ANDREW M

. CUOMO GOVERNOR



### Honorable 

### Lisa P. Jacl<:son SrATE

.oF NEw**YoR~ DEP~RTM.ENT** **OF** EtMRQNMERTAL CoNSERVATION ALBANY,**Nt Y-9RK**  1.2.233-1:010 

## OCT 24 

# 2011

Administrator
. . 

### United 'States Environmentat ·Protection Agency 1200 Pennsylvania A

### venue. , NW 

### Washington, DC 20460 Dear Administrator Jackson: · i

.. JOl;**t~'Rt£N S** **Co r~MlSSIONE~** 



### The Department ofEnvironmental Conservation 

### :is petitioning EPA 

### to add 

### n.:.propyl bromide 

### (nPB) to the iist ofhazardous 

### air po11utants (HAPs) regulated under Sectiqn 

### 112 of**th~** 

### Clean Air Act{CAA). In**particular ~**  

### DEC believes the evidence pro¥ided in 

### the enclosed p. etition is 

## niore than
.sufficient to·indicate that the 

### potential emissions and associated ·ambient 

### con· ccntrations of 

### n-PB meets the
.CAA Sections 112(b).(3)(A) and (B) 

### criterion: "The Administrator shall 

### a:d'd a substance to tl1e HAP list upon showing b)i'the petitioneror on the Administrator's
.own detennination that the 

### substance is an air 

### pO.llutani and 

### that emissions, ambient·concentrations, bioaccumulation, or deposition ofthe·substance are l..'11own to cause·or may-reasonably be anticipated to cause adverse effects ·to human 

### health or adverse ert!\r.i
. ronmental effects
. " 

### In accord·witb EPA's statutory
.criterion, weseeksuch 

### an action. 

### Ourpetition summ.anzes the tox;icological concerns associated 

### with n-PB
.exposures, as well as the current 

### and potential 

### future·n-PB usage- and the
.exposure:concerns. 

### The high 

### toxicity of 

### n-PB inc1ud· es adverse 

### ilhpacts 

### on numerous**cti~er.ent** 

### health
. 

### anp ·enviro.mrtental · end points. We 

### believe · our petition sufficiently demoruitrates th:etoxicity· hazards and potential for elevated exposure that
.are likely 

### to result in adversepublic'health 

### effectS if

### this air pollutant

### is not



### . regulated under SeCtion 112 ofthe CAA.

Our 

### concern is · heightened 

### due·to recent attempts 

### to market solvents with n-PB content 

### as an unregulated**~ternative dry-cle~ng-** **so lve** **nt.** 

### for perchloroethylene (perc), since the latter'is 

### tb be 

### ph3$ed· out 

### ofuse by 

### EPA requirements 

### ovc;:r the next 

### decade, 

### In addition, n-PB
.is being marketed as "organic,'' 

### "green,"**"non-:hazardo1is'~** 

### and 

### "envirbnmentally fri'endlY' inl'art due · t o the lack 

### oftoXicity designations
. that \vould
. jndicate that 

### n-PB ·is
. n<;>t the 

### :'benign'· '·chemical 

### it is clahned to:.be bythe· manuracnirer o'fthe · solvent. Furthermore, the use ofn-PB · by various**"" ·-** **-~**

### . 2
.
industrial 

### sectors is

### increasing**~d** 

## it is·**b:e.ing use.d** **t.o :r~place** **qzone ¢iepleting**  

### . chemiC;aJs ' <:>r'Other 

### chlorinated chemicals
.

### that

. are·**currently:-t:egul~ted** .a§ 

### HAP· s. Fodhese:reasons, .Ii>EC believes that 

### the · U.Se of1r-PB

### will**~ely in~rea$e** **S:u~tantia11y,** especially by 

### the dry-cleaning 

### industl'y'
. ·· Please 

### call me at (518) 402-8540 

## if**~ou** 

### have any 

### questidns. Sincerely,

Enclosure

'·

### Petition to Add n-Propyl Bromide to the Environmental Protection Agency's List ofHazardous Air Pollutants Regulated under§ 112 ofthe Clean Air Act

Background The Environmental Protection Agency (EPA) published an initial list ofhazardous air pollutants (HAPs) in the Clean Air Act (CAA) Amendments of 1990 which are regulated under Section 112 ofthe CAA. Section 112 authorizes the petitioning ofthe Administrator to add a substance to the HAP list, to which an EPA decision and response with explanation are required within 18 months. To be added to the list, sufficient data demonstrating that the substance is indicated or anticipated to cause adverse human health and/or environmental effects is required. The New York State Department ofEnvironmental Conservation (NYSDEC or "Petitioner") concurs with the Halogenated Solvents Industry Alliance, Inc
., who previously submitted a petition to the EPA to list n-propyl bromide (n-PB)- chemical abstract service registry number (CAS#) 106-94

