Kit (Part) #00289-TGOKT-DS | Kit (Part) #00289-SOOKT-DS | Kit (Part) #00289-T01KT-DS
(3 liters Noxudol, | (3 liters Noxudol, | (2 liters Noxudol,
1 liter 712AM) 2 liters 712AM) No 712AM)
0.792 gal (3 liters)/kit 0.792 gal (3 liters)/kit 0.528 gal (2 liters)/kit
x 7.97 lbs/gal x 7.97 lbs/gal x 7.97 Ibs/gal
x 98.9% solids by weight x 98.9% solids by weight x 98.9% solids by weight
Noxudol x 15% (100% - 85%] x 15% (100% - 85%] x 15% (100% - 85%
transfer efficiency) transfer efficiency) transfer efficiency)
= 0.94 Ibs PMivehicle = 0.94 Ibs PM/vehicle = 0.62 lbs PMivehicle
0.264 gal (1 liter)/kit 0.528 gal (2 liters}/kit
x 7.885 Ibs/gal x 7.885 Ibs/gal
x 97.9% solids by weight x 97.9% solids by weight
TIZAM x 1.5% (100% - 985%] x 1.5% (100% - 985%] None
transfer efficiency) transfer efficiency)
= 0.03 Ibs PM/vehicle = 0.06 Ibs PMivehicle
Combined PM = 0.97 Ibs PMivehicle = 1.0 Ibs PMivehicle = 0.62 Ibs PMivehicle
emissions: (solids available for emission | (solids available for emission | (solids available for emission
to ambient air as PM) to ambient air as PM) to ambient air as PM}

MAXIMUM POTENTIAL EMISSIONS

TMS also has calculated maximum potential emissions resulting from the CRC campaigns
based on a conservative, worst-case operating scenario. This scenario reflects the following
assumptions:

> 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 fiters) of Noxudol 300 S and 0.792
gallons (3 liters) of 712AM.

A three-hour vehicle processing time, including 2 hours for application of 3 liters of Noxudol
300 s and one hour for application of 3 liters of 712AM.

y

A continuous operation in one or two CRC campaign spray spaces, 24 hours per day, seven
days per week.

W

* The 98.5% value is the lowest transfer efficiency calculated for all of vehicles subject to CRC campaigns to date.
TMS does not anticipate that the transfer efficiency will vary substantially for vehicle models that may be subject to a
subsequent CRC campaign or that the impact on the PM emission factors will be significant. More specific
information on the transfer efficiency value applicable to any future CRC campaigns will be available at that time

Page 3 of 5
Under these assumptions, a dealer could process 2920 vehicles in one year in each spray
space, or 5,840 vehicles per year if both spray spaces are used.

Actual emissions at any dealership will not come anywhere close to this worst-case operating
scenario because dealers are using less CRCs for each vehicle and do not engage in 24/7 CRC
campaign processing. Thus, the emissions calculations summarized below based on this
scenario are truly “worst-case”.

1. Maximum Operating Scenario - VOC Emissions

Per Vehicle 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/kit x 0.09 lbs VOCs/gal + 0.792 gals 712AM/kit « 0.165 Ibs
VOCs/gal = 0.2 lbs VOCs/vehicle).

Hourly Emissions: Since 712 AM has a higher VOC content than Noxudol 300 S, maximum
VOC emissions will occur during the application of 712 AM. Three liters of 712AM applied over
one hour, will result in emissions of 0.131 lbs VOCs/hour in each spray space (0.792 gals
712AM/kit x 0.165 Ibs VOCs/gal = 0.131 Ibs VOCs).

Daily Emissions: The maximum CRC processing rate, under which one vehicle would be
processed in each spray space every 3 hours over a 24-hour day, would yield no more than 4.8
pounds of VOCs per day (0.2 Ibs VOCs/vehicle x 8 vehicles/day = 1.6 Ibs VOCs/day) or, in the
event a second spray space is used, 3.2 pounds of VOCs per day.

Annual Emissions: Over an annual period, under the maximum annual CRC scenario, a dealer
would emit no more than 0.29 tons of VOCs in any one year (2,920 vehicles/year x 0.2 Ibs
VOCsivehicle, divided by 2,000 Ibs/ton = 0.29 tons VOCs/year) or, if a second spray space is
used, 0.58 tons of VOCs per year.’

