•  Evaluate each application to ensure there is a need for paint stripping (e.g., evaluate whether it is possible to re-coat the piece without removing the existing coating).
•  Evaluate each application where a paint stripper containing MeCl is used to ensure that there is no alternative paint stripping technology that can be used.
•  Reduce exposure of all paint strippers containing MeCl to the air.
•  Optimize application conditions when using paint strippers containing MeCl to reduce MeCl evaporation (e.g., if the stripper must be heated, make sure that the temperature is kept as low as possible to reduce evaporation).
• Practice proper storage and disposal of paint strippers containing MeCl (e.g., store stripper in closed, air-tight containers).
•  Maintain Annual Usage Records

AND

Paint Stripping Operations (Annual usage is >1 ton)

•  Develop a MeCl Minimization Plan
•  Post a Sign in the process area

Spray Painting of Motor Vehicles & Mobile Sources

•  All painters must be certified that they have completed training in the proper spray application of surface coatings and the proper setup and maintenance of spray equipment.
•  All spray-applied coatings must be applied in a spray booth, preparation station, or mobile enclosure
•  Booth must be fitted with a type of filter technology that is demonstrated to achieve at least 98-percent capture of paint overspray.
•  Spray booths and preparation stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed with a full roof, and four complete walls or complete side curtains, and must be ventilated at negative pressure so that air is drawn into any openings in the booth walls or preparation station curtains. However, if a spray booth is fully enclosed and has seals on all doors and other openings and has an automatic pressure balancing system, it may be operated at up to, but not more than, 0.05 inches water gauge positive pressure.
•  Spray booths and preparation stations that are used to coat miscellaneous parts and products or vehicle subassemblies must have a full roof, at least three complete walls or complete side curtains, and must be ventilated so that air is drawn into the booth. The walls and roof of a booth may have openings, if needed, to allow for conveyors and parts to pass through the booth during the coating process.
• All spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless spray gun, air-assisted airless spray gun, or an equivalent technology that is demonstrated by the spray gun manufacturer to achieve transfer efficiency comparable to one of the spray gun technologies listed above for a comparable operation
•  All paint spray gun cleaning must be done so that an atomized mist or spray of gun cleaning solvent and paint residue is not created outside of a container that collects used gun cleaning solvent. Spray gun cleaning may be done with, for example, hand cleaning of parts of the disassembled gun in a container of solvent, by flushing solvent through the gun without atomizing the solvent and paint residue, or by using a fully enclosed spray gun washer. A combination of non-atomizing methods may also be used.

•  Initial Notification
•  Notification of Compliance Status
•  Annual Notification of Change
•  MeCl Annual Usage Report (Annual usage > 1 Ton)

•  Certification that each painter has completed the training
•  Documentation of the filter efficiency of any spray booth exhaust filter material
•  Spray gun compliance certification
• Copies of all notifications and reports
•  Records of paint strippers containing MeCl used for paint stripping operations, including the MeCl content of the paint stripper used. Documentation needs to be sufficient to verify annual usage of paint strippers containing MeCl (e.g., material safety data sheets or other documentation provided by the manufacturer or supplier of the paint stripper, purchase receipts, records of paint stripper usage, engineering calculations).
•  If you are a paint stripping source that annually uses more than one ton of MeCl you are required to maintain a record of your current MeCl minimization plan on site for the duration of your paint stripping operations. You must also keep records of your annual review of, and updates to, your MeCl minimization plan.
•  Records of any deviation from the requirements.
• Records of any assessments of source compliance performed in support of the initial notification, notification of compliance status, or annual notification of changes report.