MORE PROBLEMS IDENTIFIED ~ Proposed ‘Science Facility’ in the Morgantown Industrial Park

by Duane Nichols on January 22, 2022

There are four horizontal Marcellus gas wells in the M.I.P.

THE MORGANTOWN INDUSTRIAL PARK SHOULD BE PROTECTED FROM ARBITRARY POLLUTERS

>>> From an Analysis by Duane Nichols, Mon Valley Clean Air Coalition, January 18, 2022

The proposed ‘Science Facility’ that is being planned by ‘Marion Energy Partners, LLC would be located in the Morgantown Industrial Park. The justification provided thus far to take up space, to consume natural resources (natural gas) and to pollute the local valley, is very problematic. Other concerns include: multiple vapor plumes, noises 24/365, regional competition for Internet services, and more drilling & fracking.

Northeast Natural Energy and Marion Energy Partners have kept this project secret even from the managers of the Morgantown Industrial Park and the Mon County Commission, both of whom are involving with spending public funds to sustain and improve the Park. Marion Energy is registered with the WV Secretary of State as a foreign company with activities in Marion County? This is very curious, if not problematic.

There is information which is part of the multi-year “Marcellus Shale Energy & Environment Laboratory” project that is relevant to siting, raw gas supply, facility construction, ancillary equipment specifications, and sustained operating conditions. This includes information to properly design and operate the critically important oxidation catalyst units. If these units are inefficient, the pollution emissions will be even greater than those published.

Noise and the other possible nuisances are also important issues, but will receive no consideration by the WV-DEP. There are bit-coin mining facilities in other states where there are significant noise and other complaints. The high heat generation rates of computer equipment requires additional energy for the cooling units.

The proposed facility does need an air quality permit, now in process. (A different permit would be required if an evaporative cooling system is to be used.) The 45-CSR-13 (Section 2.24) defines a “Stationary Source” as a facility that discharges more than 10 Tons Per Year (TPY) of any regulated air pollutant, or more than 5 TPY of Hazardous Air Pollutants (HAPs). The 45-CSR-13 (Section 5.1) specifies that no person may construct a “Stationary Source” without a permit. This is also confirmed in Section 2.3 of the draft permit.

The Table 3 of WV-DEP’s R13-3533 Engineering Evaluation indicates that these thresholds are exceeded for NOx (66 TPY), CO (33 TPY) and VOCs (33 TPY), as well as total HAPs (14.4 TPY) and formaldehyde (6.68 TPY). Therefore, a WV-DEP permit is necessary. [VOC is “volatile organic compounds.”]

The carbon dioxide generation and release is 55,000 tons per year, or 150 tons per day. And, the VOCs are also potent greenhouse gases along with the natural gas vents and leaks.

When these emission rates are compared on the basis of pounds per million BTU, the levels of NOx now authorized exceed that allowed under the operating permit for the Longview coal-fired power plant (R30-06100134-2018) by a factor of approximately 2.6. The VOC level proposed for the Marion Energy facility exceeds those of Longview by 21 times. The four stacks are only 20 feet tall. And there is no cure for asthma.

In conclusion, the construction of this Facility in the Morgantown Industrial Park has not been justified as needed nor consistent with regional norms, and would appear to be quite problem prone. The generation of electricity in the MIP with natural gas would unnecessarily pollute the region, and worse. Greenhouse gases here are the uncontrolled carbon dioxide plus the VOCs as well as natural gas vents and leaks, over 55,000 TPY.

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Kathryn Madison January 25, 2022 at 2:43 am

“Catching up on newspapers. From Kathryn Madison 1/22/22

Northeast Natural Energy posted a legal ad in Wednesday’s Dominion Post that they are applying for a new air permit for a natural gas dehydration unit at the Morgantown Industrial Park.

Application # 061-00265 is for an “after the fact” construction permit for a dehydrator located at what appears to be the “Science well” site, less than 500 feet from the MEP site. If I am reading that permit correctly (never a sure bet, as these are deliberately obscure), the site has been operating since 2012 without a permit.

The application states that the Potential To Emit includes 8.56 Tons Per Year (TPY) of VOCs including 7.87 TPY of Hazardous Air Pollutants (HAPs).

The application discusses “Aggregation” in Section 1.4, (Page 10) and states that NNE does not operate any other facilities within one-quarter mile, therefore this should be considered a single surface site facility. (It appears they want to retain the fiction that they are separate from Marion Energy Partners, even though the application was signed by the same guy, Brett Loflin, See Page 15.)

If we add the HAPs from this site to the 14.2 TPY at MEP, it still would not exceed the 25 TPY to be considered a major source, but it gets them almost 90 % of the way there. Any other source of HAPs would almost certainly exceed the threshold and require additional analysis and controls.

Jim Kotcon, WV Sierra Club

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