Respiratory Protection: NIOSH-approved respirator for organic vapor and mist to control exposure where
ventilation is inadequate.

Ventilation: General and local exhaust.

Personal Protective Equipment: Protective Gloves: Impervious gloves (Viton, PVOH, etc.) Eye Protection: Safety
glasses with sideshields or chemical goggles. Other Protective Clothing or Equipment: If splashing is anticipated,
wear rubber apron and boots or other protective equipment to minimize contact.

| SECTION 9: REACTIVITY HAZARD DATA

Stability: Stable

Incompatibility: Strong acids, oxidizing agents.

Hazardous Decomposition Products: Carbon monoxide, carbon dioxide. oxides of sulfur, miscellaneous
hydrocarbons.

Hazardous Polymerization: Will not occur.

| SECTION 10: PHYSICAL AND CHEMICAL PROPERTIES

Color: Tan
Appearance: Viscous Liquid
Odor: Oil

Boiling Point (initial): NA
Evaporation Rate (n-Butyl Acetate=1): » A hypothetical “4'" type” of vehicle kit that contains more of each CRC than the kits actually
being used for the CRC campaigns: 0.792 gallons (3 liters) of Noxudol 300 S and 0.792
gallons (3 liters) of 712AM.

» Aone hour vehicle processing time instead of the 2 hour vehicle processing time that TMS
has advised its dealers to adhere to for all vehicles across the CRC campaigns.

» Acontinuous operation in a CRC campaign spray space, 24 hours per day, seven days per
week,

Page 4 of §
Under these assumptions, a dealer could process 8,760 vehicles in any one year using a single
spray space.

Actual emissions at any dealership will not come anywhere close to this worst-case operating
scenario because dealers are using less CRCs, taking longer to process vehicles and do not
engage in 24/7 CRC campaign processing. Nor does this scenario account for state and/or
local regulatory limits or permit conditions that prevent dealerships from operating at the
maximum scenario. Thus, the emissions calculations summarized below based on this scenario
are truly “worst-case”.

1, Maximum Operating Scenario — VOC Emissions

The processing of vehicles with this kit (assuming all VOCs contained in the CRCs are emitted
to the ambient air) will result in VOC emissions of 0.2 pounds per vehicle (0.792 gals/Noxudol
300 S per kit x 0.09 lbs/VOCs per gal + 0.792 gals/712AM per kit « 0.165 Ibs VOCs/gal = 0.2
lbs VOCs/vehicle).

The maximum CRC processing rate, under which one vehicle would be treated per hour over a
24-hour day, would yield no more than 4.8 Ibs VOCs per day (0.2 Ibs VOCs/vehicle x 24
vehicles/day = 4.8 Ibs VOCs/day) or, in the unlikely event a second spray space is used, 9.6 Ibs
VOCs/day.

Over an annual period, under the maximum annual CRC scenario, a dealer would emit no more
than 0.88 tons of VOCs in any one year (8,760 vehicles/year x 0.2 Ibs VOCs/vehicle, divided by
2,000 Ibs/ton = 0.88 tons VOCs/year) or, if a second spray space is used, 1.76 tons VOCs/year.

2, Maximum Operating Scenario — PM Emissions

Step One: Noxudol has 0.94 pounds of solids per kit potentially available for emission to the
ambient air as PM (0.792 gals/kit x 7.97 lbs/gal x 98.9% solids by weight x (100% - 85%
transfer efficiency) = 0.94 Ibs PM/vehicle); 712AM has 0.09 pounds per kit potentially available
(0.792 gals/kit x 7.885 Ibs/gallon x 97.9% solids by weight « (100% - 98.5% transfer efficiency)
= 0.09 lbs PM/vehicie).

Step Two: Therefore, the hypothetical “4"” kit has 1.03 pounds of solids potentially available
for emission to the ambient air as PM. Applying the 90% fallout factor for Noxudol 300 S and
the 75% fallout factor for 712AM indicates that actual PM emissions would be no more than
0.12 pounds per vehicle (0.94 x 10% + 0.09 x 25% = 0.12 Ibs PM/vehicle).

