Proposed ‘Data Center’ in Morgantown Industrial Park ~ More Questions

QUESTIONS for W. V. Department of Environmental Protection about a ‘Science Facility’ 1/11/22

RE: Proposed Permit R13-3533, ‘Science Facility’ ~ Marion Energy Partners, LLC

1. Why locate the ‘Science Facility’ along side an existing gas well where there are hazards and dangers of toxic fumes, explosive leaks or future space needs to plug or otherwise service the well. Can cigarette butts, static electricity, or random lightning bolts perform an ignition on a leaking stream from casing cracks or faulty gaskets or valves?

2. Where is the “gathering line” that will supply the Facility? Will a feeder pipeline system be installed? Will it involve traps or filters, dehumidifiers, pressure regulators and/or metering hardware? What monitoring will be provided for leaks?

3. How can operating personnel or people nearby detect feed system leaks or gas well leaks if no odorant is present in the raw natural gas being piped into the Facility thru the aforesaid equipment? Mercaptans or other sulfur containing compounds are needed for safety?

4. Since raw feeder gas will contain a variety of trace components, how will deactivation of the oxidation catalyst by impurities in the gas be monitored in real time and catalyst regeneration and/or replacement be performed in a timely manner?

5. Inefficient operation of this Facility and/or poor oxidation catalyst performance can transform the emissions into the “major source” category. How will WV-DEP plan to prevent such occurrences? The operations plan is therefore faulty?

6. Given the WV Code § 22-1-1, b-10, viz. “ To promote pollution prevention by encouraging reduction or elimination of pollutants at the source through process modification, material substitutions, in-process recycling, reduction of raw material use or other source reduction opportunities.” What has WV-DEP done, or can still do, to satisfy this responsibility? It would appear that the carbon dioxide pollution is massive and is uncontrolled?

7. Reduction of pollution and of raw material use is feasible. The electrical power to serve a GIS graphics computer workstation, a large screen video display, a data logger and a color printer plotter would be advised, and sufficient for a science center and data center. These can be powered from conventional 120 volt AC circuits, thus eliminating the need for any natural gas fired engines. Can the site here be served with utility supplied electricity?

8. Will the tail pipe option be present on the natural gas engines? Will exhaust pipes connect to an exhaust header and then connected to one 200 foot stack, or will four stacks be installed?

9. Reworking or expansion of local existing wells may be needed to supply the Facility, if so should not the emissions therefrom, due to diesel engines and truck exhausts, be considered as episodes at this location, as part of normal operations which are 24/7 by 365 for the Facility? This consideration would in any case advise against the construction of any such Facility as that proposed in a populated area?

10. Should this permit application be considered premature since the results of the multi-year study entitled “Marcellus Shale Energy & Environment Laboratory” have not run to fruition, because the results which influence this site and feed gas are not known to the site owners, to the WV-DEP, or to the general public (all of whom are to be served by these very studies)? Not every application, including this one, deserves to be approved?

Duane Nichols, Mon Valley Clean Air Coalition
Morgantown, WV 26508

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SEE ALSO: Draft Permit R13-3533 for Marion Energy Partners, LLC, “Science Center” (‘data center’) for Morgantown Industrial Park

TO LISTEN IN OR PARTICIPATE IN THE PUBLIC MEETING ON TUESDAY, JANUARY 11th at 6:00 PM, REPLY TO THE FOLLOWING LINK ~ https://forms.gle/vZvJirkUKayGee1W7

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Details on how to download the Draft Permit R13-3533, the application and other materials regarding the permit decision are available at:

https://dep.wv.gov/daq/permitting/Pages/NSR-Permit-Applications.aspx

The Division of Air Quality will accept written comments until 5 p.m. Jan. 13, by email to:

Edward.S.Andrews@wv.gov with “Marion Energy Partners Comments” in the subject line, or by regular mail to Edward Andrews, WV Department of Environmental Protection, Division of Air Quality, 601 57th St. SE, Charleston, WV 25304.

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