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Merck & Co., Inc.

Letter from Jay Kardan to Robin Moran

Virginia Chapter Sierra Club

"When we try to pick out anything by itself, we find it hitched to everything else in the universe." John Muir

May 13, 1997

Ms. Robin Moran,
U.S. Environmental Protection Agency Region III,
Air, Radiation & Toxics Division
841 Chestnut St. (3A323)
Philadelphia, PA 19107-4431

Re: Merck & Co. Inc. Stonewall Plant, Project XL Proposed Rule

Dear Ms. Moran:

As Conservation Chair of the Virginia Chapter of the Sierra Club, I write to offer the Chapter's comments on the proposed Project XL agreement for the Merck & Co. Stonewall plant at Elkton, Virginia.

We would like to second the comments already submitted by the Shenandoah Group of the Sierra Club, the local representative of the Virginia Chapter and of the national Sierra Club. At the same time, we state emphatically that the permitting of the Merck plant is by no means a purely local issue. Emissions from the plant affect areas beyond its immediate vicinity, and Shenandoah National Park, a near neighbor of Elkton, is the common property of all Americans. The experimental or "pilot" nature of Project XL also makes this permit a possible precedent for national environmental policy. We therefore request that citizen participation in the permitting process be expanded to include watchdog organizations with a larger-than-local base (such as the Southern Environmental Law Center or the American Lung Association) as permanent stakeholders. This would help to balance the disproportionate veto power granted to Merck & Co.

We are also dissatisfied with the unlimited term of the permit, and suggest that it be limited to five years.

Finally, we advise the EPA to examine closely the possible implications of Virginia's "Audit privilege" law, passed in 1996, for Project XL. This law could interfere with proper monitoring of compliance.

Sincerely yours,


Jay Kardan
Conservation Chair

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