Redondo Beach City Council
October 6, 2026

633
H.14., File # 26-1222 Meeting Date: 10/6/2026
SBCCOG plans to submit an application to the Extreme Heat And Community Resilience Program for the “South Bay Extreme Heat Action Plan and Demonstration Projects.” The proposed initiative would update the SBCCOG’s 2019 subregional and city-level vulnerability assessments of climaterelated risks by incorporating current climate projections, demographic data, and community input to evaluate changes in regional vulnerabilities and identify appropriate mitigation strategies. The proposed initiative would also expand existing regional climate adaptation efforts such as implementing cool roof and tree-planting demonstrations and by developing localized recommendations for extreme heat infrastructure. The proposed initiative framework includes participation from municipalities, partner agencies, nonprofit organizations, and academic institutions, as well as structured community engagement intended to ensure that proposed strategies align with local conditions and needs.

Redondo Beach supports this initiative because it aligns with regional and local climate resilience objectives, provides opportunities to incorporate updated data into planning, and offers potential strategies to address increasing extreme heat conditions affecting residents, particularly vulnerable populations. As of October 1, 2026, Carson, Gardena, Hawthorne, Hermosa Beach, Inglewood, Lomita, Rolling Hills, Rolling Hills Estates, Torrance, and the Los Angeles County Chief Sustainability Office have indicated their support for the initiative.

COORDINATION
The City Manager’s Office prepared this report and the draft position letter for the Caltrans FY 27-28 Sustainability Planning Grant application. The SBCCOG provided the draft position letter for the South Bay Extreme Heat Action Plan And Demonstration Projects.

FISCAL IMPACT
There is no fiscal impact associated with authorizing the Mayor to sign the position letters.

APPROVED BY:

Mike Witzansky, City Manager

ATTACHMENTS
· Caltrans FY 27-28 Sustainability Planning Grant Letter of Support · Extreme Heat And Community Resilience Program Letter of Support

634
City of Redondo Beach
415 Diamond Street
Redondo Beach, CA 90277
Tel: 310.697.0630
Redondo.org
October 7, 2026
To: Ms. Jacki Bacharach, Executive Director
South Bay Cities Council of Governments
357 Van Ness Way, Suite 110
Torrance, CA 90501
RE: Support for the South Bay Cities Council of Governments Application to the Caltrans FY 27-28 Sustainability Planning Grant
Dear Ms. Bacharach,
The City of Redondo Beach is pleased to support the South Bay Cities Council of Governments' (SBCCOG) application to the FY 27-28 Caltrans Sustainable Transportation Planning Grant Program to fund the "South Bay Micromobility Destination Parking Plan." This project will build upon the SBCCOG’s micromobility strategy by adding amenities for the large number of local trips that currently are taking place while also helping to facilitate mode shift for additional short trips from full-sized gas-powered cars to zero-emission micromobility vehicles.

Increasing micromobility adoption will assist our communities in addressing congestion by encouraging residents to “right-size” their ride, electing to travel via micromobility vehicles for short distance trips in lieu of driving large vehicles congesting our roadways. As Redondo Beach fulfills housing requirements with its attendant population growth, micromobility is an important way to address further congestion and reduce VMT. Micromobility also contributes to our city, subregion, and state’s goals to reduce greenhouse gas emissions and toxic air pollutants.

The SBCCOG has taken initial steps to encourage micromobility usage through the South Bay Local Travel Network. However, to build a comprehensive micromobility ecosystem, it is important to plan for and provide safe, secure, and convenient parking amenities that support vehicles such as neighborhood electric vehicles, low speed vehicles, and other low-speed micromobility modes. Ensuring that residents and visitors can reliably access dedicated parking at major public and private destinations, such as schools, parks, shopping areas, employment centers, and downtown districts, will improve usability and help integrate these options into daily 635
City of Redondo Beach
415 Diamond Street
Redondo Beach, CA 90277
Tel: 310.697.0630
Redondo.org
travel. This project will build upon and complement the SBCCOG’s other micromobility strategies by increasing accessibility and utility for micromobility users. We will partner with the SBCCOG throughout this project as a collaborator to identify opportunities for adding micromobility amenities to key destinations. For the reasons stated, the City of Redondo Beach supports this grant application.

Sincerely,
Jim Light
Mayor
636

[Date]
Governor’s Office of Land Use and Climate Innovation
1400 10th Street
Sacramento, CA 95814
RE: Support for the South Bay Extreme Heat Action Plan & Demonstration Projects Dear LCI Extreme Heat & Community Resilience Program Grant Team, On behalf of the Cities of Carson, Hawthorne, Hermosa Beach, Inglewood, Lomita, Rolling Hills, Rolling Hills Estates, Torrance, Redondo Beach, and County of Los Angeles Chief Sustainability Office, we are writing to express our strong support for the South Bay Cities Council of Governments (SBCCOG) grant application to the Governor’s Office of Land Use and Climate Innovation for the “South Bay Extreme Heat Action Plan & Demonstration Projects”. This initiative will build upon existing plans, including the SBCCOG’s 2019 climate adaptation plan and the 2026 Los Angeles County Heat Action Plan.

With this funding, the SBCCOG will be able to implement cool roof and tree planting demonstrations, as well as develop locally tailored extreme heat infrastructure recommendations. The project emphasizes inclusive input from cities, partner agencies, nonprofit organizations, and local universities. The SBCCOG will also inform and engage residents from our communities, benefiting from their diverse perspectives to help shape the strategies that address extreme heat threats effectively, equitably, and sustainably.

The SBCCOG first created sub-regional and city-level vulnerability assessments and follow-up adaptation strategies in 2019. The work established a foundation for understanding how the South Bay and its residents will be affected by and can prepare for climate change. Seven years later, this new initiative will incorporate updated climate projections, demographic data, and community perspectives to determine how vulnerabilities have changed, as well as pinpoint new strategies to address threats from extreme heat.
637
In support of the SBCCOG on this new initiative, we are eager to share feedback on the drafted reports and community engagement efforts to help ensure the needs of our communities are addressed. In doing so, we aim to make sure that our subregion is resilient and that it remains safe and accessible to our residents in the face of extreme heat events.

Being a diverse subregion with many types of geographies and socioeconomic conditions, as well as a significantly large senior population, with little experience with more frequent hotter conditions, our communities are highly threatened and vulnerable to extreme heat events. With the new subregional plan, cool roofs, and tree plantings, communities like ours will be better equipped to understand and address these challenges.

As member agencies of the SBCCOG, we look forward to collaborating on the South Bay Extreme Heat Action Plan and Demonstration Projects. For these reasons, the Cities of Carson, Hawthorne, Hermosa Beach, Inglewood, Lomita, Rolling Hills, Rolling Hills Estates, Torrance, Redondo Beach, and County of Los Angeles Chief Sustainability Office strongly support this grant application.

Thank you for considering this proposal.

Sincerely,
David C. Roberts, Jr.

City Manager
City of Carson
Alejandro Vargas
Mayor
City of Hawthorne
Michael Detoy
Mayor
City of Hermosa Beach
Louis Atwell
City Manager
City of Inglewood
Andrew Vialpando
City Manager
City of Lomita
Karina Bañales
City Manager
City of Rolling Hills
Greg Grammer
City Manager
City of Rolling Hills Estates
Aram Chaparyan
City Manager
City of Torrance
Rita Kampalath, Ph.D., PE
Chief Sustainability Officer
County of Los Angeles
Jim Light
Mayor
City of Redondo Beach
638
Administrative
Report
H.15., File # 26-1227 Meeting Date: 10/6/2026
To: MAYOR AND CITY COUNCIL
From: STEPHEN SPRENGEL, CHIEF OF POLICE
TITLE
APPROVE AN AGREEMENT WITH SHARP PERFORMANCE, INC. FOR A COGNITIVE

PERFORMANCE COACHING PLATFORM FOR THE POLICE AND FIRE DEPARTMENTS FOR AN AMOUNT NOT TO EXCEED $75,600 AND THE TERM NOVEMBER 5, 2026 TO NOVEMBER 30, 2027

EXECUTIVE SUMMARY
Approval of this item would authorize the Police and Fire Departments to enter into a new agreement with Sharp Performance, Inc. (Sharp Performance) to continue utilizing the cognitive performance coaching platform designed specifically for high-risk professionals, including first responders. Sharp Performance’s cognitive performance coaching platform is the only commercially available tool specifically tailored to the needs of first responders and other high-risk professionals. The platform provides an essential mental wellness solution that combines preventative coaching with reactive resources in a single platform. Their proprietary application aligns closely with the wellness goals and operational demands of both the City’s Police and Fire Departments by addressing critical mental health needs and supporting the resilience and readiness of all team members in these Departments.

BACKGROUND
Maintaining an effective wellness program is integral to supporting the mental and physical health of public safety professionals, who frequently operate under high-stress conditions. The nature of police and fire service requires access to specialized resources that can help personnel manage stress, enhance focus, and sustain long-term resilience. The Sharp Performance platform is the only commercially available cognitive performance tool that consolidates coaching, training, and customized resource management exclusively for high-risk professionals.

The platform’s content and methodologies are rooted in evidence-based practices developed with the U.S. Military’s Special Operations teams and are uniquely adapted to meet the needs of first responders. These protocols emphasize stress endurance, focus, and psychological flexibility-critical attributes for law enforcement and fire service professionals. No other product replicates the training protocols or adaptive regimens tailored specifically for public safety teams. Sharp Performance employs coaches with direct experience supporting high-risk professionals. The team’s performance coaches previously led wellness and resilience programs within the Joint Special Operations Command and U.S. Army Special Forces, where they successfully facilitated cultural change to destigmatize mental health support. This experience uniquely positions them to assist our Police and Fire Departments in encouraging a proactive approach to wellness. This particular approach is

639
H.15., File # 26-1227 Meeting Date: 10/6/2026
Fire Departments in encouraging a proactive approach to wellness. This particular approach is proven to resonate with public safety personnel, and seeks to build a supportive culture that encourages individuals to seek help without fear of stigma. This preventative model proactively supports mental health, which can help decrease stress-related ailments, reduce burnout, and improve the overall resilience of the City’s first responders. In addition to the coaching services, the platform features an application that offers a centralized resource directory that includes both internal wellness resources and external support services. The directory for the Redondo Beach Police and Fire Departments will be fully customized, consolidating tools like mental health services, health incentives, and available hotlines. This comprehensive directory streamlines access to resources, making it easier for personnel to locate the help they need quickly.

With Mental Performance Coaching, users connect with a roster of highly-trained performance coaches, each experienced in working with individuals operating in high-stress environments.

Coaching sessions emphasize goal-setting, accountability, and personal growth, with unlimited access to support professional and personal development. The Self-Paced Training Modules offer a vast library of mobile-based exercises adapted for high-risk professions. These brief two-to-tenminute exercises are accessible anytime, fostering improvements in focus, stress endurance, and psychological flexibility. Sharp Performance also provides a Resource Directory of health and wellness resources designed specifically in collaboration with each agency. This directory includes internal mental health resources, chaplains, health incentives, national hotlines, and exclusive commercial partnerships. For a smooth rollout, Sharp Performance provides in-person onboarding where their staff will visit the Police and Fire Departments to introduce the platform, provide personalized performance strategies, and offer direct consultations. Additionally, anonymized Utilization Reports are shared quarterly with Department leadership, offering insights on user engagement and satisfaction. Sharp Performance also guarantees On-Demand Technical Support to ensure seamless access to all platform services.

Over a period of several months in 2024, members of the Police and Fire Departments participated in a pilot program utilizing Sharp Performance coaching services in order to evaluate the platform. The feedback from the pilot sessions revealed a high level of support for Department-wide implementation based on the positive interactions between our first responders and the coaches.

The platform’s proprietary methodologies and industry-leading destigmatized approach make Sharp Performance uniquely qualified to address the wellness needs of our Police and Fire Departments.

Several other wellness programs were evaluated including Cordico and Valor; however, none provided the same level of specialized, integrated cognitive performance coaching tailored specifically for high-risk law enforcement and fire personnel.

Sharp Performance stands as a sole source option due to its unique combination of preventative and reactive resources, proprietary training methodologies, and customized resource directory, which no other platform could match. Their product provides a comprehensive and well-suited solution for supporting the wellness of our public safety personnel. By providing preventative mental health support through a unique and specialized coaching platform, Sharp Performance offers an invaluable resource that aligns with organizational wellness objectives and supports the mental health and operational readiness of our Police and Fire Departments.

COORDINATION
The Police Department coordinated this item with the Fire Department, and the City Attorney’s Office

640
H.15., File # 26-1227 Meeting Date: 10/6/2026
approved the Agreement as to form.

FISCAL IMPACT
The total cost of the one-year Agreement is $75,600. Funding for the Police Department’s portion of the agreement ($50,000) is available through existing Wellness Grant and Supplemental Law Enforcement Services funds. Funding for the Fire Department’s portion of the agreement ($25,600) is available in the Department’s FY 2026-27 Adopted Budget.

APPROVED BY:

Mike Witzansky, City Manager

ATTACHMENTS
· Agmt - Second Amendment- Sharp Performance Inc.
· Agmt - First Amendment to the Agreement with Sharp Performance, Inc. · Insurance - Sharp Performance Inc.

641

SECOND AMENDMENT TO THE MASTER SAAS AND SERVICES AGREEMENT

BETWEEN THE CITY OF REDONDO BEACH
AND SHARP PERFORMANCE INC.

THIS SECOND AMENDMENT TO THE MASTER SAAS AND SERVICES AGREEMENT (“Second Amendment”) is made and entered into on October 6, 2026, by and between the City of Redondo Beach, a chartered municipal corporation (“Customer” or “City”), and Sharp Performance Inc., a Delaware corporation (“Contractor”).

WHEREAS, on December 1, 2024, the parties entered into a Master SaaS and Services Agreement (the “Agreement”), with a term through November 30, 2025, authorizing 216 users and providing for total compensation in a not-to-exceed amount of $75,600; WHEREAS, on August 19, 2025, the parties entered into the First Amendment to the Master SaaS and Services Agreement (the “First Amendment”), extending the term through November 4, 2026, and increasing compensation to a not-to-exceed amount of $151,200; and WHEREAS, the parties now desire to further amend the Agreement to extend the term through November 30, 2027, incorporate the additional Order Forms attached hereto as Schedule A-2, and increase the compensation to a not-to-exceed amount of $226,800.

NOW THEREFORE, in consideration of the promises and mutual covenants contained herein, and intending to be legally bound, the parties hereby agree to make the following amendments to the Agreement:

1. TERM. The term of the Agreement, as amended by the First Amendment, is hereby extended through November 30, 2027. The Order Forms attached hereto as Schedule A-2 are hereby incorporated into and made a part of the Agreement and shall govern the services provided during the extended term.

2. COMPENSATION. The compensation under the Agreement, as amended by the First Amendment, is hereby increased by $75,600, for a total not-to-exceed amount of $226,800.

The fees for services provided during the extended term shall be set forth in Schedule A-2.

3. NO OTHER AMENDMENTS. Except as expressly provided herein, the Agreement, as amended by the First Amendment, shall remain unchanged and in full force and effect. The Agreement, First Amendment, and this Second Amendment constitute the entire agreement between the parties and supersede any previous oral or written agreements with respect to the subject matter hereof. In the event of any inconsistency between the terms of the Agreement, First Amendment, and this Second Amendment, the terms of this Second Amendment shall govern.

SIGNATURES ON NEXT PAGE
642
IN WITNESS WHEREOF, the parties have executed this Second Amendment in Redondo Beach, California, as of this 6th day of October, 2026.

CITY OF REDONDO BEACH, SHARP PERFORMANCE INC.,
a chartered municipal corporation a Delaware corporation __________________________ By: _______________________
James A. Light, Mayor Name: _______________________
Title: _______________________
ATTEST: APPROVED:
__________________________ __________________________
Eleanor Manzano, City Clerk Diane Strickfaden, Risk Manager APPROVED AS TO FORM:
__________________________
Joy A. Ford, City Attorney
CEO/President
9/30/2026 | 10:02 AM PDT
Benjamin Curley
643
SCHEDULE A-2

ORDER FORMS
The order forms are attached.
644
Schedule A-2 | Order Form
Personnel
Sworn Users
Civilian Users
City of Redondo Beach
415 Diamond Street
Redondo Beach, CA 90277
United States
Stephen Sprengel
[email protected]
50 100
Authorized Users Price Per User
$500.00 / year
$500.00 / year
Sharp Performance's product being offered to the personnel listed below include subscription services, professional services, unlimited access to Sharp coaches and chaplains, Sharp self-paced exercises and training, and partnership with Sharp to develop a customized resource directory. Fees are exclusive of applicable sales/use taxes. Customer is responsible for all such taxes, when applicable.

Reference: 20260901-173641095
Quote created: September 1, 2026
Quote expires: November 30, 2026
Quote created by: Matthew Sanders
Sharp Performance
2659 State Street, #100
Carlsbad, CA 92008
[email protected]
$50,000.00 / year
$0.00 / year
after 100% discount
Total
Products & Services
Total $50,000.00
Service Term:

Payment Due:

December 1, 2026 to November 30, 2027
Within net 60 days of Customer's receipt of the invoice following execution of this Second Amendment. 645
Schedule A-2 | Order Form
Personnel
Sworn Users
Civilian Users
Jason May
[email protected]
City ofRedondoBeach
415 Diamond Street
Redondo Beach, CA 90277
United States
64 2
Authorized Users
$500.00 / year
$500.00 / year
Price Per User
Sharp Performance's product being offered to the personnel listed below include subscription services, professional services, unlimited access to Sharp coaches and chaplains, Sharp self-paced exercises and training, and partnership with Sharp to develop a customized resource directory. Fees are exclusive of applicable sales/use taxes. Customer is responsible for all such taxes, when applicable.

Reference: 20260415-132607076
Quote created: April 15, 2026
Quote expires: November 1, 2026
Quote created by: Matthew Sanders
Sharp Performance
2659 State Street, #100
Carlsbad, CA 92008
[email protected]
$25,600.00 / year
after 20% discount
$0.00 / year
after 100% discount
Total
Products & Services
Total $25,600.00
Service Term:

Payment Due:

December 1, 2026 to November 30, 2027
Within net 60 days of Customer's receipt of the invoice following execution of this Second Amendment. 646
1 FIRST AMENDMENT TO THE MASTER SAAS AND SERVICES AGREEMENT

BETWEEN THE CITY OF REDONDO BEACH
AND SHARP PERFORMANCE INC.

THIS FIRST AMENDMENT TO THE MASTER SAAS AND SERVICES AGREEMENT (“First Amendment”) is made and entered into on August 19, 2025, by and between the City of Redondo Beach, a chartered municipal corporation (“City”), and Sharp Performance Inc., a Delaware corporation (“Contractor”).

WHEREAS, on December 1, 2024, the parties hereto entered into a Master SaaS and Services Agreement (the “Agreement”) in which the term of the Agreement expires on November 30, 2025 and 216 users were authorized for services and compensation for services provided was a not-to-exceed amount of $75,600; and WHEREAS, during the FY 2025/2026 budget cycle, additional funding was approved and appropriated for the provision of additional services under the Agreement; and WHEREAS, the parties hereto now desire to amend the Agreement to extend the term to November 30, 2026 and to increase the compensation to a not-to-exceed amount of 151,200.

NOW THEREFORE, in consideration of the promises and mutual covenants contained herein, and intending to be legally bound, the parties hereby agree to make the following amendments to the Agreement:

1. TERM AND TERMINATION. The term of the Agreement is hereby extended to November 4, 2026. Any further extensions shall be agreed to by the parties and shall be approved by the City Council through a written amendment.

2. FEES & PAYMENT. The compensation is hereby amended and increased to a total not-to-exceed amount of $151,200.

3. NO OTHER AMENDMENTS. Except as expressly stated herein, the Agreement shall remain unchanged and in full force and effect. The Agreement and this First Amendment constitute the entire agreement between the parties and supersede any previous oral or written agreements with respect to the subject matter hereof. In the event of any inconsistency between the terms of the Agreement and this First Amendment the terms of this First Amendment shall govern.

SIGNATURES ON NEXT PAGE]
647
2 IN WITNESS WHEREOF, the parties have executed this First Amendment in Redondo Beach, California, as of this 19th day of August, 2025.

CITY OF REDONDO BEACH, SHARP PERFORMANCE INC.,
a chartered municipal corporation a Delaware corporation By: _______________________
James A. Light, Mayor Name: _______________________
Title: _______________________
ATTEST: APPROVED:

Eleanor Manzano, City Clerk Diane Strickfaden, Risk Manager APPROVED AS TO FORM:

Joy A. Ford, City Attorney
Benjamin Curley
CEO/ President
648
1 Master SaaS and Services Agreement
This Master SaaS and Services Agreement ( this “ Agreement”) is entered into effective this _1_ day of _December_, _ 2024_, until _30_ of _November_, _ 2025_ by and between Sharp Performance Inc., a Delaware corporation (“ Sharp Performance”) with a place of business at 175 Varick St. C/O Columbia Startup Lab, New York, NY. 10014, and the City of Redondo Beach City of Redondo Beach__(“ Customer”). Sharp Performance and Customer are sometimes referred to herein jointly as the “ Parties” or singularly as a “ Party.” RECITALS:

WHEREAS, Customer desires to obtain access to the Services ( as defined below) with respect to certain of its information technology needs, and Sharp Performance desires to provide the Services to Customer, subject to the terms and conditions of this Agreement.

NOW, THEREFORE, in consideration of the mutual covenants and promises set forth herein, and other valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties agree as follows:

1. SERVICES.

1.1 Purpose. This Agreement sets forth the terms and conditions under which Sharp Performance agrees to provide ( i) certain hosted “ software as a service” ( the “ Subscription Services”) for certain software applications ( each such application together with any applicable documentation thereto, and programming and user interfaces therefor, a “ Platform”) to Authorized Users, as further set forth and described on each order form ( the “ Order Form”) attached hereto as Schedule A, and ( ii) if applicable, all other implementation services, customization, integration, data import and export, monitoring, technical support, maintenance, training, backup and recovery, and change management collectively the “ Professional Services”, and together with the Subscription Services, referred to herein as the “ Services”) related to Customer’ s access to, and use of, such Subscription Services and each Platform, as further set forth and described on each statement of services ( the “ Statement of Work”) attached hereto as Schedule B, issued hereunder ( Order Forms and Statements of Professional Services are sometimes referred to jointly as a “ Statement of Services”).

1.2 The Services; Access and Use License. Subject to the terms and conditions of this Agreement, during the Term, Sharp Performance shall use commercially reasonable efforts to provide i) Customer and Authorized Users access to each Platform, and (ii) Customer the Professional Services.

Subject to the terms and conditions of this Agreement, during the Term, Sharp Performance hereby grants Customer and Authorized Users a non-exclusive, non-sublicensable, non-transferable ( except in compliance with Section 16 herein), worldwide license to access and use each Platform, solely for internal business purposes in connection with Customer’ s use of the Services as set forth herein.

1.3 Subscription Services. Each applicable Order Form shall specify and further describe the Subscription Services to be provided in accordance with the representations and warranties set forth herein, and shall identify, each applicable Platform, user limitations, fees, subscription term and other 649
2 applicable terms and conditions.

1.4 Professional Services. Each applicable Statement of Work shall specify and further describe the Professional Services to be provided in accordance with the representations and warranties set forth herein, and may, but need not, include, the Professional Services offered, limitations, milestones, fees, term and other applicable terms and conditions.

1.5 Changes to Platform. Sharp Performance may, in its sole discretion, make any changes to any Platform that it deems necessary or useful to (i) maintain or enhance ( a) the quality or delivery of Sharp Performance’ s products or services to its customers, ( b) the competitive strength of, or market for, Sharp Performance’ s products or services, ( c) such Platform’ s cost efficiency or performance, or ( ii) to comply with applicable law.

2. PLATFORM ACCESS AND AUTHORIZED USER

2.1 Administrative Users. During the configuration and set-up process for each Platform, Customer will identify an administrative user name and password for Customer’ s Sharp Performance account. Sharp Performance reserves the right to refuse registration of, or cancel user names and passwords it deems inappropriate.

2.2 Authorized Users. Customer may allow such number of Customer’ s employees and/or independent contractors as is indicated on an Order Form to use the applicable Platform on behalf of Customer as “ Customer Users.” Additionally, if applicable to a Platform, Customer may allow such number of (i) designees (“ Vendor Users”, and together with Customer Users, “ Authorized Users”) and, ii) subject to Sharp Performance’ s then- current Vendor Terms of Use, its vendors (“ Vendors”) as is indicated on an Order Form, and their personnel, to access each Platform in connection with such Vendor’ s activity with Customer through such Platform. Authorized User subscriptions are for designated Authorized Users and cannot be shared or used by more than one Authorized User, but may be reassigned to a new Authorized User replacing former Authorized Users who no longer require ongoing use of the applicable Platform.

2.3 Authorized User Conditions to Use. As a condition to access and use of a Platform ( i) each Authorized User shall agree to abide by the terms of Sharp Performance’ s end- user terms of use which it may adopt from time to time, ( ii) Customer Users shall agree to abide by the terms of this Agreement, and ( iii) Vendor Users shall agree to abide by the terms of the then- current Sharp Performance Vendor Terms of Service applicable to such Platform, and, in each case, Customer shall ensure such compliance.

Customer shall immediately notify Sharp Performance of any violation of the terms of any of the foregoing by any Authorized User upon becoming aware of such violation, and shall be liable for any breach of the foregoing agreements by any Authorized User as provided herein.

2.4 Account Responsibility. Customer will be responsible for (i) all uses of any account that Customer has access to, whether or not Customer has authorized the particular use or user, and regardless of Customer’ s knowledge of such use, and ( ii) securing its Sharp Performance account, passwords ( including but not limited to administrative and user passwords) and files. Sharp Performance is not responsible for any losses, damages, costs, expenses or claims that result from stolen or lost passwords.

2.5 Use Restrictions. Customer shall not use the Services for any purposes beyond the scope of the access granted in this Agreement. Customer shall not at any time, directly or indirectly, and shall not permit any Authorized Users to: (i) copy, modify, or create derivative works of the Services or 650
3 Platform, in whole or in part; ( ii) rent, lease, lend, sell, license, sublicense, assign, distribute, publish, transfer, or otherwise make available the Services or Platform; ( iii) reverse engineer, disassemble, decompile, decode, adapt, or otherwise attempt to derive or gain access to any software component of the Services, in whole or in part; (iv) remove any proprietary notices from the Services or Platform; ( v) use the Services or Platform in any manner or for any purpose that infringes, misappropriates, or otherwise violates any intellectual property right or other right of any person, or that violates any applicable law, or (vi) input, upload, transmit, or otherwise provide any information or materials that are unlawful or injurious, or contain, transmit, or activate any harmful code.

2.6 Reservation of Rights. Sharp Performance reserves all rights not expressly granted to Customer in this Agreement. Except for the limited rights and licenses expressly granted under this Agreement, nothing in this Agreement grants, by implication, waiver, estoppel, or otherwise, to Customer or any third party any intellectual property rights or other right, title, or interest in or to the intellectual property of Sharp Performance.

3. ADDITIONAL RESTRICTIONS AND RESPONSIBILITIES

3.1 Software Restrictions. Customer will not, nor permit or encourage any third party to, directly or indirectly ( i) reverse engineer, decompile, disassemble or otherwise attempt to discover or derive the source code, object code or underlying structure, ideas, know- how or algorithms relevant to a Platform or any software, documentation or data related to a Platform (“ Software”); ( ii) modify, translate, or create derivative works based on a Platform or any Software; ( iii) use a Platform or any Software for timesharing or service bureau purposes or other computer service to a third party; ( iv) modify, remove or obstruct any proprietary notices or labels; or (v) use any Software or a Platform in any manner to assist or take part in the development, marketing or sale of a product potentially competitive with such Software or Platform. For the avoidance of doubt, Software and the Services, including all user- visible aspects of the Services, are the Confidential Information of Sharp Performance, and Customer will comply with Section 4 with respect thereto.

3.2 Customer Compliance. Customer shall use, and will ensure that all Authorized Users use, each Platform, Software, and the Services in full compliance with this Agreement, Periscope’ s end-user terms of use and all applicable laws and regulations. Customer represents and warrants that it i) has accessed and reviewed any terms of use or other policies relating to a Platform provided by Sharp Performance, ( ii) understands the requirements thereof, and ( iii) agrees to comply therewith.

Sharp Performance may suspend Customer’ s account and access to each Platform and performance of the Services at any time and without notice if Sharp Performance believes that Customer is in violation of this Agreement. Although Sharp Performance has no obligation to monitor Customer’ s use of a Platform, Sharp Performance may do so and may prohibit any use it believes may be (or alleged to be) in violation of the foregoing.

3.3 Cooperation. Customer shall provide all reasonable cooperation and assistance as Sharp Performance may reasonably request to enable Sharp Performance to exercise its rights and perform its obligations under, and in connection with, this Agreement. Customer, at its discretion, may provide Sharp Performance with such access to Customer’ s premises and its information technology infrastructure, as is necessary for Sharp Performance to perform the Services in accordance with this Agreement.

3.4 Training and Education. Customer shall use commercially reasonable efforts to cause Customer Users to be, at all times, educated and trained in the proper use and operation each Platform such Customer Users utilize, and to ensure that each Platform is used in accordance with applicable 651
4 manuals, instructions, specifications and documentation provided by Sharp Performance from time to time.

3.5 Customer Systems. Customer shall be responsible for obtaining and maintaining— both the functionality and security of—any equipment and ancillary services needed to connect to, access or otherwise use each Platform, including modems, hardware, servers, software, operating systems, networking, web servers and the like.

3.6 Restrictions on Export. Customer may not remove or export from the United States or allow the export or re- export of the Software or anything related to a Platform, Software or Services, or any direct product thereof in violation of any restrictions, laws or regulations of any United States or foreign agency or authority.

4. CONFIDENTIALITY.

4.1 Confidential Information. Each Party ( the “ Receiving Party”) understands that the other party (the “ Disclosing Party”) has been, and may be, exposed to or acquired business, technical or financial information relating to the Disclosing Party’ s business ( hereinafter referred to as Confidential Information”). Confidential Information of Sharp Performance includes non-public information regarding features, functionality and performance of each Platform and Software.

Confidential Information of Customer includes non-public data provided by Customer to Sharp Performance to enable the provision of access to, and use of, the Services as well as all content, data and information recorded and stored by each Platform for Customer (“ Customer Data”), but explicitly excludes Vendor Information ( defined below). The terms and conditions of this Agreement, including all pricing and related metrics, are Sharp Performance’ s Confidential Information.

4.2 Exceptions. Notwithstanding anything to the contrary contained herein, Confidential Information shall not include any information that the Receiving Party can document ( i) is or becomes generally available to the public, ( ii) was in its possession or known by it prior to receipt from the Disclosing Party, ( iii) was rightfully disclosed to it without restriction by a third party, or (iv) was independently developed without use of any Confidential Information of the Disclosing Party.

4.3 Non- use and Non-disclosure. With respect to Confidential Information of the Disclosing Party, the Receiving Party agrees to: ( i) use the same degree of care to protect the confidentiality and prevent the unauthorized use or disclosure of such Confidential Information it uses to protect its own proprietary and confidential information of like nature, which shall not be less than a reasonable degree of care, ( ii) hold all such Confidential Information in strict confidence and not use, sell, copy, transfer reproduce, or divulge such Confidential Information to any third party, (iii) not use such Confidential Information for any purposes whatsoever other than the performance of, or as otherwise authorized by, this Agreement.

4.4 Compelled Disclosure. Notwithstanding Section 4.3, the Receiving Party may disclose Confidential Information of the Disclosing Party to the extent necessary to comply with a court order or applicable law; provided, however that the Receiving Party delivers reasonable advance notice of such disclosure to the Disclosing Party and uses reasonable efforts to secure confidential treatment of such Confidential Information, in whole or in part.

4.5 Remedies for Breach of Obligation of Confidentiality. The Receiving Party acknowledges that breach of its obligation of confidentiality may cause irreparable harm to the Disclosing Party for which the Disclosing Party may not be fully or adequately compensated by 652
5 recovery of monetary damages. Accordingly, in the event of any violation, or threatened violation, by the Receiving Party of its obligations under this Section, the Disclosing Party shall be entitled to seek injunctive relief from a court of competent jurisdiction in addition to any other remedy that may be available at law or in equity, without the necessity of posting bond or proving actual damages.

5. PROPRIETARY RIGHTS

5.1 Ownership. Customer shall own all right, title and interest in and to the Customer Data. Sharp Performance shall own and retain all right, title and interest in and to ( i) each Platform, Software and the Services and all improvements, enhancements or modifications thereto, ( ii) any software, applications, inventions or other technology developed in connection with the Services, and iii) all intellectual property and proprietary rights in and related to any of the foregoing ( collectively, Services IP”). To the extent Customer acquires any right, title or interest in any Services IP, Customer hereby assigns all of its right, title and interest in such Services IP to Sharp Performance.

5.2 No Other Rights. No rights or licenses are granted except as expressly set forth herein.

6. FEES & PAYMENT

6.1 Fees. Customer shall pay Sharp Performance the then- applicable fees described in an Order Form or Statement of Work, as applicable, in accordance with the terms set forth therein Fees”), including, for the avoidance of doubt, any fees incurred through Customer’ s use of a Platform exceeding a services capacity parameter specified on an Order Form.

6.2 Renewal Fees. Upon the commencement of each Renewal Term, ( i) Customer shall be liable to Sharp Performance for payment of a Renewal Fee. Customer hereby consents to Sharp Performance charging any such Renewal Fee to the credit card, or other payment method, associated with Customer’ s account without need to provide any further notice or receive any further consent.

Each “ Renewal Fee” shall equal the Service Fee or Renewal Fee, as applicable, due to Sharp Performance during previous term as may be increased in Sharp Performance’ s sole discretion by a percentage up to the Fee Increase Percentage specified on the applicable Order Form; provided, if the Initial Term was greater than one ( 1) year, for purposes of calculating the initial Renewal Fee the Service Fee shall be prorated to one ( 1) year. Notwithstanding the foregoing, if Customer is not liable to Sharp Performance for a Service Fee under an Order Form, no Renewal Fees shall be charged to Customer with respect to such Order Form.

6.3 Payment. Sharp Performance may choose to bill through an invoice, in which case, full payment for invoices issued in any given month must be received by Sharp Performance sixty (60) days after the mailing date of the invoice ( unless otherwise specified on the applicable Order Form). In addition to any other remedies available, Sharp Performance may suspend Services in the event of payment delinquency.

6.4 Payment Disputes. If Customer believes that Sharp Performance has billed Customer incorrectly, Customer must contact Sharp Performance no later than thirty ( 30) days after the closing date on the first billing statement in which the alleged error or problem appeared in order to receive an adjustment or credit. Inquiries should be directed to Sharp Performance’ s customer support department or the applicable Account Manager.
653
6 6.5 Taxes. All Fees and other amounts payable by Customer under this Agreement are exclusive of taxes and similar assessments. Customer is responsible for all sales, use, and excise taxes, and any other similar taxes, duties, and charges of any kind imposed by any federal, state, or local governmental or regulatory authority on any amounts payable by Customer hereunder, other than any taxes imposed on Sharp Performance’ s income.

6.6 No Deductions or Setoffs. All amounts payable to Sharp Performance hereunder shall be paid by Customer to Sharp Performance in full without any setoff, recoupment, counterclaim, deduction, debit or withholding for any reason except as may be required by applicable law.

7. TERM AND TERMINATION

7.1 Term. This Agreement shall remain in effect until its termination as provided below the “ Term”). The term of each Statement of Services shall begin on the applicable “ Services Effective Date” and continue for the “ Service Term,” in each case as specified in such Statement of Services. Each Order Form may be renewed by mutual Amendment to this Agreement for one ( 1) year periods if the Service Term is equal to or greater than one ( 1) year, or (ii) periods equal to the Service Term if the Service Term is less than one (1) year ( each, a “ Renewal Term”), provided that a written notice of intent to renew is received by the other Party at least thirty (30) days prior to the expiration of the then- current term of the Agreement.

7.2 Termination. Sharp Performance may terminate this Agreement upon written notice to Customer if no Statement of Services is in effect. In addition to any other remedies it may have, either party may also terminate this Agreement upon written notice if the other party fails to pay any amount when due or otherwise materially breaches this Agreement and fails to cure such breach within thirty 30) days or as agreed upon by both parties after receipt of written notice of such breach from the nonbreaching party. Notwithstanding the foregoing, if Customer is a state agency or a political subdivision of a state, or a federal agency or a political subdivision of the federal government, Customer may terminate this Agreement at any time (i) for convenience upon ninety ( 90) days’ written notice to Sharp Performance, or ( ii) if adequate funds to pay Sharp Performance all fees owed hereunder are not appropriated to such Customer during the Term, unless otherwise authorized by law; provided, it is expressly agreed that Customer shall not activate this non-appropriation provision for its convenience, substation for another procurement system or solution, or to circumvent the requirements of this Agreement in any way. Sharp Performance reserves the right to terminate this contract in the event of a merger, reorganization, consolidation, sale of assets, bankruptcy, and dissolution.

7.3 Effect of Termination. Upon termination of the Agreement, each outstanding Statement of Services, if any, shall terminate and Customer shall immediately cease all use of, and all access to, the Subscription Services and Sharp Performance shall immediately cease providing the Professional Services. If (i) Sharp Performance terminates this Agreement pursuant to the second sentence of Section 7.2, or (ii) Customer terminates this Agreement pursuant to clause ( i) of the last sentence of Section 7.2, all Fees that would have become payable had each outstanding Statement of Service remained in effect until expiration of its current term will become immediately due and payable.

7.4 Survival. Sections [ 3.1, 4–6, 7.2, 7.4, and 9–17] shall survive any termination or expiration of this Agreement. All other rights and obligations shall be of no further force or effect.

8. WARRANTY AND DISCLAIMER

8.1 Warranties. Sharp Performance represents and warrants that it will perform the 654
7 Professional Services in a professional and workmanlike manner. Each party represents and warrants that it has the legal power to enter into this Agreement. Additionally, Customer warrants that ( i) Customer owns or has a license to use and has obtained all consents and approvals necessary for the provision and use of all of the Customer Data that is placed on, transmitted via or recorded by a Platform and the Services; ( ii) the provision and use of Customer Data as contemplated by this Agreement and each Platform and the Services does not and shall not violate any Customer’ s privacy policy, terms- of-use or other agreement to which Customer is a party or any law or regulation to which Customer is subject to; and ( iii) no Customer Data will include social security numbers or other government- issued identification numbers, financial account numbers, credit card or debit card numbers, credit report information or other personal financial information, health or medical information or other information that is subject to international, federal, state, or local laws or ordinances now or hereafter enacted regarding data protection or privacy, including, but not limited to, the Health Insurance Portability and Accountability Act, the Health Information Technology for Economic and Clinical Health Act, the Fair Credit Reporting Act, the Children’ s Online Privacy Protection Act and the Gramm- Leach- Bliley Act.

8.2 Disclaimer. EXCEPT AS EXPRESSLY PROVIDED HEREIN OR IN A

STATEMENT OF SERVICE, SHARP PERFORMANCE DOES NOT WARRANT THAT ACCESS

TO THE PLATFORMS, SOFTWARE OR SERVICES WILL BE UNINTERRUPTED OR ERROR

FREE, NOR DOES SHARP PERFORMANCE MAKE ANY WARRANTY AS TO THE RESULTS THAT MAY BE OBTAINED FROM USE OF THE SERVICES. FURTHER, SHARP

PERFORMANCE MAKES NO REPRESENTATIONS OR WARRANTIES WITH RESPECT TO

SERVICES PROVIDED BY THIRD PARTY TECHNOLOGY SERVICE PROVIDERS RELATING

TO OR SUPPORTING A PLATFORM, INCLUDING HOSTING AND MAINTENANCE SERVICES,

AND ANY CLAIM OF CUSTOMER ARISING FROM OR RELATING TO SUCH SERVICES

SHALL, AS BETWEEN SHARP PERFORMANCE AND SUCH SERVICE PROVIDER, BE SOLELY AGAINST SUCH SERVICE PROVIDER. THE PLATFORMS, SOFTWARE AND SERVICES ARE PROVIDED “ AS IS,” AND SHARP PERFORMANCE DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF NONINFRINGEMENT, MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW.

