(2 liters Noxudol,
No 712AM)

Noxudol 300 S

0.792 gal (3 liters)/kit
x 0.09 Ibs VOC/gal

0.792 gal (3 titers)Akit
x 0.09 Ibs VOC/gal

0.528 gal (2 liters)/kit
x 0.09 Ibs VOC/gal

= 0.071 Ibs VOC/vehicle = 0.071 Ibs VOCivehicle
0.264 gal (1 liter)/kit 0.528 gal (2 liters)/kit

= 0.048 Ibs VOCivehicle

712aM x 0.165 lbs VOCIgal x 0.165 Ibs VOC/gal None
= 0,044 lbs VOCIvehicle | = 0.087 tbs VOCivehicle

Combined VOC | = 9.42 Ibs VOCivehicle = 0.16 Ibs VOCivehicle = 0.05 Ibs VOCivehicle

emissions: . ~ enue! "

B. PMEmissions

The VPL emissions calculation for PM differs from that for VOCs. In particular, both of the
CRCs contain solids; however, not all of the solids in the CRCs will be emitted to the ambient air
as PM. Instead, two factors will reduce the amount of the solids emitted as PM:

7 Some amount of the solids in the CRCs will adhere to the vehicle frame surfaces, and
therefore, not be emitted to the ambient air. To determine this amount requires an
assessment of the transfer efficiency of the Vaupel HSDR 3300 spray gun when being
used to apply the CRCs.

~ Some amount of the solids in the CRCs that do not adhere to the vehicle frame surfaces
(ie., the “overspray”) will adhere to other surfaces (e.g., the tarp underneath the vehicle),
and therefore, not be emitted to the ambient air. To determine this amount requires an
assessment of the percentage of the overspray that will faffout (and adhere to other
surfaces) and not be emitted to the ambient air.

The analysis of these factors for each of the CRCs is summarized below.

~ Noxudol 300.S: TMS retained Concurrent Technologies Corporation (CTC) to perform
two types of testing: (1) Testing to determine the Vaupel HSDR 3300 spray gun’s transfer
efficiency when being used to apply Noxudol 300 S to the external frame surfaces and
(2) Testing to produce data relevant to the amount of the overspray that will fallout, which
data were used by another TMS consultant, Environ Corporation (Environ), to determine a
“fallout factor’. The CTC testing demonstrate that the Vaupel HSDR 3300 spray gun

‘The VOC content is provided in the manufacturer's Material Safety Data Sheets for Noxudot 300 S and 712AM.

Page 2 of 5

achieves a transfer efficiency of at least 85% when being used to apply Noxudol 300 S to.
the external frame surfaces. Additionally, after analyzing the results of the CTC testing,
Environ calculated a fallout factor of at least 90%, i.e., of the 15% of the Noxudol 300 S that
does not adhere to the vehicle frame surfaces (the “overspray”), 90% of that overspray will
“fallout” and adhere to other surfaces and not be emitted to the ambient air.

742AM: CTC could not perform similar testing for 712AM due to its application to interior
frame surfaces and the closed frame configuration. However, Environ calculated the
transfer efficiency based on the dimensions of the limited openings in the otherwise closed
portions of the frame. This calculation indicates that the Vaupel HSDR 3300 spray gun
achieves at least a 98.5% transfer efficiency when being used to apply 712AM to the interior
frame surfaces.” Environ also has conservatively assumed a 75% fallout factor.

The PM emissions calculation has 2 steps:

°

Step One: Use the transfer efficiency to determine the amount of solids that would not
adhere to the vehicle frame surfaces, and therefore, would be potentially available for
emission to the ambient air as PM; and

Step Two: Use the fallout factor to reduce that amount of solids potentially available for
emission, and thereby, determine the estimated actual PM emissions.

The following table summarizes the PM emissions calculations for each CRC kit type based on
these 2 steps.

