ML25177A137

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FOIA-2025-000430 - Released Set
ML25177A137
Person / Time
Issue date: 06/25/2025
From:
NRC/OCIO
To:
References
FOIA-2025-000430
Download: ML25177A137 (1)
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Text

conf1dencta1 tnfozma;;ton submitted wtdet 10 el'tt 1.. 536 wi tltho!:d f zom pab!.t c d+/-scl:pauzc

-ae'F 10 CJi'll 2 2110 1' ifuesday, Aprils, 2016 at 2:35:38 PM Central Daylight nme

Subject:

-Fwd: FW: Disposal of waste water sludge

,Date:

Monday, April 4, 2016 at 7:06:Sl*PM Central Daylight Time ifrom:

Jarnes Burgess To:

bob.compernolle Here.it is.

  • James
  • --- Forwarded message -
  • From: Corcoran, Michael S <,corcoran.michael@cleanharbors.com>

Date: Mon, Apr 4, 2016 at 6:33 PM

Subject:

RE:. FW: Disposal of waste water sludge ro: James Burgess <james.burgess@fmrHnc.com>

James,

-The disposal pricing is still valid for both Lone Mountain and Deer Trail if ail requirements for disposal are met and accepted by all parties involved.

Safg_ty_ Starts with Me: Live It 365 Michael Corcoran Account Manager Clean Harbors Environmental Services*

8100 Chancellor Row

'Dallas, TX 75247 Mobilej~fb-'<6_} ___ ~

Office: 972-591-2000 Email: corcoran.michael@cleanharbors.com Web: www.cleanharbors.com Emergency Response: 1-800~01L~TANK.(1-800-645-8265)

Page lof3

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¥P~i5 1 9 CEP 2 190 11

from
James Burgess [1]

Sent: Monday, April 04, 2016 4:14 PM To: Corcoran, Michael S

Subject:

Re: FW: Disposal of waste water sludge

Michael, I left you a message on your phone, The NRC is asking me for an update on the quote for Caf2 disposal in Colorado. Can you confirm the numbers in your quote of April of 2015.

I know if must meet the requirements of the disposal facility.

Also is the proposal for Deer Trial also still good.

James Burgess FMRI, Inc.

918-231-1867 On Thu, Mar 5, 2015 at 1:05 PM, Corcoran, Michael S <corcoran.michael@deanharbors.com> wrote:

James, for budgetary purposes based on the analytical provided we can go with the below pricing into our Lone Mountain facility:

Disposal: $SO.DO/ton Transportation: $1000.00/trip Demurrage: $103.00/hour Washout: $350.00

  • Recovery Fee 11.5% of total invoice Page 2 of3

Ceaiidoatj a l Infonnati a Bl!lll{'litil:i!d ::&a@nr a g-ill?fi iiil;398 n St!l-.. }20!.d

e*xsm !'~lie elsiaelaa'l!!!c tlfid@I l b C1R 2. 390 Safety Starts with Me: Live It 365 Michael.Corcoran Account Manager Clean Harbors Environmental Services 8100 Chancellor Row Dallas, TX 75247 Mobile: ~l(h_l<_6 ___ ~

Office: 972-591-2000 Email: corcoran.michael@cleanharbors.com Web: www.deanharbors.com Emergency Response: 1-800-0IL-TANK.(1-800-645-8265)

> From: James Burgess [mailto:j-ames.bur~fmri-inc.com)

> Sent: Tuesday, March 03, 2015 2:57 PM

> To: Corcorah, Michael

Subject:

Disposal of waste water sludge

> Attached is the chemical and MSDS Sheet from our Calcium Fluoride Sludge from a waste water treatment system operated at our facility. It is now FMRI, Inc use to.be the old Fansteel Plant in Muskogee, Oklahoma.

> I am available any time to talk to y0u about this project. The quanity is around 173,000 cu yd.

> A(Jdress

> FMR/ Inc.

> #10 Tantalum Place

> Muskogee, Oklahoma 74403

> Contact information

> James Burgess

> Cell !(hl/6 I

> E~Mail james.burgess@fmri-inc.com<mailto:james.burgess@fmri-inc.com>

> <Caf2 and soils amount DP.pdf>

> <Pond 8.pdf>

> <MSDS for pond 8 and9 calcium fluoride.pdf> <image002.jpg>

Page 3 of3

Phase II Project@ Muskogee, OK April 2015 Sludge Minimization, Dredging, Transportation and Disposal Clean Harbors Environmental Services, Inc.

42 Longwater Drive Norwell, MA 02061 Contact Michael Corcoran ~,

(b)-(6-) --~I Email: Corcoran.michael@cleanharbors.com Insert customer logo if Allowed FMRI, Inc.

10 Tantalum Place Muskogee, OK 74403

Gel'lfiBOFllitill iFlfof'RlletiOfl OIIBl'l'litteel 1:1neer 1.9 GFR 2.aeo ",_ithhele frePI, "t1hlie eieelee11re tlm~e, 4 0 OFR 2.aoon

.FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9.

