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Comments to EPA on NSPS review for Nitric Acid Plants

Policy Integrity submitted comments to the Environmental Protection Agency (EPA) urging updates to its New Source Performance Standards (NSPS) program standards for nitrogen oxide (NOx ) and nitric acid plants, which can emit dangerous air pollutants that can cause illness and alter the climate. Though a statute requires the EPA to review and revise related regulations every eight years, the rules governing these plants have not been updated in four decades.

The EPA is first urged to revise existing NOx performance standards based on appropriate cost-benefit analysis, taking into account the costs of implementing the newest and best technologies for NOx emissions as well as the benefits of continued reduction and regulation of NOx pollutants. This will help advance policy goals while maximizing net benefits.

EPA should also include nitrous oxide (N2O) as a regulated pollutant in the new NSPS. In addition to emitting NOX air pollutants, the process of producing nitric acid also releases significant quantities of N2O. In 2009, nitric acid production emitted the equivalent of the annual greenhouse gas emissions from 2.6 million cars. As a pollutant that can cause a significant threat to public health and welfare, N2O should be regulated from nitric acid plants by the EPA.