January 4, 2020 - Clean Harbors Company Confidential

1. 1 January 4, 2020 - Clean Harbors Company Confidential

2. Our Commitment to Manage NORM and TENORM from the E&P Marketplace People and TechnologyCreating a Safer, Cleaner Environment October 30th , 2014

3. Meeting Objectives • Share Observations Regarding E&P-related NORM and TENORM Waste Management in the Marketplace. • Discuss need for National Regulatory Consistency associated with Management of NORM and TENORM especially from E&P activities. • Clean Harbors Capabilities to respond to growing demand for safe and compliant NORM and TENORM Management: • NORM and TENORM Disposal Capabilities • NORM and TENORM Field Services and Industrial Services Capabilities • Improved ability to manage company, and client environmental risk, as it relates to NORM/TENORM and Mixed-Waste.

4. The E&P-Related NORM and TENORM Marketplace • Oil and Gas E&P activities connected with the Domestic Shale Plays will generate more NORM and TENORM requiring safe and compliant disposal options throughout all of the Shale Plays. • We are seeing more state agencies taking the initiative and proposing rules and regulations connected with the management of NORM and TENORM from these activities. • Several States including ND, WY, CA, PA and NY are in the process of developing NORM and TENORM Rules in response to the dramatic increase of E&P activities within the Shale Plays- illegal disposal is driving these efforts to avoid a need to clean up abandoned disposal sites, in the future. • We think its time for the NRC and USEPA to move on Federal Rules governing the management and disposal of NORM and TENORM, especially from E&P activities. • CA’s Monterey Shale Play will soon be open for more E&P activity as Gov. Brown supports safe and environmentally responsible development of the this huge formation. • Drilling pipe, transmission pipeline, filter socks, filter cake, pit clean outs can all be NORM contaminated. Clean Harbors has managed all of them at our approved landfills.

5. The Bakken Oil Fields, ND & MT, one billion barrels • OKLAHOMA CITY, April 28, 2014 Continental Resources, Inc. announced today the Bakken field of North Dakota and Montana recently reached the milestone of 1 billion barrels of light, sweet crude oil produced. • According to data from IHS, the Bakkens cumulative oil production reached the billion barrel mark in the First Quarter of 2014. • "This milestone validates the immense potential of the Bakken field and development is just beginning," said Jack Stark, Senior Vice President of Exploration for Continental. "Two-thirds of this oil was produced in the last three years. This is something our country can celebrate as the oil and natural gas industry continues to create jobs, grow our economy and secure America's energy future." • Horizontal drilling technology has spurred the discovery of vast new resources of oil in America. Much of this potential has yet to be accounted for in our nation's proved reserves of crude oil. The Bakken field alone appears to be the largest oil field discovered in the world in more than 40 years. • Continental is the largest producer, driller and leaseholder in the Bakken field.

6. Abandoned NORM Filter Socks in the Bakkens

7. Clean Harbors Field Services (FS) Capabilities • FS Decontamination with a variety of equipment, including hand drills/wands, brusher wheels/ Power Balls, and subsequent manifesting, packaging & disposal at Deer Trail, CO or Buttonwillow, CA. • 16 field service employees dedicated to the Bakkens in  Arnegard ND. • ThreeRadiation Safety Officers (RSO) dedicated to the Bakkens. • Reciprocal Agreement capabilities for other Shale Play States. Current License is in North Dakota. • Save the customer money  by decontaminating NORM equipment for safe re-use or recycled for value, or to achieve a non-NORM disposal option. • Help customers manage risk by helping them reuse decontaminated equipment such as pipe, valves, and tanks. Eliminating over the road transportation of NORM waste. • Proper Waste Identification, Packaging, Transportation and Disposal for materials that cannot be cleaned and recycled e.g. debris, PPE, filter socks, etc, • Frac Valves that have been decontaminated can put back into service.

8. Waste characterizationisthekey • There is growing corporate responsibility to do the right thing based on an informed citizenry that is learning more about the radioactive potential of solid waste derived from E&P activities!! • Generators of E&P waste may claim RCRA exempt status. RCRA-Exempt E&P wastes might still be harmful to human health and the environment, while many non-exempt RCRA wastes might not be as harmful. The following simple rule of thumb can be used to determine if an E&P waste is exempt or non-exempt from RCRA subtitle C status: • Has the waste come from down-hole, i.e., was it brought • to the surface during oil and gas E&P operations? • Has the waste otherwise been generated by contact with • the oil and gas production stream during the removal of • produced water or other contaminants from the product? • If the answer to either question is yes, then the waste is likely • considered exempt from RCRA Subtitle C regulations but not exempt from State Regulation! • It is important to remember that all E&P wastes require proper • management to ensure protection of human health and the • Environment and often times compliance with state rules and regulation is paramount!! • Clean Harbors has Permitted and Licensed facilities to manage all of these wastes!

