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as identified in Title 22, California Code of Regulations, Section 66265.16 by December <br /> 31, 2022. <br /> Initial and refresher training associated with emergency response has been conducted in <br /> the form of an "Emergency Preparedness & Response" video covering these topics as <br /> outlined in the attached leader's guide: general preparedness, fire emergencies, <br /> medical emergencies, chemical spills, releases, & exposures, severe weather <br /> emergencies, earthquakes, and workplace violence. In addition to the video, plant <br /> specific information was presented to review elements of the facility's Combined <br /> Emergency Action, Response, and Contingency Plan (see attached "Emergency Action <br /> Plan" slides), including the file location of the plan, notification procedures for reporting <br /> an emergency, procedures for emergency evacuation, emergency levels, spill <br /> notification procedures, spill mitigation procedures, and emergency equipment. For <br /> example, during calendar year 2022, initial employee training was held for all new <br /> employees during their first week of hire. For refresher training during calendar year <br /> 2022, additional sessions will be held as needed during safety department meetings to <br /> ensure refresher training is completed for the remaining employees by December 31, <br /> 2022. Please refer to Simplot's response to the HMBP inspection for records detailing <br /> this training. <br /> Violation for Item #119 — Failed to keep copies of consolidated manifesting receipts for <br /> three years. <br /> This violation has been corrected and supporting documents are included. <br /> Receipts for antifreeze pickups for 12/8/2020, 9/2/2020, 6/10/2020 and 3/20/2020 are <br /> attached to this letter. <br /> Receipts for used oil pickups for 11/1/2021, 12/8/2020, 9/2/2020, 6/10/2020, 3/20/2020, <br /> 12/10/2019 and 9/12/2019 are attached to this letter. <br /> Simplot will assure records for consolidated manifesting receipts are retained and readily <br /> available on-site. <br /> Violation for Item #206—Waste stream or generator not eligible to use consolidated <br /> manifesting procedure. <br /> This violation has been corrected. <br /> Simplot has set up a waste profile and will use a Uniform Hazardous Waste Manifest for <br /> the transport and recycling and/or disposal of used antifreeze. <br /> Violation for Item #208 — Failure of laboratory to comply with laboratory hazardous waste <br /> treatment requirements. <br /> This violation has been corrected and supporting documents are included. <br /> Wastes that use reagents or catalysts are discussed in the response to Violation for <br /> Item#102. <br /> Page 3 of 4 <br />