1 New York State Department of Environmental Conservation Best Available Retrofit Technology Determination

Facility Kodak Park Division

Location Rochester, NY
Monroe Permit ID 8-2614-00205

Source Category Fossil-fuel boilers of more than 250 mmBtu/hr heat input; Chemical process plants

I. Introduction

The above referenced facility contains at least one emission source that falls under the requirements of the federal Best Available Retr ofit Technology (BART) rule under 40 CFR Part 51 and Appendix Y, and the New York State BA RT regulation as codified under 6 NYCRR Part 249. These requirements affect an emission s ource which fulfills the following criteria:

1. Falls within one of 26 sp ecific source categories, 2. Was not in operation prior to August 7, 1962 and was in existence on August 7, 1977, or underwent reconstruction between August 7, 1962 and August 7, 1977, and 3. Has a potential to emit (collectively, with ot her emission sources at the facility which fulfill items 1 and 2) of 250 tons per year or more of any visibility-impairing pollutant.

In accordance with BART requirements, each BART-eligible facility performed a BART analysis of controls for sulfur dioxide, nitrogen oxides and particul ate matter. This analysis took into account such factors as the cost of c ontrols, energy and non-air quality environmental impacts of compliance, any existing pollution co ntrol technology in use at the source, the remaining useful life of the source, and the de gree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

This document summarizes the reasoning be hind the Department’s BART determination, including the level of cont rols and emission limits that constitute BART for this facility’s eligible emission source(s). Each analysis and BART determination was submitted to the Federal Land Managers (FLMs) for their review in accordance with Regional Haze State Implementation Plan (SIP) requirements. Comments received from the FLMs on this determination will be included with its official submission to the U.S. Environmental Protection Agency (EPA).

The Department has modified this facility’s Title V permit to include the enforceable BART limits. The modifications were noticed in New York State’s Environmental Notice Bulletin on April 4, 2012. The final modified permit was i ssued on May 25, 2012. This permit is now being submitted to EPA as a revision to the New York Regional Haze SIP.2 II. BART Analysis Summary

The Eastman Kodak Company and Duke Ener gy Generation Services submitted a BART analysis for its Eastman Business Park in Rochester, New York dated September 29, 2010. Citing some inadequacies in this analysis, disc ussions between the Department and Kodak/Duke Energy resulted in additional correspondence as the parties worked toward a resolution. Kodak/Duke Energy submitted revised propos als on December 6, 2010 and October 12, 2011. Ultimately, the parties reached an agreement on BART compliance, as reflected in the March 29, 2012 letter from Duke Energy to the Departme nt. The compliance method and deadlines are discussed later in this determination summary.

The following emission sources had previously been identified as BART-eligible and were therefore included in the analysis:

Boiler No. 41 – Emission Unit U-00015; Emission Source 321AG Boiler No. 42 – Emission Unit U-00015; Emission Source 321AH Boiler No. 43 – Emission Unit U-00015; Emission Source 321AI

• These units are built-up cyclone boilers used for generating steam and electricity for the Kodak plant. Boilers 41 and 42 are each ra ted at 500 mmBtu/hr, while Boiler 43 is rated at 640 mmBtu/hr. These boilers primarily bur n bituminous coal, with natural gas reburn to reduce NO x and SO 2 emissions. An electrostatic precipitator (ESP) is utilized for particulate control of each. Kodak’s perm it currently contains the following emission limits for each boiler:

• NO x : 0.6 lb/mmBtu and 300 lb/hr for Boilers 41 and 42; 0.6 lb/mmBtu and 384 lb/hour for Boiler 43

• SO 2 : 2.5 lb/mmBtu sulfur content in co al and 1.5 percent sulfur in oil

• PM: 0.26 lb/mmBtu for coal and 0.10 lb/mmBtu for oil

Kodak conducted visibility modeling to demonstr ate that smaller, lower-emitting BART-eligible emission sources had visibility impacts small en ough that the sources could be omitted from the BART analysis. Maximum annual daily emission levels were used for the modeling, in concert with Department modeling protocol. Results i ndicated that, aside from Boilers 41, 42 and 43, no units necessitated a BART analysis due to low vi sibility impacts. Emissions from four BARTeligible package boilers collectively yielde d downwind visibility impairment of only 0.006 deciviews, or 0.0015 deciviews per boiler—whic h represents an insi gnificant amount of visibility impairment. The largest emissions from non-boiler units were comparable to the emissions from the package boilers, but were em itted from much shorte r stacks. These units would therefore have similarly minimal and negl igible visibility imp acts on downwind class I areas. The Department accepted Kodak’s demonstra tion and conclusion that the BART analysis need only focus on Boilers 41, 42, and 43.3 A summary of Kodak’s proposed compliance method follows:

• Overall Proposal

Kodak initially submitted its BART analysis on September 29, 2010. In this plan, Kodak proposed a “restricted operation” scenario for compliance with BART, which would entail operating two of the three boilers at any given time. This initial plan lacked specificity in large part due to uncertain ty in how Kodak would comply with other upcoming state and federal regulations (e .g., Reasonably Available Control Technology (RACT) for NO x , and National Emission Standards for Hazardous Air Pollution (NESHAP) for major boilers, otherwise known as the boi ler MACT). Still, the Department requested a follow-up to garner more information on the feasible control technologies that would yield potentially greater reductions.

Based on additional engineering and cost analyses, Kodak proposed an updated compliance strategy for Boilers 41, 42, and 43. This updated plan, which was submitted to the Department on October 12, 2011 and fu rther revised in a le tter sent March 29, 2012, entails the following conditions:

• Retiring Boiler 41 by December 31, 2013;

• Retiring or repowering Boiler 42 by the co mpliance date of the National Emission Standards for Hazardous Air Pollutant s (NESHAP) under 40 CFR 63 Subpart DDDDD, but no later than August 16, 2017; and,

• Installation of controls that meet th e NESHAP requirements on Boiler 43 by the appropriate compliance date.

A repowered Boiler 42 would have emissi ons commensurate with a natural-gas conversion project; it would meet the Department’s NO x RACT limit for natural gas, and would yield reductions of gr eater than 99 percent for SO 2 and 90 percent for PM. The use of natural gas would achieve greater emi ssion reductions than any technically feasible BART control option.

Kodak is committing to retrofit Boiler 43 as needed to comply with EPA’s NESHAP requirements. Kodak is also committing to comply with the Department’s NO x RACT regulations on Boiler 42 (if it re mains operating) and Boiler 43.

III. BART Determination

The Department finds that the following shall constitute BART for the Kodak Park Division emission sources:

• The Department is approving Kodak’s update d compliance plan, as described above, which includes the retirement of Boiler 41 a nd retirement or repowering of Boiler 42. The overall reductions gained by retiring/repow ering these two predominantly coal-fired boilers will be significant.4 Additional reductions of the visibility-im pairing pollutants will be achieved through compliance with the NESHAP and NO x RACT regulations. The ex act level of visibility improvement from these additional measures cannot be gauged at this time since the compliance method for each is still bei ng developed. The NESHAP will require reductions of mercury, hydrogen chloride, PM, and carbon monoxide emissions, and may result in significant reductions of SO 2 by association. Kodak has been analyzing selective catalytic re duction (SCR) and selective non- catalytic reduction (SNCR) as potential controls to satisfy NO x RACT for Boiler 43.

As a result of their updated compliance plan, Kodak expects a visibility improvement of approximately 0.576 deciviews (from a ba seline of 0.903 deciviews, based on 98 th percentile visibility impacts at Lye Brook Wilderness area).