TRC RBD

– Comple teness & Approval of IDNR SLEI S CROMERR Application **TRC Recommended Basis of Decision --**  **Completeness & Approval of CROMERR Authorized Program Application October 29, 2015**  **Authorized Program Applicant:** Io wa Department of Natural Resources (IDNR) **Application:** ID NR State and Local Em issions Inventory S ys tem ( SL EI S) application, submitted under Part 3 of the Cross - Media Electronic Reporting Regulation (CROMERR), rec eived b y EPA on September 22, 2015, for revision of the following authorized program s under 40 CFR:
 Part 52 - Approval and Promulgation of Implementation Plans  Part 70 - State Operating Permit Programs For electronic r eporting of the following :  51 - Voluntary

Operating Permit Applications  51.1 60(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) - Ti tle V Operating Permit Applications

– Part 2  Part 51, Subpart A, 51.211 - Minor Source Emissions Inventories **TRC Recommendation:** The CROMERR Technical Review Committee (T RC) has reviewed the IDNR SLEI S applicatio n and determined that the SLEI S sy stem, as d escribed in the application, complies with the standards in 40 CFR Part 3, section 3.2000. The Committee recommends that EPA approve the Iowa D epartment of Natural Resources’ request for program revision, as provided in CROMERR section 3.1000(c), for the a bove 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:**  Th e TRC determined the IDNR SLEI S sy stem, 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 SLEI S Part 3 application. **Summary of TRC IDNR**  **SLEIS Application Review**
 During prior review of application for IDNR legacy air sy stem replaced b y SLEI S: o June 10, 2010

– Io wa 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 I owa AG. o June 18, 2010

– Io wa’s response to EPA regarding AG certification is received and is satisfactory . June 2012

– Region 7 air program communicates that it i s 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 SL EI S sy stem and CROMERR application.  September 22, 2015

– I DNR SL EI S amended application January 13, 2010

– IADNR application received for legacy Electronic S ys tem for Air Reporting (ESAR) sy stem . o Note this “amended” application reflects an entirely new s ys tem 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 sy stem applicatio ns 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 no tifies applicant that application is approved  DATE

– EPA approval made effective b y publication of Federal Register notice **Summary of IDNR SLEIS Application**   Io wa Department of Natural Resources' (I DNR) State and L ocal Emissions Inventory Sy stem 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 Bure au (IDNR

–– AQB) will be using the State & Local Emissions Inventory Sy stem (SLEIS) as its new sy stem for receiving electronic air emission inventory reports. SL EI S 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 sy stem. SLEI S includes an integrated Exchange Network Node Client interface to gener ate facility inventory

and point source emissions submissions and transmit them to EPA’s Emissions Inventory

S ys tem (EI S).