Merck & Co., Inc.
Letter from J. W. Wade to Jon Kessler
August 31, 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 & Co., Inc.'s Project XL proposal
Dear Mr. Kessler:
Shenandoah National Park (NP) is less than 5 kilometers from the Merck & Co., Inc. (Merck) Stonewall plant in Elkton, Virginia. Since Shenandoah NP's September 18, 1990, Federal Register notice of adverse air quality impacts, Merck has consistently applied for air permits which either minimized emissions increases or resulted in actual reductions in emissions from the Stonewall plant. We appreciate Merck's efforts to "be good neighbors."
Staff from Merck and Shenandoah met on August 25 to dixucss Merck's Project XL proposal which is being submitted to your office for review. We understand that Merck wants to have the flexibility to remove hazardous air pollutants and reduce sulfur dioxide, nitrogen oxide, and hydrogen chloride emissions, while allowing themselves some increase in volatile organic compounds (VOCs).
While we have some very serious concerns about interpollutant trading, overall "caps" on total emissions (instead of on per-pollutant basis), and effects of VOCs on the resources of Shenandoah NP, we feel this project merits further discussion. We understand that if Merck is selected for participation in the Project XL program on September 1, that there will be a 6-month period to negotiate details of the project. If we can't resolve our concerns by the end of that time, we would withdraw our support of the project. However, we hope we will be able to continue to support the project.
We are extremely interested in pursuing every means of reducing air pollution impacts to Shenandoah NP. However, we don't want our support of this project to indicate a blanket endorsement of all efforts without a case-by-case analysis and review. If you have further questions regarding this matter, please contact Julie Thomas or my staff at 540/999-3499 or John Bunyak at the NPS Air Resources Division at 303/969-2818.
cc: Charles F. Vencill, Ph.D.
Plant Manager Merck & Co.,
Inc. P.O. Box 7
Elkton, Virginia 22827