Ontario Power Generation Inc. - Approval of a site-specific air standard

As a result of this public consultation, we received 59 comments. All questions and comments submitted regarding this proposal were considered. The director did not make alterations to the proposed site-specific standard approval documents in response to the received comments.

The following is an overview of common themes that were raised and the ministry’s response to each:

Comment:

It is wrong to exempt facilities from meeting Ontario’s air standards which were set to protect the public and the environment and they shouldn’t be waived when power demands are high and natural gas supply is limited.

Response:

Air standards are used by the ministry to assess the contributions of a contaminant to air by a regulated facility. Facilities challenged to meet air standards due to technical and/or economic challenges can request a site-specific standard.

Site-specific standards are developed with full public transparency through public meetings and consultations. They include technology benchmarking to determine what is feasible for a facility to achieve in terms of controlling emissions of a contaminant over a set period (i.e., at least five years but not more than 10 years).

Compliance with a site-specific standard, just like a general air standard, must be demonstrated by using air dispersion modelling. A facility that meets its site-specific standard is in compliance with the regulation.

OPG Lennox is able to comply with Ontario’s air standards when the facility uses natural gas to generate electricity, which is the most common and preferred operating scenario for the facility. The ministry’s review of OPG’s site-specific standard request determined that the proposed emission reductions due to the transitioning to lower sulphur content residual fuel oil and monitoring requirements are appropriate in consideration of requirements for similar facilities in other leading jurisdictions. In addition, the expected rare occurrences of when the facility is using residual fuel oil at maximum operating rates coinciding with meteorological conditions that may cause maximum levels of sulphur dioxide off-property, was also considered in the decision to approve the requested site-specific standards.

The ministry will closely monitor OPG Lennox’s progress to ensure that the desired results are achieved. This ensures continuous improvement and decreasing emissions to better protect the environment.

Comment

It is not acceptable for new facilities to not meet the provincial air standards.

Response:

The request for site-specific standards is for an existing facility. The Lennox Generating Station was commissioned in 1976 and requires site-specific standards in order to comply with the Local Air Quality regulation (O. Reg. 419/05) when using residual fuel oil. The Local Air Quality regulation allows new facilities to request site-specific standards and has requirements to ensure that new facilities implement best available control measures to reduce emissions of contaminants.

Comment:

I live within a few kilometres of the Lennox Generating Station and DO NOT want this additional pollution to be allowed. This can directly affect my family’s health.

Response:

The site-specific standards will require the facility to continuously reduce hourly emission rates from current levels over the duration of the approval. This will be achieved primarily through requirements for the purchase and use of residual fuel oil with a sulphur content no greater than 0.5 percent (by weight) starting immediately and for the entire duration of the site-specific standard.

In addition, the ministry will require a minimum fuel purchase of 50,000 barrels with a fuel sulphur content of 0.5 percent or below before December 31, 2023, to reduce the sulphur content in the short term, and reduce sulphur content of the entire fuel inventory at the Lennox station to an annual average of 0.6 percent (by weight) or lower within five (5) years from the time of the site-specific standards approval. OPG Lennox has already installed the best available control technology for the oxides of nitrogen.

When using residual fuel oil, there is the potential that the emissions from OPG Lennox could lead to ambient air concentrations of nitrogen dioxide, sulphuric acid and sulphur dioxide that are of a health concern. This needs to be considered in conjunction with the expected infrequent occurrence of when the facility is using residual fuel oil at maximum rates coinciding with meteorological conditions that may lead to maximum levels of contaminants off-property. Although these occurrences are rare, the ministry is working with OPG Lennox to reduce these emissions and better protect the surrounding community by providing monitoring and notification system through transparent community communication.

Comment:

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

Response:

OPG Lennox operates as a “peaking plant” providing additional electricity to the grid during peak demand situations. Due to this mode of operation, the facility only operated at 0.5 per cent of its annual capacity in the last 10 years. Out of this 0.5 per cent capacity utilization, the facility used residual fuel oil less than 46 per cent of the time. OPG Lennox is expected to operate at approximately 2 per cent of capacity in the future due to projected generation shortfalls from other facilities expected to occur in Ontario in 2026.

