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Merck & Co., Inc.

Testimony before EPA, Region III

Public Hearing on Merck, Project XL Site-Specific Rulemaking

April 14, 1997

Tedd H. Jett, P.E.
Manager, Environmental Engineering
Merck, Stonewall Plant

Merck appreciates this opportunity to contribute to the informed involvement of the public in EPA's rulemaking process. Throughout our XL project, we have endeavored to assure that our stakeholders and other interested parties were provided with complete and accurate information. Tonight, our objective is to provide for the record a summary of the principal features of the project in support of the proposed rulemaking. Supporting documentation for this summary may be found in the docket.

The fundamental requirement for any XL project is to produce superior environmental performance relative to what would result from conformance with the existing regulatory requirements. Any reasonable analysis of our project must conclude that this requirement will be more than satisfied. The conversion of the coal-fired powerhouse to natural gas will result in up-front reductions in total criteria pollutant emissions of over 50% from recent actual levels, or more than 900 TPY. These reductions are not required by any current or reasonably anticipated regulations. The commitment to cap these emissions at a point 20% below recent actual levels will result in a permanent retirement of 300 TPY of emissions to the benefit of the environment. This permanent reduction and capping of emissions is not only not required by current regulations, it goes far beyond current requirements. The innovative permit which is proposed to be issued pursuant to the proposed rulemaking will provide strong incentives for Merck to minimize its actual emissions on an ongoing basis through the total emissions cap and the system of tiered monitoring, recordkeeping and reporting requirements. The environmental benefits associated with the project are truly significant and unique.

Even more unique, is the collaborative process employed to develop the project. We sought to involve those parties with a direct and specific stake in the project from the beginning. A wide variety of interests was represented and all contributed to the innovative proposed permit. Based on the success of this process, the proposed permit provides for these stakeholders to have a continuing opportunity for direct and valued input during operation under the permit as well. Particularly for the local community and regional public interest groups, these opportunities are truly rare and far exceed anything which they would be afforded under the current regulatory system.

For Merck, the project will provide an increased level of operating flexibility and certainty when compared to the current system. In addition, the simplification of the regulatory framework and focus on actual emissions accountability will contribute to the project's environmental benefits. These improvements over the current system offer added support for implementation of the project. We urge EPA to promulgate the site-specific rule as proposed thus enabling these advances to be realized.

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