Top chemical gets regulatory exemption
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April 03, 2014
Top chemical gets regulatory exemption

In a direct final rule, the EPA has added 2-amino-2methyl-1-propanol (AMP) to its list of organic compounds that are explicitly excluded from the definition of volatile organic compounds (VOCs) subject to federal emissions requirements.  According to the EPA, AMP does not reach the reactivity level that serves as the Agency’s threshold for VOC regulation. 

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VOCs react in sunlight with nitrogen oxides to form ground-level ozone (03), a pollutant that is regulated under the Clean Air Act’s (CAA) national ambient air quality standards (NAAQS).

AMP is a versatile chemical with uses that include stabilizing pH in latex paints; removing carbon dioxide (CO2) in boiler-water systems; inhibiting corrosion in metalworking fluids; and neutralizing resins in cosmetic products.  EPA’s latest production data show that between 10 and 50 million pounds of AMP were manufactured in 2005.  In October 2012, the Dow Chemical Company petitioned the EPA to add AMP to the VOC regulatory exemption list at 40 CFR 51.100(s)(1). 

Ethane threshold

The CAA gives the EPA the authority to define a VOC for regulatory purposes.  In 1977, to aid in developing the definition, the Agency conducted smog-chamber tests that indicated that when reacted with nitrogen oxide (NOx), 1 gram of ethane resulted in the formation of 0.28 grams of ozone (0.28 gm/O3 gm ethane).  Subsequently, the Agency decided that negligibly reactive compounds excluded from the definition are those that are less reactive than or equally reactive to ethane under certain assumed conditions.  Compounds that are more reactive than ethane continue to be considered VOCs for regulatory purposes and therefore are subject to control requirements.

Dow supported its petition with several peer-reviewed documents indicating that the reactivity of AMP is 0.25 gm/O3 gm AMP in the maximum incremental reactivity scale (MIR).  In fact, the data indicate that, when released, AMP is slightly more reactive than ethane, but then reacts in a way that reduces ozone.  The EPA accepted the data and concluded that AMP is a negligibly reactive compound.

Other environmental effects
The EPA is also required to assess whether the deregulation of AMP would have other environmental effects.  The Agency states that AMP is short-lived in the atmosphere—about 4 hours—which makes it an unlikely contributor to climate change.  Further, since AMP does not contain chlorine or bromine, it is not expected to contribute to the depletion of the Earth’s protective stratospheric ozone layer. 

Control is not compliance

As a result of the direct final rule, no entity that uses or produces AMP and is subject to EPA VOC limits in a product may count reductions in AMP as contributing to compliance with those limits. 

The action may also affect whether AMP is considered a VOC for state regulatory purposes to reduce ozone formation if a state relies on EPA’s regulatory definition of VOCs.  States are not obligated to exclude from control as a VOC those compounds that the EPA has found to be negligibly reactive.  However, no state may take credit for controlling this compound in its ozone control strategy.  For example, reduction in emissions of AMC will not be considered or counted in determining whether states have met the rate of progress requirement for VOCs in state implementation plans for the purpose of meeting the ozone NAAQS.

EPA’s direct final rule was published in the March 27, 2014, FR.

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