9. INDEMNITY.

9.1 Sharp Performance Indemnification. To the maximum extent permitted by law, Sharp Performance hereby agrees, at its sole cost and expense, to defend protect, indemnify, and hold harmless Customer, its elected and appointed officials, officers, employees, volunteers, attorneys, and agents ( collectively “ Indemnitees”) from and against any and all claims, including, without limitation, claims for intellectual property infringement, bodily injury, death or damage to property, demands, charges, obligations, damages, causes of action, proceedings, suits, losses, stop payment notices, judgments, fines, liens, penalties, liabilities, costs and expenses of every kind and nature whatsoever, in any manner arising out of, incident to, related to, in connection with or arising from any act, failure to act, error or omission of Sharp Performance’ s Services ( including any of its officers, agents, employees, Subcontractors) or its failure to comply with any of its obligations contained in the Agreement, or its failure to comply with any current or prospective law, except for such loss or damage which was caused by the sole negligence or willful misconduct of Customer. Sharp Performance’ s obligation to indemnify shall not be restricted to insurance proceeds, if any, received by Sharp Performance or Indemnitees. This indemnification obligation shall survive this Agreement and shall not be limited by any term of any insurance policy required under this Agreement.

9.2 Customer Indemnification. Customer shall indemnify, hold harmless, and, at Sharp 655
8 Performance’ s option, defend Sharp Performance from and against any damages, losses, liabilities, costs and fees ( including reasonable attorney’ s fees) incurred by Sharp Performance resulting from any thirdparty claim, suit, action, or proceeding that is based on Customer’ s or any Authorized User’ s ( i) use of the Services in a manner not authorized by this Agreement; ( ii) use of the Services in combination with data, software, hardware, equipment, or technology not provided by Sharp Performance or authorized by Sharp Performance in writing; or (iii) modifications to the Services not made by Sharp Performance. This section sets forth Customer' s sole obligation and liability and Sharp Performance' s exclusive remedy with respect to any actions or losses described herein

9.3 Sole Remedy. THIS SECTION 9 SETS FORTH CUSTOMER’ S SOLE REMEDIES AND SHARP PERFORMANCE’ S SOLE LIABILITY AND OBLIGATION FOR ANY ACTUAL,

THREATENED, OR ALLEGED CLAIMS THAT THE SERVICES INFRINGE, MISAPPROPRIATE,

OR OTHERWISE VIOLATE ANY INTELLECTUAL PROPERTY RIGHTS OF ANY THIRD PARTY.

9.4 Insurance. Sharp Performance shall comply with the insurance requirements set forth in Exhibit D. Insurance requirements that are waived by the City’ s Risk Manager do not require amendments or revisions to this Agreement.

10. GOVERNING LAW AND DISPUTE RESOLUTION. This Agreement is governed in all respects by the laws of the State of California, without giving effect to its rules relating to conflict of laws. Any action at law, suit in equity, or judicial proceeding arising out of this Agreement shall be instituted and maintained only in the Superior Court for the County of Los Angeles or the United States District Court for the Central District of California. Neither any adoption of the Uniform Computer Information Transactions Act nor the U.N. Convention on the International Sale of Goods applies to this Agreement or to the rights or duties of the parties under this Agreement. Any dispute arising out of or relating to this Agreement, or its subject matter, shall be resolved exclusively by binding arbitration under the Commercial Arbitration Rules of the American Arbitration Association (“ AAA”). Either party may send a notice to the other party of its intention to file a case with the AAA under this Section (“ Arbitration Notice”). The arbitration will be conducted in California by a single arbitrator knowledgeable in government contracting matters and the commercial aspect of “ software as a service” arrangements and intellectual property. The parties will mutually appoint an arbitrator within thirty ( 30) days of the Arbitration Notice. If the parties are unable to agree on an arbitrator, then the AAA will appoint an arbitrator who meets the foregoing knowledge requirements. The arbitration hearing will commence within sixty ( 60) days after the appointment of the arbitrator and the hearing will be completed and an award rendered in writing within sixty ( 60) days after the commencement of the hearing. Prior to the hearing, each party will have the right to take up to four ( 4) evidentiary depositions, and exchange two 2) sets of document production requests and two sets, each, of not more than ten ( 10) interrogatories.

The arbitrator will provide detailed written explanations to the parties to support their aware and regardless of outcome, each party shall pay its own costs and expenses ( including attorneys’ fees) associated with the arbitration proceeding and fifty percent ( 50%) of the fees of the arbitrator and the AAA. The arbitration award will be final and binding and may be enforced in any court of competent jurisdiction.

11. SECURITY. Sharp Performance may, from time to time, host and/or maintain a Platform using a third-party technology service provider. Customer acknowledges that Sharp Performance cannot offer any additional or modified procedures other than those put in place by such technology provider with respect to such technology service.
656
9 12. PUBLICITY. Notwithstanding anything herein to the contrary, Customer acknowledges that Sharp Performance may disclose the existence and terms and conditions of this Agreement to its advisors, actual and potential sources of financing and to third parties for purposes of due diligence.

13. NOTICES. All notices, consents, and other communications between the Parties under or regarding this Agreement must be in writing ( which includes email and facsimile) and be addressed according to information provided on an Order Form. All notices, consents and other communications between the parties under a Statement of Services will be sent to the recipient’ s address specified thereon.

All communications will be deemed to have been received on the date actually received. Either Party may change its address for notices by giving written notice of the new address to the other party in accordance with this Section.

14. FORCE MAJEURE. Sharp Performance is not responsible nor liable for any delays or failures in performance from any cause beyond its control, including, but not limited to acts of God, changes to law or regulations, embargoes, war, terrorist acts, acts or omissions of third party technology providers, riots, fires, earthquakes, floods, power blackouts, strikes, weather conditions or acts of hackers, internet service providers or any other third party or acts or omissions of Customer or any Authorized User.

15. ASSIGNMENT. Neither party may assign this Agreement to any third party without the prior written consent of the other; provided that no consent is required in connection with an assignment to an affiliate or in connection with any merger, reorganization, consolidation, sale of assets or similar transaction. Sharp Performance may only sublicense any or all of its obligations hereunder with prior written consent of Customer. For the avoidance of doubt, a third-party technology provider that provides features or functionality in connection with a Platform shall not be deemed a sublicensee under this Agreement. This Agreement is binding upon and insures to the benefit of the Parties and their respective permitted successors and assigns.

16. GENERAL PROVISIONS. If any provision of this Agreement is found to be unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary so that this Agreement will otherwise remain in full force and effect and enforceable. This Agreement, together with Statement of Services entered into hereunder and all exhibits, schedules, annexes, and addenda hereto and thereto is the complete and exclusive statement of the mutual understanding of the parties and supersedes and cancels all previous written and oral agreements, communications and other understandings relating to the subject matter of this Agreement. All waivers and modifications must be in a writing signed by both parties, except as otherwise provided herein. No agency, partnership, joint venture, or employment is created as a result of this Agreement, and neither party has authority of any kind to bind the other party in any respect whatsoever. In the event of a conflict between this Agreement and any Statement of Services, such Statement of Services shall prevail unless otherwise expressly indicated in this Agreement or such Statement of Services. The heading references herein are for convenience purposes only and shall not be deemed to limit or affect any of the provisions hereof. Unless otherwise indicated to the contrary herein by the context or use thereof: ( i) the words “ hereof,” “ hereby,” herein,” “ hereto,” and “ hereunder” and words of similar import shall refer to this Agreement as a whole and not to any particular Section or paragraph of this Agreement; ( ii) the words “ include,” “ includes” or including” are deemed to be followed by the words “ without limitation;” ( iii) references to a “ Section” or “ Exhibit” are references to a section of, or exhibit to this Agreement; and ( iv) derivative forms of defined terms will have correlative meanings. This Agreement may be executed in counterparts, each of which is deemed an original, but all of which together are deemed to be one and the same agreement. 657
10 IN WITNESS WHEREOF, the undersigned execute this instrument as of the day and date first above written.

SHARP PERFORMANCE, INC. CITY OF REDONDO BEACH
By: ___________________________ By: ______________________________ Name: Benjamin Curley Name: James A. Light
Title: CEO/President Title: Mayor
ATTEST:

Eleanor Manzano, City Clerk
APPROVED AS TO FORM:

Michael W. Webb, City Attorney
APPROVED:

Diane Strickfaden, Risk Manager
12/ 4/ 2024 | 4: 56 PM PST
658
11 Sharp Performance Inc.
2659 State St #100,
Carlsbad, CA 92008
andrew@sharpperformance. tech, ben@sharpperformance. tech Schedule A
Order Form
Customer: City of Redondo Beach
Product: Subscription Services, Professional Services: unlimited access to Sharp coaches and chaplains, Sharp self-paced exercises and training, and partnership with Sharp to develop a customized resource directory.

Authorized Users:

Police Department: ~ 150 users; ~ 100 sworn, ~ 50 civilians Fire Department: ~ 66 users; ~ 64 sworn, ~ 2 civilians
Dates: Services Effective Date: TBD
Service Term: 1 year from Contract date
Payment: Due upon delivery
Total Price: $ 75,600
Total Discount: 30%
Year 1
Police Department Annual Contract Value: $ 75,000
Discount: ~33% with free civilians
Price per User: $ 500/sworn
Total Year 1 Cost: $50,000
Fire Department Annual Contract Value: $ 33,000
Discount: ~20% with free civilians
Price per User: $ 400/sworn
Total Year 1 Cost: $25,600
659
12 Sharp Performance Inc.
2659 State St #100,
Carlsbad, CA 92008
andrew@sharpperformance. tech, ben@sharpperformance. tech Schedule B
Statement of Services
Customer: _ City of Redondo Beach_
Subscription Services: Unlimited access to application and all features within for authorized users ( see Schedule A Order Form), and ongoing platform upgrades throughout the term of the contract.

Sharp Performance Mobile- App Features

1. Mental Performance Coaching. Connect with Sharp Performance’ s roster of highly- trained performance coaches.

Each coach has been specially trained to work with high-risk professionals and help them reach their full potential on the job and at home. Work with coaches often focuses on goal- setting and accountability. Users have unlimited access to coaches.

2. Self-Paced Training Modules. Access hundreds of mobile- based training exercises, adapted from training protocols originally developed for the U.S. Military’ s Special Operations teams. These 2 to 10-minute exercises are designed specifically for high-risk professions and have demonstrated significant improvements in focus, stress endurance, and psychological flexibility.

3. Resource Directory. Access a customized directory of health and wellness resources that is designed in close collaboration with your agency. The directory includes, but is not limited to, internal mental health services, chaplains, health incentives, national hotlines, and commercial partnerships exclusive to Sharp Performance.

Professional Services:

1. In-person onboarding with the Sharp team. Sharp leadership will travel to the agency and work directly with personnel to maximize engagement with the platform. Sharp will consult with agency leadership and determine the most effective way to provide services to the highest number of personnel possible including. Services include, but are not limited to, a platform overview, personalized performance strategies, 1-on-1 coach matching consultations, and testimonials from coaches and existing users.

2. Anonymized utilization reports. Share anonymized data on utilization and user satisfaction with Department Leadership and/or program point- of-contact on a quarterly basis.

3. Technical support. On-demand customer support.

Sharp Performance Inc. will not charge the customer for travel associated with In-person training overview, onboarding, and Q&A.
660
13 EXHIBIT “ D”

INSURANCE REQUIREMENTS FOR CONTRACTORS
Without limiting Contractor’ s indemnification obligations under this Agreement, Contractor shall procure and maintain for the duration of the contract insurance against claims for injuries to persons or damages to property which may arise from or in connection with the performance of the work hereunder by the Contractor, its agents, representatives, or employees.

Minimum Scope of Insurance
Coverage shall be at least as broad as:

Insurance Services Office Commercial General Liability coverage ( occurrence form CG 0001).

Insurance Services Office form number CA 0001 (Ed. 1/87) covering Automobile Liability, code 1 (any auto).

Workers’ Compensation insurance as required by the State of California.

Employer’ s Liability Insurance.

Cyber Liability Insurance.

Minimum Limits of Insurance
Contractor shall maintain limits no less than:

General Liability: $ 2,000,000 per occurrence for bodily injury, personal injury and property damage. The general aggregate limit shall apply separately to this project.

Automobile Liability: $ 1,000,000 per accident for bodily injury and property damage.

Employer’ s Liability: $ 1,000,000 per accident for bodily injury or disease.

Cyber Liability Insurance: $ 2,000,000 per occurrence for data breaches, cyberattacks, and other cybersecurity risks
Deductibles and Self-Insured Retentions
Any deductibles or self-insured retentions must be declared to and approved by the City. At the option of the City, either: ( 1) the insurer shall reduce or eliminate such deductibles or selfinsured retentions as respects the City, its officers, officials, employees and volunteers or (2) the Contractor shall provide a financial guarantee satisfactory to the City guaranteeing payment of losses and related investigations, claim administration and defense expenses. 661
14 Other Insurance Provisions
The general liability and automobile liability policies are to contain, or be endorsed to contain, the following provisions:

Additional Insured Endorsement:

General Liability: The City, its officers, elected and appointed officials, employees, and volunteers shall be covered as insureds with respect to liability arising out of work performed by or on behalf of the Contractor. General liability coverage can be provided in the form of an endorsement to the Contractor’ s insurance, or as a separate owner’ s policy.

Automobile Liability: The City, its officers, elected and appointed officials, employees, and volunteers shall be covered as insureds with respect to liability arising out of automobiles owned, leased, hired or borrowed by or on behalf of the Contractor.

For any claims related to this project, the Contractor’ s insurance coverage shall be primary insurance as respects the City, its officers, elected and appointed officials, employees, and volunteers. Any insurance or self-insurance maintained by the City, its officers, officials, employees, or volunteers shall be excess of the Contractor’ s insurance and shall not contribute with it.

Each insurance policy required by this clause shall be endorsed to state that coverage shall not be canceled by either party, except after thirty ( 30) days prior written notice by certified mail, return receipt requested, has been given to the City.

Each insurance policy shall be endorsed to state that the inclusion of more than one insured shall not operate to impair the rights of one insured against another insured, and the coverages afforded shall apply as though separate policies had been issued to each insured.

Each insurance policy shall be in effect prior to awarding the contract and each insurance policy or a successor policy shall be in effect for the duration of the project. The maintenance of proper insurance coverage is a material element of the contract and failure to maintain or renew coverage or to provide evidence of renewal may be treated by the City as a material breach of contract on the Contractor’ s part.

Acceptability of Insurers
Insurance shall be placed with insurers with a current A.M. Best’s rating of no less than A:VII and which are authorized to transact insurance business in the State of California by the Department of Insurance.
662
15 Verification of Coverage
Contractor shall furnish the City with original certificates and amendatory endorsements effecting coverage required by this clause. The endorsements should be on the City authorized forms provided with the contract specifications. Standard ISO forms which shall be subject to City approval and amended to conform to the City’s requirements may be acceptable in lieu of City authorized forms. All certificates and endorsements shall be received and approved by the City before the contract is awarded. The City reserves the right to require complete, certified copies of all required insurance policies, including endorsements effecting the coverage required by these specifications at any time.

Subcontractors
Contractor shall include all subcontractors as insured under its policies or shall furnish separate certificates and endorsements for each subcontractor. All coverages for subcontractors shall be subject to all of the requirements stated herein.

Risk Management
Contractor acknowledges that insurance underwriting standards and practices are subject to change, and the City reserves the right to make changes to these provisions in the reasonable discretion of its Risk Manager.
663

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.

INSURER( S) AFFORDING COVERAGE
INSURER F :

INSURER E :

INSURER D :

INSURER C :

INSURER B :

INSURER A :

NAIC #
NAME:

CONTACT
A/C, No):

FAX
E- MAILADDRESS:

PRODUCER
A/C, No, Ext):

PHONE

INSURED
COVERAGES CERTIFICATE NUMBER: REVISION NUMBER:

IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement( s).

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER( S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

OTHER:

Per accident)
Ea accident)
N / A
SUBR
WVD
ADDL
INSD

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS

CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.

PROPERTY DAMAGE
BODILY INJURY ( Per accident)
BODILY INJURY ( Per person)

COMBINED SINGLE LIMIT

AUTOS ONLY

AUTOSAUTOS ONLY

NON- OWNED

SCHEDULEDOWNED

ANY AUTO

AUTOMOBILE LIABILITY
Y / N

WORKERS COMPENSATION

AND EMPLOYERS' LIABILITY
OFFICER/ MEMBER EXCLUDED?
Mandatory in NH)
DESCRIPTION OF OPERATIONS below
If yes, describe under

ANYPROPRIETOR/ PARTNER/ EXECUTIVE
E.L. DISEASE - POLICY LIMIT
E.L. DISEASE - EA EMPLOYEE
E.L. EACH ACCIDENT
STATUTEPER EROTHMM/ DD/ YYYY) LIMITS(

POLICY EXP(

MM/ DD/ YYYY) NUMBERTYPEEFFPOLICYPOLICY INSURANCELTRINSR OF DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES ( ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

EXCESS LIAB
UMBRELLA LIAB $ EACH OCCURRENCE

AGGREGATE
OCCUR

CLAIMS- MADE
DED RETENTION $

PRODUCTS - COMP/ OP AGG

GENERAL AGGREGATE

PERSONAL & ADV INJURY
MED EXP ( Any one person)

EACH OCCURRENCE
DAMAGE TO RENTED $
PREMISES ( Ea occurrence)

COMMERCIAL GENERAL LIABILITY

CLAIMS- MADE OCCUR
GEN' L AGGREGATE LIMIT APPLIES PER:

POLICY
PROJECT LOC

CERTIFICATE OF LIABILITY INSURANCE

DATE ( MM/ DD/YYYY)

CANCELLATION

AUTHORIZED REPRESENTATIVE
ACORD 25 (2016/ 03)
1988- 2015 ACORD CORPORATION. All rights reserved.

CERTIFICATE HOLDER
The ACORD name and logo are registered marks of ACORD
HIRED

AUTOS ONLY

EMBROKER
09/04/2024
Embroker Insurance Services LLC
5214F Diamond Heights Blvd. Unit #1261
San Francisco, CA, 94131
Julie Noonan
844) 436-2765
[email protected]
Sharp Performance Inc
175 Varick St
C/o Columbia Startup Lab
Manhattan New York, NY, 10014
HARTFORD UNDERWRITERS INS CO 30104
HARTFORD ACCID & IND CO 22357
STATE NATL INS CO INC 12831
59bf0af4-6ab9-11ef-b08c-d7f4513bb6d3
x
x
x
Y Y
2,000,000
1,000,000
10,000
2,000,000
4,000,000
4,000,000
A 57SBMBD6V90 02/14/2024 02/14/2025
x x
Y Y
2,000,000
A 57SBMBD6V90 02/14/2024 02/14/2025
N
x
1,000,000
1,000,000
1,000,000
B 57WECBD6V9B 02/14/2024 02/14/2025
Redondo Beach Police Department
401 Diamond St
Redondo Beach, CA, 90277
LiabilityC 000Tech EO Cyber EHJADM00911437 03/20/2024 03/20/2025 Aggregate 2,000, Redondo Beach Police Department is included as an Additional Insured on the General Liability and Auto Liability policies as per written contract.

A Waiver of Subrogation applies to the Additional Insured with respect to the General Liability and Auto Liability policies as per written contract.

Redondo Beach Police Department is included as an Additional Insured on a primary non-contributory basis on the General Liability and Auto Liability policies as per written contract.
664
09/30/2026
Sequoia Benefits & Insurance Services, LLC
1850 Gateway Drive, Suite 700
San Mateo CA 94404
Certificate Request
[email protected]
Sharp Performance Inc.
2659 State Street, Suite #100
Carlsbad CA 92008-1627
Hartford Underwriters Insurance Company 30104
Hartford Accident & Indemnity Company 22357
The Hartford / Rated by Multiple Companies 00914
26-27 LIAB
A 57SBMBK8L6Y 09/27/2026 09/27/2027
2,000,000
1,000,000
10,000
2,000,000
4,000,000
4,000,000
B 57UECBF1401 09/27/2026 09/27/2027
1,000,000
A 57SBMBK8L6Y 09/27/2026 09/27/2027
2,000,000
2,000,000
C N 57WECBD6V9B 02/14/2026 02/14/2027
1,000,000
1,000,000
1,000,000

SEE ADDENDUM FOR ADDITIONAL
COVERAGES (E&O, Cyber, Prof Liab) See Addendum
Evidence of Insurance.

Redondo Beach Police Department
401 Diamond St
Redondo Beach CA 90277

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.

INSURER(S) AFFORDING COVERAGE
INSURER F :

INSURER E :

INSURER D :

INSURER C :

INSURER B :

INSURER A :

NAIC #
NAME:

CONTACT
(A/C, No):

FAX
E-MAIL
ADDRESS:

PRODUCER
(A/C, No, Ext):

PHONE

INSURED
COVERAGES CERTIFICATE NUMBER: REVISION NUMBER:

IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

OTHER:
(Per accident)
(Ea accident)
$
$
N / A
SUBR
WVD
ADDL
INSD
THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED.

NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE

ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. *LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. LIMITS SHOWN ARE INCLUSIVE OF AMOUNTS REQUESTED BY THE CERTIFICATE HOLDER AND MAY NOT REFLECT POLICY LIMIT AMOUNTS IN EXCESS OF THOSE REQUESTED. *Not Applicable in WY $
$
$
$

PROPERTY DAMAGE
BODILY INJURY (Per accident)
BODILY INJURY (Per person)

COMBINED SINGLE LIMIT

AUTOS ONLY

AUTOS ONLY AUTOS

NON-OWNED

OWNED SCHEDULED

ANY AUTO

AUTOMOBILE LIABILITY
Y / N

WORKERS COMPENSATION

AND EMPLOYERS' LIABILITY
OFFICER/MEMBER EXCLUDED?
(Mandatory in NH)
DESCRIPTION OF OPERATIONS below
If yes, describe under

ANY PROPRIETOR/PARTNER/EXECUTIVE
$
$
$
E.L. DISEASE - POLICY LIMIT
E.L. DISEASE - EA EMPLOYEE
E.L. EACH ACCIDENT
ER
OTHSTATUTEPER
(MM/DD/YYYY) LIMITS

POLICY EXP
(MM/DD/YYYY)

POLICY EFF

LTR TYPE OF INSURANCE POLICY NUMBER
INSR
DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

EXCESS LIAB
UMBRELLA LIAB EACH OCCURRENCE $
AGGREGATE $
$
OCCUR

CLAIMS-MADE
DED RETENTION $
PRODUCTS - COMP/OP AGG $
GENERAL AGGREGATE $
PERSONAL & ADV INJURY $
MED EXP (Any one person) $
EACH OCCURRENCE $

DAMAGE TO RENTED
PREMISES (Ea occurrence) $

COMMERCIAL GENERAL LIABILITY

CLAIMS-MADE OCCUR
GEN'L AGGREGATE LIMIT APPLIES PER:

POLICY
PROJECT LOC

CERTIFICATE OF LIABILITY INSURANCE DATE (MM/DD/YYYY)

CANCELLATION

AUTHORIZED REPRESENTATIVE
ACORD 25 (2025/12) © 1988-2025 ACORD CORPORATION. All rights reserved.

CERTIFICATE HOLDER
The ACORD name and logo are registered marks of ACORD
HIRED

AUTOS ONLY
665
Sequoia Benefits & Insurance Services, LLC Sharp Performance Inc. 25 Certificate of Liability Insurance: Notes
ADDITIONAL COVERAGES:

Coverage: Tech E&O/Cyber - Primary
Carrier: State National Insurance Co; NAICS 12831
Policy#: EHJADO02695791
Term: 3/20/2026 to 3/202/2027
Limits of Insurance: $2,000,000 Each Claim / $2,000,000 Policy Aggregate Coverage: Tech E&O/Cyber - Excess
Carrier: Everspan Indemnity Insurance Co; NAICS 16882
Policy#: EM3EIIXS00033401
Term: 3/20/2026 to 3/20/2027
Limits of Insurance: $3,000,000 excess of $2,000,000 Primary Coverage: Professional Liability
Carrier: United Specialty Insurance Co; NAICS 12537
Policy#: GCT114379502
Term: 1/27/2026 to 1/27/2027
Limits of Insurance: $1,000,000 Each Claim / $1,000,000 Policy Aggregate ACORD 101 (2008/01)
The ACORD name and logo are registered marks of ACORD
© 2008 ACORD CORPORATION. All rights reserved.

THIS ADDITIONAL REMARKS FORM IS A SCHEDULE TO ACORD FORM, FORM NUMBER: FORM TITLE:

ADDITIONAL REMARKS
ADDITIONAL REMARKS SCHEDULE Page of
AGENCY CUSTOMER ID:

LOC #:

AGENCY

CARRIER NAIC CODE

POLICY NUMBER

NAMED INSURED
EFFECTIVE DATE:
666
Administrative
Report
H.16., File # 26-1231 Meeting Date: 10/6/2026
To: MAYOR AND CITY COUNCIL
From: JOY A. FORD, CITY ATTORNEY

CHERYL PARK, ASSISTANT CITY ATTORNEY
TITLE

APPROVE AN AMENDMENT TO THE AGREEMENT WITH BEST BEST & KRIEGER LLP FOR

LEGAL SERVICES TO INCLUDE SERVICES FOR BOND COUNSEL FOR AN ADDITIONAL AMOUNT OF $35,000

APPROVE AN AMENDMENT TO THE ENGAGEMENT LETTER WITH NOSSAMAN LLP FOR LEGAL SERVICES TO DECREASE THE COMPENSATION TO $45,000

EXECUTIVE SUMMARY
On March 18, 2025 the City Council approved an Engagement Letter for Legal Services with Nossaman LLP for the provision of bond counsel services related to the Measure FP General Obligation Bonds. On April 15, 2025, the City Council approved an Agreement for Legal Services with Best Best & Krieger LLP for the provision of disclosure counsel services also related to Measure FP Bonds.

Lolly Enriquez from Nossaman LLP, the attorney providing bond counsel services, has notified the City that she will be leaving Nossaman LLP in October 2026. As a result, she has recommended Mrunal Shah, a partner at Best Best & Krieger LLP, to provide the remaining bond counsel services.

There is no conflict with Best Best & Krieger LLP providing both bond and disclosure counsel services since the City is the client.

Therefore, an amendment to the existing Agreement for Legal Services with Best Best & Krieger LLP is necessary to add Mrunal Shah as bond counsel and an amendment to the Engagement Letter for Legal Services with Nossaman LLP is necessary to modify the compensation amount and reflect the termination of services.

BACKGROUND
As you are aware, in November 2024, Measure FP was passed by the voters, which approved the issuance of City of Redondo Beach General Obligation Bonds in an amount not to exceed $93,350,000 (“Bonds”), the proceeds of which will fund the reconstruction of Fire Station #1, Fire Station #2, and the Police Headquarters, and renovation of the Police Annex facility (“Project”). If this First Amendment to the Agreement for Legal Services is approved, Best Best & Krieger LLP will act as Bond Counsel for the City of Redondo Beach.

Best Best & Krieger LLP (“BBK”) was established in Riverside, California in 1891, and has been in

667
H.16., File # 26-1231 Meeting Date: 10/6/2026
Best Best & Krieger LLP (“BBK”) was established in Riverside, California in 1891, and has been in business for more than 130 years. BBK is a full-service law firm with 250 attorneys in 12 offices located throughout California, Oregon, Texas and Washington, D.C. As one of the largest and oldest California law firms, BBK has the resources to provide its clients with legal advice and representation in any matter related to disclosure counsel matters. Also, BBK’s municipal law practice is the largest of any firm in the State of California. BBK regularly represents cities in connection with matters outside of public finance.

Mrunal Shah is a partner in and practice group leader of Best Best & Krieger’s Public Finance Department. Mrs. Shah has over 20 years of experience as bond counsel assisting cities and other public agencies with general fund supported debt, including issuance of general obligation bonds, lease revenue bonds, installment purchase agreements and other financing structures. As bond counsel, Mrs. Shah regularly confers and consults with staff and consultants regarding financing methods that are contemplated to ensure the successful completion of the financing. Mrs. Shah will conduct all due diligence necessary for the issuance of the City’s General Obligation Bonds as taxexempt obligations and prepare all legal agreements and related documents that are needed to complete the issuance of such bonds. Upon our satisfaction that all legal requirements have been met, we will issue an opinion regarding the validity and enforceability of the General Obligation Bonds.
$80,000 was originally set aside from the bond proceeds specifically for bond counsel. The compensation amount for the remaining bond counsel services to be provided by Best Best & Krieger LLP through bond closing scheduled for November 2026 will be $35,000, which is a flat fee payable from bond proceeds and contingent on the bond closing.

Additionally, an amendment to the Engagement Letter for Legal Services with Nossaman LLP is necessary to modify the compensation amount and reflect the termination of services due to Lolly Enriquez’s departure from the firm. The original flat fee compensation amount will be reduced to $45,000 for time incurred from March 2026 to date.

COORDINATION
The First Amendment to Agreement for Legal Services has been approved by Best Best & Krieger LLP and the City Attorney’s Office. The First Amendment to Engagement Letter for Legal Services has been approved by Nossaman LLP and the City Attorney’s Office.

FISCAL IMPACT
The amended compensation for bond counsel with Nossaman LLP is a flat fee of $45,000 payable from the bond proceeds and contingent upon bond closing. The compensation for continued bond counsel services with Best Best & Krieger LLP is a flat fee of $35,000, payable from the bond proceeds and contingent upon bond closing. The financial consultant has confirmed that $80,000 has been set aside for bond counsel services as part of the cost of issuance.

Submitted by:

Joy A. Ford, City Attorney

ATTACHMENTS

668
H.16., File # 26-1231 Meeting Date: 10/6/2026
· First Amendment to Agreement for Legal Services with Best Best & Krieger LLP · Agreement for Legal Services with Best Best & Krieger LLP · First Amendment to Engagement Letter for Legal Services with Nossaman LLP

669

FIRST AMENDMENT TO AGREEMENT FOR LEGAL SERVICES

WITH BEST BEST & KRIEGER LLP
THIS FIRST AMENDMENT to the Agreement for Legal Services (“First Amendment”) is made this 6th day of October, 2026, by the CITY OF REDONDO BEACH, a chartered municipal corporation, ("City"), and BEST BEST & KRIEGER LLP, a Limited Liability Partnership ("Attorney”).

RECITALS
The following recitals are a substantive part of this First Amendment:

WHEREAS, on April 15, 2025 the parties entered into an Agreement for Legal Services to provide specific legal services as disclosure counsel in relation to Measure FP (“Agreement”); and
WHEREAS, the parties desire to amend the Agreement to include bond counsel services and modify the compensation.

NOW THEREFORE, in consideration of the promises and mutual covenants contained herein, and intending to be legally bound, the parties hereby agree to make the following amendments to the Agreement:

1. SERVICES TO BE PROVIDED. The Agreement is hereby amended to expand the scope of legal services to include bond counsel services as specified below:

Attorney shall confer and consult with the City staff on all matters relating to financing including participation in the review and selection of appropriate financing methods. Attorney shall assist the City in determining the most appropriate method based upon Attorney’s experience and shall attend all meetings of the City staff, consultants and underwriter at which financing methods are to be discussed and analyzed for successful completion of the financing. Attorney is available to engage in these services according to the City’s time schedule.

Attorney services shall include the preparation of all materials necessary for the proper legislative approval of the financing. Attorney shall prepare all agreements, resolutions, notices, forms of the security and all other legal documents required by California law for the execution, sale and delivery of the relevant security, as the City chooses.

Subject to completion of the financing to our satisfaction, Attorney shall issue approving legal opinion to the purchasers of the obligations, to the effect that all proceedings have been legally undertaken for the authorization, execution, sale and delivery of the obligations or other transactions relating to the financing and that interest paid with respect to the obligations is excluded from gross income for 670
2 federal income tax purposes and is exempt from State of California personal income tax. Attorney shall also issue appropriate supplemental opinions and certificates as may be necessary or appropriate.

As a necessary part of bond counsel services, Attorney shall assist with the delivery of the obligations and conduct a preclosing meeting to assure delivery of all necessary documents. After the preclosing meeting and the successful delivery of the bonds, Attorney shall prepare and distribute transcripts to all of the participants.

2. COMPENSATION. The Agreement is further amended to compensate for bond counsel services by Attorney (Mrunal Shah) at a flat rate of $35,000 rendered on the closing date of the bond from bond proceeds. The compensation is contingent on the closing of the bonds and applies to all time spent on matters related to the representation described in Section 1 above, including but not limited to, the ordinary and customary services rendered as bond counsel in connection with transactions of the type described herein.

3. NO OTHER AMENDMENTS. Except as expressly stated herein, the Agreement shall remain unchanged and in full force and effect. The Agreement and this First Amendment constitute the entire agreement between the parties and supersede any previous oral or written agreement with respect to the subject matter hereof.

In the event of any inconsistency between the terms of the Agreement and this First Amendment, the terms of this First Amendment shall govern. [SIGNATURES FOLLOW ON NEXT PAGE]

671
3 IN WITNESS WHEREOF, the parties have executed this First Amendment in Redondo Beach, California, as of this 6th day of October, 2026.

CITY OF REDONDO BEACH, BEST BEST & KRIEGER LLP
a chartered municipal corporation a Limited Liability Partnership _____________________________ By: ______________________ James A. Light Name: _______________________
Mayor Title: _______________________

ATTEST:
_____________________________
Eleanor Manzano, City Clerk
APPROVED:
_____________________________
Diane Strickfaden, Risk Manager
APPROVED AS TO FORM:
_____________________________
Joy A. Ford, City Attorney
672

AGREEMENT FOR LEGAL SERVICES
WITH

BEST BEST & KRIEGER LLP
THIS AGREEMENT is made this 15th day of April, 2025, by the CITY OF REDONDO BEACH, a chartered municipal corporation, (" CITY"), and BEST BEST & KRIEGER LLP, a Limited Liability Partnership (" ATTORNEY").

RECITALS
The following recitals are a substantive part of this Agreement:

A. This Agreement is entered into pursuant to Redondo Beach City Council authorization on April 15, 2025.

B. The CITY is a chartered municipal corporation duly organized and validly existing under the laws of the State of California with the power to carry on its business as it is now being conducted under the statutes of the State of California and the Charter of the CITY.

C. ATTORNEY is qualified to do business, and is doing business, in the State of California.

ATTORNEY represents it has the background, knowledge, experience and expertise necessary to provide the services set forth in this Agreement.

D. The CITY and ATTORNEY desire to enter into an Agreement for services upon the terms and conditions herein.

AGREEMENT
THE PARTIES MUTUALLY AGREE AS FOLLOWS:

1. Term of Agreement. This Agreement shall cover services rendered from April 15, 2025 and until terminated.

2. Attorney' s Services. The services to be performed by ATTORNEY shall consist of the following: Legal services as disclosure counsel for the CITY on the issuance of $93, 350, 000 in General Obligation ( GO) bonds authorized by Measure FP during the November 5, 2024 General Election, which includes but is not limited to the following legal services: ( 1) assist with the preparation of the Preliminary Official Statement and the Official Statement, ( 2) preparation of the Continuing Disclosure Agreement, ( 3) render negative assurance opinion letter, and ( 4) provide other legal guidance with respect to securities laws. ATTORNEY will complete the services in accordance with Section 4 of this Agreement.

3. City' s Services. CITY agrees to:

3. 1. Make available to ATTORNEY any currently existing documents, data or information required for the performance of the services.

3. 2. Designate a representative authorized to act on behalf of CITY. 673

3. 3. Promptly examine and render findings on all documents submitted for staff review by the ATTORNEY.

4. Compensation. ATTORNEY shall be compensated as follows:

4. 1. Amount.

ATTORNEY shall receive compensation at a flat rate of $65, 000 for legal services rendered on the closing date of the bonds from bond proceeds. The compensation is contingent on the closing of the bonds and applies to all time spent on matters related to the representation as described in Section 2, including but not to, the ordinary and customary services rendered as disclosure counsel in connection with transactions of the type described herein.

4. 1. 1. Any travel related to the case, excluding commuting to and from the primary office location shall be included in the flat rate above.

4. 1. 2. Reasonable travel expenses, including airfare and lodging will included in the flat rate above. For air travel, economy class tickets are expected unless otherwise justified. In no event shall meals or mileage be reimbursed. Prior to incurring any travel expense, ATTORNEY must obtain CITY's prior written approval of the charge to ensure its reasonableness. Costs, such as court fees, litigation costs, messenger and delivery services, copy expense and other similar costs will be included in the flat rate above.

4. 1. 3. Compensation for non attorneys assisting ATTORNEY shall be included in the flat rate above.

4. 1. 4. Compensation under this Agreement is contingent upon the assignment of work by CITY, acceptance of the work by ATTORNEY, and subsequent approval of the submitted hourly billing statement ( if applicable) by the City Attorney. No payment shall be made for work performed without prior authorization.

4. 2. Payment.

4. 2. 1. Payments under this Agreement shall be made based on a final invoice submitted by ATTORNEY at the closing of the bonds. The invoice must itemize the services rendered in detail, including the date, nature of the work, and time spent.

4. 2. 2. CITY agrees to pay the undisputed amount of each invoice within sixty 60) days of its receipt.

4. 2. 3. Invoices submitted to CITY for payment must be comprehensive and include the following details:

Hourly rate charged, if applicable.

Number of hours worked, specifying the dates and duration of services rendered.
674
Detailed description of the services performed, including the matter name or case reference.

Itemization of all expenses incurred, with a clear description of each expense, the cost associated with it, and a subtotal of expenses.

The total amount due, clearly stated.

4. 2. 4. All invoices must be accompanied by supporting documentation for each expense claimed. This includes, but is not limited to, receipts, billing statements, and any other relevant documents that substantiate the expenses.

4. 2. 5. Invoices must be itemized and detailed to provide a clear and transparent account of the services rendered and expenses incurred.

4. 2. 6. CITY reserves the right to request additional backup material or documentation for any charges or expenses billed by ATTORNEY.

ATTORNEY is obliged to provide such material upon CITY' s request.

4. 2. 7. ATTORNEY acknowledges that failure to attach all necessary supporting documentation may result in delayed payment or denial of the respective invoice until such documentation is provided and verified.

4. 3. Records of Expenses.

4. 3. 1. ATTORNEY shall maintain accurate and detailed records of time spent and expenses incurred in connection with services under this Agreement for a period of four (4) years following the completion of the services.

4. 3. 2. Upon CITY' s request, ATTORNEY shall provide copies of these records.

CITY shall have the right to audit these records to verify the accuracy of billing and expenses.

4. 4. Hours. No specific number of hours of work is guaranteed. It is expected that Attorney's services will be on an as needed basis depending upon the work load.

5. Default and Termination.

5. 1. Default. If ATTORNEY fails or refuses to perform any of the provisions of this Agreement, and if the default is not cured within a period of five days after the CITY' s written notice of default specifying the nature of the default, CITY may immediately terminate this Agreement by written notice to the ATTORNEY.

5. 2. Convenience. The CITY has the option, at its sole discretion and without cause, of terminating this Agreement by giving fifteen ( 15) days written notice to the ATTORNEY. Upon termination of this Agreement, CITY will pay the ATTORNEY any compensation earned and unpaid up to the effective date of termination.

5. 3. Post Termination. Upon termination of this Agreement:

5. 3. 1. ATTORNEY shall cease all services immediately, except as 675
directed in writing by CITY to conclude pending matters.

5. 3. 2. ATTORNEY shall submit a final statement of services rendered and expenses incurred up to the termination date.

5. 3. 3. ATTORNEY shall promptly return all CITY documents, materials, and any other CITY property in their possession. ATTORNEY shall also ensure the secure return or destruction of confidential information, as directed by CITY.

5. 3. 4. ATTORNEY' s duty to maintain the confidentiality of information, as stipulated in the Confidentiality Clause of this Agreement, shall persist beyond the termination of this Agreement.

5. 3. 5. ATTORNEY shall provide a concluding report to CITY, summarizing services rendered and highlighting any pending issues or areas requiring further attention.

5. 3. 6. Any disputes arising from or related to the services rendered under this Agreement shall be addressed through negotiation in good faith between the parties.

5. 3. 7. Obligations accrued prior to the termination of this Agreement shall survive its termination. This includes, but is not limited to, obligations pertaining to indemnification, confidentiality, and compliance with applicable laws.

5. 3. 8. ATTORNEY shall provide a list of any unresolved matters to CITY, and the parties shall mutually agree upon a method for resolution.

6. Records and Work Product.

6. 1. Records Maintenance. ATTORNEY must maintain complete and accurate records with respect to costs, expenses, receipts, and other such information required by CITY for services where compensation is based on hourly rates, subcontractor costs, or other direct costs. Records must be kept separate from other documents and maintained for four (4) years after final payment or as required by law.

6. 2. Accessibility and Audit Rights. These records should be accessible to CITY upon request. CITY reserves the right to audit these records to verify billing and expenses.

ATTORNEY agrees to provide any necessary supporting documentation.

