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