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Hazardous Substances

WM 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% 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 2019, 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.

Table: Volume of Toxic Chemical Releases
by Industry, 2020 (Percent)
Industry %
Metal Mining 45
Chemical Manufacturing 16
Primary Metals 8
Electric Utilities 7
Food Manufacturing 5
Paper Manufacturing 5
Hazardous Waste Management 4
All Others 10

Total does not equal 100% due to rounding.

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. WM’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 WM TRI-reporting facilities (five hazardous waste treatment and disposal facilities, one non-hazardous treatment and disposal facility and one underground injection facility). The table below shows containment in pounds for WM facilities subject to TRI reporting.

Also integral to WM’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 WM Sustainability Services employees work with customers to reduce the generation of hazardous waste at the outset, in the design process.