BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    IN THE MATTER OF:
    A BBOTT LABORATORIES' PROPOSED
    SITE-SPECIFIC AMENDMENT TO
    APPLICABILITY SECTION OF ORGANIC
    MATERIAL EMISSION STANDARDS AND
    LIMITATIONS FOR THE CHICAGO AREA;
    SUBPART T: PHARMACEUTICAL
    MANUFACTURING (35
    ILL. ADM. CODE
    218.480(6))
    R08-8
    (Rulemaking -Air)
    NOTICE OF FILING
    T O: Mr. John Therriault
    Assistant Clerk of the Board
    I llinois Pollution Control Board
    100 West Randolph Street
    S uite 11-500
    Chicago, Illinois 60601
    (VIA ELECTRONIC
    MAIL)
    Kathleen M. Crowley
    Hearing Officer
    Illinois Pollution Control Board
    100 West Randolph Street
    Suite 11-500
    Chicago, Illinois 60601
    (VIA U.S. MAIL)
    (PERSONS ON ATTACHED SERVICE LIST)
    PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of
    the Illinois Pollution Control Board ABBOTT LABORATORIES'
    MOTION TO
    FILE REVISED EXHIBIT 3 AND MINOR REVISION TO PROPOSED
    SUBSECTION 218.480(6)(4),
    a copy of which is herewith served upon you.
    Respectfully submitted,
    Dated: February 29, 2008
    K atherine D. Hodge
    Lauren C. Lurkins
    H ODGE DWYER ZEMAN
    3150 Roland Avenue
    Post Office Box 5776
    Springfield, Illinois 62705-5776
    (217) 523-4900
    B y: /s/ Katherine D. Hodge
    Katherine D. Hodge
    T HIS FILING SUBMITTED ON RECYCLED PAPER
    Electronic filing - Received, Clerk's Office, February 29, 2008
    CERTIFICATE OF SERVICE
    I,
    Katherine
    D. Hodge, the undersigned, hereby certify that I have served
    ABBOTT
    LABORATORIES' MOTION TO FILE REVISED EXHIBIT 3 AND
    MINOR REVISION TO PROPOSED SUBSECTION 218.480(6)(4) upon:
    Mr. John Therriault
    Assistant Clerk of the Board
    Illinois Pollution Control Board
    100 West Randolph Street
    Suite 11-500
    Chicago, Illinois 60601
    v ia electronic mail on February 29, 2008; and upon:
    Kathleen M. Crowley
    Hearing Officer
    Illinois Pollution Control Board
    James R. Thompson Center
    1 00 West
    Randolph Street, Suite 11-500
    Chicago,
    Illinois 60601
    Matthew J. Dune, Chief
    Environmental Bureau North
    O ffice of the Attorney General
    6 9 West Washington Street, Suite 1800
    Chicago, Illinois 60602
    Charles E. Matoesian, Esq.
    Assistant Counsel
    Division of Legal Counsel
    Illinois Environmental Protection Agency
    1021 North Grand Avenue East
    P ost Office Box 19276
    Springfield, Illinois 62794-9276
    O ffice of Legal Services
    Illinois Department of Natural Resources
    One Natural Resources Way
    Springfield, Illinois 62702-1271
    b y depositing said document in the United States Mail, postage prepaid, in Springfield,
    Illinois on February 29, 2008.
    /s/ Katherine D. Hodge
    Katherine D. Hodge
    A BOT003/FilingsNOF, Exhibit 3
    Electronic filing - Received, Clerk's Office, February 29, 2008
    BEFORE THE ILLINOIS POLLUTION CONTROL
    BOARD
    IN THE MATTER OF
    )
    )
    A BBOTT LABORATORIES' PROPOSED
    )
    SITE-SPECIFIC
    AMENDMENT TO
    )
    APPLICABILITY SECTION OF ORGANIC )
    R08-8
    MATERIAL EMISSION STANDARDS AND ) (Rulemaking-Air)
    LIMITATIONS
    FOR THE CHICAGO AREA; )
    SUBPART T: PHARMACEUTICAL
    )
    MANUFACTURING (35 ILL. ADM. CODE )
    218.480(6))
    )
    ABBOTT
    LABORATORIES'
    MOTION TO FILE REVISED EXHIBIT 3 AND
    MINOR REVISION TO PROPOSED SUBSECTION 218.480(6)(4)
    NOW COMES ABBOTT LABORATORIES ("Abbott"), by and through its
    attorneys, HODGE DWYER ZEMAN, and hereby requests the Illinois Pollution Control
    B oard (`Board") to accept for filing Abbott's Revised Exhibit 3 and Minor Revision to
    proposed 35 Ill. Admin, Code Subsection
    218.480(6)(4). In support of this Motion,
    Abbott states as follows:
    1 .
    Abbott filed its original Proposal of Amendments to 35 III. Admin. Code
    Part 218.480(6) ("Original Proposal of Amendments") with the Board on September 4,
    2007.
    2.
    Abbott's Original Proposal of Amendments included: 1) the Proposed
    Amendments; 2) the Statement of Reasons; 3) Appearances for the attorneys representing
    Abbott; 4) a Motion to Waive Requirement to Submit 200 Signatures;
    5) a Motion
    for
    Expedited
    Review; 6) Exhibit 1, Aerial Photograph of Abbott Park and Vicinity,
    Libertyville Township, Illinois;
    7) Exhibit 2, Improvina Air
    Quality with
    Economic
    Incentive Proerams, United States Environmental Protection Agency, January 2001; and
    Electronic filing - Received, Clerk's Office, February 29, 2008
    8) Exhibit 3, a table entitled "Historical
    VOM Air Emissions from Tunnel Dryers and
    Fluid Bed Dryers at the
    Abbott Park Facility."
