RECEIVED
CLER~cS
OFFJCE
S~P24
1999
NOTICE OF FILING
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
R99-18
(Rulemaking-Land)
111 THE MATTER OF:
)
AMENDMENTS TO PERMITTING
)
FOR USED OIL MANAGEMENT AND
)
USED OIL TRANSPORT
)
35
IL ADM. CODE
807 AND 809
NOTICE OF FILING
TO:
Persons on the attached service list (via U.S. Mail)
PLEASE TAKE NOTICE that I have today filed with the Office of
the
Clerk
ofthe Pollution Control Board the comments ofLenz Oil Service Peoria,
Inc. a copy ofwhich is herewith served upon you.
~4~/
~ei~
(Name
of
Lenz Represen,3ti~~.
Date:
T—Z~--77
Lenz Oil
Service Peoria, Inc.
3001
SW
Washington Sireet
Peotia, IL
61602
(309)
676-0211
STATE
OF
ILLINOIS
Pollution
Control Board
COMMENTS AND RESPONSES TO TH1~
IEPA’S USED OIL 807 PERMITTING
PROPOSAL AND AUGUST 23’~
HEARING TESTIMONY
Re: Docket R 99-18
Mr. Dragovich stated that unpermitted facilities can easily relocate and change company
names and that inspections are infrequent at unpermitted facilities.
Response:
Facilities relocate due to customer demands and industry changes
and need to
be able to react to these demands and changes
quickly to survive in the very competitive
used oil industry.
Inspections do not have to be infrequent at used oil facilities. That is an
agency policy choice.
Under current requirements, facilities are already requiredto
notify any change in location or operations ofany off-specification used oils under US
EPA and IL Special Waste Regulations.
Mr. Dragovich stated that the proposed regulations would not regulate marketers ofon-
specification fuel if the used oil also met the defmition of “re-refined oil”
in Section 3.36
ofthe Illinois
environmental Protection Act
(415
ILCS
5/3.36)(”Act”).
Response:
Placing a requirement on EPA on-specification used oil that it also must meet
the defmition ofre-refmed oil to not be considered a special waste is unrealistic.
“Re-
refmed oil”
is
used oil that has been re-refined to
make a new lube oil base stock for
lubricating oil and does not apply to the used oilfuel universe.
It was never USEPA’s
intention orunderstanding that on-specification used oil would meet substantially the
same standards as new oil.
USEPA did say that on-specification fuel oil was virtually
equivalent .to virgin fuels.
Flowever, their comparisons were not only against new oil, but
all virgin fuels,
including coal, due to the fact that used oil could be and is used as an
alternative to coal.
IEPA is concerned that even though the oil was on-specification it
could still
have no value due to a high BS&W level,
and that aspect caused them concern
about allowing unpermitted storage ofsuch.
To address the “value” issue,
NORA
proposed a maximum BS&W limit
also be placed on on-specification fuel.
This would
allow recyclers and generators alike to be able to
determine when a used oil destined for a
fuel exits regulation as a special waste.
Having that defmition be achieved on a permit by
permit basis and be defined differently, from permit to permit would cause a lot of
confusion to recyclers,
and especially generators ofthe regulated community.
Imagine
time confusion if IEPA or US EPA left up what the defmition of a hazardous waste was on
an individual permit by permit basis.
In either case, generators would be totally confused
because this definition could potentially change every time they used a different recycling
or disposal company.
We feel a universal definition must he achieved for all to go by in
the state, and that the requirement ofit meeting the re-refined
definition is inappropriate
and
unacceptable.
Mr. Dragovich mentioned fifty-six former used oil management sites that EPA
has or
will have to act on.
Response:
It was failed to mention however that most ofthose sites are generator sites.
Evenunder the proposed 807 permitting program, generator
sites would be exempt from
permitting, so these examples are largely irrelevant.
Mr. Dragovich also states that many
used oil management sites that operated before 1985 have
had
environmental
problems.
Here we want to point out
two
important points.
First, the actual
Facility
Management
Standards did not become law until 1993 in Illinois,
not 1985.
Secondly, the problems at
those sites may have been discovered recently, or action taken on them recently, but the
problems were actually created in the sixties and seventies for the most part.
Also, again,
there are major problems with the examples in
Attachment 2
to Mr.
Dragovich’s
testimony.
Examples one, two, four, and ten, are not “used oil problems”.
