Daimler Trucks North America Western Star Truck Plant

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Daimler Trucks North America Western Star Truck Plant Oregon Solutions, April 2, 2014 Paul Erdy, Plant Manager Security Classification Line

Agenda 1. Western Star Overview 2. Environmentally Conscious Operations 3. Environmental Responsibility a) History of Compliance and Continuous Improvement b) Air Quality Monitoring Program c) Results and Actions Daimler Trucks and Buses 2

Portland Western Star Truck Manufacturing Plant Constructed in 1969 Square Footage: Office 19,092 sq. ft. Manufacturing 359,959 sq. ft. Warehouse 95,336 sq. ft. Build Rate: 26 Trucks per day ~ 1 shift 4 Unions: Local 1005 Machinists Local 1094 Painters Local 305 Teamsters Local 49 Service Employees Total TMP Employees = 744 Daimler Trucks and Buses

Daimler Trucks and Buses 4

PORTLAND TRUCK PLANT BLUE SKY Longevity- here for the long haul : Achieve the lowest normalized, plant controlled cost Zero Environmental impact to our Community Deliver a high quality vehicle on time Employee Driven Waste Elimination: Employees owning and continuously improving their processes Awesome 5-S processes Employee owned Total Productive Maintenance (TPM) Asset to the Community: Meaningful contributors to our community 100% participation in charitable causes Support local business Ownership by All: Robust training programs and ongoing people development All work performed to up-to-date standard work Employees providing solutions to problems Everyone is the CEO of their job Benchmark Truck Manufacturer: DTNA s Presidents Cup winner Achieve the highest DTNA TOS assessment Shingo Prize winner (the ultimate LEAN award) Great Place to Work: Highest Employee survey scores 100% Employee involvement Employer of choice Transparent communication at all levels Create safety 1 st accident free workplace Daimler Trucks and Buses

Environmentally Conscious Operations ISO 14001 Certification Environmental Policy Compliance Pollution Prevention Goals and Targets Monitoring and Measurements Daimler Due Diligence Program Site Assessment Proactive Target Agreement Key Performance Indicators Regulatory Reviews Semi-Annual Compliance Certification Bi-annual Inspections Daimler Trucks and Buses 6

Coating Operations Pollution Prevention Application Technology Source Reduction Waste Minimization Training Standard Work Daimler Trucks and Buses 7

Volatile Organic Compounds VOC VOC Tons VOC lbs/truck TONs of VOC 500 450 400 350 300 250 200 150 100 50 70 60 50 40 30 20 10 lbs of VOC 0 2007 2008 2009 2010 2011 2012 2013 2014 0 RACT (Reasonably Available Control Technology) Permit limits : Clear Coatings = 4.3 lb VOC per gal Actual 3.18 lb VOC Forced Air Dried = 3.5 lb VOC per gal Actual 2.93 lb VOC Daimler Trucks and Buses 8

Compliance Hazardous Air Pollutants lbs HAPS per gal Solids 3 2.5 2 1.5 1 0.5 0 1.05 40 CFR Part 63 Subpart PPPP (Coatings of Plastic Parts) Limit 0.16 lb HAP/lb solids Actual 2013 emissions 0.005 lb HAP/lb solids 97% reduction since 2007 MMMM 2.6 lb/gal limit 0.37 0.19 0.21 0.15 0.061 0.059 2007 2008 2009 2010 2011 2012 2013 HAPs per year 2.6 lb/gal limit lbs HAPs per lbs. Solids 0.18 0.16 0.14 0.12 0.1 0.08 0.06 0.04 0.02 0 0.156 40 CFR Part 63 Subpart MMMM (Coatings of Metal Parts) Limit 2.6 lb HAP/gal solids Actual 2013 emissions 0.059 lb HAP/gal solids 94% reduction since 2007 0.049 PPPP 0.16 lb/lb limit 0.16 lb/lb limit 0.017 0.021 0.02 0.007 0.005 2007 2008 2009 2010 2011 2012 2013 HAPs per year Daimler Trucks and Buses 9

