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6. New retreaded tires that have not been used since undergoing the retreading process are considered new tires. Tuff Boy will be allowed to store such tires in an unlimited quantity with no limitation on storage requirements. 7. Tuff Boy can store new tires in any way Tuff Boy sees fit. This includes storing new tires in an enclosed portable over-the-road-highway van trailer. 8. Tuff Boy will be allowed to stack"maintenance ready used tires"in rows that are not more than two rows wide in over-the-road-highway trailers. However, in order for such tires to not be counted as part of the 1,500 waste tire limit, (1)the tires must stacked as just described and(2) be ready for resale which includes having the trailer being easily accessible, having sufficient lighting for inspection of each tire, and having a safe method of access and egress during normal business hours. 9. The EHD has the understanding that Tuff Boy Trailer Sales Inc. sells tires as a normal part of their business. That is why the classification of"tire dealer"most appropriately fits the business operation of Tuff Boy as it pertains to tires. 10. A"tire dealer" is a classification that exempts a facility from obtaining a Waste Tire Facility Permit. Under this classification, a facility is allowed up to 1,500 waste tires on-site. However if a facility has more than 1,500 waste tires on-site,the facility will be given a violation and a compliance deadline to either bring the number of waste tires down to under 1,500 or obtain a Waste Tire Facility Permit. 11. The number of documented tires that are hauled between facilities will not be double or triple counted. Only waste tires on-site will be counted. The waste tire manifesting system is for tracking the movement of waste tires and does not affect the counting of tires onsite. It will allow Calrecycle and the EHD staff to determine tire movements and final deposition of tires coming and going from the site. 12. All used and waste tires transported over the road in registered waste tire hauling vehicles must be documented by filling out waste tire manifests (Title 14 Section 18459). The definition of a used tire includes "maintenance ready used tires" and do not have a separate designation on the manifest. 13.As stated in response#12, "maintenance ready used tires" do not have a separate designation on waste tire manifests. 14. "Maintenance ready used tires"are classified as used tires. Such tires, when delivered to customer locations in quantities of 10 or more and/or using a registered waste tire hauling vehicle,must be documented by completing the waste tire manifest. 15. When hauling 9 waste tires or less, a registered waste tire hauling vehicle is not required. Bill of Ladings will be sufficient. However when hauling 10 waste tires or more, a registered waste tire hauling vehicle is required, complete with waste tire manifests. Also, when using a registered waste tire hauling vehicle to haul 9 waste tires or less, a waste tire manifest(s)must be filled out.