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 JacksonBoulevard, AR-18J Chicago, Illinois 60604-3598 Attn: Jay Bortzer Re: 

### AS 08-8: In theMatterof: AbbottLaboratories' ProposedSite-SpecificAmendmentto Applicability Section ofOrganicMaterialEmission Standards andLimitationsforthe 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 AirAct (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 ImplementationPlan (SIP). On September4,2007, Abbott Laboratories (Abbott) filed aproposal ofamendments 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 aFinal Opinion and Order granting Abbott's proposed amendments to 35 Ill. Adm. Code 218.480(b). In orderto assist with yourreview ofthis SIP submittal, the following documents are enclosed: Attachment 1) Abbott's Proposal ofAmendments, filed September4,2007
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 October4, 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 October26,2007 IPCB Hearing Officer Order, Notice ofHearing, dated January 31,2008 Pre-filed testimonyofLauren C. Lurkins andDianeBeno, filedFebruary22, 2008. Abbott's Motionto File Revised Exhibit 3 andMinorRevisions to Proposed Subsection 218.480(b)(4), filed February29,2008 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 byN.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 byN.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 yourreview. Iffurther information is required, please contact Shannon Bilbruck ofmy staffat 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 ShannonBilbruck- letter, checklists, attachmentsSTATE IMPLEMENTION PLAN CHECKLISTS
R08-08: In the Matter of: Abbott Laboratories' Proposed Site Specific Amendment to Applicability Section ofOrganic Material Emission Standards and Limitations Forthe 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 accompaniedby 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 orbody ofregulations. letter, 24 

## • The date ofadoption is September 12,2008
. 

## • Testmethods/rules are correctly incorporatedby reference 3. Evidence is provided that the State has the necessary legal Sections 28 of authorityunder 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 givenby the 3,4,7,17,24 State, including the date ofpublication. 7. Certification is provided that the public hearing was held in 11,14 accordance with the infonnationprovided 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 byrevision 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 ofaffected 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 (ifnecessary) 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 workpractice standards requirements are incorporated 1 (ifnecessary) to ensure emission levels. The recordkeeping/reporting requirements are incorporated 1 (ifnecessary) 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.....iiENI1

### 1 >IRi'1'i.•,i·**~I.f:li( )Hbi.":KI:l~T**  . ii.'i Re: R08-08 Attachment 1. Applicability What sources are being regulated? 1 What are criteria for exemption? N/A Is calculationprocedure 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 ofcompliance (lbs VOC per gallon of Tons per year solids applied less water, grains per standard cubic foot)? Is bubbling or averaging ofany type allowed? Ifyes, state Yes, various dryers at criteria. Could a USEPA inspectorindependently same source. Yes. determine ifthe criteriawere met? Does EPA have to No. approve each case? Ifthere is a redesignation, will this change the emission N/A limitations? Ifyes, 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) Ifyes, list the formula, period ofcompliance, and/or 18, 19 evaluationperiod. 4. Incorporation byReference What is the state authority for rulemaking? Section 28 ofthe Ill. Env. Prot. Act Are methods/rules incorporatedbyreference 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 affirmativelyrequire the records be kept? N/A 6. Exemption List any exemptions allowed. No Is the criteria for application clear? N/A