UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 2
 

290 BROADWAY
 

NEW YORK, NY 10007-1866
 

APR 11 2012 

Mr. Roger T. McDonough 

New York State Department of 

Environmental Conservation 

Region 8 Headquarters 

6274 E Avon-Lima Rd 

Avon, New York 14414 

Dear Mr. McDonough 

This is in response to the New York State Department of Environmental Conservation's (The. 

Department's) announcement in the April 4, 2012 publication of the Environmental Notice 

Bulletin (ENB) concerning a proposed modification of the Title V Facility Permit issued March 

13, 2009 for the Eastman Kodak Company - Eastman Business Park Boilers. The proposed 

modification is based on the Department's determination that the coal-fired Kodak Boilers 41, 42 

and 43 are subject to 6 NYCRR Part 249 Best Available Retrofit Technology (BART). The 

proposed modification specifies requirements that Kodak must implement for the three boilers to 

meet the Department's Part 249 BART requirements. This announcement provides for an 

opportunity for public comment on the proposed permit modification that ends on May 4, 2012. 

The US Environmental Protection Agency (EPA or the Agency) has reviewed the Department's 

proposed permit modification and is hereby providing official comments for the record as 

indicated below. 

EPA has completed its review ofthe proposed permit modification for the three Kodak boilers 

and the Agency agrees with the Department's requirements for Boilers 41 and 43. However, 

EPA disagrees, in part, with the Department's proposed BART requirements for Kodak's Boiler 

42 because it does not include an emission limit for controlling emissions of oxides of nitrogen 

(NO~). However, EPA agrees with the Department's required compliance date for Boiler 42. 

The Department is proposing that Boile,r 42 either permanently retire or repower with natural gas 

by the Boiler MACT compliance date but no later than August 16,2017. With regards to EPA's 

requirement that a NOx emission limit be specified for Boiler 42, it should be noted that both 

EPA and the Department define BART in their regulations as "an emission limit based on the 

degree of reduction achievable through the application of the best system of continuous emission 

reduction for each pollutant. .. " Therefore, to comply with this definition, EPA is requiring that 

the Department issue a final permit to include an emission limit for NOx by including the 

following additional wording, or equivalent, to the current proposed permit: "Should Boiler 42 

repower with natural gas, then Boiler 42 shall comply with BART by controlling NOx emissions 

to meet an emission limit not to exceed 0.20 pound per million BTU (lb/mm BTU)." This is the 

required limit for very large oil/gas fired cyclone boilers established by the Department's 

adopted regulation Subpart 227-2 ("Reasonably Available Control Technology (RACT) for 

Major Sources of Oxides of Nitrogen (NOS'). 

Intemet Address (URL). http://www.epa.gov
 

RecycledlFlecycl8ble • Printed wlh Vegetable 01 Based Inks on Recycled Paper (Minimum 30"1'. PoslconSUmer)
 
The existing testing, monitoring and reporting requirements at Conditions 63 and 64 in the 

current Title V permit would suffice for meeting BART requirements for this new permit limit 

for Boiler 42. 

EPA is not requiring limits on emissions of sulfur dioxide (S02) and particulate matter (PM) 

because EPA agrees with the Department that these emissions from a natural gas fired boiler are 

small and limiting these contaminants is not practically enforceable. 

We thank the Department for this opportunity to comment on this important permit modification 

for the three BART eligible boilers at the Kodak facility. If you have aIlY comments or wish to 

discuss this further, please contact Mr. Richard Ruvo of my staff at 212-637-4014. 

smll!JIl~ Ra ~11I W. Werner, Chief 

Air Pr~rams Branch 

cc:	 David Shaw, NYSDEC 

Rob Sliwinski, NYSDEC 

Matt Reis, NYSDEC 

Thomas Marriott, NYSDEC - Region 8 

Bernette Schilling, NYSDEC - Region 8 
Bee:	 Richard Ruvo, DEPP/APB/SIP 

Bob Kelly, DEPPIAPB/SIP 

Ted Gardella, DEPPIAPB/SIP 

Mary McHale, ORCIAB 

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