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,