THERMO

j

FLWDS”

September

29, 2009

The

Responsible Solution

Ms.

Dorothy

Gun

ILLINOIS

POLLUTION

CONTROL BOARD

James

Thompson

Center

100

West Randolph

Road

Suite

11-500

Chicago,

IL 60601

CLERK’S

OFp,

OCT

OIItIn

STATE

OF

Control

ILLINOIS

Board

RE:

PROPOSED

AMENDMENTS

TO THE

BOARD’S

SPECIAL

WASTE REGULATIONS

CONCERNING

USED

OIL,

35 ILL. ADM.

CODE 739,

808, 809 (R06-20)

Dear

Ms. Gun,

Thermo

Fluids Inc. (TFI)

applauds the Illinois

Pollution

Control

Board’s

decision to eliminate

the

need

to use a uniform

hazardous waste

manifest

for all

used

oil shipments. The

transportation

document

requirements

are already addressed

by the

Federal

Used

Oil

Management System

and the new amendments

will

encourage

the recycling of

used oil.

It is note worthy to

mention the

state

of

Arizona

tried

to

track

used

oil manifests when

they

adopted the Federal

Used Oil Management

Standards.

Arizona quickly

rescinded

the

requirement. TFI believes

this

decision will reduce

the

administrative

burden

required

to

manage manifests

for used oil shipments.

TFI believes Illinois

is making

the right amendment

in

this

bill to encourage recycling.

Our

hope is that

the

state

will promote

these

regulatory

improvements

to other

valuable

resources,

such as

used

antifreeze.

Used

antifreeze is

a sought after

commodity that is recycled

in

the

Southwest

United

States

without

requirements

for manifesting

and special

use

permits.

For the reasons

listed

above, TEl agrees

with the Board

to adopt its

proposed

amendments

without any changes.

Should

you

have any

further

questions

or comments

please contact

me

at

(602)

477-8623.

Sincerely,

THERMO

FLUIDS INC.

Troy Hacker

Corporate

Environmental,

Health &

Safety Manager

Mountain States

Region

3534 West 500

South

Salt

Lake City,

UT

84104

801.433.1114 Main

801.433.1120

Fax

Northwest

Region

12533 SE

Carpenter Dr.

Clackamas,

OR 97015

503.788.4612

Main

503.788.4629

Fax

South Central Region

9900

North Crowley

Crowley, TX

76036

806.637.9336 Main

806.637.4505

Fax

Southwest Region

4301

West Jefferson St.

Phoenix, AZ

85043

602,272.2400 Main

602.272.5590

Fax

Corporate Office

8925

6. Pima Center Pkwy,

#105

Scottsdale,

AZ 85258

480.302.6221 Main

480.302.6599

Fax