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Hazardous Substances

Waste Management owns five hazardous waste treatment and disposal facilities, one non-hazardous waste treatment and disposal facility, one mercury recovery facility and one underground injection facility that are subject to reporting to the EPA’s Toxics Release Inventory (TRI), a data repository compiled to inform the public about the presence of chemicals in their communities. Under TRI, facilities in certain industry sectors that “manufacture,” “process,” or “otherwise use” listed toxic chemicals above the TRI reporting thresholds must report annually on their environmental releases. WM is required to file annual TRI reports because EPA includes in its definition of “otherwise use” the placement of chemicals received from off-site generators in modern, secure hazardous waste landfills for land disposal. In the EPA’s most recent inventory of TRI releases (2018), 3.80 billion pounds of chemicals were reported to have been released in the United States, and 4.5 percent of these “releases” 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 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.

Volume of Toxic Chemical Releases
by Industry, 2018 (percent)
Industry %
Metal Mining 47%
Chemical Manufacturing 14%
Electric Utilities 9%
Primary Metals 9%
Hazardous Waste Management 4%
Paper Manufacturing 4%
Food Manufacturing 4%
All Others 9%

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.

TRI Chemical Containment at Waste Management Hazardous Waste Facilities
(in Pounds)
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
RCRA
Subtitle C
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
Transfer
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.