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HomeMy WebLinkAboutHAZARDOUS WASTE October 12, 1998 Mr. David Martin, District Mgr. F~.E cHiEF Wedge Dia-log Inc. RON FRAZE 4730-A Armstrong St. ,,aatiN~S'mxnw sew~cEs Bakersfield, CA 93313 2101 'H' Street Bakersfield. CA 93301 VOICE (805) 326-3941 FAX (805) 395-1349 Dear Mr. Martin: SUPPRESSION SERVICE8 On October 8, 1998, I made an inspection of the Wedge Dia-log facility at 2101 'H' Street Bak~mfield. CA 93301 4730-A Armstrong St. I was called out to inspect the track wash station. VOICE (805) 326-3941 FAX (805) 395-1349 As we walked through the warehouse, I observed an acetylene torch and " 35-40 well shot guns. The guns had both caps and snap rings in place, an PREVEHTION SERVICES 171s c~sto, ^vo. indication that they are loaded. The torch and the guns are in violation of Bake,m,~d, CA ~mOl the Uniform Fire Code, Section 103.4.3.1, Article 77.. As per our VOtCE (805) 326-3951 " FAX (805)326-0576 conversation of April 1998, I advised you that this building would not meet the separation distances and that no guns or explosives were to be at this ENVIRONMENTAL SERVICES 1715 Chester Ave. site, period. You are, also, in violation of ATF and DOT regulations in Bako~,e~d. CA ~a01 that you have transported the explosives into town without a permit. You VOICE (805) 326-3979 FAX (805) 326-0576 _ are ordered to cease and desist all gun or explosive handling at this location. If you continue, we will take legal action to correct this problem, TRAINING DMSION 5642 Victor Avo. including confiscation of all explosives, closing down Your business, and Bakersfield, CA 93308 VOICE (805) 399-4697 COUrt action which includes criminal penalties. FAX (805) 399-5763 ,, Yours truly, Gary Lowrey Inspector Prevention Services GL/d S:\Letters (Lowrey)\4730-A Armstrong WEDGE DIA-LOG, INC. BAKERSFII(~ DISTRICT G[]N LOADIND PROC 1. Ail shaped charges and primacord will be picked up from the out- door magazine (located at: Property owned by Windell Weller off Woody Road, Kern County, located approximately 5 miles north of Bakersfield). and will be brought to the shop in order to conduct the gun loading operations. 2. At the shop the gun loaders will load the guns needed for the next scheduled job(s). At all times when loading operations are taking place, Wedge Die-Log personnel experienced in gun loading opera- tions will be present ensuring that the explosives are always tended. The gun loading area of the shop will be clearly marked and defined. The floor will have a bright red tape on it clearly out- lining the gun loading area. This area will also contain the two indoor explosives storage magazines. In addition to the floor marking, this restricted area will be clearly posted with signs stating "No Unauthorized Personnel Beyond This Point". The explosives storage magazines located in the gun loading area will be separated from each other and the gun loading operations by a one hour fire wall around each magazine. This fire wall, coupled with the sprinkler system in the building, will protect both the occupants of the facility and the explosives themselves from the dangers posed by fire. 3. Once the guns are loaded they will be placed on gun trailers for transport to the well site where the perforating work will be con- ducted. Also loaded on the transport vehicles will be the number electric detonators (blasting caps) needed for the job. The crews scheduled to conduct the perforating operations will pick up their equipment shortly after the loading operation is complete and will proceed to the well site. 4. At the shop there will be two indoor explosives storage magazines constructed in accordance with the Uniform Fire Code, Article 7?. One of these magazines will contain the electric detonators (blasting caps) needed for the jobs (total magazine storage is an- ticipated to range between 500 and 750 detonators which will have a total explosives weight of less than 1 pound). GUNLOADING PROCED~ PAGE - 2 The second magazine will be used for the limited storage of shaped charges and detonating cord. The actual amount will be limited by the gunloading operations conducted on any particular day. Should the gun loading operations not use all of the explosives brought to the shop (one or two boxes of charges and/or a partial roll of detonating cord, for example) they will be Placed in the shop magazine for immediate use the next day. We would anticipate that in most cases any explosives not loaded in guns during the day will be returned to the outside storage magazine. Wedge Dia-Log, Inc. anticipates that at no time will more than 15 pounds total explosive weight be stored in magazines at this facility at any one time. In most cases less than this amount will be in the shop magazines. It should be noted that both the Bureau of Alcohol, Tobacco and Firearms (BATF) regulations and the Uniform Fire Code (Article .77) allows for the indoor storage of 50 pounds total explosives weight AND 5000 detonators. A~ described above, our magazine storage will always be far below these limits. 