TOYOTA

TO: KENTUCKY DEALER PRINCIPALS, SERVICE MANAGERS AND PARTS

MANAGERS
DATE: 2012
RE: Information Packet for Corrosion-Resistant Compound (“CRC”) Campaign COD

SEQUOIA CORROSION-RESISTANT COMPOUND CAMPAIGN COD

KENTUCKY DEALER INFORMATION PACKET

Toyota is launching a Corrosion-Resistant Compound (“CRC”) Campaign for 2001-2004 model
year ("MY") Sequoia vehicles registered in certain cold climate states with high road salt use
("Cold Climate States"). For ease of reference, this Campaign will be referred to by its assigned
internal designation — “COD".

For the Sequoia COD, your dealership will use the same two Vaupel HSDR 3300 spray guns
already issued to you for the Tundra BOD to apply the same CRC materials now being used for
the BOD —ie., 712 AM and Noxudol 300 S. You will apply these CRCs in the same spray
space already being used for the BOD.

Applying the CRC materials and using the Vaupel HSDR 3300 spray gun raises compliance
obligations under federal, state and/or local laws related to air emissions, fire code approval
and recordkeeping. The Tundra BOD Dealer Information Packet (“BOD Packet") contained a
detailed explanation of these compliance obligations. This Sequoia COD Dealer Information
Packet does not repeat that extensive discussion, but instead assumes your familiarity with
these obligations and identifies the steps that Toyota Motor Sales, U.S.A., Inc. ("TMS")
recommends you undertake to assure your dealership’s continued compliance with these
obligations while conducting the Sequoia COD.

Please review this Dealer Information Packet carefully. If, after reviewing this Packet, you have
any questions or concerns, please call the C.L.E.A.N. Dealer EH&S Hotline (877-572-4347) to
discuss your particular situation.
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Step One

Step Two

Before You Begin The Sequoia COD, Re-Review the
Tundra BOD Dealer Information Packet.

Due to the substantial similarities between the Sequoia COD and the Tundra
BOD, this Dealer Information Packet does not repeat the extensive discussion of
legal requirements set forth in the BOD Packet.

Instead, it is expected that you will carefully and fully re-review the BOD Packet
prior to starting the Sequoia COD, so that you understand all steps your
dealership must take to comply with the applicable legal requirements while
conducting the Sequoia COD.

You received a copy of the BOD Packet previously, but in the event you need an
additional copy, that Packet is available for download on the C.L.E.A.N. Dealer
Website (http://cleandealer.cam).

Before You Begin The Sequoia COD, Confirm That
Your Dealership Satisfies All Of The Criteria Set Forth
Below.

Your dealership will conduct the Sequoia COD in the same spray space
currently being used for the Tundra BOD and in accordance with the
Technical Instructions for the Sequoia COD.

a. The spray space currently being used for the Tundra BOD has already
been approved by your iocal fire code enforcement official.

b, To operate consistent with this approval, you must conduct the Sequoia
COD in this same spray space currently being used for Tundra BOD and
do so in accordance with the Technical Instructions for the Sequoia COD.

c. lf your dealership is not participating in the Tundra BOD or will not conduct
the Sequoia COD in the same spray space currently being used for
Tundra BOD, you will need a new approval from your local fire code
enforcement official. Please call the C.L.E.A.N. Dealer EH&S Hotline
(877-572-4347) to discuss your particular situation.

Your deaiership will remain exempt from air permitting by continuing to
comply with all applicable air regulatory requirements as set forth in the
Tundra BOD Packet. These requirements are summarized below. You should
refer to the BOD Packet for details.

a. Your dealership does not currently have an air registration or an air
permit issued by the Kentucky Department for Environmental Protection,
Division for Air Quality (KDAQ").

b. Your dealership does not operate a very large on-site or off-site body
shop.
c. Your dealership keeps its potential to emit (“PTE”) for VOCs and PM from
all operations combined below the 10 tons per year (“tpy") trigger for air
registration.

i. TMS has obtained a determination from KDAQ that the Tundra
BOD and Sequoia COD will not require your dealership to obtain
an air registration.

ii. Thus, as long as your dealership complies with the requirements
in this Packet, you should remain exempt from air registration
requirements when conducting the BOD and COD.

b. Your dealership will continue to restrict vehicle processing as follows:
(1) Process no more than one Tundra every 2 hours.
(2) Process no more than one Sequoia every 2 hours.

Please refer to Appendix B of this Packet for guidance on how to follow
these vehicle processing restrictions.

d. If your dealership is located in Jefferson County, you will continue
to comply with the requirements set forth in the air permit issued to
your dealership by the Louisville Metro Air Pollution Control District
(“LMAPCD”").

i. TMS worked with your dealership to obtain an air permit from the
LMAPCD for the Tacoma LSC 90D. You may conduct the Tundra
BOD and the Sequoia COD under this permit.

ii. Appendix C of this Packet summarizes your obligations and
contains new forms that you should use for recordkeeping.

