Regulatory and compliance historyRC-003

Lehigh multi-plant Clean Air Act settlement

Lehigh Cement and Lehigh White Cement · 14 kilns at 11 facilities, USA · 2019

Use this record when

The decision this case can inform

Use this record when standardizing environmental-control and assurance practices across a geographically distributed cement network.

Evidence scope

EPA/DOJ consent-decree summary covering alleged violations at 14 kilns. Emission reductions are estimates and the cited record has no post-control verified inventory.

Source-supported facts

What the public record actually establishes

4 sourced points
  1. F1

    The settlement covered 14 kilns at 11 Lehigh and Lehigh White facilities.

  2. F2

    It required new or tighter SNCR operation across the network and lime injection at five or six kilns.

  3. F3

    The agreement included stringent limits, including 1.5 lb NOx per ton of clinker at two kilns, and replacement of older off-road diesel equipment.

  4. F4

    EPA estimated about 4,500 tons/year of NOx and nearly 1,000 tons/year of SO₂ reductions; the civil penalty was $1.3 million.

Structured interpretation

Facts and reported results are kept separate from the lesson a plant may choose to test.

01

Operating context

EPA and DOJ settlement covered alleged Clean Air Act violations across a multi-site cement network.

02

Intervention or finding

Settlement required SNCR installation or tighter operation, lime injection, low SO2 limits, and off-road diesel replacements.

03

Documented result

EPA estimated about 4500 t/y NOx and nearly 1000 t/y SO2 reductions.

04

Plant interpretation

Use common engineering standards, site permit maps, control-availability metrics, emissions-data assurance, and executive obligation closure.

05

Transfer boundary

Estimated settlement impact; no post-control emissions inventory in the cited record.

Before applying the lesson

Questions to verify at your plant

These are decision checks, not operating instructions. Resolve them through local risk assessment, technical review, and authorization.

  1. 01

    Is there a common control standard with site-specific permit and process limits mapped for every kiln?

  2. 02

    Are reagent use, control availability, emissions intensity, exceedances, maintenance, and data validity visible at both plant and executive level?

  3. 03

    How are decree or permit obligations assigned, evidenced, independently checked, and closed after organizational change?

  4. 04

    Are projected reductions reconciled with certified emissions data and clinker production after controls stabilize?