WILLISTON BASIN
INTERSTATE PIPELINE COMPANY
A Subsidiary of MDU Resources Group, Inc.

TRANSMITTAL FORM

TO: U.S. EPA
rcra-docket@epamail.epa.gov
  
FROM: Roger Kotschegarow
Staff Engineer
Williston Basin Interstate Pipeline Co.
P.O. Box 131
Glendive MT 59330
phone  (406) 359-7308
fax (406) 359-7225

DATE: 02 June 1998

RE: Recycled Used Oil Management Standards
Proposed Rule, Federal Register 06May98
F-98-CUOP-FFFFF

Williston Basin is a natural gas transportation and storage
company operating approximately 3,000 miles of underground
natural gas transmission pipeline in Montana, North Dakota, South
Dakota, and Wyoming.  Williston Basin operates pipeline booster
stations in which engines driving compressors, compress the
natural gas and discharges it at higher pressures down the
pipeline.  Williston Basin generates used oil from its compressor
engines during periodic oil changes.  This used oil is "on-spec"
and always has been on-spec - very low in contaminants. 
Williston Basin is pleased to provide the following
comment/clarification.

Currently, EPA is making the following clarification:

"... the initial marketer of used oil that meets the
used oil fuel specification need only keep a record of a
shipment of used oil to the facility to which the
initial marketer delivers the used oil."

Would you please clarify if Subpart H-"Standards for Used Oil
Transporters and Transfer Facilities" is applicable to those
processor and re-refiners who transport their on-spec oil or fuel
product. (We do not process/re-refine!)

We all know that used oil that is to be burned for energy
recovery and that meets the specification provided under
40CFR279.11 is essentially exempt from the regulations.  So how
about those entities that manage the on-spec used oil.  Are we,
as a generator consolidating on-spec used oil from satellite
locations to a central location regulated as a transporter and
subject to the Standards for Used Oil Transporter and Transfer
Facilities?

Their remains ambiguity in the regulations.  You can see this
ambiguity if you review the "Notification of Regulated Waste
Activity" booklets published by the U.S. EPA, dated 30NOV93.

"Persons who transport, process, re-refine, market or
burn off-spec used oil for energy recovery are  required
to notify..." (emphasis added)

Call if you have questions.  Thank you.