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For better clarity, we can draw inferences from Section 66265.193 of Title 22 of the California Code of Regulations which discusses containment and detection of releases of hazardous waste (not hazardous substances). Specifically, subsection (a) uses this phrase: "in order to.prevent the release of hazardous waste or hazardous constituents to the environment, secondary containment shall be provided." Additionally, 22 C.C.R. Section 66265.1.96 provides that no notification or report is required if the quantity of hazardous waste was less than or equal to one pound and immediately contained and cleaned up. Lastly Title 19 of the California Code of Regulations§2703(c) relating to hazard substances(as opposed to hazardous waste) states that"immediate reporting shall not be required if there is a reasonable belief that the release or threatened release poses no significant present or potential hazard to human health and safety,property,or the environment." Accordingly, a release to secondary containment would not be considered a "release to the environment" and therefore would not be reportable. The report also makes the determination that any material that has been spilled is a hazardous waste. This is not the case. Material that is contained is not a waste and is returned back to the process for use and therefore is not a hazardous waste. It should also be noted that several of the pictures taken during the inspection were of piping that contains no hazardous materials and does not pose a threat to the environment if released. Sincerely, �7 Ryan Mock Environmental Specialist J.R.Simplot Company Enclosures: California Hazardous Waste Manifests; 004907913JJK,004907765JJK,00,6915021JJK,001991177SKS Consolidated Manifest#004908287JJK Lab procedures Signed Compliance Certification Compliance Photo's CC: John Yanak Alan Prouty File