Comments on OPG’s…

Comments on OPG’s Application for Site Specific Air Standards (SSRA permit)

OPG Lennox Generating Station (LGS) will not be able to meet the provincial air pollution standards that come into effect in 2023. The SSRA permits will allow OPG to pollute even more.

OPG Lennox makes use of residual fuel oil (RFO) when there is a shortage of natural gas. With some of the nuclear power plants scheduled to go offline in the near future and the cancelling of renewable energy programs by the provincial government, OPG will be called upon to provide more power as backup to the grid.

According to OPG’s records, from 2015 to 2019 at LGS: residual fuel oil was used 45 % of the time, and from 2010 to 2020 at LGS: residual fuel oil was used 49 % of the time. Thus, their use of RFO is commonplace, even though OPG has given reports to the public that their use of RFO is rare.

The cumulative health risks and impacts on the surrounding population have not been rigorously studied. In addition to OPG - LGS, this area also has the Napanee generating plant, and cement plants in Bath and Picton. All of these are in close proximity.
The pollution from these plants adversely affects the nearby communities of Bath and Napanee, as well as the cities of Kingston and Belleville. The health of many citizens is at risk.

A coastal weather fumigation event is another area of concern. Over the next ten years, we are likely to experience more severe meteorological “events.” There has been insufficient “real time” modeling of the lateral and vertical dispersion of air pollutants from the OPG tall stack that is very close to the Lake Ontario shoreline. There should be a climate analysis of this proposal.

Even infrequent events of polluting emissions may still present very serious impacts on community health and the environment. Sulfur Dioxide can do substantial harm to the respiratory systems of people and animals.

Questions:
How will OPG effectively warn people when they are about to burn residual fuel oil?
If this burning of residual fuel oil lasts for 24 hours or longer, how can citizens be expected to protect themselves?

Why is OPG is pursuing these specific air standard exemptions instead of seeking alternative methods for meeting the new air standards that are not so detrimental to health?

What would happen in a worst-case weather fumigation event and how would people be affected?

Why Is OPG not providing real time modelling to the public?

Why does OPG continue to burn Residual Fuel Oil at this plant? The adverse health effects of Sulfur Dioxide alone are well known.

The Ontario Environmental Bill of Rights:
Its purposes include preventing, reducing, and eliminating pollutants that are an unreasonable threat to the integrity of the environment.
This application for Site Specific Air Standards is an unreasonable threat to the integrity of our environment.

Thank you for consideration of our comments.