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Merck & Co., Inc.
Letter from James W. Rue to Robin Moran
Dep - Pennsylvania Department of Environmental Protection
Rachel Carson State Office Building
P.O. Box 2063
Harrisburg, PA 17105-2063
May 15, 1997
717-772-2724
Office of Air, Recycling and Radiation Protection
Ms. Robin Moran
U.S. Environmental Protection Agency
Region III
Air, Radiation & Toxics Division
841 Chestnut Building (3AT23)
Philadelphia, PA 19107-4431
Dear Ms. Moran:
Pennsylvania Department of Environmental Protection (PADEP) is pleased to have this opportunity to comment on the Merck XL Project. PADEP is committed to finding innovative and cost-effective ways of implementing protective environmental programs while promoting operational flexibility. The Merck XL Project is an excellent example of this type of innovative permitting, and we commend EPA for its efforts.
We also believe that a number of features of the project may be transferable to future permitting efforts. The tiered approach to monitoring, recordkeeping and reporting in particular may have broad applicability. The concept that less rigorous monitoring is warranted when a permittee is well below the applicable limit is compelling; we believe that it may provide real environmental benefits to the extent that it provides an incentive to maintain low actual emissions.
We support EPA's approach to stakeholder involvement as well. It is impressive to read the extent to which the community was directly involved with the negotiation of the project. We believe that the amount of community participation in the ongoing operation of the permit is unique and sets a new standard for this type of stakeholder involvement. Focusing the community representation through the county government is especially innovative, because it ensures full community representation. It will help protect against promotion of values and ideas that are at odds with the interests of the community at large.
I would like to commend the EPA and Merck, as well as all the participants in this project, on the efforts that were made to develop this innovative permit. it is a great example of the reinventing regulation initiative EPA has taken on and I believe will provide significant environmental performance while allowing industry the flexibility warranted by such a permit.
Sincerely,
James W. Rue
Deputy Secretary for Air, Recycling and Radiation Protection
cc: Larry Simmons