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Merck & Co., Inc.

Letter from Chris Bolgiano to Robin Moran

Route 1, Box 331
Fulks Run, VA 22830
540-896-4407; Fax 540-896-4407*51
Email: bolgiace@jmu.edu

May 6, 1997

Ms. Robin Moran
USEPA, Region III
Air, Radiation & Toxics
841 Chestnut St. (3AT23)
Philadelphia, PA 19107

Dear Ms. Moran:

As a resident of Rockingham County, VA, I am writing in regard to the Merck Project XL General Variance and Proposed PSD permit. I have a number of concerns:

  1. First and foremost, I oppose the increase of VOC emissions. Having recently completed literature research on the impact of air pollution on forests and wildlife, I have come to understand that ozone is currently regarded by many in the scientific community as an even more significant problem for forest ecosystems than acid rain. Research in Shenandoah and Great Smoky Mountains National Park has identified 95 species of plants susceptible to ozone, including some of the most valuable wildlife food and habitat plants. Acid rain continues as a major problem: the VA Dept. of Gam and Inland Fisheries has documented a 50% decrease in benthic invertebrate taxa since the 1970s in the St. Mary's River, just south of Shenandoah National Park. Virginia forests are already under tremendous stress from air borne pollutants of all kinds. Although I realize that part of Merck's proposal entails the reduction of SO2 and NO, I don't think it is good policy to balance that reduction with an addition in VOCs.
  2. There should be a 10 year term limit on the permit.
  3. There should be community representation in the process.
  4. The particulate emissions standard should be PM-2.5 rather than PM-10.

Thank you for the opportunity to comment.

Sincerely,

 

Chris Bolgiano


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