Pennzoil Company
P.O. Box 2967  Houston, Texas 77252-2967  (713)546-8516  Fax (713) 546-4355
Internet: SaroshManekshaw@pennzoil.com

Sarosh J. H. Manekshaw
Director, Environmental, Safety & Health

June 4, 1998

Docket Number F-98-CUOP-FFFFF 
RCRA Docket Information
Center, Office of Solid Waste (name changed to Office of Resource Conservation and Recovery on January 18, 2009) (5305G),
U. S. Environmental Protection Agency
401 M Street, SW.,
Washington, DC 20460.

Subject:  Hazardous Waste Management System; Identification and
          Listing of Hazardous Waste; Used Oil Management Standards
          Federal Register Dated May 6, 1998, 63 FR 24963-24969

Dear Sir or Madam:

     Pennzoil Company is a natural resource company engaged, with
its subsidiaries, in the exploration, production, refining,
sales, and distribution of petroleum and petroleum-based
products, and in the automotive quick oil change and lubrication
service industry.  Pennzoil operates a number of facilities
including petroleum refineries, distribution terminals and
petroleum bulk plants, numerous gasoline and approximately 1700
Jiffy Lube (quick lube) service stations nationwide, and oil and
gas exploration, production, and distribution facilities. 
Pennzoil also jointly owns and operates two petrolatum and white
oil specialty plants.

     Pennzoil Company's commitment to the environment includes
collecting the used oil from automobiles requesting service and
having it sent by approved haulers to facilities that use the oil
for energy producing purposes or for blending to manufacture
off-spec blend oils.  The Jiffy Lube stores also collect used oil
from individuals that decide to change their own oil.  This
service helps minimize illegal dumping by individuals thus
reducing any adverse impacts resulting from this activity.  The
May 6, 1998 proposed regulation should have a positive impact on
our current operations and continue our commitment to handle used
oil in a responsible manner.

     Pennzoil Company appreciates EPA's efforts to maintain used
oil in its present status as a non-hazardous waste.  We therefore,
support the direct final rule of May 6, 1998 and do not have any
adverse comments for submission.

     Please feel free to contact me if there are any questions at
(713) 546-8516.

Sincerely,