Use the Emissions
Date Number Number Estimator to determine the
of Time of Completion of Time of Completion daily total
Sequoias Tundras VOC (Ibs) | PM (Ibs)

Duplicate as Necessary

Indiana Sequoia and Tundra Daily Production Log

Emissions
Use the Emissions

SEQUOIA TUNDRA

Date Number Number Time of Completion Estimator to determine the
of Time of Completion of daily total
Sequoias Tundras VOC (Ibs) | PM (Ibs)

Emissions Estimator

Locate the row that corresponds to the number of Sequoias (down the left side} and the column that
corresponds to the number of Tundras (across the top) processed each day. Enter the values in the box
where the row and column intersect in the production log to record the amount of VOC and PM emissions
produced,

TUNDRAS
0 4 2 3 4 5
SEQUOIAS voc=0 | VOC=011| VOC=022] VOC=033| VOC=044| VOC =0.55
PM=0| PM=010} PM=020] PM=030] PM=040] PM=0.50
VOC =0.16| VOC=0.27 | VOC=038| VOC=0.49| VOC=060| VOC=071|
PM=0.11| PM=0.21| PM=031| PM=041| PM=051| PM=061
VOC =0.32 | VOC=043 | VOC=0541 VOC =0.65 | VOC =0.76 | VOC =087
PM=0.20| PM=0.32| PM=0.42] PM=052| PM=062| PM=072
Voc =0.48 | VOC=059| VOC=0.70| voCc=081 | VOC =092] VOoCc=1.03
PM=0.33| PM=0.43| PM=053| PM=063| PM=073| PM=0.83
VOC =0.64| VOC=075 | VOC=086 | voc=097 | VOoC=1.08] VvOoc=1.19
PM=0.44| PM=0.54| PM=064| PM=0.74| PM=084| PM=0.94
VOC =0.80| VOC=0.91| VOC=1.02 | VOC=1.13 | VOC=124/ VOoCc=1.35
PM=055| PM=065| PM=0.75| PM=085| PM=095| PM=1.05

Duplicate as Necessary

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INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue
Governor Indianapolis, Indiana 46204

{317) 232-8603
Thomas W. Easterly Toll Free (800) 451-6027
Commissioner www.idem.IN.gov

June 12, 7012

Daniel E. Monette

Toyota Motor Sales, U.S.A., Inc.
19001 South Western Avenue
Torrance, CA 90501

Re: Exempt Construction and Operation Status
Toyota Corrosion Resistant Compound
(CRC) program

Dear Mr. Monette:

Representatives of Toyota Motor Sales, U.S.A. Inc. (“TMS”) met with us recently to discuss the
Sequoia Corrosion Resistant Compound (“CRC”) program for model year 2001-2004 vehicles. In
addition, TMS has asked that IDEM consider whether future CRC campaigns, not yet specifically
identified, that would be conducted using the same equipment and coatings would also be exempt
from permitting requirements. Based upon the information and data provided to IDEM Office of Air
Quality (“OAQ”) and the provisions in 326 IAC 2-1.1-3, it has been determined that the activities
surrounding the Sequoia CRC program, as well as any other CRC program that meets the parameters
outlined in the letter dated May 15, 2012, submitted to IDEM on behalf of TMS, would be
considered exempt from air pollution permit requirements. This exemption applies to all CRC
activities in the State of Indiana.

The following conditions shall be applicable:

1. 326 IAC 6-3-2(d) (Particulate emission limitations, work practices, and control technologies) —
Based on information provided as part of this exemption request, IDEM has determined that
given the higher transfer efficiency of the Vaupel HSDR 3300 spray gun, in combination with the
high solids and high viscosity of the anti-corrosion sealants (Noxudol 300 § and 712AM) being
applied inside a partition area will satisfy the requirements of this rule. Toyota dealers
implementing the CRC program should maintain and operate the spray guns according to the
manufacturer’s recommendations and within the parameters established by the manufacturer for
setup and operations. If accumulation of overspray is observed on the ground outside the work
area, then the dealer should install additional overspray controls or implement additional IDEM-
approved control measures.

