Second report of the National Pollutant Release Inventory working group 2001 to 2002: chapter 6
6. Substance-specific Changes
6.1.1 Background
Nonylphenol and its ethoxylates (NP/NPEs) have been recommended for addition to the List of Toxic Substances under CEPA 1999. Thirteen NPs and NPEs, and one octylphenol (OP), are currently individually listed on the NPRI. Thus, reporting is only triggered when the individual substance is MPO in quantities of 10 tonnes or more. EC risk managers have found that coverage under these conditions is inadequate. In addition, EC is concerned that industry may be replacing NP/NPEs with octylphenol and its ethoxylates (OP/OPEs), which research suggests will amplify environmental impacts resulting from effluent. (The toxicities of the two groups of substances are not significantly different; however, OPEs are associated with higher estrogenic effects.) EC has identified 20 additional NP/NPEs & OP/OPEs (i.e., beyond the ones already listed) that are likely to be used in Canada. Canadian sources of concern include both manufacturers of NP/NPE, and effluents from users (e.g., textile and pulp and paper mills) and municipal wastewater treatment plants.
6.1.2 Options and WG Recommendations Related to the Trigger
WG members concur on the need for a different approach to the listing of NP/NPEs and OP/OPEs. The logic of targeting groupings rather than individual substances was also acknowledged (related in large measure to the fact that these substances are released as complex mixtures, making it difficult to report release quantities for the individual substances); although the need to provide indicative CAS numbers to ease due diligence was noted.
The WG considered the following three options in terms of a trigger for these substances. (Note that under any of these options, the grouping(s) would include the individual NP/NPEs and the OP already listed on the NPRI, so the current separate listings could be eliminated. Refer to Table F-1 in Annex F for the proposed complete list. Also note that the threshold that triggers reporting would apply to the group of NP/NPEs and/or the group of OP/OPEs, and not the individual substances.)
- Option 1: A combined NPRI listing of NP/NPEs & OP/OPEs, with the standard threshold trigger of 10 tonnes MPO.
- Option 2: Separate listings for NP/NPEs and OP/OPEs, with NP/NPEs at 10 tonnes MPO, and an alternate MPO threshold for OP/OPEs.
- Option 3: Separate listings for NP/NPEs and OP/OPEs, each at 10 tonnes MPO.
Option 1 was put forward by EC, on the grounds that it would trigger better coverage (i.e., reporting from a larger number of facilities that use these substances), which is required in order to develop risk management strategies. It would also send the signal that switching from NPEs to OPEs is not a viable alternative. Some concern was expressed, however, that grouping different substances (i.e., the OPEs with the NPEs) in order to achieve desired coverage is not an approach used for other NPRI substances.
Option 2 was put forward as an approach to address this concern. Risk managers are concerned that there may not be adequate reporting of OP/OPEs at a 10 tonne threshold, and suggest that an ATH is needed if OP/OPEs are to be triggered separately. (OPEs are currently used at lower quantities than NPEs.) The problem is that the data is not available to confidently establish an ATH that will yield reasonable coverage without being needlessly burdensome.
Option 3 was suggested by some WG members as a preferred approach, since it is not clear that a single grouping of NP/NPEs and OP/OPEs is really required to ensure adequate reporting; nor that an ATH is requires if OP/OPEs are a separate grouping. It was suggested that if a single 10 tonne thresholds for all OP/OPEs does not trigger adequate reporting of these substances, an alternative threshold for this group could then be considered.
6.1.3 Derivatives
Eight of the substances proposed for inclusion in the NP/NPE groups are derivatives of nonylphenol or its ethoxylates. (Refer to Table F-2 in Annex F for a listing of the derivatives.). They are structurally different than their precursors, and their use patterns are not necessarily correlated with those of NP/NPE. In addition, their toxicity and hazard profiles may be different; however in general there is almost no information on the profiles for these derivatives. These derivatives were not considered in the Priority Substances List 2 Assessment of NP/NPEs. There was limited discussion by the WG on whether or not they should be included in the proposed NPRI listing; but no decision was reached. EC requests feedback and information from stakeholders on these derivatives.
6.1.4 Options and WG Recommendations Related to Reporting
At the May meeting of the WG, the Alkylphenols and Ethoxylates Research Council had recommended that the ethoxylates be reported separately from the nonylphenols and octylphenols, since toxicities differ for each of the four groups. However, WG members felt that there was logic to maintaining the groupings (NP/NPEs and OP/OPEs) for reporting purposes.
Therefore, the WG recommends that once the reporting threshold is met, the NP/NPEs should be reported as one group, and the OP/OPEs separately as another group. (In other words, the reporting requirement would be stated along the lines of "NP and its ethoxylates, total quantity; and OP and its ethoxylates, total quantity".) This will enable tracking of any trend towards replacing NPEs with OPEs. Some WG members expressed the expectation that reporting a single number for each group will be sufficient in the long-term, so that EC will not come back with a request for more detailed break-out in future.
WG members indicated a need for guidance to assist reporters, especially with respect to calculating the amount being released through wastewater treatment systems.
6.2.1 Background
COS was screened out of consideration for NPRI when the program was created in 1992 because it did not meet the listing criteria of more than 1 tonne usage for any facility identified in the Domestic Substances List. However, this substance is predominantly a by-product of various industrial processes, and is consistently reported with very large releases to air in the U.S. TRI (where it has been included since 1987). Based on this, potentially large releases to the Canadian environment are probable.
COS has both human health and environmental effects associated with releases to air. There is evidence of acute narcotic effects on human health of individuals working at petroleum refineries that are exposed to COS through inhalation. There is also potential for human health effects for those populations living near petroleum refineries, due to background ambient air concentrations of COS. (COS has been detected in mother’s milk of residents living near refineries.) Environmental concerns relate to enhanced depletion of stratospheric ozone, since COS is a source of sulphur to the upper atmosphere.
6.2.2 WG Recommendation
The WG supports EC’s proposal to add COS to the NPRI for 2003 reporting year at the conventional 10 tonne, MPO threshold. It also supports EC’s proposal to contact facilities in affected sectors to notify them about the addition of COS to the NPRI.
6.3.1 Background
Phosphorous (yellow or white) is currently listed on the NPRI. Phosphoric acid was delisted from the NPRI in 2001, since it was not the appropriate form to capture releases of concern. (Phosphoric acid is generally neutralized prior to release, and the salt which is formed was not reportable.) Thus, phosphates which are biologically available in the aquatic environment (where they contribute to eutrophication) are not currently reported to the NPRI. Therefore, at that time of delisting of phosphoric acid, EC had committed to considering the addition of phosphates/phosphorus to the NPRI as an alternative. (This commitment is referenced in the First Report of the current WG.)
6.3.2 Options and WG Position
EC has proposed adding phosphates to the NPRI, at the conventional 10 tonne MPO threshold. The proposed listing is "total phosphorus", which includes total phosphorous and the various reactive forms (soluble reactive phosphorous, total reactive phosphorous, total dissolved reactive phosphorous). Given removal of the employee threshold for municipal wastewater treatment facilities, the listing will trigger reporting from these facilities. As with other NPRI substances, the reporting requirement will apply to emissions to all media. In this way, phosphates in sewage sludge transported off site will be reported, in addition to those in wastewater effluent.
Some WG members indicated that more information is required on what information on phosphates is currently being collected, and how it would relate to what would be reported through the NPRI. EC will present information obtained on this issue, and any further information available on the coverage implications of the proposed threshold, in time for discussion at the September meeting of the WG. EC is also seeking broader stakeholder input on its proposed approach to adding phosphates.
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