OFFICE OF
                          ENVIRONMENTAL
                          INFORMATION
                                                                           February 2009
For More Information on
this Application Contact:

Tom Copeland
Oklahoma Department of
Environmental Quality
tom.copeland@deq.ok.gov
405.702.7103

For More Information on
CROM ERR Contact:

Evi Huffer
Office of Information Collection
huffer.evi@epa.gov
202.566.1697

David Schwarz
Office of Information Collection
schwarz.david@epa.gov
202.566.1704

http://www.epa.gov/cromerr/
    Oklahoma Department of Environmental

        Quality CROMERR Success Story
On September 26, 2008, the Oklahoma Department of
Environmental Quality (OKDEQ) received official approval from EPA,
under the Cross-Media Electronic Reporting Regulation (CROMERR),
for modifications/revisions to multiple authorized programs to allow
electronic reporting for their Electronic Document Receiving System
(ERDS). EPA announced its approval in a Federal Register notice
published shortly thereafter (73 FR 58587, October 7, 2008).
OKDEQ submitted a consolidated CROMERR compliance application
covering program modifications and  revisions for multiple authorized
programs under 40 CFR for air, waste and water programs, including
existing electronic document receiving  systems that accept reports
with electronic signatures and "priority reports". OKDEQ used a
unified approach to meet CROMERR requirements that encompasses
all applications and  programs within  an entity that is operating
delegated programs. Under this approach, compliance with the
requirements of CROMERR becomes  a single, unified, and consistent
effort, independent of the various programs and their supportive
software applications. This approach  provides a  number of
advantages, including lower cost, faster implementation, and a single
compliance infrastructure to understand, support, and maintain.
EDRS  is designed to be an agency-wide system, extensible to any
and all program  areas.

The Oklahoma Solution to Meeting CROMERR
Requirements
OKDEQ developed and implemented  the ERDS as an organization-
independent, complete solution to the receipt of electronic
documents. ERDS is a web portal based document management
system that provides repository, management auditing and retrieval
features through an intuitive, easy to learn but highly secure user
interface. OKDEQ also incorporated advanced workflow, routing, and
application integration features into their system. EDRS uses a public
key infrastructure (PKI) based signature approach,  including the use
of a challenge question and response methodology intended to
obtain signature validations required under the rule. Representatives
of regulated entities, usually referred to as signatories, navigate to
the  portal, sign in, answer questions  that validate their identity, and
submit digitally signed documents to the system. These documents
are  then validated, stored, and routed to the appropriate authority
within the agency for acceptance or rejection.

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