Managing Hazardous Waste Amid Climate Risks: A Call for EPA Action
The U.S. Government Accountability Office (GAO) report GAO-25-106253 highlights critical vulnerabilities in hazardous waste treatment, storage, and disposal facilities (TSDFs) in light of climate change. More than 68% of these facilities are located in areas exposed to natural hazards such as flooding, wildfires, storm surges, and rising sea levels, all of which are intensifying due to climate change. These risks pose significant threats to both human health and the environment, necessitating stronger regulatory frameworks and proactive risk management.
The Environmental Protection Agency (EPA) oversees these facilities under the Resource Conservation and Recovery Act (RCRA), which governs hazardous waste management to prevent environmental contamination. While EPA has taken steps to address climate risks in permitting processes, its efforts remain limited in compliance and enforcement areas. For example, the agency issued guidance in June 2024 to help states and regions integrate climate considerations into TSDF permitting. However, many facilities and states are unlikely to act without explicit regulatory amendments that clarify their responsibilities.
EPA’s current challenges include the need for more comprehensive training and technical assistance to authorized states and facilities, as well as the development of clear guidance for assessing and managing climate risks. State and facility officials often struggle with identifying appropriate data and tools to evaluate these risks. To address these issues, GAO recommends that EPA enhance its training programs and assess the feasibility of issuing regulations to ensure consistent and effective management of climate risks across all regions.
The GAO’s analysis revealed that 743 of the 1,091 TSDFs studied are situated in areas prone to climate-related hazards. Flooding poses the most widespread threat, with over 500 facilities located in high-risk flood zones. This includes the potential for damage from extreme precipitation events that exceed the design standards of many facilities, potentially compromising hazardous waste containment systems. Similarly, nearly 400 TSDFs face wildfire risks, which can result in on-site fires, equipment overheating, and even explosions if ignitable materials are present.
Storm surges and sea level rise add further complexities. Around 185 facilities are located in areas susceptible to storm surges from Category 4 or 5 hurricanes, while 103 face threats from sea level rise projected to occur by 2100 under moderate climate scenarios. These conditions could undermine infrastructure and emergency response capabilities, increasing the likelihood of hazardous waste releases into the environment.
The EPA has the authority to mitigate these risks by amending RCRA regulations and ensuring that climate considerations are integrated into TSDF operations. For instance, regulations could mandate the use of updated climate projections for facility design and require contingency plans to address more severe weather events. These actions would align with the EPA’s broader climate adaptation goals outlined in its 2021 and 2024 Climate Adaptation Plans, which emphasize integrating climate resilience into regulatory frameworks.
However, implementing these changes requires addressing barriers such as funding constraints and coordination challenges between federal, state, and local agencies. GAO suggests leveraging existing programs, like FEMA’s Emergency Management Performance Grants, to support state efforts in incorporating climate adaptation measures. Additionally, fostering partnerships with stakeholders—including industry groups and environmental organizations—could enhance data sharing and innovative risk management solutions.
This blog post is for informational purposes only and does not constitute legal advice. Accuracy of the summarized content is not guaranteed.