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Even though TRI-reportable releases must be within levels authorized by permit or regulation, the TRI was initiated to supplement established regulatory and permitting processes and provide communities with information about chemical releases from all the facilities in their vicinity — those releasing emissions to air and water and those containing toxins within structures on their property. As intended by the TRI regulation, disclosure of the total releases emitted in each community has encouraged the regulated community to undertake pollution prevention efforts designed to reduce releases.
On page 24 of the Releases of Chemicals section of the TRI National Analysis 2018, the EPA states that “disposal of chemicals to land is often regulated by EPA under the Resource Conservation and Recovery Act (RCRA).” Furthermore, on page 25, EPA defines the RCRA Subtitle C disposal category in TRI as “disposal to landfills and surface impoundments authorized to accept hazardous waste” under the RCRA. The EPA further clarifies the standards for disposal of hazardous wastes by citing RCRA design standards, which “include a double liner, a leachate collection and removal system, and a leak detection system. Operators must also comply with RCRA inspection, monitoring, and release response requirements.” This reinforces the EPA’s view that hazardous wastes disposed of in RCRA Subtitle C landfills and surface impoundments are subject to stringent regulations governing the design and management of these facilities.
|Hazardous Waste Management||4%|
The EPA continues to reiterate its view that increased quantities of TRI-reportable 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.” For example, in its most recent commentary about the inventory, the EPA 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. 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. This distinction is continued in EPA’s most recent update, p. 16. Waste Management’s emissions under TRI are reported annually to the EPA, in July. These tables reflect the most up-to-date information.
The EPA reports the actual releases and containment at the seven Waste Management TRI-reporting facilities (five hazardous waste treatment and disposal facilities, one non-hazardous treatment and disposal facility and one underground injection facility). In 2019, WM reported 8.49 pounds released into the air and 0 pounds, or 0%, into the water. The table below shows containment in pounds for Waste Management facilities subject to TRI reporting.
|2009: 34,040,988||2010: 24,479,007||2011: 26,143,719||2012: 24,214,088||2013: 21,930,366||2014: 19,280,924||2015: 23,822,274||2016: 30,177,412||2017: 25,568,656||2018: 30,885,281|
|Under ground Injection||2009: 5,025,712||2010: 9,574,712||2011: 9,253,272||2012: 7,374,493||2013: 9,949,743||2014: 8,842,344||2015: 10,968,603||2016: 10,134,130||2017: 7,659,617||2018: 7,940,553|
Off-Site to Treatment / Containment
|2009: 71,948||2010: 171,240||2011: 111,704||2012: 124,394||2013: 580,720||2014: 523,149||2015: 296,284||2016: 183,050||2017: 194,160||2018: 64,585|
*Note that we use U.S. EPA’s official reporting on TRI for consistency in numbers. These are the most up-to-date at the time of publication.
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 wastes in our permitted facilities to work in-plant and on-site with industrial customers to eliminate, reduce and avoid potential exposures from hazardous wastes 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.