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Merck & Co., Inc.

Letter from Betty Sellers to Carol Browner

December 20, 1996
Route 4, Box 245
Elkton, VA 22827

Ms. Carol Browner
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460

Mr. Richard D. Wilson
Deputy Assistant Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460

Dear Ms. Browner and Mr. Wilson:

Yesterday, I received a copy of the letter that Mr. David Carr, Staff Attorney with Southern Environmental Law, mailed to you. I felt it imperative that I relay my thoughts to you immediately concerning representation at the Merck XL five year reviews by public interest groups such as Mr. Carr's.

First, I need to communicate to you a basic problematic fact, that while the Merck XL Project invites community representation to the process, the project does not provide in any way any kind of technical assistance specific to community needs. May I also point out that such a situation creates a very risky and lax community representation for projects such as these. I personally have had to spend an inordinate amount of time in the library in an attempt to represent my community intelligently. The final Merck XL product would have been considerably weaker in its protection of the community and environment if we had not had the vital technical, balanced assistance Mr. Carr and his public interest representation contributed generously to the Merck XL Project. I must further point out that Merck's "permanent permit", as Mr. Carr refers to it, dictates a critical need for the local community to be alert at these five year reviews. Given the fact that Merck is a multi-billion dollar company that will soon have unprecedented flexibility, please allow our community the added protection of needed technical representation at these critical review periods. Mr. Carr's group has provided that service.

Throughout this project, Mr. Carr's committed involvement has contributed largely in allowing the project to accomplish its intended goals -- increased industrial flexibility without endangerment in the future to the environment and community.

In conclusion, I would greatly encourage EPA on behalf of my community to please provide for a public interest stakeholder in the Merck XL Project who will have a consensual voice at the five year reviews. Regarding my previous letter to you, I would again restate a plan on behalf of my community that EPA reinstate the ability of the three community representatives to have a true voice in any future permit changes.

Any consideration EPA gives to my requests will truly be appreciated. Again I highly support the extremely commendable environmental goals your project wishes to accomplish. I applaud Robin Moran and Cecil Rodrigues for all their efforts they have put into the project. If you should wish to speak to me on these matters, please feel free to speak to me at your convenience at 540-298-9992.


Betty S. Sellers - Community Representative Merck XL Project

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