1-bromoprane: Its Regulatory Evolution from Unregulated to a Hazardous Air Pollutant
Remember 10 to 12 years ago when solvent salesmen were touting a great “alternative” to Trichloroethylene or TCE. The alternative was 1-bromopropane (1-BP). It had several appealing selling points since it worked almost as well, it was unregulated and, thanks to the removal of “once in, always in”, the solvent swap could get sources out of the Halogenated Solvent Cleaning NESHAP (40 CFR 63, Subpart T). As a result, a large number of industrial users flocked to it. Yeah, it was more expensive, but what was the downside? There wasn’t one at the time (at least they thought).
It didn’t take long to figure out that 1-BP wasn’t some inert, benign chemical. In fact, the Department of Health and Human Services classified it as “reasonably anticipated to be a human carcinogen”. The US EPA then followed their standard protocol of first throwing it on a petition to add it to the hazardous air pollutant (HAP) list on February 6, 2015.
Later that year, 1-BP was added to the 313 Chemical list as it was to be tracked and potentially reported for sites that qualified for TRI 313 reporting beginning with RY 2016 by sources that clipped the usage of 10,000 pounds per year for Otherwise Used chemicals.
Fast forward almost 7 years later and finally, on December 22, 2021, the EPA signed the final rule adding 1-BP to the HAP list. The ruling was published in the January 5th Federal Register, and went effective February 4, 2022.
So, if your operation uses 1-BP in a vapor degreaser, aerosol solvent, or other form of degreaser, it would behoove you to react as quickly as you can. Depending on your operations, you may find you only require a minor modification to your air permit, or it could result in a change to your permitting level. Either way, jump on it or seek out a professional consultant with knowledge in this area (yes, I can help), whatever makes the most sense for you.
So, what’s going to happen down the line for 1-BP? It could find its way into a NESHAP. That would be kind of ironic since it became famous for getting sources out of a NESHAP. Go figure!!
Further Information
Cornerstone’s air experts follow the state permitting regulations that affect our clients very carefully. Contact us at info@corner-enviro.com to discuss your facility’s situation and how it may affect any new project plans.
Greg Towler is a Senior Air Quality Project Manager whose role is to oversee and perform air permitting and compliance-related projects and work directly with clients to achieve full compliance. He also performs compliance work in wastewater, stormwater, hazardous waste generation, EPCRA reporting and general environmental compliance.
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