European Vinyls Corporation and INEOS at Hillhouse: the PVC plant, what it used and released, and how it closed

This page is one of a set of profiles of the companies that have operated on the Hillhouse site at Thornton-Cleveleys. It covers the plant that made PVC (polyvinyl chloride) from vinyl chloride, from ICI’s time to its closure in 2019, and the companies that ran it: European Vinyls Corporation (EVC), INEOS, and Vinnolit. The earlier ICI site as a whole, including the chlorine plant, is on the ICI page. The present landowner is on the NPL page.

Each statement below is attributed to the document it comes from. Where documents disagree, both accounts are given.

None of the documents about this plant that we read for this page mentions PFAS or PFOA. We searched the Environment Agency’s surrender documents, the 507-page site condition report and the 383-page environmental statement chapters prepared for the site’s next occupier, the EC decisions and the ICI register below for “PFAS”, “PFOA”, “perfluoro” and “polyfluoro”, with no match. This page makes no connection between this plant and PFAS.

The short version

What it made: paste (emulsion) PVC, a grade used, in EVC’s words, for “flooring and wallcoverings” and in “consumer goods, industrial and automotive applications, coated fabrics, sealants”. The raw material was vinyl chloride, delivered to the plant.
Who ran it: ICI; then European Vinyls Corporation, the ICI and EniChem joint venture that began operating on 1 October 1986 (the EC decision recording that date does not name Hillhouse, and a 2024 consultants’ report dates the transfer at Hillhouse to 1995); then INEOS, which held 75.3% of EVC by December 2002 and replaced the EVC names with its own in 2005; then Vinnolit, after a sale announced and cleared in 2007, with its permit issued on 2 September 2008.
What it released: the Pollution Inventory datasets the Environment Agency publishes on data.gov.uk cover 2013 onwards. They contain Vinnolit’s figures for 2013 to 2019: vinyl chloride releases to air of 26,400 kg in 2013, falling to 11,300 kg in 2019, and to water of between 12.4 kg and 69 kg a year.
How it ended: production stopped in August 2019. The Environment Agency accepted the surrender of the permit, taking effect from 26 October 2021, after soil sampling at six points.
What is not known: what the plant released before 2013, and what the ground and groundwater beneath the former plant contain.

Who ran the plant

Date	Operator or owner, as each record names it	Source
1977	ICI announces “a new PVC plant at Hillhouse”, to “come on stream in 1979”	Hansard, 3 February 1977
1 October 1986	European Vinyls Corporation, a 50/50 joint venture of EniChem and ICI, begins operating. The decision does not name Hillhouse, and says the parent companies “retain the ownership of the plants”	EC Decision 88/87/EEC
1995	The site “transferred to European Vinyls (UK) Limited”; “According to available information the first authorised permit for the Site operations was recorded as AP7563. This was authorised for European Vinyls (UK) Limited in February 1995”	Smith Grant LLP, 2024
By 12 December 2002	INEOS holds 75.3% of EVC	INEOS, 12 December 2002
2005	European Vinyls Corporation (UK) Limited renamed INEOS Vinyls UK Ltd. The business is described as INEOS ChlorVinyls in 2007	Companies House; ChemEurope, 29 June 2005 and 23 May 2007
2007 to 2008	Sale to Vinnolit announced (May 2007) and cleared by the European Commission (26 June 2007). Smith Grant says Vinnolit took over “in around 2008”; the permit for the plant was issued to Vinnolit Hillhouse Ltd on 2 September 2008	ChemEurope; EC case M.4572; Smith Grant LLP, 2024
August 2019	Production stops	Vinnolit site condition report

ICI. Hansard records the Secretary of State for Employment telling the Commons on 3 February 1977 of “the decision announced on Friday by ICI to invest £25 million on a new PVC plant at Hillhouse near Blackpool”, a plant “which will come on stream in 1979 and increase the ICI’s capacity to 350,000 tons a year”. The 350,000-ton figure is ICI’s total PVC capacity, not this plant’s. The minister put the jobs at “90 permanent jobs”.

The consultants who assessed the site in 2024 for its next occupier, Smith Grant LLP, call it “PVC 9 Plant (originally known as CORVIC 9)” and write: “It is understood that industrial operations on Site commenced in the late 1970s and continued until 2020.” The applicant’s environmental statement gives the period as “between 1980 and 2020”. Neither document, nor any other listed in this page’s sources, says whether PVC9 is the plant announced in 1977.

