RECEIVED

CLERK’S

OFFICE

SOUTHWEST OIL,

INC.

~PR

-

91999

17348 Deer Creek Drive

Orland Park, Illinois

60467

STATE OF

ILLINOIS

(708) 460-3245

Pollution

Control Board

FAX:

(708)

460-3328

April 7,

1999

illinois Pollution Control Board

100

West Randolph

Chicago, Illinois

60601

~

/

F’

V

RE:

Docket R9S-29; DocketR9718

•17~:”~~

~V’~

Used

Oil

Regulations

Dear Ladies and Gentlemen:

I am writing to provide Southwest Oil’s comments

on any proposed regulatory changes pursuant to 35

III.

Adm.

Code 807

or 739,

that

may affect

oil

recyclers operating in

the State of Illinois.

Our company’s

principal concerns aretwofold:

1.

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 our understanding that Part

739

requires

that

Illinois’

used

oil

regulations

must

be

“identical

in

substance”

to

the

federal

requirements.

This

makes excellent sense because the federal used oil management standards work

well, is enforceable, and encourages legitimate methods ofused oil recycling.

As you know, the vast

majority ofstates have opted Part 279 with very minorchanges or none at all.

2.

It is

imperative that Illinois regulations not place 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 also imperative that Illinois burners of EPA on specification fuel NOT be

required to

obtain permitting or they

will

simply switch

back to virgin

fueL

Where will the oil

going to these

burners go for recycling if they are not willing to burn it?

This would become an alarming

issue for

Illinois, sincethis is a good portion ofall the oil in the state.

There are other important issues concerning the requirements affectingthe oil recyclers in Illinois.

These

are addresses

in a letter to

the Board

by the General Counsel of the

national

Oil

Recyclers Association

(“NORA”).

Southwest Oil fully endorsesNORA’s comments.

Ifyou need

iti

nal information, please don’t hesitateto contact me.

Sh~~&

Victoria M. Custer

Vice President

VMCJkm