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Page 1 of 2 <br /> Jennifer Frase [EH] <br /> From: Spreadborough, Allison [aspreadborough@CIWMB.ca.gov] <br /> Sent: Thursday, February 21, 2008 7:14 AM <br /> To: Jennifer Frase [EH] <br /> Cc: Cambridge, Keith <br /> Subject: FW: Ameron Pipe Group-TPID#1370161 <br /> Attachments: Common CarrierDraftl1.doc <br /> Hi Jenni, thanks for your e-mail message. Your information is correct. It does not appear that Ameron <br /> International Pipe Group is transporting the tires to an end use but are using the tires "beneficially" for <br /> cushioning during the transport of cement pipe. This activity is proposed as a new exemption in the <br /> latest draft version of the regulations. As such, please hold off any enforcement of this activity at this <br /> time. <br /> Please refer to the attached copy of the draft proposed regulations under Sections 18451 (e), and 18453.2 <br /> (d). In addition, your input on the draft regulations would be greatly appreciated. <br /> Sincerely, <br /> Allison Spreadborough <br /> Tire Hauler Compliance Section <br /> Compliance Evaluation and Enforcement Division <br /> Waste Compliance and Mitigation Program <br /> California Integrated Waste Management Board <br /> 1001 1 Street <br /> P.O. Box 4025 <br /> Sacramento, CA 95812-4025 <br /> Phone: (916) 324-9609/Fax: (916) 319-7617 <br /> E-mail: aspreadb@ciwmb.ca.gov <br /> Reduce, Reuse, Recycle, Re-Buy (close the loop) <br /> From: Jennifer Frase [EH] [mailto:jfrase@sjcehd.com] <br /> Sent: Wednesday, February 20, 2008 1:48 PM <br /> To: Spreadborough, Allison <br /> Cc: Cambridge, Keith; Robert McClellon [EH]; Michael Kith [EH] <br /> Subject: Ameron Pipe Group-TPID#1370161 <br /> Hi Allison, <br /> It is my understanding that the regulations regarding Beneficial Reuse for Waste and Used Tires are being <br /> revised. This site, Ameron International Pipe Group, is currently in violation for transport of used and waste tires, <br /> PRC§ 42951. They have been using tires as bumpers underneath large pieces of cement pipe for transport <br /> purposes and then returning the tires as dunnage to their site for re-use in the same manner. As of September 12, <br /> 2007 an extension was requested and granted in order to apply for a re-use exemption. A letter dated September <br /> 17, 2007 was written from Ameron to CIWMB to apply for a re-use exemption. At time of re-inspection dated <br /> November 30, 2007 no exemption had been issued or denied. Thus, the facility is still in violation. <br /> Your last voice message informed me that these regulations are currently in revision and that as LEA we can hold <br /> off on persuing violation enforcement. Please confirm for our records that this information has been understood <br /> 2/21/2008 <br />