European Vinyls Corporation. The European Commission’s decision of 22 December 1987 describes the agreement, signed on 12 February 1986, under which “EVC is set up as a 50/50 jointly-owned enterprise” of EniChem and ICI, “to operate for at least five years from 1 October 1986”. It covered the two companies’ “interests in VCM and all forms of PVC”. The decision says the parents kept ownership of the plants: “For legal and business reasons, however, the parent companies retain the ownership of the plants”, and “the local EVC operating companies fully manage the plants under production service agreements with the parent companies”. It also says: “None of Enichem’s or ICI’s chlorine or ethylene manufacturing facilities are to be dedicated to EVC.” The decision does not name Hillhouse; we searched its text for “Hillhouse”, “Thornton” and “Blackpool”.

The UK operating company was European Vinyls Corporation (UK) Limited. Companies House shows company 00547640 under that name from 12 June 1986 to 30 June 2005; it had been incorporated in 1955 under another name. The register records the company’s names, not where it operated. Smith Grant gives a later date for Hillhouse: “The Site was initially operated by ICI Chemicals Limited and then in 1995 this transferred to European Vinyls (UK) Limited.” It says that “According to available information the first authorised permit for the Site operations was recorded as AP7563. This was authorised for European Vinyls (UK) Limited in February 1995 under the Environmental Protection Act 1990”. Wyre Council’s planning register shows European Vinyls Corporation (UK) as the applicant in 1997 for a stack at “ICI HILLHOUSE” (below). None of the documents listed in this page’s sources reconciles the 1987 decision (EVC managing plants that its parents still owned) with Smith Grant’s 1995 date.

EVC’s own website, in figures “last updated on 02 February 2000”, listed Hillhouse as an E-PVC (emulsion PVC) site of 45 kilotonnes a year, with no VCM (vinyl chloride monomer) production. Its other UK VCM and PVC sites were Runcorn (VCM and suspension PVC) and Barry (suspension PVC).

INEOS. A release by INEOS and Hawkslease of 12 December 2002 states that “The INEOS group presently holds a 75.3% interest in EVC”, acquired “by a series of public and private transactions”. ChemEurope reported on 29 June 2005 that “With effect from 1 July 2005 the EVC name will be changed to the INEOS name”, listing European Vinyls Corporation (UK) Limited as becoming INEOS Vinyls UK Ltd. Companies House shows the old name in use until 30 June 2005. By 2007 the trade press and the EC refer to the business as INEOS ChlorVinyls or “Ineos CV”. A Groundsure database extract in the 2024 site condition report lists permit EPR/BU5534IQ for the “PVC9 Plant”, held by INEOS Vinyls UK Limited and issued on 22 January 2007; Smith Grant describes it as a Part A(1) industrial installation permit.

INEOS Vinyls UK Ltd was put into a members’ voluntary winding up on 17 June 2021, with a declaration of solvency, and was dissolved on 30 April 2023 (Companies House filing history). Its filings in 2021 record Inovyn ChlorVinyls Holdings Limited as a person with significant control.

Sale to Vinnolit. On 23 May 2007 ChemEurope reported that INEOS ChlorVinyls had announced it was to sell its E-PVC business to Vinnolit GmbH & Co. KG, including “production facilities at Hillhouse (UK) and Schkopau (Germany)”. The European Commission cleared the purchase on 26 June 2007, describing it as Vinnolit acquiring “sole control of part of INEOS Vinyls Ltd. (INEOS CV Specialty PVC Business) by way of purchase of assets”, which included “Ineos CV’s specialty PVC production facilities at Hillhouse (UK) and Schkopau (Germany)”. None of the documents listed in this page’s sources gives the date the sale completed. Smith Grant writes that “Ineos Vinyls UK Ltd took over operations in around 2007” with Vinnolit Hillhouse Limited “taking over in around 2008”, and that the Environment Agency permit for the plant, EPR/TP3833GG, was issued to Vinnolit Hillhouse Ltd on 2 September 2008. By 2020 Vinnolit was part of Westlake Group: NPL Group (1 September 2020) names the seller of the closed plant as “Vinnolit GmbH (part of Westlake Group)”.