    3.
    Since filing its Original Proposal of Amendments,
    Abbott has discovered
    that several revisions and
    clarifications were necessary to Exhibit 3, the table
    entitled
    "Historical
    VOM Air Emissions from Tunnel Dryers and Fluid Bed Dryers
    at the Abbott
    Park Facility."
    4.
    Therefore,
    Abbott seeks to file Revised Exhibit 3 with the Board that
    includes the following changes: 1) correct a typographical
    error for the 1999 total,
    changing 26.1 to 25.1; 2) show single-unit
    data at 2 decimal places; 3) add a line for 90%
    of the baseline, with the
    corrected value of 20.6 tons per year; 4) add Note c to identify
    the round-off issue and specify that totals are
    correct based on calculations with more
    significant figures; and 5)
    update the reference in Note a to reflect the correct condition in
    the renewed CAAPP
    Permit, issued on September 26, 2007.
    5.
    In addition,
    Abbott also seeks to file a minor revision to Proposed Section
    218.480(b)(4)
    to reflect the change made to the 90% baseline calculation,
    as follows:
    4J
    For fluid bed dryers # 1. #2, and
    #3 and for tunnel dryers # 1#2, #3
    and #4, the combined total
    annual emissions from the dryers listed
    in this subsection 218.480(b)(4) shall not exceed AW9 18,688
    kgNear (29-7 20.6 tons/year). [BOARD
    NOTE: tunnel dryers
    are
    otherwise referred to as
    warm air drversl, and
    ý r*
    Electronic filing - Received, Clerk's Office, February 29, 2008
    WHEREFORE, for the above and foregoing reasons, ABBOTT
    LABORATORIES hereby respectfully requests the Illinois Pollution Control Board to
    accept for filing ABBOTT LABORATORIES'
    Revised Exhibit 3 and Minor Revision to
    Proposed Subsection 218.480(b)(4).
    Respectfully submitted,
    ABBOTT LABORATORIES
    By: /s/Katherine D. Hodge
    One of Its Attorneys
    Date: February 29, 2008
    Katherine D. Hodge
    Lauren C.
    Lurkins
    HODGE DWYER ZEMAN
    3150 Roland Avenue
    Post Office Box 5776
    Springfield, Illinois 62705-5776
    (217) 523-4900
    ABOT:003/Filings/NOF Motion to
    file Revised Exhibit 3 and Amended Proposal
    Electronic filing - Received, Clerk's Office, February 29, 2008
    Revised Exhibit 3 (2/29/08)
    Historical VOM Air Emissions from Tunnel Dryers and Fluid Bed Dryers at the Abbott Park Facility a
    (tons per year) `
    Year
    Tunnel
    Dr yer
    1
    Tunnel
    Dr yer
    g
    Tunnel
    Dr yer
    3
    Tunnel
    Dr yer
    4
    Fluid
    Bed
    Dr yer
    1
    Fluid
    Bed
    Dr yer
    g
    Fluid
    Bed
    Dr yer
    3
    Total
    Tunnel
    Dryer
    Emissions
    Total
    Fluid Bed
    Dryer
    Emissions
    Total
    Dryer
    VOM
    Emissions
    1998
    2.65
    2.19
    2.59
    3.27
    1.34
    1.12
    b
    10.7
    2.5
    13.2
    1999
    4.52
    5.58
    5.31
    5.16
    2.35
    2.15
    b
    20.6
    4.5
    25.1
    2000
    3.79
    4.01
    3.15
    3.30
    3.16
    3.16
    0.17
    14.2
    6.5
    20.7
    2001
    0.70
    1.60
    1.70
    1.30
    1.70
    1.60
    1.70
    5.3
    5.0
    10.3
    2002
    1.80
    1.80
    1.80
    1.20
    0.90
    0.90
    3.10
    6.6
    4.9
    11.5
    2003
    2.40
    2.10
    2.20
    1.20
    1.00
    1.00
    2.90
    7.9
    4.9
    12.8
    2004
    3.40
    1.70
    1.50
    0.60
    0.00
    0.00
    3.90
    7.2
    3.9
    11.1
    2005
    2.10
    1.50
    1.20
    0.00
    0.10
    0.10
    3.00
    4.8
    3.2
    8.0
    2006
    1.00
    1.11
    0.91
    0.00
    0.66
    0.66
    2.97
    3.0
    4.3
    7.3
    2007
    1.71
    0.69
    1.03
    0.00
    0.41
    0.41
    3.19
    3.4
    4.0
    7.5
    Average of Years 1999 & 2000 baseline
    22.9
    90
    Percent
    of Baseline
    20.6
    Notes to Exhibit 3
    a
    Emissions
    of
    VOM were
    calculated
    based on records
    of
    production batches,
    corresponding
    VOM
    content of
    the
    batch, and
    specified
    loss factors for the respective equipment, as detailed in CAAPP Permit Section 7.1.12(e).
    b Fluid Bed Dryer 3 was not operating prior to 2000.
    c Some data were included in calculations to more precision than one decimal place, which can result in apparent discrepancies for
    total emissions. Total emissions are calculated with available precision and rounded to one decimal place.
    Electronic filing - Received, Clerk's Office, February 29, 2008

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