They are
problems that occurred but the requirements over such activities
are regulated not by the
EPA, but by the
State Fire Marshall and/or OSHA.
And
in the case ofexample number
two,
(which was our facility) the explosion was due to
a welding contractor error.
However, due to the fact we had already brought the tank farm facility upto the Used Oil
Management Standards, the facilities tank farm had impervious containment.
Therefore,
even though there was an explosion and an instant release ofover 15,000 gallons ofused
oil, over 99
ofthat oil was recovered and no environmental harm occurred.
This
example proves that the used oil performance standards work and iftank releases
do
occur, the impervious secondary containment and applicable SPCC requirements
adequately address the potential environmental harm.
Examples five,
six, seven,
twelve,
thirteen,
and
fourteen, are TSCAviolations
and would not be regulated any more strictly
under
807 permits.
The remaining problems
are all well addressed under the current 739
regulations.
Mr. Dragovich’s stated that according to
the current requirements of
Parts
739
and 809,
used oil generators are already subject to the manifestingrequirements ofPart 809,
and
that these generators have obtained Illinois ID numbers and are currently using manifests.
Response: Automotive used oil generators have not previously been required to obtain
Part 809 ID numbers and manifest their oil due to time fact most recyclers have in the past,
and are still,
using the old multi-stop method ofusing one manifest for the load,
plus a
log ofwhere that loads oil came
from.
We know ofno recyclers in the state that have
been told by EPA
they had to discontinue this practice.
We also do not know of any
notification sent out to recyclers concerning this issue or to automotive generators
alerting them to the fact that they now needed to obtain
ID numbers, after years ofIEPA
telling them they did not when they inquired or were inspected due to the multi-stop
permits.
This apparent change of agency philosophy was totally unknown by the
regulated community, and recyclers and generators were
not notified ofthis change.
In
fact, in
1996 we were told to go
on doing things as we had under the
old multi-stop
permit until the agency could better determine howthey wanted to handle the situation.
The EPA
also
told NORA that the agency was considering dropping the manifesting
requirements for used oil in Illinois,
in
1996.
Apparently much confusion exists currently
in this area.
Howevem; we estimate that less than
10
ofautomotive used oil generators
have
IL EPA II) numbers and are manifesting their individual oil pick-ups.
So this
requirement would require tens ofthousands ofautomotive generators to register.
We
also want the Board to be aware
that even when manifesting used oil, no copies are
required to
be
sent to the agency, as is the case with hazardous waste.
Therefore, the
tracking aspect ofthe manifesting requirements is basically lost to the agency anyway.
2
In Mr. Dragovich’s prefiled testimony
response to
Mr. Harris’s statementthat his
previous testimony failed to identify a single actual problem that would not be addressed
by the Used Oil Management Standards,
the real issue surfaces.
As is under current
regulation, used oil recyclers are ultimately responsible as to how they will run
their
facilities and operations to achieve continuing compliance with the regulations.
Under
the 807
proposal, EPA
wants to make more ofthose determinations.
For instance, EPA
states “the contents ofthe tank may impact the rate ofcorrosion that will occur in a metal
tank”.
The
“contents”
in a used oil facility are normally oil.
Internal corrosion just is not
a problem in the real world ofoil storage.
Tanks used for used oil storage experience
little internal corrosion, even after many years ofuse. By reviewing the proposed
management standards issued to Lenz Oil in 1995 and
our response to them (previously
submitted), you can see there can be a large difference ofopinionMwhat
is needed to
achieve compliance by the recyclerverses the agency
in this one instance.
This is where
the concern comes into play, that the permit and conditions felt needed by the agency
could become overkill, costing the IL recycler their competitiveness verses their out of
state competitors due to the costs incurred complying with these operating conditions,
and straight jacketing the permittee from being able
to quickly react to
customers,
industry, or competitors changes and challenges.
We’re not againstregulation, but we
are an unsubsidized, stand alone industry and because of such need to operate freely in
the free market system we are competing against (our out of state competitors and the
virgin fuel market).
Going ~y
further
n the 7~regulations ~yjil~
allow ti~tt~
ppm.
Ifthis is what is desired by government, then we feel the government would also
need to subsidize the industry to enable it to
compete in the
free
market due to the
additional burdens placed on it from a cost and reaction competitive standpoint by
further
regulation than what 739 prescribes.
