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David Irey <br />Page two <br />G. All spread sheets indicate an average of 100 lbs are left on each deliver. There is no way of <br />knowing that when the 100 lbs of CO2 was delivered that on the same day a 50 lb cylinders <br />was placed on line. This would place the facility over the 137lbs. To avoid any confusion on <br />quantities on hand, Mr. Badway should keep one cylinder on line with one backup. Once the <br />one on line is empty, he could move the backup into operation and have the empty one <br />replaced with a new backup cylinder. <br />H. In response to the publications to the restaurant community regarding limits, it would be <br />found in Health and Safety Code, Chapter 6.95. If OES followed the letter of the law and did <br />not raise the CO2 limit to 1,200 cubic feet or 137lbs, business would be reporting at 200 <br />cubic feet or 53lbs. OES discovered that restaurants were placing the 4001b tanks in their <br />facilities. OES decided to send a special survey to restaurants to identify those that were <br />above the County quantity. <br />Regarding the risk factor, Mr. Badway has more of a safety risk by utilizing cylinders than <br />when he had the bulk tanks. Mr. Badway would have to handle the cylinders no matter how <br />many cylinders he had on site. The facility on South El Dorado has the CO2 cylinders stored <br />in another building behind the restaurant. This is a great distance to travel which handling <br />could become an issue. I don't know how the employees at this facility move the cylinders <br />from one building to the other. During the inspections, the cylinders were not properly <br />chained and in some cases the cylinders were not chained at all. <br />F. It should be noted that on Airgas invoice they charge a hazardous materials handling fee. <br />Airgas has determined that CO2 is considered a hazardous material to be handled as such. <br />