L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

ATTACHMENT A

REVISED FIGURE 2 FOR GROUNDWATER MONITORING WELLS

(PART OF GROUNDWATER MONITORING PLAN)

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2 STORY

OFFICE

BUILDING

STORMWATER MANAGEMENT

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GUARD

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SITE

HAIFA 31013, ISRAEL

ELCON RECYLCING SERVICES, LLC.

P.O.B 1428

Surveyor:

Applicant :

GILMORE & ASSOCIATES

PHONE NO. 972-4-8468470/2

65 EAST BUTLER AVE

NEW BRITAIN, PENNSYLVANIA 18901

PHONE NO. (215) 345-4330

L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

ATTACHMENT B

REVISED PAGES FOR RCRA PART B APPLICATION

RCRA PART B SECTION I – CLOSURE PLAN

L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

PART B

SECTION I

(REVISED PAGES ONLY ARE PROVIDED)

L:\Projects\Elcon\1065\EV201065.01\Section I - All.docx I-14 Revised January 29, 2020

TABLE I-1

FINAL CLOSURE COST ESTIMATE SUMMARY1

Cost Summary

Decontaminating the Facility $16,559,282

Groundwater Monitoring $ 91,531

Surface Water Monitoring $ 880

Other Monitoring $ 15,157

Subtotal $16,666,850

Inflation Adjustments

Inflation Rate 6.3%

Inflation Cost $ 1,050,012

Contingency and Administrative Fees

Administrative Fees (10%) $1,666,685

Contingency Fee (20%) $3,333,370

TOTAL ≈ $22,716,917

1 See Appendices I-4 and I-5 for a detailed breakdown of costs and assumptions.

L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

PART B

SECTION I

APPENDIX I-4

2510-FM-BWM0057b 1/2009 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION

BUREAU OF WASTE MANAGEMENT

- 1 - Revised January 29, 2020

BONDING WORKSHEETS FOR HAZARDOUS WASTE

STORAGE AND TREATMENT FACILITIES

BONDING WORKSHEET B GROUNDWATER MONITORING SYSTEM

1. Number of wells in the approved monitoring plan: 5 a. Average well depth 30 ft. b. Number of wells with dedicated pumps 0 2. Number of wells monitored per Act 108: 0 3. Unit cost to upgrade a well with a dedicated pump: NA $/well (Provide supporting documentation from third parties for this cost)

4. Unit cost to install a well (including drilling, installation

developing and pump installation): 6,000 $/well (Provide supporting documentation from third parties for this cost)

5. Number of wells to be installed (wells in the approved plan that have not been installed): 0

6. Number of wells to be replaced over the life of the

monitoring period (10% of line 1 rounded up): 1 7. Number of pumps to be replaced/repaired

(25% of line 1 over the monitoring period): 0 8. Unit cost to purge and sample a well: 750 $/well (Provide supporting documentation from third parties for this cost. Labor costs should conform to US Dept. of Labor, Bureau of Labor Statistics most recent rates)

9. Unit cost to analyze samples: a. Quarterly analyses 828 $/well b. Annual analysis NA $/well c. Other approved frequency of analysis NA $/well (Provide supporting documentation from a third party laboratory)

2510-FM-BWM0057b 1/2009

- 2 - Revised January 29, 2020

10. Unit cost to analyze data (including review of lab QA/QC data, database input, form completion, statistical analysis and data review): 1,500 $/well

(Provide supporting documentation from third parties for this cost)

11. Cost to purge, sample and analyze: quarterly (line 8 + line 9a + line 10): 3,078 $/well

12. Cost to purge, sample and analyze: annually

(line 8 + line 9b + line 10): NA $/well 13. Cost to purge, sample and analyze: other

(line 8 + line 9c + line 10): NA $/well 14. Number of years of sampling (operational plus

closure time): 1 years 15. Cost to decommission monitoring well 1,460 $/well 16. Cost Summary:

a. System upgrade ([line 1- line 1b] x line 3) $NA

b. Wells to be installed (line 4 x line 5) $0

c. Wells to be replaced (line 4 x line 6) $6,000

d. Pumps to be replaced (line 3 x line 7) $0

e. Cost of quarterly monitoring ([line 1 + line 2 + 1] x “4” x line 11 x line 14) $73,872

(Note: Act 108 wells required to be monitored quarterly)

f. Cost of annual monitoring

([line 1 +1] x line 12 x line 14) $NA

g. Cost of other frequency monitoring ([line 1 +1] x line 13 x line 14) $NA

h. Cost to decommission monitoring well $7,300

Subtotal $87,172 Adjustment for resampling, assessments, etc.

a. Use 5% of subtotal if assessment in last 2 years. b. Use 10% of subtotal if in assessment,

abatement or increase monitoring $4,359 (5%) Total $91,531

2510-FM-BWM0057d 4/2009 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION

BUREAU OF WASTE MANAGEMENT

Revised January 29, 2020

BONDING WORKSHEETS FOR HAZARDOUS WASTE STORAGE AND TREATMENT FACILITIES

BONDING WORKSHEET D

SUMMARY COST WORKSHEET

Cost Summary See Attachment I-4-1.1 for cost documentation. 1. Decontaminating the Facility $16,559,282 2. Groundwater Monitoring $91,531 3. Surface Water Monitoring $880 4. Other Costs $15,157 (Site specific monitoring or reporting costs)

Subtotal $16,666,850 Inflation 4. Inflation rate (projected inflation based on the inflation rate for the prior year)

6.3 % 5. Inflation cost for facility (subtotal x line 4) $1,050,012 Contingency and administrative fees 6. Administrative fees (10%) (subtotal x 0.1) $1,666,685 7. Contingency fee amount – 20% $3,333,370

Total (subtotal + line 5 + line 6 + line 7) $22,716,917

2510-FM-BWM0057q 4/2009 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION

BUREAU OF WASTE MANAGEMENT

- 1 - Revised January 29, 2020

BONDING WORKSHEETS FOR HAZARDOUS WASTE DISPOSAL AND POST-CLOSURE CARE FACILITIES

BONDING WORKSHEET Q

SUMMARY COST WORKSHEET

Cost Summary See Attachment I-4-1.1 for cost documentation.

1. Decontaminating the Facility $16,559,282

2. Groundwater Monitoring $91,531

3. Surface Water Monitoring $880

4. Gas Monitoring $NA

5. Gas Collection $NA

6. Other Monitoring $15,157

7. Leachate Management $NA

8. Borrow Area Closure $NA

9. Facility Maintenance $NA

10. Other Costs $NA (Explain)

Subtotal $16,666,850 Inflation

11. Inflation rate (projected inflation based on the inflation for the prior year) 6.3 %

12. Inflation cost for facility (subtotal x line 11) $1,050,012

Contingency and administrative fees

13. Administrative fees (10%) (subtotal x 0.1) $1,666,685

14. Contingency fee amount – 20% $3,333,370

Total (subtotal + line 12 + line 13 + line 14) $22,716,917

Revised January 29, 2020

Attachment I-4-1.1 SUPPLEMENTAL NOTES: CLOSURE COST

CALCULATIONS

The following sections describe the assumptions and calculations that were used to determine

costs for worksheets A, B, C, D, G, J, and Q . The other worksheets were not applicable to this

facility.

Worksheet A – Facility Decontamination

• Inputs to the CostPro software are summarized in Table I-4-1.1

• Cost estimates and outputs from CostPro are summarized in Table I-4-1.2. Print outs of the

CostPro sheets are included in Appendix I-5.

• Analytical costs are summarized in Table I-4-1.3. Quotes are included in Attachment I-4-1.2.

• Engineering costs are summarized in Table I-4-1.4.

• Inflation rate calculation from 2009-2018 is in Table I-4-1.5. This includes the 2018 GDP Data

that was not previously available in January 2019 due to the Federal Government Shut Down.

• A table of each line item in worksheet A is in Table I-4-1.6.

Worksheet A – Assumptions and Background Information

Waste Calculations:

The revised calculations are based on the maximum tank capacity for the facility. The calculations also

consider solid waste in the warehouse and liquid waste in incoming totes/drums. The closure bond

scenario consists of the following:

• 225 metric tons of solid waste in warehouse

• 11,100 gallons liquid waste in incoming totes/drum area

• Liquid waste in tanks and vessels = 2,830,156 gallons.

Additional Assumptions:

• Flushing volume is 10 percent of tank volumes, tanks are flushed twice

• Piping volume – assumed 1,000 ft of 4” diameter piping in each tank area

• Only inside of tank is pressure washed, not the outside

• In-line equipment (e.g., pumps, compressors) will be cleaned with the piping.

• Decontamination of the inside of the tanks requires level B personal protective equipment

(PPE), all other activities requires level C PPE

• Maintenance cost is $5,000/month for 6 months = $30,000

• The revised calculations provide for sampling of the containment area water to determine if it is

contaminated – 99 samples are proposed – 10 samples for each of the 9 containment areas + 9

blanks.

• The revised calculations include a 10,000 gallon “contingency volume” in Area 5 to account for

the closure of day tanks and other small vessels.

Revised January 29, 2020

Worksheet B – Groundwater Monitoring System Upon startup, Elcon will install five groundwater monitoring wells, as requested by the Department.

During closure (approximately 1 year) Elcon will continue to implement the quarterly groundwater

monitoring program. The Groundwater Monitoring System costs assume 4 quarters of sampling.

For cost estimating purposes for the bonding process, it has been assumed that Appendix IX parameters

will be analyzed during the closure process and that four quarterly sampling events will be performed

during the closure.

Elcon obtained laboratory cost estimates from two prospective vendors and selected the vendor with the

highest unit cost. In addition, Elcon obtained well closure costs to properly decommission the wells when

they are not longer needed.

Cost inputs for Worksheet B are summarized in Table I-4-1.14. Actual vendor cost data follows.

Worksheet C+G – Surface Water Sampling

• Waste Permit Surface Water Sampling

o The facility will not have a waste permit for surface water discharges

• NPDES Surface/Stormwater Discharge –

o The facility will have one sampling location for a NPDES stormwater discharge permit.

o It is assumed that the facility will close out the permit within one year of closure

o Cost Calculations are summarized in Table I-4-1.11

Worksheet J – Other Monitoring

• Additional costs are summarized in Table I-4-1.12

Worksheet D+Q – Closure Cost Summary

• Costs were added from worksheets A, B, C, G, and J.

• Worksheet Q inputs are summarized in Table -4-1.13

Table I-4-1.13 Worksheet Q - Closure Cost Summary

Line & Description Value

Cost Summary

1. Decontaminating the Facility $16,559,282

2. Groundwater Monitoring $91,531

3. Surface Water Monitoring $880

4. Gas Monitoring $0

5. Gas Collection $0

6. Other Monitoring $15,157

7. Leachate Management $0

8. Borrow Area Closure $0

9. Facility Maintenance Included in line 1.

10. Other Costs $0

Subtotal $16,666,850

Inflation

11. Inflation Rate 6.3%

12. Inflation Cost for Facility $1,050,012

Contingency & Administrative Fees

13. Administration Fees (10% subtotal) $1,666,685

14. Contingency Fee Amount (20% subtotal) $3,333,370

TOTAL $22,716,917

Work Sheet Q - Bond Cost Summary

Revised January 29, 2020

Number of Wells 5

Monitoring frequency Quarterly

No. of samples per Well1

Well Installation (per well)$6,000

Sampling - Assume 8 hours for

sampling by a technician @$93.75/hr

per well, per quarter$750.00

Unit cost for analysis (per sample,

based on cost estimates from

laboratory)

$828.00

Unit cost for quarterly data analysis

$1,500.00

Well decommissioning Cost (based on

Vendor Cost Estimate, per well)

$1,460.00

No. of years of sampling (4 quarters) 1

WORKSHEET B - GROUNDWATER MONITORING

SYSTEM

Revisied January 29, 2020

Proposal

Client IES ENGINEERS Date 1/7/20

Job

Address

Qty U/M Unit Price Extended

Cost to properly abandon (5) wells using grout in place methods

with cement-bentonite solution.

Mobilizaion of equipment and crew/ls 1 $750.00 $750.00

Per diem/crew night 1 $340.00 $340.00

Bucks County Well Permits by IES 0 $0.00 $0.00

Cement grout backfill/ft 150 $5.00 $750.00

Removal of well protector, cut well below grade and patch 5 $125.00 $625.00

excavation

Debris disposal if required/ls 1 $150.00 $150.00

Completion of well abandonment reports/ea 5 $35.00 $175.00

Environmental and consumables surcharge 4% 1 $111.60 $111.60

Project duration 1--1.5 days

Total $2,901.60

107 Texaco Road, Mechanicsburg, PA 17050

1-800-360-0660 717-766-4800 fax 717-691-6069

Elcon

Fairless Hills, PA

Description

Not Official

107 Texaco Rd., Mechanicsburg PA 107050

717-766-4800 or 800-360-0660 fax 717-691-6069 1 of 3

1. Job Information

Estimate Not Official

Client IES ENGINEERS Date 01/07/20

Job Elcon

Address Fairless Hills, PA Total $2,901.60

2. Scope of Work:

* Site preparation for accessibility of truck mounted drill rigs.

* Availability of on-site water for drilling operations. NA

* Availability of secure staging area for equipment and supplies.

* Erosion/Sedimentation controls and restoration provisions.

be in writing and agreed to by both parties before the work can be performed.

This proposal includes only the materials and services specifically stated in our proposal form. Items that

will be assumed to be "by others" unless specifically stated in our proposal form shall include, but not be

limited to, the following:

In delivering this proposal and entering thereafter into a contractual Arrangement, EICHELBERGERS,

INC. assumes no responsibility for existing site conditions and any liabilities, costs, claims, suits,

expenses, penalties, or demands that may result there from. Also, should the scope of services expand

or require alternative techniques not stated in our proposal form due to the existing site conditions,

EICHELBERGERS, INC. shall have the right to offer additional pricing or decline to quote accordingly

and the Owner shall have the right to accept or reject such proposals. Where trenching is required,

rock excavation and dewatering are not included unless specifically stated as such in the proposal.

EICHELBERGERS, INC. will give PA ONE CALL (or appropriate agency in other states) notification for

location of underground utilities in public right-of -ways. All location of utilities on private property will be

"by others" and EICHELBERGERS, INC. will bear no responsibility for damage or costs associated with

such utilities on private property unless they are clearly marked "by others".

EICHELBERGERS, INC. will strive to execute its' work in compliance with all laws, orders, rules, and

regulations with respect to Health & Safety. Site specific Health & Safety Plans if required shall be

provided "by others". Unless stated otherwise in our proposal form, it is assumed that all work is to be

performed in level D protection. Level upgrades will require additional compensation.

Prior to commencing work, EICHELBERGERS, INC. management personnel shall be informed of all

known wastes or hazardous materials to be encountered on-site in the execution of the work

covered by this contract. All waste handling, disposal and transportation costs shall be "by others". Also,

any air monitoring for hazardous substances shall be "by others".

EICHELBERGERS, INC. will maintain General Liability, Automobile Liability, Excess Liability, and

Worker's Compensation and Employer's Liability coverages and at the limits shown on its' standard

Certificate of Insurance ( available upon request ) during the term of this contract. Broader coverages

(ie: Pollution Liability) and higher limits will be quoted on request. Unless specifically stated otherwise,

nothing in this contract shall constitute a waiver of the right to subrogation..

Standard Terms & Conditions

107 Texaco Rd., Mechanicsburg PA 107050

717-766-4800 or 800-360-0660 fax 717-691-6069 2 of 3

Invoices will be issued at least monthly and will be due within 60 days of the invoice date

EICHELBERGERS, INC. IES

Signature:_____________________________ Signature:_______________________________

Date:______________________ Date:____________________

EICHELBERGERS, INC. agrees to perform all work and furnish all materials in conformance with the

contract documents and generally accepted industry practices/standards.

EICHELBERGERS, INC. shall indemnify and hold harmless the Owner, Consultant, or Higher Tier

Contractor and their agents and employees from and against any and all liabilities arising from

negligence by its' employees in the performance of this contract.

The Indemnified Parties identified in the preceding paragraph shall indemnify and hold harmless

EICHELBERGERS, INC. and its' agents and employees from and against any and all liabilities arising

from negligence by their employees in connection with this contract.

107 Texaco Rd., Mechanicsburg PA 107050

717-766-4800 or 800-360-0660 fax 717-691-6069 3 of 3

Eichelbergers, Inc.

Proposal

Client IES ENGINEERS Date 1/7/20

Job

Address

Qty U/M Unit Price Extended

Drill (5) wells down to 30 feet in overburden with a finished

well consisting of 2" PVC using Geoprobe 7822DT

Mobilizaion of equipment and crew/ls 1 $950.00 $950.00

Bucks County Well Permits by IES 0 $0.00 $0.00

Per diem/crew night 4 $340.00 $1,360.00

Set up charge/well 5 $100.00 $500.00

Hollow stem auger drilling with macro core soil samples/ft 150 $28.00 $4,200.00

2" X 10' well screens/ea 5 $52.00 $260.00

2" X 10' rsier pipe/ea 10 $38.00 $380.00

2" cap and plug set/set 5 $35.00 $175.00

Provide filter sand/ bag 50 $10.00 $500.00

Provide bentonite seals/bag 5 $20.00 $100.00

Cement grout above the bentonite seals/bag 25 $18.00 $450.00

Provide & install 8" flush mount w/pad or stick-ups/ea 5 $225.00 $1,125.00

Provide 55 gallon drums/drum 12 $50.00 $600.00

Hourly charge for well construction, decon and handle drums /hr 8 $210.00 $1,680.00

Perform well development using surging and pumping/hr 5 $210.00 $1,050.00

Development equipment expendables/ls 1 $100.00 $100.00

107 Texaco Road, Mechanicsburg, PA 17050

1-800-360-0660 717-766-4800 fax 717-691-6069

Elcon

Fairless Hills, PA

Description

Not Official

107 Texaco Rd., Mechanicsburg PA 107050

717-766-4800 or 800-360-0660 fax 717-691-6069 1 of 4

Environmental and consumables surcharge 4% 1 $537.20 $537.20

Project duration 4--5 days

Total $13,967.20

107 Texaco Rd., Mechanicsburg PA 107050

717-766-4800 or 800-360-0660 fax 717-691-6069 2 of 4

1. Job Information

Estimate Not Official

Client IES ENGINEERS Date 01/07/20

Job Elcon

Address Fairless Hills, PA Total $13,967.20

2. Scope of Work:

* Site preparation for accessibility of truck mounted drill rigs.

* Availability of on-site water for drilling operations. NA

* Availability of secure staging area for equipment and supplies.

* Erosion/Sedimentation controls and restoration provisions.

be in writing and agreed to by both parties before the work can be performed.

This proposal includes only the materials and services specifically stated in our proposal form. Items that

will be assumed to be "by others" unless specifically stated in our proposal form shall include, but not be

limited to, the following:

In delivering this proposal and entering thereafter into a contractual Arrangement, EICHELBERGERS,

INC. assumes no responsibility for existing site conditions and any liabilities, costs, claims, suits,

expenses, penalties, or demands that may result there from. Also, should the scope of services expand

or require alternative techniques not stated in our proposal form due to the existing site conditions,

EICHELBERGERS, INC. shall have the right to offer additional pricing or decline to quote accordingly

and the Owner shall have the right to accept or reject such proposals. Where trenching is required,

rock excavation and dewatering are not included unless specifically stated as such in the proposal.

EICHELBERGERS, INC. will give PA ONE CALL (or appropriate agency in other states) notification for

location of underground utilities in public right-of -ways. All location of utilities on private property will be

"by others" and EICHELBERGERS, INC. will bear no responsibility for damage or costs associated with

such utilities on private property unless they are clearly marked "by others".

EICHELBERGERS, INC. will strive to execute its' work in compliance with all laws, orders, rules, and

regulations with respect to Health & Safety. Site specific Health & Safety Plans if required shall be

provided "by others". Unless stated otherwise in our proposal form, it is assumed that all work is to be

performed in level D protection. Level upgrades will require additional compensation.

Prior to commencing work, EICHELBERGERS, INC. management personnel shall be informed of all

known wastes or hazardous materials to be encountered on-site in the execution of the work

covered by this contract. All waste handling, disposal and transportation costs shall be "by others". Also,

any air monitoring for hazardous substances shall be "by others".

EICHELBERGERS, INC. will maintain General Liability, Automobile Liability, Excess Liability, and

Worker's Compensation and Employer's Liability coverages and at the limits shown on its' standard

Certificate of Insurance ( available upon request ) during the term of this contract. Broader coverages

(ie: Pollution Liability) and higher limits will be quoted on request. Unless specifically stated otherwise,

nothing in this contract shall constitute a waiver of the right to subrogation..

Standard Terms & Conditions

107 Texaco Rd., Mechanicsburg PA 107050

717-766-4800 or 800-360-0660 fax 717-691-6069 3 of 4

Invoices will be issued at least monthly and will be due within 60 days of the invoice date

EICHELBERGERS, INC. IES ENGINEERS, INC.

Signature:_____________________________ Signature:_______________________________

Date:______________________ Date:____________________

EICHELBERGERS, INC. agrees to perform all work and furnish all materials in conformance with the

contract documents and generally accepted industry practices/standards.

EICHELBERGERS, INC. shall indemnify and hold harmless the Owner, Consultant, or Higher Tier

Contractor and their agents and employees from and against any and all liabilities arising from

negligence by its' employees in the performance of this contract.

The Indemnified Parties identified in the preceding paragraph shall indemnify and hold harmless

EICHELBERGERS, INC. and its' agents and employees from and against any and all liabilities arising

from negligence by their employees in connection with this contract.

107 Texaco Rd., Mechanicsburg PA 107050

717-766-4800 or 800-360-0660 fax 717-691-6069 4 of 4

Eurofins Lancaster Laboratories Environmental ● 2425 New Holland Pike, Lancaster, PA 17601 ● 717-656-2300 ● www.EurofinsUS.com/LancLabsEnv

01/24/2019Sent via e-mail

RE: Analytical Laboratory Services by EurofinsLancaster Laboratories Environmental, LLC Quote No. 221153

Dear Rick:

Eurofins Lancaster Laboratories Environmental, LLC (ELLE) is pleased to provide this quotation for analytical testing services. The quotation includes pricing and all relevant information regarding our accreditation status, technical details, turnaround time, deliverables, and a copy of our General Provisions.

In the absence of a site specific QAPP or Statement of Work ELLE will follow the terms in our General Provisions and the method procedures and reporting limits as outlined in our Standard Operating Procedures.

For more than 50 years, ELLE has provided analytical services in the chemical and biological sciences with excellent quality and on time delivery. As one of the nation’s largest single-site contract laboratories, we offer extensive capabilities, instrumentation, and personnel resources at our 330,000-square-foot facility. We have a highly experienced staff of more than 300 that provide testing and support services 7 days a week. Our capacity, equipment, and instrumentation inventory is unmatched by any other single laboratory facility.

If you have any questions about our quotation or would like to request additional information about Eurofins Lancaster Laboratories Environmental, LLC please contact me at (717) 693-5814 and JeremyYoung@eurofinsUS.com.

Sincerely,

Jeremy R YoungAccount Manager

Enclosures

Eurofins Lancaster Laboratories Environmental ● 2425 New Holland Pike, Lancaster, PA 17601 ● 717-656-2300 ● www.EurofinsUS.com/LancLabsEnv

Mr. Rick Sacks Quote #: 221153AIES Engineers (A# 10868) Account Mgr: Jeremy Young1720 Walton Rd (717) 693-5814Blue Bell, PA 19422 JeremyYoung@eurofinsUS.com610-316-7878 Project Mgr: Eurofins Client Servicesrsacks@iesengineers.com 717-656-2300

ClientServicesLancaster@eurofinsUS.comPrepared On: 01/24/2019Expires: 04/24/2019Prepared By: Tara Spaide

Project Requirements:Project Name: RCRA App IX - Southeast PAAccreditations: Electronic Deliverable: Excel EDDData Package: Level II with QC SummaryDetection Limits: ELLE 's standard limitsMinimum Login Charge: N/AAnalysis Name Method Name Qty Cat # Unit Cost Total CostApp IX Volatiles SW-846 8260C 8 11997 $72.00 $576.00App IX Metals SW-846 6010C 8 05769 $66.00 $528.00Total Cyanide (water) SW-846 9012B 8 08255 $30.00 $240.00Sulfide SM 4500-S2 D-2011 8 00230 $17.00 $136.00App IX OC Pesticides SW-846 8081B 8 10589 $87.00 $696.00PCBs in Water SW-846 8082A 8 10591 $54.00 $432.00App IX OP Pesticides SW-846 8141B 8 10593 $136.00 $1 088.00App IX Herbicides1 SW-846 8151A 8 10407 $102.00 $816.00App IX SVOCs SW-846 8270D 8 14241 $145.00 $1 160.00Subtotal $5 672.00Environmentally Responsible Sample Handling 8 $2.50 $20.00Estimated Total per Quarterly Submittal $5 692.00

Our CertificationsEurofins Lancaster Laboratories Environmental, LLC (ELLE) holds all accreditations offered by the state of Pennsylvaniafor your project scope.

Potential Additional Charges1ELLE doesn't include hexachlorophene with our standard App IX herbicides analysis. This compound can be reported if specifically requested on the Chain of Custody submitted with the samples. The cost to add this compound to thereporting list is $42 per sample. ELLE doesn't hold PA accreditation for analysis of this compound.

The unit rates for VOCs and SVOCs do not include the addition of library searches used for identifying non-target compounds, referred to as Tentatively Identified Compounds (TICs). ELLE offers interpretive and non-interpretive TIC reporting options. If TICs are required for your project, additional charges will apply.

Pennsylvania

Eurofins Lancaster Laboratories Environmental ● 2425 New Holland Pike, Lancaster, PA 17601 ● 717-656-2300 ● www.EurofinsUS.com/LancLabsEnv

Mr. Rick Sacks Quote #: 221153AIES Engineers (A# 10868) Account Mgr: Jeremy Young1720 Walton Rd (717) 693-5814Blue Bell, PA 19422 JeremyYoung@eurofinsUS.com610-316-7878 Project Mgr: Eurofins Client Servicesrsacks@iesengineers.com 717-656-2300

ClientServicesLancaster@eurofinsUS.comPrepared On: 01/24/2019Expires: 04/24/2019Prepared By: Tara Spaide

Data Package and EDD InformationLevel II sample reports with QC summary and a standard Excel spreadsheet will be provided. Other EDD formats are available. Please let your project manager know if another format is needed. If a higher level package is needed for your project we offer Level III or IV upon request. These may be surcharged up to 20% of the total analytical cost and are available on myEOL 21 calendar days after SDG closure. These must be requested at the time of sample submittal. After-the-fact packages will be charged on a per hour basis.

Important Items to NoteIf the scope of work requires site-specific Matrix Spike/Matrix Spike Duplicates (MS/MSD), triplicate volume must be submitted and indicated as QC samples on the Chain-of-Custody. Unless sufficient volume is submitted to perform an MS/MSD for each analytical batch, a Laboratory Control Spike/ Laboratory Control Spike Duplicate (LCS/LCSD) will be performed to demonstrate precision and accuracy at a batch level. Site specific QC including matrix spikes, duplicates, and trip/field/equipment blanks will be billed at the same rates as field samples.

If your project requires special limits of quantitation or method requirements, the analyses listed may not be applicable and additional fees may apply. Please provide additional information such as required reporting limits and deliverable formats prior to submitting samples.

Sample Container Delivery and ShippingShipping bottles to the site or your office will be provided by ELLE via ground transportation at no charge. Please placeyour request for bottle delivery at least 3 days prior to your required delivery date. If fewer than 3 days notice is provided and alternative/quicker shipping is required, additional shipping and handling charges will apply. ELLE can bill your commercial courier shipping account for the next day shipping charges.

Our Same Day Courier service is available Monday through Friday from 8:00 AM to 3:00 PM for no additional charge on our regularly scheduled routes if a minimum order of $200 is met. For orders <$200, a $45 per pick-up fee will apply. Special arrangements can be made for pick-ups at other times and from outside of our standard routes. Please call at least 24 hours in advance to schedule a courier pick-up.

Eurofins Lancaster Laboratories Environmental ● 2425 New Holland Pike, Lancaster, PA 17601 ● 717-656-2300 ● www.EurofinsUS.com/LancLabsEnv

Mr. Rick Sacks Quote #: 221153AIES Engineers (A# 10868) Account Mgr: Jeremy Young1720 Walton Rd (717) 693-5814Blue Bell, PA 19422 JeremyYoung@eurofinsUS.com610-316-7878 Project Mgr: Eurofins Client Servicesrsacks@iesengineers.com 717-656-2300

ClientServicesLancaster@eurofinsUS.comPrepared On: 01/24/2019Expires: 04/24/2019Prepared By: Tara Spaide

Our TAT Commitment to YouLevel II results will be provided in 10 business days by email, or can be accessed via myEOL, our internet data access site. Rush analysis may be available and will be surcharged. Please contact your project manager for rush approval prior to submitting samples. Not all methods quoted are eligible for all rush turnaround times due to method constraints.

Client Signature: Purchase Order:

Unless agreed in writing prior to sample receipt, the attached General Terms of Sale apply to this sample submittal.

Eurofins Lancaster Laboratories Environmental ● 2425 New Holland Pike, Lancaster, PA 17601 ● 717-656-2300 ● www.EurofinsUS.com/LancLabsEnv

Purchase Orders and Contract Terms

Quoted Fees

Reporting Format (MDL/LOQ)

Data Deliverables

Turnaround Time (TAT)

Bottle Orders/Shipping

Sample Receiving

Hazardous Sample Communications

Sample Receipt Notification

Quality Control Samples

Safe and Environmentally Responsible Waste Management (SERWM)

Minimum Charge per Sample Group

Hold Analyses

Sample Storage/Disposal

Data Storage

We will hold your unused sample portions for 7 days past the date the analysis report is issued and, unless your samples need special handling, we will dispose of them following applicable regulations including but not limited to CFR, DOT, and USDA. All unused sample portions, bottles, labels, etc. are incinerated.

Analysis reports and all supporting documentation including instrument printouts, raw data, and summary forms are stored for a minimum of 5 years.

The client is responsible for communicating to the laboratory any known or suspected hazardous characteristics of the samples they intend to submit. This information should be provided in advance if available or with the samples as documentation on the Chain of Custody form. Please submit all relevant Safety Data Sheets (SDS) with each sample shipment.

Upon receipt of samples at our lab, we will review the COC, measure and record the temperature, and contact you if there are sample discrepancies. You can view your sample information including the sample ID, tests to be performed, etc. via our web site at www.Eurofinsus.com\lanclabserv. Contact your Project Manager to receive an electronic Sample Acknowledgement with the sample ID, tests to be performed, COC, and sample receipt log.

Eurofins Lancaster Laboratories Environmental, LLC will analyze and evaluate the required method quality control samples at no charge. If your project requires analysis of site-specific MS/MSD or Field QC (trip blanks, field blanks, field duplicates, equipment blanks, etc.), they are billable at the unit rates presented in the quotation.

A fee, notated as Safe and Environmentally Responsible Waste Management (SERWM), will be applied to all invoices for each sample processed by the laboratory.

Eurofins Lancaster Laboratories Environmental, LLC reserves the right to charge a minimum $150 per sample group submitted to the lab.

Any samples received at the lab but not analyzed will be invoiced at $25 per sample.

Reduced Data Packages - includes Standard Analysis Reports, a Case Narrative, QC Summary forms, Sample Prep and Run Logs, and Raw Data for GC and GC/MS analyses.

State-Specific Deliverables including New Jersey Reduced or Regulatory, New York ASP-A or ASP-B, Texas TRRP-13, Massachusetts MA MCP, Connecticut CT RCP, and other formats are also available.Hard copy (paper) data packages are not routinely provided. If a paper copy is requested, additional fees will apply.

Standard Analysis Reports are provided via email in PDF with your COC within 10-15 business days depending on the analyses requested. Samples put on hold or sequential analyses will lengthen the TAT, and may also require rush surcharges if less than half of the holding time remains when notification to proceed with testing is given.

Unless otherwise agreed or presented in this quotation, Eurofins Lancaster Laboratories Environmental, LLC requires at least 5 business days notice to prepare and ship your sample containers. We will provide shipping of the containers to you via Federal Express Ground service at no charge. Shipping of the containers back to the lab is the client's responsibility. Returned coolers and containers that are not used for sampling may be charged to the client. Eurofins Lancaster Laboratories Environmental, LLC covers shipping costs to the 48 contiguous states, excluding AK, HI, PR, and international shipping. ELLE will provide adequate sample containers, coolers, and packing materials for your project. Fees for extra supplies and the associated shipping costs will depend upon your project needs. Additional fees will apply for unused or returned sampling supplies.

Eurofins Lancaster Laboratories Environmental, LLC can receive samples 24/7. Samples will be logged in our LIMS the same day received except on Sundays, major holidays, or if discrepancies exist between samples and the chain of custody.

General Provisions (These provisions apply unless alternate provisions have been agreed to by both parties)

A valid purchase order is required with all sample submissions. Unless otherwise agreed in writing by both parties, submitting samples for testing services constitutes acceptance of the Eurofins Lancaster Laboratories Environmental, LLC Standard Terms and Conditions. Eurofins Lancaster Laboratories Environmental, LLC standard payment terms are NET 30 Days.

Unless the fees quoted are based on contractually agreed upon rates, the fees provided in this quotation are subject to revision if the size and scope of the project differs from what was originally presented to us at the time of the quote request. We reserve the right to modify our fees if there is a significant reduction in the number of samples and/or tests performed or if samples require additional preparation work in order to successfully perform the test or meet specifications.

Eurofins Lancaster Laboratories Environmental, LLC's default reporting format is to report to our MDL (Method Detection Limit). For data reported to the MDL, our standard protocol is to qualify any detections between the MDL and LOQ with a "J" on your analysis report. Please contact your project manager if you require the lab to report to the LOQ (Limit of Quantitation).

Standard Analysis Reports include a Quality Control (QC) Summary, Lab Sample Analysis Record, and your chain of custody (COC).Full Data Package (Level IV or non-CLP Validation Package) includes Standard Analysis Reports plus a case narrative, sample, standards, and QC raw data as well as QC and data summary forms required for data validation.

Eurofins Lancaster Laboratories Environmental ● 2425 New Holland Pike, Lancaster, PA 17601 ● 717-656-2300 ● www.EurofinsUS.com/LancLabsEnv

General T&C

7. Transfer of Property7.1 Title in any analysis results, products, equipment, software or similar supplied by ELLE to the customer will remain with ELLE until all invoices in respect thereof have been paid by the customer in full, and until such full payment, the customer shall have no property rights or other rights to use them. In addition, even if ELLE has accepted and begun to fulfill an order, ELLE has the right at any time to stop processing that order and to stop doing any work for a customer if that customer is late in paying any amount due to ELLE, whether for that or any other order.

5. Property Rights on Sample Material and Sample Storage5.1 All samples become the property of ELLE to the extent necessary for the performance of the order.5.2 ELLE can dispose of or destroy samples immediately after the analysis has been performed, unless ELLE and the customer have agreed in writing on the terms of ELLE’s retention of the sample. ELLE also can dispose of or destroy the samples after the agreed upon retention period, without further notice and at customer’s cost, should an extra cost for ELLE arise to comply with any regulation (for example, with respect to disposal of hazardous waste). If the customer requests the return of unneeded sample material, ELLE will return them to the customer, at the customer’s cost and risk.

6. Delivery Dates, Turnaround Time6.1 Delivery dates and turnaround times are estimates and do not constitute a commitment by ELLE. Nevertheless, ELLE shall make commercially reasonable efforts to meet its estimated deadlines.

6.2 Results are generally sent by email and/or by USPS mail, or via other electronic means, to the attention of the persons indicated by the customer in the order, promptly after the analysis is completed.

3.4 ELLE has the right to charge an administrative fee of up to fifteen dollars ($15) to re-issue an invoice.3.5 The invoice settlement method is check, bank transfer or direct debit. Any other method of payment must receive prior agreement from ELLE. The customer undertakes to provide bank account details.

3.6 ELLE is entitled to require payment of up to 100% of the quoted order price as a condition of acceptance.

4. Duties of Customer in Delivering Samples or Materials4.1 The samples or materials must be in a condition that makes the preparation of reports/analyses or the production of ordered products possible without difficulty. ELLE is entitled to conduct an initial examination of the samples or materials to check their condition before processing the samples, drawing up a report or using them in production. The customer shall bear the costs of this initial examination, if the samples or materials do not comply with the requirements described in this clause 4.1. If the result of the initial examination is that an analysis or production is impossible or is possible only under more difficult conditions than originally anticipated—for example, because the samples or materials have been interspersed with foreign materials or substances that were not reported by the customer or are degraded—ELLE shall be entitled to terminate or interrupt the order and the customer shall bear costs incurred by ELLE to that point.

4.2 The customer must ensure, and hereby warrants, that no sample poses any danger, including on its site, during transportation, in the laboratory or otherwise to ELLE premises, instruments, personnel or representatives. It is the customer’s responsibility to ensure compliance with hazardous waste regulations, including regarding information, transportation and disposal and to inform ELLE personnel or representatives about sample health and safety concerns, including any known or suspected toxic or other contaminant that may be present in the sample and its likely level of contamination as well as the risks to ELLE premises, instruments, personnel and representatives related to the contamination. The customer shall be responsible for, and indemnifies ELLE against, all costs, damages, liabilities and injuries that may be caused to or incurred by ELLE or its personnel or representatives including on the sampling site, during the transportation or in the laboratory by the customer’s sample or by sampling site conditions. The customer shall bear all extraordinary costs for adequate disposal of hazardous waste resulting from the sample, whether or not described as hazardous waste. At ELLE’s request, the customer must provide ELLE with the exact composition of the samples.

2.2 Unless specifically accepted in writing and signed by an officer of ELLE, any terms proposed or submitted by a customer at any time (including, but not limited to, terms or provisions in the customer’s purchase order, instructions or other document) which differ from these Terms and Conditions are rejected as a material alteration of these Terms and Conditions and shall be of no force or effect. Furthermore, special terms or conditions of prior orders, including special pricing, will not automatically apply to subsequent orders. Each order accepted by ELLE will be treated as a separate contract between ELLE and the customer.

2.3 A request for additional services on samples that have entered the laboratory will be treated as a new order and may postpone estimated delivery date accordingly.

3. Price and Terms of Payment3.1 If the acknowledgment of an order does not state otherwise, ELLE’s prices apply. Any additional cost or disbursement (e.g., incurred by ELLE in connection with the order) must be paid by the customer.

3.2. Prices are exclusive of all applicable taxes (including sales, use and VAT) and are based on tariffs in force at the day of the remittance of the offer to the customer. Applicable taxes are those in force at the date of invoicing.3.3 Unless specifically agreed otherwise by ELLE in its acceptance of an order, payment of all invoices is due strictly within 30 days of the invoice date. Any dispute about invoices must be raised within 30 days of the invoice date. The challenge of an analytical result will not entitle a customer to defer payment. Any invoice which remains outstanding after due date, may be additionally charged with an administrative penalty of seventy-five dollars ($75) and may carry interest at the rate of one percent (1%) per month or the maximum interest rate permitted by applicable law, whichever is lower.

1. Area of Application1.1 All Orders accepted by “Eurofins Lancaster Laboratories Environmental, LLC or any of its subsidiaries or affiliates” (collectively, “ELLE”) will be governed by these General Terms and Conditions of Sales (the “Terms and Conditions”), including orders placed by telephone which have not been confirmed in writing and orders made by delivery of samples. A contract with these Terms and Conditions comes into being when an order that has been placed with ELLE is accepted by ELLE. An order placed with ELLE is considered as accepted by ELLE when (a) ELLE proceeds to fulfill that order, without need for any written confirmation from ELLE or (b) ELLE accepts the order in writing.

If ELLE and Customer have an existing Services Agreement in place (i.e., Master Service Agreement, Laboratory Service Agreement or Environmental Service Agreement), that Agreement will constitute the entire agreement between the parties and any additional or conflicting terms and conditions are null and void.1.2 These Terms and Conditions supersede and replace all prior verbal or written price quotations and agreements between the parties and, unless specifically indicated otherwise therein, take precedence over all conflicting or inconsistent provisions of subsequent written agreements between the parties. Only the chairman or president (collectively, “officer”) has the authority to alter or waive any of these Terms and Conditions or to make any representation which conflicts with or purports to override any of these Terms and Conditions; and no such alteration, waiver or representation shall be binding upon ELLE, unless it is in writing and signed by an officer of ELLE.

2. Placement of Order2.1 A customer's order will be valid only if it is sent by mail or fax or other electronic message on letterhead of the customer or by using ELLE approved sample dispatch sheets or electronic order forms and the commercial aspects of the order which are not specifically set out in these Terms and Conditions (including price, estimated turnaround times and delivery date) must be agreed at the time of the order. The customer must confirm in writing orders given by telephone immediately after they are made and will be deemed to have placed an order if the customer sends samples to ELLE quoting the customer reference. ELLE is not obligated to start any analytical work unless the order is clear and it has been provided all required information.

Eurofins Lancaster Laboratories Environmental ● 2425 New Holland Pike, Lancaster, PA 17601 ● 717-656-2300 ● www.EurofinsUS.com/LancLabsEnv

15. Disclaimer and Miscellaneous15.1 ALL TERMS, CONDITIONS AND WARRANTIES (INCLUDING ANY IMPLIED WARRANTY AS TO MERCHANTABLE QUALITY OR FITNESS FOR A PARTICULAR PURPOSE) AS TO THE MANNER, QUALITY AND TIMING OF THE TESTING SERVICE AND RESULTS, EQUIPMENT, PRODUCTS OR SOFTWARE SUPPLIED BY ELLE ARE EXCLUDED TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW. THE WARRANTIES, OBLIGATIONS AND LIABILITIES OF ELLE CONTAINED IN THESE TERMS AND CONDITIONS ARE EXCLUSIVE.15.2 These Terms and Conditions may be modified in writing from time to time by ELLE and orders will be governed by the most recent version of these Terms and Conditions that is in effect at the time ELLE accepts the order.15.3 Should a court waive, limit or hold to be invalid, illegal or unenforceable any part of these Terms and Conditions, all other parts shall still apply to the greatest extent possible.15.4 Failure by either ELLE or the customer to exercise the rights under these Terms and Conditions shall not constitute a waiver or forfeiture of such rights.

13. Force MajeureELLE cannot be held liable for delays, errors, damages or other problems caused by events or circumstances which are unforeseen or beyond ELLE’s reasonable control, or which result from compliance with governmental requests, laws and regulations.

14. Confidentiality & Processing of Customer Data14.1 ELLE shall be entitled to save and process personal or commercial data received from the customer in any way, no matter whether such data stem from the customer directly or from a third party and shall use commercially reasonable efforts to keep such data confidential, in compliance with applicable law.14.2 ELLE shall use commercially reasonable efforts to keep all analysis results and service reports confidential, and the right to use them in order to demonstrate its entitlement to payment for services rendered.

14.3 Analysis results are prepared and supplied exclusively for the use of the customer and should not be divulged to a third party for any purposes without the prior written agreement of ELLE. In addition, the customer is required to maintain secrecy concerning all services provided by ELLE and their results as well as the composition of products and software delivered by ELLE. Analysis results are not to be publicly disclosed or exploited without the prior written consent of ELLE. Even if such written consent is given by ELLE, the customer (a) remains responsible for any consequences due to the divulgence of such results to a third party and any reliance of such third party on such results and (b) hereby agrees to indemnify the ELLE Indemnified Parties against any liability which the ELLE Indemnified Parties may incur as a result of such divulgence or any such third-party reliance.

10. SERWMA fee, notated as Safe and Environmentally Responsible Waste Management (SERWM), will be applied to all invoices for each sample processed by the laboratory.

11. Minimum Charge per Sample GroupEurofins Lancaster Laboratories Environmental, LLC reserves the right to charge a minimum $150 per sample group submitted to the lab.

12. Repeated AnalysisObjections to test results can be made within thirty (30) days after the customer receives the results. However, unless it would appear that the results of the repeated analysis do not match those of the first one, the customer shall bear the costs of the repeat testing or review. Furthermore, a repeated analysis will be possible only if ELLE has a sufficient amount of the original sample on hand when it receives the customer’s objection. Otherwise the customer will be required to pay all costs, including sampling, transportation, analytical and disposal costs for the repeat analysis.

8.4 The customer warrants and represents to ELLE that all samples sent to ELLE for analysis are safe and in a stable condition and undertakes to indemnify ELLE for any losses, injuries, claims and costs which ELLE, or its personnel, may suffer as a result of any sample not being in a safe or stable condition, notwithstanding that the customer may have given an indication on the sample or any order form of any perceived problem with the sample. The customer must always inform ELLE in writing prior to shipment and label the packaging, samples and/or containers appropriately, if the samples are dangerous or otherwise of a hazardous nature.

8.5 Unless explicitly agreed in writing by all parties, the contractual relationship shall be exclusively between the customer and ELLE. There shall be no third party beneficiary or collateral warranty relating to any order and the customer shall indemnify and hold ELLE harmless from and against any and all third party claims in any way relating to the customer or to the order by the customer.

9. Limitation of Liability9.1 Except to the extent that such limitations are not permitted or void under applicable law: (a) ELLE (together with its workers, office clerks, employees, representatives, managers, officers, directors, agents and consultants and all ELLE partners and affiliates, the “ELLE Indemnifying Parties”) shall be liable only for the proven direct and immediate damage caused by the ELLE Indemnifying Parties’ willful misconduct in connection with the performance of an order and then, only if ELLE has received written notice thereof not later than six (6) months after the date of the customer’s knowledge of the relevant claim (unless any longer period is prescribed under applicable law and cannot be contractually limited), and (b) in all cases (whether arising under contract, tort, negligence, strict liability, through indemnification or otherwise), the ELLE Indemnifying Parties’ liability per claim or series of related claims, and the customer’s exclusive remedy, with respect to ELLE’s services which fall under these Terms and Conditions, shall be limited to the lesser of: (I) the direct and immediate loss or damage caused by the ELLE Indemnifying Parties’ willful misconduct in connection with the performance of the order and (ii) ten times the amount ELLE actually received from the customer in relation to the order up to fifteen thousand dollars ($15,000).

9.2 The ELLE Indemnifying Parties shall not be liable for any indirect, direct or consequential loss or damage (including, but not limited to, loss of business, profits, goodwill, business opportunities or similar) incurred by the customer or by any third party.9.3 It is a condition of ELLE’s acceptance of an order that the customer indemnifies the ELLE Indemnifying Parties for any losses, injuries, claims and costs which the ELLE Indemnifying Parties may suffer as a result of arising from or in any way connected with its role under or services or products or software provided pursuant to these Terms and Conditions, except to the extent that the ELLE Indemnifying Parties are required to bear them according to these Terms and Conditions, and by placing an order the customer agrees to provide that indemnification.