In Mr. Dragovich’s prefiled testimony, he answered a question we had posed concerning
multi-stop type permits.
Mr. Dragovich’ s testimony here reflects another long term
problem recyclers had under 807 permitting in the past.
Multi-stop permits should be
issued under Part 809 transporter permits and not under Part 807 facility permits.
Multi-
stop permits are a transportation issue not a facility issue.
Out ofstate competitors
collecting used oil in Illinois need multi-stop permits and EPA
has no authority to issue
them under Section 807.
If
required, having multi stop permits issued under Section 809
would level the playing
field for instate and.out ofstate recyclers alike operating in
Illinois.
Mr. Dragovich stated that the proposed amendments to
Part 809 would eliminate the
manifesting and special waste hauling permit requirements for all used oil transported to
a used oil collection center or aggregation point.
Response:
However, as proposed,
809.211 restiicts a generator ofover 220 pounds a
month ofspecial waste from seiftransporting their used oil in small shipments of
filly-
five gallons or less
to a used oil processing facility unless they obtain
a special waste
hauling permit.
We feel that these generators who want to haul
small amounts oftheir
used oil to a used oil processing facility for recycling should be allowed to do so without
a transporter permit,
as is allowed under Section
739.
Requiring a permit to do
such, as is
3
the case with the agency’s proposal, reduces the incentive for such generators to recycle
their oil.
Generators that generate less than 220 pounds of special waste a month are
already exempt from obtaining a special waste hauling permit and manifesting under
current regulation, up to fifty-five gallons at a time, and are free to take their used oil
anywhere for recycling.
Therefore, this part ofIEPA’s proposal only effects generators
ofover 220 pounds of special waste per month.
Currently they must have a special waste
hauling permit under 809 and
manifest the
oil. Under EPA’s
proposal, they will not have
to do this if going to a collection center or aggregation point, but would have to if going
to a 807 permitted facility like a used oil processor.
NORA’s proposal contains a
provision to drop this requirement for a special waste hauling permit and manifesting for
any and all generators that want to self transport fifty-five gallons or less
at a time for
recycling to
a oil collection center,
aggregation point or processor.
This would,
where
economically attractive to the generator, further encourage used oil recycling over
IEPA’s proposal.
We have generators currently delivering single fifty-five gallon drum
shipments to our processing facility.
Some ofthem may be over 220 pounds per month
generators, but this information is very hard to obtain and track.
Allowing all generators
to transport fifty-five gallons or less themselves without a permit and manifest would
allow us to encourage such self transportation.
Due to the factwe have a hard time
tellingif the generator is exempt or not, we currently discourage all unmanifested
deliveries. We can see no reason to restrict such activities.
Mr. Dragovich stated that “the requirementto obtain a Part 807 permit would not be
unduly burdensome to a well-run facility which is currently operating in compliance
with
Part 739.”
Response:
Well, that depends.
It depends on the additional conditions, design and
operating standards imposed on the facility.
As we stated, we feel the
1995
proposed
permit draft to Lenz Oil would be unduly burdensome.
Further, Mr. Dragovich’s
testimony that the federal regulations allow states to be more stringent,
and impose state
regulations, seem to indicate the agency’s thinking has not changed much since the
1995
proposed permit draft.
Further evidence ofthis is the fact that Mr. Merriman stated at the
hearing that “this is just the proposal to require permits to go back to the status quo, and
isn’t even completely the status quo because we’ve left out some and because we’ll be
implementing through that permit Part 739”, and that the permits would be less onerous
than the past permits (I believe he meant over the
1995 proposed permit), because certain
tImings that 739 has done and to clarify obligations and to limit testing and some other
kinds ofthings.
Mr. Dragovich also indicated in the hearing that EPA
would not be
hying to establish operating standards under 807 permit conditions.
However because
the complexity ofthe previous
1995 draft permit,
and secondly, because the draft permit
was promulgated two years after the 739 regulations were adopted, we are somewhat
skeptical ofhow far EPA
wants to
go concerning permit conditions, etc.
Ifthey only
want to enforce 739 conditions,
why did they add so much more two years after adopting
the 739 regulations, as proposed permit conditions?
Most states have seen the folly of
adding more stringent state regulations on top ofthe 739 regulations due to just the
reasons we have brought up in these comments and
our previous comments.
illinois oil
recyclers either need to compete freely in the market place, or at least as freely as their
competitors (virgin fuel distributors and out ofstate oil recyclers).
