Project XL Progress Report
Andersen Corporation
On March 16,1995, the Clinton Administration announced a portfolio of reinvention initia-
tives to be implemented by the U.S. Environmental Protection Agency (EPA) as a part of its
efforts to achieve greater public health and environmental protection at a more reasonable
cost. Through Project XL, which stands for excellence and Leadership, EPA enters into
specific proj ect agreements with public or private sector sponsors to test regulatory, policy, and
procedural alternatives that will produce data and experiences to help the Agency make
improvements in the current system of environmental protection. The goal of Proj ect XL is to
implement 50 proj ects that will test ways of producing superior environmental performance
with improved economic efficiencies, while increasing public participation through active
stakeholder processes. As of October 1999,15 XL projects are in the implementation phase
and 35 XL projects are under development. EPA Project XL Progress Reports provide
overviews of the status of XL proj ects that are implementing Final Proj ect Agreements
(FPAs). The progress reports are available on the Internet via EPAs Proj ect XL web site at
http ://www.epa.gov/Proj ect XL. Or, hard copies may be obtained by contacting the Office
of Reinvention's Proj ect XL general information number at 202-260-7434. Additional
information on Proj ect XL is available on the web site or by contacting the general informa-
tion number.
Background
The Andersen Corporation is a leading manufacturer of durable, energy-efficient, high-
performance clad wood windows and patio doors. Andersen's main manufacturing plant is
located in Bayport, Minnesota, along the St. Croix River, a federally designated "Wild and
Scenic River" which forms the border between Minnesota and Wisconsin. Existing manufac-
turing facilities are located on the 110-
acre Fourth Street Site, which consists
of 78 buildings, most of which are
interconnected. Andersen purchased
an undeveloped 245-acre tract of land
in 1994 that is located approximately
1 mile west of the Fourth Street
manufacturing complex. This plot,
which is referred to as the Andersen
West Site, is intended to be used as an
expansion site for various operations.
Andersen XL Project
Bayport, Minnesota
Major Milestones
January 30, 1998
Andersen Project
Proposal Submitted
June 30, 1999
Final Project Agreement
Signed
Summer 2000
Minnesota Pollution
Control Agency Issues
XL Permit
Late Summer 2000
EPA Rule Effective Date
Late Summer 2010
Termination of FPA
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Andersen XL Project 12-31-99
The Fourth Street Site, together with the Andersen West Site, are collectively referred to as the Bayport
Facility. Manufacturing and related processes at Andersen's Bayport Facility include wood cutting and
milling, wood preservative application, painting, vinyl processing, adhesive operations, by-product transfer,
wood-fired boilers, assembly operations, technology development, production support, and maintenance
functions.
The Andersen proj ect will test an innovative experiment to reduce air emissions per unit of production. This
reduction will be achieved by using performance-based regulatory approaches based on volatile organic
compound (VOC) emissions per standard measure of production: the "performance ratio." While providing
an incentive for better performance, the performance ratio will essentially lock in Andersen's current produc-
tion methods and processes. The ratio obviates a return to traditional solvent-based coating and wood-
preservative processes, while allowing the company the flexibility to research even greater efficiencies and
emissions improvements. The company will be allowed to increase production levels without undergoing case-
by-case reviews prompted by VOC emission changes, as long as its VOC emissions per unit of production
remain below the performance ratio and its overall emissions remain below a facilitywide VOC cap.
The anticipated superior environmental benefits of the Andersen XL proj ect include
• maintaining or reducing current levels of VOCs and milling and nonmilling particulate matter (PM) emissions
at the Bayport Facility by implementing an enforceable mass-emissions cap and a subcap for PM at the
adjacent Andersen West Site;
• committing that any new paint and preservative processes will perform as well as existing environmentally
efficient processes;
• installing baghouse filters, or any other pollution control devices found to be the best available control
technology (B ACT), on all suitable milling equipment;
• ensuring that air toxic levels remain below risk-based levels;
• attempting to cease operation of the oldest diptank on site within 5 years after the start of the XL proj ect;
• continuing to study and evaluate the concept of recycling windows as feedstock for the Fibrex composite
process, and reporting the findings to the Community Advisory Committee (C AC), the Minnesota Pollution
Control Agency (MFC A), Washington County, and EPA by no later than 2 years after the effective date of
theFPA;
• continuing to use an Environmental Management System (EMS) to move beyond compliance; and
• expediting efforts to produce more of its window and door components with more environmentally friendly
materials and processes, such as Fibrex composite, waterborne preservative treatment, and higher solids
paint coatings, thereby encouraging continued reductions in its use of virgin materials.