8. Limited Warranties and Responsibilities8.1 Orders are handled in the conditions available to ELLE in accordance with the current state of technology and methods developed and generally applied by ELLE and the results may not always be 100% exact and/or relevant. Analyses, interpretations, assessments, consulting work and conclusions are prepared with a commercially reasonable degree of care but ELLE cannot guarantee that these will always be correct or absolute. This limited warranty expires six (6) months after the delivery date of the samples, if the acknowledgement of the order does not specifically state otherwise. In all cases, the customer must independently verify the validity of any results, interpretations, assessments and conclusions supplied by ELLE, if it wishes to rely on the same in respect of matters of importance and shall do so at its own risk.

8.2 Each analytical report relates exclusively to the sample analyzed by ELLE. If ELLE has not expressly been mandated and paid for the definition of the sampling plan (including which samples of which raw materials and finished products and at which frequency should be analyzed) and the definition of the precise range of analysis to be performed or if the customer has not followed ELLE recommendations, ELLE shall not bear any responsibility if the sampling plan and/or the range of analysis to be performed prove to be insufficient or inappropriate.

8.3 The customer is responsible for the proper delivery of samples sent to ELLE for examination/analyses or materials sent for production. Unless otherwise specifically agreed in writing by ELLE, ELLE accepts no responsibility for any loss or damage, which may occur to any sample in transit or to any facility or site where logistics services are being delivered. The customer will at all times be liable for the security, packaging and insurance of the sample from its dispatch until it is delivered to the offices or the laboratories of ELLE. ELLE will use commercially reasonable care in handling and storing samples, but ELLE shall not be held responsible for any loss or destruction of samples even after their receipt at its laboratories.

Eurofins Lancaster Laboratories Environmental ● 2425 New Holland Pike, Lancaster, PA 17601 ● 717-656-2300 ● www.EurofinsUS.com/LancLabsEnv

16.1 The construction, validity and performance of these Terms and Conditions shall be governed by the laws and the commercial courts of Lancaster, Pennsylvania, in which the registered office of the ELLE company which accepted the order in question is located (including in cases involving multiple counsels for the defense or third-party respondents), which shall have exclusive jurisdiction.

16. Governing Law/Jurisdiction

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

January 24, 2019

Tel:Fax:www.testamericainc.com

(732) 549-3900(732) 549-3679

Quote Number: 46028462Project Description: Appendix IX

Dear Mr. Richard Sacks:

TestAmerica Laboratories, Inc. is pleased to provide this laboratory services price quotation for the referenced project. The parameters that you have requested a price quotation for follow this page. The quoted prices apply until the expiration date that is listed on the quote.

Standard services that are provided at no additional cost include precleaned sample containers, sample labels, shipping coolers, and Reduced format pdf laboratory reports with detailed Quality Assurance documentation. Additional free value added services offered by TestAmerica's Edison laboratory include: on-line data access, Final Reports in pdf format on CD-ROM. Hardcopy deliverables can be requested for an additional fee.

In the absence of any prior written agreement to the contrary, the most recent TestAmerica Standard Terms and Conditions apply to this quotation and any resulting services.

We look forward to serving as your analytical laboratory for this testing program.

Please feel free to contact me with any questions that you might have regarding this price quotation.

Sincerely yours,

Aidan ScottClient Relations ManagerTestAmerica Laboratories, Inc.Tel: 646 7450906aidan.scott@testamericainc.com

Issued on: 1/24/2019 Page 1 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Water Samples TAT:

Matrix QuantityTest DescriptionMethod Unit Extended

PricePrice

10_Days (Business Days)

$ 480.00Appendix IX Volatiles $ 60.00 8Water 8260C

$ 280.001,4-Dioxane $ 35.00 8Water 8260C SIM

$ 760.00PAH SIM $ 95.00 8Water 8270D SIM

$ 400.00PCBs $ 50.00 8Water 8082A

$ 760.00Appendix IX Herbicides $ 95.00 8Water 8151A

$ 680.00Appendix IX Metals (Price includes Hg) $ 85.00 8Water 6020B

$ 0.00Mercury (CVAA) $ 0.00 8Water 7470A

$ 200.00Cyanide, Total $ 25.00 8Water 335.4

$ 160.00Sulfide, Total $ 20.00 8Water SM 4500 S2 F

Water Samples TAT:

Matrix QuantityTest DescriptionMethod Unit Extended

PricePrice

(to be analyzed by Sacramento)15_Days (Business Days)

$ 4,200.00Dioxin/ Furan Full List w/ Totals $ 525.00 8Water 1613B

Water Samples TAT:

Matrix QuantityTest DescriptionMethod Unit Extended

PricePrice

(to be analyzed by Buffalo)10_Days (Business Days)

$ 360.00EDB, DBCP $ 45.00 8Water 8011

$ 1,160.00Appendix IX Semi-Volatiles $ 145.00 8Water 8270D

$ 640.00Appendix IX Pesticides $ 80.00 8Water 8081B

Total Water Samples $ 10,080.00

Description Quantity Unit Extended

Quote Other Charges

Price Price

$ 20.00$ 2.50Safe and Environmentally Responsible Waste Management (per sample) 8

Total Other Charge $20.00

Total Other Charges $ 20.00

Total Analysis Charges

Grand Total for Quote 46028462

$ 10,080.00

$ 10,100.00

**Quoted charges do not include sales tax. Applicable sales tax will be added to invoices where required by law.

Issued on: 1/24/2019 Page 2 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

PROJECT DETAILS

Miscellaneous QC Samples

Non-project specific Matrix spike/matrix spike duplicate included at no additional cost. All Other QA/QC samples including Trip/Field Blanks and duplicates, will be billed at the same rate as regular samples

PA DEP Certification Exceptions:TestAmerica is certified for 8270D by PADEP, however not for the following compounds:2,6-Dichlorophenol; 2-Picoline: 2-Toluidine: 3,3'-Dimethylbenzidine; 4-Nitroquinoline-1-oxide; a,a-Dimethylphenethylamine; Aramite, Total: Dimethoate:DinosebHexachlorophene: o,o',o''-Triethylphosphorothioate: p-Dimethylamino azobenzene: p-Phenylene diamine: Sulfotepp: Thionazin

TestAmerica is certified for 8081B by PADEP, however not for the following compounds: Chlorobenzilate

Details - High-res Methods (Dioxin/PCB)

Trace Level AnalysisSamples submitted for trace level analysis of dioxins or PCBs are assumed to have concentrations no greater than 1ppb. It is important to notify the laboratory of any samples with potential concentrations above 1ppb. Unannounced samples grossly contaminated with dioxins (>1ppb) can have a severe impact on the laboratory's glassware and instrumentation. It is important our clients share in this risk and be held financially accountable for destroyed glassware that cannot be cleaned to trace level requirements. Screening, special handling, and alternative methods (8280A) will expedite the analysis and help guard against cross contamination.

Expedited Turnaround Time for High-res Methods

· Expedited turnaround times may be available and must be pre-approved by the laboratory. Samples received after 11 AM will be considered received the next business day. Expedited turnaround time surcharges for high-res analyses are:

- 5 Business Days TAT = 40%- 4 Business Days TAT = 60%- 3 Business Days TAT = 75%- 2 Business Days TAT = 100%- 1 Business Day TAT = call for pricing

MS/MSDsMatrix Spike and Matrix Spike Duplicates are not required or recommended by TestAmerica for isotope dilution methods 1613, 1668, 8280 or 8290. Each sample result is "matrix adjusted" because samples are spiked prior to sample preparation with isotopically labeled internal standards (IS). Results are recovery adjusted based on the recovery of the IS.

Matrix Spikes, if requested for high-res methods, will be billed at the unit rate.

TestAmerica Business Terms & Conditions

Confidentiality -This quote has been prepared by TestAmerica Laboratories, Inc. (“TestAmerica"), solely for the use of the customer to whom it is addressed in evaluating TestAmerica's qualifications and capabilities in connection with a particular project. The user of this document agrees by its acceptance to return it to TestAmerica upon request and not to reproduce, copy, lend, or

Issued on: 1/24/2019 Page 3 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0otherwise disclose its contents, directly or indirectly, and not to use it for any purpose other than that for which it was specifically provided. The user also agrees that where consultants or other outside parties are involved in the evaluation process, access to this document shall not be given to said parties unless those parties also specifically agree to these conditions. In the absence of signed acceptance, submittal of samples will indicate acceptance of this quotation.

Terms and Conditions - This quotation is based solely upon TestAmerica's standard product (routine QA/QC, detection limits, deliverables and standard turnaround times) and noted exceptions herein. The discounts incorporated into the pricing are based upon the sample quantity, test method, and schedule quoted. Any deviations may impact pricing and/or the acceptance of work. Final acceptance of this work is contingent upon a mutually agreed Sample Delivery Schedule. All sales are subject to TestAmerica's Terms and Conditions unless alternative terms have been agreed to in writing. Submittal of samples will indicate acceptance of this quotation.

Quote Expiration - Pricing listed in the proposal will expire 90 days from the quote date unless the project is awarded/confirmed within that time period. Unless otherwise set forth in this quotation, TestAmerica reserves the right to re-evaluate pricing for extended length projects on an annual basis.

SERWM - A fee, notated as Safe and Environmentally Responsible Waste Management (SERWM), will be applied to all invoices for each sample processed by the laboratory.

PROJECT SETUP

Field Sampling Products -TestAmerica can provide field sampling products upon request and these products are billable to the client at the time of shipment. Field sampling products may include, but are not limited to:· VOA sampling devices, preservation kits, ISM supplies, tubing and filters· Industrial Hygiene media, surface sampling wipes, source sampling traps

The cost of the soil sampling devices is not included in the quoted rates for volatile analysis. Core Samplers· 5 gram Core N’ One and EnCore samplers are available at $10 each (three required per

sample). · Disposable Core N’ One T-Handles are available at $15 each.· TestAmerica does not supply EnCore T-Handles.Field Preservation· TerraCore Kits (varied) - quoted based on client required configurations· Disposable Lock N’ Load Handles are available at $12 each.

If any sampling supplies for soil VOCs are requested, they will be included in the quote under Other Charges.

Coolers and Sampling Supplies -

· Sampling Supplies: TestAmerica will provide sample containers and coolers to support the sampling of water and soil samples. Extra bottles may be provided (up to 10%) in case of breakage. TestAmerica expects that samples and supplies will be returned to the lab, including empty coolers and a reasonable percentage of the projected sample load - 70% or higher of the expected/quoted sample number. Coolers not received back by the

Issued on: 1/24/2019 Page 4 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0projected deadline or as agreed with the PM may be charged at $30 per cooler. Similarly, if the sample containers received as samples are less than 90% of the containers provided, the sample containers not received as samples will be charged at a flat rate of $1 per container.

· Sample Container Shipping: The containers and preservatives required by the project shall be delivered via ground transportation. A minimum of 5 business days advance notice is required in order to achieve shipment by ground transportation. Supply shipments requiring priority delivery due to insufficient lead time for ground transportation shall be charged to the client at TestAmerica's cost. Alternatively, TestAmerica can ship the supplies via carrier of choice by the client using the client's shipping account.

TestAmerica does not supply wet ice or blue ice for shipments. If shipping containers are not returned within 60 days, a charge for the containers will be billed at the current market rate. Please contact your PM for the current charges.

Courier Services and Sample Pick-Up - Courier Services are offered by some TestAmerica facilities. Where offered, the cost of the services will vary based on the distance traveled, the scope of the project being supported, and whether sufficient notice (typically 48 hours) is provided to facilitate efficient scheduling. If no details are described in this quotation and you are interested in learning more about courier options, please contact your Client Relations Manager or Project Manager to inquire about availability and cost.

Minimum Log-In Charges - TestAmerica’s minimum charge is $100 for a group of samples received together for analysis. Our minimum invoice value is $100.

QC Limit Disclaimer - The laboratory's reporting limits, detection limits, and control limits are subject to change as these values are updated periodically to reflect analytical sensitivity and capability.

Turnaround Time -

· Quoted Turnaround Time - Data will be delivered at the proposed turnaround time in Business Days from Sample Receipt unless otherwise agreed upon. TAT begins the day the laboratory performing analyses receives the samples (day of lab receipt = day zero).

Samples received after 11 AM will be considered received the next business day.

· Expedited Turnaround Time: Expedited turnaround times may be available and must be pre-approved by the laboratory. Expedited turnaround delivery is contingent upon meeting the agreed upon delivery date/time and number of samples. Samples received after 11 AM will be considered received the next business day. Results will be provided via e-mail or TotalAccess by close of business in the lab's time zone unless another time has been agreed to in advance. Expedited turnaround time surcharges for standard analyses are:

- 5 Business Days TAT = 30%- 4 Business Days TAT = 45%- 3 Business Days TAT = 60%- 2 Business Days TAT = 75%- 1 Business Day TAT = 100%

Different surcharges may apply for specialty analyses. These will be provided in your

Issued on: 1/24/2019 Page 5 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0quotation. Weekend TAT can be arranged on a project-specific basis at an additional cost. Please contact your PM to inquire about availability and cost.

PROJECT DELIVERABLES

TestAmerica will provide two analytical report formats, a final report in PDF format and a standard TestAmerica EDD. Both electronic report formats will be delivered via email or web portal. If additional formats or retroactive deliverables are requested, costs of report generation will be billable. Charges will be based on labor and materials cost of report generation and data retrieval. Please contact your PM to inquire about availability and the price of additional deliverables.

· Report Format: Unless a level III or IV deliverable is specifically listed on the pricing page, this quotation includes delivery of a Level I or II report. Level III or IV reports are available at an additional charge.

· Electronic Data Deliverable Format: TestAmerica has many EDD formats available to our clients including the most widely used commercial formats. TestAmerica offers data using a standard EDD. Other EDD formats are available for a minimal cost of $25 per format (if not included as part of the report options listed in the quotation). The development of EDD formats that are not already available, including modification to existing formats to fit client specific needs, can be provided for a fee starting at $100. Additional fees will be estimated by the lab and approved by the client. Additional programming fees are billed at $50/hour.

PROJECT SPECIFICATIONS

Cancellation Fee - A fee will be charged for cancellation of samples/analyses after a project is received in the laboratory. The fee will be based on the status of analysis at the time of cancellation in accordance with the following categories:· Received - 35%· Prepped - 50% · Analyzed - 95% Changes in Scope and Work Revisions - Project requirements must be agreed upon prior to sample receipt. Samples will be logged according to the chain of custody received with the samples. Changes after initiation of the project will be subject to additional charges, including labor time required to reset project, communicate changes to laboratory staff, and rework data. Turnaround time will be reset or rush surcharges will be assessed where applicable. Analyses added with less than 1/2 of the analytical hold time remaining will incur rush turnaround charges. Your project manager will evaluate project specific charges at the time a change order is received.

Held Samples -

· Held samples not analyzed: Samples submitted on hold will be billed at 35% of the analysis fee (minimum $10/sample). If samples are later analyzed, the handling fee will be waived and only the analysis price will be charged. Samples taken off hold with less than 1/2 of the analytical hold time remaining may incur rush turnaround charges. Samples will be disposed of 30 days after the report for analyzed samples in the same job is issued, unless alternate archival arrangements are made in advance.

· Extracted/Prepped and Held samples: Samples submitted for prep and hold will be billed at 60% of the analysis fee for each prepped sample (minimum $30/sample). Samples taken

Issued on: 1/24/2019 Page 6 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0off hold with less than 1/2 of the analytical hold time remaining may incur rush turnaround charges. Samples will be disposed of 30 days after the report for analyzed samples in the same job is issued, unless alternate archival arrangements are made in advance.

· Extended archival of samples: Extended archival of samples (including held samples) may be available for a fee starting at $2 per container per month (minimum $10/sample). This fee will be billed in advance on a quarterly basis for every quarter after the standard sample retention time of 30 days after the report is issued. Fees for larger volumes, non-standard matrices or cold storage will be negotiated on a case-by-case basis. Please contact your PM to inquire about availability and pricing for samples that are sent to the lab and archived.

Matrix Spike/Spike Duplication (MS/MSD) Samples - When MS/MSDs are not specifically requested, TestAmerica will strive to perform the required QC using whatever sample is available but will not report the QC results unless the client requests it. The reporting of client requested MS/MSD results will be charged at applicable unit rates. If MS/MSDs are specifically required or requested, the client must provide additional sample volume.

Multiple Dilutions Analyzed - TestAmerica strives to analyze samples without dilution or with the minimum dilution required. Samples are diluted to bring the primary analyte within the calibration range of the instrument, to compensate for matrix co-extractives, or to prevent instrument contamination. TestAmerica will report the analytical run containing the highest concentration component/analyte in the sample within the calibrated (quantifiable) range of the method. Analytical screening runs are not reported. If project specific data quality objectives require additional runs, analyses will be billable unless otherwise noted in this quote. Please contact your PM to inquire about the availability of this service for your project.

Sample Disposal - TestAmerica will dispose of non-hazardous samples, sample extracts and digestates 30 days after the final report is issued. Charges for disposal of non-routine or uniquely hazardous samples will be billed to the client. Alternatively, samples can be returned to the client for disposal. Cost of return shipping will be billable to the client.

Special Sample Handling Fees - Unit prices assume that samples are a single-phase matrix and that analyses can be performed in accordance with the laboratory's standard analytical procedures. If additional handling is required, additional fees may apply. Examples of special handling include (but are not limited to):· Matrices requiring additional dilutions or special clean up steps· Multiphasic samples requiring separate preparations and/or analyses· Particle size reduction or special sub-sampling procedures · Extra disposal costs for unique waste streams

Trip Blanks - TestAmerica typically provides trip blanks with our sample kits containing volatile analysis. When samples are received at the laboratory with trip blanks, the lab will analyze, report and charge the unit rate for the analysis. Please add this sample to your chain of custody. If you do not want the trip blank analyzed, please note this on the COC. ADDITIONAL BUSINESS TERMS AND CONDITIONS

Environmental Management Fee

Issued on: 1/24/2019 Page 7 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0If this fee is included in the Other Charges section of the pricing page, a fee equal to the listed percentage of the total invoice amount will be applied to all work done under this quotation. The Fee will appear as a separate line item on each invoice. In the absence of any other firm pricing agreements, your sending work to us under this quotation will signify your acceptance of responsibility for payment of the Fee.

Field Parameters - pH, Temperature, and Dissolved Oxygen analyses, along with Residual Chlorine screening, are properly performed and treated in the field at the time of sample collection. Laboratory analysis may result in a holding time exceedance qualifier.

Network or Subcontract Labs -

· Networking: TestAmerica reserves the right to perform the services at any laboratory in the TestAmerica network, unless the Client has required a particular location for the work.

· Subcontracting: TestAmerica reserves the right to subcontract services ordered by the Client to another laboratory or laboratories, if, in TestAmerica's sole judgment, it is reasonably necessary, appropriate or advisable to do so. TestAmerica will make every effort to notify the client prior to delivering samples to an out-of-network laboratory. TestAmerica will in no way be liable for any subcontracted services (outside the TestAmerica network) except for work performed at laboratories which have been audited and approved by TestAmerica.

Price Surcharge Due To Sample Volume - Unless dictated by contract, this quotation is based on the scope of work defined in the quote request. If the volume of samples submitted is less than 70% of the projected volume, a surcharge of 10% of the total project cost may be assessed.

Professional and Administrative Services - A variety of professional and administrative services are available. Prices for services not specifically detailed in this quotation will be billed in accordance with TestAmerica's Professional Rate Schedule.

Taxes - Where reports are issued in or delivered to a state which assesses sales tax on TestAmerica's services, applicable sales taxes will be added to the invoice as required by law, unless an appropriate sales tax exemption form is on file with TestAmerica.

Rev: 11/22/2016

Issued on: 1/24/2019 Page 8 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Water Samples

Matrix Method Test Description Analyte

RL MDL Units

Water Appendix IX Volatiles 1,1,1,2-Tetrachloroethane 0.2681.00 ug/L8260C

1,1,1-Trichloroethane 0.2381.00 ug/L

1,1,2,2-Tetrachloroethane 0.3671.00 ug/L

1,1,2-Trichloroethane 0.4331.00 ug/L

1,1-Dichloroethane 0.2641.00 ug/L

1,1-Dichloroethene 0.1171.00 ug/L

1,2,3-Trichloropropane 0.6611.00 ug/L

1,2-Dibromo-3-Chloropropane 0.3761.00 ug/L

1,2-Dichloroethane 0.4301.00 ug/L

1,2-Dichloropropane 0.3531.00 ug/L

2-Butanone (MEK) 1.855.00 ug/L

2-Chloro-1,3-butadiene 0.3221.00 ug/L

2-Hexanone 2.905.00 ug/L

4-Methyl-2-pentanone (MIBK) 2.735.00 ug/L

Acetone 4.985.00 ug/L

Acetonitrile 4.9910.0 ug/L

Acrolein 1.124.00 ug/L

Acrylonitrile 0.7692.00 ug/L

Benzene 0.4281.00 ug/L

Bromoform 0.5361.00 ug/L

Bromomethane 1.001.00 ug/L

Carbon disulfide 0.1551.00 ug/L

Carbon tetrachloride 0.2081.00 ug/L

Chlorobenzene 0.3771.00 ug/L

Chlorodibromomethane 0.2811.00 ug/L

Chloroethane 0.3201.00 ug/L

Chloroform 0.3261.00 ug/L

Chloromethane 0.1431.00 ug/L

Dibromomethane 0.6041.00 ug/L

Dichlorobromomethane 0.3431.00 ug/L

Dichlorodifluoromethane 0.1211.00 ug/L

Ethyl methacrylate 0.5301.00 ug/L

Ethylbenzene 0.2981.00 ug/L

Ethylene Dibromide 0.4981.00 ug/L

Iodomethane 0.4791.00 ug/L

Methacrylonitrile 5.1210.0 ug/L

Methyl methacrylate 0.9722.00 ug/L

Methylene Chloride 0.3151.00 ug/L

m-Xylene & p-Xylene 0.2961.00 ug/L

o-Xylene 0.3611.00 ug/L

Propionitrile 7.0510.0 ug/L

Tetrachloroethene 0.2491.00 ug/L

Toluene 0.3791.00 ug/L

trans-1,2-Dichloroethene 0.2351.00 ug/L

trans-1,3-Dichloropropene 0.4851.00 ug/L

trans-1,4-Dichloro-2-butene 0.3421.00 ug/L

Issued on: 1/24/2019 Page 9 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Water Samples

Matrix Method Test Description Analyte

RL MDLContinued Units

Trichloroethene 0.3141.00 ug/L

Trichlorofluoromethane 0.1441.00 ug/L

Vinyl acetate 0.8282.00 ug/L

Vinyl chloride 0.1711.00 ug/L

cis-1,3-Dichloropropene 0.4551.00 ug/L

Styrene 0.4151.00 ug/L

3-Chloro-1-propene 0.1661.00 ug/L

Surrogate Cpnd

1,2-Dichloroethane-d4 (Surr)

Toluene-d8 (Surr)

Dibromofluoromethane (Surr)

RL MDL Units

Water 1,4-Dioxane 1,4-Dioxane 0.2000.400 ug/L8260C SIM

Surrogate Cpnd

1,2-Dichloroethane-d4 (Surr)

4-Bromofluorobenzene

RL MDL Units

Water PAH SIM Benzo[a]pyrene 0.02160.0500 ug/L8270D SIM

Benzo[g,h,i]perylene 0.03510.0500 ug/L

Benzo[k]fluoranthene 0.02780.0500 ug/L

Chrysene 0.02990.0500 ug/L

Dibenz(a,h)anthracene 0.01140.0500 ug/L

Indeno[1,2,3-cd]pyrene 0.03620.0500 ug/L

RL MDL Units

Water PCBs Aroclor 1016 0.1190.400 ug/L8082A

Aroclor 1221 0.1190.400 ug/L

Aroclor 1232 0.1190.400 ug/L

Aroclor 1242 0.1190.400 ug/L

Aroclor 1248 0.1190.400 ug/L

Aroclor 1254 0.1070.400 ug/L

Aroclor 1260 0.1070.400 ug/L

Aroclor-1262 0.1070.400 ug/L

Aroclor 1268 0.1070.400 ug/L

Polychlorinated biphenyls, Total 0.1190.400 ug/L

Surrogate Cpnd

DCB Decachlorobiphenyl

RL MDL Units

Water Appendix IX Herbicides 2,4,5-T 0.1201.20 ug/L8151A

Issued on: 1/24/2019 Page 10 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Water Samples

Matrix Method Test Description Analyte

RL MDLContinued Units

Silvex (2,4,5-TP) 0.1101.20 ug/L

2,4-D 0.1301.20 ug/L

Surrogate Cpnd

2,4-Dichlorophenylacetic acid

RL MDL Units

Water Appendix IX Metals (Price includes Hg) Silver 0.5912.00 ug/L6020B

Arsenic 0.7342.00 ug/L

Barium 1.164.00 ug/L

Beryllium 0.2450.800 ug/L

Cadmium 0.8082.00 ug/L

Cobalt 1.604.00 ug/L

Chromium 2.304.00 ug/L

Copper 1.994.00 ug/L

Nickel 2.364.00 ug/L

Lead 0.5521.20 ug/L

Antimony 0.3992.00 ug/L

Selenium 5.3510.0 ug/L

Thallium 0.1570.800 ug/L

Tin 4.5416.0 ug/L

Zinc 11.116.0 ug/L

Vanadium 1.114.00 ug/L

RL MDL Units

Water Mercury (CVAA) Mercury 0.1150.200 ug/L7470A

RL MDL Units

Water Cyanide, Total Cyanide, Total 0.004000.0100 mg/L335.4

RL MDL Units

Water Sulfide, Total Sulfide 0.5791.00 mg/LSM 4500 S2 F

RL EDL Units

Water Dioxin/ Furan Full List w/ Totals 2,3,7,8-TCDD 10.0 pg/L1613B

2,3,7,8-TCDF 10.0 pg/L

1,2,3,7,8-PeCDD 50.0 pg/L

1,2,3,7,8-PeCDF 50.0 pg/L

2,3,4,7,8-PeCDF 50.0 pg/L

1,2,3,4,7,8-HxCDD 50.0 pg/L

1,2,3,6,7,8-HxCDD 50.0 pg/L

1,2,3,7,8,9-HxCDD 50.0 pg/L

1,2,3,4,7,8-HxCDF 50.0 pg/L

Issued on: 1/24/2019 Page 11 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Water Samples

Matrix Method Test Description Analyte

RL EDLContinued Units

1,2,3,6,7,8-HxCDF 50.0 pg/L

1,2,3,7,8,9-HxCDF 50.0 pg/L

2,3,4,6,7,8-HxCDF 50.0 pg/L

1,2,3,4,6,7,8-HpCDD 50.0 pg/L

1,2,3,4,6,7,8-HpCDF 50.0 pg/L

1,2,3,4,7,8,9-HpCDF 50.0 pg/L

OCDD 100 pg/L

OCDF 100 pg/L

Total TCDD 10.0 pg/L

Total TCDF 10.0 pg/L

Total PeCDD 50.0 pg/L

Total PeCDF 50.0 pg/L

Total HxCDD 50.0 pg/L

Total HxCDF 50.0 pg/L

Total HpCDD 50.0 pg/L

Total HpCDF 50.0 pg/L

Isotope Dilution

13C-2,3,7,8-TCDD 2000

13C-2,3,7,8-TCDF 2000

13C-1,2,3,7,8-PeCDD 2000

13C-1,2,3,7,8-PeCDF 2000

13C-2,3,4,7,8-PeCDF 2000

13C-1,2,3,4,7,8-HxCDD 2000

13C-1,2,3,6,7,8-HxCDD 2000

13C-1,2,3,4,7,8-HxCDF 2000

13C-1,2,3,6,7,8-HxCDF 2000

13C-1,2,3,7,8,9-HxCDF 2000

13C-2,3,4,6,7,8-HxCDF 2000

13C-1,2,3,4,6,7,8-HpCDD 2000

13C-1,2,3,4,6,7,8-HpCDF 2000

13C-1,2,3,4,7,8,9-HpCDF 2000

13C-OCDD 4000

Surrogate Cpnd

37Cl4-2,3,7,8-TCDD 2000

RL MDL Units

Water EDB, DBCP 1,2-Dibromoethane 0.007900.0110 ug/L8011

1,2-Dibromo-3-Chloropropane 0.006000.0110 ug/L

RL MDL Units

Water Appendix IX Semi-Volatiles Acenaphthene 0.4105.00 ug/L8270D

Acenaphthylene 0.3805.00 ug/L

Acetophenone 0.5405.00 ug/L

Aniline 0.61010.0 ug/L

Issued on: 1/24/2019 Page 12 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Water Samples

Matrix Method Test Description Analyte

RL MDLContinued Units

Anthracene 0.2805.00 ug/L

Aramite, Total 1.6020.0 ug/L

Benzo[a]anthracene 0.3605.00 ug/L

Benzo[a]pyrene 0.4705.00 ug/L

Benzo[b]fluoranthene 0.3405.00 ug/L

Benzo[g,h,i]perylene 0.3505.00 ug/L

Benzo[k]fluoranthene 0.7305.00 ug/L

Benzyl alcohol 2.0020.0 ug/L

Bis(2-chloroethoxy)methane 0.3505.00 ug/L

Bis(2-chloroethyl)ether 0.4005.00 ug/L

Bis(2-ethylhexyl) phthalate 2.205.00 ug/L

Butyl benzyl phthalate 1.005.00 ug/L

2-Acetylaminofluorene 2.3010.0 ug/L

4-Aminobiphenyl 0.81010.0 ug/L

4-Bromophenyl phenyl ether 0.4505.00 ug/L

bis (2-chloroisopropyl) ether 0.5205.00 ug/L

2-Chloronaphthalene 0.4605.00 ug/L

2-Chlorophenol 0.5305.00 ug/L

4-Chloroaniline 0.5905.00 ug/L

4-Chloro-3-methylphenol 0.4505.00 ug/L

4-Chlorophenyl phenyl ether 0.3505.00 ug/L

1,2-Dichlorobenzene 0.40010.0 ug/L

1,3-Dichlorobenzene 0.48010.0 ug/L

1,4-Dichlorobenzene 0.46010.0 ug/L

2,4-Dichlorophenol 0.5105.00 ug/L

2,6-Dichlorophenol 0.46010.0 ug/L

2,4-Dimethylphenol 0.5005.00 ug/L

2,4-Dinitrophenol 2.2210.0 ug/L

3,3'-Dichlorobenzidine 0.4005.00 ug/L

3,3'-Dimethylbenzidine 2.5040.0 ug/L

4,6-Dinitro-2-methylphenol 2.2010.0 ug/L

7,12-Dimethylbenz(a)anthracene

0.62010.0 ug/L

Chrysene 0.3305.00 ug/L

Diallate 2.5010.0 ug/L

Dibenz(a,h)anthracene 0.4205.00 ug/L

Dibenzofuran 0.51010.0 ug/L

Di-n-butyl phthalate 0.3105.00 ug/L

Diethyl phthalate 0.2205.00 ug/L

Dimethoate 0.54010.0 ug/L

Ethyl 4,4'-Dichlorobenzilate 0.67020.0 ug/L

a,a-Dimethylphenethylamine 39.6100 ug/L

p-Dimethylamino azobenzene 0.75010.0 ug/L

Thionazin 0.38010.0 ug/L

Dimethyl phthalate 0.3605.00 ug/L

Dinoseb 2.9410.0 ug/L

Diphenylamine 0.82010.0 ug/L

Disulfoton 0.42010.0 ug/L

Issued on: 1/24/2019 Page 13 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Water Samples

Matrix Method Test Description Analyte

RL MDLContinued Units

Di-n-octyl phthalate 0.4705.00 ug/L

Ethyl methanesulfonate 0.39010.0 ug/L

Famphur 1.9040.0 ug/L

Fluoranthene 0.4005.00 ug/L

Fluorene 0.3605.00 ug/L

Hexachlorobenzene 0.5105.00 ug/L

Hexachlorobutadiene 0.6805.00 ug/L

Hexachlorocyclopentadiene 0.5905.00 ug/L

Hexachloroethane 0.5905.00 ug/L

Hexachloropropene 2.5010.0 ug/L

Hexachlorophene 129310 ug/L

Indeno[1,2,3-cd]pyrene 0.4705.00 ug/L

Isodrin 0.18010.0 ug/L

Isophorone 0.4305.00 ug/L

Isosafrole 0.58010.0 ug/L

Kepone 1.8050.0 ug/L

Methapyrilene 1.8050.0 ug/L

Methyl methanesulfonate 2.5010.0 ug/L

Parathion methyl 0.37010.0 ug/L

Naphthalene 0.7605.00 ug/L

Nitrobenzene 0.2905.00 ug/L

1,3-Dinitrobenzene 0.82020.0 ug/L

1,2-Diphenylhydrazine 0.35010.0 ug/L

1,4-Dioxane 1.1010.0 ug/L

1,4-Naphthoquinone 0.24310.0 ug/L

1-Naphthylamine 1.3010.0 ug/L

2,4-Dinitrotoluene 0.4475.00 ug/L

2,6-Dinitrotoluene 0.4005.00 ug/L

2-Methylnaphthalene 0.6005.00 ug/L

2-Methylphenol 0.4005.00 ug/L

2-Nitroaniline 0.42010.0 ug/L

2-Nitrophenol 0.4805.00 ug/L

2-Naphthylamine 2.5010.0 ug/L

3-Methylphenol 0.40010.0 ug/L

3 & 4 Methylphenol 0.36010.0 ug/L

3-Methylcholanthrene 2.5010.0 ug/L

3-Nitroaniline 0.48010.0 ug/L

4-Methylphenol 0.36010.0 ug/L

4-Nitroaniline 0.25010.0 ug/L

4-Nitrophenol 1.5210.0 ug/L

4-Nitroquinoline-1-oxide 2.5010.0 ug/L

1,2,4,5-Tetrachlorobenzene 0.5805.00 ug/L

1,2,4-Trichlorobenzene 0.44010.0 ug/L

1,3,5-Trinitrobenzene 2.5010.0 ug/L

2,3,4,6-Tetrachlorophenol 0.3205.00 ug/L

2,4,5-Trichlorophenol 0.4805.00 ug/L

2,4,6-Trichlorophenol 0.6105.00 ug/L

Issued on: 1/24/2019 Page 14 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Water Samples

Matrix Method Test Description Analyte

RL MDLContinued Units

2-Toluidine 1.4810.0 ug/L

2-Picoline 1.4080.0 ug/L

N-Nitrosodi-n-propylamine 0.5405.00 ug/L

N-Nitrosodiethylamine 0.36010.0 ug/L

N-Nitrosodimethylamine 2.2010.0 ug/L

N-Nitrosodi-n-butylamine 0.60010.0 ug/L

N-Nitrosodiphenylamine 0.5105.00 ug/L

N-Nitrosomethylethylamine 2.5010.0 ug/L

N-Nitrosomorpholine 2.5010.0 ug/L

N-Nitrosopiperidine 2.5010.0 ug/L

N-Nitrosopyrrolidine 2.5010.0 ug/L

N-Nitro-o-toluidine 0.65610.0 ug/L

Parathion ethyl 0.64010.0 ug/L

Pentachlorobenzene 0.53010.0 ug/L

Pentachloronitrobenzene 2.5010.0 ug/L

Pentachlorophenol 2.2010.0 ug/L

Phenacetin 0.61010.0 ug/L

Phenanthrene 0.4405.00 ug/L

Phenol 0.3905.00 ug/L

p-Phenylene diamine 200800 ug/L

Phorate 0.50010.0 ug/L

Pronamide 2.5010.0 ug/L

Pyrene 0.3405.00 ug/L

Pyridine 0.41025.0 ug/L

Safrole 0.46010.0 ug/L

Sulfotepp 0.64010.0 ug/L

o,o',o''-Triethylphosphorothioate 0.43010.0 ug/L

Surrogate Cpnd

2,4,6-Tribromophenol (Surr)

2-Fluorobiphenyl

2-Fluorophenol (Surr)

Phenol-d5 (Surr)

Nitrobenzene-d5 (Surr)

p-Terphenyl-d14 (Surr)

RL MDL Units

Water Appendix IX Pesticides 4,4'-DDD 0.009200.0500 ug/L8081B

4,4'-DDE 0.01160.0500 ug/L

4,4'-DDT 0.01100.0500 ug/L

Aldrin 0.008100.0500 ug/L

alpha-BHC 0.007700.0500 ug/L

beta-BHC 0.02480.0500 ug/L

Chlordane (technical) 0.2900.500 ug/L

Chlorobenzilate 0.08995.00 ug/L

delta-BHC 0.01000.0500 ug/L

Dieldrin 0.009800.0500 ug/L

Issued on: 1/24/2019 Page 15 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Water Samples

Matrix Method Test Description Analyte

RL MDLContinued Units

Endosulfan I 0.01100.0500 ug/L

Endosulfan II 0.01200.0500 ug/L

Endosulfan sulfate 0.01570.0500 ug/L

Endrin 0.01380.0500 ug/L

Endrin aldehyde 0.01630.0500 ug/L

gamma-BHC (Lindane) 0.008000.0500 ug/L

Heptachlor 0.008500.0500 ug/L

Heptachlor epoxide 0.007400.0500 ug/L

Toxaphene 0.1200.500 ug/L

Methoxychlor 0.01410.0500 ug/L

Surrogate Cpnd

DCB Decachlorobiphenyl

Tetrachloro-m-xylene

Issued on: 1/24/2019 Page 16 of 17

Mr. Richard SacksIES Engineers1720 Walton RoadBlue Bell, PA 19422rsacks@iesengineers.com

TestAmerica Edison777 New Durham RoadEdison, NJ 08817

Prepared for:Prepared by

Date

Expiration Date

Est. Start Date

1/24/2019

12/31/2019

Scott, Aidan J

Project: Appendix IX Quote Number: 46028462 - 0

Volume RequiredContainerPreservativeMatrixMethod

Analysis

Analytical Sample Information

Holding Time

Client Sub List Desc

Cyanide, Total Cyanide, Total

335.4 Water Sodium Hydroxide Plastic 250ml - with Sodium Hydroxide

100 mL 14 Days

Dioxins and Furans (HRGC/HRMS) Dioxin/ Furan Full List w/ Totals

1613B Water None Amber Glass 1 liter - unpreserved

2000 mL 1 Year

EDB, DBCP, and 1,2,3-TCP (GC) EDB, DBCP

8011 Water Hydrochloric Acid Voa Vial 40ml - Hydrochloric Acid

120 mL 14 Days

Herbicides (GC) Appendix IX Herbicides

8151A Water None Amber Glass 250ml - unpreserved

500 mL 7 Days

Mercury (CVAA) Mercury (CVAA)

7470A Water Nitric Acid Plastic 250ml - with Nitric Acid

60 mL 28 Days

Metals (ICP/MS) Appendix IX Metals (Price includes Hg)

6020B Water Nitric Acid Plastic 250ml - with Nitric Acid

100 mL 180 Days

Organochlorine Pesticides (GC) Appendix IX Pesticides

8081B Water None Amber Glass 250ml - unpreserved

500 mL 7 Days

Polychlorinated Biphenyls (PCBs) by Gas Chromatography PCBs

8082A Water None Amber Glass 250ml - unpreserved

500 mL 7 Days

Semivolatile Organic Compounds (GC/MS SIM) PAH SIM

8270D_SIM Water None Amber Glass 250ml - unpreserved

0 mL 7 Days

Semivolatile Organic Compounds (GC/MS) Appendix IX Semi-Volatiles

8270D Water None Amber Glass 250ml - unpreserved

500 mL 7 Days

Sulfide, Total Sulfide, Total

SM4500_S2_F Water Zinc Acetate and Sodium Hydroxide

Plastic 500ml - with Zn Acetate and NaOH

100 mL 7 Days

Volatile Organic Compounds (GC/MS) 1,4-Dioxane

8260C_SIM Water Hydrochloric Acid Voa Vial 40ml - Hydrochloric Acid

40 mL 14 Days

Volatile Organic Compounds by GC/MS Appendix IX Volatiles

8260C Water Hydrochloric Acid Voa Vial 40ml - Hydrochloric Acid

120 mL 14 Days

Hold Times listed above represent the minimum allotted time between sampling and lab extraction, prep or analysis.

Multiple analyses may be consolidated into fewer containers. Please contact your Project Manager for clarification when requesting sample containers.

Except for some special tests, all samples should be kept cold at 6 degrees C.

Issued on: 1/24/2019 Page 17 of 17

TESTAMERICA TERMS AND CONDITIONS OF SALE (Short Form)

© 2015, TestAmerica Laboratories, Inc., All Rights Reserved Std TC-1 (v9), Page 1 of 3

When a purchaser (Client) places an order for laboratory, consulting or sampling services from TestAmerica Laboratories, Inc., a Delaware corporation (TestAmerica), TestAmerica shall provide the ordered services pursuant to these Terms and Conditions and the related Quotation or Price Schedule, or as agreed in a negotiated contract. In the absence of a written agreement to the contrary, a client order constitutes an acceptance by the Client of TestAmerica's offer to do business under these Terms and Conditions, and an agreement to be bound by these Terms and Conditions. Receipt of a Client’s samples at a TestAmerica laboratory constitutes acceptance of these Terms and Conditions (in the absence of any other negotiated contract). No contrary or additional terms and conditions expressed in a Client's document shall be deemed to become a part of the contract created upon acceptance of these Terms and Conditions, unless accepted by TestAmerica in writing.

1. ORDERS AND RECEIPT OF SAMPLES

1.1 A Client may place an order (i.e., specify a Scope of Work) either by submitting a purchase order to TestAmerica in writing or by telephone subsequently confirmed in writing, or by negotiated contract. Whichever option the Client selects for placing an order, the order shall not be valid unless it contains sufficient specification to enable TestAmerica to carry out the Client’s requirements. In particular, samples must be accompanied by: a) adequate instruction on type of analysis requested, and b) complete written disclosure of the known or suspected presence of any hazardous substances, as defined by applicable federal or state law. If a Client fails to provide these required disclosures accompanying the submission of samples, and such failure results in an interruption in the lab’s ability to process work due to contamination of instruments or work areas, the Client will be responsible for the costs of clean-up and recovery.

1.2 The Client shall provide one week’s advance notice of the sample delivery schedule, or any changes to the schedule, whenever possible. Upon timely delivery of samples, TestAmerica will use its best efforts to meet mutually agreed turnaround times. All turnaround times will be calculated from the point in time when TestAmerica has determined that it can proceed with defined work following receipt, inspection of samples, and resolution of any discrepancies in Chain-of-Custody forms and project guidance regarding work to be done (Sample Delivery Acceptance). Rush turnaround times not requested in advance of the delivery of samples and specifically agreed to by the lab are not guaranteed. If the Client changes the sample delivery schedule prior to Sample Delivery Acceptance, TestAmerica reserves its rights to modify its turnaround time commitment, change the date upon which TestAmerica will accept samples, or refuse Sample Delivery Acceptance for the affected samples.

1.3 TestAmerica reserves the right, exercisable at any time, to refuse or revoke Sample Delivery Acceptance for any sample which in the sole judgment of TestAmerica: a) is of unsuitable volume; b) may pose a risk or become unsuitable for handling, transport, or processing for any health, safety, environmental or other reason, whether or not due to the presence of any hazardous substance in the sample and whether or not such presence has been disclosed to TestAmerica by the Client; or c) holding times cannot be met, due to passage of more than 48 hours from the time of sampling or 1/2 the holding time for the requested test, whichever is less.

1.4 Prior to Sample Delivery Acceptance, the entire risk of loss or damage to samples remains with the Client, except where TestAmerica provides courier services. In no event will TestAmerica have any responsibility or liability for the action or inaction of any carrier shipping or delivering any sample to or from TestAmerica's premises. Client is responsible for assuring that any sample that contains or may contain any hazardous substance to be delivered to TestAmerica's premises is properly packaged, labeled, transported and delivered, all in accordance with applicable laws.

1.5 TestAmerica reserves the right to begin processing samples upon receipt, unless the Client specifically notifies TestAmerica in writing prior to sample receipt that the samples are to be held without preparation or other processing or pending receipt of a purchase order. TestAmerica shall under no circumstances be responsible for missed holding times or turnaround times or for re-sampling costs if samples are released from hold with less than 48 hours or 1/2 the holding time for the requested test remaining, whichever is less.

2. PAYMENT TERMS

2.1 Services performed by TestAmerica will be in accordance with prices quoted and later confirmed in writing or as stated in the Price Schedule. Quoted prices do not include sales tax. Applicable sales tax will be added to invoices where required by law.

2.2 Invoices may be submitted to Client upon completion of any sample delivery group. Billing corrections must be requested within 30 days of invoice date. Payment in advance is required for all clients except those whose credit has been established with TestAmerica. For clients with approved credit, payment terms are net 30 days from the date of invoice by TestAmerica, unless alternative terms have been agreed in a separate written agreement. Payment shall be made without retainage, and shall not be contingent upon the receipt of funds from third parties. All overdue payments are subject to an additional interest and service charge of one and one half percent (1.5%) (or the maximum rate permissible by law, whichever is less) per month or portion thereof from the due date until the date of payment. All fees are charged or billed directly to the Client. The billing of a third party will not be accepted without a statement, signed by the third party, acknowledging and accepting payment responsibility in accordance with these payment terms.

2.3 If Client fails to make timely payment of its invoices, TestAmerica reserves the right to pursue all appropriate remedies, including withdrawing certifications, suspending work and withholding delivery of data under this order without recourse. Client shall be responsible for all reasonable fees, expenses, and costs of collection including but not limited to arbitrator's and attorney’s fees. TestAmerica reserves the right to refuse to proceed with work at any time based upon an unfavorable Client credit report.

3. CHANGE ORDERS, TERMINATION

3.1 Changes to the Scope of Work, price, or result delivery date may be initiated by TestAmerica after Sample Delivery Acceptance due to any condition which conflicts with analytical, QA or other protocols warranted in these Terms and Conditions. TestAmerica will not proceed with such changes until an agreement with the Client is reached on the amount of any cost, schedule change or technical change to the Scope of Work, and such agreement is documented in writing.

3.2 Changes to the Scope of Work, including but not limited to increasing or decreasing the work, changing test and analysis specification, or acceleration in the performance of the work may be initiated by the Client after Sample Delivery Acceptance. Such change must be documented in writing and may result in a change in cost and turnaround time commitment. TestAmerica's acceptance of such changes is contingent upon technical feasibility and operational capacity.

