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Attachment 5 - Bulk Cryogenic Storage Tank Safety Compliance Presentation

Redondo Beach City Council
October 6, 2026

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Attachment 5 - Bulk Cryogenic Storage Tank Safety Compliance Presentation
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October 6, 2026
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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
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
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.

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.

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."
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
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
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
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
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.

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
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 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
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.

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.

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
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 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
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 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
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
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.

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
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
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
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
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
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 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 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:

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.

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