The Experiment
The Andersen proj ect aims to reduce air emissions per unit of production by using performance-based
regulatory approaches based on VOC emissions per standard measure of production. The company will be
allowed to increase production levels without undergoing case-by-case reviews prompted by VOC emission
changes, as long as its VOC emissions per unit of production remain below the performance ratio and its
overall emissions remain below a facilitywide VOC cap.
The Flexibility
In return for superior environmental performance, EPA, the MFC A, and Washington County intend to offer
Andersen Corporation regulatory flexibility under this Proj ect XL pilot. The proj ect will allow modification
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Andersen XL Project 12-31-99
and addition of preapproved sources (such as waterborne treatment lines and Fibrex production) without
additional review by EPA or the MFC A. EPA and the MFC A agreed to develop both a site-specific rule
under the Clean Air Act's Prevention of Significant Deterioration (PSD) program and a streamlined Minnesota
Proj ect XL multi-media permit (Minnesota XL Permit). The Minnesota XL Permit will be a consolidation of
Andersen's various environmental obligations. The permit will, to the extent possible, combine air, hazardous
waste, and water discharge conditions at the Bayport Facility into one permit, and it will incorporate the
Federal air permit as required by Part 40 Code of Federal Regulations (CFR) Part 70 for the Bayport Facility.
The modifications that would be allowed under the XL Permit trigger Minnesota's environmental review
requirements. Therefore, the MPCA will prepare an Environmental Assessment Worksheet (EAW) on the
project. An EAW gathers and discloses information about a project and its potential environmental conse-
quences.
In addition, the XL proj ect allows Andersen, with the approval of EPA, the MPCA, and the C AC, to remove
its door paintline catalytic oxidizer control equipment if the company converts a portion of the paintline to
waterborne coatings. Andersen must show that cost savings resulting from shutting this equipment down have
been reinvested in emission reduction projects.
The statutory programs, and the EPA offices administering the programs, that affect the Andersen XL proj ect are
• Clean Air Act (CAA) programs administered by EPA's Office of Air Quality Planning and Standards;
• Resource Conservation and Recovery Act (RCRA) programs, administered by EPA's Office of Solid
Waste; and
• Pollution Prevention Act (PPA) programs administered by EPA's Office of Prevention, Pesticides, and Toxic
Substances.
Air Quality Permitting. The XL Permit will eliminate emission limits on certain existing processes (i.e., limits
that prevent these processes from being used once the limit is reached) and combine 26 different emission limits
applicable to Andersen's two diptanks into one rolling average limit. The MPCA will provide Andersen with
flexibility on closure of the facility's diptanks.
The XL Permit will contain the CAA Title V, minor New Source Review (NSR), and PSD permits. The XL
Permit will be issued subj ect to public notice and comment, and the opportunity for EPA to raise obj ections
and petition the public. During the permit's development, overlapping or conflicting conditions from existing
permits will be combined or reconciled, as allowed by applicable requirements. The flexibility granted
Andersen Corporation includes relief from specific applicable synthetic minor air emission limits with the
condition that Andersen comply with the site-specific permit limits for PM and certain VOCs. The new permit
establishes emission caps for these compounds both on a "per standard measure of production" basis and a
facilitywide basis. Andersen will be allowed to modify or add VOC units and modify or add certain PM and
PM-10 units as long as the emissions remain below the caps established in the permit. This regulatory flexibility
grants preapproval for emission increases that would otherwise require permit modification approval by the
regulatory agency. The Minnesota XL Permit will, to the extent possible, reduce the administrative burden
through simplified monitoring, reporting, and record keeping.
