UPS-BIRMINGHAM

EPA ECHO records index UPS-Birmingham as a single-facility entry under NAICS 492110 (Couriers and Express Delivery Services), assigned EPA Facility Registry ID 110003026430, with a most recent permit action dated May 29, 2025 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The quarterly noncompliance flag count across the trailing eight quarters is zero. Despite that clean flag record, the derived 24-month penalty allocation totals $2,120,000 — a 24-of-60-month proration of the parent entity's five-year monetary penalty exposure under the harness's stated derivation formula [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The dollar figure is an allocated share of parent-level settlements, not the product of a Birmingham-specific civil action.

That $2.12 million traces principally to two parent-level actions under the Resource Conservation and Recovery Act (RCRA). On June 16, 2021, EPA Region 6 issued a Consent Agreement and Final Order against United Parcel Service, Inc. and TForce Freight, Inc. The order required corrective action across 183 facilities in Arkansas, Louisiana, Oklahoma, New Mexico, and Texas, and assessed a $3.8 million civil penalty [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement]. Alabama lies outside Region 6's geographic jurisdiction. The Birmingham facility does not appear in the publicly released Region 6 location list [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement]. Sixteen months later, on October 19, 2022, EPA announced a second RCRA settlement — nationwide in scope — extending corrective compliance obligations beyond the original Region 6 perimeter [source: https://epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. Law360 placed the combined monetary value of the two RCRA actions at $5.3 million [source: https://www.law360.com/real-estate-authority/commercial/articles/154154].

The compliance record reviewed here centers on a single physical location: EPA Facility Registry ID 110003026430, Birmingham, Alabama, classified to NAICS 492110 (Couriers and Express Delivery Services) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. ECHO records show no active permits at the facility level, with a most recent permit action dated May 29, 2025 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The 24-month violation count of zero follows the harness rule: the lesser of quarterly noncompliance flags and eight quarters. The $2.12 million penalty figure is a 24/60 proration of five-year aggregate monetary penalties traceable to the parent organization, per the stated formula 'viol_24mo=min(qtrs_with_nc,8); penalty_24mo=total_5yr*(24/60)' [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The chronology underlying that derivation begins in mid-2021. On June 16, 2021, EPA Region 6 announced a Consent Agreement and Final Order with United Parcel Service, Inc. and TForce Freight, Inc. — covering 183 facilities across Arkansas, Louisiana, Oklahoma, New Mexico, and Texas — with a 24-month corrective compliance window and a civil penalty of $3.8 million [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement]. The accompanying CAFO document is on file with EPA's Office of Enforcement [source: https://www.epa.gov/enforcement/consent-agreement-and-final-order-ups]. Sixteen months later, on October 19, 2022, EPA announced a nationwide settlement extending compliance obligations beyond Region 6 to the broader UPS operating footprint [source: https://epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. Trade press placed the cumulative monetary value at $5.3 million [source: https://www.law360.com/real-estate-authority/commercial/articles/154154].

Through May 6, 2026, ECHO records show no new noncompliance quarter for UPS-Birmingham inside the 24-month window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $2.12 million figure therefore reflects allocated parent-level monetary exposure rather than fresh local enforcement. That distinction carries weight given the facility's metropolitan context: Birmingham's northern districts appear in peer-reviewed environmental-health literature as carrying long-running cumulative-impact concerns, among them the EPA-led 35th Avenue Superfund investigation [source: https://bb.uab.edu/soph/home/images/documents/news/Allen_et_al_2019_The_Search_for_Environmental_Justice_the_Story_of_North_Birmingham.pdf]. Inside Climate News reported in July 2020 on EPA's renewed cumulative-impacts attention to North Birmingham [source: https://insideclimatenews.org/news/1607202]. The EPA data field 'ej_index_avg' for this facility is reported as 0.0; the snapshot's empty top_pollutants array signals a null or unpopulated data state rather than a measured zero exposure — a data uncertainty analysts should flag when interpreting community exposure context [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Two federal enforcement actions sit upstream of the derived penalty figure for UPS-Birmingham.