Your dealership will continue to comply with all applicable fire, building
and zoning code requirements as set forth in the BOD Packet. These
requirements are summarized below. You should refer to the BOD Packet for
details.

a. As noted above, your dealership should conduct the Sequoia COD in the
spray space that already has been approved by the local fire code
enforcement official and is now being used to conduct the Tundra BOD.

b. If, when approving your spray space, the local fire code enforcement
official issued you a conditional permit or approval that established
special requirements or restrictions, then you must:
i. Confirm that the permit or approval is not time-, vehicle- or CRC
material-limited in such a way that it will not apply to the Sequoia
COD;* and

ii. Continue to comply with the special requirements or restrictions in
the permit or approval.

Cc. Your dealership also must continue to comply with any additional
environmental, health, safety and zoning requirements identified for your
local jurisdiction in "Table 1” of the BOD Packet.

d. The Tundra BOD Packet contained a model letter for you to provide notice
to your local fire code enforcement official, in writing, that your dealership
plans to apply CRC materials to Tundra as well as possibly to other
vehicle models. As long as you provided this notice prior to starting the
BOD, then you will not be required to provide any additional notice for the
Sequoia COD.

e. During application of the CRCs in the spray space approved by the local
fire code enforcement official, your dealership must:

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.

iif. Have fire extinguishers rated "B", "AB", or "ABC" within 30 feet of
the spray space.

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

" If you are facing this situation, or you have any questions on this point, please call the C.L.E.A.N. Dealer EH&S
Hotline (877-572-4347) for assistance
Step Three Before You Begin The Sequoia COD, Complete The
Readiness Checklist Process

1. For Tacoma LSC 90D and Tundra BOD, you completed a detailed Readiness
Survey to confirm that your dealership was ready to begin each of these CRC
campaigns. As long as your dealership will conduct the Sequoia COD in the
spray space that already has been approved by the local fire code enforcement
official (and is now being used to conduct the Tundra BOD) and will otherwise
satisfy the requirements in Steps One and Two above, then you may use a more
simple Readiness Checklist process. To complete the Readiness Checklist
process and confirm that your dealership is ready to begin conducting the
Sequoia COD, please go to the CLEAN. Dealer website

(http://cleandealer.com),

2. Only after completing the Readiness Checklist process will your dealership be
able to order kits with the CRC materials for the Sequoia COD.

Step Four You Can Now Begin Conducting The Sequoia COD,
But Do So In Compliance With The Requirements Set
Forth Below.

1. Adhere to the vehicle processing limits discussed in Step Two above by
not processing more than one Tundra every 2 hours or one Sequoia every
2 hours. Please use the “Sequoia and Tundra Daily Production Log” in
Appendix A of this Packet to document that you are following these vehicle
processing restrictions. As noted above, Appendix B of this Packet includes
guidance on how to follow these vehicle processing restrictions.

2: Comply with air recordkeeping obligations that apply to both the Tundra
BOD and the Sequoia COD by using the new forms provided in Appendix A
of this Packet. (You should no longer need to use the forms provided with
the Tundra BOD Packet, but you must keep the previously completed forms
on file for the time period specified in the Tundra BOD Packet.)

a. The BOD Packet details the air recordkeeping obligations that apply to
CRC campaigns. Your dealership must comply with these same
obligations when conducting the Sequoia COD.?

b. Appendix A to this Packet provides a new “Sequoia and Tundra Daily
Production Log” that you should use to track the number of vehicles
processed under the Tundra BOD and the Sequoia COD and the resulting
air emissions.

C. Your dealership must also maintain a copy of the air registration
exemption determination issued by KDAQ on May 21, 2012 in your

? Please note that while your dealership must comply with hazardous waste requirements generally, the materials
associated with the Tundra BOD and the Sequoia COD do not constitute “hazardous waste" when discarded. As
such, neither the Tundra BOD nor the Sequoia COD will generate hazardous waste or impact your dealership’s
hazardous waste generator status.
records. A copy of this determination is provided in Appendix A of this

Packet.
d. Your dealership must also keep copies on file of other documents
describing the CRC materials and the spray gun that were provided in the

BOD Packet.
3. If your dealership is located in Jefferson County, comply with the

requirements of the air permit issued to your dealership by the LMAPCD.
Please see Appendix C to this Packet for more information and a new
recordkeeping form.

The steps outiined above, in conjunction with the more detailed explanation provided in the
Tundra BOD Packet, should help to assure that your dealership conducts both the Tundra BOD
and the Sequoia COD in compliance with the relevant federal, state, and local requirements.
This Sequoia COD Dealer Information Packet is not intended to cover other air, waste
management, hazardous material, water, or other environmental laws and regulations that might
apply to operations at your dealership other than the application of CRC materials as part of the
Tundra BOD or Sequoia COD. We assume that you already comply with other environmental,
health, and safety requirements that apply to your facility.

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

Thank you for your cooperation.

TOYOTA MOTOR SALES, U.S.A., INC.
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SEQUOIA CORROSION-RESISTANT COMPOUND CAMPAIGN COD

KENTUCKY DEALER INFORMATION PACKET

APPENDIX A —- AIR RECORDKEEPING

Your dealership must maintain the records included in this Appendix to comply with state air
regulatory recordkeeping and retention requirements. This Appendix contains the following
new documents:

1.