-5, as a HAP. We are also requesting that n-PB be added to EPA' s list ofHAPs. The information provided herein summarizes what we consider to be " sufficient data" regarding the adverse effects that result from n-PB exposures and the potential that exists for such exposures to occur. Therefore, please accept and consider this petition to add n-PB to the CAA 

### § 112 HAP list. NYS has many dry-cleaning facilities , including a large number co-located with residences or other commercial facilities , which may involve exposure to sensitive subpopulations. The use ofn-PB is already increasing by 10 to 15% per year overall and is poised to potentially increase substantially more, especially at dry-cleaners due to several factors. Because ofthe lack of certain toxicity designations (including being listed as a HAP) and the current lack ofstate and federal regulations similar to those for perchloroethylene (" perc"), it is being marketed as a nonregulated and "environmentally friendly" and "non hazardous" replacement for perc. The n-PB alternative dry-cleaning solvent suppliers are also marketing this chemical as the only known drop-in replacement for perc which can be used in the dry-cleaners' existing machines making it the least expensive option. However, the higher volatility ofn-PB as compared to perc, its incompatibility with a variety ofthe dry-cleaning machine components, and its reactivity with any water that might be present during the dry-cleaning process (resulting in the generation ofa highly corrosive and toxic acid) result in a high potential for leaks. Several different studies measuring concentrations ofn-PB within dry-cleaning facilities using this solvent found that the concentrations exceeded the variety ofdifferent n-PB exposure levels, indicating that the use ofthis solvent will result in concentrations that are expected to cause adverse human health effects
. Additionally, there have already been documented cases ofpoisonings resulting from n-PB exposures with several different end uses including dry-cleaning.

1The adverse health effects demonstrated to occur with exposures to n-PB are indicated to affect a wide variety ofend points and include high reproductive toxicity and high neurotoxicity. More recently, n-PB has also been demonstrated to be carcinogenic
. These exposure and toxicity studies and findings are summarized in the next two sections.


