LENZ OIL PEORIA

INC.

3001

S.W. WASHINGTON

PEORI~

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RECEIVED

Cr~m(’snFr~r~

I\PR

9

1999

Illinois

I~oJl

ut

Con

(rol

Boa

~

STATE

OF ILLINOIS

100

West

Randolph

Pollution

Control Board

Chicago,

Illinois

GOGOI

Ladies

and

Con tJe~me

n:

I

am

writing to

j)rOVi(iC the corn monL.’~of my

C0iflj)~~2~

on

an

pro1)osod

regulatory

changes,

•

pursuant.

to 36

111.

Adm.

Code

807

or 7:19,

that. may

aiThct. oil recyclers operating in

the

State

of’ illinois.

Our company’s prwcspnl C0flC0~il5are

twofbld:

First.,

used oil recyclers

should

not be subject to any regulatory or

permit.

requirements that

are

more stringent

than

the f~derairequirements set

lorth

in

4() CN~.

Part

279.

it.

is

my

understanding

that

PrI:

7R9 requires that illinois’ used

oil

regulations must. be

“identical in substance”

to

the

•

federal

requiremenl;s.

This iiiakes good sense because the federal

used oil management

standards

work

Well,

are

(

ilorccuible,

mid encourage

lCgittmaf.e methods of used oil

recycling.

As

you

know, the vast,

majority

oi

states

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 than

t;heir out ofstate competitors.

Specifically, if a

recycler

in

another state

is

allowed to pick

up used oil in

illinois without; a manifest or

special permit eon(li(iOns and restrictions,

it is uiif~

ir

to

impose

those requirements on

a

recycier

operating

out

of’a

facility

in

illinois.

Also, many transporters

and

recyclors 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

Iliwois transporters and recyclers store their

oil

then?

Because those

requiremehts impose signiflcant paperwork and cost burdens, the out-of-state rocyclor

enjoys a major competitive advantage.

What useful purpose could

be

served

by

this kind

ofdiscrimination?

En

addition,

it.

is imperative

that

Illinois burners of

EPA

on-

specification fuel

g~j,

be

required to

be permitted or they

will simply switch

back

to

virgin

fuel.

Where will the oil going to

(hem

(which

is a good

pOL’LLOn

of all

the oil

in the st.~te)

go

for

recycling if they are not. willing

to burn

it.?

There are other important. issues concerning the requirements affecting the

oil recyclors in

!iiinoi~.The~~

are addressed in

a

letter to the

Board

by the General Counsel of the

National

Oil l~.ecyclors

Association

(“NORA”).

My company fully endorses NORA’s

coinmeats.

If you

need additional

inftrination, please

tot

me know.

~

~2

Re:

Docket

1198-29; Docket 1t~18

Used

Oil Regulations

Since rely,