by Cindy Madrick
On June 11, 2021, EPA issued an Advanced Notice of Proposed Rulemaking as a further step in the process toward implementing the
addition of 1-bromopropane (1-BP) to the Clean Act Act’s (CAA) list of hazardous air pollutants (HAP). EPA intends to add 1-BP to the HAP list by the end of 2021. EPA is soliciting data and information on 1-BP usage, emission controls, and associated costs that would inform the implementation of the upcoming listing action and ensure that the regulatory infrastructure is in place to control the emissions of 1-BP effectively and efficiently. After 1-BP is added to the list, EPA must promulgate standards to address emissions of 1-BP in the
Federal Register
What is 1-BP?
According to EPA, “1-BP, also known as n-propyl bromide (nPB), is a solvent used in electronics and metal cleaning, surface coatings, dry cleaning, adhesives, and as an intermediate chemical in the manufacture of pharmaceuticals and agricultural products,”
Next Steps
Whether you choose to monitor the rulemaking or be preemptive, all sources emitting 1-BP will need to reevaluate potential applicability and compliance requirements – this applies to those with current air permits AND those that have been under permitting thresholds in the past. National Emissions Standards for Hazardous Air Pollutants/NESHAP requirements may differ for a Major Source (potential to emit (PTE) at least
10 tons/year for a single HAP or 25 Tons/year for any combination of HAP*) compared to an Area Source (smaller source). Regardless of your current permit status (or if you are currently below thresholds), sources may need to apply for a permit or modify an existing permit to ensure compliance with all regulations.
Cornerstone is monitoring this rulemaking and will provide updates on associated milestone events as they transpire.
Questions? Reach out to Cornerstone at
info@corner-enviro.com
Important notes:
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- When EPA publishes a final rule, the rule’s effective date (in this case, a major rule) is no less than 60 days after the publication date in the Federal Register. [for CAA, EPA sometimes allows several months for a permittee to comply - TBD]
- If you subscribe to Cornerstone’s Cloud-based SDS & Chemical Inventory tool - Foundation system allows you to review chemicals and CAS #’s 24/7. Just go to the Advanced Search screen and input the CAS#.
- *Certain States or regions may have more stringent (lower thresholds) to qualify as a Major source of HAPs.