Project XL Progress Report
Andersen Corporation
In 1995, the U.S. Environmental Protection Agency (EPA) embarked on a series of innova-
tive initiatives in an effort to test new ways to achieve greater public health and environmental
protection at a more reasonable cost. Through Proj ect XL, which stands for excellence and
Leadership, EPA enters into specific proj ect agreements with public or private sector spon-
sors to test regulatory, policy, and procedural alternatives that will produce data and experi-
ences to help the Agency make improvements in the current system of environmental protec-
tion. 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 January 2001, EPA has
reached its goal of 5 0 proj ects in the implementation phase. EPA Proj ect XL Progress
Reports provide overviews of the status of XL projects that are implementing Final Project
Agreements (FPAs). The progress reports are available on the Internet via EPAs Proj ect XL
Web site at http://www.epa.gov/Project XL. Hard copies may be obtained by contacting the
Office of Policy Economics and Innovation's (formerly the Office of Reinvention) Project XL
general information number at 202-260-5754. Additional information on Proj ect XL is
available on the Web site or by contacting the general information number. The information
and data presented in this Progress Report is current as of January 2001.
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 a large portion of the border between Minnesota and Wisconsin.
Existing manufacturing facilities are
located on the 110-acre Fourth
Avenue Site, which consists of 78
buildings, most of which are intercon-
nected. Andersen purchased an
undeveloped 245-acre tract of land in
1994 that is located approximately
one mile west of the Fourth Avenue
manufacturing complex. This plot,
which is referred to as the Andersen
West Site, is intended to be used as an
Andersen XL Project
Bayport, Minnesota
Major Milestones
January 30, 1998
Andersen Project
Proposal Submitted
June 30, 1999
Final Project Agreement
Signed
Mid 2001
Minnesota Pollution
Control Agency Issues
XL Permit
Mid 2001
EPA Rule Effective Date
Late Summer 2011
Termination of FPA
-------
Andersen XL Project 1-31-01
expansion site for operations related to the Fourth Street Site. The two sites are together 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 Experiment
The Andersen project aims to reduce air emissions per unit of production. This reduction, which will be
achieved by using performance-based regulatory approaches based on volatile organic compound (VOC)
emissions per standard measure of production, is referred to as the "performance ratio." While providing an
incentive for better performance, the tiered performance ratio system, with both rewards and penalties, will
essentially prevent a return to traditional solvent-based coating and wood-preservative processes, while allow-
ing the company the flexibility to research even greater efficiencies and emissions improvements (such as Fibrex
composite and waterborne preservation treatment that release significantly less VOCs). 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 facility-wide VOC cap.
The anticipated superior environmental benefits of the Andersen XL project include:
• reducing on a par unit basis VOC emissions while capping overall VOC and particulate matter (PM) emis-
sions to levels based upon representative actual emissions and production levels;
• 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 tech-
nology (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 five years after the start of the XL proj ect
because it is the largest single source of VOC emissions at the plant;
• 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 (CAC), the Minnesota Pollution
Control Agency (MFC A), Washington County, and EPA by no later than two 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 Flexibility
In return for superior environmental performance, EPA, the MFC A, and Washington County intend to offer
Andersen Corporation regulatory flexibility under this XL Project. The project will allow modification and
addition of pre-approved sources (such as waterborne treatment lines and Fibrex production) without additional
review by EPA or the MFC A. In the FPA, 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 (XL Permit). The XL Permit will be a consolidation of Andersen's various
-------
Andersen XL Project 1-31-01
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 for the
Bayport Facility as required by Part 40 Code of Federal Regulations (CFR) Part 70.
The modifications that would be allowed under the XL Permit trigger Minnesota's environmental review require-
ments. Therefore, the MPCA will prepare an Environmental Assessment Worksheet (EAW) on the proj ect. An
EAW gathers and discloses information about a proj ect and its potential environmental consequences.
In addition, the XL project allows Andersen, with the approval of the MPC A and the CAC, to remove its door
paintline catalytic oxidizer control equipment if the company demonstrates that shut down will not cause an
exceedence of the permit limits. Anderson can accomplish this by adding waterborne treatment to the paint
lines, or making other changes in the facility prior to shutdown. 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 EPAs Office of Air Quality Planning and Standards;
• Resource Conservation and Recovery Act (RCRA) programs, administered by EPAs Office of Solid Waste;
and
• Pollution Prevention Act (PPA) programs administered by EPAs 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 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, EPA review, and petition by the public for
review to the Environmental Appeals Board. During the permit's development, overlapping or conflicting
conditions from existing permits will be combined or reconciled, as allowed by applicable requirements and
EPA guidance. 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
VOCs. The new permit establishes emission caps for VOCs on a "per standard measure of production" basis
and emission caps for VOCs and PM on a facility-wide basis. Andersen will be allowed to modify or add VOC
units and modify or add certain PM units as long as the emissions remain below the caps established in the
permit. This regulatory flexibility grants preapproval for process changes 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 to below applicable maj or source or modification threshold levels. Andersen's
Fourth Avenue Site is currently subj ect to eight different VOC synthetic minor limits. Under this proj ect,
Andersen has requested relief from these specific current synthetic minor limits at the Fourth Avenue Site. In
response, EPA plans to propose and promulgate (subj ect to public review and comment) a site-specific regula-
tion 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.