9. Typical Remote Location owned, and managed by Clean Harbors 7 types of Protective Barriers • Location • Geology • Climate • Secure perimeter • Multi HDPE & clay liners • Air & water monitoring with, multi leachate collection systems • Indemnification

10. Deer Trail, CO Landfill • Deer Trail - Fully permitted Subtitle C Landfill. RCRA/TSCA (mega rule for PCB’s). • Facility located 75 miles east of Denver • Only “Designated Facility” under the Rocky Mountain Low-Level Radioactive Waste Compact. • Only Commercial Landfill Facility possessing a Radioactive Materials Disposal License from the State of Colorado. • Permitted for NORM/TENORM waste for U-238, U-235 & Th-232 decay series. Permitted for up to 2000 pCi/g.. • Can handle liquids, sludge's and solids • Can accept in bulk, drums, totes and special containers. • Specialize in waste water haz stream. • Can also take mixed RCRA/TENORM waste. • Radiation monitoring/ Surveillance of incoming loads and outgoing NORM free released loads overseen by an on-site Certified Radiation Safety Officer (RSO).

11. Check in: weight and radioactive monitoring

12. Deer Trail is a dailycover Landfill

13. What Deer Trail Requires • If waste is generated out side of NM, CO or NV Generator will need to apply to RMLLRB compact. • Need waste profile sheet. • Need 1000 gram sample, independent of any analytical generator has • Need radiation questionnaire • Below is the minimum analysis we will run on the sample: • 1. Total Uranium (mg/kg) by ICP; alternate Isotopic Uranium by Alpha Spec. • 2. Total Thorium (mg/kg) by ICP; Alternate Isotopic Thorium by Alpha Spec. • 3. Gamma spectrum and Ra-226 quantization pCi/g • 4. Gross alpha (pCi/g) • 5. Gross beta (pCi/g) • 6. Pb-210 if applicable (pCi/g) (Natural Gas Processing Waste Only) • 7. Percent Moisture • Instrumentation: • Ludlum Gate Monitor - Model 4525, 7000, 37520 & 3502 • Thermal Fisher Scientific - hand held gamma spectrometer

14. Buttonwillow California Landfill • Located in Central California.Approximately 40 miles West of Bakersfield within the Kern County/ Bakersfield E&P Play ( Tertiary Recovery rampant in this geological province ). • Only RCRA/NORM Permitted Landfill in California with permitted disposal capacity. • Deep water table with, < 5 inches of rain per year ( high evapo-transportation rate ). • NORM /TENORM Waste up to 1800 pCi/g ( U & Th decay series ). • Offer treatment of liquids, solids, and sludge's, RCRA & Mixed – Waste. • Can handle waste in bulk liquids, and solids and in a variety of containers. • Permitted capacity in excess of 10 million cubic yards. • Industries served;Oil & Gas, General Manufacturing, Coal combustion • Mining of uranium, and metals, Phosphate production, Municipal water treatment.

15. Typical Cell Construction

16. How to start the disposal process • Waste must have a completed E-profile, sample (COC) and analysis (if you have it), LDR, MSDS. For Deer Trail NORM sample required. • Credit & Service Agreement • Waste Must be approved into the Clean Harbors System • Facility Approval • CPG Approval • Signed quote • Waste must be scheduled via Customer Service

17. Submitting an e-profile assures the proper review

18. Summary • The U.S. Oil and Gas Exploration and Production Industry has been transformed due to new horizontal drilling practices. • However, new waste streams, such as NORM and TENORM and associated waste management challenges have also resulted from these innovative practices. • There is a “Boom Times” attitude throughout the stakeholder communities associated with accelerated development of the Shale Plays and this attitude has caused significant strain on local infrastructure to keep up with these “Boom-Times”. • While most E&P firms practice compliant and safe practices when managing drilling residues some, unfortunately, do not and irresponsible disposal of waste, including NORM and TENORM Waste is occurring in the Shale Plays.

19. Summary • Several States are quickly moving to shore up Solid Waste and Radioactive Materials Regulations to assure safe collection and disposal of drilling waste, especially waste containing NORM and TENORM. • We think its time for the USEPA and NRC to seriously consider adoption of NORM and TENORM Rules and Regulations to help support State Initiatives • Clean Harbors has a strongly committed to helping the E&P industry meet their compliance commitments for all varieties of exploration and production wastes, especially NORM and TENORM. • Our Deer Trail, CO and Buttonwillow, CA landfill facilities handle NORM and TENORM from the industry, today, plus our Field Services teams are very active in the Shale Plays assisting with the safe handling of NORM and TENORM wastes, decontamination of equipment and remediation of contaminated soil and debris at the well pads. • We need to learn from our past experiences dealing with abandoned and uncontrolled waste disposal sites and proactively engage all stakeholders to assure that Shale Play Development can and should co-exist with protection of Human Health and the Environment!