### n-PB Usage and Exposures Data on the usage and potential emissions ofn-PB is difficult to ascertain since it is not listed as a reportable chemical under EPA's Toxic Release Inventory (TRI). However, there are reports about increased n-PB usage by various source categories as a replacement for chlorinated solvents. Overall, it has been reported that the usage ofn-PB is already increasing 10 to 15% per year (National Clothesline 2010). n-PB started increasing in production and use as a substitute for 2-bromopropane (2-BP) primarily in degreasing applications, but also as a solvent in adhesives and coatings and in aerosols, after concerns ofhigh toxicity for 2-BP were indicated. However, current studies indicate that the "substitute", n-PB, is actually more toxic than 2-BP, especially with respect to neurotoxicity (Ichihara 2005a, Ichihara 2005b, Yu et al. 2001). More recently, n-PB has been marketed as a potential replacement for perc as a dry-cleaning solvent, but again it has been suggested to be more toxic than the original solvent both in terms of carcinogenic and non-carcinogenic end points (Finkel2010a, Finkel2010b). The EPA has already disapproved n-PB for the adhesives and aerosols end uses after being reviewed under the Significant New Alternatives Policy (SNAP)
. The reason for the disapproval in these two end uses was because the n-PB concentrations anticipated in the workplace are elevated enough to lead the EPA to conclude that "n-PB in these end uses poses unacceptable risks to human health when compared to other substitutes that are available". For the coatings end use, n-PB was determined to be " acceptable, subject to use conditions" as long as it could be demonstrated that the n-PB airborne concentrations in the workplace will not exceed the EPA proposed workplace limits (17- 25 ppm (85.5-125.8 mg /m3) 8-hour Time-Weighted Average (TWA)). There have already been reports ofpoisonings in occupational settings resulting from n-PB exposures . For example, occupational exposures to higher concentrations ofn-PB have been reported to result in serious and possibly permanent neurological health effects (Centers for Disease Control and Prevention (CDC) 2008, Majersik et al. 2007)
. Chronic n-PB exposure ofan electronics factory worker, where this solvent was used to degrease circuit boards, resulted in this worker being severely poisoned with some ofthe nervous system effects (such as continued difficulty in walking) persisting, indicating that they are potentially permanent effects (CDC 2008 and personal communications with Dr. James Blando)
. Another case involved foam cushion gluers exposed to n-PB in spray adhesives which resulted in some indicators ofnervous system toxicity (profoundly impaired gait and continued deficits in test ofmotor and sensory function) persisting for at least two years after the exposure ended (Majersik et al. 2007). Recently, n-PB has also been introduced as an alternative dry-cleaning solvent to perc. While there is only limited use in this capacity currently, several factors could make the transition from perc to n-PB an attractive option for dry-cleaners. These include: the supplier' s marketing ofn-PB as "environmentally friendly" , " green", "organic", and " non-hazardous" and as a simple drop-in or drain-and-drop replacement for perc in the dry-cleaner's existing perc 2machine, making it the least expensive option (Enviro Tech 2010a), the upcoming Federal and California bans on perc usage by dry-cleaners in co-located residential settings, and the fact that the use ofthe n-PB solvent by dry-cleaners is essentially unregulated under Section 112. There are two known non-industry supported studies investigating the n-PB concentrations expected to occur at dry-cleaning facilities. These studies were conducted by the New Jersey Department ofHealth (NJDOH) and the National Institute for Occupational Safety and Health (NIOSH). These two investigations measured average personal exposure n-PB concentrations at several small NJ dry-cleaning shops for both the operators and the clerks/cashiers that were well 3 above the California proposed Permissible Exposure Limit (PEL) of5 ppm (25 mg /m) and the 8-hr TWA American Conference ofGovernment Industrial Hygienists (ACGIH) Threshold Limit Value (TL V) of 10 ppm (Eisenberg and Ramse y 2010, Blando et al. 2010). The basis of the ACGIH TL V was to protect against not only adverse neurological, reproductive, and developmental effects but also to protect against adverse health effects ofthe liver (hepatotoxicity). California' s proposed PEL for n-PB of 5 ppm was derived from a reproductive and developmental review performed by the National Toxicology Program's (NTP's) Center for the Evaluation ofRisks to Human Reproduction (CERHR). The NTP reviewed the CERHR Expert Panel's assessment ofthe NIOSH's 8-hr TWA personal brea thing zone concentration measurements for n-BP at 3 spray adhesives facilities and at 1 cold bath degreaser facility. The NTP agreed with the CERHR Expert Panel conclusions that ''t here is serious concern for reproductive and developmental effects at the upper end ofthe human occupational exposure range (18-381 ppm)" (NTP 2003). The average personal exposure n-PB concentrations measured for the operators during both the NJ DOH and the NIOSH study were within the NTP-CERHR serious concern exposure range. The average personal exposure n-PB concentration measured for the clerks/cashiers was also within the NTP-CERHR serious concern exposure range for the NJ DOH study (Blando et al. 2010) and wasjust below this level for the NIOSH study (Eisenberg and Ramsey 2010). Additionally, both the ACGIH and California occupational exposure limits and the NTP-CERHR serious concern exposure level were derived prior to the release ofthe NTP rodent bioassay indicating that n-PB is carcinogenic, which is likely to lower these exposure limits, perhaps substantially. The average personal exposure 8-hour TWA n-PB concentrations measured were as high as 54 ppm for the operators and 22 ppm for the clerks in the NJ DOH study (Blando et al. 2010) and was 40 ppm for the operator and 17 ppm for the cashier in the NIOSH study (Eisenberg and Ramsey 2010). The NJ DOH investigation also measured average airborne n-PB concentrations which were found to be as high as 35 ppm in the area near the dry-cleaning machine to which the operator would be exposed and 18 ppm in the area near the front counter to which the clerk would be exposed (Blando et al. 201 0)
. These average airborne n-PB concentrations exceeded both the ACGIH and California occupational exposure limits and were within the NTP-CERHR serious concern exposure range. We are aware ofone n-PB poisoning incident involving a dry-cleaner owner /operator in NJ, where n-PB is currently allowed to be used as an alternative solvent for perc. This drycleaner poisoning case involved a transition from perc to n-PB without the correct adjustments/modifications being made to the dry-cleaning machine settings and using improper work practices. Because n-PB is much more volatile than perc, dry-cleaning machine 3adjustments are necessary including the need to reduce the temperature and pressure settings. Additionally, because ofboth the increased volatility ofn-PB and the incompatibility ofthis solvent with certain components ofthe dry-cleaning machines, modifications are also necessary including the need to replace the gaskets, seals, and still door ifthey are not the right material and the machines need to be checked regularly for leaks. The operator at this facility did not make the proper adjustments and modifications to the perc machine for the switch to n-PB because he did not realize that this was necessary due to the "drain-and-drop" marketing ofthis solvent by the dry-cleaning supplier (Blando et al. 20 10). The operator started feeling ill and showing exposure symptoms, including nausea, dizziness/vertigo, headaches, and tremors, after only several weeks ofusing the n-PB solvent. The operator stated that he interpreted the term "environmentally friendly" used in the manufacturer's marketing campaign to mean that it was non-toxic (Blando et al. 2010, CDC 2008, and personal communications with Dr. Blando). We are concerned that other dry-cleaning operators will interpret the information presented by the distributor's marketing using buzz words such as "green", "organic", and "non-hazardous" (Enviro Tech 201 Oa) to mean non-toxic when this is certainly not the case. Another undesirable issue with n-PB occurs when this solvent mixes with water and chemically reacts to form the very toxic and corrosive acid gas, hydrogen bromide. The hydrogen bromide corrodes the degreasing or dry-cleaning equipment causing it to rust and components to fail , consequently ruining the machine (Wolf2009). This happened at a California dry-cleaning facility after the supplier indicated that n-PB could be used as a " drainand-drop" replacement solvent for perc, making it the only alternative for perc that did not require the purchase ofa new machine
. After this incident, it was reported that due to the abundance ofwater in the dry-cleaning process, this solvent "going acid" was very likely to happen eventually when n-PB replaces perc in a perc machine. In this particular case, the acid destroyed the facility's perc dry

