Merck & Co., Inc.

Letter from Mark J. Roberts to Robin Moran

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

Dear Ms. Moran:

It is very commendable that the Merck Company is planning to replace its coal powered boilers at its Elkton, Virginia, facility with cleaner gas-burning units in order to reduce sulfur dioxide and nitrogen oxide emissions, and thereby help to improve the air pollution problem in adjacent Shenandoah National Park. However, granting Merck a permit exempting it from adherence to federal clean air standards under the Project XL program is flawed and therefore not appropriate.

First, the permit minimizes public participation in the review process. This is unfair because the land effected, Shenandoah National Park, is federal public land. A lack of public voice for the park may mean that future emissions-caused degradation of the park will be insufficiently addressed or ignored completely.

Secondly, the permit has unlimited term and Merck has total veto power over proposed changes. With veto power and unlimited term, Merck will have complete dictatorial power over the permitting process and can ignore any future findings of harmful effects to Shenandoah National Park by the operation of its Elkton plant - with impunity.

Thirdly, Merck's new gas units will not decrease all total pollutants. Volatile organic compounds (VOCs) may actually increase by switching to gas. The complete picture of harmful effects of VOCs on human health and Shenandoah's ecosystems is still not known. The permit in its current form almost totally prohibits future knowledge of harmful effects of VOCs from being included into the permit's conditions.

As a concerned, voting Virginian who wants Shenandoah National park to be as free as possible from harmful effects of industry, I insist that the E.P.A.:

require greater public input and involvement in the permit review process;
put a term limit on the permit. A 10-15 year initial term limit would be much more appropriate; and
remove Merck's veto power over proposed permit changes.

I understand I have commented on this issue before the May 15, 1997 deadline. Thank you very much.

Sincerely,

Mark J. Roberts

Merck & Co., Inc.

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