SIP Package No. ___________________ Date Rec. _______________________ Date Due __________________ (For USEPA Use Only) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY SIP APPROVABILITY CHECKLIST-ENFORCEABILITY

District: _Monterey Bay Unified APCD________ Rule No.: 205_________ Date Adopted or Amended: 3/21/01_______________ Rule Title: _Provisions of Sampling and Testing Facilities_________________________________________________________________

Enforceability Analysis District Response EPA Requirement (For EPA Use Only) Approvability (Approvable or Not)

1.Applicability

a. What sources are being Section 1.2 Clarity regulated? b.What are criteria for Section 1.3 Clarity exemption?

c. Is calculation procedureN/A Example calculation or clear for exemption clearly explanation of how to specified? determine exemption (line by line, etc.) d. Is emission inventory N/A Inventory including listed in the background allowable and actual document of the emissions in source category attainment should be included, for demonstration? enforcement purposes and independent of any Clean Air Act requirements, in the attainment demonstration if such data is necessary for determining baselines in regulations.Enforceability Analysis District Response EPA Requirement (For EPA Use Only) Approvability (Approvable or Not)

e. Is the averaging time(s)N/A The averaging time in the used in the rule different rule must be consistent with from that of the ambient protecting the ambient standard? standard in question. Normally, it should be equal to or shorter than the time associated with the standard. Longer term averaging is available only in limited instances provided that the ambient standard is not compromised. f. What are the units of N/A Clearly stated in the rule. compliance (lbs VOC per gallon of solids applied less water, grains per standard cubic foot?) g. Is bubbling or averagingN/A Explicit description of how of any type allowed? If averaging, bubbling, or yes, state criteria. Could a equivalency is to be U.S. EPA inspector determined. VOC independently determine equivalency must be on a if the criteria were met? “solids applied” basis. Any Does EPA have to method must be approve each case? independently reproducible. Provision must be explicit as to whether EPA case-by-case approval is required. If provision intended to be “generic” then EPA bubble policy must be met.Enforceability Analysis District Response EPA Requirement (For EPA Use Only) Approvability (Approvable or Not)

h. If there is a redesignation,No Regulation may not will this change the automatically allow for self emission limitations? If nullification upon yes, which ones and how? redesignation of area to attainment. New maintenance demonstration required in order to drop regulation. 2. Compliance Dates

a. What is the compliance N/A Must not be later than date? approved or about to be approved date of attainment unless emission reductions not necessary for attainment. In some cases, it will be necessary for the regulation to specify dates in compliance schedules that are required to be submitted by source to state. b.What is the attainment 1/17/97 date? 3. Specificity of Conduct

a. What test method is N/A Test method must be required? explicitly stated. b.What is the averaging N/A Averaging time and time in compliance test application of limit must be method? explicit.

c. Is a compliance N/A calculation or evaluation required? (i.e., daily weighted average for VOC).Enforceability Analysis District Response EPA Requirement (For EPA Use Only) Approvability (Approvable or Not)

d. If yes to “c”, list the N/A Formula must be explicit. formula, period of compliance, and/or evaluation method. 4. Incorporation by Reference

a. What is state authority forSection 1.5 rulemaking? b. Are methods/rules N/A incorporated by reference in the right manner. 5. Record Keeping

a. What records are requiredN/A Clarity. to determine compliance? b. In what form or units N/A Records to be kept must be (lbs/gal, gr/dscf, etc.) consistent with units of must the records be kept? compliance in the On what time basis performance requirements, (instantaneously, hourly, including the applicable time daily)? period.

c. Does the rule N/A There must be a clear, affirmatively require the separately enforceable records be kept? provision that requires records to be kept. 6.Exemptions

a. List any exemptions Section 1.3 Must be clearly defined and allowed. distinguishable from what constitutes a violation. b. Is the criteria for Section 1.2 application clear?Enforceability Analysis District Response EPA Requirement (For EPA Use Only) Approvability (Approvable or Not)

7.Malfunction Provisions N/A Rule must specify what exceedances may be excused, how the standard is to be applied, and who makes the determination.

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