Waste Management owns six hazardous waste treatment and disposal facilities, five of which are active disposal facilities and one underground injection well, subject to U.S. EPA’s Toxics Release Inventory (TRI), a data repository compiled to inform the public about the presence of chemicals in their communities.1 In U.S. EPA’s most recent inventory of TRI releases (2014), 3.89 billion pounds of chemicals were reported to have been released in the United States, 3 percent of which came from the hazardous waste management sector.
Even though TRI-reportable releases must be within levels authorized by permit or regulation, the TRI was initiated to provide a supplement to the permitting process that would provide communities with information about chemicals from all of the facilities in their vicinity – those releasing emissions to air and water and those containing toxins within structures on their property. Disclosure of the total releases emitted in each community was intended as an indirect means of encouraging pollution prevention, and it has, in fact, served that purpose.
U.S. EPA continues to reiterate its view that increased quantities of TRI materials in containment can represent “a generally positive environmental trend because these facilities are in the business of managing hazardous waste and do so under strict controls.”3 For example, in explaining what TRI data mean to a community, U.S. EPA, in its most recent commentary about the TRI inventory, prioritized sites by subtracting emissions to land reported by RCRA Subtitle C regulated units because those units were considered to be physically controlling toxic releases rather than emitting them.4 Moreover, releases are reported differently based on whether they involve placement in RCRA Subtitle C landfills versus other kinds of landfills, in recognition of the stringent regulation of Subtitle C landfills.5 Waste Management’s emissions under TRI are reported annually to the U.S. EPA and are posted at https://www3.epa.gov/enviro/facts/multisystem.html.
Continuing delays in obtaining permits for new units at two hazardous waste landfills have had two impacts: (1) a sharp decline in containment in the RCRA Subtitle C units on-site and (2) a corresponding increase in transfers off-site as new arrangements needed to be made to accommodate customer needs.
U.S. EPA reports the actual releases and containment at the seven Waste Management hazardous waste facilities as follows:
|RCRA Subtitle C||34,040,988||24,479,007||26,143,719||24,214,088||21,930,366||19,280,924||23,822,274|
|Transfer Off-Site to
Also integral to Waste Management’s focus on eliminating exposure to hazardous substances is our work with customers, using our experience in safely containing hazardous waste in our permitted facilities to work in-plant, on-site with industrial customers to eliminate, reduce and avoid potential exposures from hazardous waste at their facilities. Our Waste Management Sustainability Services employees work with customers to reduce the generation of hazardous waste at the outset, in the design process.
1 The six facilities include five active landfills and one underground injection well. In addition Waste Management owns one inactive hazardous waste landfill.
3 EPA Toxics Release Inventory 2006 Public Data Release Key Findings, p. 10, www.epa.gov/tri/ tridata/tri06/pdr/key_findings_v12a.pdf. See also www.epa.gov/tri/tridata/tri08/national_analysis/pdr/TRI_key_findings_2008.pdf . (Deleted from public website, but available in paper docket.)
4 See www2.epa.gov/sites/production/files/2013-09/documents/tri_factors_to_consider_2013.pdf. (Deleted from public website, but available in paper docket.)
5 Ibid., p. 18.
6 Note that U.S. EPA considers the information reported for 2014 to be current as of November 2015. 2015 data have been calculated from site reporting; when U.S. EPA’s official national tabulations become available, we will correct our numbers in future reports to reflect any adjustments they make in their national characterization.