The installation or modification of large emission units at Andersen's Fourth Avenue Site are currently subj ect
to PSD regulations. To avoid future PSD review, a facility may accept a "synthetic minor limit," which restricts
the new or modified unit's emissions below applicable major source or modification threshold levels.
Andersen's Fourth Avenue Site is currently subj ect to eight different VOC synthetic minor limits. Under this
project, Andersen has requested relief from these specific current synthetic minor limits at the Fourth Avenue
Site. In response, EPA plans to propose and promulgate (subject to public review and comment) a
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Andersen XL Project 12-31-99
site-specific regulation that would revise 40 CFR 52.21 (r)(4) and 40 CFR 52.21 (b)(3)(ii)(a) as they apply to
Andersen. This regulation would in turn enable the MPCA to issue a permit that eliminates specific synthetic
minor air emission limits on VOCs that apply to the Fourth Avenue Site, so long as certain conditions described
in the rule are satisfied.
To release Andersen from existing synthetic minor limits on PM, Andersen must receive a PSD permit as
required by law. The MPCA has been delegated the authority to issue PSD permits in the State of Minnesota
subj ect to administrative review before the EPA's Environmental Appeals Board. To streamline certain Title V
and minor NSR permit modification requirements, the PSD permit will preauthorize certain types of changes.
The PSD permit will include sufficiently detailed descriptions of the preauthorized changes for compliance
purposes, and it will give the public sufficient notice of the types of changes that will be authorized. The descrip-
tions also will identify all applicable requirements, such as for periodic monitoring or record keeping, that would
apply to the proposed change.
Hazardous Waste Permitting. Andersen will obtain flexibility related to its wood-treating process equipment.
Specifically, the Corrective Action Agreement dated May 4,1995 between the MPCA Hazardous Waste
Division and Andersen Corporation will be terminated. All remediation activities related to the dismantling of
Andersen's wood-treating equipment in Building 15 are now to be managed and controlled through the commit-
ments in the FPA, the Minnesota XL Permit, and the January 27,1987 Superfund Consent Order between
Andersen and the MPCA. Currently, the May 4,1995 Corrective Action Agreement requires the shutdown and
removal of both diptanks and of the floodcoater. However, the MPCA agrees with Andersen that removal of
the tanks at this time is not warranted environmentally. The east diptank never used penta-based preservatives.
The floodcoater reservoir already has been cleaned and closed. The west diptank will be cleaned when it is no
longer used. Based on groundwater monitoring data, the tanks do not currently leak and will not likely add any
contamination to the groundwater. Previous releases, including soil contamination due to a rail car spill in Sep-
tember 1982, are being effectively remediated through Andersen's groundwater treatment system. That con-
tamination is being effectively remediated through Andersen's groundwater treatment system. Its continued
operation is required by the Superfund Consent Order, which will remain in effect.
Andersen will be allowed to keep the floodcoater reservoir capped, and will be allowed to clean and cap the
west diptank reservoir once it is permanently shut down.
In addition, Andersen will be allowed to manage the metal components of its dismantled wood- treating equip-
ment from Building 15 by transporting its components to metal-smelting operations for recycling.
Promoting Innovation and System Change
Proj ect XL provides EPA opportunities to test and implement approaches that protect the environment and
advance collaboration with stakeholders. EPA is continually identifying specific ways in which XL proj ects are
helping to promote innovation and system change. The innovations and system changes emerging from the
Andersen XL project are described below.
Performance Ratios. This proj ect represents an innovative approach to allow changes in manufacturing
processes that may result in reduced air emissions per standardized measure of production. The project also
provides an opportunity to test whether a tiered air emission ratio system with both rewards and penalties can
provide a better incentive for reducing air emissions. The proj ect will result in a new, flexible, performance-
based approach designed to achieve superior environmental results and cost savings. The main measure of
VOC efficiency is a comparison of the performance ratio to the C AC Limit. This community-driven limit, set
below the Enforcement Limit, is defined so as to encourage Andersen to go beyond compliance without being
threatened with penalties if it should fail to meet these higher standards, and establishes the stakeholder group's
important role in ensuring Bayport Facility environmental performance. The proj ect will provide EPA with
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important reference data.