2. Maximum Operating Scenario — PM Emissions

Per Vehicle Emissions: Noxudol 300 S has 0.94 pounds of solids per kit potentially available for
emission to the ambient air as PM (0.792 gals Noxudol/kit x 7.97 Ibs/gal x 98.9% solids by
weight x (100% - 85% transfer efficiency) = 0.94 Ibs PM/vehicle); 712AM has 0.09 pounds of
solids per kit potentially available for emission as PM (0.792 gals 712AM/kit * 7.885 Ibs/gallon x
97.9% solids by weight x (100% - 98.5% transfer efficiency) = 0.09 Ibs PM/vehicle). Therefore,
the processing of vehicles with this hypothetical "4" kit could result in emissions of no more
than 1,03 pounds of PM per vehicle.

Hourly Emissions: Since Noxudol 300 S has a much higher solids content and a lower transfer
efficiency, maximum PM emissions will occur during apptication of Noxudol 300 S to the
external frame surfaces. Three liters of Noxudol 300 S applied to a vehicle over a two-hour
period will result in PM emissions of 0.47 Ibs PM per hour (0.94 Ibs PM/vehicle + 2 hours = 0.47
ibs PM/hour).

* The annual VOC emission limit in the NJDEP-issued Minor Source Permits for the CRC Campaigns is substantially
higher (3.34 tons per year) because it included emissions from the Tacoma LSC 90D campaign which used a
different CRC (X128T) for the internal frame surfaces.

Page 4 of 5
Daily Emissions: The maximum CRC processing rate, under which one vehicle would be
treated every three hours over a 24-hour day in a single spray space, would yield no more than
8.24 pounds of PM emissions per day (1.03 Ibs PM/vehicle x 8 vehicles/day = 8.24 ibs PM/day)
or, if a second spray space is used, 16.5 pounds of PM per day.

Annual Emissions: Over an annual period, under the maximum annual CRC operating scenario,
a dealer would emit no more than 1.5 tons of PM per year from each spray space (2,920
vehicles/year x 1.03 Ibs PM/vehicle, divided by 2,000 Ibs/ton = 1.5 tons PM/year) or, if two spray
spaces are used, 3.0 tons of PM per year.®

* The annual PM emission limit in the NJDEP-issued Minor Source Permits for the CRC Campaigns is substantially
higher (4.12 tons per year, or 2.06 tons per spray space) because it conservatively assumed that the spray space
would centinuously operate at the highest possible PM hourly emission rate, which occurs only when applying
Noxudal 300 S. The calculation presented here assumes that, for one-third of the year, the spray space would be
used for application of 712AM, which has a much lower emission rate.

Page Sof 5
(This page intentionally left blank.)

State of Net Jersey

CHRIS CHRISTIE DEPARTMENT of ENVIRONMENTAL PROTECTION BOB MARTIN
Governar Division of Air Quality Acting Commissioner
Bureau of Air Permits
MAILCODE: 401-02
KIM GUADAGNO 401 E. State Street, 2™ floor, P.O. Box 420
it. Governor Trenton, NJ 08625-0420

August 31, 2011
Mr, Steven J. Picco
Saul Ewing LLP.
750 College Road East, Suite 100
Princeton, NJ 08540-6617

Re: Toyota Motor Sales — Extended Limited Service Campaign
Dear Mr. Picco:

This letter will confirm the NJ Department of Environmental Protection (Department) decision
regarding your request to use alternative coating application equipment at several New Jersey
Toyota dealerships in conjunction with the Extended Limited Service Campaign. The
Department has determined that the proposed use of the Vaupel HSDR-3300 spray gun meets the
requirements for equivalent coatings transfer efficiency as described in 7:27-16.12 (f) (10)
{Subchapter 16].

In addition, the Department has received written confirmation from the U.S. Environmental
Protection Agency- Region 2 (USEPA) in a letter dated August 17, 2011, indicating their similar
determination of equivalent coatings transfer efficiency in accordance with Subchapter 16
requirements. This determination was based on their review of the materials on the Vaupel
HSDR-3300 spray gun and particularly, the approval letter from the South Coast Air Quality
Management District dated March 22, 2011 for the application of two corrosion coating; Auson
AB Noxudol 300 § and the Parker 712am.