6. 3. Work Product Ownership. All documents or other information developed or received by ATTORNEY in the course and scope of work for the City shall be the property of CITY. ATTORNEY shall provide CITY with copies of these items upon demand or upon termination of this Agreement. No work product may be released by ATTORNEY without prior written approval by CITY.

6. 4. Access for Inspection. CITY shall have free access to ATTORNEY' s books, records, and all work, data, documents, proceedings, and activities related to this Agreement. 676

7. Non -Liability of Officials and Employees of the CITY. No official or employee of CITY shall be personally liable for any default or liability under this Agreement.

8. Confidentiality. ATTORNEY agrees to maintain the confidentiality of all confidential information obtained in the course of providing the services under this Agreement. This includes, but is not limited to, CITY' s proprietary information, trade secrets, and any other information designated as confidential by CITY. ATTORNEY shall not disclose, disseminate, or use such confidential information, except as required for the performance of services under this Agreement or as required by law. This obligation of confidentiality shall survive the termination or expiration of this Agreement and continue for a period of five ( 5) years thereafter. Any breach of this confidentiality clause may result in immediate termination of this Agreement and potential legal action for damages.

9. Non -Discrimination. ATTORNEY covenants there shall be no discrimination based upon race, color, creed, religion, sex, sexual orientation, marital status, age, national origin, ancestry, AIDS, disability, or any other legally protected characteristic in any activity pursuant to this Agreement.

10. Independent Parties. Both parties to this Agreement will be acting in an independent capacity and not as agents, employees, partners, or joint venturers of one another. Neither the CITY nor its officers or employees will have any control over the conduct of the ATTORNEY or any of the ATTORNEY' s agents, employees, or subcontractors, except as otherwise provided in this Agreement.

11. Defense and Indemnification. ATTORNEY shall indemnify, defend, and hold harmless CITY, including but not limited to, its officials, officers, employees, agents, contractors, and volunteers against any or all loss, damages, liability, claims, suits, costs, expenses, and judgments, whatsoever, including reasonable attorney' s fees, to the extent caused by the negligent or willful acts, errors or omissions of ATTORNEY or ATTORNEY' s officers, agents, employees, or subcontractors, in the performance of services, activities or work conducted pursuant to this Agreement, excepting claims of professional negligence or malpractice.

12. Insurance Requirements. Prior to commencing work, the ATTORNEY must procure, maintain and pay for insurance against claims for injuries to persons or damage to property that may arise from or in connection with the performance of the services by ATTORNEY or ATTORNEY' s agents, representatives, employees or subcontractors for the duration of this Agreement. ATTORNEY must obtain insurance that, at a minimum, meets the requirements for insurance set forth in Exhibit A, Insurance Requirements.

13. Compliance with Law. ATTORNEY shall comply with all applicable laws, ordinances, codes, and regulations of the federal, state, and local government.

14. Nuisance. ATTORNEY may not maintain, commit, or permit the maintenance or commission of any nuisance in connection with the performance of services under this Agreement.

15. Conflict of Interest and Reporting. ATTORNEY shall at all times avoid conflict of interest or appearance of conflict of interest in performance of this Agreement unless such conflict is waived by CITY. ATTORNEY agrees to complete and file a California State Form 730 disclosure statement if required by the City Attorney.
677

16. Notices. All notices, demands, requests or approvals to be given under this Agreement, must be in writing and will be deemed served when delivered personally, by email, or on the third business day after deposit in the United States mail, postage prepaid, registered or certified, addressed as follows:

16. 1. To CITY:

City of Redondo Beach
City Attorney' s Office
415 Diamond Street
Redondo Beach, California 90277
Attention: City Attorney

16. 2. To ATTORNEY:

Best Best & Krieger, LLP
300 South Grand Ave., 25th Floor
Los Angeles, CA 90071
Attention: Danny Kim

17. Licenses, Permits, and Fees. ATTORNEY, at its sole expense, shall obtain and maintain a current California State Bar License, and all permits, fees, or licenses as may be required by this Agreement during the term of this Agreement.

18. Familiarity with Work. By executing this Agreement, ATTORNEY warrants that: ( 1) he has investigated the work to be performed, ( 2) he has investigated the site of the work and is aware of all conditions there; and ( 3) he understands the difficulties, and restrictions of the work under this Agreement. Should ATTORNEY discover any conditions materially differing from those inherent in the work or as represented by CITY, it shall immediately inform CITY and shall not proceed, except at ATTORNEY'S risk, until instructions are received from CITY.

19. Standard of Care. ATTORNEY agrees to provide all services, including services performed by any subcontractor, in a manner consistent with the level of care and skill ordinarily exercised by members of the ATTORNEY' s profession currently practicing in the same locality under similar conditions.

20. Time of Essence. Time is of the essence in the performance of this Agreement.

21. Limitations Upon Subcontracting and Assignment.

21. 1. ATTORNEY may not assign, hypothecate, or transfer this Agreement or any interest therein directly or indirectly, by operation of law or otherwise without the prior written consent of CITY. Any attempt to do so without the CITY' s consent will be null and void, and any assignee, hypothecatee or transferee acquires no right or interest by reason of such attempted assignment, hypothecation or transfer.

21. 2. The sale, assignment, transfer or other disposition of any of the issued and outstanding capital stock of ATTORNEY or of any general partner or joint venture or syndicate member of ATTORNEY, if a partnership or joint venture or syndicate exists, which results in changing the control of the ATTORNEY, will be construed as an assignment of this Agreement. Control means 50% or more of the voting power of the 678
corporation.

22. Subcontractors.

22. 1. If ATTORNEY proposes to have any subcontractor perform any part of the services, ATTORNEY must submit a request for approval in writing, describing the scope of work to be subcontracted, the name of the proposed subcontractor, and the total price or hourly rates used in preparing an estimated cost for the subcontractor' s services. CITY, in its sole discretion, may grant or deny the request.

22.2. The ATTORNEY will be responsible for the quality of any subcontractor's work.

23. Integration. This Agreement represents the full and complete understanding of every kind or nature whatsoever between the parties. Any preliminary negotiations and agreements of any kind or nature are merged into this Agreement. No oral agreement or implied covenant may be held to vary the provisions of this Agreement. This Agreement may be modified only by written agreement signed by CITY and ATTORNEY, and approved as to form by the City Attorney.

24. Authority to Execute. The persons executing this Agreement on behalf of the parties warrant that they are duly authorized to execute this Agreement.

25. Modification. This Agreement constitutes the entire agreement between the parties and supersedes any previous agreements, oral or written. This Agreement may be modified on provisions waived only by subsequent mutual written agreement executed by CITY and ATTORNEY.

26. California Law. This Agreement shall be construed in accordance with the laws of the State of California. Any action commenced about this Agreement shall be filed in the central branch of the Los Angeles County Superior Court.

27. Interpretation. This Agreement shall be interpreted as though prepared by both parties.

28. Waiver. A waiver of any breach of this Agreement may not be deemed a waiver of any subsequent breach of the same or any other term, covenant, or condition of this Agreement.

29. Governing Law. The laws of the State of California, without regard to any choice of law provisions, will govern this Agreement.

30. Venue and Jurisdiction. CITY and ATTORNEY agree that the Services will take place in Los Angeles County. Any litigation arising out of this Agreement may only be brought in the Superior Court of the County of Los Angeles, Southwest Judicial District. The parties agree that venue exists in either court, and each party expressly waives any right to transfer to another venue. The parties further agree that either court will have personal jurisdiction over the parties to this Agreement.

31. Survival of Provisions and Obligations. Any provision of this Agreement, which by its nature must be exercised after termination of this Agreement, will survive termination and remain effective for a reasonable time. Any obligation that accrued prior to termination of this Agreement will survive termination of this Agreement. 679

32. Exhibits. The following exhibit is incorporated by reference into this Agreement as though fully set forth herein.

Exhibit A: Insurance Requirements

33. Severability. Should any provision of this Agreement be found invalid or unenforceable, the decision shall affect only the provision interpreted, and all remaining provisions shall remain enforceable.

SIGNATURES FOLLOW ON NEXT PAGE]
680
IN WITNESS THEREOF, these parties have executed this Agreement on the day and year shown below.

CITY OF REDONDO BEACH,
a chartered municipal corporation
IDocusignetl
by:
0853B...

James A. Light
Mayor
4/ 20/ 2025 1 8: 14 AM PDT
Date:

ATTEST:

DocuSignetl by:

C 2F2AC116C214CF... nF
Eleanor Manzano, City Clerk
F.... 91TA : 119
EPSigned
by:
icun, t, 5fV'il,cFa
ABED8CF35EEF48C_._
Diane Strickfaden, Risk Manager
APPROVED AS TO FORM:
signea by:

I ASA2] AAE40834DE...

Joy A. Ford, City Attorney

BEST BEST & KRIEGER, LLP,
a Limited Liability Partnership
Signed by:

By: EE58 BO6k
Name:

Dzu
Title: Partner
Date:
4/ 9/ 2025 1 3: 24 PM PDT
9 681

EXHIBIT A

INSURANCE REQUIREMENTS FOR ATTORNEYS
Without limiting ATTORNEY' s indemnification obligations under this Agreement, ATTORNEY shall procure and maintain for the duration of the contract insurance against claims for injuries to persons or damages to property which may arise from or in connection with the performance of the work hereunder by the ATTORNEY, its agents, representatives, or employees.

Minimum Scope of Insurance
Coverage shall be at least as broad as:

Insurance Services Office Commercial General Liability coverage ( occurrence form CG 0001).

2. Insurance Services Office form number CA 0001 ( Ed. 1/ 87) covering Automobile Liability, code 1 ( any auto).

3. Workers' Compensation insurance as required by the State of California.

4. Employer' s Liability Insurance.

5. Professional Liability Insurance shall be required if the ATTORNEY is providing a professional service regulated by the State ( e. g., insurance agents, doctors, lawyers, architects, engineers, certified public accountants, etc.). However, some professions, such as software designers, claims administrators, or human resources professionals, should also carry Professional Liability insurance.

Minimum Limits of Insurance
ATTORNEY shall maintain limits no less than:

1. General Liability: $ 2, 000, 000 per occurrence for bodily injury, personal injury and property damage. The general aggregate limit shall apply separately to this project.

2. Automobile Liability: $ 1, 000, 000 per accident for bodily injury and property damage.

3. Employer' s Liability: $ 1, 000, 000 per accident for bodily injury or disease.

4. Professional Liability: Insurance appropriate to the ATTORNEY' s profession with a limit of not less than $ 2, 000, 000 each claim and $ 4, 000, 000 in the annual aggregate.

5. If the ATTORNEY maintains higher limits than the minimums shown above, the City of Redondo Beach requires and shall be entitled to coverage for the higher limits maintained by the ATTORNEY. Any available insurance proceeds in excess of the specified minimum limits of insurance and coverage shall be available to the City of Redondo Beach. 682
Deductibles and Self -Insured Retentions
Any deductibles or self -insured retentions must be declared to and approved by the City. At the option of the Citythe ATTORNEY shall provide a financial guarantee in form of a letter from ATTORNEY' s CFO that is satisfactory to the City guaranteeing payment of losses and related investigations, claim administration and defense expenses.

Other Insurance Provisions
The general liability and automobile liability policies are to contain, or be endorsed to contain, the following provisions:

Additional Insured Endorsement
General Liability: The City, its officers, elected and appointed officials, employees, and volunteers shall be covered as insureds with respect to liability arising out of work performed by or on behalf of the ATTORNEY. General liability coverage can be provided in the form of an endorsement to the ATTORNEY' s insurance, or as a separate owner' s policy.

2. Automobile Liability: The City, its officers, elected and appointed officials, employees, and volunteers shall be covered as insureds with respect to liability arising out of automobiles owned, leased, hired or borrowed by or on behalf of the ATTORNEY.

3. For any claims related to this project, the ATTORNEY' s insurance coverage shall be primary insurance as respects the City, its officers, elected and appointed officials, employees, and volunteers. Any insurance or self-insurance maintained by the City, its officers, officials, employees, or volunteers shall be excess of the ATTORNEY' s insurance and shall not contribute with it.

4. Each insurance policy shall be endorsed to state that the inclusion of more than one insured shall not operate to impair the rights of one insured against another insured, and the coverages afforded shall apply as though separate policies had been issued to each insured.

5. Each insurance policy shall be in effect prior to awarding the contract and each insurance policy or a successor policy shall be in effect for the duration of the project. The maintenance of proper insurance coverage is a material element of the contract and failure to maintain or renew coverage or to provide evidence of renewal may be treated by the City as a material breach of contract on the ATTORNEY' s part.

Acceptability of Insurers
Insurance shall be placed with insurers with a current A.M. Best's rating of no less than A:VII and which are authorized to transact insurance business in the State of California by the Department of Insurance.

M
683
Claims Made Policies
If the Professional Liability policy provides " claims made" coverage:

The Retroactive Date must be shown, and must be before the date of this Agreement or the start of work.

2. The insurance must be maintained and evidence of insurance must be provided for at least 5 years after completion of work.

3. If the policy is cancelled or not renewed, and not replaced with another " claims made" policy form with a Retroactive Date prior to the effective Agreement date, the ATTORNEY must purchase " extended reporting" coverage for a minimum of 5 years after completion of work.

Verification of Coveraae
ATTORNEY shall furnish the City with original certificates and amendatory endorsements effecting coverage required by this clause. The endorsements should be on the City authorized forms provided with the contract specifications. Standard ISO forms which shall be subject to City approval and amended to conform to the City' s requirements may be acceptable in lieu of City authorized forms. All certificates and endorsements shall be received and approved by the City before the contract is awarded. The City reserves the right to require - declaration pages of all required insurance policies, including endorsements effecting the coverage required by these specifications at any time.

Subcontractors
ATTORNEY shall include all subcontractors as insured under its policies or shall furnish separate certificates and endorsements for each subcontractor. All coverages for subcontractors shall be subject to all of the requirements stated herein.

Risk Management
ATTORNEY acknowledges that insurance underwriting standards and practices are subject to change, and the City reserves the right to make changes to these provisions in the reasonable discretion of its Risk Manager or Human Resources Director.

WE
684

FIRST AMENDMENT TO ENGAGEMENT LETTER AGREEMENT

FOR LEGAL SERVICES

WITH NOSSAMAN LLP
THIS FIRST AMENDMENT to the Engagement Letter agreement for legal services (“First Amendment”) is made this 6th day of October, 2026, by the CITY OF REDONDO BEACH, a chartered municipal corporation, ("City"), and NOSSAMAN LLP, a Limited Liability Partnership ("Attorney”).

RECITALS
The following recitals are a substantive part of this Agreement:

WHEREAS, on March 18, 2025, the parties entered into an Engagement Letter agreement for legal services for the provision of bond counsel services related to Measure FP (the “Agreement”) which was approved by the City Council at its March 18, 2025 meeting; and
WHEREAS, the parties desire to amend the Agreement to reduce the compensation amount and to reflect that there will be a cessation of bond counsel services due to the departure of Lolly Enriquez from the firm.

NOW THEREFORE, in consideration of the promises and mutual covenants contained herein, and intending to be legally bound, the parties hereby agree to make the following amendments to the Agreement:

1. COMPENSATION. The Agreement is hereby amended to decrease the flat rate from $65,000 to $45,000, rendered on the closing date of the bond and payable from bond proceeds due to the departure of Lolly Enriquez from Nossaman LLP.

The compensation is contingent on the closing of the bonds and applies to all time spent on matters related to the representation described in the Agreement, including but not limited to, the ordinary and customary services rendered as bond counsel in connection with transactions of the type described in the Agreement which were incurred prior to Lolly Enriquez’s departure from Nossaman LLP.

2. NO OTHER AMENDMENTS. Except as expressly stated herein, the Agreement shall remain unchanged and in full force and effect. The Agreement and this First Amendment constitute the entire agreement between the parties and supersede any previous oral or written agreement with respect to the subject matter hereof.

In the event of any inconsistency between the terms of the Agreement and this First Amendment, the terms of this First Amendment shall govern. [SIGNATURES FOLLOW ON NEXT PAGE]
685
2 IN WITNESS WHEREOF, the parties have executed this First Amendment in Redondo Beach, California, as of this 6th day of October, 2026.

CITY OF REDONDO BEACH, NOSSAMAN LLP
a chartered municipal corporation a limited liability partnership _____________________________ By: ______________________ James A. Light Name: _______________________
Mayor Title: _______________________

ATTEST:
_____________________________
Eleanor Manzano, City Clerk
APPROVED:
_____________________________
Diane Strickfaden, Risk Manager
APPROVED AS TO FORM:
_____________________________
Joy A. Ford, City Attorney
10/1/2026 | 3:28 PM PDT
Partner
Lolly Enriquez
686
Administrative
Report
J.1., File # 26-1213 Meeting Date: 10/6/2026
TITLE
For eComments and Emails Received from the Public

687
Administrative
Report
L.1., File # 26-1233 Meeting Date: 10/6/2026
To: MAYOR AND CITY COUNCIL
From: MARC WIENER, COMMUNITY DEVELOPMENT DIRECTOR
TITLE

PUBLIC HEARING FOR CONSIDERATION OF AN APPEAL OF A DENIAL BY THE PLANNING COMMISSION OF AN EXEMPTION DECLARATION AND VARIANCE TO EXCEED THE 30-FOOT

MAXIMUM BUILDING HEIGHT REQUIREMENT FOR THE INSTALLATION OF FOUR (THREE

INITIALLY) BULK CRYOGENIC STORAGE TANKS WITH A PROPOSED HEIGHT OF APPROXIMATELY 38 FEET AT AN EXISTING MANUFACTURING FACILITY ON PROPERTY LOCATED WITHIN AN INDUSTRIAL-COMMERCIAL (IC-1) ZONE

PROCEDURES

1. Open the public hearing, receive and file all documents and correspondence on the proposed project;

2. Accept all testimony from staff, the applicant, and the public and deliberate;

3. Close the public hearing;

4. Adopt the attached Resolution by title only, and waive further reading.

ADOPT BY TITLE ONLY RESOLUTION CC-2610-083 OF THE CITY COUNCIL OF THE CITY OF

REDONDO BEACH GRANTING AN APPEAL AND APPROVING AN EXEMPTION DECLARATION AND VARIANCE TO EXCEED THE 30-FOOT MAXIMUM BUILDING HEIGHT REQUIREMENT FOR

THE INSTALLATION OF FOUR BULK CRYOGENIC STORAGE TANKS WITH A PROPOSED HEIGHT OF APPROXIMATELY 38 FEET AT AN EXISTING MANUFACTURING FACILITY ON PROPERTY LOCATED WITHIN AN INDUSTRIAL-COMMERCIAL (IC-1) ZONE

EXECUTIVE SUMMARY
An application for a Height Variance to exceed the height limit of 30 feet for the installation of four Cryogenic bulk storage tanks with a proposed height of approximately 38 feet at 2477 Manhattan Beach Boulevard was submitted by Michael Gillway on behalf of Impulse Space on June 23, 2026.

The tanks will be used to store liquid nitrogen and liquid argon and are constructed with a vacuuminsulated double-wall design. The tanks support the technical requirements of Impulse’s aerospace manufacturing operation and cannot be accommodated at a lesser height without resulting in the fabrication of customized units that do not have the same historical record of safety, or the procurement of significantly smaller tanks that would require more frequent supply deliveries and negatively impact the site’s parking availability.

The application for the Height Variance was heard by the Planning Commission on August 20, 2026.

While not a consideration of the height variance request, staff from the Fire Department attended the meeting and provided general information on the building and fire code permitting process and

688
L.1., File # 26-1233 Meeting Date: 10/6/2026
meeting and provided general information on the building and fire code permitting process and addressed questions related to the safety of the proposed tanks. The item was continued by the commission to September 17, 2026 to further consider concerns raised by some of the members of the commission regarding the safety of the materials stored in the proposed tanks. On September 17, 2026, the Height Variance application was denied (vote 4-3) as reflected in the attached Planning Commission Resolution for Denial. The project applicant, Impulse Space, filed an appeal for a de novo hearing with City Council in accordance with RBMC § 10-2.2510(g) (see attached).

The decision on the application is limited to the Variance criteria provided in RBMC § 10-2.2510(b).

The Planning Commission Resolution identifies that the application was denied based on a lack of compliance with the criteria, specifically height; however, most of the discussion that occurred at the two Planning Commission meetings was focused on safety concerns related to cryogenic tanks which is not at issue.

The installation and safety requirements of the proposed cryogenic tanks, as well as any other equipment installation or on-site construction, is reviewed by the Building and Safety Division of the Community Development Department and the Fire Department. A detailed summary of the permitting process for the cryogenic tanks has been provided in the background section of the administrative report for informational purposes.

The City Council’s decision on the application should be limited only to the Height Variance and the required Municipal Code criteria which are described below. It is not within the scope of this application, or within Council’s purview, to consider technical requirements pertaining to the enforcement of State Building and Fire Codes.

BACKGROUND
The subject property is located at 2477 Manhattan Beach Boulevard, between Redondo Beach Avenue and Inglewood Avenue. The lot is approximately 4.43 acres in size with lot dimensions of 501 feet in width and 385 feet in depth. The zoning of the subject property is Industrial-Commercial (IC-1) as is the adjacent property immediately west of the subject property and also fronting Manhattan Beach Boulevard. The properties immediately adjacent to and north and further west of the subject property are zoned Industrial (I-1) and the properties south of the subject property and across Manhattan Beach Boulevard are zoned Single-Family Residential (R-1).

Impulse Space is an aerospace manufacturing company headquartered in Redondo Beach. Impulse manufactures space craft for the delivery of satellites into orbit. In addition to the subject location, Impulse Space also has a similar facility located immediately east at 2651 Manhattan Beach Boulevard. The subject location at 2477 Manhattan Beach Boulevard will be used for manufacturing, assembly, integration, warehousing, and office operations associated with the development of spacecraft. Primarily, the facility will be used to manufacture, assemble and test components. Below is an area breakdown of the operations at 2477 Manhattan Beach Boulevard. • Office: 52,240 SF
• Storage/IT Infrastructure/Restrooms: 20,520 SF
• Manufacturing: 126,580 SF
• Kitchen/Walkways: 51,260 SF
• Total: 250,600 SF

689
L.1., File # 26-1233 Meeting Date: 10/6/2026
The applicant is proposing to install four cryogenic storage tanks required to support the existing manufacturing operations on site. The tanks will be used to store liquid nitrogen and liquid argon and are constructed with a vacuum-insulated double-wall design. The proposed tanks are specialized industrial equipment whose dimensions are determined by required storage capacity, engineering design, and safety standards associated with bulk cryogenic systems. The height and location of these vessels cannot be materially reduced or relocated without impacting their intended function, required access, and compliance with applicable safety requirements.

Because the height of the tanks is driven by technical, operational, and regulatory requirements rather than design preference, the applicant is requesting a variance to exceed the 30-foot maximum building height requirement for the installation of four bulk cryogenic storage tanks. The existing manufacturing structure/facility conforms to the height regulations. The requested variance would allow the proposed storage tanks to exceed the maximum height requirement by 8 feet.

In addition to the proposed tanks, Impulse Space has recently completed, or has plans in process for, other site and building improvements which are largely itemized above (internal tenant improvements). All of the other building and site improvements are permitted by right and subject to the City’s standard ministerial building plan check and permit procedures. One of these additional ministerial permits is for the development of a new CMU block wall approximately eight (8) feet in height to be located along the eastern and southern property line fronting Manhattan Beach Boulevard. The planned eight (8) foot high wall is permitted pursuant to Federal security requirements which is allowed under the City’s Zoning Ordinance (RBMC § 10-2.1524). Although the primary purpose for the wall is for securing the property, it will also provide an additional buffer between the facility and the residential neighborhoods south of Manhattan Beach Boulevard, which are approximately 230 feet from the proposed storage tanks.

VARIANCE CRITERIA
The following is a list of the Variance criteria in RBMC § 10-2.2510(b) with an analysis from staff as to how the proposed application complies:
a) There are special circumstances applicable to the property, including size, shape, topography, location, or surroundings, such that the strict application of the zoning provisions deprives such property of privileges enjoyed by other property in the vicinity and under identical zone designation
Staff Analysis: The subject property’s current use, and General Plan and Zoning land use designation are consistent with other industrial parcels in the surrounding industrial neighborhood. The subject property’s zoning designation (IC-1) allows for the same “industrial uses” as the surrounding I-1 (Industrial) designation. Furthermore, the use on the subject property, aerospace manufacturing, is the same as the uses of many of the surrounding Industrial properties.

The “special circumstances” applicable to this project are based on the fact that the development standards for the subject property are significantly more restrictive than those of the surrounding industrial-zone properties which, as noted above, allow for the exact same manufacturing/industrial uses. Additionally, the surrounding industrial uses are allowed

690
L.1., File # 26-1233 Meeting Date: 10/6/2026
same manufacturing/industrial uses. Additionally, the surrounding industrial uses are allowed at heights of over 100 feet while the subject property’s uses are limited to a height of 30 feet.

Strict adherence to the zoning district’s 30-foot height limit would eliminate the ability of the property owner to use the property for aerospace manufacturing purposes. The surrounding industrial properties have been allowed to install numerous similar storage tank structures which are similarly required for their manufacturing needs.

Accordingly, relief from the standard height restriction to afford this property some of the development privileges provided to the nearby properties with the same uses is justified.

Additionally, the technical requirements in support of this aerospace manufacturing operation cannot be accommodated at a lesser height without resulting in the fabrication of customized units that do not have the same historical record of safety, or the procurement of significantly smaller tanks that would require more frequent supply deliveries and negatively impact the site’s parking availability.
b) The Variance granted shall be subject to such conditions as will assure that the adjustment thereby authorized shall not constitute a grant of special privileges inconsistent with the limitations upon other properties in the vicinity and zone in which such property is situated.

Staff Analysis: The variance does not constitute a special privilege, as it allows development that is consistent with the existing industrial uses in the vicinity and maintains compliance with the intent of the zoning district. The adjustment allows for critical infrastructure with technical requirements that cannot be significantly altered and that are common for the allowed industrial use and required for many aerospace manufacturing operations. The adjustment does not grant development rights unavailable to other similarly situated properties with similar General Plan and Zoning designations, many of which utilize comparable cryogenic storage tanks.
c) The granting of a Variance shall not be contrary to the objectives of the Comprehensive General Plan.

Staff Analysis: Granting this Variance supports the General Plan’s Goal of Economic Sustainability LU-6, and specifically Responsible Development Policy LU-6.1, Business Retention and Expansion Policy LU-6.12, and Job/Housing Balance Policy LU-1.4. Further, the granting of this variance supports the General Plan’s objective to maintain existing employers within the North Redondo Tech District (SPA-1). The requested Variance is vital to the operations of Impulse Space and helps support and execute these critical General Plan policies and objectives. Impulse Space is unable to conduct their manufacturing operations without these tanks. By allowing the existing business to install the proposed bulk cryogenic storage tanks, the City is facilitating the specialized industrial infrastructure necessary for the business to conduct their permitted industrial activities.

Building & Safety/Fire Department Review
Although safety considerations associated with the proposed tank installations are not within the purview of the Variance Criteria outlined above, the following information is presented to assure the public and City Council that if approved, the safety considerations will be addressed through the

691
L.1., File # 26-1233 Meeting Date: 10/6/2026
public and City Council that if approved, the safety considerations will be addressed through the subsequent building plan check, permit issuance, and construction/installation process. If approved, personnel from the Redondo Beach Building & Safety Division of the Community Development Department and the Fire Department will conduct a detailed plan review process as summarized below.

1. Building Permit application and plan set submitted by Impulse Space for the proposed cryogenic tanks.

2. The plans in the application are then reviewed by the Building and Safety Division of the Community Development Department for compliance with the California Building Code, including structural foundations and the attachment details/requirements for the tanks.

3. The plans are then routed to the Fire Department to review for compliance with the California Fire Code and National Fire Protection Association (NFPA) standards and certifications, including site conditions, required clearances, tank specifications, pressure-relief systems, and emergency shutoffs.

4. Following review, Building & Safety Division and Fire Department personnel will note any deficiencies in the plans and return them to the applicant for corrections.

5. When compliance is fully demonstrated in the final plan set, the permit is issued to the applicant for the installation of the cryogenic tanks.

6. During the installation of the tanks, personnel from the Building & Safety Division and Fire Department will perform life-safety inspections to ensure compliance with the approved plans.

7. Following installation of the cryogenic tanks Impulse Space is required to submit a hazardous materials business plan to the California Environmental Reporting System (CERS), which triggers a notification to the local Certified Unified Program Agency (CUPA), which in this instance is the Los Angeles County Fire Department.

8. The Los Angeles County Fire Department will then conduct a hazardous materials inspection within 30 days to verify compliance with all applicable hazardous materials requirements.

PUBLIC CORRESPONDENCE
Staff received multiple public comments in anticipation of the August 20, 2026 and September 17, 2026 Planning Commission meetings. Since the September 17, 2026 Planning Commission meeting additional public comments have also been received. The majority of the public comments to date, shared concerns citing changes to the property such as the number of employees and public safety concerns. Additionally, Staff did organize a meeting between the applicant and a concerned neighbor to further discuss and clarify the operations and safety associated with the business and the tanks.

Attached to this Administrative Report are all public comments received to date concerning the Height Variance application.

ENVIRONMENTAL STATUS
Staff has determined that the proposed project is Categorically Exempt from the provisions of the California Environmental Quality Act (CEQA), under Article 19, Section 15301 (Existing Facilities) of the California Guidelines for Implementation of the CEQA. Specifically, the project includes installation of equipment necessary for the permitted manufacturing existing on the subject property.

COORDINATION
The Community Development Department coordinated review of the Variance Request with the City Attorney’s Office and the Fire Department.

692
L.1., File # 26-1233 Meeting Date: 10/6/2026

FISCAL IMPACT
Processing the project application is within the Community Development Department’s annual operating budget.

APPROVED BY:

Mike Witzansky, City Manager

ATTACHMENTS
Attachment 1 - Appeal Application
Attachment 2 - Proposed Resolution
Attachment 3 - Site Plan
Attachment 4 - Project Renderings
Attachment 5 - Bulk Cryogenic Storage Safety & Compliance Presentation Attachment 6 - August 20, 2026 (Signed) and September 17, 2026 (Draft) Planning Commission Meeting Minutes
Attachment 7 - Planning Commission Resolution of Denial Attachment 8 - CEQA Exemption Declaration
Attachment 9 - Public Comments

693
694
695
696
697
698
699
700
701
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 1
RESOLUTION NO. CC-2610-083

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

REDONDO BEACH GRANTING AN APPEAL AND APPROVING AN
EXEMPTION DECLARATION AND VARIANCE TO EXCEED THE 30-

FOOT MAXIMUM BUILDING HEIGHT REQUIREMENT FOR THE

INSTALLATION OF FOUR BULK CRYOGENIC STORAGE TANKS
WITH A PROPOSED HEIGHT OF APPROXIMATELY 38 FEET AT

AN EXISTING MANUFACTURING FACILITY ON PROPERTY
LOCATED WITHIN AN INDUSTRIAL-COMMERCIAL (IC-1) ZONE
WHEREAS, a Variance is requested under Redondo Beach Municipal Code Section 10-2.2510 to allow the proposed cryogenic storage tanks to exceed the 30-foot maximum building height requirement with a proposed height of approximately 38 feet in the IC-1 Zone; and
WHEREAS, the subject lot is approximately 4.43 acres in area with approximate dimensions of 501 feet in width and 385 feet in depth with an existing ±250,000 square foot manufacturing structure consisting of office, storage, IT infrastructure, restrooms, manufacturing (aerospace), kitchen space, and walkways/hallways; and WHEREAS, the surrounding industrial uses west, north, and east have similar industrial zoning and General Plan land use designations and allow for the same uses, including aerospace manufacturing (use on the subject property), however these adjacent industrial areas allow for significantly higher development than the subject property; and
WHEREAS, the project is Categorically Exempt from CEQA under Section 15301 (Existing Facilities) of the CEQA Guidelines; and
WHEREAS, the Planning Commission conducted a duly noticed public hearing on August 20, 2026 and continued the public hearing on the application to a date certain on September 17, 2026. The Height Variance application was continued to September 17, 2026 to address concerns from commissioners regarding the safety of the materials stored; and
WHEREAS, the Planning Commission of the City of Redondo Beach considered evidence presented by the applicant, the Planning Division, the Redondo Beach Fire Department, and other interested parties at the public hearings held on the 20th day of August and the 17th day of September, 2026, with respect thereto and on September 17, 2026, the Height Variance application was denied (vote 4-3); and 702
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 2
WHEREAS, the project applicant, Impulse Space, filed an appeal of the Planning Commission’s denial for a de novo hearing with City Council in accordance with RBMC § 10-2.2510(g); and
WHEREAS, notice of the time and place of the public hearing where the Exemption Declaration and the appeal of the Planning Commission’s denial of the Height Variance application would be considered by the City Council was given pursuant to State law and local ordinances by publication in the Easy Reader, by posting the subject property, and by mailing notices to property owners within 300 feet of the exterior boundaries of the subject property; and WHEREAS, the City Council of the City of Redondo Beach has considered evidence presented by the applicant, the Planning Division, and other interested parties at the public hearing held on the 6th day of October, 2026, with respect thereto.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF REDONDO BEACH DOES HEREBY RESOLVE:

SECTION 1. That the above recitals are true and correct and are incorporated herein by reference as if set forth in full.

SECTION 2. That based on the findings below, the City Council hereby grants the appeal and approves the Exemption Declaration and the Variance pursuant to the plans and applications considered by the City Council at its meeting on the 6th day of October, 2026.

SECTION 3. In accordance with Section 10-2.2510(b) of the Redondo Beach Municipal Code, the applicant's request for a Variance is consistent with the criteria set forth therein for the following reasons:
a) There are special circumstances applicable to the property, including size, shape, topography, location, or surroundings, such that the strict application of the zoning provisions deprives such property of privileges enjoyed by other property in the vicinity and under identical zone designation
The subject property’s current use, and General Plan and Zoning land use designation are consistent with other industrial parcels in the surrounding industrial neighborhood. The subject property’s zoning designation (IC-1) allows for the same “industrial uses” as the surrounding I-1 (Industrial) designation.

Furthermore, the use on the subject property, aerospace manufacturing, is the same as the uses of many of the surrounding Industrial properties.

The “special circumstances” applicable to this project are based on the fact that the development standards for the subject property are significantly more 703
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 3
restrictive than those of the surrounding industrial-zone properties which, as noted above, allow for the exact same manufacturing/industrial uses.

Additionally, the surrounding industrial uses are allowed at heights of over 100 feet while the subject property’s uses are limited to a height of 30 feet. Strict adherence to the zoning district’s 30-foot height limit would eliminate the ability of the property owner to use the property for aerospace manufacturing purposes.

The surrounding industrial properties have been allowed to install numerous similar storage tank structures which are similarly required for their manufacturing needs.

Accordingly, relief from the standard height restriction to afford this property some of the development privileges provided to the nearby properties with the same uses is justified. Additionally, the technical requirements in support of this aerospace manufacturing operation cannot be accommodated at a lesser height without resulting in the fabrication of customized tanks that do not have the same track record of safety, and would also require more frequent supply deliveries. b) The Variance granted shall be subject to such conditions as will assure that the adjustment thereby authorized shall not constitute a grant of special privileges inconsistent with the limitations upon other properties in the vicinity and zone in which such property is situated.

The variance does not constitute a special privilege, as it allows development that is consistent with the existing industrial uses in the vicinity and maintains compliance with the intent of the zoning district. The adjustment allows for critical infrastructure with technical requirements that cannot be significantly altered and that are common for the allowed industrial use and required for many aerospace manufacturing operations. The adjustment does not grant development rights unavailable to other similarly situated properties with similar General Plan and Zoning designations, many of which utilize comparable cryogenic storage tanks.
c) The granting of a Variance shall not be contrary to the objectives of the Comprehensive General Plan.

Granting this Variance supports the General Plan’s Goal of Economic Sustainability LU-6, and specifically Responsible Development Policy LU-6.1, Business Retention and Expansion Policy LU-6.12, and Job/Housing Balance Policy LU-1.4. Further, the granting of this variance supports the General Plan’s objective to maintain existing employers within the North Redondo Tech District (SPA-1). The requested Variance is vital to the operations of Impulse Space and helps support and execute these critical General Plan policies and objectives.

Impulse Space is unable to conduct their manufacturing operations without these tanks. By allowing the existing business to install the proposed bulk cryogenic 704
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 4
storage tanks, the City is facilitating the specialized industrial infrastructure necessary for the business to conduct their permitted industrial activities.

SECTION 4. That the proposed development is exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15301 (Existing Facilities) of the CEQA Guidelines.

SECTION 5. That this permit shall be void in the event that the applicant does not comply with the following conditions:

1. The approval granted herein is to exceed the maximum height requirement of 30 feet for the installation of 38-foot-tall cryogenic storage tanks at an existing manufacturing facility located within an Industrial-Commercial (IC-1) zone. Four (4) tanks are permitted to be installed as shown on the approved site plan and the renderings. Any additional tanks that exceed the height regulation would require a “Modification” to this “Variance”.

2. A copy of this Resolution shall be copied onto a sheet in the construction plan set submitted to the Building and Safety Division.

3. The site shall be fully fenced prior to the start of construction. The site is currently fully fenced.

4. The site shall be maintained in a clean and orderly condition throughout construction, with reasonable measures taken to prevent the accumulation of litter and debris.

5. Construction work shall occur only between the hours of 7:00 a.m. and 6:00 p.m. on Monday through Friday, between 9:00 a.m. and 5:00 p.m. on Saturday, with no work occurring on Sunday and specified holidays per RBMC Section 9-1.12.

6. The project developer and/or general contractor shall be responsible for counseling and supervising all subcontractors and workers to ensure that neighbors are not subjected to excessive noise, disorderly behavior, or abusive language.

7. The streets and sidewalks adjacent to the job site shall be maintained free of debris resulting from construction activities.

8. All construction shall strictly conform to the architectural drawings, elevations, and site plan and renderings stamped “Approved” on October 6, 2026. The Planning Division shall be authorized to approve minor changes. 705
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 5

9. The applicant shall obtain all required demolition, building, grading, electrical, and mechanical permits and shall comply with all applicable provisions of the California Building Code, Fire Code, and City ordinances.

10. The applicant may be required to install noise mitigation equipment and measures in the event of measured noise violations of the City’s noise ordinance (RBMC Title 4, Chapter 24. Noise Regulation).

11. The design shall be constructed per building and fire code requirements and include measures to minimize risks of vehicle impact.

12. The installation area shall be graded in accordance with the approved engineering design.

13. The applicant shall install and maintain NFPA 704 hazard diamond signage at all applicable access points in accordance with applicable code requirements.

14. The Impulse Space site will be sufficiently secured to prevent unauthorized access to the site and cryogenic storage tanks.

15. The applicant shall develop, maintain, and post written operating procedures for the cryogenic storage equipment at the storage area.

16. The applicant shall notify the local fire department of the cryogenic installation and provide the fire department with a copy of this document.

17. The applicant shall clearly mark the facility address and location of the cryogenic storage equipment to facilitate emergency vehicle access.

18. The applicant shall post and maintain a 24-hour emergency contact telephone number at the facility entrance in a readily visible location.

19. The applicant shall maintain a current site map at the facility entrance identifying the cryogenic vessel locations, designated exclusion zones, and emergency access routes.

20. The applicant shall install and maintain silencers on venting valves associated with the cryogenic storage tanks to suppress noise generated during tank venting operations.

21. The applicant shall limit deliveries of liquefied gas to normal business hours. Very limited off hour deliveries are permitted as a minor change subject to the approval of the Community Development Director.
706
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 6

22. The applicant shall provide a noise report measuring noise generated by tankrelated operations, including delivery of gas, filling of the tanks, and tank venting, to confirm compliance with the City's Noise Ordinance. Additional noise mitigation may be required, including, but not limited to, installation of a solid wall along the Manhattan Beach Boulevard frontage.

SECTION 6. That the approved Variance shall become null and void if not vested within 36 months after the City Council’s approval of the project.

