COMMENTS FROM ENVIRONMENT CANADA
On Environmental
Bill of Rights (EBR)
Registry No. RA01E0008 (Lakeview Thermal
Generating Station Emission Limits)
Introduction
Environment Canada is
providing comments on the Ontario proposal Environmental Bill of
Rights (EBR) Registry No. RA01E0008 (Lakeview Thermal Generating
Station Emission Limits) with respect to Canadian domestic and
international requirements to protect the environment and human
health.
Context
Ontario Power Generation
Inc.'s (OPG) Lakeview Generating Station is located in Mississauga, on
the shore of Lake Ontario in the Greater Toronto Area, home to about
five million people. It is the oldest of Ontario's fossil fuel-fired
plants, fuelled by coal and put into service from 1962 to 1969. In the
face of declining nuclear generation, it has been used increasingly
since 1995. Some of Lakeview's units were given extensive overhauls in
the 1990's, and have an estimated remaining life of between five and
ten years. The Lakeview Generating Station consists of four units that
are currently being operated and four units currently out of service
and now considered as surplus.
The Lakeview Generating
Station is located in a region of Ontario that exceeds the Canada-Wide
Standard for Ozone of 65 parts per billion (ppb) (averaged over an
eight hour period) and the Canada-Wide Standard for Particulate Matter
(PM) of 30 micograms per cubic metre (mg/m3) (averaged over a 24 hour
period).
The Lakeview station provides
two basic functions within the context of the electricity provided to
Ontario by OPG. It provides generating capacity to meet overall system
load demands and it provides reactive support to maintain local
voltages. The high demand for electricity in the Toronto area has led
to the need for generation at Lakeview during peak periods in order to
meet system demand. Current plans are for Lakeview to continue its
role as a peaking plant and to provide system reliability as
necessary.
Lakeview has in-service
generating capacity of 1140 MW from four coal-fired units. This
represents nearly 12% of OPG's net fossil plant capacity. In 1999
Lakeview generated 3.2 TeraWatt-hours (TWh) or nearly 9% of fossil net
energy produced by OPG.
Pollution control technologies in place at Lakeview include
low-NOx burners and boiler tuning and optimization for reduction of nitrogen
oxides (NOx) and electrostatic precipitators (ESPs) for particulate control.
There are no controls in place for sulphur dioxide (SO2) or toxic substances (such as
mercury).
A comparison of recent emissions inventories for the Greater
Toronto Area (GTA) indicates the Lakeview accounts for 26% of the GTA's SO2 emissions and 8 per cent of NOx
emissions. Lakeview is the second largest emitter of mercury in the
GTA and emitted 83 kilograms in 1999. The coal burned at Lakeview
produces a high proportion of ionic mercury - about 65% of the total
emitted. Ionic mercury emitted in the flue gas tends to be deposited
locally, that is within 50 kilometres of the point of origin.
EBR Proposal
On Monday, March 26, 2001,
Ontario requested comment by April 25, 2001 on a proposal regarding
the operation of the Lakeview Generating Station. The proposal was
that the station cease burning coal by April 30, 2005 and that after
April 2005, any future electricity generation at the Lakeview site
would be required to meet the emissions performance of efficient
natural gas technology.
Further, the proposal was that in the interim period before
April 2005, emissions of nitrogen oxides from the Lakeview station would be
capped. Beginning January 1, 2002 for the years 2002, 2003 and 2004, nitrogen
oxide emissions would be capped at 3.9 kilotonnes per year of NO (equivalent
to 6 kilotonnes as NO2). For the partial 2005 year (January 1, 2005
to April 30, 2005), before ceasing to burn coal at the site, nitrogen oxide
emissions would be capped at 1.3 kilotonnes of NO (equivalent to 2 kilotonnes
as NO2).
The proposal was made in the
context of a proposal for other coal-burning plants in Ontario that
included emissions trading (EBR RA01E0009). Separate comments are
being made on this proposal.
Canadian domestic and international requirements
Domestic requirements
Federal or provincial regulations/standards/guidelines for thermal
power generation emissions
The Canadian Environmental Protection Act (CEPA),
sets out a guideline "Thermal Power Generation Emissions - National
Guidelines for New Stationary Sources". The CEPA guidelines contains
numerical emission limits which are intended to apply to new units
only, including units which replace an existing unit. Therefore, the
Guideline limits do not apply to the existing units at Lakeview. The
Guideline however, recognizes that opportunities to reduce nitrogen
oxides may arise during major alterations to existing units, and
therefore recommends that an assessment of the feasibility of nitrogen
oxides reduction measures be completed prior to such alterations. No
other federal or provincial emission limit standards exist to apply to
a modifications of an existing thermal generation plant such as
Lakeview Generating Station (aside from the provision of a Certificate
of Approval (Air) under the Ontario Environmental Protection Act).