Multi-Media Permitting. The Minnesota XL Permit is intended to facilitate multi-media permitting ap-
proaches to environmental protection. In March 1999, EPA approved a detailed plan for "The Next Genera-
tion in Permitting." The multi-media permit concept is an important part of this plan and is expected to be a key
component in the Agency's ongoing permit improvement process.
Administrative Burden Reduction. A number of XL proj ects are testing different approaches to reducing the
administrative permitting and reporting requirements imposed by Federal, state and local regulatory agencies.
This XL proj ect will result in cost savings to Andersen and regulatory agencies by eliminating certain synthetic
minor limits and allowing flexibility for most modifications under the facilitywide caps. In addition, flexibility
from MFC A on the regulation of the diptanks will result in further cost savings. The parties believe that specific
long- term cost savings and paperwork reduction will be realized in the areas of air permitting, streamlined
Minnesota XL Permit compliance, combined reporting and record keeping, emergency response planning, and
training integration.
Reward Limit Options. This proj ect also tests the use of rewards as incentives for Andersen to achieve
superior environmental performance. If Andersen's performance ratio decreases below the reward limit, as
outlined in the FPA, Andersen will qualify for one of several different proj ect-related rewards agreed to by
MPCA and EPA, including the following.
• Recognition: For each period in which Andersen's performance ratio is below the reward limit, U.S. EPA
and MPCA will provide a letter from high-ranking Agency officials describing Andersen's overall environ-
mental performance, which Andersen can publicly distribute.
• Addition of Mini-Projects: For performance below the reward limit for more than three reporting periods,
Andersen may present to MPCA and EPA other innovative proj ects that Andersen would like to include as
part of this XL project.
• Extension of the Project Duration: For performance below the reward limit for 13 reporting periods or
more, Andersen may request an extension of the duration of the current proj ect. If Andersen chooses this
reward, Andersen would have to demonstrate to EPA and MPCA that the extension is not only consistent
with the goals of the current proj ect, but also that the extension is consistent with EPA rules and policy
concerning the duration of plantwide applicability limit permits.
Project Commitment Summary
Commitment
Status
Andersen Commitments
Andersen will calculate a 5-year average
performance ratio of pounds of VOCs emitted per
volume of production.
To be calculated in late summer 2000
and included in the XL Permit.
Limit VOC emissions to 2,397 tons per year for entire
Bayport Facility, with a subcap of 96 tons per year for
the Andersen West Site.
To be completed in late summer 2000
and included in the XL Permit.
Combine the existing diptank VOC synthetic minor
limits into a single rolling average limit of 1,573.9 tons
per year.
To be completed in late summer 2000
and included in the XL Permit.
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Commitment
Status
Andersen Commitments
Limit nonmilling PM emissions for Bayport Facility to
209.1 tons per year, with a subcap of 96 tons per
year (milling and nonmilling PM) for the Andersen
West Site.
To be completed in late summer 2000 and included
in the XL Permit.
Control all existing and future milling operations with
B ACT (currently believed to be baghouse filters), and
meet all PSD requirements for PM and PM-10
Pending.
emissions.
Continue to control the door plant paintline emissions
with a catalytic oxidizer until the company receives
approval to discontinue the use of the control equip-
ment from the MFC A.
Pending.
Ensure that any new or reconstructed paintline
equipment does not emit at a rate greater than 4.5
pounds of VOCs per gallon of coating applied.
Pending.
Ensure that any new or reconstructed preservative
application process does not emit VOCs at a rate
greater than 2.0 pounds per gallon of preservative
used.
Pending.
Conduct a health risk analysis for toxic air emissions.
Pending.
Continue to investigate the possibility of recycling
windows as feedstock for the Fibrex composite
process, and present its findings to EPA, the MFC A,
Washington County and the CAC within 2 years of
the effective date of the FPA.
Pending.
Attempt to cease operation of the west diptank within
5 years after the start of the project.
Pending.
Remove all hazardous waste from the west diptank
within 90 days of permanent shutdown; remove all
metal parts that have contacted the penta-containing
wood preservative and recycle the material using a
metal-smelting operation; provide verification accept-
able to the MFC A that the parts were properly
recycled.
