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NHTSA ID Number: 10134048

Manufacturer Communication Number: Ohio C0D Packet

TSB/Document Date: 2018-04-23


Summary

ToyotaeBay logo is launching a Corrosion resistant Compound Campaign for 2001-2004 model year Sequoia vehicles registered in certain cold climate states with high road salt use.


TOYOTAeBay logo

TO: OHIO DEALER PRINCIPALS, SERVICE MANAGERS AND PARTS MANAGERS
DATE: 2012

RE: Information Packet for Corrosion-Resistant Compound (CRC) Campaign

SEQUOIA CORROSION-RESISTANT COMPOUND CAMPAIGN COD

OHIO DEALER INFORMATION PACKET

ToyotaeBay logo 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 ToyotaeBay logo 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.
(This page intentionally left blank.)
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,com).

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 local 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.

Cc. 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 dealership may conduct the Sequoia COD under the Permit to Install
and Operate (PTIO) previously issued to you at the time of the Tacoma LSC
90D as [ong as you will continue 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 will conduct the Sequoia COD at the specific address
listed on your PTIO. (If you intend to conduct it elsewhere, then you will
need a new permit.)

b. Your dealership will continue to restrict vehicle processing in order to
comply with hourly PM emissions limits 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 in Appendix C of this Packet to for guidance on how to follow
these vehicle processing restrictions.

c.

Your dealership will process no more than a total of 1,398 vehicles
per year under the Sequoia COD and Tundra BOD combined.

If located in Butler, Clark, Clermont, Greene, Hamilton, Miami, Montgomery
or Warren County (the “Nonattainment Counties”), your dealership will
comply with certain training and notification requirements.

a.

Dealerships in the Nonattainment Counties must complete the necessary
training by:

i. Having all employees who will conduct the Sequoia COD review
and confirm that they understand this Packet, the Tundra BOD
Dealer Information Packet, and the Technical Instructions; and

ii. Completing a log which documents that such training has
occurred.

Dealerships in the Nonattainment Counties also must provide a
notification to the Ohio EPA district office or local air agency responsible
for your county that you intend to conduct the Sequoia COD and submit a
copy of the completed training log with the notification.

Appendix D of this Packet contains a log that you can use to document
the training and a model notification letter.

Your dealership will

(i) notify the local fire code enforcement official of your plans to apply
CRCs to additional vehicle models besides Tundra and

{ii} 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.

As a courtesy, TMS recommends that you provide notice to the local fire
code enforcement official in writing that your dealership plans to apply
CRC materials to vehicle models other than Tundra in this previously
approved spray space. Appendix A of this Packet contains a letter that
you can use to provide such notice.

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:

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

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

Your dealership also must continue to comply with any additional
environmental, health, safety and zoning requirements identified for your
local jurisdiction in "Table 71" of the BOD Packet.

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

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.

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

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

1

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

1.

Step Four

Readiness Checklist Process

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).

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

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

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 B of this Packet to document that you are following these vehicle
processing restrictions. As noted above, Appendix C of this Packet includes
guidance on how to follow these vehicle processing restrictions.

Comply with all training, housekeeping, recordkeeping and reporting
requirements specified in the PTIO and/or in Ohio EPA regulations by using
the forms provided in Appendix B of this Packet. (You no longer need to
use the forms provided with the BOD Packet, but you must keep the
previously completed forms on file for the time period specified in the BOD
Packet.)

a. The BOD Packet details the training, housekeeping, recordkeeping and
reporting requirements that will apply to CRC Campaigns.

b. Your dealership must comply with these same obligations when
conducting the Sequoia COD. *

Cc. Appendix B provides forms that you can use to meet these obligations as
follows:

? 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.
i. Track the number of vehicles processed under the Tundra BOD
and the Sequoia COD and resulting air emissions using the
“Sequoia and Tundra Daily Production Log".

ii. Record the total volume of VOC-containing materials used by your
dealership on a yearly basis using the "Ohio BOD and COD
Emissions Log”.

d. Train all staff at your dealership that will be conducting the Sequoia COD
in the proper use, handling and storage of the CRCs.

e. Complete and submit the annual Permit Evaluation Report using the
forms and following the instructions that you will receive from the Ohio
EPA.

f. Your dealership should keep copies of documents that address the

guaranteed transfer efficiency of the Vaupel HSDR 3300 spray gun and
that describe the materials and equipment used to conduct the Tundra
BOD and the Sequoia COD. Copies of such documents were provided
with the Tundra BOD Packet.

The steps outlined above, in conjunction with the more detailed explanation provided in the
Tundra BOD Packet, should help to assure that your dealership conducts both the 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 maierials 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.

TOYOTAeBay logo MOTOR SALES, U.S.A., INC.
(This page intentionally left blank.)

