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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 Retrofit Technology (BART) rule under 40 CFR Part 

51 and Appendix Y, and the New York State BART regulation as codified under 6 NYCRR Part 

249. These requirements affect an emission source which fulfills the following criteria: 

1. Falls within one of 26 specific 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 other 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 particulate matter. This analysis took 

into account such factors as the cost of controls, energy and non-air quality environmental 

impacts of compliance, any existing pollution control technology in use at the source, the 

remaining useful life of the source, and the degree of improvement in visibility which may 

reasonably be anticipated to result from the use of such technology. 

This document summarizes the reasoning behind the Department’s BART determination, 

including the level of controls 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 issued on May 25, 2012. This permit is now being 

submitted to EPA as a revision to the New York Regional Haze SIP. 

 
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II. BART Analysis Summary 

The Eastman Kodak Company and Duke Energy 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, discussions between the Department and Kodak/Duke 

Energy resulted in additional correspondence as the parties worked toward a resolution. 

Kodak/Duke Energy submitted revised proposals 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 Department. 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 rated at 500 mmBtu/hr, while Boiler 43 is rated 

at 640 mmBtu/hr. These boilers primarily burn bituminous coal, with natural gas reburn 

to reduce NOx and SO2 emissions. An electrostatic precipitator (ESP) is utilized for 

particulate control of each. Kodak’s permit currently contains the following emission 

limits for each boiler: 

• NOx: 0.6 lb/mmBtu and 300 lb/hr for Boilers 41 and 42; 0.6 lb/mmBtu and 384 

lb/hour for Boiler 43 

• SO2: 2.5 lb/mmBtu sulfur content in coal 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 demonstrate that smaller, lower-emitting BART-eligible 

emission sources had visibility impacts small enough 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 indicated that, aside from Boilers 41, 42 and 43, no 

units necessitated a BART analysis due to low visibility impacts. Emissions from four BARTeligible package boilers collectively yielded downwind visibility impairment of only 0.006 

deciviews, or 0.0015 deciviews per boiler—which represents an insignificant amount of 

visibility impairment. The largest emissions from non-boiler units were comparable to the 

emissions from the package boilers, but were emitted from much shorter stacks. These units 

would therefore have similarly minimal and negligible visibility impacts on downwind class I 

areas. The Department accepted Kodak’s demonstration and conclusion that the BART analysis 

need only focus on Boilers 41, 42, and 43. 

 
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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 uncertainty in how Kodak would comply with other 

upcoming state and federal regulations (e.g., Reasonably Available Control Technology 

(RACT) for NOx, and National Emission Standards for Hazardous Air Pollution 

(NESHAP) for major boilers, otherwise known as the boiler 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 further revised in a letter sent March 29, 

2012, entails the following conditions: 

• Retiring Boiler 41 by December 31, 2013; 

• Retiring or repowering Boiler 42 by the compliance date of the National Emission 

Standards for Hazardous Air Pollutants (NESHAP) under 40 CFR 63 Subpart 

DDDDD, but no later than August 16, 2017; and, 

• Installation of controls that meet the NESHAP requirements on Boiler 43 by the 

appropriate compliance date. 

A repowered Boiler 42 would have emissions commensurate with a natural-gas 

conversion project; it would meet the Department’s NOx RACT limit for natural gas, and 

would yield reductions of greater than 99 percent for SO2 and 90 percent for PM. The 

use of natural gas would achieve greater emission 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 NOx RACT 

regulations on Boiler 42 (if it remains 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 updated compliance plan, as described above, 

which includes the retirement of Boiler 41 and retirement or repowering of Boiler 42. 

The overall reductions gained by retiring/repowering these two predominantly coal-fired 

boilers will be significant. 
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Additional reductions of the visibility-impairing pollutants will be achieved through 

compliance with the NESHAP and NOx RACT regulations. The exact level of visibility 

improvement from these additional measures cannot be gauged at this time since the 

compliance method for each is still being developed. The NESHAP will require 

reductions of mercury, hydrogen chloride, PM, and carbon monoxide emissions, and may 

result in significant reductions of SO2 by association. Kodak has been analyzing 

selective catalytic reduction (SCR) and selective non-catalytic reduction (SNCR) as 

potential controls to satisfy NOx RACT for Boiler 43. 

As a result of their updated compliance plan, Kodak expects a visibility improvement of 

approximately 0.576 deciviews (from a baseline of 0.903 deciviews, based on 98th

percentile visibility impacts at Lye Brook Wilderness area).