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Sent by: CDAA/SJDA EPU 209 468 9784; 12/13/99 5:35PM;Jetfau #465;Page 5111 <br /> Received: 1211 Of eQ 3:21PM' 2Ud 4/A 40Z)o -> LUm^fwu0% cru; r.jj" <br /> i2/10/99 15:04 FAX 209 474 _ y•E-S.6t. f004/010 <br /> mr. David Irey <br /> Deputy District Attorney <br /> December 10, 1999 <br /> Page Three <br /> As can be seen from the enclosed documents, my client <br /> orders CO2 to minimize the handling of this product , My <br /> client could eaaily order it more often, and keep less on <br /> hand, but there are certain safety issues associatedWith <br /> having to take out and connect the tanks - my <br /> ient <br /> believes that he has 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 to <br /> the tour hundred (404) tank system which was actually more <br /> costly for his operation. It should be noted that the four <br /> hundred (400) pound tanks were changed for the following <br /> reasons: <br /> 1) They do not require handling, and 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 Det�ember 11', : 1998 • . `Those tanks were at each <br /> location for'-a period of three weeks in the case of the <br /> Hammer Lane location, to a maximum period of time of seven <br /> (7) weeks, in the case of El Dorado location,": MY client <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 on site <br /> and the logistics of their safe removal, I feel that my <br /> clienL acted as promptly as possible to comply. <br />