AK STEEL A

AK Steel A, registered in EPA ECHO under a single facility ID (110070672270) with headquarters in Butler, Pennsylvania, now operates as a legacy corporate entity following its 2020 acquisition by Cleveland-Cliffs. ECHO data shows one active facility, zero quarters-with-noncompliance across the trailing 24 months, and $2.4 million in derived 24-month penalty exposure prorated from 5-year totals [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The NAICS code attached to the ECHO record — 211130, Natural Gas Extraction — is an apparent classification artifact. The actual operational footprint and the full enforcement history attach to integrated steelmaking and coke operations spread across Butler, PA; Middletown, OH; Ashland, KY; Dearborn, MI; and Coshocton, OH.

Two matters dominate the trailing 30-day news cycle, and they pull in opposite directions. On April 30, 2026, the U.S. Department of Justice lodged a proposed consent decree requiring $12 million in corrective measures at the Middletown Works — a 2,600-acre integrated mill operating continuously since 1901 — resolving a civil action originally filed against predecessor AK Steel Corporation and later joined by Ohio and environmental-group intervenors [source: https://insurancejournal.com/news/midwest/2026/04/30/867934.htm] [source: https://claimsjournal.com/news/national/2026/05/04/337287.htm]. That filing keeps Middletown squarely in the active enforcement column. Moving the other direction, a federal judge terminated the consent decree governing the former AK Steel Ashland Coke Plant after court-supervised cleanup of hazardous-waste contamination completed in 2022, closing roughly fourteen years of judicial oversight on that property along 40th Street and Winchester Avenue in Ashland, Kentucky [source: https://www.herald-dispatch.com/news/environmental-order-on-former-ak-steel-site-lifted/article_eaedea53-de63-43e7-ad51-61c9aaa97273.html]. Against that backdrop, University of Cincinnati researchers reported elevated arsenic concentrations in soil adjacent to the Middletown mill, with levels characterized as having worsened since prior sampling rounds [source: https://www.wcpo.com/news/local-news/finding-solutions/its-gotten-worse-researchers-at-uc-find-elevated-arsenic-levels-next-to-middletown-steel-mill]. The combination — a freshly lodged $12 million corrective-action commitment and a deteriorating fenceline arsenic signal — defines the current environmental risk profile for this asset cluster.

The AK Steel compliance file splits into two distinct tracks. The first is the ECHO record attached to facility 110070672270 in Butler, PA. The second is a longer docket of federal consent decrees covering legacy sites now carried by Cleveland-Cliffs as successor. ECHO reports zero quarters with noncompliance across the trailing 24 months at the Butler facility, with a derived 24-month penalty figure of $2.4 million prorated from the 5-year total using the standard ECHO exporter methodology — specifically, viol_24mo=min(qtrs_with_nc,8) and penalty_24mo=total_5yr*(24/60) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No active permits appear in the current snapshot. The most recent permit action on file carries a date of September 10, 2025 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The 24-month narrative is defined by two closure events at legacy sites, each worth examining in sequence. In 2022, court-ordered remediation completed at the former AK Steel Ashland Coke Plant in Ashland, Kentucky. The original complaint alleged violations of federal and state hazardous-waste regulations based on sampling conducted between 2010 and 2012. A federal judge lifted the consent decree in the first week of May 2026, ending approximately fourteen years of court supervision over that property [source: https://www.herald-dispatch.com/news/environmental-order-on-former-ak-steel-site-lifted/article_eaedea53-de63-43e7-ad51-61c9aaa97273.html]. Ashland is now closed. Middletown is not. On April 30, 2026, DOJ lodged a separate proposed consent decree at the Middletown Works committing $12 million to corrective measures across several site areas [source: https://insurancejournal.com/news/midwest/2026/04/30/867934.htm]. That case traces directly to the June 29, 2000 federal complaint in which DOJ, acting on behalf of EPA, sued AK Steel for RCRA, CAA, and CWA violations at Middletown, with Ohio subsequently joining as a party [source: https://www.justice.gov/archive/opa/pr/2000/June/376enrd.htm]. The litigation ran for more than 25 years before reaching the April 2026 proposed resolution.

Older actions remain material to the full chronology. A consent decree entered May 19, 2015, in U.S. v. AK Steel Corporation, Case No. 15-cv-11804 in the Eastern District of Michigan, was jointly prosecuted by the United States and the Michigan Department of Environmental Quality and governed air-program compliance at the Dearborn Works following its acquisition from Severstal [source: https://www.justice.gov/sites/default/files/enrd/pages/attachments/2015/05/19/env_enforcement-2523241-v1-ak_steel_lodged_decree.pdf]. Ohio EPA Director's Final Findings and Orders dated December 31, 2007, transmitted January 3, 2008, imposed obligations on the Coshocton facility under EPA ID OHD 004 294 567, including penalty payments referenced in Order paragraphs 9.a and 9.b [source: http://edocpub.epa.ohio.gov/publicportal/ViewDocument.aspx?docid=52127]. A December 2, 2004 settlement resolved hazardous-waste, air, and water allegations at the Butler mill for a $300,000 civil penalty plus $900,000 committed to supplemental pollution-reduction projects [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/64e88eb10f903452852570d60070feea.html]. EPA also ordered AK Steel on June 7, 2000 to reduce nitrate discharges and provide alternative drinking water to residents near the Butler works in Zelienople, PA, documenting a direct impact on a small municipal water system [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/47fa9262390cad85852570d60070fb44.html].

