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• Further questions a • <br /> 11. Should Tuff Boy be concerned about the potential to double or triple count the actual <br /> number of documented tires that are hauled between facilities, with the affect of skewing <br /> the total number of waste tires handled? <br /> 12. Should Tuff Boy provide a separate designation on the waste tire manifest for <br /> "maintenance ready used tires" versus true waste tires transported over the road? <br /> 13. Where should this information appear on the manifest and how would the separate <br /> classification affect an audit of manifest records? <br /> Furthermore, as a dealer, for Tuff Boy to transport "maintenance ready used tires" raises further <br /> questions about ultimate delivery sites. <br /> 14. How should Tuff Boy document trucking activity when delivering "maintenance ready <br /> used tires" for sale and reinstallation at a customer's {ovation? <br /> 15. Is Tuff Boy required to utilize a registered waste hauling truck complete with manifest <br /> documents in place when hauling nine true waste tires or less? <br /> 1b. How should a comoination of;rue waste tires and repairable/reusable tires be <br /> designated on a manifest? <br /> 17. If Tuff Boy delivers only "maintenance ready used tires" to a customer site, does the <br /> customer need to be registered with the State? <br /> 18. Does Tuff Boy need to maintain any manifest when it is hauling reusable tires? <br /> 19. Does the truck hauling "maintenance ready used tires" need to be registered as a waste <br /> hauling vehicle? <br /> 20. Is a manifest even required when hauling "maintenance ready used tires"? <br /> 21. For off-road-field harvest equipment (field dollies) utilizing used tires with as little as <br /> 3/32" tread depth, is it possible for Tuff Boy to classify their existing loose "field only use" <br /> tire inventory in such a way that will allow for hauling 'spare tires exempt from waste tire <br /> manifest requirements? <br /> 22. Are both the California Highway Patrol and the California Department of Transportation <br /> rules consistent with Cal Recycle rules in terms of waste tire designation, hauling and <br /> manifest requirements? <br /> 23. As a tire dealer, how often can Tuff Boy expect the SJCEHD to conduct an inspection of <br /> the Tuff Boy facility? <br /> 24. What event or situation might cause Tuff Boy to be responsible for billing charges from <br /> SJCEHD (as per county office posting showing a billing rate of $122.00 per hour)? <br /> 25. Is it unreasonable for Tuff Boy to expect that SJCEHD will allow a reasonable amount of <br /> time to achieve meaningful compliance while both parties work through the issues <br /> brought forth in this letter? <br /> In closing, Tuff Boy requests SJCEHD'S assistance in determining the best approach as Tuff <br /> Boy attempts to navigate its way through what seems to be very costly and burdensome waste <br /> tire compliance issues. <br /> Thank you for your attention to this matter. <br /> Very truly yours, <br /> TUFF BOY SALES, INC. <br /> fT�j <br /> Bryce Perkins <br /> Encls: <br /> cc: Michael Babitzke, Esquire <br /> BP:MH:yw <br /> 3 <br />