4
Mr. Dragovich stated that requiring a used oil marketer who markets used oil other than
that generated by its own activities from the site where it is generated to obtain an Part
807 permit is consistent with the Act because the definition of “transfer station” in
Section 3.83 ofthe Act includes shipments of waste that are stored for less than 24 hours
iftransfer is involved,
Section 3.47 includes transfer stations in the definition ofstorage
site,
and Section
21(d) ofthe Act requires all storage sites to obtain a permit.
Response:
Used oil that sits somewhere for less than 24 hours is in transit.
Those
locations could be different every time depending on where the oil is coming from.
In
these situations,
lime oil is not in a transfer facility nor in storage at all,
it’s stopped in a
truck awaiting someone else to add to it or move it further.
Requiring permitting for each
and
every place this mayneed to be done,
every time it may need done, is impossible due
to
constantly changing needs of the recycler, such as where the oil is ultimately going,
who and where it’s coming from,
etc.
This requirementwould severely
restrict the
recyclers most economical means oftransport in many cases.
There are already adequate
DOT and oil pollution act laws on the books to regulate
this
type
ofactivity.
In addition,
this
activity is not permitted for even hazardous waste shipments.
Also, concerning
actual transferfacilities, we realized afterreading the August 23~’
hearing transcripts, that
there was not much discussion abouttransfer facilities.
Transfer facilities are becoming
much more important to recyclers in an effort to keep transportation costs as low as
possible.
Mr. Dragovich states in EPA
prefiled testimony to the August
231~1
hearing in
response number three and number twelve that transferfacilities
should be permitted as a
“facility” under Part
807, and would be under IEPA”s proposal.
Under part 739
regulations,
a transfer facility is
as a facility used for hulking up
loads ofused oil and can
hold
oilfor
up to thirty-five days, and
is considered part of the ~
nsorters activities.
This oil is usually untested or uncertified as to
meeting the EPA specifications.
Where
oil is held under 24 hours Ihe “facility” is not considered
a transfer facility under Section
739 regulations.
EPA
not only wants to permit transfer facilities, but also transporters
and marketers that store oil less than 24 hours as stated above, and
states that the Act
provides for this.
This is very odd due
to the fact that even some hazardous waste
marketers or~
md hazard
traisferlisare
not requircdt~kt~jii~ny
type of“facility” permit as far as we know.
In fact, the 739 transferfacility regulations
are much more comprehensive than the hazardous
waste transfer facility regulations (Part
723), requiring impervious secondary containment, which is ~
required, even at
hazardous waste transfer facilities.
We question why used oil marketers orbrokers and
used oil transfer facilities need “facility permits”,
and need to be regulated more heavily
than hazardous waste transporters and transfer facilities in many cases?
Also, as we
stated in our pj~vjp~~pjmmments
and above, if a recycler leases a sp~t
as a 24 hour point,
orleases
all orpart ofa small tank farm for use as a transfer facility, requireing the owncr
ofthose properties tQ~taina “faciljtypennit” would effectively remove them from the
market for used oil recyclers,
causing severe transportation and competitive issues for
Illinois recyclers.
As stated in our earlier comments,
we would have no problem
notifying IEPA oflocations oftransfer facilities and certifying they meet the Used Oil
Management Requirements as a requirement ofour Special Waste Transporters permit,
but that burden has to be on
time recyç
eflicility_own~or as stated we will find
no one interested in leasing us storage or property.
Due to the fact this
is a
“transportation” issue and hinges
on where and how many used oil generators we service
in a given area, it would not be prudent to purchase our own facility or land for this
purpose because it may be a shorter term need.
Leasing or renting is a much smarter
business decision for these locations,
and therefore, requiring the “owner” ofthe property
to obtain the permit would persuade 99
of time “owners”
to n~i
offer such an
arrangement to a used oil recycler.
In addition, we also feel it would be impossible to list
accurately 24 hour transporters “facilities”.
As stated, these will constantly be changing
due to customer and industry changes
and are often not even a leased property, perhaps
just a customers parking lot in many instances.
In Mr. Dragovich’s finalprefiled testimony comment, he states that 60
of automobile
drivers
change their own oil.
This is a very important point.
Sixty percent ofall
automotive oil sold gets
into the recycling system, completely voluntarily.
Why do these
generators use the “system”?
