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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 531bs. 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 /> I. Regarding the risk factor, Mr. Badway has a 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 />