Pending.
If the west diptank reservoir is eventually removed,
Andersen will submit a plan to test the adj acent soils
and address the sand fill material, the soil under the
reservoir, and the reservoir itself.
Pending.
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Commitment
Status
Andersen Commitments
Evaluate and manage any waste generated from new
preservative formulations at the diptanks in accor-
dance with appropriate regulations.
Continue to seek ways to enhance the existing
groundwater remediation system.
Continue to provide administrative support to the
Andersen CAC that was established in 1997; con-
tinue outreach work with all stakeholders; give local
residents a voice at CAC meetings.
Operate pursuant to the facility's existing EMS; strive
to meet the goals outlined in the Corporate Pollution
Prevention Plan.
Report the facility's compliance status to the CAC at
least semiannually
Prepare and submit to EPA, the MFC A, Washington
County, and the CAC a status report at least annually;
monitor VOC and PM emissions and make data
available to public.
Complete an Environmental Assessment Worksheet
as required under Minnesota environmental review
regulations.
Ongoing.
In progress.
In progress.
In progress.
First semiannual report anticipated March 2001 .
First annual report anticipated August 200 1 .
To be completed in spring 2000.
EPA Commitments
EPA will issue a final rule providing regulatory
flexibility for this Proj ect XL pilot.
Provide rewards, as outlined in the FPA, for superior
environmental performance.
To be promulgated following the issuance of Minne-
sota XL Permit in late summer 2000.
As needed.
MPCA Commitments
Issue a Minnesota Proj ect XL Permit allowing the
proj ect to commence.
Grant Andersen approval to discontinue the use of a
catalytic oxidizer, if Andersen meets commitments
outlined in the FPA.
Review Andersen's Health Risk Analysis for toxic air
emissions.
Terminate Corrective Action Agreement, dated May
4, 1995, between the MPCA and Andersen.
To be issued in late summer 2000.
To be determined.
To be completed by late summer 2000.
To be terminated by late summer 2000.
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Commitment Status
MPCA Commitments
Grant Andersen regulatory flexibility regarding the
closure of the diptanks and management of removed
metal components.
Provide rewards, as outlined in the FPA, for supe-
rior environmental performance.
To be completed by late summer 2000.
As needed.
Washington County Commitments
Amend its hazardous waste management ordinance or
take administrative action to allow this XL proj ect to
proceed.
To be completed by late summer 2000.
This table and the environmental performance section that follows summarize progress in meeting commitments
described in the FPA for the Andersen XL proj ect:
Environmental Performance
Enforcement Limit
Project Limit
Reward Limit
VOC Performance Ratio
_ To be reported
- To be reported
- To be reported
_ To be reported
- To be reported
0 25 50 75 100
Pounds of VOCs Emitted per Cubic Foot of Product
This section summarizes progress in meeting the environ-
mental performance described in the FPA for Andersen's
Bayport Facility. No information regarding performance
measures is available at this time. Anticipated results will be
reported as follows.
Volatile Organic Compounds (VOCs): Regarding VOC
emissions, Andersen has agreed to report two unique
parameters to confirm environmental performance: the
performance ratio and the facilitywide VOC cap. The
performance ratio is a measure based on VOCs emitted per
standard measure of production, including a VOC emissions
subcap at the Andersen West Site. On a per-period basis
(13 periods per year) Andersen will calculate the ratio of
pounds of VOCs emitted per cubic foot of product shipped
(performance ratio) for the preceding 13 periods. That calculation will be compared to the CAC Limit, En-
forcement Limit, Proj ect Limit, and Reward Limit, all of which will be established by late summer 2000.
The CAC Limit, which is the average of the prior 5 years' performance ratios, is the main limit for evaluating
Andersen's ongoing environmental performance and will be established in late summer 2000 using past perfor-
mance data. It will be recalculated every 3 years.
The Enforcement Limit, which is a static limit for the 10-year duration of the XL project, will be established in
late summer 2000 utilizing the initial CAC Limit plus two standard deviations.
