TOYOTA

10: DEALER PRINCIPALS, SERVICE MANAGERS AND PARTS MANAGERS
DATE: 2013
RE: Information Packet for Corrosion-Resistant Compound (“CRC”) Campaigns

TOYOTA CORROSION-RESISTANT COMPOUND CAMPAIGNS

DEALER INFORMATION PACKET

Toyota has been offering Corrosion-Resistant Compound (“CRC”) campaigns for different model year
("MY") Toyota vehicles registered in certain cold climate states with high road salt use. Toyota Motor Sales,
U.S.A., Inc. (“TMS”) has developed this Dealer Information Packet to apply across all current and any
potential future CRC campaigns.

IMPORTANT

For Tacoma LSC 90D, Tundra BOD, Sequoia COD and Tundra BXD -- which are collectively referred
to in this Packet as “the previous CRC campaigns” -- TMS provided your dealership with a separate
packet for each campaign.

This Packet supersedes those separate packets and should be used for:

>» Any of the previous CRC campaigns that are still ongoing and

> Any potential future CRC campaign.

You will still receive separate Technical Instructions for any potential future CRC campaign before
faunch.

For the CRC campaigns, you are applying two CRCs --

> 712 AM (interior frame surfaces)

> Noxudol 300 S (exterior frame surfaces)

-- using the two Vaupel HSDR 3300 spray guns issued to your dealership for the previous CRC campaigns.
Applying the CRC materials and using the Vaupel HSDR 3300 spray gun raises legal compliance
obligations pertaining to air emissions, fire safety approval and recordkeeping. This Packet explains
these obligations and recommends steps to assure your dealership's continued compliance with them."

This Packet consists of two parts:

> Part One — General Guide for Compliance: Part One identifies the general compliance steps all
dealerships should take irrespective of location.

> Part Two: State Compliance Supplement: This Supplement identifies additional compliance steps for
your dealership’s particular state and also includes recordkeeping forms and documents.

Please review this CRC Campaigns Dealer Information Packet carefully. If, after reviewing this Packet, you
have any questions or concerns, please go to the C.L.E.A.N. Dealer website (http://cleandealer.com) or call
the EH&S Hotline (877-572-4347).

' This Packet is not intended to cover other air, waste management, hazardous material, water, or other environmental laws and
regulations that might apply to non-CRC campaign operations at your dealership. We assume that you already comply with other
environmental, health and safety requirements.
TABLE OF CONTENTS

PART ONE -- GENERAL GUIDE FOR COMPLIANCE

COMPLIANCE STEPS ONE AND TWO, FOR ALL STATES...0......c.ccecesseseescccssreseenersoees

APPENDIX A: VEHICLE PROCESSING GUIDANCE .........0...000.: cece

APPENDIX B: COMPLIANCE WITH STATE AND LOCAL AIR PERMITTING

REQUIREMENTS..

PART TWO — STATE COMPLIANCE SUPPLEMENT

COMPLIANCE STEPS FOR YOUR PARTICULAR STATE... cee tecteeeeseereceee
APPENDIX A: SUMMARY OF ADDITIONAL FIRE AND OTHER LOCAL

REQUIREMENTS ...

APPENDIX B: RECORDKEEPING FORMS AND OTHER DOCUMENTS................0...
APPENDIX C: SUMMARY OF FEDERAL, STATE AND LOCAL REGULATIONS

RELATED TO AIR EMISSIONS ..

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TOYOTA CORROSION-RESISTANT COMPOUND CAMPAIGNS
DEALER INFORMATION PACKET

PART ONE — GENERAL GUIDE FOR COMPLIANCE

Applying the CRC materials with a Vaupel HSDR 3300 spray gun produces Volatile Organic Compounds
(“VOCs") and Particulate Matter (“PM”) air emissions subject to federal and state regulations. Generally,
these regulations allow emissions up to a certain level and require an air permit to exceed that level. The
CRC campaigns do not require a federal air permit. However, air emissions regulations differ in each state;
as a result, the CRC campaigns require an air permit in some states. A few local jurisdictions also require
an air permit for the CRC campaigns.

Additionally, the CRC materials are Class lil combustible liquids subject to state and/or local fire codes.
These codes require approval to conduct the CRC campaigns from each dealership’s state and/or local fire
code enforcement official.

For the previous CRC campaigns, TMS worked with participating dealerships to obtain:

> An ait permit and/or any other approvals, if necessary, to assure compliance with the air emissions
regulations; and

>» Approval from the appropriate fire code enforcement official.
‘your dealership conducted the previous CRC campaigns, then you should be able to conduct any potential

iuture CRC campaign as long as you continue to comply with the legal requirements explained in this
Packet.

