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SEP-30-2010 15:31 T' ---: BOY TRAILERS 2092397026 P.05 a. As part of th ,f Boy letter sent to 5JULHU on Hugi i, "�u i u, two l/-1 ul awu iya were enclosed demonstrating the method of storage. u_ drawing shows an 18" aisle down the center of a portable over-the-road-highway van trailer to access and view the stored tires in the van. Will this method of storage satisfy the storage requirements as defined by T14CCR Sections 17353 and 17354? 9. Tuff Boy question submitted to SJCEHD on August 11, 2010. Since Tuff Boy does not expect to ever have over 250 true "waste" tires staged for disposal on site at any one time, is there any other business designation that might more appropriately fit Tuff Boy's business operation rather than the "tire dealer category" proposed by SHCEHD? SJCEDH response to Tuff Boy on August 19, 2010. The EHD has the understanding that Tuff Boy Trailer Sales Inc. sells tire 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. Additional comments/questions by Tuff Boy submitted to SJCEHD on October 01, 2010: a. Although Tuff Boy does indeed sell tires as part of its normal business, it is not the primary part of its business. It may be important to note that the majority portion of the "maintenance ready used tires" anticipated to be stored on site are not available for sale- In fact, a significant quantity of"maintenance ready used tires" will be kept on hand and serve as the rotating service inventory for customer-owned trailer fleets totaling 2,500 trailers and under contract with Tuff Boy to maintain. b. SJCEHD should understand that Tuff Boy sells 95% plus to one customer and has no retail facility or plans for retail facility. 10.Tuff Boy question submitted to SJCEHD on August 11, 2010. Will a change in how SJCEHD views Tuff Boy's business type, resulting from an additional categorical change as a tire dealer, create a situation that might cause additional use permit requirements or any other additional permit requirements to be mandated to Tuff Boy? SJCEDH response to Tuff Boy on August 19, 2010, 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. Additional comments/questions by Tuff Boy submitted to SJCEHD on October 01, 2010: a. The SJCEHD does not address the important question of use permit or other permits needed or that will be required. The question presented is simply not answered or even responded to! 11.Tuff Boy question submitted to SJCEHD on august 11, 2010. Should Tuff Boy be concerned about the potential to double or triple count the actual number of documented tires that are hauled between facilities, with the affect of skewing the total number of waste tires handled? SJCEDH response to Tuff Boy on August 19, 2010. The number 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. 4