3.3 Suspension or termination of all or any part of the work may be initiated by the Client. TestAmerica will be compensated consistent with Section 2 of these Terms and Conditions. TestAmerica will complete all work in progress and be paid in full for all work completed.

4. WARRANTIES AND LIABILITY

4.1 Where applicable, TestAmerica will use appropriate and approved analytical test methods. TestAmerica has referenced these methods in its Laboratory Quality Manuals and has documented them in Standard Operating Procedures. TestAmerica reserves the right based on its reasonable judgment to deviate from these methodologies as necessary or appropriate to the extent required by the nature or composition of the sample, which deviations, if any, will be made on a basis consistent with recognized standards of the industry and/or TestAmerica's Laboratory Quality Manuals. Client may request that TestAmerica perform according to a mutually agreed Quality Assurance Project Plan (QAPP). If samples arrive prior to agreement on a QAPP, TestAmerica will proceed with analyses under its standard Quality Manuals then in effect. TestAmerica will not be responsible for any resampling or other charges if work must be repeated to comply with a subsequently finalized QAPP.

4.2 TestAmerica shall start preparation and/or analysis within holding times provided that Sample Delivery Acceptance occurs within 48 hours of

© 2015, TestAmerica Laboratories, Inc., All Rights Reserved Std TC-1 (v9), Page 2 of 3

sampling or 1/2 of the holding time for the test, whichever is less, unless the Client has specifically requested that TestAmerica hold the samples without preparation or other processing or pending receipt of a purchase order. Where resolution of inconsistencies leading to Sample Delivery Acceptance does not occur within this period, TestAmerica will use its best efforts to meet holding times and will proceed with the work provided that, in TestAmerica's judgment, the chain-of-custody or definition of the Scope of Work provide sufficient guidance. Reanalysis of samples to comply with TestAmerica's Quality Manuals will be deemed to have met holding times provided the initial analysis was performed within the applicable holding time. Where reanalysis demonstrates that sample matrix interference is the cause of failure to meet any Quality Manual requirements, the warranty will be deemed to have been met.

4.3 TestAmerica warrants that it possesses and maintains all licenses and certifications that are required to perform services under these Terms and Conditions provided that such requirements are specified in writing to TestAmerica prior to Sample Delivery Acceptance. TestAmerica will notify the Client in writing of any decertification or revocation of any license, or notice of either, that affects work in progress.

4.4 The warranty obligations set forth in Sections 4.1, 4.2 and 4.3 are the sole and exclusive warranties given by TestAmerica in connection with any services performed by TestAmerica or any results generated from such services, and TestAmerica gives and makes NO OTHER REPRESENTATION OR WARRANTY OF ANY KIND, EXPRESS OR IMPLIED. No representative of TestAmerica is authorized to give or make any other representation or warranty or modify this warranty in any way.

4.5 Client's sole and exclusive remedy for breach of warranty in connection with any services performed by TestAmerica will be limited to repeating any services performed, contingent on the Client's providing, at the request of TestAmerica and at the Client's expense, additional sample(s) if necessary. Any reanalysis requested by the Client generating results consistent with the original results will be at the Client's expense. If resampling is necessary, TestAmerica's liability for resampling costs will be limited to actual cost or one hundred and fifty dollars ($150) per sample, whichever is less.

4.6 TestAmerica's liability for any and all causes of action arising hereunder, whether based in contract, tort, warranty, negligence or otherwise, shall be limited to the lesser amount of compensation for the services performed or $100,000. All claims, including those for negligence, shall be deemed waived unless suit thereon is filed within one year after TestAmerica's completion of the services. Under no circumstances, whether arising in contract, tort (including negligence), or otherwise, shall TestAmerica be responsible for loss of use, loss of profits, or for any special, indirect, incidental or consequential damages occasioned by the services performed or by application or use of the reports prepared.

4.7 In no event shall TestAmerica have any responsibility or liability to the Client for any failure or delay in performance by TestAmerica that results, directly or indirectly, in whole or in part, from any cause or circumstance beyond the reasonable control of TestAmerica. Such causes and circumstances include, but are not limited to, acts of God, acts of Client, acts or orders of any governmental authority, strikes or other labor disputes, natural disasters, accidents, wars, civil disturbances, equipment breakdown, matrix interference or unknown highly contaminated samples that impact instrument operation, unavailability of supplies from usual suppliers, difficulties or delays in transportation, mail or delivery services, or any other cause beyond TestAmerica's reasonable control.

5. RESULTS, WORK PRODUCT

5.1 Data or information provided to TestAmerica or generated by services performed under this agreement shall only become the property of the Client upon receipt in full by TestAmerica of payment for the entire order. Ownership of any analytical method, QA/QC protocols, software programs or equipment developed by TestAmerica for performance of work will be retained by TestAmerica. Client shall not disclose such information to any third party without TestAmerica’s express prior consent.

5.2 Data and sample materials provided by Client or at Client’s request, and the result obtained by TestAmerica shall be held in confidence (unless such information is generally available to the public or is in the public domain or Client has failed to pay TestAmerica for all services rendered or is otherwise in breach of these Terms and Conditions), subject to any disclosure required by law or legal process.

5.3 Should the results delivered by TestAmerica be used by the Client or Client's client, even though subsequently determined not to meet the warranties described in these Terms and Conditions, then the compensation will be adjusted based upon mutual agreement. In no case shall the Client unreasonably withhold TestAmerica's right to independently defend its data.

5.4 TestAmerica reserves the right to perform the services at any laboratory in the TestAmerica network. If a Client has requested a particular location for the work, TestAmerica will inform the Client when operational constraints require the work to be performed at another TestAmerica location. In addition, TestAmerica reserves the right to subcontract services ordered by the Client to another laboratory or laboratories, if, in TestAmerica's sole judgment, it is reasonably necessary, appropriate or advisable to do so. TestAmerica will in no way be liable for any subcontracted services (outside the TestAmerica network) except for work performed at laboratories which have been audited and approved by TestAmerica.

5.5 TestAmerica will dispose of non-hazardous samples, sample extracts and digestates 30 days after the final analytical report is issued, unless instructed to store them for an alternate period of time or to return such samples to the Client, in a manner consistent with U.S. Environmental Protection Agency regulations or other applicable federal, state or local requirements. Charges for disposal will be billed to the client. Alternatively, samples can be returned to the client for disposal. Cost of return shipping will be billable to the client. Air samples in Summa canisters and tedlar bags are used and the containers cleaned immediately after testing, such that those samples are not retained. Longer storage periods may be requested and may be accommodated if space allows, and for an additional charge. Any samples for projects that are canceled or not accepted, or for which return was requested, will be returned to the Client at its own expense. TestAmerica reserves the right to return to the Client any sample or unused portion of a sample that is not within TestAmerica's permitted capability or the capabilities of TestAmerica's designated waste disposal vendor(s). ALL DIOXIN, MIXED WASTE, AND RADIOACTIVE SAMPLES WILL BE RETURNED TO THE CLIENT, unless prior arrangements for disposal are made.

5.6 Unless a different time period is agreed to in an order under these Terms and Conditions, TestAmerica agrees to retain all records for five (5) years.

5.7 If TestAmerica is required to respond to legal process related to services for Client, Client agrees to reimburse TestAmerica for hourly charges for personnel involved in the response and attorney’s fees reasonably incurred in obtaining advice concerning the response, preparation to testify, and appearances related to the legal process, travel and all reasonable expenses associated with the litigation. Additional consulting beyond that normally associated with lab reports will be billed at TestAmerica’s current published rates.

6. INSURANCE

6.1 During the performance of services under these Terms and Conditions, TestAmerica shall maintain in force Workers' Compensation and Employer's Liability Insurance in accordance with the laws of the states having jurisdiction over TestAmerica's employees who are engaged in the performance of the work. TestAmerica shall also maintain during such period Comprehensive General and Contractual Liability (limit of $1,000,000 per occurrence/ $2,000,000 aggregate), Comprehensive Automobile Liability, owned and hired, ($1,000,000 combined single limit), and Professional/Pollution Liability Insurance (limit of $1,000,000 per claim/occurrence, $2,000,000 aggregate).

7. MISCELLANEOUS PROVISIONS

7.1 These Terms and Conditions, together with any additions or revisions which may be agreed to in writing by TestAmerica, embody the whole agreement of the parties and provide the only remedies available. There are no promises, terms, conditions, understandings, obligations or agreements other than those contained herein, and these Terms and Conditions shall supersede all previous communications, representations, or agreements, either verbal or written, between the Client and TestAmerica. These Terms and Conditions, and any transactions or agreements to which they apply, shall be governed both as to interpretation and performance by the laws of the state where TestAmerica's services are performed.

© 2015, TestAmerica Laboratories, Inc., All Rights Reserved Std TC-1 (v9), Page 3 of 3

7.2 The invalidity or unenforceability, in whole or in part, of any provision, term or condition hereof shall not affect in any way the validity or enforceability of the remainder of these Terms and Conditions, the intent of the parties being that the provisions be severable. The section headings of these Terms and Conditions are intended solely for convenient reference and shall not define, limit or affect in any way these Terms and Conditions or their interpretations. No waiver by either party of any provision, term or condition hereof or of any obligation of the other party hereunder shall constitute a waiver of any subsequent breach or other obligation.

7.3 The obligations, liabilities, and remedies of the parties, as provided herein, are exclusive and in lieu of any others available at law or in equity. Indemnifications, releases from liability and limitations of liability shall apply, notwithstanding the fault, negligence or strict liability of the party to be indemnified, released, or whose liability is limited, except to the extent of sole negligence or willful misconduct.

L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

ATTACHMENT C

INFORMATION FROM PROPOSED GATEWAY RADIATION MONITORING SYSTEM

L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

ATTACHMENT D

ADDITIONAL SUPPORTING INFORMATION REGARDING COST CALCULATIONS

Hazardous Waste Disposal Cost Review

Elcon obtained actual cost estimates from three hazardous waste vendors that included Clean

Harbors, Veolia, and EcoFlo. For the purposes of the estimates, Elcon assumed that the four waste

streams outlined in Table D-1 below are likely to be the largest volumes of waste stored at the

facility that is expected to be treated. The actual cost estimates for the disposal of four waste

streams were obtained from each vendor and summarized at the end of this Attachment.

Table D-1

Summary of Hazardous Waste Disposal Costs

Waste Stream Clean Harbors

($/gal)

Veolia

($/gal)

EcoFlo1

($/gal)

High

($/gal)

Solvent Waste

(10-20%)

3.65 3.67 4.36 4.36

Solvent Waste

(80-90%)

1.80 3.67 1.95 3.67

Acid Waste 1.98 2.12 3.83 3.83

Caustic Waste 1.65 2.12 1.52 2.12

Elcon calculated the highest hazardous waste disposal cost for each waste stream from each

vendor. The volume of each waste stream that Elcon will store on site varies. Therefore, Elcon

determined the distribution of the hazardous waste stored on site in four general waste categories

for which it has obtained actual vendor disposal cost estimated. Based on the distribution, Elcon

calculated a weighted dollar per gallon disposal cost, based on the highest unit disposal costs. This

distribution and weighted cost calculations are summarized in Table D-2 below.

Table D-2

Hazardous Waste Distribution

Wastestream Total Volume (gallons)

% of Total

Volume High Value $/gallon Weighted Cost

Solvents - 10-20% 2,548,456 88.44% 4.36 $ 3.86

Solvents - 80 to

90% 131,272 4.56% 3.67 $ 0.17

Acids 189,224 6.57% 3.83 $ 0.25

Caustic 12,727 0.44% 2.12 $ 0.01

Total 2,881,679 100% $ 4.28

Copies of Vendor Cost Estimates

L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

ATTACHMENT E

AUDIT PACKAGES FROM DISPOSAL VENDORS

L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

ECOFLO, GREENSBORO, NORTH CAROLINA

[ENTITY NAME] [DEPT / DIV NAME]

[ Entity Logo; Smaller than ECOFLO logo]

RFP No: [#’s / Letters / ID]; [PROPOSAL NAME as shown in RFP]

Opening / Due: [DATE & TIME]

ECOFLO, Inc. ECOFLO Southeast, Inc. ECOFLO, Inc. Transfer Station 2750 Patterson Street 300 Swett Avenue 1059 Kings Mill Road Greensboro, NC. 27407 Americus, GA. 31709 York, PA. 17403

Facility/Company Information

Facility Name: ECOFLO, Inc.

Facility Address: 2750 Patterson Street, Greensboro, NC 27407

Phone: 336-855-7925 or 800-999-6510

Fax: 336-855-4132

Vice President of Operations: Graeme Manning

Company Contact: Stuart Stapleton, Vice President of Environmental Compliance and HHW

Programs

EPA ID: NCD980842132

Date of Incorporation: 1982

State of Incorporation: Maryland

Duns & Bradstreet #: 07-121-2823

Federal Identification #: 52-1272359

ECOFLO Mission Statement

ECOFLO, Inc is in business to provide industrial and hazardous waste management services

of the highest quality with maximum efficiency, ensuring:

To Our Clients:

Confidence in our solutions and peace of mind as to their liabilities

To Our People:

Respect, orderly growth, and opportunity for individual achievement

To Our Shareholders:

Growth in profitability and stability as a business.

ECOFLO, Inc. Corporate Environmental Policy

ECOFLO, Inc, advocates a clean and safe environment. Its policy is to minimize the generation

of hazardous and non-hazardous solid wastes and, insofar as possible, to eliminate air and water

pollutants. It seeks the help of all employees in the achievement of these objectives. Further,

ECOFLO wants its employees to be fully aware of all hazardous and potentially dangerous

chemicals or equipment used in the work place and to use them in a completely safe manner.

Finally, it is ECOFLO's desire to operate in full compliance with all applicable Federal and State

environmental regulations.

ECOFLO is committed to excellence and leadership in protecting the environment. In keeping

with this policy, our objective is to reduce waste and emissions. We strive to minimize adverse

impact on the air, water, and land through excellence in waste reduction. By successfully reducing

waste at its source, we can achieve cost savings, increase operational efficiencies, improve the

quality of our products and services, and maintain a safe and healthy workplace for our

employees. Secondarily, ECOFLO promotes environmentally sound recycling, reuse, and

reclamation of all waste streams when practical.

At ECOFLO, protecting the environment is a high priority. We are pledged to eliminate or reduce,

wherever possible: 1) our use of toxic substances; 2) our release of toxic pollutants; and 3) our

generation of hazardous and other wastes. When wastes or releases cannot be avoided, we are

committed to recycle, treatment, and disposal in ways that minimize any undesirable impacts on

the air, water, and land.

ECOFLO's policy is to reduce all hazardous and non-hazardous waste to levels economically and technically practical while remaining in full compliance with all Federal and State waste regulations.

As both a responsible citizen and ECOFLO employee, each individual is responsible for

reducing waste during working hours, for complying fully with all waste reduction program goals

established by the company, and adhering to applicable Federal or State waste regulations.

ECOFLO, Inc. History and Corporate Structure

ECOFLO is a privately held corporation organized under the laws of the state of Maryland in 1982.

In January 2007, ECOFLO, Inc. became a wholly-owned subsidiary of ECOFLO Holding, Inc., a

privately held corporate organized under the laws of the state of North Carolina in 2006. ECOFLO

Holding, Inc. also owns ECOFLO Southeast, Inc, a privately held corporate organized under the

laws of the state of North Carolina in 2006.

The Greensboro site was purchased in September 1983, the Resource Conservation and

Recovery Act (RCRA) permit was approved on July 1985, and the construction was completed in

early 1988. The facility was the first “greenfield” site to receive a Part B permit under the Resource

Conservation and Recovery Act (RCRA). ECOFLO received interim status under Toxic Substance

Control Act to store Polychlorinated Biphenyl (PCB) waste in 1990 and its final permit in 2002.

ECOFLO’s corporate headquarters and permitted hazardous waste treatment, storage and

disposal facility are located at 2750 Patterson Street, in Greensboro, North Carolina.

The Greensboro facility is not the final disposal site for the waste it currently receives. Much of

the waste it receives arrives in less-than-truck load drum quantities. Full truckloads of drums, bulk

liquids, and bulk solids are accumulated and are then shipped to final approved destinations.

Other waste having fuel value is removed from the drums, bulked in storage tanks, blended to

specifications and transported to cement and aggregate kilns for incineration.

ECOFLO’s York, Pennsylvania office houses the sales organization and field operations for the

Northeast. This location also serves as a Ten-Day Transfer Facility.

ECOFLO Southeast, Inc. owns and operates a permitted non-hazardous waste solidification

facility located in Americus, Georgia. (GA DNP Solid Waste Handling Transfer Permit 129-01 JP)

The 40,000-square foot facility is situated on approximately 3 acres of land. The facility can handle

drum bulk loads and totes. Solidified waste is disposed of in Subtitle D (RCRA) landfill.

ECOFLO Holding, Inc. Corporate Officers:

President/CEO: Paul McAllister

Executive Vice President/CFO: Charlie Witzke

Corporate Secretary: Caroline McAbee

TRANSPORTATION

ECOFLO services clients with both its rolling stock as well as sub-contracted trucks, depending

on what serves the client best.

Driver training requirements ECOFLO's Health & Safety Training Program is fashioned to

provide ECOFLO personnel with a program of classroom instruction and on the job training that

teaches them to perform their duty in a way that ensures compliance with the requirements of

RCRA (40 CFR 264.16), OSHA (29 CFR 1910.12 and 1910.1200), and DOT (49 CFR 172

Subpart H). Until completion of the training program, all personnel are under the direct

supervision of a trained, experienced Supervisor. Review sessions are held periodically to

comply with regulatory requirements.

Labeling responsibilities of drivers – We assume full service which would include ECOFLO to

provide all shipping documents.

Labeling responsibilities of Customer - Internal management of waste as required by EPA and

final approval of all outbound paperwork

Labeling and packaging requirements per classification - Strict adherence to standard RCRA

and DOT regulations

Additional responsibilities -the customer will either load or provide access to a forklift so that the

Field Chemist/Driver can load the truck. All paperwork will have to be approved by the customer

before departure. All containers are to be externally cleaned and properly sealed. ECOFLO

provides the Emergency Response telephone number for use by emergency personnel in route

in the unlikely event of an incident.

Waste Facility – ECOFLO TSDF GREENSBORO NC

ECOFLO owns the facilities detailed herein; an additional approved major outbound facilities list

is available.

Inspections & Audits:

1) Inspections of monitoring equipment, safety and emergency equipment, security devices,

operating and structural equipment are conducted on a daily and weekly basis by ECOFLO

personnel.

2) ECOFLO is audited by CHWMEG and the reports are available to CHWMEG clients

3) 6 monthly unannounced inspections by NCDEQ

4) Bi-annual inspections by US EPA

5) A minimum of 10% of each RCRA waste stream is fingerprinted

6) 100% of fuel material is sampled for compatibility

7) All rainwater that falls into diked areas is treated as waste and pumped into tanks.

ECOFLO is a zero-discharge facility.

ECOFLO’s facility is located on a 3.14-acre site within the city limits of Greensboro North

Carolina and is within a land area that is zoned heavy industrial (INDH) and Light Industrial

(INDL) a minimum of 1,000 feet in all directions. The facility is conveniently located in close

proximity to 1-40 and 1-85, on NC Highway 6, and is approximately 90 miles north of Charlotte,

75 miles west of Raleigh and 30 miles east of Winston-Salem. The predominant industry, in the

surrounding area are chemical manufacturing, distribution, transportation and warehousing.

Originally a food manufacturing and distribution warehouse, the ECOFLO site was converted to

a hazardous waste treatment storage and disposal facility in 1988. It is located 3,200 feet south

of the North Buffalo Creek. The 100-year flood plain elevation for this body of water is 790 feet.

The elevation of the ECOFLO facility averages 840 feet mean sea level. ECOFLO’s facility is

therefore well above the 100-year floodplain.

ECOFLO FACILIIY FEATURES

A. Tank Farm

• 70,000 gallons of bulk liquid storage

• 3 x 5,000-gallon phase layer tanks, 4 blending tanks

• High level alarms and automatic feed cut-offs on all tanks

• All tanks are nitrogen blanketed

• Fire protection consists of foam delivery system adequate for 10 minutes, then followed by water. Fire department is notified electronically when system is activated. Infrared sensors are utilized.

• Containment for tanks is 110%. The truck loading area will hold 8,900 gallons.

B. Decant Room

• Completely contained area

• Protected from fire by IR sensors and foam delivery system

• Drums 100% compatibility tested prior to blending

• Liquid fuels pumped into tank system

• Pegasus system permits automated auguring of sludge and solid drums

• Hard debris and non-processable solids consolidated and containerized for destruction

• After drums are processed, labels are removed and containers are sent to a reconditioner

C. Compatibles Storage

• Storage limit of 633 (55-gallon) drums: can double-stack drums

• Storage for non-RCRA wastes. PCBs and TCLP wastes having the hazard code (T).

D. Flammable Vault

• Dimensions: 32' x 96': surrounded by a minimum 5" curb: storage for 437 (55-gallon) drums

• Storage for materials that have a flash point equal to or below 140 degrees Fahrenheit or wastes having the hazard code (I) indicating ignitability.

• 4-hour fire wall: temperature sensors

• Explosion- proof lighting

• Forced air ventilation/complete air turnover once every 10 minutes

E. Toxic Vault

• Dimensions: 35' x 52' surrounded by a 7" curb. Maximum storage for 250 (55-gallon) drums

• Storage for materials with a flash point greater than 140 degrees Fahrenheit (i.e. chlorinated solvents, metal contaminated wastes, pesticides, cyanides, phenols, etc.) or wastes having the hazard code (T) indicating toxicity.

• 3-hour fire wall

• Forced air ventilation

F. Corrosive Vaults

• Separate adjacent sections, one for acids (pH<2) and two for alkaline (pH>12.5). Dimensions are 35'x 26' for each section: vaults are separated by a 7” high curb. The

alkaline vaults have a maximum capacity of 100 (55-gallon) drums or 200 drums total.

The acid vault has a maximum capacity of 153 (55-gallon) drums.

• No fire wall (materials are essentially aqueous. Low risk)

• Corrosive wastes arc generally aqueous mixtures or solutions of organic or inorganic materials that carry the hazard code (C) indicating corrosivity.

G. Reactive Storage

• Storage area consists of two vaults, each 19' x 17' separated by an 8" thick concrete block wall: capacity is limited to 1,500 gallons (33 x 55-gallon drums) in each vault.

• Each vault has a separate entrance and is surrounded by a 3" high dike.

• Reactive storage is limited to reactive liquids in reagent bottles stored in lab packs or 55- gallon containers. These wastes include classification number D003 or wastes having the hazard code (R) indicating reactivity.

H. Security

• Security procedures and equipment used by ECOFLO fulfill the requirements of 40 CFR 270. Twenty-four-hour surveillance is accomplished with a combination of employees manning the facility during operating hours and an electronic monitoring system during non-operating hours.

• An extensive electronic surveillance system is used to monitor activities within the truck loading/unloading, tank storage, roll-off storage and warehouse container storage areas. The system uses passive motion detectors, cameras, and fire detectors. The fire detection system is monitored 24 hours by a security contractor. The motion detectors and cameras arc monitored during non-operating hours, in addition to 24-hour surveillance.

• The facility is enclosed by a 6-foot high chain link fence with barbed wire strands along the top. The fence encloses the truck yard and exterior tank systems. The fence is kept locked to only allow entry of authorized personnel and vehicles. Facility walls and locked doors provide barriers to the interior portions of the facility and waste container storage areas. Warning signs bearing the statement "DANGER. Authorized Personnel Only" are posted at each entrance to the facility. The signs are clearly legible at a distance of 25 feet. Signs are also posted on fence entrance gates to the truck yard. The signs are visible from any approach to the active portion of the facility. Signage meets the requirements of 40 CFR 264.

I. Groundwater Monitoring

• There are no surface impoundments, landfills, or land treatment facilities at ECOFLO. Therefore, ground water monitoring, as per 40 CFR 265.90 and 270.1(4)(1), is not required.

• ECOFLO is not within 200 feet of a surface water impoundment or a surface water system with continuous flow. The facility is not believed to be located in an area that will allow direct surface or subsurface dis charge to WS- 1, WS-11, or SA waters or a Class III reservoir. ECOFLO is not located in an area that will allow direct surface or subsurface discharge to a watershed for a Class I or Class II reservoir. There are no surface water users within the immediate drainage basin. Surface waters within 1,000 feet of the facility drain into a Class "C" stream defined as not suitable for water supply nor body contact recreation.

• ECOFLO has performed ground water monitoring since 1985 in accordance with North Carolina requirements.

• ECOFLO has three monitoring wells to document the quality of ground water beneath the facility in compliance with requirements of North Carolina Hazardous Waste Management Rule 1 5 A NCAC 13A.0009 R. The monitoring wells consist of 2-inch ID. PVC casing screened 8 lo 18 feet below the ground surface, across the water table. The permanent monitoring system has been sampled annually since 1985.

ECOFLO Operation Capabilities

Drum Storage/Consolidation

The storage/consolidation operation consists of the off-loading of drums/containers from box

trailers or trucks, sampling and testing, consolidation in appropriate storage areas, and

shipment to ECOFLO approved facilities once full truckload quantities have been accumulated.

Waste containers are unloaded and temporarily staged in areas with spill containment and fire

suppression equipment. The drums/containers are sampled and tested for hazardous

characteristics and then moved by forklift into appropriate storage areas. Container storage is

segregated into vaults designed specifically to store wastes containing similar hazardous

characteristics. Descriptions and maximum capacities of each or these storage areas are given

below.

1) Flammables: 19,250 gallons or 437 55-gallon drum equivalents

2) Toxic: 13,750 gallons or 250 55-gallon drum equivalents

3) Reactive (alk): 1,856 gallons or 33 55-gallon drum equivalents

4) Reactive (acid): 1,856 gallons or 33 55-gallon drum equivalents

5) Corrosives (acid): 8,456 gallons or 153 55-gallon drum equivalents

6) Corrosives (alkl): 5,500 gallons or 100 55-gallon drum equivalents

7) Corrosives (alk2): 5,500 gallons or 100 55-gallon drum equivalents

8) Compatibles: 34,856 gallons or 633 55-gallon drum equivalents

9) Roll-Off Storage: 30 cubic yards

Storage areas are constructed of concrete flooring and cinder block walls and have bermed

entryways. Secondary spill containment is provided by concrete diking. Fire protection and

ventilation controls are provided in each storage area which meet or exceed local fire code

requirements.

Drum Decant

Decanting consists of the removal of liquid wastes from drum containers so that the materials

may be bulked and blended in the tank system. Solid wastes are also bulked into large roll-off

box trailers. Prior to being removed from their original containers, all wastes are compatibility

tested and fingerprinted in accordance with the permit's Waste Analysis Plan.

Decanting of liquid waste takes place in the fully enclosed decant room, which measures 24 feet

by 32 feet with a nine-foot ceiling. The room is completely contained by ceiling and walls with

1/8 " stainless steel plates on the interior and welded steel on the exterior. The floor consists of

3 inches of concrete poured on top of a steel plate and 8 inches of concrete under the steel. Fire

protection is provided by infrared heat detectors, which automatically activate a foam fire

suppression system.

The electrical motors and fixtures in the room are explosion proof. Volatile organics are

controlled by continuous ventilation of the room through permitted activated carbon filters.

Personal Protective Equipment consists of Level B protection. Breathing air is supplied by

compressor to overhead air hose connections designed to minimize air hose/operator

interference.

Adjacent to the decant room is a utility room which houses a foam tank for the fire suppression

system.

Before entering the decant room container s of liquid wastes that will be blended into fuel in

ECOFLO's tank system are organized into batches. Representative samples are pulled from

each container, labeled with a bar code, and taken to the lab for testing. In the lab, a bench-

scale pilot run of the batch is performed to determine compatibility by compositing proportional

amounts of the samples in sequence with a proportional amount of the blend already in the

designated receiving tank. As each aliquot is added, careful observations are made to detect

any of the following: evolution of gases, generation of heat, precipitation of solids, sudden

layering, polymerization, and drastic change in pH, coagulation, vigorous churning, or any other

effect which might indicate that the material is not compatible with the contents of the receiving

tank.

Liquids Bulking

Materials stored in the tanks include flammable solvents and oils that are blended to a fuel

specification to be used as a supplemental fuel source for cement kilns. All materials entering

the tanks are tested in accordance with the facility's Waste Analysis Plan. All materials undergo

compatibility testing to insure quality control and safe bulking of waste streams. The tanks are

inspected daily and are equipped with sonar activated high level alarms and automatic feed cut-

off systems. Tanks are vented through conservation vents and are nitrogen blanketed. The

loading area for tractor tanker trucks provides secondary spill containment for 8,900 gallons.

Fire protection includes the use of alarms, infrared sensors, and automatic foam water dispersal

systems. The fire department is notified automatically when the system is activated.

Two forms of treatment occur in the tanks: phase separation and fuels blending.

Phase Separation: The organic and aqueous phases of the waste are separated in the phase

separation area. The aqueous hazardous waste is shipped to an off-site wastewater treatment

facility, where the waste will be treated to achieve RCRA and/or Clean Water Act treatment

standards.

The phase separation area measures 21' x 43' and is surrounded by a four-foot high

containment wall. The entire area is covered with a rain shelter and is provided with

foam/sprinkler fire suppression. Phase separation equipment is comprised of 5,000-gallon tank,

an inert gas system for preventing fire within the tanks, an electrical pump, a pneumatic pump, a

safety shower, a sump and level gauges /alarms for each tank and the sump.

Fuels Blending: The remaining liquid organic wastes contain energy which can be recovered by

blending the wastes into a usable fuel product. Users of the fuel, predominantly cement kilns,

have explicit specifications for the fuel. which typically must have an energy content greater

than, 5,000 BTU/ lb. Halogen and water specifications are also established but vary from user to

user and with time, use of this waste-derived energy resource replaces the consumption of

virgin coal, gas, or oil.

The fuel blending area measures 64' x 32' and is surrounded by a four-foot high containment

wall. The entire area is covered with a rain shelter and is provided with foam sprinkler fire

suppression. Fuel blending equipment is comprised of two 20,000-gallon tanks, one 10,000-

gallon tank, and one 5,000-gallon tank, an inert gas system for preventing fire within the tanks,

two electrical pumps, one pneumatic pump, a safety shower, associated piping and valves, a

sump, and level gauges/alarms for each tank and the sump.

Solids Bulking

Hazardous and non-hazardous solid materials received in Greensboro may be consolidated into

roll-off boxes for bulk shipment to secure landfill, Waste to Energy, recycling, or RCRA

incineration. There are a number of criteria for acceptance into ECOFLO's bulking program:

▪ Material must be solid (<5% free liquids) ▪ Not water or air reactive (D003) ▪ Waste must be removable from drums ▪ No material with strong odors ▪ Material must not react with stabilizing agents ▪ No PCB contaminated material

Waste characterization analyses are performed on solid mate ria ls in the roll-off container prior

to off-site treatment or disposal. The specific analyses are determined based on informational

requirements of the receiving disposal or treatment facility and process knowledge of the

contributing ECOFLO processes. There are six solid bulking processes at the TSDF: two for

non­hazardous solids, which include waste-to energy and landfill and one each for hazardous

solids for landfill. waste-to-energy, recycling and incineration. A typical roll-off container will

handle the contents of 60-80 drums, depending on weight restrictions. Drums of compatible

material are emptied into the roll-off containers using forklifts and a pneumatic drum tilter, and

any residual solids are removed from the interior of the drum.

As indicated in 40 CFR 264.175(c), the roll-off area is not required to be diked. However, to

prevent run-off from precipitation, the area has been covered with a rain shelter and diked with a

concrete curb. The maximum volume of material stored in this area is one 30 cubic yard

container. The perimeter curb height is six inches, therefore, although the area does not receive

free liquids and is sheltered from precipitation. The containment area has been constructed to

exceed all containment requirements of 40 CFR 264.l75(c).

The six-inch concrete curb is tied into the concrete slab with PVC water stops. The concrete

slab is underlain by a 6-mil polyethylene liner on compacted gravel. The interior slab of the

containment system is sloped to the south-west to provide drainage to a 2' x 2' x l' sump system.

Potential fluids collected in the sump are pumped to the "ST" and "P" series storage tanks and

sent to an appropriate off­ site treatment facility. The containment system includes a removable

steel grate that prevents roll-off containers from coming into contact with potential fluids. Roll-off

containers are placed and removed from the containment area by a 16-foot-wide concrete ramp

over the curbing. The rain shelter which completely covers the containment area is designed

and constructed in the same fashion.

Non-Hazardous Solidification

ECOFLO is capable of processing containers, roll-offs and tankers of non-hazardous waste for

solidification. Liquid and sludge non-hazardous wastes are solidified at ECOFLO for disposal by

landfill or reuse at a waste-to-energy facility. ECOFLO has a 10,000-gallon solidification tank

and 7,000-gallon liquid storage tank for this process. The solidification tank, which is dedicated

to this process, is constructed of 12" of concrete walls and floor with a 3/8" steel liner. The

storage tank is above ground and constructed of carbon steel. The entire solidification building

has over 15,000 gallons of secondary containment. Wastes are solidified with sawdust or a

sorbent media and then transferred to roll-offs or dump trailers for shipment to the ultimate

disposal or recycling facility.

Lab Pack De-pack

Laboratory chemicals packaged for ECOFLO's de-pack program are repackaged and/or

consolidated at the Greensboro facility. Corrosives, organic fuel materials, and non-regulated

materials that are amenable to bulking are consolidated into 55-gallon drums and shipped off-

site to an appropriate disposal technology. Organic materials are fuel blended and shipped to

cement kilns or incineration. Corrosive materials are poured up and sent to an appropriate

treatment or incineration facility. Non-regulated solids are packaged into 55-gallon drums or

cubic yard containers for fuels blending or landfill. All remaining materials (oxidizers, reactives,

and P-listed wastes) are shipped to approved incineration facilities.

PCB (Polychlorinatedbiphenal) Waste

In 2002, ECOFLO received a permit from EPA for the commercial storage of 3,520 gallons of

PCB's and, 10,000 pounds of PCB articles in the approved PCB storage area at the company's

Greensboro, NC TSD facility.

Waste Classification

All waste received at the ECOFLO facility must be classified through the completion of a “Waste

Characterization Form”, otherwise known as a “Waste Profile” that is received and approved

prior to any shipment of waste.

Laboratory Analysis

Analytical capabilities include: PCB testing and solvent scans, % halogen, wet chemistry

procedures, halogen content, BTU value, pH and flash point testing. The laboratory provides a

primary quality control function necessary for the safe accurate and timely processing of wastes

through ECOFLO's waste management programs. At this time, no commercial laboratory

services are provided.

ECOFLO performs basic inspection and analytical procedures on all wastes received into the

facility to insure the waste conforms with its characterization. All wastes processed through

ECOFLO's solids bulking or fuels blending programs are further analyzed for compatibility and

fuel value. Analysis is performed in accordance with the Waste Analysis Plan contained in

ECOFLO's permit.

D001 D002 D003 D004 D005 D006 D007 D008 D009 D010 D011 D012 D013 D014 D015 D016 D017 D018

D019 D020 D021 D022 D023 D024 D025 D026 D027 D028 D029 D030 D031 D032 D033 D034 D035 D036

D037 D038 D039 D040 D041 D042 D043

F001 F002 F003 F004 F005 F006 F007 F008 F009 F010 F011 F012 F019 F020 F021 F022 F023 F024

F025 F026 F027 F028 F032 F034 F035 F039

K001 K002 K003 K004 K005 K006 K007 K008 K009 K010 K011 K013 K014 K015 K016 K017 K018 K019

K020 K021 K022 K023 K024 K025 K026 K027 K028 K029 K030 K031 K032 K033 K034 K035 K036 K037

K038 K039 K040 K041 K042 K043 K044 K045 K046 K047 K048 K049 K050 K051 K052 K060 K061 K062

K069 K071 K073 K083 K084 K085 K086 K087 K088 K093 K094 K095 K096 K097 K098 K099 K100 K101

K102 K103 K104 K105 K106 K107 K108 K109 K110 K111 K112 K113 K114 K115 K116 K117 K118 K123

K124 K125 K126 K131 K132 K136 K141 K142 K143 K144 K145 K147 K148 K149 K150 K151 K156 K157

K158 K159 K161 K169 K170 K171 K172 K174 K175 K176 K178 K181

P001 P002 P003 P004 P005 P006 P007 P008 P009 P010 P011 P012 P013 P014 P015 P016 P017 P018

P020 P021 P022 P023 P024 P026 P027 P028 P029 P030 P031 P033 P034 P036 P037 P038 P039 P040

P041 P042 P043 P044 P045 P046 P047 P048 P049 P050 P051 P054 P056 P057 P058 P059 P060 P062

P063 P064 P065 P066 P067 P068 P069 P070 P071 P072 P073 P074 P075 P076 P077 P078 P081 P082

P084 P085 P087 P088 P089 P092 P093 P094 P095 P096 P097 P098 P099 P101 P102 P103 P104 P105

P106 P108 P109 P110 P111 P112 P113 P114 P115 P116 P118 P119 P120 P121 P122 P123 P127 P128

P185 P188 P189 P190 P191 P192 P194 P196 P197 P198 P199 P201 P202 P203 P204 P205

U001 U002 U003 U004 U005 U006 U007 U008 U009 U010 U011 U012 U014 U015 U016 U017 U018 U019

U020 U021 U022 U023 U024 U025 U026 U027 U028 U029 U030 U031 U032 U033 U034 U035 U036 U037

U038 U039 U041 U042 U043 U044 U045 U046 U047 U048 U049 U050 U051 U052 U053 U055 U056 U057

U058 U059 U060 U061 U062 U063 U064 U066 U067 U068 U069 U070 U071 U072 U073 U074 U075 U076

U077 U078 U079 U080 U081 U082 U083 U084 U085 U086 U087 U088 U089 U090 U091 U092 U093 U094

U095 U096 U097 U098 U099 U101 U102 U103 U105 U106 U107 U108 U109 U110 U111 U112 U113 U114

U115 U116 U117 U118 U119 U120 U121 U122 U123 U124 U125 U126 U127 U128 U129 U130 U131 U132

U133 U134 U135 U136 U137 U138 U140 U141 U142 U143 U144 U145 U146 U147 U148 U149 U150 U151

U152 U153 U154 U155 U156 U157 U158 U159 U160 U161 U162 U163 U164 U165 U166 U167 U168 U169

U170 U171 U172 U173 U174 U176 U177 U178 U179 U180 U181 U182 U183 U184 U185 U186 U187 U188

U189 U190 U191 U192 U193 U194 U196 U197 U200 U201 U202 U203 U204 U205 U206 U207 U208 U209

U210 U211 U213 U214 U215 U216 U217 U218 U219 U220 U221 U222 U223 U225 U226 U227 U228 U234

U235 U236 U237 U238 U239 U240 U243 U244 U246 U247 U248 U249 U271 U278 U279 U280 U328 U353

U359 U364 U372 U373 U387 U389 U394 U395 U404 U409 U410 U411

HAZARDOUS WASTE FROM NON-SPECIFIC SOURCES

HAZARDOUS WASTE FROM SPECIFIC SOURCES

DISCARDED COMMERCIAL CHEMICAL PRODUCTS, OFF-SPECIFICATION SPECIES, CONTAINER RESIDUES

AND SPILL RESIDUES THEREOF

PERMITTED HAZARDOUS WASTE CODES

ECOFLO, Inc.

CHARACTERIZATION WASTE

ROY COOPER Governor

MICHAEL S. REGAN Secretary

Air Quality ENVIRONMENTAL QUALITY MICHAEL A. ABRACZINSKAS

Mr. Charles Witzke Excutive Vice President/CFO Ecoflo, Inc. 2750 Patterson Street Greensboro, NC, 27407

Subject: Air Permit No. 06225R07 Ecoflo, Inc.

May 17, 2018

Greensboro, Guilford County, North Carolina Permit Class: Small Facility ID# 4100795

Dear Mr. Witzke:

Director

In accordance with your completed application received May 1, 2018, we are forwarding herewith Permit No. 06225R07 to Ecoflo, Inc., Greensboro, Guilford County, North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Additionally, any emissions activities determined from your air permit application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the records retention requirements are contained in General Condition 2 of the General Conditions and Limitations.

If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of the entire permit. This hearing request must be in the form of a written petition, conforming to G.S. 150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Unless a request for a hearing is made pursuant to G.S. 150B-23, this air permit shall be final and binding.

You may request modification of your air permit through informal means pursuant to G.S. 150B-22. This request must be submitted in writing to the Director and must identify the specific provisions or issues for which the modification is sought. Please note that the permit will become final and binding regardless of a request for informal modification unless a request for a hearing is also made under G.S. 150B-23.

Unless exempted by a condition of this permit or the regulations, construction of new air pollution sources or air cleaning devices, or modifications to the sources or air cleaning devices described in this permit must be covered under a permit issued by the Division of Air

State of North Carolina I Environmental Quality I Air Quality Winston-Salem Regional Office I 450 West Hanes Mill Road, Suite 300 I Winston-Salem, NC 27105

336 776 ~800 T I 336 776 9797 F

Charles Witzke May 17, 2018 Page2

Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-215.114B.

This permit shall be effective from May 17, 2018 until April 30, 2026, is nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified therein.

Changes have been made to the permit stipulations. The Permittee is responsible for carefully reading the entire permit and evaluating the requirements of each permit stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit. Noncompliance with any permit condition is grounds for enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application. Specific changes and additions are summarized below (note: this list may not include all changes and additions):

• The permit term has been changed from five years to eight years per NC General Statute 143-215.108 (dl).

• The description for Control Device EVl has been changed to more accurately describe the system.

• Previous permit condition A.7 regarding 15A NCAC 2D .0958 has been removed as it is no longer applicable to your facility.

• Condition B.1 has been updated to reflect the new Winston Salem Regional Office contact information.

• Insignificant Emission Source 1-2 (pH neutralization system) has been removed from the Insignificant/Exempt Activities List as it is no longer at the facility. ·

• Effective on June 13, 2016, 15A NCAC 2Q .0102 for "Activities Exempted from Permit Requirements" was amended. As such, the facility's Insignificant/Exempt Activities attachment was modified to provide the new exemption citation for each source.

Should you have any questions concerning this matter, please contact Dylan Wright at 336-776-9646.

DAW Enclosures

c: Winston-Salem Regional Office

Sincerely,

Lisa Edwards, P.E., Regional Supervisor Division of Air Quality, NC DEQ

I I

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION

DEPARTMENT OF ENVIRONMENTAL QUALITY

DIVISION OF AIR QUALITY

AIR PERMIT NO. 06225R07

Issue Date: May 1 7, 2018

Expiration Date: April 30, 2026 Effective Date: May 17, 2018

Replaces Permit: 06225R06

To construct and operate air emission source(s) and/or air cleaning device(s), and for the discharge of the associated air contaminants into the atmosphere in accordance with the provisions of Article 21B of Chapter 143, General Statutes of North Carolina (NCGS) as amended, and other applicable Laws, Rules and Regulations,

Ecoflo, Inc. 2750 Patterson Street

Greensboro, Guilford County, North Carolina Permit Class: Small

Facility ID# 4100795

(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air cleaning devices and appurtenances described below:

Emission Emission Source Control Control System Source ID Des~l'iption System ID Description

One hazardous waste storage, bulking and transferring facility consisting of the following: P61 (NESHAP) storage tank (5,000 gallons) NIA NIA P62 (NESHAP) storage tank (5,000 gallons) NIA NIA P63 (NESHAP) storage tank (5,000 gallons) NIA NIA

...... STl 0 1 (NESJIJ\.1') storage tank (10,000 gallons) NIA NIA ST 201 (NESHAP) lstor~g~ tallk (20,00() g~ll~~s) 1 ··· NIA NIA

! ST 501 (NESHAP) storage tank (5,000 gallons) 1 .................. NIA ··-- =f · . .. . 1'fi 1\ ..... ~··~ r STJ.> 201 (NES:HAJ.>) storage tank (20,000 gallon;5r·-·- .. -- NIA NIA

Vl (NESHAP) decant room vent EVl activated carbon panels in

series (cm roof)

L1 (NESHAP) tank truck loading/unloading NIA NIA

operation

in accordance with the completed application 4100795.18A received May 1, 2018 including any plans, specifications, previous applications, and other supporting data, all of which are filed with the Department of Environmental Quality, Division of Air Quality (DAQ) and are incorporated as part of this permit.

Permit No. 06225R07 Page2

This permit is subject to the following specified conditions and limitations including any TESTING, REPORTING, OR MONITORING REQUIREMENTS:

A. SPECIFIC CONDITIONS AND LIMITATIONS

1. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordance with the provisions contained herein. The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D .0202, 2D .0535, 2D .0540, 2D .0611, 2D .0948, 2D .1110, 2D .1806 and 2Q .0711.

2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with 15A NCAC 2Q .0304(d) and (f). Pursuant to 15ANCAC 2Q .0203(i), no permit application fee is required for renewal of an existing air permit (without a modification request). The renewal request (with AA application form) should be submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this permit, the Permittee shall submit the air pollution emission inventory report (with Certification Sheet) in accordance with 15A NCAC 2D .0202, pursuant to N.C. General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ and shall document air pollutants emitted for the 2024 calendar year.

3. NOTIFICATION REQUIREMENT - As required by 15A NCAC 2D .0535, the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall:

a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming aware of the occurrence and describe:

1. the name and location of the facility,

11. the nature and cause of the malfunction or breakdown,

111. the time when the malfunction or breakdown is first observed,

1v. the expected duration, and

v. an estimated rate of emissions.

b. Notify the Director or his designee immediately when the corrective measures have been accomplished.

This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations.

Permit No. 06225R07 Page3

4. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints are received or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 2D .0540(£).

"Fugitive dust emissions" means particulate matter that does not pass through a process stack or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas, process areas stockpiles, stock pile working, plant parking lots, and plant roads (including access roads and haul roads).

5. ACTIVATED CARBON PANEL REQUIREMENTS - As required by 15A NCAC 2D .0611, emissions shall be controlled as described in the permitted equipment list.

a. Inspection and Maintenance Requirements - To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform periodic inspection and maintenance (I&M) as recommended by the manufacturer. In addition, the Permittee shall perform an annual inspection of the activated carbon panels, including the following:

I. Inspect and maintain the structural integrity of the activated carbon panels;

II. Inspect and maintain the structural integrity of duct work and piping leading to the activated carbon panels; and

III. In addition, the Permittee shall change the activated carbon panels regularly as recommended by the manufacturer.

b. Recordkeeping Requirements - The results of all inspections and any variance from manufacturer's recommendations or from those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a logbook. Records of all maintenance activities, including the changing of the activated carbon panels, shall be recorded in the logbook. The logbook (in written or electronic format) shall be kept on-site and made available to DAQ personnel upon request.

