Environmental
Approach
Atmosphere’s approach is grounded in a simple principle: build responsibly from the start. The project is designed to deliver a high-performance data center campus that carefully manages energy use, protects natural resources, and aligns with local and regional environmental goals. From power sourcing to water use and system design, each element reflects a focus on long-term sustainability.
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Atmosphere Data Centers is committed to exploring a practical and measurable path toward cleaner energy at the Dickerson campus. This memo outlines the realities of powering a 24/7 hyperscale data center, explains the current limitations of the regional energy grid, and details the technologies and procurement strategies being evaluated to reduce emissions over time while maintaining the reliability required for critical infrastructure.
This technical annex provides the detailed data, methodology, and supporting analysis behind Atmosphere’s Clean Energy Path Memo for the Dickerson campus. It offers a deeper look at topics including PJM grid composition, renewable energy limitations, fuel cell technology, REC procurement strategies, and the challenges of achieving 24/7 carbon-free energy for hyperscale data centers — all grounded in current market conditions, regulations, and available technologies.
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Power will be supplied via existing FirstEnergy transmission lines that border the site. Atmosphere will:
Construct a new on-site substation and switchyard
Fund the substation construction at its expense
Connect directly to adjacent transmission infrastructure
No new off-site transmission corridors are required.
Backup Power
The campus will include diesel generators for emergency use and required periodic testing only. These generators:
Are not used for primary operations
Are subject to Maryland Department of the Environment air-quality permitting
May include Selective Catalytic Reduction (SCR) and Diesel Particulate Filters (DPF) to reduce emissions
Fuel storage and handling systems must meet strict state requirements for spill prevention, containment, and monitoring.
Storage facilities
On-site water treatment and wastewater treatment buildings
Surface parking areas
24/7 secured operations
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Domestic Water
Supplied by an existing on-site well
Usage reallocated among existing wells
No net increase in groundwater use
Cooling Water
Sourced from the Potomac River
Maximum daily withdrawal is approximately 900 times less than the former coal-fired power plant
Reuses existing intake infrastructure to avoid riverbank disturbance
Discharge temperatures will align with ambient air conditions
All withdrawal and discharge permits have been submitted to the Maryland Department of the Environment and are subject to state oversight.
Forest Conservation
The project complies with Montgomery County’s Forest Conservation Law. Approximately 500 acres of Terra Energy-owned agricultural land are proposed for permanent forest conservation easement.
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System Design and Operation
Water for the cooling process is reused multiple times (3–6 cycles of concentration) before discharge, reducing overall demand on the river.
Daily withdrawal is not constant and can range from 0 to 500,000 gallons depending on weather and cooling demand.
On average the campus withdraws 69,300 GDP from the Potomac River. About 46,200 GDP are evaporated and the remainder is returned to the River near its ambient temperature, under State permit conditions. That is far less than a 150-acre, 18-hole golf course in Maryland that uses about 107,100 GPD on average, according to the U.S. Golf Association, none of which is returned to local water resources.
Water is only used for cooling when air temperatures exceed roughly 75°F, meaning little to no river water use during winter months.
The system includes on-site storage capacity to manage operational needs efficiently and reduce variability in withdrawals.
Intake and Aquatic Protection
Water intake is engineered for aquatic protection, using:
A 1-millimeter screen system to mitigate entrainment of small organisms
Ultra-low intake velocity of less than 0.02 ft/sec — well below the EPA’s recommended limit of 0.5 ft/sec, and about 45 times slower than the former power plant’s intake — allowing fish and other wildlife to easily move away from the intake.
The project reuses the site’s existing river intake infrastructure, avoiding new disturbance to the Potomac River shoreline and limiting construction-related impacts.
Water Treatment Process
Treatment relies primarily on physical filtration rather than chemicals, including multi-media filtration and micro sand filtration. These processes remove sediment and particles before water enters the cooling system.
The only chemical used is a targeted oxidant (sodium hypochlorite) for biological control. It is only used when needed, typically in warmer temperatures and is generated on-site, eliminating transport and storage risks. Sodium hypochlorite is fully neutralized prior to discharge.
Waste and Byproducts Management
The treatment process produces two managed byproducts:
Filtered solids are removed and transported offsite and are not discharged into the river. Water is recycled back into the system.
Cooling system blowdown is treated and returned to the river in compliance with permit limits.
