TN

THE MATER

OF:

PROPOSED

AMENDMENTS

TO THE

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNING USED

OIL

35 ILL.

ADM.

CODE

808,

809

)

COMMENTS

OF

VARIOUS

ENTITIES

)

PRE-FILED

TESTIMONY

)

Office

of

the Attorney

General

69

West

Washington

Street,

Suite

1800

Chicago,

Illinois

60602

Mr.

Matthew

J.

Dunn

Illinois

Environmental

Protection

Agency

1021

North

Grand

Avenue

East

P.

0. Box

19276

Springfield,

Illinois

62794

Stephanie

Flowers,

Esquire

Brown,

Hay

and

Stephens,

L.L.P.

700 First

Mercantile

Bank

Building

205

South

Fifth Street

P.

0. Box2459

Springfield,

Illinois

62705

Claire

A.

Manning,

Esquire

Illinois

Environmental

Regulatory

Group

215

East

Adams

Street

Springfield,

Illinois

62701

NOTICE

OF

FILING

CLERK’S

OFFICE

SEP

262008

STATE

OF

ILLINOIS

PIItj

Control

Board

Ms.Deirdre

K. Hirner

Executive

Director

Illinois

Pollution

Control

Board

100 Randolph

Street

Suite

11-500

Chicago,

Illinois

60601

Ms.

Dorothy

Gunn

Clerk

of Illinois

Pollution

Control

Board

100

Randolph

Street

Suite

11-500

Chicago,

Illinois

60601

Tim

Fox,

Esquire

Hearing

Officer

Illinois

Pollution

Control

Board

100

Randolph

Street

Suite

11-500

Chicago,

Illinois

60601

PLEASE

TAKE

NOTICE

that

I

have

today

filed

with

the

Office

of

the

Clerk

of

the Pollution

Control

Board,

comments

of: Independent

Lubricant Manufacturers

Assoc.,

Noble

Oil Services,

BEFORE

THE

ILLINOIS

POLLUTION

CONTROL

BOARD

)

)

)

R06-20

)

(Rulemaking

— Land)

)

---

Christopher

September

22, 2008

2001 South

Tracy

Bozeman,

Montana

59715

Telephone: (406)

586-9902

---

CLERK’S

OFFICE

SEP262008

FROM

:Ejic

OIL

-

VVV

V

•

:3e54779410

Sep. ZB

2908

Ø:5iPM

pj

STATE

OF

ILLINOIS

V

V

PollUtion

Control

Board

V

:&.VV

V

V

Liconse8&Isured

V

V

V )

MO. Box

520582

• Murn,

FL 331

52

11952

V

Dilde:

305-477-7497

V

V

Toll

Free:

1-809-344-9590

V

INTHE

MATTER

OF:

V

PROPOSED

AMENDMENTS

TO

TI-tB

V

BOARD’S

SPECIAL

WASTE

V

V

V

V

CONCERNIN(3

V

V

USED

OIL,

35 iLL.

VAPM.c0l808,

809

V

V

V

V

VPR,-FILED

TESTIMONY

OF

MARIA

F.

LEON

-

V

V

V On

bthalfV

Qf

V

the

recyclers

and

generators

of

used oil

in

Illinois,

your

dompany

name

is- asking

the

Illinois

Pollution

Control

Board

to

mitigate

the

V

unreasonable

and

expensive

regulatory

hordes

of

additiànal

documentation

V

V

V

and

special

facility

permitting

imposed

by

the

current

rules.

These

V

requirements

re

already

addresd

by the

Federal

Regulatory

System.

The

V

V

current

duplicative

-Illinois

V

regulations

do

not

increase

compliance

with

V

V

V existing

Federal

Regulations

— especially

when

the

Iillnis

EPA

does

not

V

V

receive,

analyze

or

Vtr.ack

manifests

and

their data,

:

The

fundamental

problem

is

that the

regulattoes

that the

Illinois

EPA

has

V

V

V

proposed

to

Vgulate

used

oil

V

and

cothpatible

wastes

V:mider

(mixtures

that

/

V

are

conidered

used

il

under

Vtlle

Federal.

Regulations),

does

iÔtV

allow

for

any

type of

tilinois

noi-hagardous

transfr

facil

ies àhd

processors

to

V

V

VV

operate

uider

just-the

used

oil regulations

V

V

V

V

The

Illinois

EPA

has propos

tO.

clisconiniie

maiiifesting

used

oils

— hut

V

V

V

would

reqUire

a

manifcstfor

mixtures

regulated

as

üsedoil

and require

those

V

V

V

materials

to

go

‘to

siecially

permitted

facilities

iii

Uhinois.

NORA

proposes

V

V

V

that

‘all

materials

classified

as

used

oil (uhder.

the

federal

regulations)

would

NOT

n&d

-a

manifest

-- but

all

mievant

information

would

be

set forth

in

a

tracking

document

(bill

of

lading)

In addition,

the

requirement

of

specially

permitted

facilities

to

handle

such

materials

if

based

in

Tllrnois

would

put

V

V

:

illinois

hosed

recyclers

at a

se’ere

disadvantage

Vwhn

çoniprd

to

thair

out

---

FRON

:

ElC

DL

CO

FPX NO.

3554775415

Sep 18 28 m 51PM

P2

of

state

competitors,

who would

not be subject

to this expensive

requirement,

The

language

that the illinois

EPA

proposes and the Illinois Pollution

Control

Board

is considering does

not

address the unreasonable and

expensive

burden,

and would

increase

recycling

costs

to

Illinois

generators

due to

transportation

costs of common

and compatible waste often mixed

with used

oil,

even including water.

Unfortunately,

the

Illinois Environmental Protection Agency

language

discourages recyclers

from

basing

their business

in Illinois.

Illinois

businesses

will

relocate

to a

state

that

addresses used oil

recycling with

the

simplicity

of the Federal

Regulatory

System. The lost of

revenue to Illinois

will

only compound Illinois

extreme

financial problems, and generators in

rural areas would lose service

options

and face increased

costs for

recycling,

NORA started out these

discussions with

the

Illinois

EPA

believing

we

were

dealing

with mainly

a

paperwork issue to

rectilj some problems.

Now it has

also

become a permitting issue

as

well,

with much

more

serious potential

consequences

for

Illinois

based

recyclers

and

generators. Why

can’t

Illinois

be like

other

states?

For all the

reasons

NORA has

articulated — we

agree with the need

of

NORA’s

proposed language

being

submitted

today

and the

importance of it

being

adopted by th

board and

added

to the

state

regulations.

Respectfully

submitted,

i

4

RIA E,

--

LEON-PRES.

E.M.C. OIL

CO.

Dated:

September 19,

2008

---

. .:..

:

..

..

•.•

.:

.

. . .

:

:

•

.

. .

:

•

;

:

:•

,

i•

:••

•

•.

MQneeWiQs6O449..

..

. :

:

SEP

6

2Uü

IN

THE

MATTER

OF

jATE

n

OF141No1s

PROPOSED

AMENDMENTS

TO

THE

\)

ü.

BOARD’S SPECIAL

WASTE

REGULATIONS

CONCERNING

USED

OIL,

35 ILL

ADM

CODE

808,

809

PRE-FILED TESTIMONY

OF

RONALD

A WINKLE

On

behalf

of

the

recyclers

and

generators

of used

oil in

Illinois,

RS Used

Oil

Services,

Inc

is

asking

the Illinois

Pollution

Control

Board

to

mitigate

the

unreasonable

and

expensive

regulatory

burden

of

additional

documentation

and

apeetaI-ethty-permittfng

imposed—by-the--current--rules

These

requirements

are

already

addressed

by

the

Federal

Regulatory

System

The

current

duplicative

Illinois

regulations

do

not increase

compliance with

existing

Federal

Regulations

— especially

when

the

Illinois

EPA

does

not

receive,

analyze

or track

manifests

and

their

data

The

fundamental

problem

is

that

the

regulations

that

the

Ilimois

EPA has

proposed

to

regi4ate

used

oil

and

compatible

wastes

(mixtures

that

are

considered

used

oil

under

the

Federal

Regulations),

does

not

allow

for

any

type

of Illinois

non-hazardous

transferfacilities

and

processors

to

operate

under

just

the

used

oil regulations

The

Illinois

EPA

has

proposed

to

discontinue

manifesting

used

oils

— but

would

require

a

manifest

for

mixtures regulated

as

used

oil

and

require

those

materials

to

go

to specially

permitted

facilities

in

Illinois

NORA

proposes

that

all

matenals

classified

as

used

oil

(under

the

federal

regulations)

would

NOT

need

a

manifest

-

but all

relevant

infonnation

would

be

set forth

in

a

tracking

document

(bill

of

lading)

In

addition,

the

requirement

of

specially

permitted

facilities

to

handle

such matenals,

if

based

in

Illinois

would

put

Illinois

based

recyclers

at

a

severe

disadvantage

when

compared

to their

out

www

RSUsedOiI

corn

Phone

(708>

534-9300

a-Fax

(708)

534

9400

oToll

Free

1-866

SUEDOIL

---

of

state

competitors,

who

would

not be

subject

to

this expensive

requirement.

The

language

that the

Illinois

EPA

proposes

and the

Illinois

Pollution

Control

Board

is considering

does

not

address

the

unreasonable

and

expensive

burden,

and

would

increase

recycling

costs to

Illinois

generators

due to

transportation

costs

of common

and

compatible

waste

often

mixed

with

used

oil,

even including

water.

