Ms. Dorothy Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph

Suite 11-500

Chicago, Illinois 60601

July 28, 2006

RE: R2006-020

Dear Illinois Pollution Control Board (IPCB) Members

:

ORIGIN 11

RECEIVED

CLERK'S OFFICE

AUG'

0 2 2006

STATE OF

ILLINOIS

Pollution Control Board

Shell Lubricants

Health, Safety, Security & Environment

700 Milam Street, Houston, TX 77002

P. 0. Box 4427, Houston, TX 77210-4427

Tel (713) 546 4209

Fax 713) 546 8505

Email brett .morton@shell.com

Internet http.//vovvv .shell-com

VIA UPS GROUND

P

C 3

~

Our company is writing you in regards to : In the Matter of Amendments to the Board's Special

Waste Rules Concerning Used Oil, 35 111 . Adm. Code 808, 809, RC 06-20 .

Thank you for this opportunity to provide public comment in the above-referenced rulemaking . I

am submitting this comment on behalf of Shell Lubricants, an associate member of NORA, An

Association of Responsible Recyclers (NORA). Shell Lubricants (which collectively refers to the

companies within Royal Dutch Shell engaged in the lubricants business) is the manufacturer,

marketer and seller of a number of popular brands of motor oil in the United States, including

Pennzoil, Quaker State, Q, Rotella, Formula Shell, and others that together make Shell Lubricants

the largest marketer and seller of motor oil products by volume in the United States

.

Shell

Lubricants also owns and either franchises or operates jiffy Lube stores in Illinois and much of the

rest of the United States. Furthermore, for the benefit of our SecureCycle TM program, we evaluate

many companies that transport, store, process and otherwise handle used oil, used oil filters and

used antifreeze to qualify them to handle the used products that result from the responsible use of

our new products by our facilities and those of our customer companies .

Shell Lubricants generally supports regulation of used oil and related materials that is consistent with

federal standards promulgated by the U .S. Environmental Protection Agency. To the extent that the

proposed amendments to the IPCB's special waste rules would make the state's regulations

consistent with USEPA regulations, Shell Lubricants supports these amendments, endorses and

supports NORA's rule proposal, and requests that the Board adopt the language proposed by

NORA. Shell Lubricants agrees with NORA's position that Special Waste manifesting for used oil,

including those substances subject to regulation as used oil pursuant to federal and state regulations,

is burdensome and unnecessary, as there are other regulatory requirements in place in the Illinois

regulations (and referenced federal regulations) to effectively track these materials

.

---

B. Morton to IPCB

July 28, 2006

Page 2

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 and we look forward to the Board's adoption of

NORA's rule proposal .

Sincerely,

Shell Lubricants

Brett Morton

Sr. Environmental Engineer/Product Stewardship

DBM/ajg

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