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Mr. Juston Smithers -3- 11 February 11, 2015 As indicated in the laboratory report, the only organic constituent that was detected in the analysis following the TCLP extraction was dimethyl phthalate. There is no TCLP threshold for dimethyl phthalate. Therefore, the test results indicate that the ash does not exhibit a RCRA characteristic of toxicity. In absence of any detected TCLP organic constituents and based on the low likelihood that significant concentrations of organic constituents would be present in the ash, ENVIRON concludes that a single sample is sufficient for assessing the potential for RCRA toxicity due to organics. Based on the above-described test results, the ash would be classified as a non-RCRA hazardous waste in California. Waste Characterization of DPF Units DPFs are generally in one of the following configurations: • DPFs comprised of an outer metal casing coated with a substrate (usually ceramic) that contains precious metals (e.g., platinum, palladium); • Uncoated DPFs that are made of ceramic and do not contain precious metals; • Uncoated DPFs that are made of stainless steel and do not contain precious metals; or All DPFs may contain small amounts of the ash that was characterized in the preceding section of this letter. The DPFs are evaluated for potential waste characteristics attributable to zinc in the ash and platinum in the substrate, as described below. Red Fox will also collect non-DPF catalysts comprised of flow-through substrates that have honeycombs coated with precious metals. ENVIRON understands that flow-through catalysts are much less likely to contain a significant amount of ash as they do not trap particles in the same manner as DPFs, and that the weight proportion of ash in non-DPF catalysts is much smaller than in the DPF catalysts. Zinc in DPFs The DPFs may potentially exhibit a characteristic of hazardous waste if the quantity of ash present in the DPF is large enough to impart a characteristic to the entire DPF. Based on the information you provided, a typical weight for a DPF is 21 kilograms and the quantity of ash within the DPF is typically 500 grams to 1,000 grams (0.5 to 1 kilogram); we understand that 44 Energy Tech has determined that it is extremely unlikely that the proportion of ash in a DPF would exceed the upper bound reflected by these weights. The concentration of zinc in the four samples tested ranged from 29,000 mg/kg to 70,000 mg/kg. Based on these results, the range of zinc concentrations in the DPF would be as follows: Minimum zinc in DPF = 29,000 mg/kg x 0.5 kg = (21 kg + 0.5 kg) 674 mg/kg Maximum zinc in DPF = 70,000 mg/kg x 1 kg = (21 kg + 1 kg) = 3,182 mg/kg 0