Unfortunately,

the Illinois

Environmental

Protection

Agency

language

discourages

recyclers

from

basing

their

business

in Illinois.

Illinois

businesses

will

relocate

to

a

state

that addresses

used oil recycling

with

the

simplicity

of the

Federal Regulatory

System.

The lost

of revenue

to

Illinois

will only

compound

Illinois

extreme

fmancial

problems,

and

generators

in

rural

areas would

lose

service

options

and

face

increased

costs

for

recycling.

NORA

started

out

these discussions

with

the

Illinois

EPA

believing

we were

dealing

with

mainly

a

paperwork

issue

to rectif’

some

problems.

Now

it

has

also

become

a permitting

issue as

well,

with

much

more

serious

potential

consequences

for

Illinois based

recyclers

and

generators.

Why can’t

Illinois

be

like

other

states?

For

all the

reasons

NORA

has articulated

— we

agree

with

the need

of

NORA’s

proposed

language

being

submitted

today

and

the

importance

of it

being

adopted

by

the

board and

added

to

the

state

regulations.

Res ect

ily

submitted,

Ronald

A.

Winide

President

RS

Used

Oil

Services,

Inc.

Dated:

September

16,

2008

---

Hds

ENVIRONMFNT41

SERVI.CES,ir

\)

1’

iN

THE

MATTER

OF:

SEP

STATE

OF

iLLlNOJ

PROPOSED

AMENDMENTS

TO

THE

Pollution

Control

Soarci

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNING

USED

OIL,

35

ILL.

ADM.

CODE

808,

809

PRE-FILED

TESTIMONY

OF

Roger

L.

Wilson

On

behalf

of

the

recyclers

and

generators

of used

oil

in Illinois,

Holston

Environmental

Services,

Inc.

is

asking

the

Illinois

Pollution

Control

Board

to

mitigate

the

unreasonable

and

expensive

regulatory

burden

of

additional

documentation

and

special

facility

permitting

imposed

by

the

current

rules.

These

requirements are

already addressed

by

the

Federal

Regulatory

System.

The

current

duplicative

Illinois

regulations

do

not

increase

compliance

with

existing

Federal

Regulations

— especially

when

the

Illinois

EPA

does

not

receive,

analyze

or track

manifests

and

their

data.

The

fundamental

problem

is

that

the

regulations

that

the

Illinois

EPA

has

proposed

to

regulate

used

oil

and

compatible

wastes

under

(mixtures

that

are

considered

used

oil under

the

Federal

Regulations),

does

not

allow

for

any

type

of Illinois

non-

hazardous

transfer

facilities

and

processors

to

operate

under

just

the

used

oil

regulations.

The

Illinois

EPA

has

proposed

to

discontinue

manifesting

used

oils

— but

would

require

a

manifest

for

mixtures

regulated

as used

oil and

require

those

materials

to

go

to

specially

permitted facilities

in Illinois.

NORA

proposes

that

all materials

classified as

used

oil

(under

the federal

regulations)

would

NOT

need

a

manifest

--

but

all

relevant

information

would

be

set

forth

in

a

tracking

document

(bill

of

lading). In

addition,

the

requirement

of

specially

permitted

facilities

to

handle

such

materials, if based

in

Illinois

would

put

Illinois

based

recyclers

at

a severe

---

disadvantage

when

compared

to

their

out

of state competitors,

who would

not

be

subject

to

this

expensive

requirement.

The

language

that

the

Illinois

EPA proposes

and

the Illinois

Pollution

Control

Board

is

considering

does not

address

the unreasonable

and expensive

burden, and

would

increase

recycling

costs

to

Illinois

generators

due

to transportation

costs of

common

and

compatible

waste

often mixed

with

used oil,

even including

water.

Unfortunately,

the Illinois

Environmental

Protection

Agency

language

discourages

recyclers

from

basing

their

business

in

Illinois.

Illinois businesses

will relocate

to

a

state

that

addresses

used

oil

recycling

with

the

simplicity

of

the Federal

Regulatory

System.

The

loss of

revenue

to Illinois

will

only compound

Illinois’

extreme

financial

problems,

and

generators

in

rural

areas would

lose

service

options

and face

increased

costs for

recycling.

NORA

started

out these

discussions

with

the Illinois

EPA

believing

we

were

dealing

with

mainly

a

paperwork

issue to

rectify some

problems.

Now it

has also

become

a

permitting

issue as

well,

with much

more

serious

potential

consequences

for

Illinois based

recyclers

and

generators.

For

all

the

reasons

NORA

has

articulated

—

we

agree

with

the need

of NORA’s

proposed

language

being submitted

today

and the

importance

of it

being adopted

by

the

board

and added

to the state

regulations.

Respectfully

submitted,

?Oifon

Roger

L.

Wilson

Operations

Manager

Hoiston

Environmental

Services,

Inc.

September

18, 2008

---

iDBL.E

SEP

2

62008

01.1

SERVICES®

STATEOF,LLINO

PoIkjtjor

Control

8od

IN

THE MATThR

OF:

/

PROPOSED

AMENDMENTS

TO

THE

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNING

USED OIL,

35

ILL.

ADM. CODE

808,

809

PRE-FILED

TESTIMONY

OF

James

J.

Noble

On

behalf

of

the recyclers

and

generators

of

used

oil in

Illinois,

Noble

Oil

Services,

Inc.

is

asking

the Illinois

Pollution

Control

Board

to

mitigate

the

unreasonable

and

expensive

regulatory

burden

of additional

documentation

and

special

facility

permitting

imposed

by.

the current

rules.

These

requirements

are

already addressed

by

the

Federal

Regulatory

System.

The

current

duplicative

Illinois

. regulations

do not

increase

compliance

with

existing

Federal

Regulations

— especially

when the

Illinois

EPA does

not

receive,

analyze

or track

manifests

and

their

data.

The

fundamental

problem

is that

the

regulations

that the

Illinois

EPA

has

proposed

to

regulate

used

oil and

compatible

wastes under

(mixtures

that

are

considered

used oil

under the

Federal

Regulations),

does

not allow

for

any

type of

Illinois

non-hazardous

transfer

facilities

and.

processors

to

operate under

just

the

used oil

regulations

The

Illinois

EPA

has

proposed

to

discontinue

manifesting

used . oils

— but

would

require a

manifest for

mixtures

regulated

as used

oil

and require

those

materials

to

go to specially

permitted

facilities

in

Illinois.

NORA

proposes

that

all

materials

classified

as used oil

(under

the fe4eral

regulations)

would

NOT

need

a manifest

-- but

all relevant

informatiOn

would

be set forth

in

a

tracking

document

(bill

of lading).

In

addition,

the

requirement

of

specially

permitted

facilities

to handle

such materials,

if based

in

Illinois

would

put

Illinois

based recyclers

at a severe

disadvantage

when

compared

to their

out

of

state

competitors,

who

would not

be

subject

to

this expensive

requirement.

---

The

language

that

the

Illinois

EPA

proposes

and

the

Illinois

Pollution

Control

Board is

considering

does

not

address

the

unreasonable

and

expensive

burden,

and

would

increase

recycling

costs

to

Illinois

generators

due

to

transportation

costs

of

common

and

compatible

waste

often

mixed

with

used

oil,

even

including

water.

Unfortunately,

the

Illinois

Environmental

Protection

Agency

language

discourages

recyclers

from

basing

their

business

in

Illinois.

Illinois

businesses

will

relocate

to

a state

that

addresses

used

oil

recycling

with

the

simplicity

of

the

Federal

Regulatory

System.

The

lost

of

revenue

to

Illinois

will

only

compound

Illinois

extreme

financial

problems,

and

generators

in

rural

areas

would

lose

service

options

and

face

increased

costs

for

recycling.

NORA

started

out

these

discussions

with

the

Illinois

EPA

believing

we

were

dealing

with

mainly

a paperwork

issue

to

rectif’

some

problems.

Now

it

has

also

become

a

permitting

issue

as

well,

with

much

more

serious

potential

consequences

for

illinois

based

recyclers

and

generators.

Why

can’t

Illinois

be

like

other

states?

For

all

the

reasons

NORA

has

articulated

—

we

agree

with

the

need

of

• NORA’s

proposed

language

being

submitted

today

and

the

importance

of

it

being

adopted by

the

board

and

added

to

the

state

regulations.

Respectfully

submitted,

James

J.

Noble

President

Noble Oil

Services,

Inc.

September

18,

2008

---

THERMO

FLUIDS

The

Responsible Solution

September 16, 2008

CLERK’S

OFFICED

ILLINOIS POLLUTION

CONTROL BOARD

SEP

2

6

2008

STATE

OF

ILLINOIS

RE:

PROPOSED AMENDMENTS

TO THE

Pollution

Control

Board

BOARD’S SPECIAL

WASTE

REGULATIONS

CONCERNING

USED OIL,

35 ILL. ADM. CODE

808, 809

To whom it may

concern,

Thermo Fluids

Inc. (TFI) is asking the Illinois

Pollution Control

Board to elinjinate

the above

proposed

amendments that

would necessitate

a

uniform

hazardous waste manifests

for all used oil

shipments and

require

a

special facility permit

to accept certain

used

oil

mixtures. These requirements

are already

addressed

by the

Federal

Used

Oil Management

System which Illinois has

adopted. TFI feels these

amendments

are

unwarranted and will not promote

protection of human health and

the

environment.