SECTION 7. That the City Clerk shall certify the passage and adoption of this resolution and shall enter the same in the Book of Original Resolutions. 707
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 7
PASSED, APPROVED AND ADOPTED this 6th day of October, 2026. ________________________
James A. Light, Mayor
APPROVED AS TO FORM: ATTEST:
______________________ ______________________
Joy A. Ford, City Attorney Eleanor Manzano, CMC, City Clerk 708
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 8
ATTEST:

STATE OF CALIFORNIA )

COUNTY OF LOS ANGELES ) SS

CITY OF REDONDO BEACH )
I, Eleanor Manzano, City Clerk of the City of Redondo Beach, California, do hereby certify that the foregoing Resolution No. CC-2610-083 was passed and adopted by the City Council of the City of Redondo Beach, California, at a regular meeting of said City Council held on the 6th day of October, 2026, and there after signed and approved by the Mayor and attested by the City Clerk, and that said resolution was adopted by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:
_______________________________
Eleanor Manzano, CMC
City Clerk
709
JKN (E) EXTERIOR WALL INFILL WALL INFILL 6'-0" HIGH BLOCK WALL EMERGENCY DOOR 6'-0" HIGH BLOCK WALL WITH STOREFRONT GLASS 6'-0" HIGH BLOCK WALL WITH STOREFRONT GLASS BLOCK WALL INFILL 39'-0" 9'-0" RAMP UP 1:12 RAMP UP 1:12 STEPS UP FDC 6" BOLLARDS STEPS DN. NO PARKING NO PARKING SHIPPING LOADING GUARD BOOTH 24 S 3 S GATE PRKG SIGN PRKG SIGN PRKG SIGN 18'-0"
3'-0" 3'-0" 12'-0" SCE CONDUIT FEED INTO TRANSFORMER 19'-11" (6'-0") 32'-3" 13'-0" 3'-0" TYP LN2 LN2 LAR FUTURE LAR/LN2 16'-0" SUPPORTING EQUIPMENT BELOW 25'
5'-0"
5'-0" 12'-0" TANK RELOCATION 8/12/26
710
711
712
713
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 1

BULK CRYOGENIC STORAGE

SAFETY & COMPLIANCE PRESENTATION
Liquid Nitrogen (LIN), Liquid Argon (LAR)
5+
Layers of Safety
Engineered redundancy at every
level
100%
NFPA 55 Compliant
Meets all applicable codes &
standards
CGA S-1.2
PRD Certified
11th Edition 2024 — factory
verified

SUBMITTED TO THE AUTHORITY HAVING JURISDICTION (AHJ)
This presentation demonstrates that bulk cryogenic storage of LIN & LAR is a wellestablished, highly regulated, and engineered-safe industrial practice. The tanks proposed for this installation are among the most thoroughly tested and regulated pressure vessels in industrial use — backed by ASME, NFPA, CGA, OSHA, and DOT standards.

Prepared By: Matheson
Facility: Impulse Space
Site Address: 2425 Manhattan Beach
Date: 6/9/26
Revision: 1.0 — Initial AHJ Submission
Standards: NFPA 55 · CGA S-1.2 (11th Ed.) · ASME BPVC · OSHA 29 CFR 1910.101 · 49 CFR 173.318
714
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 2

TABLE OF CONTENTS

1. Executive Summary — Why These Tanks Are Safe 3

2. Physical Description of Cryogenic Vessels 4

3. Pressure Relief Device Standards — CGA S-1.2 (11th Ed.) 5

4. Layers of Protection — Engineered Safety Systems 8

5. Product Descriptions — LIN, LAR 10

6. Hazard Identification & Risk Context 12

7. Emergency Response Procedures 14

8. Spill Response & Containment Procedures 17

9. Safety Policies & Mitigation Measures 18

10. Regulatory Compliance Summary 20

11. Site-Specific Safety Measures 21

12. Emergency Contacts & Notification 22
715
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 3

1. EXECUTIVE SUMMARY — WHY THESE TANKS ARE SAFE
Bulk cryogenic storage of liquid nitrogen, liquid argon, and liquid oxygen is a mature, wellregulated industrial practice with a strong safety record spanning decades of global use across medical, industrial, manufacturing, and food processing applications. These tanks are not experimental technology — they are engineered, tested, certified, and operated under some of the most rigorous safety standards in industry.

CORE SAFETY STATEMENT
The bulk cryogenic vessels proposed for this installation are vacuum-insulated, doublewalled pressure vessels designed with multiple independent, redundant safety systems.

They are manufactured to ASME BPVC Section VIII, Division 1 (BPVC.VIII.1) standards, pressure relief devices are certified to CGA S-1.2 (11th Edition, 2024), and the installation will comply fully with NFPA 55, OSHA 29 CFR 1910.101, and all applicable local codes.

1.1 Key Safety Facts for the AHJ
✓ Cryogenic tanks of this type are in operation at thousands of facilities across the United States including hospitals, universities, manufacturing plants, and research facilities in communities similar to this one.
✓ The vacuum-insulated double-wall design means the outer shell never directly contacts the cryogenic liquid — the product is contained entirely within the inner vessel under controlled conditions.
✓ Pressure relief devices are factory-set, factory-tested, and factory-marked per CGA S-1.2.

They cannot be field-adjusted and are designed to activate automatically before any unsafe pressure can develop.
✓ All cryogenic products — LIN & LAR — are non-toxic and non-explosive in their pure form.

The hazards associated with these products are well understood, predictable, and manageable with proper procedures.
✓ This safety packet, the proposed installation design, and the operational policies described herein are specifically designed to give the AHJ full visibility into every hazard, every mitigation, and every emergency response procedure.
✓ The proposed installation will be designed, installed, and operated in full compliance with NFPA 55, the primary national code governing cryogenic fluid storage, and all other applicable standards listed in Section 10.
716
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 4

1.2 Industry Safety Record
Bulk cryogenic storage has one of the strongest safety records in the industrial gas industry.

The Compressed Gas Association (CGA) and National Fire Protection Association (NFPA) have continuously refined their standards over decades based on operational experience, resulting in a comprehensive, proven regulatory framework. Incidents involving properly installed and maintained cryogenic bulk tanks are extremely rare and are almost always attributable to procedural non-compliance rather than equipment failure.

1.3 Purpose of This Document
This document serves two purposes: first, to demonstrate the inherent safety of modern cryogenic storage technology and the multiple layers of protection engineered into these vessels; and second, to provide the AHJ with complete transparency regarding identified hazards, emergency scenarios, and the comprehensive policies in place to prevent and respond to those scenarios. Both sections are essential — not because the tanks are dangerous, but because thorough emergency preparedness is part of what makes this installation safe. 717
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 5

2. PHYSICAL DESCRIPTION OF CRYOGENIC VESSELS

2.1 Overview
The bulk cryogenic storage vessels proposed for this installation are purpose-designed, engineered pressure vessels manufactured for long-term storage of cryogenic liquefied gases under pressure. All vessels are manufactured to ASME BPVC Section VIII, Division 1 (BPVC.VIII.1) requirements and operate from 5 PSI (0.4 kg/cm²) up to the Maximum Allowable Working Pressure (MAWP) stamped on the vessel nameplate.

DESIGN PHILOSOPHY
These vessels are engineered around a single principle: keep the cryogenic product safely contained under all foreseeable conditions. The double-wall vacuum design, redundant pressure relief systems, and factory-sealed insulation all exist to ensure the product never contacts the outside world except through controlled, designed pathways.

2.2 Physical Description
A cryogenic vessel is designed for long-term storage of cryogenic liquefied gases under pressure in the range of 5 PSI (0.4 kg/cm²) to the MAWP (Maximum Allowable Working Pressure). While hardware may vary slightly from model to model, each unit essentially performs the same functions.

The vessel is comprised of an alloy steel inner tank encased in an outer carbon steel vacuum shell. The insulation system between the inner and outer containers consists of super insulation and high vacuum to ensure long holding time. The insulation system designed for long-term vacuum retention is permanently sealed at the factory to ensure vacuum integrity. The units have a tank pressure relief device, which is set at the factory. As a secondary pressure relief device, the container is further protected from over-pressurization by a rupture disc. The bursting disc will rupture completely to relieve inner tank pressure in the event the tank relief valve fails and pressure exceeds the rupture disc setting. The vacuum space is protected from over-pressurization by use of a tank annulus rupture disc assembly. Pressure relief devices used on cryogenic vessels designed for the U.S. specifications meet the requirements of CGA Pamphlet S1.2, "Pressure Relief Device Standards, Part 2, for Cargo and Portable Tanks for Compressed Gases."
718
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 6

2.3 Key Design Features
Feature Description & Safety Significance
Inner Tank Material Alloy steel — engineered specifically for cryogenic temperature service down to -320°F
Outer Shell Material Carbon steel vacuum shell — never in direct contact with cryogenic liquid
Insulation System Super insulation with high vacuum — permanently sealed at factory. Zero maintenance required for insulation integrity Vacuum Integrity Factory-permanently sealed — eliminates field maintenance as a failure mode
Primary PRV Factory-set spring-loaded pressure relief valve — auto-opens and reseats at predetermined pressure. Set at ≤110% of design pressure per CGA S-1.2
Secondary PRD Factory-set rupture disc — activates only if primary PRV fails.

Total secondary flow capacity ≤150% design pressure per CGA S-1.2
Vacuum Space
Protection
Tank annulus rupture disc — prevents outer vessel overpressurization PRD Standard CGA Pamphlet S-1.2, 11th Edition (2024) — Pressure Relief Device Standards, Part 2
ASME Compliance Manufactured per ASME BPVC Section VIII, Division 1 (BPVC.VIII.1) — Rules for Construction of Pressure Vessels.

Confirm specific Division against vessel nameplate as some vessels may be built to Division 2 (Alternative Rules)
DOT Compliance Designed per DOT specifications and 49 CFR 173.318 for cryogenic liquid service
Pressure Range 5 PSI (0.4 kg/cm²) to MAWP as factory-stamped on vessel nameplate
719
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 7

2.4 ASME Certification, U-Stamp & Vessel Documentation
Every bulk cryogenic vessel manufactured to ASME BPVC Section VIII, Division 1 (BPVC.VIII.1) carries a mandatory set of certifications, documentation, and physical markings that verify the vessel was designed, fabricated, inspected, and tested in full compliance with the code. The following documentation is available for inspection by the AHJ upon request.

U-STAMP CERTIFICATION
The ASME 'U' stamp is the manufacturer's official certification mark that the vessel was designed, built, inspected, and hydrostatic tested per ASME BPVC Section VIII, Division 1.

A vessel cannot legally carry the U-stamp unless it has been fabricated under an ASMEauthorized quality control program and inspected by an Authorized Inspector (AI) from an ASME-accredited inspection agency. The U-stamp is physically stamped or engraved on the vessel nameplate.

2.4.1 ASME U-Stamp — What It Means
Item Requirement & Significance
U-Stamp Marking The letter 'U' stamped on the vessel nameplate certifies the manufacturer holds a valid ASME Certificate of Authorization and that the vessel was fabricated under an approved Quality Control (QC) program
ASME Certificate of
Authorization
Manufacturer must hold a valid ASME Certificate of
Authorization to apply the U-stamp. Certificate is issued by ASME and renewed on a regular inspection cycle
Authorized Inspector
(AI)
All ASME U-stamp vessels must be inspected by an Authorized Inspector employed by or representing an ASME-accredited inspection agency — typically an insurance company holding National Board accreditation
National Board
Registration
U-stamped vessels are typically registered with the National Board of Boiler and Pressure Vessel Inspectors (NB). The NB registration number appears on the vessel nameplate and U-1 Data Report
Nameplate Information The vessel nameplate will show: manufacturer name, serial number, U-stamp, MAWP (psig), design temperature (°F), shell material specification, year built, National Board number, and ASME code edition
Division Confirmation The vessel nameplate confirms whether the tank was manufactured to Division 1 (standard rules) or Division 2 (alternative rules). The AHJ should verify this against the nameplate on the specific vessels installed
720
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 8

2.4.2 Manufacturer's Data Report — Form U-1
Every ASME U-stamp vessel is accompanied by a Manufacturer's Data Report, designated Form U-1. This is the vessel's official birth certificate and contains the complete design and fabrication record. A copy of the U-1 form for each vessel at this installation is available for AHJ review upon request.

U-1 Form Field Description
Vessel Description Tank type, service, orientation (vertical/horizontal), and overall dimensions
Design Pressure &
Temperature
MAWP (psig) and minimum/maximum design temperature —
critical for cryogenic service rating
Shell & Head Materials Specific ASME material specification numbers (e.g., SA-240 Type 304 stainless, SA-553 Type 1 nickel alloy) confirming materials are code-approved for cryogenic temperatures
Joint Efficiency Weld joint efficiency factor used in design calculations — confirms weld quality and inspection level
Hydrostatic Test
Pressure
The actual test pressure applied at the factory — must be at minimum 1.3x MAWP per BPVC.VIII.1. Recorded on the U-1
form with date and result
Heat Treatment Documents whether post-weld heat treatment (PWHT) was performed — required for certain materials and thicknesses Radiographic
Examination
Documents X-ray or radiographic inspection of welds —
confirms weld integrity
Authorized Inspector
Certification
AI signature and stamp certifying the vessel was fabricated and inspected per ASME BPVC Section VIII, Division 1
National Board
Registration
NB number assigned upon registration — cross-references with nameplate marking
721
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 9

2.4.3 Material Specifications — Cryogenic Service
ASME BPVC Section VIII, Division 1 requires that all pressure-retaining materials be selected from approved specifications listed in ASME Section II — Materials. For cryogenic service, the inner vessel materials must maintain adequate toughness and ductility at operating temperatures as low as -320°F (-196°C). Common ASME-approved materials for cryogenic inner vessels include:

ASME Material Spec Common Name Cryogenic Suitability
SA-240 Type 304 /
304L
Austenitic Stainless Steel Suitable to -425°F (-254°C) — widely used for LIN & LAR inner
vessels
SA-240 Type 316 /
316L
Austenitic Stainless Steel (Mo) Suitable to -425°F — enhanced corrosion resistance
SA-553 Type 1 9% Nickel Steel Suitable to -320°F (-196°C) — used for larger high-pressure
cryogenic vessels
SA-304 / SA-312 Stainless Steel Pipe & Tube Used for cryogenic piping and connections on the inner vessel
Outer Shell —
Carbon Steel
SA-516 or equivalent Outer vessel only — not in contact with cryogenic liquid. Standard
carbon steel grades
722
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 10

2.4.4 Hydrostatic Test Certification
Per ASME BPVC Section VIII, Division 1, every pressure vessel must pass a hydrostatic pressure test before leaving the manufacturer's facility. This test is one of the most important safety certifications a pressure vessel carries.

Hydrostatic Test Item Requirement
Test Pressure Minimum 1.3x MAWP (Maximum Allowable Working Pressure) — per ASME BPVC.VIII.1 UG-99
Test Medium Water (or other suitable liquid) — conducted at ambient temperature before cryogenic insulation is applied
Duration Vessel held at test pressure for sufficient time for full inspection of all welds, joints, and connections
Acceptance Criteria No leakage, no permanent deformation, no visible distortion at any point on the vessel
Authorized Inspector
Witness
AI must witness and certify the hydrostatic test — recorded on Form U-1
Documentation Test date, actual test pressure applied, and AI certification recorded permanently on the U-1 Data Report
Significance for AHJ The hydrostatic test confirms the vessel can safely contain pressure at 130% of its rated MAWP — providing a substantial safety margin above any operating pressure

AHJ DOCUMENTATION REQUEST
Upon request, the facility operator will provide the AHJ with the following for each vessel installed at this site: (1) Copy of ASME Form U-1 Manufacturer's Data Report, (2) Vessel nameplate photograph showing U-stamp and MAWP, (3) National Board registration number, (4) Manufacturer's Certificate of Conformance, (5) Current certificate of inspection if required by the jurisdiction.
723
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 11

3. PRESSURE RELIEF DEVICE STANDARDS — CGA S-1.2
(11TH EDITION, 2024)
This section details the applicable requirements of CGA Pamphlet S-1.2, Pressure Relief Device Standards — Part 2: Cargo and Portable Tanks for Compressed Gases, 11th Edition (2024). All pressure relief devices installed on cryogenic vessels at this facility comply fully with CGA S-1.2 requirements. This standard is incorporated by reference into OSHA 29 CFR 1910.101(c) and referenced in 49 CFR 173.318.

WHY CGA S-1.2 MATTERS
CGA S-1.2 is the definitive standard for pressure relief device design, sizing, installation, marking, and inspection on cryogenic portable tanks. Every PRD on these vessels has been factory-verified and factory-marked per this standard — meaning an independent, thirdparty-validated safety system is already built into the vessel before it arrives at this site.

3.1 Scope & Purpose
CGA S-1.2 establishes minimum requirements for pressure relief devices on cargo and portable tanks for compressed gases including cryogenic liquids such as LIN and LAR. The standard applies to tanks with water capacity exceeding 1,000 pounds that comply with DOT specifications. The 11th Edition (2024) added improved guidance for ambient temperature effects on secondary PRD systems, updated inlet/outlet pressure drop requirements for springloaded PRVs, and enhanced equations for emergency temperature conditions at the PRD inlet.

3.2 PRD Types & Application
Device Type How It Works Application on These Vessels
Spring-Loaded
PRV (Primary)
Automatically opens and closes
at factory-set pressure. Reseats
after pressure is relieved — no
manual intervention required
Required primary PRD. Set to
discharge at ≤110% of tank design
pressure per 49 CFR 173.318 and
CGA S-1.2. Activates and reseats
automatically
Rupture Disc
(Secondary)
One-time bursting disc that
ruptures completely when PRV
fails or is insufficient. Provides
full flow relief
Required secondary PRD.

Activates only if the PRV fails.

Total secondary flow capacity at
≤150% of design pressure. Vessel
removed from service after
activation
Vacuum Annulus
Disc
Protects the vacuum jacket
space between inner and outer
vessels from over-pressurization
Specific to vacuum-insulated
cryogenic vessels — protects outer
vessel integrity
724
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 12 Thermal
Expansion Valve
Relieves pressure from liquid
trapped between isolation valves
in piping
Required on all piping sections that
can isolate cryogenic liquid. Sized
per CGA S-1.2 formulas. Added in
10th/11th Editions

3.3 Set Pressure & Flow Capacity Requirements
Primary Relief System:
• Set Pressure: PRV set to discharge at no higher than 110% of tank design pressure — factory-set, factory-stamped, non-adjustable in the field. • Automatic Operation: PRVs auto-open and auto-close at predetermined pressures. No operator action required or permitted.
• Cryogenic Design Temperature: Every PRD is designed and constructed for pressure at or exceeding tank design pressure at the coldest expected temperature — critical for LIN/LAR service ranging from -183°C to -196°C.
• Inlet/Outlet Pressure Drop: CGA S-1.2 (11th Ed.) specifies inlet and outlet pressure drop requirements for spring-loaded PRVs to ensure accurate set pressure operation under all flow conditions.

Secondary Relief System:
• Flow Capacity: Secondary PRD total flow capacity at pressure not exceeding 150% of tank design pressure — ensures adequate relief if primary PRV fails under any condition.
• LIN & LAR Service: Flow capacity meets or exceeds CGA S-1.2 formula calculations for both non-fire and fire exposure conditions.

3.4 Manufacturer Verification, Marking & Labeling
Per CGA S-1.2 and 49 CFR 173.318, all PRDs on these vessels carry factory-verified markings:
• Flow capacity and rating verified and marked by the manufacturer — field-marking is not permitted under any circumstances
• Set pressure (psig) stamped or permanently marked on PRV body • Temperature rating confirming suitability for cryogenic service • CGA S-1.2 compliance marking on all devices
• Manufacturer identification and model number for full traceability 725
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 13

3.5 Inspection & Maintenance Requirements (CGA S-1.2)
Inspection Item Requirement & Frequency
Daily Visual Inspect PRV and rupture disc for frost, icing, damage, or leakage — frost on PRV body may indicate weeping
PRV Reseating After any activation: confirm full reseat. Continuous venting after pressure normalizes = failed PRV — remove from service
Rupture Disc Status Inspect for bulging, corrosion, or damage — a ruptured disc means an overpressure event occurred — remove from service, do not refill
Vacuum Annulus Disc Inspect vent for signs of activation — activation indicates vacuum loss — remove from service immediately
PRV Replacement
Interval
Per manufacturer and CGA S-1.2 — typically every 5 years for cryogenic service
Thermal Relief Valve CGA S-1.2 (11th Ed.) added specific inspection requirements — inspect per manufacturer schedule
Documentation All PRD inspections, activations, replacements, and service events documented on-site — available to AHJ upon request Field Modification STRICTLY PROHIBITED — any PRD that has activated or shows damage must be replaced by authorized service
personnel only

3.6 CGA S-1 Series — Standard Applicability
Standard Covers This Installation
CGA S-1.1 PRDs for cylinders for
compressed gases
Applies to portable cylinders used with
the system
CGA S-1.2 —

PRIMARY
PRDs for cargo & portable
tanks for cryogenic gases
PRIMARY REFERENCE for all bulk
cryogenic vessels at this facility
CGA S-1.3 PRDs for stationary storage
containers
May also apply — AHJ and supplier to
confirm applicable edition
726
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 14

4. LAYERS OF PROTECTION — ENGINEERED SAFETY

SYSTEMS
Modern bulk cryogenic vessels employ a defense-in-depth approach to safety. No single system is relied upon to prevent an incident — instead, multiple independent, redundant layers of protection are engineered into the vessel and the installation. The failure of any single layer does not result in an incident because the next layer is already in place.

DEFENSE IN DEPTH
These tanks are designed so that multiple independent safety systems would have to fail simultaneously before any hazardous condition could develop. In practice, properly maintained cryogenic bulk tanks have an exceptional safety record precisely because of this layered approach.
# Layer Protection Provided
1 Inner Vessel
Design
ASME-code alloy steel inner vessel engineered for full operating pressure at cryogenic temperatures. This is the primary containment — the inner tank holds the product under all normal operating conditions.
2 Vacuum
Insulation
Jacket
Permanently sealed high-vacuum super-insulation jacket isolates the inner vessel from ambient temperature. Slows any heat ingress to a predictable, manageable rate — no sudden pressure spikes from insulation failure.
3 Primary
Pressure
Relief Valve
Factory-set, spring-loaded PRV automatically vents pressure before the vessel can reach unsafe pressure levels. Compliant with CGA S1.2 — set at ≤110% of design pressure. Auto-reseats after pressure is relieved.
4 Secondary
Rupture Disc
If the primary PRV fails to activate or reseat, a factory-set rupture disc provides complete pressure relief. Set at a higher pressure than the PRV — ensures full flow relief. Compliant with CGA S-1.2 at ≤150% of design pressure.
5 Vacuum
Annulus
Rupture Disc
Protects the outer vessel from over-pressurization in the event of inner vessel leak into the vacuum jacket space. Independent of the inner vessel relief system.
6 Secondary
Containment
(Site)
Site-installed containment berm or dike — sized to contain 110% of the largest vessel capacity. Prevents any spilled product from reaching drains, waterways, or adjacent structures.
7 Atmospheric
Monitoring
Fixed and portable oxygen monitors with alarm setpoints provide early warning of any atmospheric change — alerting personnel before conditions become hazardous.
727
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 15 8 Operational
Policies &
Training
Written procedures, trained operators, restricted access, and regular inspections ensure human error is minimized as a failure mode. 728
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 16

5. PRODUCT DESCRIPTIONS — LIN, LAR
The following section describes the physical, chemical, and safety properties of each product.

Understanding these properties allows for precise hazard identification and targeted emergency response planning.

5.1 Liquid Nitrogen (LIN)
Property Value / Description
Chemical Formula N₂
Boiling Point -320°F (-196°C) at atmospheric pressure
Liquid Density 50.4 lb/ft³ (807 kg/m³)
Expansion Ratio 1 liter of liquid expands to approximately 694 liters of gas at ambient temperature
Color / Odor Colorless liquid — odorless gas
Flammability Non-flammable — non-reactive
Primary Hazard Asphyxiation — displaces oxygen in confined or low-lying spaces
Secondary Hazard Cryogenic burns and frostbite on direct contact IDLH Threshold Oxygen below 19.5% is oxygen-deficient — below 16% causes loss of consciousness
DOT Classification Refrigerated Liquid (Cryogenic), Non-Flammable Gas

5.2 Liquid Argon (LAR)
Property Value / Description
Chemical Formula Ar
Boiling Point -303°F (-186°C) at atmospheric pressure
Liquid Density 87.0 lb/ft³ (1393 kg/m³)
Expansion Ratio 1 liter expands to approximately 841 liters of gas at ambient temperature
Color / Odor Colorless liquid — colorless, odorless gas Density vs. Air 38% heavier than air — settles and accumulates in pits, trenches, and low areas
Flammability Non-flammable — chemically inert
729
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 17 Primary Hazard Severe asphyxiation — heavier than air with no sensory warning IDLH Threshold Oxygen below 19.5% is immediately dangerous — argon provides zero warning
DOT Classification Refrigerated Liquid (Cryogenic), Non-Flammable Gas 730
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 18

6. HAZARD IDENTIFICATION & RISK CONTEXT
The following section identifies the hazard categories associated with bulk cryogenic storage.

These hazards are well understood, predictable, and manageable through the safety systems, policies, and procedures described in this document. The identification of these hazards does not indicate that the installation is inherently dangerous — rather, it demonstrates that every hazard has been anticipated and addressed.

6.1 Asphyxiation Hazard (LIN & LAR)
MANAGED RISK — ASPHYXIATION (LIN / LAR)
LIN and LAR are colorless and odorless. A large release can displace ambient oxygen. This hazard is managed through atmospheric monitoring systems with automatic alarms, restricted access zones, and personnel training. Properly operating vessels with intact relief systems will not release product under normal conditions. • Releases can displace ambient oxygen — oxygen monitors with automatic alarms are required
• Argon is heavier than air — accumulates in low areas and confined spaces — no oxygen-deficient entry without atmospheric monitoring and SCBA • Oxygen levels below 19.5% trigger evacuation alarm — well before dangerous concentrations occur
• Properly maintained tanks have factory-sealed vacuum insulation — normal evaporation through relief valves is minimal and expected

6.2 Cryogenic Contact Hazard (All Products)
• Direct skin contact with cryogenic liquids or cold equipment surfaces causes immediate frostbite — PPE requirements prevent contact
• Appropriate PPE (cryogenic gloves, face shield, apron) eliminates this hazard for trained, equipped personnel
• Cryogenic liquids evaporate quickly at ambient temperature — spill pools are temporary and self-resolving

6.3 Pressure Hazard
• All vessels operate under pressure — redundant PRDs (CGA S-1.2 certified) prevent unsafe pressure buildup
• Rapid phase change (liquid to gas) generates pressure — managed by factory-sized, factory-set PRDs that vent automatically
• PRDs are the safety system designed specifically for this hazard — they work automatically without human intervention
731
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 19

7. EMERGENCY RESPONSE PROCEDURES
The following emergency response procedures are established for all personnel at this facility.

These procedures are documented, posted on-site, and form the basis of annual training for all employees. First responders should consult this document upon arrival at the facility. A copy of this document is provided to the local fire department as part of the facility's hazardous materials notification.

GENERAL EMERGENCY PRINCIPLE
In any cryogenic emergency: (1) Protect people first — evacuate. (2) Call 911. (3) Identify the product and communicate it to responders. (4) Do not re-enter until atmospheric conditions are confirmed safe by calibrated monitor. Equipment can be replaced — people cannot.

7.1 Small Liquid Spill — Less than 10 Gallons
Item Detail
Likely Cause Valve connection leak, hose failure during fill, operator error Immediate Actions
(ALL Products)
(1) Stop spill source if safe. (2) Clear area — 25-foot minimum. (3) Don appropriate PPE. (4) Allow liquid to evaporate naturally. (5) Monitor O₂ levels before re-entry. (6) Document and report to supervisor.

Re-Entry Criteria O₂ confirmed 19.5%–23.5% by calibrated monitor Required PPE Cryogenic gloves, face shield, cryogenic apron, insulated safety footwear

7.2 Large Liquid Release — Greater than 10 Gallons
LARGE RELEASE — LIFE SAFETY EMERGENCY
A large cryogenic release is a life-safety emergency. Evacuate first. Call 911 and wait for trained HAZMAT response. Provide responding units with this document and wind direction upon arrival.

IMPORTANT — AHJ CONTEXT ON EVACUATION DISTANCES
The isolation and evacuation distances below are taken directly from the DOT Emergency Response Guidebook 2024 (ERG 2024), published by PHMSA. These are worst-case 732
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 20 precautionary isolation distances measured from the spill source for a large, uncontrolled release — they are NOT automatic neighborhood evacuation orders. The site design, secondary containment, and monitoring systems at this installation are specifically engineered to prevent a release from reaching this scale. First responders reference these distances as initial planning figures, not mandatory perimeters in all scenarios.

LIN (Liquid Nitrogen) — ERG 2024, Guide 120: Gases — Inert (Including Refrigerated Liquids)
Scenario ERG 2024 Guide 120 Distance
Spill / Leak —
Immediate
Precautionary
Isolate spill or leak area for at least 100 meters (330 feet) in all directions
Large Spill —
Downwind Evacuation
Consider initial downwind evacuation for at least 100 meters (330 feet)
Fire Involving Tank ISOLATE for 800 meters (1/2 mile) in all directions — consider initial evacuation for 800 meters (1/2 mile)
ERG Source DOT ERG 2024, Guide 120 — verified at:
https://cameochemicals.noaa.gov/chemical/4069
LAR (Liquid Argon) — ERG 2024, Guide 120: Gases — Inert (Including Refrigerated Liquids)
Scenario ERG 2024 Guide 120 Distance
Spill / Leak —
Immediate
Precautionary
Isolate spill or leak area for at least 100 meters (330 feet) in all directions
Large Spill —
Downwind Evacuation
Consider initial downwind evacuation for at least 100 meters (330 feet)
Fire Involving Tank ISOLATE for 800 meters (1/2 mile) in all directions — consider initial evacuation for 800 meters (1/2 mile)
ERG Source DOT ERG 2024, Guide 120 — verified at:
https://cameochemicals.noaa.gov/chemical/2509
733
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 21

7.3 Pressure Relief Valve Activation
• PRV activation is a normal safety function — cold white vapor cloud is expected and is not an emergency condition
• Ensure PRV discharge area is clear of personnel and combustibles — this is addressed in the site design
• If PRV does not reseat after pressure normalizes — contact product supplier for emergency service. Do not attempt field repair
• Document the activation event, date, time, and conditions — report to supervisor and supplier

7.4 Fire in the Vicinity of Cryogenic Storage
• For LIN/LAR near fire: evacuate, monitor O₂ levels, prevent personnel from entering gas accumulation areas
• Provide first responders with this document and the SDS upon arrival

7.5 Vessel Damage or Structural Failure
• Any suspected vessel impact, structural damage, or vacuum jacket failure — evacuate immediately, establish minimum 330-foot isolation zone (ERG 2024 Guide 120/122) and call 911
• Loss of vacuum insulation causes accelerated pressure buildup and venting — do not approach a damaged vessel
• Call 911 and product supplier emergency line — vessel must be inspected before any return to service
• Do not attempt to assess or approach a damaged cryogenic vessel — HAZMAT response required
734
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 22

8. SPILL RESPONSE & CONTAINMENT PROCEDURES

8.1 Immediate Spill Response — All Products

1. Assess spill size and source from a safe distance before approaching.

2. Alert all nearby personnel — clear the immediate area.

3. Don appropriate PPE — cryogenic gloves, face shield, cryogenic apron, insulated boots.

4. Stop the source if safely possible. If not — evacuate and call 911.

5. Allow liquid to evaporate naturally — cryogenic liquids evaporate quickly at ambient temperature.

6. Ventilate any enclosed areas affected by the release.

7. Monitor oxygen levels continuously with a calibrated portable O₂ monitor.

8. Do not re-enter until O₂ is confirmed between 19.5% and 23.5%.

9. Document the event — volume (estimated), conditions, time — report to supervisor and supplier.

8.2 Cryogenic Contact (Skin/Eye)

10. Flush affected skin with large amounts of lukewarm (NOT hot) water for at least 15 minutes.

11. Remove clothing and jewelry from affected area — do not force-remove clothing frozen to skin.

12. Do not rub or massage the area — increases tissue damage.

13. For eye contact: flush with water immediately for minimum 15 minutes — call 911.

14. Seek emergency medical attention for all cryogenic contact injuries — even minorappearing ones involve potential deep tissue damage. 735
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 23

9. SAFETY POLICIES & MITIGATION MEASURES
The following policies are mandatory for all personnel, contractors, and visitors at this facility.

These policies collectively eliminate the most common pathways to cryogenic incidents.

9.1 Access Control
• Cryogenic storage area is a restricted access zone — unauthorized personnel prohibited • All personnel working in or near the storage area must complete facility safety orientation before first access
• Visitors and contractors escorted by trained facility personnel at all times within the storage area
• NFPA 704 hazard diamond signage posted at all access points

9.2 Atmospheric Monitoring
Parameter Setpoint / Requirement
Low O₂ Warning
(LIN/LAR)

19.5% — personnel alert and precautionary action
Low O₂ Alarm /
Evacuation

18.0% — mandatory evacuation of affected area
High O₂ Warning 23.5% — eliminate ignition sources, investigate source High O₂ Alarm /
Evacuation

25.0% — mandatory evacuation, treat as fire emergency
Monitor Calibration Per manufacturer specifications — calibration records maintained on-site and available to AHJ
Fixed Monitoring Required in all enclosed or semi-enclosed areas adjacent to cryogenic storage
Portable Monitoring Required for all personnel entering areas where cryogenic gas may accumulate

9.3 PPE Requirements
Activity Required PPE
Routine area access /
observation
Safety glasses, closed-toe footwear
Working near cryogenic
equipment
Cryogenic gloves, safety glasses, face shield
736
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 24 Tank filling / transfer
operations
Cryogenic gloves, full face shield, cryogenic apron, insulated footwear
Spill response / cleanup All of the above PLUS cryogenic suit if significant spill Confined space near

LIN/LAR
All of the above PLUS supplied air respirator (SCBA)

9.4 Inspection & Maintenance
• Daily visual inspection of vessels, PRDs, and connections by trained personnel • PRD inspection and testing per manufacturer recommendations and CGA S-1.2 • Vacuum integrity monitored — excessive frost on outer vessel, increased product usage, or PRV venting reported to supplier immediately
• All records maintained on-site and available to AHJ upon request • Equipment modifications and repairs only by product supplier or authorized service personnel

9.5 Emergency Preparedness
• Emergency response procedures posted at the storage area and at the facility's main entrance
• All personnel complete emergency response training upon hire and annually thereafter • Annual emergency drill simulating cryogenic spill or release • Copy of this document provided to local fire department • This packet reviewed and updated annually or upon any change to storage area, product, or quantity
737
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 25

10. REGULATORY COMPLIANCE SUMMARY
The installation, operation, and emergency response procedures at this facility are designed to meet or exceed all applicable standards and regulations. The table below summarizes the primary regulatory framework governing this installation.

Standard / Regulation Applicability to This Installation NFPA 55 — Compressed
Gases & Cryogenic
Fluids Code
Primary code governing storage quantities, setbacks, and safety systems. All NFPA 55 requirements met or exceeded CGA S-1.2 (11th Ed.,
2024) — PRD Standards
Part 2
PRIMARY PRD standard. Governs PRV set pressures (110%
max), secondary flow capacity (150% max), factory marking.

All vessels CGA S-1.2 compliant
CGA S-1.3 — PRD
Standards Part 3
Stationary storage PRD standard — may also apply. AHJ and supplier to confirm applicable edition
CGA P-9 — Inert Gases CGA standards for nitrogen and argon. LIN and LAR operations compliant
OSHA 29 CFR 1910.101(c) Compressed gas PRD requirements — CGA S-1.2 incorporated by reference. Compliant
OSHA 29 CFR 1910.146 Confined space requirements — atmospheric monitoring and SCBA protocols in place
49 CFR 173.318 Cryogenic liquid cargo tank requirements — PRV set ≤110%, secondary ≤150% design pressure. Compliant
ASME BPVC Section VIII,
Division 1 (BPVC.VIII.1)
All vessels manufactured per ASME BPVC Section VIII,
Division 1 — Rules for Construction of Pressure Vessels. This is the code stamped on the vessel nameplate. Confirm specific Division against the nameplate, as some vessels may be
manufactured to Division 2 (Alternative Rules) depending on design pressure and manufacturer specification. Official reference: ASME BPVC.VIII.1
State & Local Fire Code Applicable adopted edition — all permits to be obtained prior to fill
738
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 26

11. SITE-SPECIFIC SAFETY MEASURES

11.1 Physical Safeguards
• Vehicle impact protection (bollards or barriers) installed around all cryogenic storage equipment
• Secondary containment berms or dike walls — sized to contain 110% of the largest vessel capacity
• Positive drainage from storage pad — prevents ponding of cryogenic liquids or water • NFPA 704 hazard diamond signage at all access points per applicable code requirements
• Perimeter fencing with locked access gate — prevents unauthorized access

11.2 Operational Controls
• Written operating procedures developed and posted at the storage area • Minimum two-person rule for all filling and transfer operations • Pre-operation checklist completed before every delivery and filling operation • Emergency shutoff valve accessible from outside the exclusion zone

11.3 First Responder Coordination
• Local fire department notified of cryogenic installation and provided a copy of this document
• Facility address and cryogenic storage location clearly marked for emergency vehicle access
• 24-hour emergency contact number posted at facility entrance • Site map showing vessel locations, exclusion zones, and access routes available at facility entrance
739
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 27

12. EMERGENCY CONTACTS & NOTIFICATION
IN ANY CRYOGENIC EMERGENCY — CALL 911 FIRST
Always call 911 as your first action in any life-safety emergency. Provide the dispatcher with your address, the product involved (liquid nitrogen, liquid argon, or liquid oxygen), the approximate quantity, and the nature of the incident.

12.1 Emergency Contact List
Contact Name / Organization Phone Number
Fire / Police / EMS 911 Dispatch 911

CHEMTREC
Emergency
Chemical Emergency Response
— 24 Hour
1-800-424-9300
National Response
Center
CERCLA/SARA Title III
Reportable Releases
1-800-424-8802
Facility Emergency
Contact
Tone Conte 310-714-3688
Product Supplier
(24-hr)
___________________________ _______________
Tank Manufacturer
Service
___________________________ _______________
Local Fire
Department
___________________________ _______________
Local HAZMAT
Team
___________________________ _______________
Facility Manager Tone Conte _______ _310-714-3688_________ Safety Officer Mike McDermott____________ _323-605-9782_____________

12.2 Notification Requirements
• Any release, spill, fire, or personal injury involving cryogenic products reported to facility manager within 1 hour
• CERCLA/SARA reportable quantities reported to National Response Center: 1-800-424- 8802
• AHJ notified within 24 hours of any significant incident at this facility • Product supplier notified within 24 hours of any equipment malfunction, unusual venting, or suspected vessel damage
740
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 28

REFERENCES & SOURCE DOCUMENTS
The following references were used in the preparation of this Safety & Compliance Presentation. All sources are publicly available and can be independently verified by the AHJ.

Web links are provided where applicable. Where standards are subscription-based, the official publisher website is listed for procurement.

NOTE TO AHJ
All regulatory standards referenced in this document should be confirmed against the currently adopted edition in your jurisdiction. Adoption of NFPA, IFC, and other model codes varies by state and municipality. Contact your state fire marshal's office or building department to confirm which edition applies.

