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 plant s **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, 196 2 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 mor e of an y visibility

- impairing pollutant. In accordance with BART requirements, each BART

- eligible facility must perform a BART anal ys is of controls for sulfur dioxide, nitrogen oxides and particulate matter. This anal ys is 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 reasonab ly

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 anal ys is 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.2

**II. BART**  **Analysis Summary**  Kodak submitted a BART anal ys is for its Eastman Business Park in Rochester, New York dated September 29, 2010. A supplemental document updating this BART anal ysis 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 anal ys is: **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 NO x and SO 2 emissions

. An electrostatic precipitator (ESP) is utilized for particulate control. Kodak’s permit limits NO x emission s from this unit at 0.6 lb/mmBtu and 3 00 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 NO x and SO 2 emissions. An ESP is utilized for particulate control. Kodak’s permit limits NO x emission s 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 NO x and SO 2 emissions. An ESP is utilized for particulate control. Kodak’s permit limits NO x emission s 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 anal ys is . The Department , under 6 NYCRR Part 249.1(c)(3), established a visibility

impairment threshold of 0.1 deciviews (dv) in Class Iareas to determine whether a unit’s visibility impacts were high enough to warrant an anal ys is 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 anal ys is of controls due to low visibility impacts. Emissions from four BART

- eligible package boil ers yi elded 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 boiler s , 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 analy sis. A summary

of the analy sis’ findings for each pollutant are as follows:3

 SO 2 Kodak identified a few potential SO 2 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 technicall y 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 e quipment would likely

be required if installed downstream of the existing ESP. Also, space constraints may preclude installation of a wet FGD s ys tem 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. Is sues 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 onl y about 5 percent SO 2 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 technicall y feasible for all three units. A CFBA would likely achieve similar SO 2 removal as an FGD sy stem 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 SO 2 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 variou s SO 2 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

PM4

Kodak’s proposed method of SO 2 control is included in the “Overall Proposal” section below.

 NO x 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 NO x burners and air staging, and natural gas is currentl y used as a reburn fuel to reduce NO x emissions. Kodak identified selective catal yt i c reduction (SCR) and selective non

- cataly tic reduction (SNCR) as potential NO x control options. Both are considered technically feasible, though the effectiveness of SNCR is very boiler

- specific; it is assumed b y Kodak to have moderate effectiveness on B oilers 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 improve ments 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 $2 5.0M/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 NO x control is included in the “Overall Proposal” section below.

 PM The following PM c ontrols/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 f urther because any particulates that would be caught b y these units are already caught b y the existing ESPs. Kodak’s proposed method of PM control is included in the “Overall Proposal” section below.

 Overall Proposal Kodak propose s to use an alternate method of compliance after ruling out the above options based on an analysis of the five BART factors , and partl y in re sponse to other upcoming regulatory

requirements which may cause conflicts with the ty pes of controls that would be required

. Boilers 41, 42 and 43 are subject to the proposed National5

Emission Standards for Hazardous Air Pollutants (NESHAPs) for Major So urce Industrial/Commercial/Institutional Boilers and Process Heaters, which will require compliance b y J anuary

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 operat e concurrentl y. The resulting emissi on 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)**  SO 2 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 Reasonabl y Available Control Technology (RACT) standard b y 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 co nstitute BART for the Kodak Park Division emission sources

. (Note that the Department does not agree with the anal ysis’ claims minimizing the benefits of a 0.5 deciview improvement nor its comparisons to unrelated determinations in other states.)

 As prev iously

stated, Boilers 41, 42 and 43 at Kodak Park are subject to upcoming NO x 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 S O 2 by

association. NO x 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 SO 2 , PM and NO x will be realized, even as Kodak continues to plan for the final NESHAP requirements. Kodak has also committed to comply with the Department’s NO x RACT standard of 0.20 lb/mmBtu for coal

- fired boilers.