On March 6, 2026, the U.S. Environmental Protection Agency filed a Consent Agreement and Final Order against ALCO Products, LLC, a roofing materials manufacturer operating at 580 Old St. Jean Street in Detroit, Michigan. The settlement closed an enforcement case documenting nearly a decade of systematic Clean Air Act violations at a facility manufacturing asphalt shingles and roll roofing in a residential area.

ALCO Products never performed the emission testing federal law required. The company never filed compliance reports with regulators. It never established operating parameter monitoring plans. For years, it operated two asphalt coating lines—one built in 1999, another in 2016—without any of the hazardous air pollutant controls or documentation mandated by the National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart 7A.

When EPA inspectors finally arrived in August 2022, they found a facility producing asphalt roofing products with no records, no testing protocols, and no emission controls. The company was releasing polycyclic aromatic hydrocarbons (PAH) (a class of carcinogenic compounds formed during asphalt processing) into the air around homes and schools without any measurement or mitigation.

Opacity testing conducted in 2023 under EPA order revealed visible emissions 12 times the legal standard at the sand storage silo and 5 times the standard at the black mag silo. These are not abstract regulatory thresholds. Opacity measures how much light pollution blocks. A 12.3% reading means thick, visible plumes of particulate matter drifting into the neighborhood. The legal limit is 1%.

The Non-Financial Ledger

No one died in this case, according to the public record. No worker was hospitalized for acute poisoning. There are no wrongful death claims attached to Docket No. CAA-05-2026-0010. That absence is not evidence of safety. It is evidence of how environmental harm accumulates slowly, invisibly, in lung tissue and bloodstream, in childhood asthma rates and elevated cancer risk, in outcomes that take decades to manifest and are nearly impossible to trace to a single source.

Polycyclic aromatic hydrocarbons are not an obscure hazard. The EPA classifies PAH exposure as a cancer risk. Chronic inhalation is linked to respiratory disease, cardiovascular damage, and developmental harm in children. These are the chemicals released when asphalt is heated and processed. ALCO Products was heating and processing asphalt at two separate coating lines, at scale, for commercial roofing production, in a city neighborhood, without testing what came out of the stacks.

The consent decree identifies the facility’s affected sources: Line 1, a newer asphalt coater constructed in 2016; Line 2, an older coater built in 1999; a sand storage silo; and a black mag storage silo. None of these units used pollution control devices. All were subject to NESHAP 7A regulations requiring emission testing, operating parameter documentation, and regular compliance reporting. None of that happened.

For residents living downwind of 580 Old St. Jean Street, the absence of testing meant the absence of knowledge. There was no public data on what they were breathing. No monitoring reports. No compliance filings. The plant operated in a regulatory shadow, and the people nearest to it had no way to know what it was putting into the air they shared.

“You can’t claim compliance when you refuse to measure what you’re emitting.”

This is the non-financial ledger: the years of exposure without disclosure, the childhood years spent living next to an unmonitored industrial polluter, the累积 cumulative dose of carcinogens inhaled during a morning walk or a backyard barbecue. ALCO Products didn’t just violate the Clean Air Act. It denied an entire community the right to informed coexistence with industrial activity.

Legal Receipts

The consent decree filed with EPA Region 5 is not ambiguous. It lists 17 separate alleged violations, each tied to a specific regulatory requirement ALCO Products failed to meet. These are not disputed facts—ALCO signed the agreement and admitted jurisdiction. The company neither admitted nor denied the violations, but it consented to the penalty and waived appeal rights.

Paragraph 91, Consent Agreement: “In violation of the NSPS Subpart UU, 40 C.F.R. § 60.8, ALCO has failed to conduct performance tests and to furnish the Administrator with a written report of the results of the performance tests at its NSPS UU affected facilities Line 1, Line 2, the sand silo, and the black mag silo, within 60 days after achieving the maximum production rate at which the affected facility will be operated, but not later than 180 days after initial startup of such facility.”

The regulation is clear: within 180 days of startup, you test your emissions and report the results. Line 2 started in 1999. Line 1 started in 2016. ALCO conducted its first emissions tests in April 2023, under EPA compulsion, after a Section 114 information request issued in October 2022. That is 24 years late for Line 2 and 7 years late for Line 1.

Paragraph 94, Consent Agreement: “In violation of NSPS Subpart UU, 40 C.F.R. § 63.11560(a), ALCO’s Line 2 was not in compliance with the applicable provisions of NESHAP 7A by December 2, 2010.”

NESHAP 7A took effect for existing asphalt roofing sources on December 2, 2010. ALCO’s Line 2, as an existing source, was required to demonstrate initial compliance within 180 days—by June 1, 2011. The company did not comply in 2011. It did not comply in 2015. It did not comply in 2020. It complied in 2023, after the EPA showed up with legal authority and no patience left.

Paragraph 101, Consent Agreement: “In violation of the NESHAP 7A, 40 C.F.R. § 63.11563(g), ALCO failed to develop and make available for inspection by the delegated authority, a site-specific monitoring plan for Line 1, that specifies the process parameters established during the initial compliance assessment and how they are being monitored and maintained to demonstrate continuous compliance.”

This is not a paperwork error. A site-specific monitoring plan is the operational blueprint for pollution control. It defines what you measure, how often you measure it, and what values indicate you’re out of compliance. Without it, there is no continuous compliance—there is only continuous operation, unverified and unaccountable.