Because it costs generators very little to nothing to do so.
Putting expç~sivepen j~çpn4jtions_anddesign and ~
facilities in Illinois will insure the costs g~ed
along to time transporter trying to
sell
the oil to the recyc~,~nd
then to the oil collection Do-It-Yourself(DIY) point,
with the
DIYers
mmntimately payingfor itjfijwQways~
reduced locations available to drop offthe
oil due
to IL m~cy~l~~s
gQing.put ofbusiness~
the DTYers will, have to i~yt°
~g~Lrid
oftheir oil.
Under this scenario, we predict they
will still “get rid” ofthe oil, but not as much will go into the recycling system,
that’s for
sure.
Costs to generators (DIY and commercial) for recycling, heavily impacts generator
proper. disposal habits, very hea~~ily.
USEPA understood this in
developing the 279 (IL
739) standards.
Too rnilc
ensive regulation ofused oil can actually, be worse than
too little, for the environment.
Mr. Eastep testified that three problems are aflen encountered at used oil facilities.
Let’s
address these problems:
1)
Flandling:
Under the 739 management standards,
areas where used oil is
loaded or unloaded must nowhave
impervious secondary containment.
This,
has stopped the contamination issues from handling the Mr. Eastep eluded to.
2)
Storage in tanks and containers:
Again, totally these areas are required to
have impervious
secondary containment where overfill oftanks or leaking
containers could occur.
3)
~quipment and piping,
Buried piping is now regulated by the UST
regulations.
Above ground piping is again required to have impervious
secondary containment,
as is any processing equipment.
All three of these examples are now regulated by the Used Oil Management Standards to
adequately protect the environment and stop the problems that Mr. Eastep eluded to.
Also, leaks and spills in the areas are also required to he promptly
cleaned
UI)
under the
Used Oil Management Standards.
Mr. Eastep provided a summary list ofproblem used oil sites.
All these sites operated
from the 1960’s or 70’s
on, however, all but two never operated under the Federal Used
Oil Facility Management Standards (IL Part 739 Standards).
In fact, all but two were
closed prior to the Used Oil Facility Management Standards even being enacted.
The
6
two that continued to operate in the 90’s, after the Used Oil Management Standards were
enacted, have problems stemming from past actions from the 60’s through the 80’s that
are plaguing those sites.
The point here is that the major problems and pollution
encountered happened before the current Facility Management Standards were enacted
and could not happen today, legally, under those standards.
Mr. Eastep also brought up another very important fact.
He stated that frequently used
oil recyclers claim not to have the funds to properly clean up their facilities.
Iwant to
state here that I believe this is not
a “claim”,
and must be true when claimed for one
important reason.
Ifmy company cannot clean up an owned facility, I personally could
be held liable for these expenses.
I wouldn’t want that, no
one would want that.
No one
would subject themselves and their families to that possibility,
unless they had no
choice.
So that being said, why do some not have enough money?
The unfortunate fact is
because there is not a lot ofmoney to be made in this business.
Ifthere was, you would
see Pennzoil, Exxon,
etc. in this business.
There are some larger companies in this
business, but they have continually lost money in it.
Only time smaller, nimble,
quicker to
react independent companies have survived (and prospered at times) in this business.
Are
we all making enough money to make sure every possible expense will be covered if we
were to later go out ofbusiness?
No, we are not, in some cases.
Is that bad?
Yes, but
what are the alternatives?
-Charge the generators a very high collection/recycling fee so we can be assured ofthat
money?
No, not when 60
ofthe oilneeding recycled comes from completely
unregulated voluntary DIY oil changers.
Those users ofthe “system” along with a lot of
rural commercial generators will ~
use the system if the costs are high.
This would also
result in recyclers volumes
plummeting, forcing recyclers to charge the ones staying in
the system,
doing the rightthing, even more, further compounding the problem.
-Have the government subsidize the industry?
I think recyclers would readily go along
with that,
but where will the state or federal government come up with that money,
and
are they willing to do so?
The state could do some things that would help oil recyclers immensely.
One is to drop
the sales tax on
all recycled oil products.
This would give us an instant price advantage.
And secondly, require or evenjust suggest that any burners explore the possibility of
using Recycled Used Oil Fuel, in their air permits.
Even a suggestion here would tell
burners Recycled Fuel Oil
is ok in the states and EPA’s
eyes.
This could make a huge
difference and not cost the state anything!
