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FOODHAKER.INC. <br /> Wr — 7 I� 9350 BALBODIEGO. AYEVUF. <br /> (RIr id.�'DIEGO.CA 92I23-I3Io <br /> 6191571-2121 <br /> a <br /> FOOD"iXR - "-- <br /> October 1, 1998 <br /> San Joaquin County <br /> Office of Emergency Services <br /> Hazardous Materials Division <br /> 222 E. Weber Avenue, Room 610 <br /> Stockton, CA 95202 <br /> SUBJECT: Carbon Dioxide Survey Form <br /> Enclosed are the completed "Carbon Dioxide Disclosure Survey" forms for the following <br /> JACK IN THE BOX restaurant locations: <br /> JIB #464 JIB #557 <br /> 1504 Pacific Ave. 611 W. Grant Line Rd. <br /> Stockton, CA Tracy, CA <br /> JIB #498 JIB #588 <br /> 1105 N. Main 100 E. Louise Ave. <br /> Manteca, CA Lathrop, CA <br /> JIB #534 JIB #3427 <br /> 2592 March Lane 1081 E. Main St. <br /> Stockton, CA Manteca, CA <br /> Also enclosed for your information are specifications for the "Carbo-Matic 400" CO, <br /> delivery system used at some of our restaurants, including the six listed above. We <br /> appreciate your assistance in clarifying our responsibilities under Chapter 6.95 of the <br /> California State Health and Safety Code. We thought that such CO, systems were not <br /> subject to Hazardous Materials Management Plan requirements because: <br /> 1 . CO, is not listed as having any Hazardous Substance Reportable Quantity for <br /> releases under USEPA rules (40 CFR Part 302). <br /> 2. CO, is non-flammable, not reactive, and relatively non-toxic. Although exposure to <br /> very high concentrations can cause toxic effects, NIOSH guidelines do not require <br /> personal protective equipment in emergency situations, except for respirators when <br /> airborne concentrations in excess of 40,000 ppm may be present. <br /> 3. It is very improbable that a steel reinforced low pressure delivery system as used in <br /> the restaurant environment could produce CO, releases resulting in hazardous <br /> airborne concentrations. <br /> 4. We previously believed the amount of CO, stored at each facility was less than the <br /> threshold quantity of 500 pounds. We now understand that a limit of 200 cubic <br /> feet for hazardous gases is also specified in the state Code. However, we are <br /> confused as to the basis for the 1,200 cubic feet and 137 pound thresholds <br /> indicated on the form, and would appreciate a clarification. <br /> Page 1 of 2 <br />