August 16, 2014 - Clean Harbors Company Confidential

1. 1 August 16, 2014 - Clean Harbors Company Confidential

2. Reflections on the DOECAP Audit Process from a RCRA/TSCA TSDF Vendor’s Perspective People and TechnologyCreating a Better Environment September 21, 2010

3. Table of Contents • Company Overview • Description of Contract Work Conducted by Clean Harbors for DOE Facilities • Description of Clean Harbors Facilities Audited by DOECAP: • Deer Park, Texas ( RCRA/TSCA Incinerator ) • El Dorado, Arkansas ( RCRA Incinerator) • Aragonite, Utah ( RCRA/TSCA Incinerator ) • Clean Harbor’s Response to DOECAP’s Request to Audit several of our Incineration TSDFs: • Pre-audit preparation • Audit Support • Post-Audit follow-up and CAP • Clean Harbors Feedback on the overall DOECAP Audit Process

4. Company ProfileNYSE STOCK SYMBOL:CLH • More than 50,000 customers including 325 of the Fortune 500 • More than 6,400 employees in over 130 service locations in US, Canada, Mexico and Puerto Rico • Over 50 waste management facilities • Offers a broad range of environmental services • Environmental Services = Technical Services, Field Services • Energy & Industrial Services = Industrial Services, Exploration Services • Improvements in operating and financial performance through investment in technology and asset optimization • Strong financial position – rising sales and earnings, declining debt

5. Environmental Services Locations Energy & Industrial Services Locations Waste Management Facilities Landfill Transformer Processing Facility Wastewater Treatment Solvent Recycling or Oil Recovery Incineration Treatment, Storage & Disposal Facility United States Footprint

6. Alberta Locations FortMcMurray Peace River Edmonton Provost Ft. Nelson British Columbia Alberta Saskat-chewan Manitoba Ft. St. John Dawson Creek Macenzie Grand Prairie Quebec Prince George Ryley Ontario Regina Winnipeg Red Deer Environmental Services Locations Delta Dryden Swift Current Nanaimo Thurso Ville Ste. Catherines Debert Mercier Energy & Industrial Services Locations Guelph Pickering Dartmouth London Mississauga Waste Management Facilities Nova Scotia Sarnia Burlington Lambton Landfill Wastewater Treatment Thorold (Niagara) Incineration Treatment, Storage & Disposal Facility Canadian Footprint

7. Summary of Clean Harbors Services provided to USDOE • Laboratory Waste Disposal and Hazardous Waste Disposal Services at numerous USDOE and National Laboratory Facilities such as Savannah River, Los Alamos, Idaho, Lawrence-Livermore, etc. • Commercialization of TSCA PCB Waste Disposal* at our Deer Park, Texas RCRA/TSCA Incineration Facility: • Piketon/USEC PCB Dielectric Fluid Disposal • Piketon/USEC large-scale PCB Capacitor Disposal • Piketon/USEC Transformer Disposal • Argonne National Laboratories PCB Capacitor and Transformer Disposal * Commercialization of TSCA PCB Waste Disposal is a key USDOE EM Goal

8. Brief Overview of TSDFs Audited Under the DOECAP Program

9. Clean Harbors Deer Park, Texas RCRA/TSCA Incineration Facility

10. Brief Overview of TSDF’s audited by DOECAP • Deer Park, Texas RCRA/TSCA Incineration Complex: • Established in 1971 • Facility Size: 145 acres • 215 Employees • RCRA and TSCA-Permitted with 99.99997 DRE • USEPA MACT II Air Emissions Controls • Three Incineration Trains with total liquid and solid incineration capacity of 140,000 tons - Largest Commercial Incineration Complex in US ! • Operates under 56 Local, State and Federal Operating Permits and Approvals • Can accept diminimis levels of TCEQ-regulated radionuclides • USEPA CERLCA Off-Site Approved RCRA TSDF

11. Clean Harbors El Dorado, Arkansas RCRA Incineration Facility

12. Brief Overview of TSDF’s audited by DOECAP • El Dorado, Arkansas RCRA Regulated Incineration Complex: • Established in 1974 • Facility Size: 370 acres • 235 Employees • RCRA Permitted with 99.999 DRE • USEPA MACT II Air Emissions Controls • Two Incineration Trains with total liquid and solid incineration capacity of 100,000 tons – Second-Largest Commercial Incineration Complex in US ! • Can store 40,000 drums plus segregated storage for highly reactive and oxidizing RCRA waste streams • Operates under 32 Local, State and Federal Operating Permits and Approvals • USEPA CERLCA Off-Site Approved RCRA TSDF

13. Clean Harbors Aragonite, Utah RCRA/TSCA Incineration Facility

14. Brief Overview of TSDF’s audited by DOECAP • Aragonite, Utah RCRA/TSCA Regulated Incineration Complex: • Established in 1991 • Facility Size: 35 acres • 132 Employees • RCRA and TSCA-Permitted with 99.99997% DRE • USEPA MACT II Air Emissions Controls • One Incineration Train with total liquid and solid incineration capacity of 55,000 tons • Operates under 30 Local, State and Federal Operating Permits and Approvals • USEPA CERLCA Off-Site Approved RCRA TSDF

15. Clean Harbors Facility Audit Expertise • Clean Harbors has an extensive Corporate-wide Internal EHS Audit Program that comports with the USEPA/DOJ Audit Privilege Rules and Regulations: • 24 internal multi-media audits conducted annually utilizing lead Corporate Audit staff and Visiting Auditors from other business segments in the Company. • Extensive Audit Reports are prepared and incorporate Corrective Action Plans which require the Facility Manager to correct any deficiencies by calendar date deadlines. • Red-Flag Reports provided Executive Management.