6. VOC EMISSIONS FROM TRANSFER OPERATIONS -As required by 15A NCAC 2D .0948 "VOC Emissions from Transfer Operations," the Permittee shall not transfer more than 20,000 gallons of VOC per day from a storage tank into a tank-truck or railcar with a vapor pressure of 1.5 pounds per square inch or greater under actual conditions unless the loading uses submerged loading through boom loaders that extend down into the compartment being loaded.

7. NESHAP REQUIREMENTS - For the hazardous waste hanqling facility listed above, the Permittee shall comply with applicable provisions, including the notification, testing and monitoring requirements contained in Environmental Management Standard 15A NCAC 2D

Permit No. 06225R07 Page4

.1110 "National Emission Standards for Hazardous Air Pollutants" (NESHAP) as promulgated in 40 CFR 61, Subpart FF.

LIMITATIONS TO AVOID 40 CFR 61.342(b) and (c) -To comply with this permit and avoid applicability of 40 CFR 61.342(b) and ( c ), as requested by the Permittee, the total amount of NESHAP-applicable benzene in the waste streams handled by the Permittee on an annual basis must be less than ten (10) megagrams. The permittee shall maintain records in written or electronic form of the quantity of benzene handled on an annual basis. These records shall be maintained for a period of at least three years and shall be made available to Division of Air Quality Personnel upon request.

8. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" the Permittee shall not operate the facility without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary.

9. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT- The emission sources at the facility shall be operated and maintained in such a manner that emissions of any listed toxic air pollutant(s) from the facility, including fugitive emissions, will not exceed the toxic permit emission rate(s) (TPERs) specified in 15A NCAC 2Q 0711. In order to ensure compliance with this condition, the Permittee must comply with the following requirements:

a. In no case shall the Permittee hold in its process tanks any waste containing benzene with a concentration of more than 800 parts per million by weight.

b. The average number of drums decanted in the decant room (ID No. Vl) within a 24 hour period shall not exceed 80 drums when averaged over 365 consecutive days. In no case shall more than 240 drums be decanted in any 24 hour period in the decant room.

c. The average number of tanker trucks being loaded or unloaded at this facility within a 24-hour period shall not exceed 3 tanker trucks when averaged over 365 consecutive days. In no case shall more than 12.5 tanker trucks be loaded or unloaded at this facility within any 24-hour period. The maximum rate of loading or unloading of tanker trucks shall not exceed eighty (80) gallons per minute.

d. The Permittee shall keep a daily written screening log of all waste streams received by tanker truck containing one or more of the following pollutants:

Pollutant

Ammonia Carbon Disulfide

Dichlorofluoromethane

Screening Level % by volume % by weight

6.8 7.1 1.4 1.9

0.9 1.3

Permit No. 06225R07 Page5

Ethylenediamine Formaldehyde

Hexane

5.1 0.17 16.2

5.9 0.14 11.2

The Permittee shall keep these daily logs on file for a minimum of two years and the logs must be made available to personnel of the Division of Air Quality upon request. Upon inspection of these daily logs, ifDAQ personnel find that any waste stream received through tanker truck by the Permittee contains any of the above pollutants in levels above the percent by volume or the percent by weight screening levels listed above, the Permittee may be required to submit records and/or calculations necessary to satisfy DAQ personnel that the TPERs in 15A NCAC 2Q .0711 have not been exceeded.

B. GENERAL CONDITIONS AND LIMITATIONS

1. In accordance with G.S. 143-215.108(c)(l), TWO COPIES OF ALL DOCUMENTS, REPORTS, TEST DATA, MONITORING DATA, NOTIFICATIONS, REQUESTS FOR RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall be submitted to the:

Regional Supervisor North Carolina Division of Air Quality Winston-Salem Regional Office 450 West Hanes Mill Road Suite 300 Winston-Salem, NC 27105 336-776-9800

For identification purposes, each submittal should include the facility name as listed on the permit, the facility identification number, and the permit number.

2. RECORDS RETENTION REQUIREMENT - In accordance with 15A NCAC 2D .0605, any records required by the conditions of this permit shall be kept on site and made available to DAQ personnel for inspection upon request. These records shall be maintained in a form suitable and readily. available for expeditious inspection and review. These records must be kept on site for a minimum of 2 years, unless another time period is otherwise specified.

3. ANNUAL FEE PAYMENT- Pursuant to 15A NCAC 2Q .0203(a), the Permittee shall pay the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a timely manner will cause the DAQ to initiate action to revoke the permit.

4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q .0301, a new air permit shall be obtained by the Permittee prior to establishing, building, erecting, using, or operating the emission sources or air cleaning equipment at a site or location not specified in this permit.

Permit No. 06225R07 Page 6

5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the following that would result in previously unpermitted, new, or increased emissions must be reported to the Regional Supervisor, DAQ:

a. changes in the information submitted in the application regarding facility emissions;

b. changes that modify equipment or processes of existing permitted facilities; or

c. changes in the quantity or quality of materials processed.

If appropriate, modifications to the permit may then be made by the DAQ to reflect any necessary changes in the permit conditions. In no case are any new or increased emissions allowed that will cause a violation of the emission limitations specified herein.

6. In accordance with 15A NCAC 2Q .0309, this permit is subject to revocation or modification by the DAQ upon a determination that infonnation contained in the application or presented in the support thereof is incorrect, conditions under which this permit was granted have changed, or violations of conditions contained in this permit have occurred. In accordance with G.S. 143-215.108(c)(l), the facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of its associated air cleaning device( s) and appurtenances.

7. In accordance with G.S. 143-215.108(c)(l), this permit is nontransferable by the Permittee. Future owners and operators must obtain a new air permit from the DAQ.

8. In accordance with G.S. 143-215.108(c)(l), this issuance of this permit in no way absolves the Permittee of liability for any potential civil penalties which may be assessed for violations of State law which have occurred prior to the effective date of this permit.

9. In accordance with G.S. 143-215.108(c)(l), this permit does not relieve the Permittee of the responsibility of complying with all applicable requirements of any Federal, State, or Local water quality or land quality control authority.

10. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such intervals and in such form and detail as may be required by the DAQ. Information required in such reports may include, but is not limited to, process weight rates, firing rates, hours of operation, and preventive maintenance schedules.

11. A violation of any term or condition of this permit shall subject the Permittee to enforcement pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.l 14C, including assessment of civil and/or criminal penalties.

12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or access to any authorized representative of the DAQ who requests entry or access for purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such representative while in the process of carrying

Permit No. 06225R07 Page 7

out his official duties. Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties.

13. In accordance with G.S. 143-215.108(c)(l), this permit does not relieve the Permittee of the responsibility of complying with any applicable Federal, State, or Local requirements governing the handling, disposal, or incineration of hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Act (RCRA) administered by the Division of Waste Management.

14. PERMIT RETENTION REQUIREMENT- In accordance with 15A NCAC 2Q .0110, the Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel of the DAQ, upon request, the current copy of the air permit for the site.

15. CLEAN AIR ACT SECTION 112(r) REQUIREMENTS -Pursuant to 15A NCAC 2D .2100 "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEP A in accordance with 40 CFR Part 68.

16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I Part A Section 112(r)(l) of the Clean Air Act "Hazardous Air Pollutants - Prevention of Accidental Releases - Purpose and General Duty," although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental release of such substance and to minimize the consequences of any release. This condition is federally-enforceable only.

17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing to the DAQ in support of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ procedures including protocol approval, regional notification, report submittal, and test results approval. Additionally, in accordance with 15A NCAC 2D .0605, the permittee shall follow the procedures for obtaining any required audit sample and reporting those results.

Permit issued this the 17th of May, 2018. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION

Lisa Edwards, P .E. Regional Supervisor By Authority of the Environmental Management Commission Air Permit No. 06225R07

ATTACHMENT to Permit No. 06225R07, May 17, 2018

Insignificant / Exempt Activities

Source Exemption Source of Regulation TAPs?

1-1 - Aerosol can crusher (800 cans per hour crushing capacity) vented to activated carbon 2Q .0102 (h)(5) Yes

panels (EV 1)

Source of.Title V Pollutants?

Yes

1. Because an activity is exempted from being required to have a permit or permit modification does not mean that the activity is exempted from an applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement.

2. When applicable, emissions from stationary source activities identified above shall be included in determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates Requiring a Permit."

3. Sample permit conditions showing the regulatory requirements for exempt sources subject to NESHAP, NSPS, and NCAC rules may be found here: https://deq.nc.gov/about/divisions/air-quality/air-quality-permits/specific-pem1it-conditions­regulatory-guide

“World Class ProfessionalsEnabling Veteran Business Opportunities by Protecting the Veteran Advantage - One Vet at a Time”

EVAL.T3.TEMPL.030 Page 1 of 2

DEPARTMENT OF VETERANS AFFAIRSCenter for Verification and Evaluation

Washington DC 20420

5/20/2019In Reply Refer To: 00VE

Mr. Paul A. McAllisterECOFLO Holding, Inc. DUNS: 0794336502750 Patterson StreetGreensboro, NC 27407

Dear Mr. McAllister:

On behalf of the U.S. Department of Veterans Affairs (VA), Center for Verification and Evaluation (CVE), I am writing to inform you that your application for reverification has been approved. ECOFLO Holding, Inc. will remain eligible to participate in Veterans First Contracting Program opportunities with VA as a verified Veteran-Owned Small Business (VOSB).

This verification is valid for three (3) years from the date of this letter. Please retain a copy of this letter to confirm ECOFLO Holding, Inc.'s continued program eligibility in accordance with 38 Code of Federal Regulation (CFR) § 74.12. You may reapply 120 days prior to your new expiration date by logging into https://www.vip.vetbiz.gov/.

To promote ECOFLO Holding, Inc.'s verified status, you may use the following link to download the logo for use on your marketing materials and business cards: https://www.vetbiz.gov/cve_completed_v.jpg. In addition, please access the following link for information on next steps and opportunities for verified businesses:http://www.va.gov/osdbu/verification/whatsNext.asp.

While CVE has confirmed that ECOFLO Holding, Inc. is presently, as of the issuance of this notice, in compliance with the regulation, ECOFLO Holding, Inc. must inform CVE of any changes or other circumstances that would adversely affect its eligibility. Eligibility changes not reported to CVE within 60 days could result in a referral to the Office of Inspector General (OIG), a referral to the Debarment and Suspension Committee, and the initiation of cancellation proceedings—all of which could result in ECOFLO Holding, Inc. being removed from the VIP Verification Program.

Please be advised all verified businesses may be required to participate in one or more post-verification audits at CVE's discretion. Additionally, this letter and other

Page 2Mr. Paul A. McAllister

EVAL.T3.TEMPL.030 Page 2 of 2

information pertaining to ECOFLO Holding, Inc.'s verification application may be subject to Freedom of Information Act (FOIA) requests. However, FOIA disclosures include exceptions regarding the personal privacy of individuals, and VA policy similarly provides limitations on the release of individuals records.

If ECOFLO Holding, Inc. receives a negative size determination from the U.S. Small Business Administration (SBA), CVE must act in accordance with 38 CFR § 74.2(e). Also note, if at any time ECOFLO Holding, Inc. discovers that it fails to meet the size standards for any NAICS Code(s) listed on its VIP profile, CVE requires such NAICS Code(s) be removed within five (5) business days. If these NAICS Codes are not removed within the allotted five (5) business days, CVE may request SBA conduct a formal size determination. In addition, CVE may initiate a referral to OIG, a referral to the Debarment and Suspension Committee and pursue cancellation proceedings. All of the aforementioned referrals and procedures could result in ECOFLO Holding, Inc. being removed from the VIP Verification Program.

Thank you for your service to our country and for continuing to serve America through small business ownership.

Sincerely,

Thomas McGrathDirectorCenter for Verification and Evaluation

The ACORD name and logo are registered marks of ACORD

CERTIFICATE HOLDER

© 1988-2014 ACORD CORPORATION. All rights reserved.ACORD 25 (2014/01)

AUTHORIZED REPRESENTATIVE

CANCELLATION

DATE (MM/DD/YYYY)CERTIFICATE OF LIABILITY INSURANCE

LOCJECTPRO-POLICY

GEN'L AGGREGATE LIMIT APPLIES PER:

OCCURCLAIMS-MADE

COMMERCIAL GENERAL LIABILITY

PREMISES (Ea occurrence) $DAMAGE TO RENTEDEACH OCCURRENCE $

MED EXP (Any one person) $

PERSONAL & ADV INJURY $

GENERAL AGGREGATE $

PRODUCTS - COMP/OP AGG $

$RETENTIONDED

CLAIMS-MADE

OCCUR

$

AGGREGATE $

EACH OCCURRENCE $UMBRELLA LIAB

EXCESS LIAB

DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

INSRLTR TYPE OF INSURANCE POLICY NUMBER

POLICY EFF(MM/DD/YYYY)

POLICY EXP(MM/DD/YYYY) LIMITS

PERSTATUTE

OTH-ER

E.L. EACH ACCIDENT

E.L. DISEASE - EA EMPLOYEE

E.L. DISEASE - POLICY LIMIT

$

$

$

ANY PROPRIETOR/PARTNER/EXECUTIVE

If yes, describe underDESCRIPTION OF OPERATIONS below

(Mandatory in NH)OFFICER/MEMBER EXCLUDED?

WORKERS COMPENSATIONAND EMPLOYERS' LIABILITY Y / N

AUTOMOBILE LIABILITY

ANY AUTOALL OWNED SCHEDULED

HIRED AUTOSNON-OWNED

AUTOS AUTOS

AUTOS

COMBINED SINGLE LIMIT

BODILY INJURY (Per person)

BODILY INJURY (Per accident)PROPERTY DAMAGE $

$

$

$

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIODINDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THISCERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS,EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.

INSDADDL

WVDSUBR

N / A

$

$

(Ea accident)

(Per accident)

OTHER:

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THISCERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIESBELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZEDREPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. If SUBROGATION IS WAIVED, subject tothe terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to thecertificate holder in lieu of such endorsement(s).

COVERAGES CERTIFICATE NUMBER: REVISION NUMBER:

INSURED

PHONE(A/C, No, Ext):

PRODUCER

ADDRESS:E-MAIL

FAX(A/C, No):

CONTACTNAME:

NAIC #

INSURER A :

INSURER B :

INSURER C :

INSURER D :

INSURER E :

INSURER F :

INSURER(S) AFFORDING COVERAGE

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORETHE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED INACCORDANCE WITH THE POLICY PROVISIONS.

12/23/2019

Scott Insurance - Greensboro628 Green Valley RoadSuite 306Greensboro NC 27408

Carrie Sowards336-510-0073 434-455-8549

csowards@scottins.com

Zurich American Insurance Company (A+) 16535ECOFINC-01 Indian Harbor Insurance Company (A+) 36940

Ecoflo Holding, Inc., ECOFLO Inc.Ecoflo Southeast, Inc., Ecoflo Logistics, LLCEcoflo Field Servcies, LLC, Ecoflo Recycling, LLC2750 Patterson StreetGreensboro NC 27407-2317

Markel Insurance Company (A) 38970

549981096

C X 1,000,000X 100,000

15,000

1,000,000

2,000,000

X X

MKLV2ENV101490 12/31/2019 3/1/2021

2,000,000

A 1,000,000X

BAP 9282326-00 12/31/2019 2/29/2020

C 10,000,000X

10,000

MKLV2EFX100430

X10,000,000

12/31/2019 3/1/2021

A

N

WC 9282325-00 12/31/2019 2/29/2020 X1,000,000

1,000,000

1,000,000BC

Pollution & RemediationPollution & Professional

PEC000514706MKLV2ENV101490

12/31/201712/31/2019

12/31/20203/1/2021

See BelowSee Below

SEE ATTACHED

See Attached...

Evidence of Coverage

ACORD 101 (2008/01)The ACORD name and logo are registered marks of ACORD

© 2008 ACORD CORPORATION. All rights reserved.

THIS ADDITIONAL REMARKS FORM IS A SCHEDULE TO ACORD FORM,FORM NUMBER: FORM TITLE:

ADDITIONAL REMARKS

ADDITIONAL REMARKS SCHEDULE Page of

AGENCY CUSTOMER ID:LOC #:

AGENCY

CARRIER NAIC CODE

POLICY NUMBER

NAMED INSURED

EFFECTIVE DATE:

ECOFINC-01

1 1

Scott Insurance - Greensboro Ecoflo Holding, Inc., ECOFLO Inc.Ecoflo Southeast, Inc., Ecoflo Logistics, LLCEcoflo Field Servcies, LLC, Ecoflo Recycling, LLC2750 Patterson StreetGreensboro NC 27407-2317

25 CERTIFICATE OF LIABILITY INSURANCE

The following applies at Owned Disposal Sites:$10,000,000 Each Pollution Condition$17,500,000 Aggregate

Sublimit of Liability at Non-Owned Disposal Sites:$1,000,000 Each Pollution Condition$1,000,000 Aggregate

Pollution & Professional LiabilityINSURER AFFORDING COVERAGE:POLICY NUMBER: EFF DATE: 12/31/2019 EXP DATE: 3/1/2021 NAIC#:

TYPE OF INSURANCE: LIMIT DESCRIPTION: LIMIT AMOUNT:Professional Liability Each Claim $5,000,000

Incl Defense CostsAggregate $10,000,000

INSURER AFFORDING COVERAGE:POLICY NUMBER: EFF DATE: 12/31/2019 EXP DATE: 3/1/2021 NAIC#:

TYPE OF INSURANCE: LIMIT DESCRIPTION: LIMIT AMOUNT:Contractors Pollution Legal Liability Each Claim $5,000,000

Incl Defense CostsAggregate $10,000,000

Includes MCS90 Endorsement for Hazardous Waste. Hired Car-Physical Damage Limit of $80,000- at $100 Deductible Comprehensive and $1,000- Collision.

Improper container storage.

Improper aisle space

maintained.

March 1, 2017 NC NCD980842132 NCDEQ NOVTank integrity testing had not

been performed.Closed

Improper aisle space

maintained.

Consolidation being performed

in an alleged unpermitted room.

Proper closure was not followed

for the acid base neutralization

machine.

Calibration records for Subpart

BB were not available.

ECOFLO, INC. COMPLIANCE HISTORY 2015-2018

(Includes all EPA/DOT/OSHA Violations)

Closed

August 5, 2015 NC NCD980842132 NCDENR NOV Closed

April 20, 2017 NC NCD980842132 USEPA NOV

TRANSPORTATION

CONTINGENCY PLAN

The Transportation Contingency Plan contains practices and procedures to following during an emergency transportation situation. EHS-PRO-004 Revised May 14, 2018

Page 1 of 11 EHS-PRO-004 Revised 05/14/18

TITLE: Transportation Contingency Plan PURPOSE: The Transportation Contingency Plan contains practices and procedures to following during an emergency transportation situation. SCOPE: This program applies to ECOFLO, Inc. facilities and job sites. IMPLEMENTATION: The Transportation Contingency Plan is effective immediately. All affected employees will receive training on the Program and its requirements, as it relates to their job function, prior to performance of a function and annually thereafter. REVIEW & UPDATES: ECOFLO will review the Transportation Contingency Plan annually and update it as needed by no later than January 31 of each calendar year.

RESPONSIBILITIES: Operations Manager: The Operations Manager is responsible for ensuring the success of this program and for all operations under his control. The Operations Manager or his/her designee shall monitor the employees periodically to ensure they provide their employees with sufficient training and equipment to allow them to both understand and comply with this procedure. EHS Manager: The EHS Manager is responsible for providing technical information and ensuring a safe and healthy working environment. Employees: Employees are responsible for compliance with the requirements of this program.

EMERGENCY CONTACTS ECOFLO, Inc. will utilize an in-house emergency information and response system (1-800-999-6510). When provided with the proper information, ECOFLO will give emergency action information, help identify the hazardous material, contact manufacturers or generators of the material, and if required, will activate appropriate mutual aid groups. ECOFLO's Emergency Coordinators are: Primary Contact

Graeme Manning - Vice President, Operations ECOFLO, Inc. 2750 Patterson Street Greensboro, NC 27407 Phone: (336) 617-2717 Mobile: (336) 517-9264

Secondary Contact

Stuart Stapleton – Director, Environmental Compliance & HHW Programs ECOFLO, Inc. 2750 Patterson Street Greensboro, NC 27407 Phone: (336) 617-2733 Mobile: (336) 324-6789

Page 2 of 11 EHS-PRO-004 Revised 05/14/18

EMPLOYEE TRAINING

1. Employees shall be trained annually. Newly hired personnel and temporary employees shall receive instructlon.at the time of initial assignment;

2. Training shall include an overview of this procedure with specific emphasis on the following:

a. Immediate actions to be taken in the event of a spill or leak; b. Identification of equipment in a work area that is to be shut down in an

emergency, if it can be done safely; c. The method by which employees will be notified of an emergency; d. Identification of the emergency Coordinator and his alternates and their

telephone numbers; e. Location and type of spill containment equipment and instructions in its use; and f. Precautionary measures developed since the previous training.

SPILL RESPONSE PROCEDURES The following actions are to be taken in the event of a spill or leak:

1. Assess the Situation

The first thing to do if you see or smell a hazardous spill or leak is to move away to a safe distance and tum off any ignition sources if you can.

2. Identify the Spill or Leak Material

Try to answer these questions. If you cannot answer these questions, do not go back to the spill area to answer them at this time. What was it?

• Did you see a label on the container?

• Was it foaming or fuming?

• Was there a fire?

• What did it smell like?

• What color was it?

• What was it doing?

3. Contain the Spill

Once you are properly protected, prevent the spill from spreading. Minimize the danger to yourself, other people. and the environment. The faster you can contain a spill the less damage there will be.

Stopping the source of the leak or spill may only require closing a valve or shutting down a pump to stop the flow. It may mean putting a suitable "bandage" on a leaking hose, applying putty or packing to a joint or valve, or plugging a leak with whatever is handy (i.e., rags, or even a crude boil7r patch). To minimize leakage in torn or punctured containers, orient the containers so that the chemical doesn't escape or overpack in a suitable salvage drum.

Page 3 of 11 EHS-PRO-004 Revised 05/14/18

Build a barrier so that the spill or leak can't spread, or make a flow channel to control the spread. Materials such as clay granules or sorbent sheets or pillows should be used to prevent the spill from spreading. A drain can be plugged with specially made drain plugs or shop rags, or use sorbent booms to keep the material from reaching the drain. De careful not to add sorbent which would adversely react with the released chemical.

4. Get Help

Call the Emergency Coordinator or his Alternate. Briefly explain what happened, then let them ask the questions.

5. Seal Off Area and Alert Others

Without going back in, seal off the area and warn nearby public of the potential dangers.

6. Look for Injuries

If you find an injured person, don't attempt to rescue them from the spill area unless you are completely protected yourself. Get them to fresh air as soon as safely possible. Keep the victim warm and quiet. Get medical help right away. If the victim is not breathing, use artificial respiration. Administer oxygen if breathing is difficult. Remove contaminated clothing and shoes. If the victim came into contact with the spilled material. immediately flush the affected area with running water for at least 15 minutes.

7. Identify the Hazards

What chemical is involved? What are the dangers? Locate the shipping papers for the material and look for placards, package labels, and fellow workers that may be able to identify the hazardous material and how to deal with it. For example, container labels often explain the procedures to take in the event of a spill. A placard may identify the material as flammable, corrosive, or poisonous.

If it Is necessary to enter the spill area to identify the material, then assume the worst. Protect yourself by putting on a self-contained breathing apparatus (SCBA) and an encapsulating suit. Use the Buddy System, and never go in without a backup.

8. Prepare a Plan of Action

Develop a plan of action to:

• Help anticipate problems;

• Remember what you are supposed to do;

• Properly coordinate tasks and people; and

• Accomplish the task faster.

Page 4 of 11 EHS-PRO-004 Revised 05/14/18

9. Assemble the Equipment and Materials Needed

When you do not know what you are dealing with, wear the maximum protection possible (SCBA and fully protective clothing).

10. Clean up the Spill

When you are cleaning up the hazardous material, observe the following safety precautions:

• Do not touch or taste the material. Do not breathe gases, vapors•. or mists. Use the right clothing and equipment, and always approach a spill from upwind. Do not smoke or make sparks of any kind;

• Use the right sorbent for the spill. It is important to select the right sorbent products in advance for the liquids to be cleaned up, then place the contaminated sorbents in a container that can safely hold and store the spilled material;

• The sorbents used to clean up the spill must be packaged according to local, state, and federal regulations. They have the same properties and hazards as the original spilled materials;

• Safely dispose of disposable coverall, gloves, and respirators. Decontaminate all non-disposable items such as shovels, scrapers, SCBAs, protective clothing, etc.; and

• Review what happened to make sure that it would not happen again. Record it, along with an evaluation of your plan and the actions that were taken.

EVACUATION PROCEDURES

1. If the spill or leak is of such magnitude that containment or control is impractical, then employees shall evacuate the immediate area in which a leak or spill has taken place and from adjacent area that may be endangered by the occurrence.

2. When a spill or leak event is so severe that it may endanger a major portion of the immediate area, the area will be evacuated in coordination with local authorities

3. When instructions are given to evacuate the area, employees are to:

a. Shut down equipment that, if allowed to run, may create a hazard or cause damage if left unattended;

b. Leave in an orderly manner and meet at a designated meeting area utilizing the nearest and safest route; and

c. Remain in the meeting are until an "all clear" is signaled or until directed by the authorities to leave the area.

EMERGENCY REPORTING In the event of an emergency or hazardous material/waste spill during transportation, ECOFLO will immediately contact the proper authorities as necessary, and provide the following information:

1. Name of person reporting incident;

Page 5 of 11 EHS-PRO-004 Revised 05/14/18

2. Transporter's name, address, and EPA ID# 3. Telephone number at incident; 4. Location of incident; 5. Type of incident (spill or leak); 6. Chemicals Involved:

a. Trade name; b. Chemical names or formulas; c. CAS#, if available; d. DOT ID# (UN/NA#); e. DOT Guide Number; and f. EPA/State waste code(s).

7. Type and condition of containers; 8. Generator/Shipper's name, address, telephone number and EPA ID#; 9. TSD/Consignee name, address, telephone number and EPA ID#; 10. Nature and extent of injuries; 11. Nature and extent of property damage (quantity, extent of soil, water or air

contamination): 12. Weather conditions; and 13. Type of area (populate, rural, etc.).

The transporter will send a written report of the incident to the following places:

1. Director, Office of Hazardous Material Registration; 2. Proper state authorities (within 15days); 3. Federal Environmental Protection Agency; 4. Generator of waste; and 5. DOT F-5800 Hazardous Materials Incident Report.

The driver must notify state authorities within 1 hour after a spill. The driver should stay with the vehicle if possible and assist authorities. CHEMICAL INFORMATION SOURCES ECOFLO uses two primary sources for chemical information. First is the company's Manguard System, a hazardous material database. Information on all waste materials handled and transported by ECOFLO is contained in this system. The second source is ECOFLO's library references, including:

1. Condensed Chemical Dictionary 2. Handbook of Chemistry and Physics 3. The Merck Index 4. Materials Safety Data Sheets 5. NIOSH/OSHA Pocket Guide Hazardous Materials Emergency Response Guidebook; 6. NIOSH/OSHA Pocket Guide to Chemical Hazards; 7. Dangerous Properties of Industrial Materials; 8. Chemical Hazard Response Information System; 9. The Condensed Chemical Dictionary; and 10. Emergency Handling of Hazardous Materials in Surface Transportation.

Page 6 of 11 EHS-PRO-004 Revised 05/14/18

SPILL CONTAINMENT EQUIPMENT Trucks carrying drummed hazardous materials are also provided with a spill kit that contains at a minimum:

1. Salvage drum; 2. Shovel; 3. Sorbent material; 4. Spill pads; 5. Five-gallon pail; and 6. Personal Protective Equipment;

Page 7 of 11 EHS-PRO-004 Revised 06/13/18

APPENDIX I - STATE EMERGENCY SPILL REPORTING PHONE NUMBERS

Alabama (800) 842-0699 Emergency Management Agency

Arkansas (501) 682-0716 Arkansas DEQ

Delaware (800) 662-8802 Delaware ONR

District of Columbia (202) 727-6161 DC Emergency Management Agency

Georgia (404) 654-4300 State Operations Center

Illinois (800) 782-7860 Illinois Emergency Management Agency

Indiana (888) 233-7745 IDEM Emergency Response Section

Kentucky (502) 564-6716 KYEQC

Louisiana (225) 925-6595 DEQ - Hazmat Hotline

Maryland (866) 633-4686 MDE's Emergency Response Division

Michigan (800) 292-4706 Pollution Emergency Alert System

Mississippi (800) 222-6362 Mississippi Emergency Management Agency

Missouri (573) 634-2436 Missouri DNR

New Jersey (877) 927-6337 WARNDEP Hotline

Ohio (800) 282-9378 Ohio EPA - Emergency Response Section

Pennsylvania (800) 541-2050 Statewide Emergency Response

(866) 825-0208 DEP South Central

(484) 250-5900 DEP Southeast

(570) 826-2511 DEP Northeast

(570) 327-3636 DEP North Central

(800) 373-3398 DEP Northwest

(412) 442-4000 DEP Southwest

South Carolina (803) 896-4111 DHEC

Tennessee (888) 891-8332 Environmental Assistance Center

Virginia (800) 468-8892 Virginia Emergency Response Council

West Virginia (800) 642-3074 DEP Emergency Hotline

Page 8 of 11 EHS-PRO-004 Revised 05/14/18

APPENDIX II - FEDERAL HAZARDOUS WASTE PHONE NUMBERS

DOT (202) 366-4000

CHEMTREC (800) 424-9300

National Response Center (800) 424-8802

(202 267-2675

EPA Hotline (800) 424-9346

EPA Region 1 (617) 918-1111

EPA Region 2 (201) 637-3000

EPA Region 3 (215) 814-5000

EPA Region 4 (404) 562-9900

EPA Region 5 (312) 353-2000

EPA Region 6 (214) 665-2200

CDC Poison Control Center (800) 222-1222

RCRA Superfund (202) 272-0167

TSCA (202) 272-0167

National Safety Council (800) 621-7619

OSHA (800) 321-6742

ACGIH (513) 742-2020

Page 9 of 11 EHS-PRO-004 Revised 05/14/18

APPENDIX Ill - ADDITIONAL NUMBERS

PA DEP - Low Level Radioactive Waste (800) 232-2786

PA DEP Water Management Manager (717) 705-4795

PA DEP Emergency Response Coordinator (717) 705-4741

PA DEP Waste Management Manager (717) 705-4938

Water Supply & Community Health Program Manager

(717) 705-4934

PA State Police (717) 428-.1011

York Fire Department (717) 854-3921

York Health Bureau (717) 849-2252

York EMS 911

Page 10 of 11 EHS-PRO-004 Revised 05/14/18

APPENDIX IV - EMERGENCY SPILL RESPONSE CONTRACTORS

ECOFLO, Inc. (910) 855-7925

EPS of Vermont (800) 577-4557

SWS (877) 742-4215

Hepaco (800) 888-7689

Hulls (866) 450-9077

Page 11 of 11 EHS-PRO-004 Revised 05/14/18

APPENDIX V – TRUCK EMERGENCY EQUIPMENT

Protective Clothing Chemical Resistant Gloves

Boots

Chemical goggles

Hard hat w/ face shield

Chemical Resistant Clothing

First Aid Kit Standard first aid kit w/ eye wash

Respirator Full-face or half-face w/ organic vapor/acid gas combination cartridges w/ HEPA filter

Tool Kit Basic manufacturing tool kit

Portable Fire Extinguishers

20# Class ABC extinguisher in cab, additional units may be mounted on outside of tractor or trailer

Communications CB radio and/or cellular phone

Spill Control Kit One (1) overpack drum, one (1) shovel, sorbent material suitable for caustic and solvent spills

DOT Emergency Response Guide Book DOT Emergency Response Guidebook for hazardous materials incidents

UNITED STATES OF AMERICADEPARTMENT OF TRANSPORTATIONPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION

HAZARDOUS MATERIALSCERTIFICATE OF REGISTRATIONFOR REGISTRATION YEAR(S) 2019-2021

Registrant: ECOFLO INC

ATTN: Preston Black2750 PATTERSON STREETGREENSBORO, NC 27407

This certifies that the registrant is registered with the U.S. Department of Transportation as required by

49 CFR Part 107, Subpart G.

This certificate is issued under the authority of 49 U.S.C. 5108. It is unlawful to alter or falsify this

document.

Reg. No: 050619550138BC Effective: July 1, 2019 Expires: June 30, 2021

HM Company ID: 36103

Record Keeping Requirements for the Registration Program

The following must be maintained at the principal place of business for a period of three years from the

date of issuance of this Certificate of Registration:

(1) A copy of the registration statement filed with PHMSA; and

(2) This Certificate of Registration

Each person subject to the registration requirement must furnish that person's Certificate of Registration

(or a copy) and all other records and information pertaining to the information contained in the

registration statement to an authorized representative or special agent of the U. S. Department of

Transportation upon request.

Each motor carrier (private or for-hire) and each vessel operator subject to the registration requirement

must keep a copy of the current Certificate of Registration or another document bearing the registration

number identified as the "U.S. DOT Hazmat Reg. No." in each truck and truck tractor or vessel (trailers

and semi-trailers not included) used to transport hazardous materials subject to the registration

requirement. The Certificate of Registration or document bearing the registration number must be made

available, upon request, to enforcement personnel.

For information, contact the Hazardous Materials Registration Manager, PHH-52, Pipeline and

Hazardous Materials Safety Administration, U.S. Department of Transportation, 1200 New Jersey

Avenue, SE, Washington, DC 20590, telephone (202) 366-4109.

U.S. Department of Transportation

Federal Motor Carrier Safety 1200 New Jersey Ave., S.E.

Administration Washington, DC 20590

May 14, 2018

In reply refer to:

USDOT Number: 310422

MC Number: MC727029

PAUL MCALLISTER

PRESIDENT

ECOFLO HOLDING INC

ECOFLO INC

2750 PATTERSON ST

GREENSBORO, NC 27407

HAZARDOUS MATERIALS SAFETY PERMIT HM Safety Permit ID: US-310422-NC-HMSP

Effective Date: May 14, 2018

Dear PAUL MCALLISTER:

The Hazardous Materials Safety Permit (HMSP) is verification of the motor carrier's permission

to engage in the transportation of hazardous materials listed in 49 CFR 385.403 by motor

vehicle in interstate, intrastate, or foreign commerce.

This HMSP will be effective beginning May 14, 2018 and remain effective through February 29,

2020 if your company maintains compliance with the requirements pertaining to the safe and

secure movement of hazardous materials for the protection of the public (49 CFR 385 and other

applicable Federal Motor Carrier Safety Regulations and Hazardous Material Regulations).

Failure to maintain compliance will constitute sufficient grounds for suspension or revocation

of this authority.

Willful and persistent noncompliance with applicable safety fitness regulations as evidenced by

a Department of Transportation safety fitness rating less than "Satisfactory" or by other

indicators, could result in a proceeding requiring the holder of this permit to show cause as to

why this authority should not be suspended or revoked.

For questions regarding this document you may contact the FMCSA Hazardous Materials Division

at 202-366-6121.

Sincerely,

Joseph P. DeLorenzo

Director, Office of Enforcement and Compliance

Tracking Number: 2017078076 DUNS Number on file: 071212823

SPECIAL PERMIT AUTHORIZATION

DOT-SP 12102

EXPIRATION DATE: 2021-06-30

GRANTEE: ECOFLO, INC.GREENSBORO, NC

In response to your July25, 2017 application for renewal of DOT-SP 12102, the grantee status to DOT-SP 12102 for ECOFLO, INC. is

_________________________William SchoonoverAssociate Administrator for Hazardous Materials Safety

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US ECOLOGY, YORK, PENNSYLVANIA

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Table of Contents

I. Facility Overview II. Treatment Capabilities III. Site Description IV. Waste Evaluation, Pre-Approval and Receipt V. Insurance and Financial Information VI. Training, Safety, Security & Contingency Planning VII. Regulation by Government Agencies VIII. Management System and ISO Certification

Appendices

1. Organization 2. Driving Directions and Facility Location Map 3. Facility Diagram 4. PADEP Operating License 5. PADEP National Pollution Discharge Elimination System 6. City of York - Industrial Wastewater Permit 7. DOT Hazardous Materials Certificate of Registration 8. PADEP AQD - Air Permit 9. Permit List 10. Waste Profile Form 11. Closure Financial Assurance 12. Insurance Certificate and MCS-90 13. List of Acceptable Waste Codes 14. ISO/OHSAS Certification

The electronic version of this document is the controlled version. Each user is responsible for ensuring that any document being used is the current version.

COM-FM-010-COR September 2018

I. Facility Overview

Facility Location Regional Office Corporate Office 730 Vogelsong Road 17440 College Pkwy 101 S. Capitol Blvd York, PA 17404 Suite 300 Suite 1000 (717) 846-1900 Livonia, MI 48152 Boise, ID 83702 (734) 521-8000 (800) 590-5220

Office Hours

8:00 a.m. to 5:00 p.m. Monday - Friday

Relationship to Other US Ecology Companies US Ecology York is an independent company represented in the marketplace by the US Ecology name. The following information is an overview of the US Ecology York facility. The facility handles a multitude of hazardous and non-hazardous liquids, solids, and debris and provides safe and effective hazardous waste management solutions. If the answers to your questions about the facility do not appear in the following pages, all you need to do is ask and an associate will be pleased to assist you. The facility was acquired by EQ – The Environmental Quality Company in May 2010. In June, 2014, EQ was acquired by US Ecology, Inc., which is headquartered in Boise, Idaho. US Ecology is a leading North American provider of environmental services to commercial and government entities. The Company addresses the complex waste management needs of its customers, offering treatment, disposal and recycling of hazardous and radioactive waste, as well as a wide range of complementary field and industrial services and has been protecting the environment since 1952. For more information visit www.usecology.com.

Facility Type

EPA ID # NAICS Code

SIC Code Corporate Federal Tax ID#

Dun & Bradstreet

Storage, stabilization and waster water treatment of hazardous and nonhazardous wastes PAD 010 154 045 562211 4953 20-5676570 80-283-9220

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US Ecology Locations

We address the complex waste management needs of our customers, offering treatment, disposal and recycling of hazardous and radioactive waste, as well as a wide range of complementary field and industrial services across North America.

Corporate OfficeBoise, ID (800) 590-5220

Regional OfficeLivonia, MI (800) 592-5489

National Emergency Response(800) 839-3975

US Ecology Locations

Alabama

Sulligent, AL TSDF

(205) 698-8915

Sulligent, AL Service Satellite

(404) 346-6860

Arizona

Phoenix, AZ Service Center

(623) 243-1200

California

Los Angeles, CA Service Satellite

(623) 243-1200

San Francisco, CA Service Satellite

(623) 243-1200

Vernon, CA TSDF

(800) 266-7747

Florida

Miami, FL Service Satellite

(800) 624-5302

Tampa, FL TSDF

(800) 624-5302

Georgia

Atlanta, GA Service Center

(404) 346-6860

Idaho

Boise, ID Corporate Office

(800) 590-5220

Grand View, ID TSDF

(800) 274-1516

Illinois

Chicago, IL TSDF

(708) 596-7040

Chicago, IL Service Satellite

(317) 247-7100

Indiana

Indianapolis, IN Service Center

(317) 247-7100

Kentucky

Lexington, KY Service Satellite

(317) 247-7100

Louisiana

Baton Rouge, LA Service Satellite

(404) 346-6860

Maryland

Baltimore, MD Service Center

(443) 304-3050

Massachusetts

Boston, MA Service Center

(800) 426-9878

Michigan

Belleville, MI TSDF

(800) 592-5489

Detroit, MI (North) TSDF

(800) 396-3265

Detroit, MI (South) TSDF

(313) 923-0080

Detroit Service Center Service Center

(800) 592-5489

Grand Rapids, MI Service Satellite

(800) 592-5489

Livonia, MI Admin Office

(800) 592-5489

Romulus, MI Recycling

(734) 727-5500

Taylor, MI Service Center

(734) 941-4357

Minnesota

Minneapolis, MN Recycling

(612) 727-1582

Nevada

Beatty, NV TSDF

(800) 239-3943

New Jersey

Bayonne, NJ Service Center

(201) 436-3500

New York

Albany, NY Service Satellite

(800) 426-9878

North Carolina

Mt. Airy, NC Recycling

(336) 719-0058

Mt. Airy, NC Service Satellite

(404) 346-6860

Ohio

Canton, OH TSDF

(330) 456-6238

Canton Service Center Service Center

(330) 617-4318

Dayton, OH Service Satellite

(800) 592-5489

Rudolph, OH Service Satellite

(800) 839-3975

Oklahoma

Tulsa, OK TSDF

(918) 582-9595

Tulsa, OK Service Satellite

(404) 346-6860

Pennsylvania

Pittsburgh, PA Recycling

(412) 472-1007

York, PA TSDF

(717) 846-1900

York, PA Service Satellite

(443) 304-3050

Rhode Island

Providence, RI Service Satellite

(508) 803-1250

Texas

Dallas, TX Service Satellite

(404) 346-6860

Houston, TX Service Center

(800) 715-5812

Robstown, TX TSDF

(800) 242-3209

Washington

Richland, WA TSDF

(509) 377-2411

Tacoma, WA Service Satellite

(734) 578-7957

Canada

Blainville, QC TSDF

(450) 430-9230

Tilbury, ON TSDF

(519) 682-2903

Mexico

Monterrey, Nuevo Leon Service Center

81 8335 2446

Environmental Waste Treatment,

Recycling or Disposal

Industrial Industrial Cleaning &

Maintenance, Sewer Services, Tank & Oil

Processing, Marine & Terminal Processing,

Vacuum Excavation and Other Services

Field Total Waste Management, Retail,

Household Hazardous Waste, Lab Pack,

Less-Than-Truckload, Remediation

Emergency Response

Services

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UNITED STATES OF AMERICADEPARTMENT OF TRANSPORTATIONPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION

HAZARDOUS MATERIALSCERTIFICATE OF REGISTRATIONFOR REGISTRATION YEAR(S) 2018-2020

Registrant: ENVIRITE OF PENNSYLVANIA INC

ATTN: STEFANIEANA M. HERSH730 VOGELSONG ROADYORK, PA 17404

This certifies that the registrant is registered with the U.S. Department of Transportation as required by

49 CFR Part 107, Subpart G.

This certificate is issued under the authority of 49 U.S.C. 5108. It is unlawful to alter or falsify this

document.

Reg. No: 061418550049AB Effective: July 1, 2018 Expires: June 30, 2020

HM Company ID: 32747

Record Keeping Requirements for the Registration Program

The following must be maintained at the principal place of business for a period of three years from the

date of issuance of this Certificate of Registration:

(1) A copy of the registration statement filed with PHMSA; and

(2) This Certificate of Registration

Each person subject to the registration requirement must furnish that person's Certificate of Registration

(or a copy) and all other records and information pertaining to the information contained in the

registration statement to an authorized representative or special agent of the U. S. Department of

Transportation upon request.

Each motor carrier (private or for-hire) and each vessel operator subject to the registration requirement

must keep a copy of the current Certificate of Registration or another document bearing the registration

number identified as the "U.S. DOT Hazmat Reg. No." in each truck and truck tractor or vessel (trailers

and semi-trailers not included) used to transport hazardous materials subject to the registration

requirement. The Certificate of Registration or document bearing the registration number must be made

available, upon request, to enforcement personnel.

For information, contact the Hazardous Materials Registration Manager, PHH-52, Pipeline and

Hazardous Materials Safety Administration, U.S. Department of Transportation, 1200 New Jersey

Avenue, SE, Washington, DC 20590, telephone (202) 366-4109.

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9/13/2018

Envirite of Pennsylvania (dba US Ecology York) 730 Vogelsong Road

York, PA 17404 PAD 010 154 045

INDUSTRIAL WASTEWATER CONTRIBUTION PERMIT (POTW)

Issued by: City of York, Department of Public Works Permit #: CYP-0005 Date Effective: October 01, 2015 Date of Expiration: September 30, 2018

STORMWATER DISCHARGE PERMIT (NPDES General Permit PAG-03)

Issued by: Pennsylvania Department of Environmental Protection Permit #: PAR 403503 Date Effective: June 1, 2015 Date of Expiration: May 31, 2020

AIR PERMIT – STATE ONLY OPERATING PERMIT

Issued by: Pennsylvania Department of Environmental Protection State Only Permit #: 67-03043 Date Issued: September 30, 2013 Date Effective: October 1, 2013 Date of Expiration: September 30, 2018

DOT HAZARDOUS MATERIALS REGISTRATION

Issued by: United States Department of Transportation Registration #: 061418550049AB Date Issued: July 01, 2018 Date of Expiration: June 30, 2020

PART A PERMIT APPLICATION

Current Update Submitted: March 2009 RCRA PART B PERMIT RENEWAL

Issued by: Pennsylvania Department of Environmental Protection APS ID #: 465670 EPA ID/Permit #: PAD010154045 Date Effective: February 17, 2006 Date of Expiration: February 17, 2016 *The facility is authorized to operate under the conditions of the existing license until the department makes a final determination on the renewal application.

ISO Certifications ISO 14001:2015 ISO 9001:2015 OHSAS 18001:2007 NSF NSF NSF Cert No: 6S202-EM8-C0066982 Cert No: 6S202-IS8-C0066982 Cert Number: 6S202-EM8-60066982 Issue Date: May 08, 2018 Issue Date: May 08, 2018 Issue Date: May 08, 2018 Expiration Date: May 07, 2021 Expiration Date: May 07, 2021 Expiration Date: March 11, 2021

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CSV-FM-001-COR EQ-The Environmental Quality Company Page 1 of 4 12/12

Profile Tracking #

WASTE PROFILE FORM

For assistance in completing this document or for additional information on service offerings, please visit our website at www.usecology.com, or call 800-592-5489.

US Ecology will choose the appropriate facility and method of waste management for your waste from the

technologies offered at each operation.

If you wish to direct this waste to a specific facility(s) or treatment technology please indicate here:

Waste Common Name:

Section 1 – Generator & Customer Information Generator EPA ID #

NAICS/SIC Code

Generator

Facility Address

City State Zip

24-hour Emergency Response Number

Mailing Address

City State Zip

Generator Contact

Title

Phone Fax

E-mail

Internal Use Only: EQ Division

EQ Customer No.

