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Merck & Co., Inc.
Merck XL Permit - Request for Hearing
National Parks and Conservation Association
ALERT SHENANDOAH NATIONAL PARK TO BE NATIONAL TEST FOR AIR QUALITY PROTECTION STANDARDS
Proposed Emissions Permit for Merck's Elkton Plant Leaves the Public with Little Say over the Future of the Park's Air Quality
EPA is on the verge of granting Merck's Elkton plant, which is two miles from Shenandoah National Park, a new permit that will exempt Merck from strict adherence to federal environmental regulations governing air quality. The exemption is being granted under a federal program (Project XL) that exempts companies from strict adherence to federal regulations if the company's alternative pollution control program results in superior environmental conditions than would be attained through normal regulatory compliance. Specifically, Merck is proposing to replace its coal-fired boilers with natural gas to reduce NOx and SO2 emissions.
We are highly supportive of the overall intent of Merck's proposed program. However, the problem is that there are serious flaws in the proposed permit. If these shortcomings are allowed to go unchallenged, they could set a dangerous precedent for similar permit requests near Shenandoah and other national parks. We need your help in persuading EPA to rectify these problems:
- Inadequate community and public interest participation in the permit review process. The proposed permit minimizes public participation in the permit review process. Full public participation is supposed to be a major component of the Project XL program. A lack of a public interest voice for the park may mean that potential future evidence of emissions-linked resource degradation in Shenandoah National Park will be insufficiently addressed or ignored altogether.
- The permit has an unlimited term, and any proposed changes can be vetoed by Merck. Once the permit is granted, it can continue indefinitely. Although review of the permit is to occur every five years, Merck can veto any proposed changes. For example, it can ignore evidence that pollution is increasing as the result of its pollutant's operation. The danger of such an arrangement is obvious. With veto power and an unlimited term, Merck is given virtual control over the permitting process and can ignore evidence of harmful effects o the park's resources and air quality.
- Not all pollutants may decrease with Merck's new boilers. Although the total pollutants emitted will decrease, there is the potential for the emission of volatile organic compounds (VOC) to increase. Currently, the role of VOCs in the formation of ozone is considered minimal, but their direct impact on human health and natural resources is not well known. The proposed permit's review structure would put severe limitations on incorporating any future knowledge about VOCs into the permit's conditions.
- Require greater public involvement in the permit review process.
- Put a term limit on the permit. A 10-15 year initial term limit would be more appropriate.
- Remove Merck's veto authority over proposed permit changes.
(over)
Please urge EPA to:
Send your comments by May 15 to:
Ms. Robin Moran
U.S. Environmental Protection Agency, Region III
Air, Radiation & Toxins Division
841 Chestnut St (3AT23)
Philadelphia, PA 19107-4431
(215) 566-2064 - phone
(215) 566-2124 - fax
I agree with the above Betty C. Phillip
THANK YOU FOR HELPING TO PROTECT SHENANDOAH NATIONAL PARK!