Hazardous Air Pollutants 9 HAPs lbs per Truck Haps lb/truck 8 7 6 5 4 3 2 1 0 Changed military coatings to comply with NESHAP MACT MMMM and PPPP 2007 2008 2009 2010 2011 2012 2013 Changed topcoat from DMHS to UB tint system Eliminated chrome from metal surface preparation Changed basecoat converter Changed chassis coating Changed clear coat Formula Changed cleaner Changed chassis coating Changed primer 57% Reduction per Truck from 2007 85% Reduction per Truck from 2007 85% Reduction per Truck from 2007 84% Reduction per Truck from 2007 93% Reduction per Truck from 2007 97% Reduction per Truck from 2007 7.65 lb HAP/truck 3.26 lb HAP/truck 1.11 lb HAP/truck 1.13 lb HAP/truck 1.18 lb HAP/truck 0.48 lb HAP/truck 0.24 lb HAP/truck Daimler Trucks and Buses 10

Air Emissions Continuous Improvements Decommissioned Booths 100% elimination of n-butanol Solvent Recovery Unit 36% reduction of 1-methoxy 2- propyl acetate Oven 1 Booth 2 Booth 1 12% reduction of VOC Touch Up Booths 1,2,3 Main Ovens Main Paint (3,4&5) Prime Booth Chassis Booth Parts Booth (PB D) 100% elimination of HAP E-coat Ovens * HAPS Free Not in Use < 30 gal/yr NG Combustion Daimler Trucks and Buses 11

Odor Complaint Investigation Evaluated odor complaints time, days, location, etc. Individual components and mixtures were raked for potential odor risks Air sampling program began on May 15, 2012 and ended on May 20, 2013 Sampled twice per day during operations and various other times when the plant was not operating Neighbors were complimentary and supportive Neighbors were encouraged to participate. Summa canisters (and training) were provided to neighbors. Daimler Trucks and Buses 12

Air Sampling Program Summary Five hundred fifty eight (558) samples have been collected using summa canisters to analyze for a broad range of volatile organic compounds (VOC). Twenty four (24) samples have also been collected with tedlar bags for a broad range of sulfur compounds heavy oil, natural gas, etc. One hundred sixty eight (168) different compounds have been detected. Fifteen (15) are potentially associated with paint activities. Date Name Odor Threshold Result Common Source 06012012 1-methoxy 2-propyl acetate 0.0014 0.0032 coatings 06082012 dimethyl sulfide 0.0025 0.0073 decay, sewage 06082012 hydrogen sulfide 0.0006 0.008 decay, sewage 11012012 hexanal 0.00028 0.01 natural gas, oil 11012012 nonanal 0.00034 0.0025 natural gas, oil 11012012 octanal 0.00001 0.003 natural gas, oil 11052012 hexanal 0.00028 0.00089 natural gas, oil 01142013* 1-methoxy 2-propyl acetate 0.0014 0.0016 coatings 04192013 hexanal 0.00028 0.00074 natural gas, oil *DTNA not operating Daimler Trucks and Buses 13

Western Star Air Sampling Program Stafford-University 1 (V) Amherst-Dwight 4 (V) Newman- Stafford 1 (V) Amherst-Olin 2 (V) Amherst-Menlo 1 (S) Willamette-Olin 3 (V) W NW SW 30 N NE 20 10 0 S Willamette-Menlo 10 (V) 6(S) SE winter wind data E W NW SW 10 0 Amherst-Cambridge 1 (S) 20 NE 30 N SE spring wind data S E Bluff Train Tunnel 4 (V) Amherst-Woolsey 1 (V) 1 (S) Amherst-Newman 1 (S) Willamette-Woolsey 5 (V) Willamette 1 (S) Amherst-Wellesley (S1) 492 (V) 12 (S) Willamette-Wellesley 4 (V) 1 (S) Amherst-University 6 (V) Daimler Trucks and Buses 14

Nov 2011 First neighborhood meeting and plant tour approximately 20 attendees including neighbors and DEQ. Plant tour has conducted. Apr 2012 Consulted with industrial hygienist to evaluate coatings and rank them according to odor thresholds. Identified key components for potential odor risks. Discovered that changes to lower VOC or eliminate HAP may increase risk of odor. May 2012 Contracted with Air Toxic Ltd. for sampling protocol and analysis of air samples. Evaluated odor complaints to determine the types, times and locations. Air samples were collected in various locations in and around the neighborhood twice a day (during operation) for one year one at noon and alternate mornings and afternoon/evenings. Neighbors were complimentary and cooperative and suggested we were sampling in the right places. Some samples were collected when we were not operating. Air Toxic Ltd. provided analysis for 62 various VOC and 4 different sulfur compounds. Based on the industrial hygienist study, we contracted with the lab to add 4 additional compounds with low odor thresholds. 98 other tic s (tentatively identified compounds) were also included. Jun 2012 1-methoxy 2- propyl acetate above its odor threshold. This compound is associated with the clear coat. The coating was reformulated to reduce this compound and put into production in September. Hydrogen sulfide and dimethyl sulfide detected above their odor thresholds. These compound are not associated with coatings. Daimler Trucks and Buses 15

