CICI/:rIndust

September 19,

0fJ1fl0Is

SEP22

2008

Dorothy Gunn, Clerk

Illinois Pollution Control

Board

STATE

OF

ILLINOIS

James R. Thompson

Center

PoIIuton

Control

Board

Chicago,

100 W. Randolph

IL 60601

Street, Suite 11-500

íç

Re:

R 06-020, Proposed Amendments

to the Board’s

Special Waste

Regulations

Concerning

Used Oil, 35 III. Adm. Code 808,809

Dear Illinois Pollution

Control Board Members,

The Chemical Industry

Council of Illinois (“CICI”) would like to

register its voice

in

support of NORA, an

Association

of Responsible Recyclers. CICI is a

statewide trade

association representing

the chemical industry in Illinois. CICI has 198

member

companies employing

over 49,000

workers

in 726

manufacturing facilities and

877

wholesale and distribution

facilities in Illinois.

The Illinois

EPA’s

Used Oil Manifesting Program is a

burden

to

the

generators,

transporters, transfer

facilities and processors

in

our industry. NORA is asking

for relief

of the unreasonable

and expensive

regulatory burden of

additional documentation

and

special facility permitting

that is already addressed

by the

Federal Regulatory

System.

None of the

states bordering Illinois requires manifesting for used oil

shipments

or special permitting for

used oil mixtures such

as

used oil and water, and

they do not

deal with this

odd, expensive and confusing

system. There is no

logical reason

why

materials otherwise regulated

as used oil

(e.g. oily

water) should not be handled as

used

oil. The IEPA language discourages

recyclers from basing their business

in Illinois.

CICI believes that the current

proposal by NORA will

improve the used

oil

recycling system in Illinois

by dispensing with the manifest for used oil and

materials

regulated

as used oil. All

of the information that IEPA might need will be put

on

a

bill of

lading or

other tracking document.

There is no need for duplicative

paperwork.

The

federal used oil regulations

do not require

a manifest and neither do any

of the states

that border Illinois.

There is

absolutely no environmental benefit from the manifest. It’s an

expensive

waste of

paper that imposes

an unfair burden on Illinois used oil

generators

and transporters.

It is therefore

that CICI

supports the NORA’s

petition designated

R06-020.

Respectfully

submitted,

Lisa

Frede

Director

of Regulatory

Affairs

Chemical

Industry

Council

of Illinois

Headquarters

1400 E.

TOUHY AVENUE, SUITE 110, DES PLAINES, IL 60018 TEL:

(847)

544-5995 FAX:

(847)

544-5999

Springfield

400W. MONROE, SUITE 205, SPRINGFIELD, IL 62704 TEL: (217) 522-5805 FAX: (217) 522-5815

Website: www.cicil.net