Therefore, both the Department and USEPA have confirmed that the proposed use of the Vaupel
HSDR-3300 spray gun meets the requirements for equivalent coatings transfer efficiency as
described in Subchapter 16 for this particular case.

Should you have any questions regarding the above confirmation, please contact me at (609)
984-7940.

at

Sincerely, fr
=

f

John Preczewski, P.E.
Asspight Director
Attachment

Ce: Toby Hanna
DSHW Aug 26 2011 10:17 P. 02

seo By
- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
z 8 REGION 2
é WZ g 280 BROADWAY !
Bee ee NEWYORK, NY 10007-1866

< oA era . i

ee oe, | sl

_ Division of Air Quality ©

AUG 17 20%f1

Mr, Jobn Preczewski .
Assistant Director, Air Quality Pennitting

New Jersey Department of Environmental Protection
P.O. Box.420

401 East State Street

Trenton, New Jersey 08625-0420 _

Re: Toyota Motor Sales — August 4, 2011 Equivalency Determination

Dear: Mr. John Preezewski:

This is to provide EPA’s determination regarding the alterative ene application
equipment for use at New Jersey Toyota dealerships in conjunction: with the August 4,
2011 Equivalency Determination. You forwarded Toyota’s request in an E-mail dated
August 4, 2011 which plans on applying new corrosion resistant compounds using the
Vaupel HSDR 3300 spray guns. Subchapter 16:(7:27-16.12(f)(10)) provides forthe use

of equivalent’ or better transfer equipment. Specifically, section (f) 10 states.

emissions resulting from this application method do not exceed the emissions that would
result from either HVLP or electrostatic spray application method; and” requires both
New Jersey Department of Environmental Protection (NJDEP) and EPA approval.

Region 2 has reviewed the transfer efficiency and emissions information on the Vaupel
HSDR 3300 spray gun and ‘particularly the South Coast Air Quality: Management District
(SCAQMD) approval letter of March 22, 2011 for a similar campaign. The SCAQMD

has determined that the spray guns were capable of achieving equivalent or better transfer
efficiency than high-volume, low pressure (HVLP) equipment with the conditions
identified in the March 22, 2011 letter. This evaluation was based on the application of

itis two coatings AusorAD-Noxadol300-S protective-coating andthe Parker 712. AM... -

protective coating.

Similar conditions that were . imposed i in the SCAQMD approval letter of March 22, 2011,
should also be considered by New Jersey for the spray guns with odifications
appropriate to New Jersey regulations and conditions. Approval o of the use of such
equipment in New Jersey is, of course, up to the NJIDEP.

In summary, EPA Region 2, based on the documentation provided, would support a
determination by. NJDEP that the Vaupél HSDR 3300 spray guns applying the two.
specific Coatings achieves a transfer efficiency equal to.or batter than FVLP. gui

7 > my

el

Intemet Address (URL) « httpyAvww.epa.gov
Recycled/Recyclable «Printed with Vegetable Oll Based Inks on Recycled Paper (Minimum 60% Pestconsumer conieiny

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—
DSHW Aug 26 2011 10:18 P.O3

and would therefore satisfy the provisions of Subchapter 16. 12(6)( ] 6 and the New Jersey ©
State Implementation Plan (SIP) for the use of the spray guns in this instance, The final

decision is up to the NJDEP. If you have any questions, please do not hesitate to contact
me at (212) 637-4014.

Sincerely,

) fi of
Richard Ruvo, Chief

State Implementation Section . .
Air Programs Branch iis I

i

cc: Frank Steitz, New Jersey Department of Environmental Protection

CORROSION-RESISTANT COMPOUND CAMPAIGNS
DEALER INFORMATION PACKET

PART TWO — STATE COMPLIANCE SUPPLEMENT FOR NEW JERSEY

APPENDIX C —- SUMMARY OF FEDERAL, STATE AND LOCAL
REGULATIONS RELATED TO AIR EMISSIONS FOR NEW JERSEY

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 New Jersey as of March 2013.