? 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

Kit (Part) #00289-TOOKT-DS | Kit (Part) #00289-SOOKT-DS | Kit (Part) #00289-T01KT-DS
(3 liters Noxudol, (3 liters Noxudol, (2 liters Noxudol,
1 bier 712AM) 2 liters 712AM) No 712AM)
STEP ONE = ¢ amount of solids potentially available as PM. sions to ambient air
(using transfer efficiency to determine the amount of solids that would not adhere to the vehicle frame surfaces)
0.792 gal (3 liters)/kit 0.792 gal (3 liters)/kit 0.528 gal (2 liters)/kit
x 7.97 lbsigal x 7.97 Ibs/gal x 7.97 lbsigal
x 98.9% solids by weight x 98.9% solids by weight x 98.9% solids by weight
Noxudol x 18% (100% - 85% x 15% (100% - 85% x 18% (100% - 85%
transfer efficiency) transfer efficiency) transfer efficiency)
= 0.94 Ibs PMivehicle = 0.94 Ibs PMivehicle = 0.62 Ibs PMivehicle
0.264 gal (1 titer)rkit 0.528 gal (2 liters)/kit
x 7.885 bbs/gal x 7.885 Ibs/gal
x 97.9% solids by weight x 97.9% solids by weight
aaeAnA x 1.5% (100% - 98.5% x 1.5% (100% - 98.5% None
transfer efficiency) transfer efficiency)
= 0.03 Ibs PM/vehicle = 0.06 Ibs PM/vehicle
Fotentarpm | = 097 ibs PMivehicle = 41.0 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)
STEP TWO - Determine Estimated Actual PM Emissions
(using fallout factor to adjust (reduce) the amount of solids potentially available for emission)
Noxudol
(90% fallout 0.94 Ibs PM/vehicle x 10% 0.94 Ibs PMiVehicle x 10% 0.62 Ibs PM/vehicle x 10%
factor)
T12AM
(75% faltout + 0.03 Ibs PMvehicle x 25% | + 0.06 Ibs PMivehicle x 25% -
factor)
Estimated PM | 0.10 Ibs PMWvehicle = 0.41 Ibs Piiivehicle = 0.06 Ibs PMivehicle

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:

> Ahypothetical “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 ina CRC campaign spray space, 24 hours per day, seven days per

week.

Page 4 of 5

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”.

4. 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 Ibs/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 lbs 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 lbs 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 Ibs/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 Ibs PM/vehicle).

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 Ibs 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 5 of §

(This page intentionally lefi blank)

OhioEPA

Stale of Ohio Envionmental Protection Agency

STREET ADDRESS: MAILING ADDRESS:
Lazarus Government Center TELE: (614) 644-3020 FAX (614) 644-3184 P.O. Box 1049
50 W. Town SL., Suite 700 Rat TEED Columbus, OH 43216-1049
Columbus, Ohio 43215
AUG 2 7 2009
Chuck Taylor, P.E.

GT Environmental/Toyota Motor Sales, Inc.
635 Park Meadow Road, Suite 112
Westerville, Ohio 4343081

Re: Vaupel HSDR 3300 spray gun transfer efficiency vs HVLP
Dear Mr. Taylor

This letter is in response to your letter dated August 3, 2009, in which you requested
written approval to authorize the use of the Vaupel HSDR 3300 spray gun for the proposed
implementation of a Limited Service Campaign (LSC) by Toyota Motor Sales in Ohio
pursuant to Ohio Administrative Code (OAC) 3745-21-18(C)(1){k). Ohio EPA Division of
Air Pollution Control (DAPC) has reviewed your letter, the supporting test documentation
included in your letter and the approval letter from the South Coast Air Management
District (SCAQMD) dated March 10, 2009.

OAC rule 3745-21-18(C)(1) provides that a person at a facility located in an atfected
county, specified in OAC rule 3745-21-18(A), subject to the requirements of the rule, shall
use one or more of the listed application techniques in accordance with manufacturer's
specifications. This rule also allows a person to use an equivalent application technique.
OAC rule 3745-21-18(C)(1)(k) allows for the use of:

“Any other coating application method that the applicable facility demonstrates and Ohio
EPA determines achieves emissions reductions equivalent to HVLP or electrostatic spray
application methods. This demonstration shall be submitted for approval to the director of
Ohio EPA. Any equivalent coating application method approved by the director shall

be submitted to the U.S. environmental! protection agency as a revision to the Ohio state
implementation plan for ozone."

