41
USED OIL SERVICES. INC .
July 26, 2006
MS. DOROTHY GUNN, CLERK
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph
Suite 11-500
Chicago, Illinois 60601
Lee J . Plankis
Senior VP Operations
RECEIVED
CLERKS
OFFICE
JUL 2 8 2006
ORIGINAL
RE
:
R2006-020
Dear Illinois Pollution Control Board Members
:
Our company is writing you in regards to: In the Matter of Amendments to the Board's
Special Waste Rules Concerning Used Oil . 35 Ill. Adm. Code 808, 809, RC 06-20
.
Thank you for this opportunity to provide public comment in the above-referenced
rulemaking. I submit this comment on behalf of RS Used Oil Services, Inc., a member
of NORA. RS Used Oil Services is a used oil collector headquartered in Monee, Illinois .
We have two other branches in Illinois that service Wisconsin and Missouri customers
.
RS has been in this business for over 25 years and we provide the same services in more
than 15 states. Illinois is the only State to require these unnecessary and extremely costly
procedures. RS Used Oil Services endorses and supports NORA's rule proposal and
requests that the Board adopt the language proposed by NORA
.
Special Waste manifesting for used oil, including those substances entitled to be
regulated as used oil pursuant to federal and state regulations, is burdensome and
unnecessary .
In closing, our company believes that the current manifesting requirements in Illinois for
Used Oil and items regulated as Used Oil are unnecessary and burdensome . We strongly
encourage the Board to adopt the language proposed by NORA . We look forward to the
Board's adoption of NORA's rule proposal
.
www.RSUsedOil.com
Phone: (708) 534-9300
•
Fax: (708) 534-9400
•
Toll Free: t-866-RSUSEDOIL
July 26, 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
i
Dear Illinois Pollution Control Board Members
:
Our company is writing you in regards to: In the Matter of Amendments to the Board's
Special Waste Rules Concerning Used Oil, 35 Ill. Adm. Code 808, 809, RC 06-20 .
Thank you for this opportunity to provide public comment in the above-referenced
rulemaking. I submit this comment on behalf of RS Used Oil Services, Inc ., a member
of NORA. RS Used Oil Services is a used oil collector headquartered in Monee, Illinois
.
We have two other branches in Illinois that service Wisconsin and Missouri customers
.
RS has been in this business for over 25 years and we provide the same services in more
than 15 states. Illinois is the only State to require these unnecessary and extremely costly
procedures. RS Used Oil Services endorses and supports NORA's rule proposal and
requests that the Board adopt the language proposed by NORA .
Special Waste manifesting for used oil, including those substances entitled to be
regulated as used oil pursuant to federal and state regulations, is burdensome and
unnecessary.
In closing, our company believes that the current manifesting requirements in Illinois for
Used Oil and items regulated as Used Oil are unnecessary and burdensome . We strongly
encourage the Board to adopt the language proposed by NORA. We look forward to the
Board's adoption of NORA's rule proposal
.
Sincerely,
Rick Shipley
National Sales Manager
www.RS!Jseci(
.ors
lieov : (708) 534 9;if0
•
Fax : ,709) 5=i!i-9 06
•-
Ibil Frere 1 -DG6 F?S[USEf(114
.
ORIGINAL
63O3 S . RidgeInruci Avenue
Moesee. Illinois 6JS-15
RECEIVED
CLERK'S OFFICE
JUL 2 8 2006
STATE OF ILLINOIS
Pollution Control Board
Pd*
U CI :. SE't1,I CES .. INC
.
July 25, 2006
MS. Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph
Suite 11-500
Chicago, IL 60601
RE:
R2006-020
Dear Illinois Pollution Control Board Members :
Our company is writing you in regards to : In the Matter of Amendments to the Board's
Special Waste Rules Concerning Used Oil, 35 Ill. Admin. Code 808, 809, RC 06-20
.
Thank you for this opportunity to provide public comment in the above-referenced
rulemaking. I submit this comment on behalf of RS Used Oil Services, Inc, a NORA
member. RS Used Oil Services, Inc has been in the business of recycling used oils for
over 25 years . Our company has provided a valuable service to its customers by
providing our services as an alternative to illegal disposal of used oils in addition to
supplying a quality recycled product to end-users to minimize our countries dependency
on foreign oil . RS Used Oil Services, Inc endorses and supports NORA's rule proposal
and requests that the Board adopt the language proposed by NORA
.
Special Waste manifesting for used oil, including those Substances entitled to be
regulated as used oil pursuant to federal and state regulations, is burdensome and
unnecessary. RS Used Oil Services, Inc provides used oil recycling options to customers
in 17 states. Illinois is the only state our company operates in requiring the use of a
Special Waste manifest
.
In our operations, we abide by the federal and state regulations concerning used oil,
including the tracking requirements . Our company's internal paperwork has been
reviewed by every state with the exception of Illinois and has approved as meeting the
requirements in 40 CFR 279 .46 for tracking used oil. We believe that the IEPA's
position, as explained at the Board's hearing in this case, is inconsistent with the federal
program requirements and does not promote used oil recycling, as envisioned by that
program .
ORIGINAL
Cotporr.te tteatJ pint ,er
.
25903 S FSLdce and Avr n
•_
y."
R9
NO-. llhncis 604"9
C
R
'S OFFICE
JUL 2 8 2006
STATE OF ILLINOIS
Pollution Control Board
4;~1
7
www.RSUsed0ii .coni
Phone : (708) 534-9300
•
Fax: (708) 5349400 -Toll Free: 1-866-RSUSEDOIL
In closing, our company believes that the current manifesting requirements in Illinois for
Used Oil and items regulated as Used Oil are unnecessary and burdensome . We strongly
encourage the Board to adopt the language proposed by NORA . We look forward to the
Board's adoption of NORA's rule proposal .
Sincerely,
Ronald A. Winkle
President