April 30, 2026 — Middletown Works (Middletown, OH), RCRA corrective-action track. DOJ lodged a proposed consent decree requiring $12 million in corrective measures addressing several site areas at the 2,600-acre integrated mill. The action provides final resolution of a civil lawsuit against predecessor AK Steel Corporation, later joined by the State of Ohio and environmental-group intervenors. Cleveland-Cliffs carries the obligation as successor [source: https://insurancejournal.com/news/midwest/2026/04/30/867934.htm] [source: https://claimsjournal.com/news/national/2026/05/04/337287.htm].

May 1, 2026 (reported) — former AK Steel Ashland Coke Plant (Ashland, KY), RCRA. A federal judge terminated the consent decree originally predicated on a September 2012 EPA order that required monitoring, testing, and analysis at four areas on the 40th Street and Winchester Avenue property abutting the Ohio River. The original complaint alleged federal and state hazardous-waste storage, management, and release violations documented by sampling between 2010 and 2012. Court-ordered cleanup completed in 2022. The plant was idled and demolished following Cleveland-Cliffs' 2020 acquisition [source: https://www.herald-dispatch.com/news/environmental-order-on-former-ak-steel-site-lifted/article_eaedea53-de63-43e7-ad51-61c9aaa97273.html].

May 19, 2015 — Dearborn Works (Dearborn, MI), multi-program. Consent decree lodged in U.S. and Michigan DEQ v. AK Steel Corporation, Civil Action No. 15-cv-11804 (E.D. Mich., Southern Division). Terms addressed air-program compliance at the facility acquired from Severstal [source: https://www.justice.gov/sites/default/files/enrd/pages/attachments/2015/05/19/env_enforcement-2523241-v1-ak_steel_lodged_decree.pdf].

December 31, 2007 — Coshocton Works (Coshocton, OH), RCRA. Ohio EPA Director's Final Findings and Orders issued against the facility under EPA ID OHD 004 294 567, transmitted January 3, 2008 to Senior Vice President David C. Horn. Orders included penalty invoices under paragraphs 9.a and 9.b [source: http://edocpub.epa.ohio.gov/publicportal/ViewDocument.aspx?docid=52127].

December 2, 2004 — Butler Works (Butler, PA), RCRA/CAA/CWA. Settlement imposed a $300,000 civil penalty plus $900,000 committed to pollution-reduction projects, resolving allegations of improper storage and disposal of baghouse dust and related air and water violations [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/64e88eb10f903452852570d60070feea.html].

June 29, 2000 — Middletown Works, originating federal complaint. DOJ, on behalf of EPA, sued AK Steel under CWA, CAA, and RCRA; Ohio moved to join [source: https://www.justice.gov/archive/opa/pr/2000/June/376enrd.htm]. June 7, 2000 — Butler Works, CWA/SDWA. EPA order required reduction of nitrate discharges and provision of safe drinking water for Zelienople residents [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/47fa9262390cad85852570d60070fb44.html].

Middletown Works (Middletown, OH) — 2,600 acres, operating since 1901. This facility anchors the 2026 consent decree committing $12 million to corrective measures and simultaneously sits at the center of adjacent-community arsenic sampling conducted by University of Cincinnati researchers. Those researchers characterized conditions as having worsened rather than improved since prior measurement rounds [source: https://claimsjournal.com/news/national/2026/05/04/337287.htm] [source: https://www.wcpo.com/news/local-news/finding-solutions/its-gotten-worse-researchers-at-uc-find-elevated-arsenic-levels-next-to-middletown-steel-mill]. Cleveland-Cliffs declined an on-camera interview and stated via spokesperson that the company has 'invested substantially' in environmental performance since the 2020 acquisition [source: https://www.wcpo.com/news/local-news/finding-solutions/its-gotten-worse-researchers-at-uc-find-elevated-arsenic-levels-next-to-middletown-steel-mill]. The $12 million corrective-measures commitment and the fenceline arsenic trend together make Middletown the highest-priority site in the portfolio for ongoing monitoring.

Butler Works (Butler, PA) — the facility tied to the ECHO record at issue (ID 110070672270) and to AK Steel A's headquarters address. EPA's historical corrective-action page for 'AK Steel Corporation (Armco) in Butler, Pennsylvania' catalogs the site's hazardous-waste posture [source: https://19january2021snapshot.epa.gov/hwcorrectiveactionsites/hazardous-waste-cleanup-ak-steel-corporation-armco-butler-pennsylvania_.html]. The 2004 settlement covered baghouse-dust mismanagement. The 2000 drinking-water order addressed nitrate impacts on the nearby Borough of Zelienople [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/64e88eb10f903452852570d60070feea.html] [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/47fa9262390cad85852570d60070fb44.html].

