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1-BP Added to Hazardous Air Pollutants List

EPA has now added 1-BP to the Clean Air Act List of Hazardous Air Pollutants.  EPA Administrator Michael Regan signed the final rule on December 22, 2021 and this action was published in the Federal Register on January 5, 2022. The effective date of this final rule is February 4, 2022.
EMAP previously wrote about this topic which can be found here.
1-bromopropane (1-BP), also commonly known as nPB, is a chemical solvent often used in surface coating operations, dry cleaning, and in electronics and metal cleaning. 1-BP is also used an adhesive and is sometimes used in the manufacturing process in pharmaceutical and agricultural industries.

What does this rule mean for Pennsylvania small businesses?

If you are a Pennsylvania small business and use 1-BP as part of your operations, you will now need to take into account the use of 1-BP as a regulated Hazardous Air Pollutant (HAP). In Pennsylvania, an air quality permit is required if the actual emissions of a single HAP is greater than 1.0 ton per year or if emissions from multiple HAPs are greater than 2.5 tons per year. If you are an existing Pennsylvania small business that already uses 1-BP then you will now need to take into account the use of 1-BP in facility wide air quality permit limits, requirements, and reporting standards.

Are there any new special requirements that apply due to the 1-BP listing as a HAP?

Simply answered, no, there are no new requirements that will apply to a facility for simply using 1-BP in normal small business operations. The more complex narrative is that the use of 1-BP may affect a facility’s classification as an area source or air quality emissions into a major source, or Title V facility, due to the use of 1-BP and taking into account the facility’s Potential To Emit (PTE).  To help better explain this, EPA has put together a Question and Answers document on the Listing of 1-BP as a Clean Air Act Hazardous Air Pollutant.

Small Business Assistance with 1-BP

If any of this confuses you as a Pennsylvania small business owner or operator, EMAP’s highly skilled team of environmental assistance providers is available to talk one-on-one.  Simply call our toll-free environmental hotline at (877) ASK-EMAP or send us an email at questions@askemap.org.

Proposed Rulemaking for Dry Cleaning Facilities

EPA has proposed amendments to the National Perchloroethylene Air Emission Standards for Dry Cleaning Facilities. This proposal would add provisions which would require all dry-to-dry machines at new and existing facilities to have both refrigerated condensers and carbon adsorbers as secondary controls.
The request for comment period is currently open.  EPA seeks comments and information regarding the number of third generation and earlier model dry cleaning machines that potentially could still be in operation.  In addition, EPA seeks information on dry cleaning practices, processes, and control technologies that could reduce emissions from hazardous air pollutions, or HAPs, for fourth generation (or better) dry cleaning machines.
A copy of the rule summary, the new proposed rule, and fact sheets can be found here.
General speaking, most dry cleaning facilities and operations are small businesses.  Estimates from EPA report that there are approximately 10,000 to 15,000 perchloroethylene dry cleaning facilities in the United States.  Unfortunately, due to the COVID-19 pandemic it is estimated that 10-15% of perc dry cleaners have closed.

Environmental Reports due March 1st 2022

March 1st is an important deadline for some small businesses that may be subject to Air Quality Emissions Inventory or Hazardous Waste Biennial Reporting. The Annual Emission Statement (AES) report is required by the Pennsylvania DEP Bureau of Air Quality to report on point sources meeting certain thresholds for large emitters of air pollution.  Facilities inventoried for emission statement purposes may include Non-Title V facilities, or smaller “area sources” of air emissions. Regional DEP air quality staff will often determine and notify which facilities are required to report on their air emissions. More often than not, this requirement will be listed in a facility’s State-Only Operating Permit. There are some emission reporting exemptions for small stationary sources. If you are a small business and question whether or not you are subject to air quality emissions reporting, please contact one of our EMAP environmental consultants for further assistance.
The Hazardous Waste Biennial Report is due March 1, 2022 and is required of any Pennsylvania hazardous waste Large Quantity Generator (LQG) for the calendar year ending December 31, 2021.  A small business is considered a LQG of hazardous waste if your operation generates more than 2,200 lbs of hazardous waste or more than 2.2 lbs of acute hazardous waste per calendar month.
Small businesses with an obligation to report hazardous waste acitivities should use EPA’s RCRAInfo system for the electronic submission process.
Additional information on hazardous waste reporting requirements can be found on the Pennsylvania DEP’s website found here.
If you are a Pennsylvania small business that needs further assistance with air quality emissions reporting or the hazardous waste biennial report, contact EMAP by calling our toll-free environmental hotline at (877) ASK-EMAP or email us at questions@askemap.org.

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Jeremy Hancher is the EMAP Program Manager located at the Widener University SBDC.  He holds over 15 years of experience in environmental compliance, environmental policy, and program management.  He is proud to be the team lead of the award-winning EMAP program which provides free and confidential environmental assistance to the Pennsylvania small business community in fulfillment of the requirements of the Pennsylvania Air Pollution Control Act and Section 507 of the federal Clean Air Act.
In 2015, Jeremy was part of the team effort when EMAP was recognized by US EPA Administrator Gina McCarthy for Outstanding Accomplishments by a State Small Business Environmental Assistance Provider in Providing Technical Environmental Assistance to the Small Business Community. Jeremy holds a Bachelor’s degree from the University of Pittsburgh, a Master’s degree from the University of Pennsylvania, and a certificate from the Wharton School.
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