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ENB Region 8 Completed Applications 07/25/2012

Monroe County


Rochester Silver Works LLC
681 W Ridge Rd
Rochester, NY 14652


Rochester Silver Works
Eastman Business Park Buildings 101, 110, 117, 138, 143, 144, 145, & 156
Rochester, NY 14652

Application ID:


Permit(s) Applied for:

Article 19 Air Title V Facility

Project is Located:

Rochester, Monroe County

Project Description:

The Department has received an application from Rochester Silver Works LLC for renewal of its current Title V Facility Permit for silver recovery and silver nitrate production operations occurring in eight Buildings in Eastman Business Park, Buildings 101, 110, 117, 138, 143, 144, 145, and 156. No significant changes in operations are proposed.

The current Title V Permit was transferred to Rochester Silver Works LLC from Eastman Kodak Company. Silver recovery and silver nitrate production operations are subject to Title V regulations due to potential emissions of individual Hazardous Air Pollutant (HAP) compounds greater than 10 tons per year each, total HAP potential emissions greater than 25 tons per year, and potential emissions of oxides of nitrogen (NOX), particulate matter (PM), particulates smaller than 10 microns (PM-10), sulfur dioxide (SO2), and volatile organic compounds (VOC), greater than 100 tons per year each.

Rochester Silver Works is also a major facility as defined in 40 CFR 52.21 Prevention of Significant Deterioration (PSD) due to potential emissions of NOX, PM, PM-10, SO2, HAP, and VOC greater than 250 tons per year each.

Rochester Silver Works proposes to maintain three variances approved previously when the processes were run by Kodak: A Part 212.10 VOC Reasonably Available Control Technology (RACT) variance with a 30.02 tons per year limit on VOC emissions from the Cowles Washers, a caustic process which recovers silver film emulsion from film scrap; A Part 212.4(a) Best Available Control Technology (BACT) variance limiting Cowles Washer emissions of dichloromethane, acetone, butanol, and cyclohexane to a total of 37.04 tons per year and the A-rated HAP dichloromethane to a total of 3.14 tons per year; and A Part 212.10 NOX RACT and 40 CFR 52 PSD variance with a 10.5 ton per year limit on NOX emissions from the Silver Roaster, which burns off the extracted film emulsion to produce a silver-rich ash for further refining. The Part 212 VOC RACT and BACT variances for the degree of control required for the Cowles Washer emissions are based on demonstrations that additional controls were found to not be technically feasible or cost effective. For the Silver Roaster, the NOX RACT and PSD variance is based on the use of natural gas fired low-NOX burners and that no further controls were found to be cost effective.

In response to the application, the Department has generated a Draft Title V Facility Permit, and has made a tentative determination to send the Draft as a Proposed Permit to EPA for review, if comments received do not raise significant issues that must be addressed. The application, Draft Permit, and Permit Review Report 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

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 not subject to SEQR because it is a Type II action.

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 Aug 24, 2012.


Roger T McDonough
NYSDEC Region 8 Headquarters
Avon, NY 14414

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