Ohio EPA agrees that the results of the transfer efficiency testing you submitted indicates
that the Vaupel HSDR 3300 spray gun is capable of achieving equivalent or better transfer
efficiency than HVLP equipment (greater than 65%). This approval is also subject to the
following conditions (as similarly found in the SCAQMD approval letter) and shail apply to
any equipment operated in the affected counties in Ohio:

a. The Vaupol HSDR 3300 spray gun shall only be used to apply Daubert NOX-RUST
X128T and NOX-RUST 712AM corrosion preventive coatings to the frame rails
of Toyota Tacoma trucks model years 2001-2004 at the approved Toyota

1

Ted Strickland, Governor
Lea Fisher, Lieutenant Governar
Chris Korleski, Director

® Pninied on Recycled Papar Ohio EPA is an Equal Opportunity Employer

dealerships in Ohio that have been authorized to perform such service during the
Limited Service Campaign.

b, This approval is only valid if the air pressure supplied to the Vaupel HSDR 3300
spray gun is equal to or less than 50 psig when applying the Daubert NOX-RUST
X128T coating and equal to or less than 75 psig when applying the Daubert
NOX-RUST 712AM coating.

c. This approval is only valid if during actual operation the Vaupel HSDR spray gun
is equipped with a 160 psig (full scale) mechanical pressure gauge with markings
every 2 psig and the pressure gauge is operating properly.

d. The Vaupel HSDR 3300 spray gun shall be equipped with a Vaupel Cavity Spray
Tube 3900/3901-WH spray wand when applying the corrosion preventive
coatings. The Daubert NOX-RUST X128T protective coating shall only be
applied to the exterior of the frame rails. The Daubert NOX-RUST 712AM
protective coating shall only be applied to the interior of the frame rails. During
operation, the maximum distance of the spray wand tip to the substrate to be
coated shail not exceed 12 inches.

e. This approval is only valid for the Vaupel HSDR 3300 spray gun model tested.
Any modification of the spray gun or pressure gauge design shall invalidate this
approval unless the modification is approved by Ohio EPA.

By means of this letter | am approving the use of the Vaupel HSDR 3300 spray gun as an
equivalent coating application method. Ohio EPA will revise OAC rule 3745-21-18 to
include this spray gun as an acceptable coating application method and will submit the
modified rule to the US EPA as a revision to the Ohio State implementation Plan (SIP) for
ozone. Prior to this rule revision, Ohio EPA plans to add a link on our website for this rule

which will indicate that this spray gun has been approved as an equivalent method to
HVLP.

lf you have any additional questions, please call Lee F. Burkleca at 614-728-1344 or e-mail
him at lee.burkieca@ epa.state.oh.us.

Sincerely,

20. R20

Chris Korleski
Director
Ohio EPA

cc: Lee Burkleca, DAPC

CORROSION-RESISTANT COMPOUND CAMPAIGNS
DEALER INFORMATION PACKET

PART TWO — STATE COMPLIANCE SUPPLEMENT FOR OHIO

APPENDIX C - SUMMARY OF FEDERAL, STATE AND LOCAL
EGULATIONS RELATED TO AIR EMISSIONS FOR OHIO

L 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 laws related to air emissions. To assist you in making compliance
decisions for your dealership, TMS has prepared this summary of federal, state and local laws
and regulations related to air emissions in Ohio as of March 2013.

i. AIR PERMITTING

Both federal and Ohio laws and regulations require an air permit for “major” and “minor” sources
of VOCs and PM as described below.

1. Major Source

A major source is any source with a potential to emit (PTE)' at or above 100 tons per year (tpy)
for PM and 100 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.

* “Potential to emit” or “PTE” refers to the maximum capacity of a stationary source to emit air pollutants under its
physical and operational design OAC § 3745-77-01(CC). The PTE calculation generally requires conservalive
assumptions, and a source's actual emissions are usually well below its PTE.