'f ABLE OF CONTENTS 1.0 EXECUTIVE

SUMMARY

....................................................................... ;.............................. 2 2.0 PROJECT UNDERSTANDIN"G..................................................................................... *......... 4 MA T:ERIAL CIIARACTERIZATION.............,.................................................................................................... 4 3.0 APPROACH TO ONSITE DREDGING AND DEW ATERING............................................ 6 MOBILIZATION.................................................................................................................................................... 6 DEMOBILIZATION............................................................................................................................................. 6 MATERIAL REMOVAL-PONDS 6, 7, 8, AND 9............................................................................................. 7 PIIASE SEPARATION..................................................................................................... :................................... 8 HEALTII A.NJ) SAFETY.................,.............. -...................................................................................................... 9 Onsite Project Schedule...............................................................................................................................,.. 9 4.0 OFFSITE TRANSPORTATION AND DISPOSAL PLAN................................................... 10 TRANSPORTATION I LOGISTICS................................................................................................................... IO WASTEDISPO.SAL............................................................................................................................................ 12 Clean Harbors Deer Trail Landfill............................................................................................................... : 12 5.0 PRICING............................................................-.................................................................... 14 ONSITE SERVICES................................................................... :......... :..................................... :........................ 14 TRANSPORTATION AND DISPOSAL................................'.......................................................................... '.. 15 6.0 PROIBCT ASSUMPTIONS AND CONDITIONS................................................................ 16 ONSITE SERVICES............................................................................................................................... :............ 16

'TRANSPORTAITON AND DISPOSAL............................................................ :............................................... 17 7.0 IMPLEMENTATION................... :..........,......... :.... :.:............................................................. 18 www.cleanharbors.com Oo111pa11J Oot1Rde11tial

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FMRI, Musl<ogee, OK Phase II Ponds*5,6,7,8,9 1.0 EXEC,UTIVE

SUMMARY

Clean Harbors understands the importance of effectively managing the complexities and risks associated with large, multi task environmental cleanup projects. We are pleased to provide our proposal to manage the Phase II project at your Muskogee, OK facility to provide dredging, dewatering, transportation and disposal services for Ponds 6, 7, 8, & 9. We believe our qualifications and technical capabilities are second to none and that ourproposal demonstrates the true value of our experience with large environmental cleanup projects.

Based upon your request, Clean Harbors understands that FMRI is looking for contractor that can provide:

Project Expertise Liability Protection Proven Performance Record Project Expertise Our work history clearly demonstrates that we perform tasks in a safe,, cost effective, timely and envitonmentally-sound manner. This is a direct result of our work force.having a high degree of experience, professionalism, skill and dedication. Clean Harbors is the single company that has the expertise in both dredging & dewatering services as well as transportation an,d disposal services for the Calcium Fh1oride solids.

Clean Harbors has been performing dewatering & dredging services with th_e same core group of people for over 2,5 years. The Material Processing Group focuses on waste minimization. We have evaluated the information provided by FJ.4RI and provided a solution that we believe will best minimize the materials requiring off-site disposal in the most cost effective manner.

The transportation and disposal oftbe resulting Calcium Fluoride solids will be mana*ged by our Waste Projects Group. Our Waste Projects Group as a department has more than 20 years, experience and specializes.with the development and management of transportation logistics and disposal plans for customer projects that generate large volumes of waste. We have outlined our approach to transportation and disposaJ within our response.

Clean Harbors will assign a single Project Manager to act as the single point of contact for all activities from material removal to final disposal to ensure that this turnkey project runs smoothly, effectively and safely until its completion.

Liability Protection Clean Harbors offers maximum liability protection to its customers. Being the largest hazardous Waste Comp~y in North America, we understand the risk associated with managing customers' projects and associated waste. Clean Harbors will reduce FMRI's environmental Uability in the following ways:

As long as we are providing your transportation, Clean Harbors will take title to waste at your generation site. Your liability js shifted to us as soon as your material is loaded onto our Gondola cars.

www.cleanharbors.com 2

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eu11Rde"tial ii'lfePffl!ltio" Stlbft,iHe d t111der 10 OFF! 2.998 II.. 111,i,old r, 0111 public diselOSUIC t111de 1 10 OFF! 2.ese2 FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9 Clean Harbors will list FMRI as an additional insured on* our Automc5bile and General Liability policies. This further protects FMRI during the onsite processing of material and the transportation of your material to our disposal site.

Clean Harbors will dispose ofFMRI's material at its Deer Trail, CO NORM landfill. The company is required by law to provide financial guarantees to state and federal agencies for Closure and Post Closure costs associated with company owned TSDFs. Currently Clean Harbors' insurance coverage exceeds $270 million dollars.

Proven Pei:form.ance Clean Harbors philosophy and practices have established it as the preeminent provider of environmental services in North America. We have provided similar dredging, dewatering, transportation and disposal services for the following projects/customers:

ExxonMobil Western Refining Hudson E.iver Dredge Project.

U.S. Army Corp of Engineers U.S. Department of Energy Why Clean ~arbors?

One Company with the expertise and experience to provide ALL

  • the services-required to safely, efficiently and effectively remove the materials from-your ponds and properly dispose of them.

35 years experience offering waste management solutions to over 65% of Fortune 500 ~ompanies.

. -Clean Harbors. can significant.ly reduce FMRI's liability exposure associated with the management of hazardous wc1ste.

Because Clean Harbors understands the level of trust. that you are willing to extend to a supplier and you can be assured th~t addressing your needs is our primary focus.

www.cleanharbors.com 3

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Phase II Ponds 5,6,7,8,9 2.0 *PROJECT *UNDERSTANDING FMRI has requ_ested that Clean Harbors provide a proposal for sludge removal, dewatering,

.,transportation and disposal of sludge associated with Pond Nos. 5, 6, 7, 8, and 9 at FRMl's s Muskogee, OK location. FMRI requires all that all sludge and liquids io the basin~. to be removed and dewatered in order to meet off-site landfill disposal acceptance criteria. All dewatered -

.materials are to be transported offsite for disposal at an acceptable landfill. FMRI requests.the

-HPDE liner in Ponds 8 & 9 remain in the ponds for inspection.