TFI is a used oil recycler who operates in the

Western United States. TFI

has

the

ability to service

used oil

generators

in Illinois. With certainty,

TFI can claim used oil is

a

valuable

commodity aggressively

sought

after

to

produce Recycled Fuel Oil (RFO), Marine

Diesel Oil (MDO), and Re-refined industrial

base lube.

In

the current market, used

oil generators

get

paid for their oil.

The competition for this

used

oil proves

its value

as a

commodity. Certainly a commodity that

can be

easily

recycled would have more used oil

recycling

facilities able

to

accept it. Most importantly, used oil is being recycled

and the

recycling

program at the

state

level works.

Requiring

uniform hazardous waste manifests and special permits

to

handle

used oil in Illinois

will burden the

state, used oil generators, transporters

and processors, thereby reducing the effectiveness

of

the

program.

Oil

recycling facilities in Illinois already have agency reporting requirements,

agency inspections, waste

analysis plans

and other permit conditions

(by

rule) that IPCB regulates.

That said, it would seem prudent

to

determine if a need

for more rules are truly warranted.

A

Life

Cycle

Analysis

(LCA) drafted from

agency and

stake

holder cooperation

would

be one resource that could produce clear results. For example, there

may be

additional used oil

generator, transporter

and

processor operating

costs and compliance costs to consider.

Further, there may be

additional agency costs to roll out this type of program. Both industry

and agency

costs

and their

long term

benefits (if

any)

should

be

examined

in an LCA before significant changes

to a working

program are

considered. Presently it is unclear what additional permitting

and waste

tracking

forms will

accomplish.

TFI

will argue

that states that have implemented and run

a

used oil program that is stricter than the

Federal

standards

are not any

more successful than those

of states who regulate only by the Federal standards.

States

that do

not

require used oil

to

be transported on a waste manifest or received

by a

special permitted

facility

have

successful

programs. This point could be further substantiated in the LCA.

If Illinois

continues to

unnecessarily

burden generators and recyclers, the less likely the market will

promote

recycling. This is seen

in California who has only three permitted

used oil recycling facilities in the

state. In

Mountain States

Region

Northwest Region

South Central Region

Southwest Region

3534

West

500

South

12533

SE

Carpenter Dr.

9900

North

Crowley

4301 West Jefferson St

Salt Lake City,

UT 84104

Clackainas, OR 97015

Crowley, TX 76036

Phoenix, AZ 85043

Ph: (801) 433-1114

Ph:

(503) 7884612

Ph: (806) 637-9336

Ph: (602) 272-2400

Fax: (801) 433-1120

Fax:

(503)

788-4629

Fax:

(806) 637-4505

Fax: (602) 272-5590

---

THERMO

FLUIDS’

The Responsible

Solution

the California market the state provides incentives to used oil generators born from taxes. Contrary

to what

the State of Illinois has suggested, market experience has shown over-regulation is

counter-intuitive and

damaging to the recycling initiatives. A recent report authored in May 2008

by

Lawrence

Livermore National

Laboratory (LLNL) will support this point.

TFI does not see any

significance

by the

Illinois Pollution

Control Board (IPCB) to require manifests

for used

oil

shipments.

If

there was a

need

to

track these

shipments

further,

Illinois EPA would receive, analyze

and

track used oil manifests. At the present time I am not aware of this happening. It is note worthy

to mention

the state of Arizona tried to track used oil manifests and quickly rescinded the requirement.

V

TFI challenges the thought that use of a waste

manifest would allow

for better tracking of the used oil mixture

volumes. We respectfully disagree with this unsubstantiated statement and submit that Illinois

used oil rules

would offer no more

protection of

human

health than the Federal program. For example,

some states, such

as

Arizona, require similar used oil tracking. In fact, the

Arizona quarterly

used

oil report

requires transporters,

used oil

processers

and

marketers to provide the same if not more oil collection detail than Illinois EPA. TFI

would like

to

see a report that acknowledges

there is evidence

of a

direct connection between

the use of

a

hazardous waste

manifest and the elimination of used oil pollution. Again, I point to the need of an LCA

to

provide facts.

TFI

feels that before these amendments

are fully considered

a

formal LCA be commissioned.

The LCA

should be

developed by state agency

and stakeholders

to

address the current status of the Illinois used oil

recycling

program before

additional amendments are made. Inaccurate or lack of research into the need for

more

rules may result in proposed

amendments that overly burden state

resources, negatively affect

the used

oil recycling

market (including used oil

mixtures) and ultimately impair a working state recycling program.

Should you have any

further questions or

comments please contact me at (602) 477-8623.

Sincerely,

THERMO

FLUIDS INC.

Troy

Hacker

Corporate

Environmental,

Health

&

Safety

Mountain States Region

Northwest Region

South Central Region

Southwest Region

3534

West 500

South

12533 SE Carpenter Dr.

9900

North Crowley

4301 West Jefferson St

Salt Lake

City, UT

84104

Clackamas, OR 97015

Crowley, TX 76036

Phoenix, AZ

85043

Ph:

(801)

433-1114

Ph: (503) 788-4612

Ph:

(806) 637-9336

Ph: (602) 272-2400

Fax:

(801)433-1120

Fax:

(503)

788-4629

Fax: (806) 637-4505

Fax: (602)272-5590

---

0

92’

()•f

5

’y

2620118

Cd

IN THE

MATTER

OF:

/

v

PROPOSED

AMENDMENTS

TO

THE

BOARD’S

SPECIAL

WASTE

U

REGULATIONS

CONCERNING

USED

OIL,

35

ILL. ADM.

CODE

808, 809

PRE-FILED

TESTIMONY

OF

CHRIS

RICCI

On

behalf

of

the recyclers

and generators

of

used

oil in Illinois,

Ricky’s

Oil

Service,

Inc.

is asking

the

Illinois Pollution

Control

Board

to mitigate

the

unreasonable

and expensive

regulatory

burden

of additional

documentation

and

special

facility

permitting

imposed

by

the current

rules.

These

requirements

are

already

addressed

by

the Federal

Regulatory

System.

The

current

duplicative

Illinois

regulations

do

not

increase

compliance

with

existing

Federal

Regulations

— especially

when

the

Illinois

EPA

does not

receive, analyze

or track

manifests

and

their data.

The

fundamental

problem

is that

the regulations

that the

Illinois

EPA has

proposed

to

regulate used

oil

and

compatible

wastes

under

(mixtures

that

are considered

used

oil under

the

Federal

Regulations),

does

not

allow

for

any type

of

Illinois

non-hazardous

transfer

facilities

and processors

to

operate

under just

the used

oil regulations.

The

Illinois

EPA

has proposed

to

discontinue

manifesting

used

oils

— but

would

require a

manifest

for

mixtures

regulated

as used

oil

and require

those

materials

to go

to

specially

permitted

facilities

in

Illinois.

NORA proposes

that all

materials

classified

as used

oil

(under the

federal

regulations)

would

NOT

need

a

manifest

-- but

all relevant

information

would

be set forth

in

a

tracking

document

(bill

of lading).

In

addition,

the requirement

of specially

permitted

facilities

to handle

such

materials,

if based

in Illinois

would

put

Illinois

based

recyclers

at a severe

disadvantage

when compared

to

their out

of

state

competitors,

who

would

not be

subject

to

this

expensive

requirement.

---

The

language that

the

Illinois

EPA proposes

and the

Illinois Pollution

Control Board

is considering

does not

address the

unreasonable

and

expensive

burden,

and would

increase recycling

costs

to Illinois

generators

due to transportation

costs

of

common

and compatible

waste

often mixed

with

used oil, even including

water.

Unfortunately,

the Illinois

Environmental

Protection

Agency

language

discourages

recyclers

from

basing their

business

in Illinois.

Illinois

businesses

will

relocate

to

a state that addresses

used oil

recycling

with

the

simplicity

of

the Federal Regulatory

System.

The

lost

of revenue

to Illinois

will only

compound Illinois

extreme

financial problems,

and generators

in

rural

areas

would

lose service

options

and

face increased

costs for recycling.

NORA started

out these discussions

with

the Illinois EPA believing

we

were

dealing

with

mainly

a paperwork

issue to rectify

some problems.

Now

it has

also become

a

permitting

issue as well,

with much

more serious potential

consequences

for Illinois based

recyclers and

generators.

Why

can’t

Illinois

be like

other states?

For

all the reasons NORA

has

articulated — we

agree

with

the need

of

NORA’s

proposed

language

being

submitted

today and the

importance of

it

being adopted

by the board

and

added

to the state regulations.

Respectfully

submitted,

Chris

Ricci

President

Ricky’s

Oil Service,

Inc.

Dated:

September

17, 2008

---

SEP

262008

COflfroI

Board

IN THE

MATTER

OF:

PROPOSED

AMENDMENTS

TO THE

BOARD’S SPECIAL

WASTE

REGULATIONS

CONCERMNG

USED OIL,

35 ILL. ADM.

CODE 808, 809

PRE-FILED

TESTIMONY

OF BILL

BRIGGS

On behalf

of

the

recyclers

and generators of

used oil in Illinois,

ORRCO

is asking

the

Illinois

Pollution Control

Board

to

mitigate

the unreasonable

and expensive

regulatory

burden of additional

documentation

and special

facility permitting

imposed

by

the current

rules.

These requirements

are already

addressed

by the Federal

Regulatory

System. The

current

duplicative Illinois

regulations

do

not increase

compliance with

existing Federal

Regulations

— especially

when the Illinois

EPA

does

not receive,

analyze or track

manifests and their

data.

