OMB No. 2010-0032 Expiration Date 01/10/2010

Performance Track Membership Renewal Application 2007 Kodak Colorado Division Eastman Kodak Company Member since 2004 A080018

In the table below, please enter your facility's amount of non-hazardous waste, broken down by waste management method. Please enter both the amounts that you manage currently and that you intend to manage in 2009. "Waste" is defined as all materials that are sent off-site that are neither product nor product packaging.

Is the goal of your non-hazardous waste commitment to reduce non-hazardous waste, to improve methods of waste management, or a combination of both?		Combination of Both Strategies
4a	Please provide information for these calendar years.	Baseline: 2006	Future: 2009
4b	Method of Waste Management	How much of your waste is handled using each management method?
		Baseline	Future	Units
Reused/recycled off-site		11,364,216	11,468,526	Pounds
Landfill		2,086,201	1,981,891	Pounds
Total Non-Hazardous Solid Waste		6,725.21	6,725.21	Tons

5	Does the quantity presented in the future quantity column represent an absolute goal or a normalized goal?	Normalized goal (i.e. indexed to level of business in        baseline year)
6	Whether your goal is absolute or normalized, in your annual performance reports you will need to provide normalizing factors and normalized quantities of your annual data. In the textbox to the right, please briefly describe your basis for normalizing. Examples of potential normalizing bases include:      -gallons of paint produced -square feet of circuit boards sold -number of patients seen -dollars of sales adjusted for inflation -number of employees (for R&D and administrative sites only)	Normalized by million square meters (MSM) of total product produced at the facility
7a	Are you subject to Federal, State, Tribal, or local regulatory requirements for this indicator?	No
7b	If yes, please list those requirements, including the quantitative limits and compliance deadlines that apply to you. Explain how your commitment exceeds requirements.

Commitment 3

1a	What category have you selected from the Environmental Performance Table?	Water Use
1b	What indicator have you selected from the Environmental Performance Table?	Total water used
1c	Does your commitment include everything covered by the indicator (e.g., all VOCs, all non-hazardous waste), or a specific substance or component (e.g., ethane, cardboard)?	All
1d	What activities or process changes do you plan to undertake at your facility to accomplish your commitment e.g., technology changes in a particular process line, employee training?	Water conservation and use reduction efforts have been ongoing at KCD and will continue following the recent divesture. Specific utility projects have been identified but, to date, have not been initiated. These projects and any new projects will be reviewed by both KCD and the 3rd party contract that operates the utility facilities on-site to determine the current feasibility. Manufacturing uses of water at KCD include not only direct incorporation into coatings but also steam generation, operation of multiple cooling towers, and multiple baths associated with lithographic plate manufacturing. The Graphic Communications Group in building C-60 conducts the manufacturing of lithographic plates and has specific projects underway to reduce water use within their operations. Additional opportunities for conservation arise in all aspects of water use at KCD will be considered for near-term reduction projects. Site Environmental personnel will be involved in tracking water use reductions against PTrack commitments and site management will be advised of current progress quarterly.
2	Are you proposing this as a Challenge Commitment?	No
3a	Does this commitment address a significant aspect in your EMS?	Yes
3b	If no, please explain why you believe this indicator should be included as a performance commitment.

		Baseline	Future
4a	Please provide information for these calendar years.	2006	2009
4b	What units are you using to quantify this indicator?	Gallons
4c	List the baseline annual quantity of the indicator and the annual quantity you are commited to achieve by the future year.	214,324,996	203,608,746

5	Does the quantity presented in the future quantity column represent an absolute goal or a normalized goal?	Normalized goal (i.e. indexed to level of business in        baseline year)
6	Whether your goal is absolute or normalized, in your annual performance reports you will need to provide normalizing factors and normalized quantities of your annual data. In the textbox to the right, please briefly describe your basis for normalizing. Examples of potential normalizing bases include:      -gallons of paint produced -square feet of circuit boards sold -number of patients seen -dollars of sales adjusted for inflation -number of employees (for R&D and administrative sites only)	Normalized by million square meters (MSM) of total product produced at the facility
7a	Are you subject to Federal, State, Tribal, or local regulatory requirements for this indicator?	No
7b	If yes, please list those requirements, including the quantitative limits and compliance deadlines that apply to you. Explain how your commitment exceeds requirements.