Aug 2012 The cleaner used for paint equipment maintenance and color changes was reformulated to eliminate n-butanol and replaced with isopropyl alcohol. Sep 2012 Second neighborhood meeting was held at the site. Invitations included 150 households, regulatory and health officials, faculty from the local University of Portland, NCA representatives and retired EPA experts. Primary focus was to share the data that was collected and discuss the reformulation of the clearcoat. Nov 2012 Held third neighborhood meeting at the site. Invitations included 150 households, regulatory and health officials, faculty from the local University of Portland, NCA representatives and retired EPA experts. Communicated the results of the air sampling program and discussed ways to improve the sampling. As a result, DTNA agreed to continue the sampling through the winter months and provide summa canisters and training to the neighbors to collect air samples when they experience odor. The dialogue indicated that the neighbors experience a myriad of odors with varying intensity during different times of the week and seasons of the year. The experience is not necessarily localized and odors are said to exist throughout the entire North Portland area. The group indicated that their underlying concern is health impacts of air quality in their neighborhood and the lack of access to relevant information regarding those potential impacts. Daimler Trucks and Buses 16

Nov 2012 Participated at a supplemental Public Informational Meeting hosted by DEQ. Nov 2012 Pentanal, hexanal and octanal detected above their odor thresholds as tentatively identified compounds. The most common source of alkanes is natural gas and oil. Apr 2013 Hexanal detected above its odor threshold. Jun 2013 Changed chassis paint and eliminated 12% VOC and reduced odor risk. Jul 2012 Changed primer and eliminated 100% of HAPS. Daimler Trucks and Buses 17

Closing Thank You! commit comply prevent improve achieve design Daimler Trucks and Buses 18

Back Up Daimler Trucks and Buses 19

Attorney/Client Privilege Portland Air Toxics Solutions (PATS) Summary Portland Air Toxics Solutions Committee Report and Recommendations Published April 2012 Modeling Study that projects air toxics concentrations for 19 pollutants in 2017 industrial, mobile, residential activities 14 of the 19 pollutants are above health based benchmarks 8 of the 14 cause the most risk 1,3 Butadiene Benzene Diesel particulate 15 PAH Naphthalene Cadmium Acrolein Formaldehyde Department 01.04.2014 Daimler Trucks and Buses 20

Attorney/Client Privilege Portland Air Toxics Solutions (PATS) Summary Priority Emission Source Categories Residential Wood Combustion On Road Mobile Light Duty On Road Mobile Heavy Duty Construction Industrial Metals Mobile Source 1,3 Butadiene Benzene Ethylbenzene Chromium VI Arsenic Residential Wood 15 PAH Industrial Cadmium Manganese Nickel Lead* Secondary Acetaldehyde Formaldehyde Naphthalene Acrolein *Added not visible on concentration maps Department 01.04.2014 Daimler Trucks and Buses 21

PATS Point Source Summary Attorney/Client Privilege % Point Source DTNA Cascade General Gunderson Malarkey Paramount Petro Conoco Phillips lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr Acetaldehyde 0 658* Acrolein 1 5* 1.3 1491* 9 Benzene 2 <1 143* <1 122* 1020 648 Butadiene 0 1 Naphthalene 9 <1 <1 116 <1 841 15 PAH <1 <1 <1 135 3* Formaldehyde 1 14 7* 20 4372* 27 Arsenic 2 <1 <1 <1 <1 <1 Cadmium 70 3* Chromium 6 7 Lead 99 Manganese 100 Nickel 100 * Priority reduction for Portland to meet ambient air quality benchmarks. Acrolein is a byproduct of natural gas combustion. Overall, DTNA is not considered a high priority with respect to the Portland Air Toxics Solutions study. Department 01.04.2014 Daimler Trucks and Buses 22