The

fundamental problem

is that the

regulations that the

Illinois

EPA

has proposed

to

regulate used

oil

and compatible

wastes

under

(mixtures

that are considered

used oil

under

the Federal Regulations),

does not

allow for any

type of Illinois

non-hazardous

transfer

facilities and processors

to operate

under

just

the

used oil regulations.

The Illinois

EPA has proposed

to discontinue

manifesting used

oils

— but would

require

a

manifest

for mixtures regulated

as used

oil and require

those materials

to go to specially

permitted

facilities in Illinois.

NORA

proposes

that all materials

classified as

used

oil

(under

the federal regulations)

would

NOT

need

a

manifest

-- but all relevant

information

would be

set forth in

a

tracking

document

(bill of lading).

In addition,

the requirement

of

specially permitted

facilities

to

handle

such

materials, if

based in Illinois

would

put

Illinois based recyclers

at a severe

disadvantage when

compared

to their out of

state

competitors, who

would not

be subject

to

this expensive

requirement.

The

language

that the Illinois

EPA proposes

and the Illinois

Pollution

Control

Board

is

considering

does

not

address the

unreasonable

and expensive

burden, and would

increase

Oil Re-Refining

Company

---

Oil

Re-Refining

Company

recycling

costs

to

Illinois

generators

due

to

transportation

costs

of

common

and

compatible

waste

often

mixed

with

used

oil,

even

including

water.

Unfortunately,

the

Illinois

Environmental Protection

Agency

language

discourages

recyclers

from

basing

their

business

in Illinois.

Illinois

businesses

will

relocate

to

a state

that addresses

used

oil

recycling

with

the

simplicity

of

the Federal

Regulatory

System.

The

lost

of revenue

to

Illinois

will

only

compound

Illinois

extreme

financial

problems,

and generators

in

rural

areas

would

lose

service

options

and

face

increased

costs

for

recycling.

NORA

started

out these

discussions

with

the

Illinois

EPA

believing

we were

dealing

with

mainly

a

paperwork

issue

to

rectify

some

problems.

Now

it has

also

become

a permitting

issue

as well,

with

much

more

serious

potential

consequences for

Illinois

based

recyclers

and

generators.

Why

can’t

Illinois

be

like

other

states?

For

all

the

reasons

NORA

has

articulated

—

we

agree

with

the

need

of

NORA’s

proposed

language

being

submitted

today

and

the

importance

of

it being

adopted

by

the board

and

added

to

the

state

regulations.

Respectfully submitted,

Bill

Briggs

President

Oil Re-Refining

Company

Dated:

September

16th,

2008

---

KIEP

P

26

2008

rd

INDEPENDENT

LUBRICANT

MANUFACTURERS

ASSOCIA11ON

Grw1ngStmng

September

19,

2008

4

Mr. Scott

Parker

President

NORA

Anwer

Hussain

5965

Amber

Ridge

Road

Cl-IS

Inc.

Haymarket,

Virginia

20169

Vice.

President

Ronald

M. PoweI

Re:

Illinois

Rule

Proposal

R06-20

Moroill’echnologies

Treasurer

•

Dear

Scott:

CatherineC.

Novak

Eastern

Oil

Company

The

Independent

Lubricant

Manufacturers

Association

(“ILMA”)

supports

the

efforts

of

NORA

to make

the

Illinois

used

oil

management

program

equivalent

to

the

Federal

Secretary

used

oil

management

program.

ILMA

agrees

that the

Illinois

EPA’s

proposed

rule

Rhett

Ffancrsco..

Cincinnati

Vulcan

Company

should

he

modified

so that

all

materials

classified

as

used

.dil

would

not

need

a

manifest,

Immediate

Past

President

GregT.

Julian

1LMA,

established

in 1948,

is

a

national

trade

assoëiation

of

142

manufacturing

Specialties

Advanced

lubrication

member

companies..

The,

overwhelming

majority

of

these

companies

are

“small

businusses”

as

defined

by

the Small.

Business

.Administratio.

As

a group

ILMA

Executive’:Directbr

member

companies blend,

compound and

sell

over

25

percent

of

the United

States’

Celeste

M.

Pówrs,

CAE

lubricant

needs

and

over

75

percent

of

the

metalworking

fluids

utilized

in

the country.

Jeffrey

General

1.

Cne1

Leiter

Independent

lubricant

manufacturers by definition

are

neither

owned

nor

controlled

by

companiesthat

explore

fOr

or.

refine

crude

oil

to

produce

lubricant

base

$tocks.

Base

oils

arepurchased

from

refiners

and

rerefiners,

who

are also

competitors

in

t.he

sale of

finished products.

Independent lubricant

manufacturers

succeed

by

manufacturing

and

marketing

high-quality,

often

specialized,

lubricants. Their

success

in this

competitive

market

also

is directly

attributable

to their

tradition

of

providing

excellent,

individualized

service

to

their

customers.

The

Association has

been

iiivoh’ed

wit,h

used

oil

regulatory

issues

at.the

national

and

state

levels

for more

than

28

years.

ILMA

consistently

has

sought

the

promulgation

of

used

oil management

standards

that

encourage

the

proper

handling

and

recycling

of

used oil

asa

non-hazardous

waste.

ILMA

agrees

that

the

current

Illinois

EPA’s

Used

Oil

Manifesting

Program

is a

burden

to

generators, transporters,

transfer

facilities,

processors

and

end-users.

Accordingly, the

Association

supports

NORA’s

efforts

to have

the

Illinois

EPA

modify

its proposed

rule

such

that

no manifest

would

be required

for

used

oil that

is

properly

managed

and

recycled

— that

is,

the

rules

are

parallel

to

the Federa,l

used oi

management

standards.

400

N.

Columbus

Street

Suite

201

Please

let me

know

if

ILMA

can

be

of further

assistance

on this

matter.

Alexandria,

VA

22314

phone:

703/684-5574

Sincerely

lax:

703/83685O3

email:

ilma@ilma.org

web:

www.ilrna.org

(j-

Celeste

M.

Powers,

CAE

Executive

Director

---

CLERK’S

OFFICE

SEP

2

6

2OO

Gencor

Industries

sTht

OF

ILLINOIS

5201

N

OBT

POllution

Control

Board

Orlando,

Fl

32810

INTHE

MATTER

OF:

\

z

PROPOSED

AMENDMENTS

TO

THE

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNING

USED

OIL,

35

ILL.

ADM.

CODE

808,

809

PRE-FILED

TESTIMONY

OF

MARK

HOWARD

On

behalf

of

the

recyclers

and

generators

of

used

oil

in

Illinois,

Gencor

Industries

is asking

the

Illinois

Pollution

Control Board

to mitigate

the

unreasonable

and

expensive

regulatory

burden

of

additional

documentation

and

special

facility

permitting

imposed by

the

current

rules.

These

requirements

are

already

addressed

by

the

Federal

Regulatory

System.

The

current duplicative

Illinois

regulations

do

not

increase

compliance

with

existing

Federal

Regulations

—

especially

when

the

Illinois

EPA

does

not

receive, analyze

or track

manifests

and

their

data.

The

fundamental

problem

is that

the

regulations

that

the

Illinois

EPA

has

proposed

to

regulate

used

oil

and

compatible

wastes

under

(mixtures

that

are

considered

used

oil

under

the

Federal

Regulations),

does

not

allow

for

any

type

of

Illinois

non-hazardous

transfer

facilities

and

processors

to

operate

under

just

the

used

oil

regulations.

The

Illinois

EPA

has

proposed

to

discontinue

manifesting

used

oils

—

but

would require

a

manifest

for

mixtures

regulated

as used

oil

and

require

those

materials

to

go

to

specially

permitted

facilities

in Illinois.

NORA

proposes

that

all

materials

classified

as

used

oil

(under

the

federal

regulations)

would

NOT need

a

manifest

--

but

all

relevant

information

would

be

set

forth

in

a

tracking

document

(bill

of

lading).

In

addition,

the

requirement

of

specially

permitted facilities

to

handle

such

materials,

if

based

in

Illinois

would

put

Illinois

based

recyclers

at

a

severe

disadvantage

when

compared

to

their

out

of

state

competitors,

who

would

not

be

subject

to

this

expensive

requirement.

---

The language

that

the

Illinois

EPA proposes and the Illinois Pollution

Control Board is considering does not address the

unreasonable and

expensive burden, and would increase recycling

costs to Illinois generators

due to

transportation costs

of

common

and compatible waste often mixed

with used oil, even including water.

Unfortunately,

the Illinois

Environmental Protection Agency language

discourages recyclers from

basing their business in Illinois.

Illinois

businesses

will relocate

to a state that addresses used oil recycling

with the

simplicity of the Federal Regulatory System. The lost of revenue

to Illinois

will only compound Illinois extreme financial problems,

and generators in

rural areas would

lose

service options and face increased costs for recycling.

NORA started out these discussions with the

Illinois

EPA believing we were

dealing with mainly a paperwork issue to rectify some problems. Now it has

also become a

permitting issue as well, with much more serious potential

consequences for Illinois based recyclers and generators. Why can’t Illinois

be

like other states?

For all the

reasons NORA has articulated — we agree with the need of

NORA’s

proposed

language being submitted today and the importance of it

being

adopted by the

board and

added to

the state regulations.