IMPORTANT:

If your dealership did not conduct the previous CRC campaigns or now plans to change its location
for conducting CRC campaigns, then:

e This Compliance Guide is not applicable; and

« Your dealership may not conduct any CRC campaigns until you contact the EH&S Hotline (877-
572-4347) to discuss your particular situation and obtain the necessary air regulatory and fire
code approvals.

If your dealership has been conducting previous CRC campaigns, but has decided to discontinue its
participation, you must contact your regional representative before doing so and also inform
Headquarters.

One Before You Begin Any CRC Campaign, Confirm That Your
Dealership Will Satisfy All Criteria Below.

1. CONDUCT IN SAME SPRAY SPACE AS THE PREVIOUS CRC CAMPAIGNS.

a. The spray space used for the previous CRC campaigns already should have been
approved by your state and/or local fire code enforcement official.

b. You must conduct any CRC Campaign in this same approved spray space.

c. If your dealership is not able to do so, then you will need a new approval before you
begin a CRC campaign.

2. FOLLOW TECHNICAL INSTRUCTIONS.
a. Each CRC campaign has its own Technical Instructions.

b. You must review the Technical Instructions for the CRC campaign with all employees
involved in the campaign.

3. COMPLY WITH AIR PERMITTING REQUIREMENTS.
a. Your dealership currently should:

i. Not hold an air permit for operations other than the CRC campaigns (if so,
then that permit might need to be amended before conducting the CRC
campaigns.);

ii. Not operate a very large onsite or offsite body shop and/or otherwise engage
in significant painting, coating or other spraying operations (if so, then your
dealership might trigger air permitting due to its non-CRC campaign
activities.); and

ili. For the CRC campaigns either:

(1) Hold the necessary state and/or local air permit, where required, or
(2) Continue to satisfy air permit exemption requirements.
Refer to Part One, Appendix B and Part Two for details.
4. COMPLY WITH OTHER AIR EMISSIONS OBLIGATIONS.
a. Continue to process no more than 1 vehicle every 2 hours, except New Jersey

dealerships are subject to a more stringent vehicle processing limit. Refer to
Part One, Appendix A & B and Part Two for details.

b. Continue to comply with air recordkeeping and other special air regulatory obligations,
such as training and housekeeping, where applicable. Refer to Part Two for details.

5. COMPLY WITH FIRE AND OTHER LOCAL CODES.

a. Continue to comply with the approval issued by your state and/or local fire code
enforcement official for the previous CRC campaigns. If this approval established any
special restrictions,

i. Make sure that these restrictions will not prevent you from conducting the
CRC campaign, and

ii. Continue to comply with them, including any renewal requirements.
b. Continue to do all of the following when applying CRCs:
i. Maintain adequate ventilation in the spray space and surrounding area;

ii, Have no open flames, spark-producing equipment, or drying, curing, or fusion
apparatuses within 20 feet of the spray space;

iii. Make fire extinguishers rated “B,” "AB,” or “ABC” available within 30 feet of the
spray space; and

iv. Follow best management practices for handling and storage of the CRC
materials including:

(1) Do not store more than 25 gallons of the CRC materials and any other
regulated flammable or combustible materials in any one fire area; or

(2) If you store more than 25 gallons of regulated flammable or
combustible liquid in any one fire area, then you must use a fire
cabinet.

(a) A single fire cabinet may hold up to 120 gallons. Your
dealership may only have up to three such fire cabinets in each
fire area.

{b) If you store regulated flammable or combustible liquids at these
levels (3 x 120 gals. = 360 gals.), you should confirm with your
appropriate fire code enforcement official that such storage
does not require an operational permit in your locality.

c. Continue to comply with any additional requirements imposed under fire, building,
environmental, safety or zoning codes for your particular locality. Refer to Part Two
for details.

Step Two Begin Conducting The CRC Campaign In Compliance With The
Vehicle Processing Limit And The Other Requirements Discussed
Above and in Part Two.

Thank you for participating in the CRC campaigns.
TOYOTA MOTOR SALES, U.S.A., INC.
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CORROSION-RESISTANT COMPOUND CAMPAIGNS
DEALER INFORMATION PACKET

PART ONE — GENERAL GUIDE FOR COMPLIANCE
APPENDIX A VEHICLE PROCESSING GUIDANCE

VEHICLE PROCESSING LIMIT FOR CRC CAMPAIGNS: No more than 1 vehicle every 2 hours.