According to tbe table provided *by FMRI below, there is approximately 173,072 cubic yards to be

  • removed and processed. *There is an additional waste stored in supersacks at FMRJ warebouse to be shipped with this waste.

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  • . 130 1,378 No. 6 3.0 100 160 l,636 No. 7 3.0 120 205 2,555 No. 8 25 350
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565 84,170 Total 173,072 MATERIAL CHARACTERIZATION Samples ~f Pond 9 insitu material were provided by f'MRI. Clean Harbors has used the samples from Pond 9 as representative of the material contained in Ponds 6:, 7 and 8 to do the volume reduction estimates. Cl~an Harbors conducted limited laboratory analysis and 'bench scale treatability testing on this material. The production data and project duration estimates used in this proposal are based upon the results from tbis*sample analysis. Any variation in the actual characteristics of materials in Ponds ~,7,8, and 9 may result in extended project duration and higher project cost.

Table I, In-situ Material Characterization are estimated values based on sample provided and Clean Harbors' previous experience with similar basins and is the basis for the production rates, estimated recovery rates and pricing contained in this proposal.

Table I In-situ Material Characterization Pond 6, 7,.8 & 9 Com-poncnt**:.::~* ( *...,:;-x.:* ~Vaitie:r:: : ;~1,* t-._. *,V.ofome--',s:f:'*,&t*.!.;.-- --, :,wcight~#l"i::)v:~~T,esi:Meth.ocr1'.t~-

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  • ..,, *JI In--situ 100.0%...

825,766 bbfs 185,120 tons ByFMRl -

Solids 35.9 %

66,458 tons A'~TMD473

  • Organics Water 64.!'%

118,662 tons AS'fMD95 Specific Gravity 1.28 10.681b / gal SM2710G www.cleanharbors.com 4

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  • MOBILIZATION Pre-job Meeting Clean Harbors and FMRI review.

Establish work area Clean Harbors will layout the process area and install temporary containment in process areas, pump areas, and other spill hazard areas. Once spill containment has been installed the equipment will be positioned to establish the work area.

Mobilize personnel and equipment Clean Harbors will mobilize equipment and personnel from our Seaco facility located in Houston, Texas. The mobilization schedule will be coordinated with the FMRI representative to ensure there are no delays during the mobilization phase.

Lock and tag-out all applicable energy sources Clean Harbors will confirm that standard lock out and tag out procedures to isolate the basin from all energy sources and inflows have been completed.by FMRI and will apply Clean Harbors' Jocks as required. This will only be required for the final entry cleaning. Ponds will stay in service during dredging except for one being cleaned.

Utility Requirements Clean Harbors understands that FMRI will supply, at no cost to Clean Harbors, the following to the Clean Harbors' process area:

ITEM Electrical

. Utility Water

  • Process Water
  • Rail Service
  • Electrician Permit
  • Break Room Warehouse DEMOBILIZATION Decontamination of equipment Requirements 800 AMP, 480 VAC, 3 Phase 100 GPM@ 40 PSI, non-continuous 50 GPM@ 40 PSI, for chemical make up Ability to use Rail Spur during Project
  • During mobili7..ation to assist with connections Safety and Operations Permits Break and restrooms onsite Access to warehouse(supersack stored building) and a staging area(preferable in the warehouse) for processed material waiting to be loaded into rail cars.

Clean Harbors will decontaminate all equipment and materials at the Clean Harbors process site or at another location specified by FMRl. All rinsates will be returned to FMRI "as-is" with no further process by Clean Harbors. All project debris will be packaged in containers provided by Clean Harbors for disposal by Clean Harbors.

Demobilization www.cleanharbors.com 6

Ou111ide11til!I infeP1111!1ie11 submitted undeP 10 OFR i!.898 " nill1llold hv111 public diselosmc 011dc, 10 OFR !.S!0' FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9 Once all equipment has been decontaminated and debris packaged, Clean Harbors will demobilize all equipment and personnel from the site.

Final site inspection Following site demobilization, Clean Harbors and FMRI will jointly make a final site inspection.

MATERIAL REMOVAL - PONDS 6, 7, 8, AND 9 Based upon the information provided by FMRJ, Clean Harbors will place a floating dredge into Pond 9 upon our arrival on-site. The dredge will have rubber tires on the auger to prevent any damage to the existing HPDE Liner. Clean Harbors is not responsible for any existing holes or tears in the existing liner. Clean Harbors will install a cable system from each corner of the pond connected to the dredge. Floating pipe and land pipe will be installed to transfer the in-place sludge to the process area. Clean Harbors will direct a sludge stream from the dredge to multiple mix tanks for dewatering. Clean Harbors expects approximately 2: I of water will be transferred with the sludge and returned back to the pond. A minimum 18 inches of water is required to remain in the pond during this operation.

This operation will continue on Pond 9 until 12 inches or less material is left in the basin. Clean Harbors will remove the floating dredge and place into Pond 8. The cable system will be attached to the existing anchor points. Clean Harbors will begin the dredging operation on Pond 8 to remove the sludge. At this time Clean Harbors will enter Pond 9 and firewater wash the remaining sludge and transfer the material to Pond 8. FMRI will test and inspect Pond 9 for completion.

