Veolia Catalog Draft v16 by Winsby Inc.

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Vancouver, WA

Sacramento, CA Richmond, CA Fremont, CA

North Salt Lake, UT Henderson, CO

Azusa, CA Huntington Beach, CA

Our Vision

San Diego, CA

Phoenix, AZ

To be the company trusted by all to protect and improve the environment

Table of Contents About Veolia About Veolia Environnement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 Veolia Environmental Services, Worldwide Division . . . . . . . . . . . . . . .5 Veolia Environmental Services, North America Business Activities . . .6 Industrial Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 Planet Care Environmental Excellence . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 Why Veolia ES Technical Solutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

Environmental Regulations Resource Conservation and Recovery Act . . . . . . . . . . . . . . . . . . . . .10-11 Toxic Substance Control Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 Comprehensive Environmental Response, Compensation and Liability Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 The Universal Waste Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14

Services Proposed Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15 Convert Waste to Product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 Drum Express™/LTL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

Electronic Recycling Electronic Waste Recycling Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18 Recycling Batteries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 Recycling E-Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20 Recycling Lamps and Ballasts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 Recycling Mercury Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22 Recycling Power Distribution Equipment . . . . . . . . . . . . . . . . . . . . . . . .23 RECYCLEPAK® . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 Emergency Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 Fuels Blending (Energy Recovery) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26-27 Healthcare Healthcare Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28 Dental Amalgam and Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29 Medical Waste Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30 Pharmaceutical Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31 Easy Disposal of Sharps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32 Household Hazardous Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .33

Veolia ES Technical Solutions Locations

Marlborough, MA Charlestown, MA West Bridgewater, MA Newington, CT

Blaine, MN Schenectady, NY

Greenville, WI Port Washington, WI Menomonee Falls, WI Lombard, IL

Tonawanda, NY Livonia, MI Flanders, NJ Wampum, PA

East Chicago, IN North Jackson, OH

York, PA

West Carrollton, OH Poca, WV Sauget, IL

Wantagh, NY Middlesex, NJ Philadelphia, PA

Fredericksburg, VA Richmond, VA

Louisville, KY

Creedmoor, NC Mooresville, NC

Morrow, GA

www.VeoliaES.com Tallahassee, FL

Baytown, TX Port Arthur, TX

Gurabo, PR

Incineration Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34 Specialty Waste Incineration and Assured Destruction . . . . . . . . . . .35 Flexible Waste Processing Incineration . . . . . . . . . . . . . . . . . . . . . . . . . .36 Laboratory Services Laboratory Chemical Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .37 Chemical Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .38 Chemical Moving Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39 Equipment Decontamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .40 Lab Packing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41 Low-Level Radioactive Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .42-43 Online Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44 Online Reporting Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .45 On-Site Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .46 Program Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .47 Recycling and Recovery Solvent Recovery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .48-49 Catalyst Recycling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .50

Remediation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .51 Specialty Chemical Services Cylinder Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .52 High Hazard Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .53 Reactive Chemicals Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .54 Remote Opening . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .55 Specialized Packaging and Transport . . . . . . . . . . . . . . . . . . . . . . . . . . . .56 Stabilization and Landfill . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .57 Training Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .58-59 Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .60 Veolia Audited Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .61 What to Expect - The Veolia Business Process . . . . . . . . . . . . . . . . . . . . . . .62 Capabilities for Each Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .63

Technical Solutions strives to deliver a comprehensive package of services at each location. All services may not be available at all locations, however.

About Veolia Environnement Operating in 48 countries, Veolia Environnement has over 220,000 employees focused on delivering environmentally sustainable solutions through our three business units, Veolia Water, Veolia Environmental Services, and Veolia Energy.

formed SARP Industries to recycle hazardous waste. SARP was the first European center for the treatment of liquid toxic waste. One of Europe’s largest paper and plastic recyclers, Groupe Soulier, has also become part of Veolia through various acquisitions.

Veolia Water CONTINUITY The Veolia logo begins with the circle, a perfect shape that symbolizes the earth.

RING The circle is enriched to become a ring, which symbolizes the union between two people or two entities and represents two destinies, joined together.

PROTECTION A person emerges within the circle, which becomes two arms, coming together to nurture, unify and protect.

Veolia traces its roots to the original water supply Veolia Energy company Compagnie Générale des Eaux (CGE), Two heating and air conditioning service founded through an imperial decree in 1853, to businesses formed the foundation of Veolia’s irrigate the countryside energy division: Compagnie around Lyon, France and, Générale de Chauffe (CGC) and Veolia Environnement later, to supply water to Chauffage Service, founded in • $38 billion in revenue and over Paris. By 1953 when CGE 1944 and 1935, respectively, $58.8 billion in assets celebrated its 100th merged in 1960 and joined • Fortune global 150 company • Operating in 77 countries anniversary, it was supplying CGE seven years later. CGE • 317,000 employees focused on delivering eight million people with developed services that environmentally sustainable solutions water in France over a evolved into facilities • Over 150 years of experience 10,000-kilometer network management contracts. and had branched into Groupe Montenay was created municipal waste collection. in 1860 and merged with CGC; the first waste drop-off centers opened in 1986, establishing the waste-to-energy plants. Veolia Environmental Services Three companies merged with CGE to expand its footprint in the waste arena. Two acquisitions Our Future occurred in 1980: Generale d’Entreprise As the world’s population continues to migrate to Automobiles (CGEA), which had entered the waste cities, the availability of core services long term collection market in 1919, and a second company must be addressed continually. Through ongoing that began in 1867 when Francois Grandjouan won research, Veolia Environnement evaluates which a contract with Nantes to “clear the streets of technologies and resources will be required to sewage and waste.” The third company, added in meet these evolving environmental challenges. We 1990, was a business that had been established in are all dependent on our ability to face the future 1870 by the Soulier Brothers to process old rags with cost effective, energy efficient answers. and paper in Rouen and Chauny. One hazardous waste service, incineration, was first established in 1967 by CGE. The hazardous waste division was first created in 1975 when CGE

Veolia Environmental Services Worldwide Services

Veolia Environmental Services is the largest waste services company in the world. We are the only global service provider whose processes include: liquid, solid, nonhazardous and hazardous waste; on-site waste processing; industrial cleaning and processing maintenance; and recycling, recovery, and disposal. Our customers include agencies and companies in both the public and private sectors.

Turning Waste into a Resource We have embraced our business of managing and disposing of waste by turning to innovative technologies to discover ways of turning waste into a resource. We are recycling over 30% of the waste that we manage and delivering products from that waste. The metal content of waste, spent solvents and landfill gas are just a few of the products that are being recycled and reused.

Environmental Management Systems Veolia Environmental Services views its responsibilities for environmental compliance to extend beyond simply adhering to applicable regulations. The company carefully audits the hundreds of facilities it operates. Through its proprietary Environmental Management System, all employees are helping to achieve the environmental compliance targets that have been defined.

Government and Technical Expertise

Veolia Environmental Services â&#x20AC;˘ $12 billion in revenue â&#x20AC;˘ 84,800 employees â&#x20AC;˘ 686 treatment facilities worldwide

Continuous training for regulatory changes and current research assures that your Veolia contacts are informed about the latest trends and developments in their respective industries. Veolia Environmental Services seeks the most qualified employees in every field to assure that our customers receive the best possible service. Our environmental regulatory specialists help you comply with existing regulations, and comment on or prepare for proposed changes.

Reliable, Responsive Service When we promise any on-site service, you can depend on us to be there on time, every time. Our services are critical for day to day maintenance; we have built our company on our commitment to provide these services quickly and efficiently.

Veolia Environmental Services North America Business Activities Headquartered in Chicago, IL, Veolia Environmental Services North America Corporation (VESNA), offers fully integrated environmental solutions to the industrial and commercial sectors. It is the North American division of Veolia Environmental Services group, the only global company that manages a complete range of waste services and also provides industrial maintenance. VESNA delivers services through the Veolia ES Industrial Services and Veolia ES Technical Solutions business units. These subsidiaries provide the following services, respectively: industrial cleaning, mechanical, and environmental services; and hazardous and nonhazardous waste services. A core strength of VESNA is its ability to deliver integrated services to customers who require a broad spectrum of environmental services. Industrial customers especially benefit from relying on only one company for multiple services. As part of Veolia Environnement, VESNA can also provide water and energy solutions to the industrial sector.

Veolia ES Industrial Services, Inc. Industrial Cleaning, Mechanical, and Environmental Services • Advanced Catalyst Handling Services • Capital Projects • Chemical Cleaning • Dredging • Emergency Response • Explosives Cleaning and Deslagging • Fabrication, Construction and Repair • Hazardous Waste Management Canada

Veolia ES Technical Solutions, L.L.C. Hazardous and Nonhazardous Waste Services See Table of Contents on pages 2-3 for a list of available services.

• Hydroblasting & Ultrahigh Pressure • Project Management • Solids Separation • Tank Cleaning • Tank Repair and Maintenance • Total Sewer Management Inspection, Cleaning and Rehabilitation • Turnaround Management

• Turnkey Heat Exchanger Maintenance • Turnkey Tower and Vessel Maintenance • Waste Transportation and Temporary Storage • Wet & Dry Vacuuming

North America Business Activities

Industrial Services Special Services Asbestos and Lead Abatement Black Water Diving Emergency Response & Disaster Recovery Government Contract Services High Hazard Energetic Services Hydrographic Survey Services InSite Resource Solutions Standby Confined Space Rescue Services

Veolia ES Industrial Services provides a complete range of maintenance and cleaning services for industrial, municipal and offshore facilities to keep them in peak operating condition.

Network of North America Service Centers Routine maintenance, turnarounds and emergency callouts are managed through our network of over 80 service centers in the United States and Canada where we house our state-of-the-art equipment and teams of trained professionals.

Cutting Edge Technology, Technical Expertise Contact Information Veolia ES Industrial Services, Inc. 2525 South Shore Boulevard Suite 410 League City, TX 77573 Phone: 713-307-2160 Fax: 713-307-7622 www.veoliaes.com

We combine cutting edge technological capabilities with technical expertise in maintenance, cleaning services, environmental and marine services to offer a focused, business plan approach that enables us to deliver cost effective solutions.

Industrial Cleaning Chemical Cleaning Coldcutting Degassing Dredging

Hydroblasting and Ultrahigh Pressure In-Plant Managed Services Precommissioning

Surface Coatings and Sandblasting Wet and Dry Vacuuming

Environmental and Waste Management Biosolids Management Explosives Cleaning and Deslagging Services Hazardous Waste Management—Canada Hydroexcavation InSite Resource Solutions Landfill Management Services Remediation Solids Separation

Solid Waste Services (Canada only) Tank Cleaning Total Sewer Management—Inspection, Cleaning and Rehabilitation Total Tank Management—Design, Construction, Repair, Cleaning Waste Minimization Waste Transportation and Temporary Storage

Mechanical Services Construction/Capital Projects Piping and Welding Plant Maintenance Project Management

Tank Services Towers, Vessels and Drums Turnaround Services Turnkey Exchanger Maintenance

Planet Care Environmental Excellence Our Global 2015 Environmental Objectives Veolia helps organizations around the world improve their sustainability performance, and our customers turn to us for expert guidance and creative solutions for their most pressing environmental challenges. Veolia has developed its Planet Care 2015 Environmental Objectives. Key to achieving improvements is to continue developing innovative solutions and to focus on one simple commitment: to turn waste into a resource.

Protect Biodiversity • Carry out an evaluation and implementation action plan for 95% of the sites with significant potential stakes and opportunities for biodiversity. • Include an evaluation of the impact on biodiversity for 100% of the development projects. • Establish preservation plans in our six primary countries of operation.

Combat Climate Change Our efforts are focused in five areas, and we have identified specific goals for each area. We are tracking and reporting our progress each year, using our existing environmental management system.

Prevent Pollution • Assess the environmental risks for 95% of the sites and implement preventive actions. • Reach 95% of the sites that are ISO 14001 certified or covered by an environmental management system (EMS).

• Achieve a 70% global methane capture rate. • Calculate the carbon footprint for 95% of our business units and implement emission reduction plans.

Reinforce Environmental Awareness • Provide environmental training to 90% of our employees. • Increase the proportion of our supplier contracts that integrate environmental requirements. • Train our sales teams in the company’s environmental themes and raise our customers’ awareness.

Conserve Natural Resources • Increase the production of renewable energy from waste by 10%, compared with 2011. • Implement water consumption reduction plans for 80% of the sites. • Achieve a global material recovery rate of 30%. • Implement energy efficiency plans on 80% of the sites.

Check our website for updates on how we are progressing toward our goals

www.VeoliaES.com

Why Veolia ES Technical Solutions Managing Hazardous and Nonhazardous Waste When you manage multiple environmental responsibilities, including hazardous waste and its associated liability, you must rely on the capabilities and expertise of your service provider. Veolia ES Technical Solutions (Veolia) stands alone in meeting the criteria you use to determine the most viable environmental service partner. From on-site services and transportation to final treatment or disposal, Veolia assures regulatory compliance by channeling hazardous and nonhazardous waste and related information through its network of nearly 400 company-owned or certified service centers nationwide. These service centers include treatment, recovery and disposal facilities, sales offices and transportation locations.

Environmental Compliance Veolia maintains an excellent record of compliance with environmental regulations. This record is ready for inspection at any time. A culture of compliance is a way of life at Veolia, where we manage hazardous and nonhazardous waste with the utmost care. 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 Strength Our parent is Veolia Environnement, a publicly owned company with over 150 years of experience delivering environmental solutions. The Paris-based company is the international leader in providing environmental services for waste, water, energy and transportation. With over $38 billion in revenue, it is the largest environmental services company in the world.

Technical Expertise Our account, project and technical representatives understand hazardous and nonhazardous waste and the related regulatory requirements. Over 5,400 Veolia employees are ready to assist you in any wayâ&#x20AC;&#x201D;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.

Excellent Health and Safety Record Safety is critical in our business, and Veoliaâ&#x20AC;&#x2122;s safety record is strong. Our OSHA log summary shows a recordable injury case rate that is nearly 65% lower than the average for the North American Industry Classification System Group, and a lost time injury case rate that is 84% lower than the NAICS Group average. Similarly, our Experience Modification Rate, which is used by the insurance industry to determine premiums for workers compensation insurance and is based on past safety performance, is .81. An EMR less than 1.0 demonstrates a safety record that is better than average. The reason for our excellent record is, simply, training excellence. Our field employees alone receive nearly twice as much training than is required by government regulations.

