What’s on the Horizon for Air Quality and How Do Industrial Facility Owners Prepare?

A major storm related to air quality is on the horizon. Together, a variety of challenges are spurring change for industrial clients. From ambitious decarbonization goals to funding from the Infrastructure Investment and Jobs Act, the insight of an experienced air quality specialist brings clarity and confidence to establishing an effective air quality plan. 

Greg Raetz is a specialist in air quality and permitting who’s spent 20 years at HDR. He’s a guiding force for our industrial clients as they address evolving air quality issues. 

Q: What do you see as upcoming air quality challenges for industrial owners?

A: Right now, there’s a combination of regulatory and market forces that require planning, and they’re bringing some significant operational concerns. These items are tied together, and the preferred solution for one will impact the solution for others. For instance:

• Regional Haze requirements are dictating possible onerous and expensive pollution controls.
• Ambient air quality standards and aging infrastructure require multimillion dollar investments for boiler stack modifications.
• Customer demands and future greenhouse gas requirements are putting extreme demands on fuel flexibility and carbon emission reductions.
• Regional natural gas supplies are scarce and present some long-term investment concerns.
• Environmental Justice is an emerging trend that can result in greater public visibility and potential project approval delays.

I can tell you there is a lot of uncertainty and partnering with a trusted advisor who’s monitoring the requirements can simplify decision-making. As GHG requirements continue to evolve and energy production shifts to renewables, many industrial facilities are looking at how they can stabilize their own energy production and costs, as well as answer to stakeholder demands, with combined heat and power. Many rules are subject to periodic review and revision that can change dramatically with changing government administrations. Emerging trends such as environmental justice and environmental, social and governance criteria can be challenging to navigate. Finally, with every passing year, enhanced monitoring and compliance activities are also becoming more complex and facilities as well as regulators are having to tackle it all with fewer resources.   

The answer is not yet apparent, but the message is: these are converging major issues that are going to impact much more than the air permit, and they must be acted on now while clients still have a chance to direct the solution and not just react.

Q: How have you helped industrial owners with changing air quality requirements in the past? 

A: I’ve worked with many industrial clients for more than 20 years, and we’ve worked through a lot of regulatory and market changes together. One of my primary clients is American Crystal Sugar Company. We’ve maintained a very strong relationship with them since 1995, and a good example of the kind of partnership we have with American Crystal comes from an event more than 10 years ago. 

At that time, there was what I like to call “a perfect storm of regulations” brewing on the horizon — similar to what is happening now. The federal government had just passed new, restrictive ambient air quality regulations that limited the concentrations of pollutants allowed to be emitted from industrial operations. There was also a new regulation that had been slowly making its way to final form that would impact all industrial boilers, specifically coal-fired boilers. 

In looking at these rules, we knew there were going to be challenges for American Crystal. They had five factories in the upper Midwest that utilized a fleet of coal-fired boilers, and all of them were looking at significant modifications to reduce emissions and comply with the new rules. At the time, the bulk of new requirements were still in draft form and changing continually. However, we knew once the new rules were finalized, facilities would only have a year to confirm they were in compliance. 

Given a fleet of more than a dozen boilers and five factories, American Crystal’s changes could not take place in one year, and we needed to start early — before the rules were even final. Not only was it a huge financial commitment, but it was also operationally impossible to shut down every factory and orchestrate all the required changes at once. One afternoon, I took a trip to American Crystal’s corporate office and broke the news — it was time to start updating equipment. 

Given our long-term relationship, American Crystal never questioned what I was telling them was on the horizon, they just asked what they needed to do to get ready. That began a multi-year journey to compliance with numerous studies and planning all the way to final project implementation and compliance. Two notable events included:

1. About a year into the process, I had the opportunity to present a paper at the Council of Industrial Boiler Owners annual conference. I highlighted our initial studies at American Crystal and what would be necessary for boiler modifications to meet compliance, as well as our plan going forward. After the talk, I was surrounded by vendors who asked me, “How did you get American Crystal to move forward and start planning and engineering prior to all of the rules being finalized? We can’t get anyone to move; they are all waiting.” I took it as great testament to the trust between our team and American Crystal. They knew we were not leading them on for a quick buck, but understood they had some major challenges coming.
2. After we finished the initial strategy for compliance that outlined necessary equipment modifications, I brought in a team of our engineers to talk a little bit about what we could do on the owners engineer side to assist with design, equipment procurement and construction management. After that talk, the vice president of operations took me in the back room and asked, “Can your team do this?” I said, “Yes, we can.”  We were given an opportunity that lasted over the next four years to manage all the engineering work. It was really a testament to our relationship.

Q: Has our relationship with American Crystal grown over the years?

A: Since the start of our relationship, we have provided just about every air quality service you can think of to American Crystal: 

• Construction and operating permits.
• Ambient air quality risk analysis using computerized dispersion models.
• Regulatory compliance support.
• Operator training.
• Performance test management.
• Air pollution control equipment analyses.
• Site-specific emission factor development.
• Compliance audits.
• Strategic consulting for operational flexibility and design.
• Regulatory negotiation and enforcement support.

Of course, air quality is a unique service. Helping with air quality issues allows us to touch upon every area of a given facility from the very beginning of the process to the very end of the final product going out the door. We look at everything in the production process to determine if air emissions might be generated, including the building itself and things like comfort heating and hot water. Because of this, we, get to see and understand the whole process and all the operational concerns. 

Throughout the years, we have developed and strengthened our relationship with American Crystal to become a true trusted advisor, which gives American Crystal quick access to national experts it can count on as additional air quality standards evolve. We have expanded our services to help with other aspects of plant operations, including:

• Owners engineer services for coal-fired boiler modifications.
• Air pollution control equipment technical analyses.
• Air pollution control engineering and procurement.
• On-site construction management.
• Wastewater plant evaluation.
• River diffuser design.
• Sustainability program management.
• GHG reporting.
• Compliance software development.
• Process safety management plan development and training.

Our work with American Crystal is a great example of our ability to partner with clients to address changing air quality regulations, like those on the horizon. Right now, there’s even potential to help clients take advantage of programs and grants offered through the Infrastructure Investment and Jobs Act.

Q: What opportunities might there be related to industrial facilities and air quality in the IIJA?

A: One thing we’ve seen already, which is supported by IIJA investments, is the U.S. Department of Agriculture investing $1 billion in Climate Smart Commodity Grants. A climate-smart commodity is an agricultural commodity, like sugar or a sugar production byproduct like lime, that is produced and managed using new agricultural practices the applicant proposes to reduce GHG emissions or sequester carbon. To apply for the grants, applicants must show how their proposed projects implement climate-smart production practices, activities and systems on working lands; quantify, monitor, and verify the carbon and GHG benefits associated with those practices, and develop markets and promote the resulting climate-smart commodities. We can help our industrial clients apply for investments like this to help them meet air quality goals.

We’re watching as new programs like the Climate Smart Commodity Grants become available and advising our clients on how to take advantage of these potential investments in their businesses. We’re also keeping on top of air quality regulatory discussions, such as environmental justice, so we can help our clients proactively plan for changes.