Clean Harbors will repeat this procedure for Ponds 6 and 7. Ponds 6 and 7 are clay lined and Clean Harbors will dredge until the sludge above the clay bas been removed. Clean Harbors will remove the dredge and lower the water for inspection. No pressure washing is required for Ponds 6 and 7.

www.cleanharbors.com 7

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Coufide11tial i11fo1111atio11 sobliiitted 011de1 16 erR !.386 wltliliOlcJ ft OIi i pobllc dlsclosate Ofldet 10 CP'"- 2.590 FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9 PHASE SEPARATION The fluidized material will be transferred to multiple centrifuges for dewatering. There will be a polymer system inline to floe the solids from the water during this operation. The material will be separated into 2 streams, recovered water and solids. The recovered water will be gravity fed from the centrifuges and returned to the pond. The processed solids will be deposited waste into soft-side lift bag containers which will be loaded into gondola rail car containers provided by Clean Harbors for collection and disposal by Clean Harbors.

Table II details the cake Clean Harbors expects to generate during this project from Pond 9.

This data should be similar for the solids in Ponds 6, 7 & 8.

The estimates are based on the insitu material samples as detailed in Table I. Variations in the material characteristics from that in Table l will impact the disposal cake as represented in Table ll.

Solids Organics Water Total 42.8%

57.2 %

100%

Pond Sand Warehouse (supersacks waste)

, r~ I, 1 66,458 tons ASTM D 473 88,818 tons ASTMD95 155,276 tons Estimated Clean Harbors will provide heavy equipment to excavate approximately 1,378 cubic yards from Pond 5 and add to the containers with the centrifuge cake simultaneously during the dredging operation of Ponds 6, 7, 8 and 9. The supersacks will be lifted and loaded with the disposal cake.

www.cleanharbors.com 8

Company Ccofidontial

Oonf18entiel ii 1fo1,, 1atio1, sub,, 1iltcd n, 1de1 18 OFR i!~S98 tt will 11 sold ~ 01,, public disclosa, e 011de1 18 efrft l.396' FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9 HEAL TH AND SAFETY Safety is Clean Harbors' first priority. Beginning with initial training, safety procedures are emphasized throughout an extensive safety program. All personnel are trafoed to meet and exceed the OSHA requirements in 29 CFR 1910.120. This is followed by monthly safety/operational meetings to reiterate, and update existing procedures, and introduce new ones as required.

Before any project may begin, a site specific Safety Plan must be completed by the Clean Harbors Health and Safety department. This includes the determination of all safety related facilities and the required equipment on the job site. Special handling requirements are noted such as the use of respiratory protection and protective garments.

The Plan will identify the hazards associated with the project and will establish the appropriate procedures and protocols for minimizing these hazards and their potential impact upon customers, employees, subcontractors and the community. Though unlikely, if a leak or spill occurs during the on-site phase of the project, the Clean Harbors crew will take immediate action to contain the release. Clean Harbors will notify FMRJ immediately of any release as well as Clean Harbors management so that additional action can be arranged as appropriate. FMRI is responsible for notifying the proper government agencies as necessary.

Clean Harbors has identified two (2) areas for personnel protective equipment. Clean Harbors will conduct periodic on-site testing to verify the level of protection proposed is adequate for the hazard encountered. We do not anticipate dealing with H2S during onsite activities. Additional costs to FMRI may be incurred should a hjgher level of protection be required as specified below.

Basin - Entry Clean Harbors anticipates personnel will enter into each basin during the course of this project and has included provisions for such herein. Operations in the confined space area will be conducted in OSHA level D personnel protective equipment. This includes life jackets, hard hat, safety boots, long sleeve shirts, and safety glasses.

Dewatering and Support Areas Operations in the dewatering and support areas will be conducted in OSHA level D persorn1el protective equipment. This includes fire retardant outerwear, hardhat, safety boots, long sleeve shirts, and safety glasses.

Onsite Project Schedule Clean Harbors estimates the following time line for completion of the onsite material processing portion of the project. Estimated days are based upon the assumption of workmg 12-hour days. We may be able to shorten the schedule by increasing daily throughput which will be dependent upon Transportation and Disposal scheduling once the project has started.

  • !* Mobilization I day
  • ~ Site Set Up 4 day
Removal & Processing Pond 9 304 days
  • !* Removal & Processing Pond 8 301 days
  • !* Removal & Processing Pond 7 15 days
  • !* Removal & Processing Pond 6 12 days
  • !* Site Rig Down 4 days

-~ Demobilization 1 day www.cleanharbors.com 9

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  • nilhheld fru.. I 1111elio dioelee111re 111neier 1 Q GFFI z!.8QQ" FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9 Note: Pond 5 and the warehouse material will be processed simultaneously during this schedule.

4.0 OFFSITE TRANSPORTATION AND DISPOSAL PLAN FMRl has requested proposals for the transportation and disposal of approximately 173,000 tons of Calcium Fluoride material (solids) resulting from the direct closure activities of four (4) surface impoundments (Ponds 5, 6, 7, 8 and 9) located at the former Fansteel facility in Muskogee, Oklahoma.

The work prescribed herein pertains to activities associated with Phase 2 of the Decommissioning Plan. Jmpoundment sediments containing low levels of Uranium and Thorium residue will be treated and prepared by Clean Harbors Industrial Services (CHJS) team by means of dredging and dewatering to meet our disposal facility requirements including but not limited to paint filter testing.

Clean Harbors' Industrial Services Group will load the waste into soft-side lift bag containers and place loaded bags into the gondola cars that will be provided by Clean Harbors. We are exceptionally familiar with these large lift bags and have safely transported tens of thousands of tons in this type of packaging.

TRANSPORTATION / LOGISTICS It is understood that the site (origination) is served by the Union Pacific Railroad (UPRR). Either FMRl or the UPRR will provide local power to move the gondola cars on and off the private siding. Loaded cars will be shipped to Cleru1 Harbors' rail siding in Sterling, NE which is served by the UPRR Railroad.

