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Merck & Co., Inc.

Letter from helen V. Ininger to Robin Moran

Rt. 1, Box 217
McGaheysville, VA 22840

May 8, 1997

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

Dear Ms. Moran:

I have been a resident of this area since September, 1969. My home lies within eight miles of the nearest entrance to Shenandoah National Park. I am a frequent visitor to the Park and I often take members of my family and visitors from other parts of the country to the Park. The pollution has increased steadily since 1969. My concerns are for the current Proposed Emissions Permit for Merck's Elkton Plant and its impact on future environmental problems of the community and the Park.

There is very little public awareness and participation in the permit review process of Project XL; this minimization of public participation is a result of the lack of publicity to the community surrounding the project. The permit has an unlimited term; any proposed changes can be vetoed by Merck. Merck can ignore evidence that pollution is increasing as the result of its plant's operation. Although total pollutants emitted may decrease, the potential for the emission of volatile organic compounds could increase.

With the above in mind, I urge the EPA to require a greater public involvement in the permit review process, to put a term limit on the permit which is more appropriate, such as a 10-15 initial term limit, and to remove Merck's veto authority over proposed permit changes.

Sincerely yours,


Helen V. Ininger
Professor Emerita
James Madison University

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