What was made

Paste PVC. EVC described its E-PVC business in 2000 as “Western Europe’s major manufacturer of Paste PVC with a capacity of 160 Kilotonnes per annum”, spread over “three plants in Germany, Italy and the United Kingdom”. Hillhouse was the UK plant, at 45 kilotonnes a year. The 2007 EC decision describes the Hillhouse and Schkopau plants as “specialty PVC production facilities”, and says that paste PVC “accounts for approximately 10% of total PVC”.

The process, as Smith Grant describes it from documents provided to it, including an ICI Chemicals and Polymers document of 8 September 1993, “PVC Plant – An Introduction”:

“the mixing and polymerisation of liquid vinyl chloride monomer (VCM) to produce polyvinyl chloride (PVC)”;
the VCM “was delivered by tanker via the VCM off-loading area located in the southwest of the Site and then pumped across the Brook in aboveground pipes and gantries to the main Site”;
“There was also an aboveground pipeline which carried liquid PVC monomer (VCM) to the Site from the VC4 Plant.” The report does not say where the VC4 plant was or who ran it;
unreacted VCM was stripped from the product with steam and “sent to the VCM gas holder”, and “Unreacted VCM in addition to residual PVC was used in future processing”;
“Granular PVC powder was produced and milled with four main types of PVC being produced on Site”.

Chlorine and chlor-alkali. None of the plant documents listed in this page’s sources (the EA surrender documents, the Smith Grant report, the EC decisions and EVC’s web pages) describes chlorine or caustic soda production by EVC, INEOS or Vinnolit at Hillhouse. ICI’s chlorine plant is on the ICI page. The 1987 EC decision states that none of ICI’s chlorine facilities were to be dedicated to EVC.

Vinyl chloride production. EVC’s 2000 capacity table lists no VCM production at Hillhouse. Whether VCM was made anywhere on the Hillhouse estate at any time, including at the “VC4 Plant” Smith Grant names, is not established by the documents listed in this page’s sources.

Substances used and released

Vinyl chloride. Vinyl chloride is classified by the International Agency for Research on Cancer as “carcinogenic to humans (Group 1)”, on human evidence that has “substantiated the causal association between vinyl chloride and angiosarcoma of the liver” (IARC Supplement 7, 1987).

The plant held hazardous substances consent. Groundsure lists a historical consent entry with an application date of 19 October 1992 for “Vinyl Chloride (250 tonnes)”, with an address beginning “Vinnolit pka European Vinyls Corporation (UK) Ltd, PVC 9”. The entry does not name the applicant; Vinnolit’s UK company was not incorporated until 2007. Wyre Council’s planning register records a further “Application for hazardous substance consent” for the “PVC 9 Plant”, 04/01410/HAZ, received on 22 November 2004 and permitted on 26 January 2005; Groundsure lists its substance as “Vinyl Chloride”, and Smith Grant describes it as relating to “the storage and processing of VCM”.

Annual releases, 2013 to 2019. The Pollution Inventory datasets the Environment Agency publishes on data.gov.uk cover 2013 onwards. Their rows for permit TP3833GG (Vinnolit Hillhouse Limited) give these releases. They are figures reported by the operator; the dataset does not say whether each was measured, calculated or estimated.

Year	Vinyl chloride to air (kg)	Vinyl chloride to controlled waters (kg)	Non-methane volatile organic compounds to air (kg)
2013	26,400	69	34,100
2014	25,600	41.9	33,500
2015	24,200	31.2	34,500
2016	23,000	34.6	32,100
2017	20,700	47.1	32,170
2018	17,900	42.8	26,100
2019	11,300	12.4	16,100

The reporting threshold is 1,000 kg a year for vinyl chloride to air and 1 kg a year to water. In every year in which the inventory lists them, the plant’s releases of 1,2-dichloroethane (ethylene dichloride, EDC) to air and water, and of mercury to water, are recorded as “below reporting threshold”. In 2013 to 2017 it also reported “Halogenated organic compounds - as AOX” to water of 1,940 kg, 3,210 kg, 2,810 kg, 2,980 kg and 1,140 kg; in 2018 and 2019 these were “Below Reporting Threshold”. The 2020 dataset has no rows for the permit. The inventory does not name the receiving water.