Innovation through Research Veolia Environnement has established the only research and development program in the world dedicated to environmental services, with laboratories in France, Australia, Germany, the United Kingdom, and the United States. This program develops technical innovations for nonhazardous and hazardous waste processes, recovery and disposal, supporting Veoliaâ&#x20AC;&#x2122;s commitment to environmental sustainability. Locally, we use these innovative processes to improve our efficiencies in recycling electronic waste, metal scrap and organic solvents. To ensure the most cost effective waste processing, we evaluate your waste streams to reduce overall waste volume and expense, while minimizing environmental impact. We always look for ways to reuse, recycle and reduce waste, including using waste as a product. As announced in our 2015 environment objectives, which we released in June of 2012, we promise to improve our own environmental performance on a global scale in the following five areas: preventing pollution, conserving natural resources, preserving biodiversity, combating climate change, and reinforcing environmental awareness. Throughout all of our operations, we are pursuing waste treatment options to assure sustainability.

Resource Conservation and Recovery Act Waste Regulated

Purpose

• Hazardous waste exhibits at least one of four characteristics—toxicity, corrosivity, ignitability or reactivity • EPA also maintains a list of hazardous wastes which include: discarded commercial chemical products, hazardous wastes from specific industries or sources, and hazardous wastes from non-specific sources. • A mixture of nonhazardous and hazardous waste (e.g., gasoline impacted soil from leaking underground storage tank) • Waste derived from treatment, storage or disposal of hazardous waste (e.g., incineration ash) • Soil, groundwater or sediment contaminated with hazardous waste • Listed Wastes—The F-list includes non-specific source waste from common manufacturing and industrial processes. The K-list includes sourcespecific wastes from specific industries. The P-list and the U-list include discarded commercial chemical products with specific commercial chemical products in an unused form. D-Listed wastes are capable of leaching into the surrounding environment and fail the Toxicity Characteristic Leaching Procedure (TCLP) test method.

In 1976 the Resource Conservation and Recovery Act (RCRA) was enacted to give the US Environmental Protection Agency the authority to control hazardous waste from the point of generation to its ultimate disposal site—“from cradle to grave”. Besides generation and disposal, RCRA addresses the regulation of hazardous waste transportation, treatment, and storage. The Act also establishes a framework for managing nonhazardous wastes. This summary provides the highlights of RCRA; please refer to 40 CFR 260-279 for details.

The information contained herein is provided by Veolia ES Technical Solutions, L.L.C. for general informational purposes only. This information should not be construed as legal advice or a legal opinion on any specific facts or circumstances.

RCRA was enacted by Congress as an amendment to the Solid Waste Disposal Act, which established a regulatory structure to manage solid and hazardous wastes. There have been two major amendments to RCRA: the Federal Hazardous and Solid Waste Amendments (HSWA) in 1984, which gradually eliminated land disposal of hazardous waste, and the 1986 amendments, which addressed underground storage tanks for petroleum and other hazardous substances.

Requirements RCRA applies to any company that generates, transports, treats, stores or disposes of hazardous waste. A waste can be hazardous by exhibiting at least one of four characteristics—toxicity, corrosivity, ignitability or reactivity—or by falling under one of the categories of listed hazardous wastes. These listed hazardous wastes include discarded commercial chemical products, hazardous wastes from specific industries or sources, and hazardous wastes from non-specific sources. The amount of hazardous waste generated by a facility determines its category. The three categories are: • Conditionally Exempt Small Quantity Generator (CESQG) produces under 100 kg (220 lbs) per month and less than 1 kg (2.2 lbs) per month of acutely toxic waste and is exempt from most reporting requirements, though still responsible for safe management of waste.

Who Is Regulated Any company that generates, transports, treats, stores or disposes of hazardous waste. Sample Industries include: Aerospace Automotive Chemical Consumer products Government and municipalities High technology and electronics Manufacturing Metals Pharmaceutical and biotechnology Pulp and paper Refining Service providers Universities and hospitals Utilities

For details, see 40 CFR: Protection of the Environment

• Small Quantity Generator (SQG) produces between 100 and 1000 kg (220 - 2,200 lbs) per month and less than 1 kg per month of acutely toxic waste. Waste cannot be accumulated for more than 180 days without a permit. • Large Quantity Generator (LQG) produces over 1000 kg (2,200 lbs) per month or greater than 1 kg per month of acutely toxic waste. Waste cannot be accumulated for more than 90 days without a permit. Generators are subject to a variety of requirements that include: • They must be knowledgeable about applicable regulations and train personnel to comply with these regulations. • All waste must be tracked through the manifest system, the data sheet that documents each shipment of hazardous waste, from the facility that generates it to its final disposal site. Waste must be properly packaged and labeled. Record keeping and reporting requirements must be addressed. • A waste minimization program must be established, which reduces or eliminates hazardous wastes. • Standards for accumulation of hazardous waste must be met. • All sources of hazardous waste must be identified. It may be necessary to obtain a facility identification number, as well. Facilities that treat, store or dispose of hazardous waste are also subject to requirements under RCRA and must obtain a permit from EPA or the authorized state agency.

State Regulations The EPA encourages states to assume primary responsibility for enforcing provisions under RCRA. State requirements must be at least as stringent as those adopted by the EPA.

Penalties

RCRA authorizes EPA to assess penalties of up to $32,500 per day of noncompliance for each violation of the Act. Several factors are considered in determining the penalty amount, including the seriousness of the violation, good faith efforts to comply with applicable requirements, the length of the violation, and whether the company benefited monetarily through noncompliance. 11

Toxic Substance Control Act Chemicals Regulated

Purpose

The list of TSCA regulated chemicals is updated every four years. The TSCA Inventory contains about 82,000 chemical substances, including: • Asbestos • Chlorofluorocarbons (CFCs) • Polychlorinated biphenyls (PCBs) • New chemical substances and mixtures

The Toxic Substances Control Act (TSCA), enacted by Congress in 1976, authorizes EPA to regulate the manufacture, use, distribution and disposal of over 82,000 chemical substances produced or imported into the United States. One major objective of TSCA is to weigh the risks to humans and the environment against the social and economic benefits of a new chemical substance before it is actually distributed.

Who is Regulated Any company that manufactures, imports, or processes certain chemical substances or mixtures.

State Regulations TSCA is federally managed. Regulatory authority is not delegated to the states.

Requirements A premanufacture notice (PMN) for a new chemical substance must be submitted to EPA at least 90 days before manufacturing or importing begins. Information on the manufacturing process, the disposal method and possible health and environmental effects must be included. EPA is authorized to protect human health and the environment against unreasonable risk associated with chemicals and may ban the manufacture or distribution of chemicals or mixtures, limit their use, require labeling or place restrictions on chemicals. EPA is required to gather data, mandate record keeping and reporting for activities related to manufacturing, using, distributing or disposing of chemical substances. Manufacturers and importers must perform various health and environmental tests, establish quality control as part of their production processes, and notify the EPA if they obtain information on possible adverse health effects from use of their products.

Penalties The information contained herein is provided by Veolia ES Technical Solutions, L.L.C. for general informational purposes only. This information should not be construed as legal advice or a legal opinion on any specific facts or circumstances.

Failure to comply with TSCA regulations can result in civil penalties for each day of each violation. Continued failure to comply can result in criminal penalties that include a fine and/or imprisonment.

Comprehensive Environmental Response, Compensation and Liability Act Wastes Regulated

Purpose

CERCLA requires EPA to prepare a list, in order of priority, of substances that are most commonly found at facilities located at the sites requiring clean up— the National Priorities List. The list is updated every two years. In 2011, 275 entries were included. The top ten are: • Arsenic • Lead • Mercury • Vinyl Chloride • Polychlorinated Biphenyls • Benzene • Cadmium • Benzo(a)pyrene • Polycyclic Aromatic Hydrocarbons • Benzo(b)fluoranthene

The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) was enacted by Congress in 1980 and is widely known as Superfund. CERCLA establishes procedures for cleaning up closed and abandoned hazardous waste sites, assigns liability to those responsible for releasing hazardous waste at such sites and established a trust fund to be used as the source of funds for clean up when no responsible party can be identified. Initially, the fund was created with a tax on the chemical and petroleum industries. CERCLA also provides broad authority to the federal government to respond directly to releases of any hazardous substances that could endanger public health or the environment.

Who Is Regulated Any person responsible for releasing any hazardous substances that could endanger public health or the environment.

Requirements When there is an emergency situation where contaminants are released, CERCLA authorizes both short-term removals and long-term remedial response actions. Shortterm removals require prompt response to address releases or possible releases. Longterm remedial response actions are necessary to reduce the dangers associated with releases of hazardous substances that are serious but not immediately life threatening. Long-term actions may be conducted only at sites listed on EPA’s National Priorities List.

Joint and Several Liability

CERCLA imposes joint and several liability for cleaning up contamination caused by hazardous waste. Responsibility for the effects of hazardous waste lie with the generator from inception of the waste to its final disposal, from "cradle to grave". There are four groups of potentially responsible parties, which include: (1) the current owner or operator of a vessel or a facility; (2) the owner or operator of a vessel or facility at the time of the disposal of any hazardous substance; (3) the generator(s) of any hazardous substances located on the site; and (4) any transporter of hazardous substances to a site the transporter selected. No agreement protects a responsible party from CERCLA liability, which even includes liability for any contamination prior to the passage of CERCLA in 1980. 13

The Universal Waste Rule Waste Regulated

Purpose

Common items that contain hazardous wastes include fluorescent lamps and batteries. There are several categories of materials designated as universal waste: • Batteries • Banned and recalled pesticides • Mercury containing equipment • Lamps

In 1995 the US EPA adopted a set of regulations commonly referred to as the Universal Waste Rule (UWR) in order to promote the recycling and proper disposal of wastes that are widely generated and include certain hazardous materials.

Who Is Regulated Under the UWR, anyone who generates, accumulates or stores universal wastes is classified as a handler of universal wastes. The UWR defines two categories of handlers: small quantity handlers and large quantity handlers.

Veolia Environmental Services’ RECYCLEPAK® meets all UWR requirements.

Requirements The requirements for small and large quantity handlers include: practicing good container management and adhering to restrictions regarding waste types, labeling, dating, inventory control, employee training, waste tracking, export and rejection notifications and US DOT rules. Requirements for universal waste transporters and destination facilities are defined. According to these standards, universal wastes must be packaged in a way that prevents breakage, and packages must be labeled with the words “Universal Waste”, followed by the category of universal waste. Universal wastes cannot be diluted, treated or recycled by handlers. The intentional crushing of lamps is considered treatment under the UWR. All handlers are required to train their employees.

State Regulations Since the adoption of the federal rule, all authorized states have adopted their own universal waste rules or guidance allowing the management of universal wastes under a reduced set of management standards. The UWR also allows individual states to modify the UWR by adding other waste types. Regulations vary from state to state.

Benefits of Recycling Universal Waste By recycling universal wastes, valuable materials can be recovered from the wastes and reused in the manufacture of new products. There is an added benefit to the generator in that recycling universal waste greatly reduces the generator’s long term environmental liability. The information contained herein is provided by Veolia ES Technical Solutions, L.L.C. for general informational purposes only. This information should not be construed as legal advice or a legal opinion on any specific facts or circumstances.

Proposed Regulations Pharmaceuticals to be packaged as Universal Waste by Pharmacies Hospitals Physicians’ offices Dentists’ offices Outpatient care centers Ambulatory health care services Residential care facilities Veterinary clinics Other facilities that generate hazardous pharmaceutical wastes

Subpart K for Colleges and Universities • Required Laboratory Management Plan • Laboratory clean-outs annually • Delay identifying hazardous waste determination until waste is removed or within four days of arrival at the onsite central accumulation area • Labeling prior to removal from campus • Removal at least once every six months • Unify sites and EPA ID numbers

EPA has proposed regulatory changes to waste governed under RCRA that could reduce the cost of compliance with RCRA for many types of institutions and industries.

Redefining Solid Waste under RCRA A new definition of “solid waste” under RCRA has been proposed to exclude hazardous secondary materials that are recycled through reclamation. Three categories of materials would be excluded: those generated and reclaimed by the generator; those generated and transferred for reclamation by another company; and those categorized as non-wastes by EPA or an authorized state agency. The new rule reflects court challenges about whether materials are considered solid waste if they are destined for recycling. It also promotes recycling. The EPA estimates that about 5,600 facilities will be affected and 1.5 million tons of hazardous waste will be deregulated or receive reduced regulation. The result is an estimated annual cost savings for industry of $95 million.

Categorizing Pharmaceuticals as Universal Waste It has been proposed that hazardous pharmaceutical wastes be added to the Universal Waste Rule to promote proper disposal of these wastes. Under this rule, it would be necessary for these wastes to be packaged in a way that prevents breakage, and packages must be labeled with the words “Universal Waste”, followed by the waste category. This addition would facilitate collection and proper disposal of pharmaceutical waste and would remove this type of waste from wastewater treatment plants and municipal solid waste landfills. The proposed rule would apply to all types of medical related facilities (see list at left). It is anticipated that collection arrangements would be developed for personal medications, as well.

Revised Standards for Laboratory Waste at Colleges and Universities

EPA has finalized a rule that allows academic entities to manage laboratory waste under a more flexible arrangement. The new Subpart K to EPA’s generator standards in 40 CFR Part 262 provides separate management standards for waste generated and accumulated in college or university laboratories. Changes involve annual laboratory clean outs, when and where waste is designated as hazardous, labeling, accumulation time, and requirements for EPA numbers and multiple sites. The new rule, which is summarized at left, is not effective in RCRA authorized states until it is adopted by each state. 15

Convert Waste to Product Waste Candidates For Fuels Blending or Solvent Recovery Hydrocarbons Active solvents Alcohols For Metals Recycling Metal bearing sludges Electronic waste Many types of waste can be considered

Beneficial Reuse Examples Used solvent reused as spray gun wash Spent refractory liner crushed and used as landfill daily cover Substituted waste methanol for virgin for use in denitrification at wastewater treatment plants

Veolia ES Technical Solutions has developed several alternatives for beneficial reuse of waste by converting waste to product. Because waste can be exempt from the Resource Conservation and Recovery Act (RCRA) if it is used to produce another product, industry is encouraged to seek positive ways of using waste, rather than simply disposing of it.

