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:._... 1 7 4 Page 1 of 1 Robert McClellon [EH] From: Robert McClellon [EH] Sent: Monday, November 23, 2009 3:08 PM To: 'Motmans, Bill'; Strough, Barbara; Lee, Jim Cc: Donna Heran [EH]; Michael Kith [EH]; Benjamin Escotto [EH] Subject: Brannon Tire Inspection Reports till, I received your e-mail and would like to thank you for your advice. However, I would like to clarify a few points before the :HD submits any additional drafts, edits, or final inspection reports. Please note that I numbered the issues below so they can e referenced easily to reduce confusion. Advanced Equipment Sales does not have a business license to sell tires(only equipment sales) (see attached). San Joaquin County Code Enforcement informed me that they cannot store tires there without this license. Because the total tires on site are below 500, there will not be a violation noted on the inspection, but there should be an Area of Concern pursuant to T14 CCR 17225.820. The Brannon Fleet Tire retread facility does have a County business license and proper land use approvals. During the inspection, the Brannon Fleet Tire facility did not have any violations. The tire count for the facility was less than 3,000 waste tires. There were some tire casings and two full vans being shipped out that day (the vans are approximately 105 cubic yards each). I do not think that we should issue a violation for the facility. The field area North and adjacent to Brannon Fleet Tire does not have a County business license or land use approvals. The tires there could be counted as waste tires (some due to storage and some because of T14 CCR 17225.820). The EHD did not plan to advise Brannon Fleet Tire to obtain a TPID number for this area. This was done in the past at the direction of CIWMB for Brannon Fleet Tire at the adjacent Open Air Mall. It was very unsuccessful. Each time a tire moved between the Brannon Fleet Tire facility and the Open Air Mall it needed to be tracked. This became a paperwork nightmare and Brannon Tire agreed. Instead, the EHD plans to complete an inspection report and treat it as a complaint. Similar to when a pile of tires is discovered. Our office will generate a complaint, complete the inspection report, and will follow up to insure that the issue is resolved (business license and land use approval is obtained to allow the area to added to Brannon Fleet tire or the waste tires are removed from this area). If Brannon Fleet makes an application to amend the land use and obtains a business license within 30 days, the EHD will work with them on a time extension, should it be necessary. The inspection report for the Advanced Trailer Facility will be issued as no A/C's or Violations. 'lease review and comment. The issues at the Brannon sites are confusing because there are different sites, with similar ames and similar activities. I hope that the information provided here will help clarify the findings of the inspection and help irovide Mr. Brannon with clear guidance on how to maintain his facilities in compliance. I know the holidays are upon us, but I rould like to get the inspection reports to Mr. Brannon in a timely manner and would appreciate your expediency on this. you have any questions, please call me at 209-468-0332. :obert McClellon,Program Coordinator REHS ;nvironmental Health Department 00 E.Main Street tockton,CA 95202 209)468-0332