A. Emergency Response References
Source Details & Access
DOT Emergency Response
Guidebook 2024 (ERG 2024)
Guide 120 — Gases: Inert
(Including Refrigerated
Liquids) Applies to: LIN, LAR
Publisher: U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) Free PDF:
https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024- 04/ERG2024-Eng-Web-a.pdf Guide 120 direct:
https://cameochemicals.noaa.gov/erg_guides/en/Guide_120.pdf LIN verified: https://cameochemicals.noaa.gov/chemical/4069 LAR verified: https://cameochemicals.noaa.gov/chemical/2509 Matheson Tri-Gas MSDS —
Liquid Nitrogen
Independently confirms fire involving tank evacuation distance:
800 meters (1/2 mile) Source:
https://www.scribd.com/document/244169919/Matheson-Tri-GasLiquid-Nitrogen For current Matheson SDS documents:
https://www.mathesongas.com
NOAA CAMEO Chemicals
Database
Chemical hazard data, ERG guide assignments, and emergency response information for LIN, LAR. Free access:
https://cameochemicals.noaa.gov
B. Fire & Safety Codes
Standard Details & Access
NFPA 55 — Compressed
Gases and Cryogenic Fluids
Code Current Adopted Edition
Publisher: National Fire Protection Association (NFPA) Primary code governing storage quantities, setback distances, and safety systems for all cryogenic installations Purchase/access:
https://www.nfpa.org/product/nfpa-55-code/p0055code Free readonly access available at: https://link.nfpa.org/all-publications/55 741
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 29 International Fire Code (IFC)
Chapter 55 — Cryogenic
Fluids 2018 or currently
adopted edition
Publisher: International Code Council (ICC) Cryogenic fluid storage and handling requirements — adopted by many
jurisdictions as local fire code Access:
https://codes.iccsafe.org/content/IFC2018/chapter-55-cryogenicfluids C. CGA Standards
Standard Details & Access
CGA S-1.2 — Pressure Relief
Device Standards Part 2:

Cargo and Portable Tanks for
Compressed Gases 11th
Edition, September 2024
Publisher: Compressed Gas Association (CGA) PRIMARY PRD standard for all cryogenic vessels at this facility. Governs PRV set pressures, secondary flow capacity, factory marking, and inspection Purchase: https://store.accuristech.com/standards/cgas-1-2 CGA overview: https://www.cganet.com/cga%E2%80%99ss-1-series-what-distributors-need-to-know-about-pressure-reliefdevice-standards/ CGA S-1.3 — Pressure Relief
Device Standards Part 3:

Stationary Storage Containers
for Compressed Gases
Publisher: CGA May apply to stationary bulk cryogenic storage — AHJ to confirm applicable edition Purchase:
https://www.cganet.com
CGA P-9 — The Inert Gases:

Argon, Nitrogen, and Helium
Publisher: CGA CGA standards for nitrogen (LIN) and argon (LAR) handling and storage Purchase/info: https://www.cganet.com D. OSHA Regulations
Regulation Details & Access
OSHA 29 CFR 1910.101 —
Compressed Gases (General
Requirements)
Incorporates CGA S-1.2 by reference for PRD requirements on all compressed gas containers Free access:
https://www.osha.gov/lawsregs/regulations/standardnumber/1910/1910.101 Also:
https://up.codes/s/compressed-gases-general-requirements OSHA 29 CFR 1910.146 —
Permit-Required Confined
Spaces
Applies to any confined spaces adjacent to LIN/LAR storage where oxygen deficiency may develop Free access:
https://www.osha.gov/lawsregs/regulations/standardnumber/1910/1910.146 E. DOT & Transportation Regulations
Regulation Details & Access
49 CFR 173.318 — Cryogenic
Liquids in Cargo Tanks
Governs cryogenic liquid cargo tank design and PRD requirements — PRV set ≤110% design pressure, secondary system ≤150% design pressure Free access: https://www.ecfr.gov/current/title49/subtitle-B/chapter-I/subchapter-C/part-173/subpart-G/section173.318 742
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 30 49 CFR Parts 100–185 —
Hazardous Materials
Transportation
DOT hazardous materials transportation regulations governing delivery of LIN & LAR to this facility Free access:
https://www.ecfr.gov/current/title-49
CERCLA / SARA Title III —
Emergency Planning &
Community Right-to-Know
Reportable quantity requirements for accidental releases of hazardous substances National Response Center: 1-800-424- 8802 EPA info: https://www.epa.gov/epcra
F. ASME Codes & Standards
Standard Details & Access
ASME BPVC Section VIII,
Division 1 (BPVC.VIII.1) Rules
for Construction of Pressure
Vessels PRIMARY
manufacturing code for
vessels at this facility
Publisher: American Society of Mechanical Engineers (ASME) Governs design, fabrication, inspection, testing, and U-stamp certification of pressure vessels operating above 15 psig Purchase: https://www.asme.org/codes-standards/find-codesstandards/bpvc-viii-1-bpvc-section-viii-rules-construction-pressurevessels-division-1 ASME overview: https://www.asme.org ASME BPVC Section VIII,
Division 2 (BPVC.VIII.2)
Alternative Rules for
Construction of Pressure
Vessels
Publisher: ASME Alternative rules for higher-pressure vessels using design-by-analysis methods. May apply to some vessels depending on manufacturer specification — confirm against vessel nameplate Purchase: https://www.asme.org/codes-standards/findcodes-standards/bpvc-viii-2-bpvc-section-viii-rules-constructionpressure-vessels-division-2-alternative-rules-(1) ASME BPVC Section II —
Materials
Publisher: ASME Approved material specifications for pressure vessel construction — governs inner vessel material selection for cryogenic service (SA-240, SA-553, SA-304, etc.) Purchase:
https://www.asme.org
National Board of Boiler and
Pressure Vessel Inspectors
Maintains the National Board Register of all ASME U-stamp pressure vessels. AHJ can verify vessel registration and manufacturer authorization Website: https://www.nationalboard.org Vessel registration lookup:
https://www.nationalboard.org/index.aspx?pageID=140
G. Additional Reference Resources
Resource Details & Access
CHEMTREC — Chemical
Emergency Response
24-hour emergency chemical response hotline — available to first responders and AHJ for product-specific emergency guidance Phone: 1-800-424-9300 (US) | +1-703-527-3887 (International) Website: https://www.chemtrec.com
National Response Center
(NRC)
Federal reporting center for CERCLA/SARA reportable releases Phone: 1-800-424-8802 Website: https://www.nrc.uscg.mil PHMSA — Pipeline and
Hazardous Materials Safety
Administration
DOT agency responsible for ERG publication, hazmat
transportation regulations, and pipeline safety Website:
https://www.phmsa.dot.gov ERG 2024 download:
743
LIN / LAR— Bulk Cryogenic Tank Safety Presentation | AHJ Submission 31 https://www.phmsa.dot.gov/training/hazmat/erg/emergencyresponse-guidebook-erg Compressed Gas Association
(CGA)
Industry association that publishes all CGA standards referenced in this document — G-4, P-9, S-1.2, S-1.3 Website:
https://www.cganet.com Standards store:
https://www.cganet.com/store
American Society of
Mechanical Engineers (ASME)
Publisher of ASME Boiler and Pressure Vessel Code including BPVC.VIII.1 and BPVC.VIII.2 Website: https://www.asme.org Codes & Standards: https://www.asme.org/codes-standards National Fire Protection
Association (NFPA)
Publisher of NFPA 55 and NFPA 50 referenced in this document Website: https://www.nfpa.org Free read-only code access:
https://link.nfpa.org

CERTIFICATION
The undersigned certifies that the information in this Safety & Compliance Presentation is accurate and complete to the best of their knowledge, and that the policies and procedures described herein are in effect or will be implemented prior to commencement of cryogenic storage operations.

Signature: _______________________________________________ Printed Name: _______________________________________________ Title: _______________________________________________
Company: _______________________________________________ Date: _______________________________________________
This document is provided as a boilerplate safety reference. Verify all information with the product supplier, tank manufacturer, and qualified safety professionals prior to AHJ submission. All regulatory references should be confirmed against the currently adopted edition in the applicable jurisdiction. 744
745
746
747
748
749
750
751
752
753
754
755
756
757
758

CITY OF REDONDO BEACH

EXEMPTION DECLARATION

PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
DATE: September 17, 2026
PROJECT ADDRESS: 2477 Manhattan Beach Boulevard
PROPOSED PROJECT: Consideration of an Exemption Declaration and Variance to exceed the 30-foot maximum building
height requirement for the installation of four bulk
cryogenic storage tanks with a proposed height of
approximately 38 feet at an existing manufacturing
facility on property located within an IndustrialCommercial (IC-1) zone. (Case No. 2026-0595) In accordance with Chapter 3, Title 10, Section 10-3.301(a) of the Redondo Beach Municipal Code, the above-referenced project is Categorically Exempt from the preparation of environmental review documents pursuant to:

The project is Categorically Exempt from the provisions of the California Environmental Quality Act (CEQA), under Article 19, Section 15301 (Existing Facilities) of the California Guidelines for Implementation of the CEQA.

Specifically, the project includes a negligible expansion of the existing residence.

Additionally, the subject site is not located within an area designated as an environmental resource of hazardous or critical concern, or within the California Coastal Zone, or within an officially designated, state scenic highway, or within a hazardous waste site included on any list compiled pursuant to Section 65962.5 of the Government Code.

Daniel Besinaiz
Daniel Besinaiz
Associate Planner
759

CITY OF REDONDO BEACH CITY COUNCIL APPEAL RECORD
October Appeal to CC -
Public Comments
2477 Manhattan Beach Boulevard
Case No. 2026-0595

COMPLETE PUBLIC-COMMENT RECORD
45 distinct email submissions
Chronological by original public sender within each meeting section AUGUST 20 PLANNING COMMISSION 16 comments
SEPTEMBER 17 PLANNING COMMISSION 18 comments
OCTOBER CITY COUNCIL APPEAL 11 comments
Duplicate source files excluded; supporting materials retained with the parent email October 2026 760
CITY OF REDONDO BEACH AUGUST 20 PLANNING COMMISSION
Planning Commission Public
Comments
Meeting Date: August 20, 2026
Agenda Item J.1 - Case No. 2026-0595

PUBLIC COMMENT COMPILATION
16 distinct email submissions
Original public-sender dates: August 6 - August 20, 2026 Emails are arranged by the original public sender's date and time. Non-government email addresses and personal phone numbers are permanently redacted. 2477 Manhattan Beach Boulevard Case No. 2026-0595
761
PUBLIC COMMENT 01 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Roxanne Ferebee

ORIGINAL SENT
Thursday, August 6, 2026 at 4:34 PM

SUBJECT
Re: IMPULSE INDUSTRIES
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
762
From: Roxanne Ferebee
To: Marc Wiener
Cc: Scott Behrendt; James Light; Mike Witzansky; Quality of Life; Steven Giang Subject: Re: IMPULSE INDUSTRIES
Date: Thursday, August 6, 2026 4:34:27 PM
Attachments: image001.png
You don't often get email from Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

August 6/2026,
Good Afternoon,
I would like to follow up on your offer of scheduling a meeting, to go over some current concerns that are happening across the street from our homes.

There seems to be a lot of activity regarding Impulse Industries with no community outreach, information or any contact information.

I have looked at past City Council meetings and I can not find any early discussions on this project that appeared in our area.

It would be nice to have some knowledge and answers when we reach out to the city, when this type of construction and development is going to happen in our neighborhood. For several months I have been reaching out to the city and have been told to call/email this person, that person, and just recently I was advised to NOW reach out to the planning department. I approached our planning commissioner in district 5, and he was not aware of this project. Who in the planning department has the answers and why couldn't I have been advised to reach out to that contact months ago?
This is not just a simple business moving in after a similar business moved out.

These are major changes to the structure of the current property - walls, windows, doors, lighting and the change of the type of work that will be done at the property.

Impulse Industries clearly states they will do their hot testing (Rocket engines) in the Mojave desert, however, they also state that they will be doing testing at the new Redondo Beach 60,000 square-foot facility
The site discusses:
-Vibration testing
-Heat testing (not rocket boosters) but products being assembled to withstand extreme heat -Cooling testing for products to withstand extreme freezing temperatures.

What about the installment of a half dozen new electrical transformers, and new grotesquely large AC units across the rooftops, visibly noticeable to accommodate the electrical surge for extreme heat and cooling testing of products. What liquids will be stored over there. 763
With 3 Major warehouse fires in the last few months, what precautions are being made for safety?
Warehouse fire and Garden Grove scare test CA chemical safety Garden Grove chemical leak plant faces lawsuits, supply disruption - Los Angeles Times And with the notice of an increase (several hundred employees), how are they going to accommodate the parking for workers.

We are now daily having numerous employees parking in the neighborhood at astonishing numbers.

As a 25 year resident, seeing 30+ extra cars parking on your residential street and dozens of strangers walking by our yards is a high alert safety concern.

Too much has been going on over at the location, with little information from the city.

Roxanne
On Mon, Jul 20, 2026 at 1:07 PM Marc Wiener <[email protected]> wrote:

Hi Roxanne,
The City has been working closely with Impulse Space on this project. The activities at this facility will primarily consist of product and component assembly, similar to their existing facility in Redondo Beach. The rocket testing occurs at their facility in Mojave Desert and will not take place at the facility in Redondo Beach. Impulse Space is working on an information brochure that they will be circulating to the neighborhood soon. I am happy to speak with you sometime this week about the project.

Marc Wiener, AICP
Community Development Director
310.697.3185
[email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
764
From: Lorena Soules <[email protected]>
Sent: Monday, July 20, 2026 9:36 AM
To: Roxanne Ferebee
Cc: James Light <[email protected]>; Mike Witzansky <[email protected]>; Marc Wiener <[email protected]>; Scott Behrendt <[email protected]>; Daisy Canales <[email protected]>
Subject: RE: IMPULSE INDUSTRIES
Good morning Roxanne,
Thank you for your follow-up email and for taking the time to share your concerns regarding the construction activity and the Impulse Industries project. I appreciate your patience while I gathered information.

Regarding your concerns about employee parking and whether the project is providing adequate parking, these matters fall under the City's Planning Division and are governed by the Redondo Beach Municipal Code parking regulations. For questions regarding parking requirements, land use approvals, or conditions of approval associated with this project, please contact the Project Planner:

Steven Giang, Senior Planner
Email: [email protected]
Phone: (310) 697-3696
Mr. Giang will be able to discuss the applicable parking requirements, any planning-related approvals associated with the project, and answer questions regarding the approved land use.

If you are interested in learning more about the project, the approved construction plans are public records and are available for review at City Hall. Mr. Giang can review the approved plans with you and discuss the project, including the approved use and any applicable Planning conditions. 765
With respect to your concern regarding construction activity beginning at approximately 6:00 a.m., the City's permitted construction hours are enforced through Code Enforcement and the Police Department. If you observe construction occurring outside the permitted hours, I recommend contacting the Redondo Beach Police Department Non-Emergency Dispatch at (310) 379-2477 while the activity is occurring. Reporting it at the time of the occurrence allows the incident to be documented and investigated appropriately.

Regarding the construction signage, the City does require that construction projects post signage identifying the contractor and providing contact information. I appreciate your feedback that it would also be helpful for nearby residents to have contact information for the project owner or owner's representative. I will reach out to the project team and request that the primary project contact, in addition to the contractor's information, be included on the project signage to improve communication with the surrounding neighborhood.

I understand the neighborhood's interest in learning more about the future operations of the business. Questions regarding the approved use of the property, operational activities, and any Planning approvals are best directed to the Planning Division, as they oversee the land use entitlements and conditions associated with the project.

Thank you again for bringing these matters to the City's attention. We appreciate residents taking the time to report concerns so they can be directed to the appropriate department for review.

Sincerely,
Lorena Soules, CBO, CASp
Building Official
310.697.0636
[email protected]
766
For further assistance contact [email protected] or call 310-318-0636.

Please take our short survey so that we can understand how to better serve you (click here).

From: Roxanne Ferebee
Sent: Friday, July 17, 2026 4:45 PM
To: Lorena Soules <[email protected]>
Cc: James Light <[email protected]>; Mike Witzansky <[email protected]>; Marc Wiener <[email protected]>; Scott Behrendt <[email protected]>; Daisy Canales <[email protected]>
Subject: Re: IMPULSE INDUSTRIES
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello,
I am checking back for a follow up regarding my email.

There remain numerous concerns about the ongoing construction and development across the street with the business Impulse Industries.

We remain concerned about the lack of information regarding the business, what their operations will be, the parking issues for the employees, and the massive changes to the nature of the warehouses across the street from Redondo Beach residential homes, to accommodate "space industries operations"
We still have construction being done in violation of city codes. Yesterday 7/16/2026, we had jack hammering and other construction work start at 6am. My neighbor physically walked over to the site at 615 am, looking for a supervisor. None was able to be found. She approached the security guard at the gate and asked about the sign that states "Construction hours" and she states they just shrugged their shoulders.

The work stopped until she left the site, then they started right back up. 767
We also are continuing to have our streets being impacted with Impulse employees parking here.

We would also like to have a better understanding what type of work will be done across the street close to our homes.

Residents here are concerned by - what we see being done to the warehouse site and the changes being made to a simple storage warehouse -to accomodate what Impulse Industries manufactures and the types of testing that is needed for their business.

Why have the residents in this neighborhood not been advised of what the situation is.

I can find no discussion to the community of this, by the city, or of any notice to the residents.

We have reached out to the city a few times and are still waiting for some information on how we can be assured we will not be victims of a massive toxic warehouse fire, as seen in the latest news, or be exposed to toxic waste, heat, vibrations and noise.

Impulse Industries own websites discusses the "testing" they will be doing at their "new RB location", and it is unclear how all the changes being done to that location and the inhouse testing expected to be done, is not going to affect the homes across the street.

Please help provide some follow up information.

Thank you
Roxanne
On Wed, Jul 1, 2026 at 4:05 PM Lorena Soules <[email protected]> wrote:

Roxanne,
Your email is received, I will respond soon.

Thank you,
768
Lorena Soules, CBO, CASp
Building Official
310.697.0636
[email protected]
For further assistance contact [email protected] or call 310-318-0636.

Please take our short survey so that we can understand how to better serve you (click here).

From: Roxanne Ferebee
Sent: Wednesday, July 1
To: Lorena Soules <[email protected]>
Cc: James Light <[email protected]>; Mike Witzansky <[email protected]>; Marc Wiener <[email protected]>; Scott Behrendt <[email protected]>; Daisy Canales <[email protected]> Subject: IMPULSE INDUSTRIES
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good Afternoon,
I have an additional concern regarding the ongoing process of Impulse Industries located on Manhattan beach blvd in North Redondo beach.

We have begun to notice a number of additional vehicles parking in our neighborhood 769
that are not in - anyway - associated with the residents who live here. This is an immense concern.

It was known that on the Manhattan Beach "front street" that runs east / west between Gibson and Mcbain - had become a huge parking lot for the Impulse employees located across the street at 2651 MBBLVD.

Six months ago myself and a neighbor counted the cars parked on that side street and as a homeowner 25+ years of living and daily walking our neighborhood, we have a very strong "knowing' of who's cars belong to which houses on our streets. We counted 27 cars parked there that were not from the homes on that street.

With Impulse expanding over to the new area at 2425 MBBLVD we are NOW seeing Impulse employees parking on Sebald and walking over to the warehouses. I asked the workers if there was a problem with parking due to the ongoing construction and they said - There just is not enough parking and to contact the CEO Tom Mueller.

Doesn't the city and planning assess this during the application and permitting process. I have watched and attended enough city council meetings and watched the city express concerns and guidelines with new construction and the parking requirements.

While our streets are public, this is a safety and quality of life issue impacting our homes in Redondo Beach.

Does Impulse have no obligation to provide adequate parking for its employees and are not getting the grilling and scrutiny regarding parking concerns like many other applicants are forced to abide by.

If this is a temporary matter due to ongoing construction / remodeling work, over there - we can be patient, but 5 cars turn into 10, then 20, then 30, then 40.

Also curious why are they not obligated to put some contact information up to call, like a construction manager? owners rep?)
Also is there any information on when we can expect the construction process to be close to being somewhat completed?
Thanks for your help
Roxanne
Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be 770
responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email.

Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email.
771
PUBLIC COMMENT 02 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Roxanne Ferebee

ORIGINAL SENT
Thursday, August 6, 2026 at 5:46 PM

SUBJECT
Fwd: neighbors concerned about Impulse Industries
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
772
From: Jamaal Brown
To: ‘Sean Scully Cc: ‘Mare Wiener Subject: FW: neighbors concerned about Impulse Industries Date: Thursday, August 6, 2026 5:51:28 PM Attachments: imaaeQO1.ona
Jamaal Brown
Planning Analyst
310.697.3142
Please complete our short Customer Service Survey if you would like to share your experience with management and help us improve our services! @%& REDONDO == BEACH Business Hours: 7:30AM-5:30PM
Please note: City Hall is closed holidays and every other Friday From: Roxanne Fereh:>
Sent: Thursday, August 6, 2026 5:46 PM
To: Jamaal Brown <[email protected]>
Subject: Fwd: neighbors concerned about Impulse Industries You don't often get email {rom III Lcarn why this is important | reached out to the city this am for information on how to email our Planning Commisioner / District 5 Roger Light.

He lives several blocks from us in North Redondo (TRW) tract and | spoke to him regarding some concerns and he asked that | send him some information. | called the Planning office and was told to reach out to you? lam forwarding an email for him, please advise if this is the correct process to have this information sent to him.
773
To Dr. Light,
We spoke last week regarding some concerns about Impulse Industries and the building and expansion of the business located on MBBLVD.

There were a number of issues you asked me to send to you - but - there is no direct RBemail for you (per the Planning office - and | was advised to email this person as a liaison?)
| have many concerns, and NOW...
we just received a public hearing notice on this matter coming to you at the next Planning commission meeting.

Please reach out to me via email, | would love to come by and discuss this - and say hello to Dr. Lori.(it's been awhile, | cc'd an old email address) Roxanne
text a
weseeenn= Forwarded message ---------
From: Roxanne Ferebee is
Date: Thu, Aug 6, 2026 at 5:24 PM
Subject: Fwd: neighbors concerned about Impulse Industries To: Scott Behrendt <[email protected]>
cece ncnne Forwarded message ---------
From: Roxanne Ferebee
Date: Thu, Aug 6, 2026 at 5:22 PM
Subject: neighbors concerned about Impulse Industries
To: <[email protected]>
For several months, | have reached out to the city and elected officials regarding Impulse Industries.

There has been an unsatisfactory response on providing the information to residents when they need to know when a large business corporation is embarking on a massive restructuring of the building area and the change of day to day operations, directly across the street from an entire residential community. 774
Of all the questions and inquiries sent to the city with minimal answers, TODAY our neighborhood received the "city of redondo beach notice of public hearing" that will be held on THIS months planning commission meeting to review a request for “a variance to exceed the 30 foot maximum height requirement:

For the installation of three 3 BULK cryogenic storage tanks with a proposed height of 38 feet at the existing facility" ie: they want to go to 4 stories.

This ?? 300 ft. from our homes? How long was the city aware of this and why was this not disclosed?
Warehouse fire and Garden Grove scare test CA chemical safet After all the inquiries, emails and calls to the city and code enforcement, related to construction without approved permits, violations of construction hours (3 am, 11pm, 5am, Sundays etc.) and violations of construction rules on the ground, digging, dust control, parking issues, and even being shut down due violations, why is this just now becoming public knowledge.

Again,
How long was the city aware of this and why was this not disclosed by anyone when we asked?
This is ridiculous, so unsafe and how did the city do this? Roxanne
Understanding Cryogenic Liquids and Storage Safety Near Residential Areas Cryogenic liquids are gases that remain in liquid form only at extremely low temperatures — below about -150 °C (-238 °F) — such as liquid nitrogen (-196 °C), liquid oxygen (-183 °C), liquid argon (-186 °C), and others like hydrogen or methane Environment, Health & Safety+1.

They are odorless, colorless, and expand into large volumes of gas when they warm to room temperature, which can create significant pressure and safety hazards.

Key Hazards
Extreme cold: Can cause frostbite or cold burns on contact with skin or equipment 775
Environment,
Health & Safety+1.

Oxygen deficiency: Large volumes of gas released can displace oxygen, leading to asphyxiation in enclosed or poorly ventilated spaces
Environment, Health & Safety.

Pressure build-up: Rapid vaporization in sealed containers can rupture tanks Air Products.

Material embrittlement: Cold temperatures can make metals, plastics, and rubber brittle Air Products.

Flammability: Some cryogens (e.g., hydrogen, methane) are flammable; others (e.g., oxygen) can make nearby flammable materials more combustible Environment, Health & Safety.

Storage Tank Design
Cryogenic storage tanks are engineered to minimize heat transfer:

Inner vessel: Holds the liquid, made from materials strong at cryogenic temperatures.

Outer jacket: Encloses the inner vessel, often with a vacuum and multi-layer insulation to reduce boil-off www.cryogenictank.com+1.

Pressure relief systems: Valves and rupture discs prevent over-pressurization www.cryogenictank.com+1.

Ventilation: Tanks are typically located in well-ventilated areas to prevent oxygen depletion Linde.

Should They Be Near Residential Areas?
No — cryogenic storage tanks should not be located close to residential areas without strict safety controls.

Nearby homes or occupied spaces increase the risk of:

Asphyxiation if gases leak into air.

Cold injury from splashes or leaks.
776
Fire or explosion if flammable cryogens are involved.

Unnoticed leaks because cryogens are odorless and colorless Environment, Health & Safety+1.

Best practice:

Store cryogenic liquids in dedicated, well-ventilated, and isolated facilities away from public access.

Maintain buffer zones and perimeter controls to limit exposure.

Conduct hazard assessments and install gas detection and ventilation systems Environment, Health & Safety+1.

Follow local, state, and federal regulations for hazardous material storage.

In summary: Cryogenic liquids are essential in many industries but pose serious health and safety risks. Storage tanks should be kept away from residential ar with engineering an ministrative controls in pl. to protect ni 777
PUBLIC COMMENT 03 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Saturday, August 15, 2026 at 7:25 PM

SUBJECT
Public Comment - Planning Commission - Permit
Application Defects - 2425/2477 Manhattan Beach Blvd
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
778
From: Mark Nelson (Home Gmail)
To: CityClerk; Sean Scully
Ce: Fire-HHMDCERS@fire,Jacounty.gov
Subject: Public Comment - Planning Commission - Permit Application Defects - 2425/2477 Manhattan Beach Blvd Date: Saturday, August 15, 2026 7:25:47 PM
Attachments: RB Cryogenic Tank Permit Record Deficiency Memo,odf Planning Commission, Planning Department, RBFD, RBPD, City Attorney On behalf of a resident approximately 1000 feet or less from the permit action property, | file the following analysis and defect list of the application and materials. This application has not had proper QA/QC and must be corrected prior to wasting any more of the public's time. LA County Fire has been noticed as well. As a process note, the City should have had the public materials posted concurrent with the signage. The public was forced to waste significant time, effort and analysis guessing what the permit request entailed. As is, the current permit package and record is filled with contradictions and has lacks significant disclosures. See below. Ata minimum, the proponent and the City need to complete the punch list at the end of the memo.

Mark Nelson
Expert Witness

MEMORANDUM
TO Redondo Beach Planning Commission; Redondo Beach
Fire Department; Redondo Beach Police Department;
Redondo Beach City Attorney; Community
Development Department; Building & Safety Division
CC/ OTHER JURISDICTIONAL Los Angeles County Fire Department Health Hazardous REVIEW Materials Division / CUPA, as applicable; other
hazardous-materials and emergency-response
agencies having jurisdiction
FROM Interested public / permit-record review
DATE August 15, 2026
RE 2477 Manhattan Beach Boulevard — Case No. 2026-
0595 / PC26-1012 — Cryogenic Storage Tank Variance
SUBJECT Inconsistencies, informational shortfalls, public-safety deficiencies, and items that should be remedied before
approval

EXECUTIVE SUMMARY
The submitted package is not presently a coherent, site-specific safety record for the proposed 779
installation. It contains material contradictions about the number of tanks, the products to be stored, and even the project address. It also omits basic information needed to evaluate the relationship between the tanks and the immediately adjacent residential neighborhood.

The most consequential defect is the absence of a readable vicinity/context map showing street names, property boundaries, surrounding land uses, residences, tank-to-property-line distances, tank-to-residence distances, emergency access, delivery routes, and the applicant's own emergency isolation distances. The Administrative Report expressly recognizes R-1 residences south of the site across Manhattan Beach Boulevard, while the safety presentation instructs responders to establish a 330-foot isolation zone for a large release or vessel damage and a one-half-mile isolation distance for a fire involving a tank. Those facts should be shown together on a single scaled map before the Commission makes findings concerning safety, neighborhood impacts, or CEQA.

The record also does not disclose the capacity, inventory, operating pressure/MAWP, manufacturer/model, relief-device discharge configuration, or U-1/nameplate data for each proposed vessel. The applicant's safety presentation repeatedly states that such vessel-specific documentation exists or is available to the Authority Having Jurisdiction, but it is not included in the public packet. Without the quantities and design data, staff and the public cannot independently verify NFPA 55 quantity-dependent requirements, setbacks, emergency planning assumptions, delivery frequency, or the consequences of a credible release.

These deficiencies do not establish that the proposed tanks are unsafe. They establish that the present record is insufficiently consistent and site-specific to support the broad safety conclusions stated in the Administrative Report and draft findings. The appropriate remedy is to require a corrected, consolidated submittal and documented review by the agencies having jurisdiction before final approval or, at minimum, before the tanks may be installed or filled.

1. Documents Reviewed
« Administrative Report, File No. PC26-1012, meeting date August 20, 2026.

Attachment 1 — Draft Planning Commission Resolution No. 2026-08-PCR-11.

Attachment 2 — Site Plan, including revision notation “Tank Relocation 8/12/26.” Attachment 3 — Project Renderings.

Attachment 4 — Bulk Cryogenic Storage Safety & Compliance Presentation, prepared by Matheson, dated June 9, 2026.
e Attachment 5— CEQA Exemption Declaration, dated August 20, 2026. e Attachment 6 — Public Comment and City correspondence.

2. Principal Record Inconsistencies
A. Tank count is inconsistent
The CEQA Exemption Declaration describes three tanks. The Administrative Report and title of the draft Resolution describe four tanks, with three initially. The Resolution's conditions attempt to reconcile this by authorizing three initially and a fourth in the future. A CEQA determination and project description should address the same project that is being approved, including the reasonably contemplated fourth tank.

Record references: Attachment 5 describes “three bulk cryogenic storage tanks”; Administrative Report describes “four (three initially)”; Draft Resolution authorizes three initially and a future fourth.

The record is sloppy and convoluted.

B. Stored products are inconsistent — and liquid oxygen appears in the safety record The Administrative Report first states that the tanks will store liquid nitrogen (LIN) and liquid argon (LAR). Its Safety section then states that the proposed storage includes liquid nitrogen, liquid argon, and liquid oxygen (LOX). The Matheson presentation is titled for LIN/LAR, but its Executive Summary and emergency instructions also refer to liquid oxygen. By contrast, the submitted site plan labels two LN2 tanks, one LAR tank, and a future LAR/LN2 tank. 780
This is not a clerical detail. LOX is an oxidizer with a materially different fire-risk profile from inert LIN/LAR. The approved product for each tank must be unambiguous, and any future product conversion should require prior Fire/CUPA review and any necessary land-use or environmental review.

C. Project address is inconsistent
The Planning documents identify 2477 Manhattan Beach Boulevard. The Matheson AHJ safety presentation identifies the site as “2425 Manhattan Beach.” Public correspondence also refers to 2425. The safety document therefore should be corrected and reissued for the exact parcel and installation being approved.

D. The safety presentation makes site-specific claims without supplying the site-specific proof The presentation states that NFPA 55 requirements are met or exceeded, that secondary containment will hold 110% of the largest vessel, that an emergency shutoff is accessible outside the exclusion zone, and that a site map identifies exclusion zones and emergency access. Those items are either not shown in the Planning packet or cannot be verified from the submitted plan. A conclusion of compliance should be supported by a code matrix and drawings demonstrating the applicable distances and features.

3. Missing Site Context — Critical Mapping Defect
The packet lacks a usable vicinity map with street names and surrounding uses. Attachment 2 is essentially an internal facility plan. It does not give the Planning Commission or first responders a clear neighborhood-scale depiction of the hazard source relative to the public.

At minimum, a corrected scaled exhibit should show:

Manhattan Beach Boulevard and all surrounding streets by name; the project parcel boundary and adjoining parcel boundaries; all adjacent zoning and actual land uses, with the R-1 residential area prominently identified; the location of the nearest residences and measured distances from each tank, fill connection, vent/PRV discharge point, and property line; e the 100-meter/330-foot isolation radius cited by the applicant for a large release or vessel damage;
e the 800-meter/one-half-mile isolation radius cited for a fire involving a tank, preferably as a separate emergency-planning exhibit;
¢ prevailing access points, Fire Department apparatus access, hydrants/FDC, emergency shutoff location, staging area, and HAZMAT access;
¢ cryogenic delivery truck route, on-site maneuvering/turning, unloading location, and whether a delivery vehicle blocks emergency access;
topography, drainage direction, low areas, pits, trenches, storm drains, and other locations where cold argon or nitrogen gas could accumulate;
the location and height of walls/fences and any structures that may channel or confine a vapor cloud.

4. Vessel and Inventory Information Is Missing
The public record should identify each tank as an actual engineered vessel, not merely as a 38-foot generic cryogenic tank. The Matheson presentation itself says the AHJ can review Form U-1, nameplate photographs, National Board registration, manufacturer certificates, and inspection information. Those records should be submitted before a finding of site-specific compliance. e Manufacturer, model, serial number, National Board number and ASME U-stamp. documentation for each vessel.
¢ Gross and usable capacity of each vessel in gallons and pounds; maximum inventory of LIN, LAR and any LOX.
e Normal operating pressure, design pressure, MAWP, design temperature, and relief-device 781
set pressures/capacities.
e Exact tank diameter and overall height, foundation/anchorage design, center of gravity, and seismic design criteria.
¢ Fill connection, piping, vaporizers, valves, emergency shutoffs, relief devices, rupture discs, vent outlets and discharge elevations/directions.
¢ Product-specific Safety Data Sheets and a definitive tank/product assignment. ¢ Maximum delivery-truck inventory and transfer hose location during filling. e Expected consumption rate and substantiation for the stated approximately weekly delivery frequency.

5. Emergency Planning Is Not Adequately Connected to the Residential Setting
The applicant's own safety presentation classifies a release greater than 10 gallons as a life-safety emergency, directs evacuation and HAZMAT response, cites 330 feet as an initial isolation/downwind planning distance for LIN/LAR, and cites one-half mile for a fire involving a tank. Yet the Planning packet contains no neighborhood emergency plan, no overlay showing how many residences fall within those distances, and no documented evacuation/shelter protocol for the surrounding neighborhood.

The emergency contact page is also incomplete: the product supplier, tank manufacturer service contact, local Fire Department, and local HAZMAT team are left blank. Those blanks are inconsistent with the document's representation that it provides complete first-responder coordination.

6. Conditions of Approval Omit Several Measures Claimed in the Safety Presentation
The safety presentation lists several measures as site-specific safeguards, but the draft Resolution does not clearly make all of them enforceable conditions. Examples include:
secondary containment berm/dike sized to 110% of the largest vessel; minimum two-person rule for filling and transfer;
pre-operation checklist for every delivery/fill;
emergency shutoff accessible from outside the exclusion zone; fixed atmospheric monitoring in enclosed or semi-enclosed areas and portable monitoring where gas may accumulate;
¢ annual emergency-response training and annual cryogenic-release drill; ¢ daily visual inspections and maintenance/recordkeeping requirements; ¢ annual review/update of the safety packet upon changes in storage area, product or quantity.

If staff relies on these measures to support the safety finding, they should be incorporated expressly into enforceable conditions or into an approved safety plan incorporated by reference.

7. Fire Department / HAZMAT / CUPA Review Should Be Documented, Not Merely Described
The Administrative Report says staff consulted the Redondo Beach Fire Department and that Fire's assessment is consistent with staff's safety conclusion. The packet does not include a written Fire Department plan-review memorandum, code analysis, approval, conditions, or sign-off. For a large cryogenic installation adjacent to residences, the record should contain the actual written technical review.

Los Angeles County Fire Department is the Certified Unified Program Agency (CUPA) for most incorporated areas of Los Angeles County, with Redondo Beach identified as a participating agency in County materials. County guidance requires hazardous-material handlers above reporting thresholds to submit hazardous-material inventory, a site map, emergency response/contingency 782
information, and training information through CERS. The City should identify on the record which agency is administering each applicable hazardous-material program for this site and document required permits/submittals before operation.

8. CEQA Documentation Contains a Material Template/Error Issue and an Incomplete Project Description
Attachment 5 states that the project is exempt under CEQA Guidelines section 15301 because it is a “negligible expansion of the existing residence.” This is an industrial aerospace manufacturing facility, not a residence. That language appears to be an uncorrected template error in the operative exemption document.

More importantly, the Exemption Declaration describes only three tanks while the proposed entitlement contemplates a fourth. It also does not discuss the unusual site circumstance that single-family residences are immediately across Manhattan Beach Boulevard, even though the applicant's emergency materials identify substantial isolation distances for large releases and tank fires. The City Attorney should review whether the exemption record adequately defines the whole project and addresses applicable exceptions to categorical exemptions before the exemption is adopted.

9. Variance Findings Need Better Evidentiary Support
The draft findings state that the tank height/location cannot be materially reduced or relocated, that no feasible location exists, that nearby facilities have comparable taller tanks, and that a lower tank configuration would cause significantly more frequent deliveries. The packet does not provide the engineering alternatives analysis, tank-sizing calculation, delivery-frequency comparison, or mapped comparison facilities needed to evaluate those assertions.

The draft Resolution also states that strict adherence to the 30-foot height limit would “eliminate the ability of the property owner to use the property for the existing manufacturing facility.” That is substantially broader than the evidence shown in the packet. At most, the materials indicate that the proposed bulk-storage configuration supports operations; they do not demonstrate that the entire 250,600-square-foot manufacturing facility cannot be used without these particular 38-foot tanks.

10. Noise and Operational Impacts Are Deferred
Staff concludes that noise is not expected to impact adjacent properties, but the Resolution requires the applicant to provide a tank-operation noise report later and allows additional mitigation after measured violations. Given the acknowledged residential frontage, the better sequence is to establish baseline and predicted noise from filling, transfer equipment, venting/PRV events, truck idling and nighttime/off-hour scenarios before operation. The condition allowing “very limited” offhour deliveries as a minor change should also define objective limits and require Fire/Planning review.

11. Public Comment Identifies Broader Operational Context That Is Not Fully Resolved
The public correspondence raises construction-hour violations, employee parking spillover, substantial facility modifications, increased electricaV/mechanical equipment, testing activities, and uncertainty about materials stored on site. City correspondence directs several of these matters to Planning and acknowledges the need for better project contact information. The Administrative Report reduces the public correspondence to concerns about employee numbers and public safety.

The Commission should receive a clearer response matrix identifying which concerns are within this variance, which are governed by existing permits, and which require separate enforcement or entitlement review.
783

12. Recommended Agency Responsibilities
Agency / Office Recommended documented action
Planning Commission / Planning Division Require a corrected, internally consistent project description; neighborhood context map;
substantiation of variance findings; definitive
tank count/products; and conditions
incorporating relied-upon safety measures.

Redondo Beach Fire Department Issue written plan-review findings addressing adopted Fire Code/NFPA 55, quantities,
setbacks, separation, venting, vehicle
protection, access, monitoring, emergency
shutoffs, delivery operations and emergency
response.

Redondo Beach Police Department /
Emergency Management
Review traffic/access and neighborhood
evacuation or perimeter-control implications for
the applicant's 330-foot and one-half-mile
emergency planning distances; coordinate
public warning/traffic control roles.

City Attorney Review variance findings, CEQA project
description and exemption language, including
the “existing residence” error and the
contemplated fourth tank; confirm that deferred
safety measures are enforceable.

Building & Safety Verify structural foundation/anchorage, seismic design, electrical/mechanical work, barriers,
grading/drainage and consistency of final
construction drawings with approved plans.

Los Angeles County Fire Department HHMD /
CUPA and applicable Participating Agency
Confirm hazardous-material handler status,
CERS/HMBP inventory and site-map
requirements, emergency response/contingency
plan, applicable Unified Program permits,
inspections and any CalARP applicability.

PUNCH LIST — ITEMS TO REMEDY BEFORE APPROVAL / OPERATION The following is intended as a concise completion checklist for the Planning Commission and reviewing agencies. Items marked “before approval” affect the adequacy and consistency of the entitlement record; operational items should be completed and verified before any tank is filled.

Required correction Minimum remedy

1. Correct the project description Reconcile three versus four tanks in the Administrative Report, Resolution, CEQA
784
Exemption and drawings. Define whether the
fourth tank is part of the present project.

2. Definitively identify tank contents State the authorized product in each tank.

Resolve all references to LOX versus LIN/LAR.

Prohibit product substitution without prior
agency review.

3. Correct the project address Reissue the Matheson safety document for 2477 Manhattan Beach Boulevard or explain the
relationship of 2425 to the project parcel.

4. Provide a neighborhood-scale vicinity map Show street names, parcel boundaries, actual surrounding uses, R-1 residences, tank locations
and measured tank-to-home/property-line
distances.

5. Overlay emergency planning distances Map the applicant's 330-foot largerelease/vessel-damage isolation area and onehalf-mile tank-fire isolation area relative to residences, streets and neighboring facilities.

6. Provide complete vessel specifications For each tank: manufacturer/model, serial/National Board number, capacity,
maximum inventory, dimensions, operating
pressure, MAWP, design temperature and
product assignment.

7. Submit vessel certification records Provide ASME U-1 data reports, nameplate photographs, U-stamp/National Board
information, certificates of conformance and
applicable inspection records.

8. Submit a site-specific NFPA/Fire Code
compliance matrix
Identify the adopted code provisions, quantity
thresholds, required setbacks/separations, and
drawing references demonstrating compliance.

9. Provide complete engineered site drawings Show foundations/anchorage, seismic design, bollards, piping, fill points, vaporizers,
emergency shutoffs, PRVs/rupture discs, vent
discharge locations, walls, fencing, drainage and
containment.