Invoicing Company

Address

City State Zip

Country

Invoicing Contact

Phone Fax

Technical Contact

Phone Fax

Cell Phone

E-mail

Section 2 – Shipping & Packaging Information 2.1) Shipping Volume & Frequency:

a) Volume of Waste to be Shipped:

b) Frequency: One time Month Year Other:

2.2) DOT Information a) Is this a U.S. Department of Transportation (USDOT) Hazardous Material? Yes No

b) If “Yes”, indicate the proper shipping name per 49CFR 172.101 Hazardous Materials Table:

Section 3 – Special Properties 3.1) Color

3.2) Odor None Ammonia Amines Mercaptans Sulfur Organic Acid Amines/Ammonia

Other:

3.3) Consistency at 700F: Solid Dust/Powder Debris Sludge Liquid Gas/Aerosol Varies

3.4) What is the pH? <2 2.1-4.9 5 – 10 10.1 – 12.4 >12.5 N/A

3.5) What is the flash point? <900F 90-1390F 140-1990F >2000F N/A

CSV-FM-001-COR EQ-The Environmental Quality Company Page 2 of 4 12/12

3.6) Does this waste exhibit any of the following properties? (check all that apply)

None Free Liquids Metal Fines Water Reactive Biohazard Shock Sensitive Oily Residue Dioxins Furans Aluminum Asbestos – non-friable Asbestos – friable Other Radioactive Air Reactive Isocyanates Biodegradable Sorbents Pyrophoric Reactive Sulfide Reactive Cyanide Explosives Temperature Controlled Organic Peroxide NORM TENORM

Section 4 – Composition and Generating Process

4.1) Provide a physical and chemical composition of the waste (e.g. soil, water, PPE, debris, etc.). List the percent ranges

of the material, either estimated or known.

to % to %

to % to %

to % to %

4.2) Provide a description of the generating process. Remediation & IDW Sites: please provide a site history. 4.3) Are there any known previous handling or treatment issues involving this waste? Yes* No

*If yes, describe:

Section 5 – Hazardous Wastes

As determined by 40 CFR, Part 261 and State Rules: Please list applicable waste code(s):

5.1) Is this waste exempted from RCRA? Yes, please provide exemption: No

5.2) Is this an EPA RCRA listed hazardous waste (F, K, P or U)? Yes: No a) For F006–F009, F012, does this come from a generator that conducts a cyanide plating process? Yes No

5.3) Is this an EPA RCRA characteristic hazardous waste (D001-D043)? Yes: No

5.4) Do any State Specific Hazardous Waste Codes apply? Yes: No

If you answered ‘no’ to 5.2, 5.3 and 5.4, please proceed to Section 6.

5.5) EPA Source Code: EPA Form Code:

5.6) Waste Code Determination Is Based On: Generator Knowledge Analysis MSDS Analysis and/or MSDS may be required for review and approval for hazardous and non-hazardous waste streams.

5.7) Does this waste exceed Land Disposal Restriction levels? Yes No

a) Is this stream a wastewater (WW) or non-wastewater (NWW)? WW NWW b) If this waste stream is greater than 50% soil, does it meet the alternative soil treatment standards of 40CFR 268.49? Yes No

c) Does this waste contain greater than 50% debris, by volume? Yes No (Debris is greater than 2.5 inches in size.)

d) If the debris is larger than 3 ft x 3 ft x 3 ft, please provide the approximate dimensions and weight:

5.8) If this is a characteristic hazardous waste, does it contain Underlying Hazardous Constituents? Yes* No

*If Yes, please list: For a complete list of UHC constituents, please refer to 40 CFR 268.48

CSV-FM-001-COR EQ-The Environmental Quality Company Page 3 of 4 12/12

Section 6 – Non-Hazardous Wastes Please list applicable waste code(s):

6.1) Do any State Specific Non-Hazardous Waste Codes apply? Yes No 6.2) Is this a Universal (UNIV) waste or a Recyclable Good (RG)? UNIV RG N/A 6.3) Is this waste used oil as defined by 40 CFR Part 279? Yes No a) If yes, is the total halogen content of the used oil waste stream greater than 1,000 ppm? Yes No b) If yes, what is the source of the halogen content?

This is a metalworking oil/fluid containing chlorinated paraffins. This is used oil contaminated with chlorofluorocarbons from refrigeration units. This oil contains halogenated solvents. List specific solvents: Other, describe:

Section 7 – TSCA Information

7.1) What is the concentration of PCBs in the waste? None 0-49 ppm 50-499 ppm 500+ ppm 7.2) Does the waste contain PCB contamination from a source with a concentration > 50 ppm? Yes No Unknown If you answered “none” or “0-49 ppm”’ to 7.1 and “no” to 7.2, please proceed to Section 8. 7.3) Has this waste been processed into a non-liquid form? Yes* No *If yes, what was the concentration of PCBs prior to processing? 0-499 ppm 500+ ppm 7.4) Is this non-liquid PCB waste in the form of soil, rags, debris, or other contaminated media? Yes No 7.5) Are you a PCB capacitor manufacturer or a PCB equipment manufacturer? Yes No 7.6) Has the PCB Article (e.g., transformer, hydraulic machine, PCB-contaminated electrical equipment) been drained/flushed of all PCBs and decontaminated in accordance with 40 CFR 761.60(b)? N/A Yes No

Section 8 – Clean Air Act Information

8.1) Is this waste subject to regulation under 40 CFR, Part 264, Subpart CC (VOC > 500 ppmw)? Yes No 8.2) Is this waste subject to regulation under 40 CFR, Part 63, Subpart DD (VOHAP > 500 ppmw)? Yes No 8.3) Is the site, or waste, subject to any other NESHAP/MACT standard(s)? Yes* No

*If Yes this document serves as notification that this waste contains chemicals , required to be managed in accordance with Part 61 62 63 Subpart of NESHAP/MACT standards.

8.4) Does this waste stream contain Benzene? Yes No If you answered “no” to 8.4, please proceed to Section 9. 8.5) Does the waste stream come from a facility subject to 40 CFR 61, Subpart FF (Benzene NESHAP)?

Yes, please provide the SIC/NAICS code: No

If you answered “no” to questions 8.5, please proceed to Section 9. 8.6) Does your facility manage the waste subject to Benzene NESHAP in a manner other than shipping off-site?

Yes, please specify: No

8.7) Is the generating source of this waste a facility with Total Annual Benzene (TAB) >10 Mg/year? Yes No 8.8) Does the waste contain >10% water? Yes No 8.9) What is the TAB quantity for your facility? Mg/Year

8.10) What is the total Benzene concentration in your waste? Percent or ppmw. Supporting analysis must be attached. Do not use TCLP analytical results. Acceptable laboratory methods include 8020, 8240, 8260, 602 and 624.

Section 9 – Certification

I certify that all information (including attachments) is complete and factual and is an accurate representation of the known and suspected hazards, pertaining to the waste described herein. I authorize EQ’s personnel to add supplemental information to the waste approval file, provided I am contacted and give verbal permission. I authorize EQ’s personnel to obtain a sample from any waste shipment for purposes of verification and confirmation. I agree that, if EQ approves the waste described herein, all such wastes that are transported, delivered, or tendered to EQ by Generator or on Generator’s behalf shall be subject to, and Generator shall be bound by, the attached Standard Terms and Conditions. If I am an agent acting on behalf of the generator, I also certify that I have permission to sign any and all waste characterization paperwork on the generator’s behalf and that I can produce such certification in writing upon request.� Generator Signature Printed Name Company Title Date

CSV-FM-001-COR EQ-The Environmental Quality Company Page 4 of 4 12/12

STANDARD TERMS AND CONDITIONS

The Agreement between the Customer and EQ – The Environmental Quality Company and/or its member companies (hereinafter “EQ”) related to or associated with Delivered Waste, as herein defined, shall be governed by the following Standard Terms and Conditions in addition to the terms and conditions contained in any Waste Profile Form, Customer Approval Quote Confirmation, Generator Approval Notification, Notice of Waste Approval Expiration, and/or Credit Agreement associated with such Delivered Waste. The Customer may use its standard forms (such as purchase orders, acknowledgments of orders, and invoices) to administer its dealings under this Agreement for convenience purposes, but all provisions thereof in conflict with these terms and conditions shall be deemed stricken. Definitions The following definitions shall apply for purposes of this Agreement: “Acceptable Waste” shall mean any hazardous waste, as defined under applicable State or federal law, determined by EQ as acceptable for treatment and/or disposal in accordance with this Agreement. “Delivered Wastes” shall mean all wastes (i) which are transported, delivered, or tendered to EQ by the Customer; (ii) which the Customer has arranged for the transport, delivery or tender to EQ; or (iii) ) which are transported, delivered, or tendered to EQ under a Credit Agreement between the Customer and EQ. “Non-Conforming Wastes” shall mean wastes that (a) are not in accordance in all material respects with the warranties, descriptions, specifications or limitations stated in the Waste Profile Form and this Agreement; (b) have constituents or components of a type or concentration not specifically identified in the Waste Profile Form (i) which increase the nature or extent of the hazard and risk undertaken by EQ in treating and/or disposing of the waste, or (ii) for whose treatment and/or disposal a Waste Management Facility is not designed or permitted, or (iii) which increase the cost of treatment and/or disposal of waste beyond that specified in EQ’s price quote; or (c) are not properly packaged, labeled, described, or placarded, or otherwise not in compliance with United States Department of Transportation and United States Environmental Protection Agency regulations. Control of Operations. EQ shall have sole control over all aspects of the operation of any treatment and/or disposal facility of EQ receiving Delivered Wastes under this Agreement (hereinafter, “Waste Management Facility”), including, without limitation, maintaining EQ’s desired volume of Acceptable Wastes being delivered to any Waste Management Facility by the Customer or any other person or entity. Identification of Waste. For each waste material to be transported, delivered, or tendered to EQ under this Agreement, the Customer shall provide, or cause to be provided, to EQ a representative sample of the waste material and a completed Waste Profile Form containing a physical and chemical description or analysis of such waste material, which description shall conform with any and all guidelines for waste acceptance provided by EQ. On the basis of EQ’s analysis of such representative sample of the waste material and such Waste Profile Form, EQ will determine whether such wastes are Acceptable Wastes. EQ does not make any guarantee that it will handle any waste material or any particular quantity or type of waste material, and EQ reserves the right to the decline to transport, treat and/or dispose of waste material. The Customer shall promptly furnish to EQ any information regarding known, suspected or planned changes in the composition of the waste material. Further, the Customer shall promptly inform EQ of any change in the characteristic or condition of the waste material which becomes known to the Customer subsequent to the date of the Waste Profile Form. Non-Conforming Wastes. In the event that EQ at any time discovers that any Delivered Waste is Non-Conforming Waste, EQ may reject or revoke its acceptance of the Non-Conforming Waste. The Customer shall have seven (7) days to direct an alternative lawful manner of disposition of the waste, unless it is necessary by reason of law or otherwise to move the Non-Conforming Waste prior to expiration of the seven (7) day period. If the Customer does not direct an alternative disposal, at its option, EQ may return any such Non-Conforming Wastes to the Customer, and the Customer shall pay or reimburse EQ for all costs and expenses incurred by EQ in connection with the receipt, handling, sampling, analyses, transportation and return to the Customer of such Non-Conforming Wastes. If it is impossible or impractical for EQ to return the Non-Conforming Waste to the Customer, the Customer shall reimburse EQ for all costs, of any type or nature whatsoever, incurred by EQ, solely because such Delivered Waste was Non-Conforming Waste (including, but not limited to, all costs associated with any remedial steps necessary, due to the nature of the Non-Conforming Waste, in connection with material with which the Non-Conforming Waste may have been commingled and all expenses and charges for analyzing, handling, locating, preparing for transporting, storing and disposing of any Non-Conforming Waste). Customer Warranty - Acceptable Wastes. All Delivered Wastes shall be Acceptable Wastes and shall conform in all material respects to the description and specifications contained in the Waste Profile Form. The information set forth in the Waste Profile Form or any manifest, placard or label associated with any Delivered Wastes, or otherwise represented by the Customer or the generator (if other than the Customer) to EQ, is and shall be true, accurate and complete as of the date of receipt of the involved waste by EQ. Customer Warranty - Title to Wastes. Either the Customer or the generator (if other than the Customer) shall hold clear title, free of any all liens, claims, encumbrances, and charges to Delivered Waste until such waste is accepted by EQ. Customer Warranty - Compliance with Laws. The Customer shall comply with all applicable federal, state and local environmental statutes, regulations, and other governmental requirements, as well as directives issued by EQ from time to time, governing the transportation, treatment and/or disposal of Acceptable Wastes, including, but not limited to, all packaging, manifesting, containerization, placarding and labeling requirements. Customer Warranty - Updating Information. If the Customer receives information that Delivered Waste or other hazardous waste described in the Waste Profile Form, or some component of such waste, presents or may present a hazard or risk to persons, property or the environment which was not disclosed to EQ, or if the Customer or generator (if other than the Customer) has changed the process by which such waste results, the Customer shall promptly report such information to EQ in writing. Customer Indemnity. The Customer shall indemnify, defend and hold harmless EQ, and its affiliated or related companies, and all of their respective present or future officers, directors, shareholders, employees and agents from and against any and all losses, damages, liabilities, penalties, fines, forfeitures, demands, claims, causes of action, suits, costs and expenses (including, but not limited to, reasonable costs of defense, settlement, and reasonable attorneys’ fees), which may be asserted against any or all of them by any person or any governmental agency, or which any or all of them may hereafter suffer, incur, be responsible for or pay out, as a result of or in connection with bodily injuries (including, but not limited to, death, sickness, disease and emotional or mental distress) to any person (including EQ’s employees), damage (including, but not limited to, loss of use) to any property (public or private), or any requirements to conduct or incur expense for investigative, removal or remedial expenses in connection with contamination of or adverse effect on the environment, or any violation or alleged violation of any statues, ordinances, orders, rules or regulations of any governmental entity or agency, caused or arising out of (i) a breach of this Agreement by the Customer, (ii) the failure of any warranty of the Customer to be true, accurate and complete, or (iii) any willful or negligent act or omission of the Customer, or its employees or agents in connection with the performance of this Agreement. Force Majeure EQ shall not be liable for any failure to accept, receive, handle, treat, and/or dispose of Delivered Waste due to an act of God, fire, casualty, flood, war, strike, lockout, labor trouble, failure of public utilities, equipment failure, facility shutdown, injunction, accident, epidemic, riot, insurrection, destruction of operation or transportation facilities, the inability to procure materials, equipment, or sufficient personnel or energy in order to meet operational needs without the necessity of allocation, the failure or inability to obtain any governmental approvals or to meet Environmental Requirements (including, but not limited to voluntary or involuntary compliance with any act, exercise, assertion, or requirement of any governmental authority) which may temporarily or permanently prohibit operations of EQ, the Customer, or the Generator, or any other circumstances beyond the control of EQ which prevents or delays performance of any of its obligations under this Agreement. Governing Laws This Agreement shall in all respects be governed by and shall be construed in accordance with the laws of the State of Michigan applied to contracts executed and performed wholly within such state. Bulk Disposal Charges Quoted bulk disposal charges for solid materials will be billed by the cubic yard, if the waste density is less than 2,000lbs./cubic yard. If waste density is greater than 2,000 lbs./cubic yard, then bulk disposal charges will be billed by the ton, regardless of the approved container.

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SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN

ACCORDANCE WITH THE POLICY PROVISIONS.

INSURER(S) AFFORDING COVERAGE

INSURER F :

INSURER E :

INSURER D :

INSURER C :

INSURER B :

INSURER A :

NAIC #

NAME:CONTACT

(A/C, No):FAX

E-MAILADDRESS:

PRODUCER

(A/C, No, Ext):PHONE

INSURED

REVISION NUMBER:CERTIFICATE NUMBER:COVERAGES

IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on

this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES

BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED

REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

OTHER:

(Per accident)

(Ea accident)

$

$

N / A

SUBRWVD

ADDLINSD

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIODINDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THISCERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS,EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.

$

$

$

$PROPERTY DAMAGE

BODILY INJURY (Per accident)

BODILY INJURY (Per person)

COMBINED SINGLE LIMIT

AUTOS ONLY

AUTOSAUTOS ONLYNON-OWNED

SCHEDULEDOWNED

ANY AUTO

AUTOMOBILE LIABILITY

Y / N

WORKERS COMPENSATION

AND EMPLOYERS' LIABILITY

OFFICER/MEMBER EXCLUDED?(Mandatory in NH)

DESCRIPTION OF OPERATIONS belowIf yes, describe under

ANY PROPRIETOR/PARTNER/EXECUTIVE

$

$

$

E.L. DISEASE - POLICY LIMIT

E.L. DISEASE - EA EMPLOYEE

E.L. EACH ACCIDENT

EROTH-

STATUTEPER

LIMITS(MM/DD/YYYY)POLICY EXP

(MM/DD/YYYY)POLICY EFF

POLICY NUMBERTYPE OF INSURANCELTRINSR

DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

EXCESS LIAB

UMBRELLA LIAB $EACH OCCURRENCE

$AGGREGATE

$

OCCUR

CLAIMS-MADE

DED RETENTION $

$PRODUCTS - COMP/OP AGG

$GENERAL AGGREGATE

$PERSONAL & ADV INJURY

$MED EXP (Any one person)

$EACH OCCURRENCEDAMAGE TO RENTED

$PREMISES (Ea occurrence)

COMMERCIAL GENERAL LIABILITY

CLAIMS-MADE OCCUR

GEN'L AGGREGATE LIMIT APPLIES PER:

POLICYPRO-JECT LOC

CERTIFICATE OF LIABILITY INSURANCEDATE (MM/DD/YYYY)

CANCELLATION

AUTHORIZED REPRESENTATIVE

ACORD 25 (2016/03)

© 1988-2016 ACORD CORPORATION. All rights reserved.

CERTIFICATE HOLDER

The ACORD name and logo are registered marks of ACORD

HIREDAUTOS ONLY

Willis of Colorado, Inc.

c/o 26 Century Blvd

P.O. Box 305191

Nashville, TN 372305191 USA

US Ecology, Inc.

US Ecology Livonia, Inc.

101 S. Capitol Blvd., Suite 1000

Boise, ID 83702

Umbrella/Excess Policy is not over any Pollution Policy.

SEE ATTACHED

Verification of Insurance

08/02/2019

1-877-945-7378 1-888-467-2378

certificates@willis.com

Greenwich Insurance Company 22322

XL Specialty Insurance Company

XL Insurance America Inc

37885

24554

Tokio Marine Specialty Insurance Company 23850

W12242719

A

1,000,000

500,000

25,000WA Stop Gap

1,000,000

2,000,000

2,000,000

GEC0001731-19 08/01/2019 08/01/2020

SIR 100,000

B

1,000,000

08/01/202008/01/2019

Includes MCS

90 Endt

AEC004634204

B25,000,000

10,000

UEC000173619 08/01/2019 08/01/2020 25,000,000

RWD3000908-04C 1,000,000

No 08/01/2019 08/01/20201,000,000

1,000,000

D Contractors Poll & Professional

Retro Date: 08/1/96

Each IncidentERAFKTK19 08/01/2019 08/01/2020

Aggregate

Deductible Per Incident

131060718344421SR ID: BATCH:

$100,000

$25,000,000

$25,000,000

Page 1 of 2

ACORD 101 (2008/01)

The ACORD name and logo are registered marks of ACORD

© 2008 ACORD CORPORATION. All rights reserved.

THIS ADDITIONAL REMARKS FORM IS A SCHEDULE TO ACORD FORM,

FORM NUMBER: FORM TITLE:

ADDITIONAL REMARKS

ADDITIONAL REMARKS SCHEDULE Page of

AGENCY CUSTOMER ID:

LOC #:

AGENCY

CARRIER NAIC CODE

POLICY NUMBER

NAMED INSURED

EFFECTIVE DATE:

US Ecology, Inc.

US Ecology Livonia, Inc.

101 S. Capitol Blvd., Suite 1000

Boise, ID 83702

INSURER AFFORDING COVERAGE: Tokio Marine Specialty Insurance Company NAIC#: 23850

POLICY NUMBER: PPK2012582 EFF DATE: 08/01/2019 EXP DATE: 08/01/2022

TYPE OF INSURANCE: LIMIT DESCRIPTION: LIMIT AMOUNT:

Pollution & Remediation Legal Each Condition $25,000,000

Liability Aggregate $25,000,000

SIR $250,000

INSURER AFFORDING COVERAGE: Tokio Marine Specialty Insurance Company NAIC#: 23850

POLICY NUMBER: PPK2012586 EFF DATE: 08/01/2019 EXP DATE: 08/01/2020

TYPE OF INSURANCE: LIMIT DESCRIPTION: LIMIT AMOUNT:

Pollution Legal Liability Per Incident $4,000,000

(RCRA Locations) Aggregate $20,000,000

Ded. Per Incident $250,000

2 2

Willis of Colorado, Inc.

See Page 1

See Page 1 See Page 1 See Page 1

25 Certificate of Liability Insurance

W12242719CERT:1310607BATCH:18344421SR ID:

EQ HOLDINGS, INC.

NAMED INSURED SCHEDULE – Casualty

EQ Parent Company, Inc.EQ Holdings, Inc.US Ecology Livonia, Inc.US Ecology Sulligent, Inc.US Ecology Taylor, Inc.US Ecology Tulsa, Inc.US Ecology Tampa, Inc.US Ecology Romulus, Inc.

Michigan Disposal, Inc.

Wayne Disposal, Inc.

EQ Industrial Services, Inc.

EQ Northeast, Inc.

Wayne Energy Recovery, Inc.

EQ Detroit, Inc.

EQ Resource Recovery, Inc.

Certificate Addendum

EQ Mobile Recycling, Inc.

Envirite of Ohio, Inc. (DBA - EQ Ohio) EQ

Metals Recovery, LLC

Envirite of Illinois, Inc. (DBA - EQ Illinois)

Envirite of Pennsylvania, Inc.

Envirite Transportation, LLC

RTF Romulus, LLC.

US Ecology Houston, Inc.

US Ecology Transportation Solutions, Inc.

Dormant Named Insureds:

EQ The Environmental Quality Company

EQ Florida Inc. EQ Alabama, Inc.

EQ Oklahoma, Inc.

Vac-All Services, Inc.

FORM MCS-90 Revised 01/05/2017 OMB No.: 2126-0008 Expiration: 01/31/2020

MCS 90 01/05/2017 Page 1 of 4

US DOT Number: Date Received:

A Federal Agency may not conduct or sponsor, and a person is not required to respond to, nor shall a person be subject to a penalty for failure to comply with a collection of information subject to the requirements of the Paperwork Reduction Act unless that collection of information displays a current valid OMB Control Number. The OMB Control Number for this information collection is 2126-0008. Public reporting for this collection of information is estimated to be approximately 2 minutes per response, including the time for reviewing instructions, gathering the data needed, and completing and reviewing the collection of information. All responses to this collection of information are mandatory. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to: Information Collection Clearance Officer, Federal Motor Carrier Safety Administration, MC-RRA, Washington, D.C. 20590.

Endorsement for Motor Carrier Policies of Insurance for Public Liability under Sections 29 and 30 of the Motor Carrier Act of 1980

FORM MCS-90

Issued to Envirite of Pennsylvania, Inc of York, PA

(Motor Carrier name) (Motor Carrier state or province)

Dated at 505 Eagleview Blvd, Exton PA. 19341

on this

27th

day of

July

2017

Amending Policy Number: AEC004634202 Effective Date: 08/01/2017

Name of Insurance Company: XL Specialty Insurance Company

Countersigned by:

(authorized company representative)

The policy to which this endorsement is attached provides primary or excess insurance, as indicated for the limits shown (check only one): X This insurance is primary and the company shall not be liable for amounts in excess of $ 1,000,000 for each accident.

This insurance is excess and the company shall not be liable for amounts in excess of $ for each accident in excess of the underlying limit of $ for each accident.

Whenever required by the Federal Motor Carrier Safety Administration (FMCSA), the company agrees to furnish the FMCSA a duplicate of said policy and all its endorsements. The company also agrees, upon telephone request by an authorized representative of the FMCSA, to verify that the policy is in force as of a particular date. The telephone number to call is: 800-688-1840. Cancellation of this endorsement may be effected by the company of the insured by giving (1) thirty-five (35) days’ notice in writing to the other party (said thirty-five (35) days’ notice to commence from the date the notice is mailed, proof of mailing shall be sufficient proof of notice), and (2) if the insured is subject to the FMCSA’s registration requirements under 49 U.S.C. 13901, by providing thirty (30) days’ notice to the FMCSA (said thirty (30) days’ notice to commence from the date the notice is received by the FMCSA at its office in Washington, DC).

United States Department of Transportation

Federal Motor Carrier Safety Administration

FORM MCS-90 Revised 01/05/2017 OMB No.: 2126-0008 Expiration: 01/31/2020

MCS 90 01/05/2017 Page 2 of 4

Filings must be transmitted online via the Internet at http://www.fmcsa.dot.gov/urs.

FORM MCS-90 Revised 01/05/2017 OMB No.: 2126-0008 Expiration 01/31/2020

MCS 90 01/05/2017 Page 3 of 4

Accident includes continuous or repeated exposure to conditions or which results in bodily injury, property damage, or environmental damage which the insured neither expected nor intended. Motor Vehicle means a land vehicle, machine, truck, tractor, trailer, or semitrailer propelled or drawn by mechanical power and used on a highway for transporting property, or any combination thereof.

Bodily Injury means injury to the body, sickness, or disease to any person, including death resulting from any of these.

Property Damage means damage to or loss of use of tangible property. Environmental Restoration means restitution for the loss, damage, or destruction of natural resources arising out of the accidental discharge, dispersal, release or escape into or upon the land, atmosphere, watercourse, or body of water, of any commodity transported by a motor carrier. This shall include the cost of removal and the cost of necessary measures taken to minimize or mitigate damage to human health, the natural environment, fish, shellfish and wildlife. Public Liability means liability for bodily injury, property damage, and environmental restoration.

The insurance policy to which this endorsement is attached provides automobile liability insurance and is amended to assure compliance by the insured, within the limits stated herein, as a motor carrier of property, with Sections 29 and 30 of the Motor Carrier Act of 1980 and the rules and regulations of the Federal Motor Carrier Safety Administration (FMCSA). In consideration of the premium stated in the policy to which this endorsement is attached, the insurer (the company) agrees to pay, within the limits of liability described herein, any final judgment recovered against the insured for public liability resulting from negligence in the operation, maintenance or use of motor vehicles subject to the financial responsibility requirements of Sections 29 and 30 of the Motor Carrier Act of 1980 regardless of whether or not each motor vehicle is specifically described in the policy and whether or not such negligence occurs on any route or in any territory authorized to be served by the insured or elsewhere. Such insurance as is afforded, for public liability, does not apply to injury to or death of the insured’s employees while engaged in the course of their employment, or property transported by the insured, designated as cargo. It is understood and agreed that no condition, provision, stipulation, or limitation contained in the policy, this endorsement, or any other endorsement thereon, or violation thereof, shall relieve

the company from liability or from the payment of any final judgment, within the limits of liability herein described, irrespective of the financial condition, insolvency or bankruptcy of the insured. However, all terms, conditions, and limitations in the policy to which the endorsement is attached shall remain in full force and effect as binding between the insured and the company. The insured agrees to reimburse the company for any payment made by the company on account of any accident, claim, or suit involving a breach of the terms of the policy, and for any payment that the company would not have been obligated to make under the provisions of the policy except for the agreement contained in this endorsement. It is further understood and agreed that, upon failure of the company to pay any final judgment recovered against the insured as provided herein, the judgment creditor may maintain an action in any court of competent jurisdiction against the company to compel such payment. The limits of the company’s liability for the amounts prescribed in this endorsement apply separately to each accident and any payment under the policy because of anyone accident shall not operate to reduce the liability of the company for the payment of final judgments resulting from any other accident.

DEFINITIONS AS USED IN THIS ENDORSEMENT

FORM MCS-90 Revised 01/05/2017 OMB No.: 2126-0008 Expiration 01/31/2020

MCS 90 01/05/2017 Page 4 of 4

Type of carriage Commodity transported January 1, 1985

(1) For-hire (in interstate or foreign commerce, with a gross vehicle weight rating of 10,000 or more pounds).

Property (nonhazardous) $750,000

(2) For-hire and Private (in interstate, foreign, or intrastate commerce, with a gross vehicle weight rating of 10,000 or more pounds).

Hazardous substances, as defined in 49 CFR 171.8, transported in cargo tanks, portable tanks, or hopper-type vehicles with capacities in excess of 3,500 water gallons; or in bulk Division 1.1, 1.2, and 1.3 materials, Division 2.3, Hazard Zone A, or Division 6.1, Packing Group I, Hazard Zone A material; in bulk Division 2.1 or 2.2; or highway route controlled quantities of a Class 7 material, as defined in 49 CFR 173.403.

$5,000,000

(3) For-hire and Private (in interstate or foreign commerce, in any quantity; or in intrastate commerce, in bulk only; with a gross vehicle weight rating of 10,000 or more pounds).

Oil listed in 49 CFR 172.101; hazardous waste, hazardous materials, and hazardous substances defined in 49 CFR 171.8 and listed in 49 CFR 172.101, but not mentioned in (2) above or (4) below.

$1,000,000

(4) For-hire and Private (In interstate or foreign commerce, with a gross vehicle weight rating of less than 10,000 pounds).

Any quantity of Division 1.1, 1.2, or 1.3 material; any quantity of a Division 2.3, Hazard Zone A, or Division 6.1, Packing Group I, Hazard Zone A material; or highway route controlled quantities of a Class 7 material as defined in 49 CFR 173.403

$5,000,000

*The schedule of limits shown does not provide coverage. The limits shown in the schedule are for information purposes only.

SCHEDULE OF LIMITS — PUBLIC LIABILITY

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PERMITTED HAZARDOUS WASTE CODES

Envirite of Pennsylvania, Inc. PAD 010 154 045

CHARACTERISTIC WASTE D001 A D005 A D009 A D013 A D017 A D021 A D025 A D029 A D033 A D037 A D041 A D002 A D006 A D010 A D014 A D018 A D022 A D026 A D030 A D034 A D038 A D042 A D003 A D007 A D011 A D015 A D019 A D023 A D027 A D031 A D035 A D039 A D043 A D004 A D008 A D012 A D016 A D020 A D024 A D028 A D032 A D036 A D040 A

HAZARDOUS WASTE FROM NON-SPECIFIC SOURCES F001 A F004 A F007 A F010 A F019 A F022 D F025 A F028 D F035 A F039 A F002 A F005 A F008 A F011 A F020 D F023 D F026 D F032 A F037 A F003 A F006 A F009 A F012 A F021 D F024 A F027 D F034 A F038 A

HAZARDOUS WASTE FROM SPECIFIC SOURCES K001 A K017 A K032 A K047 D K086 A K105 A K124 A K150 A K178 A K002 A K018 A K033 A K048 A K087 A K106 A K125 A K151 A K181 A K003 A K019 A K034 A K049 A K088 A K107 A K126 A K156 A K004 A K020 A K035 A K050 A K093 A K108 A K131 A K157 A K005 A K021 A K036 A K051 A K094 A K109 A K132 A K158 A K006 A K022 A K037 A K052 A K095 A K110 A K136 A K159 A K007 A K023 A K038 A K060 A K096 A K111 A K141 A K161 B K008 A K024 A K039 A K061 A K097 A K112 A K142 A K169 A K009 A K025 A K040 A K062 A K098 A K113 A K143 A K170 A K010 A K026 A K041 A K069 A K099 A K114 A K144 A K171 A K011 B K027 B K042 A K071 A K100 A K115 A K145 A K172 A K013 B K028 A K043 A K073 A K101 A K116 A K174 A K014 A K029 A K044 B K083 A K102 A K117 A K147 A K175 A K015 A K030 A K045 B K084 A K103 A K118 A K148 A K176 A K016 A K031 A K046 A K085 A K104 A K123 A K149 A K177 A

DISCARDED COMMERCIAL CHEMICAL PRODUCTS, OFF-SPECIFICATION SPECIES, CONTAINER RESIDUE AND SPILL RESIDUES THEREOF

P001 B P012 B P024 B P038 B P049 B P060 B P071 B P085 B P099 B P112 D P127 B P198 B P002 B P013 B P026 B P039 B P050 B P072 B P087 B P101 B P113 B P128 B P199 B P003 B P014 B P027 B P040 B P051 B P062 B P073 B P088 B P102 B P114 B P185 B P201 B

p P004 B P015 B P028 B P041 B P063 D P074 B P089 B P103 B P115 B P188 B P202 B P005 B P016 B P029 B P042 D P064 B P075 B P092 D P104 B P116 B P189 B P203 B P006 C,D P017 B P030 B P043 B P054 B P065 C,D P076 B P093 B P105 B P118 B P190 B P204 B P007 B P018 B P031 B P044 B P066 B P077 B P094 B P106 B P119 B P191 B P205 B P008 B P020 B P033 B P045 B P056 B P067 B P078 B P095 B P108 B P120 B P192 B P009 D P021 B P034 B

P046 B P057 B P068 B P081 D P096 B P109 B P121 B P194 B

P010 B P022 B P036 B P047 B P058 B P069 B P082 B P097 B P110 B P122 D P196 B P011 B P023 B P037 B P048 B P059 B P070 B P084 B P098 B P111 B P123 B P197 B

U001 A U024 A U047 A U071A U093 A U117 A U140 A U162 A U185 A U210 A U239 A U395 A U002 A U025 A U048 A U072 A U094 A U118 A U141 A U163 A U186 A U211 A U240 A U404 A U003 A U026 A U049 A U073 A U095 A U119 A U142 A U164 A U187 A U213 A U243 A U409 A U004 A U027 A U050 A U074 A U096 C,D U120 A U143 A U165 A U188 A U214 A U244 A U410 A U005 A U028 A U051 A U075 A U097 A U121 A U144 A U166 A U189 C,D U215 A U246 A U411 A U006 C,D U029 A U052 A U076 A U098 A U122 A U145 A U167 A U190 A U216 A U247 A U007 A U030 A U053 A U077 A U099 A U123 A U146 A U168 A U191 A U217 A U248 A U008 A U031 A U055 A U078 A U101 A U124 A U147 A U169 A U192 A U218 A U249 A U009 A U032 A U056 A U079 A U102 A U125 A U148 A U170 A U193 A U219 A U271 A U010 A U033 A U057 A U080 A U103 A U126 A U149 A U171 A U194 A U220 A U278 A U011 A U034 A U058 A U081 A U105 A U127 A U150 A U172 A U196 A U221 A U279 A U012 A U035 A U059 A U082 A U106 A U128 A U151 A U173 A U197 A U222 A U280 A U014 A U036 A U060 A U083 A U107 A U129 A U152 A U174 A U200 A U223 C,D U328 A U015 A U037 A U061A U084 A U108 A U130 A U153 A U176 A U201 A U225 A U353 A U016 A U038 A U062A U085 A U109 A U131 A U154 A U177 A U226 A U359 A U017 A U039 A U063 A U086 A U110 A U132 A U155 A U178 A U203 A U227 A U364 A U018 A U041 A U064 A U087 A U111 A U133 C,D U156 A U179 A U204 A U228 A U367 A U019 A U042 A U066 A U088 A U112 A U134 A U157A U180 A U205 C,D U234 D U372 A U020 C,D U043 A U067 A U089 A U113 A U135 A U158 A U181 A U206 A U235 A U373 A U021 C,D U044 A U068 A U090 A U114 A U136 A U159 A U182 A U207 A U236 A U387 A U022 A U045 A U069 A U091 A U115 A U137 A U160 C,D U183 A U208 A U237 A U389 A U023 A U046 A U070 A U092 A U116 A U138 A U161 A U184 A U209 A U238 A U394 A

Container Category: A No restrictions on storage or handling B Restricted to storage only C Restricted to lab pack quantities D Restricted to mixture/derived from waste or spill cleanups E Restricted to reshipment only – no storage or repacking

US Ecology - York August 2016

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Certificate of RegistrationThis certifies that the Occupational Health and Safety Management System of

US Ecology York730 Vogelsong Road

York, Pennsylvania, 17404, United States

has been assessed by NSF-ISR and found to be in conformance to the following standard(s):

OHSAS 18001:2007

Scope of Registration:Provider of hazardous and non-hazardous waste management services including recycling, treatment, storage, disposal, and transportation.

Carl Blazik,Director, Technical Operations & Business Units, NSF-ISR, Ltd.

Certificate Number: 6S202-OH9-C0066982

Certificate Issue Date: 01-JUN-2018Registration Date: 08-MAY-2018

Expiration Date *: 11-MAR-2021

Certificate of RegistrationThis certifies that the Environmental Management System of

US Ecology York730 Vogelsong Road

York, Pennsylvania, 17404, United States

has been assessed by NSF-ISR and found to be in conformance to the following standard(s):

ISO 14001:2015

Scope of Registration:Provider of hazardous and non-hazardous waste management services including recycling, treatment, storage, disposal, and transportation

Carl Blazik,Director, Technical Operations & Business Units, NSF-ISR, Ltd.

Certificate Number: 6S202-EM1-C0066982

Certificate Issue Date: 01-JUN-2018Registration Date: 08-MAY-2018

Expiration Date *: 07-MAY-2021

Certificate of RegistrationThis certifies that the Quality Management System of

US Ecology York730 Vogelsong Road

York, Pennsylvania, 17404, United States

has been assessed by NSF-ISR and found to be in conformance to the following standard(s):

ISO 9001:2015

Scope of Registration:Provider of hazardous and non-hazardous waste management servicesincluding recycling, treatment, storage, disposal, and transportation.

Carl Blazik,Director, Technical Operations & Business Units, NSF-ISR, Ltd.

Certificate Number: 6S202-IS11-C0066982

Certificate Issue Date: 01-JUN-2018Registration Date: 08-MAY-2018

Expiration Date *: 07-MAY-2021

UNITED STATES OF AMERICADEPARTMENT OF TRANSPORTATIONPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION

HAZARDOUS MATERIALSCERTIFICATE OF REGISTRATIONFOR REGISTRATION YEAR(S) 2018-2020

Registrant: ENVIRITE OF PENNSYLVANIA INC

ATTN: STEFANIEANA M. HERSH730 VOGELSONG ROADYORK, PA 17404

This certifies that the registrant is registered with the U.S. Department of Transportation as required by

49 CFR Part 107, Subpart G.

This certificate is issued under the authority of 49 U.S.C. 5108. It is unlawful to alter or falsify this

document.

Reg. No: 061418550049AB Effective: July 1, 2018 Expires: June 30, 2020

HM Company ID: 32747

Record Keeping Requirements for the Registration Program

The following must be maintained at the principal place of business for a period of three years from the

date of issuance of this Certificate of Registration:

(1) A copy of the registration statement filed with PHMSA; and

(2) This Certificate of Registration

Each person subject to the registration requirement must furnish that person's Certificate of Registration

(or a copy) and all other records and information pertaining to the information contained in the

registration statement to an authorized representative or special agent of the U. S. Department of

Transportation upon request.

Each motor carrier (private or for-hire) and each vessel operator subject to the registration requirement

must keep a copy of the current Certificate of Registration or another document bearing the registration

number identified as the "U.S. DOT Hazmat Reg. No." in each truck and truck tractor or vessel (trailers

and semi-trailers not included) used to transport hazardous materials subject to the registration

requirement. The Certificate of Registration or document bearing the registration number must be made

available, upon request, to enforcement personnel.

For information, contact the Hazardous Materials Registration Manager, PHH-52, Pipeline and

Hazardous Materials Safety Administration, U.S. Department of Transportation, 1200 New Jersey

Avenue, SE, Washington, DC 20590, telephone (202) 366-4109.

PERMITTED HAZARDOUS WASTE CODES

Envirite of Pennsylvania, Inc. PAD 010 154 045

CHARACTERISTIC WASTE D001 A D005 A D009 A D013 A D017 A D021 A D025 A D029 A D033 A D037 A D041 A D002 A D006 A D010 A D014 A D018 A D022 A D026 A D030 A D034 A D038 A D042 A D003 A D007 A D011 A D015 A D019 A D023 A D027 A D031 A D035 A D039 A D043 A D004 A D008 A D012 A D016 A D020 A D024 A D028 A D032 A D036 A D040 A

HAZARDOUS WASTE FROM NON-SPECIFIC SOURCES F001 A F004 A F007 A F010 A F019 A F022 D F025 A F028 D F035 A F039 A F002 A F005 A F008 A F011 A F020 D F023 D F026 D F032 A F037 A F003 A F006 A F009 A F012 A F021 D F024 A F027 D F034 A F038 A

HAZARDOUS WASTE FROM SPECIFIC SOURCES K001 A K017 A K032 A K047 D K086 A K105 A K124 A K150 A K178 A K002 A K018 A K033 A K048 A K087 A K106 A K125 A K151 A K181 A K003 A K019 A K034 A K049 A K088 A K107 A K126 A K156 A K004 A K020 A K035 A K050 A K093 A K108 A K131 A K157 A K005 A K021 A K036 A K051 A K094 A K109 A K132 A K158 A K006 A K022 A K037 A K052 A K095 A K110 A K136 A K159 A K007 A K023 A K038 A K060 A K096 A K111 A K141 A K161 B K008 A K024 A K039 A K061 A K097 A K112 A K142 A K169 A K009 A K025 A K040 A K062 A K098 A K113 A K143 A K170 A K010 A K026 A K041 A K069 A K099 A K114 A K144 A K171 A K011 B K027 B K042 A K071 A K100 A K115 A K145 A K172 A K013 B K028 A K043 A K073 A K101 A K116 A K174 A K014 A K029 A K044 B K083 A K102 A K117 A K147 A K175 A K015 A K030 A K045 B K084 A K103 A K118 A K148 A K176 A K016 A K031 A K046 A K085 A K104 A K123 A K149 A K177 A

DISCARDED COMMERCIAL CHEMICAL PRODUCTS, OFF-SPECIFICATION SPECIES, CONTAINER RESIDUE AND SPILL RESIDUES THEREOF

P001 B P012 B P024 B P038 B P049 B P060 B P071 B P085 B P099 B P112 D P127 B P198 B P002 B P013 B P026 B P039 B P050 B P072 B P087 B P101 B P113 B P128 B P199 B P003 B P014 B P027 B P040 B P051 B P062 B P073 B P088 B P102 B P114 B P185 B P201 B

p P004 B P015 B P028 B P041 B P063 D P074 B P089 B P103 B P115 B P188 B P202 B P005 B P016 B P029 B P042 D P064 B P075 B P092 D P104 B P116 B P189 B P203 B P006 C,D P017 B P030 B P043 B P054 B P065 C,D P076 B P093 B P105 B P118 B P190 B P204 B P007 B P018 B P031 B P044 B P066 B P077 B P094 B P106 B P119 B P191 B P205 B P008 B P020 B P033 B P045 B P056 B P067 B P078 B P095 B P108 B P120 B P192 B P009 D P021 B P034 B

P046 B P057 B P068 B P081 D P096 B P109 B P121 B P194 B

P010 B P022 B P036 B P047 B P058 B P069 B P082 B P097 B P110 B P122 D P196 B P011 B P023 B P037 B P048 B P059 B P070 B P084 B P098 B P111 B P123 B P197 B

U001 A U024 A U047 A U071A U093 A U117 A U140 A U162 A U185 A U210 A U239 A U395 A U002 A U025 A U048 A U072 A U094 A U118 A U141 A U163 A U186 A U211 A U240 A U404 A U003 A U026 A U049 A U073 A U095 A U119 A U142 A U164 A U187 A U213 A U243 A U409 A U004 A U027 A U050 A U074 A U096 C,D U120 A U143 A U165 A U188 A U214 A U244 A U410 A U005 A U028 A U051 A U075 A U097 A U121 A U144 A U166 A U189 C,D U215 A U246 A U411 A U006 C,D U029 A U052 A U076 A U098 A U122 A U145 A U167 A U190 A U216 A U247 A U007 A U030 A U053 A U077 A U099 A U123 A U146 A U168 A U191 A U217 A U248 A U008 A U031 A U055 A U078 A U101 A U124 A U147 A U169 A U192 A U218 A U249 A U009 A U032 A U056 A U079 A U102 A U125 A U148 A U170 A U193 A U219 A U271 A U010 A U033 A U057 A U080 A U103 A U126 A U149 A U171 A U194 A U220 A U278 A U011 A U034 A U058 A U081 A U105 A U127 A U150 A U172 A U196 A U221 A U279 A U012 A U035 A U059 A U082 A U106 A U128 A U151 A U173 A U197 A U222 A U280 A U014 A U036 A U060 A U083 A U107 A U129 A U152 A U174 A U200 A U223 C,D U328 A U015 A U037 A U061A U084 A U108 A U130 A U153 A U176 A U201 A U225 A U353 A U016 A U038 A U062A U085 A U109 A U131 A U154 A U177 A U226 A U359 A U017 A U039 A U063 A U086 A U110 A U132 A U155 A U178 A U203 A U227 A U364 A U018 A U041 A U064 A U087 A U111 A U133 C,D U156 A U179 A U204 A U228 A U367 A U019 A U042 A U066 A U088 A U112 A U134 A U157A U180 A U205 C,D U234 D U372 A U020 C,D U043 A U067 A U089 A U113 A U135 A U158 A U181 A U206 A U235 A U373 A U021 C,D U044 A U068 A U090 A U114 A U136 A U159 A U182 A U207 A U236 A U387 A U022 A U045 A U069 A U091 A U115 A U137 A U160 C,D U183 A U208 A U237 A U389 A U023 A U046 A U070 A U092 A U116 A U138 A U161 A U184 A U209 A U238 A U394 A

Container Category: A No restrictions on storage or handling B Restricted to storage only C Restricted to lab pack quantities D Restricted to mixture/derived from waste or spill cleanups E Restricted to reshipment only – no storage or repacking

US Ecology - York August 2016

L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

VEOLIA, MIDDLESEX, NEW JERSEY

1

Business & Environmental Audit InformationVeolia North America - Middlesex, NJ

125 Factory Lane, Middlesex, NJ 08846

www.veolianorthamerica.com 732-469-5100

2

Table of Contents• Why Work with Veolia Page 3

• Veolia’s Worldwide Areas of Expertise Page 4

• Corporate Information Page 5

• General Facility Information Page 6 - 7

• Facility Permits Page 8 - 9

• Waste Types Page 10

• Waste Analysis Page 11

• Waste Handling Page 11 - 15

• Water Management Page 15 - 16

• Transportation Practices Page 16

• Safety Page 17

• Preparedness & Prevention Page 18

• Compliance Management Programs Page 19

• Incident History Page 20

• Financial/Insurance Information Page 21

• Attachments Page 22 - 56

3

Why Work with Veolia?

