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Merck & Co., Inc.

Letter from Betty Sellers to Carol Browner and Richard Wilson

December 27, 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 A. Wilson
Deputy Assistant Administrator
U.S. Environmental Protection Agency
401 M Street S.W.
Washington, D.C. 20460

Dear Ms. Browner and Mr. Wilson:

I would again like to voice my continued support of the Merck XL Project. My letter of December 20, 1996, stated support of a project that has, in the main, accomplished the highly desirable goals of increased industrial flexibility and environmental benefit to the community and Park. Even though I have not received technical support from EPA, specific to community health, I have continued to delve deeper into the following troublesome issues of the draft permit that represent serious concerns for the community:

1. Section 8 - Termination of the PSD permit - My personal research yields the fact that "consent orders" and "judgments" could conceivably be allowed to cumulate into fairly large numbers of future violations. Such a situation would allow Merck to start all over again with a clean slate every five years. I do not remember having had any opportunity to provide input on this very important decision. While no one would want this project to terminate in such an unfortunate way, certainly "four consent orders or two judgments" should be sufficient reason or proof that the project isn't working according to design. To do less would be putting the lives of many people who live in very close proximity to the plant at risk. More importantly, if Merck realized that "four consent orders or two judgments" mean termination, Merck then has a built-in incentive to be more efficient and vigilant with air emissions.

2. Affirmative renewal - Robin Moran has attested to the fact that the Merck XL Project is a pilot project that EPA will be constantly looking at and evaluating to see if in reality the project truly does what it was purported to do. I believe it to be the sincere wish of all of the stakeholders that this will be the case. However, I would urge EPA to consider stakeholder affirmative renewal . Such an action would greatly provide additional evaluation benefit. Why not allow the stakeholders who are the people directly involved in the project to enter fully into a true evaluation process of a pilot project?

3. Section 4.10.2. - Operation of control equipment - The community strongly encourages EPA to please reconsider present permit language of "75 per cent" operation of control equipment. EPA's basic goal for the XL Project aims directly at improved environmental performance and not business as usual. After all the time and money EPA has put into this project, surely we should insist on the superior benefit of "90 per cent" operation of control equipment.

4. Title V permit - Since this permit will replace all other permits, continued public participation needs to be insured through a public notice requirement - five years represents a very significant time.

5. PM-10 site-specific rulemaking - Speaking from the community's standpoint of having the coal powerhouse in operation since 1941, it was truly hoped that there would be some environmental benefit in the XL Project with regard to PM-10. Due to the refinement of various formula computations, PM-10 tonage actuals moved from an estimated 16 TPY at the beginning of the project to 42 TPY as actuals at the end of the project. Since the community is looking for some kind of health benefit from this project, again, not business as usual, the language in the site-specific rulemaking for PM-10, "remaining very close to the cap" concerns me - almost a foreboding that PM-10 will increase above recent actuals. PM-10 should be referred to as being kept at least the same as the cap, or better yet, slightly below the cap.

6. 8.1.1. - "...imminent and substantial endangerment to public health or welfare, or the environment..." - I strongly request a change from the present wording in the permit to "...if the EPA or VADEQ determine that continuation of the PSD permit may be an imminent and substantial endangerment to public health...". My reasoning for this change lies in the great difficulty for EPA or VADEQ to make such an "is" determination, hence the possible likelihood of never making such a crucial determination, or a needed one at the right time.

7. EPA funded community VOC research - Since Merck agrees that the big increases in their emissions will be VOC's, I want to go on record, December 27, 1996, for my community, as stating that the deleterious effects of large, or even small amounts of VOC's over long periods of time on the health of people living very close to the Merck Plant have never been studied or documented by EPA. EPA certainly needs to initiate such health studies in its review of this innovative, unprecedented project.

8. SIP relief - As a community representative, new to much of this information, I do not always understand all the future ramifications that various changes and additions to the permit will mean to the community. As I understand it, Merck will be receiving some relief from State Implementation Plans (SIP) with regard to adverse impact on the Park's AQRV's, should Merck be found to be a contributor but not a cause of such. Does this also mean that Merck would be exempt from anything a SIP would require from other contributors? My serious concern here relates back to the fact that the Park is located very close to the community. Actually, the community regards the Park as community. If Merck is not going to comply with a new SIP rule, then Merck should conceivable compute the expected emission reduction amount that would occur if SIP were complied with.

On behalf of my community, I would urge EPA to give serious consideration to the above suggestions during the short amount of time that we have left for the Merck XL Project. Again, many thanks to EPA for its highly commendable efforts.


Betty S. Sellers
Community Representative - working group

cc: Stakeholders

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