Before 2013. The Pollution Inventory replaced the Chemical Release Inventory in 1998, according to the dataset’s description, but the downloadable datasets begin in 2013 and so contain no annual figures for the EVC or INEOS years. We have not established whether earlier figures are published elsewhere.

Discharges to water. Smith Grant describes the process water route: “Process water was sent to the effluent treatment tank for treatment and further stripping processes before it was discharged to a settling lagoon and then to the adjacent discharge point to the Royles Brook and River Wyre. The settling lagoon was no longer used from around 2003 and was located off Site.” Under Vinnolit’s permit, as Smith Grant summarises it, discharges to the River Wyre were monitored for VCM, chemical oxygen demand, suspended solids, mercury (“0.05mg/l (0.1kg annually)”), temperature, pH and flow, while the discharge to Royles Brook was “Uncontaminated storm water from main plant areas”, with “No parameters set”. It adds that under the previous permit “dichloroethane was monitored with an associated limits of: MAC 5 mg/l and 2mg/l as AA” (maximum admissible concentration and annual average), and that “The results of monitoring undertaken have not been provided for review.”

The Groundsure extract lists “List 1 Dangerous Substances” discharges to the Wyre estuary. They include, all marked “Not Active”, “European Vinyls Corporation (uk) Ltd - Treatment Plant” authorised for “Carbon tetrachloride, Chloroform, 1,2-dichloroethane”, and “European Vinyls Corporation (uk) Ltd” for “1,2-dichloroethane”. Groundsure places these about 470 m west of the former PVC9 site and does not say which plant they served. It also lists “Ineos Vinyls Uk Limited, Pvc9 Plant” for “Mercury (other)”, marked “Active” as at 1 December 2023. On mercury, Smith Grant states: “It is understood that mercury was not used as a catalyst within the processing on the Site but this occurred on other areas of the Hillhouse Site up until 1993.”

Smith Grant also gives a figure for discharges, without saying which year it describes or which document it comes from: “The process generated a total of 454.2 tonnes (t) of aqueous discharges within 430,000 tonnes (m3) of water per year. Aqueous discharge included 2.5t free ammonia, 0.22t chromates, 0.25t lauroyl peroxide, 0.2t sodium hydroxide, 1t lubricating oils, 0.93t methyl styrene 6.8t active matter surfactant plus 431.1t VC and 6.8t VCM to plant drains.” The report does not define “VC” as distinct from “VCM”. Elsewhere it uses “VC” both for the gas and for the solid “pebbles” formed in the autoclaves.

Emissions to air, as Smith Grant lists them: “VCM gas, PVC, methane, carbon dioxide, nitrogen, nitrous oxides (NOx), sulphur dioxide (SOx), carbon monoxide, chlorine gas, ammonia gas, water vapour and active matter surfactant.” Wyre Council’s planning register records application 97/00731, received on 26 September 1997 from “EUROPEAN VINYLS CORPORATION (UK)” at “ICI HILLHOUSE”, for the “ERECTION OF 46M HIGH CHIMNEY GAS TURBINE EXHAUST STACK AND EXTERNAL PLANT AND EQUIPMENT”, permitted on 22 December 1997.

Other process chemicals named by Smith Grant include ammonium persulphate, aqueous ammonia, ammonium myristate, ascorbic acid, sodium sulphite, copper sulphate, emulsifiers, lauroyl peroxide, “Synperonic NP5 (viscosity depressant)” and “Empimin OT (contains ethanol)”. Vinnolit’s site condition report adds “Ammonia and Kristol used in the Recovery Plant”.

Incidents, enforcement and worker health

Liver cancer register. A “World Register of Cases of Angiosarcoma of the Liver (ASL)”, with a review date of 1 January 1988 and collated by the Occupational Health Department of ICI Chemicals and Polymers Limited at the Hillhouse site, records cases of the rare liver cancer linked to vinyl chloride. Its Table 3, “Pattern of ASL Cases by Factory”, attributes three cases to “ICI, Hillhouse, UK”. Hillhouse is one of 12 factories listed under the register’s statement that “Of the 79 cases in W Europe, 68 have occurred in clusters at 12 factories.” Its Table 8, of western European PVC producers, lists “ICI/EVC Hillhouse” against the same three cases. The register uses the same “ICI/EVC” label for ICI’s Runcorn plant, which it records as “Closed 1948”, so the label is the company name at the time of the register and does not show who employed the workers when they were exposed. EVC began operating in October 1986 (EC Decision 88/87/EEC). The register is held in the ToxicDocs archive of industry documents (Bates CMA 009941 to CMA 010004); we use only its counts.

