NEED FOR POLLUTION CONTROLS AT HOLYROOD A CASE OF FRAUDALENT MISREPRESENTATION

PlanetNL44: Holyrood Air Pollutants Surprisingly Low

Need for Pollution Abatement Equipment Was Another Muskrat Fraud

As Uncle Gnarley properly pointed out in his post last week, the vilification of the Holyrood Thermal Generating Station was a central tactic of Nalcor and Government’s communications strategy for proceeding with the Muskrat Falls project.  Tremendous tales of woe were repeated ad nauseum about the risks of using the Holyrood plant by the shameless promoters of Muskrat. 

They were all untrue.

This post sums them all up with particular emphasis on the topic of pollutant emissions, a problem that no longer existed.  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.

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.   

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 as required in the terms of 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. 

Holyrood SO2 Emissions 2002-2016 (Source: Nalcor 2016 Environmental Performance Report)

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 as linked in the References below.

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)

OPINION POLL OVER-RATES INEFFECTIVE TORY OPPOSITION

Having survived in spite of themselves, in Opposition the Tories have been lazy and uninspiring.  The fact that it is summer, and the House of Assembly is closed, admittedly makes their job tougher, except that the Party’s manifest weakness is not a seasonal problem.

REMEMBERING CABOT MARTIN (1944-2022)

He was an exceptional person. A gifted intellect for sure; irascible and argumentative, too. What endeared him to many was not just that he was analytical and insightful, but that he was honest and forthright. He was a public policy wonk; resource policy interested him most. He loved to travel and read; people, with something to say, were always important.

GNL RUSHING INTO ANOTHER “SCHEME”: CABOT MARTIN

I must say that after the Muskrat Falls fiasco, I thought our government had finally learnt its lesson and would not to rush into another such scheme where calling it “green” was enough to suspend all critical analysis.