TENORM Waste Disposal CRCPD Annual Meeting Scottsdale, AZ May 8, 2017 Thank yous, etc. My talk will focus on the waste mgt side of TENORM. Building off what we’ve learned from the previous speakers, I will provide some background and current regulatory information regarding disposal. CRCPD Annual Meeting Scottsdale, AZ May 8, 2017

US Ecology Overview Vision: To be the premier North American provider of environmental services where the highest caliber people work delivering sustainable solutions for our customers and long term value for stockholders and the communities in which we live and operate Fully Integrated North American Environmental Services Provider Unique and Irreplaceable Assets with Robust Waste Permits Diverse, Blue Chip Customer Base across a Broad Range of Industries with over 7,000 Customers 60 + year Commitment to Health, Safety and the Environment Strong Financial Performance Canada (2) (4) United States Mexico Treatment & Recycling Disposal Sites Service Centers Headquarters Retail Satellites (2)

Safety and Compliance OSHA VPP Star Status at 2 Sites USEM ISO 9001 (Quality), ISO 14001 (Environment), and OHSAS 18001 (Safety) certified USEM celebrating 4+ years without OSHA recordable injury (>1.4M hours) Very strong compliance record

USE Facility Comparison US Ecology WAC Levels USE Facility Comparison WAC Parameter USE Nevada (RCRA-C) USE Texas USE Michigan USE Idaho USE Washington (NRC LLRW) Ra-226 5 pCi/g 30 pCi/g 50 pCi/g 500 pCi/g (bulk) 1,500 pCi/g (IP-1) 10,000 pCi/g or <1.2 Ci Pb-210 None 150 pCi/g 260 pCi/g 1,500 pCi/g Unlimited K-40 TBD 818 pCi/g(1) No Limit Other TENORM Tubulars (<50 uR/hr) MDI Downblending(2) Ra-228 Radium Sources, etc. Source Material (10CFR 40 or State) < 500 ppm bulk + Exempt Items Class A/B/C LLRW Byproduct Material (10 CFR 30 or State) Exempt Items Exempt Items, <3,000 pCi/g*(3) Class A/B/C LLRW SNM (10CFR 70) Natural amount of K-40 in elemental potassium Consult USEM for more information Requires Exemption, License Termination, or Release from Regulation

US Ecology Michigan Permit MOD Approved by MDEQ on 12/16/16 Established formal WAC Authorizes TENORM downblending at MDI Treatment Plant. No upper limit.

USEM Environmental Monitoring On-site MDEQ inspector Quarterly MDEQ & Wayne County inspections 7 perimeter air monitoring stations Over 50 groundwater monitoring wells Leachate, surface water, sediment, soil, and radon monitoring programs Landfill leak detection monitoring by WDI and MDEQ Regular and rigorous customer audits

TENORM Disposal Challenges Not federally regulated Up to States to regulate – Wide Disparity Rapidly changing regulatory environment Complex environment for generators. “It Depends…” State Licensing of TENORM as ‘LLRW’ Politics… Changing gears to the disposal landscape…TENORM is a challenge. The lack of uniform federal regulations leaves the individual states to regulate it as they see fit. On top of that, disposal regulations have been evolving rapidly as states attempt to keep pace with O&G activities. The answer “it depends” is often given when I’m asked questions by generators

State TENORM Disposal Options Ra-226 (pCi/g) Notes / Basis Nevada 5 Via State Licensing Exemption Ohio 6.99 5 + Bkg (1.99 pCi/g) Texas 30 Montana 15-50 Based on MDEQ 11/2015 Update North Dakota 50 In approved ‘Special Waste’ landfills Michigan For all landfill types (Sub-C and -D) Illinois 100* Requires IEMA approval Pennsylvania 270* Subject to dose rate and volume limits Colorado Variable From 3-400 based on facility type Idaho 1,500 At RCRA Subtitle-C landfills only Here’s a partial list of state TENORM disposal limits (all for Ra-226). What’s most interesting about this list is how the states have arrived at their limits: some are straight licensing exemptions while others have passed legislation and/or promulgated rules to implement higher disposal limits. IL allows landfill disposal and land application with IEMA approval and other considerations. ND’s level was implemented by statute. However, I do not believe any landfills have been approved yet by NDDOH.

Common TENORM Wastes Drinking Water Filtration Residuals Oil & Gas E&P/Treatment Residuals Radium Site Cleanup Wastes Ore and Rare-earth Processor Sites Military Base Cleanups

Pop Quiz This plot is from an unnamed site, in an unnamed state, going to one of our facilities. It shows tons of waste received over time. Can you guess by looking at the plot when regulatory enforcement actions were taken at this site? Point being…the work you do as regulators matters. Most of our generators are vigilant about following regulations and making sure their wastes are going to the appropriate places. Some, however, need some assistance.

Summary If you don’t like TENORM regulations, check back in 10 minutes… States and Industry have developed several appropriate TENORM disposal options Ample TENORM disposal capacity However…some states are complicated Need to understand the disposal landscape and where your waste best fits

Contact Information Joe Weismann, CHP VP, Radiological and Government Affairs (208) 319-1634 Joe.Weismann@usecology.com Chad Hyslop Director of Sales, West (208) 319-1604 Chad.Hyslop@usecology.com