2175 Point Boulevard – Suite 375, Elgin, IL 60123
    Phone: (847) 836-5670 Fax: (847) 836-5677 Toll Free: (877) WE TRY 4 U
     
     
     
    July 28, 2006
      
    Ms. Dorothy Gunn, Clerk
    Illinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph, Suite 11-500
    Chicago, Illinois 60601
      
    RE:
        
    R2006-020
    Reform to using a DOT Bill of Lading for used oil shipments
     
      
    To Whom It May Concern:
      
    Heritage-Crystal Clean, LLC is writing to express support for the Amendments to the Board’s Special
    Waste Rules Concerning Used Oil proposal, 35 Ill. Adm. Code 808, 809, RC 06-20. Thank you for this
    opportunity to provide additional comments in the above-referenced rulemaking.
     
    In almost all states, used oil is transported under Department of Transportation (DOT) shipping papers.
    DOT requires that specific information be included on shipping papers, but DOT does not require use of
    a specific form. The advantage of such an approach is that shipping papers may fulfill both regulatory
    requirements and business needs. Shipment information and business transaction information may be
    combined on one piece of paper. This is the approach that is taken in almost all states.
     
    Current Illinois regulations require use of a hazardous waste manifest for used oil. This means that both
    a manifest and another business transaction document (such as a work order) must be used for each
    transaction.
     
    The definition of used oil is outlined in U.S. Environmental Protection (U.S. EPA) regulations found at
    40 CFR 279. Used oil includes used oil, oily water, and other used oil soaked debris and absorbent.
    Illinois has requirements for equivalency to these Federal regulations. In order to promote recycling of
    used oil, U.S. EPA does not require a hazardous waste for shipments of used oil. Illinois has over
    reached its statutory authorities by imposing requirements that go beyond Federal requirements for used
    oil.
     
    The use of hazardous waste manifests for used oil does not promote additional recycling and does not
    provide additional environmental protection or integrity of the regulatory framework. The requirement
    to use hazardous waste manifests is wasteful and puts an undue burden on Illinois businesses. Current
    manifesting requirements and is not a good use of the resources of the State of Illinois.
      
     
     
     
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JULY 31, 2006
    * * * * * PC #9 * * * * *
    In closing, Heritage-Crystal Clean supports the NORA proposal for the elimination of hazardous waste
    manifests for used oil shipments in Illinois. We urge the Illinois Pollution Control Board to also support
    this regulatory improvement.
      
    If you have further questions or comments, please contact me at 847-783-5949 or
    catherine.mccord@crystal-clean.com.
     
    Sincerely,
     
     
    Catherine A. McCord
    Vice President
    Environment, Health & Safety
     
     
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JULY 31, 2006
    * * * * * PC #9 * * * * *

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