Respectfully

submitted,

Mark

Howard

VP

of Sales

Gencor

Industries

Dated:

September 17,

2008

---

ECELENVJRONMENTAL

lNCORPORTED

•.--

WtèOU

--

-

SCS

-

-

S

:-

-

IN

THE

MATTER

OF

PROPOSED

AMENDMENTS

TO

THE

f-BOARD’S

SPECIAL

WASTE

-

-

-.

:

---

REGULATT0N5

CONCERNTh4G

-

-

:

-

-

-

--

-

USED

OIL,

35

ILL.

ADM.

CODE

-808,809

-

--

--

-

-

PRE-FILED

TESTIMONY

OF

KENNETH

B

PETRUCK

On

behalf

of

the

recyclers

and

generators

of

used

oil

in

Illiuois,

Excel

Environmental,

Inc

is

asking

the

illinois

Pollution

Control

Board

to

mitigate

the

unreasonable

and

expensive

reguiatory

burden

of

additional

documentation

and

special

facility

permitting

imposed

by

the

current

rules

These

requirements

are

already

addressed

by

the

Federal

Regulatory

System

The

current

duplicative

Illinois

regulations

do

not

increase

compliance

with

existing

Federal

Regulations

especially

when

the

Illinois

EPA

does

not

receive,

analyze

or

track

manifests

and

their

data

The

fundamental

problem

is

that

the

regulations

that

the

Illinois

EPA

has

proposed

to

regulate

used

oil

and

compatible

wastes

under

(mixtures

that

are

considered

used

oil

under

the

Federal

Regulations)

does

not

allow

for

any

type

of

Illinois

non-hazardous

transfer

facilities

and

processors

to

operate

under

just

the

used

oil

regulations

-

The

Illinois

EPA

has

prOposed

to

discontinue

manifesting

used

oils-

-

but

wouki

require

a

manifest

for

mixtures

regulated

as

used

oil

and

require

those

materials

to

go

to

specially

permitted

facilities

in

Illinois

K1ORA

proposes

that

all

materials

classified

as

used

oil

(under

the

federal

regulations)

would

NOT

need

a

manifest

—

but

all

relevant

information

would

be

set

forth

in

a

tracking

document

(bill

of

lading)

In

addition,

the

requirement

of

specially

permitted

facilities

to

handle

such

materials,

if

based

in

Illinois

would

put

Illinois

based

recyclers

at

a

severe

disadvantage

when

compared

to

their

out

of

state

competitors,

who

would

not

be

subject

to

this

expensive

requirement

The

language

that

the

Illinois

EPA

proposes

and

the

Illinois

Pollution

Control

Board

is

considering

does

not

address

the

unreasonable

and

expensive

burden,

and

would

increase

recycling

costs

to

Illinois

generators

due

to

transportation

costs

of

common

and

compatible

waste

often

mixed

with

used

oil,

even

including

water

Unfortunately,

the

Illinois

Environmental

Protection

Agency

language

discourages

recyclers

from

basing

their

business

in

Illinois

Illinois

businesses

will

relocate

to

a

state

that

addresses

used

oil

recycling

with

the

simplicity

of

the

Federal

Regulatory

System

The

lost

of

revenue

to

Illinois

will

only

compound

Illinois

extreme

financial

problems,

P.O.

8Ox

5010-

-

River

Forest.

lIliois

6030

(708)

36440

Fax

(7OS

.o0707

--

-

-

-

Oil

Cleaning

-

and

Recycling

-

-

Envirónmentdl

-

Consulting

SEP

262008

STATE

OF

-

ILLINOIS

-

POfltjn

Control

Board

---

and

generators

m

rural areas

would

lose

service

options

and

face increased

costs

for

recycling

NORA

started

out

these

discussions

with

the Illinois

EPA

believing

we

were

dealing

with

mainly

a paperwork

issue

to rectify

some

problems

Now it

has

also

become

a

permitting

issue

as

well

with

much

more

serious

potential

consequences

for

Illinois

based

recyclers

and

generators

Why can’t

Illinois

be

like

other states

9

For

all the

reasons

NORA

has articulated

— we

agree with

the

need

ofNORA’s

proposed

language

being

submitted

today

and the

importance

of it

being

adopted

by the

board

and

added

to

the state

regulations

Respectfully

submitted,

Kenneth

B

Petruck

President

Excel

EnvironnientaI

Inc

Dated

September

16,2008

---

CLERK’S

OFFICE

SEP

26

2008

STATE

OF

1LLlNOij

C. —

Chicago

Petroleum

CluIfollUtiOn

Control

Boar&

iN THE MATTER

OF:

PROPOSED

AMENDMENTS

TO THE

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNiNG

USED OIL,

35 ILL. ADM. CODE

808,

809

PRE-FILED

TESTIMONY

OF The

Chicago Petroleum

Club

On behalf

of the recyclers

and

generators

of

used

oil in Illinois,

The

Chicago

Petroleum

Club

is

asking

the Illinois Pollution

Control

Board

to mitigate

the

unreasonable

and

expensive

regulatory

burden of additional

documentation

and special

facility permitting

imposed

by the

current rules.

These

requirements

are already

addressed

by

the Federal

Regulatory

System.

The current

duplicative

Illinois regulations

do not

increase compliance

with

existing Federal

Regulations

— especially

when the Illinois

EPA does

not receive, analyze

or track manifests

and

their

data.

The fundamental problem

is that the

regulations that

the Illinois

EPA

has proposed

to regulate

used

oil and compatible

wastes under

(mixtures

that

are considered

used oil under

the Federal

Regulations),

does not allow

for any

type of Illinois

non-hazardous

transfer facilities

and

processors

to operate under

just the

used

oil

regulations.

The Illinois EPA

has proposed

to discontinue

manifesting

used oils

— but would require

a

manifest for

mixtures

regulate4

as used oil

and require

those materials

to go to

specially

permitted facilities

in Illinois.

NORA

proposes that all

materials classified

as used oil

(under

the

federal regulations)

would

NOT need

a manifest

-- but all relevant information

would

be set

forth

in a tracking document

(bill

of lading).

In addition,

the requirement

of specially

permitted

facilities

to handle such materials,

if

based

in Illinois

would put Illinois

based recyclers

at

a

Chicago

Petroleum

Club

Phone:

708

728-1912

16W281

83

rd

Street, Suite

C, Burr Ridge,

IL 60527

---

Chicago

Petroleum

Club

severe

disadvantage

when

compared

to

their

out of state competitors,

who would not

be subject

to this

expensive

requirement.

The language

that

the Illinois

EPA proposes

and the

Illinois

Pollution Control

Board is

considering

does not address

the

unreasonable

and expensive

burden, and would

increase

recycling

costs to

Illinois generators

due

to

transportation

costs of

common

and compatible

waste

often

mixed

with used oil, even

including

water.

Unfortunately, the

Illinois Environmental

Protection

Agency

language discourages

recyclers

from

basing their

business in

Illinois. Illinois businesses

will relocate

to a state that

addresses

used

oil

recycling with the simplicity

of the

Federal Regulatory

System. The lost

of revenue to

Illinois

will only

compound

Illinois extreme

financial

problems, and generators

in rural areas

would lose

service

options

and

face

increased costs for

recycling.

NORA

started

out these

discussions with the

Illinois

EPA

believing we were

dealing with

mainly a

paperwork issue

to rectify

some

problems. Now it

has

also become

a

permitting issue

as

well,

with much

more serious potential

consequences

for

Illinois

based

recyclers

and

generators.

Why

can’t

Illinois

be like other states?

For all

the reasons

NORA

has articulated

— we

agree

with the need of

NORA’s proposed

language

being

submitted

today and

the importance of

it

being

adopted by

the board and

added

to

the state

regulations.

Respectfully

submitted,

Maureen

McGovern

President

The

Chicago

Petroleum Club

Dated:

September

16,

2008

Chicago

Petroleum

Club

Phone: 708 728-1912

16W281

83

Street,

Suite

C,

Burr

Ridge, IL

60527

---

CORPORATE

OFFICE

Cono1idated

EV

/

\

R

E

C

E V E

D

812465-5895

FAX

Pecychn

,CLERK’S

OFFICE

O

Inc

TROY, IN

47588

STATE

OF

LLINOS

Pollution

Controkct±emgroup.com

INTHEMATTEROF:

PROPOSED AMENDMENTS

TO THE

BOARD’S

SPECIAL WASTE

REGULATIONS CONCERMNG

USED OIL,

35

ILL.

ADM. CODE 808,

809

PRE-FILED

TESTIMONY OF DAVID

CARSON

On behalf of the

recyclers

and generators of used oil in Illinois, Consolidated

Recycling

Co.

Inc. is

asking

the

Illinois Pollution

Control Board to mitigate the unreasonable and expensive

regulatory burden of

additional

documentation and special facility permitting imposed

by the

current rules. These requirements are already addressed

by

the Federal

Regulatory System.

The current duplicative Illinois regulations

do

not increase

compliance with existing Federal

Regulations — especially when the Illinois EPA

does not receive,

analyze

or track manifests

and

their

data.

The

fundamental problem is that the regulations that the Illinois EPA has proposed

to

regulate used

oil and compatible wastes under (mixtures that are considered used

oil under

the

Federal Regulations),

does

not allow for

any

type of Illinois non-hazardous transfer

facilities and

processors

to operate

under

just

the

used

oil regulations.