Alternatively, Clean Harbors may utilize a different siding under exclusive BNSF lease to Clean Harbors, near Brush, CO. The siding is in an exceptionally remote location, but roads are wholly suitable for rear dray truck traffic and over the road conveyance. Clean Harbors reserves the right to utilize either location or both sidings at its sole discretion to ensure materials are moving smoothly and efficiently to the disposal site. We have calculated this flexibility into our pricing.

Clean Harbors will provide I 00-ton gondola railcars (or equivalent) for transportation from the site to the Clean Harbors rail siding. We anticipate having to provide approximately 60 railcars to maintain production rates. Clean Harbors expects that the approved soft-sided sack will be of such design and construction to adequately repel precipitation therefore we don' t believe that the gondola cars need to be lined. Clean Harbors is amenable to further consideration of additional measures to line the gondola if FMRI requests this. In that scenario, each gondola would be lined with a robust woven polymeric fabric designed to our exact railcar specifications and size. Liners have center zipper enclosures and are fitted with a tamper indication device to deter unauthorized access. At the destination siding, Clean Harbors will lift the sack from the railcars leaving its contents intact and the sacks will be placed on trucks for the rear dray shuttle into the NORM landfill, Clean Harbors Deer Trail facility.

Since drayage vehicles will be limited to roughly 48,000 NET pounds, we propose that the NET weight of each soft-side lift bag container be managed to a maximum bag weight of24,000 10

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FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9 pounds (12 short tons). Bags exceeding 24,000 pounds would result in a higher dray cost and additional costs to FMRI.

www.cleanharbors.com 11 t;:&A'lfiiiAY Canfi&lenliel

eu11fidenlial infon11alio11 sab111itted ande, 18 8FR Z.396

  • witliliold f.0111 public disclosa,e 011de1 1e eFR l.390 FMRI, Muskogee, OK Phase JI Ponds 5,6,7,8,9 WASTE DISPOSAL Clean Harbors understands the Fansteel facility generated approximately 173,000 tons of calcium fluoride (CaF2) waste material as a result of Tantalum and Columbium oxide extraction, purification and production. Tantalum and Columbium oxide are used mainly for production of capacitors and heat resistant alloys, respectively. However, as a result of uranium and thorium utilization at the facility, the four (4) surface impoundments are regulated under the sites' Nuclear Regulatory Commission (NRC) license.

Clean Harbors Deer Trail Landfill Clean Harbors proposes to utilize our Deer Trail landfill facility for disposal of the calcium fluoride waste material. Deer Trail is a fully permitted Subtitle C landfill authorized to treat, store and dispose of a wide variety of hazardous and industrial wastes including RCRA, TSCA (Megarule) and debris for encapsulation. Since December 2 I, 2005, Deer Trail has been licensed to dispose of Naturally Occurring Radioactive Material (NORM) and Technologically Enhanced Naturally Occurring Radioactive Material (TENORM) wastes. This license was issued by the State of Colorado, Department of Public Health and Environment. Deer Trail can accept NORM and TENORM wastes containing radionuclides (in the decay series ofU-238, U-235 and Th-232) up to 2000 pCi/gram. The Rocky Mountain Low Level Radioactive Waste Compact has designated Deer Trail as the Low Level Waste Facility for Colorado, New Mexico and Nevada.

Deer Trail is located 75 miles east of Denver, CO. The facility can store, treat and dispose of wastes in bulk and containerized quantities. Deer Trail receives waste by truck and also by rail from a trans-loading point located in Colorado. Deer Trail is set in an extremely rural and remote location with the following features:

325 acres of active permitted facility Surrounded by 5760 acres of Clean Harbors owned buffer zone 2.5 million cubic yards of permitted, constructed cell space over an impermeable Pierre Shale formation.

Deer Trail Permits and Licenses Colorado Radioactive Materials License Number: Colo. 1101-01, CDPHE RCRA Part B Permit renewed 2005, No:

CO-05-12-21-01, CDPHE EPA ID No: COD99l300484 USEPA Certificate of Designation, No:

147-82-C-CD, Adams County Colorado Wastewater Discharge Pennit, No: CO-

0042064, CDPHE Colorado Air Emissions No: 0IAD0713 A facility fact sheet is attached with further information regarding the Deer Trail facility www.cleanharbors.com 12 Cowpnv CoRlidoR&iiill

eo11nde11lial h1fo1111alio11 sab111ilted 0 11de1 FMRI, Muskogee, OK 18 eFR: l.3~6 >> ooitlrliold f1011 1 public discfosu,e ande, 18 8FR 2.990' Phase II Ponds 5,6,7,8,9 Transportation & Disposal Deer Trail, Colorado Facility Facts Colorat.lo Radioactive Maleriab License Issued on December 21, 1005 The Deer Trail facility is a fully permitted Subtitle C landfill authorized to treat, store and di~ose of a wide variety of hazardous and indUBtrial wastes including RCRA., TSCA (megarule) and debris for encapsulatioa Since December 21, 2005, Deer Trail has beenlioen.~ed lo dispose ofNaturally Occumng Radioactive Mat~nl {NORM) and Technologically Enhanced Narwally Occurring Radioactive Material (fENOR.M) wastes. This license was issued by the State of Colorado, Department of Public Health and Environment DeerTrail canaooeptNORM and TENO RM wastes containing radionuclides (in the decay *eries ofU-238, U-235 and Th-232) up lo 2000 pCi/gnun. The Rocl'Y Mountain Low Level Redioactiw Waste C~pact has designated Deer Trail as the Low Level Waste Facility for Colorado, New Mexico and Nevada.

