TOYOTA

TO: DEALER PRINCIPALS, SERVICE MANAGERS AND PARTS MANAGERS
DATE: 2014
RE: Information Packet for Corrosion-Resistant Compound ("CRC") Campaigns

TOYOTA CORROSION-RESISTANT COMPOUND CAMPAIGNS

NEW JERSEY 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.

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).

1 This Packet is not intended to cover other air, waste management, hazardous material, water, ar 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.........ccccccseessstneeerersssessenees 5

APPENDIX A: VEHICLE PROCESSING GUIDANCE ..000.00..occcceccececeeeeeees sida ina heated 9

APPENDIX B: COMPLIANCE WITH STATE AND LOCAL AIR PERMITTING

REQUIREMENTS... arias: Gissrwenceenl
PART TWO — STATE COMPLIANCE SUPPLEMENT

COMPLIANCE STEPS FOR YOUR PARTICULAR STATE ........ccccccc ccc 2

APPENDIX A: SUMMARY OF ADDITIONAL FIRE AND OTHER LOCAL

APPENDIX B: RECORDKEEPING FORMS AND OTHER DOCUMENTS....................39

APPENDIX C: SUMMARY OF FEDERAL, STATE AND LOCAL

REGULATIONS RELATED TO AIR EMISSIONS 00... ccc esssescceeerescseesesetereecneerenenee 81
(This page intentionally left blank.)
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 II| 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 air 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.
{f your dealership conducted the previous CRC campaigns, then you should be able to conduct

any potential future 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 nct 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. |

Step One

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

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.

Cc. If your dealership is not able to do so, then you will need a new approval

before you begin a CRC campaign.

FOLLOW TECHNICAL INSTRUCTIONS.

a. Each CRC campaign has its own Technical !nstructions.

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

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

iii. 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.

COMPLY WITH OTHER AIR EMISSIONS OBLIGATIONS.

a. Continue to process no more than 7 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.
5.

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.

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,

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

Continue to comply with them, including any renewal
requirements.

Continue to do all of the following when applying CRCs:

iti.

iv.

Maintain adequate ventilation in the spray space and surrounding
area;

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

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

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.

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.

¥ “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.

r 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:

r 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.

- 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.

800 to 1000 AM 10 00 AK to 12:00 PM 12 OC to 2 00 PM 20010 400 PM 400lo 6 00 PM 6000600 Ph
ro H
| 3 :
5° 44 ) Carrot sant
1_> ] t] ervoerae vote ured 1000 AM
KS 7 — |
3 Cannot stan grocessing ==?
E cy anette vehicle ured 1000 AM | Carrot sart processing
© : :
>
: —=
En it] Srcther vetecie ured 1200 PM} see §) Cannet stant processing
a 7 a) ercxher vehice unsl 700
> . "| PM
a — l =
2 | Cannot start processing ~~
Q ¢ hs arcthe: vehicke utd fe
a 200 Pu Cannol start processing
> I stot vohicie ut 400 PM
o Cannes stan proceseang ‘ 7
3 jancther vehucia ured 4.00 ‘ -
rw Pu ‘ Cannol start processing
o 4) another webacie und 6 00
> ‘ Pai
o Carea tariproomeng of '
3 encther voted ural 6 00 Pal 4
& 6 } fc :
> j '
1
Mote This sample ucheduis is only on exemple end Ihe order ol models sprayed will vary by customer sppointment

Tundra Mintmum Saquata Minimum Process
Proceas Time Is 7 Hours Tune ta? Hours

10

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.

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

11
Glossary of Common Abbreviations Used In This Table

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

gal/day: Gallons per day

gal/yr: Gallons per year

Ibs/hr: Pounds per hour

Ibs/day: Pounds per day

Ibsimo: 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
gallons of paints, solvents, coatings, sealants
(including the CRCs) 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.)

No additional requirements.

DELAWARE

Comply with the Self-Registration submitted by
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.

if 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.

No additional requirements.

12

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.

= This permit authorizes any potential future
CRC campaign being conducted at the
same dealership location.

lf your dealership never obtained this
permit, or has moved its location since
obtaining it, please contact your please
call the EH&S Hotline (877-572-4347)
BEFORE conducting any CRC campaigns.

INDIANA

Remain exempt by keeping total actual
emissions across your entire dealership under
the “permit by rule” exemption tevels of 20 tpy
for VOCs and 20 tpy for PM.

Dealerships located in Evansville: Comply with
the Certificate of Operation already issued by
the Evansville Environmental Protection
Agency to your dealership for the previous
CRC campaigns.

= This Certificate authorizes any potential
future CRC campaign being conducted at
the same dealership location.

If your dealership never obtained this
Certificate, or has moved its location since
obtaining it, please call the EH&S Hotline
(877-572-4347) BEFORE conducting any
CRC campaigns.

13

KENTUCKY

Remain exempt by keeping PTE across your
entire dealership below the state permitting
thresholds of 10 tpy for VOCs and 10 tpy for PM.

Dealerships located in Jefferson County:
Comply with the air permit already issued by
the Louisville Metropolitan Air Pollution
Control District to your dealership for the
previous CRC campaigns by (i} Processing no
more than 12 vehicles per day for any CRC
campaign; and (ii) Perferming monthly
inspections of the exterior to the building in
which you conduct the CRC operations to
ensure no visible emissions are visable.

=> This permit authorizes any potential future
CRC campaign being conducted at the
same dealership location.

=> If your dealership never obtained this
permit, or has moved its location since
obtaining it, please call the EH&S Hotline
(877-572-4347) BEFORE conducting any
CRC campaigns.

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