-------
Andersen XL Project 1-31-01
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. Previous releases, including soil contamination due to a rail car spill in September
1982, are being effectively remediated through Andersen's groundwater treatment system. The continued
operation of the ground water treatment system is required by the Superfund Consent Order, which will remain
in effect and not be superseded by the XL permit.
Andersen is allowed to keep the floodcoater reservoir capped, and is allowed to clean and cap the east and
west diptank reservoirs once they are permanently shut down. Anderson also has the option to continue to
operate the east diptank. The MPCA provides Andersen with flexibility on closure of the facility's diptanks by
providing them with the following two choices once diptank operations are discontinued: (1) thoroughly clean
the diptanks, fill them with sand, and cap them with concrete; or (2) remove the diptanks (note: removal is often
a difficult process because in certain cases the diptanks are part of the structural foundation of the facility).
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 proj ect are described below.
Performance Ratios. This project represents an innovative approach to allowing 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 CAC 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. Failure to improve VOC performance
on a per unit basis may be grounds for early termination of the proj ect, even if Anderson complies with the
enforceable limit and establishes the stakeholder group's important role in ensuring Bayport Facility environmen-
tal performance. The proj ect will provide EPA with important reference data.
Multi-Media Permitting. The Minnesota XL Permit is intended to facilitate multi-media permitting approaches
to environmental protection. In March 1999, EPA approved a detailed plan for "The Next Generation in
-------
Andersen XL Project
1-31-01
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 projects are testing different approaches to reducing the
administrative permitting and reporting requirements imposed by Federal, state and local regulatory agencies.
This XL project will result in cost savings to Andersen and regulatory agencies by eliminating certain synthetic
minor limits and allowing flexibility for most modifications under the facility-wide caps. In addition, flexibility
from MPCA 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.
RewardLimit Options. This project 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 plant-wide applicability limit permits.
Project Commitment Summary
This table and the environmental performance section that follows summarize progress in meeting commitments
described in the FPA for the Andersen XL proj ect:
Commitment
Status
Andersen Commitments
Andersen will calculate a five-year average
performance ratio of pounds of VOCs emitted per
volume of production.
The performance ratio has been calculated and
will be included in the permit. The calculation will
be posted after permit fmalization, as it may
slightly fluctuate up to that point.
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.
Andersen has reached VOC emission require-
ments and is awaiting permit fmalization to make
the emission cap enforceable.
Combine the existing diptank VOC synthetic minor
limits into a single rolling average limit of 1,573.9 tons
per year.
Andersen has achieved the limit but is awaiting
permit finalization for completion.
-------
Andersen XL Project
1-31-01
Commitment
Status
Andersen Commitments
Limit nonmilling PM emissions for Bayport Facility to
209.1 tons per year (calculated based on permit
issuance date, and may change), with a subcap of 96
tons per year (milling and nonmilling PM) for the
Andersen West Site.
Andersen has achieved the limit but is awaiting
permit fmalization for completion.
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
Will be achieved upon permit fmalization.
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.
Final permit will contain procedure for approval.
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.
Andersen has achieved the limit but is awaiting
permit fmalization for completion.
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.
Andersen has achieved the limit but is awaiting
permit fmalization for completion.
Conduct a health risk analysis for toxic air emissions.
Will be completed prior to permit fmalization.
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 C AC within two years of
the effective date of the FPA.
Pending.
Attempt to cease operation of the west diptank within
five years after the start of the proj ect.
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 east and/or west diptank reservoirs are eventu-
ally removed, Andersen will submit a plan for each to
test the adj acent soils and address the sand fill
material, the soil under the reservoir, and the reservoir
itself.
Pending.
-------
Andersen XL Project
1-31-01
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 MPCA, 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 August 200 1 .
First annual report anticipated March 2002.
In progress.
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 permit fmalization.
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 Summer 200 1 .
Approval process will be included in the final permit.
To be completed prior to permit fmalization.
To be terminated upon permit issuance.
-------
Andersen XL Project
1-31-01
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 upon permit issuance.
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 upon permit issuance.
Environmental Performance
This section summarizes progress in meeting the environmental performance described in the FPA for
Andersen's Bayport Facility. No information regarding performance measures is available at this time. Antici-
pated results will be reported as follows.
Enforcement Limit
Project 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
Volatile Organic Compounds (VOCs): Regarding VOC
emissions, Andersen has agreed to report two unique
parameters to confirm environmental performance: the
performance ratio and the facility-wide 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, Enforcement Limit, Proj ect Limit, and Reward Limit,
all of which were established in Fall 2000.
The CAC Limit., which is the average of the prior five years' performance ratios, is the main limit for evaluating
Andersen's ongoing environmental performance and was established in Fall 2000 using past performance data.