16. Clean Harbors Facility Audit Expertise • Our Major Customers also audit our TSDF Facilities utilizing: • Internal Audit Teams • Third-Party Consultants • Industry Specific Third-Party Audit Organizations such as CHWMEG • Our Incineration Facilities typically have 3 to 4 customer audits per week: • Average audit team consists of 2 people • Average audit length 2-3 days Bottom Line: Our Facility Teams are very comfortable with the Auditing Process – a good thing when one considers preparing for a DOECAP Audit…

17. Reflections on the DOECAP Audit Process • Clean Harbors has participated in the DOECAP Audit Process since 2007 when a pilot audit was conducted at our Aragonite, Utah Facility. • Experiencing the Pilot Audit plus review of the DOECAP Audit Procedures Manual prepared each of the aforementioned incineration facilities for DOECAP audits. • Clean Harbors gathered a multi-disciplined team of Corporate and Facility Operations, EHS Management and Engineering Professionals to prepare for the facility-specific audits and to oversee the pre- and post-audit processes.

18. Reflections on the DOECAP Audit Process • Pre-Audit Preparation (using Deer Park Facility Experience as a benchmark): • Preparation of Audit Review Folders: • EMS Policies and Procedures • Best Management Practices and SOPs applicable to Facility • 5-Year Compliance History • Regulatory Agency Permits/Approvals summaries • Incineration Process Operations Summary Descriptions • OSHA PSM Management • USEPA/OSHA/USDOT Training Compliance Tracking • RCRA/TSCA Financial Assurance documentation • P&ID Plats • Sensitive Ecological Receptor Summaries • Emissions/ Discharge Inventory Reports • Community Relations Experience

19. Reflections on the DOECAP Audit Process • Actual Staff Time Spent preparing for DOECAP audit = 150 work-hours: • Our previous audit experience and documentation preparation resources made the prep work straightforward. • Our DOECAP Audit Prep Team has extensive experience both preparing for and either conducting or assisting with audits. • DOECAP Audit Policies and Procedures allowed our Audit Prep Team to tailor information needs to the needs of DOECAP.

20. Reflections on the DOECAP Audit Process • The Actual DOECAP Audit Process: • We allocated one full work-week for the on-site audit process based upon our experience with the Aragonite Pilot Audit. • Representatives from Corporate EHS, Site Operations and Engineering dedicated their work-week in support of the on-site audit. • We held daily pre-and post audit activity meetings to chart progress, identify and respond to DOECAP Auditor observations and findings, and implement on-the-spot corrective measures as deemed appropriate. • Actual Staff time spent connected with on-site audit support = 220 work-hours

21. Reflections on the DOECAP Audit Process • Post – DOECAP Audit and Follow-up: • Site Audit Team participates in the DOECAP Audit Summary and Findings Review and Corrective Action Recommendations. • Site Audit Team, lead by the Facility Compliance Manager, reviews formal written DOECAP audit report and allocates findings and observations to team experts for review, analysis and recommendations/path forward. • Facility Compliance Manager prepares written response to DOECAP findings documenting our position regarding each observation and finding for Corporate EHS representative review, approval and release to the DOECAP Audit Team Leader.

22. Reflections on the DOECAP Audit Process • Actual staff time spent reviewing formal DOECAP Audit Report, preparing responses to Audit Findings and Observations and follow-up discussions with DOECAP = 135 work – hours. • Total Clean Harbors Staff Work-Hours Connected with Deer Park Facility DOECAP Audit: • Pre-audit Prep >150 work-hours • Audit Oversight >220 work-hours • Post-audit Review >135 work-hours Total: 505 work-hours

23. Lessons Learned from the DOECAP Audit Experience • It pays to review the DOECAP Audit Policy Manual and live through a Pilot Audit. • Treat the DOECAP Audit Process as a Multi-Media Audit similar to what USEPA would conduct at a TSDF - plus the QAPP overlay. • DOECAP Audits look for policies and procedures much like an ISO 14001 or 18001 audit would so its essential for non-ISO certified TSDFs like Clean Harbors facilities to show equivalency through Policies and Procedures, Best Management Practices, SOPs, etc.

24. Lessons Learned from the DOECAP Audit Experience • Recognize that USDOE’s emphasis on QAPP /QAQC plans and documentation of conformance and performance might not comport with established quality programs in place at corporate and plant levels: • Clean Harbors is building a QAPP Plan in concert with revised Corporate –wide EMS Program to satisfy DOECAP Findings in all three Incineration Facility Audits. • Above all, invite various Company staff, with varied disciplines, to be part of the DOECAP Process. Familiarization with the DOECAP Audit process is essential toward building company-wide EHS and Operations Quality Programs that are consistent with USDOE Quality Program requirements.