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AUG-11-2010 14:27 Tl":F BOY TRAILERS 2092397086 P.02i06 TUFF BOY SALES, INC. 3870 W. YOSEMITE AVE. • LATHROP, CA 95330 • (209) 858-4131 • FAX (209) 858-2835 August 11, 2010 Ben Escotto San Joaquin County Environmental Health Dept, 600 E. Main St. Stockton, CA 95202 Re: Tire Inventory Dear Mr. Escotto, Thank you for taking the time to meet with Martin Harris and myself on July 28, 2010. Additionally I appreciate you arranging for your supervisor, Robert McClellon, and your colleague, Alfonso, to join us in the meeting. As you are aware, the purpose of our meeting was to discuss the results of your recent inspection of our facility, and to allow your office to inform Tuff Boy as to the different ways that Tuff Boy can operate within the waste tire rules set forth by the California Department of Resources Recycling and Recovery (Cal Recycle), as well as operation within the enforcement of those rules by SJCEHD. The meeting further allowed for an exchange of information that hopefully will lead to a better understanding by SJCEHD of the tire maintenance activities relating to the seasonal operations of Tuff Boy and the various trailer fleets serviced by Tuff Boy. Over the course of the meeting, Tuff Boy was given the opporfunity to explain how a "flawed" waste tire definition and the associated compliance requirements enforced by SJCEHD, were creating a costly and unfair burden to the Tuff Boy operation, Mr. McClellon, representing SJCHED, was most understanding'of Tuff Boy's concerns relating to their tire operation and offered that the intent of the law was not meant to entrap businesses exhibiting proper waste tire disposal practices, but was meant to allow for broad enough rules to aid enforcement actions against individuals accumulating or improperly disposing of waste tires. Tuff Boy proceeded to seek confirmation on their understanding that Tuff Boys' present designation as a minor waste tire generator allows for 500 waste tires to be stored on its property. Within this designation, SJCHED includes all tires previously used on a vehicle, including good-used-federally-approved for highway service tires that are mounted on a rim and ready for reinstallation on a vehicle ("maintenance ready used tires"). Additionally, Tuff Boy sought rule clarification that, under the present designation of a waste tire facility, exceeding the current total "waste" tire storage limit of 500 tires on Tuff Boy properly, would require accepting a reclassification to the next level (i.e.: re-designating Tuff Boy as a major waste tire generator). SJCHED responded with a suggestion that Tuff Boy be reclassified as a tire dealer as a means to more appropriately define the operational needs of Tuff Boys' business activities. 1