From Lowering Costs and Impact to Assuring Sustainability Historically, industry has focused on reducing costs while alleviating environmental impact, which formed the foundation for developing beneficial reuse technology. As the types of materials being reused has broadened and gained acceptance from both industry and regulators, goals have shifted toward sustainability, research has provided more options for how waste can be reused, and there is a significant increase in the types of waste that can be converted into products. When waste is reused, everyone benefits with lower energy use, a reduction in greenhouse gases, conservation of natural resources, decreased disposal costs and, often, more efficient production by using recycled materials.

Increasing Reuse of Waste Solvent waste streams are quite promising candidates for expanding waste reuse. There is a wide variety of manufacturing processes that use solvents, including the electronics, automotive, pharmaceutical and paint industries. Veolia evaluates waste streams individually and recommends alternative uses, many of which are developed through our Solvent Research and Development Laboratory.

Information Sources Veolia Environmental Services is a member of the US Business Council for Sustainable Development, an organization that unites industries to discover ways of reusing waste, rather than disposing of it. Many states have developed their own beneficial use determination criteria, which can be found on the web site for the agency that oversees environmental regulations for each individual state.

DrumExpressâ&#x201E;˘/LTL Transportation and Disposal Services for Small Quantities of Waste LTL Program Features

LTL Services

Set-up and approval services Complete waste removal services Electronic tracking of shipments to final disposal, treatment or recycling Pre-printed manifests, land ban forms, drum labels Instructions on obtaining permits

A less-than-truckload (LTL) program is available to provide flexibility for small to mid-sized volumes of waste. Our LTL services are scheduled to optimize container movements within regional areas. A nationwide network of transportation resources supports these services to assure efficient and cost effective pick-ups, which include manifest and label services. Dedicated route specialists are always ready to answer technical or logistical questions.

LTL Services

Timely waste removalâ&#x20AC;&#x201D;within ten business days, or as prescheduledâ&#x20AC;&#x201D;and the "onestop" waste management services are critical features of our LTL program. We also provide assistance for: characterizing and packaging wastes generated at your facilities; choosing appropriate and cost efficient treatment and/or disposal methods; instructions on obtaining any required permits; and developing accurate, pre-printed manifests, land ban forms and drum labels.

Preset date for hazardous waste pickups Approve your schedule every six months for flexibility Compliance necessary with 90 day clock requirement Typical lead time of two or three days for locations that are near our service locations, if not a prearranged pick-up

Trained and Knowledgeable Our personnel are specially trained to handle hazardous and nonhazardous waste safely and legally. All employees keep current on regulatory and safety requirements by passing periodic training courses. Safety is important for our transportation vehicles, too, which are maintained under strict quality standards.

Regulatory Requirements We will advise you of legal stipulations when we begin service. The U.S. EPA has storage and pick up requirements, based on the quantity of hazardous waste generated. Both the U.S. EPA and the U.S. DOT can impose restrictions on hazardous waste transportation. State rules may be different.

Electronic Waste Recycling Services Why Use Recycling Services? • Compliance with municipal, state and federal regulations • Reduced administrative burden • Cost effective • Easy to use • Expert help available

Liability Protection through Veolia Environmental Services • Environmentally compliant • Over $400 million in annual revenues • Pollution coverage • Contractors operations and professional services protection (COPS) • Excess umbrella policy • Global sustainability policies

What’s Included in Recycling? • Packaging—Boxes, drums, pails to store waste* • Transportation to Recycling Facilities* • Tracking Documents • Waste Processing • Written Documentation

Facilities • 4 fully-permitted lighting and electronic recycling facilities, located in Arizona, Florida, Massachusetts and Wisconsin

*Available with RECYCLEPAK® services only.

Veolia ES Technical Solutions has four electronic waste recycling facilities located throughout the United States. Our facilities process a wide variety of items for recycling: products containing mercury, such as lighting waste, switches, gauges, thermometers, laptops, hard drives, printers, copiers, and fax machines; electronic equipment with and without PCBs, including transformers, bushings, switches, lighting ballasts, capacitors; and batteries. Veolia is one of the largest commercial recyclers of lamps and ballasts in the U.S., capable of processing up to 250,000 lamps per day. We provide recycling services to customers located throughout the United States who represent many different industries, including utilities, municipalities, lighting contractors, government agencies, hospitals, distribution centers, retail groups, and many other types of large companies.

Customized Recycling Services The start-up process is easy. An account representative presents a proposal, which includes pricing. Once the proposal is agreed upon, we start scheduling the pick-ups. Depending on your needs, pick-ups can be arranged weekly, quarterly, annually—or whatever is convenient and meets your company’s needs. Once service begins, we can provide the right sized boxes, drums and pails you’ll need to store your waste. When the waste is ready to ship, we dispatch a vehicle, selecting transportation from our fleet of semi trailers, box vans or approved third party transporters, to carry your waste safely to one of our four fully permitted recycling facilities. There, the waste is demanufactured—recyclable components are removed and recycled. These components include metals (e.g., copper, aluminum, steel, mercury) and glasses (e.g., lamp glasses, monitor glass). You receive documentation that verifies environmentally compliant disposal for all waste. It includes tracking documents and details on the materials that were both disposed of and recycled. These documents protect your company from exposure to long-term liability for hazardous waste.

Recycling Batteries Types of Batteries Recycled • AAA, AA, C, D, 9 volt • Alkaline • Lead acid • Lithium / lithium ion • Mercury • Nickel-cadmium • Nickel metal hydride • Silver • Zinc carbon

Environmental Fact About three billion batteries are sold every year in the United States. These sales represent ten batteries per person.

Veolia ES Technical Solutions offers safe environmental recycling of batteries in all 50 states through our fully permitted facilities with state-of-the-art equipment.

Customized Recycling Services We have developed recycling solutions for large and small quantities of batteries. Whether you need service for one facility or multiple locations across the country, we can offer a combination of prepaid recycling containers for small quantities or arrange for a pick up for larger quantities. We'll help you analyze your current waste streams, assist with setting up a collection programs and educate your staff on the benefits of recycling. We'll even offer safe packaging guidelines to ensure your shipments of batteries are delivered safely. Our turn-key recycling services provide everything you need, including packaging, transportation, tracking documents, waste processing, and written documentation that details what materials were recycled and meets all environmental regulations.

Regulatory Requirements The following regulations apply to most batteries waste: federal Resource Conservation and Recovery Act (RCRA) and the Universal Waste Rule. See pages 10-14 for detailed information on regulatory requirements.

Hazardous Waste Used batteries may be considered a hazardous waste, because they may contain corrosive materials such as potassium hydroxide (lye) or sulfuric acid, reactive metals such as lithium, or toxic metals such as mercury, lead, cadmium and nickel. If batteries are disposed of through the trash, these wastes could be released into the water system through runoff or leaching from landfills. If improperly incinerated, metals might be released into the air.

Recycling E-Waste Types of E-Waste Recycled • Monitors/cathode ray tubes (CRTs) • Personal computers • Components and peripherals • Printer/fax/copiers • Mainframes and servers • Consumer electronics • Telephone systems • Medical and office equipment • Generators, wire and motors

Environmental Fact The United Nations Environmental Program estimates that between 20 and 50 million tons of e-waste are dumped each year into landfills around the world. The U.S. properly recycles only about 13% of its e-waste.

Veolia ES Technical Solutions can manage the disposal of all your e-waste, including monitors, personal computers, mainframes, servers, copiers, printers and all other types of office waste. Veolia provides everything—demanufacturing, recycling, asset management, data destruction, and metals recycling. These processes convert waste into useable products through our fully permitted facilities, using state-of-the-art equipment.

Customized Recycling Services In all 50 states Veolia provides a complete range of compliant and cost effective services to customers needing to manage end-of-life electronics, or e-waste. Our knowledgeable representatives understand e-waste and are ready to tailor a recycling solution to fit your needs, ranging from complete destruction and recovery of metals, plastics and glass, to maximizing the reuse and resale of intact components. We recycle many materials, including monitors /cathode ray tubes (CRTs), personal computers, computer components, printer/fax/copiers, mainframes, servers, peripherals, consumer electronics, telephone systems, medical equipment, office equipment, generators, wire, and motors. We offer our clients a variety of services designed to fit their needs. We can manage a company's computer assets, provide sufficient data security, de-manufacture, recycle and reuse/resell various equipment in order to offer the most cost effective service options available. Both large and small quantity programs are available to make it easy to recycle electronic waste.

Regulatory Requirements The following regulations apply to most e-waste: federal Resource Conservation and Recovery Act (RCRA). See pages 10-14 for detailed information on regulatory requirements.

Hazardous Waste Your outdated electrical equipment, including batteries, may contain hazardous materials, such as heavy metals (e.g., cadmium, lead, or mercury). Most often, this electrical equipment is disposed of as solid waste, and these hazardous materials end up in the environment, either by improper incineration, or by leaching into surface or groundwater. 20

Recycling Lamps and Ballasts Types of Lamps and Ballasts Recycled • Straight fluorescent lamps • Compact fluorescent light bulbs (CFL’s), u-shape and circular fluorescent lamps • High intensity discharge (HID) lamps • Neon lamps • Shatterproof and other specialty lamps • Broken or crushed lamps • PCB lamp ballasts • Non-PCB lamp ballasts

Environmental Facts Less than 30% of lamps discarded in the United States are currently being recycled. These wastes are being banned from landfills, because they can contaminate our water supply with mercury. Rare earth metals, contained in the phosphor powder, are extracted from fluorescent lamps and recovered during the recycling process. These metals are used in many other products that are rapidly increasing in demand: ear buds; small electric motors; computer screens; smart phones; and defense systems. The demand for rare earth metals continues to grow, yet 97% of the world's supply comes from China. Recycling is a critical way to replenish the supply of rare earth metals.

Veolia ES Technical Solutions is one of the largest commercial recyclers of lamps and ballasts in the U.S. With our state-of-the-art equipment, we can process up to 250,000 lamps per day. Our fully permitted facilities offer safe environmental recycling of fluorescent lamps and ballasts in all 50 states. We service a broad range of customers that includes utilities, institutions, municipalities, retailers and Fortune 500 companies. Federal, state and local regulators endorse recycling as the preferred method of disposal.

Customized Recycling Services Whether you need our recycling services for a few lamps and ballasts, resulting from spot maintenance, or for a large number, in conjunction with a major re-lamp or retrofit project, we can develop a recycling program that meets your needs. Everything can be included in our recycling programs—packaging, transportation, tracking documents, waste processing, and written documentation that details what materials were recycled. These programs comply with all environmental regulations.

Regulatory Requirements The following regulations apply to most lighting waste: federal Resource Conservation and Recovery Act (RCRA), the Toxic Substances Control Act (TSCA), the Superfund liability laws and the Universal Waste Rule. See pages 10-14 for detailed information on regulatory requirements.

Hazardous Waste Many lamps contain mercury, which is considered a hazardous substance. When lamps or tubes containing mercury are broken, mercury is released into the air as mercury vapors or into the water through runoff or leaching from landfills.

Recycling Mercury Waste Types of Mercury Waste Recycled • Fluorescent and HID lamps • Electrical devices • Precision instruments • Medical apparatus • Mercury compounds • Dental amalgam • Debris and contaminated soil • Automotive switches • Thermostats

Veolia ES Technical Solutions has developed state-of-the-art distillation and retort technologies that use advanced mechanical and thermal processes to extract the highest possible levels of mercury from a variety of devices. These processes recover valuable materials, and the by-products are recycled and reused to manufacture new products. We reclaim over 99% of mercury from wastes that contain mercury. Our processes are in compliance with EPA, OSHA and state agency requirements. Mercury has traditionally been used in medical and electrical devices, precision instruments and with other elements to form compounds for industrial applications.

Customized Recycling Services Environmental Fact Mercury from one four foot lamp can contaminate 7,000 gallons of water.

A recycling program can be developed to fit your needs, depending upon the quantity of materials you need to recycle. We'll assist you with profiling and can provide containers and labeling in order to transport and dispose of any items containing mercury, safely and legally. We determine the best container size and composition for your waste and coordinate convenient pick-up intervals.

Regulatory Requirements The following regulations apply to mercury waste: federal Resource Conservation and Recovery Act (RCRA) and the Universal Waste Rule. See pages 10-14 for detailed information on regulatory requirements.

Hazardous Waste Mercury is considered a hazardous waste. When items containing mercury are broken, mercury is released into the air as mercury vapors or into the water through runoff or leaching from landfills.

Recycling Power Distribution Equipment Types of Electrical Equipment Recycled • Transformers • Regulators • Capacitors • Circuit breakers • Re-closers • Switch gear • Bushings • Arrestors • Wire, cable and oil

Veolia ES Technical Solutions has the capabilities to handle both non-PCB and PCB contaminated materials and offers a unique combination of recycling and total destruction services, which include testing, draining, recycling, and asset recovery services for all types of electrical equipment. Retired electrical equipment may contain regulated materials such as asphalt potting compounds, used oil, polychlorinated biphenyls (PCBs) or PCB contaminated oils.

Customized Recycling Services Environmental Fact PCB Production was banned in 1978 due to the high toxicity of PCBs.

Here at Veolia, we evaluate each project to match environmental requirements to cost effective solutions, which may include recycling, landfill, incineration or a combination of each. Trained in a wide range of processing technologies with extensive knowledge of metal recovery markets, our on-site teams are available to manage the decommissioning, testing and removal of all types of electrical equipment. Our disciplined, strategic approach ensures maximum values for valuable ferrous and non-ferrous metals and oils extracted.

Regulatory Requirements PCB wastes are regulated under the Toxic Substances Control Act (TSCA). Decontamination (recycling) is one of the approved disposal methods contained in the TSCA regulations for PCB equipment. PCBs are also identified as a hazardous substance under the Superfund liability laws and the federal Resource Conservation and Recovery Act (RCRA). See pages 10-14 for detailed information on regulatory requirements.

Regulated Waste Polychlorinated Biphenyls (PCBs) Non-PCB waste Lead Mercury

RECYCLEPAK® Why Use RECYCLEPAK®? • Compliance with municipal, state and federal regulations • Reduced administrative burden • No contracts • Cost effective • Easy to order • Easy to use • Expert help available

How it works • Order your containers • Fill them with items to be recycled • Seal the containers • Ship the containers • Receive a record that your waste was disposed of safely

Call Toll Free 1-888-669-9725 or Order Online www.LampRecycling.VeoliaES.com

RECYCLEPAK® makes recycling easy. The prepaid recycling program ensures compliance and reduces the risk of contamination from storing hazardous materials at your facility. When using RECYCLEPAK®, simply fill, seal and ship—it's that easy! One price includes everything you need to begin recycling—packaging, prepaid freight from your facility, processing, and certificates of recycling. Simply order, fill, seal and ship with the prepaid shipping label.