The Project Limit is an adjustable limit that will also be set at two standard deviations above the CAC Limit,
but will be adjusted at the same time as the CAC Limit, every 3 years. If Andersen's performance ratio ex-
ceeds the Proj ect Limit but is below the Enforcement Limit, the XL proj ect will end unless Andersen demon-
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strates to the satisfaction of the CAC, EPA, and the
MFC A, each acting in its independent capacity, why the
project should continue.
The Reward Limit is set at two standard deviations
below the CAC Limit. The Reward Limit will not in-
crease and will only decline if Andersen remains below it
for 3 consecutive years.
The second parameter for confirming environmental
performance, referred to as the facilitywide VOC cap, is
based on total VOC emissions from the Bayport Facility.
The VOC cap for the Bayport Facility is set at 2,397
tons per year, with a subcap of 96 tons per year for the
Andersen West Site. The existing VOC synthetic minor
limits on the diptanks have been combined into a single
rolling average limit of 1,573.9 tons per year.
In addition, any new or reconstructed paintline shall not
emit at a rate greater than 4.5 pounds of VOCs per gallon
of coating applied, and any new or reconstructed preserva-
tion application processes shall not emit VOCs at a rate
greater than 2.0 pounds per gallon of preservative used.
Progress: To be reported in first semiannual report.
Particulate Matter: The Minnesota XL Permit will
include an enforceable cap for nonmillingPM emissions
of 209.1 tons per year that will apply to the entire
Bayport Facility. The Andersen West Site also will be
subj ect to a separate limit for total PM (milling and
nonmilling) of 96 tons per year.
Progress: To be reported in first semiannual report.
Facility-wide Actual
Facility-wide Cap
Past Performance
Andersen West Actual
Andersen West Subcap
Andersen West
Past Performance
Diptank Actual
Diptank Rolling
Average Limit
Diptank Past Performance
Volatile Organic Compounds
- To be reported
- To be reported
- To be reported
- To be reported
- To be reported
- To be reported
1000 2000
Tons per Year
PaintSine and Preservation AppSication
VOC Emission Rate
Paintline Actual
Paintline
VOC Cap
Paintiine Past
Performance
Preservative
VOC Cap
Preservative Past
Performance
- To be reported
To be reported
To be reported
- To be reported
1234
Pounds per Gallon
Partieulate Matter
Bayport Facility
Non-milling PM Actual
Bayport Facility
Non-milling PM Cap
Bayport Facility
Non-milling PM Past
Performance
Andersen West
Total PM Actual
Andersen West
Total PM Cap
Andersen West Total PM
Past Performance
- To be reported
- To be reported
- To be reported
_ To be reported
50
100
Tons per Year
150
200
Diptank Closure: Andersen has two active diptanks
used to apply solvent-based wood preservative to an
array of different window and door parts and as backup equipment for inline waterborne preservative pro-
cesses. Andersen will attempt to cease use of the west diptank within 5 years after the start of the XL proj ect.
This will result in a reduction of VOC emissions of approximately 180 tons per year, as well as a reduction in
hazardous waste generation of 800 gallons per year.
Progress: Proj ect goal (nonenforceable) to be completed by 2005.
Stakeholder Participation
The Andersen Community Advisory Committee (CAC) has been established and has functioned as the pri-
mary contact with the local community and other stakeholder groups. The CAC is composed of individuals
representing a variety of stakeholders, including local residents, employees, businesses, environmental groups,
and government. It i s important to the success of the XL proj ect that the C AC's role continues throughout the
life of this proj ect. The CAC is guided by the Stakeholder Involvement Plan attached to the FPA. Stakeholder
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support has been built through 12 meetings of the CAC held from December 1997 through September 1998.
C AC meetings initially covered detailed briefings on all aspects of the Andersen Proj ect XL proposal. CAC
involvement evolved into active questioning, comments, and participation by CAC members in FPA negotia-
tions, and in the work groups established to address specific FPA issues. Andersen will report its compliance
status to the CAC at least semiannually.
In addition, Andersen Corporation has kept local residents informed of Proj ect XL initiatives through the
Andersen Community Update newsletter, Internet postings, news media contacts, open houses, displays, and
responses to community inquiries.
