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r <br />February 11, 2015 <br />V 0 3 2015 <br />Mr. Juston Smithers, CTO <br />44 Energy Technologies Incorporated ENVIRONMENTAL <br />1001 42nd Street, Suite 200 HEALT14 n1=PAQW1=hrr <br />Oakland, California 94608 <br />Re: Evaluation of Hazardous Waste Requirements Applicable to Catalytic Emissions <br />Control Units from Diesel Engines <br />Dear Juston: <br />As you requested, ENVIRON International Corporation (ENVIRON) conducted an evaluation for 44 <br />Energy Technologies Incorporated (44 Energy Tech) of hazardous waste regulatory requirements <br />applicable to certain activities planned by Red Fox Resources (Red Fox) for collection and recycling <br />of catalytic emission control units from diesel engines. ENVIRON understands that Red Fox plans to <br />collect the engine exhaust control units from customers for recovery of precious metals used as <br />catalysts. The purpose of ENVIRON'S evaluation was to identify applicable hazardous waste <br />regulatory requirements applicable to Red Fox's planned operations. <br />ENVIRON'S evaluation was based primarily on the following: <br />• Review of the Red Fox Business Background document provided by 44 Energy Tech; <br />• Review of laboratory testing results of ash samples collected by 44 Energy Tech and <br />analyzed by McCampbell Analytical, Inc. <br />• Review of federal Resource Conservation and Recovery Act (RCRA) hazardous waste <br />regulations set forth in Title 40 of the Code of Federal Regulations (40 CFR); <br />• Review of California hazardous waste regulations set forth in Title 22 of the California Code <br />of Regulations (22 CCR); <br />• Review of California hazardous recycling requirements set forth in California Health and <br />Safety Code (H&SC), Section 25143. <br />ENVIRON understands that Red Fox plans to collect exhaust catalyst parts known as diesel <br />particulate filters (DPFs) from customer facilities in California and store them at a Red Fox facility in <br />Oakland, California. Red Fox will ship the DPFs to a third -party entity in North Carolina for <br />disassembly of the DPFs. Certain components of the DPFs will be shipped from North Carolina to a <br />precious metal recovery facility located in Europe, where platinum, palladium, and potentially other <br />precious metals will be recovered in a smelting and refining furnace. <br />Based on our discussions, we understand that Red Fox may also collect ash filtrate from customer <br />facilities. The ash filtrate, which contains small particles of catalyst, would also be shipped to the <br />North Carolina facility and ultimately to the precious metals recovery facility in Europe. We <br />understand that the DPFs and ash may be collected at another facility in order to aggregate sufficient <br />quantities for economical shipments to North Carolina. <br />ENVIRON Intemational Corp., 2200 Powell Street, Suite 700, Emeryville, CA 94608 <br />V +1 510.420.2503 F +1 510.655.9517 <br />environcorp.com <br />