1. The information below indicates why ‘Marion Energy’ needs an Air Permit. JK

2. Northeast Natural Energy and Marion Energy Partners kept this plan 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. Even the fact of a secret project was not disclosed to these local entities! DGN

3. I have been told in writing that this project is for “gas combustion research.” My reply was, “this does not hold water.” I can understand why they don’t want publicity about cryptocurrency and the unnecessary polluting of the Mon River valley. I cannot conceive of any logical purpose that fits the facts as we know them. DGN

4. They also told me they had made no final plans to proceed. I would call this an understatement, because even the information that has been released is not well defined. That doesn’t mean that our air quality is protected. DGN

5. There is information 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. Some of this information is not now available, but will become public later this year. This includes information to design and operate the oxidation catalyst units effectively. Does the WV-DEP want all the information? DGN

6. Noise and other possible nuisances are relevant issues, but will receive secondary (if any) consideration. There are bit-coin mining facilities In other states where there are significant noise complaints. DGN

7. I have heard no descriptors that indicate this is not a bit-coin mining operation. To the contrary, at some other locations, bit-coin mining facilities are called ‘data centers’ and attempt to operate 365/24. Bit-coin mining is now a hot topic internationally and, yes, elsewhere in West Virginia (Parkersburg, Marion-Mercer-McDowell counties) because the potential payouts look huge. DGN

8. The proposed facility does need an air quality permit. They may need to modify this draft and/or get a different permit if they choose an evaporation - cooling system. They do not need to go before the Public Service Commission. JK

NOTE. 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.

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.

Table 3 of the Engineering Evaluation for R13-3533 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).

When these emission rates are compared on the basis of pounds per MMBTU, the levels of NOx authorized exceed those allowed under the Operating permit for the Longview coal-fired power plant (R30-06100134-2018) by a factor of approximately 2.6. The VOC levels proposed for the Marion Energy facility exceed those of Longview by 21 times. JK

Duane Nichols & Jim Kotcon