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Sent by: CDAA/SJDA EPU <br />-Received: t2/lo/ee a;21pm; <br />12/10/99 15:04 FAX 202 474 3 <br />209 468 9784; 12/13/99 5:35Ph1;JetEu #465;Page 5/11 <br />ZUU 4(4 JG54 > lU,w/w UM trV rnyv + <br />_ H,E.S.K. A004/010 <br />Mr. David Irey <br />neputy District Attorney <br />December 10. 1999 <br />page Three <br />Ae can be seen from the enclosed documents, my client <br />orders CO2 to minimize the handling of this product. MY <br />client could easily order it more often, and keep less on <br />hand, but there are certain safety issues aassocitatedlith <br />having to take out and connect the tanka- <br />believee that he haw always been responsible to his <br />employees, and has never had a problem in this regard. The <br />problem only occurred when my client contemplated going <br />the four hundred (400) tank system which was actually more <br />costly for his otioll. it should be tanks were changed nfordthat the follow g <br />ur <br />hundred (400) pound <br />reasons: <br />1) They do not require handling, a. -.d a service <br />truck fills them up in place; <br />2) They are placed outside the building, so <br />should an accident occur, (which has never <br />occurred in the last twenty two (22) years) <br />the gas could be vented in the atmosphere <br />and not in an enclosed space; <br />3) There are no tanks to change or valves to <br />leak or be serviced. <br />We have previously forwarded documentation to your <br />office that shows that the four hundred (400) tanks were <br />removed on December ll,. 1998 .'Those tanks were at each <br />location for ' -a period of three weeks in the case of the <br />Hammer Lane location, tc a maximum period of time oflient <br />(7) weeks, in the case of El Dorado location:'; My c <br />directed Air Gas to stop filling the tanks and to remove <br />them as soon as possible after he learned the tanks would <br />require an HMMP. Despite my client's urging, Air Gas took <br />approximately two weeks to remove them, allowing the tanks <br />to empty so that they could be safely transported. <br />Considering the short period of time the tanks were cn site <br />and the logistics of their safe removal, I feel that my <br />client acted as promptly as possible to comply. <br />