Specialty Manufacturing Facility

Roux was contracted to expedite a New York State Department of Environmental Conservation (NYSDEC) Air State Facility (ASF) permit modification application for a specialty manufacturing facility in Western New York, where hydrochloric acid and dioxin/furan emissions are controlled via packed tower wet caustic scrubbers and mist eliminators.

Roux provided support for process modification improvements, Toxics Best Available Control Technology (T-BACT) analysis, air dispersion modelling, and Climate Leadership and Community Protection Act (CLCPA) analysis. Because the facility is within a Disadvantaged Community (DAC) and potential Environmental Justice (EJ) area, Roux also supported developing an enhanced Public Participation Plan and cohosted the virtual public meeting.

Roux addressed the NYSDEC and local environmental advocacy group concerns and negotiated a modified ASF permit that allows operation of a third production line at full capacity with no additional monitoring, recordkeeping, or reporting burden. Roux also assisted in preparing the Quality Assurance Monitoring Plan (QAMP) and Preventative Maintenance and Inspection Procedure (PM&IP) Plan required of the ASF permit. Roux continues to provide permit compliance assistance including permit modifications and renewal support.