-cleaning machine, laundry dryer, and pressing equipment, resulted in owner /operator exposure and potential impaired health, and caused this individual to question the use ofn-PB as an alternative dry-cleaning solvent by any dry-cleaner. 

### Ithas been reported that similar situations have occurred at other dry-cleaners across the United States (Wolf2009)
.
n-PB Toxicity Although the available toxicological information on the health effects ofn-PB exposures in humans is still somewhat limited, this database is growing and the occupational studies and case reports raise serious concerns about the adverse health effects ofexposures to n-PB, especially on the human nervous system (CDC 2008, Harney et al. 2002, Ichihara et al. 2002, Ichihara et al. 2004, Li et al. 2010a, Li et al. 2010b, 

### Li et al. 2010c, Majersik et al. 2007, Sclar 1999). Some of these studies indicate adverse neurological health effects at n-PB concentrations as low as 1-3 ppm or 5-15 mg/m3 (Ichihara et al. 2004, 

### Li et al. 2010a, 

### Li et al. 2010c). In occupational settings, people exposed to n-PB frequently reported headaches and malaise. Neurological effects reported in workers spraying adhesives containing n-PB include neuropath y, weakness and numbness ofthe lower extremities, headaches, trouble sleeping, dizziness, neurobehavioral differences, and blurred vision
. Other neurological effects observed in n-PB exposed workers include staggering, numbness with paresthesia/dysesthesia, and a decrease in vibration sensations 4ofthe legs. Some studies ofworkers exposed to n-PB suggest that humans ma y experience nervous system toxicity at lower n-PB exposure levels than those reported to cause nervous system toxicity in laboratory animals (Ichihara et al. 2004, Li et al. 2010a, Li et al. 2010c). Some ofthese nervous system effects, including pain and difficulty walking, are very long lasting and possibly permanent indicating permanent nerve damage (CDC 2008, Majersik et al. 2007). There are also reproductive concerns with n-PB that have been documented in humans. As discussed previously, the NTP-CERHR released a report in 2003 discussing the potential for adverse developmental and reproductive health effects in humans from exposure to n-PB (NTP 2003). After their comprehensive review ofnumerous animal studies and the limited available human exposure data demonstrating adverse developmental and reproductive health effects, the NTP agreed with the conclusions ofthe CERHR and wrote, " The NTP concurs with the CERHR Bromopropanes Expert Panel that there is serious concern for reproductive and developmental effects at the upper end ofthe human occupational exposure range (18-381 ppm) ." NTP-CERHR also wrote that "Additional support for the expert panel's conclusion is found in more recent rodent and limited but consistent human studies showing that exposure to 1-bromopropane <nPB> can lead to adverse developmental and /or reproductive effects. " Furthermore, since the release ofthis report, more information on the adverse developmental and reproductive effects in humans exposed to n-PB has become available
. For example, a male patient who had visited a fertilization specialist prior to being poisoned by n-PB initially had a below average sperm count at 42 million/ml but normal sperm motility at 65%. However, after the poisoning the patient was retested and his sperm count and percent motility had both decreased substantially to 3 million/ml and 15%, respectively, and these numbers have not recovered (Blando 2010). Most ofthe toxicological information about n-PB is derived from animal studies and this database is not only relatively large but, like the human studies database, is also constantly growing. In animals, n-PB is reported to cause adverse effects on the liver, kidne y, and the nervous and respiratory systems in addition to causing a variety ofdevelopmental and reproductive health effects in animals exposed by inhalation. The developmental/reproduction studies (through the release date ofthe NTP-CERHR toxicological study discussed above) are well summarized in the above referenced monograph (NTP 2003). The full database ofanimal toxicity studies will not be summarized herein, nor will the full range ofdata indicating observed adverse health effects besides the neurological and reproductive /developmental effects be highlighted. However, the animal data confirms the adverse health effects described above in humans exposed to n-PB
. The developmental effects include skeletal variations and a dose-dependent reduction in fetal body weight consistent with developmental delays. Reproductive toxicities in female rats resulting from n-PB exposures include decreased litter size and implantation sites, ovarian dysfunction, increase in the number ofirregular estrous cycles with extended diestrous, and increased ovarian follicular cysts, while in males, n-PB exposures caused decreases 