Deer Trail is localed 75 miles east of Denver, CO. The facility cmi store, treat and diiJ>OSe ofw;wtes in bulk and containeri~

quantities. Deer Trail receives waste by truck and also by rail from a buns-loading point located in Sterling, Colorado.

Permits Colorado Radioactive Materials License Nwnber Colo.

I 101-01, CDPHE RCRA Part B Pennit renewed 2005, No. ffi-05-12 01, CDPHE EPA ID No. COD991300484, US EPA

~

0~~~r_bp13 ENVIRONMENTAL SERVICES" Certificate of Designation, No. l4H!2-C-CD, Adams Comity Colorado Wastewater Discharge Pennit, No. CO*

0042064, CDPHE Colorado Air Emissions No. 0IAD0713 Facility Description & General Information Pennit issued - 1987, first waste received - 1991 325 acres of pennitted facility SWTounded by 5760 acres of Clean Harbors owned buffer zone Rural location 2.5 million cubic yards of permitted cell space Sited on the impenneable Pierre Shale formation Services Provided:

Storage, final treatment and lllnd.fill disposal Stabilization treatment of toxic metnl wastes Custom treatment of organic wastes Chemical reduction Solidification of liquid wnsles Deactivation and neuln!lization Micro encspw.lati on Macro encapsulation Direct landfill Typical Customers: Customers include, but are not limited to, remediation sites, chemical focilitics, manufacturer&,

refinerie$, mines, plating facilities, nnd brokers.

Typical Waste Streams: Typical waste streams accepted include, but are not limited to, NORM and TENORM wastes, industrial metal bearing wastes, contaminated process wastewaters, refinery wastes, inorganic cleaning solutions.

plating wastes, paint residues, debris from toxic or reactive chemical cleanups, off*!lpec commercial prodacts.

Treatment, Storage and Disposal Capabilities Totally enclosed waste treal:ment building with dual emission control systems Drum Storage Building with capacity for 600 x 55-gallon drums or 33,000 gallons Bulk Container Storage Alea A; 2000 C'Ubic yards of bulk solids Bulk Container Storage Area B: I 000 cubic yards of bulk.

solids Wide rnnge ofpennittoo wnsw oodes Clean Harbors~ Tnil. LLC

  • 10~l5 Bast Hi8'Jway 36
  • Deer Tnil, CO 80105
  • 970.386.2293
  • www.clC1Ulharl>on.com www.cleanharbors.com 13 Co11,1pany t;enlielentiel

8 0111itiel'l1iel il'lfel'ff'lft1ie11 sabl'!lilteti 011t1er 10 SFR 2.888 ".uitflliuld f. 011 1 public disclosmc u;;Jc, 18 eFR i!.SBO' FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9 5.0 PRICING ONSITE SERVICES Based on the written scope of work provided by FMRI and the scope of Services described herein, Clean Harbors is pleased to offer the following pricing for the onsite dredging and dewatering portion of the project. Pricing includes loading dewatered solids into. soft-side lift bag containers and placing the loaded bags into gondola cars..

Mobilization of personnel and equipment (Lump Sum)........................................................ $41,070 Demobilization of personnel and equipment (Lump Sum).................................................... $41,070 Site Set Up (Lump sum)............................................................................................................ $42,350 Site Rig Down (Lump Sum)...................................................................................................... $42,350 Material Removal & Dewatering..................................................................... _.. S44 per disposal ton Unit rate includes supervision, manpower, equipment, and materials necessary to perform the scope of work as described herein. Clean Harbors estimates 608 onsite days will be required for.processing 173,072 cubic yards of insitu material. This rate will be used for the material in Ponds 5,6,7,8 and 9 and the supersack material from the warehouse. The unit rate is based on 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day, 6 days per week.

Any downtime caused by debris in the lagoon will be considered billable time and will be invoice at the below daily rate. Additionally, FMRI will be invoiced cost plus 15% for all repairs to the dredge caused by debris damage.

Process Chemistry Clean Harbors will invoice FMRI on an as used basis for all process chemistry. Process chemistry may include polymer, surfactant, body additives and carbon.

Polymer........................................................................................................... $2.20 per pound The sample from Pond 9 required 482 ppm of Polymer per diluted volume. Clean Harbors will invoice for the actual quantity of polymer required on an as used basis.

Diesel Fuel...................................................................................................................... Cost Plw 10%

FMRI may, at FMRI's discretion provide diesel fuel for Clean Harbors' on-site equipment or request Clean Harbors to provide. If the diesel fuel is provided by Clean Harbors, FMRI will be invoiced cost plus 10%.

Loading Frames and Lifting Frames (Lump Sum)............................................................ :... $57,000 Clean Harbors expects to initially charge the site with 6 loading frames and 3 lifting frames for loading 15 ton PACTEC LP 855-11 Bags.

PACTEC LP 855 -Il Bags (15 ton capacity)........................................................................ $361 each Clean Harbors will invoice for actual quantity of bags required bags on an as used basis.

www.cleanharbors.com 14 6e,nr,en, 6 el'ltiae:,tiel

eur1ffde1.1tial i11fo1111a tio1 1 sab111itted u11de1 10 er rt: 1'..390 wm11101a r10111 pabllc dlsclosure 11uer 10 CPR 2.390 FMRI, Muskogee, OK Phase II Ponds 5,6,7,B,9 TRANSPORTATION AND DISPOSAL These rates arc provided exclusively to FM.RI based on the approach and general understanding presented herein and should be wholly regarded as confidential material.