Managing Hazardous and Nonhazardous Waste When you manage multiple environmental responsibilities, including hazardous and its associated liability, you must rely on the capabilities and expertise of your service provider. Veolia stands alone in meeting the criteria you use to determine the most viable environmental service partner.

Environmental ComplianceVeolia maintains an excellent record of compliance with environmental regulations. This record is ready for inspection at any time. We follow procedures meticulously with our on-site teams, and continue to focus on the details throughout transportation, treatment and disposal. Our waste processing, storage and disposal locations are routinely audited and certified, and all disposal documentation is verified to assure compliance.

Financial StrengthVeolia is the international leader in providing environmental services for waste, water, and energy. With over $29 billion in revenue, it is the largest environmental services company in the world.

Technical ExpertiseOur account, project and technical representatives understand hazardous and nonhazardous waste and the related regulatory requirements. Over 1,750 Veolia employees are ready to assist you in any way - from providing information about government regulations and answering technical questions regarding treatment alternatives, to training your employees and setting up disposal programs that save you time and money.

4

Veolia’s Worldwide Areas of ExpertiseVeolia designs and implements water, waste and energy management solutions. Together, these three complementary business activities work together to create synergies. We are a partner to cities, for which we are reinventing our approach to traditional markets and to industry, by providing customized solutions covering all requirements, whatever the business sector.

WATERVeolia treats and monitors water quality at all stages of the cycle, from extraction to discharge into the natural environment. We innovate to preserve the resource and promote water recycling and reuse for cities and industry.

96million people supplied with drinking water

62million people connected to

wastewater systems

4,117water production plants managed

2,878wastewater

treatment plants managed

WASTEVeolia specializes in waste management, regardless of whether it is liquid or solid, non-hazardous or special. Our expertise covers the entire waste lifecycle, from collection to recycling and final recovery in the form of materials or energy.

40million people provided with

collection services on behalf of

municipalities

47million metric tons of

waste treated

737,977business customers

ENERGYAn expert in energy services, Veolia supports the economic growth of its municipal and industrial customers while reducing their ecological footprint. Energy efficiency, efficient management of heating and cooling networks, production of green energy - unique expertise for a more sustainable world.

45million MWh

produced

40,210thermal installations

managed

2,291industrial sites

managed

595heating and cooling networks managed

579waste-processing facilities operated

5

Corporate Information

Parent Company Name Veolia North America

Corporate Headquarters53 State Street, 14th FloorBoston, MA 02109Tel.: +1 617 849 6600

National Locations• TSD Facilities: Flanders, NJ/Creedmoor, NC/Richmond, CA/Menomonee Falls, WI/Phoenix, AZ/Morrow,

GA/Tallahassee, FL

• TSDF Fuels Facilities: Middlesex, NJ/Azusa, CA/Henderson, CO/W. Carrollton, OH

• TSDF Incinerator Facilities: Sauget, IL/Port Arthur, TX

• Other Locations: Veolia also operates numerous in-transit storage locations and sales/service offices throughout the country.

Year Company was Established

2007 (May 2007 purchase of Marisol Inc.)

Federal Identification Number36-4287998

Dunn and Bradstreet Number 08-218-4156

Veolia Audit ContactsJohn Schantz New Jersey Branch Environmental, Health, & Safety Manager973-691-3923

Kevin Anderson New Jersey BranchGeneral Manager973-691-3922

6

General Facility Information

Site HistoryThis Veolia facility was founded in 1962 as Marisol Incorporated. In May 2007; Marisol was acquired by Veolia Environmental Services now Veolia North America.

Facility NameVeolia ES Technical Solutions, L.L.C.

Address 125 Factory Lane, Middlesex, NJ 08846

732-469-5100

Branch Management Kevin Anderson, General Manager Michael Pikulin, Facility Manager John Schantz, EH&S ManagerRobert Romano, PSM Coordinator Rodney Reynolds, Operations SupervisorMichael Connolly, EHS Supervisor

Property Ownership Status The site is owned by Veolia North America (purchased in May 2007 from Marisol Inc.)

EPA ID NumberNJD 002 454 544

SIC/NAICS Code4953/562211

Property Size 3.886 Acres (all currently active)

Facility Layout See Attachment #1

Hours of Operation24-Hours (365 days a year)

Number of Employees Approximately 55 at this location

7

Surrounding Area DescriptionThis Veolia facility is located near River Road, approximately 1.6 miles North of Interstate Route 287. The area is primarily industrial and is bordered by Conrail to the North and South, and Reagent Chemical to the East and West.

Proximity toResidences: ¼ mile - NorthIndustrial Buildings: 100 feetSchools: 2 milesParks: 2 milesHospitals: 5 miles – Somerset HospitalFire Dept. ¼ mile – Middlesex FirePotable Wells: 4-5 miles to the NorthFlood Plain: The facility is outside the “100 year flood zone”Rivers: ½ mile – Raritan River

SecurityA six-foot chain link fence equipped with barbed wire on the top surrounds the site. Surveillance cameras are located throughout the plant. There are “Danger - Unauthorized Personnel - Keep Out” signs posted at each facility entrance. There is no history of problems with unauthorized entry or vandalism.

Site TopographyA USGS topographic map is available for review. The topography is generally flat with an elevation of approximately 55 feet above sea level.

Population within 1 mile and 3 miles of the siteThe facility is located in the Borough of Middlesex, which has a population of approximately 14,000. The facility is located in Middlesex County, New Jersey, which has a population of approximately 600,000 and a population density of 1,800 inhabitants per square mile.

The nearest Towns/Cities of interest include:• Bound Brook – Population 9,600• New Brunswick – Population 56,000• East Brunswick – Population 47,000• Piscataway – Population 51,000

Wind RoseWinds are predominately from the Southwest at a mean speed of 10.2 mph.

Community RelationsVeolia maintains excellent relations with neighbors, local agencies and the surrounding community. Veolia participates and assists with several local organizations. A summary of the local Community Relations Policy can be found in Attachment #9.

8

Facility Permits

RCRA Part A (EPA ID # NJD 002 454 544)The initial application was submitted and approved under Marisol Incorporated. In May 2007, the ownership was changed to Veolia Environmental Services, and in January 2008 the name was changed to Veolia ES Technical Solutions, L.L.C.

RCRA Part B applicationThe current permit is HWP150001 (Issuance Date: 09/30/2014; Expiration Date: 10/30/2019). A copy of current Part B Permit cover page is in Attachment #2.

TSCA Waste StorageVeolia Middlesex facility is approved as a commercial storer of TSCA waste (PCBs) pursuant to 40 CFR s761.65(d); however, the site does not actively receive and store PCBs.

CERCLA Waste AcceptanceVeolia is authorized to accept CERCLA regulated waste streams for treatment, or storage and transfer to other CERCLA authorized treatment and disposal facilities.

Acceptability of Non-hazardous Waste for StorageVeolia has been issued a permit to accept both hazardous and non-hazardous “solid” waste. Non-hazardous wastes are not required to be on a hazardous waste manifest. For tracking purposes Veolia requires the use of either a hazardous waste manifest or a non-hazardous manifest for receiving non-hazardous wastes.

New Jersey Solid Waste Codes:ID10 – Household Hazardous WasteID27 – Dry Industrial Waste solidsID27A – AsbestosID27I – Incinerator AshID72 – Non-hazardous Liquid and Semiliquids

Maximum Capacity of the FacilityThe total hazardous waste storage capacity is limited to a maximum of 557,000 gallons in containers and 741,200 gallons in tanks, receivers and stills. Container storage is limited to: 72,000 gallons in tank wagons, 210,000 gallons in rail cars, and 275,000 in other containers up to 6,000 gallon capacity. Container stacking is limited to three 55-gallon drums.

Water permitsVeolia discharges site storm water outside containment under NJPDES General Permit No. NJ0088315, NJPDES#: NJG0127477. This permit presently requires no discharge monitoring. Storm water inside permitted containment is discharged to the POTW (Middlesex County Utilities Authority) under Permit No. 11064 (Expires September 30, 2021). Copies of these permits are in Attachment #3.

9

Discharge Prevention Containment and Countermeasure/Discharge Cleanup & Removal Plan (DPCC/DCR)Veolia has an approved DPCC/DCR plan (DIFF# 121100235000). The plan was renewed effective January 26, 2014 and expires on January 26, 2017. A copy of the current approval letter is in Attachment #4. An application for renewal was submitted and is being reviewed by NJDEP.

Air PermitsThe facility operates five separate Air Pollution Control Permits under Plant ID# 15436:

Storage Tanks PCP140001 Expires: 05/04/2019Boiler Unit PCP100001 Expires: 10/30/2023

Distillation Units/Stills PCP150001 Expires: 06/21/2019Air Stripper A & B PCP100002 Expires: 04/10/2022Paint Can Crusher PCP170001 Expires: 04/30/2022

Inspections/Frequency/ContactAgency Frequency Contact Phone #

NJDEP-Compliance Weekly Tiffany Chiles (609) 439-6405NJDEP – Trans Quarterly Lawrence Lewis (609) 209-1762

NJDEP – Air Annually Kevin Eichman (609) 292-3187NJDEP – Water Annually Anthony Rotondo (609) 584-4200MCUA – Water Annually Richard Bartz (732) 593-2536

EPA-Region II Annually John Wilk (212) 637-4130NJDEP-DPCC Annually Sunday Ogunsola (609) 633-0610

Middlesex Fire Annually Jim Rinker (732) 735-4356

A copy of the most recent NJDEP inspection is available on request or on the NJDEP website. The facility is in compliance with all permit conditions.

10

Waste Types

Waste Types Handled at the Facility• Bulk: Liquid, Solid, Sludge • Containerized: Liquid, Solid, Sludge, Gas

Waste Characteristics Handled at the Facility• Corrosive, Ignitable, Toxic, Reactive • Radioactive waste is not handled at this facility

Types of Hazardous Materials Handled: (All RCRA codes are acceptable)

Chemicals Yes No CommentsOrganics YesOils YesHalogenated Solvents YesNon-halogenated Solvents YesInsecticides YesHerbicides YesChlorinated Hydrocarbons YesPhenols YesPCBs YesPaint, Pigments YesExplosives No*Cyanides YesWater Reactives YesInorganics:• Acids Yes• Bases Yes• Metals YesSludges:• Metal Yes• Sewage NoRadioactive No*Asbestos YesPharmaceutical YesPathological No*Lab Packs Yes

*Currently Veolia manages the following waste types: Explosive, Radioactive and Regulated Medical Waste (RMW), through direct transportation of these materials from the customer’s location to the ultimate waste management facility.

11

Waste Analysis

Waste IdentificationVeolia requires a Waste Information Profile (WIP) (Attachment #5) be completed and certified by the generator prior to waste shipment to the facility. The information regarding waste identification can be from generator knowledge or chemical analysis.Based on the information provided in the WIP, the wastestream is assigned a DOT proper shipping name, EPA or state waste codes, and an ultimate treatment facility approval code. The WIP is wastestream and generator specific and a unique WIP number is assigned to each wastestream.If the generator cannot accurately complete the WIP, a sample of the waste will be taken at the generator’s facility.The approval for the management of waste streams must be obtained prior to acceptance of the waste stream at the Middlesex Veolia facility.

Written Waste Analysis PlanThe Waste Analysis Plan (WAP) was developed in accordance with 40 CFR s264.13(b) and will be available at the facility at all times. The WAP will be reviewed regularly to ensure compliance with all regulatory standards and standard operating procedures.A copy of the Waste Analysis Plan (WAP) from the facility Part B Permit is included in Attachment #6.The objective of the WAP is to ensure proper classification, transportation and storage of the specific waste, as well as safe handling at both Veolia and the ultimate disposal facility. The WAP is designed to perform all waste identification, sampling and analysis at the generator’s site prior to transportation and acceptance by the Veolia facility.

Waste HandlingThis section covers Veolia’s: process units, storage tanks, container storage, loading and unloading areas, rail siding, and the secondary and tertiary containment units. Process methods include: container transfer, distillation, fuel processing, water treatment and solids consolidation.

1. Loading/Unloading AreasA. Containers (Bulk & Drums)B. Tank WagonsC. Rail Cars

2. Storage AreasA. Containers

1. Areas for Container Storage2. Drum Processing3. Tank wagons and Rail cars

B. Tanks1. Tank Design and Information2. Tank Operations

3. Process MethodsA. Transfer Operations

12

B. DistillationC. Fuel ProcessingD. Water TreatmentE. Solid Consolidation

1. Loading and Unloading Areas

A. ContainersContainers refer primarily to 55-gallon DOT approved drums, however, this may also include, but are not limited to, 85-gallon overpacks, approved totes, drums smaller than 55 gallons, and other DOT approved containers. Upon arrival at Veolia, all applicable paperwork is reviewed and inspected for completion, accuracy, and regulatory compliance.All containers are unloaded, providing space for the Laboratory Technician to inspect and sample. The primary unloading areas are referred to as “staging areas” and are considered a temporary location. Once containers are sampled the “finger print” analysis is completed, the containers are appropriately marked and labeled according to process code. Drums are then stacked using a forklift vehicle and other containers are staged in process areas as needed.Any drums or other containers found to be leaking or in poor condition are either put into an overpack drum or transferred to a secure drum. All transfers of either product or waste are completed within the facility containment area utilizing the same procedure to unload and load.

B. Tank WagonsAll tank wagons enter through the southwest gate and are weighed on the scale both full and empty. Paperwork is reviewed for accuracy, completion, and regulatory compliance. After this review is completed, the tank wagon is brought into the facility containment area. All sampling is done within this area.Once a sample is taken it is sent to the lab for analysis and approval to unload. The Chemical Operator gauges the tank wagon to confirm its volume, which is then noted on the receiving ticket. The gauged volume is compared to the manifested and weighed volume to verify accuracy.After approval by the laboratory, the Chemical Operator or driver will move the tank wagon to the designated unloading location. The material is unloaded into either the 100 Tank Farm, 200 Tank Farm, 300 Tank Farm, or 400 Tank Farm/Process Area. The material may also be unloaded into another tank wagon or a rail car located within the containment area.

C. Rail CarsThe facility rail siding is completely contained within the facility containment area. The concrete is pitched into the containment area. The actual rails are level but the rail supports are of varying thickness to account for the pitched concrete. Therefore, this rail siding is merely an extension of the facility containment.The same procedure for loading and unloading tank wagons is used for loading and unloading railcars. The exceptions to this are that the rail car is not weighed “in” or “out” and that sampling, staging and unloading are all done in the same area. The material is transferred through pumps and flexible hoses connecting the cars to off-loading tanks. The rail cars are currently leased from GATX and moved by Conrail.

2. Storage Areas

A. ContainersContainers primarily refer to 55-gallon steel drums. However, this may also include, but are not limited

13

to, 85-gallon overpacks, totes, and drums smaller than 55 gallons, and other DOT approved containers.

1. Areas for Container StorageAfter sampling and preliminary evaluation, drums are sorted by “S” code and stacked in appropriate drum storage areas. Veolia stores all drums within the facility containment area. The maximum drum storage capacity for Hazardous Waste is 275,000 gallons or 5,000 (55-gallon) drums. Drums are stacked no more than three (3) high.Drums are stacked in rows that are at a minimum of 30” apart. The facility classification code is visible on all drums from within the drum rows. Drums containing flammable and or reactive material are stored beyond 50’ from the property fence line.

2. Drum ProcessingAll approved drums are sorted and stacked according to their classification code. The Production Planner, based upon the analytical results from the laboratory, schedules drums to be pumped. The Planner completes an Operation Report and enters it on the appropriate shift’s work list. The Lab Supervisor and Operations Manager review the work list and all Operation Reports. This is then forwarded to the Shift Supervisor who assigns the work to the Chemical Operators.The drums are then moved from the storage area to the processing area closest to the receiving tank. Only spark-proof equipment is used during this and the proceeding processes. The Operator gauges the receiving tank prior to pumping any material to the receiving tank and documents the amount of material on the Operation Report. The drum bung is removed using a bung wrench. The drum is pumped to less than 1” of material. The facility utilizes stationary and portable pumps. All drums are tipped to remove any remaining material. Once the drum is empty, it is sent off-site for recycling.

3. Tank Wagons and Rail CarsAny loaded tank wagons are kept in the containment area until emptied. The tank wagon storage locations and truck parking area (the truck parking area is for tractors and empty trailers) are noted on the Facility Layout (Attachment#1). Trucks and drums are segregated within individual storage areas. Tank wagons with material are inspected daily.The rail siding has a maximum volume capacity of 180,000 gallons. Rail cars follow the same procedure as tank wagons, as explained above. All vehicles with Hazardous Waste for more than 24 hours will constitute storage and will count toward the existing permitted facility storage capacity.

B. Tanks

1. Tank Design and InformationThe storage tanks located in the 100, 200, and 300 Tank Farms are anchored to 12” thick concrete bases and are within four feet high secondary containment dikes. The storage tanks within the process area and the 400 Tank Farm are also anchored to a concrete base and within a 6” high secondary containment curb. In the center of the process area is a trench leading to a sump approximately 3 feet by 7 feet and 6 feet deep. There are no underground storage tanks. All storage tanks are constructed of carbon steel. The receivers are constructed of either stainless or carbon steel.Containment/spill volumes of all tank farms exceed legal requirements. Veolia conducts three daily informal inspections of all tanks, one by each of the three Shift Supervisors, and one documented daily inspection by the Operations Manager. Veolia also has a tank integrity plan for measuring tank thickness.

2. Tank OperationsVeolia’s tanks are utilized for storage of crude material, processed material, in-process material,

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and for fuel processing. Inventory levels of each tank to be loaded or unloaded are gauged prior to loading or unloading. The specific level and volume are noted on the receiving ticket or operations report. After loading or unloading is complete, the tank is again gauged and the level and volume recorded. The volume of material from the source of the incoming material is also calculated.If the source is from a tank wagon, the tank wagon is gauged. If the source is from drums, the number of drums is specified on the Operations Report and verified by the Chemical Operator. Source volumes are also recorded on the receiving ticket or operations report. The gauging of both the tank and source/recipient of material provides a double check to verify accuracy.

3. Process Methods

A. Transfer OperationsVeolia utilizes a number of off-site facilities for treatment of waste including recycling, wastewater treatment, fuel blending, incineration, and landfill. Veolia can provide assistance to the generator in this selection.A partial list of authorized treatment facilities approved by Veolia is included in Attachment #7.

B. DistillationVeolia utilizes various forms of distillation to extract solvents that can be sold as products. Spent material is received and sampled per the Waste Analysis Plan. The Laboratory determines which drums are to be consolidated based upon distillation ranges, gas chromatography results, and various other analytical results. Based upon schedules, current volumes in-house, projected receipts and sales, and various other factors, specific solvents are consolidated and distilled. The Planner schedules processing operations and the Laboratory Supervisor and Operations Manager review the schedules.The Chemical Operator follows the instructions on the Operation Report and still run sheet and records appropriate information (i.e., boiling point, temperatures at various stages, etc.) and samples as required. The material to be pumped into the still is from either: drum(s), tank(s), tank car(s), or tank wagon(s). After the still run is completed, the paperwork is forwarded and samples sent to the Laboratory for analysis.

Types of distillation include:i. Simple Distillationii. Fractional Distillationiii. Thin Film Evaporation

C. Fuel ProcessingVeolia utilizes incoming material with BTU value in its Fuel Processing Program. The resulting fuel product is processed to meet the customers’ predetermined specifications. The current common specifications include some or all of the following: BTUs, Percent Chlorine, Percent Ash, Percent Moisture, PCBs, and various metals.Incoming drums and bulk tank wagons are tested as described in the Waste Analysis Plan. The Planner schedules which drums are to be pumped and where bulk material is to be unloaded. A work schedule with appropriate Receiving Ticket(s) and/or Operation Reports is prepared by the Planner and reviewed and approved by the Laboratory Supervisor and Operations Manager.Equipment utilized for fuels processing includes: Various sized stationary and portable gear and centrifugal pumps, Muffin Monster Ginders, strainers, Auger/Hydropulper.Once the material is processed and meets appropriate specifications, it is assigned an “M” code, signifying its process status as complete. The fuel product is shipped with a Hazardous Waste manifest to the customer. Veolia does not utilize any of this fuel on-site.

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D. Water TreatmentIncoming water for treatment is treated based on the level of contaminants. If a high level of solids exists, the water will be put into a storage or water treatment tank for settling. Removed sediment with heat valve would be processed in the fuel program.For water with solvent contamination the solvent would be removed through phase separation and/or distillation. Water with layered solvents would require separation through decanting of either the water or the solvent depending upon the Specific Gravity of the solvent. Water with a high level of non-layered solvents would require distillation.Water with a low level of non-layered solvents may be fuel blended or sent off-site for treatment and disposal.

E. Solid ConsolidationSolids are consolidated into either Hazardous or Non-Hazardous roll-off containers based on their RCRA classification. The Hazardous roll-offs are sent to a RCRA permitted facility for incineration. The Non-Hazardous roll-offs are sent to a waste- to-energy facility for incineration.

Waste Management

StormwaterThe entire production and storage area, which includes: 1) production storage tanks, 2) process equipment, 3) bulk storage tanks, 4) drum storage areas, and 5) loading and unloading areas; is bermed and constructed of eight inches of reinforced concrete. All material stored in any storage tank is impermeable to the secondary containment unit.The construction of the concrete bermed area is graded so that all liquid material would flow to two concrete 50-gallon stainless steel lined collection sumps. From the collection sumps, the storm water is transferred to tanks in the process area or directly into specifically designated rail cars. All storm water is tested prior to discharge into the POTW per Middlesex County Utilities Authority Permit 11064 (Attachment #3).The western end of the property is not contained and engages in “industrial activity” including the facility maintenance, and truck and tractor entry and exit. The storm water discharge from this area is a “Point Source Discharge” because this area is curbed, concreted, and pitched to collect and convey runoff to Factory Lane.A Stormwater Pollution Prevention Plan (SWPPP) was developed in accordance with the requirements for discharges of storm water associated with industrial activities under New Jersey Pollutant Discharge Elimination System (NJPDES) General Permit number NJ0088315 (Attachment# 3); approved by the New Jersey Department of Environmental Protection. This plan may be used in conjunction with Veolia’s approved Discharge Prevention Containment and Countermeasure/Discharge Cleanup and Removal Plan (DPCC/DCR) plan prepared under N.J.A.C. 7:1E. Both plans are located in the Environmental, Health and Safety Manager’s office and is available for reference and review.

GroundwaterGroundwater supplies in Middlesex County occur in unconsolidated deposits and in bedrock aquifers. The major groundwater reservoirs in the vicinity of the site consist of the Triassic sandstones and shales of the Brunswick Formation. This Formation is largely a fracture aquifer with an open structure that allows for little natural filtration and percolation of the water.Various groundwater studies, dating back to the early part of 1980, have confirmed that contamination with Volatile Organic Compounds (VOC) (primarily halogenated hydrocarbons) exists under the site and surrounding areas. The contamination is presumed to have been caused by heavy industrial usage over the past 50 years.

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The groundwater flow at the Veolia site is influenced by the pumping of an on-site production well. Prior to that pumping, natural groundwater flow was probably southward toward the Raritan River, (elevation about 20 feet), which is located about one-half mile to the southwest.Pumping of water from the production well has essentially been continuous since 1975 except for a nine-month interruption during 1980. This has significantly altered the potentiometric head throughout the site. The head has been lowered throughout the site and the slope of the potentiometric surface has been toward the production well during continuous pumping. Therefore, groundwater flow is from areas outside of Veolia property toward the production well.Veolia (formerly Marisol Inc) has been conducting a RCRA Facility Investigation (RFI) since the USEPA issued a HSWA Permit effective July 15, 2002. The first phase of the work, investigating soils and shallow groundwater at and near the facility, was completed at the end of 2004. The second phase of the work, investigating the deeper bedrock groundwater, was completed in 2007. While the RFI is not finished, the investigation of soils and groundwater underlying the facility containment found relatively high concentrations of volatile organic compounds (VOC’s), including Non-Aqueous Phase Liquids, that decrease markedly off the facility. Thus it appears these VOC’s in soil and groundwater are the result of operations conducted at the facility prior to construction of the concrete containment in 1981.The prime technical consulting contractor for the RFI is Princeton Geoscience, Inc. and the contact at PGI is James Peterson, P.G. (609-279-0008). Assisting PGI on various aspects of the project is Langan Engineering & Environmental and the contact there is Richard LoCastro, P.G. RFI progress reports are issued quarterly to USEPA and NJDEP. The costs of the RFI and any remediation are borne by insurance. To date, the RFI costs total approximately $3.5 million. The insurance coverage available for this project is over $50 million, which is considered more than adequate.

Transportation Practices

VehiclesVeolia is a primary provider of hazardous waste transportation services. Veolia New Jersey maintains approximately: 5 tractors, 15 tank trucks, 10 closed trailers, 17 straight trucks, 12 pick-ups, 6 vans and an air induction vehicle, at the Flanders and Middlesex locations.Veolia is permitted to transport waste in approximately 40 states.Additionally, Veolia uses subcontractors to supplement its fleet. Transporters are approved based on their permits, insurance, and compliance with the motor carrier safety regulations.

BrokerageVeolia, as a hazardous waste management company, has the capabilities to manifest waste directly from the client’s facility to the ultimate treatment facility. Approved subcontractors are frequently used for these shipments.

SecurityVeolia has developed and implemented a security plan compliant with the requirements of 49 CFR, Part 172, Subpart I. In addition, Veolia’s employee training program includes security awareness and in-depth security training as required by 49 CFR s172.704. A security plan certification letter is available on request.

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Safety

All accidents and incidents are recorded on an Accident/Incident Investigation Report Form and reviewed by the employee’s immediate supervisor, the Operations Manager, the Facility Manager and Site Safety Coordinator (Health & Safety Specialist).The person responsible for overall safety at the Middlesex, NJ location is John Schantz, Branch Environmental Health & Safety Manager. Additionally, Veolia has a full time Director of Safety and there is also has a full time EH&S Specialist located at this facility.

The following personnel are authorized to conduct accident investigations and job safety inspections:• General Manager • Facility Manager • Plant Engineer • Shift Supervisor • EHS Manager • EHS Specialist

Frequency of site safety inspections:The Shift Supervisor performs daily inspections of all: drum areas, tank areas, safety equipment and supplies, site security and containment.The EHS Specialist performs monthly inspections and testing of all safety and emergency equipment and supplies.

Safety MeetingsSafety and training meetings are conducted every two weeks for all plant personnel. Additionally, a Safety Committee meets every month to discuss and resolve safety issues.

TrainingAll plant operations personnel receive immediate site safety and emergency response training and certification. Additional off-site training to meet the OSHA 24-hour certification is completed and documented prior to working in the plant.Fork truck training and certification is completed internally.Additional training is completed throughout the year typically at the biweekly safety and training sessions. A summary of the training programs can be found in Attachment #10.

OSHA 200 forms are posted within the facility (copies available on request):

OSHA Injury Rates 2016 2017 2018Veolia Middlesex OSHA Recordable Rate: 3.61 3.61 3.59Veolia Middlesex OSHA Lost Time Accident Rate: 0.00 0.00 0.00Veolia Middlesex OSHA Severity Rate: 0.00 0.00 0.00

A copy of the 5-year OSHA 200 Log summary can be found in Attachment #11.

2018 EMR = 0.51

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Preparedness & Prevention

Written Contingency PlansThe facility maintains a Contingency Plan and Emergency Procedures as well as a Discharge Prevention Containment and Countermeasures plan approved by the NJDEP. Both plans are available for review upon request. Copies of the contingency plan have been distributed to local authorities in accordance with state and federal regulations.The facility has also completed a USDOT Security Plan and site vulnerability and risk assessment. All employees have been trained in security awareness and in-depth security training.

Emergency Response• Periodic emergency response drills, mock spills and fire drills are conducted at least annually.• The facility maintains adequate aisle space for equipment access in the event of an emergency; 30-

inch aisle space is required in waste storage areas, by the Part B Hazardous Waste Permit. Additionally, drums are stored no more than three high.

• The facility maintains an extensive inventory of emergency equipment. An equipment list is available (contained in the Contingency Plan). Emergency equipment and spill cleanup stations are placed throughout the facility.

• Fire extinguishers are placed strategically throughout the property. All operations personnel receive hands-on fire extinguisher training each year.

• The facility has a written inspection policy/procedure including a checklist of items to look for during inspections.

TrainingVeolia has an extensive internal training program including 24-hour OSHA RCRA Facility, Hazard Communication, Security, Reactive Chemical, Emergency Response, Confined Space Entry, DOT HM-126F, Lockout/Tagout, Bloodborne Pathogens, Hearing Conservation, Electrical Safety, Forklift Safety, and CPR and First Aid training programs. Summary of classes is available in Attachment #10.

SecurityThe facility is equipped with a twenty-four (24) hour surveillance system that continuously monitors, records and controls entry to the active portion of the facility. Additionally, the facility operates 24/7/365 so there are always employees on the property.

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Compliance Management Systems

Veolia follows a four (4) part approach to assuring compliance with federal, state, and local regulations and company policies. The program is known by its acronym, PACT. A demonstration of these systems can be provided upon request.

Prevention Veolia uses an internal Environmental Management System (EMS). This program helps to assure compliance by creating a calendar and monthly task assignment form related to compliance issues. Tasks include start and due dates, person assigned, and a description of actions required. Once completed, the task is entered as such in the system.

Assessment Veolia utilizes a two-phase audit system to assure consistency and compliance of our facilities nation-wide; Peer Audits and Self Assessments.Peer Audits of Veolia facilities are conducted by groups composed of Veolia employees assembled from multiple locations. These audits are completed at the Middlesex facility every two years.Self-Assessments are conducted by teams composed of facility and branch employees. The Self-Assessments are completed on various management areas throughout the year, with a goal of 50% of the management areas being completed each year.

Corrective Action Veolia uses the software package Dakota - Tracer to track progress related to correcting compliance issues. Issue reports include due dates, root cause analysis, corrective and preventive actions, and person assigned. Tracer issues are transmitted to corporate directors on a monthly basis for review.

TrainingIn addition to the training regimen outlined in Attachment #10, the Veolia Middlesex facility holds biweekly training sessions with all Branch Employees covering compliance, safety, and other policy issues.

PACT

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Incident History

Site Spill HistoryVeolia did experience a release in June 2014 that required an agency notification. The release was reported to NJDEP & NRC. The release did not result in any injuries.A copy of this report in available on request.

Consent OrdersVeolia (Marisol) has been conducting a RCRA Facility Investigation (RFI) since the USEPA issued a HSWA Permit effective July 15, 2002. The first phase of the work, investigating soils and shallow groundwater at and near the facility, was completed at the end of 2004. The second phase of the work, investigating the deeper bedrock groundwater, was completed in 2008.While the RFI is not finished, the investigation of soils and groundwater underlying the facility containment found relatively high concentrations of volatile organic compounds (VOC’s), including Non-Aqueous Phase Liquids that decrease markedly off the facility. Thus it appears these VOC’s in soil and groundwater are the result of operations conducted at the facility prior to construction of the concrete containment in 1981.The prime technical consulting contractor for the RFI is Princeton Geoscience, Inc. and the contact at PGI is James Peterson, P.G. (609-279-0008). RFI progress reports are issued quarterly to USEPA and NJDEP. The costs of the RFI and any remediation are borne by insurance. To date, the RFI costs total approximately $3.5 million. The insurance coverage available for this project is over $50 million, which is considered more than adequate.Additional information is available on request.

Compliance HistoryVeolia is committed to working with agency representatives to insure compliance with all regulations. The Middlesex facility is inspected weekly by NJDEP Compliance, quarterly by NJDEP Transportation, annually by NJDEP Discharge Prevention, annually by NJDEP Air Compliance, and periodically by EPA and TSCA and the local MCUA.A compliance summary is available in Attachment #12.

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Financial/Insurance Information

Closure PlanPlan includes (Copy is in Attachment #8):• A description of how and when the facility will be closed.• A description of the steps necessary to decontaminate facility equipment during closure.

There is no anticipated date for final closure.• Closure Cost Estimate:

$1,200,528.90 (Adjusted for inflation in September 2018)

Financial Assurance MechanismLetter Of Credit (LOC) – Copies available on request.

Written post-closure planThe facility is not required to have post-closure coverage.

InsuranceA copy of the insurance summary is located in Attachment #13.

Marsh USA Inc., Houston, TX:• $1MM General Liability• $10MM PLS Each Incident• $10MM PLS Aggregate

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Attachments Table of Contents1. Middlesex Facility Layout Page 23

2. Facility Part B Permit Cover Page Page 24 - 26

3. NJPDES Storm Water Permit & MCUA Permit Page 27 - 28

4. DPCC/DCR Plan Approval Letter Page 29 - 30

5. Waste Information Profile (WIP) Page 31 - 33

6. Waste Characterization and Analysis Plan (WAP) Page 34 - 39

7. Veolia Authorized Treatment Facilities Page 40 - 41

8. Facility Closure Plan & Closure Cost Estimate Page 42 - 48

9. Community Relations Policy Page 49

10. Middlesex Training Program Page 50 - 51

11. 5 - Year OSHA Summary Page 52

12. 5 - Year Compliance History Page 53

13. Veolia Insurance Coverage Summary Page 54 - 56

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1. Middlesex Facility Layout

March 2016

VEOLIA ES TECHNICAL SOLUTIONSMIDDLESEX, NEW JERSEY

EVACUATION MAP AND PROCEDURE

W = Wheeled Units (4) ox = ExtinguisherE = Hydrant G = Gas Meters: Control Room & Maint.H = Fire Hydrants (3) M = Electric Meters: Maint, Boiler Room,Red Arrows = Identify Exit Routes

Plant Page Process: Announce the Code and Location Code 1 = Spill Code 2 = Injury Code 3 = Fire Code 4 = Evacuate

Safe Distances and Places of Refuge:I t is important to state that the three following staging areas are subject to change based upon the location of the incident and wind direction. A different staging area will only be chosen by the Emergency Coordinator and will be communicated via the Public Address (P.A.) system, (if different than Area #1).

Area 1:This area is to be used by all non-essential employees, contractors, and visitors in the event of an emergency.

Area 2:This area is to be used for evacuation by all non-essential employees, contractors, and visitors, should the Emergency Coordinator determine that the emergency warrants evacuation due to the location of the incident and wind direction.

Area 3:At the discretion of the Emergency Coordinator, evacuees may be directed to points even further than the property.

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2. Facility Part B Permit Cover Page

25

26

27

3. NJPDES Storm Water Permit & MCUA Permit

28

29

4. DPCC/DCR Plan Approval Letter

30

31

5. Waste Information Profile (WIP)

V e o l i a E S T e c h n i c a l S o l u t i o n s L. L. C.

WASTESTREAM INFORMATION PROFILE

______________________________

__ Disposal Code

| | __ Recertification

____________

__ Veolia ES Location VEOLIA - MIDDLESEX ______________________________ MIDDLESEX__________________ NJ__ | | | ____________ 001 800

| | Invoice Address __ OFFICE CITY ST

-----------------------------------------------------------------------------------------------------------------------------------------

_____Veolia ES TSDF requested _____ __________ Technology requested __________ Generator No. 457751 ______ Generator EPA ID No. NJD002454544 ____________

1. Generator Name VEOLIA ES TECHNICAL SOLUTIONS _________________________________________________________________Generator State No. _____________________

Address L.L.C. ______________________________125 FACTORY LANE ______________________________ State Wastestream No. _____________

City MIDDLESEX __________________ State NJ __ Country US ___ ZIP 08846 _____ ____

NAICS(SIC) Code 4953 ____ 562211 ______ ______ ______ Source G44 ___ Origin 1 _ Form W209 ____ System Type ________

-----------------------------------------------------------------------------------------------------------------------------------------

2. Waste Name PCB HHW PAINTS & RELATED FOR TSCA INCIN ________________________________________ Lab or Waste Area _______________

3. Process Generating Waste

HHW Collections________________________________________________________________________________________________________________________

4. Shipping Name WASTE FLAMMABLE LIQUIDS, n.o.s. _____________________________________________ ________________________________________________

Hazard Class 3 ____ UN/NA No. UN1993 ______ PG I ___ RQ amt 0 ____ lb Waste: Y _ PIH: N _ IH: N _ DWW: N _ P: N _

RQ Des: 1.____________________________________________________________ 2.____________________________________________________________

DOT Des: 1.POLYCHLORINATED BIPHENYLS ____________________________________________________________ 2.PAINT ____________________________________________________________

5. Waste Codes D001 ______ PCB2 ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______

Wastewater ______ _ Non Wastewater ______ X _ Sub Category D001-IL _________________________________________________________ Mix: N _ Sol: N _

-----------------------------------------------------------------------------------------------------------------------------------------

6. Physical and chemical properties:

pH Specific Gravity Flash Point(F) Solids

a ___ < 2 _ a ___ <.8 _ a ___ < 80 _ _________ % suspended0 ___ - 0 ___ _________ % ash 0 ___ - 50 ___

b ___ 2 - 5 _ b ___ .8 - 1.0 _ b ___ 80 - 100 _ _________ % settleable1 ___ - 100 ___ _________ % water solubility 0 ___ - 0 ___

c ___ 5 - 9 X _ c ___ 1.0 _ c ___ 100 - 140 X _ _________ % dissolved0 ___ - 0 ___ _____________ BTU/lb 8000 _____ -12000 _____

d ___ 9 - 12.5 _ d ___ 1.0 - 1.2 _ d ___ 140 - 200 _

e ___ > 12.5 _ e ___ > 1.2 _ e ___ > 200 _ Free Liquid _________ % 1 ___ -100 ___

___________ exact - ___________ exact - f ___ no flash ___________ exact - VOC _________ % 0 ___ - 0 ___

-----------------------------------------------------------------------------------------------------------------------------------------

Physical State Hazardous Characteristics Odor

s ___ solid _ a ___ air reactive _ r ___ radioactive or NRC regulated _ a none _____ _

m ___ semi-solid X _ w ___ water reactive _ s ___ shock sensitive _ b mild _____ _

l ___ liquid X _ c ___ cyanide reactive _ t ___ temp sensitive _ c strong _____ _

p ___ pumpable semi-solid _ f ___ sulfide reactive _ m ___ polymerization/monomer _ describe _________________________

f ___ flowable powder _ e ___ explosive _ n ___ OSHA carcinogen _ __________________________________

g ___ gas _ o ___ oxidizing acid _ i ___ infectious _ Halogens

a ___ aerosol _ p ___ peroxide former _ h ___ inhalation hazard _ Br .0 _____ - .0 _____ % Bromine

r ___ pressurized liquid _ Zone: _ Cl .0 _____ - .0 _____ % Chlorine

d ___ debris per 40 CFR 268.45 _ F .0 _____ - .0 _____ % Fluorine

h ___ sharps _ I .0 _____ - .0 _____ % Iodine

q ___ pumpable liquid _

-----------------------------------------------------------------------------------------------------------------------------------------

Layers: ____ | a multilayered: ____ _ ____ b bi-layered: ____ X _ ____ c single phase | ____ _

-----------------------------------------------------------------------------------------------------------------------------------------

| Top Layer | Second Layer | Bottom Layer |___________________________________________________________________________________________________________ Color

Viscosity | ___ high(syrup)X_ | ___ high(syrup) _ | ___ high(syrup) _ | VAR ___

by | ___ medium(oil) _ | ___ medium(oil) _ | ___ medium(oil)_ | ___

Layer: | ___ low(water) _ | ___ low(water)X_ | ___ low(water)_ | ________

| ___ solid _ | ___ solid _ | ___ solid_ |

-----------------------------------------------------------------------------------------------------------------------------------------

page 1 WIP NO. 444292 ______

32

V e o l i a E S T e c h n i c a l S o l u t i o n s L. L. C.

WASTESTREAM INFORMATION PROFILE

___Used oil y/n ___ ___ HOC < 1000 ppm ___ _ ___ HOC > 1000 ppm ___

-----------------------------------------------------------------------------------------------------------------------------------------

7. Chemical Composition [M=Marine Pollutant, S=Severe Marine Pollutant, O=Ozone Depleting Substance,

U=Underlying Hazardous Constituent, B=Benzene NESHAP, T=TRI Chemical, C=OSHA Carcinogen]

Constituents Ranges Units

_______________________________________________________________________________________________________

|______________|_VARIOUS PAINT, COATING & THINNERS CONTAINING PETROLEUM ____________________________________________________________| _ 40.00 __________| _ 60.00 __________| _ % ____| _

|______________|_DISTILLATES AND/OR SOLVENTS (IN VARIOUS SIZE CONTAINERS) ____________________________________________________________| ___________|___________|_____| _

|_______S _, _T _, _U _, __| _POLYCHLORINATED BIPHENYLS (SHIPMENT BY HIGHWAY) LIQUID MIXTU ____________________________________________________________| _ 50.00 __________| _ 1000.00 __________| _ M ____| _

|______________|_RE ____________________________________________________________|___________|___________|_____| _

|_________T _, ____| _LATEX PAINTS ____________________________________________________________| _ 40.00 __________| _ 60.00 __________| _ % ____| _

Other:

8. Is the wastestream being imported into the USA? Yes __ No X __

9. Does the wastestream contain PCBs regulated by 40CFR? Yes X __ No__

PCB Concentration 1000.00 __________ ppm

10. Is the wastestream subject to the Marine Pollutant Regulations? Yes __ No X __

11. Is the wastestream from an industry regulated under Benzene NESHAP? Yes __ No X __

If yes:

Is the wastestream subject to Notification/Control Requirements? Yes __ No X __

Benzene Concentration .00__________ ppm

Does it contain >= 10% water? Yes __ NoX __

What is the TAB at your facility? .00______ Mg/Yr

12. Is the wastestream subject to RCRA subpart CC controls? Yes __ No X __

Volatile Organic Concentration .00__________ ppmw

CC Approved Analytical Method? Yes __ No X __

Generator Knowledge? Yes __ No X __

13. Is the wastestream from a CERCLA or state mandated cleanup? Yes __ No X __

______________________________ ____________________________________________________________ ____________________________________________________________ ______________________________________________________________________________________________________________

14. Container Information :

Packaging: 551A2______ Type/Size: DM __ 55 GAL OPEN HEAD (17H) DM______________________________

551H2______ Type/Size: DF __ 55 GAL OPEN HEAD PLASTIC DRUM______________________________

Shipping Frequency: Units 100.00 ________ Per Day _ Per Week _ Per Month _ Per Qtr _ Per Year _ One Time X _

UOM DRUMS ___ DESCRIPTION: __________

______________________________ _____ _________________________ ______________________________ ____________________________________________________________ ______________________________________________________________________________________________________________

15. Additional Information :

__________________________________________________________________________________________________________________________________

__________________________________________________________________________________________________________________________________

__________________________________________________________________________________________________________________________________

__________________________________________________________________________________________________________________________________

page 2 WIP NO. 444292 ______

33

V e o l i a E S T e c h n i c a l S o l u t i o n s L. L. C.

WASTESTREAM INFORMATION PROFILE

GENERATOR CERTIFICATION

I hereby certify that all information submitted in this and all attached documents contains true and accurate descriptions of this

waste. Any sample submitted is representative as defined in 40 CFR 261 - Appendix I or by using an equivalent method. All relevant

information regarding known or suspected hazards in the possession of the generator has been disclosed. I authorize sampling of

any waste shipment for purposes of recertification.

__________________________________________________ ____________________ ____________________

Name(Print or Type) Phone Date

______________________________ _________________ ____________________ ________________________________________

Signature Title

______________________________ ____________________________________________________________ _______________________________________________________________________________________________________________________________________________________________

If approved for management, Veolia ES has all the necessary permits and licenses for the waste that has been characterized

and identified by this profile.

page 3 WIP NO. 444292 ______

34

6. Waste Characterization and Analysis Plan (WAP)

SECTION 3 Waste Analysis Plan

{40 CFR s270.14(b)(3)}

3.1 Waste Analysis Plan (WAP)

The Veolia Waste Analysis Plan (WAP) was developed in accordance with 40 CFR s264.13(b) and will be available at the facility at all times. The WAP will be reviewed regularly to ensure compliance with all regulatory standards and standard operating procedures. The objective of Veolia’s WAP is to ensure proper classification prior to storage, treatment or transfer off-site.

New waste streams are not accepted at the facility until a Waste Information Profile (WIP) is completed and approved by Veolia technical representatives. The WIP is waste stream and generator specific and a unique WIP number is assigned to each wastestream. If the generator cannot accurately complete the WIP, a sample of the waste will be taken at the generator’s facility and sent for analytical testing.

Each WIP is thoroughly reviewed to determine acceptability. The essential parameters required for fuel-blending and distillation are determined by reviewing the listed chemical constituents, including: BTU value and Total Halogen content. The listed chemical constituents are also used to determine chemical compatibility prior to bulking of waste streams.

A re-evaluation of the WIP information and the designated treatment approval for the waste will be conducted under the following circumstances:

1. The generator modifies the process or operation generating the waste; or2. Veolia operations or the disposal facility determine that the waste does not conform to the WIP; or3. There is a regulatory revision that affects the classification or management of the waste for disposal.

All active WIPs will be periodically reviewed for accuracy and all WIPs and approvals are entered into the Veolia computer database. This allows for easy review of both the WIP and the treatment approval information. In addition, the database maintains an electronic “stamp” that documents the initial date of entry, the date of the last revision, and the name of the person making the modifications to the WIP information.

3.2 Container Sampling

Upon arrival at the facility, Veolia personnel inspect all containers to insure that the packaging and labeling has been prepared in accordance with DOT regulations. Prior to unloading, a receiving document is completed. The receiving document is customer specific and a unique number is assigned to that load. The receiving document is then given to the Veolia sampler. The sampler must be in possession of the completed receiving document prior to sampling the material. Sampling is completed within the facility’s secondary containment area, as follows:

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Bulk Shipments – A minimum of one (1) sample of each shipment unless the shipment is to betransferred off-site without processing. For multi-compartment tank wagons, all compartments shallbe sampled individually.

Non-Bulk Shipments – Every drum that will be processed at the facility is sampled individually,however, composite samples may be taken, from a maximum of forty (40) drums, of the samewaste stream received from the same generator. A fingerprint analysis is done for liquids by pullinga sample from each drum with a sampling device that consists of a graduated cylinder attached to aflexible metal rod and/or a coliwassa. Essential parameters are confirmed prior to compositing.

3.3 Sampling Parameters

All samples will be analyzed, as determined by Veolia Laboratory personnel, for the following parameters; depending on the source and process generating the waste streams, and the specific treatment process to be utilized. All sampling and testing is completed using SW-846 methods or other industry standards, as outlined in the Waste Analysis Plan Test Methods Document (Attachment 4).

The following is a list of sampling parameters and descriptions:

1. BTU’s (British Thermal Units) – The amount of energy needed to raise the temperature of onepound of water by one degree Fahrenheit. This heat value is critical in fuel processing. Requiredheat value is needed in fuel products produced.

