## ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NORTH GRAND AVENUE EAST, P.O. BOX 19276, SPRINGFIELD, ILLINOIS 62794-9276 • (217) 782-3397 PAT QUINN, GOVERNOR JOHNJ. KIM, INTERIM DIRECTOR
217/782-5544 217/782-9143 (TDD)

June 20, 2012

Susan Hedman, Regional Administrator United States Environmental

ProtectionAgency Region V 77 West Jackson Boulevard, AR-18J Chicago, Illinois 60604-3598 Attn: George Czerniak CERTIFIED MAIL RETURN RECEIPT REQUESTED 7009 2820 0001 7496 1268

Re: AS 11-01: In the Matter of: Petition ofGreifPackaging, LLC for an Adjusted Standard from 35 Ill Adm. Code Part 218, Subpart TT Dear Ms. Hedman: Pursuant to Section 110(a)(2) ofthe Clean Air Act (CAA) (42 U.S.C. §7410 (a)(2)), and Section 28 ofthe Illinois Environmental Protection Act (415 ILCS 5/28), the Illinois Environmental ProtectionAgency (Illinois EPA) submits the following amendments to the Illinois State Implementation Plan (SIP). The amendment reflects an adjustment to the general rule due to the extenuating circumstances ofGreifPackaging, LLC ("Greif'). Thepetitionfor anadjusted standardwas docketedbythe Illinois PollutionControlBoard (IPCB) as AS 11-01. ApublichearingwasheldDecember 20,2011, inChicago, Illinois. TheIllinois EPA:filed no post-hearing comments but did file answers to questions posed at hearing. OnApri15, 2012, the Board adopted a Final Opinion and Order.

Inorderto assist withyourreview ofthis SIP submittal, the following documents are enclosed and an electronic disc is included which contains identical copies ofthese documents: Attachment 1) The petition ofGreiffor an adjusted standard, filed onJanuary 24, 2011.

4302 N. Main St., Rockford, IL 61 103 (815)987-7760 595 S. State, Elgin, IL 60123 (847)608-3131 2125 S. First St., Champaign, IL 61820 (217)278-5800 2009 Mall St., Collinsville, IL 62234 (618)346-5120 PLEASE PRINT ON RECYCLED PAPER 9511 Harrison St., Des Plaines,IL 60016 (847)294-4000 5407 N. University St., Arbor 113, Peoria, IL 61614 (309)693-5462 2309 W. Main St., Suite 116, Marion, IL 62959 (618)993-7200 100 W. Randolph, Suite 11-300, Chicago, IL 60601 (312)814-6026Attachment 2) Attachment 3) Attachment 4) Attachment 5)
Attachment 6) Attachment 7)
Attachment 8) Attachment 9)
Attachment 10) Attachment 11) Attachment 12) Attachment 13) Attachment 14) Attachment 15)
Attachment 16)
Attachment 17) Attachment 18)
Attachment 19) Attachment 20) ProofofFiling, filed February 10, 2011. Board Order, filed onMarch 17, 2011. Board Hearing Officer Order, filed onMarch 21, 2011. Petitioner's First Amended Petition for anAdjusted Standard, filed May 31,2011. ProofofFiling, filed June 17, 2011. Petitioner's Second Amended Petition for anAdjusted Standard, filed August 10, 2011. ProofofFiling, filed August 30, 2011. Recommendation ofthe Illinois Environmental Protection Agency, filed October 11, 2011 Submission ofAir Quality Analysis, filed onNovember 1, 2011. Board Order, Notice ofHearing, filed onNovember 8, 2011 Board Hearing Officer Order, filed onNovember 8, 2011 Notice ofPublication, Filed November 18, 2011 Transcript ofHearing Held onJanuary 5, 2012. · Redacted Submission ofNon-Disclosable Information, filed December 8, 2011 Application for Treatment as Non-Disclosable Information, filed December 20,2011 Board Hearing Officer Order, filed January 10, 2011. Illinois EPA Answers to Illinois Pollution Control Board Questions at Hearing, filed January 12, 2012. Post-Hearing BriefofPetitioner, filed January 26, 2011. Order ofIllinois Pollution Control Board Granting Petitioner's Adjusted Standard, filed April 5, 2012.The SIP Checklists are also enclosed to assist in your review. Iffurther information is required, please contact Vicky Von Lanken ofmy staffat 21 7/782-7001

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# ~ Bureau ofAir AttachmentsSTATE IMPLEMENTION PLAN CHECKLISTS
AS 11-01: In the Matter of: Petition ofGreifPackaging, LLC for an Adjusted Standard from 35 Ill Adm. Code Part 218, Subpart TT

Illinois Environmental Protection Agency Bureau ofAir Division ofLegal Counsel 1021 North Grand Ave. East P.O. Box 19276 Springfield, Illinois 62794-9276'>:,> '::< 

### :ADMINISTRATIVE CHECKLIST : ' ;' c,,''' "'<:>' 'c,' ',**~** ', ; Re: AS 11-01 Attachment 1. The Submittal is accompanied by a formal letter of Yes, Cover submittal from the Governor or designee. letter The date ofsubmittal is June 20, 2012 2. Evidence is provided that the revision has been adopted in NIA the State Code or body ofregulations. 