### in seminal vesicle weight, prostate weight, sperm motility and percent normal sperm (NTP 2003). The animal n-PB exposure studies also indicate adverse neurological effects supporting the human n-PB neurotoxicity data. Exposure to n-PB resulted in rats experiencing weakened muscle strength in their limbs along with decreased speed ofnerve signal transmission (Ichihara et al. 2000)
. This weakening oflimb strength (Honma et al. 2003, Banu et al. 2007) along with
5

### an ataxic gait (Ohnishi et al. 1999) has been observed in both humans and in animals by a number ofstudies performed b y different groups ofscientists. Similar to the human studies, some ofthese effects appeared to be permanent or at least long-lasting (Banu et al. 2007). In 

### February 2006, the California Environmental Protection Agency (CalEPA) Air Resources Board (CARB) released a document called "California Dry Cleaning Industry Technical AssessmentReport", 

### which includes a summary ofthe various toxicological issues with n-PB. After identifying their various concerns with n-PB use by dry

-cleaners, CARB closes this section ofthe document by stating that, "Based on current toxicity data, OEHHA staffis concerned about its <n-PB> use as a dry cleaning solvent." (Pong etal. 

### 2006). While CARB has not restricted n-PB use, they produced an alternative dry-cleaning solvent fact sheet in March of 2008 which summarizes the health and environmental impacts ofthe available substitutes for perc, such that owners can be informed about the potential consequences of switching to an alternative solvent (CARB 2008)
. In 

### March of2008, CARB distributed a fact sheet to all dry-cleaners located in California, entitled: "Dry Cleaning- Alternative Solvents: Health andEnvironmental Impacts," 

### which set forth toxicological concerns associated with n-PB. Ofnote, is an excerpt from this document in which CARB states the following about the health and environmental impacts for n-PB: "According to the California Department ofHealth Services, this solvent <n-PB> is a neurotoxicant and reproductive toxicant and is listed under Proposition 65 as a reproductive toxicant. It causes sterility in both male and female test animals, and harms developing fetuses. It can damage nerves, causing weakness, pain, numbness, and paralysis." n-PB is recognized as a reproductive hazard. It is required that n-PB be labeled as a reproductive hazard not only by California, but also by the European Community (DLI 2007). Additionally, the European Union Classification and Labeling System has assigned numerous "risk phrases" to n-PB including: R 11 (highly flammable), R 20 (harmful by inhalation), R 36/37/38 (irritant to eyes/skin/respiratory system), R 48 (danger ofserious damage to health by prolonged exposure), R 60 (may impair fertility), R 63 (possible risk to the unborn child), and R 67 (vapors may cause drowsiness and dizziness) (HSIA 2010). n-PB has been evaluated for carcinogenicity in a NTP two-year bioassay in which rats and mice were exposed to n-PB by inhalation for their lifetimes. The raw data were released in 2008 and the draft report was released in the autumn of2009. The NTP report on n-PB is still a draft but, it draws conclusions about the carcinogenic potential and non-cancer toxicities ofn-PB based on the two year inhalation bioassay
. The draft NTP report indicates n-PB carcinogenicity with "clear evidence" ofcarcinogenic activity in both female F344/N rats and female B6C3F1 mice and "some evidence" in male F344/N rats (NTP 2009)
. Increased incidences ofadenomas in the large intestine were the reason for the classification ofclear carcinogenic evidence in female rats exposed to n-PB. Increased incidences ofalveolar/bronchiolar neoplasms were the reason for the classification ofclear carcinogenic evidence in female mice exposed to n-PB. Increased incidences ofskin neoplasms, along with the occurrence ofrare adenomas in the large intestine, were the reason for the classification ofsome carcinogenic evidence in male rats exposed to n-PB. There were also increased nonneoplastic lesion incidences resulting from the 2- year exposures to n-PB in both rats and mice (NTP 2009)
. These nonneoplastic lesions were 6 