(1) EPA Region 6 Consent Agreement and Final Order, announced June 16, 2021, In re United Parcel Service, Inc. and TForce Freight, Inc. — RCRA Subtitle C alleged violations involving hazardous waste handling across 183 facility locations in EPA Region 6 (AR, LA, OK, NM, TX). Civil penalty: $3,800,000. Compliance window: 24 months for corrective action across the cited locations. The respondents agreed to enhanced compliance programs to address the cited conduct [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement] [source: https://www.epa.gov/enforcement/consent-agreement-and-final-order-ups].

(2) Nationwide RCRA settlement, announced October 19, 2022 — alleged hazardous waste handling violations at UPS facilities outside Region 6, with a corrective compliance program structured to extend to the broader operating footprint [source: https://epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. Law360 placed the combined monetary component of the two RCRA actions at $5.3 million [source: https://www.law360.com/real-estate-authority/commercial/articles/154154]. Both actions proceeded under RCRA Subtitle C. No federal Clean Water Act (CWA) or Clean Air Act (CAA) civil action against UPS-Birmingham appears in the supplied research bundle.

The Birmingham facility was not listed individually in the publicly disclosed Region 6 location set, and ECHO records no Birmingham-specific local enforcement event inside the 24-month review window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The facility-level $2.12 million figure is a proration assignment from the two parent-level RCRA settlements — not the result of a discrete Alabama state action or a local CWA or CAA matter [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The dataset for this entity contains a single facility — EPA Facility Registry ID 110003026430, Birmingham, AL — so a conventional top-five facility ranking does not apply within the entity itself [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The nearest available proxy is a comparison against peer-set entities under NAICS 492110 indexed in ECHO under United Parcel Service legal-name variants, which together represent the largest concentration of monetary penalty allocation in the same NAICS bucket.

The top-ranked peer entity, UNITED PARCEL SERVICE INC (UPS), carries 11 indexed facilities. ECHO records 8 quarters of noncompliance flags inside the 24-month window and $10,640,000 in proratable penalty exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. This entity holds the highest violation count and dollar allocation in the peer set.

Second by allocation: UNITED PARCEL SERVICES, with 10 facilities, 6 quarters flagged, and $6,424,160 in 24-month penalty allocation [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Third: UNITED PARCEL SVC, indexed under the broader NAICS 49211 code, with 16 facilities, 6 quarters flagged, and $5,760,000 in penalty allocation [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. It carries the largest facility count in the comparator group.

The subject entity, UPS-BIRMINGHAM, records 1 facility, 0 quarters of noncompliance flags, and a $2,120,000 derived 24-month penalty allocation. The dollar figure traces to parent-entity settlements rather than a Birmingham-specific action [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip] [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement]. A fifth comparator at this NAICS level is absent from the supplied bundle; the ECHO peer benchmark for this brief stops at three legal-name variants plus the subject [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The 'top_pollutants' array for UPS-Birmingham in the supplied ECHO snapshot is empty [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That gap is a data-availability issue, not evidence of a non-emitting operation. NAICS 492110 (Couriers and Express Delivery Services) facilities typically generate three operationally salient pollution exposures, none reported individually in this bundle. The three categories below are framed using the parent-entity RCRA settlement record rather than facility-specific TRI or AFS data; that data uncertainty should be carried forward when downstream parties act on this brief.

First: hazardous waste streams under RCRA Subtitle C. The alleged violations underlying both the June 2021 Region 6 and October 2022 nationwide UPS settlements involved hazardous waste handling at courier and package facilities — specifically, damaged-shipment management and waste accumulation practices at sorting hubs [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement] [source: https://epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. Damaged packages containing batteries, solvents, paints, and other consumer hazardous products enter the RCRA waste stream at such facilities. Relevant waste codes include corrosives, ignitables, and listed hazardous waste. Primary exposure pathways are worker handling and fugitive releases at sorting and transfer points.

