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Merck & Co., Inc.

Merck XL Permit - Request for Hearing

National Parks and Conservation Association
Northeast Regional Office

14 May 1997

Via Facsimile and U.S. Mail

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

RE: Merck Project XL Permit Elkton, Virginia

Dear Ms. Moran:

The National Parks and Conservation Association (NPCA) is pleased to have this opportunity to comment on the proposed Project XL permit for Merck's Elkton, Virginia plant. NPCA is America's only private nonprofit citizen organization dedicated solely to protecting, preserving, and enhancing the U.S. National Park System. An association of "Citizens Protecting America's Parks," NPCA was founded in 1919, and today has 500,000 members of whom 13,000 are Virginia residents.

NPCA is highly supportive of the Project XL program and of the overall intent of Merck's proposed program. However, there are some serious flaws in the proposed permit and Final Project Agreement that have the potential to harm Shenandoah National Park. Generally, NPCA associates itself with the concerns expressed by the Southern Environmental Law Center. Specifically, NPCA is deeply concerned with the following:

Shenandoah National Park is a nationally significant example of the central Appalachian ecosystem. The park's air quality has long been of serious concern to the National Park Service, NPCA, and to the park's constituents. Much has been done to identify and begin to rectify those factors contributing to air quality problems in the area. We hope that Merck's permit will not reverse this hard-won progress. NPCA urges EPA to resolve the problems with the proposed permit to make the Merck program the model you intend it to be.



Eileen T. Woodford
Northeast Regional Director

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