http://www.dec.ny.gov/enb/20120404_reg8.html#826140020501827

Applicant: 

Eastman Kodak Co 

343 State St 

Rochester, NY 14650 

Facility: 

Kodak Operations at Eastman Business Park 

1669 Lake Ave 

Rochester, NY 14652 

Application ID: 

8-2614-00205/01827 

Permit(s) Applied for: 

Article 19 Air Title V Facility 

Project is Located: 

Rochester, Monroe County 

Project Description: 

The Department has received an application for modification of the Title V Facility Permit 

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

Kodak Boilers generate steam and electricity to support Kodak manufacturing activities, and are 

operated by SUEZ-Duke Energy Generation Services of Rochester (SDEGS) under a Title V 

Permit which is separate from the Title V Permit for Kodak manufacturing activities. 

In response to the application, the Department has generated a Draft Modified Title V Facility 

Permit, and made a tentative determination to issue the Modified Permit. 

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. 

Part 249 regulations restrict emissions of visibility-impairing pollutants by requiring installation 

of Best Available Retrofit Technology (BART) on sources identified under the rule, to reduce 

regional haze and restore natural visibility conditions. 

To comply with Part 249 BART regulations, Kodak has submitted an evaluation of Boilers 41, 

42, and 43, with a plan that the Department has accepted as meeting Part 249 requirements, and 

included in conditions in the Draft Modified Permit. 
The plan includes: The permanent shutdown of Boiler 41 by December 31, 2013; Either the 

permanent shutdown of Boiler 42, or conversion of Boiler 42 from coal fired to natural gas fired, 

by the compliance date specified in the National Emission Standards for Hazardous Air 

Pollutants (NESHAP) under 40 CFR 63 Subpart DDDDD, but no later than August 16, 2017; 

and the installation of emission control equipment on Boiler 43, sufficient to meet requirements 

of 40 CFR 63 Subpart DDDDD Boiler and Process Heater NESHAP. 

In addition, Kodak's boilers are subject to the 40 CFR 64 Compliance Assurance Monitoring 

(CAM) rule with respect to Part 227-1 particulate emission limits. The Draft Modified Permit 

includes CAM requirements for particulate emissions from Boilers 41 and 44, similar to those 

for Boilers 42 and 43 included in modifications authorized in January 2007. The CAM 

requirements for Boilers 41 and 44 were derived from testing conducted in 2009 to establish 

opacity limits, and specify opacity monitoring as a surrogate parameter for Part 227-1 particulate 

limits. Opacity will be measured with a continuous monitoring system to verify compliance with 

particulate standards for each of the large coal boilers. 

Also, new conditions have been added to the Draft Modified Permit for record keeping to 

demonstrate compliance with 40 CFR 63 Subpart DDDDD Boiler and Process Heater NESHAP 

requirements, and the 6 NYCRR Part 243 Clean Air Interstate Rule (CAIR) NOx Ozone Season 

Trading Program. 

Finally, conditions for the 6 NYCRR Part 204 NOx Budget Rule, which has been repealed, have 

been eliminated. 

The application, Draft Permit, and Permit Review Report are available for review at the Region 8 

NYSDEC office. The Draft Permit and Permit Review Report may be viewed or downloaded as 

.pdf files at: http://www.dec.ny.gov/dardata/boss/afs/draft_atv.html 

In accordance with 6NYCRR Parts 621.7(b)(9) and 201-6.4(c), the Administrator of the United 

States Environmental Protection Agency (USEPA) has the authority to bar issuance of any Title 

V Facility Permit if it is determined not to be in compliance with applicable requirements of the 

Clean Air Act or 6NYCRR Part 201. 

Persons wishing to inspect the subject Title V files, including the application with all relevant 

supporting materials, the draft permit, and all other materials available to the DEC (the 

"permitting authority") that are relevant to this permitting decision should contact the DEC 

representative listed below. The Draft Permit and Permit Review Report may be viewed and 

printed from the Department web site at: http://www.dec.ny.gov/dardata/boss/afs/draft_atv.html. 

DEC will evaluate the application and the comments received on it to determine whether to hold 

a public hearing. Comments and requests for a public hearing should be in writing and addressed 

to the Department representative listed below. A copy of the Department's permit hearing 

procedures is available upon request or on the Department web site at: 

http://www.dec.ny.gov/permits/6234.html. 

Availability of Application Documents: 
Filed application documents, and Department draft permits where applicable, are available for 

inspection during normal business hours at the address of the contact person. To ensure timely 

service at the time of inspection, it is recommended that an appointment be made with the 

contact person. 

State Environmental Quality Review (SEQR) Determination: 

Project is an Unlisted Action and will not have a significant impact on the environment. A 

Negative Declaration is on file. A coordinated review was not performed. 

SEQR Lead Agency: None Designated 

State Historic Preservation Act (SHPA) Determination: 

Cultural resource lists and map have been checked. No registered, eligible or inventoried 

archaeological sites or historic structures were identified at the project location. No further 

review in accordance with SHPA is required. 

Coastal Management: 

This project is not located in a Coastal Management area and is not subject to the Waterfront 

Revitalization and Coastal Resources Act. 

Opportunity for Public Comment: 

Comments on this project must be submitted in writing to the Contact Person no later than May 

04, 2012. 

Contact: 

Roger T McDonough 

NYSDEC Region 8 Headquarters 

6274 E Avon-Lima Rd 

Avon, NY 14414 

(585)226-2466 

r8dep@gw.dec.state.ny.us