Six-Month Outlook
The key focus areas for continued successful implementation of the FPA over the next 6 months will be the
following.
• MPCAs issuance of a Minnesota Proj ect XL multi-media permit.
• EPAs promulgation of a final rule that will allow regulatory flexibility for this XL project.
• Washington County's amending of its hazardous waste management ordinance.
• Andersen Corporation's calculation of the performance ratio and implementation of the emissions caps.
Project Contacts
• KirkHogberg, Andersen Corporation, (651) 430-7437.
• Brian Barwick, EPA Region 5, (312) 886-6620.
• Nancy Birnbaum, EPA/XL HQ, (202) 260-2601.
• Andrew Ronchak, MFC A, (651) 296-3107.
Information Sources
The information source used to develop this progress report is the FPA for the Andersen Corporation XL
Project, dated June 30,1999. The information source is current through June 1999.
Glossary
Bag-house Filter Collectors: Vacuum-like systems used to collect sawdust generated by milling operations.
Baseline: The measure by which future environmental performance can be compared.
Best Available Control Technology (B ACT): A case-by-case technology determination that considers energy,
environmental, and economic impacts in determining the maximum achievable pollutant reduction.
Commentors: People or organizations with an interest in an XL proj ect, but without the need to participate
intensively in its development. The project development process should inform and be informed by
commentors on a periodic basis. The views of informed commentors are a strong indicator of the broad
potential for wider applicability of the innovations being tested in a proj ect.
Community Advisory Committee (CAC): The body formed to assist Andersen Corporation in the development
and implementation of its XL proposal. The CAC is made up of direct participants: individuals representing a
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variety of stakeholders including local residents, employees, business, environmental groups, and government.
Criteria Air Pollutants: Currently, there are six criteria pollutants that are subj ect to National Ambient Air
Quality Standards (NAAQS), which are regulations promulgated by EPA under the authority of the Clean Air
Act (CAA). EPA has identified and set standards for six criteria air pollutants—particulate matter (PM),
carbon monoxide (CO), sulfur dioxide (SO2), nitrous oxides (NOx), lead (Pb), and ozone (O3)—that are
known to be hazardous to human health.
Diptank: A piece of process equipment used to apply wood preservative to pallet loads of milled wood pieces.
The process equipment consists of an open-top tank containing wood preservative and carriages that convey
pallet loads of wood pieces into and out of the preservative solution.
Direct Participants: People or organizations representing a variety of stakeholders who work intensively with
proj ect sponsors to build a project from the ground up. For example, the CAC is made up of direct partici-
pants.
Emissions: Airborne discharges from sources such as industrial processes.
Emissions Cap: A provision designed to prevent projected growth in emissions of a specific contaminant
established at a facility from exceeding a specified limit. Generally, such provisions require that emissions
increases from one operation be offset by reductions at other facility operations under the same cap.
Environmental Management System (EMS): A comprehensive, documented program implemented by a
company to promote compliance with environmental laws and promote environmental performance.
Environmental Protection Agency (EPA): The Federal government agency charged with implementing U. S.
environmental laws and the sponsoring agency for XL proj ects.
Fibrex: Andersen Corporation's reclaimed wood/vinyl composite used in production of window and patio
door components.
Final Proj ect Agreement (FPA): The FPA outlines the details of the XL proj ect and each party's commitments.
The proj ect's sponsors, EPA, state agencies, Tribal governments, other regulators, and direct participant
stakeholders negotiate the FPA.
General Public: The broad category of people and organizations who are not direct participants in the Project
XL development process, but who have an interest in, and wish to be informed about, progress on the proj ect.
Groundwater Remediation System: A system designed to remove groundwater contamination. Often, such
systems use wells to recover contamination.
Hazardous Air Pollutants (HAPs): Air pollutants that are not covered by NAAQ S but that may present a
threat of adversely effecting human or environmental health.
Media: Specific environments-air, water, soil-which are the subject of regulatory concern and activities.
Milling: Milling operations are those activities that involve the cutting and shaping (except by extrusion) of
wood or Fibrex.
Minnesota Pollution Control Agency (MFC A): The regulatory agency charged with implementing environmen-
tal laws in the State of Minnesota.
