They Buried the Poison and Lost Track of It
Chemical Waste Management runs the largest hazardous waste dump in America. Federal inspectors showed up. What they found inside should terrify everyone.
Source Document Filed: May 23, 2024 • EPA Region 4 • Emelle, AlabamaThe Largest Toxic Waste Dump You’ve Never Heard Of
The FactsChemical Waste Management, Inc. (CWM) operates a hazardous waste facility at 36964 AL Highway 17 N., Emelle, Alabama. Emelle sits in Sumter County β a county that is over 70% Black and one of the poorest in the state. The facility is, by any measure, massive: it contained an active landfill, sixteen closed landfills undergoing post-closure monitoring, a new landfill under construction, a hazardous waste treatment operation, multiple storage buildings for PCB and hazardous waste, leachate storage tanks, a waste sampling area, and an on-site laboratory.
PCBs β polychlorinated biphenyls β are a class of industrial chemicals banned in the United States since 1979 because they cause cancer, damage the immune system, disrupt hormones, and accumulate in the bodies of people, fish, and wildlife. The EPA strictly regulates how they must be stored, labeled, and disposed of. CWM received federal approval on September 18, 2020, to commercially store, process, and dispose of PCB waste at this site under a detailed set of conditions designed to prevent these chemicals from escaping into the surrounding environment.
Those conditions included a clear, non-negotiable rule: every drum of PCB waste must be disposed of within one year of the date it is removed from service. CWM agreed to all of it. Then federal inspectors showed up.
β EPA Consent Agreement, Findings of Facts, May 2024
Six Buildings. Chaos in All of Them.
When EPA and Alabama Department of Environmental Management (ADEM) representatives arrived on May 2, 2023, they found PCB waste stored in Buildings 600, 603, 604, 700, 702, and 2200. In every single one of those buildings, drums of toxic waste were observed stored “randomly,” comingled with both hazardous and non-hazardous waste, with inspectors actively struggling to locate the PCB items. The labels required by federal law β which exist so that workers and emergency responders can identify what they’re dealing with β were positioned so they couldn’t be easily read.
This is a company that was granted federal approval precisely because it was supposed to be a professional, reliable handler of the most dangerous industrial waste in existence. The approval came with detailed conditions. CWM agreed to meet those conditions. What inspectors found was a facility operating as if those conditions were a polite suggestion.
Violations Found During May 2, 2023 Inspection
Data sourced directly from EPA Consent Agreement Findings of Facts, Section IV. Each bar represents a distinct category of regulatory violation. Items within each category were individually identified and documented by EPA inspectors.
The Non-Financial Ledger: What a Number Can’t Capture
The MisconductPCBs do not belong in the bodies of the people who live near them. They cause cancer. They disrupt hormones. They accumulate in human tissue and do not leave. They pass from mother to child through breast milk. The federal government banned their manufacture in 1979 specifically because the science was unambiguous: these chemicals kill people slowly, quietly, and disproportionately. CWM sits at the center of this reality, holding these chemicals on behalf of industry, in a Black, rural Alabama community that has had essentially zero political power to resist it.
Emelle, Alabama is not an accident. The placement of the nation’s largest commercial hazardous waste landfill in Sumter County β a majority-Black, deeply poor county β was a political and economic decision made by people who understood that resistance would be minimal. Environmental justice researchers have documented this facility for decades as a textbook case of sacrifice zone politics: the practice of concentrating industrial risk in communities whose suffering doesn’t reach the ears of legislators or executives. The people of Emelle did not consent to become the nation’s chemical waste custodians. They were simply chosen.
What the EPA inspection revealed goes beyond regulatory checkbox failures. Inspectors found drums of poison labeled with duct tape that said “Presumed PCBs.” They found one drum labeled “PCBC” β a notation that has no legal meaning under federal hazardous waste regulations. They found six drums that had been removed from service in January 2022 with no ML mark at all, which means no one looking at those drums would know, from the outside, that they contained one of the most dangerous chemical classes ever manufactured. In a facility where workers enter every day, this represents a direct occupational hazard that no settlement dollar amount addresses.