Regulatory Requirements The following regulations apply to most lighting and battery waste: federal Resource Conservation and Recovery Act (RCRA), the Toxic Substances Control Act (TSCA), the Superfund liability laws and the Universal Waste Rule. See pages 10-14 for detailed information on regulatory requirements.

Customized Recycling Services With RECYCLEPAK®, you customize your recycling program by ordering what you need, when you need it. RECYCLEPAK® is the perfect solution for small quantities of fluorescent lamps, ballasts, batteries, computer electronics and items containing mercury. Our award winning program has been used by thousands of companies across the country for routine maintenance and for rolling out national recycling programs. RECYCLEPAK® is ideal for spot lamp maintenance as well as re-lamp and retrofit projects.

What’s included in RECYCLEPAK® • Outbound shipping to your business • Step-by-step instructions • Waste shipping containers—Choose from small, medium, large and bulk recycling kits for 4 foot or 8 foot fluorescent lamps, HIDs and u-tubes; 5 gallon pails for lamps or ballasts; 3½ gallon, 1 gallon and ½ gallon pails for dry cell batteries. • Prepaid return shipping labels • Prepaid destruction or recycling • Tracking documents

Emergency Response Emergency Response Services • Spill response—transportation, marine, plants • Compressed gas emergencies • Container remote opening • Industrial firefighting • Emergency waste removal and disposal • Emergency remediation • Reactives/explosives disposal • Site clean-ups—fires, storm, disasters

Regulatory Compliance • Coordination with government agencies • DNR Response • Contingency plans

Specialized Capabilities • Rail, pipeline, marine and over-the-road • Specialized off-loading equipment and techniques • Compressed gas transfers • Marine services • Contractor

Veolia’s Emergency Response team is on call 24 hours a day, 365 days a year for any type of environmental emergency. With over 45 sales, services, treatment and disposal facilities throughout the United States, Veolia ES Technical Solutions is positioned to respond quickly to emergencies at any location. Call your local branch emergency response number, or our 24-Hour Emergency Hotline 800-688-4005, and our knowledgeable staff will gather essential information to dispatch the specialized equipment and personnel to the emergency location and initiate our emergency response procedures. From the initial dispatch to final site clean-up, our turnkey services assure regulatory compliance with federal, state and local requirements.

Customized Services Each emergency situation is different. Veolia ES Technical Solutions has a wide range of experience in emergency response and depends on this experience to handle each new situation quickly and efficiently, while assuring regulatory compliance. Veolia’s Spill/Incident Management Team arrives at the emergency location to stabilize and clean-up the site. Each member of the response team is trained and certified to perform response activities. During the emergency situation, we can coordinate with local fire and police departments and any other government agencies as your emergency response liaison.

Contingency Planning 24/7 Hotline 800-688-4005

A Contingency Plan is a critical component of cost effective emergency response for environmental emergencies and disasters. Planning for emergencies decreases response time and minimizes the length of time that normal activities are not possible. Veolia ES Technical Solutions develops contingency plans for industrial and governmental entities to provide the fastest possible response times for emergency situations.

Veolia ES Industrial Services, our sister company, also provides emergency response services – See page 7. 25

Fuels Blending (Energy Recovery) Facility Services • Bulk high and low BTU and halogen liquids blending • Drum liquid, sludge and solid processing • Consolidation programs for Reclamation, Treatment, Incineration and Landfill • Depack/Repack programs for laboratory chemicals and household hazardous wastes • Bulk and drum transportation

Unique Services • Drum dispersion processing at our Middlesex, NJ and West Carrollton, OH facilities • Rail car receiving at our Middlesex, NJ, Azusa, CA, and Henderson, CO facilities • Automated tanker cleaning services at our West Carrollton, OH facility

Veolia ES Technical Solutions owns and operates four energy recovery facilities, located in Azusa, CA, Henderson, CO, West Carrollton, OH and Middlesex, NJ. All of our facilities are equipped to manage BTU containing wastes shipped in drums, totes, or tankers. Our energy recovery experts are skilled at preparing the proper mix of BTU containing wastes for use as an alternative fuel at audited and approved cement kilns. Veolia’s energy recovery services help minimize your environmental impact by displacing the use of oil, coal or gas in cement kilns with a “green” fuel produced from our high BTU liquid, sludge and solid organic wastes. This process is an environmentally friendly alternative to more traditional disposal methods.

Customized Services Veolia’s energy recovery facilities are fully permitted and equipped to process a wide variety of hazardous and nonhazardous wastes. In addition to our comprehensive energy recovery services, we offer customers the flexibility to ship wastes for reclamation, incineration, waste to energy and landfill technologies in a single shipment, reducing your logistics costs. Veolia economically processes a wide variety of these materials internally and transships all other wastes to audited and approved facilities.

Experience Veolia’s technical representatives are knowledgeable and trained, with extensive experience in energy recovery. They are conveniently available to assist with your regulatory, waste approval or general inquiry questions. Our waste stream approval process is efficient and can be completed by registered users with our online tools at www.veoliaes-ts.com.

Azusa, CA

Middlesex, NJ

• Bulk High and Low BTU, Halogen and Water Liquids Blending Tank Farm • Solid and Liquid Waste Consolidation Programs for Energy Recovery, Incineration, Waste to Energy and Landfill • Bulk and Container Organics Recovery • Railcar Accessible • Over 5 million gallons recovered annually

• Bulk High and Low BTU, Halogen and Water Liquids Blending Tank Farm • Solid Waste Consolidation Programs for Energy Recovery, Incineration, Waste to Energy and Landfill • Bulk and Container Organics Recovery • Railcar Accessible and Cleaning • Nearly 8 million gallons recovered annually

Henderson, CO

West Carrollton, OH

• Bulk High and Low BTU, Halogen and Water Liquids Blending Tank Farm • Container Dispersion Unit for Sludges and Solids • Solid Waste Consolidation Programs for Energy Recovery, Incineration, Waste to Energy and Landfill • Depack and Repack Programs for Laboratory Chemicals and Household Hazardous Waste • Bulk and Container Organics Recovery • Tanker Cleaning • Nearly 6.5 million gallons recovered annually

Healthcare Services Best Management Practices Although the Resource Conservation and Recovery Act (RCRA) imposes requirements for the disposal of certain pharmaceutical wastes, environmental responsibility extends beyond regulatory requirements. Veolia ES Technical Solutions can help your facility identify Best Management Practices and implement them in your organization. For example, approximately 5% of commonly used pharmaceuticals are defined as hazardous waste under the Resource Conservation and Recovery Act (RCRA) and include nine chemotherapeutic agents, epinephrine and warfarin. These regulations have not been updated in over 30 years, and many more drugs that are not subject to the regulations are equally hazardous. Included in this category are over 100 newer chemotherapy drugs, endocrine disruptors and drugs meeting NIOSH hazardous drug criteria. Best Management Practices dictate that these drugs be managed as though they were subject to regulation under RCRA.

Precautionary Principle The Precautionary Principle is an approach to environmental practices that is under consideration by the Science and Environmental Health Network as a basis for environmental and public health policy and is gaining acceptance throughout the scientific community. This approach requires the proponent of an activity that appears to have adverse environmental effects to bear the burden of proving that the activity does not have deleterious consequences. Every healthcare institution must determine whether its disposal practices meet the Precautionary Principle. The Joint Commission has established standards regarding hazardous materials and wastes that accredited institutions must follow. These standards require healthcare institutions to develop a written management plan for hazardous materials and to maintain an inventory list, which identifies related wastes. Healthcare institutions are directed to implement processes that minimize improper disposal of pharmaceutical wastes.

Dental Amalgam and Waste Types of Dental Waste • Inline filters • Non-contact amalgam • Contact amalgam • Chair side traps environment • Vacuum pump filters • Amalgam sludge • Empty amalgam capsules • X-ray fixer • Lead foil or lead shields

What’s Included in RECYCLEPAK® • Outbound shipping to your business in special dental waste containers • Step-by-step instructions • Waste shipping containers • Prepaid return shipping labels • Prepaid recycling • Tracking documents • Certificates of recycling

Call Toll Free 1-888-669-9725 or Order Online www.prepaidrecycling.com

Veolia ES Technical Solutions has developed an easy way to recycle amalgam and dental waste, a practice recommended by the American Dental Association (ADA). The ADA urges dental offices to avoid disposing dental amalgam waste in the garbage, infectious waste “red bag” or a sharps container. We now offer prepaid, mail-back disposal kits called RECYCLEPAK®. One price includes everything you need—packaging, freight, environmental compliance, reclamation and certificates of recycling.

RECYCLEPAK® RECYCLEPAK® is a comprehensive prepaid recycling program* that’s easy to use and allows you to recycle toxic and hazardous dental waste in compliance with federal, state and local regulations. With RECYCLEPAK® you’ll receive certification to document the recycling. Using state-of-the-art distillation and retort technologies that use advanced mechanical and thermal processes, we extract the highest possible levels of mercury from many different types of waste, including dental amalgam waste. For more information, see page 24.

Regulatory Requirements The following regulations apply to mercury waste: federal Resource Conservation and Recovery Act (RCRA). See pages 10-14 for detailed information on regulatory requirements.

Why Recycle Mercury and lead can be considered hazardous materials and could be found in dental waste. If disposed of as solid waste, improperly incinerated or washed down a drain, these items can contaminate our environment. Environmental regulations require this waste be managed properly. Failure to follow regulations could result in costly environmental liability and adverse publicity. You may be at risk if you’re not recycling. *NOTE: This program is NOT CURRENTLY AVAILABLE IN THE FOLLOWING STATES: Alaska, Arkansas, Hawaii, Maine, and Rhode Island, or in Puerto Rico. Please call for details. 29

Medical Waste Services Regulated Medical Waste Chemotherapy waste Radioactive biohazardous waste Pharmaceutical waste Sharps waste Chemical sharps waste

Medical Waste Services Staff training Waste segregation containers, labeling Flexible pick-ups Online shipping documents, manifests Recommendations for waste minimization Protocols for regulatory compliance

Veolia ES Technical Solutions provides medical waste disposal services in conjunction with our pharmaceutical waste services. Medical waste treatment can take place at Veolia facilities if the waste is both medical and RCRA, or at audited and approved third party partner facilities. Our third party partners can supply the following services.

Customized Services The process begins by identifying the key services that youâ&#x20AC;&#x2122;ll need. Once these services are determined, our partners train your staff to assure that waste stream segregation is understood and that procedures are strictly followed. A convenient bin location is important, and they are careful to provide appropriate sizes and shapes, with required labels, packaging and signage. Personnel are thoroughly trained in safety procedures. All waste is tracked through our proprietary computer system, from pick-up at the department where the waste is generated through transfers and treatment to final disposal. Bar coding for waste is available. All shipping documents and manifests can be viewed and downloaded online for documentation. Regular pick-ups are scheduled, but they can be revised as needed. Service is available throughout the U.S. An initial review of your waste streams provides recommendations for reducing waste in order to minimize your costs, including detailed breakdowns of waste and associated costs. They also conduct compliance audits and can help you develop systems for your training records. Disaster planning and emergency preparedness services are also available.

Regulatory Requirements The majority of medical waste generated in the U.S. is regulated at the state and local level, as provided through the Medical Waste Management Act. Environmental Health and Safety agencies in each state have requirements for medical waste segregation, labeling for waste containers, treatment and disposal, and specialized waste, such as chemotherapy, pharmaceutical, radioactive biohazardous and sharps. Our partnerâ&#x20AC;&#x2122;s representatives understand and stay abreast of any changes in federal, state and local requirements to assure compliance at all regulatory levels.

Pharmaceutical Waste Examples of Waste Managed Chemotherapy Waste DEA Controlled Substances Chloral hydrate, Phentermine Dermal Patches Dual Waste RCRA hazardous and Infectious Expired Pharmaceuticals Hazardous Waste under RCRA P-listed waste, U-listed waste and waste demonstrating ignitability, corrosivity, reactivity, or toxicity P-Listed Pharmaceuticals Arsenic trioxide, Epinephrine, Nicotine, Phentermine, Physostigmine, Physostigmine salicylate, Warfarin >.3% Personal Protective Equipment (Contaminated) RCRA Hazardous Waste (Laboratory) Ignitable, Corrosive, Reactive, Toxic spill materials Partial list of U-Listed Pharmaceuticals Chlorambucil, Cyclophosphamide, Daunomycin, Dichlorodifluoromethane, Diethylstilbestrol, Hexachlorophene, Lindane, Melphalan, Mercury, Mitomycin C, Reserpine, Selenium sulfide, Streptozotocin, Trichloromonofluoromethane

Veolia ES Technical Solutions will determine relevant regulatory requirements for your organization and will identify additional steps to follow under Best Management Practices. In every case, we provide cost effective, environmentally safe practices that can be incorporated into daily routines. Our field technicians undergo extensive and continual training to assure that they are current with all safety, health and environmental requirements.

Customized Services We begin with an on-site waste consultation to assess your current status of compliance. By evaluating your existing systems, including a formulary review, we can target those areas where your facilities may be exposed to regulatory action. Our systems allow online waste shipment tracking for quick access to your waste streams and manifestsâ&#x20AC;&#x201D; track shipment locations, transport methods and the final disposal location.

Regulatory Requirements When the Resource Conservation and Recovery Act (RCRA) was enacted in 1976, industrial waste was the primary focus in controlling waste disposal activities. Management of hazardous pharmaceutical waste is an area that was not targeted at that time but definitely falls under regulatory purview. State regulations may be more stringent than federal requirements and vary by state. Approximately 5% of commonly used pharmaceuticals are defined as hazardous waste under RCRA and include nine chemotherapeutic agents, epinephrine and warfarin. These regulations have not been updated in over 30 years, and many more drugs that are not subject to the regulations are equally hazardous. Included in this category are over 100 newer chemotherapy drugs, endocrine disruptors and drugs meeting NIOSH hazardous drug criteria. Best Management Practices dictate that these drugs be managed as though they were subject to regulation under RCRA.