Canada-Wide Standards for Ozone, PM and Mercury
In June 2000, Canadian
Environment Ministers agreed to meet, by 2010, Canada-Wide Standards
for Ozone of 65 ppb and PM of 30 mg/m3 by 2010. In Ontario, a 45%
reduction from 1990 levels of Nitrogen Oxide (NOx) and Volatile
Organic Compound (VOC) emissions is the provincial goal to achieve the
Canada-Wide Standard for Ozone.
To achieve the Canada-Wide Standards, each jurisdiction,
including the federal government, has committed to prepare a jurisdictional
plan for reductions of emissions. Reduction of emissions of NOx and Sulphur
Dioxide (SO2) from the electric power generation
sector is part of the Ontario regional implementation plan.
Joint Initial Actions were agreed by Ministers of Environment
in January 2000 as the first steps to reduce PM and ozone by 2010. The Joint
Initial Actions for PM and Ozone are to be undertaken through the development
of multi-pollutant emissions reduction strategies (MERS) for major industrial
sectors, including the electric power generation (EPG) sector. The EPG MERS
is intended to provide national multipollutant analysis for use by jurisdictions
in setting emission reduction targets and actions for this sector. A national
picture of sectoral emission reduction requirements across jurisdictions for
key pollutants (i.e., NOx, SO2, PM and mercury) will be assembled
in 2003.
Canada-Wide Standards for
Mercury in the EPG Sector are currently being developed under the
auspices of the Canadian Council of Ministers of the Environment
(CCME). A report from the Development Committee for the CWS for
Mercury is anticipated to be delivered to the CCME by Spring of 2002.
Because of the importance of
economic trade and competition within industrial sectors in Canada and
the United States, there are some key U.S. regulatory requirements
relevant in reviewing the proposal for Lakeview Thermal Generating
Station Emission Limits.
In the United States, a generating station comparable to
Lakeview in age, generating capacity and location with respect to the region's
attainment of the U.S. air quality standards for ozone and particulate matter
would be required to make mandatory upgrades in abatement technology when any
significant modification was made to the station's operation. Among the requirements
would be the requirement to meet a NOx emission rate of 0.15 lb/MMBtu as a modified
new source under the New Source Review requirements established in 1998. In
addition, mandatory requirements exist for such a plant to install and operate
and report the data from continuous emissions monitoring for emissions and flow
rates of NOx, SO2 and Carbon Dioxide (CO2). A power plant
comparable to the Lakeview plant, with all required monitoring installed, would
expect to be allocated SO2 and NOx allowances and to be able to participate
in interstate SO2 or NOx cap and trade programs.
The United States
Environmental Protection Agency (U.S. EPA) is currently in the process
of developing regulations for emissions of mercury and toxics from
coal- and oil-fired electric power plants. Mercury has been identified
as the hazardous air pollutant of greatest concern among those emitted
by power plants. Coal fired power plants represent the largest source
of mercury air emissions in the USA. The U.S. EPA will propose
regulations by December 2003 and will issue final regulations by
December 2004.
The U.S. EPA has found that
there are cost effective ways of controlling mercury emissions from
power plants. The U.S. EPA concludes that technologies available today
and technologies expected to be available in the near future can
eliminate most of the mercury from utilities at a cost of less than
one % of utility industry revenues.
Canada-Wide Acid Rain Strategy for Post-2000
To prevent damage to ecosystems in Canada from acidification,
estimates are that a further 75% reduction of SO2 emissions is required
beyond existing commitments in both eastern Canada and in the United States.
The Canada-Wide Acid Rain Strategy for Post-2000, signed in 1998, committed
eastern Canadian jurisdictions including Ontario to establishing new targets
for overall SO2 emission reductions. To fulfill that requirement,
Ontario announced, in January 2000, a SO2 emission reduction target for the
province of 50% reduction by 2015, from the provincial cap of 885
kilotonnes (kt.).