HI. AIR PERMITTING

Both federal and New Jersey reguiations require an air permit for “major” and “minor” sources of
VOC and PM emissions as described below.

A. Major Source

A major source is any source which emits or has the potential to emit (PTE)® at or above 100
tons per year (tpy) for PM and 25 tpy for VOCs.’ TMS has calculated the PTE for each prior
and ongoing CRC campaign.*° The PTE is just a small fraction of these major source
thresholds. Thus, the CRC campaigns will not, standing alone, cause your dealership to trigger
air permitting as a major source.

However, the major source air permitting thresholds 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 PTE from
your activities at each of those buildings and locations would have to be combined to determine
whether your dealership’s total PTE falls below the thresholds. In some cases, even PTE from
offsite locations that are not physically adjacent to a dealership (such as an offsite body shop)
must be combined with the dealership’s emissions to make this air permitting determination.

® “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.

? NJAC. § 7: 27-22.2(a)(2).

® For details on this calculation, see the CRC Campaigns Air Emissions Calculation Summary in Appendix B of this
Part Two — State Compliance Supplement for New Jersey.

81
Therefore, operations besides the CRC campaigns could cause your dealership to qualify as a
major source. It is not expected, however, that your dealership would do so as long as you
satisfy the two criteria below:

1. Your dealership does not operate a very large on-site or an off-site
body shop;’ and

2. Your dealership does not otherwise engage in significant painting,
coating or other spraying operations.

B. Minor Source

A minor source is any source that (a) does not constitute a major source and (ib) conducts an
operation that qualifies as a “significant source.”"" The CRC campaigns are a surface coating
operation. Any surface coating operation will qualify as a “significant source” if “the quantity of
coating or cleaning material used in any one hour is equal to or greater than one half-gallon of
liquid.”"' The CRC campaigns exceed this threshold, and thus, require a “Permit to Construct,
Install or Alter Control Apparatus or Equipment” (Preconstruction Permit) and a “Certificate to
Operate Control Apparatus or Equipment” (Operating Certificate) from the New Jersey
Department of Environmental Protection (NJDEP).

TMS worked with each dealership in New Jersey to obtain a Preconstruction Permit and an
Operating Certificate for the CRC campaigns, which were issued together as a single permit
(referred to hereinafter as the “CRC Campaigns Air Permit”).'*_ This CRC Campaigns Air Permit
was issued for most dealerships in September of 2011" and authorized the remainder of
Tacoma LSC 90D and Tundra BOD as well as all potential future CRC campaigns."

* 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 onsite 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.

NJAC. § 7: 27-8.2(c).

" NLLA.C. § 7: 27-8.2(c)(12). None of the exemptions from the definition of “significant sources” apply to the CRC
Campaigns. N.J.A.C. §§ 7: 27-8.2(d) — (f).

2 NLA. §§ 7: 27-8.3(a) & (b).

°° A few dealerships worked with TMS to have their CRC Campaigns Air Permit amended or reissued after it was
issued in September of 2011 due to a change in their location or facility configuration; these dealerships should make
sure to have a copy of the amended Permit on file.

The first page of the CRC Campaign Air Permit issued to your dealership lists an expiration date, which is five
years from the date of effectiveness. You will need to cease all CRC campaign operations as of that expiration date
unless the Permit is renewed by NJDEP.

82
Each dealer must comply with the following applicable requirements” identified in the CRC
Campaigns Air Permit under the “operating scenario” entitled “OS2 Application of Anti-Corrosion
Sealant Materials To Toyota Vehicle Frame Rails”:

t. Limit emissions of VOCs from the CRC campaigns to 0.131 !b/hr and of PM to
0.47 Ib/hr;

2. Apply only CRC materials (referred to in the permit as “anti-corrosion sealant
materials") with a VOC content less than or equal to 4.6 Ibs/gal;

3. Use only the Vaupel HSDR 3300 spray guns to apply CRC materials; and

4, Do not. process more than 2920 vehicles over any consecutive 12-month
period.