Easy Disposal of Sharps What’s included in SHARPS+PAK® • Outbound shipping to your business • Step-by-step instructions • Waste shipping containers • Prepaid and pre-addressed return shipping labels • Prepaid destruction • Tracking documents

Why Use SHARPS+PAK®? • Compliance with municipal, state and federal regulations • Reduced administrative burden • No contracts • Cost effective • Easy to order • Easy to use • Expert help available

Veolia ES Technical Solutions has developed an easy way to dispose of regulated medical waste sharps safely and legally. We now offer prepaid, mail-back disposal kits called SHARPS+PAK®. One price includes everything you need for proper management of regulated medical waste—outbound shipping, the kit itself, return postage, destruction of the sharps and proof of destruction.

SHARPS+PAK® The SHARPS+PAK® kits are available with containers in several different sizes. They include an approved plastic sharps container, a return mail-back box with a poly containment liner and a multipart tracking form. All containers have been approved by the U.S. Postal Service. Mail-back sharps disposal is one of the disposal methods recommended by the U.S. Environmental Protection Agency.

Definition of Sharps Sharps include any contaminated sharp instrument used in the medical industry, such as needles, syringes, scalpels, lancets, orthodontic wires, blood tainted knife blades, contaminated broken glassware and glass slides.

Regulatory Requirements The majority of medical waste generated in the U.S. is regulated at the state and local level. State regulations generally cover potentially infectious medical waste, sometimes referred to as regulated medical waste. Sharps are one of the categories of regulated medical waste. Sharps are also regulated under OSHA's Bloodborne Pathogens Standard, which requires a written Exposure Control Plan to minimize employee exposure to disease and includes placing contaminated sharps into containers immediately after use.

Risk of Exposure to Disease Improper management of discarded needles and other sharps can pose a health risk to the public and waste workers. Improperly discarded needles may expose waste workers to potential needle stick injuries and potential infection. Janitors and housekeepers also risk injury if loose sharps poke through plastic garbage bags. Used needles can transmit serious diseases, such as HIV and hepatitis. 32

Household Hazardous Waste Potential Sources of Household Hazardous Waste Automotive Products—Antifreeze, motor oil, refrigerants, starter fluids, batteries, fluids, carburetor and fuel injection cleaners Cleaning Products—Oven, drain, and bathroom cleaners, laundry bleach, pool chemicals Computer Equipment—PC’s, central processing units, printers, scanners, keyboards, circuit boards, monitors Electronic Equipment—VCR’s/DVD’s, stereos, telephones, copiers, fax machines, televisions Indoor Pesticides—Insect sprays and baits, rodent poisons Lawn and Garden Products—Herbicides, insecticides, fungicides/wood preservatives Miscellaneous Items—Batteries, mercury thermometers, fluorescent light bulbs, pharmaceuticals, propane/gas cylinders, kerosene, oil and fuel Pharmaceuticals–Antibiotics, hormone regulators, pain killers, chemotherapy drugs, and over-the-counter remedies Workshop Supplies—Adhesives, furniture and paint strippers, stains and finishes, oil or enamel based paint thinners, turpentine

Every household, farm and small business in America generates wastes that can be hazardous to human health and the environment. Quite a few common household products contain hazardous chemicals that are poisonous, corrosive, reactive and ozone depleting. Included in this group are many lawn and garden products, automotive and household cleaning products, Freon refrigerants, pharmaceuticals, batteries and most computers and electronic equipment. Veolia has assisted over 2,500 city and county governments across the United States in organizing, promoting and managing household hazardous waste collection programs to assure that these wastes are managed safely and in the most environmentally responsible manner. Wherever possible, we promote recycling, reclamation, and reuse of these chemicals. This approach helps reduce our carbon footprint while protecting human health and the environment.

Customized Community Services Developing effective collection programs for household hazardous waste requires careful planning, publicity, efficient collection systems, and appropriate recycling and disposal. We have organized collections for community household hazardous waste and for specialized waste, such as agricultural, chemicals or pharmaceuticals. Our services include: • Event planning, including site selection, promotion and assistance in proposal preparation • Collection site setup and traffic control • Unloading, segregating and classifying wastes • Packaging, bulking, inventorying and labeling wastes • Manifesting, transporting and recycling or disposal of collected materials • Completion of required reports

Prescription Drug Collection

Environmental Fact

We have also developed collection programs for unused prescription drugs and other pharmaceuticals. By working with local law enforcement officials to accept controlled substances, we comply with U.S. Drug Enforcement Agency requirements. All collected medications are incinerated at one of Veolia's facilities.

Americans generate 1.6 million tons of household hazardous waste each year.

Veolia Environmental Services provides trained field service teams at your collection event and assures compliance with all applicable regulations when disposing of items. 33

Incineration Services Excellent Safety Record Experience Modification Rate The Experience Modification Rate (EMR) is a widely used indicator developed by the insurance industry. It is used to determine premiums for workers compensation insurance and is based on a company's past safety performance. Companies in similar types of businesses are compared to develop the rating. An EMR of 1 indicates that the company's safety record is average for its industry; less than 1.0 demonstrates a safety record that is better than average. Veolia Environmental Services, Technical Solutions 2012 Experience Modification Rate (EMR) 0.81 2012 OSHA 300 Log Summary Recordable Injury Case Rate 2011 NAICS Group Average 4.90 2012 Veolia Environmental Services, Technical Solutions 2.08 Lost Time Injury Case Rate 2011 NAICS Group Average 1.00 2012 Veolia Environmental Services, Technical Solutions 0.94

Veolia ES Technical Solutions offers incineration services for all types of hazardous and nonhazardous waste. Our facility in Sauget, IL provides assured destruction services and a closed loop system for odiferous or reactive waste. We are licensed by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) to store and destroy explosives and authorized by the U.S. Drug Enforcement Administration (DEA) to witness destruction on your behalf. A second facility, Gulf Coast Service Center, located at Baytown and Port Arthur, TX, accommodates any type of waste, shipped via rail or truck, in bulk and/or drums. Everything can be shipped together and separated when it arrives.

Customized Services We evaluate each project to match environmental regulatory requirements to the most cost effective solutions for your needs. Our experienced incineration team provides technical expertise to assure compliance.

Technical Expertise Veolia Environmental Services technical representatives are thoroughly trained in safety and environmental regulations and are ready to assist you in any way. • Providing information on governmental regulations • Answering technical questions about treatment alternatives • Training your employees • Setting up disposal programs designed to save you time and money

Specialty Waste Incineration and Assured Destruction Specialty Waste Capabilities Air bag actuators Ammunition Blasting Caps Bomb Components DEA Controlled Substances Explosives Reactive Liquids Reactive Metals Reactive Solids Odiferous Liquids Pyrophoric Gases Assured Destruction Compressed Gases Virtually all Types of Waste Accepted— Hazardous or Nonhazardous, except PCB

Candidates for Assured Destruction • Chemicals Designated as DEA Controlled Substances • Drugs • Goods with Expired Dates • Seized Goods • Returned Goods • Lab Chemicals

Facility Information US EPA ID# ILD 098642424 Thermal Throughput One unit at 50 million BTU/hour Two units at 16 million BTU/hour each Capacity 35,000 tons/year Permits Part B, CERCLA, RCRA, ATF

Veolia ES Technical Solutions’ Sauget, IL facility provides incineration services for virtually any type of waste, even unusual, specialty waste and controlled substances. We are authorized to process all types of explosives and any waste requiring a closed loop system, such as odiferous or reactive liquids, pyrophoric gases, solids and liquids. We are also authorized by DEA to witness destruction on your behalf and accept DEA regulated and DEA/RCRA regulated materials with turnkey services. All steps are handled by Veolia personnel and facilities, from on-site pick-up through transport and incineration. Veolia Environmental Services is registered with the DEA as a Reverse Distributor.

Customized Services The facility is licensed by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) to store and destroy explosives, which include anything from air bag actuators and ammunition to blasting caps and munition components. Veolia employees receive extensive training to identify, handle and repackage explosives for incineration. The rotary kiln has been retrofitted with unique designs to accommodate explosives. All systems are closed loop. Our assured destruction service includes completing all required forms, taking possession of the substance or product, and witnessing the destruction on your behalf. If you prefer, you can observe the receipt, storage and incineration process. We have performed these services for a wide range of materials on behalf of both government and private customers. Brand protection is assured through a state-of-the-art security camera system, and anonymity is guaranteed.

Regulatory Requirements Incineration is an acceptable disposal method for hazardous and nonhazardous wastes that are regulated under the Toxic Substances Control Act (TSCA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the federal Resource Conservation and Recovery Act (RCRA). See pages 10-14 for detailed information on regulatory requirements. The United States Drug Enforcement Administration (DEA) regulates certain chemicals by requiring strict tracking from the time of manufacture to the time of dispensation to the consumer. They are called Controlled Substances and can be found in Title 21 of the Code of Federal Regulations (CFR) section 1300.

Flexible Waste Processing Incineration Capabilities and Services Direct inject capabilities for hard to handle liquids Low flash waste treatment Cleaning of customer roll-off containers Bulk rail shipments accepted Tanker cleaning PCB destruction Baytown OSHA VPP Star Status

Facility Information US EPA ID# TXD000838896 Thermal Throughput 150 million BTU/hour Capacity 60,000 tons/year Permits CERCLA, RCRA, TSCA, Permitted TSDF

Virtually all types of waste accepted— hazardous or nonhazardous Aerosols Drum Liquid Drum Solid Drum Sludge Bulk Liquid Lab Packs PCB Drum Liquid Bulk Solids and Sludges Cylinders PCB Capacitors PCB Drum Solids and Sludges PCB Bulk Solids and Sludges PCB Bulk Liquid Dual Waste—RCRA and Infectious

Our Gulf Coast Service Center is located in Baytown and Port Arthur, TX. Because of its unique processing capabilities, this facility offers the most flexible requirements in the industry. Any quantity and any type of waste are accepted, shipped any way you like— in bulk and/or drums, arriving by rail or truck. No samples are needed for most drummed waste. The facility houses state-of-the-art incineration technology, which includes a large rotary kiln with secondary combustion chamber design. Air pollution control systems provide gas cleaning, neutralization, particulate removal and thermal oxidation of fumes and process air. A wet electrostatic precipitator further reduces emissions.

Customized Services Wastes requiring different treatment technologies can all be shipped to the Gulf Coast Service Center. For example, solvent for recycling, treatment sludges for landfill, and organics for incineration can be shipped to us in one truck. For bulk wastes requiring incineration, a large receiving pit mixes waste for optimum receipt and processing efficiency. There is a separate nitrogen inerted shredding system for low flash waste streams, which minimizes fires. A hydraulic ram feeder manages mixed low flash solids, sludges and liquids to the rotary kiln. The Gulf Coast Service Center provides every service required for processing your waste—customer service center, treatment storage disposal facility (TSDF) and incineration facility. One example of the benefits of our streamlined processing is that roll-off containers are tracked to insure rapid turnaround, reducing customer rental charges. This facility also offers low cost roll-off cleaning services and has the capabilities to handle both non-PCB and PCB contaminated materials.

Laboratory Chemical Services Services Identify and analyze laboratory chemicals Relocate laboratory chemicals Handle and dispose of reactive chemicals Remove any quantity of chemical waste, including less-than-truckload amounts Destruction of controlled substances

Quality Assurance Periodic environmental and technical audits of all disposal sites Packaging methods meet all regulatory standards, maximize usable volume, decrease costs and enhance safety. Customized computer tracking system documents movement of all chemical waste from your site to final disposal.

Veolia ES Technical Solutions provides a full range of laboratory chemical services, distinguished by an unusually high level of service, with strict attention to detail. Our experienced, trained professionals are dedicated to following procedures that provide accurate identification, proper packaging, transportation, and disposal to meet regulatory guidelines for your laboratory chemicals. These procedures have been carefully developed to assure safety and compliance.

Customized Services Every laboratory houses a unique group of chemicals. Veoliaâ&#x20AC;&#x2122;s experienced team follows procedures that include detailed, methodical identification and categorization to assure proper packing and disposal of each chemical. All of our technicians have been trained and certified. Appropriate packaging methods are selected to maximize usable volume, decrease costs and enhance safety. All chemical waste is tracked through our industry leading computerized field system to document movement at every point of transportation and disposal. We can also evaluate your laboratory practices to help develop programs that minimize the generation of laboratory chemical wastes at your site. Our methods have become the industry standard for cutting edge technology and environmental suitability.

Regulatory Requirements Laboratory chemicals may be subject to regulation under the federal Resource Conservation and Recovery Act (RCRA). See pages 9 â&#x20AC;&#x201C; 13 for detailed information on regulatory requirements.

Chemical Inventory Laboratory Safety Tips Conduct unannounced laboratory inspections to identify hazardous conditions and unsafe practices. Minimize amounts of flammable liquids in a laboratory. Store acids and bases separately. Store fuels and oxidizers separately. Monitor safety practices—e.g, use of a ventilated hood for hazardous chemicals. Require the appropriate eye protection in laboratories and any area where chemicals are transported. Safety equipment should always be available, including: • Personal protective equipment • Fire extinguishers, safety showers, eye wash fountains, first aid kits, fire blankets and fume hoods in each laboratory, which are tested or checked monthly • Guards on all vacuum pumps • Secure all compressed gas cylinders • First aid equipment Label all chemicals with the name, the type and degree of hazard, and precautions. Date all stored chemicals and recertify or discard them after a maximum storage period. Fireproof cabinets to store flammable chemicals. Store chemicals in well ventilated areas.

Management of hazardous materials, from initial procurement to proper disposal as chemical waste is a critical component of laboratory safety and compliance. Veolia ES Technical Solutions provides chemical inventory services to help monitor the quantities of hazardous waste in a laboratory. An annual inventory is recommended to eliminate outdated or unnecessary chemicals and assures that unnecessary quantities of chemicals are not purchased.

Customized Services Our chemical inventory service documents the quantities and types of hazardous chemicals in your laboratory. In addition to quantifying your chemicals, we will provide safety guidelines that are customized for the chemicals that are common in your laboratory. Our technicians are trained to handle all types of hazardous chemicals. A potentially dangerous situation can be averted through regular chemical inventories.

Regulatory Requirements Hazardous waste disposal is regulated under the federal Resource Conservation and Recovery Act (RCRA). States may have additional regulatory requirements. See pages 9 – 13 for detailed information on regulatory requirements.

Chemical Moving Services Moving Tips • Clean and decontaminate laboratory surfaces, including work surfaces, shelves, chemical fume hoods and benches. • Wear gloves and eye protection when removing biological and chemical hazards. • Areas where radioactive materials were used or stored must be decontaminated. • Attach safety caps to compressed gas cylinders. • Biological safety cabinets must be decontaminated before moving. • Freezers with biological materials do not need to be emptied before moving. • Refrigerators must be emptied before moving. • Qualified personnel must move: liquid nitrogen freezers, equipment containing hazardous materials, liquid scintillation and gamma counters, x-ray machines, any device containing a radioactive source.

