Lennox Generating Station applies for increased air pollution limits, public input sought

Ontario Power Generation (OPG) is seeking approval for site-specific standards for its emissions of sulphur dioxide, oxides of nitrogen, and sulphuric acid for a 10-year period (2022-2032) at Lennox Generating Station on the Lake Ontario shoreline near Bath. However, the Canadian Environmental Law Agency (CELA) would like the public to be aware of the risks to their health before the public consultation closes on Thursday, Sept 29, 2022.

Lennox Generating Station (Lennox GS) is a natural gas- and fuel oil-fired power station built in the 1970s. It is the largest natural gas power station in Canada by installed capacity. Lennox GS produces electricity by burning natural gas or residual fuel oil to turn turbines that generate electricity into the grid. It is mostly kept on low power as a backup to the main power grid for emergencies and peak load periods.

“The type of permit Ontario Power Generation is asking for, I would characterize as a deviation from the provincial air standard that would otherwise apply,” says Theresa McClenaghan, CELA Counsel and Executive Director. “Ontario has introduced new, more stringent air standards designed to protect human health, to begin in 2023.”

The OPG request is concerning, says McClenaghan, because “in OPG’s materials, the modelling with their current operation wouldn’t meet the new [2023] air standards, which are more stringent than today’s standards. And not only that, but they would not even have met the previous standard.”

For example, she points out that, beginning in 2023, plant emissions of sulphur dioxide should be no more than 100 micrograms per cubic metre, instead of the current 190 micrograms per cubic metre. OPG is asking the Ministry of the Environment, Conservation and Parks (MECP) to approve a site-specific standard at Lennox GS of 2,026 micrograms per cubic metre for the first five years: over 20 times the approved limit.

Sulphur dioxide is not the only contaminant OPG is looking for site-specific approvals on. In 2023, the new nitrous oxide standard will be 400 micrograms per cubic metre, and OPG is asking the ministry to approve 839 micrograms per cubic metre. For sulphuric acid, they are asking for 7.6 micrograms per cubic metre instead of 5.

According to McClenaghan, CELA worries that OPG’s climate analysis doesn’t take into consideration that, in the face of increasing extreme weather, the use of Lennox GS, and therefore emissions, could increase: “Because that’s what it’s used for: backup for hot weather.”

Further, even infrequent weather events could present very serious impacts on community health and the environment. For example, McClenaghan explains the “shoreline effect” caused by high rolling winds that keep emissions concentrated for longer periods right along the shoreline. “Such things have happened in the past at other facilities, so it’s not an improbable event. And this is one of the reasons we think that much better evidence of the impact in those worst case scenarios is required for this.”

McCleneghan also points out that OPG’s proposal does not contain a cumulative impact assessment: “There’s no calculation of the existing cumulative emissions in the results, including health results of those emissions… Where this plant is, there are other plants emitting a variety of contaminants, including Napanee Generating Station, and cement plants in Bath and Picton, among other local facilities.”

The lack of accounting for the cumulative health effects of all of the emissions from area plants is a serious concern for CELA. 

Exposure to these chemicals can be dangerous to human health, according to the National Pollutant Release Inventory of Canada.

 Sulphur dioxide may cause irritation to the eyes, nose, and throat: nasal mucus, choking, cough, and reflex bronchi constriction. 

Breathing nitrous oxide can cause dizziness, unconsciousness, and long-term exposure can lead to infertility.  

And lastly, when sulphuric acid is inhaled into the lungs in the form of small droplets that exist in the air, these droplets are deposited within the lung, possibly decreasing the ability of the respiratory tract to remove other small, unwanted particles. A study has shown that children can have more deposits of sulphuric acid in their lungs than adults, due to children’s smaller airway diameters. 

Ontario has been planning to close the Pickering Nuclear Generating Station for a long time, and it has been operating even longer than it was originally intended, McClenaghan says, so being ready for fluctuations in power should and could have been taken seriously years ago.

Previous governments sought and received proposals from all over the world based on things other countries were already implementing, McClenaghan says, “so what was happening in Ontario energy policy is that conservation was being encouraged strenuously — but then, unfortunately, it started to be backpedalled.” Further, some projects that had already begun were even cancelled, she explains.

“There’s huge [opportunity] for more conservation in Ontario. And I’m not talking about hardship conservation, but easy-to-accomplish conservation: solar and wind, for example, and geothermal (ground source heat),” McClenaghan continues.

”We’re talking existing technology at much less cost than when it was being priced originally. Our friends at Ontario Clean Air Alliance have very good modelling showing that we could easily buy extra hydroelectric supplies from Quebec, as well, for grid security. We should be doing a lot more of that kind of regional exchange anyway, as well as the climate reasons.” 

Kingstonist reached out to OPG for comment and they acknowledged the request shortly thereafter. However, over a week later, the company has still not provided a response.

To see Ontario Power Generation’s Lennox Generating Station proposal requesting site-specific standards of sulphur dioxide, oxides of nitrogen, and sulphuric acid for a 10-year period (2022-2032), and submit comments, visit the Environmental Registry of Ontario.