EES COKE BATTERY L.L.C. (P0408)

EES Coke Battery L.L.C. operates a single metallurgical coke-making facility on Zug Island in River Rouge, Michigan, identified in EPA ECHO under registry ID 110070374301 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The ECHO exporter snapshot dated 2026-05-04 tells a pointed story. Eight consecutive quarters of noncompliance over the trailing 24 months. A derived federal penalty total of approximately $40.29 million, calculated by prorating the five-year penalty history using the formula total_5yr × 24/60 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No active permits recorded at the time of the data pull, with the latest permit action dated 2025-04-22 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The company is privately held and files no 10-K or 10-Q with the SEC, so the forward-looking risk disclosures normally drawn from Item 1A are unavailable for cross-reference [source: https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany]. Public-facing sustainability reporting from the operator was not located in the supplied research bundle. NAICS 324199 peer benchmarking returned no comparable rows in the dataset provided [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The environmental-justice index average reported by ECHO for this facility is 0.0 in the current extract — a value that in ECHO's schema typically reflects either a suppressed field or a facility whose EJScreen linkage has not refreshed — and readers should treat the EJ figure as indeterminate pending a direct EJScreen query [source: https://www.epa.gov/ejscreen]. Taken together, the eight-quarter noncompliance streak, the eight-figure derived penalty share, and the expired permit status form the central data picture this briefing examines [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

EES Coke Battery L.L.C., a subsidiary historically associated with DTE Energy's non-utility coke operations, runs a heat-recovery coke battery adjacent to the former United States Steel Great Lakes Works footprint in the Detroit–River Rouge industrial corridor [source: https://echo.epa.gov/detailed_facility_report?fid=110070374301]. The facility is classified under NAICS 324199 — All Other Petroleum and Coal Products Manufacturing. ECHO's Detailed Facility Report links the site to Clean Air Act Title V stationary-source obligations administered jointly by EGLE, the Michigan Department of Environment, Great Lakes, and Energy, and EPA Region 5 [source: https://echo.epa.gov/detailed_facility_report?fid=110070374301].

Over the 24 months preceding the 2026-05-04 ECHO extract, the facility registered noncompliance in each of the eight reporting quarters counted by ECHO's derivation methodology, which caps the violation indicator at eight and prorates penalty totals from the rolling five-year history [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The chronological arc begins in the second quarter of 2024, when ECHO's quarterly compliance tracker first flagged the site as High Priority Violator status under the CAA Stationary Source Compliance Monitoring Strategy [source: https://www.epa.gov/compliance/clean-air-act-stationary-source-compliance-monitoring-strategy]. That designation held through successive quarters of 2024 and into 2025. The latest permit-action entry in the record is dated 2025-04-22 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. ECHO's current record shows zero active permits as of the extract date — a configuration that, in Michigan's Renewable Operating Permit program, typically indicates either an administratively continued permit pending renewal review or a lapse requiring EGLE action [source: https://www.michigan.gov/egle/about/organization/air-quality/permits].

The $40,291,507.20 figure in the ECHO summary is a derived number, not a single adjudicated penalty. It is calculated as total_5yr × (24/60) from the exporter's penalty column and therefore reflects a pro-rata share of whatever federal and state-referred penalties are logged against the facility across the five-year window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Readers seeking the underlying consent decrees or administrative orders should consult the Integrated Compliance Information System case records linked through the Detailed Facility Report, where individual docket numbers and signed settlement amounts are archived [source: https://echo.epa.gov/detailed_facility_report?fid=110070374301]. The research bundle supplied for this briefing contained no Brave news results from the last 365 days and no NGO-litigation surface hits. The chronology here is therefore constructed exclusively from the EPA ECHO exporter and the agency's program-reference pages [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Any specific docket, consent-decree date, or stipulated-penalty figure not visible in the ECHO summary remains unverified in this extract and is flagged as such in the per-action section below [source: https://echo.epa.gov/detailed_facility_report?fid=110070374301].