They Falsified the Dates. That’s the Part That Should Keep You Up at Night.
The most damning finding in the EPA’s inspection report is not the mislabeled drums. It’s the falsified dates. Five drums in Row 32 of Building 700 carried a “removed from service date” of September 26, 2023 β but those same drums had a received date of August 3, 2022. The math is impossible. A drum cannot arrive at a facility more than a year before it is “removed from service” if removal from service is the event that triggers the disposal timeline. The record CWM produced suggests either incompetent record-keeping so severe it constitutes constructive fraud, or deliberate manipulation of disposal timelines to mask how long these drums had actually been sitting.
Either interpretation is a scandal. A company entrusted to handle cancer-causing chemicals under federal permit cannot keep track of when those chemicals need to be disposed of. Or it can, and chose to document them incorrectly. The consent agreement allows CWM to “neither admit nor deny” the factual findings β so the public never gets a definitive answer on which of those realities is true. Both should be disqualifying.
The inventory failures complete the picture. Eight PCB items found physically on-site during inspection were entirely absent from CWM’s PCB Waste Inventory list. In some cases, the drum labels differed from the inventory records. This is a company that accepted a federal permit, agreed to daily inventory records, and then produced records that didn’t match what inspectors could see with their own eyes. The people of Emelle live within proximity of drums of toxic waste that the company holding them couldn’t locate, couldn’t properly label, and couldn’t accurately count.
PCB Drums Stored Beyond the 1-Year Legal Limit
Each bar shows the number of months a specific PCB drum or container was stored past the federally mandated 1-year disposal deadline at the time of inspection (May 2, 2023). Data drawn directly from EPA Consent Agreement Section IV, paragraph 34.
Legal Receipts: Straight From the Document
The FactsThese are direct quotes and factual statements drawn verbatim from the EPA Consent Agreement and Final Order. Nothing below is paraphrased or invented.
“In all of these buildings, the PCB wastes were observed being stored randomly and comingled with hazardous waste and non-hazardous waste. Inspectors had difficulty locating the PCB wastes stored in these buildings, and each PCB Item and PCB Container was not stored in a manner that made it easy to read the labeling on them.”
EPA Consent Agreement, Findings of Facts, ΒΆ30 β Describing conditions in Buildings 600, 603, 604, 700, 702, and 2200“Five of the PCB waste drums located in Row 32 of Building 700 had an inaccurate RSD of 9/26/2023 but had a received date of 8/3/2022 incorrectly indicating that the drums had been removed from service over a year after the drums had already been received by the Facility.”
EPA Consent Agreement, Findings of Facts, ΒΆ33 β Documenting date falsification“One PCB drum (014268977JJK-1) stored in Bay 11, Slot 14 of Building 603 had a RSD of 11/2/2020.”
EPA Consent Agreement, Findings of Facts, ΒΆ34(a) β A drum with a removal-from-service date of November 2020, found still on-site during the May 2023 inspection: more than 2.5 years past its legal disposal deadline.“Respondent failed to produce an accurate inventory of PCB waste on-site as required by Approval Condition K.2, because the following PCB items and PCB Containers were being stored on-site but were missing from Respondent’s PCB Waste Inventory list or the labeling on drums was different from the PCB inventory.”
EPA Consent Agreement, Findings of Facts, ΒΆ36 β Eight separate items listed as examples of the inventory failures“One PCB-Contaminated drum stored in Building 702 was inappropriately labeled ‘PCBC,’ which is not a legitimate PCB ML mark; [and] one PCB drum in Row 36 of Building 700 was not labeled with a PCB ML mark but was labeled with duct tape stating, ‘Presumed PCBs.'”
EPA Consent Agreement, Findings of Facts, ΒΆ31(a) and ΒΆ31(b) β Describing specific mislabeling incidents at the facilitySocietal Impact Mapping
Environmental Degradation
The MisconductPCBs are persistent organic pollutants. They do not break down. They bind to soil particles, accumulate in groundwater, and travel through the food chain. The specific violations documented in this EPA consent agreement β drums stored past disposal deadlines, chemicals comingled without proper segregation, items impossible to locate or properly identify β each represent conditions under which PCB contamination can spread undetected. An unlabeled drum that no one can find during a routine inspection is also a drum that no one addresses when it leaks.
