MEMORANDUM 

SUBJECT: Technical Support Document for Approval to the Iowa State Implementation Plan (SIP); 

Grain Vacuuming Best Management Practices (BMPs) and Rescission Rule 

FROM: Heather 

AWMD/APDB/CP-PS 4"elf5 

TO: IA-169 & IA-170 

THRU: Michael Jay, Chief 

AWMD/APDB/AtPS 

Joshua Tapp 

AWMD/APDB 

The revisions in this SIP action are from two separate submissions from the Iowa Department of Natural 

Resources (IDNR) and are amending BMPs for grain vacuuming operations at Group 1 grain elevators 

(IA-169), revising definitions, revising requirements for Department forms, and rescinding rule 

requirements and references for conditional permits (IA-170). Tables with the rulemaking timelines are 

on page 3 of this document. 

The following Chapters will be revised with this action: Iowa Administrative Code, Chapter 20, "Scope 

of Title- Definitions- Fonns- Rules of Practice," Chapters 22, "Controlling Pollution," Chapter 31, 

"Nonattainrnent Areas," and Chapter 33, "Special Regulations and Construction Permit Requirements 

for Major Stationary Sources - Prevention of Significant Deterioration (PSD) of Air Quality." 

Submission 1: On November 20, 2014, IDNR submitted a SIP revision to 22.1 0(3) "a" (2), to revise the 

BMPs for Group 1 grain elevators to include grain vacuuming operations. Group 1 grain elevators are 

country grain elevators, country grain terminal elevators, or grain terminal elevators with the potential to 

emit less than 15 tons ofPM10 per year. Existing Group 1 facilities are those that commenced 

construction or reconstruction before February 6, 2008; new facilities are those that commenced 

construction after February 6, 2008. 

Printed on Recycled Paper 
shall fully implement applicable BMP, except that BMPs for grain vacuuming operations shall be fully 

implemented no later than September 10, 2014. Upon startup of equipment at the facility, the owner or 

operator of a new Group 1 facility shall fully implement applicable BMP. 

Additional background information for this rule revision is included on pages 3 thru 5 of the November 

10, 2014, submission. The revised BMPs were included in the submission to include grain vacuuming 

operations, as well as recording requirements. 

Submission 2: On April24, 2015, IDNR submitted a SIP revision to revise the definition of volatile 

organic compounds (VOC) in 567 lAC Chapters 20 and 33, to rescind unnecessary rules, and update 

other rules to reduce regulatory requirements. 

20.2 (definitions): "Volatile organic compounds" or "VOC" means any compound included in the 

definition of"volatile organic compounds" found at 40 CFR 51.100(s) as amended through January 21, 

2-009-March 27. 2014. 

20.3 -Air quality forms generally: With this rulemaking, this section has been rescinded and reserved 

to eliminate obsolete and duplicative references to air quality forms. 

Conditional permits were added to the Iowa Code in the 1970s to facilitate electric utility rate setting. 

The Iowa Utilities Board changed the rate setting requirements so that conditional permits were not 

needed. The Department has no record of issuing a conditional permit to an electric facility; therefore, 

references to conditional permits have been removed from the following: 

22.1(1) Permit required;22.1(3) Construction permits; 22.2(2) Public notice and participation; 22.2(3) 

Final notice; 22.3(1) Stationary sources other than anaerobic lagoons (introductory paragraph); 22.3(3) 

(Conditions of approval) "g", and 22.3(4) "a". 22.1(4) Conditional Permits, and 22.3(3) Conditions of 

Approval, "d" which describes the submittal requirements of conditional permits have been rescinded in 

their entirety and reserved. 

The revision to Chapter 31 (Special requirements for nonattainment areas designated before May 18, 

1998) removes the reference to conditional permits at 31.20(1)"m"- "Enforceable permit condition." 

Revisions to Chapter 33 (Special construction permit requirements for major stationary sources in areas 

designated attainment or unclassified (PSD)) at 33.3 removes references to conditional permits in the 

definitions of"Enforceable permit condition," and revises the definition of"volatile organic 

compounds," consistent with the revision at 20.2. 

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Rule package received by EPA November 20,2014 

Completeness determination January 20, 2015 

Submission 2: 

Record ofRulemaking 

Iowa Department ofNatural Resources 

Notice of Intended Action December 24, 2014 

Public Hearing January 26,2015 

Effective date of regulations April 22, 2015 

Rule package received by EPA May 4, 2015 

Completeness determination May 5, 2015 

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