Societal Impact Mapping

Environmental Degradation

Asphalt processing releases volatile organic compounds (VOCs), particulate matter (PM), and polycyclic aromatic hydrocarbons (PAH) into the air. PAH compounds include benzo[a]pyrene, a known human carcinogen. When asphalt is heated in a saturator or applied to felt in a coating process, these compounds volatilize. Without control devices—thermal oxidizers, scrubbers, or even basic capture systems—they vent directly into the ambient air.

ALCO Products operated two coating lines without control devices. Paragraph 70 of the consent decree confirms this. The facility relied on uncontrolled atmospheric dispersion. Emissions drifted according to wind patterns, weather, and the height of the exhaust stacks. There was no engineered containment. The environment absorbed whatever the plant released.

Opacity violations at the silos indicate fugitive particulate emissions during loading operations. The sand silo recorded a maximum opacity of 12.3% during a May 2023 loading event. That visible plume represents fine and coarse particulate matter—silica dust, asphalt fines, mineral aggregates—dispersing into the surrounding area. Particulate matter at this scale penetrates deep into lung tissue and contributes to cardiovascular and respiratory disease burden.

Public Health

The consent decree does not include epidemiological data. It does not quantify excess asthma cases or cancer incidence in the census tracts surrounding 580 Old St. Jean Street. Those studies take years and require funding, expertise, and political will that rarely materialize for environmental justice cases in deindustrialized cities.

What the decree does establish is chronic exposure to uncontrolled hazardous air pollutants in a residential area for at least eight years, and likely much longer. Line 2 has been operating since 1999. If ALCO’s compliance posture toward NESHAP 7A (effective 2010) is any indication, it is unlikely the facility maintained voluntary controls or monitoring before the regulation took effect.

PAH exposure is cumulative. The International Agency for Research on Cancer (IARC) classifies several PAH compounds as Group 1 carcinogens (carcinogenic to humans). Chronic low-level exposure increases lifetime cancer risk. Children are especially vulnerable due to higher respiratory rates and developing organ systems. Schools, playgrounds, and homes within a half-mile radius of the plant constitute a pediatric exposure zone.

There is no safe threshold for carcinogen exposure. Every microgram inhaled over a lifetime adds to risk. ALCO Products was not monitoring emissions. The community had no data, no warning, no recourse.

Economic Inequality

Industrial facilities are not randomly distributed. They cluster in low-income neighborhoods and communities of color, where land is cheaper, political power is weaker, and enforcement is lax. Detroit’s eastside, where ALCO Products operates, has a median household income below the city average and a predominantly Black population. This is not coincidence. It is the spatial logic of environmental racism.

Property values near uncontrolled industrial polluters are depressed. Homeowners cannot sell without taking a loss. Renters cannot move without financial strain. Families are trapped in sacrifice zones by economic necessity. ALCO Products’ failure to comply with air quality regulations imposed an external cost on the surrounding community—a cost paid in health outcomes, property devaluation, and diminished quality of life.

The $150,000 penalty does not compensate that community. It flows to the U.S. Treasury. Residents receive no damages, no remediation, no health monitoring. The settlement resolves ALCO’s liability to the federal government. It does nothing for the people who breathed the pollution.

What Now?

ALCO Products, LLC is a privately held corporation. The consent decree does not name individual executives or board members. Under the corporate veil, personal accountability is diffuse. President Lee Vandermyde signed the agreement. The EPA Division Director, Carolyn Persoon, signed for the government. Those are the only names attached to an eight-year pattern of regulatory failure.

The facility is now required to comply with all applicable Clean Air Act provisions. That is not a new obligation—it has always been the law. What has changed is the EPA’s willingness to enforce it. The consent decree includes injunctive relief: ALCO must develop site-specific monitoring plans, conduct emissions testing, and file regular compliance reports. These are the baseline requirements the company should have met in 2010.

For residents and advocates, the path forward involves local organizing and regulatory vigilance. The Michigan Department of Environment, Great Lakes, and Energy (EGLE) is the delegated state authority for Clean Air Act enforcement. EGLE received a copy of the Finding of Violation in March 2024 and has concurrent jurisdiction. Community groups can file citizen complaints with EGLE, request facility inspection records under the Freedom of Information Act, and demand transparent emission reporting.

Watchlist of Regulatory Bodies:

• U.S. Environmental Protection Agency, Region 5 (Chicago)
• Michigan Department of Environment, Great Lakes, and Energy (EGLE), Air Quality Division
• EPA Office of Enforcement and Compliance Assurance
• EPA Office of Inspector General (for enforcement failures)

Grassroots Resistance Strategies:

• Organize neighbors within a one-mile radius of 580 Old St. Jean Street to document health impacts and demand epidemiological study funding.
• File public records requests with EGLE for all ALCO Products inspection reports, emission inventories, and compliance correspondence since 2010.
• Pressure Detroit City Council to pass a municipal ordinance requiring real-time air quality monitoring at all industrial facilities within 1,000 feet of schools or residential zones.
• Build coalition with Detroit environmental justice groups including Michigan Environmental Justice Coalition, East Michigan Environmental Action Council, and Sierra Club Michigan Chapter.
• Submit comments during ALCO Products’ next permit renewal process demanding stricter emission limits and continuous monitoring technology.

The settlement is not the end. It is proof that enforcement is possible when political will exists. The goal now is to make enforcement proactive, transparent, and centered on community protection rather than corporate convenience.