2. Flash Point – This is the temperature at which the test material gives off sufficient vapor to form anignitable mixture with the air near the surface of the liquid or within the test vessel. This propertyaffects the shipping information and appropriate storage locations. There is no direct correlationbetween Flash Point and BTU value.

3. Gas Chromatography – This is a process in which the components of a mix are separated from oneanother by volatilizing the sample into a carrier gas stream which is passing through and over a bedof packing. Different components move through the bed at different rates which indicates variouspeaks. These peaks correspond to various solvents. Thus, this test is utilized for solventidentification and quantification.

4. Metals Analysis – This is used to identify the presence various metals that will affect the shippingrequirements, acceptability of the material for processing, and process determination.

5. PCB’s (Polychlorinated Biphenyls) – The level of PCBs will determine the ability to process thematerial. Waste containing PCBs will be redirected to a TSCA Permitted Facility.

6. Percent Ash – The percent of residue remaining after the combustion of the sample. This willdetermine which process method is utilized, as well as, identify the amount and solids and viscosity.

7. pH – This is the value taken to represent acidity or alkalinity. The pH affects the method orprocessing and shipping information.

8. Specific Gravity – This is the measure of material’s density in comparison to water at the sametemperature (Water Specific Gravity = 1.00). Different solvents have different Specific Gravities.This test helps to confirm the chemical composition, as well as, water content.

9. Total Halogens – As with BTU value, the percentage of halogens is critical in the processdetermination.

3.4 Process Parameters

Essential parameters are determined through a review of the chemical constituents listed on the WIP and are confirmed through fingerprint analysis, prior to identifying a site process and processing a specific waste stream:

1. Fuel Blending & Distillation (including fractionation and thin film evaporation) Physical State Specific Gravity (will confirm Heating Value & Total Halogen)

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2. Water Treatment pH Specific Gravity (will confirm Heating Value)

3. Transfer Operations – Waste analysis results as required by the ultimate disposal site.

Supplemental parameters as identified in Section 3.3, may also be analyzed in the laboratory as determined by Veolia personnel, depending on the source generating the waste streams and the specific need for final processing of the waste. Additionally, chemical compatibility is confirmed in the laboratory, by combining waste streams, prior to approving bulking operations.

3.5 Internal Waste Classification

After incoming waste is sampled and analyzed the laboratory technician will assign a specific internal classification code. For bulk tank wagons or railcars this code is documented on the receiving document and in Veolia’s computer tracking system. For containerized material, the internal classification code is marked on the actual container and entered into the Veolia computer tracking system.

The basis for the internal classification system is the material’s chemical composition. Due to the nature of the waste industry and the potential for composition fluctuations, internal classifications are based on common chemical “families”. All incoming or in-house waste material (still bottoms and line flushes) is assigned a specific Classification Code, based on the chemical “family” and physical characteristics. The following are the various chemical “families” and the corresponding “S” codes:

1) Lacquer Thinners (S-01) – Lacquers are a protective or decorative coating which, when applied, dryprimarily by evaporation of the solvent within the lacquer. This spent material often comes from thepaint and coatings industry, furniture, automotive, building and residential sources. Depending onthe quality and composition of the material, it is either processed through distillation or fuelprocessing. The following classifications apply for solvent specific or solvent rich lacquer thinnersand which contain aliphatic or aromatic diluents (Typical Specific Gravity Range) :

S-011 Acetone (.800 - .850) S-012 Methyl Ethyl Ketone (.820 - .850) S-013 Methyl Isobutyl Ketone (.820 - .850) S-010 Miscellaneous Thinners (.820 - .850)

2) Automotive Fluids (S-02) – These materials primarily to automotive fluids with the exception ofgasoline, diesel fuel, motor oils, and various battery acids. The most common automotive fluids arebrake fluid and antifreeze.

3) Halogenated Hydrocarbons (S-03) – Chlorinated and fluorinated hydrocarbons are solvents whichare used for cleaning precision instruments; metal degreasing; textile processing; extraction solventfor oils, fats and waxes; as refrigerants and heat exchange liquids; diluents in paints and adhesives;as chemical intermediates; aerospace operation; vapor degreasing and automotive maintenance.Based on the wide variety of applications the range of sources covers many industries, governmentagencies, institutions and even residential. The following classifications apply for solvent specific orsolvent rich chlorinated and fluorinated hydrocarbons (Typical Specific Gravity Range);

S-031 Chloroform (Trichloromethane) (1.20 – 1.31) S-032 Chlorofluorocarbon (1.50 – 1.56) S-033 Methylene Chloride (Dichloromethane) (1.25 – 1.31) S-034 Perchloroethylene (Tetrachloroethylene) (1.50 – 1.60) S-035 Trichloroethylene (1.35 – 1.45) S-036 1,1,1-Trichloroethane (1.25 – 1.30) S-037 Carbon Tetrachloride (Tetrachloromethane) (1.40 – 1.45) S-038 Dichlorobenzene (1.28 – 1.31) S-039 Ethylene Dichloride (Dichloroethane) (1.15 – 1.24) S-030 Miscellaneous Mixtures (1.25 – 1.51)

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4) Esters (S-04) – Esters are organic compounds similar in structure to a salt in inorganic chemistry.The typical reaction is that of an acid (either organic or inorganic) with an alcohol or other organiccompound high in OH groups. Esters of acetic acid are called acetates and esters of carbonic acidare called carbonates. Acetates are used in lacquers, thinners, nail enamels, leather finishes,coatings, plastics, pharmaceuticals, organic synthesis, smokeless powers, synthetic fruit essences,flavoring agents, perfumery, natural and synthetic resins and as lab reagents. Based on the largevariety of applications, the sources of ester materials are also quite large and varied. The followingclassifications apply for solvent specific or solvent rich esters (Typical Specific Gravity Range):

S-041 Butyl Acetate (.850 - .860) S-042 Ethyl Acetate (.870 - .900) S-043 Propyl Acetate (.850 - .890) S-044 Ethoxyethanol Acetate (---) S-040 Miscellaneous Esters & Mixtures (.850 - .890)

5) Ketones (S-05) – Ketones are a class of organic compounds in which the carbonyl group (C=O) isattached to two alkyl groups; they are produced by oxidation of secondary alcohols. The simplestketone is acetone but there are many ketones available. Ketones are used for paints, textileprocessing, varnish and lacquer solvents; to clean and dry parts of precision equipment; rubbertesting; printing; acrylic coatings; organic synthesis; cements and adhesives; paint removers, vinylfilms; and as a denaturant for alcohol. Based upon the large range of applications, the sources forketone materials are also large and varied. The following classifications apply to solvent specific orsolvent rich ketones (Typical Specific Gravity Range):

S-051 Acetone (2-Propanal, Diemthylketone) (.800 - .850) S-052 Methyl Ethyl Ketone (2-Butanone, MEK) (.820 - .850) S-053 Methyl Isobutyl Ketone (Hexone, MIK) (.820 - .850) S-050 Miscellaneous Ketone & Mixtures (.820 - .850)

6) Alcohols (S-06) – Alcohols are a broad base of hydroxyl-containing organic compounds occurringnaturally in plants and made synthetically from petroleum derivatives. Alcohols are used formanufacturing solvents, antifreeze, brake fluids, shellac, rosin, resins, dyes; as a denaturant,dehydrator for natural gas, fuel additive, coatings, preservatives, lotions, pharmaceuticals, and as adehydrating agent. Based upon the large range of applications, the sources for alcohol materialsare also large and varied. The following classifications apply to solvent specific or solvent richalcohols (Typical Specific Gravity Range):

S-061 Isopropyl Alcohol (IPA, 2-Propanol) (.790 - .850) S-062 Methyl Alcohol (Methanol, Wood Alcohol) (.790 - .850) S-063 Butyl Alcohol (1-Butanol, n-, sec-, tert-) (.800 - .820) S-064 Ethyl Alcohol (Alcohol, Ethanol, Grain Alcohol) (.790 - .850) S-060 Miscellaneous Alcohols & Mixtures (.790 - .850) S-065 Isoamyl Alcohol (.790 - .850)

7) Hydrocarbons (S-07) – Hydrocarbons are organic compounds consisting exclusively of elements ofcarbon and hydrogen. This is derived principally from petroleum, coal tar, and plant sources.Hydrocarbons are used in aviation gasoline and high-octane blending; in paints and coatings,gums, resins, oils, rubber, as diluents in lacquers, adhesive solvent in plastic toys and airplanes,pharmaceuticals, manufacturing if solvents and laboratory agents; alcohol denaturants, andgasoline manufacturing. Based upon the large range of applications, the sources for hydrocarbonmaterials are also large and varied. The following classifications apply to solvent specific or solventrich hydrocarbon (Typical Specific Gravity Range):

S-071 Toluene (Methylbenzene) (.860 - .875) S-072 Xylene (Dimethylbenzene) (.860 - .875) S-073 Benzene (.860 - .880)

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S-074 Heptane (Dipropylmethane) (.710 - .760) S-075 Hexane (.680 - .710) S-076 Naphthas (.740 - .760) S-077 Mineral Spirits (.700 - .740) S-070 Miscellaneous Hydrocarbons & Mixtures (.700 - .740)

8) Glycols (S-08) – Glycols are used as coolants and antifreeze, asphalt-emulsion paints, heat-transferagents, laminates, break fluids, polyester fibers and films, cosmetics, lacquers, resins, inks, woodstains, adhesives, leather dyeing, textile processing, de-icing fluid, foam stabilizer, polyurethane,dehydration of natural gas, paper products and many other uses. Based upon the large range ofapplications, the sources for glycol materials are also large and varied. The following classificationsapply to solvent specific or solvent rich glycols (Typical Specific Gravity Range):

S-081 Diethylene Glycol (DEG, Diglycol) (1.10 – 1.13) S-082 Ethylene Glycol (Ethylene Alcohol, Glycol) (1.10 – 1.13) S-083 Triethylene Glycol (TEG) (1.12 – 1.15) S-084 Dipropylene Glycol (1.00 – 1.05) S-085 Tripropylene Glycol (1.00 – 1.05) S-080 Miscellaneous Glycols & Mixtures (1.00 – 1.10)

9) Glycol Ethers (S-09) (.990 – 1.10)

10) Poly Glycols (S-10) (.980 – 1.05)

11) Plasticizers (S-11) (.950 - .990)

12) Surfactants (S-12) (.980 – 1.01)

13) Water (S-13) (.985 – 1.01)

14) High Water and Viscous Material (S-14) – The following classifications apply to solvent high waterand viscous materials (Typical Specific Gravity Range):

S-140 High Water Content (.950 – 1.05) S-141 Non-Hazardous High Water (.950 – 1.15) S-142A Viscous Alcohol & Glycol Mixtures S-142O Viscous Oil & Hydrocarbon Mixtures S-142P Viscous Pigment, Ketone & Paint Mixtures S-144 Non-Hazardous Solids S-145 Activated Carbon S-147 Hazardous Solids S-148 Debris S-149 Compacted Debris with Metal

15) Miscellaneous Single Component Solvents (S-15) – The following classifications apply to singlecomponent solvents (Typical Specific Gravity Range):

S-151 Tetrahydrofuran (THF) (.800 - .975) S-152 n-Methyl-2-Pyrrolidone (NMP) (.900 – 1.10)

16) Miscellaneous Low Flash Solvents (S-16) – This category is normally used for mixtures of varioussolvents in specific solvent “families” and is used in fuel processing (Typical Specific GravityRange):

S-160 Oil (.900 – 1.15) S-161 Ketone/Paints (.900 – 1.15) S-162 Viscous Ketones/Paints (.900 – 1.15)

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S-163 Flammable Solvent Mixtures (>15% Total Halogens) (.900 – 1.15) S-164 High Halogen Fuel (.990 – 1.15) S-166 Alcohol Mixtures (.900 – 1.15) S-167 Hydrocarbon Mixtures (.900 – 1.15) S-169 Flammable Solvent Mixtures (3-15% Total Halogens) (.900 – 1.15)

17) Miscellaneous High Flash Solvents (S-17) – The following classifications apply to solvent high waterand viscous materials (Typical Specific Gravity Range):

S-172 Methylene Chloride and Chlorofluorocarbons (1.35 – 1.50) S-177 Trichloroethane and Chlorofluorocarbons (1.35 – 1.50) S-170 Halogenated Hydrocarbon Mixtures (1.25 – 1.45)

3.6 Operating Record

A complete written operating record is maintained at the facility as required under 40 CFR s264.73(b). The information is recorded as it becomes available, and will be maintained until closure of the facility; or if noted below, no less than 3-years. The operating record includes:

A description and the quantity of each solid and hazardous waste received, and the method anddate of its treatment or disposal.

The location of each solid and hazardous waste within the facility, and the quantity at each location. Records and results of waste analysis and waste determinations (no less than 3-years). Summary reports and details of all incidents that require implementation of the contingency plan

(no less than 3-years). Records and results of all required inspections (no less than 3-years). All closure cost estimates.

3.7 Reporting Requirements

The following reports are completed and submitted as required by regulation:

Manifest Discrepancy Reports – Completed and submitted for significant discrepancies not resolvedwithin fifteen days.

Unmanifested Waste Reports – Completed and submitted within 15 days for receipt of unmanifestedwaste.

Biennial Reports – Completed and submitted covering facility activities during odd numbered calendaryears.

Solid Waste Monthly Reports – Completed and submitted monthly summarizing the solid wastereceived by the facility.

Exception Reports – Completed and submitted for exported waste that is returned to Veolia.

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7. Veolia Authorized Treatment Facilities

Veolia ES Technical Solutions, LLC www.veolianorthamercia.com

Veolia ES Technical Solutions, L.L.C. - Audited and Approved Facility List

Facility Name Facility Address EPA ID Number

Alaron CorporationPA State Route 18 & Park Street,

Wampum, PA 16157PAD987400157

Bethlehem Apparatus Co., Inc.890 Front Street P.O. Box Y,

Hellertown, PA 18055PAD002390961

Bethlehem Apparatus Co., Inc.935 Bethlehem Drive, Bethlehem,

PA 18017PA0000453084

Chemical Waste ManagementP.O. Box 55, Highway 17N

Milemarker 163, Emelle, AL 35459ALD000622464

Clean Earth of North Jersey115 Jacobus Ave, South Kearny,

NJ 07032NOT REQ

Clean Earth of Philadelphia, Inc3201 South 61st. Street, Philadelphia, PA 19153

NOT REQ

Clean Harbors Environmental Services

309 American Circle, El Dorado, AR 71730

ARD069748192

Clean Harbors of Baltimore, Inc.1910 Russell Street, Baltimore,

MD 21230MDD980555189

Clean Water of New York3249 Richmond Terr., Staten

Island, NY 10303NY0000968545

Covanta Niagara100 Energy Blvd. @ 56th Street,

Niagara Falls, NY 14304NOT REQ

Covanta Union, Inc.1499 Route 1 North, Rahway, NJ

07065NOT REQ

CWM Chemical Services, L.L.C.1550 Balmer Road, Model City,

NY 14107NYD049836679

Environmental Recovery Corp.1076 Old Manheim Pike,

Lancaster, PA 17601PAD987266749

EQ Michigan Disposal Inc.49350 N I-94 Service Drive,

Belleville, MI 48111MID000724831

Giant Cement Company GRR -Harleyville, Inc.

654 Judge Street P.O. Box 352, Harleyville, SC 29448

SCD003351699

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Veolia ES Technical Solutions, LLC www.veolianorthamercia.com

Facility Name Facility Address EPA ID Number

Giant Resource Recovery -Attallia, Inc.

1229 Valley Drive Highway 11, Attalla, AL 35954

ALD 070 513 767

Lancaster County Resource Recovery

1911 River Road Route 441 Southside, Bainbridge, PA 17502

PA0000103713

SET Environmental, Inc.5743 Cheswood, Houston, TX

77087TXD055135388

Veolia Environmental Services Trade Waste Incineration, Inc.

7 Mobile Avenue, Sauget, IL 62201-1069

ILD098642424

Veolia Environmental Services4301 Infirmary Road, West

Carrollton, OH 45449OHD093945293

Veolia Environmental ServicesW124 N9451 Boundary Rd., Menomonee Falls, WI 53051

WID003967148

Veolia Environmental Services9131 East 96th Avenue, Henderson, CO 80640

COD980591184

Veolia Environmental ServicesHighway 73 , Port Arthur, TX

77640TXD000838896

Veolia Environmental Services5752 West Jefferson Street,

Phoenix , AZ 85043AZ0000337360

Veolia Environmental Services1275 Mineral Springs Drive, Port

Washington, WI 53074WID988566543

Veolia Environmental Services230 Canton Street, West Bridgewater, MA 02072

MA5000004713

Vexor Technology, Inc.955 West Smith Road, Medina,

OH 44256OHD077772895

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8. Facility Closure Plan & Closure Cost Estimate

Page 1 Revised November 2013

SECTION 13 Closure Plan & Closure Cost Estimate

{40 CFR s270.14(b)(13) & (15)}

13.1 Introduction

This written closure plan has been prepared in accordance with 40 CFR Part 264. In the event of the need to cease operations, Veolia would initiate this Facility Closure Procedure.

The time frame for closure would be completed within six (6) months from the initial date of closure. For the purpose of this plan, the initial date will be referred to as "Day 0", with the final date of closure being "Day 180".

The NJDEP Bureau of Hazardous Waste and Transfer Facilities will be notified at least thirty (30) days prior to the proposed date of implementation of the closure procedure. The closure would be accomplished in a two (2) phase program, as follows:

Phase One: Facility Solvent Removal Phase Two: Facility Decontamination

13.2 Facility Solvent Removal – Day 0 to Day 90

Bulk Solvent Removal (Tanks, Tank Wagons and Roll-offs) – All bulk tanks and treatment units are to be considered at 100% capacity: 1,058,200 gallons. Solvents will be shipped off-site for disposal as a fuel product on a manifest to a permitted facility. Materials not appropriate for fuel product will be sent off-site for other final disposition. Shipments will be made in 6,000 gallon tank wagons. At a rate of five (5) tank wagons per day, it will take 35 days to complete this step. Taking into account no weekend or holiday shipments, the actual time frame would be approximately 50 days.

All tank wagons are to be considered at 100% capacity. This capacity would be twelve (12) tank wagons totaling 72,000 gallons. Solvents will be shipped off-site for disposal as a fuel product on a manifest to a permitted facility. Shipments will be made in the 6000-gallon tank wagons. At a rate of one (1) tank wagon per day, this will take twelve (12) days and be done in conjunction with the five (5) tank wagons per day described above.

Drum and Rail Car Siding Removal – This step would be more labor intensive. Drum volume is to be considered at 100% capacity: 5,000 drums (275,000 gallons). The contents of the drums would be pumped into tank wagons by the transporter under the Facility Coordinator's supervision for shipment to an authorized off-site facility. At 200 drums per day, it would generate two (2) tank wagons per day and also one (1) truck load of empty drums per day. The empty drums would go for drum reconditioning. At the rate of 200 drums per day, it will take 25 days to complete this step. Taking into account no weekend or holiday shipments, the actual time frame would be 45 days.

All rail cars are to be considered at 100% capacity: 210,000 gallons (This represents a requested increase in rail capacity). Solvents will be shipped off-site for disposal as a fuel product on a manifest to a permitted facility. Shipments will be made in 6000-gallon tank wagons. At a rate of three (3) tank wagons per day, it will take ten (10) days to complete this step. Taking into account no weekend or holiday shipments, the actual time frame would be twelve (12) days. This would be done simultaneously with drum removal shipments.

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Page 2 Revised November 2013

13.3 Facility Decontamination – Day 91 to Day 180

The second phase would require decontamination of all tanks, tank wagons, rail cars and treatment units (and associated equipment such as stills, condensers, etc.), piping, pumps, and secondary containment. Within this phase, there are three (3) steps needed to achieve complete decontamination.

Step One: Removal of Sediment – Removal of all sediment and/or sludge from the tanks, tank wagons, hydrapulper, rail cars and treatment units and associated equipment (boilers, condensers, etc.). The removal of the sludge and/or sediment would be accomplished by utilizing the on-site vacuum truck and/or a "guzzler" apparatus.

This process will generate approximately ten (10) drums, or 500 gallons, of waste material on average per tank. The empty drums would have been retained from the drum pumping stage. These drums would also go for fuel processing and would be shipped in drums to an authorized off-site facility.

In addition, removal of sludge and/or sediment from tank wagons and rail cars would also be accomplished by utilizing the on-site vacuum truck and/or a “guzzler” apparatus. This process will generate three (3) drums for each tank wagon and ten (10) drums for each rail car. The empty drums would have been retained from the drum pumping stage. These drums would also go for fuel processing and would be shipped in drums to an authorized off-site facility. This step would take approximately 25 days, allowing for weekends and holidays.

Step Two: Decontamination of Tanks and Treatment Units – A "blank sample" of tap water to be used in this decontamination step is taken and analyzed at a certified laboratory with results being sent to the Bureau of Hazardous Waste and Transfer Facilities. Decontamination of all tanks, tank wagons, rail cars and treatment units will be achieved by using a water rotator nozzle and jet gun. Initial wash water for each tank may be reused, if practical. Decontamination will continue until the concentration of contaminants in the wash water is less than or equal to the concentrations present in the wash water blank sample. Samples will be tested for VOCs, metals, and pH.

Disposal of wash water would have an estimated composition of 90% water, 5% suspended solids, and 5% solvent. This water would be sent to a water treatment facility for proper disposal. Final washes that meet POTW limits would be discharged to the POTW following sample analysis. Approximately 60,000 gallons of waste water for off-site treatment would be generated.

All piping, pumps, and valves would also achieve decontamination during this process, due to their use in the program. The samples would be drawn using the existing ancillary equipment. The ancillary equipment will be decontaminated with the same wash water used in the tank decontamination. For example, to transfer wash water out of a pressure washed tank, the lines and pumps that would need decontamination would be used. Due to the volume of water being removed and suction from the pumps, decontamination would be achieved. Samples would then be sent to a certified laboratory.

Average turn-around at the lab would be two (2) weeks. Within one (1) week of receiving these results, they will be sent by certified mail to the Bureau of Hazardous Waste and Transfer Facilities for review and approval of the decontamination. This step would take approximately 25 days, allowing for weekends and holidays.

Step Three: Decontamination of Secondary Containment/Concrete – Secondary containment would be decontaminated after all tanks, treatment units, and associated equipment (i.e., stills, condenser, etc.), pumps, and lines were decontaminated and drained. The secondary containment would be pressure washed using detergent and water. All water would be contained within the tertiary containment. This would include the concrete (including all rail car and vehicle loading and unloading areas), walls, sumps, dikes, and curbs for the entire contained area (approximately 3 acres).

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Page 4 Revised November 2013

13.6 Closure Cost Estimate

The closure cost estimate for the Veolia Middlesex Facility has been prepared based on the worst case volume scenario. A detailed summary of all specific costs is outlined in the Facility Closure Cost Estimate (Attachment 32).

13.7 Financial Mechanism

The financial assurance mechanism established for the closure of the facility is an Irrevocable Standby Letter of Credit (LOC). The current Letter-of-Credit is LOC #68000950 (Attachment 33).

13.8 Closure Cost Adjustments

The closure cost estimate will be adjusted for inflation within sixty (60) days prior to the anniversary date of the establishment of the financial instrument used to comply with 40 CFR s264.143.

The adjustment for inflation will be made by recalculating the maximum costs of closure using an inflation factor derived from the most recent Implicit Price Deflator for Gross National Product published by the U.S. Department of Commerce.

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FACILITY CLOSURE COST ESTIMATE

I. PHASE ONE FACILITY SOLVENT REMOVAL

Step One - Bulk Solvent Removal (Tanks and Tank Wagons)

Transportation and disposal of solvents (waste & product) 1,130,200 gallons @ $.35/gallon $395,570

Step Two - Transportation and Disposal of Drum and Rail Car Solvents

1. Transportation and Disposal - Railcars210,000 gallons @ $.35/gallon $73,500

2. Transportation and Disposal - Drums5,000 drums equivalent @ 55 gallons per drum = 275,000 gallons @ $.35/gallon $96,250

3. Transportation and Disposal of Empty ContainersDisposal of 4,480 drums (520 drums retained for removal of sediment from tanks - see Phase Two, Step One) 16 loads @ 280 drums/load @ zero cost/load No Cost

4. Disposal of Laboratory and Maintenance Chemicals $10,000

Phase One Total: $575,320

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II. PHASE TWO DECONTAMINATION

Step One - Removal of Sediment 1. Tank cleaning of 50 waste storage tanks

@ $2,500/tank $125,000 2. Tank cleaning of 8 process tanks & 5 stills

@ $500/tank $6,500 3. Tank Wagon Cleaning of 12 tank wagons

@ $500 each $6,000 4. Rail Car Cleaning of 7 rail cars

@ $2,500 each $17,500 Step One Subtotal: $155,000

Step Two - Decontamination of Tanks 1. 36 "large" tanks (15-28,500 gallons)

@ $1,500/tank $54,000 2. 29 "smaller" tanks (8-15,000 gallons)

@ $1,000/tank $29,000 3. 12 Tank wagons @ $500/tank wagon $6,000 4. 7 Rail Cars @ $1,000/rail car $7,000 5. Disposal of washwater at water treatment facility:

i. 600 gallons washwater - large tanks x 36 = 21,600 ii. 300 gallons washwater - small tanks x 28 = 8,400 iii. 250 gallons washwater - tank wagons x 12 = 6,000 iv. 500 gallons washwater - rail cars x 7 = 3,500

39,500 Cost = $1.00/gallon X 39,500 $39,500

6. Transportation to disposal facility at 5000 gallon/shipment,8 @ $1,200 per load $9,600

7. Sampling and analysis of water65 tanks @ $200 per analysis $13,000

Step Two Total: $158,100

Step Three - Decontamination of Secondary Containment/Concrete 1. Power wash approximately 3 acres $10,000 2. Wash water - 5000 gallons generated @ $1.00/gallon $5,000 3. Transportation for one load @ $1,200 $1,200 4. Disposal of Cleanup Debris (rags, absorbents, etc.)

drums 20 @ $150/drum $3,000 5. Transportation for Debris Removal $1,250

Step Three Total: $20,450

Phase Two Total: $333,550

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III. OVERHEAD COST

Overhead would be those costs not provided by the third party contractors.

Water (based on three shifts for full year) $1,000 Electricity (To operate pumps lighting) $3,000 Fuel Oil (For forklifts) $2,200 Telephone (For scheduling and Administrator use) $1,000 Professional Engineer Fee (60 hrs. @ $100/hr.) $6,000

Overhead Total: $13,200

SUMMARY OF FACILITY CLOSURE COST ESTIMATE

Phase One $575,320 Phase Two $333,550 Overhead $13,200

SUBTOTAL: $922,070

Plus 10% Administrative & 10% Contingency $184,414

GRAND TOTAL: $1,106,484

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9. Community Relations Policy

VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. 125 Factory Lane

Middlesex NJ 08846 COMMUNITY RELATIONS POLICY

Industry and Business Organizations

Community Advisory Panel (CAP) – The CAP, which is sponsored by Veolia, facilitates communication and fosters positive working relationships among the businesses and citizens who reside or work in the Middlesex, Bound Brook and Piscataway NJ area. The panel provides an ongoing mechanism to promote open dialogue about issues of mutual importance and concern. Members include local businesses, hospitals, township officials, fire department and police representatives. Veolia became the sponsor in 2015.

Chemistry Council of New Jersey – The Chemistry Council of New Jersey represents the interests of over 100 New Jersey companies in the chemistry business. The organization’s mission is to advance member interests, operational and environmental excellence, science education and community outreach in New Jersey.

New Jersey Chamber of Commerce – The New Jersey Chamber of Commerce is a business advocacy organization based in Trenton. The State Chamber represents its members on a wide range of business and education issues at the State House in Washington. The organization also links the state’s local and regional Chambers on issues of importance through its grass roots legislative network. The Chamber’s goal is to represent the varying interests of its members and help them clear burdensome regulatory hurdles that stifle growth.

Local Fund Raising Support

Middlesex Boro Fire Department Middlesex Boro Rescue Squad Middlesex Police Department Bound Brook Fire Department Piscataway Township Fire Department Bound Brook High School (Robotics team) Middlesex school system (Officer Phil program)

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10. Middlesex Training Program

Page 1

Personnel Training Programs

Training Program

OVERVIEW – Veolia has developed an extensive Health and Safety training program for facility personnel who are involved in or related to hazardous materials and/or waste functions at the facility. These employees include, but are not limited to, the following job titles: Material Handler, Distillation Operator, Lab Technician, Maintenance Mechanic, and Process Engineer.

Each job title has a written job description which includes the duties and responsibilities relating to hazardous substances, and necessary training to qualify for the positions.

NEW EMPLOYEE ORIENTATION – All new employees are trained and certified to either 24-hour or 40-hour level in accordance with 29 CFR s1910.120. In addition, new employees receive site specific Safety and Emergency Orientation training which covers the following:

1. Safety rules and responsibilities.2. Site management and emergency contacts.3. Location of all safety equipment and supplies.4. Emergency and evacuation procedures.5. Accident & incident reporting.6. Smoking and break locations.

ON-THE-JOB TRAINING – Once the above classroom instruction is completed, the new employee will engage in the On-the-Job (OJT) Training program. This site-specific training will be provided by a trained and experienced employee who has been trained in hazardous waste management procedures and site specific Standard Operation Procedures (SOPs). Veolia has always used a mentorship approach to on-the-job training for all new employees involved with hazardous waste operations.

Facility personnel shall successfully complete this program within six months after their date of employment or assignment to a new position at Veolia. The on-the job training is to include, but is not limited to, the following topics:

1. Equipment Use and Standard Operating Procedures2. Operating data collection and entry3. Actual equipment start-ups and shutdowns4. Control and adjustment of operating conditions5. Unloading procedures for Tank Wagons, Tank Cars, and Storage Tanks6. Loading procedures for Tank Wagons, Tank Cars, and Storage Tanks7. Drum transfers, including drum pumping and drum filling8. Blending operations

Additional specialized training may include the following topics: distillation operations, powered industrial equipment, hot work procedures and confined space entry.

ANNUAL REFRESHER TRAINING – Veolia provides its employees with a minimum of eight (8) hours of annual refresher training in 1-2 hour biweekly training sessions, throughout the year. This refresher training has been designed to incorporate OSHA (29 CFR 1920.120), RCRA (40 CFR 265.16/ N.J.A.C. 7:26-9.4G), and DOT (HM-126F) training requirements.

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Page 2

Annual Refresher Training topics include, but are not limited to, the following:

1. Confined Space Entry Procedures2. DOT (HM-126F) training3. Emergency Contingency and Response Plan and DCR Plan (includes a minimum of an annual

drill)4. Evacuation Drill5. Fire Extinguisher Training6. Hazard Communication Program (with MSDS workshop)7. Hazwoper/RCRA Overview8. Personal Protective Equipment Program9. Respiratory Protection Program

Standard Operating Procedures used for handling hazardous substances, when new or updated, are trained on with all operations employees. These reviews are either completed as a group or one-on-one training.

Training Records

For each training session records are maintained on the Middlesex Employee Training Log. The log includes the name of the attendees, the date & time, location of training, and the topic of training. Annual training records are maintained on a spreadsheet that identifies the department, employee name, job title and date of completed training.

Written job descriptions are also maintained for all personnel. The job descriptions indicate the requisite skill, education, and other qualifications, as well as, the duties of employees assigned to each position.

Facility and operations personnel are evaluated annually by means of performance appraisals. These evaluations include critiques of the employee’s ability to carry out waste handling and safety procedures, and his/her knowledge of hazardous communication, chemical awareness and general operating procedures.

All training records on current employees will be kept until the closure of the facility. Training records on former employees are kept for at least three (3) years from the date the employee last worked at the facility.

Contractor Training Requirements

At a minimum, all Contractor employees must be trained in accordance with 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response, and 29 CFR 1910.1200, Hazard Communication. Other training may be required as dictated by work-task or other regulatory requirements.

Veolia reserves the right to request from the Contractor documentation or certification that an employee has received such training, and to refuse job site admission to any Contractor employee who has not received proper training.

Other requirements for the use of contractors are identified in the Contractor Safety Policy established by Veolia's Safety and Environmental Health Department. This policy includes a Contractor Safety Questionnaire that must be completed and approved, and the Contractor Safety Rules that are reviewed with all contractors.

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11. 5 - Year OSHA Summary

Veolia ES Technical Solutions125 Factory Lane

Middlesex, NJ 08846

OSHA 300 Log Summary2014 - 2018

SIC Code – 4953NAICS Code – 562211

2014 2015 2016 2017 2017

Fatalities 0 0 0 0 0

Restricted and Lost Workday Cases 1 1 1 0 0

Lost Workday Cases 0 0 0 0 0

Medical Attention Only Cases (First Aid Only) 9 7 7 3 5

OSHA Recordable Cases 1 1 2 0 2

Employee Hours 135,000 113,500 110,900 109,960 111,315

Recordable Injury Case Rate 1.48 1.76 3.61 0.00 3.59

Lost-time Injury Case Rate 0.00 0.00 0.00 0.00 0.00

Number of Lost Workdays 0 0 0 0 0

Severity Rate 0.00 0.00 0.00 0.00 0.00

EMR Rate 0.82 0.75 0.46 0.48 0.51

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12. 5 - Year Compliance History

Veolia ES Technical SolutionsMiddlesex, New Jersey Facility (NJD 002 454 544)

Compliance History (2013 – Present)

Location Date Description Penalty

Middlesex, NJTSDF

7/18/13NJDEP Air Permit NOV – Failure to meet the conditions of two air permits. Stack height on Auger discharge & pump rate on 100 tank-farm.

$3,000NEA 140001

Middlesex, NJTSDF

12/18/13NJDEP Compliance Plan NOV – Failure to prevent a spill outside containment (1 Liter). The spill was immediately remediated.

No Penalty

Middlesex, NJTSDF

7/30/14NJDEP Air Permit NOV – Storage tank permit violation for exceeding the annual VOC permitted emissions.

$1,500NEA 140002

Middlesex, NJTSDF

8/28/14NJDEP Compliance NOV – Failure to label one container in-storage with the words “Hazardous Waste”.

$3,375NEA 150001

Middlesex, NJTSDF

11/25/14OSHA Violation – Unintentional escape of flammable vapors from a storage vessel.Date of settlement meeting – 7/2/2014

$3,400(983521.015)

Middlesex, NJTSDF

3/2/15OSHA Violation – Two violations related to the site PSM program.Date of settlement meeting – 9/4/2014

$5,500(993386.015)

Middlesex, NJTSDF

4/26/16EPA Violation – Not monitoring pumps monthly as required by Subpart BB, and not closing drums immediately after sampling.

$36,600(2016-7101)

Middlesex, NJTSDF

5/13/16NJDEP Violation – February 2016 inspection. Staging a tank-wagon containing hazardous waste outside containment.

$12,000PEA 160001

Middlesex, NJTSDF 9/13/16

NJDEP Violation – Failure to close a wastecontainer prior to leaving the area. Pending

Agency Contacts:Agency Contact Phone NumberNJDEP - Waste Tiffany Chiles 609-439-6405NJDEP – DPCC Sunday Ogunsola 609-633-0610NJDEP – Transportation Lawrence Lewis 609-209-1762NJDEP – Air Kevin Eichman 609-292-3187NJDEP – Water Anthony Rotondo 609-584-4200EPA – Region II John Wilk 212-637-4130MCUA – Water Richard Bartz 732-593-2536

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13. Veolia Insurance Coverage Summary

A Summary of Property, Liability, and Casualty Insurance Protection for Veolia and its Subsidiaries

Veolia offers a very generous and strong indemnity program which is backed by our financial strength, and our unique ability to assume responsibility for conforming waste once it is within the control of Veolia. This indemnity is intended to offer complete assurance to our customers that there are Veolia financial resources available to cover any liability, loss, or damage resulting from or arising out of our negligent acts, omissions, or willful misconduct in performance of the work.

Veolia can and will agree in all instances to be responsible for any and all loss or damage caused by our own acts of negligence, willful misconduct, or breach of the Agreements we enter into. However, as good stewards of our insurance program, and in an effort to effectively manage risks, Veolia prefers to assume an indemnity obligation that requires us to indemnify for any loss or damage that is caused by our own negligent acts, negligent omissions, willful misconduct or breach of the Agreement.

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L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

CLEAN HARBORS, EL DORADO, ARKANSAS

Facility Audit: El Dorado, AR

Table of Contents

1.0 General Company Information ......................................................................................................................... 2 Introduction ......................................................................................................................................................... 2

2.0 Facility Information .......................................................................................................................................... 3

Facility Overview................................................................................................................................................ 3 Facility Site Plan ................................................................................................................................................. 4 Facility History ................................................................................................................................................... 4 Facility Locale .................................................................................................................................................... 5 Climatology and Regional Hydrogeology .......................................................................................................... 5

Security ............................................................................................................................................................... 6 Directions to Facility........................................................................................................................................... 7

3.0 Operating Licenses and Permits........................................................................................................................ 8

Permit Summary ................................................................................................................................................. 8 Principal Operating Licenses/Permits ................................................................................................................. 8 Principal Contacts/Agencies ............................................................................................................................... 9

4.0 Process Description ......................................................................................................................................... 10 Waste Analysis.................................................................................................................................................. 15 Safety and Training ........................................................................................................................................... 22

5.0 Closure Plan .................................................................................................................................................... 25 6.0 Insurance ......................................................................................................................................................... 25

7.0 Financial Information...................................................................................................................................... 26 8.0 Appendix ......................................................................................................................................................... 26

2

1.0 General Company Information

Introduction

Clean Harbors is the leading provider of environmental, energy and industrial services

throughout North America. The Company serves a diverse customer base, including a majority

of the Fortune 500 companies, thousands of smaller private entities and numerous federal, state,

provincial and local governmental agencies. Through its Safety-Kleen subsidiary, Clean Harbors

also is a premier provider of used oil recycling and re-refining, parts washers and environmental

services for the small quantity generator market.

Within Clean Harbors Environmental Services, the Company offers Technical Services and Field

Services. Technical Services provide a broad range of hazardous material management and

disposal services including the collection, packaging, transportation, recycling, treatment and

disposal of hazardous and non-hazardous waste. Field Services provide a wide variety of

environmental cleanup services on customer sites or other locations on a scheduled or emergency

response basis.

Within Clean Harbors Energy and Industrial Services, the Company offers Industrial Services

and Oil & Gas Field Services. Industrial Services provide industrial and specialty services, such

as high-pressure and chemical cleaning, catalyst handling, decoking, material processing and

industrial lodging services to refineries, chemical plants, pulp and paper mills, and other

industrial facilities. Oil & Gas Field Services provide exploration, surface rentals, solids control,

and environmental services to the energy sector serving oil and gas exploration, production, and

power generation.

Clean Harbors' Safety-Kleen subsidiary is a leading North American used oil recycling and re-

refining, parts washers and environmental solutions company for small quantity waste generators

supported by the largest re-refining capabilities to convert used oil into base and blended lube

oils. Safety-Kleen provides a broad set of environmentally-responsible products and services that

keep businesses in balance with the environment.

Headquartered in Norwell, Massachusetts, Clean Harbors has waste disposal facilities and

service locations throughout the United States and Canada, as well as Mexico and Puerto Rico.

3

2.0 Facility Information

Facility Overview

Clean Harbors El Dorado LLC, a subsidiary of Clean Harbors, Inc. headquartered in Norwell,

Massachusetts, owns and operates a hazardous waste incineration facility located in El Dorado,

Arkansas. This facility is has been permitted by the Arkansas Department of Environmental

Quality (ADEQ) to receive, store, and incinerate a variety of waste streams.

Facility Name:

Clean Harbors El Dorado, LLC

Location:

309 American Circle

El Dorado, AR 71730

County: Union

Facility Owner:

Clean Harbors El Dorado LLC

309 American Circle

El Dorado, AR 71730

Property Owner:

Clean Harbors El Dorado LLC

309 American Circle

El Dorado, AR 71730

Facility I.D. No.:

ARD069748192

Permit Type:

RCRA Permitted

Waste Description:

RCRA and CERCLA organic and inorganic wastes

Services Provided:

Incineration, Storage, Transfer, Recycling: Solvents, Fluorescent bulbs

4

Facility Site Plan

5

Facility History

The site was used for industrial purposes as a petroleum refinery beginning in 1921. The last

owner was American Oil Company which discontinued operations in 1972. In 1974, the El

Dorado facility opened and began limited operations. In 1977, the facility received a permit

from the ADEQ to incinerate hazardous waste. In 1981, the facility became one of the first

companies in the United States authorized under the EPA to destroy PCB’s and PCB

contaminated waste by incineration.

In 1985, Clean Harbors El Dorado’s RCRA Part B application was submitted to the ADEQ.

Effective July 2, 1988, Clean Harbors El Dorado facility achieved the milestone of becoming one

of the nation’s first commercial incineration facilities to receive its final Part B permit. The Part

B permit issued by ADEQ in conjunction with the EPA Region VI authorized Clean Harbors El

Dorado to destroy RCRA and CERCLA wastes for a period of 10 years. In December, 2006,

Clean Harbors El Dorado submitted its 10 year renewal permit which was found administratively

complete. That permit renewal was granted in March, 2008.

Facility Locale

The site is located east of El Dorado in Union County, Arkansas. The main gate of the facility is

approximately 5,000 feet south of the intersection of Arkansas Highway 63 and US Highway

167. Clean Harbors El Dorado owns approximately 370 acres; however, only 50 acres are

currently utilized for active waste management.

The nearest residential neighbor is approximately ½ mile west of the site. Various industries

border the facility to the north while natural forested areas form the south and east borders.

Downtown El Dorado is approximately 1-½ miles west of the site.

Climatology and Regional Hydrogeology

Prevailing winds are generally from the south. Average rainfall at the site is approximately 60

inches.

The Clean Harbors El Dorado site is supplied by city well water. The nearest city well water

source is located within approximately 1 mile of the site at a depth of 755 feet.

The nearest surface watercourse is Boggy Creek, a tributary of Bayou de Loutre, running through

the eastern portion of the site. Clean Harbors El Dorado’s discharge to this watercourse is that of

on-site accumulated stormwater and treated groundwater. Hazardous waste is not treated in the

wastewater treatment plant. All waste is handled on site. The facility is approximately 240 feet

above sea level.

Surface water run-on and run-off is controlled by a series of open channels and diked retention

ponds. Stormwater that falls over non-active plant areas is retained in several retention ponds

6

until it is pumped into the wastewater treatment plant. The water then enters through a sand and

clay filtration system, Treated water is discharged into Boggy Creek under an NPDES permit.

Active portions of the facility are located outside the 100 and 500-year floodplains of Boggy

Creek. The facility is not located in a recharge zone of a sole-source aquifer. The uppermost

aquifer underlying the Clean Harbors El Dorado El Dorado site is the Cockfield formation which

consists of alternating zones of fine sands inter-bedded with clay lenses to zones of clean, fine

sand without clay. Formation thickness ranges from approximately 150 feet in the northwest area

of the site to about 200 feet near Boggy Creek. The ratio of sand to clay varies in the inter-

bedded zones of the formation. Clay lenses range from less than one inch to more than several

feet in thickness and are discontinuous. Laboratory permeability tests were performed on

selected formation samples collected during a hydrogeologic study. The results typically

indicated values ranging from 10- 3cm/sec for sands to 10-9cm/sec for clays.

The Cockfield formation overlies the Cook Mountain formation, also being a part of the

Claiborne group. The major components of the Cook Mountain formation are shale and clay.

Because of its thickness and low permeability, the Cook Mountain formation is a known

confining layer separating the Cockfield from the deeper Sparta formation.

Groundwater occurs in all layers discussed except the Cook Mountain formation with water

occurring throughout the entire Cockfield formation. General groundwater flow is to the

southeast. There are no underlying aquifers that are hydraulically interconnected with the

Cockfield formation at or near the Clean Harbors El Dorado site. Clean Harbors El Dorado’s

facility has installed over 100 monitoring wells across the facility. These are sampled and

analyzed quarterly.

Regarding the Seismic Standard, the facility is located in Union County, Arkansas. The facility

location is not listed in 40 CFR 264, Appendix VI; therefore, no further information is required

to demonstrate the facility's compliance with the seismic standards of the federal regulation.

Security

Access to the Clean Harbors El Dorado facility is controlled by a surveillance system utilizing

guards, operating personnel and surveillance cameras. This surveillance is conducted on a 24-

hour basis, seven days per week by Clean Harbors El Dorado employees. Natural barriers and a

cyclone fence secure the property, which is six feet high and topped with barbed wire. The

north, south, east and west boundaries are fenced and the east boundary is restricted by Boggy

Creek and surrounding bottomlands. The plant boundaries are severed on the east and west sides

by a Union Pacific railroad track. The track has sign placards at each of the facility’s boundaries

and on both sides of the railroad tracks. It is monitored by security with video surveillance

cameras.

Clean Harbors employees man the north gate at all times. Access for all personnel entering and

waste shipped to the site is controlled through this gate. Visitors entering the premises require

prior approval as well as a Clean Harbors El Dorado employee escort.

Security controls utilize both internal and external communications. Internal communications

include: telephone, mobile radios, cellphones, 2 way radios (hand held), sirens, auto alarms.

7

External communications are with the local emergency response agencies. Clean Harbors El

Dorado also posts the necessary warning signs along the site perimeter to help prevent

unauthorized access into the facility.

Directions to Facility

Clean Harbors El Dorado, LLC

309 American Circle

El Dorado, AR

870.863.7173

From Little Rock, AR: (Approximately 2 hours, 30 minutes)

I-440 to Hwy 65-167 South. Hwy 167 South splits from Hwy 65.

Continue on 167 South passing through Sheridan, Fordyce and Hampton.

Exit onto Main Street going east (left).

Turn right onto American Road. Facility is at the end of American Road.

From Monroe, LA: (Approximately 1 hour 45 minutes)

I-20 West to Ruston, LA. Hwy 167 North from Ruston to El Dorado, AR.

Exit onto Main Street going east (right).

Turn right onto American Road. Facility is at the end of American Road.

From Shreveport, LA: (Approximately 1 hour 45 minutes)

I-20 East to Ruston, LA.

Hwy 167 North from Ruston to El Dorado, Hwy 167,

Exit onto Main Street going east (right).

Turn right onto American Road.

Facility is at end of American Road.

8

3.0 Operating Licenses and Permits

Permit Summary

The Arkansas Department of Environmental Quality (ADEQ) is the authority governing the

generation, treatment, storage, and disposal of hazardous wastes within the State of Arkansas.