Commitment 4

1a	What category have you selected from the Environmental Performance Table?	Alternate Commitment
2	Please provide a short description of the environmental problem or issue that you propose to address.	Currently, NPDES permitted dischargers are assigned permit limits at their discharge point(s) and very little information exists about the ambient water quality in the receiving water body. KCD and other dischargers to Segments 11,12, & 13 of the Cache la Poudre River have come together to form an ambient water quality-monitoring group. This group was formed in cooperation with the Colorado Department of Public Health & Environment (CDPHE) to monitor the ambient water quality of the receiving water body.
3	Why is this an important environmental issue?	This is an important environmental issue because the ambient water quality of the river is the true measure of the effectiveness of established permit limits. This group will provide coordinated and accurate data about the water quality along 45 river miles year round, which will be available to members of the monitoring group, regulators, and the public.
4	Please provide a description of the activities you intend to conduct.	KCD will actively monitor and fund the associated biological studies for 2.5 of the 9 currently established river assessment locations (sites). Each of these sites will be sampled at least 4 times per year for water quality, at least twice a year for benthic analysis, and at least once a year for fish. The water quality parameters evaluated and the associated testing methods will be reviewed annually with CDPHE. All ambient water quality results obtained by the group will be provided to regulators and the public through an intermediate database that will subsequently upload the data to the EPA database STORET.
5	How do you plan on measuring the environmental benefit(s) of the project?	The environmental benefits of this project will become evident as the water quality data is acquired and analyzed by the interested parties. State regulators will apply new or adjust existing effluent limitations in the event that the ambient water quality suggests that additional limitations are warranted. Beyond potential changes to discharger’s permits, the public will have access to the ambient water quality information as its obtained.
6	Summarize the milestones for the next three years, projected dates of milestones, and desired outcome/environmental benefit below.
	Milestone Project Date of Completion Desired Outcome & Environmental Benefit Measurable Improvement, if applicable Participant’s Agreement June 30, 2007 Solidify group relationship and ensure continuity of program Annual commitment to acquire and publish ambient water quality data Data Sharing Defined August 31, 2007 Program in-place to act as a repository for data accessible by dischargers, regulators, and the general public. Ambient water quality data readily available. Annual Participant’s Agreement Renewal May 31, 2008 Solidify group relationship and ensure continuity of the program. Annual commitment to acquire and publish ambient water quality data Annual Review of Water Quality Parameters with CDPHE July 31, 2008 Ensure that the data acquired is relevant to potential water quality concerns in the segments Accurate and Relevant water quality data will be available Annual Participant’s Agreement Renewal May 31, 2009 Solidify group relationship and ensure continuity of the program. Annual commitment to acquire and publish ambient water quality data Annual Review of Water Quality Parameters with CDPHE July 31, 2009 Ensure that the data acquired is relevant to potential water quality concerns in the segments Accurate and Relevant water quality data will be available
7	List any stakeholders or collaborators that you propose to work with on this project and indicate whether you’ve secured a goal from them.	City of Fort Collins (Committed) South Fort Collins Sanitation District (Committed) Boxelder Sanitation District (Committed) Town of Windsor Sanitation District (Committed) City of Greeley Sanitation District (Committed) North Front Range Water Quality Planning Association (Collaborator, 208 Committee Subgroup) Colorado State University (Collaborator, Conduct Fish and Benthic studies at each of the sampling loctions) Colorado Department of Public Health & Environment - Water Quality Control Division (Collaborator)

Section C Attachments (if applicable):

