ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST, P.O. Box 19276, SPRINGFIELD, ILLINOIS 62794-9276 - ( 217) 782-2829

JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601 - (312) 814-6026

PAT QUINN, GOVERNOR DOUGLAS P. SCOTT, DIRECTOR

217/782-5544

217/782-9143 (TDD)

July 17, 2009 JUL 22 2009

Ii ~.:RfiNfC8GE·r=,'.~_~".!,,'"t. f~RTIFIED MAIL

! U.S.EPi\:-R,;m:CflDElj'"' -'I ~TURN RECEIPT REQUESTED

~7007 3020 0002 3214 3756

Cheryl Newton, Director

Air and Radiation Division

United States Environmental

Protection Agency Region V

77 West Jackson Boulevard, AR-18J

Chicago, Illinois 60604-3598

Attn: Jay Bortzer

Re: AS 08-8: In the Matter of: Abbott Laboratories' Proposed Site-Specific Amendment to

Applicability Section ofOrganic Material Emission Standards and Limitations for the

Chicago Area: Subpart T: Pharmaceutical Manufacturing (35 Ill. Adm. Code

218..480(b))

~C4e;:;i I Dear.~v'''-!Pn:

Pursuant to Section llO(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).

On September 4,2007, Abbott Laboratories (Abbott) filed a proposal of amendments with the

Illinois Pollution Control Board (IPCB). Notice ofHearing was filed on January 31,2008. A

public hearing was held March 7, 2008, in Libertyville, Illinois. The Illinois EPA filed posthearing comments in support ofthe proposed amendments. On August 21, 2008, the IPCB

adopted a Final Opinion and Order granting Abbott's proposed amendments to 35 Ill. Adm. Code

218.480(b).

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

Attachment 1) Abbott's Proposal of Amendments, filed September 4,2007

ROCKFORD - 4302 North Main Street, Rockford, IL 61103 - (815) 987-7760 • DES PLAINES - 9511 W. Harrison St., Des Plaines, IL 60016 - (847) 294-4000

ELGIN - 595 South State, Elgin, IL 60123 - (847) 608-3131 • PEORIA - 5415 N. University St., Peoria, IL 61614 - (309) 693-5463

BUREAU OF LAND - PEORIA - 7620 N. University St., Peoria, IL 61614 - (309) 693-5462 • CHAMPAIGN - 2125 South First Street, Champaign, IL 61820 - (217) 278-5800

COLLINSVILLE - 2009 Mall Street, Collinsville, IL 62234 - (618) 346-5120 • MARION - 2309 W. Main St., Suite 116, Marion, IL 62959 - (618) 993-7200

PRINTED ON RECYCLED PAPER
Attachment 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)

Proposed Rule, First Notice, Opinion Order ofthe IPCB by N.J. Melas,

dated October 4, 2007

Letter from Acting Chairman Girard, IPCB to Jack Lavin, Director,

Department ofCommerce and Economic Opportunity, request for

economic impact study, dated October 18, 2007

Illinois Register Notice ofProposed Amendments, volume 31, issue 43, p.

14581, published October 26,2007

IPCB Hearing Officer Order, Notice ofHearing, dated January 31,2008

Pre-filed testimony ofLauren C. Lurkins and Diane Beno, filed February 22,

2008.

Abbott's Motion to File Revised Exhibit 3 and Minor Revisions to Proposed

Subsection 218.480(b)(4), filed February 29,2008

IPCB Hearing Officer Order, dated March 4, 2008

Transcript ofHearing, filed March 18,2008

Hearing Exhibits, filed March 28, 2008

IPCB Hearing Officer Order, Hearing Report, dated March 28, 2008

Abbott's Motion to Correct Transcript, filed April 7, 2008

Illinois EPA Post Hearing Comments, filed May 1, 2008

Abbott's Post Hearing Comments, filed May 1, 2008

Proposed Rule, Second Notice, Opinion and Order ofthe IPCB by N.J.

Me1as, dated June 19,2008

JCAR memorandum accepting the proposal for Second Notice; Second

Notice period began July 10, 2008 and ends no later than August 23, 2008

and the proposal will be considered at the August 19, 2008 meeting, filed

July 14, 2008

JCAR Letter stating the proposed rulemaking was considered at JCAR's

August 19,2008 meeting with the attached Certification ofNo Objections,

dated August 21, 2008

Adopted Rule, Final Order, Opinion and Order ofthe IPCB by N.J. Melas,

dated August 21, 2008
Attachment 19) Illinois Register Notice ofAdopted Amendments, volume 32, issue 37, p.

14874, published September 12,2008.

The SIP Checklists are also enclosed to assist in your review.

Iffurther information is required, please contact Shannon Bilbruck ofmy staff at 217/557-4261.