Many potential burners are scared ofhow the
state and IEPA will react to them wanting to burn Recycled Fuel Oil.
If anyone has any
other suggestions,
ourselves and NORA would be very interested in hearingthem.
The used oil recycling system in place currently in Illinois,
has evolved quite a bit into
more ofa commodity type operation since EPA
more or less exited the picture for the
most part in 1996.
Many changes have taken place in this industry in the past fewyears.
Much more oil is being stored in commercial
storage facilities,
destined for use as a fuel
in far away places, thanjust
a few short years ago when many more end markets in
Illinois
existed for the oil.
What’s needed is just a little more oversight by the agency to
make sure everyone is playing by the rules (the 739 rules), nothing more.
EPA currently
7
holds the authority to oversee this activity,
without 807 permits, using 809 and 739
granted authorities
In closing, we feel it’s
becoming clear to the Board why we don’t want the straight jacket
that Part 807 permitting would entail.
EPA
seems intent
on telling recyclers how to run
many facets of theirbusiness, without knowing how those businesses actually operate,
function, and survive
in the real world.
Also,
a detailed permit that may work today may
not tomorrow, in this ever changing industry.
The 807 Proposal is a straight jacket
recyclers can’t contend with in this changing industry and a recipe for economic and
environmental disaster,
we feel.
NORA’s counter proposal to permit recyclers etc. under
Part 809 will give EPA
the organizational structure to permit us, without all the expense
to the recycler in applying and obtaining the permit we would have under Part 807,
plus
itwould limit EPA’s
leeway to add expensive permit conditions.
We also estimate that
the permitting time and expense, from start to finish, would be approximately one halfof
807 permitting.
In addition,
NORA’s proposal defmes what is and isn’t a special waste
concerning used oil with a bright line that the regulated con’imunity (recyclers and
generators) can see and understand.
It allows us to operate freely, but with an
organizational structure that EPA
can use to monitor us more closely than what is in
place now.
Wehope the Board and EPA
understand our concerns, and feel NORA’s
809 permitting proposal has merit.
We would be willing to work with the agency in
developing these permits.
We feel the Board should adopt NORA’s proposal.
We have also submitted, as requested a cost estimate for the engineering portion of
submitting Part 807 permit applications.
We estimate an additional minimum of$5000 in
company costs.
~eLenz,
President
Lenz Oil Service Peoria, Inc.
IvHJbr
8
Robert
M.
Randolph,
RE.,
M.B.A.
President &
CEO
September 2,
1999
Mr. Mike Lenz
Lenz Oil Service, Inc.
3001
SW. Washington
Peoria, Illinois 61602
Randolph
& Associates,
Inc.
Consulting
Engineers
-
Surveyors
9!!
W
Pioneer
Parkway,
Peoria,
IL
61615
309-693-8844
.
-800-831-922!
FAX
309-693-6655
http://whw.randolphinc.com
Re:
Cost Estimate
for Development ofPermit Applications for Used Oil Facilities
RAT Job #901.001
DearMr. Lenz:
Peryourrequest,
Randolph
& Associates, Inc. hasreviewed the information providedby the
Illinois Environmental ProtectionAgency (IEPA), Division of
Land Pollution Control,
regarding
the proposed permit application process forused oil facilities.
Our review included the followingapplicable forms and their associated instructions:
•
LPC-PA1
•
LPC-PA3
•
LPC-PA4
•
LPC-PA8
•
LPC-PAI3
•
LPC-PA16
“GeneralApplicationfor Permit”
“Applicationfor a Solid Waste Management Permit to Develop Treatment
and/or Storage Facilities”
“Applicationfor Operating Permit”
“CertUication ofSiting Approval”
“Applicationfor a Permit to Develop a UsedOil Storage Facility”
“Notice ofApplicationjbr Permit to Manage
Waste”
Based upon review ofthe applicable forms and instructions, the following is
a list of
supplemental items which will be required to be
addressed in each potential application:
•
Development ofHydrogeologic Information
•
Groundwater Modeling or Classification
•
U.S.G.S.
