ATTACHMENT I

Alkylphenols & Ethoxylates Research Council
Comments on the
Working Document Regarding Pollution Prevention Planning for Nonylphenol and its Ethoxylates Used in the Wet Processing Textile Industry and Effluents from Textile Mills that Use Wet Processing

Nomenclature and CAS Numbers for Nonylphenol

NP is produced by the reaction of phenol with branched nonene. Commercial NP is a mixture of various branched nonylphenol isomers rather than a discrete chemical structure. The nonyl group is positioned predominantly in the para position on the phenol ring. Therefore, APERC considers CAS number 84852-15-3 to be most descriptive of commercially available NP. The other two CAS numbers listed below are less descriptive with respect to the branching and position of the nonyl group on the phenol ring. Linear, or normal, n-NP is difficult to produce and is therefore less likely to be commercially relevant. The following CAS numbers may be assigned to NP products in commerce.

TABLE 1
CAS NUMBERS FOR NP

CAS NUMBER	DESCRIPTION
25154-52-3	Phenol, nonyl-
104-40-5	Phenol, 4-nonyl-
84852-15-3	Phenol, 4-nonyl-, branched

Nomenclature and CAS Registry Numbers for Nonylphenol Ethoxylates

NPEs are produced by the base-catalyzed reaction of para-Nonylphenol (p-NP) with ethylene oxide (EO). It is important to note that all of these products are polymers with varying levels of ethoxylation. Branching of the nonyl group results in additional structural isomers.

Following is a list of the CAS numbers in the Working Document for NPEs that are known to APERC as having commercial usage. While these CAS numbers differ with respect to their description of branching and position of the nonyl group on the phenol ring, APERC understands that manufacturers of NPEs use essentially the same starting materials and synthesis process; therefore, commercially available NPEs have essentially the same structure and isomeric mix.

TABLE 2
CAS NUMBERS FOR NPE

CAS NUMBER	DESCRIPTION
9016-45-9	Poly (oxy-1,2-ethandiyl), alpha-(nonylphenyl)-omega-hydroxy-
26027-38-3	Poly (oxy-1,2-ethanediyl), alpha-(4-nonylphenyl)-omega-hydroxy-
37205-87-1	Poly (oxy-1,2-ethanediyl), alpha-(isononylphenyl)-omega-hydroxy-
68412-54-4	Poly (oxy-1,2-ethanediyl), alpha -(nonylphenyl)-omega- hydroxy-, branched
127087-87-0	Poly (oxy-1,2-ethanediyl), alpha-(4-nonylphenyl)-omega-hydroxy-, branched
104-35-8	2-(p-Nonylphenoxy) ethanol
20427-84-3	2-(2-(p-Nonylphenoxy)ethoxy) ethanol
27177-05-5	Nonylphenol hepta(oxyethylene)ethanol
28679-13-2	Ethoxynonyl benzene
27986-36-3	Nonylphenoxy ethanol
37251-69-7	Oxirane, methyl-, polymer with oxirane, mono(nonylphenyl) ether
7311-27-5	2-(2-(2-(2-(p-Nonylphenoxy)ethoxy)ethoxy)ethoxy)ethanol
27176-93-8	Ethanol, 2-[2(nonylphenoxy)ethoxy]-
37340-60-6	Nonylphenol ethoxylate
51938-25-1	Poly (oxy-1,2-ethanediyl), alpha-(2-nonylphenyl)-omega-hydroxy-
68412-53-3	Nonylphenol ethoxylate

CAS Registry Numbers That Do Not Represent NP or NPE

The Working Document incorrectly lists the following compounds as "CEPA toxic substances, Nonylphenol and Its Ethoxylates."

TABLE 3
CAS NUMBERS THAT ARE NOT NP OR NPE

CAS NUMBER	DESCRIPTION
68515-93-5	Phenol, nonyl derivs, sulfides
68081-86-7	Phenol, nonyl derivs
26523-78-4	Phenol, nonyl-, phosphite
28987-17-9	Phenol, nonyl, barium salt
68515-89-9	Barium, carbonate nonylphenol complexes
1323-65-5	Phenol, dinonyl
9051-5-4	Ammonium salt of sulphated nonylphenol ethoxylate
51811-79-1	Poly (oxy-1, 2-ethanediyl) alpha- (nonylphenyl)-omega-hydroxy, phosphate

 

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