Jump to main content.

Project XL Logo

Merck & Co., Inc.

Letter from William E. Damon, Jr. to S. Margaret Key

United States Department of Agriculture
Forest Service
George Washington Jefferson National Forests
5162 Valleypointe Pkwy.
Roanoke, VA 24019-3050

File Code: 2580

Date: February 21, 1997

S. Margaret Key
Department of Environmental Quality
Valley Regional Office
PO Box 1129
Harrisonburg, VA 22801-1129

Dear Ms. Key:

This correspondence addresses USDA/Forest Service (FS) comments to the draft Prevention of Significant Deterioration/Project XL permit of Merck and Company, Inc. (Merck/Rockingham County; Registration No. - 20524). More specifically, our comments relate to two documents: 1) XL Project Team Final Draft Permit (dated 12-13-96) and 2) PSD Permit Support Document (dated 2-6-97, which incorporates many USDI/National Park Service comments from their 1-30-97 correspondence to Mr. Tedd Jett of Merck).

The FS is very supportive of the innovative way Merck and the other permit signatories have drafted the Project XL permit. Hopefully it will serve as a model for other industries to follow. The draft permit is well thought out and attempts to anticipate many future contingencies. In general, we have no serious reservations regarding the permit as written.The FS is obviously not a signatory to the agreement, but we consider ourselves a definite stakeholder in this permit.

The FS is keenly interested in this permit since three FS Class I areas are located between 96 and 110 km. from the Merck Rockingham facility. Class I areas include the James River Face Wilderness in western Virginia and two areas in eastern West Virginia: Dolly Sods and Otter Creek Wildernesses. Our comments relate to potential impacts at those three areas.

Specific comments to the XL Project Team Final Draft Permit:

  1. Section 6.2.1.b. solely discusses an AQRV assessment at the Shenandoah National Park (SNP). Potential AQRV impacts at SNP from the Merck facility would obviously be greater than at FS Class I areas, but differing AQRVs and "threshold values" at each Class I area speak to the need to do AQRV analyses for each Class I area. Therefore, please change the verbiage to read "... contribute adverse impacts on any AQRVs at Class I areas."
  2. Section 6.2.1: What are the consequences if an AQRV analysis, modeling VOC emissions, shows adverse impacts at a Class I area? What mitigating measures would occur? Would offsets be sought?
  3. Recommend that all references to the National Park Service, apart from it's "signatory" responsibilities, be deleted and replaced with Federal Land Managers (FLMs).

Specific comments to the PSD Permit Support document:

  1. SAI's VOC (ozone) assessment (Attachment 2) done for the permit is a needed part of the permit process. Have other assessments for SO2, NOx, and PM-10 emissions been done in modeling impacts at the SNP? If yes, what have those assessments shown with regard to impacts at the SNP?
  2. We agree that the region of the Merck facility is NOx limited most of the year, the permit needs to address the issue that under certain meteorological conditions and at certain times of the year, VOCs can be a significant factor in rural ozone formation.
  3. On page 39 of the draft, second paragraph, is a statement regarding modeling needs once VOC emissions reach a certain level. In addition to what is written, we recommend the following statement - "The DEQ, EPA, and FLMs will decide on appropriate modeling protocols."
  4. On page 42 of the draft is a section titled "Definitions for Terms in the PSD Permit", this section is blank in our draft. We would like to see a definition of AQRVs in this section. The definition stated in EPA's draft revision to the new Source Review regulations has been accepted by the EPA and FLMs.

Please contact Cindy Huber, Air Quality Specialist, at 540-265-5156 if you have any questions regarding this correspondence.



Forest Supervisor
George Washington and Jefferson National Forests

cc: Charles Myers, Forest Supervisor, Monongahela National Forest
Julie Thomas, Air Specialist, Shenandoah National Park
Robin Moran, EPA Region III



Local Navigation

Jump to main content.