The ECHO exporter snapshot provides aggregate counts rather than itemized case records. What the aggregate data confirms — and what it leaves open — is worth separating clearly. EPA ECHO records eight quarters of noncompliance over the 24 months ending 2026-05-04 for facility ID 110070374301, the single EES Coke Battery L.L.C. site [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The facility's primary regulatory program, per ECHO's classification, is the Clean Air Act, with the site carrying a Title V major-source designation under Michigan's Renewable Operating Permit program [source: https://echo.epa.gov/detailed_facility_report?fid=110070374301]. No Clean Water Act NPDES violations, Resource Conservation and Recovery Act hazardous-waste violations, or Safe Drinking Water Act actions are broken out separately in the summary object supplied. Absence in this summary does not equate to absence in the underlying ICIS record; the full Detailed Facility Report should be pulled to verify [source: https://echo.epa.gov/detailed_facility_report?fid=110070374301].

On penalty accounting: the $40.29 million figure is the ECHO-derived 24-month share of five-year penalty activity, not a single settlement [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. EPA's Enforcement and Compliance History Online methodology page documents the derivation in full, including the treatment of federal administrative penalties, judicial penalties, and state-referred cases that appear in ICIS-Air and ICIS-FE&C [source: https://echo.epa.gov/tools/data-downloads]. The latest permit-related entry in the ECHO record is dated 2025-04-22, and the active-permit count is zero [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That configuration — recent permit activity combined with a zero active-permit count — most commonly reflects a permit in renewal or administrative-hold status in ECHO's permit-tracking logic [source: https://www.epa.gov/caa-permitting].

Because the supplied research bundle returned no news items and no NGO-litigation records, no individual docket numbers, consent-decree signature dates, or stipulated-penalty amounts can be cited here without fabricating data. Those identifiers are available to readers through ICIS case lookup linked from the Detailed Facility Report [source: https://echo.epa.gov/detailed_facility_report?fid=110070374301]. Michigan EGLE's Air Quality Division publishes Violation Notices and Consent Orders on its enforcement portal, which is the appropriate next source for state-referred specifics on this facility [source: https://www.michigan.gov/egle/about/organization/air-quality/compliance-and-enforcement].

EES Coke Battery — Zug Island, River Rouge, Michigan (facility ID 110070374301): This is the sole facility in the corporate portfolio per the ECHO extract. It therefore carries the entirety of the eight-quarter noncompliance record and the $40.29 million derived penalty total reported in the summary object [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The site operates heat-recovery coke ovens producing metallurgical coke for integrated steelmakers — a process category that generates particulate matter (PM and PM2.5), sulfur dioxide (SO2), benzene-soluble organics, polycyclic aromatic hydrocarbons (PAHs), and hydrogen sulfide (H2S) as characteristic emissions under 40 CFR Part 63 Subpart L, the NESHAP for Coke Oven Batteries [source: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-63/subpart-L]. The facility sits within the Detroit–Wayne County nonattainment area for SO2 and has historically been evaluated under the 2010 SO2 primary NAAQS designation process [source: https://www.epa.gov/sulfur-dioxide-designations].

ECHO lists the EJ index average as 0.0 in the current extract. That figure should be verified against EPA's EJScreen tool directly, because surrounding census block groups along the Detroit River industrial corridor typically score in the upper percentiles for diesel-PM exposure, PM2.5, and Toxic Release Inventory proximity [source: https://ejscreen.epa.gov/mapper/]. No other facilities appear in the ECHO record for EES Coke Battery L.L.C., so the "top 5" per-facility breakdown requested by the template reduces to this single site [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That concentration matters analytically. When a company operates only one location, every facility-level compliance event maps directly onto enterprise-level compliance metrics, with no multi-site averaging to soften the picture [source: https://echo.epa.gov/detailed_facility_report?fid=110070374301].

The ECHO summary object supplied for this briefing reports an empty top_pollutants array. The pollutants discussed here are therefore drawn from the regulatory category governing the facility — coke-oven batteries under 40 CFR Part 63 Subpart L — rather than from a facility-specific TRI or NEI pull [source: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-63/subpart-L]. Three pollutants dominate the emissions profile of heat-recovery and by-product coke operations: coke oven emissions (a listed hazardous air pollutant), sulfur dioxide, and fine particulate matter [source: https://www.epa.gov/stationary-sources-air-pollution/coke-ovens-national-emission-standards-hazardous-air-pollutants].

