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Holcim (US) Inc. Settlement

(Washington, DC - July 11, 2013) The U.S. Environmental Protection Agency (EPA) and the U.S. Justice Department today announced a Clean Air Act settlement with Holcim (US) Inc. (Holcim) and former owner St. Lawrence Cement Company, LLC, that covers the Portland cement manufacturing facility in Hagerstown, Maryland.  Holcim has agreed to invest approximately $20 million or more to resolve violations of the Clean Air Act.

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Overview of Company

Holcim is a Delaware corporation that owns and operates a number of Portland cement plants in the United States, including one located in Hagerstown, Washington County, Maryland, the subject of this proposed Decree. St. Lawrence Cement Company is a Delaware corporation that formerly owned and operated the Hagerstown plant.

The Hagerstown, Maryland facility consists of two components, the Portland cement manufacturing plant and the quarry adjacent to the plant. At the plant, stockpiled raw materials, including limestone from the quarry, are combined with other materials and processed through a rotary kiln to form clinker, small nodules that are further ground and combined with gypsum to produce cement. During the clinker and cement producing process, the plant emits air pollutants, including SO2 and NOx.

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While operating the cement manufacturing plant at Hagerstown, the companies made modifications and upgrades, including installing a mid-kiln tire injection system, in order to use whole tires as a fuel source. The companies made these modifications between 2003 and 2007, which resulted in significant net increases in SO2 emissions, without first obtaining the permit required by the Clean Air Act’s Prevention of Significant Deterioration and Non-Attainment New Source Review requirements.

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Injunctive Relief

The proposed Decree requires the installation and continuous operation of BACT-level controls at the Holcim Hagerstown plant to control SO2 emissions. It will also require Holcim to continue to operate continuous emissions monitoring (“CEMS”), and require regular reporting to the United States. The Decree provides Holcim with the choice of one of three options, to achieve compliance.

The following injunctive relief will result from Holcim’s selection of Option A for compliance with the Decree.

SO2 Emission Controls: By no later than September 9, 2016, Holcim will: (1) convert the kiln from the current kiln configuration to a preheater/precalciner kiln configuration; (2) install and continuously operate a Lime Injection System for the control of SO2 emissions; (3) comply with an SO2 30-day rolling average emission rate limit of 1.6 lbs/ton; and (4) comply with an SO2 12-month rolling total emission tonnage limit of 655 tons.

NOx Emission Controls: By no later than September 9, 2016, Holcim will (1) install and continuously operate SNCR technology for the control of NOx emissions; and (2) comply with a NOx 30-day rolling average emission rate limit of 1.8 lbs/ton.

The Decree provides Holcim with an alternative option (Option B) for compliance. If Holcim selects the alternative compliance option, by no later than September 9, 2016, Holcim will: (1) install and continuously operate additional technology for the control of SO2 emissions at the kiln; and (2) comply with an SO2 30-day rolling average emission rate limit of 1.5 lbs SO2/ton clinker. The significant difference is that Holcim would not convert the kiln to preheater precalciner/configuration. NOx emissions would continue to be controlled under existing operations which includes the mid kiln tire chute fuel source.

In addition, the Decree provides Holcim with an Option C wherein the company would retire the Hagerstown kiln and relinquish all permits by September 9, 2015.

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Pollutant Reductions

Depending on the option selected for compliance, Holcim will reduce emissions of SO2 by an amount no less than 230 tons per year. If Holcim selects Option A, an additional 92 tons per year of NOx emissions reductions will also occur.

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Health Effects and Environmental Benefits

The pollutants reduced under this settlement have numerous adverse environmental and health effects. Sulfur dioxides and nitrogen oxides can be converted to fine particulate matter once in the air. Fine particulates can be breathed in and lodged deep in the lungs, leading to a variety of health problems and even premature death. Other health and environmental impacts from the pollutants addressed in this settlement include the following:

Sulfur Dioxide – High concentrations of SO2 affect breathing and may aggravate existing respiratory and cardiovascular disease. Sensitive populations include asthmatics, individuals with bronchitis or emphysema, children and the elderly. Sulfur dioxide is also a primary contributor to acid deposition, or acid rain.

Nitrogen Oxides – Nitrogen oxides can cause ground-level ozone, acid rain, particulate matter, global warming, water quality deterioration, and visual impairment. Nitrogen oxides play a major role, with volatile organic chemicals, in the atmospheric reactions that produce ozone. Children, people with lung diseases such as asthma, and people who work or exercise outside are susceptible to adverse effects such as damage to lung tissue and reduction in lung function.

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Environmental Mitigation Projects

Holcim will spend at least $150,000 on a mitigation project which will reduce emissions of NOx, CO, VOC and PM through replacement of an outdated loader with a newer model that complies with Tier 4 emission standards, 40 CFR 89.112 and 40 CFR 1039.101-102. Over approximately seven years, Holcim’s new loader will emit 5 tons less NOx and hydrocarbons and 0.03 tons less PM due to operating a Tier 4 engine over a Tier 2 engine.

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Civil Penalty

Holcim will pay $700,000 in civil penalties.

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Comment Period

The proposed settlement, lodged in the U.S. District Court of Maryland, is subject to a 30-day public comment period and final court approval. Information on submitting comments is available at the Department of Justice website.

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Robert G. Klepp
1200 Pennsylvania Ave. NW
Washington, DC 20460
(202) 564-5805
Robert G. Klepp (

Shaun Burke
Senior Environmental Engineer
1200 Pennsylvania Ave. NW
Washington, DC 20460
(202) 564-1039
Shaun Burke (

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