2. 326 IAC 8-10 (Automobile Refinishing) — Rule 326 IAC 8-10 applies to Automobile
Refinishing in all counties in Indiana with some exemptions. Section (5)(b)(3) of the rule states,
“Any other coating application equipment that has been demonstrated, by the owner or operator,
to the satisfaction of the department to be capable of achieving at least sixty-five percent (65%)
transfer efficiency. The owner or operator must submit sufficient data for the department to be
able to determine the accuracy of the transfer efficiency claims”. Based on a review of the

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information submitted as part of this exemption request, and the relevant portions of the South
Coast Air Quality Management District determination related to the Vaupel HSDR 3300 spray
gun, these guns are approved under 326 IAC 8-10-5(b)(3) for affected sources in Indiana. Toyota
dealers implementing the CRC program shall operate these guns in accordance with
manufacturer’s specifications and within the parameters established by the manufacturer for setup
and operations.

An application or notification shall be submitted in accordance with 326 IAC 2 to OAQ ifa
Toyota dealer implementing a CRC program proposes to construct additional emission units, modify
existing emission units, or otherwise alter the conditions or parameters of the project in a way that
requires application or notification under the applicable rules. If you have any questions on this
matter, please contact Matthew Stuckey, OAQ Permits Branch Chief, 100 North Senate Avenue,
MC-61-53 IGCN 1003, Indianapolis, Indiana 46204-2251, at 317-233-0203 or at 800-451-6027 (ext.
3-0203).

Sincerely,

Keith Baugues, Assistant Commissioner
Office of Air Quality

cc: Compliance and Enforcement Branch

Barnes & Thormburg, LLC
c/o Anthony C. Sullivan

11 S. Meridian Street
Indianapolis, IN 46204-3535
(_)

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SEQUOIA CORROSION-RESISTANT COMPOUND CAMPAIGN COD

INDIANA DEALER INFORMATION PACKET

APPENDIX B —- EVANSVILLE AIR PERMITTING

if your dealership is not located in Evansville, indiana, you may stop reading, as the
information and requirements in this Appendix B do not apply to you.

The application of CRCs results in emissions of Volatile Organic Compounds (“VOCs”) and
Particulate Matter (“PM”). In Evansville, Indiana, the emission of these pollutants requires your
dealership to obtain, and to operate in accordance with, a Certificate of Operation from the
Evansvilie EPA.

At the time of the Tacoma LSC 90D, TMS worked with you to obtain a Certificate of Operation
from Evansville EPA, and then, to obtain a new Certificate of Operation under which you are
now conducting the Tundra BOD. Your dealership can conduct the Sequoia COD under this
same Certificate of Operation issued for the Tundra BOD. A copy of this Certificate is attached
to this Dealer Packet, please keep this for your records.

19
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20
CITY OF EVANSVILLE

Environmental Protection Agency
100 East Walnut Street
C.K. Newsome Community Center
Evansville, Indiana 47713
Ph: 812/435-6145 Fax: 812/435-6155

win. evansvillezoy.arg/epa

Jonathan Weinzapfel

Mayor
Expires: September 2016 Certificate of Operation #0872
EEPA Will Initiate Municipal Permit Renewal Supercedes all permits issued prior to 9/15/11

Issued To:

Kenny Kent Toyota Service Center
5600 Division Street

Evansville, IN 47715

Is hereby authorized to operate (X)
Is hereby authorized to install (X)

Facility Description NAICS 811111 - General Automotive Repair
¢ Three (3) Vaupel HSDR 3300 spray guns to apply additional corrosion-resistant compounds to truck
frame rails. Corrosion-resistant compounds to be applied are NOX-Rust 712AM, NOX-Rust X128T,
and Noxudol 300 8.

