MS . DOROTHY GUNN, CLERK

Illinois Pollution Control Board

James R . Thompson Center

100 West Randolph

Suite 11-500

Chicago, Illinois 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 III . 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 Safety-Kleen Systems, Inc ., a member

of NORA. Safety-Kleen services a large number of customers in Illinois by collecting

used oils, both automotive crank case industrial derived oils .

We direct this oil to our re-

refining plant in Indiana for processing into salable lubricating oil, or if the used oil is not

of suitable quality for re-refining it will be recycled through energy recovery .

Safety-

Kleen is the largest re-refiner of used oil in North America and plays a vital role in

conserving this resource. Last year alone we collected greater than 180 million gallons

of used oils . Therefore, Safety-Kleen 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 .

Sincere y,

Lin Lo gsh re

Sr

. Vice President of Env .,

Health and Safety

RECEIVED

saten~~K~een

ORIGINAL

JUL 312006E

Pollution

STATE OF

Control

ILLINOISBoard

July 26, 2006

5400 Legacy Drive

Cluster II, Building 3

Piano, TX 75024

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