Six Days Left on the Antioxidant Plant
New York's order gave Goodyear until October 31 2026 to have permanent emission controls installed and running at Niagara Falls. October 31 2026 is also the last day Goodyear says the plant will operate. Here is what the order actually required, what the 8-K still will not tell you, and what to do with the six days.
In 2021 New York revised its outdoor air guideline for ortho-toluidine from 21 micrograms per cubic metre to 0.02.
That is a factor of 1,050, decided in one revision, on a molecule that one plant in the state buys by the tanker to make rubber antioxidants.
Four years later the state wrote Goodyear an order setting the date by which permanent controls had to be installed and operational at the Niagara Falls plant. The date was October 31, 2026.
Last month Goodyear's board approved closing the plant. The company's own statement puts the last operating day at October 31.
"What happens to a control project when the deadline and the final shift are the same day?"
The Deadline and the Last Shift
Start with the sequence, because the sequence is the whole story (chart above).
DEC issued a notice of violation in July 2023, on two violations, and its own public briefing is explicit that there were "No violations related to public health impacts." The Order on Consent was signed January 14, 2025. It required, in DEC's own wording, "Interim controls and a reduction in production limits that will take effect within two months of DEC approval of Goodyear's proposal which is due by January 31, 2025."
Note the second half of that clause. A reduction in production limits is a capacity action written into an enforcement document, and it has been in force at this site for most of two years.
Then the long one: "Submission of an air pollution control engineering study ... proposing permanent pollution controls to be installed and operational by October 31, 2026."
(DEC's slide prints the study deadline as March 15 2024, which precedes the order. Contemporaneous reporting puts it at 60 days after signing, so the year is a slip for 2025 and we use that.)
Two more obligations sit behind the controls. A stack test once they are installed, and an air dispersion model run on the approved protocol using that test's results.
Both are conditional on equipment that now has six days to appear.
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