Your dealership can satisfy these applicable requirements by adhering both to the Technical
Instructions and to the following vehicle processing and CRC materials usage limits:

1. All Dealerships (except for dealerships located in Toms River, NJ)

a. Process no more than one vehicle every 2.5 hours:

b. Apply no more than three liters of Noxudol 300 S in any two-hour period;
and

Cc. Process no more than 2,920 Toyota vehicles in any consecutive 12-
month period.

2. Dealerships located in Toms River, NJ: As explained in Section IV.B below,
due to a local ordinance, these dealerships are subject to more stringent PM
limits than imposed by the CRC Campaigns Air Permit. To satisfy these more
stringent limits, dealerships located in Toms River, NJ must further restrict
vehicle processing and CRC materials usage as follows:

a. Process no more than one vehicle every 3 hours;

b. Apply no more than one liter of Noxudo! 300 S in any 1-hour period and
no more than three liters of Noxudo!l 300 S in any 3-hour period; and

5 The CRC Campaigns Air Permit contains 2 other operating scenarios: (i) “OS1 LSC” that applied to the Tacoma
LSC 90D which concluded on December 31, 2011 and (ii) “"OS3 Application of Anti-Corrosion Sealant Materials To
Toyota Vehicle Frame Rails” that would allow your dealership to establish a 2™ CRC spraying space. TMS sought
approval for the OS3 scenario so that dealers would have the flexibility to establish a 2" spray space if, in the future
TMS determines that additional vehicle processing capacity is needed. However, unless TMS informs you otherwise,
you should continue to conduct the CRC campaigns in only one spray space, In addition, there may be other
regulatory approvals (such as an approval from the fire code enforcement official) that would be needed before you
could conduct a CRC campaign in a 2" spray space.

8 The CRC Campaign Air Permit refers to a vehicle processing limit of 5,840 vehicles over any consecutive 12-
month period, but that limit applies to the OS2 and OS3 operating scenarios combined. However, the CRC
campaigns are being conducted by all dealers in New Jersey in a single spraying space, and therefore onty under the
OS2 operating scenario and not the OS3 operating scenario that allows a 2 spraying space. As a result, a
processing limit % of 5,840 or 2,920 vehicles currently applies under the Permit.

83
c. Process no more than 2,920 Toyota vehicles in any consecutive 12-
month period.

Hl. MOBILE EQUIPMENT REPAIR AND REFINISHING FACILITIES

New Jersey imposes special requirements on "mobile equipment repair and refinishing (MERR)
operations, including surface coating operations like the CRC campaigns. These requirements
limit the VOC content of coatings” and require the use of high-efficiency coating application
systems approved by NJDEP and the United States Environmental Protection Agency
(USEPA).'® The CRC materials meet the VOC content limit in these regulations, and TMS also
has obtained approval of the Vaupel HSDR 3300 spray gun as a high-efficiency coating system
from NJDEP and USEPA.”

The MERR regulations also impose special requirements for training,?’ materials handling,
transfer and storage** and recordkeeping.”* The specifics of these requirements are addressed
in the Part Two -- State Compliance Supplement for New Jersey (in Steps One & Two and in
Appendix B).”4

NAC. §§ 7: 27-8.2(c), 8.3(a}, 8.3(b).
8 NJAC. § 7: 27-16.12(c)
"8 NJAC. § 7: 27-16.12(f)

2° TMS obtained these approvals from NJDEP and USEPA pursuant to N.J.A.C. § 7: 27-16.12(f}. Appendix B to the
Part Two — State Compliance Supplement for New Jersey contains a copy of the approvals.

27 NJAC. § 7: 27-16.42(i).
22 NJAC. § 7: 27-16.12(h) (requiring use of designated coating storage and handling procedures).

2 NJAC § 7: 27-16.12(e) (requiring retention of a record at MERR facilities for each coating or other solvent-
containing material showing the VOC content of each coating used); N.J.A.C. § 7: 27-16.22(a)(five-year retention
period for required records).

24 New Jersey also imposes special requirements on “sealants” that applied to the Tacoma LSC 90D. NWA. §
7:27-26.2 ef seq.; NJAC. § 7:27-26.1. With the substitution of Noxudol 300 $ for X128 T, subsequent CRC
campaigns are exempt from these sealant requirements because both Noxudol 300S and 712 AM contain less than
20 grams of VOCs per liter, NJAC. § 7:27-26.4(a)(3). Your dealership is responsible for determining whether it
must comply with these sealant regulations for any of its non-CRC campaign operations.

