—
    RECEIVED
    CLERK’S
    OFFT(’E
    MORGAN
    DISTRIBUTING
    M/\Y
    2
    01999
    __
    —
    INC.
    “THEPETROLEUM PEOPLE”
    STATE
    OF
    IWNOIS
    PoIlut~onControl Board
    Illmois Pollution Control Board
    100 West Randolph
    Chicago, IL 60601
    ~
    ~~/cc2
    RE: Docket R98-29; Docket R~9I8Used
    Oil Regulations
    ~
    ,~//~__
    Ladies and Gentlemen:
    I am writing this letter in order to provide the conmients ofmy 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
    CFRPart 279.
    It is my understanding that Part 739 requires that Illinois’ used oilregulations 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 ofused oil
    recycling.
    As you know, the vast majority ofstates 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 thantheir 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 with conditions
    and restrictions, it is unfair
    to impose these 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 pennitting requirements.
    Where will
    Illinois transporters and recyclers store theiroil then?
    Since those requirements impose significant
    paperwork and end burdens, the out-of-state recycler enjoys a major competitive advantage.
    What useful
    purpose could be served by this kind ofdiscrimination?
    In addition, it is imperative that Illinois burners of
    EPAon-specification fuel ~
    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 portionof all the oil in the state, go for recycling ifthey
    arenot willing to burn
    it?
    There are other important issues concerning the requirements affecting the oil recyclers in Illinois.
    These
    are addressed in a letterto the Board ofthe General Counsel ofthe National Oil Recyclers Association
    (“NORA”).
    My companyfully endorses NORA’s comments.
    Ifyou need addition information, please contact me at the number listed below.
    Thanks for your
    consideration in this matter.
    M
    RGAN DISTRIBUTING
    INC.
    CEO
    3425
    N.
    22nd
    Street
    •
    Decatur,
    Illinois
    62526
    800-334-1555
    •
    217-877-3570
    •
    Fax 217-877-3613

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