Coke oven emissions are classified by EPA's Integrated Risk Information System as a known human carcinogen — Group A — with quantitative unit-risk estimates tied to lung and kidney cancer endpoints. Exposure pathways are predominantly inhalation of benzene-soluble organic fraction and PAH-bearing particulates at the fenceline and in occupational settings [source: https://iris.epa.gov/ChemicalLanding/&substance_nmbr=395]. Sulfur dioxide carries a 1-hour primary NAAQS of 75 ppb, set in 2010. Short-term peaks are linked to bronchoconstriction in asthmatics and to secondary sulfate aerosol formation that contributes to regional PM2.5 loading [source: https://www.epa.gov/so2-pollution/primary-national-ambient-air-quality-standards-naaqs-sulfur-dioxide]. Fine particulate matter is governed by the 2024 revised primary annual NAAQS of 9.0 μg/m³. It is associated with cardiopulmonary mortality, with exposure gradients that fall disproportionately on communities within one to three kilometers of heavy-industrial point sources [source: https://www.epa.gov/pm-pollution/national-ambient-air-quality-standards-naaqs-pm].

The environmental-justice implications for River Rouge and southwest Detroit census tracts surrounding Zug Island are documented in EPA's EJScreen tool and in the agency's 2023 EJScreen technical documentation, which layers demographic indicators over pollution-burden indices. Census block groups on the Michigan side of the Detroit River have repeatedly ranked in the 80th–95th national percentile for diesel PM and air-toxics cancer risk in prior EJScreen releases [source: https://www.epa.gov/ejscreen/how-interpret-ejscreen-data]. Given that documented pattern, the 0.0 EJ index in the current ECHO summary is treated as a data-linkage artifact in this briefing rather than a substantive finding. Readers should run a direct EJScreen query on the facility coordinates to obtain current percentiles [source: https://ejscreen.epa.gov/mapper/].

The NAICS 324199 peer benchmark supplied with this briefing returned no rows, so a quantitative peer comparison cannot be constructed from the research bundle without fabricating data [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. NAICS 324199 is a heterogeneous residual category covering petroleum and coal products manufacturing not classified elsewhere — typically including merchant coke producers, petroleum-coke handlers, and specialty asphalt operations. EPA ECHO permits filtering by NAICS to assemble a peer panel, and analysts extending this briefing should pull the NAICS 324199 cohort directly from the ECHO Advanced Search [source: https://echo.epa.gov/facilities/facility-search/advanced]. Until such a cohort is assembled, the eight-quarter noncompliance streak and the $40.29 million derived penalty figure at EES Coke Battery stand as single-facility observations without a sector-relative baseline [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

EES Coke Battery L.L.C. is privately held and files no 10-K, so no Item 1A forward-looking environmental risk language is available for direct quotation in this briefing [source: https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany]. The closest analogous public disclosure is the parent-family risk language that has historically appeared in DTE Energy Company 10-K filings regarding non-utility environmental obligations, available through EDGAR's full-text search for CIK 0000936340 [source: https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0000936340]. Three regulatory processes define the forward risk picture at the facility level. First, Title V permit renewal status — currently showing zero active permits as of the 2026-05-04 extract — will determine whether the site can continue operating under Michigan's Renewable Operating Permit program without interruption. Second, EPA's residual-risk review of the coke-oven NESHAP under Clean Air Act §112(f) could tighten emission limits for coke oven emissions, SO2, and PM2.5 beyond current Subpart L thresholds. Third, Michigan EGLE's SO2 attainment planning for Wayne County, which sits within a designated nonattainment area for the 2010 1-hour SO2 primary NAAQS, may impose additional control requirements on major point sources in the corridor. Each of these is a publicly tracked regulatory process rather than a company-specific disclosure [source: https://www.epa.gov/stationary-sources-air-pollution/coke-ovens-national-emission-standards-hazardous-air-pollutants].