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Chemical Industry

I

I

/

Illinois

of

VED

OCT

01

2Q09

STATE

OF

ILL1NOS

September

30,

2009

PoIutiOfl

Control

Board

Dorothy

Gunn, Clerk

Illinois Pollution Control Board

James R Thompson

Center

100W Randolph Street, Suite 11-500

-

Chicago, 1L60601

Re:

R06-020, Proposed Amendments

to

the Board’s

Special Waste Regulations

Concerning Used Oil, 35 III. Adm.

Code 739, 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,

National

Oil Recyclers Association. CICI is

a

statewide

trade

association

representing the

chemical industry in Illinois. CICI has 200

member

companies employing over 49,000 workers in 726

manufacturing

facilities and 877

wholesale and distribution facilities in Illinois.

CICI would like

to

thank

the Board for its careful consideration in regard

to this

proposed rule to improve

used

oil regulations in the

state

of Illinois.

Eliminating the

requirement

for unnecessary and duplicative

manifests will reduce paperwork

and costs.

This is especially important for small

businesses. Under the Board’s proposed

amendments the tracking of used oil shipments will continue,

but

will

be much more

efficient and

cost-effective

for facilities.

The proposed amendments

will help level the playing field for Illinois

based

businesses by

reducing the burden.

These burdens are not imposed on businesses

in

other states.

It is therefore that CICI urges the Board

to adopt its proposed amendments

without any changes.

Respectfully submitted,

k/c

Lisa Frede

Director of Regulatory Affairs

Chemical Industry Council of Illinois

Headquarters

1400

E.

Touhy

Ave.,

Suite 110, Des Flames, 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