Column 1 Column 2 Column 3 Column 4 Column 5
Total monthly VOC Total volume (in VOC content of Total monthly VOC Total monthly
emissions (in pounds) | gallons) of all paints, non-CRC emissions (in pounds) | VOC emissions (in
from CRC campaigns | coatings, solvents or materials {in from the use of non- pounds) [Note:
other VOC-containing | pounds/gatlon) CRC materials [Note: | Sum of Column 1
materials used [See note on Product of Column 2 | and Column 4]
assumptions and Column 3]
below]
January 14 10 7.0 70 84
February 14.5 20 7.0 140 164.5
March 13 15 7.0 105 118
i April 13.75 25 7.0 175 188.75
May 13.5 10 7.0 70 83.5
dune 16.45 30 7.0 210 226.45
July 7.5 25 7.0 175 182.5
August 13.5 20 7.0 140 153.5
September 13.15 20 7.0 140 153.15
October 12.15 15 7.0 105 117.15
November 14 10 7.0 70 84
December 21.6 30 7.0 210 231.6
Total annual VOC emissions: 1777.1

Step 5: At the end of each year, sum all of the
entries in Column 5 and enter the total in the box
below the column. That total reflects your
dealership's total annual VOC emissions {in
pounds). If that value exceeds 6,000 pounds, your
dealership may trigger Wisconsin's annual emissions
inventory report requirement and you should contact
the EH&S Hotline (877-572-4347).

dote: The estimated actual VOC emissions produced by your dealership’s usage of paints, coatings, solvents
or other VOC-containing materials are based on a conservative assumption that the VOC content of those
materials will not exceed an average of 7 pounds per gallon.

15

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16

®eporting Mont!

Use this log to track your dealership’s usage of VOC-containing materials and to calculate your dealership's total annual VOC
emissions. You can use this form to demonstrate that actual annual VOC emissions at your dealership are BELOW 6,000

Wisconsin VOC-Containing Materials Usage Log

lh and Year:

Dealership name:

Pounps PER YEAR and that your dealership is not subject to Wisconsin's annual emissions inventory report requirement.

Important: You must comply with Wisconsin's annual emissions inventory report requirement if your dealership’s
actual annual VOC emissions are greater than 6,000 pounds per year.

promptly call the EH&S Hotline (877-572-4347) for assistance.

If you are facing this situation, please

| December

VOG-Containing Materials, Paints, Coatings and Solvents
Column 1 Column 2 Column 3 Column 4 Column §
Total monthly VOC. Total volume (in VOC content of | Total monthly VOC Total monthly
emissions (in pounds) | gallons) of all paints, non-CRC emissions (in pounds) | VOC emissions (in
from CRC campaigns | coatings, solvents or materials (in from the use of non- pounds) [Note:
other VOC-centaining | pounds/gallon) CRC materials [Note: | Sum of Column 1
materials used Product of Column 2 | and Column 4]
and Column 3]
January 7.0 |
February 7.0
March 7.0
April 7.0
May 7.0
June 7.0
July 7.0
August 7.0
September 7.0 |
October 7.0
November 7.0
T
7.0 |

Total annual VOC emissions:

This record must be maintained for 5 years. Duplicate as necessary.

(This page intentionally left blank)

State of Wisconsin
DEPARTMENT OF NATURAL RESOURCES
101 S. Webster Street Scott Walker, Governor
Box 7921 Cathy Stepp, Secretary
Madison WI §3707-7921 Telephone 608-266-2621
FAX 608-267-3579
TTY Access via relay - 711

ee

DEPT. OF NATURAL RESOURCES

April 19, 2012 File Code: 4560

Benjamin C. Grawe

Gonzalez Saggio & Harlan LLP
225 East Michigan Street, 4th Floor
Milwaukee WI 53202

Subject: Toyota Sequoia Campaign
Dear Mr. Grawe:

This letter is in response to your April 17, 2012 notification to the Department requesting an exemption for the
application of additional corrosion resistant compounds on the Toyota Sequoia 2001-2004 year vehicles and for
the Tundra trucks years that have not yet been processed under the previous campaign. The potential emissions
are higher for the Sequoia than with the Tundra because of the use of an additional liter of the 712AM interior
corrosion-resistant compound (CRC) so the calculations will be based on Sequoia only. The exterior CRC is
Noxudol 300 S, and both are applied by a Vaupel HSDR 3300 spray gun (only one issued to each dealer),
Specifically the compounds will be applied to the vehicle frame rails, one to the interior frame rail surfaces and
one to the exterior frame rail surfaces.

Additionally, future campaigns, substantially similar to this one may be done, using the same or similar coatings.

