TOYOTA

TO: MINNESOTA 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

MINNESOTA 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 — i.e., 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 (hitp://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.

c. lf your dealership is not participating in the Tundra BOD or will not conduct
the Sequoia COD in the same spray space currentiy 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 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 permit issued by the
Minnesota Pollution Control Agency.

b. Your dealership will continue to keep its potential to emit ("PTE) of
Volatile Organic Compounds (“VOCs”) and Particulate Matter ("PM")
below the levels that would trigger air permitting — i.e., 100 tons per year
(“tpy”) for VOCs and 25 tpy for PM. Doing so should not pose an issue as
long as your dealership:
i. Does not operate a very large on-site or off-site body shop; and

ii. Does not otherwise engage in substantial painting, spraying or
other activities that use spray guns.

c. 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 Appendix C of this Packet for guidance on how to follow
these vehicle processing restrictions.

3. 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.

b. 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,

Cc. lf, 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.

d. Your dealership also must continue to comply with any additional

"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.
environmental, health, safety and zoning requirements identified for your
local jurisdiction in "Table 1" of the BOD Packet.

a. 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.

iii. 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.

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 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.
2. Comply with air recordkeeping obligations that apply to both the BOD and
the Sequoia COD by using the new 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 air recordkeeping obligations that apply to
CRC Campaigns.

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

: Appendix B to this Packet provides forms that you can use track the
number of vehicles processed under the Tundra BOD and the Sequoia
COD and resulting air emissions using the “Tundra and Sequoia Daily
Production Log.”

d. Your dealership should keep copies of documents that address the
guaranteed transfer efficiency of the Vaupel HSOR 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.

? 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.
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 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

MINNESOTA DEALER INFORMATION PACKET

APPENDIX A — FIRE OFFICIAL MODEL OUTREACH LETTER

The BOD Packet directed you to notify your local 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
BOD Packet. Please remember that you must send this letter before you begin conducting the
Sequoia COD.

Please note that the mode! 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 Toyota 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
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10
[DEALER LETTERHEAD]

[Insert Date] |

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 Mode! 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.

Toyota 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 $ or similar
Class IIIB liquids. Thus, the CRC program will involve application of only Class I!IB 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 I] combustible liquids to Toyota 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,
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12
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SEQUOIA CORROSION-RESISTANT COMPOUND CAMPAIGN COD

MINNESOTA 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 a new version
of the “Minnesota Sequoia and Tundra Daily Production Log” that was included in the
Tundra BOD Packet. Please use this updated form for both the BOD and the Sequoia COD
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. (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.)

The Tundra BOD Packet contained several documents that your dealership must keep on file
along with the completed Production and Usage Logs. You should continue to keep these
documents 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). 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.

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

Follow these 4 steps to complete the Minnesota 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 apply CRCs to a Sequoia or Tundra vehicle at your dealership.

Step 1: Step 2: Step 3: Step 4:
Enter the Enter the date and. Enter the time that you Locate the row that corresponds
“Reporting Year" the number of finished processing each to the number of Sequoias (down
and your Sequoias and , vehicle. To comply with the left side) and the column that
“Dealership Tundra vehicles air emissions limits, you corresponds to the number of
Name” at the top that you processed should not process more Tundras (across the top)
of the tog. 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:
JL / SEQUOIA \ / \TUNDRA Emissions
Use the Emissions
Date Nuptber Number Estimator to determine the
of Time of Completion of ime of Completion daily total
equoias Jf \ginares VOC (tbs) | PM (Ibs)
a
3-1-12 0 -- 2 2:30, 5:00 0.22 0.20
32-12 1 10:30 2 1:00, 3:15 0.38 0.31
=F
3-3-12 3 12:00, 2:15, 5:30 0 - ,| 0.48.7 0.33
3-4-12 2 3:00, 5:15 2 10:45,1:00,’ 944 0.42
é Z
35-12 2 11:15, 5:00 1 2:15 - -” 0.43 0.32
36-12 0 - 4 10:35, 12:50, 3:44, 5:45° | 0.44 0.40
7
4 —g§—_____ dt
‘ , ¢ . ui “
EMISSIONSESTIMATOR =,’ so’ f aa
¢ 7 a i - -
TUNDRAS ,’ |”) ae
eo tg
0 1 2 2 4 p27 &
SEquolas | 0 VOC =0 VOC =0.11 | VOC=0.22 | VGC=0.33 | VOC =0.44,) VOC = 0.55
PM =0 PM=0.10| PM=0.20| -PM=030]} PM=0.40| PM=0.50
4 | vOoC=016 | VoC=0.27 | VOC=0.38 |-voc=049 | VOC =060 | VOC=0.71
PM = 0.14 PM = 0.21 PM=0.31-[ PM=0.41 PM =0.51 PM = 0.61
2 {| voc=0.32 |] voc=043 | voc=0.54 | voc=065 | vOC=0.76 | VOC =0.87
PM=0.22 | PM=032/ PM=0.42| PM=0.52] PM=062] PM=0.72
3 | voc=0.48] voc=059 [ voc=070/ voc=081 | VOC=092 | VOC=1.03
PM=0.33 | PM=043| PM=0.53| PM=06.63] PM=0.73] PM=0.83
4 | voc=064/ voc=075 | voc=0.a6 | VOC=0.97 / VOC=108 | VOC=1.19
PM=0.44 | PM=0.54 | PM=0.64| PM=0.74] PM=0.84/ PM=0.94
§ | vOC=0.680/ voc=091 | vOC=1.02 [| voc=113 | VoC=124[ VOC=7.35
PM=0.55} PM=0.65/ PM=0.75} PM=085/ PM=095] PM=1.05