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NHTSA ID Number: 10134050

Manufacturer Communication Number: Wisconsin C0D Pa

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: WISCONSIN 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

WISCONSIN 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 — 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 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.

c. If 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 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
Wisconsin Department of Natural Resources (“WONR’).

b. Your dealership will continue to keep its total actual emissions of Volatile
Organic Compounds ("VOCs") and Particulate Matter ("PM") below the
levels that would trigger air permitting - ie., 10 tons per year (“tpy*) of
VOCs and 10 tpy of PM. These levels apply to all operations across your
entire dealership, including the Sequoia COD, the Tundra BOD and all
other air emitting activities.

iy TMS has contacted WDNR and explained Sequoia COD and its air
emissions. WDNR has issued a determination that COD will not
require an air permit based upon an understanding that total
actual air emissions at each ToyotaeBay logo dealership in Wisconsin are
less than 10 tpy of VOCs and 10 tpy of PM. (Appendix A contains
a copy of this determination.)

ii, Keeping total actual emissions below these levels should not pose
an issue as long as your dealership:

(1) Does not operate a very large on-site or off-site body
shop; and

(2) 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 B of this Packet for guidance on how to follow
these vehicle processing restrictions.

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. 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.

c. 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.

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.

"If you are facing this situation, or if 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 the 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
simpler 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 C.LEAN. Dealer website
(bttp://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.

Z.. Comply with air recordkeeping obligations that apply to both the BOD and
the Sequoia COD by using the new forms provided in Appendix A 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.”

Cy Appendix A to this Packet provides forms that you can use to meet these
obligations as follows:

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".

? 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 generale hazardous waste or impact your dealership's
hazardous waste generator status.

6

ii, Record the total volume of VOC-containing materials used by your
dealership on a yearly basis and your dealership's actual annual
VOC emissions using the "VOC-Containing Materials Usage Log".

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.

Your dealership should also keep a copy of the letter from the Wisconsin
Department of Natural Resources, dated April 19, 2012, confirming that
the Sequoia COD is exempt from air permitting requirements in
Wisconsin. A copy of this letter is included in Appendix A.

Comply with the annual emissions inventory report requirement, if
applicable to your dealership. Wisconsin imposes an annual emissions
inventory report requirement, separate from its air permitting requirements, on
sources that emit more than 6,000 pounds per year of VOCs. This 6,000 pounds
level applies to all operations across your entire dealership, including the
Sequoia COD, the Tundra BOD and all other air emitting activities.

Based on typical dealership operations, TMS does not anticipate that the
Sequoia COD, when added to other air emitting activities at your
dealership, will cause your dealership to exceed the 6,000 pounds per
year emission level.

However, you should evaluate whether your dealership’s actual
emissions of VOCs, including the Sequoia COD, do or might exceed
6,000 pounds per year by using the “VOC-Containing Materials Usage
Log” in Appendix A.

You may call the EH&S Hotline (877-572-4347) for assistance with
calculations specific to your dealership and to evaluate whether your
dealership must comply with this reporting requirement.

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 80D 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.

SEQUOIA CORROSION-RESISTANT COMPOUND CAMPAIGN

WISCONSIN DEALER INFORMATION PACKET

APPENDIX A —- AIR RECORDKEEPING FORMS

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. ‘Wisconsin Sequoia and Tundra Daily Production Log" A new “Vermont 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.)

2. “Wisconsin VOC-Containing Materials Usage Log" Use this form to track your
dealership's usage of VOC-containing materials and to calculate your dealership's

total annual VOC emissions. You can use this form to demonstrate that your
dealership does not produce more than 6,000 pounds of VOC emissions per year,
and therefore does not trigger Wisconsin’s annual emissions inventory report
requirement. Note that this form calculates your dealership’s estimated actual VOC.
emissions from the use of non-CRC materials based on a conservative assumption
that the VOC content of those materials will not exceed an average of 7 pounds per

gallon.

3. Letter issued by WDNR This letter, dated April 19, 2012, confirms that the Sequoia
COD is exempt from air permitting requirements in Wisconsin.

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.

(This page intentionally left blank)

10

instructions for Completing the Sequoia and Tundra Daily Production Loq

Follow these four (4) steps to complete the Wisconsin 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
that you apply CRCs to a Sequoia or Tundra vehicle at your dealership.

Step 1:
Enter the

“Reporting
Month and Year”
and your
“Dealership
Name” at the top
of the log.

Step 2:

Enter the date and
the number of
Sequoia and
Tundra vehicles
that you processed
on that date.

Step 3:

Enter the time that you
finished processing each
vehicle. To comply with
air emissions limits, you
should not process more
than one vehicie (Sequoia
or Tundra) every two
hours.

Step 4:

Locate the row that corresponds to the
number of Sequoias (down the left side)
and the column that corresponds to the
number of Tundras (across the top)
processed each day. Enter the values in
the box where the row and column
intersect in the production lag to record
the amount of VOC and PM emissions
produced on that day. At the end of

123

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