2 OAC § 3745-77-01(X)(2)-(3)(a). Sources in serious ozone nonattainment areas or ozone transport areas, severe
ozone nonattainment areas and extreme ozone nonatlainment areas with PTE of 50 tpy, 25 tpy or 10 tpy of VOCs,
respectively, are considered major sources. OAC § 3745-77-01(X)(3)(a)-(b). Likewise, sources in serious PM
nonattainment areas with PTE greater than 70 tpy of PM-10 are considered major sources. OAC § 3745-77-
01(X}(3Xd). As of the time of writing this memorandum, no areas of Ohio were considered serious, severe or
extreme nonattainment areas for ozone and no areas of Ohio were considered nonattainment areas for PM-10.

? For details on this calculation, see the CRC Campaigns Air Emissions Calculation Summary in Appendix B of the
Part Two ~ State Compliance Supplement for Ohio

77

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.

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

a. Your dealership does not operate a very large on-site or an off-site body
shop;* and
b. Your dealership does not otherwise engage in significant painting, coating
or other spraying operations.
2. Minor Source

A minor source is any source that (a) does not constitute a major source® and (b) conducts an
air emitting operation that does not qualify for permit exemption. © Ohio offers various types of
permit exemptions, including one for “de minimis” air emitting operations”.’ To qualify for this de
minimis exemption, an air emitting operation (in combination with any “similar” operations)® must
satisfy the following criteria:

a Not emit any air pollutant above 10 Ibs/day*;

b. Not be subject to a federal standard that limits emissions to less than 10
Ibs/day;

‘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 patticular, 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 fram air
Permitting. Moreover, the state might require you to combine the PTE from an offsite body shop — even if the body
shop 's 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.

* OAC § 3745-77-01(Y)

“OAC § 3745-31-02(AK1)(b}; OAC § 3745-31-03

7 OAC § 3745-15-05.

San operation would qualify as “similar” to the CRC campaigns if it involves (a) the same type of spray space set up:
(0) the same or functionally similar materials to the CRCs; and (c) the application of those materials with a spray gun.
See OAC § 3745-15-05(A)(7) (defining ‘similar’ operations). TMS assumes that you are not conducting other
operations that qualify as “similar” to the CRC campaigns, and therefore, that the de minimis exemption criteria apply
only to the CRC campaigns, including in particular the 10 Ibs/day emissions limit. If you are or believe that you might

be conducting Operations that qualify as “similar” to the CRC campaigns, please contact the EH&S Hotline (877-572-
4347) to discuss your panticular situation

° OAC § 3745-15-08(b)

78

Ch Not be subject to an emission limit adopted by Ohio EPA to achieve and
maintain the national ambient air quality standards or protect public health
and welfare that limits emissions to less than 10 Ibs/day the emissions;

d. Not emit radionuclides;
e. Not have a PTE above 25 tpy; and

f. Not emit more than one ton per year of any hazardous air pollutants or
combination of hazardous air pollutants. '°

The Tacoma LSC 90D did not satisfy the above criteria for the de minimis exemption due to the
possibility that a dealership conducting the campaign could emit greater than 10 Ibs/day of
VOCs; nor did LSC 90D qualify for any other permit exemption. TMS worked with each
dealership, therefore, to obtain a Permit To install And Operation (PTIO) that authorized LSC
90D and any subsequent CRC campaigns."

With the substitution after Tacoma LSC 90D of the lower VOC-containing Noxudol 300S for
X128T, actual and potential emissions of VOCs from the CRC campaigns were reduced below
the 10 Ibs/day level. Thus, as long as your dealership satisfies the other criteria above in b-f.,
the CRC campaigns will qualify for the de minimis exemption, and you will no fonger need the
PTIO to conduct the CRC campaigns.

Given the PTIO triggers special reporting obligations as well as assessment of fees, TMS
recommends that you revoke the PTIO. You can do so by signing the form available through
your Regional Representative authorizing TMS to request that Ohio EPA revoke the PTIO
issued to your dealership at the time of the Tacoma LSC 90D.

"© OAC § 3745-15-05(C)

'" This PTIO imposes the following conditions: (1) Conduct the CRC campaign at the specific address listed on the
PTIO; (2) Do nat process more than 1,398 vehicles per year from all CRC campaigns combined; (3) Comply with the
recordkeeping and reporting requirements specified in the PTIO; and (4) Paying fees for the PTIO assessed by Ohio
EPA.