Typically, the OPG Lennox Generating Station is the last on and the first off in the Ontario electricity generating system. Most of the time, the plant sits idle at or near a minimum load of 28 megawatt (MW) with the ability to ramp up quickly, if needed. When called upon to operate, the station typically operates at less than 200 MW, and occasionally up to 500 MW. Data from 2015-2019 shows that the Lennox Generating Station operated between five and 200 MW for over 95 per cent of the time. The facility is expected to meet Ontario’s air standards during these operating periods when using natural gas or residual fuel oil.

Comment:

The cumulative health risks and impacts on the surrounding population have not been rigorously studied. In addition to the OPG Lennox Generating Station, this area also has the Napanee generating plant, and cement plants in Bath and Picton. All of these are in close proximity.

Response:

Emissions from other major industrial facilities near OPG Lennox, including the Napanee Generating Station, and the cement plants were reviewed, and their cumulative impacts were considered during the technical review of this site-specific standard request. The ministry’s technical review found that the additional impact from other facilities on the same location (sensitive receptors) in the vicinity of OPG Lennox are not significant.

Comment:

A coastal weather fumigation event is another area of concern. Over the next ten years, we are likely to experience more severe meteorological conditions. There has been insufficient coastal modeling of the lateral and vertical dispersion of air pollutants from the OPG tall stack that is very close to the Lake Ontario shoreline.

Response:

The facility did consider shoreline fumigation conditions in their assessment using the CALPUFF dispersion model, which utilizes 3D meteorology (both lateral and vertical directions) assessed over a five-year meteorological data set. The predicted site-specific standard values are based on shoreline fumigation effects and the ministry did review the maximum modelled concentrations against fumigation characteristics to confirm the maximum concentrations. The shoreline fumigation effects were found to generally not occur during hot summer or colder winter weather conditions which are times that the Lennox facility may be operating at elevated levels utilizing residual fuel oil.

Comment:

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.

Response:

When using residual fuel oil at elevated rates, there is potential that this could lead to ambient air concentrations of contaminants that are high enough to cause serious respiratory and other health effects, and for this reason are of concern. However, this needs to be considered in conjunction with the expected infrequent occurrence of when the facility is using residual fuel oil together with operating at maximum rates coinciding with meteorological conditions that may lead to maximum levels of contaminants occurring off-property. Although these occurrences are rare, the ministry is working with OPG Lennox to reduce these emissions and better protect the surrounding community.

Comment:

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?

Response:

The site-specific standards approvals and corresponding amendment to the facility’s environmental compliance approval (ECA) require the Lennox Generating Station to:

• install and operate two monitoring stations and a meteorological tower in the areas where higher concentrations of sulphur dioxide are expected. These locations were selected based on a modelling and statistical analyses.
• create a community liaison committee that includes interested local citizens, First Nations and Public Health representatives to provide timely and transparent information about operations and emissions
• notify the ministry and the public when two consecutive five-minute concentrations of sulphur dioxide exceed 530 micrograms per cubic metre or when the 1-hour concentration exceeds 320 micrograms per cubic metre through a notification system established through consultation with the community liaison committee
• notify the public and ministry in advance of peak use of residual fuel oil when high emissions of sulphur dioxide and oxides of nitrogen are anticipated, and increased community exposures are expected and make monitoring information easily accessible to the public on a website

Comment:

The looser emission standards reflects OPG’s intention to run more fuel oil (vs. natural gas).

Response:

The Lennox Generating Station is the only facility in Ontario that has the ability to operate on either natural gas or residual fuel oil (RFO). The use of natural gas is preferred for the facility due to the benefits of reduced emissions and increased operating and economic efficiencies. It is not always possible for the facility to use natural gas due to the lack of availability during extended periods of cold weather when natural gas becomes increasingly scarce and used primarily for residential or domestic heating.

The Lennox Generating Station cannot run solely on RFO at high operating loads for an extended period of time. If the station were to operate at full capacity on RFO, the onsite supply would be utilized in approximately three days. RFO is delivered to Lennox Generating Station by rail and unloaded in a maximum of 30 car increments per day, which makes it impossible to replenish the RFO supply quickly while operating at high loads.

Comment:

Who makes the decision on the Fuel Oil / Natural Gas mixture fed into the plant? Are the potential impacts to the environment factored into this decision?