The maximum CRC processing rate, under which one vehicle would be treated per hour over a
24-hour day, would yield no more than 2.88 Ibs PM per day (0.12 Ibs/vehicle x 24 vehicles/day =
2.88 lbs PM/day) or, if a second spray space is used, 5.76 lbs PM/day.

Over an annual period, under the maximum annual CRC operating scenario, a dealer would

emit no more than 0.53 tons of PM in one year (8,760 vehicles/year x 0.12 Ibs/vehicle, divided
by 2,000 Ibs/ton = 0.53 tons PM/year) or, if two spray spaces are used, 1.06 tons PM/year.

Page § of §
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MassDEP Commonwealth of Massachusetts

erp

Executive Office of Energy & Environmental! Affairs

~ Department of Environmental! Protection
One Winter Street Boston, MA 02108 +61 7-292-5500

LATHER HIDARIG & Bur MAND

Sarr analy

MALIAY FS RA EAY SENN aa 6 IMMEL 1

eclenant Severna

Comurnianianer

August 28, 2012

Ms. Ruth H. Silman
Nixon Peabody LLP
100 Summer Street
Boston. MA 02110-2131

RE: Toyota Motor Sales — Sequoia and Tundra Anti-Corrosion Campaign - Motor Vehicle
Maintenance Exemption

Dear Ms. Silman

The Massachusetts Department of Environmental Protection (MassDEP), Bureau of Waste
Prevention, Planning and Evaluation Division acknowledges the information you provided
MassDEP by letter dated J uly 26, 2012. on the subject of a corrosion-resistant compound (CRC)
campaign proposed for certain Toyota Tundra and Sequoia trucks in Massachusetts.

Toyota provided MassDEP a detailed description of the Tundra and Sequoia campaign coating
Procedure to be used by authorized dealerships and estimates of resulting emissions. The
process includes high-solids, low volatile organic compound (VOC) coatings, a high efficiency
spray application method and no solvent used for surface preparation or Spray gun cleaning.
Similar service campaigns were approved for Toyota Tacoma and Tundra trucks in letters dated
July 21, 2009 and August 12, 2011. respectively.

Based on the information you provided, Toyota maintains that the CRC campaign process of
coating truck frames to protect against corrosion should be considered motor vehicle
maintenance, and therefore, exempt from plan approval requirements under 310 CMR 7.02.

Review of the submitted documentation demonstrates that the CRC campaign is eligible for an
exemption under 310 CMR 7.02(2)(b)20.

Toyota may proceed with the CRC campaigns for Tundra (model years 2004-2008) and Sequoia
(model years 2001-2008) as described in submitted documents with ? conditions:

THs information is availatle in elternate format. Catl Michelte Waters-Ekanem, Diversity Director, at 617-292-6751. TODA 1.866-539 7622 or 1-617-874-6668

MassDEP Wehsite www mass gov dep
Printed on Recycled Paper
1. Authorized dealerships must keep records and documentation pursuant to 310 CMR
7.20(2)(d). Each authorized dealership must keep the following records/documents:
- Number of coating kits used.
- MSDS for NOX-Rust 712AM and Noxudol 300S.
+~SCAQMD approval letter for the Vaupel HSDR 3300 Spray Gun, dated 3/22/2011.
- Description of CRC campaign procedure.
- Acopy of this MassDEP letter.

he

If the CRC campaign is significantly modified, Toyota must notify MassDEP beforehand.
Significant modifications include, but are not limited to: changes in the coatings, spray
equipment, or solvent usc.

This determination only applies for the CRC campaign as proposed. Any additional similar
proposals will be reviewed on a case-by-case basis.

If you have any questions concerning this letter, please contact Mare Wolman at (617) 292-5515.

Very truly yours,

Mh 4 Mor ee f _

Glenn Keith, Deputy Director
Planning and Evaluation Division
Bureau of Waste Prevention

cc: BWP, Regional C/E Chiefs
BWP, Regional Permit Chiefs
eas Commonwealth of Massachusetts
Executive Office of Energy & Environmental Affairs

Department of Environmental Protection

One Winter Street Boston, MA 02108 « 617-292-5500

DEVAL L PATRICK RICHAAD K SULLIVAN JR

Governor Secratary

TIMOTHY P OMURRAY KENNETH L. XIMMELL

Gautenant Governor Commntururna:

August 12, 2011

Ms. Ruth H. Silman
Nixon Peabody LLP
100 Summer Street
Boston, MA 02110-2131

RE: Toyota Motor Sales — Tundra Anti-Corrosion Campaign — Motor Vehicle Maintenance and
Repair Exemption

Dear Ms. Silman:

The Massachusetts Department of Environmental Protection (MassDEP), Bureau of Waste
Prevention, Business Compliance Division acknowledges the information you provided
MassDEP by letter dated August 1, 2011, on the subject of an Anti-Corrosion Campaign
proposed for certain Toyota Tundra trucks (Tundra BOD) in Massachusetts. :

Toyota provided MassDEP a detailed description of the Tundra BOD coating procedure to be
used by authorized dealerships and estimates of resulting emissions. The process includes high-
solids, low VOC coatings, a high efficiency spray application method and no solvent used for
surface preparation or spray gun cleaning. A similar service campaign was approved for Toyota
Tacoma trucks by MassDEP in a letter dated July 21, 2009.

Based on the information you provided, Toyota maintains that the Tundra BOD process of
coating truck frames to protect against corrosion should be considered motor vehicle
maintenance, and therefore, exempt from plan approval requirements under 310 CMR 7.02.

Review of the submitted documentation demonstrates that the Tundra BOD is eligible for an
exemption under 310 CMR 7.02(2)}(b)20.

Toyota may proceed with the Tundra BOD as described in submitted documents with two
conditions:

This Information Is available In alternate format. Call Michelle Waters-Ekanem, Diversity Dlrector, al 647-292-5751. TOD# 1-866-539-7622 or 1-617-574-6868
MassDEP Websile vaav.maes govidep

Panled on Recycled Paper
1. Authorized dealerships must keep records and documentation pursuant to 310 CMR
7.02(2)(d). Each authorized dealership must keep the following records/documents:
- Number of coating kits used.
- MSDS for NOX-Rust 712AM and Noxudol 300 8S,
- SCAQMD approval letter for the Vaupel HSDR 3300 Spray Gun, dated 3/22/2011.
- Description of Tundra BOD procedure.
- A copy of this MassDEP letter.

2. If the Tundra BOD is significantly modified, Toyota must notify MassDEP beforehand
and MassDEP will notify Toyota if this determination is still valid. Significant
modifications include, but are not limited to, changes in coatings, spray equipment,
solvent use or establishment of a second service bay at a dealership.

This determination only applies for the Tundra BOD as proposed. Any additional similar
proposals will be reviewed on a case-by-case basis.

If you have any questions concerning this letter, please contact Mare Wolman at (617) 292-5515.

Very truly yours,

foe Ld

Steven A. DeGabriele, Director
Business Compliance Division
Bureau of Waste Prevention

cc: BWP, Regional C/E Chiefs
BWP, Regional Permit Chiefs
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS

DEPARTMENT OF ENVIRONMENTAL PROTECTION
ONE WINTER STREET, BOSTON, MA 02108 617-292-5500

DEVAL L. PATRICK IAN A. BOWLES

Governor Secretary

TIMOTHY P. MURRAY LAURIE BURT

Lieutenant Governor Commissioner
July 21, 2009

Ms. Ruth H. Silman
Nixon Peabody LLP

100 Summer Street
Boston, MA 02110-2131

RE: Toyota Motor Sales - Limited Service Campaign for Tacoma Trucks

Dear Ms. Silman

The Massachusetts Department of Environmental Protection (MassDEP), Bureau of Waste
Prevention, Business Compliance Division acknowledges the information you provided
MassDEP at the meeting on April 23, 2009 and by letters dated April, 2009 and May 21, 2009,
on the subject of a Limited Service Campaign (LSC) proposed for certain Toyota Tacoma trucks
in Massachusetts.

During the meeting and in the subsequent communications, Toyota provided MassDEP a detailed
description of the LSC coating procedure to be used by authorized dealerships and estimates of
resulting emissions. The process includes high-solids, low VOC coatings, a high efficiency spray
application method and no solvent used for surface preparation or spray gun cleaning.

Based on the information you provided, Toyota maintains that the LSC process of coating truck
frames to protect against corrosion should be considered motor vehicle maintenance, and
therefore, exempt from plan approval requirements under 310 CMR 7,02.