Pollution incidents. Vinnolit’s site condition report says “there have been no significant or reportable pollution incidents during the term of the permit”, and that a search of its incident database “concludes that there were no significant or notifiable releases”. The Groundsure extract records no pollution incident on the site itself. It records two within 250 m, on 1 January 2005 (water impact “Category 2 (Significant)”) and 28 August 2018 (“Significant impact to land”); Smith Grant states that “The Polluter in this instance is unknown”.

Prosecutions. The Environment Agency’s prosecutions dataset lists charges in cases that ended in a conviction. The publisher describes its coverage as cases completed from January 2000; its rows are dated 29 April 1998 to 29 January 2025. Searched by defendant name, it has no entry for “European Vinyls”, “EVC”, “INEOS Vinyls”, “Vinnolit” or “Westlake”. A search for “Thames Water” returned 143 rows, which shows the search works. The dataset records convictions only, so it cannot show whether there was any prosecution that did not end in conviction, or any enforcement before its start date.

We could not search the Health and Safety Executive’s public register of convictions and notices: it could not be reached from our connection on 14 October 2026. Hansard, searched through TheyWorkForYou on 14 October 2026 for “Hillhouse PVC”, “Hillhouse vinyl”, “EVC Hillhouse”, “European Vinyls Corporation” and “Vinnolit”, returns only the 1977 debate quoted above.

Closure, decommissioning and the land

Closure. Vinnolit’s site condition report states: “The site ceased operation in August 2019.” NPL Group announced on 1 September 2020 that it had completed “the acquisition of the former PVC Plant at Hillhouse Enterprise Zone” from Vinnolit GmbH, a plant “formally closed in 2019”, including “environmental liability transfer including the transfer of all permits and authorisations”. The Economic Prosperity Board report of 7 December 2023 gives a different year: “Majority landowner NPL Estates acquired the vacant property of the former Vinnolit site in 2022.” More on this is on the NPL page.

Decommissioning, in Vinnolit’s account. The site condition report describes the steps:

a “final batch” was run “to use up the remaining Vinyl Chloride (VCM) as this is difficult to dispose of”;
pipework and tanks were flushed with water, and “All contaminated water was either processed through the site Waste Water Treatment system and ETP or collected and disposed of as waste”;
“The residual VCM gas that could not be processed was held in the gas holder. There is no practical way to recover or remove this remaining material. Following discussion with the EA, it was diluted and vented to atmosphere over a long period, within the emission limits for the site, as per the relevant guidance.” The report gives no quantity;
once drainage had been cleaned, “It was agreed at this point with the EA Inspector that the drains could be treated as ‘surface water drains’ and the drains were diverted to a surface water outfall.”

It concludes that “During the decommissioning process there were no significant releases of contaminants to land, water or air”, and quotes an Environment Agency inspection (compliance assessment report TP3833GG/0371998): “There were no signs of any chemicals on the site … There is no reason to predict any future ground and groundwater contamination from the permitted activities including the plant demolition activity in future.” The site condition report dates the inspection 26 August 2020; the Agency’s decision document dates the report 3 September 2020.

Permit surrender. The Environment Agency’s letter of 11 November 2021 accepts the surrender of permit EPR/TP3833GG, “which takes effect from 26/10/2021” (published 12 November 2021). Its decision document records the basis: “Six sampling points have been considered and coincide with the points sampled in 1998. The parameters analysed (sampled in May 2021) are pH, sulphite, copper, sulphate, ethanol and vinyl chloride.” Copper was higher than in 1998 at two pits (14 and 16 mg/kg against 8.4 and 6.9 mg/kg), which the Agency considered “within the natural range”; “All other parameters are below the values obtained in the 1998 study.” The analyte list does not include 1,2-dichloroethane, other chlorinated solvents or mercury. The site condition report states: “There is no groundwater reference data”, and “Water quality monitoring was not deemed to be necessary.”

The soil results, the soil sampling strategy, the 2006 site report and the desktop study are referred to in the site condition report as separate files. They are not among the three documents on the Agency’s surrender publication page.

