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Note #1 Response: 19 CCR § 2760.2 (b) States that "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." The J.R. Simplot, Lathrop facility uses industry standard and regulatory compliant methodologies when conducting PHA's. The facility will inform and discuss with the AA, methodologies being used for future PHA's. The referenced CCR does not state that the AA must be invited to participate in the PHA. 19 CCR § 2755.2 (e) states "The owner or operator shall document the results of the hazard review and ensure that problems identified are resolved. The owner or operator shall enter into an agreement with the UPA on a timetable for resolution of these problems Otherwise these resolutions shall be completed within two and one-half (2.5) years of performing the hazard review or the next planned turnaround for items requiring a turnaround. These timelines shall not apply to any hazard review completed prior to January 1, 2015. The final resolution taken to address the hazard review recommendation and the actual completion date shall be documented." The referenced regulation does not state that "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." The J.R. Simplot, Lathrop facility intended to complete PHA findings within the 2.5 years as specified in the referenced regulation. The Lathrop facility is discussing the seismic study with a contracted engineering firm to assist in timely completion of these outstanding action items. Once a timeline has been established the Lathrop facility will communicate that to the SJC EHD. Note #2: The 5 -years Mechanical integrity audit was conducted on 2015. Recommendations from the mechanical integrity audit must be completed in a timely manner. The Mechanical integrity audit must cover the anhydrous ammonia and aqua ammonia vessels and piping. Note #2 Response: The Mechanical Integrality Audit does cover Anhydrous and Aqua Ammonia process and equipment. MI action items are entered into the maintenance work order system for completion. Note #3: Upon reviewing the three-year compliance audit from May 09, 2017, sixteen recommendations were noted, and five are still open. All recommendations must be corrected within one year. If more time is required, our department must be notified in writing to request an extension of up to 1.5 years. The two most recent compliance audits must be kept on file for review. The next compliance audit revalidation is due by May 09, 2020 Note #3 Response: 19 CCR § 2755.6 (d) states "The owner or operator shall promptly determine and document an appropriate response to each of the findings of the compliance audit. The owner or operator shall enter into an agreement with the UPA on a timetable for resolution of these findings Otherwise these responses shall be completed within one and one-half (1.5) years after performing the compliance audit or the next planned turnaround for items requiring a turnaround. These timelines shall not apply to any compliance audit completed prior to January 1, 2015. The owner or operator shall document the actual completion dates when deficiencies were corrected. The J.R. Simplot Co., Lathrop facility intends to complete Compliance Audit findings within the 1.5 years as specified in the referenced regulation. If more time is required the facility will contact the SJC EHD. Page 3 of 4