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1419 S. El Dorado Street <br />12/16/98 1,485 cubic feet <br />11/1/99 1,311 cubic feet <br />7/12/2000 874 cubic feet <br />18. With respect to each volume stated in response to Interrogatory No. 17 above, state the <br />exact pressure of the Carbon Dioxide that occupied that volume. <br />Not determined. <br />19. With respect to each volume stated in response to Interrogatory No. 17 above, state the <br />exact number of gallons of the Carbon Dioxide that occupied that volume. <br />1304 E. Hammer Lane <br />12/16/1998 17 gallons <br />11/1/1999 <br />23 <br />gallons <br />7/12/2000 <br />14 <br />gallons <br />1048 E Waterloo Road <br />12/16/98 <br />29 <br />gallons <br />11/1/99 <br />23 <br />gallons <br />7/12/2000 <br />11 <br />gallons <br />1419 S. El Dorado Street <br />12/16/98 20 gallons <br />11/1/99 23 gallons <br />7/12/2000 11 gallons <br />20. State the unit of measure you apply in' measuring Carbon Dioxide for purposes of <br />determining whether you require a Carbon Dioxide handler to submit a Hazardous <br />Materials Management Plan. <br />Since the hazardous materials is a compressed gas, this office utilizes cubic feet. <br />The industry standard uses pounds to measure by. This office provides the <br />conversion from pounds to cubic feet such as 1,200 cubic feet is the same as 137 <br />pounds of Carbon Dioxide. <br />21. With respect to each measured quantity of Carbon Dioxide referenced in response to <br />Interrogatory No. 13 above, was the Carbon Dioxide present in a physical state for which <br />there is valid and substantial evidence ( as that phrase is used by you in Labor Code 6382) <br />that any adverse acute or chronic risk of human health may occur from exposure. <br />There was enough Carbon Dioxide present in cubic feet that it reached the <br />reporting requirements of the California Health and Safety Code, Chapter 6.95, <br />Article One. The Labor Code is invalid in the determination whether the material <br />is reportable under the Health and Safety Code for this regulation. <br />22. If your response to Interrogatory No. 21 above is in the affirmative, please identify each fact <br />on which you base that contention. <br />California Health and Safety Code, Chapter 6.95, Article One <br />23. If your response to Interrogatory No. 21 is in the affirmative, identify by name, address and <br />telephone number each witness to each fact stated in response to Interrogatory No. 21 <br />above. <br />