Response:

OPG Lennox operates under contract with the Independent Electricity System Operator (IESO) whose mandate is to ensure that Ontario’s power needs are met under all conditions. The facility cannot use natural gas and residual fuel oil at the same time and generally only uses residual fuel oil in situations of scarce natural gas supply, which can occur during periods of significant cold weather. The use of residual fuel oil is only intended for short durations and the facility preferentially uses natural gas whenever possible. During natural gas usage, emissions from the facility comply with Ontario’s air standards and the facility operates more efficiently.

Comment:

Have capital projects to increase the effectiveness and capacity of the air pollution control system been investigated to meet the current/future air emission standards? If not, why not? When could these be carried out? These new standards have been a long time coming and should not be ignored even before they are brought into play.

Response:

Air standards are used by the ministry to assess the contributions of a contaminant to air by a regulated facility. Facilities that are not able to meet an air standard due to technological or economic limitations can request a site-specific standard.

As part of the site-specific standard process, the facility was required to prepare a technology benchmarking report to assess best practices for emission control for similar facilities in other jurisdictions globally.

The submitted technology benchmarking report highlights the importance of RFO-fired electrical generating stations. The most applicable emission control requirements and practices for facilities similar to OPG Lennox were for facilities located in the northeastern United States due to the similar climate and connected infrastructure. The benchmarking analysis indicated that these jurisdictions allow for the use of RFO fuel for plants similar to OPG Lennox and generally control sulphur dioxide emissions by specifying that the sulphur content of the fuel used by these stations be limited to 0.5 percent by weight. This is in lieu of requiring air pollution control systems to reduce sulphur dioxide emissions.

To address the increased emissions of sulphur dioxide during RFO use, OPG Lennox will immediately begin purchasing fuel with a sulphur content of 0.5 percent (by weight). This is a reduction from the current practice of purchasing fuel with a 0.85 percent (by weight) sulphur content.

Comment:

Why is the province not promoting more renewable energy?

Response:

It is the role of the Independent Electricity System Operator (IESO) to plan and competitively procure resources to meet Ontario’s energy needs today and into the future. These may be met through diverse resources such as wind, solar, hydro, biomass, nuclear, natural gas, demand response, conservation, or other innovative technologies.

The Lennox Generating Station can support the use of variable renewable power generating sources such as wind and solar power which are intermittent sources requiring backup. The utility boilers at the Lennox Generating Station can ramp-up to significant power generation, from a low idle state, faster than combustion turbines. This, in combination with the dual fuel capability, provides a key flexible and stable source of energy to meet variable electricity demands.

Comment:

Locating a new power plant near a community with economic constraints and limited resources to dispute the facility is not fair especially for children who will be exposed to increased levels of pollution. It is unlikely that this would be proposed in wealthier areas.

Response:

To clarify, this decision does not involve a new facility. The site-specific standards will apply to the existing OPG Lennox facility. Emission rates from OPG Lennox will be reduced over the duration of the site-specific standard approval.

Site-specific standards are developed with public transparency through public meetings and consultations, such as:

• OPG conducted a public meeting in accordance with the requirements of the Local Air Quality regulation. In light of COVID-19 considerations, the public meeting was held virtually on June 22, 2021.
• OPG shared its proposal with community members. Questions were received during this discussion about cumulative effects from the combined air emissions of OPG Lennox and the adjacent TransCanada Napanee Generating Station. The cumulative effects of the emissions from these facilities were considered as part of the ministry’s review and approval of the site-specific standards.
• OPG consulted with affected Indigenous communities, including Mississauga Members of Williams Treaty First Nation (WTFN) and Mohawks of Bay of Quinte (MBQ) as part of the pre-consultation requirements under the Local Air Quality regulation.
• At MBQ’s request, OPG provided third-party consultants to MBQ to assist the community with reviewing the proposed site-specific standards.
• OPG’s proposed request for site-specific standards was posted to the Environmental Registry of Ontario (ERO) for a 30-day public comment period.

The ministry contacted the local Indigenous communities to hear directly from those communities concerning any interests, comments, or questions they may have related to the proposed site-specific standards requested by OPG Lennox.