The two coatings are low VOC and are projected to be emitted at a rate of 0.16 Ib per Sequoia and 12 vehicles per
day per dealership. Based on 21 dealerships (list in 9-2-09 letter) in Wisconsin performing this work on an
maximum estimated 2142 vehicles per dealership, the total VOC emitted is:

0.16 1b VOC/vehicle x 2! dealerships x 2142 vehicles x | ton/2000 Ibs = 3.6 tons VOC per year
Particulate Matter (PM) emissions are as follows:

0.11 Ib/vehicle x 21 dealerships x 2142 vehicles x 1 ton/2000 Ibs = 2.5 tons PM per year. (This assumes that all
PM will be emitted)

The calculations are based on 12 vehicles per day and an operation of 365 days per year. Dealers do not operate
more than 12 hours per day, The number of actual units in operation (UIQ) has also been increased by a factor of
50% to provide a cushion for the number of vehicles that might actually be serviced by any one dealer.
Additionally, there is an assumption that all UIO will respond for the service program, which based on other
campaign programs is highly unlikely.

Upon review of Toyota’s notification, the Department concludes that the Wisconsin dealerships qualify for the
exemption, including all future CRC provided that they are done using the same or similar coatings.

wisconsin gov Naturally WISCONSIN eon

\

Page 2

As outlined in the September 2, 2009 letter the dealerships should keep the following records:

+ Keep records adequate to show that the facility's annual actual emissions remain below the exemption
thresholds. Records should be kept on site for at least 5 years.

« Ifa control device is used to reduce air pollution emissions, conduct monitoring and keep records of
control device parameters as required in s, NR 439.055, Wis, Adm. Code.

* Report emissions annually if required under ch. NR 438, Wis. Adm. Code.
* Operate according to the conditions submitted to the Department (Appendix A)

Although these facilities have been determined to be exempt from the requirement to obtain an air pollution
control operation permit, they are still subject to all applicable requirements in NR 400 - 499, Wis. Adm. Code
and any other applicable federal, state or loca! regulations, except as specifically provided herein. Please advise
each facility that it is required to be in compliance with all applicable requirements.

As long as each facility maintains its exempt status under s. NR 407.03(1 m), Wis. Adm. Code , it will also be
exempt from the requirement to obtain a construction permit for future additions or modifications of equipment at
the facility per s . NR 406.04(1)(zh), Wis. Adm. Code.

If you have any questions regarding this letter, feel free to contact me at 608/267-754 | or at my e-mail address:
[email protected].

Sincerely,

foph Ss. Bh

Joseph G. Brehm, Engineer
Permits & Stationary Source Modeling Section
Bureau of Air Management

na svC0.coRs80 ey

ship Council

SEQUOIA CORROSION-RESISTANT COMPOUND CAMPAIGN COD

WISCONSIN DEALER INFORMATION PACKET

APPENDIX B — GUIDANCE ON VEHICLE PROCESSING LIMITS

Wisconsin regulations impose an hourly limit on particulate matter (PM) emissions from a
“process”. To assure compliance with these regulations for the CRC application process, your
dealership must restrict its vehicle processing to

a “Processing” means the application of CRCs with the Vaupel HSDR 3300 spray
gun; it does not include vehicle preparation activities.

2. The vehicle processing limits mean that once you begin processing a vehicle,
you may not begin processing another vehicle until the 2 hours has passed.

3. Example #1: You begin processing (i.e., applying the CRCs to) a Tundra at
10:00 a.m. in the spray space. In another service bay, you begin preparing (e.g.,
cleaning the frame) a second Tundra for processing. You complete processing
the first Tundra at 11:30 a.m., and by that time, you also have completed your
preparation of the second Tundra for processing. You may move that second
Tundra to the spray space at 11:30 a.m., but you may NOT begin processing it
until 12:00 p.m. —i.e., until 2 hours after you began processing the first Tundra at
10 a.m.

4. Example #2: You begin processing (ie., applying the CRCs to) a Sequoia at
10:00 a.m. in the spray space. In another service bay, you begin preparing (e.g.,
cleaning the frame) a Tundra for processing. You complete processing the
Sequoia at 12:05 a.m., and by that time, you also have completed your
preparation of the Tundra for processing. You may move that Tundra to the
spray space and begin processing it immediately, given that more than 2 hours
has passed since you began processing the Sequoia.

8.0010 1000 AM 10 00 AM 10 1200PM 9120010200 PM > 20010400 PM 400136 99PM > 600 ta B00 PM

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‘Ties sample ochaca in onty an example atthe ores of made sorayed wil vary by Eusteme! pitt

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21