## • The date ofadoption is Aprill5, 2012
. 

## • Test methods/rules are correctlyincorporated by N/A reference 3. Evidence is provided that the Statehas the necessary legal Sections 28 of authorityunder State law to adopt and implement the the Ill. Env
. 

### . . Prot. Act reVISIOn 4. A copyofthe actual regulation or document is included in 1,20 the submittal 5. Evidence is provided that the State followed all the 1,2, requirements ofits Administrative procedures Act (or 5,6,7,8,9,11, equivalent) in conducting and completing adoption/issuance 13,14,15,17, oftherevision. 20 6. Evidence is provided that public notice was givenbythe 2,4,6,8, 11' 13, State, including the date ofpublication. 17,20 7. Certification is provided that the public hearing was held in 11,14,17 accordance with the informationprovided in the public notice. The date ofthe public hearing was January 5, 2012 8. The submittal contains a compilation ofthe exhibits entered 14,15,16,17 into the record at hearing. 9. The submittal contains a compilation ofpublic comments N/A.·.. ,. ,, . .· : 

### .... TECHNICAL CHECKLIST . :·>'

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# . .. Re: AS 11-01 Attachment 1. The regulated pollutants affected byrevision are: sulfur dioxide
__ ; ozone

### ____x_; particulate matter __ ; 1 nitrogen oxides ; carbon monoxide 2. Attainment status designation for the affected area is 1,5,7,20 included in the submittal. Status ofthe attainment plan for the affected area is 20 included in the submittal. The attainment date for the affected area is included in the N/A submittal. 3. The locations and types ofaffected sources are identified. 1, 5, 7, 20 4. Changes in SIP-allowable emissions for affected sources are 1, 5, 7, 10, 20 quantified or estimated. Changes in actual emissions from affected sources are 1, 5, 7, 10, 20 quantified or estimated. 5. Evidence is provided that the NAAQS will beprotected if 20 the revision is approved and implemented. Evidence is provided that the PSD increment will be 20 protected ifthe revision is approved and implemented. Evidence is provided that the RFP demonstration will be N/A protected ifthe revision is approved and implemented. Evidence is provided that visibility will be protected ifthe 20 revision is approved and implemented. 6. Modeling information is provided (ifnecessary) in support 1, 5, 7, 10, 20 ofthe revision. 7. The proposed emission limitations are based on continuous N/A emissions reduction technology. 8. The emissions limitations requirements are incorporated (if N/A necessary) to ensure emission levels. The work practice standards requirements are incorporated N/A (ifnecessary) to ensure emission levels. The recordkeeping/reporting requirements are incorporated 20 (ifnecessary) to ensure emission levels. 9. The submittal contains enforcement/compliance strategies, N/A including how compliance will be determined in practice and at what frequency.· .. ; : i 

### ENFORCEABILITYCHECKLlST ..

. >:, ......:\ ·:. Re: AS 11-01 Attachment 1. A:tmlicability What sources are being regulated? 1, 5, 7 What are criteria for exemption? N/A Is calculationprocedure for exemption clearly specified? N/A Is emission inventorylisted in the background document of N/A the attainment demonstration? Are the averaging times used in the rule different from N/A those ofthe ambient standard? What are the units ofcompliance (lbs VOC per unit of N/A volume; pounds VOM per month) Is bubbling or averaging ofanytype allowed? Ifyes, state No criteria. Could a USEPA inspector independently determine ifthe criteria were met? Does EPAhave to approve each case? Ifthere is a redesignation, will this change the emission No limitations? Ifyes, which ones and how? 2. Com12liance Dates What is the compliance date? 20 What is the attainment date? N/A 3. S12ecificity ofConduct What test method is required? 20 What is the averaging time in compliance test method? N/A Is a compliance calculation or evaluationrequired? (i.e., N/A daily weighted average for VOC) lfyes, list the formula, period ofcompliance, and/or N/A evaluationperiod. 4. Inco;morationbyReference What is the state authority for rulemaking? Section28 ofthe Ill. Env. Prot. Act Are methods/rules incorporated byreference in the right N/A manner? 5. Recordkee12ing What records are required to determine compliance? 20 In what form orunits (lbs/gal, gr/dscf, etc...) must the Tons/month, records be kept? On what time basis (instantaneously, monthly and hourly, daily)? annual Does the rule affirmatively require the records be kept? yes 6. Exem12tion List any exemptions allowed. N/A Is the criteria for application clear? N/A