Guest Post by PlanetNL
PlanetNL44: Holyrood Air Pollutants Surprisingly
Low
Need for Pollution Abatement Equipment Was Another
Muskrat Fraud
They were all untrue.
This post sums them all up with particular emphasis on the topic of pollutant emissions, a problem that had ceased to exist. Not that Government or Nalcor could ever let something as simple as the facts stand in their way of building Muskrat.
The Holyrood Fact Sheet Was
Completely Made Up
Most of the claims made against
the Holyrood thermal plant in the period leading up to Muskrat Falls sanction
in December 2012, and indeed often repeated in the years that have followed,
fall into four main categories.
There was a load forecast filled
with unending growth: projections meant to show that Holyrood would be unable
to supply the demand within a few short years.
That has proven totally false.
Load trended slightly upward in the decade of the 2010s but has since
fallen back to the levels of the decade prior. Official load forecasts were notably reduced a
few years ago. Realistically, there is
no reasonable basis to forecast any resurgence in growth, just more gradual
decline.
There was also a projection of oil
prices endlessly escalating. This would lead
to unaffordable rate increases if we continued to depend on Holyrood. This has prove untrue. The oil-fired share of electricity rates certainly
fluctuates but it has been quite stable overall. Ironically, ratepayers are certain to suffer
major rate increases to pay for Muskrat, the supposed antidote to the oil price
threat.
Claims were also made that the Holyrood
plant was worn out and unreliable. The
latest consultant report on Holyrood plant life extension proves that to have
been false. The plant has plenty of
useful life remaining and requires only ordinary upkeep. The truth is that Nalcor (Hydro) was
negligent in their management of Holyrood along with virtually all Hydro assets. This was effectively proven in the
utility-wide review performed by Liberty Consulting following DarkNL. Those problems are now largely corrected, and
utility reliability statistics have improved substantially.
The final talking point heard many times was that Holyrood would need $600-800 Million in pollution control equipment installed to meet regulatory compliance requirements. Even to the most jaded sceptics, this one sounded so plausible it was hardly scrutinized. Has it too proven false? Evidence has been uncovered to conclusively determine that this was also completely unfounded.
 |
| Environment Minister Tom Hedderon, 2012 |
Holyrood's "closure will also complement our Climate Change Action Plan and be the equivalent of taking 300,000 cars off the road”, claimed a statement issued jointly by the Departments of Natural Resources and Environment in November 2012.
Annual Air Monitoring Reports
While researching emissions data
for another purpose, several Ambient Air Monitoring Reports were found on the
Province’s website. These reports
include year-round analysis at several sites around the province including St.
John’s, Mount Pearl, Corner Brook, Labrador City, Holyrood and in the general
area of the North Atlantic Refinery. Most
of the locations are within the proximity of major industrial sites known to
have significant pollution risks.
The key pollutants measured are
Sulphur Dioxide (SO2), Particulate Matter (PM2.5 and PM10),
Nitrogen Oxides (NOx), Ozone, and Carbon Monoxide. Carbon Dioxide and other greenhouse gases are
not discussed.
The reports present actual measurements
of pollutant concentration relative to the “maximum concentrations of air
pollutants considered to be protective of the environment” as defined in
the Province’s Air Pollution Control Regulations, 2004. The report notes that local readings can be
impacted by emissions from such sources as vehicular traffic, forest fires, and
woodstoves. No area is pollutant free.
The report does not provide
commentary on the levels of pollution measured.
If that formal contextual analysis exists, it is likely being kept out
of the public’s reach.
Left Photo: Typical Air Monitoring Station (source: GNL report)
There are six air monitoring
stations situated in Holyrood. Most
were installed in the 1990s to perform data collection required for the Certificate of Approval issued by the Department of Environment. Only reports from 2008 onward appear to be publicly
available. Nalcor (Hydro) and Government
certainly would have had earlier reports and analysis in their possession.
Map of Air Monitoring Station
Locations in Holyrood (Source – GNL report)
What Government and Nalcor Truly
Knew
The oldest available Ambient Air
Monitoring Reports, for the 4-year period of 2008-2011, are especially
relevant. During this time, the Muskrat
Falls project was being promoted and Government and Nalcor officials were
routinely criticizing their perceived liabilities of the Holyrood plant.
It was easy to expect the worst
to be found in these reports, particularly during the winter operating season
when the plant was frequently run to full power and maximum fuel burn. Would there be a high number of exceedances
when measured levels were higher than what the regulations allowed?
Nothing of the sort was found.
The report data shows that
pollutants from the plant were routinely a tiny fraction of that allowed within
the regulations. For example, SO2,
arguably the most harmful environmental emission that causes acid rain, was
rarely above 1/10th the levels defined in the regulations. NOx was rarely above 1/8 the limits. There were just a few rare occurrences in
which PM2.5 exceeded the regulatory maximum, but it was comfortably
below that level nearly all the time.
From a layman’s perspective the
results are surprisingly very good. The
Holyrood site even fared better than the other industrial sites examined. Measurements nearest to North Atlantic Refining
and the Iron Ore Company in Labrador City showed tremendous exceedance of
maximum pollution levels in multiple categories although the levels detected in
the towns appear generally satisfactory.
Corner Brook also had more exceedances presumably from the pulp and
paper mill.
Even the levels in some other towns not directly adjacent to major industrial emitters are not squeaky clean. The levels measured at Holyrood can only be interpreted as a pleasant surprise. A relief even. Because those with long memories know it probably was not always the case.
