:ECE~iVEE~
    CJ.F
    EKS
    OFFICE
    ~i
    :~
    i9~9
    BEFORE THE ILLINOIS
    POLLUTION CONTROL BOAR~jyr~
    OF ~WNO~S
    Pollution
    Control
    Board
    IN
    THE MATTER
    OF:
    )
    )
    AMENDMENTS TO PERMITTING FOR
    )
    R99-18
    USED OIL
    MANAGEMENT AND USED
    )
    (Rulemaking
    —
    Land)
    OIL TRANSPORT 35 ILL. ADM.
    CODE
    )
    807 AND 809
    )
    ~
    NOTICE OF FILING
    TO:
    Dorothy M. Gunn, Clerk
    Joel Stemstein, Hearing
    Officer
    Illinois
    Pollution Control
    Board
    Illinois
    Pollution Control
    Board
    100 West Randolph Street
    100 West Randolph Street
    Suite 11-500
    Suite
    11-500
    Chicago,
    Illinois 60601
    Chicago,
    Illinois 60601
    Attached Service
    List
    PLEASE TAKE NOTICE today that
    I
    have filed with the Clerk of the Illinois Pollution
    Control Board an original and nine copies of the COMMENTS OF THE CHEMICAL
    INDUSTRY
    COUNCIL OF ILLINOIS, copies of which are herewith served upon you.
    Respectfully Submitted,
    By:
    JtM/M~4
    HdA~
    Jennifer Marsh
    Date:
    March
    1,
    1999
    Jennifer Marsh
    Regulatory Affairs
    Director
    Chemical
    Industry Council of Illinois
    920 South Spring Street
    Springfield,
    Illinois
    62704
    217/522-5805
    THIS FILING
    IS SUBMITTED ON
    RECYCLED PAPER
    CLERg’~
    OFFICr-’
    ~
    BEFORE THE
    ILLINOIS POLLUTION CONTROL BOARb~TE
    OF
    iWNO~’S
    ~~iIu~~onCon
    tro/
    Board
    IN THE MATTER
    OF:
    )
    )
    AMENDMENTS TO PERMITTING FOR
    )
    R99-18
    USED
    OIL MANAGEMENT AND USED
    )
    (Rulemaking
    —
    Land)
    OIL TRANSPORT 35
    ILL. ADM.
    CODE
    )
    8O7AND 809
    )
    COMMENTS OF THE
    CHEMICAL INDUSTRY COUNCIL OF ILLINOIS
    NOW COMES the Chemical Industry Council of Illinois (“CICI”) through its
    Regulatory
    Affairs Director,
    Jennifer Marsh, and hereby submits the following comments relating to the
    above-referenced matter.
    CICI is a
    not-for-profit association which represents 170 corporations, over one hundred
    ofwhich are chemical firms which manufacture,
    blend, distribute and sell chemicals.
    CICI’s
    members operate
    more than 700 facilities in Illinois,
    ranging from small to large operations.
    The
    chemical
    industry in
    the State of Illinois ranks third in the
    United States in
    chemical exports,
    fourth
    in the value of chemical shipments,
    and employs more than 62,000 people.
    CICI’s comments today relate specifically to the amendment to 35
    III. Adm.
    Code
    807.105(a), originally proposed
    by the Illinois Environmental
    Protection Agency (“IEPA” or
    “Agency”) and adopted by the Illinois Pollution Control Board
    (“Board”) as part ofthis First
    Notice Proposed Rule,
    R99-1 8.
    One of CICI’s member companies, Safety Kleen, has raised
    concerns with this particular portion of the proposed rule,
    which requires that used oil transfer
    facilities, used oil
    processors, used oil fuel marketers,
    used oil burners, and petroleum refining
    facilities be subject to Part 807 permitting requirements.
    Until this proposed rule,
    Part 807 had
    not required a facility to obtain a special waste permit if the facility had already obtained a
    hazardous waste management permit in accordance with
    35
    III. Adm.
    Code 705.
    The proposed
    changes would require
    a facility that manages used oil--already governed by a
    hazardous
    waste permit issued by the IEPA--to obtain a
    separate,
    non-hazardous special waste permit.
    While CICI
    recognizes the Agency’s interest in ensuring safety and maintaining oversight at
    used oil facilities, it questions whether there
    is an environmental benefit to requiring a facility
    that already manages used oil
    in
    accordance with a hazardous waste permit to obtain a
    separate,
    non-hazardous special waste permit.
    ClCl
    especially questions this proposed
    language as, according to Safety Kleen, the IEPA has been moving toward consolidating old
    non-hazardous special waste permits into current hazardous waste permits.
    In the
    circumstances mentioned above, this portion of the proposed rule appears to provide for a
    duplicative permitting process,
    and should
    be clarified and amended accordingly.
    CICI appreciates the opportunity to comment
    on the Board’s
    First Notice Proposed Rule,
    R99-18.
    CICI
    plans to continue to monitor both the progress of this proposed rule and the
    responses of its members to the proposed
    rule.
    Further,
    CICI is available to participate with the
    Board and Agency as it proceeds through the rulemaking process.
    Respectfully Submitted,
    Chemical Industry Council of Illinois
    By:
    JALM4JA
    Mcu~
    Jennifer Marsh
    Dated:
    March
    1, 1999
    Jennifer Marsh
    Regulatory Affairs Director
    Chemical Industry Council of Illinois
    920 South Spring Street
    Springfield,
    Illinois 62704
    CERTIFICATE OF SERVICE
    I,
    Jennifer Marsh, the undersigned,
    hereby certifies that copies of the COMMENTS OF
    THE CHEMICAL INDUSTRY COUNCIL OF ILLINOIS were served
    upon those persons
    on the
    attached service list by depositing said documents
    in envelopes affixed-with-sufficient postage
    into the U.S.
    Mail on the
    1st
    day of March,
    1999.
    ME
    ~L
    SEAL
    i~jIiI1

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