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    OIL
    COg IN~~
    6037
    LENZ~AVE.
    •
    HODGK~NS,~L 60525
    ~
    708/354-4040
    RE
    CE
    ~V ED
    (pP~c~
    r~T~Yr’r
    APRIL
    8,
    1999
    APR
    -
    91999
    STATE OF ILLINOIS
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    pollution Control Board
    100
    WEST
    RANDOLPH
    CHICAGO
    IL
    60601
    /
    RE:
    DOCKET R98-29;DOCKET R9~—18
    ~2
    USED OIL REGULATIONS
    /
    LADIES AND GENTLEMEN:
    I AM WRITING TO PROVIDE THE COMMENTS
    OF MY COMPANY ON ANY PROPOSED
    REGULATORY
    CHANGES
    PURSUANT TO
    35 ILL.ADM CODE 807 OR
    739,
    THAT
    MAY
    AFFECT
    OIL RECYCLERS
    OPERATING
    IN THE
    STATE OF ILLINOIS.
    OUR
    COMPANY’S
    PRINCIPAL
    CONCERNS
    ARE TWOFOLD:
    FIRST,
    USED OIL
    RECYCLERS
    SHOULD NOT BE SUBJECT
    TO ANY REGULATORY
    OR PERMIT
    REQUIREMENTS
    THAT ARE MORE STRINGENT THAN THE FEDERAL REQUIREMENTS
    SET FORTH
    IN
    40 CFR PART
    279.
    IT
    IS MY UNDERSTANDING
    THAT PART 739
    REQUIRES
    THAT ILLINOIS’
    USED OIL REGULATIONS MUST BE “IDENTICAL IN
    SUBSTANCE’
    TO THE FEDERAL REQUIREMENTS.
    THIS MAKES GOOD SENSE
    BECAUSE THE FEDERAL USED OIL MANAGEMENT
    STANDARDS
    WORK WELL,
    ARE
    ENFORCEABLE,
    AND ENCOURAGE
    LEGITIMATE METHODS
    OF USED OIL
    RECYCLING.
    AS YOU KNOW,
    THE VAST MAJORITY OF STATES
    HAVE OPTED
    PART
    279 WITH EITHER NO CHANGES
    OR VERY MINOR CHANGES.
    SECOND,
    IT
    IS IMPERATIVE THAT ILLINOIS REGULATIONS
    NOT PLACE A
    GREATER BURDEN
    ON ILLINOIS-BASED
    TRANSPORTERS
    AND RECYCLERS
    THAN
    THEIR OUT OF STATE COMPETITORS.
    SPECIFICALLY,
    IF
    A RECYCLER
    IN
    ANOTHER
    STATE
    IS ALLOWED
    TO PICK UP USED OIL
    IN ILLINOIS WITHOUT A
    MANIFEST
    OR SPECIAL
    PERMIT CONDITIONS AND RESTRICTIONS,
    IT
    IS
    UNFAIR TO IMPOSE THOSE REQUIREMENTS
    ON A RECYCLER OPERATING
    OUT OF
    A FACILITY
    IN ILLINOIS.
    ALSO,
    MANY TRANSPORTERS
    AND RECYCLERS
    IN
    ILLINOIS
    USE COMMERCIAL
    LEASED STORAGE
    FOR OIL TRANSFER FACILITIES
    OR EPA ON-SPECIFICATION
    OIL STORAGE.
    THOSE TYPES OF FACILITIES
    WILL NOT SUBJECT THEMSELVES
    TO PERMITTING REQUIREMENTS.
    WHERE WILL ILLINOIS TRANSPORTERS
    AND RECYCLERS
    STORE THEIR OIL
    THEN? BECAUSE
    THOSE REQUIREMENTS
    IMPOSE
    SIGNIFICANT PAPERWORK AND
    COST BURDENS, THE OUT—OF-STATE
    RECYCLER
    ENJOYS A MAJOR COMPETITIVE
    ADVANTAGE.
    WHAT USEFUL PURPOSE COULD
    BE SERVED BY THIS KIND OF
    DISCRIMINATION?
    IN ADDITION,
    IT
    IS IMPERATIVE THAT ILLINOIS
    BURNERS OF EPA ON-SPECIFICATION
    FUEL NOT BE REQUIRED
    TO BE
    PERMITTED
    OR THEY WILL
    SIMPLY SWITCH BACK
    TO VIRGIN FUEL.
    WHERE
    WILL THE OIL GOING TO THEM
    (WHICH
    IS A GOOD PORTION OF ALL THE OIL
    IN THE STATE)
    GO FOR RECYCLING
    IF THEY ARE NOT WILLING TO BURN
    IT?
    SPECIALISTS IN
    THE TREATMENT/RECYCLING
    OF WASTE WATER,
    COOLANTS, AND O1LS
    THERE
    ARE
    OTHER
    IIVIPORTANT
    iSSUES
    CONCERNING
    THE
    REQUIREMENTS
    AFFECTING
    ~fH5
    OIL
    RECYCLERS
    IN
    ILLINOIS.
    THESE
    ARE
    ADDRESSED
    IN
    A
    LETTER
    TO
    THE
    BOARD
    BY
    THE
    GENERAL
    COUNSEL
    OF
    THE
    NATIONAL
    OIL
    RECYCLERS ASSOCIATION
    (NORA’).
    MY COMPANY FULLY ENDORSES
    NORA’S
    COMMENTS,
    IF
    YOU
    NEED ADDITIONAL
    INFORMATION,
    PLEASE
    LET ME KNOW.
    RAY VINTIKA
    VICE PRESIDENT
    RV:md
    (708) 354-4040
    FAX
    (708) 354-5627
    /BEA
    VER/ OIL
    CO.
    INC.
    ENVIRONMENTAL SEAWCES
    TRANSPORTATION,
    TREATMENT AND RECYCLING
    6037 LENZI AVE.
    RAY VINTIKA
    HODGKINS, IL60525

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