The

Illinois EPA has proposed to discontinue manifesting used oils — but would require

a

manifest

for mixtures regulated as used oil and require those materials to go to specially

permitted

facilities in Illinois. NORA proposes that all materials classified as used oil (under

the

federal regulations) would NOT need a manifest -- but

all relevant information

would be

set

forth in a

tracking document (bill of lading). In addition, the requirement of specially

permitted

facilities to handle such materials, if based in Illinois would put

Illinois

based

recyclers at a

severe disadvantage when compared to

their

out of state

competitors,

who

would not be

subject to this expensive requirement.

The

language

that the Illinois EPA proposes and the Illinois

Pollution Control Board

is

considering does not

address the unreasonable and expensive burden,

and would

increase

recycling

costs to

Illinois generators due

to

transportation costs of common and compatible

waste

often mixed with used

oil, even including water.

---

Unfortunately,

the

Illinois

Environmental

Protection

Agency

language

discourages

recyclers

from

basing

their

business

in Illinois.

Illinois

businesses

will relocate

to

a state

that

addresses

used

oil

recycling

with

the

simplicity

of

the

Federal

Regulatory

System.

The

lost

of revenue

to

Illinois

will

only

compound

Illinois

extreme

financial

problems,

and

generators

in

rural

areas

would

lose

service

options

and

face

increased

costs

for

recycling.

NORA

started

out

these

discussions

with

the

Illinois

EPA

believing

we were

dealing

with

mainly

a paperwork

issue

to

rectify

some

problems. Now

it has

also

become

a

permitting

issue

as

well,

with

much

more

serious

potential

consequences

for

Illinois

based

recyclers

and

generators.

Why

can’t

Illinois

be

like

other

states?

For

all

the

reasons

NORA

has

articulated

— we

agree

with

the

need

of

NORA’s

proposed

language

being

submitted

today

and

the

importance

of

it being

adopted

by

the

board

and

added

to

the

state

regulations.

Respectfully

submitted,

David

E.

Carson

CEO

Consolidated

Recycling

Co.

Inc.

Dated:

September

15,

2008

---

0’3/18/2888

13:26

3138343349

USHER

OIL

tPSTP.IRS

PAGE

01

SEP

2 6

2008

tJ

I:

OIL

USHER

COMPANY

safrty recyclzng

since 1930

.

!

p

IN TI-lB

MAilER

OF:

PROPOSED

AI’vtENDMENTS TO

THE

BOARD’S

SPECIAL

WASTE

REGULATIONS CONCERNING

USED

OIL,

35

ILL,

ADM,

CODE

808, 809

PRBFILED

TESTIMONY

OF

Lyle

Saisbury

On

behalf of the

recyclers and

generators

at’ used

oil

in

lliinois,

your

compaty name is

asking the Illinois

Pollution

Coütról Board

to mitigate the

unreasonable and

expensive

regulatoty

burden

afadditional

documentation

and

special

facility

pørmitLng

nposed by

the current

rules.

These

requirements

are.alrendy

äddrèssed:by

the

Federal

Regulatory System.

The

current

duplicative

Illinois

regulations

do

not

increase compliance

with

existing

Federal

:Regulations

— especially

when

the illinois.

EPA

4oes

not

receive, analyze or track manifests

and their

data

The

fimdenmi

problem

is

that

the

regulations

that the Illinois

EPA has.

proposed

to regulate

used

oil

and

compatible wastes under

(nixtures

tI-tat

are

considered

used

oil under. the

Fedetal Regulations),

does

not allow

for

any

flpe

of

Illinois non-hazardous transfer

facilities and processors

to

operate under just the

used

oil

regulations.

The

illinois EPA has

proposed to discontinue

manifesting used

oils

— but

would require

aznanifest for

mixtures

regulated as

used

oil and

require

those

materials

to

go to specially

permitted

facilities

in

Illinois. NORA

proposes

that

all

materials classified

used

oil

(under

the federal regulations)

would

NOT

need a

manifest

— but

all

relevant

information would be set

foilli

in

a

tracking

document (bill of

lading).

In addition, the

requirement of specially

permitted facilities to handle such materials,

if

based

in illinois

would put

9000 Roxelewn Avonue

•

Dawns,

MI

48204

(813) B34-7088

Fax (313)

834-7038

---

Po22P2222

9/18/26t3B

13:26

3138343343

L19€R

OIL

UPSTOIRS

PGE

2

Illinois

based

recycIer

at

a

-evcTe

disadvantage

when

compared

to

their

out

of

state

competitors.

who

would

not

be

subject

to

this

expensive

requirement.

The

Language

that

the

Illinois

PA

propos

and

the

illinois

Pollution

Control

Board

is

considering

does

not

ad&ess

tbe

tanrcasonahle

anL

expensive

burden.

and

would

increase

recycling

costs

to

Illinois

generators

due

to

transportation

costs

of

common

and

comnattbic

waIC

olten

mi>ed

with

used

oil,

even

including

water.

Unfortunately,

the

lllinoi

Environmental

Protection

Agency

language

c1scnuraics

reeyckrs

float

basing

thcir

business

in

.Winois.

Illinois

businesses

will

rekicate

to

a

suite

that

adclrcsscs

aced

oil

reycIing

with

the

simplicity

of

the

Federal

Regulatory

System.

The

lest

of

levenue

to

Illinois

viil

only

cotnpciund

Illinois

extreme

financial

prohlcm.

and

generators

in

rural

areas

vcnild

lose

service

options

and

face

increased

costs

for

recycling.

N(.)R

started

out

these

discussions

with

the

Illinnis

EPA

believing

we

verc

dcnim

with

mainly

a

paperwork

issue

to

rectiry

some

problems.

Now

it

his

also

become

a

permitting

issue

as

well,

with

much

more

serious

potential

consequences

for

Illinois

based

rccvclcrs

az:d

generators.

Why

cant

flhinois

be

like

other

states

:(mr

all

the

rensons

SC)B.A

has

articulated

we

agree

with

the

need

of

NORA’s

proposed

language

being

submitted

today

and

the

importance

of

it

being

adopted

by

the

board

and

added

to

the

state

regulations.

Respectfully

submitted,

/

,.?

Iic

Salsbury

General

Manager

Ush

Oil

Company

Dated-

September

l,

2008

UBhe

Oil

Cerlipaily

Detroit,

Michigan

U.S.A.

---

a.

-

nd

prdcessors

to

•

.

‘diIs—bz4

- .

I

is)*ouId

f&thina

ía

wuiã. put

itotbtbput

.bof,

state-

cbmpe

.be

s

tto Lbs

expensive

.

•

.

.

.

6012

Industrial

Highway

Gary

t

?77

1151

Fax. 219977

1196

‘ToTi-Fnc

$6$.WASTE

79

-.

•

.._

t--%’

-S-.

•‘e-

-

,.MosnerEnv,tonl

.

.

.

-.

—

n

E

Op

Control

ILLINOis

8

oard

an

4

- I

--

g:.docünieUt

A:

‘emtie-

fl

Page 1

of 2

---

09/18/2008

12:98

FAX

8158029704

Mosier

EnvironRIental

t0Q2

The

language

that

the

illinois

EPA

proposes

and

the

Illinois

Pollution

Control

Board

is

considering

does

not

address

the

unreasonable

and

expensive

burden,

and

would

increase

recycling

costs

to

Illinois

generators

due

to

transportation

costs

of

common

and

compatible

waste

often

mixed

with

used

oil,

even

including

water.

Unfortunately,

the

Illinois

Environmental

Protection

Agency

language

discourages

recyclers

from

basing

their

business

in

Illinois.

Illinois

businesses

will

relocate

to

a

state

that

addresses

used

oil

recycling

with

the

simplicity

of

the

Federal

Regulatory

System.

The

lost

of

revenue

to

Illinois

will

only

compound

Illinois

extreme

financial

problems,

and

generators

in

rural

areas

would

lose

service

options

and

face

increased

costs

for

recycling.

NORA

started

out

these

discussions

with

the

illinois

EPA

believing

we

were

dealing

with

mainly

a

paperwork

issue

to

rectify

some

problems.

Now

it

has

also

become

a

permitting

issue

as

well,

with

much

more

serious

potential

consequences

for

illinois

based

recyclers

and

generators.

Why

can’t

illinois

be

like

other

states?

For

all

the

reasons

NORA

has

articulated

—

we

agree

with

the

need

of

NORA’s

proposed

language

being

submitted

today

and

the

importance

of

it

being

adopted

by

the

board

and

added

to

the

state

regulations.

Respectfully

submitted,

William

B.

Darling

President

Mosner

Energy

Alternative,

Inc.

Dated:

September

18,

2008

Page

2

of

2

---

IN

THE MATTER

OF:

PROPC

SET)

AMENDMENTh

Td

THE

BoASSPEClAI

WASTE

REGULATKNS

CONCERMNG

USEDOIL.

35

iLL.

ADM: CODE.

808,

809

V

VV

V

PRFlLEDVTflSTIMONYOF

ROLAND

AODENWAi1)JR.

-

V

VV

atwayPèfro)eiim

believes

that

ured

oil

could

be

mithifcsted

under

isriuld-stöp

log

sheeL

V

V

V

VVh

tracidoad

ofuwed

oil

coqldbe

manifested

with

one

manifest

perVtnick.