New Jersey Exception: New Jersey dealerships are subject to a more stringent vehicle processing
limit. (Refer to New Jersey Part Two for details.)

For certain CRC campaigns, your dealership may be able to process a vehicle more quickly, but
nevertheless, to assure compliance, you should adhere to this processing limit for all CRC campaigns and
all vehicles.

r “Processing” means applying the CRCs to the vehicle with the Vaupel HSDR 3300 spray gun; it does
not include vehicle preparation activities.

- The vehicle processing limit means that once you begin processing a vehicle, you may not begin
processing another vehicle until the 2 hours have passed.

Example #1
> You begin applying the CRCs to Vehicle A at 10:00 a.m. in the spray space.
In another service bay, you begin preparing Vehicle B for processing.

> You complete processing the Vehicle A at 11:30 a.m., and by that time, you also have completed
your preparation of Vehicle B for processing.

¥ You may move Vehicle B to the spray space at 11:30 a.m., but you may NOT begin processing it
until 2 hours after you began processing Vehicle A at 10 a.m., or in other words, not until 12:00 p.m.

Example #2:

- You begin applying the CRCs to Vehicle A at 10:00 a.m. in the spray space.

¥ In another service bay, you begin preparing Vehicle B for processing.

> You complete processing Vehicle A at 12:05 p.m., and by that time, you also have completed your

preparation of Vehicle B for processing.

a You may move Vehicle B to the spray space and begin processing it immediately, given that more
than 2 hours has passed since you began processing Vehicle A.

6.00 to 1000 AM 10.00 AM Io 12:00 PM 12.00 to 2.00 PM 20010 4.00PM 4000 600 PM 600 06.00PM

s ‘
| ep:
5 4 «= Canrol stariprocessng
> {| srother vehicle unot 10:00 AM
. =
2 Cannan sian processing |? ‘
EN another vehiels unbd 1000 AM |, @ Cancot start procsamng
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Hote

: This sample schedule is only an crample and the order of models sprayed vill vory by customer appointment.

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CORROSION-RESISTANT COMPOUND CAMPAIGNS
DEALER INFORMATION PACKET

PART ONE —- GENERAL GUIDE FOR COMPLIANCE
APPENDIX B -- COMPLIANCE WITH
STATE AND LOCAL AIR PERMITTING REQUIREMENTS

The table below summarizes the steps necessary for Toyota dealerships conducting CRC campaigns to
comply with state and local laws related to air permitting. When using this table, please keep in mind the
following:

e The “State Air Permitting” column indicates whether a dealership needs an air permit to conduct CRC
campaigns, and if no air permit is required, identifies permit exemption requirements.

e The “Local Air Permitting” column indicates any local jurisdiction within a particular state that requires an
air permit or other special approval to conduct the CRC campaigns.

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Glossary of Common Abbreviations Used In This Table

CRCs: Corrosion Resistant Compounds
gal/hr: Gallons per hour

galiday: Gallons per day

galfyr: Gallons per year

lps/hr: Pounds per hour

Ibs/day: Pounds per day

Ibsfmo: Pounds per month

PM: Particulate Matter

PTE: Potential to Emit

tpy: Tons per year

vpd: Vehicles per day

VOCs: Volatile Organic Compounds

STATE AIR PERMITTING LOCAL AIR PERMITTING

CONNECTICUT

Remain exempt by not using more than 2,000 | No additional requirements.
gallons of paints, solvents, coatings, sealants
(including the GRCs) and other VOC-containing
materials across your entire dealership in any
rolling 12-month period. (See Part Two for a
materials usage tracking and compliance log.)

DELAWARE

Comply with the Self-Registration submitted by | No additional requirements.
TMS for your dealership and approved by the
Delaware Department of Natural Resources and
Environmental Conservation on April 20, 2012 by
not processing more than 12 vpd.

lf your dealership never worked with TMS to
submit this Self-Registration, or has moved its
location since April 20, 2012, please call the
EH&S Hotline (877-572-4347) BEFORE
conducting any CRC campaigns.

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ILLINOIS

Remain exempt by keeping coating usage across
your entire dealership (including CRC materials)
at not more than 5,000 gal/yr. (See Part Two for
a materials usage tracking and compliance log.)

Dealerships located in the City of Chicago and
in Cook County: Comply with the air permit
issued to your dealership by either, depending
upon your location, the City of Chicago
Department of Environment or the Cook
County Department of Environmental Control
for the previous CRC campaigns.