International requirements
Ozone Annex
In December 2000, Canada and the United States signed the
Ozone Annex under the Canada-U.S. Air Quality Agreement. One of Canada's commitments
under this agreement is for the establishment of a total annual NO2 cap of 39 kilotonnes by 2007 for fossil
fuel-fired power plants with a capacity greater than 25 megawatts in
central and southern Ontario (the Pollution Emission Management Area
(PEMA)).
Great Lakes Binational Toxics Strategy
In April 1997, Canada and the
United States signed the Canada - United States Binational Toxics
Strategy for the Virtual Elimination of Persistent Toxic Substances in
the Great Lakes. One of the Canadian challenges is to seek, by 2000, a
90 percent reduction in the release of mercury, or where warranted,
the use of mercury from polluting sources resulting from human
activity in the Great Lakes Basin. The Strategy builds on and
complements the efforts under the 1994 Canada-Ontario Agreement
Respecting the Great Lakes Basin Ecosystem.
United Nations Economic Commission for Europe Convention on
Long-range Transboundary Air Pollution Protocol on NOx Emissions
In 1988, Canada signed the
Protocol to the 1979 Convention on LRTAP concerning the Control of
Emissions of Nitrogen Oxides or their Transboundary Fluxes which
Entered into Force in 1991. Canada ratified the Protocol in 1991,
committing to freeze annual national emissions of nitrogen oxides at
1987 levels.
United Nations Framework Convention on Climate Change (UNFCCC) and
Kyoto Protocol
Canada signed and ratified
the Framework Convention in 1992 and signed the Kyoto Protocol in
1998. Canada has not yet ratified the Kyoto Protocol. The objective of
the UNFCCC is to "stabilize greenhouse gas concentrations in the
atmosphere at a level that would prevent dangerous anthropogenic
interference with the climate system". In the Convention, developed
countries committed to put in place policies and measures with the aim
of returning greenhouse gas emissions including carbon dioxide
emissions to 1990 levels by 2000. The Kyoto Protocol commits developed
countries to reduce their overall greenhouse gas emissions by 5
percent by 2012. The Kyoto Protocol has not been ratified by a
sufficient number of countries for it to "Enter Into Force" so that
the Kyoto commitment is not yet binding any country.
Environment Canada Comment
The EBR proposal is a step toward important reductions in
NOx and SO2 emissions in Ontario and in the electricity sector. However,
this view is conditional on the Lakeview proposal being part of a provincial
program to reduce emissions of NOx, SO2, PM, CO2, mercury and other toxic pollutants in
the province from the electricity sector as a whole and from the
region of Ontario that contributes to transboundary pollution.
Nitrogen Oxide (NOx) emissions contribute to the formation
of ground-level ozone and particulate matter. Reduction of NOx emissions is
proposed for the Lakeview station. The proposal suggests that the Lakeview plant
will be required to meet, by 2005, an emissions performance of "efficient
natural gas technology". Such an emissions performance would be between
0.2 and 0.1 kilograms of NO2
per megawatt hour (kg/MWh). The 0.2 kg/MWh rate is consistent with
efficient gas turbine combined cycle units (with dry low NOx
combustion) whereas the 0.1 kg/MWh rate is consistent with the same
units but with the addition of Selective Catalytic Reduction
technology. The
0.1 kg/MWh rate is the
emissions rate of efficient gas turbine combine cycle units recently
permitted in northeastern United States.
While Canada does not currently require fossil fired thermal
power generators to achieve a specific NOx emission rate, in the United States,
a new source or a modified existing source of thermal power generation would
be required to meet a NO2 emission rate of 0.15 lb/MMBtu which is
considered equivalent to 0.65 kg/MWh. It is important to note that the NO2
emission rate for Lakeview, in its remaining years as a coal-fired station,
could be significantly higher than the current U.S. standard. To illustrate,
the EBR proposes to limit Lakeview's NO2 to 6 kilotonnes of NO2 beginning in 2002. If, in 2002,
Lakeview's generation remains at the 1999 production of 3.2 TWh, then
the emission rate in 2002 would actually be 1.87 kg/MWh which is well
above the 0.65 kg/MWh U.S. standard.
The conditions imposed on the
four operating units at Lakeview station should also apply to the four
units currently out of service and now considered as surplus. This
requirement should be made explicitly in any Ontario Ministry of the
Environment requirement for the Lakeview station both under its
current ownership and for any future owner/operators of the
station.