7.5
minute Quadrangle Map
•
Topographic Map with Contours of the Site
•
Plan Sheets of the Entire Facility
•
Process Flow Diagrams (PFDs)
•
Narrative Description ofthe Facility Operations
•
Description ofEach Piece ofEquipment
ENVIRONMENTAL
•
CJVIL
•
SURVEYING
•
MUNICIPAL
•
TRANSPORTATION
INDUSTRIAL
•
MECHANICAL
•
ELECTRICAL
HVAC
•
STRUCTURAL
•
FOUNDATION
Mr. Mike Lenz
Lenz Oil
Service, Inc.
September 2,
1999
Page 2
•
Waste Characterization Plans
•
Waste Analysis Plans
•
Residuals (Description ofHandling/Disposal ofResidual Wastes Generated
at the Facility)
•
Contingency Plans
•
Containment Systems
•
Stormwater Run-on/Run-off
•
Inspection Procedures
•
Closure Plans
•
Post Closure Use
•
Site Suitability
•
Demonstrations ofCompliance with Existing Regulations
Based upon review ofthe information provided, Randolph & Associates,
Inc.
estimates the
following costs for development and preparation ofan LPC Permit Application for a typical
Used Oil Facility (i.e. the Lenz Oil Facility located on
SW. Washington Street in Peoria,
IL):
•
Completion ofthe Actual Application Forms
$3,000 to
$5,000
•
Development of Supplemental Information required by the Forms
$8,000 to $12,000
•
Development ofa Topographic Map Using Standard Survey
Equipment
$4,000 to $7,000
Total Costs*
$15,000 to $24,000
*Note:
These estimates
assume some
use ofpreviously developed
and
existing information such
as Contingency Plans,
Inspection Plans, and Equipment Description Lists.
Please feel free to contact our office at 309-693-8844 if there are any questions or if any
additional
information is required.
My e-mail address is tsnarr@randolphinc.com.
Sincerely,
Randolph & Associates, Inc.
Todd W.
Snarr, P.E.
Director, Environmental Engineering
II.RAC_FSJ IRAI-PEORIA IProjectsl9lOlPerinitApplication Cost RevIeWLTR to Mike Lenz.doc
LENZ OIL
PEORIA
INC.
3001
S.W. WASHINGTON
PEORIA, ILL.
61602
(309)676-0211
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached comments on
the amendments to permitting for used oil management and used oil
transport
35
IL
ADM
Code 807
and
809, Docket R99-1 8, by U.S. Mail,
upon the following persons.
Persons on the attached
service list
SUBSCR1B~D
ANI?
SWORN TO BEFORE ME this
c(:)
day of
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19~9
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LISA
M..L~NZ
NOTARY
PuBUc,SiAT~oFIWNOIS
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EX
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Notary Seal
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FROM.
ID.
PAGE
:~
•
Matthew
J
l)unsi
Chief, Fatvironment
Bureau
•
Office ofthe Attorney (leneral
100
West
Randolph St.. II
iii
Floor
Chicago,
II.
(060I
Dorothy M. (hmn
Clerk ofthe I3oard
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
•Oiiago IL
Cynthia
Hilton
Executive
Director
Assoc. ofWaste
Hanirdous
Materials Transporters
2200 Mill Road
Alexandria
VA 22314
Jeffrey Jeep
LMCO
Chemical T)istributors, Inc.
2100 Commonwealth Avenue
North Chicago, IL 60064
Jennifer Marsh
Chemical Industry Council ofIllinois
9801
West Iliggins
Suite 515
RosemonLlL600lN
Sanjay K. Sofia
Illinois Environmental Regulatory Group
215 Last Adams Street
,Springfldd
IL 62701
‘1
Vicki Thw~uum
SCAR
Wm. 0.
Stratton Bldg..
Room 700
Springfield, Ii. 62706
Kimberly
A
(Ieving
IEPA, I)ivision ui Legal Counsel
Assistant (‘ounsel
1021
North (mmd Avenue F~sst
Springfield,
11. b27t)4-9276
Christopher I larris
Oóneral Counscl
National
Oil
Recyclors Association
1439 WestBabcock
Bowman, MT 59715
Katherine D. Hodgo
Hodge & Dwyer
808 South Second Street
Springfield, 11.62704
Robert Lawloy
ChiefLegal Counsel
Dept. ofNatural Resources
524 South Second Street
Springfield, II. 62701-1787
Paul Pike
(MC-602)
Amcrcn Services
P.O.
Box
66149
SLLouis,M063l66
Joel .1. Sternstein
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
chicago, li.c,IRg)l
a
SERVICE
E1IST
(R9t-18)
C.
1.
