Merck & Co., Inc.

Letter from Charles D. Pierce to Robin Moran

5/4/97
Charles D. Pierce
211 Evening Lane
Winchester, Va., 22603
540-667-3184
cpierce309@aol.com

Ms. Robin Moran
U.S. Environmental Protection Agency
Region 111, Air, Radiation & Toxics Division
841 Chestnut St, (3AT23)
Philadelphia, PA., 19107

Dear Ms. Moran:

The Shenandoah Group of the Virginia Chapter of the Sierra Club submits the following comments on the Merck Project XL Permit. Our group has around 400 members in the Shenandoah Valley. The Merck plant at Elkton is in the center of our group's geographic area and we have a vital interest in the project. The Elkton plant is only two miles from the Shenandoah National Park. We are concerned about this project and how it relates to air quality and forest health in particular.

We are pleased that the XL project will reduce the total air emissions of the Merck plant in Elkton. However, we have a number of concerns about the project.

The latest EPA Toxics release inventory lists Merck, a pharmaceutical manufacturer, as one of the top polluters in Virginia although recent changes have curtailed some of the worst emissions.

Project XL is based on an agreement that will create a cap for pollutants that have adverse effects on public health or welfare and allow Merck the flexibility to make cost-effective process changes without prior permit approval. As a part of the project Merck has proposed to switch from coal-fired boilers to natural gas, which will result in reductions in NOx and SO2. The major benefit of the Project XL is that it is expected to result in reduction of pollutant emissions near Shenandoah National Park. While Project XL may reduce total air emissions at the Merck plant in Elkton, the Sierra Club still has a number of concerns, such as:

The term of the permit is unlimited. The initial term should be no longer than 5 years.
The permit will allow an increase in VOC and NOx emissions. This may cause an increase in ozone, which William Grant (Sierra Club, Virginia Chapter) has statistically correlated with oak decline and hickory mortality in Eastern U.S. forests. Ozone has been found to affect 95 plant species in the Shenandoah and Great Smokies National Parks. Among the most vulnerable are black cherries and milkweeds, both extremely valuable sources of wildlife food. There may also be adverse respiratory effects for human residents of the area.
Citizens are not adequately represented in the permit review process. The citizen stakeholder should be given a vote in the 5-year review process. Merck has a veto power vote while citizens have no vote at all. Additional representation by a public interest group, such as the Southern Environmental Law Center or Virginia Chapter of the American Lung Association is needed.
The project focuses on reducing large particulates (PM10), but extensive scientific evidence shows that small particulates (PM2.5 or lower) are more dangerous in health and have a significant negative effect on visibility. EPA needs to modify the permit to include the 2.5 standard.

Sincerely,

Charles D. Pierce, Chair, Shenandoah Group,
Virginia Sierra Club

P.S. I will be in Alaska until May 27 and unavailable for any questions until then

Merck & Co., Inc.

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