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b. Title 14 Section 17225.717 details conditions, whereby, waste tires temporarily <br /> stored in a license roadable transportable container that were not stored at a <br /> permitted waste tire facility are considered in the "collection" process. With this in <br /> mind, are tires stored in this manner exempted for storage requirements detailed in <br /> Title 14, chapter 3, article 5.5? Would these tires be exempted from the total number <br /> of waste tires stored? Are these tires subject to inspection when stored subject to <br /> the conditions of 17225.717? <br /> c. Does SJCEHD's August 19, 2010 response apply to Tuff Boy under it's current <br /> classification as a non-tire dealer? <br /> Further comments based on discussion held on October 19, 2010. <br /> a. SJCEHD stated that the storage of waste tires in a licensed roadable transportable <br /> enclosed van box trailer is considered outdoor storage. <br /> b. SJCEHD stated that tires in the "collection process" are exempted from the total <br /> number of waste tires stored. SJCEHD added that "Tires in Collection" would only <br /> qualify if the van is "full" of waste tires awaiting pick up. Additional details are stated <br /> in the "Discussion of Tuff Boy Goals" section of this letter. <br /> c. This item was not confirmed <br /> 3. 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 store an unlimited <br /> quantity of "maintenance ready used tires", provided those tires are barrel stacked or row <br /> stacked in a manner that allows for inspection from a minimum of one side? (see <br /> drawings 1 and 2 attached). <br /> SJCEHD response to Tuff Boy on August 19, 2010. <br /> Tuff Boy would be allowed to store an unlimited quantity of"maintenance ready used <br /> tires" so long as (1) the tires are stored in a rack or stack not more than two rows wide, <br /> but not in a pile, and stored in accordance with local fire and vector control requirements <br /> and with state minimum standards (T14CCR Section 17353 and 17354) and (2) stored in <br /> a manner to allow the inspection of each individual tire. These requirements are under <br /> PRC Section 42806.5. <br /> Additional comments/questions by Tuff Boy submitted to SJCEHD on <br /> October 01, 2010: <br /> a. As part of the August 11, 2010 letter submitted by Tuff Boy to SJCEHD, two (2) <br /> drawings were submitted showing the proposed method of storing "maintenance <br /> ready used tires". Is it SJCEHD'S opinion that either or both of those storage <br /> methods meet the storage requirements for "maintenance ready used tires" under <br /> the governing regulation standards (T14CCR Section 17353, 17354 and 17355)? <br /> Further comments based on discussion held on October 19, 2010. <br /> a. On August 11, 2010, Tuff Boy submitted two (2) drawings to SJCEHD demonstrating <br /> two (2) different methods of storing good useable tires. SJCEHD commented that <br /> the two(2) proposed methods of storing used tires are <br /> acceptable with certain limitations as detailed in the discussion of "Tuff Boy goals <br /> section" of this letter. SJCEHD added that Tuff Boy could not store over 500 good <br /> used tires in total combination with waste tires unless they were a tire dealer. <br /> 4. 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 store an unlimited <br /> quantity of new tires with no limitation on storage requirements? <br /> 4 <br />