Emission Reduction Protocol. Ontario Power Generation - Lennox GS Units 1 to 4 Fuel Switch

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1 Emission Reduction Protocol Ontario Power Generation - Lennox GS Units 1 to 4 Fuel Switch 1.0 Introduction In 2000 Lennox completed the conversion at all four units to dual fuel capability (oil and/or natural gas). Residual Fuel oil (RFO) has a typical sulphur emission of 1.64 kg per MWh whereas natural gas has almost 0 kg per MWh. The reduction in emissions while firing with gas form the basis of the emission reduction credits claimed in this application. This Emission Reduction Protocol is prepared under the guidelines set forth in the Ontario Emissions Trading Code, dated December, Specifics on the Standard method are available in Appendix 1: Standard Method #2, SO2 Emission Reduction Credits from Fuel Switching at Electricity Generating Stations. 2.0 Proponent Identification Project Owner: Ontario Power Generation 700 University Avenue Toronto, Ontario M5G 1X6 Attention David Coates, phone (416) , dave.coates@opg.com Facilities: Lennox Generating Station P.O. Box 1000 Bath, Ontario K0H 1G0 3.0 Project Description 3.1 Site Description The Lennox Generating Station is one of six fossil-fired generating stations owned by Ontario Power Generation. Lennox GS is situated on the north shore of Lake Ontario, 32 kilometres west of Kingston, Ontario. Its four generating units were commissioned in Pre-Project Conditions Each of the four units has an electrical power output of 550 megawatts when operating at full load. Prior to the fuel switch to natural gas on Units 1 to 4 the primary fuel at Lennox was residual fuel oil (RFO), a refinery by-product. In 1998 Lennox s SO2 emissions while operating on oil were 1.64 kg/mwh.

2 3.3 The Standard Method Standard Method #2, SO2 Emission Reduction Credits from Fuel Switching at Electricity Generating Stations. 3.4 Actions Taken Lennox completed the conversion to dual fuel capability (oil and/or natural gas). 3.5 Post-Project Conditions Following the ability to fire on dual fuel the SO2 emission rate at Lennox is significantly lower. Units 1 and 2 were converted to natural gas in October 1998 and Unit 3 was converted in June 2000 and Unit 4 in May Validity of Emission Reductions 4.1 Real All four units were equipped with duel-fuel burners, capable of firing either oil or natural gas. 4.2 Surplus Lennox GS operates in compliance with the relevant NOx and SO2 regulations: NO and SO2 emissions at Lennox GS are limited by a company specific regulated cap. From January to March 1999 this was the Ontario Environmental Protection Act, Ontario Regulation Ontario Hydro, which was revoked in March 1999 and replaced with Ontario Regulation 153/99 - Ontario Power Generation. Both Regulations limit Ontario Power Generation's combined total emissions of SO 2 and NO to 215,000 Mg. Of the 215,000 total, SO 2 emissions are limited to 175,000 Mg. Table 1 is an overview of OPG s SO2 and NO emissions from 1999 to 2001, as reported to the Ontario Government. Table 1 Ontario Power Generation s Emissions Year SO2 Emission (Mg) NO Emissions (Mg) Total Acid Gas Emissions (Mg) ,200 51, , ,100 50, , ,490 44, ,121 OPG (and its predecessor company Ontario Hydro) has complied with both the Environmental Protection Act, Ontario Regulation 227/00 - Electricity Generation Monitoring and Reporting, and Ontario Regulation 127/01 - Airborne Contaminant Discharge Monitoring and Reporting and submitted the required reports by the June 1 st deadlines.