79

Ml. AUTOMOTIVE REFINISHING OPERATIONS

Ohio imposes special requirements on “commercial motor vehicle and mobile equipment
refinishing operations” in Ashtabula, Butler, Clark, Clermont, Cuyahoga, Geauga, Greene,
Hamilton, Lake, Lorain, Medina, Miami, Montgomery, Portage, Summit and Warren counties
that may apply to the CRC campaigns.’? To comply, you need to use the Vaupel HSDR 3300
spray guns approved by Ohio EPA as HVLP equivalent;”* follow housekeeping and pollution
prevention measures in the CRC work area and for handling and storage of the CRC
materials; '* conduct training for the CRC campaigns; '® and maintain certain records."© The
specifics of these obligations are addressed in Part Two (Steps One & Two) and in Appendix B
of the State Compliance Supplement for Ohio.

® See OAC § 3745-21-18. It is not certain that the CRC campaigns qualify as commercial motor vehicle and mobile
equipment refinishing operations, but TMS recommends that you conduct each campaign in accordance with the
commercial motor vehicle and mobile equipment refinishing operation requirements.

1° TMS obtained this approval from Ohio EPA as required by OAC § 3745-21-18(C}(3}{k). Appendix B to the Part
Two — State Compliance Supplement for Ohio contains a copy of this approval for you to maintain on file as part of
your recordkeeping obligations.

™ OAC § 3745-21-18(C)(6)(a)-(A)

SOaC § 3745-21-18(C)(4). You may satisfy this training requirement by having each employee conducting the CRC
campaign (1) read the Dealer Information Packet for CRC Campaigns, (2} this memorandum, and (3) the Technical
Instructions for each CRC campaign

oac § 3745-21-18(E). Appendix C of the Part Two — State Compliance Supplement for Ohio includes a copy of
the Ohio Personne! Training Log

lV. PARTICULATE MATTER EMISSIONS LIMITS

Ohio regulations require sources to limit hourly emissions of PM.'’ Under the regulations, an
allowable PM emissions rate must be developed for each type of process using a “process
weight rate” formula. "®

The process weight rate for the CRC campaigns is a function of the amount of CRCs sprayed
and the time it takes to spray them during processing of a vehicle. Due to the variation in
amounts and application times as between CRC campaigns, the process weight rate - and
therefore the applicable allowable PM emissions rate — will vary for each CRC campaign.

For each CRC campaign, TMS calculates both (1) the allowable PM emissions rate (using the
Process weight rate formula) and (2) the hourly PM emissions expected if the campaign is
conducted in accordance with the Technical Instructions. TMS then compares (1) and (2) to
make sure that each CRC campaign will fall below the allowable PM emissions rate applicable
to it.

The calculation of hourly PM emissions for each CRC campaign incorporates assumptions
tegarding how long it will take you to process a vehicle. If you were to process a vehicle in a
shorter amount of time, your actual hourly PM emissions could be higher and might not fall
below the allawable PM emissions rate.

To assure compliance with the allowable PM emissions rate, your dealership should not
process more than 7 vehicle every 2 hours. The Part One - Guide for Compliance to the
CRC Campaigns Dealer Information Packet discusses the vehicle processing limit and provides
guidance in its Appendix A on how to follow the limit. Appendix C of Part Two — State
Compliance Supplement for Ohio includes a “CRC Campaign Vehicle Production Log” that your
dealership should use to document its adherence to this limit.

v. RECORDKEEPING

Your dealership should maintain records to demonstrate your compliance with the training and
housekeeping requirements discussed in Part Ill above and your adherence to the vehicle
processing limit discussed in Part IV above. Please refer to Appendix B to the Part Two — State
Compliance Supplement for Chio 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. While
your dealership can make its own compliance decisions, it is recommended that you retain
the above documents and all completed logs until 5 years after your dealership ceases
its involvement in CRC campaigns.

OAC § 3745-17-11

"8 OAC § 3745-17-11(A}(2)

81