:A0u1

log

V

V

would

beilsed

to

identify

each

generator:

. V

:V

V

:

V

()

behalf

of

the

tecyc1ersVand.generatorofused0iI

in Illinois,

Gateway

Petroleusti

Co, Inc.

is

V eskirtgtheVlllhsois

Pollution

Control

Board

to

mitigate

the

uiireasosteble

and:exlitnsive

regulatory.

V

borden

of additional

documentation

and

special

facility

pemittting

imposed

by the current

rules

VV

V

V

V

Theserequicumenis are

alrCady?ddressed by

the Federal

Regulatory

SystenLV

VEnd current

duplicative

Illulois

regulations

do

not increase

compliance

with

existing

Federal

Regulation

—

especially

when

the illinois

EPA

does not

receive

analyze

or track

manifests

and their

data.

V

V

Tla

sitental

Vppoblcmis

that

the

regulations

that

the

illinoiS

EPA

has propoted

to

regulate

j

oil

and

conipatiblewastds

under

(niixtuzus

that arc

considered

used

cilVunder

the

Federal

V

V

V

Regulations),

does

not allow

for

any

type

of

Illiriois

nonhazaxdoos

transfer

fàcilhies

arid

V

V

pocessoçs

to operate

noder

just

the used

oil regulations.

V

V

V

V

V

The

Illinois

EPA

has

proposetito

discontinue

manifesting

used

oil—

bat would

require

a

manifest

foe

nuxtures

rcgulatcL

as used

oil and

require

those toatenals

to

goto

specially

pernutted

facilities

an Illinois

NORA

proposes

that

all

materials

classified

as

used

oil

(under

the

federal

regulations)

would

NOT

need a manifest

but all

relevant

information

would

be set

forth in

a tsackmg

document

(bill of lading)

V

-

V

V

The-language

that te

Illinois

EPA

proposes

and the

Illinois

Pollution

Control

Board is

-

considering

dqes

not address

the unreasonable

and

expenstve

burden

and would

increase

V

V:

zecycliugVcpststolllinois

gunerators

due to

transportation

costs

of

common..andebmpatible

waste often

mixed

with

used

oil

even

including

water

V

Unfortunately the

Illinois

Environmental

Protection

Agency

language

discouraged

recycles

from

basingtheir

business-

in

Illiñols.VIllinois

businesses

will

relocate

to a state

that

addresses

used

oil

recycling

withVtliè

simplicity

of

the Fdderal

Regulatory

System.

The loss

of

revenue

tOVllhinOj5

Er

262008

V

gt-LJNOI

Oat-cl

SEP

2

aooo

S:i2flM

HP LflSERJET

3200

V

Gateway

Petroleum

Ca,

Inc

V

VV

V

V

V7IoewestMajn

V

V

Bellevifle,

SIlino

353

V

V

V

Gl4)Vl4756

V

V

(Sit)

397-340

V

V

(618)

397-9590

Fax

P.

2

Page

lof

2

---

SEP

5000

9:13AM

HP

LASERJET

3200

p.3

will

only

compound

Illinois

extreme

financial

problems,

and

generators

in

rural

areas

would

lose

service

options

and

face

increased

costs

for

recycling.

NORA

started

out

these

discussions

with

the

Illinois

EPA

believing

we

were

dealing

with

mainly

a

paperwork

issue

to

rectify

some

problems.

Now

it

Isis

also

become

a

pennitting

issue

as

well,

with

much

more

serious

potential

consequences

for

illinois

based

mncycless

and

generators.

Why

caWt

Illinois

be

like

other

slates?

Respectfully

submitted,

Roland

A.

Odenwal

r.

Vice

President

Gateway

Petroleum

Co.,

Inc.

Dated:

September

l9

200S

Page2of2

---

02D

___________

SEP

26

2UO

Q9/1/2QO

PRZ

15,24

RX

3178740108

jRC5j8Q—P5)

0O2/002

Pollution

STATE

OP

Control

ILLINO,

8

oard

Environmental

O14OO1

CERTIFIED

September

19,

2008

$EFORE

THE

ILLINOIS

POLLUTION

CONTROL

BOARD

COF:

PROPOSED

AMENDMENTS

TO

ThE

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNING

USED

OIL,

35

ILL.

ADM.

CODE

808,

809

Dear

illinois

Pollution

Control

Board:

I

am

writing

in

support

of

the

petition

by

NORA

to

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

EPA

might

need

will

be

put

on

a

bill

of

lading

or

other

tracking

document.

There

is

no

need

for

duplicative

paperwork

which,

by

the

way,

IEPA

does

not

receive

and

never

looks

at.

The

federal

used

oil

regulations

don’t

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.

Please

adopt

NORA’s

petition.

It

is

sensible,

fair

and

will

end

a

big

paperwork

headache.

Thanks

for

your

consideration.

Sincerely,

Patrick

Kotler

Compliance

Manager

332

19

3i.319fM/4

:Si

%.39./9:,

r’1!!GnI31eDII,

‘(:.

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3

79i.jfl9i

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---

ECEVED

CLERKS

OFFICE

STATE

OF

ILLINOIS

Pollution Control

Board

BEFORE THE ILLINOIS POLLUTION

CONTROL BOARD

IN THE MATTER OF:

?

PROPOSED AMENDMENTS

TO THE

BOARD’S SPECIAL WASTE

REGULATIONS

CONCERNING

USED OIL, 35

ILL. ADM.

CODE 808, 809

Dear Illinois Pollution Control

Board:

I

am writing in support of the petition by NORA to 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

which

The IEPA does review, store, track or analyze. The federal used oil

regulations don’t 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.

Please

adopt NORA’s

petition.

It

is sensible,

fair

and will end a big paperwork

headache.

Thanks for

your consideration.

Sincerely,

John

Simon

---

RKS

OFFICE

SEP26

2008

Sep

15 00S

1:04PM

UNIVERSAL

LUBES

3165320451

p.1

STATEQFILLIN

ion

Control

Board

,

September16,

2008

IN THE

MATThR

OF

PROPOSED

AMENDMENTS TO THE

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNING

USED

OIL,

35 ILL

ADM.

CODE 808,

Sog

To:

ILLINOIS

POLLUTION

CONTROL

BOARD

On

behalf

of

the

recyclers

and

generators

of used

oil

in

Illinois,

Universal

Lubricants,

LLC

is asking

the Illinois

Pollution

Control

Board

to

change

the

language

In

the state

regulations

that

causes

an

unreasonable

and ezpensivc

regulatory

burden

to the

regulated

community.

The

cun’ent Illinois

regulations

require

additional

documentation

and

facility

permitting

above

and

beyond

the

current

Federal

regulations,

The current

regulations

do not

increase

compliance,

especially

when

the

Illinois

EPA does

not

receive,

analyze

or

track manifests

and

their data.

The

problem

is

that the

regulations

for used

oil

and used

oil mixtures,

does

not

allow

for any type

of Illinois

non-hazardous

transfer

facilities

and

processors

to

operate

under the used

oil

regulations.

The

Illinois

EPA has

proposed

to

discontinue

manifesting

used

oils, bza

would

require a manifst

far

mixtures

of

used oil

and

other contaminants,

hi addition,

these mixtures

are

required to

go to permitted

facilities.

NOR.A

penposes

that

all

materials

classified

as used

oil (under

the

federal

regulations)

would

NOT

need

a

manifest

as

ll

relevant

information

would

be on

a

bill of

lading.

In addition,

the

requirement

that

only

permitted

facilities

van

handle

such

materials

will

put

Illinois

based

recyclers

at

a

severe

cUsadvaittage

when

compared

to

their

out

of

state

competitors,

UnlverssiLubMcants,

Inc

2824

N. OHIO

/

P.O.

BOX

2920

/

WICHrT’A, KS

6720 1-2920

fla-832-oisI

/

FP,X

l6-832-0301/

800-444-OILS

/

www.tInlversalt.ubes.co

---

Sep ta

2008

1:04PM

UNIVERSAL

LLJ8ES

168320451

The

language

that

the Illinois

EPA

proposes

and the

Illinois

Pollution

Control

Board

is considering

will

cause an

unreasonable

and

expensive

burden

for

Illinois

generators

for

transportation

and

handling

of used

oil

mixtures.

Unfortunately,

the

Illinois

EPA

language

discourages

recyclers

torn

basing their

business

in Illinois.

Illinois

businesses

will

relocate

to

a

state

that

addresses

used

oil

recycling

with

the

simplicity

of

the

Federal

Regulatory

System.

The

loss

of

revenue

to Illinois

will only

compound

Illinois

extreme

financial

problems,

and

generators

in rural

areas would

lose

service

options

and

face increased

costs

fbr

recycling.

NORA

started

out

these

discussions

with the

Illinois

EPA

believing

we

were

dealing

with

a paperwork

Issue

to

rectl’

some

problems.

Now

it has

also has

become

a permitting

issue

as well,

with much

more

serious

potential

consequences

for

Illinois

based

recyciers

and generators.

We agree

with

the proposed

language

NORA

is snbmitting

today.

We feel

that it

is

very important

that the

board

give

consideration

to

this language.

Respectfully

submitted,

on

Smith

Environmental

Compliance

Manager

Universal

Lubricants,

LLC

c:

Gary Cain,

President

---

@1:

17

FR1:’LLEY

OISWIBUTX4

3t57529?56

TO174EePG

SEP

2

6

2008

Politj

STATE

OF

ILLINO,

Contr

9

j8od

VALLEY

ENVIRONMENTAL

SER

VICES

12041

l

3

O,

STREET

BURLiNGTON,

IA

52601

800-362-0734

[N

THE

MATTER

OF:

PROPOSED

AMENDMENTS

TO

THE

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNING

USED

OIL,

35

ILL.

