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J <br />WILLIAM A. SCHUCKMAN <br />JUDITH A. FEINBERG <br />CERTIFIED PARALEGAL <br />San Joaquin County <br />Office of Emergency Services <br />222 East Weber Avenue, <br />Room 610A <br />Stockton, CA 95202 <br />Attention: Ronald E. Baldwin <br />LAW OFFICES OF <br />WILLIAM A. SCHUCH-MAN <br />3031 WEST MARCH LANE <br />SUITE 123 SOUTH <br />STOCKTON, CALIFORNIA 95219-6500 <br />July 27, 2000 <br />Re: Proprietary Pizza dba Eddie's Pizza Cafe <br />Dear Nlr. Baldwin: <br />TELEPHONE (209) 472-1100 <br />FAx (209) 472-1079 <br />Via First -Class & Certified Mail <br />Your correspondence dated July 13, 2000, has been forwarded to this office for response. <br />1. As you may know, this office wrote to the Office of Emergency Services on July 14th <br />concerning visits made by representatives of your department and a criminal investigator to some <br />facilities operated by Mr. Badway's Proprietary Pizza. <br />For some reason we have not received any response to that letter or to a follow-up letter dated <br />July 25th. A copy of both the original unanswered letter and the unanswered follow-up letter are <br />enclosed for your action. <br />2. Our confusion concerning the unit of measure applicable to Carbon Dioxide has been <br />further compounded by your reference in a "Carbon Dioxide Disclosure Survey" to a quantity of <br />Carbon Dioxide "equal to or greater than 1200 cubic feet or 137 pounds". <br />Mr. Irey of the District Attorney's office indicates that the applicable regulation triggers the <br />HMMP requirement at 200 cubic feet of Carbon Dioxide. <br />Which is the applicable unit of measure? <br />Which is the applicable quantity? <br />3 . My informal calculations indicate that (a) if Mr. Badway and Proprietary Pizza. stored <br />Carbon Dioxide inside of his typical facility and (2) if 200 cubic feet were released instantaneously <br />