The US EPA (Environmental Protection Agency) finalized a rule to add 1-bromopropane to the federal list of hazardous air pollutants (HAPs) on December 22, 2021. This action is the first time the EPA has added a new chemical to the federal list of HAPs since the original list was created by the Clean Air Act Amendments of 1990.
The chemical 1-bromopropane (1-BP), also known as n-propyl bromide, or nPB, is an organic solvent that is used in electronics and metal cleaning products, surface coatings, dry cleaning, adhesives and in intermediate chemicals used in the manufacture of pharmaceuticals and agricultural products.
What Happened?
The EPA promulgated this amendment adding 1-BP to the federal HAPs list on January 5, 2022 (87 FR 393). The effective date for the additional HAP is February 4, 2022. As a listed HAP, 1-BP will be subject to National Emission Standards for HAPs, also known as MACT (Maximum Achievable Control Technology) standards. The Clean Air Act provides no required deadline or action period to set MACT standards for the control of a new HAP. However, as part of the final rule, the EPA stated that “a separate regulation is needed to ensure the effective and efficient implementation of requirements triggered by the addition of a new HAP” (87 FR 395). The EPA also plans to publish additional guidance on the listing of 1-BP as a new HAP.
Who May Be Affected?
Manufacturers of pharmaceuticals, pesticides, quaternary ammonium compounds, flavors, and fragrance may use 1-BP as a chemical intermediate.
1-BP may be present in various products such as:
| Adhesive Solvents | Cleaning Solvents |
| Aerosol Solvents | Vapor and immersion degreasing solvents |
Manufacturing sectors that use 1-BP as a solvent may include:
| Asphalt | Electronics | Optics |
| Aircraft | Foam and laminated | Plastics |
| Dry cleaning | Metal and metal products | Synthetic fibers |
Has the EPA regulated 1-BP before?
The EPA has listed 1-BP in the Substance Registry Services, a resource for chemical information. In 2015, the EPA added 1-BP to the Toxic Release Inventory (TRI) list of reportable chemicals. The EPA is currently reconsidering the final risk evaluation of 1-BP pursuant to Section 6(a) of the Toxic Substances Control Act (TSCA).
What Should I Do?
TRC recommends that environmental, health & safety (EHS) compliance and risk managers at potentially affected facilities:
- Monitor federal and state rulemaking for new standards controlling 1-BP emissions.
- Evaluate whether the designation of 1-BP as a HAP will alter your facility status as a major or minor source of HAPs or whether other changes to your air quality emissions permit may be needed.
- Fully review the applicability of the EPA’s “new source MACT” rules prior to construction or reconstruction of a facility with the potential to emit significant quantities of 1-BP, i.e., more than 10 tons per year or 25 tons per year when combined with other HAP emissions. These rules, based on Clean Air Act (CAA) Section 112(g), require the application of “case-by-case MACT” standards in certain circumstances.
- Ensure that the facility is accounting for 1-BP in its annual applicability review, or “threshold analysis,” for TRI reporting.
If you need assistance complying with air quality compliance requirements, TRC is your solution. Contact us here.
David A. Whitford
David A. Whitford is a Project Manager and Senior Consultant with over 25 years of experience in environmental compliance management. His mission is to efficiently obtain regulatory approval of client projects and keep client facilities in compliance. Dave’s knowledge of rules and rulemaking procedures, training and experience provide a seasoned perspective for identifying and resolving environmental compliance issues. Contact Dave at DWhitford@trccompanies.com.