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 ------- |