Ashland Coke Plant (Ashland, KY) — idled and demolished post-2020. The September 2012 EPA order, the ensuing civil action, and fourteen years of court supervision all ended with the May 2026 termination of the consent decree, following 2022 cleanup completion at the 40th Street and Winchester Avenue property [source: https://www.herald-dispatch.com/news/environmental-order-on-former-ak-steel-site-lifted/article_eaedea53-de63-43e7-ad51-61c9aaa97273.html].

Dearborn Works (Dearborn, MI) — governed by the 15-cv-11804 consent decree lodged May 19, 2015 in the Eastern District of Michigan, with the Michigan DEQ as co-plaintiff [source: https://www.justice.gov/sites/default/files/enrd/pages/attachments/2015/05/19/env_enforcement-2523241-v1-ak_steel_lodged_decree.pdf].

Coshocton Works (Coshocton, OH) — subject to Ohio EPA's December 31, 2007 Director's Final Findings and Orders under EPA ID OHD 004 294 567, with the penalty schedule set in Order paragraphs 9.a and 9.b [source: http://edocpub.epa.ohio.gov/publicportal/ViewDocument.aspx?docid=52127].

Arsenic is the pollutant drawing the most current attention. Classified by EPA as a Group A human carcinogen under the IRIS framework referenced in regulatory filings, arsenic appeared at elevated soil concentrations in University of Cincinnati sampling adjacent to the Middletown Works, with researchers describing a worsening trend relative to prior measurements. Exposure pathways at integrated-mill fencelines include soil ingestion, fugitive dust inhalation, and deposition in residential yards. The Middletown site borders residential neighborhoods directly, and community members have raised the matter with local media [source: https://www.wcpo.com/news/local-news/finding-solutions/its-gotten-worse-researchers-at-uc-find-elevated-arsenic-levels-next-to-middletown-steel-mill].

Baghouse dust and associated RCRA-listed hazardous wastes form a second pollutant category running through multiple enforcement actions. EPA's 2004 Butler settlement specifically alleged improper storage and disposal of baghouse dust generated at the plant — a waste stream that typically contains zinc, lead, cadmium, and chromium derived from steelmaking furnace off-gases [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/64e88eb10f903452852570d60070feea.html]. The June 29, 2000 Middletown complaint likewise cited RCRA violations tied to hazardous-waste releases into the surrounding environment [source: https://www.justice.gov/archive/opa/pr/2000/June/376enrd.htm]. Baghouse dust is not a single substance but a composite hazard; its metal content varies by furnace charge and scrap mix, which is why RCRA listing applies to the waste stream as a whole rather than to any single constituent.

Nitrate rounds out the pollutant picture via a CWA and SDWA pathway. The June 7, 2000 EPA order required AK Steel to reduce nitrate discharges from the Butler mill and to provide safe drinking water for Zelienople, PA residents, documenting a direct drinking-water impact on a small municipal system [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/47fa9262390cad85852570d60070fb44.html]. Nitrate concentrations above the 10 mg/L maximum contaminant level carry methemoglobinemia risk for infants — a pathway EPA has cited in comparable orders. Environmental-justice considerations attach wherever a small municipal system downgradient of an integrated mill depends on groundwater, as Zelienople did at the time of the order.

The NAICS peer set returned for code 211130 (Natural Gas Extraction) is a classification mismatch for an integrated-steel operator; the comparables surface upstream oil-and-gas facilities rather than steelmakers. Within that mismatched set, AK Steel A's ECHO-derived 24-month penalty total of $2.4 million ranks below all three listed peers, and its zero-quarter noncompliance count matches Greka Bell Compressor Plant while sitting below Red Hills Gas Processing Plant and HP Gas Pad, each of which recorded 8 quarters of noncompliance [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The comparison carries no operational meaning. Readers should treat the ECHO facility-level figure as reflecting the Butler, PA record only, with the larger liability profile carried on the consent-decree docket cited throughout this briefing [source: https://www.justice.gov/sites/default/files/enrd/pages/attachments/2015/05/19/env_enforcement-2523241-v1-ak_steel_lodged_decree.pdf].

No SEC 10-K or 10-Q was provided in the research bundle for AK Steel A. The company has been private since the March 2020 Cleveland-Cliffs acquisition, and no current CIK is attached to this record. Successor-parent disclosures sit outside the research bundle. Forward-looking environmental risk at the asset level is most directly evidenced by two open items: the $12 million Middletown corrective-measures commitment lodged April 30, 2026, and the community-monitoring arsenic trajectory reported at that fenceline, both of which remain active operational matters for the successor operator [source: https://insurancejournal.com/news/midwest/2026/04/30/867934.htm] [source: https://www.wcpo.com/news/local-news/finding-solutions/its-gotten-worse-researchers-at-uc-find-elevated-arsenic-levels-next-to-middletown-steel-mill]. Until the proposed Middletown consent decree receives final court approval and the fenceline arsenic data shows a sustained reversal, those two data points represent the clearest forward indicators available in the public record.