Transportation and Disposal @ Clean Harbors Deer Trail............................................ $169.00/ton Shipped via rail, non-RCRA, Class 9 in gondola cars Rail Fuel Surcharge............................................................................................. $168.00/gondola car Rate is based on 201 S (April) variable fuel surcharge rate of $0.16/milc applied to 1050 miles

-Rocky Mountain Low Level Radioactive Waste Compact Fee........................................... $5.00/ton Compact fee prevailing on 4-2015 Adams County Disposal Fee................................................................................ *................... $4.95/ton Railcar Mobilization (Initial, estimate 60 cars needed)............................................. $3,372 per car Railcar Demurrage:......................................................................................... $85.00 per car per day First (5) days free (after constructive placement); demurrage thereafter WWW.clea nha rbors.com 15

euI1HdeIIllal hIfoIII,atloII SUbiiillted 0IIdeI 10 CP'P{ 2.!586 11 ooitl1l1old F10111 public disclosu,e urIdeI 16 e FR !.S9QD FMRI, Muskogee, OK Phase II Ponds 5,6,7;8,9 6.0 PROJECT ASSUMPTIONS AND CONDITIONS This proposal is submitted contingent upon the right to negotiate mutually acc~ptable contract terms and conditions, which are reflective of the work contemplated and an equitable distribution of the risks involved therein. In the event that such agreement cannot be reached, Clean Harbors reserves the right to decline to enter into such an agreement without prejudice or penalty.

This proposal information is proprietary and only for FMRI internal use. FMRI may not disclose this information without Clean Harbors' written approval.

Please find below the general cQn,ditions and assumptions for this bid. These conditions are in addition to specific pricing notes provided on the pricing matrb(es. Clean Harbors must approve any exceptions to

  • this proposal.

ONSITE SERVICES

1. This proposal is based on working twelve (12) hours day, six.(6) days per week during waste processing, and se~p/rig down. FMRI agrees to sign Clean Harbors record of work accomplished (Production Sheet) on a daily basis.
2.. Clean Harbors assumes its.personnel will have c*omplete and uninterrupted access to the site.
3. FMRI will provide a suitable staging and operating arc;:a for this project.
4. FMRI will provide all required work related permits.
5. Clean Harbors is not responsible for any damage to underground structures of utilities that are not properly marked by FMRI.
6. Clean Harbors believes fh_eseprices are sufficient to complete-the project as described, but no guarantee is given or implied. The overall cost for the project may change if 1) the scope of work changes or additional time is required on site, or 2) the quantity or composition of the waste material chan~es.
7. Clean Harbors will invoice FMRI for any delays unless the delay is solely the result of Clean Harbors' acts or omissions as it relates solely to the services to be provided ~ this proposal.
8. The prices in this proposal are based on the specified level of personnel protection specified in out proposal response. If a higher level is required, the price will need to be adjusted accordingly.
9. The pricing contained herein is bas~d on each Pond being structurally sound and in serviceable condition at the time Clean Harbors arrives on site. Once on site, should Clean Harbors discover the basin to be structurally unsound, or that the integrity of the basin has been comprised, additional costs will be incurred. Clean Harbors is not responsible for replacing the Pond liners in Pond 8 and 9.

www.cleanharbors.com 16

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COiilide11t1a1111ru1111a11011 Subii,illed Olide, 1B OFR 2.SSB" nillil,old franc i,uelie dieeloe111ro ldflflor 10 G~R il.iQQ" FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9 TRANSPORTAITON AND DISPOSAL

1. The transportation and disposal rate assumes all the following
a. Minimum billing quantity of 95 tons per gondola
b.

Daily output of approximately 200w300 NET tons 5 days per week.

c. One-time cost to Free-Release each gondola at project completion
2. The impoundment material must meet the following criteria:
a. Is DOT Class 9
b. Contains low levels of natural uranium and thorium ( <500 ppm)
c.

Is not a RCRA hazardous waste

.d. Will pass the paint filter test

3. Clean Harbors Industrial Services or other FMRI contractor will:
a. Dewater, add absorbents or otherwise prepare the waste to prevent accumulation or separation of liquids during transportation.
b.
  • Load the waste into approved 10-12 ton capacity soft-side lift bag containers and maintain NET weight at a maximum of 24,000 pounds.
c. Place loaded waste sacks into Clean Harbors provided gondola railcars.
d. Provide local power to move railcars into position along the siding.
e. Conduct its operations to reasonably minimize surges and progress at a steady pace.
4. Clean Harbors will provide:
a. gondola railcars
b. rail transportation to designated siding
c. transfer from railcar to truck and rear dray transportation
d. secure landfill disposal
e. broom swept and empty railcars back to the origination site for reload
5. Clean Harbors will provide a fleet of cars, designed to arrive or be constructively placed at the point of origin (Fansteel) and be loaded promptly. Cars not loaded after five (5) days will be charged a car demurrage fee and any other railroad penalty fee's.
6. Clean Harbors will pass-through, without markwup, the Rail Fuel Surcharges, Rocky Moun_tain Low Level Radioactive Waste Compact Fee's and Adams County Disposal Fee's.
7. Rail Fuel Surcharge: This is a monthly rate applied by the serving railroads. It is variable and frequently changes on a monthly basis. We are providing the current April 2015 FSC rate:

$0.16/mile applied to 1,050 miles.

