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 

Protection Agency 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 of Greif Packaging, 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 

Protection Agency (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'). 

The petition for an adjusted standard was docketed by the Illinois Pollution Control Board (IPCB) as 

AS 11-01. A public hearing was held December 20,2011, in Chicago, Illinois. The Illinois 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. 

In order to assist with your review ofthis SIP submittal, the following documents are enclosed and an 

electronic disc is included which contains identical copies of these documents: 

Attachment 1) The petition of Greif for an adjusted standard, filed on January 24, 2011. 

4302 N. Main St., Rockford, IL 61 1 03 (815)987 -77 60 

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 1 13, Peoria, IL 61614 (309)693-5462 

2309 W. Main St., Suite 116, Marion, IL 62959 (618)993-7200 

100 W. Randolph, Suite 1 1-300, Chicago, IL 60601 (312)814-6026 
Attachment 2) 

Attachment 3) 

Attachment 4) 

Attachment 5) 

Attachment 6) 

Attachment 7) 

Attachment 8) 

Attachment 9) 

Attachment 1 0) 

Attachment 11) 

Attachment 12) 

Attachment 13) 

Attachment 14) 

Attachment 15) 

Attachment 16) 

Attachment 1 7) 

Attachment 18) 

Attachment 19) 

Attachment 20) 

ProofofFiling, filed February 10, 2011. 

Board Order, filed on March 17, 2011. 

Board Hearing Officer Order, filed on March 21, 2011. 

Petitioner's First Amended Petition for an Adjusted Standard, filed May 

31,2011. 

Proof ofFiling, filed June 17, 2011. 

Petitioner's Second Amended Petition for an Adjusted Standard, filed 

August 10, 2011. 

Proof of Filing, filed August 30, 2011. 

Recommendation of the Illinois Environmental Protection Agency, filed 

October 11, 2011 

Submission of Air Quality Analysis, filed on November 1, 2011. 

Board Order, Notice ofHearing, filed on November 8, 2011 

Board Hearing Officer Order, filed on November 8, 2011 

Notice ofPublication, Filed November 18, 2011 

Transcript of Hearing Held on January 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 Brief of Petitioner, filed January 26, 2011. 

Order of Illinois Pollution Control Board Granting Petitioner's Adjusted 

Standard, filed April 5, 2012. 
The SIP Checklists are also enclosed to assist in your review. 

If further information is required, please contact Vicky Von Lanken of my staff at 21 7/782-7001 

-

c~r.diann \ ~(/(· 0. ~ 

L~el L. Kroa~k, Chief ~ Bureau of Air 

Attachments 
STATE IMPLEMENTION PLAN CHECKLISTS 

AS 11-01: In the Matter of: Petition of Greif Packaging, LLC for an Adjusted Standard 

from 35 Ill Adm. Code Part 218, Subpart TT 

Illinois Environmental Protection Agency 

Bureau of Air 

Division of Legal 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 of submittal is June 20, 2012 

2. Evidence is provided that the revision has been adopted in NIA 

the State Code or body of regulations. 

• The date of adoption is Aprill5, 2012 . 

• Test methods/rules are correctly incorporated by N/A 

reference 

3. Evidence is provided that the State has the necessary legal Sections 28 of 

authority under State law to adopt and implement the the Ill. Env . . . reVISIOn Prot. Act 

4. A copy ofthe actual regulation or document is included in 1,20 

the submittal 

5. Evidence is provided that the State followed all the 1,2, 

requirements of its Administrative procedures Act (or 5,6,7,8,9,11, 

equivalent) in conducting and completing adoption/issuance 13,14,15,17, 

ofthe revision. 20 

6. Evidence is provided that public notice was given by the 2,4,6,8, 11' 13, 

State, including the date of publication. 17,20 

7. Certification is provided that the public hearing was held in 11,14,17 

accordance with the information provided in the public 

notice. 

The date of the public hearing was January 5, 2012 

8. The submittal contains a compilation of the exhibits entered 14,15,16,17 

into the record at hearing. 

9. The submittal contains a compilation of public comments N/A 
.· .. ,. ,, . .· : .... TECHNICAL CHECKLIST . :·>' 

. . .. 

Re: AS 11-01 Attachment 

1. The regulated pollutants affected by revision 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 of the 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 of affected 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 be protected if 20 

the revision is approved and implemented. 

Evidence is provided that the PSD increment will be 20 

protected if the revision is approved and implemented. 

Evidence is provided that the RFP demonstration will be N/A 

protected if the revision is approved and implemented. 

Evidence is provided that visibility will be protected if the 20 

revision is approved and implemented. 

6. Modeling information is provided (if necessary) in support 1, 5, 7, 10, 20 

of the 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 

(if necessary) to ensure emission levels. 

The recordkeeping/reporting requirements are incorporated 20 

(if necessary) 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 calculation procedure for exemption clearly specified? N/A 

Is emission inventory listed 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 of compliance (lbs VOC per unit of N/A 

volume; pounds VOM per month) 

Is bubbling or averaging of any type allowed? If yes, state No 

criteria. Could a USEP A inspector independently 

determine if the criteria were met? Does EPA have to 

approve each case? 

If there is a redesignation, will this change the emission No 

limitations? If yes, which ones and how? 

2. Com12liance Dates 

What is the compliance date? 20 

What is the attainment date? N/A 

3. S12ecificity of Conduct 

What test method is required? 20 

What is the averaging time in compliance test method? N/A 

Is a compliance calculation or evaluation required? (i.e., N/A 

daily weighted average for VOC) 

lfyes, list the formula, period of compliance, and/or N/A 

evaluation period. 

4. Inco;moration by Reference 

What is the state authority for rulemaking? Section 28 of the Ill. 

Env. Prot. Act 

Are methods/rules incorporated by reference in the right N/A 

manner? 

5. Recordkee12ing 

What records are required to determine compliance? 20 

In what form or units (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