An ADEQ inspector is assigned to and is located at the El Dorado facility.

Permit Type/Governing Agency

Permit No.

Expiration Date

RCRA Part B

10H-RN2

June 26, 2028

NPDES

AR0037800

September 30, 2021

AIR

1009-AOP-R16

December 26, 2018

Principal Operating Licenses/Permits

Copies of existing permits which detail types of waste management licensed capacities and waste

types accepted are available for inspection upon request at the site.

9

Principal Contacts/Agencies

The list of contacts below can provide additional information regarding Clean Harbors El

Dorado’s facility operations or compliance:

Operations:

Barry Boshears, Facility Incineration Manager

Clean Harbors El Dorado LLC

309 American Circle

El Dorado, AR 71730

870.863.7173

Regulatory:

Kathleen Shoemaker

Senior Compliance Manager

Clean Harbors El Dorado LLC

309 American Circle

El Dorado, AR 71730

870.863.7173

(RCRA Compliance)

Arkansas Department Environmental Quality

5301 North Shore Drive

North Little Rock, AR 72118

501.682.0850

Carolyn Pollard

(Permitting)

Arkansas Department Environmental Quality

5301 North Shore Drive

North Little Rock, AR 72118

501.682.0601

Nick Jones

10

4.0 Process Description

Clean Harbors El Dorado incineration capacity in El Dorado is 122,050 lbs/hour. Clean Harbors

El Dorado’s incineration capacity is broken into two units. The capacity for the Kiln 1 & 2 Unit

with its associated Secondary Combustion Chamber (SCC) is 57,152 lbs/hour and 3,873 lbs/hour

for the Waste Fired Boiler. The capacity for the Kiln 44 Unit with its associated SCC is

61,025 lbs/hr.

Unit Processes

Unit Process Operating Temperature Average Retention Time

Rotary kiln #1 1,200 - 2,150F 0.75-1.5 hours(solids)

Rotary kiln #2 1,205 - 2,050F 0.5-2.0 hours(solids)

SCC 1,800 - 2,300F 2 seconds

Waste Fired Boiler 1,800 - 2,400F 2 seconds

Rotary Kiln #44 1,200 - 2,150F .5- 2.0 hours (solids)

SCC 44 1,800 - 2,300F 2 seconds

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Process Description

RCRA liquids are fed into the rotary kilns and the SCC, depending on the specific characteristics

of the waste. RCRA solids and sludges may be received from the customer, packaged for ram

feed into the rotary kilns, repacked by Clean Harbors El Dorado personnel for ram feed or fed

directly into the kilns through an automated shredder auger machine. This system enables Clean

Harbors El Dorado to accept waste that is packaged in any size Department of Transportation

(D.O.T.) approved container.

Liquid waste, natural gas and combustion air are fed into the rotary kilns to initiate and maintain

temperature. Three rotary kilns are utilized for treatment of solids and sludges. Shredded solids

enter the incinerators via the screw-type auger systems, or they may be repackaged for ram feed.

Exiting ash from the kilns are collected and stabilized in an enclosed building. Each batch of ash

is tested to ensure that organic treatment standards have been met. Ash will then be taken to a

fully permitted hazardous waste landfill for disposal. The gases travel through a duct to the

SCC. Additional liquid wastes are injected in the SCC to maintain temperature and react all of

the remaining organics with oxygen to produce water vapor, carbon dioxide and acid gases.

The SCC for Kilns 1 and 2 exit gas stream is continuously sampled and monitored for oxygen.

The flue gas from the SCC enter the saturator. Within the saturator, the gas stream is cooled to

below 200 degrees Fahrenheit and acid gases are neutralized with lime slurry. The resulting

calcium chloride and ash solution are purged from the saturator and sent to the brine unit. The

gases exiting the saturator enter two condenser columns whose function is to condition the

particulate matter for easier removal downstream. From the condenser columns the gases pass

through a high energy scrubber on the way to the fabric filter (baghouse). Powdered lime and

carbon are fed into the fabric filter to react and remove any remaining pollutants in the gas

stream. The high energy scrubber and fabric filter ensure that the final flue gas exiting through

the stack meet all of the emissions standards promulgated by RCRA and the Clean Air Act.

Vacuum is maintained on the entire incineration and air pollution control system by an induction

fan which discharges the final clean gases into the 195 foot tall stack.

The SCC for Kiln 44 exit gas stream is continuously sampled and monitored for oxygen. The

flue gas from the SCC enters a spray dryer for gas conditioning. The spray dryer rapidly cools

the combustion gases as they exit the thermal treatment devices. The gas stream then passes into

baghouse #1 for removal of particulate matter. The gases form baghouse #1 are routed to a

saturator followed by two parallel condenser towers. After passing through the condensing

towers, the gas is routed to a demister. The combination gases are then reheated with a direct

fired natural gas burn to prevent condensation of moisture. Once the temperature of the

combustion gases is elevated above the dew point temperature, the gases enter baghouse #2 for

removal of remaining pollutants of the gas stream. The treated combustion gases then pass

through the ID fan and a DeNox unit to ensure that the final flue gas exiting through the stack

meet all of the emissions standards promulgated by RCRA and the Clean Air Act. The final

clean gases into the 199 foot tall stack.

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14

Solvent Recycling Program

Clean Harbors El Dorado has constructed a solvent recovery plant that consists of a vacuum pot

distillation unit, heat exchangers, cooling towers and storage tanks. The facility can accept a

variety of organic solvents for recycling. The facility can receive the solvents in drums, totes

and bulk tankers.

The waste solvents are sent for processing through the vacuum pot distillation unit in batches.

By varying the pressure and temperature solvent product is recovered for resale.

Lamp Recycling Systems

Clean Harbors Eldorado has a lamp recycling system which processes fluorescent lamps. The

bulbs are crushed and separated into glass, end caps and phosphor powder. The glass and end

caps are sent for recycling. The phosphor powder is sent offsite for mercury retort.

Storage Facilities

Containers:

All containerized wastes are stored in a covered warehouse with concrete-sumped floors and

loading docks. In addition, all warehouses are also constructed with the required minimum six

inch, continuous curbing and impervious coating. All liquid wastes are pumped into bulk storage

tanks and fed into the incinerators via above-ground piping. No underground tanks or surface

impoundments are utilized by the facility. Total RCRA solids containerized storage capacity is

1,484,285 gallons (26,987 55-gallon drums or equivalents). The total RCRA Solid Storage in

Roll Off containers is 608,168 gallons or 138 roll off bins. The El Dorado facility also has 2

Bulk Roll Off Storage areas.

In addition to the 204 warehouse, Clean Harbors El Dorado has seven storage vaults for isolating

containerized wastes. The vaults separate oxidizers and dangerous when wet wastes from the

wastes stored in the 204 warehouse. The vaults have inside compartments with 4-hour rated fire

walls. The oxidizer vaults also have hard piped automatic fire detection and suppression systems

that quickly detect and extinguish fires.

15

Tanks:

All storage tanks are constructed of carbon steel and have high level warning and protection

systems. The tanks are explosion protected with nitrogen blanketing and are vented through

activated carbon filters. Secondary containment is provided for each storage tank which includes

concrete pads lined with 60 mil high density polyethylene liners or concrete dikes with an epoxy

liner. The containment around each tank is sufficient for 110 percent of the tanks’ total

capacity. Only compatible wastes are stored in the same tanks. Total RCRA liquid tank storage

capacity is 1,575,990 and RCRA solid tank storage capacity is 340 cubic yards.

Included in this capacity, Clean Harbors El Dorado utilizes a “day tank” system of mechanically

agitated RCRA storage tanks which provide consistent liquid feed to the incineration system.

Leak detection systems for the tanks include ultrasonic, visual, and automatic detection systems.

Tanks are inspected visually each shift for leaks. Daily inspections are conducted for overfill

protection controls and monitoring equipment. Non-pumpable wastes are maintained in their

original shipping containers and are stored in the warehouses for feed into the rotary kilns.

Waste Analysis

The purpose of the Waste Analysis Plan (WAP) is to document the necessary procedures

undertaken for all wastes which enter the facility for storage, treatment and disposal. The WAP

delineates the following:

Pre-Acceptance (Approval) Procedures - to determine the acceptability of the waste pursuant to

the facility permit conditions, land disposal restrictions and waste management capabilities

prior to receipt of the waste.

Receiving Procedures - to fingerprint and verify that incoming waste shipments match

accompanying manifest and pre-acceptance criteria under which the waste was accepted.

Waste Management procedures - to assure proper and safe methods of storage, treatment and

management of wastes at the facility.

Lab Methodology and QA/QC - to assure that proper methods of analysis, analytical equipment

and quality assurance programs are being maintained.

Residue Disposal Procedures - to assure that resultant residues from treatment are managed and

disposed of in accordance with land disposal restrictions.

The WAP tracks a waste, starting with the examination of a sample and profile information by

the generator through management at the facility and finally, disposal from the facility.

Initial Waste Evaluation

A profile is submitted to the Clean Harbors Central Profile Group. Also submitted include the

following:

A WMPS form (hard copy or electronic) is prepared which is used to compile information

about the customer's waste. The computerized WMPS serves to notify appropriate personnel

16

of the condition under which the material will be accepted. Upon receipt the controlling

source document for tracking purposes becomes the manifest.

No unknown wastes will be disposed until they are tested and a thorough evaluation is made.

This includes a review of the El Dorado permit requirements, waste characterization and

review of the plant operations that produced the waste.

Material Safety Data Sheets are the primary constituents of the waste, unless Material Safety

Data Sheets are already available at the Clean Harbors El Dorado facility.

Any laboratory analyses, technical data, or other information regarding composition,

chemical and physical properties of the waste that the generator may make available.

Determination of whether the waste or extract is restricted from land disposal.

Based on the completeness of the above information, a decision is made whether additional

analyses are necessary.

Pre-Shipment Procedures

The Customer is notified of acceptance/rejection of the waste by a computer message. The

Approvals Group will have entered details concerning type of material, area of receiving or

storage and type of handling, including any special consideration.

The CSR and Sales Group will follow the procedures for setting up a customer including

receiving a fully executed Standard Agreement, signed quote and credit check.

The CSR Group then notifies the customer and sets up a pick-up of accepted wastes. All

necessary information for the shipment is requested by the CSR. If the customer prepares their

own paperwork, the manifest must be faxed to the CSR prior to the receiving date. The CSR will

create a sales order from this paperwork after reviewing for errors thus ensuring the paperwork is

in order before receipt. The procedure enables the shipments to be received without any major

delays and is important in minimizing demurrage charges for customers.

Post-Shipment Procedures

Upon entering the facility, the transporter is checked by security at the north gate and directed to

the respective receiving department. The paperwork is delivered to the Data Entry personnel

who then confirm the information is accurate and correct.

If there are any inaccuracies or errors, the paperwork is sent to the CSR who works with the

customers to correct any issues prior to receiving.

The correct paperwork then is sent to the receiving warehouse for off loading. The receiving

personnel check waste for gamma radiation regardless of the waste type. Further, they perform a

visual inspection, noting:

Shipment label match the manifest

Any irregularities in the shipment (e.g., leaks)

If the number and type of containers match the manifest

17

If the waste appearance matches previously noted descriptions of consistency and physical

state (i.e., solid, sludge, liquid)

Clean Harbors El Dorado screens all incoming shipments by basing key parameters/fingerprints

on these criteria. The "fingerprints" or key parameters may include: heat of combustion, total

halogen and ignitability; and for liquids, pH, and flash point. These and additional analyses may

be performed subsequent to placement in storage, particularly for waste to be shipped to an off-

site TSDF. Metals data used may consist of Clean Harbors El Dorado lab test data from either

the shipment receipt sample or data supplied by the customer or a combination. Also, analytical

information may be transferred from other Clean Harbors El Dorado laboratories by facsimile,

electronically, or by hard copy with the specific truck.

The generator must submit to Clean Harbors El Dorado an analysis or updated profile of each

waste stream performed at least annually.

Waste Tracking System

Clean Harbors El Dorado has a state-of-the-art computer system that assures accurate waste

tracking. Clean Harbors El Dorado utilizes computer systems to ensure detailed waste tracking.

Waste tracking begins when a customer contacts the CSR Group to request a pick-up or schedule

a customer routed delivery of an approved waste stream, and will continue until the waste has

been completely treated and/or disposed of. Movement of each container of waste is tracked by

the use of a bar code labeling system. Pertinent information about the waste is listed on the bar

code. Whenever a container is moved, our employees, using hand-held bar code scanners which

relay the container’s new location to the computer system, scan it.

When the material gets to the kiln, the container is scanned. This advanced system also tracks

waste that is sent off-site. Immediately prior to loading a container on a vehicle for shipment

off-site, its bar code label is scanned to record that the material has been shipped to the specific

treatment/disposal facility.

Types of Wastes Accepted

Clean Harbors El Dorado facility accepts hazardous and non-hazardous waste from off-site

generators and treatment, storage and disposal (TSD) facilities. The wastes accepted include:

RCRA Regulated Wastes:

Liquid - Aqueous, oils, petroleum products, organic solvents and other liquids suitable for

treatment by incineration or energy recovery. These wastes are accepted in drums, bulk tankers,

bulk rail cars and other suitable DOT approved containers and are to be pumped to tanks

incinerated directly, blended in tanks for energy recovery, or transferred off-site for other

treatment or disposal.

Solids - Contaminated soils, debris, sludges, spill cleanup materials and other solid materials

packaged in drums, roll-offs, boxes and other suitable containers. These wastes are incinerated

directly or are transferred off-site for other treatment or disposal. Dispersible solids and sludges

may also be blended with liquids for energy recovery, in Clean Harbors El Dorado’s on-site

boiler, or to an off-site energy recovery facility.

18

Gases, cylinders, and aerosol cans. Pressurized gases in suitable DOT regulated tanker trucks and

portable tanks or containers may be processed by direct feed to the kilns and/or the SCC. Gases

classified as explosive, and Class A poisons are prohibited.

Non-Hazardous Wastes:

Non-regulated solid and/or liquids for which a generator has chosen incineration as a means of

treatment or alternate disposal (i.e. Aerosols, Consumer Commodities) are accepted in drums,

bulk tankers, bulk rail cars, or other suitable containers.

Lab Pack Wastes:

Lab pack wastes and other wastes, which are amenable to incineration or alternate treatment as

defined by 268.42(c), are placed in the appropriate drum storage area as received. These wastes

are then repackaged, as necessary, into appropriate size containers for incineration. This

repackaged material is subsequently transferred to the incineration area for treatment or

transferred off-site for other treatment or disposal.

Aerosols:

Thin walled pressurized aerosol containers (RCRA regulated and non-regulated consumer

commodities) which are amenable to incineration or alternate treatment as defined by Regulation

23, 268.42(c) are received into the warehouse for inspection and receipt and stored in a contained

storage area prior to processing.

Based on the hazardous waste classification of the aerosols and review of the submitted profile

and/or other technical information, the Approvals group will determine the acceptance of the

material, proper handling, and proper treatment and/or disposal. The sample requirement at

receipt is waived due to the nature and packing of the aerosols.

The aerosol containers may be repackaged, as necessary, transferred to the incineration area for

subsequent treatment, transferred off-site for alternate treatment and disposal, or processed by

direct feeding into the incinerators.

Cylinders:

Pressurized cylinder containers (RCRA regulated and non-regulated) which are amenable to

incineration or alternate treatment as defined by Regulation 23, 268.42(c) are received into the

warehouse for inspection and receipt and stored in a contained storage area prior to processing or

shipment to alternate treatment facility.

Determination of the proper handling and treatment will be made by Clean Harbors Technical

Services group based on review of a submitted profile and/or other technical data supplied by the

generator or requested by the Clean Harbors Technical Services.

Cylinders may be processed by direct feed to the incinerators or prepared for shipment to an

alternate facility for final treatment and disposal.

Unacceptable Waste Codes (Subject to Modification; see your Clean Harbors Representative.)

19

Waste Codes not included in the Clean Harbors El Dorado RCRA Permit

D003 Reactivity (if due to explosivity)

F020 Tetrachlorophenol wastes

F021 Pentachlorophenol wastes

F022 Tetra-, penta-, or hexachlorobenzene wastes

F023 Tri-, tetrachlorophenol wastes

F026 Tetra-, penta-, or hexachlorobenzene wastes

F027 Discarded unused formulations of tri-, tetra-, or pentachlorophenol

F028 Residues from incineration of soil containing F020, F021, F022, F023, F026 and F027

P009 2,4,6-trinitrophenol (Ammonium picrate)

P065 Mercury fulminate

P081 Nitroglycerine (non-pharmaceutical waste streams)

Restricted Clean Harbors El Dorado Waste Codes - case by case review

D003 Reactivity (Explosive sub-category - No exceptions)

F039 Leachate (Dioxin content)

K043 2,6 - Dichlorophenol waste from production of 2,4-D (Dioxin, furan content)

K088 Spent potliners from primary aluminum reduction

K090 Emission control dust or sludge from ferrochromium silicon production

K091 Emission control dust or sludge from ferrochromium production

K099 Untreated wastewater from production of 2,4-D (Dioxin, furan content)

20

Unacceptable Bulk Waste Codes for Incineration (Specified technologies other than

incineration)

D006 Cadmium batteries RTHRM

D008 Lead acid batteries RLEAD

D009 High mercury sub-category (inorganic only) RMERC

K069 Non calcium sulfate (high lead) subcategory RLEAD

K106 High mercury sludge( >260 mg/kg mercury) RMERC

P015 Beryllium dust RMETL or RTHRM

P056 Fluorine ADGAS FB NEUTR

P076 Nitric oxide ADGAS

P078 Nitrogen dioxide ADGAS

P087 Osmium tetroxide RMETL or RTHRM

P113 Thallic oxide RTHRM or STABL

P115 Thallium Sulfate RTHRM or STABL

P119 Ammonium vanadate STABL

P120 Vanadium pentoxide STABL

U134 Hydrogen fluoride NEUTR

U151 Mercury, high level RMERC

U214 Thallium (I) acetate RTHRM OR STABL

U215 Thallium (I) carbonate RTHRM OR STABL

U216 Thallium (I) chloride RTHRM OR STABL

U217 Thallium (I) nitrate RTHRM OR STABL

TSD Status for Unacceptable Incineration Codes Accepted at TSD

D006 Cadmium batteries Yes

D008 Lead acid batteries Yes

D009 High mercury sub-category (inorganic only) Yes

K069 Non calcium sulfate (high lead) subcategory Case by case

K106 High mercury sludge ( >260 mg/kg mercury) Case by case

P015 Beryllium dust Case by case

P056 Fluorine Case by case

P076 Nitric oxide Case by case

P078 Nitrogen dioxide Case by case

P087 Osmium tetroxide Case by case

P113 Thallic oxide Yes

P115 Thallic sulfate Yes

P119 Ammonium vanadate Yes

P120 Vanadium pentoxide Yes

U105 2.4 Dinitrotoluene Yes

U105 2.1 Dinitrotoluene Yes

U134 Hydrogen fluoride Yes

U151 Mercury, high level Yes

U214 Thallium (I) acetate Yes

21

U215 Thallium (I) carbonate Yes

U216 Thallium (I) chloride Yes

U217 Thallium (I) nitrate Case by case

Wastes excluded from Lab Packs under the Alternative Treatment Standards of [268.42(c)]

(Appendix IV, 40 CFR 268)

D009 Mercury

F019 Wastewater sludge - aluminum coatings

K003 Wastewater sludge - production of molybdate orange pigments

K004 Wastewater sludge - production of zinc yellow pigment

K005 Wastewater sludge - production of chrome green pigments

K006 Wastewater sludge - production of chrome oxide green pigments anhydrous)

K062 Spent pickle liquor

K071 Muds from mercury cell chlorine production

K100 Waste leaching solution from secondary lead smelting

K106 Wastewater sludge from mercury cell chlorine production

P010 Arsenic acid

P011 Arsenic pentoxide

P012 Arsenic trioxide

P076 Nitric oxide

P078 Nitrogen dioxide

U134 Hydrogen fluoride

U151 Mercury

22

Safety and Training

Safety Starts with Me: Live it 3-6-5

Safety is an ongoing occurrence in our lives, 365 days per year. Safety is in the forefront of what we

do at Clean Harbors and it is with this intent that we require each employee to acknowledge and

commit to this effort.

We reaffirm this commitment by adhering to our Safety Starts with Me campaign initiative called

Live it 3-6-5. Our Live it 3-6-5 initiative reinforces how safety is an ongoing effort at work and at

home. Live it 3-6-5 begins with our commitment to our 3 Safety Philosophies, 6 Golden Rules, and 5

Personal Reasons for Safety below.

3 Safety Philosophies 1. Nothing is worth getting injured over

2. All near misses and accidents are preventable

3. Safety must actively be managed

6 Golden Rules of Safety 1. I will drive responsibly without distractions or impairments

2. I will think before I start and know my safety plan every day

3. I will only undertake the work in which I am trained

4. I will take responsibility for my safety and those around me at work, home or in-transit

5. I will intervene in any unsafe act

6. I will report all incidents and near misses

5 Good Reasons Why I Want to Be Safe (Write your own 5 personal reasons that are meaningful to

you.)

Continually improving safety at Clean Harbors is our commitment. We believe that zero incidents is a goal we can achieve and that no one should get hurt while working at Clean Harbors. While experience has significant value in working safely, it doesn’t ensure wisdom in all our safety actions. Combining experience with proactive safety measures and reminders will help keep you and your coworkers safe. But it’s your 100% personal commitment to safety that will have the most impact on your safety and hat of your coworkers, family, and friends. We encourage you to apply the information and share it with your family, and friends.

23

Each employee is trained on the Clean Harbors El Dorado’s Injury and Illness Prevention Plan

which outlines basic safety procedures, contingency plan, and company policies. Training with

regard to employee safety is conducted regularly. Additionally, safety meetings are conducted

daily.

Personnel protective equipment for emergency use is distributed throughout the facility and

includes: hard hats, goggles, safety glasses, steel-toed safety shoes and boots, rain and acid suits,

rubber or plastic aprons, cloth overalls, tyvek and saranex suits, face shields, appropriate

respiratory protection including dust masks, self-contained breathing apparatus ("SCBA"), air-

supplied respirators and cartridge respirators. Emergency equipment includes:

Portable fire extinguishers throughout the facility

Spill control equipment

Safety showers

Separate source of supplied air for supplied air respirators and SCBAs

Emergency eye washers

Sprinkler and fire hydrant systems

Training

Safety is always an important issue at Clean Harbors El Dorado. We have developed a training

program in accordance with OSHA and RCRA regulations to ensure a safe workplace.

Employees are required to undergo a minimum of 24 hours of classroom hazardous waste

operations training prior to beginning any on-site work. During the training program, employees

are instructed on the following major topics:

The hazardous nature of chemicals and wastes

RCRA and the importance of maintaining regulatory compliance

Proper handling and storage procedures for wastes

Emergency and contingency plan procedures

Operation of equipment

Personal protective equipment

Facility operations

Spill prevention and control

Fire fighting

Respirator use and fit testing

First aid and CPR

24

Supervised on-the-job training is also required and provides additional specialized training.

Personnel also receive twelve 1-hour monthly modules. Throughout their tenure with Clean

Harbors El Dorado, key personnel also attend seminars and conferences involving hazardous

waste management.

Employees will not work in unsupervised positions until they have completed the training

outlined above.

Records documenting the job title, job description, names of employees and completed training

programs are kept in separate personnel training files at the facility. These records will be

maintained until closure of the facility for current employees and for three years from the date of

the individual employee's last day of employment for former employees.

Site/Facility Inspections

The facility inspection plan is designed to address the types of hazards which are inherent in the

materials Clean Harbors El Dorado handles and those which are associated with equipment used

in the process. Equipment is generally classified as follows:

Safety equipment

Processing equipment

Monitoring equipment

Storage equipment

Emergency equipment

Structures containments

Laboratory equipment

Fire protection equipment

Security devices

Inspection frequencies are based upon maximum deterioration rates and the realistic probabilities

that any given equipment malfunction or failure would impact human health or the environment.

Areas subject to spills, such as loading and off-loading, are also inspected. Containers are

inspected when off-loaded and are also inspected daily while in storage. Additionally,

unannounced inspections are conducted on a random basis by supervisory personnel.

Contingency Plan

Clean Harbors El Dorado’s Contingency Plan has been developed in accordance with 40

CFR § 264, Subpart D and describes the actions which facility personnel will take in response to

on-site emergencies.

The plan identifies Emergency Coordinators and describes their responsibilities with respect to

initiating and implementing the plan. The Emergency Coordinators designated in the plan are

authorized to commit resources necessary to ensure successful, expedient implementation.

25

Clean Harbors El Dorado places emphasis on training personnel in fire prevention and response.

This training covers specific responsibilities of facility personnel and the purpose, use and

location of on-site response equipment.

Clean Harbors El Dorado has identified the following agencies in its Contingency Plan as those

it may notify in the event of implementation:

USEPA Region VI

Arkansas Department Environmental Quality

Company Physician

El Dorado Fire Department

El Dorado Police Department

Union County Sheriff’s Office

Arkansas State Office of Emergency Services

Union County Judge

Medical Center of South Arkansas

Emergency response drills are conducted periodically at random throughout the year and include

drills for fires, explosions, tornadoes and spills.

5.0 Closure Plan A comprehensive facility closure plan has been developed in accordance with RCRA

requirements and is available at the site for inspection upon request. The Company utilizes both

insurance and surety bonds to meet the Financial Assurance requirements of each state.

View Facility Closure Certificate

6.0 Insurance Clean Harbors (including Safety-Kleen and all entities) presently carries general liability and

auto liability insurance providing coverage in the aggregate amount in excess of $40 million. The

Company purchases pollution liability insurance coverage in excess of $25 million for its fixed

sites for sudden and accidental occurrences. For waste in transit, which insures the Company

against liability for sudden and accidental occurrences during transit on a Company vehicle from

the time waste is picked up through its delivery to a disposal site the Company purchases

insurance in excess of $25 million.

View Certificate of Liability Insurance

26

7.0 Financial Information Financial information on Clean Harbors and its subsidiaries are available from the Clean Harbors

website in the Investor Relations section.

View Investor Relations Web Site

8.0 Appendix If applicable, supporting facility documentation will follow.

309 American Circle El Dorado, AR 71730 870.863.7173 www.cleanharbors.com

L:\Projects\Elcon\1065\EV201065.01\2001-01.docx\saq

CLEAN HARBORS, BRISTOL, CONNECTICUT

Facility Audit: Bristol, CT

Table of Contents

1.0 General Company Information ......................................................................................................................... 1 Introduction ......................................................................................................................................................... 1

2.0 Facility Information .......................................................................................................................................... 2 Facility Overview................................................................................................................................................ 2 Facility Site Plan ................................................................................................................................................. 3

Facility History ................................................................................................................................................... 4 Site Characterization ........................................................................................................................................... 4 Security ............................................................................................................................................................... 5 Directions to Facility........................................................................................................................................... 6

3.0 Operating Licenses and Permits........................................................................................................................ 7

Permit Summary ................................................................................................................................................. 7 Principal Operating Licenses/Permits ................................................................................................................. 7

Principal Contacts/Agencies ............................................................................................................................... 8 4.0 Process Description ......................................................................................................................................... 10

Inorganic Aqueous Waste Treatment ................................................................................................................ 10 Storage and Transfer of Waste Oils .................................................................................................................. 11 Inorganic Lab Chemical Treatment/Consolidation ........................................................................................... 11

Container/Tank Storage and Transfer ............................................................................................................... 11 Stabilization/Solidification of Characteristic Waste ......................................................................................... 11

PCB Management ............................................................................................................................................. 11 Dismantling Process.......................................................................................................................................... 11 Waste Analysis.................................................................................................................................................. 12

5.0 Closure Plan .................................................................................................................................................... 13

6.0 Insurance ......................................................................................................................................................... 13 7.0 Financial Information...................................................................................................................................... 13 8.0 Appendix ......................................................................................................................................................... 13

1

1.0 General Company Information

Introduction

Clean Harbors is the leading provider of environmental, energy and industrial services

throughout North America. The Company serves a diverse customer base, including a majority

of the Fortune 500 companies, thousands of smaller private entities and numerous federal, state,

provincial and local governmental agencies. Through its Safety-Kleen subsidiary, Clean Harbors

also is a premier provider of used oil recycling and re-refining, parts washers and environmental

services for the small quantity generator market.

Within Clean Harbors Environmental Services, the Company offers Technical Services and Field

Services. Technical Services provide a broad range of hazardous material management and

disposal services including the collection, packaging, transportation, recycling, treatment and

disposal of hazardous and non-hazardous waste. Field Services provide a wide variety of

environmental cleanup services on customer sites or other locations on a scheduled or emergency

response basis.

Within Clean Harbors Energy and Industrial Services, the Company offers Industrial Services

and Oil & Gas Field Services. Industrial Services provide industrial and specialty services, such

as high-pressure and chemical cleaning, catalyst handling, decoking, material processing and

industrial lodging services to refineries, chemical plants, pulp and paper mills, and other

industrial facilities. Oil & Gas Field Services provide exploration, surface rentals, solids control,

and environmental services to the energy sector serving oil and gas exploration, production, and

power generation.

Clean Harbors' Safety-Kleen subsidiary is a leading North American used oil recycling and re-

refining, parts washers and environmental solutions company for small quantity waste generators

supported by the largest re-refining capabilities to convert used oil into base and blended lube

oils. Safety-Kleen provides a broad set of environmentally-responsible products and services that

keep businesses in balance with the environment.

Headquartered in Norwell, Massachusetts, Clean Harbors has waste disposal facilities and

service locations throughout the United States and Canada, as well as Mexico and Puerto Rico.

2

2.0 Facility Information

Facility Overview

Clean Harbors of Connecticut, Inc., a subsidiary of Clean Harbors, Inc. headquartered in

Norwell, Massachusetts, owns and operates a hazardous waste storage, treatment and disposal

facility located in Bristol, Connecticut. This facility is a RCRA Part B and Clean Water Act

permitted facility, which has been permitted by the Connecticut Department of Environmental

Protection to receive, store, treat and transfer a variety of waste streams. The treatment methods

utilized at this facility reduce the volume and or toxicity of waste materials or make them

suitable for further treatment, reuse, or disposal.

Facility Name Clean Harbors of Connecticut, Inc.

Location 51 Broderick Road

Bristol, CT 06010

County Hartford

Facility Owner Clean Harbors of Connecticut, Inc.

51 Broderick Road

Bristol, CT 06010

Property Owner Clean Harbors of Connecticut, Inc.

51 Broderick Road

Bristol, CT 06010

Facility I.D. No. CTD000604488

Permit Type Part B Hazardous Waste and Connecticut Regulated Waste Facility, with

Clean Water Act Discharge Permitting

Waste Description Most organic and inorganic waste

Services Provided

Wastewater Treatment

Stabilization

Storage/Transfer

Dismantling Process

3

Facility Site Plan

4

Facility History

The Clean Harbors of Connecticut, Inc. facility was constructed in 1980-81. Prior to the

purchase, the site had been undeveloped. The facilities original developer and owner, who had

initiated the present operating permits, sold the facility to CECOS, Inc. (Browning-Ferris

Industries', or BFI's, hazardous waste division) in March, 1984. CECOS renamed the facility

CECOS Treatment Corporation. On July 1st, 1990, most of CECOS, Inc.'s operations (including

the Bristol facility) were purchased from BFI by Southdown, Inc. Southdown renamed the

facility as the Connecticut Treatment Corporation and operated the facility until its acquisition

by Clean Harbors on July 1, 1992.

Site Characterization

The facility property is approximately 3.5 acres in size and is located in a light industrial park on

the eastern edge of Bristol, Connecticut. The facility site is located upon an outwash deposit

zone consisting of generally light brown, fine to coarse sand with silt, to a depth of

approximately 52 feet. At that depth, a glacial till zone consisting of reddish-brown fine to

coarse sand/gravel, with 20-50% silt content, is encountered. Approximately ten feet below the

till zone is bedrock.

A groundwater aquifer begins at approximately ten-foot depth and continues to bedrock. No

drinking water wells are located within a half-mile of the facility. Until 2002, the facility had

been required (by its State Discharge Permit) to conduct quarterly/annual sampling and analyses

of four groundwater monitoring wells. This monitoring has been conducted since 1981, and no

detectable release(s) attributable to the site's operations have been found. In 1988, in accordance

with provisions of the facility’s HSWA (Hazardous and Solid Waste Amendments of 1984)

Permit, the facility had installed eight additional monitoring wells, from which several years of

extensive quarterly monitoring analyses had also been conducted. No detectable groundwater

releases or contamination attributable to Clean Harbors were found. In 1998, the U.S. EPA had

published a Public Notice of the agency’s preliminary determination to issue a No Further Action

decision regarding the facility’s HSWA status. No negative comments had been received by the

EPA. As of March 2003 the EPA awaits the expected concurrence of the Connecticut

Department of Environmental Protection with this conclusion, following which the EPA intends

to render a final No Further Action decision.

A small stream runs along the southeast line of the facility, 200 feet away from any of the

facilities building. The stream is an un-named tributary of the Eight Mile River, a quarter mile

away. The stream receives stormwater run-off from Clean Harbors. The facility's discharge is

permitted and monitored under Connecticut’s General Permit for the Discharge of Stormwater

Associated with Industrial Activity.

The plant is not located within a 100-year floodplain or a coastal high hazard zone, the southeast

corner of the site (where the present stream runs) is located in the 100-year floodplain. The site

has never received any past flood damage.

All waste management operations performed at the facility are conducted indoors or within a

contained area; any resulting stormwaters are collected from outdoor process areas, tested and

treated onsite through routine treatment processes.

5

The facility is located at least one mile from any sensitive receptor (ie., school, hospital).

Security

The Clean Harbors of Connecticut facility is surrounded by a six foot high chain-link fence

topped with barbed wire. Access into the facility is controlled by a gate that is maintained in the

closed position, except when temporarily opened by a compliance guard, working within a

reception area in the adjacent building. Drivers and all other visitors are prohibited from

entering the facility until they have produced appropriate identification, received a visitor badge,

and signed into a visitor log. All the facility’s employees have been trained in these sign-in

requirements, as well as in the need to ensure facility access only to authorized personnel. Every

employee has his/her own walkie-talkie radio as a means by which to immediately communicate

any unusual findings, as well as to monitor routine activities underway within the facility.

6

Directions to Facility

Visitor entry at administrative building;

761 Middle Street,

Bristol, CT 06010

(860) 583-8917

From the North (Western Massachusetts Area)

1. Take Route 90 east to Route 91 South to Route 84 West.

2. Take Exit 31 off of 84 West.

3. At end of Exit 31, take a right (onto Route 229).

4. Go approximately 2.5 miles until you see ESPN on the right.

5. Go another 1/8th of a mile. Clean Harbors will be on the right at the bottom of a small

hill.

From the North (Eastern Massachusetts Area)

1. Take Route 90 West to Route 84 West.

2. Continue with directions as stated above in steps 2-5.

From the West

1. Take Route 84 East to Exit 31.

2. At end of exit, take left.

3. Continue with directions as stated above in steps 4-5.

From the South (Stamford, CT Area)

1. Take Route 95 North to Route 8 North to Route 84 East to Exit 31.

2. At end of exit, take a left.

3. Continue with directions as stated above in steps 4-5.

From the East

1. Take Route 6 West to Route 395 South to Route 2 North to Route 84 West.

2. Take Exit 31. At end of exit take a right.

3. Continue with directions as stated above in steps 4-5.

7

3.0 Operating Licenses and Permits

Permit Summary

Clean Harbors of Connecticut, Inc. is currently permitted by the U.S. Environmental Protection

Agency and the Connecticut Department of Environmental Protection for the collection,

analysis, storage and treatment of hazardous waste with subsequent transfer off-site.

Permit Type/Governing Agency Permit No. Expiration Date

Hazardous Waste Treatment, Storage and

Disposal facility (TSDF) - Part B Permit;

Connecticut Department of Environmental

Protection, U.S. Environmental Protection

Agency

DEEP/HWM-017-004 09/30/2018*

Connecticut Regulated Waste Facility

Permit; Connecticut Department of

Environmental Protection

DEEP/HWM-017-004 9/30/2018 **

Hazardous and Solid Waste Amendments

(HSWA) Permit; U.S. Environmental

Protection Agency

N/A N/A **

State Wastewater Discharge Permit;

Connecticut Department of Environmental

Protection

SP0000109 01/19/2014*

Registration under Connecticut’s General

Permit for Stormwater Discharge GSI000726 9/30/2016*

TSCA Interim Storage Permit – U.S.

Environmental Protection Agency N/A N/A**

General Permit to Construct and Operate

Limited Processing Recycling Facility Application No. 200501674 9/27/07**

* Currently under Review

** Combined into Part B/DEEP Hazardous Waste Permit (TSDF)

Principal Operating Licenses/Permits

Copies of existing permits which detail types of waste management licensed capacities and waste

types accepted are available for inspection upon request at the site. Selected permit pages may

be attached at the end of this audit under Appendix 8.0.

8

Principal Contacts/Agencies

The list of contacts below can provide additional information regarding Clean Harbors of

Connecticut's facility operations or compliance:

Operations

Bryan Campbell, General Manager

Clean Harbors of Connecticut, Inc.

761 Middle Street

Bristol, Connecticut 06010

(860) 583-8917 – ext. 359

Regulatory

Donald A. Smith, P.E., Sr. Environmental Compliance Manager

Clean Harbors of Connecticut, Inc.

761 Middle Street

Bristol, Connecticut 06010

513-568-6357

(RCRA

Compliance)

Juston Williams, Sanitary Engineer II

Engineering and Enforcement Division, Bureau of Waste Management

Connecticut Department of Environmental Protection

79 Elm Street

Hartford, Connecticut 06106

(860) 424-3113

(RCRA Permitting)

Carmen Holzman, Sanitary Engineer III

Engineering and Enforcement Division, Bureau of Waste Management

Connecticut Department of Environmental Protection

79 Elm Street

Hartford, Connecticut 06106

(860) 424-3155

(Discharge

Compliance)

Charles Nezinya, Sanitary Engineer II

Bureau of Water Management

Connecticut Department of Environmental Protection

79 Elm Street

Hartford, Connecticut 06106

(860) 424-3846

Brian Fowkes, Manager

Water Pollution Control Facility

City of Bristol

111 North Main Street

Bristol, Connecticut 06010

(860) 584-3821

9

(TSCA Compliance)

Lori Saliby, Supervising Environmental Analyst

Pesticide, PCB and Underground Storage Tank Program

Connecticut Department of Environmental Protection

79 Elm Street

Hartford, Connecticut 06106

(860) 424-3369

(HSWA/Facility

Investigation

Compliance)

Matthew Hoagland, Chief

RCRA Corrective Action

EPA Region I, New England

5 Post Office Square

Mail Code: ORA

Boston, MA 02109-3912

(617) 918-1361

10

4.0 Process Description

Inorganic Aqueous Waste Treatment

The facility utilizes highly refined, multi-stage, chemical precipitation processes on a batch basis

that remove heavy metals, suspended solids and residual organics from liquid wastes and render

the effluents safe for discharge into municipal sewer systems. Resulting precipitated residues are

dewatered with a filter press, and then disposed of in an approved landfill.

Chemical Precipitation

All aqueous wastes are processed on a batch flow basis through a series of treatment units, where

predetermined amounts of treatment chemicals are added and thoroughly mixed to effect

precipitation of heavy metals and coagulation of suspended particles. Coagulated solids are

removed in the form of sludge by gravity separation and filtration. Filtered effluent is stored in

effluent storage tanks and is discharged to the Bristol Water Pollution Control Facility upon

confirmation of discharge permit parameters from state certified laboratory analyses.

Additionally, the Connecticut Department of Environmental Protection periodically monitors the

discharge.

Chemical Oxidation/Reduction

Waste needing pretreatment to remove specific contaminants is batch processed in controlled

reactor vessels, the airborne emissions from which are treated within two in-series scrubbing

units. Each batch of waste is treated by adding chemical reagents specific to the batch as

determined by the laboratory bench-test simulation to achieve the desired reaction. Upon

completion of the reaction, each batch is tested to confirm the end result of the treatment, prior to

its transfer for final precipitation treatment or additional chemical treatment. Types of reactions

carried out are: oxidation of cyanides and phenols, ammonia removal, chelating agent removal

from wastes such as boiler cleaning solutions, reduction of hexavalent chromium to trivalent

chromium, acid/base neutralization, etc.

Sludge Dewatering/Fixation

Sludge produced upon treatment of the aqueous wastes and batch treatment of slurry wastes may

be first thickened by precipitation or gravity. Settled sludge from the bottom of the pretreated

tanks is pumped to a batch conditioning tank where chemical reagents are added to aid the

dewatering and to stabilize the constituents of concern. The conditioned sludge is pumped into a

plate-and-frame, membrane filter press to achieve a stable filter cake suitable for landfill.

Filtrate produced is sent to effluent holding tanks for analysis and possible subsequent discharge,

while the filter cake is collected into segregated accumulation containers, which are eventually

bulked into a dump trailer for disposal into an approved landfill.

Acid/Base Neutralization

Although this can be a final treatment method, neutralization is often used in conjunction with

other treatment processes such as chemical precipitation, phase separation and

oxidation/reduction treatment processes.

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Neutralization involves the addition of an acid or a base to a solution to adjust the pH, usually to

a level between 6 and 9. Alkaline neutralization usually involves the addition of sodium

hydroxide or potassium hydroxide to an acidic wastewater to adjust the pH. Likewise, acidic

neutralization involves the addition of a concentrated acid (such as sulfuric or hydrochloric) to an

alkaline wastewater.

Storage and Transfer of Waste Oils

Waste industrial lubricating and fuel oils received in containers are stored on-site. Once a

sufficient quantity is accumulated, the waste oil may be bulked or shipped off-site in drums for

reclamation. Oil contained within bulk receipts may be separated off and accumulated within an

onsite oil storage tank, from which loads are shipped offsite for reclamation.

Inorganic Lab Chemical Treatment/Consolidation

Drummed labs packed chemicals are segregated in groups based on their chemical compatibility.

Contents from each group of chemical containers are consolidated into a reactor through a pour-

off area where the batch is treated using laboratory directive tailored for the specific batch.

Container/Tank Storage and Transfer

A wide variety of wastes not acceptable for on-site treatment can be received for consolidation

and transfer to other Clean Harbors' sites or select audited and approved non company-owned

sites. The facility includes storage areas for tanks and containers meeting all RCRA

requirements.

Stabilization/Solidification of Characteristic Waste

The facility is authorized to solidify non hazardous waste and stabilize D004 - D011 wastes. The

resulting de-characterized waste is then subject to management in accordance with subtitle D of

RCRA. The physical absorption method of solidification utilizes clay based absorbents and/or

synthetic polymers to absorb liquids. Cement type stabilization is the process of blending high

calcium-oxide limes with liquids/ solids to generate a gypsum-like solid. The process enables

the hazardous waste to be contained in the gypsum-like matrix. These processes are performed

for wastes received in drums and other bulk containers.

PCB Management

TSCA regulated waste may be managed in containers in three areas within the facility, and solids

may be bulked for offsite shipment. Wastes are transported to TSCA approved incinerators or

landfills and managed per regulations and customer requirements.

Dismantling Process

The Connecticut facility conducts a unique recycling activity onsite that allows customers to ship

scrap or surplus equipment to the facility for the eventual offsite re-use of the various alloys and

components. This process offers the shipper confidentiality for proprietary contents, liability

protection from improper disposal, and financial benefits from the resultant recycling.

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Our dismantling process can accept scrap/surplus equipment that has a value for recycle or

reclaim, if the equipment is not itself a regulated “waste” and is not a “container” of regulated

waste. Upon processing the employees will visually or analytically determine the various metal

alloys and other components of dismantle receipts, which are reclaimable and segregate these

materials accordingly. The dismantling employees are trained in finding and removing

components which would be potentially regulated if they were improperly disposed, including

small batteries, capacitors, refrigerant gases (using EPA-registered extraction equipment),

cathode ray tubes, mercury switches, relays and thermometers, etc., among others. Such

materials are containerized by Clean Harbors as the generator, labeled, stored within the

facility’s permitted areas, and tracked and disposed of at approved offsite recycle or disposal

facilities.

Many States, including Connecticut, have adopted Universal Waste regulations that now classify

computers and monitors as regulated materials that must be tracked and recycled. The

dismantling process is able to receive these universal wastes, track, store, process, and recycle

them, while offering generators the benefits. RCRA treatment, storage and disposal facility

(TSDF) status and safeguards.

Waste Analysis

The Waste Analysis Plan for the facility outlines pre-qualification and on-site acceptance

analysis requirements.

Pre-Qualification

Prior to acceptance and treatment of a specific waste, a Waste Material Profile Sheet must be

submitted to and approved by Clean Harbors prior to any waste shipment. A waste profile can

be completed and submitted online on Clean Harbors’ website at www.cleanharbors.com. Once

the profiled waste material is approved for treatment/disposal, this information becomes part of

the permanent record in the generator's file and the waste may be scheduled for shipment.

On-Site Analysis/Acceptance

With each delivery of approved waste, a sample is taken from each container or the bulk load

and tested to determine whether the waste is the same as the previously approved profile. If this

analysis differs significantly from the wastestream profile, the waste will be deemed non-

conforming. All non-conforming wastes are further analyzed to determine the best treatment

alternatives, whether on-site handling at an adjusted price or transshipment to an alternative

treatment facility. The customer is contacted regarding any non-conforming waste and given the

option for alternate handling or return of their waste. On-specification shipments are processed

with one or more of the storage or treatment operations previously identified.

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5.0 Closure Plan A comprehensive facility closure plan has been developed in accordance with RCRA

requirements and is available at the site for inspection upon request. The Company utilizes both

insurance and surety bonds to meet the Financial Assurance requirements of each state.

View Facility Closure Certificate

6.0 Insurance Clean Harbors (including Safety-Kleen and all entities) presently carries general liability and

auto liability insurance providing coverage in the aggregate amount in excess of $40 million. The

Company purchases pollution liability insurance coverage in excess of $25 million for its fixed

sites for sudden and accidental occurrences. For waste in transit, which insures the Company

against liability for sudden and accidental occurrences during transit on a Company vehicle from

the time waste is picked up through its delivery to a disposal site the Company purchases

insurance in excess of $25 million.

View Certificate of Liability Insurance

7.0 Financial Information Financial information on Clean Harbors and its subsidiaries are available from the Clean Harbors

website in the Investor Relations section.

View Investor Relations Web Site

8.0 Appendix If applicable, supporting facility documentation will follow.

51 Broderick Road Bristol, Connecticut 06010 800.583.8917 www.cleanharbors.com