U.S. EPA Requires TRI Reporting for NPE Category

Posted on: June 29, 2018

by John J. Kowalski, CHMM

On June 12, 2018, the U.S. Environmental Protection Agency (EPA) published a final rule “to add a nonylphenol ethoxylates (NPE) category to the list of toxic chemicals subject to reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) and Section 6607 of the Pollution Prevention Act (PPA).”  The final rule, which is effective November 30, 2018, will apply for the reporting year beginning January 1, 2019, for which reports are due July 1, 2020.

“Section 313 of EPCRA requires certain facilities that manufacture, process, or otherwise use listed toxic chemicals in amounts above reporting threshold levels to report their environmental releases and other waste management quantities of such chemicals annually.  These facilities must also report pollution prevention and recycling data for such chemicals, pursuant to Section 6607 of the PPA.”  EPA compiles the information submitted by facilities in the Toxics Release Inventory (TRI), which is available to the public.

The NPE category added by the final rule published on June 12, 2018 will be defined as “Nonylphenol Ethoxylates.”  However, it will include only those chemicals listed in the table below.

CAS Numbers Chemical Names
7311-27-5 Ethanol, 2-[2-[2-[2-(4-nonylphenoxy)ethoxy]ethoxy]ethoxy]-
9016-45-9 Poly(oxy-1,2-ethanediyl), .alpha.-(nonylphenyl)
20427-84-3 Ethanol, 2-[2-(4-nonylphenoxy)ethoxy]-
26027-38-3 Poly(oxy-1,2-ethanediyl), .alpha.-(4-nonylphenyl)
26571-11-9 3,6,9,12,15,18,21,24-Octaoxahexacosan-1-ol, 26-(nonylphenoxy)-
27176-93-8 Ethanol, 2-[2-(nonylphenoxy)ethoxy]-
27177-05-5 3,6,9,12,15,18,21-Heptaoxatricosan-1-ol, 23-(nonylphenoxy)-
27177-08-8 3,6,9,12,15,18,21,24,27-Nonaoxanonacosan-1-ol, 29-(nonylphenoxy)-
27986-36-3 Ethanol, 2-(nonylphenoxy)-
37205-87-1 Poly(oxy-1,2-ethanediyl), .alpha.-(isononylphenyl)
51938-25-1 Poly(oxy-1,2-ethanediyl), .alpha.-(2-nonylphenyl)
68412-54-4 Poly(oxy-1,2-ethanediyl), .alpha.-(nonylphenyl), branched
127087-87-0 Poly(oxy-1,2-ethanediyl), .alpha.-(4-nonylphenyl), branched

These newly-added chemicals have already been added to the relevant list in our LOLI Database.

Recommended Action Items

  • Determine whether your facility manufactures, processes, or otherwise uses any of the chemicals listed in the table above and, if so,
  • Review the TRI reporting regulations at 40 CFR Part 372 to determine whether your facility is subject to reporting for the NPE category.

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Environmental Protection Agency.  “Addition of Nonylphenol Ethoxylates Category; Community Right-to-Know Toxic Chemical Release Reporting.”  Federal Register 83 (12 June 2018): 27291-27296.  [PDF]


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