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May 13, 2022
Effective Feb. 4, 2022, the U.S. Environmental Protection Agency (EPA) added 1-bromopropane CAS #106-94-5 (1-BP), also known as n-propyl bromide, to the Clean Air Act’s list of regulated hazardous air pollutants. The chemical 1-BP is used in solvent degreasing, adhesives, furniture foam fabrication and in other applications including the aerospace industry. The EPA added 1-BP to the list of pollutants because emissions of this chemical may cause adverse effects to human health or the environment.
Facilities are now required to include emissions of 1-BP when determining their potential to emit for hazardous air pollutants. This may change a facility’s classification from an area source to a major source of pollutants. A major source of pollutants is a facility with a potential to emit of 10 tons per year or more of a single regulated hazardous air pollutant, or 25 tons per year or more of total regulated hazardous air pollutants.
Action Needed
Facilities that use 1-BP should calculate their potential to emit for 1-BP and for total regulated hazardous air pollutants. 1-BP should be included in a facility’s potential to emit. Facilities with permits containing synthetic minor limits on regulated hazardous air pollutant emissions should include any 1-BP emissions when demonstrating compliance with synthetic minor limits on regulated hazardous air pollutants.
Permit Implications
Any facility that is a major source of hazardous air pollutants due to the inclusion of 1-BP as a regulated pollutant should submit an air pollution control permit application to the Wisconsin Department of Natural Resources (DNR) Air Management Program no later than Feb. 4, 2023, for either a:
- Part 70 operation permit; or
- Federally enforceable synthetic minor permit to limit hazardous air pollutant potential to emit to less than the major source thresholds.
All facilities are required to identify 1-BP emissions in any air permit applications submitted to the department. The Air Management Program is updating the air permit application checklists and instructions on the DNR’s website to instruct facilities to submit calculations of 1-BP emissions with any air permit applications.
Applicable Requirements
Currently there are no applicable 40 CFR Part 63, National Emission Standards for Hazardous Air Pollutants for 1-BP. However, if a facility is a major source of hazardous air pollutants due to the inclusion of 1-BP as a regulated pollutant, the facility may now be subject to other standards for major sources of pollutants and must comply with all applicable standards for major sources. This includes broad source categories, such as standards for boilers or reciprocating internal combustion engines. Facilities required to submit permit applications because of the inclusion of 1-BP as a regulated pollutant must also identify any applicable requirements in their permit applications.
More information, including a fact sheet and FAQ document are available on the EPA’s website. Please direct questions to DNRAMAIRPERMIT@wisconsin.gov.
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