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Technical Comments on the EPA's Proposed Amendments for National Emissions Standards for Hazardous Air Pollutants for Phosphoric Acid Manufacturing and Phosphate Fertilizer Production (79 FR 66512)
20 January 2015
Scott J. Bloomberg and Dr. Anne E. Smith
Mr. Bloomberg and Dr. Smith provided technical comments on behalf of PCS Phosphate Company, Inc. on the EPA's proposed amendments to National Emission Standards for Hazardous Air Pollutants (NESHAP) for the phosphoric acid manufacturing and phosphate fertilizer production source categories. Included in the proposed amendments were a Beyond the Floor limit for mercury emissions. Using an economic analysis of proposed costs and benefits, Mr. Bloomberg and Dr. Smith demonstrated that the proposed Beyond the Floor limits for mercury dramatically fail the cost-benefit test, and thus can be expected to decrease societal well-being.