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Final Rule Alert: EPA Adds 1-bromopropane to Clean Air Act HAP List

Posted on 1/11/2022 by Roger Marks and Anthony Cardno, CHMM

Update 01/10/2022

Last week, US EPA published a Final Rule to add 1-bromopropane (1-BP) to the list of Hazardous Air Pollutants (HAPs) listed in Section 112 of the Clean Air Act. The Rule takes effect on February 4, 2022.

1-bromopropane is the commonly used name for the chemical n-propyl bromide or nPB (CAS 106–94–5). 

For facilities that emit 1-BP, the decision may impact Clean Air Act compliance responsibilities under programs like NESHAPs and Title V permitting. 

Under the NESHAPs program, facilities in source categories listed in 40 CFR Part 63 are subject to emissions limits, pollution control requirements, and reporting & recordkeeping standards if they have the potential to emit (PTE): 
  • 10 tons per year of a single HAP; or 
  • 25 tons per year of any combination of HAPS.
With 1-BP added to the HAP list, facilities that were previously below these thresholds may now be subject to the program. The same triggers apply to HAPS under the Title V permitting program as well. 

Because EPA previously published the rationale for adding 1-BP to the HAP list in a June 2021 notice, the agency published the Final Rule without additional opportunity for public comment. 

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Original Article (Posted 07/14/21)

EPA made some history recently. For the first time since the Clean Air Act amendments of 1990, the Agency granted a petition to add a substance to its list of hazardous air pollutants (HAPs).

In the Federal Register on June 18, 2020, EPA notified the public that n-propyl bromide (nPB) [CAS 106—94—5], commonly referred to as 1-bromopropane, will be added to the Clean Air Act HAP list.

Implications for Clean Air Act Compliance

Sources covered under the National Emission Standards for Hazardous Air Pollutants (NESHAP) at 40 CFR 63 should determine if they emit 1-bromopropane and take the steps to ensure compliance. NESHAP require facilities to apply specific technologies and controls to specific equipment to prevent the volume of Hazardous Air Pollutants (HAPs) emitted from that equipment from exceeding EPA’s thresholds. 

In the Federal Register notice, EPA indicated several sectors that may be affected by the addition of 1-bromopropane to the HAPs list. The agency also reserves the right to revise existing or write new NESHAPs as they further assess the possible adverse effects of nPB on human health and the environment.

Because the NESHAPs also trigger the need for a Clean Air Act Title V permit, sources that emit the new HAP should check their permit and determine if any updates are needed. Facilities operating under a Title V permit must operate in compliance with the provisions of that permit and certify compliance periodically.

Automatically Added as a CERCLA Hazardous Substance

Once 1-bromopropane is added to the HAP list in Section 112 of the Clean Air Act, it automatically becomes a CERCLA hazardous substance. The list of regulated substances under CERCLA incorporates lists of pollutants from other environmental programs, including the Clean Air Act, Clean Water Act, TSCA, and RCRA—including the Clean Air Act HAP list.

1-bromopropane will be added to the CERCLA list with a reportable quantity (RQ) of 1 pound. If EPA decides to change that RQ, a new rulemaking will be necessary.

What is 1-bromopropane?

1-bromopropane is a colorless, water-soluble halocarbon used as a solvent in liquid and gas form. It is used in adhesives, dry cleaning, vapor degreasing, aviation maintenance, electronics and metal cleaning, and more.

The chemical has a sweet odor. Workers can be exposed by inhaling vapors and through direct skin contact. 1-bromopropane attacks the central nervous system and can lead to decreased feeling in extremities, headaches, and a drunk-like feeling at low concentrations. Exposure to high levels of 1-bromopropane can cause inability to walk and nerve damage. It irritates the skin, eyes, and mucous membranes.

Use of the chemical has increased following its inclusion in EPA’s Significant New Alternatives Policy (SNAP) as a substitute for certain ozone-depleting substances.  

A draft risk evaluation completed in August 2019 found that 1-bromopropane presents an unreasonable risk to workers, occupational non-users, and consumers under certain conditions of use.

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Tags: air pollution, Clean Air Act, environmental compliance, hazardous air pollutants, SNAP

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