84

IV. PARTICULATE MATTER EMISSIONS LIMITS

A. New Jersey State Requlations

In the application for each dealership's CRC Campaigns Air Permit, TMS included a PM
emissions calculation based on a conservative “maximum operating scenario.” This calculation
indicated that the CRC campaigns could emit as much as 0.47 lbs/hr of PM. When issuing the
CRC Campaigns Air Permit, NJDEP established 0.47 Ibs/hr as the PM emissions limit for the
CRC campaigns.

The PM emissions calculation incorporates assumptions about how long it will take to process a
vehicle, If your dealership were to process a vehicle in a shorter amount of time than
contemplated by the calculation, then your actual hourly PM emissions could be higher and
might not fall below the 0.47 Ibs/hr limit in the CRC Campaigns Air Permit.

To assure compliance with the 0.47 Ibs/hr limit, your dealership should:
» process no more than one Toyota vehicle every 2.5 hours; or
> apply no more than three liters of Noxudol in any two-hour period.
NOTE: If your dealership is located in Toms River, please see Section IV.B, below.

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 New Jersey includes a “CRC Campaign Vehicle
Production Log” that your dealership should use to document its adherence to this limit.

B. Toms River Municipal Code PM Limit

A local ordinance for the Township of Toms River limits PM emissions in certain zoning districts
to 75% of the maximum PM emissions allowed under NJDEP regulations.2> The Toyota
dealership in Toms River is located in one of these zoning districts, and therefore, must adhere
to a lower PM emissions limit than the 0.47 Ibs/hr established in the CRC Campaigns Air Permit.

The maximum PM emissions allowed under NJDEP regulations depend upon the size of the
individual PM-emitting process. For a process the size of the CRC campaigns, the maximum
PM emissions allowed under the regulations would be 0.5 Ibs/hr.”* In the CRC Campaigns Air
Permit, NJDEP decided to impose a 0.47 Ibs/hr limit below this 0.5 Ibs/hr regulatory maximum,
but for purposes of applying the Toms River ordinance, it is appropriate to use the 0.5 Ibs/hr

25 Toms RIVER CODE § 348-5.31.

78 Under NJDEP regulations, the maximum allowable PM emissions from a process with potential PM emissions of
50 Ibs/hr or less (prior to the use of any control technology) is 0.5 Ibs/hr, For a process with petential PM emissions
larger than 50 Ibs/hr, the allowable PM emission limit is established by assuming a 99% reduction of uncontrolled
emissions from the process. N.J.A.C. § 7: 27-6.2(a)

85
regulatory maximum. Under the local Toms River ordinance, therefore, PM emissions from the
CRC campaigns being conducted at the dealership located there are restricted to 75% of 0.5
lbs/hr or 0.38 Ibs/hr.

To assure compliance with this 0.38 Ibs/hr limit, your dealership located in Toms River
should:

> process no more than one Toyota vehicle in any 3-hour period; or

> apply no more than one liter of Noxudol 300 S in any 71-hour period and no more
than three liters of Noxudol 300 S in any 3-hour period.

Vv. RECORDKEEPING

Your dealership should maintain records to demonstrate your compliance with the training
requirements discussed in Part Three above and your adherence to the vehicle processing limit
discussed in Parts One & Four above.”’ Please refer to Appendix B to the Part Two — State
Compliance Supplement for New Jersey for logs that you can use and for copies of
documents to retain on file.

It is important that your dealership maintain records in compliance with New Jersey regulations,
which require that you maintain air compliance records for 5 years. While your dealership can
make its own compliance decisions, if is recommended that you retain the above
documents and alf completed logs until 5 years after your dealership ceases its
involvement in CRC campaigns.

77 In addition to permitting requirements, all facilities with actual emissions or PTE exceeding 10 tpy of VOCs and

100 tpy of PM or total suspended particulates must submit an annual emission statement to NJDEP. N.J.A.C. § 7: 27-
21.2(a). Absent a very large body shop or other significant painting, coating or other spraying operations, it is not
expected that any dealership will have emissions high enough to trigger this requirement.

86