Notice the surplus 42 inch diameter steel pipe (epoxy coated) at lower left in the Morgantown Industrial Park
From the Sierra Club, West Virginia Chapter, Box 4142, Morgantown, WV 26504, 1/4/22
>> Dear Mr. Edward Andrews @ WV-DEP:
Thank you for providing the opportunity for a public meeting on Tuesday, January 11th @ 6:00 PM, regarding the draft air permit for Marion Energy Partners, LLC (MEP). I am hopeful the format for the meeting will allow for an open discussion and information sharing. I am requesting a clarification as to the format, because although this was announced as a “public meeting”, the response to my meeting registration stated that this was to receive comments (“The purpose of the public review process is to accept public comments on air quality issues relevant to this determination.” per the e-mail from Stephanie Hammond).
WV rules at 45-CSR-13-9.1 specifies that “A public meeting(s) to provide information and receive comments on permit applications …”, and we clearly need information about this facility to provide meaningful comments.
Thank you also for extending the comment deadline to Jan. 13, however, we are concerned that this provides a very short turn-around to fully investigate the many questions we have. We hope you will consider a second extension to allow a reasonable time for further review and comments. It is my understanding that there is no immediate urgency for this permit, and a full evaluation of the issues is in the public interest and would not disadvantage the applicant.
As noted in the application and the Engineering Evaluation, this facility may be unique and have unique impacts because it would be independent of the electric grid for its energy supply. Before setting precedents on how such facilities are regulated, a public meeting to explore these issues is essential to inform the public and to allow meaningful community input.
Our review of the very limited information available has resulted in a number of questions, many of which may bear on the WV-DEP’s decision-making regarding this draft permit. In an effort to have the public information meeting be as productive as possible, we hope that the applicant will be willing to attend and that the following questions will be addressed by WV-DEP or the applicant:
1.) Has WV-DEP assessed noise impacts from the proposed MEP facility? In particular, what will be the noise impact on residential areas across the Mon River Valley, or at the nearby schools (Skyview Elementary and Westwood Middle Schools)?
2.) Has there been an estimate of “eWaste” volumes to be generated by this facility?
3.) Will the facility provide bonding or escrow funds to decommission the site at the end of its useful life? We note that legislation in 2021 required wind and solar energy facilities to post bonds sufficient to cover the full cost of site reclamation, do gas-fired electric generating facilities have similar requirements?
4.) Since gas is not “pipeline quality”, what other impurities are present and would be emitted after combustion (radon, VOCs, heavy metals, etc.)? We recommend weekly monitoring of raw gas; annual monitoring is not sufficient.
5.) Is this a Bitcoin Mining Operation or something similar?
6.) Who is buying and using these services, i.e., who are the customers? Who is benefiting/profiting from the facility? Is there an intent to generate block chain data to create cryptocurrency?
7.) What is the relationship of this proposed facility to WVU MSEEEL and the WVU Business School?
8.) If this “Science Center” is to study how electricity is generated from gas, how long is that project to last? Who are the scientists involved and providing analysis?
9.) How many jobs would be created by the proposed MEP facility?
10.) What taxes will they pay? Will gas severance taxes apply to the gas it sells to itself?
11.) Will there be water quality impacts?
12.) Were bids taken for solar energy sources? If not, why not?
13.) Has WV-DEP made any determination on whether emissions from this facility will be aggregated with those from the adjoining gas wells, pipelines and related facilities owned by the parent company? We note that the emissions from the four engines approaches the threshold for a major source for NOx, and that greenhouse gas emissions are subject to regulation if they exceed 75,000 TPY (45-CSR-14.2.80.d). What information is available on air emissions from these wells and related facilities?
14.) Are there unique functions of the Science Center that preclude it from being supplied by electricity from the electric grid? If so, what are these?
We recognize that some of these issues are only indirectly related to the draft air permit but hope that you or the applicant will be prepared to address those. Please let me know if I can provide additional information.
>> Sincerely, James Kotcon, Conservation Chair, West Virginia Chapter of Sierra Club
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TO LISTEN IN OR PARTICIPATE IN THE PUBLIC MEETING, REPLY TO THE FOLLOWING LINK ~ https://forms.gle/vZvJirkUKayGee1W7
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