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Minnesota XL Permit: A permit issued under Minnesota Statute 114C authorizing a Proj ect XL pilot in
Minnesota and containing all Federally enforceable air permits.
Multi-media: Several environmental media, such as air, water, and land.
New Source Review (NSR): The Federal regulatory program establishing preconstruction permitting require-
ments for certain facilities based on the potential emissions of the facility. The NSR, a program of the CAA,
strives to ensure that potential new sources of air pollution take proper steps to minimize pollution levels.
Nonmilling: Nonmilling operations are those activities that generate PM emissions and that are not milling
operations.
Paniculate matter (PM): Fine liquid or solid particles, such as dust, found in air or emissions.
PM-10: Particulate matter with a diameter less than 10 microns.
Penta: Short for Pentachlorophenol.
Pentachlorophenol: A wood preservative compound that was once widely used.
Prevention of Significant Deterioration (PSD): The part of the NSR program in which state or Federal permits
are required to restrict emissions for new or modified sources in locations where air quality already attains
ambient air quality standards.
Proj ect XL: A Federal program to conduct pilot proj ects that promote excellence and Leadership through
negotiated agreements with regulated parties.
Regulatory Innovation: Efforts to seek more flexible or cost-effective means of attaining environmental perfor-
mance results beyond compliance limits.
Regulatory Flexibility: The ability of a facility to make certain changes or undertake certain activities that may
otherwise be subject to specific regulatory approval.
Resource Conservation and Recovery Act (RCRA): RCRA gives EPA the authority to control hazardous
waste from the "cradle-to-grave." This includes the generation, transportation, storage, and disposal of
hazardous waste. RCRA also sets forth a framework for the management of nonhazardous wastes and
underground storage tanks. RCRA focuses only on active and future facilities and does not address aban-
doned sites.
Reporting Period: An increment of time for summarizing business performance. Andersen Corporation oper-
ates with an accounting system based on 13 periods per year. The first period of the year is 3 weeks long,
periods 2-12 are 4 weeks in duration and the thirteenth period is 5 weeks. Existing air emission permits
require Andersen Corporation to summarize emissions each period.
Rolling Average Limit: An average determined once each specified time frequency, such as daily or monthly,
for a specific time period, such as 30 days, 12 months, or 365 days. The average is calculated by summing all
data points for the time period and dividing the total by the number of data points. A new rolling average is
recalculated for each time frequency, unless specified otherwise in an applicable requirement or compliance
document.
Solvent-based: Coatings that are primarily dissolved in volatile solvents, a process usually leading to VOC
emissions.
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Stakeholders: People and organizations with varying degrees of interest and involvement in a XL proj ect. With
XL proj ects, stakeholders are categorized into direct participants, commentors, and the general public.
Stakeholder Involvement Plan: The process for involving a variety of people and organizations in the develop-
ment of a Proj ect XL initiative.
Standard Deviation: A statistic used as a measure of the dispersion or variation in a distribution, equal to the
square root of the arithmetic mean of the squares of the deviations from the arithmetic mean.
Superior Environmental Performance (SEP): An important requirement for Proj ect XL. SEP is when a facility
improves its performance in protecting the environment and human health compared to what the facility
otherwise would have attained without Proj ect XL.
Synthetic Minor Limit: A permit condition placing federally enforceable emission limits on a facility or modifi-
cation that are lower than applicable maj or source or maj or modification permit thresholds.
Title V Air Permit: An operating permit required under Title V of the Federal Clean Air Act that consolidates
all Federal air emissions requirements into one document.
Volatile Organic Compounds (VOCs): Any organic compound that evaporates easily into the atmosphere and
that participates in atmospheric photochemical reactions, except for those compounds designated by the EPA
Administrator as having negligible photochemical reactivity. VOCs are a precursor to the formation of the
criteria air pollutant ozone, and as such, are subject to regulations under the NAAQS. VOCs also may be
FLAPs that are subj ect to regulation under the MACT standards.
Waterborne Preservative: A preservative formulation wherein water replaces solvent as the carrier for preser-
vation agents which results in significantly lower VOC emissions on a per unit basis.
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