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■ 07/23/2010 16;04 Tuf f Boy Sales Inc. Lathrop (FAX)209 858 2835 P.001/003 <br /> ■ <br /> %■ TUFF SOY SALES, 111 C. <br /> 3870 W. YOSEMITE AVE. + LATHROP, CA 95330 • (209) 838.4131 • FAX (208) 888.2835 <br /> July 23,2010 <br /> Ben Escotto <br /> San Joaquin County Environmental Health Dept. i <br /> I <br /> 600 E. Main St. <br /> Stockton,CA 95202 <br /> i <br /> Re: Mr. Escotto's visit to the Tuff Boy Sales facility on July 15, 2010 j <br /> I <br /> Dear Mr Escolto, <br /> i <br /> Thank you for your recent visit to our facility and for your continuing efforts to keep us informed <br /> about the changes and requirements of the California Department of Resources Recycling and <br /> Recovery (Cal Recycle) rules pertaining to waste tires. <br /> I appreciated the opportunity to share with you information about Tuff Boy Sales, Inc, and how <br /> the flawed definition of a "waste tire" creates an unfair operational burden to Tuff Boy and many <br /> other oompanles located In the county. <br /> Furthermore, Tuff Boy Sales, Inc, acknowledges, but disagrees with the San Joaquin County <br /> view that any previously used tires, although still legally usable under the rules and guidelines i <br /> enforced by the State of California, are "waste tires". <br /> As you are aware, Tuff Soy Sales, Inc. Is a trailer manufacturing, sales and maintenance <br /> company with two locations in San Joaquin County. <br /> I <br /> One major aspect of Tuff Boy Sales, Inc's, operation is to perform maintenance inspections and i <br /> repairs to trailer lease fleets totaling nearly 2,500 trailers. <br /> The maintenance activity Includes continued inspection and maintenance necessary to support <br /> maximizing the operational life expectancy of a tire. <br /> This Involves periodic removal, rotation and reinstallation of the entire mounted tire/wheel <br /> inventory existing on the fleets of trailers being maintained, <br /> To understand this process a little better; trailers are coupled in sets of two units. The coupling <br /> includes a front located semi trailer comprised of one axle with dual mounted tires on the right <br /> and left sides of each axle (four total tires mounted on wheels). The front semi trailer Is followed <br /> by a rear pull trailer which has two axles, each of which have dual mounted tires on the right <br /> and left side of each axle (eight total tires mounted on wheels). <br /> 1 <br />