10. Resolve secondary containment
discrepancy
The safety presentation promises 110%
containment; the Administrative
Report/Resolution largely reduce this to
grading/drainage. Show the actual design and
make it enforceable if relied upon.

11. Provide gas-dispersion / oxygen-deficiency
evaluation
Evaluate credible release scenarios using actual
inventories and site geometry, including low
areas, structures, wind and potential off-site
785
migration toward residences.

12. Address LOX separately if LOX is
contemplated
Provide oxidizer-specific code analysis,
separation from combustibles/flammables,
oxygen-enrichment monitoring/controls, fire
exposure analysis and emergency procedures.

13. Complete the emergency-response plan Include neighborhood interface, incident comman4d, isolation/evacuation/shelter criteria,
public notification, staging, responder access,
shutdown, re-entry and recovery.

14. Complete emergency contacts Fillin product supplier, tank manufacturer/service, local Fire Department and
local HAZMAT team contacts in the safety plan.

15. Obtain written RBFD technical review Place a signed/dated Fire Department review, conditions and approval in the public record
rather than relying solely on a staff statement
that Fire was consulted.

16. Confirm CUPA/CERS/HMBP requirements Identify the administering CUPA/participating agency and document required hazardousmaterial inventory, site map, emergency/contingency plan, training and
permits.

17. Verify emergency responder access Demonstrate apparatus access, hydrants/FDC, gate access, Knox/emergency access as
applicable, staging, and access during cryogenic
deliveries.

18. Provide delivery route and transfer plan Show truck route, turning, unloading position, transfer hose, duration, frequency, traffic
conflicts, emergency access and limits on offhour deliveries.

19. Substantiate weekly delivery claim Provide tank-sizing/consumption calculations and compare delivery frequency for the
proposed 38-foot tanks versus code-compliant
alternatives.

20. Provide alternatives analysis supporting
the variance
Document why shorter tanks, different
capacities, multiple smaller vessels, or alternate
on-site locations are infeasible or materially
inferior.

21. Correct and supplement the CEQA
Exemption Declaration
Remove the erroneous “existing residence”
language; reconcile tank count/products;
accurately describe the industrial project;
document City Attorney review of categoricalexemption applicability and exceptions. 786

22. Tighten the variance findings Remove or substantiate the assertion that the 30-foot limit would eliminate use of the entire
manufacturing facility. Cite evidence for claimed
physical hardship and comparable properties.

23. Make relied-upon safety measures Add conditions for two-person filling, pre-fill enforceable checklist, emergency shutoff, atmospheric
monitoring, training/drills,
inspections/maintenance and annual safetyplan updates if these measures support the safety finding.

24. Complete noise analysis before operation | Measure/model filling, transfer, venting/PRV and truck noise at the residential property line; define
objective mitigation and off-hour delivery limits.

25. Provide a public-comment response Address parking, construction hours, operational matrix testing, mechanical/electrical expansion,
hazardous materials, project contacts and
enforcement responsibility; distinguish issues
inside and outside this variance.

26. Require final interagency sign-off before No cryogenic product should be introduced until first fill Planning, Building & Safety, RBFD and the
applicable hazardous-materials/CUPA authority
confirm completion of their conditions.

Source Notes
e Administrative Report, PC26-1012 (Aug. 20, 2026): project description, zoning/residential adjacency, LIN/LAR and LOX references, safety/noise discussion, Fire Department consultation statement, variance findings, CEQA conclusion.
e Draft Resolution No. 2026-08-PCR-11: four-tank title, three-initial/fourth-future condition, construction and operational conditions, site-map/noise/delivery requirements. e Attachment 2 Site Plan: tank labels LN2, LN2, LAR, future LAR/LN2; internal layout; tank relocation revision dated Aug. 12, 2026.
e Matheson Bulk Cryogenic Storage Safety & Compliance Presentation (June 9, 2026): address 2425 Manhattan Beach; LIN/LAR title; LOX references; vessel documentation; hazards; 330-foot and one-half-mile emergency planning distances; site-specific safeguards; incomplete emergency contact fields.
e CEQA Exemption Declaration (Aug. 20, 2026): three-tank project description and statement that project is a negligible expansion of an “existing residence.” e Attachment 6 Public Comment: neighborhood concerns regarding operations, parking, construction activity, testing, materials and communication. e External jurisdictional check: Los Angeles County Fire Department CUPA/Hazardous Materials Program materials and California Cal/OSHA pressure-vessel materials were consulted only to identify potential reviewing agencies and program responsibilities; final applicability should be confirmed by the City/CUPA for the specific vessels and inventories. 787
PUBLIC COMMENT 04 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Roxanne Ferebee

ORIGINAL SENT
Sunday, August 16, 2026 at 4:57 PM

SUBJECT

IMPULSE SPACE ASKING FOR EXEMPTION ON SAFETY
STUDIES ETC.

The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
788
From: ‘Sean Scully To: Sean Scully Subject: FW: IMPULSE SPACE ASKING FOR EXEMPTION ON SAFETY STUDIES ETC. Date: Thursday, August 20, 2026 12:16:25 PM From: Roxanne ere <<
Sent: Sunday, 16 August 2026 16:57:34
To: Brad Waller <[email protected]>; Chadwick B. Castle <[email protected]>; Paige Kaluderovic ee Zein Obagi <[email protected]>; Scott Behrendt <Scott. Behrendt @redondo.or:

Subject: IMPULSE SPACE ASKING FOR EXEMPTION ON SAFETY STUDIES ETC.

You don't often get email from [i Lam why this is
important
Hello City Council,
This Notice of Public Hearing was posted on the fence of the business property last week.

Many, many many (one household received a notice) neighbors have stated this was not received by residents across the street of this business.

Residents have been concerned about the retrofitting and construction activity at the site for over 8 months and have received very little data from the city when residents asked about the operations, filed complaints of violations, and are concerned of the lack of transparency and notice.

The Planning Commission will be asked on this Thursday 8/20/2026 to grant a height variance request - and- states the business is exempt from a number of important environmental, safety, fire, and other requirements due to its zoning (light industrial) and is compared to the Northrop G Space campus.

NG is a purpose built - facility - built to specifically meet the required needs of its operations.

While this warehouse is in light industrial zoning - its use has NOT been for this type of manufacturing or operations.

There has been a multitude of odd businesses throughout the years at this location. Auto parts storage, delivery and pickup (DHL, Dol&co?) furniture storage, office space, TV productions(e-ball) and NG temporarily while doing major remodeling projects to their other sites in the area. They used it for office space, mail & delivery, Trash and garbage storage, and a small design/think tank center. 789
Impulse Space is in the process of a major remodeling and restructuring of the entire area to accommodate their needs and has not been required to follow the guidelines most applicants are asked to meet.

We understand Impulse Space will remain in our neighborhood, and we support this business into our community but they need to meet the most stringent of requirements based on the nature of operations and be held accountable to the safety of the area.

We feel the city is being too lenient and is placing this whole area in a disaster zone.

We are asking the Planning Commissioners for a continuance on this project (as they have just received the 52+page staff report to consider action on this Thursday 8/20/2026) and to direct staff and the applicant to address the safety concerns and make safeguards enforceable.

We feel more time is needed to address the many concerns residents have been inquiring about. (The staff report will recommend an approval) Yet the report has errors, inconsistent data, lack of precise data, mapping defects, public safety deficiencies and items that should be remedied before approval.

This is an exciting and welcoming time for Redondo to have Impulse Space come to our area - BUT - the City better make sure everything is done properly, safely and wisely and not hastily.

The residents of Redondo Beach are not wanting to be impacted by something that looks negligent at this time.

Roxanne
8/16/2026
790
PUBLIC COMMENT 05 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Alicia Evans

ORIGINAL SENT
Monday, August 17, 2026 at 6:44 PM

SUBJECT
Public Comment RB Planning Commission Mtg 8/20 -
DEFECT LIST Impulse Space - Case No. 2026-0595
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
791
Sean Scully
From: alicia evans [is
Sent: Monday, August 17, 2026 6:44 PM
To: CityClerk; Sean Scully; alicia evans
Subject: Public Comment RB Planning Commission Mtg 8/20- DEFECT LIST Impulse Space- Case No. 2026-0595
[Some people who received this message don't often get email from in Learn why this is important at https://aka.ms/LearnAboutSenderldentification ] CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello All,
| wanted to make sure that the residents of North Redondo are heard! Impulse Space has & continues to be a nuisance to the neighborhood residents and community of NRB.

However, it’s apparent the city desperately wants their business. It doesn’t care about the residents of North Redondo Beach at all. Impulse Space has clearly been a nuisance with the noise pollution of large semi trucks very early in the morning, dust and other particles polluting the air during construction and renovations, congestion of traffic, parking issues and employees parking in residential neighborhoods. The three 40 foot tanks of who knows what material is just the icing on the cake. It’s clear the city continues to sweep all of this under the rug and doesn’t even give notice to those neighborhoods involved.
limplore you to take the necessary steps & precautions regarding these tanks and not just push this through. See checklist on file below.
https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fdrive.google.com%2Ffile%2Fd%2F1RImyE9CE4 Wd FQO108R306BiVOkUVO9pg%2Fview&data=05%7C02%7CSean.Scully%40redondo.org%7C4b7022f139bf4893 fod608defc ca34c4%7C08ea6101a7cb4984aff676e3d00172d'%7C0%7C0%7C639226142769150954%7CUnknown%7CTWFpbGZsb3d 8eyJFbXBOeU1hcGkiOnRydWUsIIYiOilwLjAUMDAWMCISIIAiOUXaW4zMilsIkFOljoiTWFpbClslldUIjoyfQ%30%3D%7C80000 %7C%7C%7C&sdata=V%2FGWMi1LOFQw8P8m0%2B%2B3jmiBv4ckhSOxp1UfYVyRouPE%3D&reserved=0 Regards,
Alicia Evans
Sent from my iPhone
792
DEFECT LIST — ITEMS TO REMEDY BEFORE APPROVAL
The following is intended as a concise completion checklist for the Planning Commission and reviewing agencies. Items marked “before approval” affect the adequacy and consistency of the entitlement record; operational items should be completed and verified before any tank is filled.

Required correction Minimum remedy
T. Correct the project description Reconcile three versus four tanks in the Administrative Report, Resolution, CEQA Exemption and drawings, Define whether the fourth tank is part of the present project.

2. Definitively identify tank contents State the authorized product in each tank. Resolve all references to LOX versus LIN/LAR. Prohibit product substitution without prior agency review.

3. Correct the project address Reissue the Matheson safety document for 2477 Manhattan Beach Boulevard or explain the relationship of 2425 to the project parcel 4, Provide a neighborhood-scale vicinity map Show street names, parcel boundaries, actual surrounding uses, R- I residences, tank locations and measured tank-to-home/propertyline distances.

3. Overlay emergency planning distances Map the applicant's 330-foot large-release/vessel-damage isolation area and one-half-mile tank-fire isolation area relative to residences, streets and neighboring facilities.

6. Provide complete vessel specifications For cach tank: manufacturer/model, serial/National Board number, capacity, maximum inventory, dimensions, operating pressure, MAWP., design temperature and product assignment
7, Submit vessel certification records Provide ASME U-I data reports, nameplate photographs, U- stamp/National Board information, certificates of conformance and applicable inspection records.

8. Submit a site-specific NFPA/Fire Code compliance matrix Identify the adopted code provisions, quantity thresholds, required setbacks/separations, and drawing references demonstrating compliance

9. Provide complete engineered site drawings Show foundations/anchorage, seismic design, bollards, piping, fill points, vaporizers, emergency shutoffs, PRVs/rupture discs, vent discharge locations, walls, fencing, drainage and containment.

10. Resolve secondary containment discrepancy The safety presentation promises 110% containment; the Administrative Report/Resolution largely reduce this to grading/drainage. Show the actual design and make it enforceable if relied upon.

TI. Provide gas-dispersion / oxygen-deficiency evaluation Evaluate credible release scenarios using actual inventories and site geometry, including low areas, structures, wind and potential off-site migration toward residences.

12. Address LOX separately if LOX is contemplated Provide oxidizer-specific code analysis, separation from combustibles/flammables, oxygen-enrichment monitoring/controls, fire exposure analysis and emergency procedures.

13. Complete the emergency-response plan Include neighborhood interface, incident command, isolation/evacuation/shelter criteria, public notification, staging, responder access, shutdown, re-entry and recovery.

14. Complete emergency contacts Fill in product supplier, tank manufacturer/service, local Fire Department and local HAZMAT team contacts in the safety plan.

15. Obtain written RBFD technical review Place a signed/dated Fire Department review, conditions and approval in the public record rather than relying solely on a staff statement that Fire was consulted.

16. Confirm CUPA/CERS/HMBP requirements Tdentify the administering CUPA/participating agency and document required hazardous-material inventory, site map, emergency/contingency plan, training and permits.

17. Verity emergency responder access Demonstrate apparatus access, hydrants/FDC, gate access, Knox/emergency access as applicable, staging, and access during cryogenic deliveries.

18. Provide delivery route and transfer plan Show truck route, turing, unloading position, transfer hose, duration, frequency, traffic conflicts, emergency access and limits on off-hour deliveries. 793

19. Substantiate weekly delivery claim Provide tank-sizing/consumption calculations and compare delivery frequency for the proposed 38-foot tanks versus code- compliant alternatives.

20. Provide alternatives analysi upporting the variance Document why shorter tanks, different capacities, multiple smaller vessels, or alternate on-site locations are infeasible or mater inferior

21. Correct and supplement the CEQA Exemption Declaration Remove the erroneous “existing residence” language; reconcile tank count/products; accurately describe the industrial project:
document City Attorney review of categorical-exemption applicability and exceptions.

Tighten the variance findings Remove or substantiate the assertion that the 30-foot limit would eliminate use of the entire manufacturing facility. Cite evidence for claimed physical hardship and comparable properties. 23, Make relied-upon safety measures enforceable ‘Add conditions for two-person filling, pre-fill checklist, emergency shutoff, atmospheric monitoring, training/drills, inspections/maintenance and annual safety-plan updates if these measures support the safety finding. 24, Complete noise analysis before operation Measure/model filling, transfer, venting/PRV and truck noise at the residential property line; define objective mitigation and off- hour delivery limits.

25. Provide a public-comment response matrix ‘Address parking, construction hours, operational testing, mechanical/electrical expansion, hazardous materials, project contacts and enforcement responsibility; distinguish issues inside and outside this varianee.

26. Require final interagency sign-off before first fill No cryogenic product should be introduced until Planning, Building & Safety, RBFD and the applicable hazardousmaterials/CUPA authority confirm completion of their conditions. 794
PUBLIC COMMENT 06 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Gary Mlynek

ORIGINAL SENT
Tuesday, August 18, 2026 at 10:24 AM

SUBJECT
Re: Planning commission meeting 8-20-2026
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
795
From: ‘Sean Scully
To: “gary mlynek"
Cc: Marc Wiener; Daniel Besinaiz Subject: RE: Planning commission meeting 8-20 -2026 Date: Tuesday, August 18, 2026 11:40:00 AM Attachments: image001.ona
Hello Mr. Mlynek,
You are very welcome. | do understand your concerns. We worked very hard with our Fire Department and the applicant to ensure the project is safe.

These projects can seem like a “surprise” sometimes. The City’s Zoning Ordinance and State Laws are very specific concerning when a project is “noticed” to the public prior to a public hearing. The “public noticing” is one of the last steps before the actual public hearing. It’s set up this way because sometimes we’re not sure the project will advance until very late in the review process and we don’t want to send out public notices on a project that may change significantly or not happen at all.

In this case the Planning Commission is the approval authority for the Variance. The only way the City Council would rule on this project is if the decision of the Planning Commission is appealed.
| hope this answers all your questions. Thank you.

Sean Scully
Planning Manager
310.697.3194
[email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
a REDONDO
= BEACH
From: gory ck
Sent: Tuesday, August 18, 2026 10:24 AM
To: Sean Scully <[email protected]>
Cc: Mare Wiener <Marc.Wiener @redondo.org>; Daniel Besinaiz <[email protected]> Subject: Re: Planning commission meeting 8-20 -2026
796
Thank you for the response and the good info. Greatly appreciated.

I can not attend the meeting this week but do know a few people who say they will be there. Some of the folks here in Dow/Johnson area just feel
like it was sort of a quick & secretive decision. Doesnt it have to go to City Council before a final decision is reached ? Thanks again.

On Tuesday, August 18, 2026 at 09:08:12 AM PDT, Sean Scully <[email protected]> wrote:

Good morning Mr. Mlynek,
You absolutely have a say in the proposed tank installation. I'm providing a link below to the Planning Commission Agenda Packet which includes City staff's analysis (Community Development and Fire Department) of the proposed project (Height Variance) that includes a "safety analysis". These tanks are proposed to be filled with liquid Argon and Nitrogen. Both of these gasses are chemically non-flammable inert noble gases that will not ignite and cannot undergo a chemical combustion explosion. That said, we've extensively reviewed this project with our Fire Department and they will be available to answer questions concerning the safety of the proposed tanks and any potential hazards at the public hearing scheduled for Thursday night at 6:30 PM. I've also included a link to register and attend the meeting by Zoom.

If you wish to discuss the project further after reviewing the staff report or have any additional questions please call me at the number below.
https://redondo.legistar.com/LegislationDetail.aspx?ID=8 173340&GUID=0F5901BE-0C57-44FD-BC2AAZ540F5988C6 htt dondo.zoomgov.com/webinar/register/WN_GikHDB7kQBKhf_sQY4PWai Thank you.

Sean Scully
Planning Manager
310.697.3194
sean,[email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
-----Original Message-----
From: gary mlynek
Sent: Monday, August 17, 2026 10:07 PM
To: Sean Scully <[email protected]>
Subject: Planning commission meeting 8-20 -2026
[You don't often get email from’ Learn why this is important at https://aka.ms/LearnAboutSenderldentification ]
797
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Dont the citizens get a say in the 4 tanks that will be placed across the street from the Dow-Johnson triangle. ? | think we should.

The gasses & chemicals could be & probably are dangerous & deadly if they escape. Seems like this decission is putting us in this area in a very precarious situation.

W.Gary Mlynek Dow Ave R.B.

Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email. 798
PUBLIC COMMENT 07 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Nick Biro

ORIGINAL SENT
Tuesday, August 18, 2026 at 12:48 PM

SUBJECT
Re: PC Agenda Item 2026-0595
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
799
From: Nick Biro
To: Daniel Besinaiz
Cc: ‘Sean Scully; Marc Wiener; Rox Ferebee; Scott Behrendt; Lorena Soules Subject: Re: PC Agenda Item 2026-0595 Date: Tuesday, August 18, 2026 12:48:52 PM | You don't often get email from [NNN Learn why this is important Hi Daniel,
Thank you - my e-comment is below.

Please continue the hearing and direct staff to complete, publicly circulate, and obtain written agency approval of the missing project-specific safety and environmental record before taking final action. Require a written Community Development Director and City Attorney determination under RBMC §10-2.1020 identifying the proper entitlement path, including whether CUP review must supplement the height variance. This request does not ask the City to prejudge or deny the project; it asks for an informed decision and enforceable residential protections.

Material gaps:
e Three versus four tanks: the CEQA declaration and original notice describe three; the staff report and resolution approve four, with the fourth deferred to a later installation.
e Gas identity: the project description says nitrogen and argon, while the safety discussion also refers to liquid oxygen. Oxygen would present a materially different oxidizer hazard and code pathway.
e Wrong/template text: the safety presentation names 2425 Manhattan Beach Boulevard and labels itself a boilerplate to be verified before AHJ submission; the CEQA declaration says the project expands an “existing residence.” © Moving design: the site plan bears “Tank Relocation 8/12/26,” but the record does not explain the change, provide a full parcel plan, or show exact distances to residential property and dwellings.
© Deferred verification: the draft requires Fire notification, a noise report and possible mitigation after approval rather than written agency approval and predictive analysis before the land-use decision.
e Emergency planning distance: the applicant’s own safety presentation cites an initial 330-foot isolation/downwind planning distance for a large nitrogen or argon spill—approximately the reported separation to residences—yet no neighborhood protective-action analysis is provided.

No approval should rest on future studies or undefined phrases such as “normal business hours,” “very limited,” “may be required,” or “as required.” Each condition should identify the duty, responsible reviewer, deadline, objective standard, required evidence, inspection method, public record, correction period and consequence of noncompliance 800
On Tue, Aug 18, 2026 at 12:32 PM Daniel Besinaiz <[email protected]> wrote: Hi Nick, I'm sorry to hear you're having difficulty with the e-comment system. I've forwarded your contact information to the City Clerk's Office so they can look into the issue.

In the meantime, if you would like, you are more than welcome to submit your public comment directly to me by email. Comments submitted this way will also become part of the public record.

LT hope this helps. | will keep you updated on what the City Clerk's Office may suggest for your e-comment account. Please feel free to reach out if you have any other questions.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | daniel [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).

From:

Sent: Tuesday, August 18, 2026 11:26 AM
To: Daniel Besinaiz <[email protected]>
Ce: Sean Scully <[email protected]>; Mare Wiener <Mare. [email protected]>; Rox Ferebee Subject: PC Agenda Item 2026-0595
[You don't often get email a Learn why this is important at me — https://aka.ms/Lea: enderldentification | CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good morning Daniel,
I am trying to post an e-comment for the subject agenda item and I have not received the email authentication required to confirm my account in order to submit the comments.

Could you please let me know if there is an issue with the system or can you help me with creating an account?
Thanks,
801
Nick
Sent from my iPhone
Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email. icholas J. Biro
802
PUBLIC COMMENT 08 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Alicia Evans

ORIGINAL SENT
Tuesday, August 18, 2026 at 1:31 PM

SUBJECT
Issues leaving a comment for meeting on August 20th
regarding Impulse Space
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
803
fod Outlook
RE: Issues leaving a comment for meeting on August 20th regarding Impulse Space (North Redondo Beach Residents want to be HEARD)!!. Fwd: Your Granicus Support Case #08472010 Has Been Created
From Daniel Besinaiz <[email protected]>
Date Wed 8/19/2026 9:54 AM
To alicia evans i James Light
<[email protected]>; Planning Redondo <[email protected]>; Sean Scully <[email protected]>
Hi Alicia,
Thank you for your comments and interest in this project. Staff is working to address the issue is with the e-comment system. In the meantime, all public comment received via email is being entered into the public record and will be added to the agenda for the public to have access to.

Please let me know if you have any questions.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | daniel. besinaiz(@redondo.org
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
ar REDONDO
= BEACH
Sent:

From:

Tuesday,
alicia evans
August
ia
18, 2026 1:31 PM
To: Daniel Besinaiz <[email protected]>; alicia evans James Light <[email protected]>; Planning Redondo <[email protected]>; Sean Scully <[email protected]> Subject: Issues leaving a comment for meeting on August 20th regarding Impulse Space (North Redondo Beach Residents want to be HEARD)!!. Fwd: Your Granicus Support Case #08472010 Has Been Created Some people who received this message don't often get email from [III [cam why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello All,
| want to make sure that our voices are represented & some of the neighbors are having issues with the website. They can’t access it to leave a comment. Some will be unable to physically 804
attend the meeting and want to be able to have a say in North Redondo Beach.

I'm asking for a continuation as a Redondo Beach resident. | want a continuance from the Planning Commission. As more time is needed to read, understand these impacts and have safety measures, noise measures, traffic measures, parking measures, and evacuation concerns addressed by The City of Redondo Beach as well as Impulse Space.

The proposed installation is not adequately defined or reviewed in the public packet. | do not support this, because there are no current environmental reviews and safeguards in place.

Regards,
Alicia Evans
Sent from my iPhone
Begin forwarded message:

From: Granicus Customer Support
Date: August 18, 2026 at 12:16:51 PM PDT
To:

Subject: Your Granicus Support Case #08472010 Has Been Created Ld
Granicus Case Created
Hi,
Thank you for contacting Granicus Support. Your case has been created successfully.

Case Reference: #08472010
805
Please include this number in any communication about your case.

Our Technical Support Team will review your request and follow up with you shortly.

For the fastest assistance:

Log in to the Granicus Support Portal and use our Virtual Assistant feature.

Chat provides quicker response times than email and ensures your case gets immediate attention, especially when time is critical.

Access your case here: Link to Case (Portal login required) Case Details:

Case #: 08472010
Status: New
Created On: 18 August 2026
eoeee
Subject: Please assist as | can’t get email to activate account.

Need a Support Portal account?
You can register anytime by following these instructions.

If you run into any issues during registration, reply to this email and we'll assist you.

Thank you for working with Granicus Support.

Granicus Use Only:

Case Thread ID: ref:!00D46018MW9.!500Vq01Bz27t:ref
806
807
PUBLIC COMMENT 09 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Katherine

ORIGINAL SENT
Wednesday, August 19, 2026 at 10:23 AM

SUBJECT
Public Comment: OPPOSE/CONTINUE Item 2026-0595 -
Impulse Space Cryogenic Tanks
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
808
From: Katherine
To: Daniel Besinaiz
Cc: ‘Sean Scully; Marc Wiener; Ferebee; Rox Scott Behrendt; Lorena Soules Subject: Public Comment: OPPOSE/CONTINUE Item 2026-0595 - Impulse Space Cryogenic Tanks (Manhattan Beach Blvd) Date: Wednesday, August 19, 2026 10:23:45 AM You don't often get email ror III carn why this is important Dear Chair and Members of the Redondo Beach Planning Commission, My name is Katherine Strohlein, and I am a 31 year resident of Redondo Beach. I am speaking tonight regarding the proposal by Impulse Space to install three (or four) bulk cryogenic storage tanks at their Manhattan Beach Boulevard facility.

While we support technological innovation, our neighborhood is already bearing a massive industrial burden. Directly across the street, Northrop Grumman operates enormous industrial gas storage tanks that are regularly filled and vented.

Surrounding residents know firsthand how incredibly loud and disruptive that highpressure gas venting noise is. Furthermore, Northrop operates extremely bright industrial lighting that bleeds directly into our neighborhood, disrupting our sleep and our quality of life. And their facility is located further away from our homes than what is being proposed tonight.

What is deeply alarming is that Impulse Space is slating these new cryogenic tanks to be 38 feet high and positioned even closer to local homes—literally a matter of mere yards away from families’ backyards. Tanks of this height and volume pose unique structural and chemical hazards. We cannot look at this application in a vacuum. The City must evaluate the cumulative impact of adding three more highcapacity infrastructure units directly adjacent to a residential zone.

The operational safety of this facility is paramount to our neighborhood. Therefore, I request that the Planning Commission continue this item tonight and direct city staff and the applicant to return only after they have fully addressed three critical concems with legally binding Conditions of Approval that can be strictly enforced by the city:

First, regarding Physical Safety and Hazard Zones:

A 38-foot vertical tank acts as a top-heavy lever in a seismic zone, and an insulation failure can trigger a catastrophic pressure explosion or unleash heavy asphyxiation clouds mere yards from our families’ yards. As an enforceable condition of approval, will the city mandate a formal Quantitative Risk Assessment to map the blast and oxygen-displacement radiuses, and require an independent Seismic 809
Bracing Audit to guarantee that a 38-foot structural failure cannot breach the residential property line?
Second, regarding Bulk Truck Deliveries and Operations: Filling these tanks requires massive, multi-axle industrial semi-trucks that bring heavy diesel idling, backup beeps, and low-frequency rumbling. Furthermore, the transfer of cryogenic liquids involves high-pressure open-valve venting that generates a sustained, loud roaring and hissing noise. Because industrial gas suppliers often run 24/7 to avoid highway traffic, our neighborhood faces the reality of sleep-disrupting deliveries at 3 AM. We request a strict, enforceable condition of approval banning all cryogenic truck deliveries, transfers, and related operations between the hours of 6 PM and 7 AM.

Third, regarding Cumulative Noise and Environmental Proximity:

Given that residents are already subjected to the disruptive venting from Northrop Grumman, what will the combined acoustic impact be once Impulse adds three more towering tanks? We request an enforceable condition requiring continuous, real-time noise monitoring with automatic fines if they violate the Redondo Beach Noise Ordinance during overnight hours.

Fourth, regarding Light Trespass and Security Illumination:

Because our neighborhood is already blinded by Northrop’s bright lights, we request an explicit condition of approval mandating zero light trespass at the residential property line, requiring fully shielded downward, north-facing fixtures, and prohibiting any direct glare from shining over into our neighborhood.

Commissioners, please do not approve this blanket permit tonight. Please continue this meeting and require staff to draft airtight, enforceable conditions of approval that protect our community's safety, peace, and health.

Thank you for your time, leadership, and dedicated service to Redondo Beach.

Sincerely,
Katherine Strohlein
810
PUBLIC COMMENT 10 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Alexander Hawkins

ORIGINAL SENT
Thursday, August 20, 2026 at 11:29 AM

SUBJECT
Cryogenic Storage Tank approval
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
811
From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Cryogenic Storage Tank approval Date: Thursday, August 20, 2026 11:47:17 AM Attachments: image001.pnq Hi Jamaal,
See below public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected] daniel
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
a REDONDO
== BEACH
From: Alexander Hawkins (i
Sent: Thursday, August 20, 2026 11:29 AM
To: Daniel Besinaiz <[email protected]>
Subject: Cryogenic Storage Tank approval
You don't often get email from II Lear why this is importa attachments or links.

Dear Planning Commission,
lam a Redondo Beach resident in District 5, writing regarding Agenda Item J.1 and the proposed cryogenic storage tanks at 2477 Manhattan Beach Boulevard. | request that the Planning Commission continue this item rather than take final action today, August 20. This will allow residents and the Commission sufficient time to fully understand the proposal and address several inconsistencies and unanswered questions in the current materials.
812
While the staff report and attachments contain extensive technical information, they were released shortly before the hearing. They also appear to contain errors and leave important project-specific questions unresolved.

Before final approval, | ask the Commission to direct staff to:
- Correct and clarify the approval documents and inconsistencies in the record. - Complete and publicly provide the project-specific safety and environmental information needed to understand the impacts of this installation. - Obtain the appropriate written agency and Fire Department review of the final proposal.
- Clearly identify the substances and quantities that will be stored, ensuring the approval is limited to what is actually being considered. - Make the safety measures and operating safeguards relied upon in approving the project enforceable conditions, rather than simply statements in supporting materials. - Address impacts on the immediately adjacent residential neighborhood, including safety, emergency response, noise, deliveries, traffic, and parking.

Installing large bulk cryogenic storage tanks next to a residential neighborhood warrants aclear, complete, and internally consistent public record before the City grants the requested variance. A continuance will allow all parties to resolve outstanding questions and make an informed decision with appropriate protections in place.

Thank you for your consideration and for allowing residents to participate in this process. Please confirm receipt of this comment.

Regards,
Alexander Hawkins
Alexander Hawkins
813
PUBLIC COMMENT 11 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Janet

ORIGINAL SENT
Thursday, August 20, 2026 at 12:58 PM

SUBJECT
Public Comment - Impulse Facility
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
814
From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Public Comment - Impulse Facility Date: Thursday, August 20, 2026 1:31:57 PM Attachments: image001.pnq
Hi Jamaal,
See below for public comment. I’m about to send you two more after this.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
ar REDONDO
== BEACH
From: Janet cy
Sent: Thursday, August 20, 2026 12:58 PM
To: Daniel Besinaiz <[email protected]>
Subject: Public Comment - Impulse Facility
You don't often get email from III [carn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good Afternoon,
My name is Janet Scully, and I have been a North Redondo Beach resident in District 5 for more than 30 years.

I am asking the Planning Commission to continue this hearing to allow additional time for the Commission, staff, and the community to fully review and understand the staff report and the proposed project. 815
Given that this facility is proposed within 500 feet of an established residential neighborhood, I believe the project warrants careful and thorough review. There appear to be issues and inconsistencies in the current report, as well as questions about whether all appropriate environmental studies and safety considerations have been adequately addressed. These issues should be resolved before any approval is granted.

I am also asking that City staff engage directly with the local community so residents have a clear understanding of what is being proposed and how the facility will operate so close to their homes. Residents deserve to understand the potential risks, applicable safety requirements, environmental reviews, monitoring, and regulations that will govern this facility.

A continuance would provide the necessary time for a more complete review and meaningful community understanding of the proposal.

Thank you for considering this request.

Janet Scully
as
816
PUBLIC COMMENT 12 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Tala Schwindt

ORIGINAL SENT
Thursday, August 20, 2026 at 1:17 PM

SUBJECT
Public comment for today's agenda
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
817
From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Public comment for today’s agenda Date: Thursday, August 20, 2026 1:32:02 PM Attachments: imaqe001.pnq Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
a REDONDO
== BEACH
From: Tala Schwindt
Sent: Thursday, August 20, 2026 1:17 PM
To: Daniel Besinaiz <[email protected]>
Subject: Public comment for today’s agenda
You don't often get email from II Lear why this is important To whomever it may concern,
My name is Tala Schwindt and | live in North Redondo Beach in district 5. | would like to ask the planning commission to please ask for a continuance of the meeting regarding the approval of Impulse’s request to add the cryogenic storage tanks. We believe there are inconsistencies in the existing report and not adequate environmental reviews considering the impact it will have on our community. There are a few measurable enforcements that |’d like to see in place before we blanket approve the report as is. It is across the street from so many young families and we must ensure their safety. Thank 818
you for your consideration!
Tala
Sent from Gmail Mobile
819
PUBLIC COMMENT 13 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Janine Villa Sison

ORIGINAL SENT
Thursday, August 20, 2026 at 1:25 PM

SUBJECT
Comments for Public Hearing

SUPPORTING MATERIALS INCLUDED
- FILE PC26-1012 - Written Public Comment
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
820
From: Daniel Besinaiz To: Jamaal Brown Subject: FW: Comments for Public Hearing Date: Thursday, August 20, 2026 1:32:17 PM Attachments: FILE PC26-1012.pdf
image001.pnq
Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
ar REDONDO
== BEACH
From: Janine Villa Sison [is
Sent: Thursday, August 20, 2026 1:25 PM
To: Daniel Besinaiz <[email protected]>
Subject: Comments for Public Hearing
You don't often get email from [MM Learn why this is important Hi Daniel,
We were instructed to send comments your way regarding PC26-1012, since the E comments are not working properly. I've attached my comments for tonight's meeting.

Our neighbors also have a list of questions that we feel are unanswered by the packet released. | want to submit these, in addition to the comment, in case they can either be answered tonight, or by the commission in the coming weeks. 821
-Can we have tank contents clarified? Administrative report mentions Oxygen, but the Impulse safety report and site map only show Argon and Nitrogen. -Can the contents change in the future? If so, is Impulse required to notify anyone, and whom?
-Will/can any CEQA exemptions and variances granted tonight be used as precedent for future decisions regarding Impulse or other companies zoned IC? -Has SCE been notified or surveyed the site? Are they required to be? They have large equipment operating less than 150 ft from the proposed tank installation. -Safety level of this project is mentioned in several places as "subject to compliance".

Who is monitoring this compliance?
-When does Impulse expect vibration testing, that is being supported by these tanks, to begin?
-Who do we reach out to for tank certification information mentioned in the safety presentation?
-Where is the secondary containment site being located? -Why does the site plan say "Tank Relocation". Are there already tanks onsite? -How will the community be alerted in the event of an emergency? -No mention of plans or safety regarding seismic events were included in the presentation. Do we have that information?
-How are lost parking spaces being replaced during construction and long term? Thank you.

Best,
Janine
Janine M Villa Sison
Cl ae
822
FILE PC26-1012
Aug, 20th 2026
We are requesting a stay of approval re: height variance and environmental exemption for 30 days to allow the Planning Commission time to consider greater community input, clarify all and any questions, and reevaluate potential impact of this project on the neighborhood. We are also requesting facilitation for a community meeting between Impulse and the community at large to allow for a Q&A session. We acknowledge the commission’s resolutions in Section 2, but ask for quantified/qualified limits to be included for clearer enforcement (ie. normal business hours, acceptable decibel of noise, etc.) We would like to see application and clerical errors corrected before any approvals or exemptions are made, as would be expected of any other application (Safety presentation has a different location listed, public hearing notice listed 3 tanks and proposal is actually 4, Site plan is missing many of the required measurements and annotations, included required safety grading, measurements to street and residential neighborhoods, location of required impact barriers, location of secondary containment site, etc)

CEQA EXEMPTION
Our view on the ruling is that the logic is loose and largely interpretive. Literal interpretation of the text, “The key consideration is whether the project involves negligible or no expansion of use”, bears consideration, as it was used as recently as June 2026 by the CA Supreme Court in the case of Sunflower Alliance v. Department of Conservation (2024) to overturn CEQA exemptions granted. The planning commission reasons that Impulse cannot continue use of their facilities without allowing a variance for the 38 foot tanks. How were they in business for 2+ years at the same location without these tanks? One could reason it is because the tanks are a new requirement for operation, and therefore an expansion of use (addition of vibration testing). Site plans show 25ft subterranean ancillary equipment for the tanks, and a secondary containment site for 110% of stored materials is also required. Plus the addition of potential sound wall construction and the tanks themselves. One could reason this is not “negligible”.

HEIGHT VARIANCE
We understand the case made for this project to be granted the same privilege as Northrop Grumman, and many of the Planning Commission points are valid. If these comparisons continue to be made as grounds for approvals, we ask to city to hold Impulse accountable to the same standards as Northrop, including issues regarding CEQA exemptions and adherence to zoning characteristics listed in 10-2,100 of city code, including: (f) Minimize the impact of industrial and commercial uses on adjacent residential zones; (g) Ensure the provision of adequate off-street parking and loading facilities.

Regardless of your decision, it needs to be stated that it shouldn’t matter that I-1 businesses nearby are less strict in zoning. Residents purchased properties knowing they are adjacent to an I-C zone, not an Industrial Zone. The burden should not be on the community to accommodate an Industrial business that CHOSE to move into a zone that cannot accommodate or sustain their business activities, regardless of what “type” of business they are. Similar zoning, is not the same zoning. 823
We urge you to consider the balance of the needs of the community with the needs of Impulse in a more thoughtful way. We know they’ve already paid the city more than a quarter million dollars in permitting fees since 2025, but that does not absolve them from proper proceedings.

Janine and Michael Villa Sison
North Redondo Beach residents
824
PUBLIC COMMENT 14 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Hilary Nash

ORIGINAL SENT
Thursday, August 20, 2026 at 1:50 PM

SUBJECT
Continuance requested for cryo storage tanks for
Impulse
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
825
From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Continuance requested for cryo storage tanks for Impact Date: ‘Thursday, August 20, 2026 1:58:25 PM Attachments: image001.pnq Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | daniel [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
a REDONDO
== BEACH
From: Hilary N2sh
Sent: Thursday, August 20, 2026 1:50 PM
To: Daniel Besinaiz <[email protected]>
Subject: Continuance requested for cryo storage tanks for Impact You don't often get email from [iE Learn why this is important Hello,
| live at [IY Redondo Beach CA 90278 and I’m requesting a continuance for the cryogenic storage tanks at IMPACT on Mb Blvd and Dow Ave.

We as residents need more time to learn about these tanks and see if there are risks to our health and safety.

Thank you,
826
a
Hilary Nash
827
PUBLIC COMMENT 15 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Cherise

ORIGINAL SENT
Thursday, August 20, 2026 at 2:15 PM

SUBJECT
Request for Continuance and Public Safety and
Environmental Records
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
828
From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Request for Continuance and Public Safety and Environmental Records Date: Thursday, August 20, 2026 3:13:31 PM Attachments: imaqe001.pnq Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
@%& REDONDO => BEACH
Sent:

From:

Thursday, August
Cherise 10 i
20, 2026 2:15 PM
To: Daniel Besinaiz <[email protected]>
Subject: Request for Continuance and Public Safety and Environmental Records You don't often get email from [BE Learn why this is important Dear Planning Commission,
lam writing regarding the requested variance for the installation and use of approximately 40-foot cryogenic storage tanks containing liquid oxygen, liquid nitrogen, and argon.

Given the nature, size, and proposed contents of these tanks, | respectfully request that consideration of this variance be continued to a later hearing date so that the public has a meaningful opportunity to review the safety and environmental information associated 829
with the proposal before any decision is made.

Before the variance is considered for approval, | request that all relevant safety and environmental records be made publicly available and circulated sufficiently in advance of the continued hearing, including, as applicable:

1. Site plans and specifications identifying the size, capacity, location, setbacks, and intended use of each cryogenic tank;

2. Hazardous-materials and hazardous-substance documentation;

3. Fire and life-safety evaluations;

4. Emergency response, spill, leak, venting, and evacuation plans;

5. Applicable environmental studies, reviews, determinations, and supporting documents;

6. Risk analyses addressing potential releases, oxygen-enriched or oxygen-deficient atmospheres, fire hazards, pressure-related incidents, and impacts to neighboring properties;

7. Applicable building, fire, mechanical, hazardous-materials, and cryogenic-storage code evaluations;

8. Correspondence, comments, conditions, approvals, or determinations from the Fire Department and any other agency having jurisdiction over these installations; and

9. Any permits or agency approvals that would be required for the proposed tanks and their operation.
| further request that the variance not be approved until the Fire Department and all other relevant safety, environmental, and regulatory agencies have reviewed the proposal and provided whatever approvals, clearances, conditions, or determinations are required within their respective jurisdictions.