SEQUOIA CORROSION-RESISTANT COMPOUND CAMPAIGN COD

OHIO DEALER INFORMATION PACKET

APPENDIX A - FIRE OFFICIAL MODEL OUTREACH LETTER

The Tundra BOD Packet directed you to notify your loca! fire code enforcement official, in
writing, of your intention to use the same space that had been previously approved for
conducting the Tacoma LSC 90D, to spray a less-combustible CRC (Noxudol 300 S) on certain
MY Tundra vehicles. Prior to conducting the Sequoia COD, TMS recommends that you provide
one additional notice informing your local fire code enforcement official that your dealership
intends to apply CRCs to additional vehicle models besides Tundra in this same spray space.

TMS has prepared a model letter that you can customize and use to provide this notice.
Contact information for your local fire code enforcement official can be found in Table 1 of the
Tundra BOD Packet. Please remember that you must send this letter before you begin
conducting the Sequoia COD.

Please note that the model letter refers to “CRC program” (instead of the Sequoia COD) to
ensure that the notification to your local fire code enforcement official covers not only the
Sequoia COD, but also any CRC program that may be offered for ToyotaeBay logo vehicles in the future
when conducted in the same space that you are now using for Tundra BOD.

An Electronic Copy of This Letter is Available on the C.L.E.A.N. Dealer website —
http://cleandealer.com
(This page intentionally left blank.)

10
[DEALER LETTERHEAD}

aaa ae ae eee ee

Re: NOTIFICATION OF INTENT TO CONDUCT CORROSION-RESISTANT COMPOUND
CAMPAIGN IN THE APPROVED SPRAYING AREA OF

Dear

Our dealership previously obtained your office's approval to conduct a Limited Service
Campaign ("LSC") for Tacoma vehicles at our facility located at [insert address]. As you may
recall, the Tacoma LSC involved the application of a Class IIIB corrosion-resistant compound
("CRC") to the interior of the vehicle's frame rails and a Class Il CRC to the exterior of the
vehicle's frame rails.

We contacted you last year to notify you that we would begin conducting a separate
CRC program for certain Model Year (MY) Tundra vehicles and would be applying a less
combustible, Class IIIB CRC material known as Noxudol 300 S$ to the exterior portion of the
frame. As we noted at the time, Noxudol 300 S has a much higher flash point (285°F) as
compared to the material used for the Tacoma LSC (Nox-Rust® X128T, which has a flash point
of 105°F). Noxudol 300 S also has the added advantage, from an environmental perspective, of
being much lower in volatile organic compounds (VOCs) than the X128T material.

ToyotaeBay logo has now expanded the CRC program to include certain additional vehicles, and
we intend to offer the expanded CRC program to our eligible customers. As with the Tundra
program, eligible vehicles will be treated with 712AM material and Noxudol 300 S$ or similar
Class IIIB liquids. Thus, the CRC program will involve application of only Class IIIB combustible

liquids.

We also wanted to take this opportunity to inform you that as a result of the Tacoma LSC
having expired on December 31, 2011, our dealership has discontinued the application of any
Class Il combustible liquids to ToyotaeBay logo vehicles and will only be applying Class IIIB combustible
liquids for the CRC program.

If you have any questions or require any additional information, please do not hesitate to
contact [Dealership] or [Number]. Thank you for your time and consideration.

Sincerely,

11
(This page intentionally left blank.)

12
()
SEQUOIA CORROSION-RESISTANT COMPOUND CAMPAIGN

OHIO DEALER INFORMATION PACKET

APPENDIX B — AIR RECORDKEEPING FORMS

Your dealership must maintain the records included in this Appendix to comply with state
regulatory recordkeeping and retention requirements. This Appendix contains new versions of
two forms that were included in the Tundra BOD Packet that you can use for both the Tundra
BOD and the Sequoia COD. (You no longer need to use the versions of these forms included in
the Tundra BOD Packet, but you must keep the previously completed forms on file for the
time period specified in the Tundra BOD Packet.)

1. "Ohio Sequoia and Tundra Daily Production Log." Use this form to track the number
of Sequoia and Tundra vehicles processed by your dealership and the daily VOC

and PM emissions produced by your dealership's CRC operations.

2. “Ohio Monthly BOD and COD Emissions Log." Use this form to record for each
month (1) the number of Sequoia and Tundra vehicles processed each day, (2) the
total emissions for each month, and (3) the gallons of each CRC used each month.

The Tundra BOD Packet contained several documents that your dealership must keep on file
along with the completed Production and Emissions Logs. You should continue to keep these
documents on file for both the Tundra BOD and Sequoia COD. If you cannot focate 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). You do not need to keep any additional
documents on file for the Sequoia COD.

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.

13
(This page intentionally left blank.)

14
Instructions for Completing the Qhio Sequoia and Tundra Daily Production Log

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

Maintain the completed logs in your dealership's records for a period of five years after the last day
that that you apply CRCs to a Sequoia or Tundra vehicle at your dealership.

Step 1:
Enter the “Reporting

Year" and = your

123

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