5. In addition to the procedural information contained on the previ- ous page, it must be noted that Wedge Dia-Log, Inc. has been in the perforating business (loading and using perforating guns in oil and gas wells) since 1987. During that almost 11 year period, not a single incident has occurred involving the Company's gun loading operations. During the past four years Wedge Dia-Log, Inc. gun loaders have assembled over 2.6 million shaped charges· into perforating guns without incident. 6. Item 4 on the previous page outlines the use of.Uniform Fire Code, Article 77, maga2ines. These magazines shall be constructed as follows: These magazines are constructed with the sides, bottoms and doors made of not less than .097-inch (2.5 mm)(12 gage) steel and are lined with a minimum of 1/2 inch of non-sparking material (in our case this will be plywood). Hinges and hasps are attached to the doors by welding on the side so the doors cannot be removed when closed and locked. Each magazine shall be equipped with two steel padlocks, each protected by 1/4" thick steel hood, having at least five tumblers with a case-hardened shackle of at least 3/8-inch (9.$ mm) diameter. These magazines have substantial casters (wheels) to facilitate removal from the building in case of emergency. GUNLOADING PROCEDURES PAGE - 3 Magazines a~e painted red and the door has the wording "EXPLOSIVES - KEEP FIRE AWAY" in white letters a minimum of 3 inches (76.2 ~m) high. The magazine construction outlined above meets the Article 77 requirements of the Uniform Fire Code as well as being compatible with BATF federal standards. In order to more clearly outline the safety of our gun loading operations, a description of the shop and the surrounding area is important. The facility is located on A~mstrong Road in Bakersfield Ca. To the immediate north of the property is a fenced parking lot used for parking commercial vehicles. On this property there are no structures (offices). It is used solely to park these vehicles. To the rear of the property (to the east) beyond the fence line is a drainage ditch and then a set of railroad tracks. On the op- posite side of the railroad tracks iL a commercial building. This structure is 40 to 45 beyond our fence. To the south of the property is a large vacant field. To the west, across Armstrong Road, is an unidentified commercial facility (some type of plant). This facility has no entrance on Armstrong Road with the structure set back off the road. The above information clearly shows that this facility is located in an extremely isolated area. With the very small quantities of e×plosives that will be stored in our magazines and with the safety precautions being taken, our operations present little ha2ard to the other business in the same Structure as we are proposing to set up our operations. In Summary, Wedge Dia-Log, Inc. has taken the following safety ac- tions and has a.proven record of explosives safety. A. over ten years of gun loading experience without incident. B. A sprinklered facility. C. Explosive storage magazines separated from each other and the other operation~ by one hour fire walls. D. Locating the gun loading and explosives magazine storage at the opposite end of the facility from the operations in the other half of the structure. ~ E. Locating the explosives storage magazines and gun loading operations in an area of our shop whereby our offices are be- tween our operations and the common wall Separating the two operations in this structure. GUNLOADING PROCEDURF.~ PAGE.- 4 8. The explosives used by Wedge Dia-Log, Inc. are ."shaped charges'', commonly refered to as perforating charges. These devices are designed to focus their energy in a specific direction. This con- struction makes them less ~usceptible to sympathetic detonation, meaning that if one is initiated it will not neCesSarily cause.one next to it to explode as well (unless the shaped charge directed directly at the charge next to'it). All'of these charac-~ teriStics make shaped charges extremely unlikely to "mass detonate". ~ ~.Another factor that must be evaluated relating?to Shaped charges is their regulation within the Uniform Fire COde. section ' provides a definition of "Special Industrial EXplosive Device". This definition states in part, ".charges of. 'explosive~ used in., jet perforation of oil well casings". Article 77 of the .. fire code specifically exemDts Special IndUStrial Explosive Devices which in the aggregate contain .less than 50 pounds (22.7 kg) of explosive materials. This will be the case in our opera- tions. This definition indicates that the fire code under~tands the limited possibility of a mass detonation of these devices, thus · - making any associated damage very limited. 9. Attached to this document is a drawing of the facility in which we propose to set up our gun loading operation. Clearly shown on this drawing is the gun loading area, including the location of the in- door explosives storage magazines.