"Kentucky Sequoia and Tundra Daily Production Log" A new “Kentucky Sequoia and
Tundra Daily Production Log” that you can use for both the Tundra BOD and the
Sequoia COD to track the number of vehicles processed by your dealership each day
and the resulting air emissions. (You no longer need to use the version of this form
included in the BOD Packet, but you must keep the previously completed forms
on file for the time period specified in the BOD Packet.)

Letter, dated May 21, 2012, issued by KDAQ This letter confirms that the Sequoia
COD does not require an air registration pursuant to 401 KAR 52:070 and is exempt

from the requirements of 40 C.F.R. Part 63, Subpart HHHHHH (National Emissions
Standards for Hazardous Air Pollutants; Paint Stripping and Miscellaneous Surface
Coating Operations at Area Sources) and 401 KAR 59:760, Section 3 (control of
VOC emissions from “Commercial Motor Vehicle and Mobile Equipment Refinishing
Operations” in Boone, Campbell, and Kenton Counties).

In addition to the above documents, the Tundra BOD Packet contained several documents that
your dealership should continue to keep on file for both the Tundra BOD and Sequoia COD. If
you cannot locate these documents, then you can download the BOD Packet that contains these
documents from the C.L.E.A.N. Dealer website (http://cleandealer.com).

Important: Please maintain these documents in your dealership’s records for a period of five

(5) years after the last day that you spray a Tundra or Sequoia at your dealership.
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10
Instructions for Completing the Sequoia and Tundra Daily Production Log

Follow these 4 steps to complete the Kentucky Sequoia and Tundra Daily Production Log.

Maintain the completed logs in your dealership’s records for a period of five (5) years after the last day that

you appiy CRCs to a Sequoia or Tundra vehicle at your dealership.

Step 1:
Enter the “Reporting

Step 2:
Enter the date and

Step 3:
Enter the time that you

Step 4:
Locate the row that corresponds

Year" and your the number of finished processing each to the number of Sequoias (down
“Dealership Name” at Sequoias and vehicle. To comply with the left side) and the column that
the top of the log. Tundra vehicles air emissions limits, you corresponds to the number of
that you processed should not process more Tundras (across the top)
on that date. than one vehicle (Sequoia processed each day. Enter the

or Tundra) every two

values in the box where the row

hours. and column intersect in the
production log to record the
amount of VOC and PM

emissions produced on that day.

Reporting Year: Dealership Name:
Te (/SEQUOIA i / \FuNDRA Emissions
Use the Emissions
Date Nu id Number Estimator to determine the
of Time of Completion of ime of Completion daily total
aquolas 4 Ny inares VOC (ibs) | PM (Ibs)
|
3-1-42 0 _ 2 2:30, 5:00 0.22 0.20
32-12 1 10:30 2 1:00, 3:15 0.38 0.31
=e
3-3-12 3 12:00, 2:15, 5:30 0 - 3 0.48 .° 0.33
34-12 2 3:00, 5:15 2 10:45,1:00 =,’ 044 0.42
# Z
3-5-2 2 11:15, 5:00 1 2:15 ao -” 0.43 0.32
3-6-12 0 - 4 10:35, 12:50, 3:4, 5:45° 0.44 0.40
—= 4 <
é ’ 4 = -
f # , ai
Emissions ESTIMATOR Plea ‘ af
af rs * of — *
TUNDRAS) ’ a
é mg é ait
O 1 2 3,7 4 pa 5
Sequoias | 0 | VvoOc=0 VOC =0.11 | VOC=0.22 | VGC=033 | VOC =0.44,/ VOC =0.55
PM =0 PM=0.10} PM=0.20] -PM=0.30| PM=040| PM=0.50
q4 | vOCc=0.16 | vOC=027 | voc=0.38 Voc =049 | voc =060 | VOC=071
PM=0.14 | PM=0.21 PM=6.31-/ PM=0.41| PM=0.51 PM = 0.61
2 | VOC=032 | VOC=043 | VOC=0547 vOC=065 | VOC=076 | VOC=087
PM=0.22| PM=0.32| PM=042| PM=052| PM=062| PM=0.72
3 | voc=048| vOC=059/ VOC=070| VOC=081 | VOC=092 | VOC=103
PM=0.33 | PM=0.43/] PM=0.53] PM=063/ PM=073! PM=0.83
4 | VOC=064 | VOC=075| VOC=086| VOC=097 | VOC=108| VOC=1.19
PM=0.44| PM=0.54| PM=064] PM=0.74| PM=0.84| PM=0.94
§ | voC=080/ VOC=091 | VoCc=102 | VOoC=1.13 | VOC=124| VOC=1.35
PM=0.55/ PM=0.65| PM=0.75/ PM=085| PM=095| PM=1.05

11
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12
Kentucky Sequoia and Tundra Daily Production Log

Reporting Year; — Dealership Name:
SEQUOIA TUNDRA Emissions
Use the Emissions
Date Number Number Estimator to determine the
of Time of Completion of Time of Completion daily total
Sequolas Tundras VOC (ibs) [| PM (Ibs)