Section E: Self-Certification of Continued Program Participation On behalf of Kodak Colorado Division, I certify that: I have read and agree to the terms and conditions for Membership Renewal and Participation in the National Environmental Performance Track, as specified in the National Environmental Performance Track Program Guide and in the Renewal Application Instructions; I have personally examined and am familiar with the information contained in this Renewal Application. The information contained in this Renewal Application is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete, and I have no reason to believe the facility would not meet all program requirements; My facility has an environmental management system (EMS), as defined in the Performance Track EMS requirements, including systems to maintain compliance with all applicable Federal, State, tribal, and local environmental requirements in place at the facility, and the EMS will be maintained for the duration of the facility's participation in the program My facility has conducted an objective assessment of its compliance with all Federal, State, tribal, and local environmental requirements, and the facility has corrected all identified instances of potential or actual noncompliance; Based on the foregoing compliance assessment and subsequent corrective actions (if any were necessary), my facility is, to the best of my knowledge and based on reasonable inquiry, currently in compliance with applicable Federal, State, tribal, and local environmental requirements. I agree that EPA's decision whether to accept participants into or remove them from the National Environmental Performance Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's acceptance or removal decision. I am the senior facility manager and fully authorized to execute this statement on behalf of the corporation or other legal entity whose facility is applying to this program.

Signature/Date:	______________________________________________________
Name:	Mr.  Robert K. Gray
Title:	Site Manager, Kodak Colorado Division
Phone Number:	(970) 686-4121
E-Mail Address:	robert.k.gray@kodak.com
Facility Name:	Kodak Colorado Division
Facility Street Address:	9952 Eastman Park Drive Windsor, CO 80551-1590
Mailing Address:	9952 Eastman Park Drive
Address cont:
City, State Zip:	Windsor, CO80551
Member ID#:	A080018

