1 December 8, Clean Harbors Company Confidential A Brief Primer on the Value of Rotary Kiln Incineration Technology relating to Pharmaceutical Waste Destruction Presented to: PSI Seminar Series on Pharmaceutical Waste Management People and Technology Creating a Better Environment

2 December 8, Clean Harbors Company Confidential Company Overview

3 December 8, Clean Harbors Company Confidential Rotary Kiln Incineration Technology Rotary Kiln Incineration Technology has been in commercial operation since the 1960’s especially in Europe. The USEPA adopted Rotary Kiln Technology as the Official Treatment Technology for Organic Hazardous Wastes and for PCBs under the Resource Conservation and Recovery Act “RCRA” in 1980 and the Toxic Substances Control Act “TSCA” in 1978, respectively. There are currently 10 commercial rotary kiln Incinerators operating in the United States today with a total aggregate annual treatment capacity of approximately 650,000 tons.

4 December 8, Clean Harbors Company Confidential Typical Process Flow Diagram for a High- Temperature Rotary Kiln

5 December 8, Clean Harbors Company Confidential Incineration Operating Parameters Guaranteeing Proper Destruction of Organic Wastes Time, Temperature and Turbulence “The Three T’s” serve as effective indicators of efficient and compliant incinerator performance. Rotary Kiln Incinerators offer superior conformance with the Three T’s by virtue of the Kiln design which typically employs: counter-current air flow coupled with high operating temperatures ( in the range of 1800 to 2000 Degrees F) long waste residence time in the rotating kiln Excellent waste tumbling/mixing and turbulence generated by the rotating kiln and low-NOx combustion burner employing turbulence enhancement nozzles. Addition of a Secondary Combustion Chamber to enhance organics destruction (Operating Temperature typically 1850 to 2000 Degrees F)

6 December 8, Clean Harbors Company Confidential Incineration Operating Parameters Guaranteeing Proper Destruction of Organic Wastes All Commercial High Temperature Incinerators are required to conduct periodic stack tests to assure compliance with Federal CAA MACT Standards. The Stack Tests confirm: –Destruction/ Removal Efficiency “DRE” typically portrayed as or % –Conformance with CAA MACT Emission Standards for heavy metals, CO, THC, Particulate Removal and Dioxin Formation and Control –Data from Stack Tests inputted into Statistical Risk Models to assure compliance with cancer and non-cancer risk avoidance levels – typically less than 1 in 100,000 risk of cancer to humans from rotary kiln incinerator emissions.

7 December 8, Clean Harbors Company Confidential Advantages of Rotary Kiln Incineration Technology versus Stepped-Hearth Technology The USEPA selected Rotary Kiln Technology as the standard for destruction of solid organic hazardous and toxic wastes under RCRA and TSCA. USEPA’s Clean Air Act MACT Standards for Commercial and Captive Hazardous Waste Incinerators recognize Rotary Kiln Technology as the Best Performing Incineration Technology for the destruction of solid, organic hazardous and toxic waste. There are no commercial hazardous waste incinerators of the hearth design operating in North America today.

8 December 8, Clean Harbors Company Confidential Comparison of Emission Standards

9 December 8, Clean Harbors Company Confidential Clean Air Act MACT Performance Test Burn Results

10 December 8, Clean Harbors Company Confidential Conclusions Both Stepped Hearth and Rotary Kiln Incineration Technologies have a role in managing solid waste. Rotary Kiln Technology offers superior DRE and “Three- T’s” Combustion Management especially for refractory organic compounds that are hard to destroy. Rotary Kiln Incinerators meet stringent USEPA, EC and WHO emissions standards and these Standards will become more stringent as the USEPA evaluates existing MACT emissions limits. Our industry believes that Pharmaceutical Waste Generators will find Rotary Kiln Incineration Technology, which is the USEPA Standard for the Destruction of Organic Hazardous and Toxic substances, to be the destruction technology of choice for expired and discarded pharmaceutical waste.