8. Clean Harbors rates provided above are accurate to the best of our knowledge and based on prevailing costs and pricing as of today's date. Rail tariff rates can be updated and put in place 90 days prior commencement of shipping. FSC rates will change monthly. All disposal Compact and local taxes and fees will be updated as to the prevailing rate at time of anticipated receipt.
9. This bid is contingent upon the waste meeting the acceptance criteria of the Colorado Radioactive Materials License 1102-01 Amendment 13. Imports of radioactive materials from outside the Rocky Mountain Region to the Clean Harbors Deer Trail Facility are subject to the approval of the Rocky Mountain Low-Level Radioactive Waste Board and the State of CO.

www.cleanharbors.com 17 euu 1pa119 ea, 1nde1 nlal

0 011fiftentinl infe,nretio11 Job, uitlcd u11dc1 18 OFR 2.998 " voithJ,old fl 0It1 _public disclusu,e a11de1 16 erR 2Ji90" FMRI, Muskogee, OK Phase II Ponds 5,6,7,8,9 7.0 IMPLEMENTATION

_ Clean Harbors is prepared to begin this project after:

FMRI provides Clean Harbors with a mutually acceptable purchase order and gives notice to begin work.

Necessary waste stream approvals are received from the disposal facility which includes the waste meeting the acceptance criteria of the Colorado Radioactive Materials License 11 02-01 Amendment 13. Imports of radioactive materials from outside the Rocky Mountain Region to the Clean Harbors Deer Trail Facility an, subject to the approval of the Rocky Mountain Low-Level Radioactive Waste Board and the State of CO Clean Harbors has scheduled appropriate items with outside parties and Clean Harbors and FMRI agree on a mobilization and project schedule.

www.cleanharbors.com 18 Companv Confidential

Phase II Project@ IVluskogee, OK April 2015 Sludge Minimization, Dredging, Transportation and Disposal Cle1111 Harbors Environmental Services, Inc.

42 Longwater Drive Norwell, MA 02.,...06"-'I ___

~

Comoct Michael CorcoranlCb)(6)

I Email: Corcoran.michact@cleanhatbors.com Imsen customer logo if Allowed FMRT, Inc.

IOTantalum Place Muskogee, OK 74403

FMAI, Muskogee, OK Phase II Ponds 5,6,7,8,9 1.0 EXECUTIVE

SUMMARY

Clean Harbors und~rsumds the importance of effectively managing the complexities and risks associated with large, multi task environmentaJ cleanup projects. We are p,teased Lo provide our proposal to manage the Phase ll project at your Muskogee, OK facility to provide dredging. dewatering, transportation and disposal services for Ponds 6, 7, 8, &. 9. We believe our qualific:ations and technical capabilities are

  • econd to none and that our proposal demonstrates the true valuie of our experience with large environmental cleanup projects.

.Bnsed upon your request. Clean Harbors understands that FMRJ[ is looking for contractor that can provide:

Project Expertise Liability Protection Pronn Performance Record Project Expcrrj e Our work history clearly demonstrates that we perform tasks in.a.s.,fe, cost effective, timely and environmentally-sound manner. This is a direct result of our WC>rk force having a high degree of experience, professionalism, skiJI and dedication. Clean Harbors is the single company that has the expertise in both dredging & dewatering services as well as transportation and dispos.,1 services for the Calcium Fluoride solids.

Clean Harbors has been performing dewMering & dredging services with the same core group of people for over 25 years. The Materi.'ll.Processing Group focuses on waste minimization. We have evaluated the information provided by FMRl and provided a solution that we bel.ieve will best minimize the mnterials requiring off-site disposal in the most co *t effective manner, The transportation and rusposal of the resulting Calcium Fluoridle solids will be managed by our Waste ProjectS Group. Our Waste.Projects Group as a department has more than 20 years e,cperience and specializes with the development and management of trnnsportation logistics and disposal plans for customer projects thai generate large volumes of waste. We ha,re ouLlined our approach to transportation and disposal within our response.

Clean Harbors will assign a single Project Manager to act as the single point of contact for all activities from material removal to final disposal to ensure that this tumk~:y project runs smoothly, effectively and safely until its completion.

Unbility Protcl-tion Clean Harbors offers maximum liability protection to its custon1ers. Being the largest. hazardous Waste Company in Nonh Americn, we understand the risk aswciated with managing customers' projeclS and associated waste. Clean Harbors will reduce Th1R1's environm~mtal liability in the following ways:

As long as we are providing your transportation. Clean lffarbors will take title to waste at your generation site. Your liability is shifted to us as soon as your material is loaded onto our Gondola cars.

www.cleanharbors.com 2

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FMAI. Muskogee, OK Phase II Ponds 5.6,7,8,9 Clean Harbors will list FMRI as :in additional insured on our Automobile and General Liability policies. This further protects FMRI during the onsite prooessing of material nnd the transportation of your material to our dispos:il site.

Clean Harbors will dispose of FMRI's material at its Deer 1rmil, CO NORM landfill. The company is required by law to provide financial guarantees to state and fedcraJ agencies for Closure and Post Closure costs associated with company owned TSDFs. Currently Clean Harbors' insurance coverageex.ceeds mo million dollars.

P ro\\'Cll Performance Clean Harbors philosophy and practices have established it as the p1reeminem provider of envirooment:il S(!rvices in North Americn. We have provided similar dredging_. dewatering, transpomtion and disposal ervice.s for the following projects/customers:

ExxonMobil Western Refining Hudson River Dredge Project U.S. Army Corp of Engineers U.S. Department of Energy Why Clean Harbors?

One Company with the expertise and e <perience to provide ALL the services required to safely, efficiently and effectively remove the materials from your ponds and properly dispose of them.

35 years experience offering waste management solutions to over 65% of Fortune 500 companies.

Clean Harbors can significantly reduce FMRI's liability exposure associated with the management of ha2tardous waste.

Because Clean Harbors understands the! level of trust that you are willing to extend to a supplier and you can be assured that addressing your needs is our primary foicus.

www.cleanharbocs.com 3

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