Building a new lab? Relocating or reconfiguring research areas? There are many reasons why you may be faced with moving chemicals. When you want professionals to handle the move, call Veolia ES Technical Solutions. Veolia ES Technical Solutions draws on its expertise in handling hazardous waste daily to provide safe, comprehensive chemical moving services. Chemicals are properly packaged by our trained technicians and transported with the appropriate vehicles from our extensive fleet, which may include refrigeration, if necessary to insure chemical stability.

Customized Services Our chemical moving services begin with coordination of laboratory locations, so the chemicals are delivered to the appropriate area at the new location. All chemicals are packaged with DOT approved materials and are transported in company vehicles. Our technicians are trained to handle all types of chemicals. Your chemical inventory is logged into our field service computer system to assure that all chemicals can be tracked to their final destination. Any out of date chemicals are disposed of properly and legally.

Regulatory Requirements Hazardous waste disposal is regulated under the federal Resource Conservation and Recovery Act (RCRA). See pages 9 – 13 for detailed information on regulatory requirements.

Equipment Decontamination Contamination Animal feces Chemicals Heavy metals Oil PCBs

Facilities Chemical tanks Hazardous waste storage areas High voltage transformer vaults Individual equipment PCB transformers Plating tank lines Transformer pads

Processes Bleach solutions Chemical cleaning HEPA negative air machines High efficiency particulate air filter vacuums Pressure washing Scraping Solvent washing Steel cutting Triple wash and rinse Vapor degreasing

Veolia ES Industrial Services, our sister company, also provides equipment decontamination services. See page 7.

Veolia ES Technical Solutions provides equipment decontamination services for any size job, from one piece of equipment to a complete facility. Our team of specialists determines the technique most suitable for the type of contamination and completes the job as quickly as possible. Depending on the situation, the techniques may rely primarily on manual labor or may require sophisticated equipment with specialized training. We assure compliance with all local, state and federal regulations in our processes and in delivering thorough decontamination.

Customized Services Whether you are decontaminating in anticipation of a real estate transaction or the decontamination is mandated through a RCRA closure of a hazardous waste storage area, our services are customized to your particular needs. We provide a decontamination solution that meets whatever requirements the situation demands and complies with all applicable regulations. We use the proper equipment and apply the correct techniques to complete the decontamination process expeditiously. Final sampling is provided.

Regulatory Requirements Closing hazardous waste storage areas in particular may be subject to regulation under the federal Resource Conservation and Recovery Act (RCRA). Other regulations, such as the Toxic Substances Control Act (TSCA) or the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), may apply. See pages 10-14 for detailed information on regulatory requirements.

Lab Packing Lab Packing Computer System Highlights Alerts for special handling Chemical library of 50,000 chemicals and compounds Cylinder management Daily uploads Inventory imports Medical waste manifesting Packing slip summary—container weight, EPA waste codes, content details Preprinted forms reduce errors Reactives identified Real time information

The key differences between the lab packing services provided by Veolia ES Technical Solutions and those offered by other companies are our people, our training and our field systems. Extensive training assures that all of our personnel follow required procedures. Our proprietary field computer system provides our technicians with proper packaging protocol, treatment methods and RCRA and DOT documents. It automatically documents each step of hazardous waste processing, packaging, transportation and disposal. The system is programmed to ensure compliance with the latest requirements under applicable regulations from the Department of Transportation and the Environmental Protection Agency. Our field computer system includes a chemical library of over 50,000 chemicals and compounds, which can be referenced online to develop waste information profiles onsite quickly and accurately. All existing profiles can be viewed and edited for each customer, so duplicate profiles are never created. Each container of waste is identified separately, including its contents and its exact point of generation. Every component of a lab pack can be tracked individually.

Customized Services Project information is uploaded daily at each field office “real time” via connection to the Veolia network. The field system uses project-specific information to generate labels, manifests and Land Disposal Restriction forms quickly and easily, with minimal data entry. This process assures data integrity, compliance, and consistency. Only those disposal sites that have been approved by the customer can be designated for shipments. On-site employees cannot override the list of approved facilities, and the system allows only approved facilities to be specified prior to shipment. When there’s unanticipated waste, the Veolia field computer system is completely flexible. We just write up the waste information profile, obtain approval for shipping and ship, all in one easy step.

Regulatory Requirements Veolia ES Technical Solutions’ field computer system handles the complexities of hazardous waste disposal, while assuring that all environmental and transportation regulations are satisfied. State requirements are also satisfied. 41

Low-Level Radioactive Waste Services Identify and classify radioactive and mixed wastes Obtain approvals for disposal at our facilities Package wastes efficiently, cost effectively Complete all manifests and shipping papers Arrange transportation to the disposal facility Answer technical questions Licensed facility access Source recovery Motor and pump refurbishment Spent fuel shipping Machine shop with “N” stamp weld and fabrication Storage Coatings and painting

Veolia’s Alaron Nuclear Services (Veolia) provides services to companies with radioactive waste, equipment and components. The company is licensed by the Pennsylvania Department of Environmental Protection and has been providing services to the nuclear industry for over twenty years. The facility is located in Wampum, Pennsylvania and includes 26 acres with over 150,000 square feet of indoor processing area. Alaron’s NRC Licenses allow for the processing, decontami-nation, storage, packaging, and handling of radioactive material and equipment.

Customized Services A broad range of services are offered, which include allowing other companies to per-form work with contaminated equipment at the Alaron facility, transporting almost any type of contaminated material, decontaminating equipment, refurbishing motors and pumps, storing materials, and applying coatings and paints. Specific services include: • Asset Recovery—Decontamination services to allow for the reuse of assets • Coatings & Painting—Nuclear Service Level 1 surface preparation and coating services • Low-Level Radioactive Waste—Dry active waste processing • Licensed Facility Access—Work under Veolia's Radioactive Materials License • Machine Shop—Nuclear licensed machining equipment • Metals & Large Components—Process and decontaminate over-sized contaminated components • Motor & Pump Refurbishment—Repair and refurbishment services for small and large motors • Source Recovery—Sealed source recovery and recycling for radioactive applications • Contaminated Asset Storage—Interior and exterior monitored and inspected storage • Transportation—Transportation services for radioactive materials, including truck and rail access • Lead Blankets—A case study on the decontamination and recycling of lead blankets

Radioactive Wastes Managed

Field Service Division

Radioactive compounds (e.g., uranium acetate, thorium nitrate) Dry active waste Sealed sources Scintillation vials and fluid Lab pack quantities of radioactive and mixed wastes Metals – Large components Sludges and wet waste Solvents Corrosive materials Aqueous liquids Resins Biological waste Soils Contaminated lead, metals, and equipment Manufacturer returns

Waste Services Veolia’s trained field personnel identify and classify radioactive and mixed wastes, including dry active waste, scintillation vials/fluids, solvents, corrosive materials, aqueous liquids, sludges, resins, biological wastes, soils, sealed sources, contaminated lead, metals and equipment.

On-Site Services Collecting low-level radioactive waste from individual labs and transferring waste to the waste storage room Packaging and labeling containers Tracking and keeping records of radioactive material in containers, including material stored for decay Coordinating waste shipments Manage incoming package receipts Training Perform audits Review procedures and programs Lab surveys

Our trained professionals are experienced in obtaining approvals for processing and disposing waste at our own facilities and at third-party sites that pass our strict audit program. Wastes are packaged efficiently and cost effectively, in compliance with all EPA, DOT, State and Waste Acceptance Criteria standards. Manifests and shipping papers are completed and presented for signature prior to shipment. Veolia arranges all transportation and ensures arrival at the selected processing facilities. On-Site Service Many on-site service programs are available and can be customized to meet the needs of each individual generator. Among the services offered are: collecting low-level radioactive waste from individual labs and transferring waste to the waste storage room; packaging and labeling containers; tracking and keeping records of radioactive material in containers, including material stored for decay; conducting lab surveys and coordinating waste shipments. Veolia personnel are available for properly managing incoming package receipts, in accordance with each generator’s procedures and surveys, as specified in the company’s radioactive materials license. In addition, our experienced radioactive project managers provide training, perform audits, and review procedures and programs to suggest recommendations that ensure total compliance.

Online Services Customer Information Management System Online Profiles

Access Your Waste Information Online

• View all your Waste Information Profiles (WIPs) • Request the recertification of your WIPs • Request a change to your WIPs • Print your WIPs • Submit a request for a new WIP

• Online Profiles • Online Invoicing

• Manifests • Certificates of Tracking

You can access all of your waste information through Veolia’s secure Web site 24 hours a day, 7 days a week at www.veoliaes.com through our Customer Information Management Solutions (CIMS). Once you register, and your information is verified, you can log in any time to manage your account from the secure system.

Online Invoicing • List and view your invoices • Reprint any of your invoices

Manifest Inquiry • List and view your manifests • Print a report on an individual manifest • View scanned manifests

Certificates of Tracking • View your COTs • Receive copy of COTs via email

Create a new waste profile or access an existing one, view invoices, and request certificates of tracking or view manifests. You can easily generate reports for your own use and pull down appropriate data for government reporting. Download data into Excel or CSV files with the click of a mouse.

Easy to Use Navigation on the CIMS site is intuitive and easy to use. All the features and generating locations that you have access to are listed on your CIMS home page. Select where you want to go without changing screens. Do you want to download a shipment activity report? Just select a date range and download the report. In addition to creating new Waste Information Profiles (WIPs) and viewing existing WIPs, registered customers of Veolia Environmental Services can also request downloads of environmental information, shipment activity data, management reports, shipment cost information, and Certificates of Tracking (COTs), and view invoices and manifest information.

Online Reporting Services Review summary reports, by manifest shipped date, in PDF or Excel format Data Download

Shipment Activity Database

Use this feature to interface your Veolia shipment data into your own waste tracking system, or into Access, Excel or any other software that imports data. The extract contains data from the following files: • Waste Information Profiles, Waste Codes and Descriptions • Approvals • Treatment Facilities • Packing Slip Headers • Packing Slip Details • Manifests • Manifest Transporter Activity • Transporters

Four separate reports are available that allow you to review and summarize your shipments, based on the manifest shipped date. Reports are available in PDF or Excel format. • Shipment Activity Detail Report—Data for each container that was manifested. • Waste Area Summary—Volume for all containers shipped, summarized by Waste Area, Waste Name and WIP. • Waste Materials—Summary of all containers shipped by Generator, Treatment Facility, WIP, Source Code, and Manifest Number. Select either RCRA or DOT and Hazardous or Nonhazardous reports. • Waste Name Summary—Volume for all containers shipped by Generator, Waste Name, listed in order, by Waste Area and Treatment Facility.

Shipment Cost Report Veolia offers a manifest-driven shipment cost report that you can print for a selected date range, based on the shipment date. This function is especially helpful when planning annual budgets. Reports are available in PDF or Excel format.

For more information, call 888-262-4910

Management Reports Critical waste management data for all waste managed by Veolia for your locations are included, for both materials handled by our field operations group and direct shipment activity. Two reports are available that can be run for hazardous waste or nonhazardous waste within a specified date range. Reports are available in PDF or Excel format. Waste Generation and Management Reports Provides data necessary to prepare annual or biennial reports. The report is sorted by Generator Source and Form Codes to facilitate the completion of regulatory reports. The following information is reported for each container. • Generator Name, Address, City, State, Zip Code and EPA ID Number • US EPA Waste Codes, State Waste Codes, Management Method • Shipment Date, Manifest Number, Page and Line Numbers • WIP, Destination Facility, Transporter and Volume • Number of Containers, Unit of Measure, Total Volume Waste Stream Activity Reports A summary of data to monitor and manage off-site shipments. The report separates data by Generator and Manifest Number and includes the following information for each manifest page and line that matches your hazardous or nonhazardous selection. • Generator Name, Address, City, State, Zip Code and EPA ID Number • Waste Information Profile Number, Waste Name, Manifest Page and Line Number • Unit of Measure, Number of Containers, Total Volume and Total Pounds • Federal EPA State Codes and State Waste Codes • Summary of Total Volume, Number of Containers and Total Pounds for each manifest

On-Site Services Services Track, package, manifest, transport, and dispose of or recycle hazardous wastes Perform collections from satellite storage areas Electronic information management for waste related activities Report generation Regulatory, safety, and technical support One manifest lists all wastes and their routes to disposal facilities Off-site inventorying for equipment and supplies Waste approvals and permit applications Unknown chemicals identification Cylinder testing

With our on-site services, you can outsource managing your hazardous waste. Transfer the burden to Veolia ES Technical Solutions, so that you can concentrate on your core business, and we can focus on ours. Through these services, we help reduce your liability, reduce your costs, and minimize hazardous wastes generated. We maintain trained employees at your facility on a full-time, part-time, or as needed basis. Our on-site professionals assume the responsibilities of tracking, packaging, manifesting, transporting, and disposing of your hazardous wastes. It is our job to meet all requirements for staffing, training, paperwork, and regulatory compliance. Data can be retrieved at any time through our field computer system, which is maintained on-site. All documents are available for inspection by government agencies, whenever requested.

Customized Services Public and private organizations across the country have contracted with us for our on-site services. Often we are already providing services to the organization, and the transfer of additional responsibility for on-site services is seamless. We review the services required and assign trained field personnel to provide all necessary support. Our on-site waste management program includes the services needed for each particular situation. Our practices emphasize safety, cost effectiveness, and compliance.

Regulatory Requirements Hazardous waste management may be subject to regulation under the federal Resource Conservation and Recovery Act (RCRA), the Universal Waste Rule, the Toxic Substances Control Act (TSCA) or the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). See pages 10-14 for detailed information on regulatory requirements.

Program Management Customer Goals Manage Costs Reduce Environmental Impact Manage Contract Startup as a Dedicated Project Build a Partnership Based on Clarity and Responsibility Increase Quality of Service with Continuous Improvement Process

Veolia Services Cost Reduction Reduce, Reuse, Recycle Documented Implementation Customer Involvement with Clear Goals and Action Plans Report Cards, Quarterly Reviews Annual Executive Reviews

When you have multiple manufacturing locations, itâ&#x20AC;&#x2122;s important to standardize processes throughout your organization to assure that procedures are followed routinely, particularly those procedures with potentially adverse legal consequences. Veolia ES Technical Solutions offers Program Management to accomplish this goal. Compliance with health, safety and environmental regulations is documented with scheduled reports to alleviate risk. At the same time, processes are continually evaluated to reduce waste and costs.

