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The spent sandblast abrasive is mentioned again in this violation, according to analytical received on February 21, 2008, the sand blast abrasive is not a hazardous waste as stated by the inspector's notes. The split sample that was received from samples taken on March 19, 2008 confirms that this abrasive is non-hazardous. The material not being acceptable to Class III landfill standards does not put this in the category of a hazardous waste nor does it imply that this facility is not maintained to minimize the release of a hazardous waste. Analytical data from a California certified lab clearly shows this a non- hazardous material and therefore would not fall under this violation. If you would like to further discuss the handling of this non-hazardous sand blast waste please contact me. Violation #42— Failed to report releases to department. On 2/14/08 unknown amount of acid spilled into a secondary containment and a decision was made not to report to the local regulating agencies. The spill referenced was recorded internally as a spill that occurred during bumping of the acid pump tank. The acid was contained in the secondary containment and there was no impact to the environment or threat to human health. The referenced CCR states, "The owner or operator shall note in the operating record the time, date, and details of any incident that requires implementing the contingency plan. Within 15 days after the incident, the owner or operator shall submit a written report on the incident to the Department." This release did not trigger the contingency plan since there was no potential effect outside of the designed containment, no fire or explosion. The documentation in the facility operating record makes it clear that the spill into secondary containment was not an emergency and that the contingency plan was not activated. As a standard in this industry, engineering precautions have been taken in design of this facility to handle minor spills of this nature. JR Simplot Co. has a protocol established for determining whether spills or releases are reportable to appropriate agencies. That protocol was followed for the February18, 2008 spill and it was determined that the incident was not reportable. A copy of the protocol was provided to the inspectors during their visit on March 19, 2008. Violation # 45 & 47- Contingency Plan Incomplete Facility lacks an emergency coordinator, thus the contingency pian is incomplete. At the time of inspection the emergency coordinator was listed as "Production Supervisor." The contingency plan has since been updated with individual names as required in the CCR. A copy of the updated contact page from the Contingency Plan is attached. Violation #93—Abandoned lead acid batteries