I would like to voice an emphatic NO to the running of diesel generators during planned outage events.  During any event except true emergencies, even then a time limitation must be in place. 

General conservative calculations of just the particulate matter (PM) ejected by the Tier IV diesel generators is an environmental catastrophe.  I have calculated PM for a few of  the proposed  data centers such as George Washington Village, Washington District (aggregate Forest Lane, Simms, Sesson) and Cranes Corner.  I am sure DEQ is fully aware of the grave hazards to humans that PM poses.   It might be logical to have a few generators run during extreme situations but when hundreds of generators are coalesced into a relatively small geographic area the PM becomes overwhelming and environmentally hazardous.  SCALE MATTERS  Imagine having one cigarette smoker in a small room, not good but perhaps bearable.  Now imagine that same small room with 50 smokers.  The situation drastically changes for the worse.  In essence this is what data centers are asking from DEQ.  Data Centers are and should be considered heavy industry and must be treated as such.  The amount of PM concentrated around these “data campuses” is staggering.  For example a typical 1 million square foot industrial data complex will consume approximately 876,000,000KW/yr that’s 2,400,000 KW/day.  

So for a  1 million square foot data complex;

Using 2,400,000 KW/day and discharge of .03gm PM per Kwh that is 72,000 gms or 158 lbs in a 24 hour period.

GWV is 7,900,000 sq ft which would expel approximately 1248 lbs of PM in a 24-hour period

Washington District combined is 12,000,000 sq ft amounting to expulsion of approximately 1896 lbs of PM in 24 hours.  

These numbers are staggering for a particle less than the width of a human hair and only milligrams in weight.  The concentration of generators in a relatively small location can only be considered an extreme health risk.  Operation of just 10 days in the summer would produce an effective plume of PM of 12,000-18,000 pounds.  This concentration of PM is not acceptable to human or animal survivability. 

DEQs own PM numbers for Cranes Corner of 5.18 total PM would only allow 240 hours of generator time per year. 

I am vehemently opposed allowing any type of extended generator usage for the purpose of grid stabilization, lack of supply or other non-emergency electrical issues

DEQ must protect the citizens of Virginia.  

Regards

JW Swain