Holyrood Pollution Problems Were Addressed
in 2006
Records found on the PUB website
from 2006 reveal some important history on Holyrood’s pollutant emissions. From those, we can find that Hydro was in
violation of at least the SO2 emissions criteria when the new Air
Pollution Control Regulations, 2004 came into effect.
Hydro advised the PUB they had reduced
the sulphur in its Heavy Fuel Oil (HFO) purchases for Holyrood from 2.2% to
2.0% maximum in 2004. Clearly this
action was as insufficient as you may think.
In September 2006, the Department of Environment was compelled to order
Hydro to use fuel with a sulphur content not exceeding 1%. Hydro indicated the expected price premium
for the lower sulphur fuel was $3 per barrel.
Hydro was clearly advised of two
important things within a consultant report appended to one of the 2006 PUB hearing
documents. First was a costing
comparison showing that using 1% maximum sulphur fuel was less costly than
installing pollution control equipment.
Second was that both SO2 and particulate matter emissions decrease
further with even lower sulphur content in the fuel. To that end, the report identified many other
North American HFO-fired thermal plants at the time, many of which used fuels
with sulphur content as low as 0.1-0.3% to achieve even lower pollutant output. This simple tactic was well understood in the
industry.
Sure enough, with the switch to
1% sulphur fuel in early 2006, emissions of SO2 began to drop
dramatically as shown in the chart below found in a Nalcor 2016 environmental
performance report. By 2007 (2006 was a
transition year in which some remaining 2% fuel was burned) the intensity
factor (white line) had dropped by a little better than 50% which correlates
exactly to the reduction of sulphur in the fuel.
The continuing decline in emission intensity in the next few years suggests that Nalcor steadily sought to purchase even lower sulphur fuels by 2010. The lower emission intensity from 2010 onward likely results only from the use of 0.7% maximum sulphur fuel.
Hydro clearly understood that
using moderately low-sulphur HFO was key to reducing Holyrood pollution
emissions and bringing it well into regulatory compliance. By 2006, they also certainly understood the
range of even lower sulphur fuel options that were available to potentially
meet any possible tightening up of regulatory compliance thresholds in the
future.
Despite the large step-change in SO2 reductions achieved commencing in 2006, Government communications as late as November 2012 chose this phrasing: “From 2000 to 2010, the Holyrood plant emitted … an annual average of 11,610 tonnes of sulphur dioxide.” Looking at the chart above we know with the permanent change to lower sulphur fuel, the pre-2006 data had become totally irrelevant. The true average SO2 emissions were about 4000 tonnes but Government wanted to communicate a scarier number. For a laugh and a cry read the entire propaganda-filled news release, linked in the References below.
Related:
Power Plant a Centerpiece of Corrupt Governance by Des Sullivan
Dispelling Lies and Half-Truths about Holyrood powerand raising questions about next black-out by PlanetNL
Nalcor and Government Committed
Fraudulent Misrepresentation
There is ample evidence that pollution
emissions from the Holyrood plant were very adequately resolved by using lower
sulphur content fuel in 2006. In all the
years subsequent leading up to Muskrat sanction, the plant was well within
regulatory compliance requirements.
Nalcor (Hydro) and Government possessed
an extensive set of air quality data allowing them to fully understand the
situation. They also had consultant
advice to adopt low-sulphur fuels rather than install pollution control
systems. Despite that, they chose to cover
up the facts and present the story of highest possible costs.
Nalcor at the time asserted that
they expected pollution regulations to become more stringent. Holding this out gave an air of inevitability
to the issue. Yet, as of 2022, the 2004
regulations have yet to be amended, therefore any sense of imminent regulatory
change has proven that worry was unwarranted.
It’s fair to ask whether any
regulatory tightening could have become so stringent as to cause a clear
pollution violation. To examine that, let’s
consider the much tighter air standards of the European Commission that allow SO2
and NOx concentrations of half or less compared to NL regulations
(PM levels are no different). A cursory
review suggests that even if the Province were to adopt EC standards,
Holyrood’s level of performance would likely still pass. If lower emissions were to prove necessary,
then we know slightly lower sulphur fuel is an available option to resolve the
issue.
However, consider that if
Holyrood had problems meeting tighter pollution limits, the air quality reports
suggest that all other heavy industries in the province would be in worse
trouble. It’s highly improbable that the
Province would impose new regulations that could be so economically damaging.
Finally, consider that the latest
consultant report about Holyrood life extension gave no consideration to
installing any new pollution control systems while continuing to use the same grade
of Heavy Fuel Oil. This conspicuous
absence in this report would seem to indicate that Hydro has relented to the
reality that such equipment is not a necessity.
We must conclude that all claims by Nalcor and Government that pollution control equipment had to be installed at Holyrood was a deliberate case of fraudulent misrepresentation. The need for it was not true then, remains untrue today, and is very unlikely to be true in the foreseeable future.
Sources and References:
NL Dept of Environment and Dept of Natural Resources News
Release - Significant Environmental Benefits to be Achieved with Closing
Holyrood Thermal Generating Station - Significant
Environmental Benefits to be Achieved with Closing Holyrood Thermal Generating
Station (gov.nl.ca)
NL Dept of Environment Air Monitoring Reports webpage - Publications -
Environmental Protection - Environment and Climate Change (gov.nl.ca)
2006 PUB Hearing for 1% Sulphur Fuel Cost Recovery - PUB: NLH 1 %
Sulphur Fuel Cost Recovery
Nalcor 2016 Environmental Performance Report (PDF) - 09-17-EPR-FINAL-web.pdf
(nlhydro.com)
European Commission Air Quality Standards webpage - Standards -
Air Quality - Environment - European Commission (europa.eu)