An important tool for flexibility that may become available
to fossil fuel-fired electricity producers in Canada is participation in transboundary
NOx and/or SO2 allowance "cap and trade" emissions trading.
In order to do so, the Lakeview station should be required to install and operate
the same continuous emissions monitoring (CEM) for NOx, SO2 and CO2 emissions that affected
electricity generating units (EGUs) of similar size in the United
States are mandated to have in place in order to participate in
emissions trading. In addition, the Lakeview station should be
required to report its emissions to the Ontario government at the same
frequency as that required by EGUs of similar size in the United
States. The Ontario MOE should establish an enforcement and compliance
program for CEMs and a reporting database. Such an effort on the part
of MOE would facilitate eventual transboundary trading of allowances
so that stations such as Lakeview could participate in transboundary
allowance trading at some future time. An MOE program of this kind
would also enhance the reliability of emissions inventory and emission
rate data and provide valuable information for the public and for
policy makers in government.
Since all other North American jurisdictions report NOx
as nitrogen dioxide (NO2), and whereas Ontario and OPG report NOx
as nitric oxide (NO), it would reduce confusion if Ontario were to adopt the
standard practice of reporting emissions and identifying the emission levels
in terms of NO2.
By ceasing to burn coal, implementing the proposal for Lakeview
will result in the reduction of other emissions of concern to the environment
and human health including PM, SO2, CO2, mercury and other toxic pollutants that
result from coal combustion. This is a significant step in the
achievement of a multipollutant emission reduction in the electricity
sector as defined by the Joint Initial Action commitment made by
Ministers of the Environment in January 2000. It is also important for
the achievement of the Canada-Wide Acid Rain Strategy for Post-2000.
Finally, the implementation of this proposal would be a step towards
achievement of the Canadian commitments in the United Nations
Framework Convention on Climate Change and the Canada - United States
Binational Toxics Strategy.
While the phase out of coal
at Lakeview is expected to reduce pollutant emissions associated with
coal combustion in the Greater Toronto Area and downwind, it must be
noted that this will not necessarily reduce Ontario's overall
emissions associated with coal if there is increased generation from
other coal-fired stations. In addition, this assumes that the Lakeview
plant will continue to function within the provincial electricity
system in its role as a peaking plant and to provide system
reliability as necessary.
However, preliminary analysis indicates that reductions
beyond the current proposal for SO2 and NOx will be required from the
province's electricity sector to meet the Canada- Wide Standard for PM
and Ozone. A formal review of the EBR Registry Number: RA01E0009 is
being prepared to address this issue. This EBR proposal appears to
suggest emission limits for the whole Ontario electricity sector and
an emissions reduction trading system through which to implement the
sector reductions.
With respect to the proposal
for emission limits for the electricity sector and the trading system,
initial analysis indicates that the proposal for the reduced emission
limits for the electricity sector, exclusive of emission trading
provisions, will enable Ontario to meet the Ozone Annex 39 kt nitrogen
dioxide emission cap. The emissions trading provisions, however,
appear under preliminary analysis, to put the achievement of such a
cap in jeopardy.
The use of an emissions cap is an important instrument for
the achievement of long-term environmental and human health goals. Within the
context of an emissions cap, however, the mix of abatement techniques and solutions
used to achieve the cap has a significant bearing on the results in terms of
emissions of all pollutants of concern including NOx, SO2, PM, CO2,
mercury and other toxic pollutants. The contribution by the Ontario
electricity sector to the achievement of Canada's domestic and
international requirements for all of these pollutants will be most
substantial if an Ontario electricity sector response were to contain
a mix of the following abatement elements, arranged in hierarchical
order of the most-preferred to least-preferred elements:
- energy conservation;
- efficient energy use;
- renewable energy (wind, biomass, solar,
etc.);
- landfill/waste gases, waste heat
recovery;
- natural gas combined heat and power
systems;
- natural gas combined cycles; and,
- emission controls at coal- and oil-fired plants.
Clearly, the Lakeview station proposal to cease burning
coal and to meet the emission performance standard of efficient natural gas
technology by 2005, could contribute to reductions of pollutants of concern
in Ontario if the reductions at the Lakeview station are part of a provincial
program to reduce emissions of NOx, SO2, PM, CO2, mercury and other toxic pollutants in
the province from the electricity sector as a whole and from the
region of Ontario that contributes to transboundary pollution.
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