The facility in Emelle includes sixteen closed landfills currently undergoing post-closure monitoring, plus one active landfill and one under construction. That is a landscape saturated with decades of deposited industrial waste, and it exists in a county bordered by the Black Belt region of Alabama β an agricultural area with a history of both environmental contamination and severe lack of access to clean water infrastructure. The regulatory violations documented here did not occur in a vacuum. They occurred within an already stressed environmental system where additional contamination pathways carry magnified risk.
The one-year disposal rule exists precisely because extended storage increases the probability of containment failure. Every day a drum sits past its disposal deadline is another day it can corrode, leak, or be improperly handled. CWM stored at least one drum for over two and a half years past that deadline. The law treats each day of continued violation as a separate, potentially penalizable offense β but the settlement resolved everything for a combined fine that amounts to less than pocket change for a company of this size.
Public Health
The MisconductPCBs are classified as probable human carcinogens by the International Agency for Research on Cancer. Long-term exposure has been linked to non-Hodgkin’s lymphoma, liver cancer, and immune system suppression. They disrupt the endocrine system, interfering with thyroid function, reproductive health, and fetal development. Workers who enter buildings where PCB drums are stored without proper labeling cannot take appropriate precautions. Emergency responders who arrive at an incident cannot respond correctly if the materials involved are not properly identified. The mislabeling and inventory failures documented by EPA inspectors are occupational health failures, not administrative ones.
The community surrounding the Emelle facility has raised concerns about environmental health for decades. Sumter County’s population is predominantly Black, rural, and medically underserved. Access to specialists, cancer screening, and environmental health monitoring is limited. The cumulative exposure burden β the combination of living near a facility handling some of the most hazardous chemicals in existence, with documented regulatory failures in storage and labeling β falls on people with the fewest resources to detect, document, or fight it.
The consent agreement states that CWM certified it “is currently in compliance with all relevant requirements of the Act” at the time of signing. That certification resolves the government’s enforcement action. It does not restore the health outcomes of workers who handled improperly labeled drums. It does not address any contamination that may have occurred during the period of non-compliance. The legal process ends; the biological reality does not.
Economic Inequality
The MisconductThe $68,699 ($68,699 β roughly equivalent to what a beginning public school teacher in Alabama earns in a full year of educating children) penalty assessed against Chemical Waste Management, Inc. is the final number that sums up the economic logic of environmental enforcement in America. CWM’s parent company, Waste Management Inc., reported $20.4 billion in total revenue for 2023. The penalty represents approximately 0.0003% of that annual revenue β proportionally equivalent to fining someone who earns $60,000 a year about $20. It is not a deterrent. It is a line item.
The economic relationship between CWM and Emelle is itself a function of inequality. Facilities handling the most dangerous industrial waste in the country are consistently sited in communities with the lowest property values and the least political representation. Those communities often receive promises of jobs and tax revenue in exchange for accepting proximity to industrial hazard. What they receive in regulatory protection β as this enforcement action demonstrates β is a fine that wouldn’t cover two months of a mid-level corporate manager’s salary.
The consent agreement explicitly states that “penalties paid pursuant to this CAFO shall not be deductible for purposes of federal taxes.” That clause exists because in previous regulatory regimes, corporations could deduct penalties as business expenses, making the public subsidize its own poisoning through the tax code. The fact that this had to be explicitly prohibited tells you exactly how the system operated before someone closed that loophole β and it tells you that the loophole existed in the first place because the system was designed for corporate convenience, not public protection.
The 17 page long consent agreement with Chemical Waste Management can be found on the EPA’s website: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/251D5DD6D3587BD785258B27003C73EA/$File/Chemical%20Waste%20Management,%20Inc.CAFO.5.23.24.TSCA-04-2024-6201(b).pdf
Explore by category
Product Safety Violations
When companies sell dangerous goods, consumers pay the price.
View Cases →Financial Fraud & Corruption
Lies, scams, and executive impunity that distort markets.
View Cases →


