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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 must perform a BART 

analysis of controls for sulfur dioxide, nitrogen oxides and particulate matter. This analysis takes 

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 reflects the Department’s determination of what level of controls constitutes 

BART for this facility’s BART-eligible emission source(s). Each analysis and 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 each determination will be included with its submission. 

The Department is now working to expeditiously modify this facility’s Title V permit to include 

the enforceable BART limits. Specific parameters and limits that are used as the technical bases 

of BART determinations, such as sulfur limits, the installation of controls, and operational 

limitations, will be incorporated into each facility's permit in enforceable conditions. These 

permit modifications will be submitted to the U.S. Environmental Protection Agency (EPA) as 

SIP revisions once complete.
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II. BART Analysis Summary

Kodak submitted a BART analysis for its Eastman Business Park in Rochester, New York dated 

September 29, 2010. A supplemental document updating this BART analysis was submitted on 

December 6, 2010 at the request of the Department. The following emission sources had 

previously been identified as BART-eligible and are therefore included in the analysis:

Boiler No. 41 – Emission Unit U-00015; Emission Source 321AG

 This unit is a built-up cyclone boiler used for generating steam and electricity for the 

Kodak plant. This boiler burns bituminous coal with natural gas reburn to reduce NOx

and SO2 emissions. An electrostatic precipitator (ESP) is utilized for particulate control. 

Kodak’s permit limits NOx emissions from this unit at 0.6 lb/mmBtu and 300 lb/hr.

Boiler No. 42 – Emission Unit U-00015; Emission Source 321AH

 This unit is a built-up cyclone boiler used for generating steam and electricity for the 

Kodak plant. This boiler burns bituminous coal with natural gas reburn to reduce NOx

and SO2 emissions. An ESP is utilized for particulate control. Kodak’s permit limits 

NOx emissions from this unit at 0.6 lb/mmBtu and 300 lb/hr.

Boiler No. 43 – Emission Unit U-00015; Emission Source 321AI

 This unit is a built-up cyclone boiler used for generating steam and electricity for the 

Kodak plant. This boiler burns bituminous coal with natural gas reburn to reduce NOx

and SO2 emissions. An ESP is utilized for particulate control. Kodak’s permit limits 

NOx emissions from this unit at 0.6 lb/mmBtu and 384 lb/hr.

Kodak conducted visibility modeling to demonstrate that smaller, lower-emitting BART-eligible 

emission sources had visibility impacts below a particular de minimis level and thus could be 

omitted from the BART analysis. The Department, under 6 NYCRR Part 249.1(c)(3),

established a visibility impairment threshold of 0.1 deciviews (dv) in Class I areas to determine 

whether a unit’s visibility impacts were high enough to warrant an analysis of controls.

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 of controls due to low visibility impacts. Emissions from four BART-eligible 

package boilers yielded downwind visibility impairment of only 0.006 dv—well below the 

Department’s established threshold. 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 visibility impacts on downwind class 

I areas. The Department accepts Kodak’s demonstration and conclusion that these units need not 

be included in the analysis.

A summary of the analysis’ findings for each pollutant are as follows:
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 SO2

Kodak identified a few potential SO2 control options for Boilers 41, 42 and 43 and 

reviewed them for feasibility: 

o Low-sulfur coal was ruled out because the design of the cyclone boilers strictly

limits the coal characteristics. Washed coal was ruled out as well.

o Flue Gas Desulfurization (FGD), including wet limestone and wet lime scrubbers, 

are technically feasible retrofit options for all three boilers. Effectiveness is 

estimated at 90 percent. A couple issues arise with FGD installation, however. 

To comply with proposed NESHAP standards, Kodak may need to install 

activated carbon injection for mercury and dioxin control; the presence of 

activated carbon may cause issues with current equipment. New PM control 

equipment would likely be required if installed downstream of the existing ESP. 

Also, space constraints may preclude installation of a wet FGD system if SCR is 

also required for compliance with NOx RACT/BART.

o Spray dryer absorbers are technically feasible for all three boilers. Effectiveness 

is estimated at 90 percent. Issues similar to those with FGD, above, are of 

concern.

o Dry injection is technically feasible for all three boilers. Additional PM control 

would be required downstream. Based on vendor input, dry powdered lime would 

achieve only about 5 percent SO2 removal. Another suitable sorbent is Trona; 

these removal efficiencies reach as high as 70 percent but sorbent quantities and 

costs are much higher.

o A circulating fluidized-bed absorber (CFBA) is also technically feasible for all 

three units. A CFBA would likely achieve similar SO2 removal as an FGD 

system but is more complicated and has less operating history, and is thus 

removed from further consideration.

Kodak considered a multi-pollutant control approach that includes fabric filtration 

downstream of SO2 controls (necessary to collect waste products and/or to meet various 

pollutant standards in EPA’s proposed boiler NESHAP rule). The table below 

summarizes the costs of control for various SO2 and PM options.