The public should not be asked to comment on, nor should the decision-making body be asked to approve, a variance involving large-scale storage of cryogenic oxygen, nitrogen, and argon without first having access to the information necessary to evaluate the 830
associated risks and regulatory requirements.

Acontinuance would allow adequate time for agency review, public disclosure of the relevant records, and informed public participation. Please include this correspondence in the administrative record for the project and provide notice of any continued hearing date.

Thank you for your consideration.

Sincerely,
Cherise Ho
831
PUBLIC COMMENT 16 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
G. P. Suddeth

ORIGINAL SENT
Thursday, August 20, 2026 at 3:12 PM

SUBJECT
Planning commission hearing regarding IMPULSE
height variance request
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
832
From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Planning commission hearing regarding IMPULSE height variance request Date: Thursday, August 20, 2026 3:14:40 PM Attachments: imaqe001.pnq Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
@%& REDONDO => BEACH
Sent:

From:

Thursday, August
G P Suddeth i
20, 2026 3:12 PM
To: Daniel Besinaiz <[email protected]>; [email protected] Subject: Planning commission hearing regarding IMPULSE height variance request You don't often get email from [III Learn why this is important To the Commission:

Please continue the meeting/discussion of this request to allow citizens to become better aware of what is being proposed at this site.

My neighbors and | are concerned because of a woeful lack of outreach from IMPULSE to residents whose homes are just feet away from where this installation is proposed to occur. The only notice my neighbors on Sebald and other nearby streets got about this height variance request was via a photo of an 8 x 11 note posted on the fence surrounding the Impulse property that one of my neighbors shared on the Dow-Johnston 833
Triangle Neighborhood Watch website.

This is not "good neighbor" behavior on the part of Impulse, and it would be a mistake for the Planning Commission to reward this misbehavior by rubber stamping Impulse's plan.

The residents of this area need time and information to better understand exactly what is being proposed, and what would be this project's potential impacts on the neighborhood.

Voting approval for Impulse's proposal at this time would be premature.

Thank You --
G P Suddeth
ME Redondo Beach, CA 90278
834
CITY OF REDONDO BEACH SEPTEMBER 17 PLANNING COMMISSION
Planning Commission Public
Comments
Meeting Date: September 17, 2026
Agenda Item K.1 - Case No. 2026-0595

PUBLIC COMMENT COMPILATION
18 distinct email submissions
Original public-sender dates: August 21 - September 17, 2026 Emails are arranged by the original public sender's date and time. Non-government email addresses and personal phone numbers are permanently redacted. 2477 Manhattan Beach Boulevard Case No. 2026-0595
835
PUBLIC COMMENT 01 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Friday, August 21, 2026 at 1:55 PM

SUBJECT
2477 Manhattan Beach Blvd. - Request for HHMD
Review of Cryogenic Tank Emergency Planning
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
836
You don't often get email from [email protected]. Learn why this is important From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:35:41 PM
Attachments: image001.png
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Raquel Doom <[email protected]>
Sent: Thursday, August 27, 2026 5:31 PM
To:

Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Mark N Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]>
Subject: RE: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use.

Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA).
837
Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation. Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail [email protected] Website: www.fire.lacounty.gov/health-hazardous-materials-division From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 PM
To: Fire-Hhmdcers <[email protected]>; FIRE-AskHHMD <[email protected]>
Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; [email protected] <[email protected]>; 838
CAUTION: External Email. Proceed Responsibly.

Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
County of Los Angeles Fire Department
Health Hazardous Materials Division
cc: Redondo Beach Councilmember Behrendt, Mr. Witzansky, Ms. Ford, Mr. Wiener, and Members of the Planning Commission:

I am transmitting the attached memorandum on behalf of myself and interested residents in the neighborhood surrounding 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278, regarding the proposed bulk liquid-nitrogen and liquid-argon storage tanks.

The August 20 Planning Commission hearing was useful in identifying both the issues of concern to nearby residents and several questions of interest to the Commissioners. Among the subjects discussed were tank capacity, separation from the residential neighborhood, oxygen displacement, emergency isolation and evacuation distances, and the consequences of a major vessel failure. The proposed tanks are approximately 222 feet from the nearest residential property.

The hearing also helped clarify the respective regulatory roles. Redondo Beach Fire Department indicated that it does not maintain its own hazardous-materials team and that Los Angeles County Fire performs the hazardous-materials/CUPA inspection function for facilities of this type.

I do not interpret the questions raised at the hearing as establishing that the proposed tanks are unsafe. Rather, my takeaway was that some of the specific technical questions being asked by Commissioners and residents could not be answered in detail at the hearing and appear more appropriately directed to HHMD/CUPA.

That is the purpose of the attached memorandum.

In particular, I believe a useful and reasonably bounded question is the consequence of catastrophic failure of one full liquid-argon vessel. Argon is nonflammable and chemically inert, but a sufficiently large release can create an oxygen-deficient atmosphere.

Because argon is denser than air—and a cryogenic release initially produces a very cold, [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
839
dense gas—the proximity of the R-1 neighborhood immediately south of Manhattan Beach Boulevard makes the off-site consequence question worth resolving quantitatively.

The attached memorandum therefore does not assume simultaneous failure of all four vessels and does not attempt to establish an evacuation zone. It asks whether the appropriate reviewing agency has evaluated, or will evaluate, a credible single-vessel catastrophic release using the actual tank inventory and site conditions, and determine the resulting oxygendeficiency/protective-action distances.

One difficulty apparent from the hearing is that responsibility for this installation is distributed among several regulatory functions. Planning is addressing the height variance; Building and RBFD have their respective responsibilities; and hazardous-materials review appears to reside principally with LA County Fire/HHMD-CUPA. That division of responsibility may be entirely appropriate, but from the standpoint of the surrounding residents it makes it difficult to determine which agency evaluates the off-site consequences of a catastrophic cryogenic release and how that analysis becomes part of the overall safety review.

Accordingly, I would appreciate HHMD's assistance in answering the questions in the attached memorandum, particularly:

For catastrophic loss of one full maximum-capacity liquid-argon vessel at 2477 Manhattan Beach Boulevard, what analysis establishes the distance and direction at which oxygen concentrations remain above applicable oxygendeficiency/protective-action criteria under reasonably conservative meteorological and site conditions, including at the R-1 residences south of Manhattan Beach Boulevard?
I am copying the City and Planning Commission because these questions arose directly from the public hearing and the answers should be useful to Commissioners, City staff, the applicant, and the surrounding residents. The hearing itself reflected substantial interest in obtaining additional information concerning these issues; one Commissioner specifically raised the possibility of continuing the matter to allow additional information and public outreach.

Thank you for your assistance. Our objective is straightforward: to identify the agency with the relevant technical responsibility, obtain the appropriate analysis, and give the surrounding residents and City decision-makers a clear factual basis for understanding the off-site emergency implications of the proposed installation.

Regards,
Mark Nelson
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
840
PUBLIC COMMENT 02 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Wednesday, August 26, 2026 at 8:15 PM

SUBJECT
Fwd: 2477 Manhattan Beach Blvd. - Request for HHMD
Review of Cryogenic Tank Emergency Planning

SUPPORTING MATERIALS INCLUDED
- 2477 HHMD Single-Tank Catastrophic Release Memorandum The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
841
From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:36:26 PM
Attachments: 2477_HHMD_Single_Tank_Catastrophic_Release_Memo.docx Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Wednesday, August 26, 2026 8:15 PM
To: [email protected]; [email protected]; Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Mark N
Subject: Fwd: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Reminder: Potentially hazardous physical situation that does not have any reported HAZMAT/HHMD Review. Basic mass transfer equations have a significant rupture of a 12,000 gallon tank of LAR rolling into the neighborhood. Residents deserve to know the plan and the City of RB/RBFD is pointing squarely at LA County Fire. Please advise. We are sending a certified communication since time is wasting before the next Redondo Beach permitting meeting.
---------- Forwarded message ---------
From: Mark Nelson (Home Gmail)
Date: Fri, Aug 21, 2026 at 1:55 PM
Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
842
To: <[email protected]>, <[email protected]> Cc: Scott Behrendt <[email protected]>, Mike Witzansky <[email protected]>, Andrew Winje <[email protected]>, Joy Ford <[email protected]>, Marc Wiener <[email protected]>, Sean Scully <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>,
<[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, Mark N Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
County of Los Angeles Fire Department
Health Hazardous Materials Division
cc: Redondo Beach Councilmember Behrendt, Mr. Witzansky, Ms. Ford, Mr. Wiener, and Members of the Planning Commission:

I am transmitting the attached memorandum on behalf of myself and interested residents in the neighborhood surrounding 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278, regarding the proposed bulk liquid-nitrogen and liquid-argon storage tanks.

The August 20 Planning Commission hearing was useful in identifying both the issues of concern to nearby residents and several questions of interest to the Commissioners. Among the subjects discussed were tank capacity, separation from the residential neighborhood, oxygen displacement, emergency isolation and evacuation distances, and the consequences of a major vessel failure. The proposed tanks are approximately 222 feet from the nearest residential property.

The hearing also helped clarify the respective regulatory roles. Redondo Beach Fire Department indicated that it does not maintain its own hazardous-materials team and that Los Angeles County Fire performs the hazardous-materials/CUPA inspection function for facilities of this type.

I do not interpret the questions raised at the hearing as establishing that the proposed tanks are unsafe. Rather, my takeaway was that some of the specific technical questions being asked by Commissioners and residents could not be answered in detail at the hearing and appear more appropriately directed to HHMD/CUPA.

That is the purpose of the attached memorandum.

In particular, I believe a useful and reasonably bounded question is the consequence of catastrophic failure of one full liquid-argon vessel. Argon is nonflammable and chemically inert, but a sufficiently large release can create an oxygen-deficient atmosphere. 843
Because argon is denser than air—and a cryogenic release initially produces a very cold, dense gas—the proximity of the R-1 neighborhood immediately south of Manhattan Beach Boulevard makes the off-site consequence question worth resolving quantitatively.

The attached memorandum therefore does not assume simultaneous failure of all four vessels and does not attempt to establish an evacuation zone. It asks whether the appropriate reviewing agency has evaluated, or will evaluate, a credible single-vessel catastrophic release using the actual tank inventory and site conditions, and determine the resulting oxygendeficiency/protective-action distances.

One difficulty apparent from the hearing is that responsibility for this installation is distributed among several regulatory functions. Planning is addressing the height variance; Building and RBFD have their respective responsibilities; and hazardous-materials review appears to reside principally with LA County Fire/HHMD-CUPA. That division of responsibility may be entirely appropriate, but from the standpoint of the surrounding residents it makes it difficult to determine which agency evaluates the off-site consequences of a catastrophic cryogenic release and how that analysis becomes part of the overall safety review.

Accordingly, I would appreciate HHMD's assistance in answering the questions in the attached memorandum, particularly:

For catastrophic loss of one full maximum-capacity liquid-argon vessel at 2477 Manhattan Beach Boulevard, what analysis establishes the distance and direction at which oxygen concentrations remain above applicable oxygendeficiency/protective-action criteria under reasonably conservative meteorological and site conditions, including at the R-1 residences south of Manhattan Beach Boulevard?
I am copying the City and Planning Commission because these questions arose directly from the public hearing and the answers should be useful to Commissioners, City staff, the applicant, and the surrounding residents. The hearing itself reflected substantial interest in obtaining additional information concerning these issues; one Commissioner specifically raised the possibility of continuing the matter to allow additional information and public outreach.

Thank you for your assistance. Our objective is straightforward: to identify the agency with the relevant technical responsibility, obtain the appropriate analysis, and give the surrounding residents and City decision-makers a clear factual basis for understanding the off-site emergency implications of the proposed installation.

Regards,
Mark Nelson
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
844
2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 — Case No. 2026-0595 — Single-Tank Catastrophic Release / HHMD Review Request

MEMORANDUM
TO: County of Los Angeles Fire Department
Health Hazardous Materials Division
5825 Rickenbacker Rd
Commerce, CA 90040
CONTACT: General: (323) 890-4045 | Data Ops/CERS: (323) 890-4000 | Fax: (323) 890-4046 [email protected] | [email protected] SUBJECT: 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 — Case No. 2026-0595 — Request for Review of Off-Site Oxygen-Deficiency Consequences from a Single-Tank Catastrophic Cryogenic Release DATE: August 21, 2026
Purpose. This memorandum requests HHMD/CUPA review of the emergency-planning implications of the proposed bulk cryogenic storage installation at 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 (City of Redondo Beach Case No. 2026-0595). The principal concern is not routine filling or normal operation, but the low-probability, high-consequence catastrophic loss of containment from a single full cryogenic vessel—especially liquid argon (LAR)— and the potential for an oxygen-deficient atmosphere to extend off site toward the R-1 residential neighborhood immediately south of Manhattan Beach Boulevard.

1. Project and Tank-Size Bounding Assumptions
The City project record describes four bulk cryogenic tanks approximately 38 feet high for liquid nitrogen (LIN) and liquid argon (LAR). To establish reasonable source-term bounds before the actual vessel specifications are available, this memorandum uses Linde's published standard cryogenic tank data. Linde's Size 300 and Size 490 air-gas tanks are both 11.55 m high (37.9 ft), closely approximating the proposed 38-ft height.

The Linde catalog lists Size 300 at 30,205 L gross / 28,700 L net and Size 490 at 49,020 L gross / 46,570 L net. At the catalog's 18-bar, 95% filling condition, the Size 300 holds 23,190 kg LIN, while the Size 490 holds 64,965 kg LAR.

Parameter Smaller 38-ft class
(Size 300)
Larger 38-ft class
(Size 490)
Significance
Overall height 11.55 m / 37.9 ft 11.55 m / 37.9 ft Both closely match proposed height
Diameter 2.40 m / 7.87 ft 3.00 m / 9.84 ft Site-plan diameter can narrow actual capacity
Gross capacity 30,205 L / ~7,980 gal 49,020 L / ~12,950 gal ~62% capacity difference Net capacity (18 bar) 28,700 L / ~7,580 gal 46,570 L / ~12,300 gal Usable liquid inventory Relevant mass LIN: 23,190 kg / ~51,100 lb LAR: 64,965 kg / ~143,200 lb
Source term for release
analysis

2. Single-Tank Catastrophic Release Scenario and Inventory Context For emergency-planning purposes, the principal scenario recommended for detailed analysis is catastrophic loss of one full maximum-capacity LAR vessel. Four-tank inventory cases may be retained only as broad inventory context; simultaneous catastrophic failure of all four tanks is not relied upon as the primary credible emergency-planning scenario.

Scenario Cryogenic inventory Approx. ambient inert-gas
equivalent*
Use
A. One large LAR tank 64,965 kg LAR; ~12,300 gal
net
~38,450 m³ / 1.36 million ft³ Primary case
recommended for detailed
HHMD off-site
consequence analysis
B. Four smaller tanks, all
LIN
92,760 kg LIN; ~30,300 gal
net total
~78,300 m³ / 2.76 million ft³ Inventory context only; not proposed as primary
845
2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 — Case No. 2026-0595 — Single-Tank Catastrophic Release / HHMD Review Request
credible failure scenario
C. Four larger tanks, all LAR 259,860 kg LAR; ~49,200
gal net total
~153,800 m³ / 5.43 million ft³ Absolute inventory
envelope only; not
proposed as primary
credible failure scenario
* Ambient-gas equivalents are approximate inventory conversions at about 1 atm and 15°C. They are not plume volumes, hazard-zone areas, or predictions of actual dispersion.

3. Why Liquid Argon Warrants Off-Site Consequence Review Argon is chemically inert and nonflammable, but it is an asphyxiant because it displaces oxygen. At ordinary temperature argon gas is denser than air; immediately after a cryogenic release, the vapor is also extremely cold. A major release can therefore initially behave as a dense gas, with dispersion affected by wind, atmospheric stability, ground heating, buildings, walls, depressions, drainage features, and local grade.

Accordingly, a generic circular isolation distance does not by itself establish whether the R-1 neighborhood is protected.

The relevant question is the predicted oxygen concentration at off-site receptors following a credible major or catastrophic release.

4. Screening Calculation — Not a Dispersion Model
A deliberately simplified perfect-mixing/ground-layer screening calculation was used only to test whether neighborhoodscale oxygen depletion is physically plausible. Assuming a uniform 2-m-deep mixed layer, the approximate equivalent radii are:

O₂ endpoint One large LAR tank 4 small LIN tanks 4 large LAR tanks

19.5% O₂ ~990 ft ~1,415 ft ~1,980 ft
18% O₂ ~690 ft ~980 ft ~1,380 ft
15% O₂ ~480 ft ~690 ft ~970 ft

12.5% O₂ ~405 ft ~580 ft ~810 ft
Important limitation. These radii are not predictions and should not be used as evacuation zones. A real cryogenic release is neither uniformly mixed nor circular. The screening result merely demonstrates that the inventories are sufficiently large that off-site oxygen-deficiency at neighborhood-scale distances cannot be excluded by inventoryvolume reasoning alone. A site-specific dense-gas/cryogenic dispersion analysis is needed.

5. Regulatory Emergency-Planning Context
California's Hazardous Materials Business Plan regulations require emergency response procedures for a release or threatened release to be scaled to the size and nature of the business, the damage potential of the hazardous materials, and the facility's proximity to residential areas and other populations. 19 CCR §5030.9 includes notification, appropriate emergency medical assistance, mitigation/prevention/abatement, evacuation, and earthquake-related inspection/isolation provisions.

Los Angeles County HHMD states that businesses handling reportable quantities must submit hazardous-material inventory, a site map, and emergency response/contingency and employee-training information through CERS. HHMD also states that its emergency responders perform hazard analysis, technical advising, multi-agency coordination, and evacuation and re-occupancy determinations. These functions make HHMD/CUPA review particularly relevant to the off-site residential consequence issue.

6. Requested HHMD/CUPA Review

1. Confirm the maximum permitted/reported LIN and LAR inventory for each vessel and for the installation as a whole, including the quantities reported or to be reported in CERS. 846
2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 — Case No. 2026-0595 — Single-Tank Catastrophic Release / HHMD Review Request

2. Identify the actual vessel manufacturer/model, gross and net capacity, maximum fill quantity, operating pressure, and product assignment for each tank.

3. Confirm whether HHMD has reviewed, or will require, a site-specific oxygen-deficiency/dense-gas dispersion analysis for a major or catastrophic LAR release.

4. Evaluate at minimum catastrophic loss of one full maximum-size LAR vessel. If a different credible worst-case release scenario is used, identify the technical basis.

5. Identify the oxygen-concentration endpoints and meteorological conditions used to establish protective-action distances, including 19.5%, 18%, and 15% O₂ contours where technically appropriate.

6. Include actual site geometry and receptors: tank location, buildings/walls, grade, streets, storm/sewer drains or depressions, and the R-1 residences south of Manhattan Beach Boulevard.

7. Identify the technical basis for the 330-ft major-release/vessel-damage isolation distance presented in the applicant's safety materials and state whether it is site-specific or generic guidance.

8. State the planned protective actions for the R-1 neighborhood for a major inert-cryogen release, including notification, evacuation versus shelter-in-place criteria, incident command, monitoring, and re-occupancy.

9. Confirm coordination among HHMD/CUPA, Redondo Beach Fire Department, the tank owner/supplier, and the facility operator, including which agency has responsibility for off-site hazard assessment and public protectiveaction decisions.

10. Provide or identify the applicable HMBP/CERS emergency response and contingency materials, site map, inventory information, and HHMD review/inspection records, subject to applicable disclosure restrictions.

7. Requested Technical Question
For catastrophic loss of one full maximum-capacity liquid-argon vessel at 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 (Case No. 2026-0595), what analysis establishes the distance and direction at which oxygen concentrations remain above applicable oxygen-deficiency/protective-action criteria under reasonably conservative meteorological and site conditions, including at the R-1 residences south of Manhattan Beach Boulevard?

8. References
 Linde AG, Cryogenic Standard Tanks LITS 2, Technical Data — Tanks for Air Gases LIN, LOX, LAR, p. 6. The catalog identifies LIN as liquid nitrogen and LAR as liquid argon and provides capacities, fill masses, diameters and heights for the Size 300 and Size 490 tanks.
 California Code of Regulations, Title 19, Division 5, Chapter 1, §5030.9, Emergency Response Plans and Procedures (CalEPA publication).
 CalEPA, Hazardous Materials Business Plan FAQ — emergency response plans/procedures and site-map requirements.
 County of Los Angeles Fire Department, Health Hazardous Materials Division — Hazardous Materials Program; CERS Information; Haz Mat Emergency Operations; HHMD Contact Information.  City of Redondo Beach project record, Case No. 2026-0595 / PC26-1012, 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278, including the proposed approximately 38-ft bulk cryogenic storage tanks and adjacent R-1 zoning south of Manhattan Beach Boulevard.
847
PUBLIC COMMENT 03 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Wednesday, August 26, 2026 at 11:09 PM

SUBJECT
Public Notice: This 2477 Manhattan Beach Blvd.

Exhibit is Defective
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
848
CAUTION: External Email. Proceed Responsibly.
https://redondo.legistar.com/View.ashx?M=F&ID=15770496&GUID=13D082F2-8474- 44DF-9249-E2F88B8D2C8E
The drawing fails to label tank size, volume or content. The drawing has no streets. The drawing has no surrounding land uses. The drawing has no as-is location despite being a purported "relocation" drawing. In short this does not meet the evidentiary requirements of any permitting or emergency response use.

As of today, LA County Fire has not responded to local neighborhood concerns regarding tank safety and rupture planning of the heavier than air Liquid argon. cc: Redondo Council
From: Mark Nelson (Home Gmail)
To: CityClerk; Sean Scully; Fire-Hhmdcers; CALFIRE State Fire Marshal Subject: Public Notice: This 2477 Manhattan Beach Blvd, Redondo Beach, CA 90278 Exhibit is Defective Date: Wednesday, August 26, 2026 11:09:58 PM
849
PUBLIC COMMENT 04 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, August 27, 2026 at 6:43 PM

SUBJECT
Re: 2477 Manhattan Beach Blvd. - Request for HHMD
Review of Cryogenic Tank Emergency Planning
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
850
From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:35:26 PM
Attachments: image001.png
Tamworth liquid nitrogen explosion December 14 2021 The Northern.mp4 Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Thursday, August 27, 2026 6:43 PM
To: Raquel Doom <[email protected]>
Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]>; [email protected]; Holly J. Mitchell <[email protected]> Subject: Re: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Here's a rupture of 20-foot tank of liquid nitrogen. Without dispute, it would have carry well into surrounding neighborhoods and displace oxygen. Also, had it been argon, it would be heavier than oxygen and be even more of a hazard. Yet, no agency cares.

Surrounding neighbors should be furious.

On Thu, Aug 27, 2026 at 5:51 PM Mark Nelson (Home Gmail) wrote:

Thank you for your response. My response is not aimed at you, but rather, a failed process.
851
I'm going to paraphrase:

I think we all agree that in a catastrophic rupture, the residents 200 to 500-feet away (depending on wind speed and direction) could be snuffed out by oxygen displacement, especially from argon, but also from nitrogen. If we aren't in agreement, I'll be happy to provide the engineering analysis of a 12,000 gallon catastrophic liquid Ar release event under perfect mixing - the best possible life preserving case.

Apparently, under state and federal law, that's ok that residents might be killed without any analysis - and no analysis is required because they are non-flammable.

Hypothetically, a million gallon tank that could saturate one-half mile radius would not require any analysis either.

However, the emergency agency does voice concerns about the life and safety of first responders in the exact same situation, as it recognizes the asphyxiation properties of N2 and Ar.

This is truly unacceptable to the surrounding neighborhoods and at the minimum, the Planning Commission needs to deny the variance and the City should not cooperate with this flawed process.

On Thu, Aug 27, 2026 at 5:31 PM Raquel Doom <[email protected]> wrote:

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use.

Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA). 852
Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation.

Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail Fire-HHMDDOU[email protected] Website: www.fire.lacounty.gov/health-hazardous-materials-division From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 PM
To: Fire-Hhmdcers <[email protected]>; FIRE-AskHHMD <[email protected]>
Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; [email protected] <[email protected]>; 853
CAUTION: External Email. Proceed Responsibly.

Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
County of Los Angeles Fire Department
Health Hazardous Materials Division
cc: Redondo Beach Councilmember Behrendt, Mr. Witzansky, Ms. Ford, Mr. Wiener, and Members of the Planning Commission:

I am transmitting the attached memorandum on behalf of myself and interested residents in the neighborhood surrounding 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278, regarding the proposed bulk liquid-nitrogen and liquid-argon storage tanks.

The August 20 Planning Commission hearing was useful in identifying both the issues of concern to nearby residents and several questions of interest to the Commissioners.

Among the subjects discussed were tank capacity, separation from the residential neighborhood, oxygen displacement, emergency isolation and evacuation distances, and the consequences of a major vessel failure. The proposed tanks are approximately 222 feet from the nearest residential property.

The hearing also helped clarify the respective regulatory roles. Redondo Beach Fire Department indicated that it does not maintain its own hazardous-materials team and that Los Angeles County Fire performs the hazardous-materials/CUPA inspection function for facilities of this type.

I do not interpret the questions raised at the hearing as establishing that the proposed tanks are unsafe. Rather, my takeaway was that some of the specific technical questions being asked by Commissioners and residents could not be answered in detail at the hearing and appear more appropriately directed to HHMD/CUPA.

That is the purpose of the attached memorandum.

In particular, I believe a useful and reasonably bounded question is the consequence of catastrophic failure of one full liquid-argon vessel. Argon is nonflammable and [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
854
chemically inert, but a sufficiently large release can create an oxygen-deficient atmosphere. Because argon is denser than air—and a cryogenic release initially produces a very cold, dense gas—the proximity of the R-1 neighborhood immediately south of Manhattan Beach Boulevard makes the off-site consequence question worth resolving quantitatively.

The attached memorandum therefore does not assume simultaneous failure of all four vessels and does not attempt to establish an evacuation zone. It asks whether the appropriate reviewing agency has evaluated, or will evaluate, a credible single-vessel catastrophic release using the actual tank inventory and site conditions, and determine the resulting oxygen-deficiency/protective-action distances.

One difficulty apparent from the hearing is that responsibility for this installation is distributed among several regulatory functions. Planning is addressing the height variance; Building and RBFD have their respective responsibilities; and hazardousmaterials review appears to reside principally with LA County Fire/HHMD-CUPA. That division of responsibility may be entirely appropriate, but from the standpoint of the surrounding residents it makes it difficult to determine which agency evaluates the off-site consequences of a catastrophic cryogenic release and how that analysis becomes part of the overall safety review.

Accordingly, I would appreciate HHMD's assistance in answering the questions in the attached memorandum, particularly:

For catastrophic loss of one full maximum-capacity liquid-argon vessel at 2477 Manhattan Beach Boulevard, what analysis establishes the distance and direction at which oxygen concentrations remain above applicable oxygendeficiency/protective-action criteria under reasonably conservative meteorological and site conditions, including at the R-1 residences south of Manhattan Beach Boulevard?
I am copying the City and Planning Commission because these questions arose directly from the public hearing and the answers should be useful to Commissioners, City staff, the applicant, and the surrounding residents. The hearing itself reflected substantial interest in obtaining additional information concerning these issues; one Commissioner specifically raised the possibility of continuing the matter to allow additional information and public outreach.

Thank you for your assistance. Our objective is straightforward: to identify the agency with the relevant technical responsibility, obtain the appropriate analysis, and give the surrounding residents and City decision-makers a clear factual basis for understanding the off-site emergency implications of the proposed installation.

Regards,
Mark Nelson
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / 855
HHMD Review Request
856
PUBLIC COMMENT 05 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Friday, August 28, 2026 at 4:23 PM

SUBJECT
Re: 2477 Manhattan Beach Blvd. - Request for HHMD
Review of Cryogenic Tank Emergency Planning
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
857
From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:35:03 PM
Attachments: image001.png
LN2_Catastrophic_Release_Screening_2477_MBB.docx
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Friday, August 28, 2026 4:23 PM
To: Raquel Doom <[email protected]>
Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]> Subject: Re: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

The attached engineering screening analysis demonstrates that a rupture of single 12,000 gallon, 38-ft tank would have sufficient product to impact the residential area to the south of the site. Absent detailed modeling, which the agencies refuse to conduct, the safety analysis is incomplete.

On Thu, Aug 27, 2026 at 5:31 PM Raquel Doom <[email protected]> wrote:

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use. 858
Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA).

Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation.

Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail Fire-HHMDDOU[email protected] Website: www.fire.lacounty.gov/health-hazardous-materials-division 859
CAUTION: External Email. Proceed Responsibly.

Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
County of Los Angeles Fire Department
Health Hazardous Materials Division
cc: Redondo Beach Councilmember Behrendt, Mr. Witzansky, Ms. Ford, Mr. Wiener, and Members of the Planning Commission:

I am transmitting the attached memorandum on behalf of myself and interested residents in the neighborhood surrounding 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278, regarding the proposed bulk liquid-nitrogen and liquid-argon storage tanks.

The August 20 Planning Commission hearing was useful in identifying both the issues of concern to nearby residents and several questions of interest to the Commissioners. Among the subjects discussed were tank capacity, separation from the residential neighborhood, oxygen displacement, emergency isolation and evacuation distances, and the consequences of a major vessel failure. The proposed tanks are approximately 222 feet from the nearest residential property.

The hearing also helped clarify the respective regulatory roles. Redondo Beach Fire Department indicated that it does not maintain its own hazardous-materials team and that Los Angeles County Fire performs the hazardous-materials/CUPA inspection function for facilities of this type.

From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 PM
To: Fire-Hhmdcers <[email protected]>; FIRE-AskHHMD <[email protected]>
Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
860
I do not interpret the questions raised at the hearing as establishing that the proposed tanks are unsafe. Rather, my takeaway was that some of the specific technical questions being asked by Commissioners and residents could not be answered in detail at the hearing and appear more appropriately directed to HHMD/CUPA.

That is the purpose of the attached memorandum.

In particular, I believe a useful and reasonably bounded question is the consequence of catastrophic failure of one full liquid-argon vessel. Argon is nonflammable and chemically inert, but a sufficiently large release can create an oxygen-deficient atmosphere. Because argon is denser than air—and a cryogenic release initially produces a very cold, dense gas—the proximity of the R-1 neighborhood immediately south of Manhattan Beach Boulevard makes the off-site consequence question worth resolving quantitatively.

The attached memorandum therefore does not assume simultaneous failure of all four vessels and does not attempt to establish an evacuation zone. It asks whether the appropriate reviewing agency has evaluated, or will evaluate, a credible single-vessel catastrophic release using the actual tank inventory and site conditions, and determine the resulting oxygen-deficiency/protective-action distances.

One difficulty apparent from the hearing is that responsibility for this installation is distributed among several regulatory functions. Planning is addressing the height variance; Building and RBFD have their respective responsibilities; and hazardous-materials review appears to reside principally with LA County Fire/HHMD-CUPA. That division of responsibility may be entirely appropriate, but from the standpoint of the surrounding residents it makes it difficult to determine which agency evaluates the off-site consequences of a catastrophic cryogenic release and how that analysis becomes part of the overall safety review.

Accordingly, I would appreciate HHMD's assistance in answering the questions in the attached memorandum, particularly:

For catastrophic loss of one full maximum-capacity liquid-argon vessel at 2477 Manhattan Beach Boulevard, what analysis establishes the distance and direction at which oxygen concentrations remain above applicable oxygendeficiency/protective-action criteria under reasonably conservative meteorological and site conditions, including at the R-1 residences south of Manhattan Beach Boulevard?
I am copying the City and Planning Commission because these questions arose directly from the public hearing and the answers should be useful to Commissioners, City staff, the applicant, and the surrounding residents. The hearing itself reflected substantial interest in obtaining additional information concerning these issues; one Commissioner specifically raised the possibility of continuing the matter to allow additional information and public outreach.

Thank you for your assistance. Our objective is straightforward: to identify the agency 861
with the relevant technical responsibility, obtain the appropriate analysis, and give the surrounding residents and City decision-makers a clear factual basis for understanding the off-site emergency implications of the proposed installation.

Regards,
Mark Nelson
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
862
PUBLIC COMMENT 06 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Stop BCHD

ORIGINAL SENT
Monday, August 31, 2026 at 4:50 PM

SUBJECT
TRW Tract Neighbors Need a Safety Analysis Prior to
Any Tank Installations
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
863
From: Sean Scully
To: Jamaal Brown
Subject: FW: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations Date: Friday, September 11, 2026 4:34:13 PM
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Stop BCHD
Sent: Monday, August 31, 2026 4:50 PM
To: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>
Subject: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Subject: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations City Council, City Manager, City Attorney, Planning Commissioners:

The residents surrounding 2477 Manhattan Beach Blvd deserve a fair analysis of the shrapnel and gas hazards from the proposed Argon and Nitrogen tanks. This link shows the explosion of a 20-foot tall tank.

The proposal is for four 38-foot tall tanks which provides much more potential damage and oxygen displacing gas release.

The explosion and shrapnel video is at https://www.youtube.com/watch?v=CHXU07zyKRA Nitrogen gas will displace oxygen and could result in asphyxiation as the level of nitrogen in the local air rises well above 80%. Argon is heavier than oxygen, so it will create a layer of unbreathable gas and potentially asphyxiate residents and pool in low lying spaces, like stairwells, underground parking, etc.

All we ask is a fair, honest analysis. You've seen the video. The proponent lost its credibility when it claimed that an explosion was impossible. It's possible and it happens periodically. 200-feet from homes is well within the range of 12,000 gallons of 864
liquid argon to travel and for large equipment to land after an explosion.

The City needs to build its own credibility and assure a transparent analysis is conducted and made public. This is a small "ask" to avoid a tragic outcome. No tanks before a SAFETY analysis. Simple. Fair.

Thank you.
--
StopBCHD.com is a Neighborhood Quality-of-Life Community concerned about the quality-of-life, health, and economic damages that BCHDs 110- foot above the street, 800,000 sqft commercial development will inflict for the next 50- 100 years. Our neighborhoods have been burdened since 1960 by the failed South Bay Hospital project and have not received the benefit of the voter-approved acute care public hospital since 1984.Yet we still suffer 100% of the damages and we will suffer 100% of the damages of BCHDs proposal.
865
PUBLIC COMMENT 07 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Marcio Nava

ORIGINAL SENT
Monday, August 31, 2026 at 8:06 PM

SUBJECT
TRW Tract Neighbors Need a Safety Analysis Prior to
Any Tank Installations
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
866
Some people who received this message don't often get email from Learn why this is important From: Sean Scully
To: Jamaal Brown
Subject: FW: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations Date: Friday, September 11, 2026 4:33:58 PM
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: M. Nava
Sent: Monday, August 31, 2026 8:06 PM
To: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>
Subject: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

City Council, City Manager, City Attorney, Planning Commissioners:

The residents surrounding 2477 Manhattan Beach Blvd deserve a fair analysis of the shrapnel and gas hazards from the proposed Argon and Nitrogen tanks. This link shows the explosion of a 20-foot tall tank.

The proposal is for four 38-foot tall tanks which provides much more potential damage and oxygen displacing gas release.

The explosion and shrapnel video is at https://www.youtube.com/watch?v=CHXU07zyKRA Nitrogen gas will displace oxygen and could result in asphyxiation as the level of nitrogen in the local air rises well above 80%. Argon is heavier than oxygen, so it will create a layer of unbreathable gas and potentially asphyxiate residents and pool in low lying spaces, like stairwells, underground parking, etc.

All we ask is a fair, honest analysis. You've seen the video. The proponent lost its credibility when it claimed that an explosion was impossible. It's possible and it happens periodically. 200-feet from homes is well within the range of 12,000 gallons of liquid argon to travel and for large equipment to land after an explosion.

The City needs to build its own credibility and assure a transparent analysis is conducted and made public. This is a small "ask" to avoid a tragic outcome. No tanks before a SAFETY 867
analysis. Simple. Fair.

Thank you.

Marcio Nava
868
PUBLIC COMMENT 08 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mina Amirzai

ORIGINAL SENT
Tuesday, September 1, 2026 at 11:40 AM

SUBJECT
Public Comment - Neighbors Deserve a Full Safety
Analysis of the Four 38-foot Cryogenic Tanks
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
869
You don't often get email from Learn why this is important From: Sean Scully
To: Jamaal Brown
Subject: FW: Public Comment - Neighbors Deserve a Full Safety Analysis of the Four, 38-foot, Cryogenic Tanks at Impulse Space Date: Friday, September 11, 2026 4:33:03 PM
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: mina amirzai
Sent: Tuesday, September 1, 2026 11:40 AM
To: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]> Subject: Public Comment - Neighbors Deserve a Full Safety Analysis of the Four, 38-foot, Cryogenic Tanks at Impulse Space CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Council Members, Commissioners, City Manager, City Attorney:

Please view the video of the explosion from 2 failed emergency discharge valves of a 20-foot liquid nitrogen tank. It is catastrophic.

Tamworth liquid nitrogen explosion December 14 2021
Mark N
youtube.com
At the recent Planning Commission meeting, we were told that liquid Nitrogen and liquid Argon are not explosive and not toxic. We were also told by RBFD that they cannot conduct any analysis of the gasses because they do not have a HAZMAT unit. We were then told that LA County HAZMAT would conduct the analysis.

In an email from August 27 by Specialist Doom of LACoFD, the City and the Residents were informed by LA County that no analysis would be conducted for residents of a catastrophic rupture of any of the tanks. LA County did make it clear that there was an asphyxiation risk from both Argon and Nitrogen and that they would have their teams analyze the health and safety impacts on first responders.

So neighbors are in a position where we know:
1) the tanks can explode,
2) the liquids inside are at -300 degrees F,
3) the liquids will roll out over the neighborhoods after a tank explosion, 4) the liquids will re-gasify to Argon or Nitrogen gas, both of which displace oxygen required for life, 5) LA County sees risk to first responders from the gas and the risk of asphyxiation, and 6) NO AGENCY WILL CONDUCT ANY SAFETY ANALYSIS FOR THE NEIGHBORHOOD RESIDENTS' SAFETY.

That is unacceptable.

The City is obligated to protect resident health and safety. Until a full analysis and mitigations are completed to protect the neighbors, we demand that no permits are issued.

If any tanks are relocated, they must be required to have safety walls that will stop a catastrophic release from flowing off the Impulse Space property. If Impulse won't allow that, then this is clearly an unsafe situation for residents also.

Please act quickly as this situation is stressing residents who are in the blast and gas zone. 870
Sincerely,
Mina Amirzai
(Concerned parent and resident of TRW tract neighborhood) 871
PUBLIC COMMENT 09 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
L. A. Stone

ORIGINAL SENT
Tuesday, September 1, 2026 at 12:08 PM

SUBJECT
Public Comment - Neighbors Deserve a Full Safety
Analysis of the Four 38-foot Cryogenic Tanks
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
872
You don't often get email from Learn why this is important From: Sean Scully
To: Jamaal Brown
Subject: FW: Public Comment - Neighbors Deserve a Full Safety Analysis of the Four, 38-foot, Cryogenic Tanks at Impulse Space
Date: Friday, September 11, 2026 4:33:37 PM
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: L. A Stone
Sent: Tuesday, September 1, 2026 12:08 PM
To: Joy Ford <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Scott Behrendt <[email protected]>
Subject: Public Comment - Neighbors Deserve a Full Safety Analysis of the Four, 38-foot, Cryogenic Tanks at Impulse Space
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Members, Commissioners, City Manager, City Attorney:

Please view the video of the explosion from 2 failed emergency discharge valves of a 20-foot liquid nitrogen tank. It is catastrophic.
https://youtu.be/CHXU07zyKRA
At the recent Planning Commission meeting, we were told that liquid Nitrogen and liquid Argon are not explosive and not toxic. We were also told by RBFD that they cannot conduct any analysis of the gasses because they do not have a HAZMAT unit. We were then told that LA County HAZMAT would conduct the analysis.

In an email from August 27 by Specialist Doom of LACoFD, the City and the Residents were informed by LA County that no analysis would be conducted for residents of a catastrophic rupture of any of the tanks. LA County did make it clear that there was an asphyxiation risk from both Argon and Nitrogen and that they would have their teams analyze the health and safety impacts on first responders.