Insignificant Activities:
e One (1) 3,000 gallon above ground gasoline storage tank. Maximum monthly throughput is estimated at
6,500 gallons.
¢ Two (2) parts cleaners (cold cleaners) using mineral spirits.

This permit is issued under the provisions of the Evansville Municipal Code (EMC) 16.05 with the following conditions:

1, That the data and information supplied in the application shall be considered part of this permit.

2. That the permittee shall comply with the provisions of the Evansville Municipal Code (EMC 16.05.010 through 16.05.510) and
the rules promulgated there under.

3. That all permitted equipment shall be operated and maintained in accordance with the manufacturers’ specifications.

City of Evansville Requirements
Pursuant to EMC 16.05,500, compliance with Particulate Matter (PM) and Volatile Organic Compound (VOC)
Emission Limitations will be assumed if requirements A-B are met:

A. Particulate Control Requirements and Procedures [Pursuant to EMC 16.05.180 (ED):

Particulate emissions from the surface coating application process shall be controlled. Permittee shall install
curtains enclosing the area in which the coating application process will occur prior to commencement of the
surface coating application process. Curtains shall be in place at all times surface coating operations are taking
place. Curtains shall consist of material such as plastic or canvas and shall be sufficient to control overspray.

(1) Conduct quarterly building exterior perimeter checks for areas which could be affected by overspray. If
no surface coating activities have taken place during that calendar quarter, no visual inspection is
required; however a notation shall be made on the records to that effect. A record of inspections must be
kept for three (3) years and made available for review by any EEPA personnel.

(over)
Kenny Kent Toyota Servier Center Page 2 of 2 CO #0872
Permit Reviewer: DO September 15, 2011

(2) Provide initial VOC emission reduction training to employees whose job responsibilities include any
refinishing method within 180 days of their employment date. Records of such training for each
employee must be maintained for three (3) years and made available for review by any EEPA personnel.

(3) Provide annual refresher VOC emission reduction training by May 1° to employees whose job
responsibilities include any refinishing method. Records of such training for each employee must be
maintained for three (3) years and made available for review by any EEPA personnel.

B. For Volatile Organic Compound (VOC) contro! (Pursuant to EMC 16.05.500 and EMC 16.05.240]:
(1) Unless in use, all VOC containing materials shall be stored in closed containers.
(2) The containers shall remain closed unless in use, being filled or emptied.
(3) All fresh or used solvent and waste coatings shall be stored in closed containers.
(4) Storage containers and equipment shall be free from cracks and holes.
(5) All VOC contaminated waste materials must be disposed of in such a manner as to minimize emissions.
(6) The owner or operator of a cold cleaning facility constructed after January 1, 1980 shall:
(a) equip the cleaner with a cover;
(b) equip the cleaner with a facility for draining cleaned parts;
(c) close the degreaser cover whenever parts are not being handled in the cleaner;
(d) drain cleaned parts for at least fifteen (15) seconds or until dripping ceases;
(e) provide a permanent, conspicuous label summarizing the operating requirements;
(f) store waste solvent only in covered containers and not dispose of waste solvent or transfer it to
another party, in such a manner that greater than twenty percent (20%) of the waste solvent (by
weight) can evaporate into the atmosphere.

C. General Requirements:

(1) All pollution control equipment controlling emissions to the environment must be operated according to
manufacturers’ specifications at all times the associated process equipment is in operation.

(2) Pursuant to EMC 16.05.270 (I) (5), a Throughput Report covering LSC and BOD usage during the
previous calendar year must be submitted to the Evansville EPA by the date specified on the request.

(3) Pursuant to EMC 16.05.320, an annual Operating fee shall be remitted to the Evansville EPA by the date
specified on the invoice. The first annual Operating fee invoices will be issued in the first calendar
quarter of 2011.

(4) Source shall comply with 326 IAC 8-10 [Automobile Refinishing] incorporated by reference in EMC
16.05.240 (see Attachment A).

Date: QLIS/ UM Approved By: > 7 - O£ =
. Ohning, Diréctor