3 The recently commissioned emission inventories conducted under the MOE s STAC Program show Lennox in compliance with the point of impingement requirement of Environmental Protection Act, Ontario Regulation General Air Pollution. The surplus nature of these reductions is based on two components. First, the baseline data is below any NO emission limit regulating the operation of the Lennox GS or OPG. Second, there are no external requirements for OPG to reduce NO, SO 2 or CO 2 emissions below the baseline. 4.3 Quantifiable The calculated emissions while operating on natural gas (or a combination of natural gas and RFO) are subtracted from what the calculated emissions would have been while operating only on RFO. The net difference becomes the emission reduction. Fuel consumption data is taken from integrator readings on the main boiler turbine units. This data is placed in the Operating Reports and Ledgers (ORAL) system. Actual level readings on the fuel oil tanks are taken to verify integrator consumption figures. Any difference between the integrator readings are reported as an adjustment in the ORAL system. Raw chemical analysis and fuel usage records are kept on file. Final data is stored in the ORAL system. A simple mass balance equation is used for the SO2 Emission Algorithms. The assumption is that the sulphur in the fuel is either oxidized in the combustion reaction according to the equation S + O 2 = SO 2 or it is bound in the ash. Because of the low amounts of ash produced at Lennox GS, the ash term is not considered. For natural gas the SO2 equation is SO2 = V, where V = volume of gas burnt in millions of cubic metres. Note the sulphur content of natural gas used in the equation is 5.46 mg/m 3 ; this data was provided by the natural gas supplier, Union Gas. Measurement and calculation of emission reductions are based on accurate records of hourly fuel consumption by each unit at Lennox, regular analysis of % sulphur and specific energy content in the fuel, and a simple mass balance of the mass of sulphur in the fuel consumed. This technique is at least as accurate as a CEM system, and is therefore a reasonable, equivalent procedure for quantifying baseline emissions and calculating reductions. It is by applying these formulas to actual production of the Lennox units on natural gas or oil/gas and subtracting the emissions from baseline emissions (by assuming that the production was from oil fired generation) that an emission reduction is calculated. 4.4 Unique

4 The year 2000 and 2001 emission reductions do not require registration with CleanAir Canada, as per section 4.9 Credit for Early Action of the Ontario Emissions Trading Code. This document is for the creation of emission reductions for the period January 1, 1999 to December 31, 1999, consistent with section 4.9 Credit for Early Action of the Ontario Emissions Trading Code. The submission was made to PERT in March 2000, with revisions in June and August The presentation was made to the PERT Working Group on April 27, 2000 and the PERT Review was completed on May 16, Currently the SO2 emission reductions from 1999 are listed for Lennox on the CleanAir Canada Registry under registration # CAC-1999-OPG-D-SO2-1. Upon registration with the Ontario Emissions Trading Registry, the CleanAir Canada Registry will reflect the new posting. These emission reductions have not been used in relation to any voluntary or regulated requirement. 4.5 Verifiable The SO2 emission data presented is the total sulphur content of the natural gas and RFO fuel burned. The basis of the Reported SO2 Emissions are data in the Lennox stations ORAL data system. These are audited on an annual basis and the reports are available at the station. Raw data in the forms of laboratory reports and natural gas sulphur content information from Union Gas are also maintained at the station and can be used to verify the data in the ORAL system. The calibration records for the gas and oil metering equipment are also on record at the station. The 100% RFO data is calculated monthly by taking the total natural gas volume s calorific value and converting this to the equivalent calorific volume of RFO. The sulphur content of that equivalent volume of RFO is then substituted for that of the natural gas giving a theoretical 100% RFO SO2 emission. The monthly volumes, sulphur contents, and calorific values are on the ORAL system and can be checked against laboratory records held at the station. The SO2 emission reductions are the simple difference between the Reported SO2 emissions and the baseline 100% RFO emission. 5.0 Quantification of Emissions Reductions 5.1 Process Description The process for quantifying and verifying emission reductions from the Lennox Fuel Switch are described in section 4.3 Quantifiable. 5.2 Data Collection All data for fuel use, and sulphur content are taken from the station s ORAL system.

5 5.3 Baseline Determination The baseline is defined as the 100% RFO emission for each month. This is directly calculated by mass, using fuel volume and laboratory sulphur content and calorific data. This describes the emissions that would have occurred in the absence of the fuel switch project. 5.4 Emission Reduction Calculation Refer to descriptions in sections 4.3 Quantifiable, and 4.5 Verifiable. 6.0 Reporting of Emission Reductions Reported SO2 = SO2 emissions using mass balance calculation and the fuel quality and consumption values recorded by Lennox in ORAL and reported by station. 100% RFO = Production derived from RFO calculates SO2 emissions on a total heat basis (GJ) assuming the use of natural gas is 2% less efficient than RFO. SO2 ERs = Emission reductions are the difference in Reported and 100% RFO values. Reported SO2 100% RFO SO2 ERs (Mg) (Mg) (Mg) 1999 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec TOTAL Jan Feb Mar Apr May Jun Jul Aug Sep Oct

6 7.0 Final Sections Nov Dec TOTAL Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec TOTAL Documents Examined Fuel volume used, quality, and calorific values available from the ORAL data system at the station from 1999 to Warranties This protocol was authored by T. David Coates, Senior Advisor, Emission Offsets, Ontario Power Generation. As the author I attest to and sign off on the accuracy of this Emission Reduction Protocol. October 15, 2002