TRC RBD – Completeness & Approval of IDNR SLEIS CROMERR Application

TRC Recommended Basis of Decision --

Completeness & Approval of CROMERR Authorized Program Application 

October 29, 2015 

Authorized Program Applicant: Iowa Department of Natural Resources (IDNR) 

Application: IDNR State and Local Emissions Inventory System (SLEIS) application, submitted 

under Part 3 of the Cross-Media Electronic Reporting Regulation (CROMERR), received by 

EPA on September 22, 2015, for revision of the following authorized programs under 40 CFR: 

 Part 52 - Approval and Promulgation of Implementation Plans

 Part 70 - State Operating Permit Programs

For electronic reporting of the following: 

 51 - Voluntary Operating Permit Applications

 51.160(c), 51.160(c)(1), 51.160(c)(2), 52.21(n) - Construction Permit Applications

 51.211, 70.6(c)(1) - Title V Source Emissions Inventories

 70.5 (a), 70.5(c)(9), 70.6(c)(1) - Title V Operating Permit Applications – Part 1

 70.5 (a), 70.5(c)(9), 70.6(c)(1) - Title V Operating Permit Applications – Part 2

 Part 51, Subpart A, 51.211 - Minor Source Emissions Inventories

TRC Recommendation: The CROMERR Technical Review Committee (TRC) has reviewed 

the IDNR SLEIS application and determined that the SLEIS system, as described in the 

application, complies with the standards in 40 CFR Part 3, section 3.2000. The Committee 

recommends that EPA approve the Iowa Department of Natural Resources’ request for program 

revision, as provided in CROMERR section 3.1000(c), for the above listed authorized programs. 

EPA should notify the applicant of EPA’s determination of completeness and approval, and 

publish an approval notice in the Federal Register. TRC Contact: Karen Seeh, Tel # (202) 566-

1175, email seeh.karen@epa.gov. 

Basis of TRC Recommendation: The TRC determined the IDNR SLEIS system, as described 

in the submitted application, complies with the standards in CROMERR section 3.2000. This 

determination is based on the TRC’s review of IDNR’s SLEIS Part 3 application. 

Summary of TRC IDNR SLEIS Application Review

 During prior review of application for IDNR legacy air system replaced by SLEIS:

o June 10, 2010 – Iowa provides supplementary required application materials 

(Attorney General (AG) Certification received).

o June 14, 2010 – Office of General Counsel determines AG certification is not 

sufficient and follows up with Iowa AG.

o June 18, 2010 – Iowa’s response to EPA regarding AG certification is received 

and is satisfactory.
 June 2012 – Region 7 air program communicates that it is working with IDNR to revise 

its State Implementation Plan (SIP) so that it does not conflict with electronic reporting.

 2013-2015 – EPA consults informally with IDNR in the preparation of their SLEIS 

system and CROMERR application.

 September 22, 2015 – IDNR SLEIS amended application January 13, 2010 – IADNR 

application received for legacy Electronic System for Air Reporting (ESAR) system.

o Note this “amended” application reflects an entirely new system from the prior 

application.

 September 22, 2015 - October 22, 2015 – EPA 30-day Completeness Review for 

amended applications.

 9/22/15-10/21/15 – EPA reviews application for completeness and approval. And 

determines approvable.

 10/21/2015 – Per September 2015 TRC consensus, off-the-shelf system applications do 

not require a TRC vote.

 11/5/2015 – Discussion with Region 7 air program that they will approve Iowa’s 

proposed revisions to its SIP as soon as the CROMERR application is approved.

TBD – Agency concurrence obtained on TRC recommendation 

 TBD – EPA notifies applicant that application is approved 

 DATE – EPA approval made effective by publication of Federal Register notice 

Summary of IDNR SLEIS Application 

 Iowa Department of Natural Resources' (IDNR) State and Local Emissions Inventory

System collects emissions and other information from facilities within the State holding 

an air permit as mandated by Title V of the Clean Air Act and required under the State's 

EPA-authorized Air Permit Program.

 The Iowa Department of Natural Resources’ Air Quality Bureau (IDNR –– AQB) will 

be using the State & Local Emissions Inventory System (SLEIS) as its new system for 

receiving electronic air emission inventory reports. SLEIS was developed by a 

consortium of states and Windsor Solutions under an EPA Exchange Network Grant. It 

will allow regulated facilities and organizations to manage and submit point source 

emissions inventory data to IDNR –– AQB using a web-based, CROMERR-compliant 

system.

SLEIS includes an integrated Exchange Network Node Client interface to generate 

facility inventory and point source emissions submissions and transmit them to EPA’s 

Emissions Inventory System (EIS).