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Merck & Co., Inc.

Letter from Charles Newton to Robin Moran

May 8, 1997

U.S. Environmental Protection Agency, Region III
Air, Radiation & Toxins Division
841 Chestnut Street (3AT23)
Philadelphia, PA 19107-4431

RE: Proposed Emissions Permit for Merck's Elkton Plant

Dear Ms. Moran:

The Project XL program seems to offer some advantages for negotiating permits that work for
industry as well as protecting our country's natural resources and our public health and welfare.
However, I believe that you should require more public involvement in the permit review process.

I do not believe that the permit should have an unlimited term. Please consider an initial term limit of
10 to 15 years. While I applaud Merck's proposal to replace their coal-fired boilers with natural gas
fired boilers to reduce the oxides of nitrogen and the sulfur dioxide emissions, I am very concerned
about their proposal to allow a very large increase in the emission of volatile organic compounds
(VOC). We seem to know very little about the adverse effects of the many different chemical
compounds that make up this class of chemicals. I believe that Merck should at least be required to
contribute to an EPA supervised study of the contribution of VOCs to air pollution.

The present permit conditions that allow the permit to be modified if all the parties agree, will
effectively give Merck the ability to veto any proposed changes. This veto power would give
Merck full control of the permit process and would allow them to ignore evidence of harmful effects
on Shenandoah National Park resources and air quality.

I strongly recommend that this permit be written to allow updating and incorporation of any future
knowledge about VOC's into permit conditions. We need to begin immediately to study the effects
of the various chemicals that will be emitted on the natural, historic and human resources of the
Shenandoah Valley and the Shenandoah National Park. Merck is a good local employer and
corporate citizen in many respects, but should not be allowed as much freedom to control the
permit conditions as the present permit draft allows.

I am also concerned that adequate safeguards be incorporated into this permit so that it does not
set a dangerous precedent for similar permit requests near Shenandoah and other national parks.

Thank you for considering my suggestions.


Charles Newton
149 Balkamore Hill Road
Stanley, VA 22851

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