Customized Services Program Management provides a model to implement an environmental program across an enterprise. It coordinates the processes and tools needed to standardize an organizationâ&#x20AC;&#x2122;s corporate EH&S plan at each individual location by focusing on key metrics for your organizationâ&#x20AC;&#x201D;cost reduction, risk management and continuous improvement. Program Management offers a structure, delineated with measurable actions. Your organization designates an executive sponsor, and Veolia provides a manager at each customer location to drive program design, remove barriers and motivate the entire team. Plans are developed for each location, and quarterly meetings are held to assess performance. If you are interested in implementing improvements across your organization, ask your Veolia representative about Program Management today.

Regulatory Requirements Veolia representatives understand and stay abreast of any changes in federal, state and local requirements to assure compliance at all regulatory levels.

Solvent Recovery Recoverable Solvents Partial list Acetic acid, Acetone ACN (acetonitrile) Automotive purge solvent Butanol, D-limonene Dibasic ester (DBE) DMF (dimethylformamide) DMSO (dimethylsulfoxide) Ethanol, Ethyl acetate Ethylene glycol, Ethyl lactate G-butyrolactone (BLO) IPA (isopropyl alcohol) Isoamyl acetate Isobutyl acetate Isopropylacetate (IPAc) MEK, Methanol Methylene chloride NEP (n-ethyl pyrrolidone) NMP (n-methyl pyrrolidone) PGMEA (propylene glycol methyl ether acetate) n-propyl bromide Propylene glycol, Sulfolane THF (tetrahydrofuran) Toluene 1,1,1-trichloroethane Trichloroethylene All Asahiklin® solvents All Flourinert® liquids All Vertrel® solvents Fomblin®, Krytox® oil Freon® solvents

*Veolia audits third party reusers. 48

Veolia ES Technical Solutions has four locations with solvent recovery operations, all of which employ state-of-the-art technology to assure high purity results. Batch fractional distillation columns are available for mixed solvent separation, as are thin film evaporators for solids separation and recovery. Processes have been developed to yield selected products up to a 99.5% minimum purity, with a water content under 500 ppm, no uncharacteristic odor, and no color. With extensive distillation experience for a wide variety of solvents, Veolia's technicians understand requirements for almost any industry. Our laboratories include the Reclaim Research and Development Center near our corporate office in Lombard, IL, as well as our production quality control laboratories located at each reclaim facility. The production quality control labs are supported and audited by the corporate Reclaim R & D Center to ensure consistency and compliance with industry, customer and Veolia analytical methods and standards.

Customized Services Veolia performs various analyses to determine which option is best for your business— refine and resell, toll processing, on-site recycling or beneficial reuse at an audited reuser.* First, we conduct a sample analysis to quantify the content of the waste material, including GC/MS, GC/FID, pH, residue upon evaporation, and flashpoint. Veolia can provide a small recovered product sample obtained during an initial pilot plant study that is representative of full-scale production. If necessary, we can also perform a full production trial run on a tanker truck or larger batch size. Our complete bench scale recovery processing is conducted with glass lab scale equipment and includes simple distillation and fractional distillation under design and capability conditions that replicate plant equipment. With the results of our analyses, you can decide whether we should sell the resulting product or return it to you for reuse. Analytical methods and standards are developed for each individual waste stream by our central lab where we continually troubleshoot processes. Product specifications are maintained by the facility lab, which also conducts feedstock and product analysis and certification.

Options for Solvent Recovery Facilities and Equipment

Veolia On-Site Services

Azusa, CA • Continuous feed thin film evaporator • Batch fractional distillation column • Glass fractional distillation column • Vacuum distillation • TTB permit

On-Site Recycling

Henderson, CO • Thin film evaporator with integral fractionation column • Batch fractionation column • Liquid-liquid extractor • Vacuum distillation • TTB permit Middlesex, NJ • Simple and fractional distillation • Thin film evaporation • Molecular sieve • Vacuum distillation • TTB permit West Carrollton, OH • Wiped film evaporator with integral fractionation column, batch and continuous process • Pot still with fractionation column, batch process • Vacuum and pressure distillation • Molecular sieve dryer • TTB permit

On-site recycling minimizes waste and reduces both transportation and disposal costs for virgin solvent. Veolia ES Technical Solutions’ technical expertise and operating experience will help you realize the benefits of on-site recycling. We can install and/or manage on-site recycling equipment. Veolia Off-Site Services

Tolling Tolling reduces the cost of solvents used in manufacturing. With tolling, Veolia accepts used solvents from customers, reclaims the solvent to predetermined specifications and returns the reclaimed solvent to the original generator for reuse.

Beneficial Reuse / Convert Waste to Product Our beneficial reuse options allow companies to convert waste to products and minimize waste. Veolia can accept used solvents from a generator as a product and then manage the solvent to an audited third party to utilize as a raw material during a manufacturing process.

Reclamation Veolia accepts used solvents from a variety of customers and reclaims the solvents to our specifications. We then deliver the clean solvents to third parties who use the material as a replacement for virgin solvent.

Catalyst Recycling Regulatory Requirements

Developing Ways of Turning Waste into a Resource

Recycling options can often remove hazardous waste from regulation under the federal Resource Conservation and Recovery Act (RCRA).

Located at Veoliaâ&#x20AC;&#x2122;s facility in Port Arthur, Texas is an indirect fire rotary calciner, a high temperature rotary oven that is being used for test runs to extract valuable metals from spent catalysts produced by the refining industry. This approach is just one that we have been developing to turn waste into a resource.

See pages 10 â&#x20AC;&#x201C; 14 for detailed information on regulatory requirements.

Refineries use catalysts in hydro-treating to remove the sulfur from intermediate refined products, such as diesel fuel. During this process, the oil is heated and exposed to hydrogen. A catalyst is introduced to cause a reaction: it removes the sulfur from the diesel fuel and replaces it with hydrogen. The metal content that exists as sulfides on the catalysts is converted to oxides, so that they can be bleached or taken to solution by an acid. In this case, molybdenum sulfide is converted into molybdenum oxide. Catalyst materials traditionally are considered waste and incinerated once they have been used. Due to rising metal prices, the value of the metals in these materials is now sufficiently high to devote resources to their recovery. Moly, nickel, and cobalt can be reused to produce alloy or steel or to recycle as new catalyst. Hydro-desulfurization catalysts are considered to be a hazardous waste and are reactive. Once the calciner removes the organics and oxidizes the sulfide in the metals, they are no longer reactive and no longer a hazardous waste. Instead, they become valuable secondary raw materials, traditionally containing about 12% moly and 4-5% of other metals, primarily nickel or cobalt. Once recovered, these metals can be managed through traditional channels.

Customized Services We are constantly developing new ways to recycle materials in a wide range of industries. Our team is always eager to evaluate new projects and develop new approaches to recovering resources.

Remediation Services Site assessment Project planning Contaminant removal Site excavation Decommissioning, removal and disposal of tanks and transformers Decontamination of laboratory and production equipment, and of industrial facilities

Technologies • In Situ Biological Treatment • In Situ Physical/Chemical Treatment • In Situ Thermal Treatment • Ex Situ Biological Treatment • Ex Situ Physical/Chemical Treatment • Ex Situ Thermal Treatment • Containment • Other Treatment • Air Emissions/Off-Gas Treatment

Veolia ES Industrial Services, our sister company, also provides remediation services. See page 7.

The Veolia ES Technical Solutions site remediation team includes experts in a variety of disciplines to address the wide range of issues presented during the remediation process. For more than 30 years, we have been assessing, cleaning up and restoring contaminated sites and structures, for both the public and private sectors. Our knowledge, training, and hands on experience assure that our approach to any situation is comprehensive and cost effective, meeting cleanup criteria while satisfying federal, state and local standards.

Customized Services Each remediation project is unique, with site specific cleanup challenges and goals. Our approach begins with a site assessment, which includes investigations, samplings and identification of contaminants. Next, we plan the remediation project, providing detailed outlines of functions and costs required. Once we receive the project approval, we proceed with containment and removal of chemicals and contaminated materials, which includes site excavation. Our capabilities include decommissioning, removal and disposal of tanks and transformers, and decontamination of laboratory and production equipment and of industrial facilities. Our technicians are equipped with state-of-the-art protective and safety equipment and communications and site-monitoring devices. Our transport and disposal vehicles are fully permitted and insured. Our fleet is extensive—drum trailers, dump trailers, roll-offs, tank wagons, vacuum trucks, excavators and flatbeds. For remediation projects, we provide a true turnkey service, which includes coordination with subcontractors, assistance with appropriate regulatory agencies, procurement of necessary approvals, and supervision of disposal.

Regulatory Requirements Site remediation is regulated under the federal Resource Conservation and Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). See pages 10-14 for detailed information on regulatory requirements.

Cylinder Management Services Unknown cylinder sampling and identification Direct transfer of liquids from cylinders Gas transfer into solvents Phosgene cylinder leak testing Cylinder decommissioning Overpacking of damaged or leaking containers Valve and body condition evaluation Alternative disposal options (e.g., recycling, energy recovery)

Veolia ES Technical Solutions is experienced in all areas of cylinder handling, from unknown cylinder sampling and identification to transferring contents, decommissioning, identifying leaks and disposal. Field personnel receive special training to assure safe handling of cylinders containing compressed and liquified gases, and highly toxic or reactive liquids. Our services include identification, packaging, labeling and transportation of any type or size cylinder. With our field computer system, a questionnaire must be completed before a cylinder can be shipped. The questionnaire includes information on the manufacturer, contents, and the condition of the cylinder and valve. Special permission must be obtained for cylinders and valves that are not in good condition. This information appears on the packing slip and project summary for subsequent handling and management needs.

Customized Services Cylinders are used in many applications and might be located anywhere in a facility. Our field personnel are qualified to identify the contents of the cylinder and to properly manage the cylinder. Our cylinder services can be routinely included in our on-site services, or we can dispatch our experts to identify cylinder contents, examine the cylinders to determine whether there are any safety issues and recommend disposal options. Our Reactive Chemicals Group has completed advanced coursework and has hands-on experience with handling reactive chemicals and cylinders.

Regulatory Requirements Contents of cylinders may be subject to regulation under the federal Resource Conservation and Recovery Act (RCRA) or have special transportation requirements. See pages 10-14 for detailed information on regulatory requirements.

High Hazard Chemicals Characteristics of High Hazard Chemicals Corrosive Reactive Flammable Carcinogen Oxidizer Explosive Poison Temperature Sensitive

Our reactive technicians are specially trained and qualified to manage all types of high hazard chemicals. These chemicals typically include any chemical that is a health hazard, flammable and/or reactive. We have developed procedures for handling each of these categories of chemicals. Specialized equipment, planning and training are required to work with all of these materials.

High Hazard Chemicals Include Biological Agents (e.g., anthrax, small pox, botulism, plague) Department of Transportation Explosives OSHA Carcinogens EPA Banned Pesticides CDC Select Agents Chemicals with an LD50 of less than 50mg/kg Organic Peroxides Peroxides Formers Self-Reactive Temperature Controlled Chemicals Explosives Chemicals Reactive Materials Spilled Hazardous Materials Poisonous Gases

For each situation, we assess the potential dangers to determine the safest, fastest method of removing the high hazard chemicals. Veolia ES Technical Solutions uses a variety of technologies to remove these chemicals from your site. Our technicians have been trained to employ safety precautions in eliminating any possibility of danger. The chemicals are removed in special containers, if appropriate, to remote locations for stabilization and identification.

Customized Services

All of our technicians and supervisors attend training classes that exceed OSHAâ&#x20AC;&#x2122;s requirements.

Regulatory Requirements Hazardous waste disposal is regulated under the federal Resource Conservation and Recovery Act (RCRA). See pages 10-14 for detailed information on regulatory requirements.

Reactive Chemicals Management Removal Technologies Remote control equipmentâ&#x20AC;&#x201D;Custom designed and constructed for moving and/or securing highly unstable materials Refrigerated vehiclesâ&#x20AC;&#x201D;Fully permitted to transport temperature sensitive materials State-of-the-art closed transfer systems and specialized packaging techniquesâ&#x20AC;&#x201D; For gases, liquids and other chemical reactives

Materials Identified and Stabilized Cylinders Monomers Temperature-sensitive compounds Oxidizers Extreme toxins Shock-sensitive and explosive materials Peroxidizing materials Water- and air-sensitive materials Multiple hazard materials

Our Reactive Chemicals Group brings more than twenty years of hands-on experience, which includes extensive levels of research, project planning and implementation. We have developed and perfected several innovative systems for handling reactive chemicals, based on the hazards posed by each material.

Customized Services Each situation is as different as the possible combinations of reactive chemicals that may be present. In each case, we provide a thorough assessment of potential dangers and/or an on-site neutralization or stabilization of chemical compounds. Among the materials we regularly identify, stabilize, ship and dispose of are: cylinders, monomers, temperature sensitive compounds, oxidizers, extreme toxins, shock sensitive and explosive materials, peroxidizing materials, water- and air-sensitive materials, and multiple hazard materials. Veolia uses a variety of technologies to assure that reactive materials are removed from your site, safely and expeditiously. Small quantities of materials and consolidation of truckload shipments are accepted to reduce transportation charges. Our computerized tracking system clearly documents the movement of all materials from your site to final chemical waste disposal or destruction. Environmental and technical audits are conducted for all disposal sites that we utilize. We obtain all necessary permits and coordinate approvals with applicable regulatory agencies. Our technicians are trained beyond federal and state requirements to assure complete compliance in all phases of chemical waste management.

Regulatory Requirements Hazardous waste disposal is regulated under the federal Resource Conservation and Recovery Act (RCRA). See pages 10-14 for detailed information on regulatory requirements.

Remote Opening Examples of Materials Opened Remotely Damaged Containers Explosive Chemicals Organic Peroxides Peroxide Formers Pressurized Containers Shock Sensitive Materials DOT Forbidden Materials Temperature Sensitive Chemicals Unstable Materials

Veolia ES Technical Solutions provides remote opening services for a wide range of potentially reactive material in containers that would otherwise be unsafe for routine handling. Our technical specialists are dispatched to your location where they follow strict internal procedures and adhere to the specific requirements of your site. We are experienced with stabilization and treatment techniques of reactive materials with potentially dangerous properties and carefully operate within applicable regulations.

