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40 so <br /> TUFF BOY SALES, INC. <br /> 3870 W. YOSEMITE AVE. • LATHROP, CA 95330 • (209) 858-4131 • FAX (209) 858-2835 <br /> July 23, 2010 IN �9 10 ®HVED <br /> Ben Escotto JUL 2 6 2010 <br /> San Joaquin County Environmental Health Dept. ENVIRU1+ 1I NT HEALTH <br /> 600 E. Main St. PERMIT/SERVICES <br /> Stockton, CA 95202 <br /> Re: Mr. Escotto's visit to the Tuff Boy Sales facility on July 15, 2010 <br /> Dear Mr Escotto, <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 companies 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 <br /> enforced by the State of California, are "waste tires". <br /> As you are aware, Tuff Boy Sales, Inc. is a trailer manufacturing, sales and maintenance <br /> company with two locations in San Joaquin County. <br /> One major aspect of Tuff Boy Sales, Inc's. operation is to perform maintenance inspections and <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 />