Demolition. Smith Grant says demolition “to slab level occurred thereafter between 1st October 2020 and 8th July 2021” under Wyre permission 20/00945/DEM, and that “It is understood that the investigation, assessment and remediation (with associated validation) of soils and shallow groundwater was not undertaken as part of the decommissioning and demolition works.” Of the effluent treatment plant, it says its “underground chambered pit” was infilled in 2020 and “It is understood that this decommissioning operation was not validated for establishing the presence of residual contamination.” The applicant’s environmental statement gives demolition dates of “between October 2020 and May 2022”.

The land now. The site is proposed for an incinerator bottom ash processing facility by Fortis IBA Limited (Environment Agency permit application EPR/RP3723LG, consulted on from 8 January to 5 February 2025). Its environmental statement lists possible contamination from “40yrs operation of the Site as a plastics powder manufacturer”, including “Volatile organic compounds (VOCs)”, “Chlorinated solvents” and “Heavy metals including copper, cadmium, mercury”, and says “A detailed site investigation would be undertaken prior to the start of construction works”. The results of such an investigation are not among the 25 documents on the Agency’s consultation page.

What today’s investigations say

The Environment Agency’s surface water investigation. The Agency’s July 2025 summary describes sampling by WSP at 13 locations on Royles Brook, Hillylaid Pools and the Wyre estuary as “part of an ongoing investigation into potential historical chemical releases from the AGCCE Ltd facility, part of the former ICI Ltd complex”. It states: “Samples were taken upstream and downstream of the facility.” It reports that “VOCs (volatile organic compounds) were primarily found in downstream Royles Brook samples, with peak concentrations of TCE (346 µg/l), cis-1,2-DCE (285 µg/l), and vinyl chloride (45.6 µg/l)”, and “Marginal exceedances for mercury … at two locations on Hillylaid Pools and Royles Brook”. It does not identify a source: “the source and mechanisms of transport are not yet fully understood. Groundwater data from the area is needed”. The summary does not mention the PVC plant, and none of the documents listed in this page’s sources ties these findings to it.

AGC’s investigation. AGC Chemicals Europe says its voluntary investigation, “within the boundaries of land owned by AGCCE”, has been extended to substances “unrelated to fluoropolymer manufacture that may be present from historical activity within or adjacent to AGCCE boundaries”, including “chlorinated solvents and heavy metals, notably mercury from historical chlorine manufacturing activities”. The page does not mention PVC or vinyl chloride, and publishes no results (retrieved 12 October 2026).

Soil and eggs. The laboratory analyses in WSP’s reports for the Environment Agency on residential soils (Phase 3, March 2026) and on soil at the Sandringham Avenue allotments (June 2026) were for PFAS, soil organic matter and pH, and the egg analysis was for four PFAS. None included vinyl chloride or chlorinated solvents, so those programmes say nothing either way about them.

What we do not know

What the plant released before 2013. The downloadable Pollution Inventory datasets begin in 2013, and the 2024 consultants write that “The results of monitoring undertaken have not been provided for review”. Records of the EVC and INEOS years would answer this.
What the ground and groundwater beneath the former plant contain. The surrender report states “There is no groundwater reference data”, and the 2021 soil sampling covered six points and six parameters. The results of the site investigation proposed for the Fortis facility are not among the documents on the Agency’s consultation page.
The soil data behind the surrender. The May 2021 and 1998 results, the soil sampling strategy and the desktop study are named in the site condition report but are not among the three documents on the Agency’s surrender publication page. They can be requested from the Environment Agency.
How much vinyl chloride was vented during decommissioning. The site condition report says “Records of this process are available for inspection” but gives no quantity.
When the sale to Vinnolit completed, and when EVC took over at Hillhouse. The listed sources do not establish the sale’s completion date: it was announced and cleared in 2007, and Smith Grant dates Vinnolit’s takeover to around 2008. Nor do they reconcile EVC’s start in October 1986, in an EC decision that does not name Hillhouse, with Smith Grant’s 1995 date for the transfer at Hillhouse.
Where the “VC4 Plant” was, and whether VCM was ever made on the estate.
Enforcement under the Health and Safety Executive. The HSE register could not be searched for this page.
Where the solid wastes went. Smith Grant says solid wastes “were collected, temporarily stored and then sent off Site to landfill”; the Pollution Inventory waste returns for 2019 list disposal operations but not the receiving sites.