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o. Tuff Boy inquired whether, van storage would be classified as outdoor storage. <br /> SJCEHD indicated that van storage would be classified as outdoor storage. <br /> p. Tuff Boy asKed SJCEHD to define "Tires in Collection". SJCEHD indicated that ''Tires in <br /> Collection" would be defined as a van "full" of waste tires awaiting pick up. A partially <br /> filled van that tires are being added to, would be considered to be holding waste tires. <br /> Tires in Collection are not included in waste tire counts. SJCEHD indicated that the tires <br /> in collection should be picked up in a reasonable time. SJCEHD did not indicate what <br /> defines a reasonable time, but indicated that SJCEHD's decision would be reasonable in <br /> their assessment. <br /> q. Tuff Boy inquired about the number of times that tires could be picked up from a <br /> customer's address before a TPID site number would be required. SJCEHD indicated <br /> two times would be considered insignificant. but no definitive number was stated. <br /> Questions and Comments Relating to Tuff Boy's Original Letter Submitted on <br /> August 11, 2010. <br /> 1. Tuff Boy question submitted to SJCEHD on August 11, 2010. <br /> If Tuff Boy chooses to add a tire dealership category to its present business operation, <br /> would the Tuff Boy operations need to undergo any modifications to our facility to <br /> become compliant with SJCEHD? <br /> SJCEHD response to Tuff Boy on August 19, 2010. <br /> If Tuff Boy changes their category to a tire dealer, no physical modification to the facility <br /> would be required by the EHD. Tuff Boy would be allowed up to 1,500 waste tires on- <br /> site. <br /> Additional comments/questions by Tuff Boy submitted to SJCEHD on <br /> October 01, 2010: <br /> a. Title 14 Section 17350 indicates that for facilities storing 500 or more waste tires <br /> outdoors, compliance with Section 17351 through 17355 is mandatory. Based on <br /> current operating practices, it is Tuff Boy's intent riot to store over 500 true waste <br /> tires at any one time. <br /> Further comments based on discussion held on October 19, 2010. <br /> a. SJCEHD stated to Tuff Boy that no modifications were needed to the Tuff Boy <br /> facility resulting from the categorical addition of ti.,-e dealer. <br /> SJCEHD added that Tuff Boy could hold several waste tire handling <br /> classifications while operating under one permit. SJCEHD further added that <br /> SJCEHD had already added the tire dealer classification to the Tuff Boy operating <br /> permit <br /> 2. Tuff Boy question submitted to SJCEHD on August 11, 2010. <br /> As a tire dealer, is it accurate to expect that Tuff Boy will be allowed to loose bulk stack <br /> ''waste" tires in any manner up to a total amount of 1,500 tires at the Tuff Boy fac:iiity? <br /> SJCEHD response to Tuff Boy on August 19, 2010. <br /> Tuff Boy would be allowed to store up to 1,500 waste tires in any manner that Tuff Boy <br /> sees fit. However, if the number of stored waste tires exceed 500, the storage of the <br /> waste tires outdoors must be in compliance with the requirements under Title 14 Section <br /> 17354. <br /> Additional comments/questions by Tuff Boy submitted to SJCEHD on <br /> October 01, 2010: <br /> a. Does SJCEHD consider the storage of waste tires in iicensed roadable transportable <br /> enclosed van box trailers to be considered outdoor storage? <br /> 3 <br />