Operational History

The Philip Services Site Site is located at 2324 Vernsdale Road, approximately 4.5 miles
southwest of the City of Rock Hill, South Carolina. The Site consists of approximately 44.5 acres of
industrial property on the west side of Wildcat Creek and approximately 108 acres of undeveloped
woodland on the east side of Wildcat Creek. Beginning in the mid to late 1960s, the Site began to be used
for the storage, treatment and recycling of hazardous waste. From approximately 1966 until 1983, Walter
and Peggy Neal operated Quality Drum Company and, later, Industrial Chemical Company, which
received spent solvents from federal agencies and private third parties. The company stored the solvents
in drums or tanks on the Site, and used distillation to recover the solvents. A liquid waste incinerator was
permitted at the Site in September 1977. In 1979, there was a fire that destroyed a distillation unit and
drums. In 1981, a hazardous waste incinerator was installed on the Site, and the facility began to process
a broader variety of waste streams. Quality Drum and Industrial Chemical merged in December 1982 and
the surviving entity dissolved in August 1983.

Environmental sampling and remediation efforts by the former Site operators started at least in
1983, when the Site was purchased from the Neals by Stablex South Carolina, Inc. When Stablex
purchased the Site, 26,000 drums of waste and 200,000 gallons of bulk liquid waste were reportedly
onsite. Stablex changed its name to ThermalKem, Inc. in January 1987. Incineration continued while
ThermalKem operated the facility as a treatment, storage and disposal facility (“TSD”). There were
several fires at the Site during ThermalKem’s ownership. In July 1987 and March 1991, there were
incinerator explosions at the Site. In January 1995, a major fire destroyed the drum repackaging area.

In November 1995, Philip Services Corporation (“PSC”) purchased ThermalKem through its
subsidiary, Petro-Chem, and assumed the operation and management of the facility. PSC curtailed
operations and submitted an incinerator closure plan in 1998. PSC operated the Site as a fuel blending
storage and transfer facility until 1999 under the name Petro-Chem. The incinerator was removed in
1999. PSC declared bankruptcy in June 2003.