Discharge and Environmental Safeguards
Before discharge, water is treated to ensure no residual sodium hypochlorite remains and the temperature and water quality meet strict State permit requirements.
The system is designed with a maximum potential discharge of approximately 480,000 gallons per day.
Returned water will be near ambient river temperature, with discharge temperature regulated under State permit requirements.
Water Sources and System Scope
Groundwater is only used for domestic purposes and not used in the cooling process.
The project does not use municipal or County water for cooling, relying instead only on river water.
System Resilience
The system includes a backup or redundant cooling approach in the event the primary water system is offline.
The system will rely on on-site storage in event of a complete failure of the water system.
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Fire Suppression Planning and Requirements
The fire-suppression system is being finalized as part of the project’s detailed design and will be submitted for review and permitting. Consistent with the project’s commitment to avoid PFAS, the system will not use PFAS-containing suppression agents.
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Cooling Systems and Heat Release
The data center uses direct evaporative cooling and air-side economizers, which rely on outside air to cool equipment rather than energy-intensive mechanical systems.
This approach reduces overall energy demand and limits the need for water-intensive systems and eliminates the need for refrigerant-based cooling systems.
Backup Power Systems (Diesel Generators)
Diesel generators are installed solely for emergency backup power, not for continuous or primary operations.
The number of generators will be finalized as part of the conditional use process and the Maryland Department of the Environment (MDE) air permitting process.
Limited and Occasional Generator Use
Utility outages: rare, typically minutes to hours until power is restored
Periodic testing: monthly, generally 30 minutes or less
Annual full-load testing: typically 2–4 hours once per year
Emissions Controls and Standards
All data center generators will meet or exceed EPA Tier 4 (or equivalent) emissions standards, the most stringent available for diesel equipment.
Each unit is equipped with:
Diesel Particulate Filters (DPF) to reduce particulate matter
Selective Catalytic Reduction (SCR) systems to reduce nitrogen oxide (NOx) emissions
Emissions limits, operating hours, and monitoring requirements are strictly regulated through the MDE air quality permitting process.
Fuel Storage and Handling
Diesel fuel will be stored either in integrated generator tanks or above-ground storage tanks.
All tanks are double-walled with continuous electronic monitoring to detect and prevent leaks.
Fuel deliveries are infrequent and typically occur only as needed, depending on testing or emergency use (generally on the order of every few weeks under normal conditions).
Technology Selection and Reliability
Diesel generators remain the most reliable and widely used technology for backup power in data centers due to their ability to operate independently of external fuel supply systems.
Unlike alternatives such as natural gas, diesel systems are not dependent on pipeline pressure or real-time fuel delivery, ensuring consistent performance during extreme weather or grid outages.
Additional Environmental Considerations
The project does not use PFAS or similar persistent chemicals in its operations.
Cooling and water treatment systems are designed to avoid the use of chemical cooling agents, relying instead on filtration and controlled biological treatment processes.
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Project complies with Montgomery County Forest Conservation Law
Terra Energy-owned agricultural land (~500 acres) proposed for forest conservation easement
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Conservation Easement
Terra continues to make progress on this effort in placing approximately 540 acres of Terra’s Ag Land into a Category 1 Conservation Easement.
All ag reserve land, with the exception of areas already supporting area utilities, will be placed in a variety of protective easements to ensure no development can ever occur, example are tree banks, steep slope restoration and wetland preservation. All areas will be enhanced, restored and protected.
The conservation easements will be recorded in phases in accordance with forest conservation plans that will be reviewed by the Montgomery County Planning Board for the development of the data center and adjacent battery storage facility
Adjacent Agricultural Land
A switching station will be constructed by First Energy on Ag zoned land owned by Terra adjacent to the existing transmission lines.
This land has no environmentally sensitive features (e.g. forest, wetlands, streams, or steep slopes).
Atmosphere will be responsible for the majority, and possibly 100% of the costs to construct the switching station.
The design of the switching station is ongoing and we will provide details as they are determined.
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Low Frequency Sound and Vibration
A vibration study has not been completed and is not expected to be necessary given the distance of this site to surrounding neighbors.
Noise Study and Compliance
The study of the anticipated sound emissions from the development was performed under normal operating conditions.
The results of the analysis indicate the proposed development will not exceed maximum day or nighttime sound levels established by the State of Maryland and Montgomery County.