Control Technology Annualized Cost 

of Control

Average Cost of 

Control ($/ton)

Incremental Cost 

of Control ($/ton)

Dry Lime Injection + 

Fabric Filtration $5,238,187 $8,732$10,578

SO2

PM

$9,947

$11,255

SO2

PM

Dry Trona Injection + 

Fabric Filtration $29,286,852 $3,487$107,530

SO2

PM

$3,545

$102,104

SO2

PM

Spray Dryer Absorber + 

Fabric Filtration $15,184,149 $1,406$55,750

SO2

PM

$1,597

$59,135

SO2

PM

Wet FGD + Fabric 

Filtration $16,006,954 $1,482$58,771

SO2

PM

$1,745

$64,614

SO2

PM
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Kodak’s proposed method of SO2 control is included in the “Overall Proposal” section 

below.

 NOx

Boilers 41, 42 and 43 currently operate with combustion controls to the extent feasible. 

The construction of the cyclone boilers precludes the use of low NOx burners and air 

staging, and natural gas is currently used as a reburn fuel to reduce NOx emissions.

Kodak identified selective catalytic reduction (SCR) and selective non-catalytic reduction 

(SNCR) as potential NOx control options. Both are considered technically feasible, 

though the effectiveness of SNCR is very boiler-specific; it is assumed by Kodak to have 

moderate effectiveness on Boilers 41, 42 and 43. Kodak estimated the cost of an SCR 

unit to be $2,206 per ton, and SNCR at $2,120 per ton. 

Kodak modeled baseline conditions as a maximum impact of 0.903 dv, and then modeled 

control combinations to determine the visibility improvements that would result. The 

SCR/dry lime injection/fabric filter option would reduce the impact to 0.812 dv on the 

maximum day, resulting in a cost of $93.1M/dv. The SCR/spray dryer absorber/fabric 

filter option would reduce the impact to 0.165 dv at $25.0M/dv; similar results would be 

obtained from the SCR/Wet FGD/fabric filter combination due to comparable costs and 

control efficiencies.

Kodak’s proposed method of NOx control is included in the “Overall Proposal” section 

below.

 PM

The following PM controls/upgrades were considered for Boilers 41, 42, and 43:

o These units currently have ESPs installed for PM control. Due to location and 

breeching configuration there is not enough space to allow for the addition of 

collection fields to the existing equipment.

o Fabric filtration is technically feasible for these units.

o Particle scrubbers and mechanical collectors were not considered further because 

any particulates that would be caught by these units are already caught by the 

existing ESPs.

Kodak’s proposed method of PM control is included in the “Overall Proposal” section 

below.

 Overall Proposal

Kodak proposes to use an alternate method of compliance after ruling out the above 

options based on an analysis of the five BART factors, and partly in response to other 

upcoming regulatory requirements which may cause conflicts with the types of controls 

that would be required. Boilers 41, 42 and 43 are subject to the proposed National 
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Emission Standards for Hazardous Air Pollutants (NESHAPs) for Major Source 

Industrial/Commercial/Institutional Boilers and Process Heaters, which will require 

compliance by January 16, 2014 (assuming EPA finalizes the rule as scheduled).

Kodak proposes a “Restricted Operation” compliance method as compliance with BART 

to grant them flexibility to respond to other upcoming requirements as new regulations 

are finalized. Under this option, Kodak would limit the simultaneous use of the boilers—

i.e., only two of the three boilers would operate concurrently. The resulting emission 

reductions are provided in the table below; this operation is estimated to result in a 

maximum visibility impact of 0.697 dv from the baseline of 0.903 dv, a reduction of 

0.206 dv.

Precursor Baseline Emissions 

(ton/yr)

Restricted Operation 

Emissions (ton/yr)

SO2 11,998 9,843

NOx 2,449 1,969

PM 619 544

In the December 6, 2010 supplemental BART letter, Kodak reiterated its commitment to 

the Restricted Operation scenario, and further committed to meeting the Department’s 

Reasonably Available Control Technology (RACT) standard by July 1, 2014, as required 

by 6 NYCRR Part 227-2. The applicable RACT limit for these boilers is 0.20 lb/mmBtu 

calculated on a 30-day rolling average.

III. BART Determination

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

emission sources. (Note that the Department does not agree with the analysis’ claims 

minimizing the benefits of a 0.5 deciview improvement nor its comparisons to unrelated 

determinations in other states.)

 As previously stated, Boilers 41, 42 and 43 at Kodak Park are subject to upcoming NOx

RACT and NESHAP regulations. The NESHAP will require reductions of mercury, 

hydrogen chloride, PM, and carbon monoxide emissions, and will result in significant 

reductions of SO2 by association. NOx emissions will be reduced through the recently

revised RACT rule at 6 NYCRR Part 227-2.

The Department accepts the two criteria proposed by Kodak for compliance with BART. 

The Restricted Operation scenario will ensure that reductions of SO2, PM and NOx will 

be realized, even as Kodak continues to plan for the final NESHAP requirements. Kodak 

has also committed to comply with the Department’s NOx RACT standard of 0.20 

lb/mmBtu for coal-fired boilers.