It will be recalculated every three years.
The Enforcement Limit, which is a static limit for the ten year duration of the XL proj ect, was established in
Fall 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 three years. If Andersen's performance ratio
exceeds the Proj ect Limit but is below the Enforcement Limit, the XL proj ect will end unless Andersen
demonstrates to the satisfaction of the CAC, EPA, and MPCA, each acting in its independent capacity, why
the proj ect should continue.
-------
Andersen XL Project
1-31-01
The RewardLimit is set at two standard deviations below
the C AC Limit. The Reward Limit will not increase and will
only decline if Andersen remains below it for three con-
secutive years.
The second parameter for confirming environmental perfor-
mance, referred to as the facility-wide 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 preservation 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, anticipated
in August, 2001.
Particulate Matter: The Minnesota XL Permit will include an
enforceable cap for non-milling PM 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 non-milling) of 96 tons per year.
Volatile Organic Compounds
Facility-wide Actual
Facility-wide Cap
Facility-wide
Past Performance
Andersen West Actual
Andersen West Subcap
Andersen West
Past Performance
Diptank Actual
Diptank Rolling
Average Limit
Diptank Past Performance
2,397
- 0 - New Facility
1000 2000
Tons per Year
3000
Paintline and Preservation Application
VOC Emission Rate
Paintline Actual
Paintline
VOC Cap
Paintline Past
Performance
Preservative Actual
Preservative
VOC Cap
Preservative Past
Performance
234
Pounds per Gallon
Particulate 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
- 0 - New Facility
50
100
Tons per Year
150
200
Progress: To be reported in first semiannual report
anticipated in August, 2001.
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 processes.
Andersen will attempt to cease use of the west diptank
within five years after the start of the XL proj ect. This
will result in a reduction of VOC emissions of approxi-
mately 180 tons per year, as well as a reduction in
hazardous waste generation of 800 gallons per year.
Progress: Project goal (nonenforceable) to be completed by 2006.
Stakeholder Participation
The Andersen Community Advisory Committee (CAC) has been established and has functioned as the primary
contact with the local community and other stakeholder groups. The CAC is composed of individuals represent-
ing a variety of stakeholders, including local residents, employees, businesses, environmental groups, and
government. It is 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 sup-
-------
Andersen XL Project 1-31-01
port has been built through 27 meetings of the C AC held from December 1997 through December 2000. C AC
meetings initially covered detailed briefings on all aspects of the Andersen Proj ect XL proposal. C AC involve-
ment evolved into active questioning, comments, and participation by C AC members in FPA negotiations, 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 six months will be the
following:
• MFC As issuance of a Minnesota Proj ect XL multi-media permit;
• EPAs promulgation of a final rule that will allow regulatory flexibility for this XL proj ect;
• Washington County's amending of its hazardous waste management ordinance; and
• MPCAs expectation to issue a public notice regarding the permit during 2001.
Project Contacts
• KirkHogberg, Andersen Corporation, (651) 264-7437.
• Brian Barwick, EPA Region 5, (312) 886-6620.
• Nancy Birnbaum, EPA/XL HQ, (202) 260-2601.
• Andrew Ronchak, MPCA, (651)296-3107.
Information Sources
The information source used to develop this progress report is the FPA for the Andersen Corporation XL
Proj ect, dated June 1999. The information source is current through December 2000.
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 (BACT): A case-by-case technology determination that considers energy,
environmental, and economic impacts in determining the maximum achievable pollutant reduction.
Clad Wood: Clad wood is covered with a layer of vinyl so thin that the form of the wood is maintained. It is low
maintenance, weather protected wood.
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.
10
-------
Andersen XL Project 1-31-01
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
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 estab-
lished 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 com-
pany 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 Project Agreement (FPA): The FPA outlines the details of the XL project and each party's commitments.
The project's sponsors, EPA, state agencies, tribal governments, other regulators, and direct participant stake-
holders negotiate the FPA.
General Public: The broad category of people and organizations who are not direct participants in the Proj ect
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.
Maximum Achievable Control Technology (MACT): A technology-based standard for each category of subcat-
egory for maj or and area sources of hazardous air pollutants.
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.
11
-------
Andersen XL Project 1-31-01
Minnesota Pollution Control Agency (MPCA): The regulatory agency charged with implementing environmental
laws in the State of Minnesota.
Minnesota XL Permit: A permit issued under Minnesota Statute 114C authorizing a Proj ect XL pilot in Minne-
sota 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.
Non-milling: Non-milling 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 abandoned sites.
Reporting Period: An increment of time for summarizing business performance. Andersen Corporation operates
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 recalcu-
lated 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.
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.
12
-------
Andersen XL Project
1-31-01
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 other-
wise would have attained without Proj ect XL.
Synthetic Minor Limit: A permit condition placing Federally enforceable emission limits on a facility or modifica-
tion 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 subj ect 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 preserva-
tion agents, which results in significantly lower VOC emissions on a per unit basis.
13
------- |