ADM.

CODE

808,

809

PRE-FELED

TESTIMONY

OF

VALLEY

ENVIRONMENTAL

SERVICES

On

behalf

of

the

recyclers

and

generators

of

used

oil

in

Illinois,

Valley

Environmental

Services

is

asking

the

Illinois

Pollution

Control

Board

to

mitigate

the

unreasonable

and

expensive

regulatory

burden

of

additional

documentation

and

special

facility

permitting

imposed

by

the

current

rules.

These

requirements

are

already

addressed

by

the

FederaL

Regulatory

System.

The

current

duplicative

Illinois

regulations

do

not

increase

compliance

with

existing

Federal

Regulations

—

especially

when

the

Illinois

EPA

does

not

receive,

analyze

or

track

manifests

and

their

data.

The

fundamental

problem

is

that

the

regulations

that

the

Illinois

EPA

has

proposed

to

regulate

used

oil

and

compatible

wastes

under

(mixtures

that

are

considered

used

oil

under

the

Federal

Regulations),

does

not

allow

for

any

type

of

Illinois

non-hazardous

transfer

facilities

and

processors

to

operate

under

just

the

used

oil

regulations.

The

Illinois

EPA

has

proposed

to

discontinue

manifesting

used

oils

—

hut

would

require

a

manifest

for

mixtures

regulated

as

used

oil

and

require

those

materials

to

go

to

specially

permitted

facilities

in

Illinois.

NORA

proposes

that

all

materials

classified

as

used

oil

(under

the

federal

regulations)

would

NOT

need

a

manifest

--

but

all

relevant

information

would

be

set

forth

in

a

tracking

document

(bill

of

lading).

In

addition,

the

requirement

of

specially

permitted

facilities

to

handle

such

materials,

if

based

in

Illinois

would

put

Illinois

based

rccyclcrs

at

a

severe

disadvantage

when

compared

to

their

out

---

sap-ie-møa

al:

1?P

mOM:

.LEY

9ISTRIBUrI1

3157529756

TO:

917es’1603328

P.3

of

state

competitors,

who

would

not

be

subject

to

this

expensive

requilement.

The

language,

that

the

Illinois

EPA

proposes

and

the

Illinois

Pollution

Control

Board

is

considering

does

not

address

the

unreasonable

and

expensive

burden,

and

would

increase

recycling

costs

to

illinois

generators

due

to

transportation

costs

of

common

and

compatible

waste

often

mixed

with

used

oil,

even

including

water.

Unfortunately,

the

Illinois

Environmental

Protection

Agency

language

discourages

recyclers

from

basing

their

business

in

Illinois.

Illinois

businesses

will

relocate

to

a

state

that

addresses

used

oil

recycling

with

the

simplicity

of

the

Federal

Regulatory

System.

The

lost

of

revenue

to

Illinois

will

only

compound

Illinois

extreme

financial

problems,

and

generators

in

rural

areas

would

lose

service

options

and

face

increased

costs

for

recycling.

NORA

started

out

these

discussions

with

the

illinois

EPA

believing

we

were

dealing

with

mainly

a

paperwork

issue

to

rectify

some

problems.

Now

it

has

also

become

a

permitting

issue

as

well,

with

much

more

serious

potential

consequences

for

Illinois

based

recyclers

and

generators.

Why

cant

Illinois

be

like

other

states?

For

all

the

reasons

NORA

has

articulated

—

we

agree

with

the

need

of

NORA’s

proposed

language

being

submitted

today

and

the

importance

of

it

being

adopted

by

the

board

and

added

to

the

state

regulations.

Respectfully

submitted,

Ken

Reif

President

Valley

Environmental

Services

Dated;

September

16,

2008

---

RcVED

CLERKS

OFFICE

SEP

2

2008

STATE

OF

ILLINOIS

Pollution

Control

Board.

,,

Environmental

Servtces

\

THE

rrEi

OF:

PROPOSED

AMENDMENTS

TO THE

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNING

USED

OIL, 35 ILL.

ADM.

CODE 808,

809

PRE-FILED

TESTIMONY

OF

Howard Miller

On

behalf

of

the recyclers

and

generators

of

used

oil in Illinois,

Solvent

Systems

International

is asking

the

Illinois Pollution

Control

Board to

mitigate

the

unreasonable and

expensive

regulatory

burden

of

additional

documentation

and

special

facility permitting

imposed

by the

current

rules.

These

requirements

are already

addressed

by the Federal

Regulatory System.

The

current

duplicative

Illinois

regulations

do not

increase

compliance

with

existing

Federal

Regulations

— especially

when

the

illinois

EPA

does

not

receive, analyze

or track manifests

and

their

data.

The

fundamental

problem is

that

the

regulations

that

the Illinois

EPA has

proposed to

regulate

used

oil and compatible

wastes under

(mixtures

that

are

considered

used

oil under

the Federal

Regulations),

does

not

allow

for

any

type

of Illinois non-hazardous

transfer

facilities

and processors

to

operate

under

just

the

used

oil regulations.

V

The

Illinois

EPA

has proposed

to discontinue

manifesting

used oils - but

would require

a

manifest

for mixtures regulated

as used oil

and require

those

materials

to go to specially

permitted

thoiities

in

illinois. NORA

proposes

that all

materials classified

as

used oil (under

the federal

regulations) would

NOT

need a

manifest

-- but all relevant

infonnation

would

be set

forth

in a

tracking

document

(bill

of

lading).

In

addition, the

requirement

of specially

permitted

facilities

to

handle

such materials,

if based in Illinois

would

put

illinois

based recyclers

at a

severe

disadvantage

when

compared

to their

out

of

state

competitors,

who

would not

be subject to

this expensive

requirement.

10

Kiiig Street • Elk

Grove

Village,

Illinci,

60007 • (547)437-1100-

l’az

(847)437-1101

XWl

13d1

WWL;TT

BOOS

91

dS

---

The

language

that

the

Illinois

EPA

proposes

and

the

Illinois

Pollution

Control

Board

is

considering

does

not

address

the

unreasonable

and

expensive

burden,

and

would

increase

recycling

costs

to

Illinois

generators

due

to

transportation

costs

of

common

and

compatible

waste

often

mixed

with

used

oil,

even

including

water.

Unfortunately,

the

Illinois

Environmental

Protection

Agency

language

discourages

recyclers

from

basing

their

business

in

Illinois.

Illinois

businesses

will

relocate

to

a

state

that

addresses

used

oil

recycling

with

the

simplicity

of

the

Federal

Regulatory

System.

The

lost

of

revenue

to

Illinois

will

only

compound

Illinois

extreme

financial

problems,

and

generators

in

rural

areas

would

lose

service

options

and

face

increased

costs

for

recycling.

NORA

started

out

these

discussions

with

the

illinois

EPA

believing

we

were

dealing

with

mainly

a

paperwork

issue

to

rectify

some

problems.

Now

it

has

also

become

a

permitting

issue

as

well,

with

much

more

serious

potential

consequences

for

Illinois

based

recyclers

and

generators.

Why

can’t

Illinois

be

like

other

states?

For

all

the

reasons

NOR.A

has

articulated

—

we

agree

with

the

need

of

NORA’s

proposed

language

being

submitted

today

and

the

importance

of

it

being

adopted

by

the

board

and

added

to

the

state

regulations.

Respectfully

submitted,

______Howard

Miller______

_____Sales

Consultant_______

______Solvent

Systems

International,

Inc._

Dated:

September

16,

2008

*j.

israasui

ni

wucstt

anna

at

da

---

26

as/16/2aaa

iB:aa

63a529e837

t)RTH

8RANO1

ET’W

‘MI

PAGE

ft2

S

COd

North

Branch

Environmental,

a

division

of

Van

Hoesen

Industries,

he.

7N458

Garden

Avenue

Rosalie,

Illinois

60172

Phone:

630-529-0240

Fax:

630-529-0837

E-Mail:

Jvaiboesenao1com

September

16,2008

INflIEMAT1EROF:

PROPOSED

AMENDMENTS

TO

TIlE

BOARD’S

SPECIAL

WASTE

REGULATIONS

CONCERNING

IJSEJ)

OIL,

35

ILL

ADM.

CODE

808,

809

North

Branch

Environmental

On

behalf

of

the

recyclers

and

generators

of

used

oil

in

Illinois,

North

Branch

Environmental

is

asking

the

flhini

Pollution

Control

Board

to

mitigate

the

uoreasonable

and

expensive

regulatory

burden

of

additional

documentation

rind

special

facility

penxd.tting

imposed

by

current

roles.

These

requirements

are

already

addreta

by

the

Federal

Regulatory

System.

The

current

duplicative

Ulinois

regulations

do

not

increase

compliance

with

existiug

Federal

Regulations

-

especially

when

the

Illinois

EPA

does

not

receive,

analyze

ortrack

manifests

and

their

data.

The

fundamental

problem

is

that

the

regulations

that

the

Illinois

EPA

has

proposed

to

regulate

used

oil

and

compatible

waste

under

(mixture

that

are

considered

used

oil

under

the

Federal

Regulations),

does

not

allow

for

any

type

of

Illinois

non-hazardous

transfer

facilities

and

processors

to

operate

under

just

the

used

oil

regulation.

The

Illinois

EPA

has

proposed

to

discoLinue