DRYCLEANER
APR 26
2004
ENVIRONMENTAL
RESPONSE
COUNCIL
MEMBERS
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John
Bredenkamp
Augustine
Chung
Andrew
Chweh
David
Gibson
Young
April
23, 2004
Michael J. McCambridge
Staff
Attorney
Illinois Pollution
Control Board
100W.
Randolph 11-500
Chicago, IL
60601
RE:
Recommended Addition to
the
following:
.
Docket R04-16:
Illinois Register
-
April 23, 2004
Proposed Rules: Pollution Control Board
-
ILRti35\pt739
Used Oil Management Standards
Dear Mr. McCambridge:
Professional
geologists
deal with
the
handling,
transport,
and
disposal of the hazardous
waste generated at leaking underground storage tank sites,
drycleaner facilities,
industrial
sites,
commercial facilities,
etc.
on a
daily basis.
Geologists
are well known
to
provide
many ofthe same services that a professional engineer performs within the environmental.
industry
and
some
services
that
professional
engineers
do
not
provide.
As
a
note,
a
significant part ofthe education and training that a geologist
receives includes chemistry,
environmental engineering, and OSHA hazardous material health and safety issues.
It is recommended that the below portion of Docket R04-16
Proposed Rules be modified
as indicated in
bold
to include “professional geologist” as having the type ofprofessional
skills necessary for compliance.
12) Initial regulatory flexibility analysis:
C)
Types
of professional
skills
necessary
for
compliance:
Compliance
with the existing rules
and proposed amendments may require the services
of
an
attorney,
certified
public
accountant,
chemist,
professional
geologist,
and registered professional engineer.
I
would
be
happy
to
discuss this
issue
with
you
in
greater
detail
and
if you
have
any
questions, please call 630-741-0022.
Sincerely,
C. Michael Perkins,
LPG, CPG,
CHMM
Environmental Project Manager
P.O.
Box
7380
Bensenvilte,
IL
60106—7380
Phone:
800-266-0663
‘
Email:
info@cleanupfund.org
Fax:
630-741-0026