Cordially,

d1{~~~

Laurel L. Kroack, Chief

Bureau ofAir

Attachments

bcc: Laurel Kroack- letter, checklists

Vicky Von Lanken- letter, checklists

Jim Ross- letter, checklists

AQPS- letter, checklists, attachments

Charles Matoesian- letter, checklists

Shannon Bilbruck- letter, checklists, attachments
STATE IMPLEMENTION PLAN CHECKLISTS

R08-08: In the Matter of: Abbott Laboratories' Proposed Site Specific Amendment to

Applicability Section ofOrganic Material Emission Standards and Limitations For the

Chicago Area; Subpart T: Pharmaceutical Manufacturing (35 Ill. Adm. Code 218.480(b))

Illinois Environmental Protection Agency

Bureau ofAir

Division ofLegal Counsel

1021 North Grand Ave. East

P.O. Box 19276

Springfield, Illinois 62794-9276
~'I1I~I.·•.• li IHIlII :KiI~lsm i

Re: R08-08 Attachment

1. The Submittal is accompanied by a fonnalletter of Yes, Cover

submittal from the Governor or designee. letter

The date ofsubmittal is June 30, 2009

2. Evidence is provided that the revision has been adopted in Yes, Cover

the State Code or body ofregulations. letter, 24

• The date of adoption is September 12,2008.

• Test methods/rules are correctly incorporated by

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 18, 19

the submittal

5. Evidence is provided that the State followed all the 2,3,4,5,6,7,

requirements ofits Administrative procedures Act (or 10,11,14,17,

equivalent) in conducting and completing 20,21,22,23,

adoption/issuance ofthe revision. 24

6. Evidence is provided that public notice was given by the 3,4,7,17,24

State, including the date of publication.

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

accordance with the infonnation provided in the public

notice.

The date ofthe public hearing was March 8,2008

8. The submittal contains a compilation ofthe exhibits

entered into the record at hearing.

9. The submittal contains a compilation ofpublic comments 13,14
~1).Ji4;f'1kljI~~i)i)••. ) ii ii ... i ii

Re: R08-08 Attachment

1. The regulated pollutants affected by revision are: sulfur

dioxide__; ozone --.K-; particulate matter__; 1

nitrogen oxides ; carbon monoxide

2. Attainment status designation for the affected area is 1

included in the submittal.

Status ofthe attainment plan for the affected area is 1

included in the submittal.

The attainment date for the affected area is included in the 1

submittal.

3. The locations and types of affected sources are identified. 1,2, 15, 18,

19

4. Changes in SIP-allowable emissions for affected sources 1

are quantified or estimated.

Changes in actual emissions from affected sources are 1

quantified or estimated.

5. Evidence is provided that the NAAQS will be protected if 1

the revision is approved and implemented.

Evidence is provided that the PSD increment will be 1

protected ifthe revision is approved and implemented.

Evidence is provided that the RFP demonstration will be 1

protected ifthe revision is approved and implemented.

Evidence is provided that visibility will be protected ifthe 1

revision is approved and implemented.

6. Modeling information is provided (if necessary) in support 1

ofthe revision.

7. The proposed emission limitations are based on continuous 1

emissions reduction technology.

8. The emissions limitations requirements are incorporated (if 18, 19

necessary) to ensure emission levels.

The work practice standards requirements are incorporated 1

(if necessary) to ensure emission levels.

The recordkeeping/reporting requirements are incorporated 1

(if necessary) to ensure emission levels.

9. The submittal contains enforcement/compliance strategies, 18, 19

including how compliance will be determined in practice

and at what frequency.
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Re: R08-08 Attachment

1. Applicability

What sources are being regulated? 1

What are criteria for exemption? N/A

Is calculation procedure for exemption clearly specified? 1

Is emission inventory listed in the background document of 1

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 gallon of Tons per year

solids applied less water, grains per standard cubic foot)?

Is bubbling or averaging of any type allowed? If yes, state Yes, various dryers at

criteria. Could a USEPA inspector independently same source.

Yes.

determine ifthe criteria were met? Does EPA have to No.

approve each case?

Ifthere is a redesignation, will this change the emission N/A

limitations? If yes, which ones and how?

2. Comoliance Dates

What is the compliance date? 18, 19

What is the attainment date? 2010

3. Specificity ofConduct

What test method is required? N/A

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

Is a compliance calculation or evaluation required? (i.e., 18, 19

daily weighted average for VOC)

If yes, list the formula, period of compliance, and/or 18, 19

evaluation period.

4. Incorporation 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. Recordkeeping

What records are required to determine compliance? 18, 19

In what form or units (lbs/gal, gr/dscf, etc...) must the 18, 19

records be kept? On what time basis (instantaneously,

hourly, daily)?

Does the rule affirmatively require the records be kept? N/A

6. Exemption

List any exemptions allowed. No

Is the criteria for application clear? N/A