LOTSONOX, INC.

Weaser County, Colorado

CONFIDENTIAL

Scope of Work
for Air Quality Services, Inc.

In response to EPA's proposed change to the national ambient air quality standards (NAAQS) for ozone -- changing the 8-hour average for 0₃ from 0.12 ppm to 0.08 ppm -- LOTSONOX plans to draft a comment to be submitted to the EPA during the public comment period on the proposed rule.

Based upon an inflation-adjusted estimate of the expense of bringing the plant into compliance in 1979, when the .12 ppm standard came into effect, we feel that if a similar cost must be incurred, the economic viability of LOTSONOX could be completely compromised, resulting in the shutdown of the Weaser Plant, the loss of 600 actual jobs in Weaser County, and the loss of upwards of 2000 jobs that indirectly depend upon them.

This would devastate the local economy and could threaten the long-term solvency of LOTSONOX's parent company, MAMMOTH ENTERPRISES INTERNATIONAL. MAMMOTH, an employer of more than 20,000 people in 9 countries, depends upon our Weaser plant to provide essential raw materials for every one of its domestic and international factories at a price significantly below that of competing vendors.

In light of these circumstances, LOTSONOX proposes the following scope of work for Air Quality Services:

1. AQS shall assess the current emissions of the Weaser plant and identify the quantity and relative abundance of ozone producing gasses.

2. Based upon LOTSONOX estimates of cost per percent reduction in each ozone-producing gas, AQS will use a computational model to determine the most cost effective way to reduce the amount of ozone precursors the Weaser plant produces to levels that would result in ozone levels at or below 0.08 ppm.

3. If the cost of compliance exceeds LOTSONOX estimates of the maximum cost the plant can absorb and still retain economic viability, AQS will use a model to determine how close LOTSONOX can come to the proposed NAAQS while maintaining economic viability.

4. AQS will draft a memo to the President and CEO of LOTSONOX explaining the process used and variables considered in reaching any final conclusions regarding possible emissions reductions. The purpose of this memo is to demonstrate that AQS has, in fact, exhausted the reasonable scientific approaches that could be applied to find the most cost effective solution. The CEO holds a scientific Ph.D. and will expect to see hard data proving the results, especially if the modeling indicates that compliance is not economically feasible.

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Copyright © 1997