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a•� ,* � Page 1 of 2 10 Jennifer Frase [EH] From: Jennifer Frase [EH] Sent: Friday, June 12, 2009 10:21 AM To: 'kurtd@tdswm.com' Cc: Robert McClellon [EH]; 'Motmans, Bill' Subject: Registered Waste Tire Hauler Vehicles Hi Kurt, It took me a minute to navigate to the sites I wanted to share with you. Okay, It looks as if you currently have 21 vehicles Registered to haul tires. The Surety Bond that is required by the CIWMB covers each one of these vehicles in the event of accident or catastrophe regarding the tires being hauled. Vehicle Registration to haul tires with CIWMB is covered with the one bond, whether one or twenty-one vehicles are registered. From the experience we have had in the past,we have worked with registered haulers that have a large fleet of vehicles, of which only a few were capable of holding ten or more tires. The fact that all of the vehicles were registered required each driver of each vehicle to manifest each single tire on each trip, one tire or ten, which proved to be quite a burden not only on the drivers, but for staff in the office that had to manage the paperwork and the staff at CIWMB that recieved it. So, it was recommended to these businesses to un-register vehicles that were incapable of carrying ten tires at a time, or vehicles that were not going to be used to haul more than nine tires at a time (ie: road service vehicles). The facilities have been directed to use only the registered vehicles to haul tires, reducing the manifesting requirements significantly. Each un-registered vehicle can transport nine or less tires. Each registered vehicle must manifest each individual tire, regardless of how many there are. Now, we have the subject of commingled solid waste. If tires are"comingled" in solid waste and it is unsafe or not possible to separate all of the tires from the load of solid waste, the tires are considered solid waste, not"waste tires". This is the gray area I was referring to when I spoke to you yesterday. But for your fleet, as a registered hauler, the laws are very specific. All 21 registered vehicles must manifest each tire, commingled in solid waste or not. So we have recommended in the past for a facility to un-register vehicles that will not be hauling tires, and to focus all tire hauling toward only the registered vehicles in the fleet. I explained this over the phone, and I hope this email makes sense. I cannot tell you how to handle your situation, only to help you get information to make the right decision for your operation. So please feel free to contact me if you have questions. I also would like to give you the name of my contact up at CIWMB in Sacramento, who has been most helpful in these situations. His name is Bill Motmans (916) 341-6869. Below is a list of all of your currently registered vehicles and the links to the website I got the information from. Let me know if I can be of further assistance. Jenni Frase, Senior REHS San Joaquin County Environmental Health Department 600 E. Main Street Stockton, CA 95202 (209) 468-9966 https://secure ciwmb ca gov/WTMS/HaulerNehicle/Default.aspx?OrganizationTPID=1278421 License Plate State Vehicle Type Model Model Year VIN Owner CA Truck International 2002 HSCBAER32CO36921 Tracy Disposal C CA Truck International 2000 HSCBAHR4YC079362 Tracy Disposal C 6/12/2009