# Ifound in the following: the tracheas ofboth genders ofmice along with female rats, the noses of both male and female mice and rats, the lungs ofboth genders ofmice, and the larynx ofmale mice and both genders ofrats.


### Conclusions The DEC is confident that the information contained in this petition demonstrates that there are ample data on the adverse health effects resulting from n-PB exposures. In addition, we believe the current occupational air monitoring data and potential exposure ofthe general public and sensitive subpopulations to unregulated vented or fugitive emissions ofn-PB provide adequate evidence to support the listing on n-PB as a HAP under CAA § 112(b)(3)(A)(B) and the listing ofsource categories using n-PB under CAA 

### § 112(c). The adverse health effects arising from n-PB exposures in humans and animal studies are numerous. Until the past few years, the adverse health effects on reproduction were the most well documented and primarily considered as the most sensitive endpoint ofexposure. More recently, it is the neurotoxicity resulting from n-PB exposures tha t has been principally identified as the most concerning and sensitive endpoint with serious neurological effects being observed. Additionally, the animal data has indicated that n-PB exposures also result in developmental toxicity, liver and kidney toxicity, immunotoxicity, and adverse effects on red blood cells and hemoglobin. Many ofthe toxicological endpoints observed in animal studies are now also being observed in humans in occupational settings. Recently, the results ofthe National Toxicology Program (NTP) 2-year rodent bioassa y concluded that n-PB has evidence ofcarcinogenicity. n-PB is already being used in some emissive applications including solvent degreasing applications and in coatings. More recently, it is also being aggressively marketed as an alternative dry-cleaning solvent to replace perc as an unregulated alternative solvent that can be used in co-residential settings after perc is banned. The DEC believes this will result in increased usage ofn-PB by dry-cleaners over time as more ofthem transition away from using perc. Overall, it has been reported that the usage ofn-PB by drycleaners is already increasing by up to 15% per year. Additionally, n-PB is currently being marketed both as a drop-in replacement for perc and also as "non-toxic", "green", "organic", "non-hazardous", and "environmentally friendly" by the n-PB suppliers because ofthe lack ofair pollution regulations and lack ofcertain toxicity designations, including being listed as a HAP. Dry-cleaning facilities using this alternative solvent would not be subject to man y states' air pollution control regulations or the recent residual risk decision made by the EPA under the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Perchloroethylene Dry-Cleaners which will phase out the use ofperc in all dry-cleaners that are co-located with residences by 2020. The n-PB supplier is heavily promoting this lack ofregulation and lack ofhazardous designations, as a marketing tool for n-PB use by dry-cleaners regardless oflocation (Enviro Tech 2010b)
. The information summarized herein indicates that it is apparent that n-PB is neither a simple drop-in replacement for perc nor is it non-toxic, green, organic, non-hazardous, or environmentally friendly. There are several exposure incidences involving n-PB and investigations ofthe n-PB airborne and personal exposure concentrations measured in the workplace. High worker


### 7

### exposure levels have been be found at dry-cleaning facilities using n-PB that will likely necessitate venting to the general atmosphere for occupational safety reasons. Poisonings from nPB exposures have already been documented with several different end uses including: spray adhesives, degreasing applications and now at a dry-cleaning facility, with permanent nervous system damage indicated.in several instances. Studies ofworker exposure levels in several drycleaning facilities have indicated that the concentrations exceed those limits currently in place (even prior to these limits being based on the cancer end point)
. While there is only one dry

cleaning end use poisoning known, currently n-PB is only used in a small fraction ofdry

cleaners
. However, as summarized above, its use at dry-cleaning facilities is expected to increase potentially at a faster rate given the several factors mentioned previously. Based on the foregoing and the data presented, it is apparent that n-PB meets the statutory criteria necessary to be listed as a CAA § 

### 112 HAP. Accordingly, the Petitioner requests that the EPA seriously consider this substantiallyjustified action in an expedited manner.

