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California Environmental Protection Agency Edmund G.Brown Jr.,Govemor CalRecycle DEPARTMENT OF RESOURCES RECYCLING AND RECOVERY 1001 1 STREET,SACRAMENTO,CALIFORNIA 95814•WWW.CALRECYCLE.CA.GOV•(916)322-4027 P.O.BOX 4025,SACRAMENTO,CALIFORNIA 95812 March 2, 2015 Mark Hope Waste Recovery West Inc. P.O. Box 83328 Portland OR 97283 Subject: Rejection of Major Waste Tire Facilities Permit Application for Waste Recovery West, Inc., TPID No. 1608939, San Joaquin County Dear Mr. Hope-- Staff ope:Staff of the Department of Resources Recycling and Recovery (CalRecycle) have completed our review of the Major Waste Tire Facility application package received on February 3, 2015, for Waste Recovery West Inc. Department staff have determined that the application content does not conform to applicable requirements of Title 14, California Code of Regulations (CCR) 18431, and we are rejecting the application. The following comments describe the areas of deficiency that must be corrected prior to CalRecycle staff's approval of the application: • Submittal Letter—The submittal letter was unclear regarding whether there were no changes at the site or if an expansion was being requested. Staff conducted this application review for an expansion to "40,000 tires &4,000 tons TDP = 390,000 PTE's" from the current permitted amount of 40,000 PTE. Tire derived product (TDP), also described as tire derived aggregate (TDA) would make up the bulk of the amount of passenger tire equivalents (PTE) stored on site. The acronym 'TDF' is also used. What is TDF? • CalRecycle Form 500—Maximum capacity does not discuss tire shreds (shreds), though the closure cost worksheet allows for up to 650 tons of stored shreds. • CalRecycle Form 501 —Outdoor storage requirements— Describe all locations where tires are to be stored, including whole tires and shreds, not just the TDP piles. Please provide the calculations by which you are measuring density for the types of TDP/TDA that you will be storing. Form 501 refers to type 'A' or 'B' TDA. Please detail what these are. • CalRecycle Form 502 —The form does not mention an increased maximum permitted storage as a proposed change in design or operation from the current permit. • CalRecycle Form 503— Emergency Response Plan — Fire Approval. The approval provided by the French Camp McKinley Fire District dated February 6, 2015, approves the fire plan as submitted, but it is not clear that the approval included the outdoor storage area to the south. The Fire Approval should more clearly state that the approval would include the increased amount of tires and TDP being applied for. • CalRecycle form 504- Closure cost estimate worksheet. 1) As indicated above, the estimated calculations describe 650 tons of shreds not listed in the application. i WGIVAL PRRJTU�ON f M%A 7ST WNSL:MER I X)NTV-T.PR(ft'FJS l'HIt 1RINE FRE!P.APF.R