions are not signed complete. The owner or operator shall promptly address and resolve the investigation findings and recommendations. The owner or operator shall enter into an agreement with the Unified Program Agency on a timetable for resolution of these findings and recommendations. Otherwise these resolutions shall be completed no later than one and one-half (1.5) years after the completion of the incident investigation, or two (2) years after the date of the incident, whichever is earlier of the two dates, or the next planned turnaround for those items requiring a turnaround. Resolutions and corrective actions with actual completion dates shall be documented. Submit documentation to our department demonstrating that the resolutions and findings have been / will be promptly addressed for the incident investigation. This is a Class Il violation. Response to Cal -ARP Item 648: During the inspection, the file that was presented was not up to date. The action item list has been updated and the action items have been resolved/completed. The J.R. Simplot Co. considers this item closed and has also included the attached Return to Compliance Certification. Additional Notes on Cal -ARP report: Note #1: Upon reviewing the 5 -years process hazard analysis (PHA) records that was conducted on February 28, 2018, seventy recommendations were noted and thirty were closed out. The PHA from March 6, 2018, has fifteen recommendations and all have been closed out. All recommendations from the PHA must be completed within one year from the date of the PHA. If more time is required, our department must be notified in writing to request an extension for up to 2.5 years. EHD was not invited or notified to participate in the PHA. The next PHA revalidation is due by February 26, 2020. Please send an invitation to our department to participate. Per title 19 CCR § 2760.2, (b) The owner or operator shall work closely with AAs in deciding which PHA methodology is best suited to determine the hazards of the process being analyzed. For the PHA, an initial seismic assessment was conducted for the anhydrous ammonia and aqua ammonia systems on November 06, 2015. Six recommendations were noted on the seismic reports Recommendations from the seismic assessment must be completed within one year. if more time is required to close these recommendations, our department must be notified in writing to request an extension for up to 2.5 years. Once the recommendation has been completed, the engineer shall certify closing out the seismic assessment recommendations. The seismic assessment must be revalidated every five years from the initial seismic assessment. The next seismic assessment revalidation is due by November 06, 2020. Page 2 of 4