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 firstname.lastname@example.org.
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.