Second: diesel particulate matter and nitrogen oxides (NOx) from line-haul tractors and ground service equipment — characteristic of any large freight or courier hub in NAICS 492110. PM2.5 from diesel combustion is associated with respiratory and cardiovascular morbidity in proximate populations. Ambient air and near-roadway communities represent the primary exposure pathway. Cumulative-impact reporting on adjacent Birmingham census tracts documents community-health concern tied to diesel and combustion exposures in the metro [source: https://insideclimatenews.org/news/1607202].

Third: stormwater runoff under industrial NPDES coverage. Vehicle-yard runoff carrying hydrocarbons, sediment, and incidental hazardous-waste residue is the standard NAICS 492110 surface-water pathway. The absence of active permits flagged in the ECHO snapshot is itself a data point worth verifying directly via the EPA ECHO facility detail page; it should not be treated as a finished compliance determination [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The North Birmingham environmental-justice context is documented in peer-reviewed work by Allen et al. (2019) covering the 35th Avenue Superfund area and surrounding census blocks. That research records concentrated cumulative pollution burden in adjacent neighborhoods, independent of any single emitter [source: https://bb.uab.edu/soph/home/images/documents/news/Allen_et_al_2019_The_Search_for_Environmental_Justice_the_Story_of_North_Birmingham.pdf] [source: https://www.mdpi.com/1660-4601/16/12/2117]. Whether the UPS-Birmingham facility sits inside or adjacent to those documented census tracts is not resolvable from the empty ej_index_avg field in the supplied ECHO snapshot; analysts should verify against EJScreen directly [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The peer set under NAICS 492110 is dominated by three United Parcel Service legal-name entities in ECHO, jointly carrying 37 indexed facilities, 20 quarter-flags of noncompliance inside the 24-month window, and approximately $22.8 million in proratable monetary penalty exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. UPS-Birmingham — 1 facility, zero recorded quarter-flags inside the window — sits below the peer-set median on both noncompliance count and absolute dollar allocation. Its $2.12 million derived figure is disproportionately high relative to its single-facility status because the proration formula passes through parent-level monetary exposure from the June 2021 Region 6 and October 2022 nationwide RCRA settlements [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement] [source: https://epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. Per-facility 24-month penalty allocation ranks as follows: UPS-Birmingham at $2.12 million (1 facility); UNITED PARCEL SERVICE INC at approximately $967,000 (11 facilities); UNITED PARCEL SERVICES at approximately $642,000 (10 facilities); UNITED PARCEL SVC at $360,000 (16 facilities) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The reported ej_index_avg of 0.0 across all four entities is consistent with an unpopulated index field — not a measured EJ profile — and should not be read as a community-exposure finding [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The supplied research bundle contains an empty SEC 10-K block ({}) and an empty 10-Q block. The entity metadata lists Ticker as 'private' and CIK as 'N/A' for UPS-Birmingham specifically, so Item 1A risk-factor language cannot be quoted directly from a primary SEC filing inside this bundle. United Parcel Service, Inc. — the publicly traded parent — does file 10-K reports with the SEC, and Item 1A forward-looking environmental risk language for the parent is available at SEC EDGAR; that primary text is absent from the research bundle assembled for this brief. Any Item 1A statements would need to be retrieved directly from EDGAR rather than reconstructed from secondary sources. The 2024 UPS GRI Report, while not an SEC filing, contains a Cautionary Note Regarding Forward-Looking Statements accompanying risk-tagged language that includes 'will,' 'believe,' 'project,' 'expect,' 'estimate,' 'assume,' 'intend,' 'anticipate,' 'target,' and 'plan' [source: https://about.ups.com/content/dam/upsstories/images/our-impact/reporting/2024-UPS-GRI-Report.pdf]. Until the parent-company 10-K Item 1A is retrieved directly from EDGAR, this section flags the data gap rather than reciting unsourced risk-factor text.