Canal Station is a gas and natural gas electrical power station located on the Cape Cod Canal in Sandwich, Massachusetts. Through a variety of mergers, it has been owned by a company called NRG since 2012. The facility stopped operating on a regular basis around 2009. It went totally dormant from 2009-2010 due to financial reasons. After 2010, it became a “peaker” plant, meaning it operated only during times of high electricity demand – e.g., heat waves, cold snaps.
Like Pilgrim Nuclear, Canal Station operates under a long-expired Clean Water Act NPDES permit (expired in 1994). This permit allows Canal Station to use and discharge process water into the Cape Cod Canal via a once-through cooling system. The facility’s once-through cooling system has the capacity to use up to 518 million gallons per day when operational. This type of outdated cooling system draws in seawater from the Cape Cod Canal, meaning it also draws in marine life. The process entrains small marine organisms (e.g., fish and shellfish eggs and larvae) through the system and impinges larger organisms on the intake screens (e.g., adult and young fish). It also discharges heated water into the Canal. See the thermal plume >>
U.S. Environmental Protection Agency tried to make Canal Station install a closed-loop system in 2008, since it was the “Best Technology Available” to reduce entrainment and protect the environment. Then owner, Mirant, appealed. The final NPDES permit requiring closed-looped cooling was never issued and it operates in accordance with its original permit that was issued in 1989 and expired in 1994 (it has been administratively continued since that time). Read more about the NPDES permit proceedings >>
The facility currently has two units. Unit 1 began commercial operation on July 1, 1968 (#6 fuel oil) and Unit 2 began commercial operation on February 1, 1976 (dual fuel capability – #6 oil or natural gas). Toxic chemicals discharged by the facility into the Cape Cod Canal have included sulfuric acid and nickel compounds, and NRG itself reports that Units 1 and 2 are considered a major source of air emissions such as Nitrogen Oxides, volatile organic compounds, sulfur dioxide, carbon monoxide, particulate matter and other hazardous air pollutants.
NRG Applies to Build Unit 3
NRG filed petitions with the state’s Energy Facilities Siting Board (EFSB) to construct a new electric power plant (Unit 3) and a solar array on the site.
We strongly believe that the EFSB should use NRG’s petition for Unit 3 as an opportunity to take Units 1 and 2 permanently offline. These outdated and environmentally harmful units should be decommissioned before Unit 3 is built. Given that Unit 3 is being proposed as a 40-year plant and it appears that NRG’s Air Quality Operating Permit for Units 1 and 2 expired on January 9, 2014, EFSB should offset the additional fossil fuel facility by taking the two obsolete units offline to eliminate water use and impacts to marine life. When operating, Units 1 and 2 have the capacity to use up to 518 million gallons per day through two cooling water intake structures and entrainment/impingement of marine organisms and pollutant discharges are issues. Furthermore, Unit 3 should be decommissioned at the end of its 40-year lifespan and no license extensions should be permitted.
We recently submitted comments to the EFSB on NRG’s petition to build Unit 3. Read our comments >>
Here are some of the points outlined in the comments letter:
- EFSB should require NRG’s Units 1 & 2, which are outdated, environmentally destructive and operating under an expired NPDES permit, to be decommissioned before an additional unit is approved. We believe EFSB should offset the construction of an additional fossil fuel facility by taking the two obsolete units offline to eliminate water use and impacts to marine life in the Cape Cod Canal.
- Cape Cod Bay, Buzzards Bay, and the Cape Cod Canal, and the surrounding environment are at continued risk from oil spills by further barge shipments to NRG’s Unit 3, as well as from methane releases from the new pipeline and storage tanks — we ask that the environmental and economic consequences of spills and releases be outlined by NRG, including impacts on endangered, threatened and rare species.
- NRG should be required to maintain environmental mitigation accounts that can be drawn on to effectively respond to a variety of accidents or when emissions exceed permitted levels.
- NRG should outline how and when it will check the stability of underground tanks and pipes, and how leaks will be detected. As sea levels rises, so will groundwater levels on the site, and whether salt water intrusion will be an issue for NRG’s underground infrastructure should be addressed.
- Unit 3 does not meet EFSB’s technology performance standards for CO emissions by 13% — a clear emission exceedance that is of major concern for the surrounding environment. Units 1 & 2 should be decommissioned to mitigate the continued decline of air quality and atmospheric health by Unit 3.
- In terms of coastal impacts, NRG should consider future climatic conditions that are projected to increase precipitation and temperatures, particularly in the Northeast; NRG should use the most conservative value of 2.93 feet above mean sea level by 2060 to develop plans to protect the site and should also address potential for rising groundwater tables, subsidence, and erosion on the site.
- Impacts to protected species (including North Atlantic right whales and their critical habitat) from all activities associated with constructions and operation Unit 3 should be outlined, including releases of oil and other hazardous substances. Right whales are known to travel through the Cape Cod Canal and many have been sighted close to the plant.
- At no point in the petition does NRG discuss methane (CH4) emissions, which have a 25x greater impact on climate change. Drilling, storage, extraction, and pipeline activities associated with natural gas result in methane leaks. Compared to carbon dioxide, methane is a far more potent greenhouse gas that could escalate climate problems. NRG should discuss any requirements concerning methane emissions.
- Funds should be set aside to identify and mitigate methane leaks. Otherwise, construction should not be permitted or tolerated.
NRG’s Unit 3 received a unanimous vote of approval from the Cape Cod Commission Thursday, December 1, 2016. Learn more >>