NATIONAL AUTOMOBILE DEALERS ASSOCIATION
8400 Westpark Drive  McLean, Virginia  22102
703-821-7000


                                   June 3, 1998

RCRA Docket Information Center
Office of Solid Waste (name changed to Office of Resource Conservation and Recovery on January 18, 2009) (5305G)
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460

          Re:  Hazardous Waste Management System; Identification
               and Listing of Hazardous Waste; Recycled Used Oil
               Management Standards; 40 CFR Parts 261 and 279;
               Docket- F-98-CUOP-FFFFF

Ladies and Gentlemen:

     The National Automobile Dealers Association (NADA) is a
national trade association of 20,000 franchised automobile and
truck dealers involved in the retail sale of new and used motor
vehicles, both foreign and domestically produced.  NADA members
also engage in automotive service, repair and parts sales. 
Virtually all automobile and truck dealership service departments
menage used oil.

     Last month, EPA issued a notice soliciting comment on a
proposal to eliminate errors and clarify ambiguities in the used
oil management standards.  63 Fed. Reg.25006, et seq. (May
6,1998). NADA generally supports EPA's proposed technical
corrections and clarifications on used oil and PCBs, responses to
used oil releases in non-authorized states, used oil fuel, and
marketer recordkeeping.  Moreover, non-withstanding the fact that
NADA advises its members (approximately half of whom are
estimated to be conditionally exempt small quantity generators
(CESQG's)) not to intentionally mix hazardous wastes into their
used oil, NADA fully supports and agrees with EPA's clarification
that mixtures of CESQG wastes and used oil should be subject to
the used oil management standards, irrespective of how the
mixture is to be recycled.

     On behalf of NADA, I thank EPA for the opportunity to
comment on this matter.

                         Sincerely,



                         Douglas I. Greenhaus
                         Director, Environment, Health and Safety