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JUL-25-2001 04:49P FROM:CWR INDUSTRIES 2093692703 TO:4688392 P:2/2 <br /> Jidy 25, 2001 <br /> Concerning what amount of storage time is acceptable,Article 3, Section <br /> 17855 (a)(6)and 17862.2 of Title 14(Storage)States that storage time of up to 7 days <br /> is excluded from complying with any regulations Concerning vectors, nuisances,fire, <br /> or record keeping. I believe it is reasonable to conclude here that 8 days is THE <br /> MEIPdUM amount of allowable days where the facility operator is even subject to <br /> the three(3)conditions listed;(1 7( )(2))- vectors, odors, and other listed <br /> nuisances, (I7 67(b)(1))- a prevention and control, and(1 7869(d))-recoTd keeping <br /> standards. I believe it is the intent of this regulation to allow reasonable flexibifity to <br /> each specific operator's circumstances without compromising the established <br /> standards regarding vectors, odors, nuisances, fire, and proper record keeping. The <br /> Scotts Company has already committed in its original letter requesting the <br /> amendment that they will not compromise any of these specific permit conditions <br /> and,in fact, stockpiled materials will be processed earlier, if necessary,to stay in <br /> permit compliance, <br /> Therefore, I propose that our request to amend the ow le storage time to <br /> 15 days, subject to all of the present permit conditions concerning vectors, odors, <br /> fires, and record keeping, is allowable under current Title 14 regulations. Lastly, <br /> and as I mentioned on the phone today,I incorrectly fisted the date we wish to <br /> commence this operation. The to should read July 30, 2001,not August 30, 2001. <br /> Please call with questions or comments. Office-369-6887. CeU481-3723. <br /> 2 <br />