Environmental Requirements Checklist

Facility Identification Information
1.	Do you have a RCRA identification number? (A RCRA number is used in the RCRAInfo database for Resource Conservation and Recovery Act (RCRA) programs).
	Yes
	RCRA ID: COD078341658
2.	Do you have a TRI identification number? (A TRI number is used in the Toxics Release Inventory (TRI) for Emergency Planning and Community Right-to-Know Act).
	Yes
	TRI ID: 80551KDKCLCOUNT
3.	Do you have an AFS identification number? (An AFS number is used in the AIRS Facility Subsystem of the Aerometric Information Retrieval System (AIRS) for Clean Air Act programs).
	Yes
	AFS ID: 0812300003
4.	Do you have a PCS/NPDES identification number? (A PCS/NPDES number is used in the Permit Compliance System (PCS) for Clean Water Act programs monitoring National Pollutant Discharge Elimination System (NPDES) permits).
	Yes
	PCS/NPDES ID: CO0032158 – Industrial Wastewater Discharge Permit, COG600373 – Minimal Discharge Permit, COR020116 - Heavy Industrial Storm Water Discharge Permit, COG380009 - Treated Water Discharge Permit
5.	Do you have a FIFRA identification number? (A FIFRA number is given to facilities regulated by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)).
	Yes
	FIFRA ID: 059441-CO-001
Air Characteristics
1.	Is your facility a State Air Permit Holder?
	Yes
2.	Is your facility a Clean Air Act Major Source?
	No
3.	Is your facility a Clean Air Act Synthetic Minor Source?
	Yes
4.	Is your facility a Clean Air Act Minor Source?
	Yes
5.	Is your facility subject to New Source Performance Standards (NSPS)?
	Yes
	If so, which NSPS are you subject to? Subpart TT - Metal Coil Surface Coating
6.	Is your facility subject to National Emissions Standards for Hazardous Air Pollutants (NESHAPS)?
	No
7.	Is your facility subject to Section 112/Maximum Achievable Control Technology (MACT) standards?
	Yes
	If so, which MACT standard(s) are you subject to?Printing & Publishing MACT (Subpart KK), Paper & Other Webs Coating MACT (Subpart JJJJ), Boiler MACT (Subpart DDDDD), Metal Coil Coating MACT (Subpart SSSS), Miscellaneous Coatings Manufacturing MACT (Subpart HHHHH), Miscellaneous Organic Chemical Manufacturing MACT (Subpart FFFF), Organic Liquids Distribution MACT (Subpart EEEE), Wood Furniture Surface Coating MACT (Subpart JJ)
8.	Is your facility subject to SIP (State Implementation Plan) requirements (including Reasonably Available Control Technology (RACT))?
	Yes
	If so, which SIP requirement(s) are you subject to?As a permitted facility in a delegated state, Kodak Colorado Division is subject to all the requirements of the Colorado SIP.
9.	Is your facility a Title V permit holder?
	Yes
10.	Is your facility subject to Section 129 combustion requirements?
	No
11.	Is your facility subject to National Ambient Air Quality Standards (NAAQS)?
	Yes
	If so, which NAAQS are you subject to?All of them in so far as the Colorado SIP determines Title V and APEN requirements for criteria pollutants in terms of attainment / non-attainment status with respect to NAAQS. Kodak Colorado is located in an attainment area for all criteria pollutants.
12.	List relevant state/local/tribal/other air requirements: (If none, please enter "n/a".)
	n/a
Water Characteristics
1.	Is your facility a State Water Permit Holder?
	Yes
2.	Is your facility Required to Pretreat?
	Yes
3.	Is your facility a National Pollutant Discharge Elimination System (NPDES) Permit Holder?
	Yes
4.	Is your facility subject to Phase I of the NPDES Storm Water Program?
	No
5.	Is your facility subject to Phase II of the NPDES Storm Water Program?
	No
6.	Is your facility subject to the Spill Prevention Control and Counter Measure (SPCC) requirements of the Clean Water Act?
	Yes
7.	Is your facility subject to industry specific effluent guidelines and standards?
	Yes
	If so, which guidelines and standards are you subject to?Separate parts of the facility are subject to 40 CFR Subchapter N Part 459 - Photographic PSC, and Part 414 - Organic Chemicals, Plastics, and Synthetic Fibers
8.	List relevant state/local/tribal/other water requirements: (If none, please enter "n/a".)
	n/a
Hazardous Waste Characteristics
1.	Is your facility a Large Quantity Generator?
	Yes
2.	Is your facility a Small Quantity Generator?
	No
3.	Is your facility a Conditionally Exempt Small Quantity Generator?
	No
4.	Is your facility a Treatment, Storage, or Disposal (TSD) Facility?
	Yes
5.	List relevant state/local/tribal/other hazardous waste requirements: (If none, please enter "n/a".)
	n/a
Environmental Clean-Up, Restoration, and Corrective Action Characteristics
1.	Is your facility a Potentially Responsible Party under CERCLA or Superfund for onsite clean-up?
	No
	If so, please provide Record of Decision date:
2.	Is your facility a Potentially Responsible Party under CERCLA or Superfund for offsite clean-up?
	Yes
	If so, please provide Record of Decision date: Action Memorandum PRP Lead Notification for Non-Time Critical Removal, September 25, 2000
3.	Is your facility a Potentially Responsible Party in a federal or state clean-up of hazardous waste and/or oil?
	Yes
4.	Is your facility Engaged in RCRA corrective action?
	No
5.	List other relevant federal/state/tribal/local environmental clean-up, restoration, or corrective actions not listed above. Please include date(s) of any remedy decisions. (If none, please enter "n/a".)
	n/a
Other Environmental Characteristics
1.	Is your facility a Toxic Release Inventory (TRI) Reporter?
	Yes
2.	Is your facility regulated under the Safe Drinking Water Act?
	No
3.	Is your facility subject to Underground Storage Tank (UST) Regulations?
	Yes
4.	Is your facility regulated under Toxic Substances Control Act (TSCA)?
	Yes
5.	Is your facility subject to Worker Right-to-Know Regulations?
	Yes
6.	Is your facility required to file an emergency management plan under the Emergency Planning and Community Right-to-Know Act (EPCRA)?
	Yes
7.	Is your facility regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)?
	Yes
8.	List relevant state/local/tribal/other requirements: (If none, please enter "n/a".)
	n/a