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Merck & Co., Inc.
Letter from Tedd Jett to Jon Kessler
August 25, 1995
Mr. Jon Kessler
Office of Policy, Planning and Evaluation
United States Environmental Protection Agency
West Tower 1013, Mail Code 2111
401 M Street, SW
Washington, DC 20460
RE: Merck Project XL Application
Dear Mr. Kessler:
To supplement the information included in our August 4, 1995 Project
XL application, Merck & Co., Inc. wishes to take this opportunity to
clarify and expand on the initial submittal.
Avoiding increased risk
Merck recognizes that any plantwide emission cap negotiated in Project
XL would require limits that provide reasonable assurance that increased
risk to the environment or individuals does not result from the project.
The project, as Merck currently envisions it, will likely involve interpollutant
trading. A portion of the emission reductions achieved by the project
would be reserved as credits for possible emission increases to accommodate
the future growth of the Stonewall Plant. The reductions would be largely
composed of SO2, NOx, HCl, and to a lesser extent VOCs while most future
increases would likely be composed of VOCs. Since the relative risks
of the various criteria pollutants are not well established, Merck recognizes
that a trading plan that assures reduced risk will be difficult to define.
Trading on a basis other than "pound for pound" would probably make
sense for certain pollutants and is expected to be a subject of negotiation
if Merck is selected to pursue a final project agreement.
Environmental benefits
The Merck project will provide environmental improvement both in terms
of reduced human health risk as well as protection of the adjacent Class
1 area. For example, if a powerhouse emission reduction project is chosen,
the environment will benefit by a reduction of hazardous air pollutants
(hydrochloric acid and hydrogen fluoride), substantial decreases in
SO2, and considerable NOx reductions. Since ground level ozone formation
in rural areas is generally NOx limited, nearby NOx reductions might
result in decreased ozone formation in the Class 1 area and elsewhere.
Apart from emission reductions derived from pollution reduction projects,
a plantwide emission cap could provide a regulatory mechanism to provide
incentives for pollution prevention which will minimize actual emissions
for the plant over the long term. We believe this approach is needed
in an increasingly competitive worldwide market.
Baseline
The baseline emissions for the project would be recent actual emissions
during periods of representative production activities, and would be
subject to negotiation. We would not mean to imply that 1987 TRI emissions
would comprise a reasonable baseline. We would expect that the baseline
would be subject to adjustment in the future to reflect new requirements,
including the pharmaceutical MACT.
Accountability
Merck understands the need for accountability in a project of this type,
and would commit to establish monitoring and reporting protocols sufficient
to provide high assurance that emission reductions are real and permanent
and that any established cap is not exceeded.
Stakeholder support
The Merck project has received strong interest from the VADEQ and the
National Park Service. Due to the benefits derived from emission reductions
associated with the project and the anticipated enhanced economic viability
of the Plant due to the increased operational flexibility afforded by
a plantwide cap, we expect strong local support. A meeting with our
local community advisory panel will be held in the near future to discuss
our possible participation in Project XL.
I hope this letter will help to clarify our proposal. If I can provide
any further clarification or additional information, please don't hesitate
to contact me.
Sincerely,
Tedd H. Jett, P.E.
Stonewall Plant Environmental Manager
cc: Steve Harper (by FAX)