Review of the submitted documentation demonstrates that the LSC is eligible for an exemption
under 310 CMR 7.02(2\b)20.

This information is available in alternate format. Call Donald M. Gomes, ADA Coordinater at 617-556-1057, TDD# 1-866-539-7622 or 1-617-574-6868,

MassDEP on the World Wide Web: hitp:/Avwww.mass.gov/dep
€ Printed on Recycled Paper
Toyota may proceed with the LSC as described in submitted documents with 2 conditions:

1.

Authorized dealerships must keep records and documentation pursuant to 310 CMR
7,.20(2)(d). Each authorized dealership must keep the following records/documents:
- Number of coating kits used.

- MSDS for NOX-Rust 712AM and NOX-Rust X128T.

- SCAQMD approval letter for the Vaupel HSDR 3300 Spray Gun, dated 3/10/2009.
- Description of LSC procedure.

- A copy of this MassDEP letter.

If the LSC is significantly modified, Toyota must notify MassDEP beforehand and
MassDEP will notify Toyota if this determination is still valid. Significant modifications
include, but are not limited to, changes in coatings, spray equipment, or solvent use; or
extension of the LSC beyond October 31, 2010.

This determination only applies for the LSC as proposed. Any additional similar proposals will
be reviewed on a case-by-case basis.

If you have any questions concerning this letter, please contact Marc Wolman at (617) 292-5515.

Very truly yours,

‘4

tue lf Daxzhn

AL

Steven A. DeGabriele, Director
Business Compliance Division
Bureau of Waste Prevention

cc: BWP, Regional C/E Chiefs
BWP, Regional Permit Chiefs

CORROSION-RESISTANT COMPOUND CAMPAIGNS
DEALER INFORMATION PACKET

PART TWO — STATE COMPLIANCE SUPPLEMENT FOR

MASSACHUSETTS

APPENDIX C SUMMARY OF FEDERAL, STATE AND LOCAL
REGULATIONS RELATED TO AIR EMISSIONS FOR MASSACHUSETTS

I. INTRODUCTION

The Corrosion Resistant Compound (“CRC”) campaigns for various models and model years of
Toyota vehicles result in emissions of Volatile Organic Compounds (“VOCs”) and Particulate
Matter ("PM"). Although Toyota Motor Sales, U.S.A., Inc. (‘TMS’) has designed the CRC
campaigns to minimize such emissions, the campaigns nevertheless are subject to various
federal, state and local regulations related to air emissions.

To assist you in making compliance decisions for your dealership, TMS has prepared this
summary of federal, state and local regulations related to air emissions in Massachusetts.

Wl. AIR PERMITTING

Both federal and Massachusetts regulations require an air permit for “major” and “minor” VOC.
and PM emissions as described below:

= Major Source. Any source with a potential to emit (‘PTE")° at or above 100 tons per year
(‘tpy”) for PM and 50 tpy for VOCs.*

= Minor Source. Any source that (a) does not constitute a major source and (b) has a PTE of
1 tpy, calculated over any consecutive 12-month period, or greater.°

? “Potential to emit" or “PTE” refers to the maximum capacity of a stationary source to emit air pollutants. The PTE
calculation generally requires conservative assumptions, and a source's actual emissions are usually well below its
PTE.

“340 CMR 7.00: Appendix A(2).
* 310 CMR 7.02(4)(a); 310 CMR 7.02(2)(b)(7).

85
TMS has calculated the PTE as well as the expected actual emissions for each prior and
ongoing CRC campaign. The PTE for each CRC campaign is just a small fraction of the major
source thresholds and also is well below the 1 tpy minor source threshold.

The Massachusetts Department of Environmental Protection (“MassDEP”) has confirmed that
the CRC campaigns launched to date all qualify as “motor vehicle maintenance and repair’
activities exempt from air permitting requirements® as long as your dealership maintains certain
records and documents on file. (See Section V for a summary of these recordkeeping
requirements.) MassDEP is requiring TMS te provide information about any potential new CRC
campaign and to obtain a written confirmation of exemption before launching the campaign.
TMS will provide you with this confirmation of exemption prior to launch of any potential future
CRC campaign.