Customized Services Each unstable chemical handling situation is unique. Veolia's first priority is to ensure the safety and security of person and property. Veolia will work with you to develop the best strategy to manage your materials. Meticulous planning at the beginning of any project assures that all details are considered, which provides the best possible outcome and minimizes the impact on activities at your facility. Our trained technicians use state-of-the-art handling equipment to protect themselves and your interests when we manage potentially unstable chemicals at your site. To enhance safety, chemical containers are often transported in a special containment vessel to the selected remote opening locations. After the reactive compound containers have been successfully opened, our team of specialists has extensive experience in stabilizing them with a variety of chemical processes including acid/base neutralization, oxidation/reduction, hydrolysis, and dilution. Once a material is stabilized, extreme hazards are eliminated and special or even routine procedures for packaging and transportation can be utilized.

Regulatory Requirements Hazardous waste disposal is regulated under the federal Resource Conservation and Recovery Act (RCRA) and various State and local regulations. Other regulations, such as the Toxic Substances Control Act (TSCA) or the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), may also apply. See pages 10-14 for detailed information on regulatory requirements.

Specialized Packaging and Transport Packaging DOT rated containers Labels and paperwork DOT exemption kits UN performance packaging

Transport Drum trailers Dump trailers Refrigerated vehicles Roll-offs Tank wagons Vacuum trucks Flatbeds

Veolia ES Technical Solutions provides specialized packaging and transportation services for reactive chemicals that require unique capabilities. Our Reactive Chemicals Group has extensive experience in all areas of packaging and transportation for any type of chemical waste. Our technicians have exceeded training requirements by the Department of Transportation, the Environmental Protection Agency and the Occupational Safety and Health Administration for all phases of chemical waste management.

Customized Services Packaging and transportation are customized for each shipment to assure safety and regulatory compliance. Packaging methods meet all regulatory standards, maximize usable volume, decrease costs and enhance safety. State-of-the-art closed transfer systems assure safe transport for gases, liquids and other chemical reactives. Fullypermitted refrigerated vehicles are available for transporting temperature sensitive materials. Our systems accept small quantities of materials, and we can consolidate truckload shipments to reduce transportation charges. Our field computerized tracking system clearly documents the movement of all materials from your site to their final destination for chemical waste disposal or destruction. Environmental and technical audits are conducted on all disposal sites that we utilize. We obtain all necessary permits and coordinate approvals with applicable regulatory agencies for all phases of the packaging and transport process.

Regulatory Requirements Hazardous waste disposal is regulated under the federal Resource Conservation and Recovery Act (RCRA). Other regulations, such as the Toxic Substances Control Act (TSCA) or the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), may apply. See pages 10-14 for detailed information on regulatory requirements.

Stabilization and Landfill Process Profile and analyze waste Develop stabilization recipe Match waste profile with landfill Identify appropriate stabilization technique, if required Process and package waste Transport waste Provide online waste tracking

Veolia ES Technical Solutions provides industry standard options in land disposal technologies. Our landfill services are available through third party facilities, which are audited regularly. For wastes in the Midwest that require stabilization, however, Veolia operates a permitted facility in Menomonee Falls, WI, which offers stabilization of metal-coded hazardous waste solids and solidification of nonhazardous liquids and solids. All approved landfill operations meet requirements for location, construction and operation that assure long term containment of wastes.

Customized Services With our extensive network of treatment and land disposal options, we can customize our stabilization and landfill services to meet your specific needs. A wide variety of hazardous wastes can be accommodated through stabilization and solidification pretreatment. Appropriate technologies are used to prevent the possibility of future migration or leaching. Our full service laboratory facilities provide profiles, analysis and profile matching services.

Training Services First Responder Operations Level/HAZWOPER Refresher— Program Highlights • Hazard Awareness, Toxic Substances • Personal Protective Equipment • Respiratory Protection • Air Monitoring Equipment Survey and Reconnaissance • Site Control Work Zones • Confinement and Containment • Decontamination • Practical Exercise

Hazardous Materials Transportation Initial/Refresher Training— Program Highlights • Introduction/General Awareness • Hazardous Materials Classification • Shipping Paper Information • Marking and Labeling • Performance Oriented Packaging • Placarding, Hazardous Materials Security • Loading and Unloading Hazardous Materials • Hazard Awareness • Assessment and Prevention • DOT Emergency Response

Veolia ES Technical Solutions offers several training courses that provide a hands-on approach to Hazardous Materials (HazMat) Regulations instruction. Basic, advanced and refresher courses are available to accommodate any level of knowledge. Our training programs are continually updated to assure compliance with the latest DOT, EPA and OSHA regulatory requirements. A wide range of learning techniques are used to increase understanding and retention of the materials presented.

Training Format We offer five HazMat courses across the United States several times a year. Our extensive field experience is incorporated into the class format to provide relevant, hands-on training that ensures confidence and mastery of the required skills. Sessions are practical and to-the-point. On-Site Training These and other classes can be adjusted for your particular needs and schedule, and presented at one of our locations or your facility.

Training Courses First Responder Operations Level/HAZWOPER Refresher 8 Hours - Complies with OSHA 29 CFR 1910.120 for responders to releases or potential releases of hazardous substances when the releases are part of the initial response to the site for the purpose of protecting nearby persons, property or the environment. Hazardous Materials Transportation Initial or Refresher Training 8 Hours - Complies with DOT training requirements stated in 49 CFR 172.704 and covers general awareness/familiarization, HazMat security and safety training for all HazMat employees.

Hazardous Waste Management Initial/Annual Refresher Training— Program Highlights

Hazardous Waste Management Initial/Annual Refresher Training 8 Hours - Complies with EPA training requirements stated in 40 CFR 265.16 for all employees who manage Hazardous Waste.

• Introduction to RCRA • Waste Identification & Classification • Generator Requirements • Transportation of Hazardous Waste • Land Disposal Restrictions • Disposal Site Technology • Enforcement • Regulatory Trends

On-Scene Incident Commander 8 Hours - Complies with the OSHA 29 CFR 1910.120(q)(6)(v) for employees who will assume control of an incident scene. Participants learn to implement the employer's incident command system and appropriate emergency response plans. Training also encompasses the risks associated with employees working in chemical protective clothing. Prerequisites: Current 24-Hour HazMat Technician Certification

On-Scene Incident Commander— Program Highlights • Incident Command System • Emergency Preparedness • Emergency Response Plan • Incident Analysis • Chemical Protective Clothing • Practical Exercise

Hazardous Materials Technician 24 Hours - Complies with the OSHA 29 CFR 1910.120(6)(iii) training requirements for employees who respond to actual or potential releases of hazardous substances for the purpose of stopping the release. The Hazardous Materials Technician assumes a more aggressive role than a First Responder.

Hazardous Materials Technician— Program Highlights • Hazard Awareness • Toxic Substances • Personal Protective Equipment • Respiratory Protection • Air-Purifying Respirators • Self-contained Breathing Apparatus • Confined Spaces • Air Monitoring Equipment • Survey & Reconnaissance • Site Control Work Zones • Confinement & Containment • Decontamination • Practical Exercise 59

Transportation Transportation Capabilities 40 ft. to 53 ft. van trailers Drummed and other containerized wastes 5,000 gallon bulk tanker and pneumatic vacuum trucks Bulk liquids Midline trucks Small quantities of drummed waste materials Flatbed trailers PCB transformers and other large items Dump trailers and roll-off containers Contaminated soil Refrigerated trucks Reactive chemicals Railâ&#x20AC;&#x201D;Tankers, intermodal

EPA Identification Number: NJD080631369

Veolia ES Technical Solutions provides a wide variety of transportation choices to accommodate any quantity of waste, including van trailers, roll-off boxes, and tanker trucks. Specialty equipment, ranging from dump trucks and flat beds to vacuum trucks and refrigerated trucks are available through a group of subcontractors who have been prescreened for compliance with all requirements for procedures, permits and inspections. Our nationwide network of facilities, combined with our distribution capabilities, offer the most extensive resources in the industry.

Customized Services Regardless of the amount of waste your operation generates, Veolia can accommodate your needs. Pick ups can be scheduled or provided on call. We will advise you of legal requirements when we begin service. Our personnel are trained to handle hazardous and nonhazardous waste safely and legally. All employees keep current on regulatory and safety requirements by passing periodic training courses. Safety is important for our transportation vehicles, too, which are maintained under strict quality standards. A less-than-truckload (LTL) program is available to provide flexibility for small to midsized volumes of waste (See page 17).

Driver Training All of our drivers complete required training under both RCRA and DOT regulations. In addition, they undergo extensive hands-on training and testing to assure thorough knowledge of regulatory and safety procedures. As required by Transportation Security Administration, all drivers are screened through extensive security and background checks. All vehicles are operated in accordance with a Hazmat Security Plan, approved by the DOT. Our safety rating is excellent.

Regulatory Requirements Under the federal Resource Conservation and Recovery Act (RCRA), the U.S. EPA regulates hazardous waste transportation. The EPA must coordinate activities with the U.S. Department of Transportation, which is also authorized to impose requirements for hazardous waste transportation under the Hazardous Materials Transportation Act (HMTA). See pages 10-11 for detailed information on RCRA requirements.

Veolia Audited Facilities Regulatory Review Site description and history Compliance history Current status of all permits Proof of liability insurance Contingency plan Process descriptions including waste acceptance procedures Acceptable waste codes

Agency File Review NOV's Response correspondence from the facility concerning audits Corrective actions Any documents concerning consent orders or other environmental litigation

Occasionally, Veolia ES Technical Solutions does not have company owned facilities to accommodate proper transportation, disposal or recycling of a particular type of waste. In these cases, we will seek appropriate facilities on your behalf. Once these facilities are located, they must pass a rigorous auditing process in order to be approved for our use. Interviews conducted with key facility personnel are especially important for us in evaluating whether the company promotes a commitment to compliance throughout the entire organization, a key attribute in determining whether the facility will be approved as a Veolia Audited Facility.

Auditing Process The auditing process is designed to verify that a facility is in complete compliance with all federal, state and local agencies prior to approval as a Veolia Audited Facility. The review process is a comprehensive environmental assessment of the facility and includes the following steps. Financial Review The financial health and long term viability of the facility is established by reviewing all financial records. Regulatory Review A Veolia inspector conducts an on-site review of the facility during which extensive information is obtained (see list at left), including any information pertinent to the facility. The on-site visit includes interviews with key facility personnel. Agency File Review Veoliaâ&#x20AC;&#x2122;s inspector may either conduct a physical file review with appropriate agencies or gather information through phone interviews with authorized agency personnel, computer searches and agency inspection reports. This review usually involves documents detailing agency inspections and results (see list at left), documents detailing any remedial/corrective action issues and/or exceedances of any environmental standards.

Three Year Reviews Approved third party facilities are audited every three years to ensure that acceptable compliance standards are maintained. 61

What to Expect

The Veolia Business Process Getting Started Site Evaluation It's important that we understand your current waste management situation in order to develop a program that meets your specific needs. There are several steps in this initial process. • Discuss needs and objectives—In preparation for the site evaluation, we discuss your waste and your needs for related environmental services, as well as your objectives. • On-site evaluation—Together, we determine your baseline costs to quantify future savings. Then, we conduct a site evaluation by going through each step of your operation to see where the waste is generated and how it is currently handled. • Profile review—After gathering copies of your waste profile sheets and your waste stream analysis, we review them thoroughly. • Employee interviews—We always interview each person responsible for any step in the hazardous waste stream process to gather every relevant detail. • Sampling—When necessary, we obtain samples of the waste. Our goal is to identify opportunities to reduce waste volumes and to reduce your costs. We overlay your needs with our capabilities to determine what services we can offer that will add value to your operation.

Next Steps Written Proposal Once we’ve gathered all the information you have available on your waste, we analyze the data and your existing procedures to determine any opportunities for improvements. We develop a detailed disposal plan to help ensure long term financial security for your company. We then provide a written proposal that details services and costs.

Contract Approval Once you’ve reviewed the proposal, we make any necessary changes and develop a contract. You may also need to provide credit information. Please arrange to tour and audit our treatment facilities.

Preparing for Service There is a great deal of planning required before we begin services. • Establish a Work Group—Representatives must be designated from our organization and yours who are responsible for services.

• Profile Waste Streams— Our on-site teams profile your waste streams and collect samples, as necessary. Then, we’ll obtain approval on each waste stream from the appropriate treatment, storage or disposal facility. • Scheduling—We’ll discuss scheduling needs with you to make sure we understand your operational requirements for pick-ups. Our transportation teams set up a waste removal schedule to maintain compliance with government hazardous waste regulations. Of course, we’re always on call 24 hours a day, 7 days a week if there’s an emergency or if you need a special pick-up. • Training—Once we’ve identified regulatory requirements and set up necessary systems, we are available to train your staff in a wide variety of environmental courses. Our hazardous waste experts are available to provide technical assistance at every step.

Service Performance Services Begin We monitor and review each step continuously to assure environmental compliance. Quality controls are a routine part of our service.

Technical Review Our Technical Manager reviews each waste that is being shipped to assure that contract requirements are met and that wastes are being tracked to the approved facility list.

Certificates of Tracking You can monitor the termination of your manifest online by requesting Certificates of Tracking. You can also generate reports to satisfy regulatory reporting requirements with our interactive web page, once you register online at www.veoliaes.com.

Questions? You are assigned an account manager, project manager and technical service representative to call with questions or problems any time. Your account manager will contact you periodically to make sure everything is running smoothly. Often, your questions can be answered online at www.veoliaes.com. For our qualified customers, we may perform quarterly performance reviews. Your complete satisfaction is our goal.

Capabilities for Each Location

Services and Technologies On Call 24/7 Convert Waste to Product Electronics Recycling Computers and Electronics Mercury Compounds Batteries Power Distribution Equipment Lamps and Ballasts RecyclePak速 Emergency Response 24/7 Fuels Blending Greenhouse Gas Tracker Household Hazardous Waste Incineration RCRA, TSCA, CERCLA Nonhazardous Laboratory Chemical Services Lab Packing Using Computerized System Chemical Inventory Equipment Decontamination Low-Level Radioactive Waste Medical Waste Services Online Services Web-Based Waste Profiling, Invoicing and Reporting On-Site Services Reactive Chemicals Management Remote Opening Specialized Packaging and Transport High Hazard Chemicals Recycling and Recovery Ethanol Recovery Solvents and Thinners Remediation Stabilization and Landfill Training and Awareness Programs Customized Training Courses Transportation