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 2 4 2011 

Administrator . . 

United 'States Environmentat·Protection Agency 

1200 Pennsylvania A venue., NW 

Washington, DC 20460 

Dear Administrator Jackson:· 

i .. 

JOl; t~'Rt£NS 

Cor~MlSSIONE~ 

The Department of Environmental Conservation :is petitioning EPA to add n.:.propyl bromide (nPB) to the iist of hazardous 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 petitioner or 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. 

Our petition 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 of the CAA. 

Our concern is ·heightened due· to recent attempts to market solvents with n-PB content as an 

unregulated ~ternative dry-cle~ng- solvent. for perchloroethylene (perc), since the latter'is tb be 

ph3$ed ·out of use by EPA requirements ovc;:r the next decade, In addition, n-PB.is being 

marketed as "organic,'' "green," "non-:hazardo1is'~ and "envirbnmentally fri'endlY' in l'art due ·to 

the lack of toXicity designations. that \vould.jndicate that n-PB·is.n<;>t the :'benign'·'· chemical it is 

clahned to:. be by the·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 of 1r-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 of Hazardous Air Pollutants 

Regulated under§ 112 of the 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 of the CAA. Section 112 authorizes the petitioning of the 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 of the lack of 

certain toxicity designations (including being listed as a HAP) and the current lack of state 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 of the dry-cleaning machine components, and its reactivity with any water that might be 

present during the dry-cleaning process (resulting in the generation of a 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 of different n-PB exposure levels, indicating that the use of this solvent will result in 

concentrations that are expected to cause adverse human health effects. Additionally, there have 

already been documented cases of poisonings resulting from n-PB exposures with several 

different end uses including dry-cleaning. 

1 
The adverse health effects demonstrated to occur with exposures to n-PB are indicated to 

affect a wide variety of end 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 of n-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 of n-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 of high 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/m

3

) 8-hour Time-Weighted Average (TWA)). 

There have already been reports of poisonings 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 of an 

electronics factory worker, where this solvent was used to degrease circuit boards, resulted in 

this worker being severely poisoned with some of the 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 of nervous 

system toxicity (profoundly impaired gait and continued deficits in test of motor 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 

2 
machine, 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 of Government Industrial Hygienists (ACGIH) Threshold 

Limit Value (TL V) of 10 ppm (Eisenberg and Ramsey 2010, Blando et al. 201 0). 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 of the 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 of the NIOSH's 8-hr TWA personal breathing 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 ''there is serious concern for 

reproductive and developmental effects at the upper end of the 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 was just 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 of the 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. 

201 0) 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 of one 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 

3 
adjustments 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 of the dry-cleaning machines, modifications are also necessary 

including the need to replace the gaskets, seals, and still door if they 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 of this 

solvent by the dry-cleaning supplier (Blando et al. 2010). The operator started feeling ill and 

showing exposure symptoms, including nausea, dizziness/vertigo, headaches, and tremors, after 

only several weeks of using 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 of a new machine. After this incident, it was reported that due to the 

abundance of water 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. It has 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 of exposures 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/m

3 

(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 neuropathy, 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 

4 
of the legs. Some studies of workers exposed to n-PB suggest that humans may 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 

of these 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 of numerous animal studies and the limited available 

human exposure data demonstrating adverse developmental and reproductive health effects, the 

NTP agreed with the conclusions of the 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 of the 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 of this 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 of the 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, kidney, and the 

nervous and respiratory systems in addition to causing a variety of developmental and 

reproductive health effects in animals exposed by inhalation. The developmental/reproduction 

studies (through the release date of the NTP-CERHR toxicological study discussed above) are 

well summarized in the above referenced monograph (NTP 2003). The full database of animal 

toxicity studies will not be summarized herein, nor will the full range of data 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 of irregular 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 of nerve signal transmission (Ichihara 

et al. 2000). This weakening of limb 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 of studies performed by different groups of scientists. Similar to the human studies, 

some of these 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 Assessment Report", which includes a summary of the various toxicological issues 

with n-PB. After identifying their various concerns with n-PB use by dry-cleaners, CARB closes 

this section of the document by stating that, "Based on current toxicity data, OEHHA staff is 

concerned about its <n-PB> use as a dry cleaning solvent." (Pong et al. 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 of the 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 and Environmental Impacts," which set 

forth toxicological concerns associated with n-PB. Of note, 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 of Health 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 of serious 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" of carcinogenic activity in both female F344/N rats and female B6C3F1 

mice and "some evidence" in male F344/N rats (NTP 2009). Increased incidences of adenomas 

in the large intestine were the reason for the classification of clear carcinogenic evidence in 

female rats exposed to n-PB. Increased incidences of alveolar/bronchiolar neoplasms were the 

reason for the classification of clear carcinogenic evidence in female mice exposed to n-PB. 

Increased incidences of skin neoplasms, along with the occurrence of rare adenomas in the large 

intestine, were the reason for the classification of some 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 
found in the following: the tracheas of both genders of mice along with female rats, the noses of 

both male and female mice and rats, the lungs ofboth genders of mice, and the larynx of male 

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 of the 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 of source 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 of exposure. More 

recently, it is the neurotoxicity resulting from n-PB exposures that 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 of the toxicological endpoints observed in animal studies are now also being 

observed in humans in occupational settings. Recently, the results of the National Toxicology 

Program (NTP) 2-year rodent bioassay concluded that n-PB has evidence of carcinogenicity. 

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 of them 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 of the lack of air pollution regulations and lack of certain 

toxicity designations, including being listed as a HAP. Dry-cleaning facilities using this 

alternative solvent would not be subject to many 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 of perc in all dry-cleaners that are co-located with residences by 2020. The n-PB supplier 

is heavily promoting this lack of regulation and lack of hazardous designations, as a marketing 

tool for n-PB use by dry-cleaners regardless of location (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 of the 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 of worker 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 drycleaning end use poisoning known, currently n-PB is only used in a small fraction of drycleaners. 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 substantially justified 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 with Alternative "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 among New 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 and Environmental 

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 Four New 

Jersey Commercial Dry Cleaning Facilities." Centers for Disease Control and Prevention 

(CDC), National Institute for Occupational Safety and Health (NIOSH), New Jersey 

Department ofHealth 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 TOXICITY and CARCINOGENICITY OF 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/health/pdfs/Finkel%20Perc%20&%20nPB.pdf 

9 
Finkel, Adam. (2010b). "PERSPECTIVES ONn-PROPYL BROMIDE NEUROTOXICITY AND 

CARCINOGENICITY IN LIGHT OF NEW EVIDENCE AND 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 Cleaning Industry- Technical Assessment Report. 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 Hazard Evaluation 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 and animal experimentsstudy 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 depleting solvents, 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 of Occupational 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 and hematological changes of female exposed workers. " 

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 

10 
workers. " 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-Dependent Neurologic Abnormalities in Workers 

Exposed to 1-Bromopropane. " Journal of Occupational and Environmental Medicine, 

August, 52(8): 769-777. 

Majersik, Jennifer J., Caravati, E.M., and Steffens, J.D. (2007). "Severe Neurotoxicity 

Associated with 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/1 0 12/npb.htm 

National Toxicology Program. (2003). "NTPICERHR Monograph on the Potential Human 

Reproductive and Developmental 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/N Rats and B6C3F1 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 of Occupational 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. 

11