Although the CRC campaigns are exempt from air permitting, you should bear in mind that the
thresholds for air permitting must be applied across your entire dealership and not just to the
CRC campaigns. For example, if your dealership's physical plant is distributed across multiple
buildings, land parcels or physical locations, then the emissions from your activities at each of
those buildings and locations would have to be combined to determine whether your
dealership's total emissions fall below air permitting levels. In some cases, even emissions
from offsite locations that are not physically adjacent to a dealership (such as an offsite body
shop) must be combined with the dealership’s PTE to make this air permitting determination.

Therefore, operations besides the CRC campaigns could cause your dealership to trigger air
permitting. It is not expected, however, that you would do so as long as your dealership:

1. Does not operate a very large onsite or an offsite body shop;’ or

2. Does not otherwise engage in significant usage of coatings, paints, solvents and
other VOC containing materials.

ll. AUTOMOTIVE REFINISHING OPERATIONS

Under Massachusetts law, “automotive refinishing operations” must comply with certain air
permitting and spray coating requirements.° MassDEP has determined that the CRC programs
do not constitute “automotive refinishing’ under Massachusetts law, and therefore the air
permitting and spray coating requirements do not apply to the CRC campaigns. However, at
MassDEP's request, TMS provided a formal submission to demonstrate that the spray guns
used in the CRC campaigns achieve a high degree of emission control. MassDEP has directed
dealers to keep on file a copy of the March 22, 2011, South Coast Air Quality Management
District's (“SCAQMD") determination that the Vaupel HSDR 3300 spray gun used in the CRC

* 310 CMR 7.02(2)(b)(20).

" A body shop or other operations that involve the use of spraying equipment will have a higher PTE than a regular
vehicle service area. Thus, you cannot be certain — without further analysis — that your dealership will remain exempt
from air permitting if it conducts such operations in addition to the CRC campaigns. In particular, if your dealership
has an onsile body shop, then the state will require you to combine the PTE from that onsite body shop with the PTE
from all other activities at the dealership. In doing so, it may not be possible for your dealership to conduct the CRC
campaigns (which would add to the air emissions already coming from your body shop) and remain exempt from air
permitting. Moreover, the state might require you to combine the PTE from an offsite body shop — even if the body
shop is not where you will conduct the CRC campaigns — if that body shop has a sufficient interconnection to the rest
of the activities at your dealership.

§ 310 CMR 7.18(28)(g)(1).

86
campaigns is equivalent to High Volume Low Pressure (“HVLP") application equipment, which
was provided as part of this submission.*®

IV. VEHICLE PROCESSING LIMITS

For each CRC campaign, TMS has calculated the hourly PM emissions to support your
dealership’s exemption from air permitting and compliance with other air regulatory
requirements. This calculation incorporates assumptions regarding how long it will take you to
Process a vehicle in accordance with the Technical Instructions. If you were to process a
vehicle in a shorter amount of time, then your actual hourly PM emissions could be inconsistent
with the emissions calculations developed by TMS. To assure consistency with the
calculations presented by TMS to MassDEP, your dealership should not process more
than one Toyota vehicle every two hours. The Part One — General Guide for Compliance
discusses the vehicle processing limit and provides guidance in its Appendix A on how to follow
the limit. Appendix B of the Part Two — State Compliance Supplement for Massachusetts
includes a “CRC Campaign Vehicle Production Log” that your dealership should use to
document its adherence to the limit.

V. RECORDKEEPING

Your dealership should maintain records to demonstrate your adherence to the vehicle
processing limits discussed in Section IV above. Your dealership should also record the total
number of CRC coating kits used in each campaign. Please refer to Appendix B to the Part
Two — State Compliance Supplement for Massachusetts for logs that you can use and for
copies of documents to retain on file.

It is important that your dealership maintain records for an appropriate period of time.
Massachusetts regulations require that you retain the documents and all completed logs
outlined in Appendix B to the Part Two — State Compliance Supplement for Massachusetts for 3
years. While your dealership can make its own compliance decisions, TMS recommends that
you retain those records until 5 years after your dealership ceases its involvement in
CRC campaigns.

®* This March 22, 2011, letter is available at the C.L-E.A.N. Dealer website (htto://cleandealer.com).

87
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