RECEIVED
CLERK’S (~~E
APR
1
2
1999
~r~Lct~
STATE
OF
ILLINOIS
Pollution
Control
BoGrd
USED
OIL
SEIWICES.
INC.
25903
S. ~idgeIand
Avenue
Licensed
~peciaI Wnete
Hauler
F
Monee,
IL ~Q449
PhOnC
(708) 534-9~00
Fax:
(708) 534-9400
Illinois Pollution ControlBoard
—/
100 West
Randolph
Chicago, IL
60601
.,~‘
cS~
RE:
DocketR98-29; Docket R95~18
Used OilRegulations
Ladies and Gentlemen:
I am writing to provide the comments ofmy company on any proposed regulatory
changes, pursuant to 35
III.
Adm., Code 807 or 739, that may affect oil recyclers
operating in the State ofillinois.
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 the federal requirements set forth in 40 CFR Part 279.
It is my
understanding that part 739 requires that Illinois used oil regulations must be “identical
in
substance” to the federal requirements.
This make 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 than their out of state competitors.
Specifically, ifa
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 ofa 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 offacilities 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 useftil purpose could be served by
this kind ofdiscrimination?
In addition, it is imperative that Illinois burners ofEPA on-
specification
fuel ~
be required to be permitted or they will switch back to virgin fuel.
Where will the oil going to them (which is a good portion ofall the oil in the state) go for
recycling if they are not 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 by the General
Counsel ofthe
National Oil Recyclers Association (“NORA”).
My company fully endorses NORA’s
comments.
If you need additional information, please let me know
Sincerely,
Ronald Winkle
President
