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 procedure N/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 averaging N/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 for Section 1.5

rulemaking?

b. Are methods/rules N/A

incorporated by reference

in the right manner.

5. Record Keeping

a. What records are required N/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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