8

## REFERENCES Banu, S., and 11 others. (2007). "Reversibility ofthe adverse effects of 1-bromopropane exposure in rats." Toxicological Sciences, December, 100(2): 504-512. Blando, James . (2010). New Jersey Department ofHealth and Senior Services. "PERC Ban among Dry Cleaners Leads to 1-Bromopropane Exposures withAlternative "Green" Solvent." Powerpoint presentation
. Northeast States for Coordinated Air Use Management (NESCAUM) Annual Meeting, Northhampton, MA. October 12-13,2010. Blando, James, Schill, D.P ., De La Cruz, M.P., Zhang, L., and Zhang, J. (2010). "Preliminary Study of Propyl Bromide Exposure amongNew Jersey Dry Cleaners as a Result of a Pending Ban on Perchloroethylene." Journal Air & Waste Management Association, 60: 1049-1056
. California Environmental Protection Agency (CalEPA) Air Resources Board (CARB). (2008). Fact Sheet entitled "Dry Cleaning- Alternative Solvents: Health andEnvironmental Impacts." March 2008. Available online at: http:// www.arb.ca.gov / toxics/dryclean/ AlternativeSolvts E.pdf Centers for Disease Control and Prevention (CDC)
. (2008)
. "Neurologic Illness Associated with Occupational Exposure to the Solvent 1-Bromopropane -New Jersey and Pennsylvania, 2007-2008." Morbidity and Mortality Weekly Report (MMWR), Vol. 57, No. 48: pp. 1300-2
. Dec. 5, 2008
. Drycleaning & Laundry Institute International (DLI). (2007). Brochure entitled: " A DLI WHITE PAPER: Key Information on Industry Solvents. " Available online at: http:// www.startadrycleaners.com/docs2008/dli%20white%20paper.final. pdf Eisenberg, Judith, and Ramsey, J
. (2010)
. "Evaluation of 1-Bromopropane Use in FourNew Jersey Commercial Dry Cleaning Facilities." Centers for Disease Control and Prevention (CDC), National Institute for Occupational Safety and Health (NIOSH), New Jersey Department ofHea lth and Senior Services. Health Hazard Evaluation Report, July 2010. Report No. HETA 2008-0175-3111. Enviro Tech International (Enviro Tech). (2010a)
. Brochure within Enviro Tech's website entitled: "DrySolvTM- The Final Solution for Dry Cleaning." Available online at: http://www.envirotechint.com/storage/ 4bb36b99f04a7 64013 .pdf Enviro Tech International (Enviro Tech) Website
. (2010b). "DrySolvTM." Available online at: http://www.envirotechint.com /products/dry-cleaning/ Finkel, Adam. (20 1 Oa). "INCREASED TOXICITYand CARCINOGENICITYOF n-P ROPYL BROMIDE (1-BROMOPROPANE ) RELATIVE TO PERCHLOROETHYLENE ." SUPPLEMENTAL REPORT TO THE CITY OF PHILADELPHIA DEPARTMENT OF PUBLIC HEALTH/ AIR MANAGEMENT SERVICES
. June 2010. Available online at: http://www.phila.gov/healt h/pdfs/Finkel%20Perc%20&%20nPB.pdf 9Finkel, Adam. (2010b). "PERSPECTIVES ONn-PROPYL BROMIDENEUROTOXICITY AND CARCINOGENICITY INLIGHT OFNEWEVIDENCEAND NEW CHALLENGE
. 11 November 12, 2010. Available online at: http://www.phila.gov/health/ pdfs/ nPB%20Perspectives.pdf Fong, Mei, Chowdhury, H
.R., Houghton, M
., Komlenic, M
., and Villalobos, S
. (2006). "California Dry CleaningIndustry- TechnicalAssessmentReport. 11 CARB. Stationary Source Division. Emissions Assessment Branch. February 2006
. Available online at: http:// www.arb.ca.gov /toxics/dryclean/finaldrycleantechreport.pdf Harney, J., Hess J., Reh C
., and Trout D. (2002). "Health HazardEvaluation Report, STN Cushion Company, Thomasville, North Carolina. " Centers for Disease Control and Prevention (CDC). National Institute for Occupational Safety and Health (NIOSH), August 2002
. Report No. HETA 2000-0410-2891. Honma, Takeshi, Suda, M., and Miyagawa M. (2003). "Inhalation of 1-Bromopropane Causes Excitation in the Central Nervous System of Male F344 Rats." NeuroToxicology, August, Volume 24, Issues 4-5 : 563-575. Ichihara, G. (2005a)
. "Neuro-reproductive toxicities of 1-bromopropane and 2- bromopropane. 11 Int Arch Occup Environ Health, March, 78(2): 79-96
. Ichihara, 

