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ENB Region 8 Completed Applications 03/11/2009

Monroe County


Eastman Kodak Co
343 State St
Rochester, NY 14650


Kodak Park Division
1669 Lake Ave
Rochester, NY 14650

Application ID:


Permit(s) Applied for:

Article 19 Air Title V Facility

Project is Located:

Rochester, Monroe County

Project Description:

The Department has prepared a Draft Permit, and has made a tentative determination to issue a modified Title V Facility Permit. This is in response to an application for modification of the Title V Facility Permit for Eastman Kodak Co - Kodak Park manufacturing operations, to allow continued operation of Synthetic Chemical production operations of Emission Unit (EU) U-00053 in Building 325 without the use of the biological oxidation control equipment (the "Bioton"). This proposed modification is limited to changes to 3 conditions in the current Permit, which specify operation of the Bioton emission control unit: Condition 27.90 for Part 201-6 Process: I35 - Biological Oxidation Control for Batch Organic Chemical Manufacturing Operations; Condition 2-235 for Part 212.10 Volatile Organic Compound (VOC) Reasonably Available Control Technology (RACT) Compliance; and Condition 2-464 for Part 212.4 Best Available Control Technology (BACT) compliance.

The Bioton unit has been inactive since July 2008, due to corrosion-induced failure of its exhaust fan. Based on an updated VOC RACT analysis, it has been determined that the Bioton has reached the end of its useful life and is no longer cost effective to operate. Therefore, the Draft Permit removes references to the Bioton (Control Device ID 32517) in Condition 27.90 and Part 212 VOC RACT and BACT compliance Conditions 2-235 and 2-464. In addition to removing the requirement to operate the Bioton, the emission limits for Part 212 VOC and regulated toxic emissions have been reduced. The limit for Part 212 VOC emissions in Condition 2-235 has been reduced from 105 tons per year (tpy) to 66 tpy. The limits for Part 212 toxic compounds in Condition 2-464 have been reduced from 160.4 tpy to 144 tpy for total combined emissions of these compounds, and from 6 tpy to 2 tpy for total combined emissions of the most toxic A-rated compounds. These reductions reflect overall emission decreases, offsetting increases due to the shut-down of the Bioton.

No other changes have been proposed to the current Title V Facility Permit. The Department has generated a Draft Title V Facility Permit and has made a tentative determination to modify the current Permit, to authorize the changes indicated above. Draft Permit changes are limited to the 3 conditions indicated above.

The application, Draft Permit, Permit Review Report, and VOC RACT analysis 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

For reference, the entire current Title V Facility Permit, without the proposed modification, may be viewed or downloaded at: http://www.dec.ny.gov/dardata/boss/afs/issued_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/chemical/32249.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 Apr 13, 2009.


Roger T McDonough
NYSDEC Region 8 Headquarters
Avon, NY 14414

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