So neighbors are in a position where we know:
1) the tanks can explode,
2) the liquids inside are at -300 degrees F,
3) the liquids will roll out over the neighborhoods after a tank explosion, 873
4) the liquids will re-gasify to Argon or Nitrogen gas, both of which displace oxygen required for life,
5) LA County sees risk to first responders from the gas and the risk of asphyxiation, and 6) NO AGENCY WILL CONDUCT ANY SAFETY ANALYSIS FOR THE NEIGHBORHOOD RESIDENTS' SAFETY.

That is unacceptable.

The City is obligated to protect resident health and safety. Until a full analysis and mitigations are completed to protect the neighbors, we demand that no permits are issued.

If any tanks are relocated, they must be required to have safety walls that will stop a catastrophic release from flowing off the Impulse Space property. If Impulse won't allow that, then this is clearly an unsafe situation for residents also.

Please act quickly as this situation is stressing residents who are in the blast and gas zone.

Sent from my iPhone
874
PUBLIC COMMENT 10 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Wednesday, September 2, 2026 at 9:12 AM

SUBJECT
Re: 2477 Manhattan Beach Blvd. - Request for HHMD
Review of Cryogenic Tank Emergency Planning
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
875
From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:30:52 PM
Attachments: image001.png
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Wednesday, September 2, 2026 9:12 AM
To: Raquel Doom <[email protected]>
Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]>; [email protected]; [email protected]; [email protected]
Subject: Re: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Also public comment LA County Board of Supervisors - Non-Agenda Item for Next Available Meeting
To LA County Fire and Hazard:

Provide a time and place to review all of your legally required analysis of the 2477 Manhattan Beach Blvd liquid N2 and liquid argon storage tanks. The following delineation of delegated responsibilities from the City of Redondo Beach Fire Department to LA County demonstrate the safety reports that we plan to inspect.

A 12,000-gallon liquid argon tank for a welding operation in Redondo Beach shifts the regulatory path directly to the Los Angeles County Fire Department (LACoFD) 876
Health Hazardous Materials Division (HHMD), which acts as the Certified Unified Program Agency (CUPA) for areas where local departments do not retain hazmat jurisdiction.

LACoFD CUPA & Hazardous Materials Requirements
Threshold Triggers: Liquid argon is stored as a cryogenic liquid and transitions to a compressed gas. Because a 12,000-gallon vessel vastly exceeds state threshold quantities (500 pounds or 55 gallons for compressed/cryogenic gases), it mandates full oversight.

California Environmental Reporting System (CERS): You must submit a comprehensive Hazardous Materials Business Plan (HMBP), including emergency response plans, facility layout maps, and exact inventory quantities, through CERS.

Aboveground Tank and Cryogenic Review: LACoFD HHMD will review the installation for compliance with safety standards regarding physical stability, pressure relief venting, and accidental release prevention.

Redondo Beach Building & Safety Integration
Local Plan Check: While hazmat goes to the county, the physical construction, foundation, and utility hookups are permitted locally through the City of Redondo Beach Building Division.

Zoning and Setbacks: The local planning division will verify that the tank meets industrial zoning restrictions and property-line setbacks. Because argon is heavier than air and displaces oxygen, strict safety clearances from building egress points, operable windows, and air intakes are heavily enforced during plan check.

Engineering & Safety Mandates
Seismic Design: Southern California building codes require site-specific structural calculations stamped by a California Professional Engineer (PE). The 12,000-gallon vessel, its concrete pad, anchoring system, and vaporization/piping infrastructure must be engineered to withstand major seismic events.

NFPA 55 & CGA Standards: The system must strictly adhere to the Compressed Gas Association (CGA) guidelines and NFPA 55 for cryogenic fluid storage, including proper placarding, security fencing, and bollards to protect against vehicle impact.

On Fri, Aug 28, 2026 at 4:23 PM Mark Nelson (Home Gmail) wrote:

The attached engineering screening analysis demonstrates that a rupture of single 12,000 gallon, 38-ft tank would have sufficient product to impact the residential area to the south of the site. Absent detailed modeling, which the agencies refuse to conduct, the safety analysis is incomplete.
877
On Thu, Aug 27, 2026 at 5:31 PM Raquel Doom <[email protected]> wrote:

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use.

Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA).

Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation.

Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail Fire-HHMDDOU[email protected] 878
CAUTION: External Email. Proceed Responsibly.

Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
County of Los Angeles Fire Department
Health Hazardous Materials Division
cc: Redondo Beach Councilmember Behrendt, Mr. Witzansky, Ms. Ford, Mr. Wiener, and Members of the Planning Commission:

I am transmitting the attached memorandum on behalf of myself and interested residents in the neighborhood surrounding 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278, regarding the proposed bulk liquid-nitrogen and liquid-argon storage tanks.

The August 20 Planning Commission hearing was useful in identifying both the issues Website: www.fire.lacounty.gov/health-hazardous-materials-division From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 PM
To: Fire-Hhmdcers <[email protected]>; FIRE-AskHHMD <[email protected]>
Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
879
of concern to nearby residents and several questions of interest to the Commissioners.

Among the subjects discussed were tank capacity, separation from the residential neighborhood, oxygen displacement, emergency isolation and evacuation distances, and the consequences of a major vessel failure. The proposed tanks are approximately 222 feet from the nearest residential property.

The hearing also helped clarify the respective regulatory roles. Redondo Beach Fire Department indicated that it does not maintain its own hazardous-materials team and that Los Angeles County Fire performs the hazardous-materials/CUPA inspection function for facilities of this type.

I do not interpret the questions raised at the hearing as establishing that the proposed tanks are unsafe. Rather, my takeaway was that some of the specific technical questions being asked by Commissioners and residents could not be answered in detail at the hearing and appear more appropriately directed to HHMD/CUPA.

That is the purpose of the attached memorandum.

In particular, I believe a useful and reasonably bounded question is the consequence of catastrophic failure of one full liquid-argon vessel. Argon is nonflammable and chemically inert, but a sufficiently large release can create an oxygen-deficient atmosphere. Because argon is denser than air—and a cryogenic release initially produces a very cold, dense gas—the proximity of the R-1 neighborhood immediately south of Manhattan Beach Boulevard makes the off-site consequence question worth resolving quantitatively.

The attached memorandum therefore does not assume simultaneous failure of all four vessels and does not attempt to establish an evacuation zone. It asks whether the appropriate reviewing agency has evaluated, or will evaluate, a credible single-vessel catastrophic release using the actual tank inventory and site conditions, and determine the resulting oxygen-deficiency/protective-action distances.

One difficulty apparent from the hearing is that responsibility for this installation is distributed among several regulatory functions. Planning is addressing the height variance; Building and RBFD have their respective responsibilities; and hazardousmaterials review appears to reside principally with LA County Fire/HHMD-CUPA. That division of responsibility may be entirely appropriate, but from the standpoint of the surrounding residents it makes it difficult to determine which agency evaluates the off-site consequences of a catastrophic cryogenic release and how that analysis becomes part of the overall safety review.

Accordingly, I would appreciate HHMD's assistance in answering the questions in the attached memorandum, particularly:

For catastrophic loss of one full maximum-capacity liquid-argon vessel at 2477 Manhattan Beach Boulevard, what analysis establishes the distance and direction at which oxygen concentrations remain above applicable oxygen880 deficiency/protective-action criteria under reasonably conservative meteorological and site conditions, including at the R-1 residences south of Manhattan Beach Boulevard?
I am copying the City and Planning Commission because these questions arose directly from the public hearing and the answers should be useful to Commissioners, City staff, the applicant, and the surrounding residents. The hearing itself reflected substantial interest in obtaining additional information concerning these issues; one Commissioner specifically raised the possibility of continuing the matter to allow additional information and public outreach.

Thank you for your assistance. Our objective is straightforward: to identify the agency with the relevant technical responsibility, obtain the appropriate analysis, and give the surrounding residents and City decision-makers a clear factual basis for understanding the off-site emergency implications of the proposed installation.

Regards,
Mark Nelson
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
881
PUBLIC COMMENT 11 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Wednesday, September 2, 2026 at 9:16 AM

SUBJECT
Re: 2477 Manhattan Beach Blvd. - Request for HHMD
Review of Cryogenic Tank Emergency Planning
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
882
From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:30:29 PM
Attachments: image001.png
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Wednesday, September 2, 2026 9:16 AM
To: Raquel Doom <[email protected]>
Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]> Subject: Re: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

City of Redondo Beach with Interdepartmental Coordination as Required:

Provide a time and place to review all of your legally required analysis of the 2477 Manhattan Beach Blvd liquid N2 and liquid argon storage tanks. The following delineation of responsibilities of the City of Redondo Beach demonstrate the safety reports that we plan to inspect.

A 12,000-gallon liquid argon tank for a welding operation in Redondo Beach shifts the regulatory path directly to the Los Angeles County Fire Department (LACoFD) Health Hazardous Materials Division (HHMD), which acts as the Certified Unified Program Agency (CUPA) for areas where local departments do not retain hazmat jurisdiction.

LACoFD CUPA & Hazardous Materials Requirements
883
· Threshold Triggers: Liquid argon is stored as a cryogenic liquid and transitions to a compressed gas. Because a 12,000-gallon vessel vastly exceeds state threshold quantities (500 pounds or 55 gallons for compressed/cryogenic gases), it mandates full oversight. · California Environmental Reporting System (CERS): You must submit a comprehensive Hazardous Materials Business Plan (HMBP), including emergency response plans, facility layout maps, and exact inventory quantities, through CERS.
· Aboveground Tank and Cryogenic Review: LACoFD HHMD will review the installation for compliance with safety standards regarding physical stability, pressure relief venting, and accidental release prevention.

Redondo Beach Building & Safety Integration
· Local Plan Check: While hazmat goes to the county, the physical construction, foundation, and utility hookups are permitted locally through the City of Redondo Beach Building Division.
· Zoning and Setbacks: The local planning division will verify that the tank meets industrial zoning restrictions and property-line setbacks. Because argon is heavier than air and displaces oxygen, strict safety clearances from building egress points, operable windows, and air intakes are heavily enforced during plan check.

Engineering & Safety Mandates
· Seismic Design: Southern California building codes require site-specific structural calculations stamped by a California Professional Engineer (PE).

The 12,000-gallon vessel, its concrete pad, anchoring system, and vaporization/piping infrastructure must be engineered to withstand major seismic events.
· NFPA 55 & CGA Standards: The system must strictly adhere to the Compressed Gas Association (CGA) guidelines and NFPA 55 for cryogenic fluid storage, including proper placarding, security fencing, and bollards to protect against vehicle impact.

On Fri, Aug 28, 2026 at 4:23 PM Mark Nelson (Home Gmail) wrote:

The attached engineering screening analysis demonstrates that a rupture of single 12,000 gallon, 38-ft tank would have sufficient product to impact the residential area to the south of the site. Absent detailed modeling, which the agencies refuse to conduct, the safety analysis is incomplete.
884
On Thu, Aug 27, 2026 at 5:31 PM Raquel Doom <[email protected]> wrote:

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use.

Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA).

Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation.

Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail Fire-HHMDDOU[email protected] 885
CAUTION: External Email. Proceed Responsibly.

Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
County of Los Angeles Fire Department
Health Hazardous Materials Division
cc: Redondo Beach Councilmember Behrendt, Mr. Witzansky, Ms. Ford, Mr. Wiener, and Members of the Planning Commission:

I am transmitting the attached memorandum on behalf of myself and interested residents in the neighborhood surrounding 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278, regarding the proposed bulk liquid-nitrogen and liquid-argon storage tanks.

The August 20 Planning Commission hearing was useful in identifying both the issues Website: www.fire.lacounty.gov/health-hazardous-materials-division From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 PM
To: Fire-Hhmdcers <[email protected]>; FIRE-AskHHMD <[email protected]>
Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
886
of concern to nearby residents and several questions of interest to the Commissioners.

Among the subjects discussed were tank capacity, separation from the residential neighborhood, oxygen displacement, emergency isolation and evacuation distances, and the consequences of a major vessel failure. The proposed tanks are approximately 222 feet from the nearest residential property.

The hearing also helped clarify the respective regulatory roles. Redondo Beach Fire Department indicated that it does not maintain its own hazardous-materials team and that Los Angeles County Fire performs the hazardous-materials/CUPA inspection function for facilities of this type.

I do not interpret the questions raised at the hearing as establishing that the proposed tanks are unsafe. Rather, my takeaway was that some of the specific technical questions being asked by Commissioners and residents could not be answered in detail at the hearing and appear more appropriately directed to HHMD/CUPA.

That is the purpose of the attached memorandum.

In particular, I believe a useful and reasonably bounded question is the consequence of catastrophic failure of one full liquid-argon vessel. Argon is nonflammable and chemically inert, but a sufficiently large release can create an oxygen-deficient atmosphere. Because argon is denser than air—and a cryogenic release initially produces a very cold, dense gas—the proximity of the R-1 neighborhood immediately south of Manhattan Beach Boulevard makes the off-site consequence question worth resolving quantitatively.

The attached memorandum therefore does not assume simultaneous failure of all four vessels and does not attempt to establish an evacuation zone. It asks whether the appropriate reviewing agency has evaluated, or will evaluate, a credible single-vessel catastrophic release using the actual tank inventory and site conditions, and determine the resulting oxygen-deficiency/protective-action distances.

One difficulty apparent from the hearing is that responsibility for this installation is distributed among several regulatory functions. Planning is addressing the height variance; Building and RBFD have their respective responsibilities; and hazardousmaterials review appears to reside principally with LA County Fire/HHMD-CUPA. That division of responsibility may be entirely appropriate, but from the standpoint of the surrounding residents it makes it difficult to determine which agency evaluates the off-site consequences of a catastrophic cryogenic release and how that analysis becomes part of the overall safety review.

Accordingly, I would appreciate HHMD's assistance in answering the questions in the attached memorandum, particularly:

For catastrophic loss of one full maximum-capacity liquid-argon vessel at 2477 Manhattan Beach Boulevard, what analysis establishes the distance and direction at which oxygen concentrations remain above applicable oxygen887 deficiency/protective-action criteria under reasonably conservative meteorological and site conditions, including at the R-1 residences south of Manhattan Beach Boulevard?
I am copying the City and Planning Commission because these questions arose directly from the public hearing and the answers should be useful to Commissioners, City staff, the applicant, and the surrounding residents. The hearing itself reflected substantial interest in obtaining additional information concerning these issues; one Commissioner specifically raised the possibility of continuing the matter to allow additional information and public outreach.

Thank you for your assistance. Our objective is straightforward: to identify the agency with the relevant technical responsibility, obtain the appropriate analysis, and give the surrounding residents and City decision-makers a clear factual basis for understanding the off-site emergency implications of the proposed installation.

Regards,
Mark Nelson
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
888
PUBLIC COMMENT 12 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Alicia Evans

ORIGINAL SENT
Sunday, September 13, 2026 at 5:47 PM

SUBJECT
Public Comment - RB City Council Non-Agenda Items
and Planning Commission Item K.1
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
889
From: alicia evans
To: Joy Ford; Mike Witzansky; James Light; Brad Waller; Chadwick B. Castle; Zein Obagi; Planning Redondo; Scott Behrendt; Eleanor Manzano; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Sean Scully; Daniel Besinaiz; Julie Young; Patrick Butler; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: SUBJECT: Public Comment - RB City Council Mtg Non-Agenda Items, RB Planning Commission Mtg Item K1 Impulse Space Tank Variance
Date: Sunday, September 13, 2026 5:47:04 PM
Some people who received this message don't often get email from Learn why this is important
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Council Members, Commissioners, and Others:

Impulse Space Tank Variance: Since time is so short and the City is ignoring resident safety - here's a comment letter that you can send to the email list to request that the safety analysis isn't an afterthought.

The safety analysis should be completed before permitting.

OPTION 1: STOP PROCESSING OF THE VARIANCE NOW AND REQUIRE COMPLETION OF THE SAFETY ANALYSIS IN ADVANCE FOR PUBLIC REVIEW. Public safety should not be an afterthought for review after approval of the permit.

OPTION 2: DENY THE VARIANCE. The proponent was clear, they can and do currently use smaller tanks but they'll need to be refilled more often. NEVER DID IMPULSE EVER CLAIM 38-FT TANKS WERE REQUIRED.

Furthermore, the staff report on the project is again incorrect! Staff states the following required for approval of the variance:
"Additionally, the technical requirements of this required infrastructure in support of this aerospace manufacturing operation (permitted use) cannot be accommodated at a lesser height without resulting in significantly more frequent deliveries which have the potential for the greatest impact on the adjacent residential neighborhood south the subject property"
Neither staff nor proponent provide ANY EVIDENCE that the frequency of refilling poses any "significant" impacts.

Nor, does staff even attempt to determine the High Consequence-Low Frequency rupture impacts vs. the traffic impacts. Without an analysis, the statement is simply conjecture that was reverse manufactured based on the variance need for approval.

This process and the City reports and processing have been haphazard and inaccurate and the City is putting the safety of surrounding residents at risk.

REALITY CHECK…!!!!!!
Safety Systems DO FAIL and Tanks DO EXPLODE
The tank in the video DID EXACTLY what it was supposed to do in the event the pressure relief valves failed - IT RUPTURED.

It launched steel hundreds of feet into the air and left a roughly 1500-foot debris field.

It also sent liquid gas pouring across the landscape for hundreds of feet. The gas itself is not explosive or toxic.

THE GAS IS ALSO NOT BREATHABLE OXYGEN and it will PUSH OXYGEN AWAY and CREATE AN ASPHYXIATION RISK.

The video at https://www.youtube.com/watch?
V=gtS8IVVCmis&pp=ygUJc3RvcCBiY2hk clearly
890
shows a 20-foot liquid nitrogen tank (about 6,000 gallons) rupturing, sending shrapnel and a non-breathable cloud of nitrogen across hundreds of feet.

The proposed tanks are twice as large with twice the metal and gas. Further, some of the tanks are argon, which is heavier than oxygen, and won't just reduce the amount of oxygen for residents to breath - it will eliminate the oxygen entirely causing asphyxiation.

The cause of the explosion in the video was the failure of the required safety systems to function. So obviously, the risks of Impulse's four, 12,000 gallon,
38-foot tall tanks are very real and a single Impulse proposed tank will have twice the blast zone and gas release as the video's 20-foot tank.

We DEMAND SAFETY first, for our health utmost priority. As well traffic, noise pollution and overall welfare of the community!!
If any of you want to reach out to me feel free! As I have been dealing with Impulse Space on my own. At times with joint effort of neighbors involvement too. We sought out help from Scott Behrendt our D5 representative as well as Joy Ford and other staff with in City of Redondo Beach, but nothing ever came of it.

Sincerely,
Alicia Evans
D5 Resident & Oppose Impulse Space 40 foot Cyro tanks
Sent from my iPhone
891
PUBLIC COMMENT 13 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Katherine

ORIGINAL SENT
Wednesday, September 16, 2026 at 8:59 AM

SUBJECT
URGENT: Public Comment Opposition to Project
2026-0595 - September 17 Meeting
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
892
You don't often get email from Learn why this is important From: Khatirah Nazif
To: Jamaal Brown; Sean Scully; Daisy Canales
Cc: Emily Bodkin
Subject: FW: URGENT: Public Comment Opposition to Project 2026-0595 (Impulse Space) – September 17 Meeting Date: Wednesday, September 16, 2026 11:48:21 AM
From: Katherine
Sent: Wednesday, September 16, 2026 8:59 AM
To: Planning Redondo <[email protected]>; CityClerk <[email protected]>; Eleanor Manzano <[email protected]>; Sean Scully <[email protected]>; Scott Behrendt <[email protected]>; Daisy Canales <[email protected]>; Lorena Soules <[email protected]>; Stephanie Johnson <[email protected]> Cc: Bill Brand <[email protected]>
Subject: URGENT: Public Comment Opposition to Project 2026-0595 (Impulse Space) – September 17 Meeting
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Date: September 16, 2026
To: Redondo Beach Planning Commission
From: Redondo Beach Resident & Coalition of Concerned Neighbors (District 5) Subject: URGENT: Public Comment Opposition to Project 2026-0595 (Impulse Space) – September 17 Meeting
Dear Honorable Commissioners
I am writing to register my absolute and unyielding opposition to Project 2026-0595, which proposes the installation of four outdoor cryogenic storage tanks by Impulse Space at 2477 Manhattan Beach Boulevard. Although I am currently out of town and unable to attend tomorrow’s September 17 meeting in person, this letter stands as a formal request to deny this hazardous project.

The proximity of these 38-foot-tall high-pressure tanks—sitting a mere 200 yards from our residential doorsteps, bedrooms, and families—poses an unacceptable risk to our community. This proposal bypasses critical local protections and introduces severe zoning, safety, and environmental hazards that have not been adequately mitigated:

1. Zoning and Height Violations: The proposed 38-foot height of these tanks severely violates local industrial-residential setback limits and height restrictions designed to protect adjacent neighborhoods. Granting relief for industrial vessels of this massive scale directly adjacent to homes sets a 893
dangerous land-use precedent.

2. Catastrophic Life-Safety Hazards & Historical Precedents: Cryogenic infrastructure is inherently volatile. Recent catastrophic cryogenic liquid nitrogen and gas system failures in states like Georgia and Texas have led to horrific workplace fatalities, rapid asphyxiation clouds, and explosive overpressurization events that leveled surrounding structures. If these tanks leak or explode, people will die—including neighboring families and Impulse Space's own on-site employees.

3. Seismic Vulnerability: Our area is highly susceptible to seismic activity. The city must not approve bulk liquid industrial storage of this magnitude without a transparent, independent Seismic Bracing Audit made available for public review.

4. Environmental and Operational Disruptions: Routine atmospheric venting, highpressure deliveries, and heavy truck traffic will generate ongoing noise pollution and severe light trespass. Furthermore, localized marine layer wind patterns mean that any toxic or asphyxiating vapor clouds will directly pool into residential areas.

Because the current application lacks rigorous, independent oversight, I formally request that the Planning Commission deny this project entirely or issue an indefinite continuance. The city must legally bind and enforce the following conditions before any approvals are considered:

Quantitative Risk Assessment (QRA): Require a comprehensive, independent analysis to model blast and asphyxiation zones.

Fixed Residential Setback: Establish a strict, non-negotiable surveyed setback distance from the residential property line.

Live Public Telemetry: Mandate continuous real-time oxygen and gas monitoring with a live, publicly accessible dashboard.

Enforceable Operational Limits: Set strict decibel limits on routine nighttime venting and delivery operations.

Your primary duty is to protect the safety and zoning integrity of Redondo Beach residents, not to accommodate high-risk aerospace infrastructure at the expense of human lives. We do not want these tanks placed here.

Respectfully submitted,
Katherine Strohlein
2402 Sebald Ave. / District 5
894
PUBLIC COMMENT 14 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Janet Scully

ORIGINAL SENT
Wednesday, September 16, 2026 at 4:31 PM

SUBJECT
Public Comment on Agenda Item K.1.

PC26-1164/Resolution No. 2026-09-PCR-11
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
895
You don't often get email from Learn why this is important From: Daniel Besinaiz
To: Jamaal Brown
Subject: FW: Public Comment on Agenda Item K.1. PC26-1164/Resolution No 2026-09-PCR-11 (Impulse) Date: Tuesday, September 22, 2026 7:28:01 AM
Attachments: image001.png
Hi Jamaal,
This is also a public comment for last week's PC meeting. The height variance for impulse.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).

From: Khatirah Nazif <[email protected]>
Sent: Monday, September 21, 2026 2:28 PM
To: Daniel Besinaiz <[email protected]>
Subject: FW: Public Comment on Agenda Item K.1. PC26-1164/Resolution No 2026-09-PCR-11 (Impulse)
Final one, thanks!
From: Janet Scully
Sent: Wednesday, September 16, 2026 4:31 PM
To: Khatirah Nazif <[email protected]>; Daniel Besinaiz <[email protected]>; CityClerk <[email protected]>
Subject: Public Comment on Agenda Item K.1. PC26-1164/Resolution No 2026-09-PCR-11 (Impulse) CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good Afternoon,
896
I am writing to strongly oppose the request by Impulse Space for a variance to install tanks taller than the allowed 30-foot limit.

Taller tanks would compromise the residential character of our neighborhood, making it look like an industrial park, and pose potential safety hazards.

Additionally, I request the following measures to protect our community:
- Hours of Operation: Limit tank refueling to Monday through Friday, between 8:00 AM and 5:00 PM.
- Safety Review: Provide residents the opportunity to review the site-specific Community Emergency Prevention and Mitigation Plan to ensure community safety is prioritized.

Thank you for the opportunity to comment. As a North Redondo Beach resident in District 5 for over 30 years, preserving the safety and character of our neighborhood is deeply important to me.

Sincerely,
Janet Scully
Burritt Ave., Redondo Beach
897
PUBLIC COMMENT 15 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Nick Biro

ORIGINAL SENT
Thursday, September 17, 2026 at 8:13 AM

SUBJECT
Re: PC Agenda Item 2026-0595
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
898
From: Daniel Besinaiz
To: Jamaal Brown
Subject: FW: PC Agenda Item 2026-0595
Date: Thursday, September 17, 2026 10:59:35 AM
Attachments: Cryogenic_Tank_Refilling_Noise_Impact_Assessment.pdf image001.png
Hi Jamaal,
Public comment #2 for variance item tonight.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).

From: Nick Biro
Sent: Thursday, September 17, 2026 8:13 AM
To: Khatirah Nazif <[email protected]>; CityClerk <[email protected]>; Daniel Besinaiz <[email protected]>; Marc Wiener <[email protected]> Subject: Re: PC Agenda Item 2026-0595
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good morning,
I would like to submit the attached Noise Assessment in reference to Agenda Item K.1 PC26-1164 and its impact to adjacent R1 residential uses. If the proper noise attenuation and controls are not implemented this operation will exceed the residential noise level limits.

Redondo Beach Municipal Code Standards
899
RBMC Section 4-24.301 applies the higher of the presumed ambient level or the measured ambient level at the receiving property. The presumed exterior limits are shown below.

Receiving District 7 AM to 10 PM 10 PM to 7 AM
Low Density Residential R-1-A R-1 R-2 50 dBA 45 dBA
Medium Density Residential R-3 R-4 55 dBA 50 dBA
High Density Residential R-5 R-6 60 dBA 55 dBA
For a low-density residential receptor with a 50 dBA daytime standard, Section 4-24.301 applies the following time-based allowances. The limits become 5 dB more restrictive if the sound contains a steady audible tone or qualifies as repetitive noise. At a boundary between two land-use categories, the lower category plus 5 dB applies. A higher measured ambient may also increase the applicable standard in 5 dB increments.

Cumulative Duration in One Hour Maximum Daytime Level
More than 30 minutes 50 dBA
More than 15 minutes 55 dBA
More than 5 minutes 60 dBA
More than 1 minute 65 dBA
Any duration 70 dBA
Under Section 4-24.201, exterior measurements are taken at the affected property line closest to the source or where the sound is greatest, generally with the microphone five feet above the ground and away from reflective surfaces. Interior residential standards under Section 4-24.401 are 45 dBA during the day and 40 dBA at night, with windows in their normal seasonal configuration. Section 4-

24.504 separately prohibits perceptible vibration at or beyond the source property boundary.

Estimated Propagation Toward Residences
The following screening calculation assumes an unobstructed point source and 6 dBA reduction for each doubling of distance. It does not include barrier shielding, ground absorption, building reflections, wind, elevated vents, simultaneous sources, or existing traffic noise.

Level at 50 Feet At 200 Feet At 300 Feet At 400 Feet
75 dBA 63 dBA 59 dBA 57 dBA
80 dBA 68 dBA 64 dBA 62 dBA
85 dBA 73 dBA 69 dBA 67 dBA
At an assumed 300-foot separation, a 75 dBA source at 50 feet would reach approximately 59 dBA; an 80 dBA source would reach approximately 64 dBA; and an 85 dBA source would reach approximately 69 dBA. The exact distance from each truck, pump and vent to the closest residential property line must be taken from the final site plan.

Source at 50 Feet Distance to 60 dBA Distance to 55 dBA Distance to 50 dBA 75 dBA 281 feet 500 feet 889 feet
80 dBA 500 feet 889 feet 1,581 feet
85 dBA 889 feet 1,581 feet 2,812 feet
900
Compliance Assessment at Approximately 300 Feet
·For a transfer lasting more than 30 minutes, all three screening cases would exceed a 50 dBA daytime low-density residential standard.
·
For a transfer lasting more than 15 minutes, all three cases would exceed the 55 dBA allowance.
·
For a transfer lasting between 5 and 15 minutes, the 80 and 85 dBA cases would exceed the 60 dBA allowance.
·
A tonal pump, whine, hum or repetitive sound could lower the applicable limits by 5 dB. ·
Nighttime standards are 5 dB lower, making off-hour filling or deliveries significantly more difficult to accommodate.

A solid barrier may provide approximately 5 to 10 dB of practical reduction when it fully blocks the line of sight between a ground-level source and receiver. A perimeter wall may therefore help with a truck or pump near grade. It may provide little protection from an elevated vent associated with a 38- foot tank unless the barrier design specifically addresses the vent's height and orientation.

Assessment of the Proposed Resolution
The revised draft resolution improves the proposal by requiring vent silencers, limiting deliveries generally to business hours, and requiring a noise report addressing delivery, filling and venting.

These conditions acknowledge that tank-related operations may create a neighborhood noise impact.

The conditions remain incomplete because they do not clearly require the acoustical study before permits or operation, establish the duration and hours to be tested, identify the nearest residential receptors, require actual manufacturer data, define a mandatory pass-fail standard, or require postinstallation testing during a complete delivery. The resolution also allows unspecified off-hour deliveries as a minor administrative change and allows mitigation to occur after a measured violation.

Recommended Conditions
·Require a qualified acoustical consultant to complete the study before installation permits or operation.
·
Use the final site plan and actual manufacturer sound data for the truck, PTO, pumps, valves, vents, silencers and alarms.
·
Measure and model truck arrival, backing, high-idle operation, pumping, filling, pressure equalization, venting, hose clearing, disconnect and emergency relief events. ·
Evaluate the complete operating cycle and cumulative duration, not merely a short spot measurement.
·
Measure existing ambient sound and evaluate every nearest residential property line and representative dwelling interior.
·
Account for elevated vent locations, tonal or repetitive corrections, simultaneous equipment, nighttime limits and downwind propagation.
·
Prohibit routine deliveries, filling and planned venting outside enforceable weekday daytime hours.
·
Require silencers, barriers, equipment enclosures and vibration isolation necessary to demonstrate compliance before operation.
901
·
Require post-installation testing during an actual full delivery and establish a prompt corrective-action and enforcement procedure.

Overall Finding
The available record does not demonstrate that nitrogen and argon refilling will comply with the Redondo Beach Noise Regulation at adjacent residences. The preliminary calculations show a credible potential for exceedances at approximately 300 feet, particularly for transfer operations lasting more than 15 minutes. Noise compliance should be demonstrated prospectively through a site-specific acoustical study and enforceable operating conditions, rather than determined only after residents experience a violation.

Thanks,
Nick
2423 Sebald Ave.

Redondo Beach, CA 90278
On Wed, Aug 19, 2026 at 1:30 PM wrote:

Hi Khatirah,
Thank you for your response. I was able to locate the email verification response in my Junk folder and I have loaded my e-comment.

Thanks,
Nick
2423 Sebald Ave.

Redondo Beach, CA. 90278
Sent from my iPhone
> On Aug 19, 2026, at 10:43 AM, Khatirah Nazif <[email protected]> wrote:
>
> Hi Nicholas,
>
> I am sorry to hear you are having trouble submitting an eComment. I reached out to our Support and they advised checking your spam/mail inbox first to make sure the email didn't go there. Also, please whitelist the email address and then request the verification email once more.
>
> Please let me know if this works.
>
902
> Thank you,
>
> Khatirah Nazif
> City Clerk's Office
> 310.318.0656 ext. 3175
> [email protected]
>
> -----Original Message-----
> From:
> Sent: Tuesday, August 18, 2026 11:26 AM
> To: Daniel Besinaiz <[email protected]>
> Cc: Sean Scully <[email protected]>; Marc Wiener <[email protected]>; Rox Ferebee
> Subject: PC Agenda Item 2026-0595
>
> [You don't often get email from Learn why this is
important at https://aka.ms/LearnAboutSenderIdentification ] >
> CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
>
> Good morning Daniel,
>
> I am trying to post an e-comment for the subject agenda item and I have not received the email authentication required to confirm my account in order to submit the comments.
>
> Could you please let me know if there is an issue with the system or can you help me with creating an account?
>
> Thanks,
>
> Nick
> Sent from my iPhone
> Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email.
903
--
Nicholas J. Biro
904
PUBLIC COMMENT 16 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Erica Davis

ORIGINAL SENT
Thursday, September 17, 2026 at 9:39 AM

SUBJECT
IMPULSE: OPPOSE
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
905
From: Daniel Besinaiz
To: Jamaal Brown
Subject: FW: IMPULSE: OPPOSE
Date: Tuesday, September 22, 2026 7:27:40 AM
Hi Jamaal,
This is a public comment for last week's PC meeting. The height variance for impulse.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
-----Original Message-----
From: Khatirah Nazif <[email protected]>
Sent: Monday, September 21, 2026 2:27 PM
To: Daniel Besinaiz <[email protected]>
Subject: FW: IMPULSE: OPPOSE
Hi! Just wanted to make sure this got included in the Planning Commission public comments -----Original Mess
From: Erica Davis
Sent: Thursday, Se
To: CityClerk <[email protected]>
Cc: Daniel Besinaiz <[email protected]>; Khatirah Nazif <[email protected]> Subject: IMPULSE: OPPOSE
[You don't often get email from Learn why this is important at https://aka.ms/LearnAboutSend
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello,
I am opposed to the height variance request and ask the commission to please deny the request until the concerns of the commissioners and residents have been properly addressed.

Residents should not be required to accept permanent impacts first and seek solutions later.

This is more than a request to place equipment above the normal height limit . It is a land use decision affecting families living near the site. A variance is discretionary and should only be granted when the complete plans, noise and visual studies, written fire approval, enforceable operating and delivery hours, and meaningful neighborhood protections are presented publicly.

Residents are concerned about unknown gas deliveries, truck traffic, refilling, venting, alarms, maintenance and recurring noise.

Residents have already been experiencing ongoing construction violations and operations and 100's of Impulse employees parking in the neighborhood, with minimal enforcement from the city or Impulse. 906
These effects should be independently studied before approval, not after the tanks are installed and operations begin.

The safety presentation describes general practices but does not provide enough site-specific information to give adjacent residents confidence.

Questions remain about the exact tank locations, gas being used, distances from homes, emergency access, response procedures, coordinations with local fire officials.

The wrong address, references to different stored products, blank fields and lack of signatures further weaken confidence in the submission.

Four approx 40foot Large tanks at the proposed height would be highly visible from homes, yards and streets. They would become a permanent feature without a complete site plan or visual study showing effective screening and compatibility with the neighborhood.

We accept Impulse Space as our new neighbor, but not at the expense of deteriorating our neighborhood and our quality of life.

Our SAFETY is paramount and the city and Impulse Space should ensure they are willing to follow the requested guidelines and stop ignoring our requests and work with the community.

Thank you,
Erica Sheerin Davis
907
PUBLIC COMMENT 17 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
G. P. Suddeth

ORIGINAL SENT
Thursday, September 17, 2026 at 10:03 AM

SUBJECT
Impulse height variance request
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
908
You don't often get email from Learn why this is important From: Daniel Besinaiz
To: Jamaal Brown
Subject: FW: Impulse height variance request
Date: Thursday, September 17, 2026 10:56:57 AM
Attachments: image001.png
Hi Jamaal,
Public comment #4 for variance item tonight.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).

From: G P Suddeth
Sent: Thursday, September 17, 2026 10:03 AM
To: Daniel Besinaiz <[email protected]>
Cc: CityClerk <[email protected]>
Subject: Impulse height variance request
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Regarding Impuse request:

We in the neighborhood nearest to the Impulse location have received a woeful lack of outreach from Impulse. This request has not been sufficiently explained to merit forwarding to the city council.

G P Suddeth
909
PUBLIC COMMENT 18 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, September 17, 2026 at 3:33 PM

SUBJECT
Blue Folder Item - Planning Commission
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
910
From: Sean Scully
To: Jamaal Brown
Subject: FW: Blue Folder Item - Planning Commission
Date: Thursday, September 17, 2026 3:36:21 PM
Here’s another to add to the K.1. item
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Thursday, September 17, 2026 3:33 PM
To: CityClerk <[email protected]>; Sean Scully <[email protected]>; Wayne Craig <[email protected]>; Mike Witzansky <[email protected]>; Scott Behrendt <[email protected]>; Garth Meyer
Subject: Blue Folder Item - Planning Commission
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Planning Commission - DENY Variance for 2477 Manhattan Beach Blvd Liquid Nitrogen and Argon Tanks
The City staff report is substandard and inaccurate. Diagrams lack customary and required markings. The wrong emergency plan and standard is used - and in fact the standard itself (U.S. DOT/PHMSA 2024 Emergency Response Guidebook (ERG 2024)) states that it is intended only for use in “the initial phase of a transportation incident involving hazardous materials/dangerous goods.” In other words, this is a transportoriented emergency-response document — not a stationary bulk-storage emergency plan. City Staff, perhaps City Fire, and Impulse are all citing incorrect references in this Planning Commission report. It is defective and without oversight. This is a fixed, nearly 50,000 gallon total array of asphyxiating gasses with ample range to snuff out surrouding lives in a rupture, as well as catapult a ton of steel shrapnel.

Further, the draft ordinance itself contains inaccuracies, such as a finding of significance in transport of gas refilling by using 20-foot vs 38-foot tanks. There's no accurate statement of WHAT is significant, nor is there any work paper or reference to Staff or Consultant work. In essence, City Staff MADE UP results, published them in the Ordinance, and recommends approval based on at best substandard work and at worst, inaccurate work.
911

CITY OF REDONDO BEACH OCTOBER CITY COUNCIL APPEAL
City Council Appeal Public
Comments
October 2026 Appeal Record
2477 Manhattan Beach Boulevard - Case No. 2026-0595

PUBLIC COMMENT COMPILATION
11 distinct email submissions
Original public-sender dates: September 24 - September 29, 2026 Emails are arranged by the original public sender's date and time. Non-government email addresses and personal phone numbers are permanently redacted. 2477 Manhattan Beach Boulevard Case No. 2026-0595
912
PUBLIC COMMENT 01 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, September 24, 2026 at 8:02 AM

SUBJECT
Public Comment: The City needs to integrate resident
safety into the permitting process

SUPPORTING MATERIALS INCLUDED
- 2477 Manhattan Beach Blvd - Cryogenic Tank Failure Analysis - Public Comment The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
913
From: Mark Nelson (Home Gmail)
To: CityClerk; Mike Witzansky; Joy Ford; Sean Scully; Scott Behrendt; Andrew Winje; Marc Wiener; Gale S. Hazeltine; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Julie Young; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Nick Biro; Zein Obagi Subject: Public Comment: The City needs to integrate resident safety into the permitting process Date: Thursday, September 24, 2026 8:02:58 AM
Attachments: 2477 Manhattan Beach Blvd - Cryogenic Tank Failure Analysis - Public Comment.pdf CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

As most of you will recall from reading public comments, there's been no safety analysis conducted regarding the tanks proposed at Impulse Space. No safety for 20-foot tanks, or 30- foot tanks or the 38-foot "variance" tanks. The now RBFD fire chief pointed at LACoFD to do conduct that analysis because RBFD doesn't have HAZMAT. I wrote LACoFD and they wrote back and UNEQUIVOCALLY stated that the City Planning Department and RBFD needed to conduct the safety analysis before permitting. LACoFD offered to help the City.

I pulled a few strings at the government based on my NSF committee service. I now possess the federally chartered suite of gas dispersion models, along with simulated 38-foot, 12,000 gallon argon tanks at 2477 Manhattan Beach Blvd. I was trained in model use today, and ran the analysis. Little surprise to me, there's a zone of potentially fatal impacts on a nice, normal Redondo Beach day if one tank has a catastrophic rupture. Given a 2x2 tank array, I'd suspect ruptures might come in pairs, but I ignored that.

The attached memo outlines the hazard on an average day and on the federally specified worst-case day. It seems intuitively obvious from the modeling results that safety analysis should have been conducted prior to any permit approval.

This is a safety issue and not explicitly part of the variance issue, other than for the failure by the City to conduct that safety analysis when it processed the applicant's plan. Nonetheless, now that it's been demonstrated using EPA and NOAA certified gas plume models that there is a safety issue, it needs to be dealt with prior to any variance - because you cannot issue a variance to an unsafe base project that has had poor City processing and lacks basic safety analysis.

See attached.
914