### G. (2005b). "Investigation oftoxicity through human cases andanimal experiments

study ofbromopropanes." Article in Japanese with only the Abstract available in English. Nippon Eiseigaku Zasshi, November, 60(4): 405-10. Ichihara, 

### G
., Kitoh, J., Yu, X., Asaeda, N., Iwai, H., Kumazawa, T., Shibata, E., Yamada, T., Wang, H., Xie, Z., and Takeuchi, Y. (2000). "1-Bromopropane, an alternative to ozone layer de pletingsolvents, is dose-dependently neurotoxic to rats in long-term inhalation exposure." Toxicological Sciences, May, 55(1): 116-123. Ichihara, 

### G., Miller, J., Ziolkokwska, A., Itohara, S
., and Takeuchi, Y. (2002). "Neurological disorders in three workers exposed to 1-bromopropane. 11 Journal ofOccupational Health, 44: 1-7
. Ichihara, Gaku, and 14 others. (2004). "Neurologic Abnormalities in Workers of a 1- Bromopropane Factory." Environmental Health Perspectives, 112(13): 1319

- 1325. 

### Li, W.H., Zhou, Z.J., Wang, Q.Y., Ichihara, G., Takeuchi, Y., and Ding, X.C. (2010a). "Effects of 1-bromopropane on neurological andhematological changes of female exposedworkers
. " Article in Chinese with only the Abstract available 

### in English. Zhonghua Lao Dong Wei Sheng Ye Bing Za Zhi, May, 28(5): 339-344. 

### Li, W.H., Wang, Q.Y., Ichihara, G. , Takeuchi, Y. , Ding, X.C., and Zhou, Z.J. (2010b). "Exposure to 1-bromopropane causes dose

-dependent neurological abnormalities in 10workers
. " Article in Chinese with only the Abstract available in English. Zhonghua Lao Dong Wei Sheng Zhi Ye Bing Za Zhi, July, 28(7): 488-93. Li, Weihua and 11 others. (2010c). "Dose-DependentNeurologic Abnormalities in Workers Exposed to 1-Bromopropane. " Journal ofOccupational and Environmental Medicine, August, 52(8): 769-777. Majersik, Jennifer J., Caravati, E.M., and Steffens, J.D
. (2007). "Severe Neurotoxicity Associatedwith Exposure to the Solvent 1-Bromopropane (n-propyl bromide). " Clinical Toxicology, 45: 270-6
. National Clothesline. (2010)
. "HSIA asks EPA to add nPB to hazardous air pollutants list." BPS Communications
. December 2010 Issue. Available online at: http://www.natclo.com/10 12/ npb.htm National Toxicology Program. (2003). "NTPICERHR Monograph on the Potential Human Reproductive andDevelopmental Effects of 1-Bromopropane." October 2003, NIH Publication No. 04-4479, 88 pp. National Toxicology Program. (2009). "NTP Technical Report on the Toxicology and Carcinogenesis of Studies of 1-Bromopropane in F344/NRats andB6C3F1 Mice." NTP TR-564, November 19, 2009. Ohnishi, A., Ishidao, T., Kasai, T. , Arashidani, K. , and Hori, H. (1999). "Neurotoxicity of 1- bromopropane in rats. " Article in Chinese with only the Abstract available in English. Journal ofThe University ofOccupational and Environmental Health, Japan (J. UOEH), March, 21(1): 23-28. Sclar, G. (1999). "Encephalomyeloradiculoneuropathy following exposure to an industrial solvent. " Clinical Neurology and Neurosurgery, 101: 199-202
. Wolf, Katy. (2009). "n-Propyl Bromide Destroys Equipment in Dry Cleaning Plant." Institute for Research and Technical Assistance (IRTA) "The Alternative" Newsletter, XVIII, No.3 pp. 1, 6, 7. Summer 2009. Yu, Xiaozhong, Ichihara, G., Kitoh, J., Xie, Z. , Shibata, E., Kamijima, M
. and Takeuchi, Y. (2001)
. "Neurotoxicity of2-Bromopropane and 1-Bromopropane, Alternative Solvents for Chlorofluorocarbons." Environmental Research, Section A, January, 85(1): 48-52.

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