EPA v. EXCEL, INC. d/b/a DHL SUPPLY CHAIN AND 3M COMPANY (DHL SUPPLY CHAIN)

Case summary

On February 5, 2020 the Regional Judicial Officer signed a Final Order ratifying a Consent Agreement between EPA and Exel Inc., d/b/a/ DHL Supply Chain (DHL) and 3M Company (3M). DHL owns and operates a warehouse located in Mechanicsburg, Pennsylvania. The Consent Agreement resolves alleged violations of RCRA C identified during a June 2018 EPA inspection of the DHL warehouse facility. The hazardous waste management regulations promulgated pursuant to RCRA Subtitle C provide for the management and transport of hazardous waste from the time and place of generation to its ultimate disposition at a RCRA treatment, storage or disposal facility. EPA routinely inspects hazardous waste generators for compliance with RCRA regulations in accordance with joint enforcement goals agreed upon by EPA and states authorized to implement RCRA C. The alleged violations of RCRA C resolved by the CAFO arose when material stored in the DHL warehouse by 3M became hazardous waste due to mishandling of product, resulting in spills and broken containers, expiration or a decision to discontinue use.

Defendants (2)

• 3M COMPANYNamed in complaintNamed in settlement
• EXCEL, INC. d/b/a DHL SUPPLY CHAINNamed in complaintNamed in settlement

Facilities (2)

• DHL SUPPLY CHAIN

  51 COMMERCE DR, MECHANICSBURG, PA, 17050

  Registry ID: 110070692767

• EXEL LOGISTICS

  245 SALEM CHURCH RD, MECHANICSBURG, PA, 17055

  Registry ID: 110060073021

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• EXCEL, INC. d/b/a DHL SUPPLY CHAIN AND 3M COMPANY (DHL SUPPLY CHAIN)entered 2020-02-05

  Primary law: RCRA

  Federal penalty: $74,360

Timeline (3 milestones)

• 2020-02-05Complaint Filed/Proposed Order
• 2020-02-05Final Order Issued
• 2020-02-27Enforcement Action Data Entered