July 28, 2006

MS. DOROTHY GUNN, CLERK

Illinois Pollution Control Board

James R . Thompson Center

100 West Randolph

Suite 11-500

Chicago, Illinois 60601

RE:

R2006-020

Dear Illinois Pollution Control Board Members:

I am the Executive Director of NORA, An Association of Responsible Recyclers . We represent 200 used

oil and liquid recycling companies throughout the United States

. I am writing in regards to: In the Matter

of Amendments to the Board's Special Waste Rules Concerning Used Oil, 35 Ill . Adm. Code 808, 809,

RC 06-20

.

As you might expect, we strongly endorse and support NORA's rule proposal and request that the Board

adopt the language proposed by NORA .

Special Waste manifesting for used oil, including those substances entitled to be regulated as used oil

pursuant to federal and state regulations, is burdensome and unnecessary

. The current manifesting

requirements in Illinois are above and beyond what is required at the Federal level without justification.

In addition, the manifesting requirements in Illinois are far outside the norm compared to almost every

other state.

NORA believes that the current manifesting requirements in Illinois for Used Oil and items regulated as

Used Oil are unnecessary and burdensome . We strongly encourage the Board to adopt the language

proposed by NORA . We look forward to the Board's adoption of NORA's rule proposal .

ORIGIN,\\L

Scott D. Parker

Executive Director

L

Association

Responsible

or

N

Recyclers

RECEIVED

CLERK'S OFFICE

AUG 0 12006

STATE OF ILLINOIS

Pollution Control Board

5965 Amber Ridge Road •

Haymarket, Virginia 20169

Phone 703-753-4277 • Fax 703-753-2445 • www.noranews .org • sparker@noranews .org