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Andersen Corporation

Andersen Proposal

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Andersen Corporation

Project XL Proposal XL Proposal

  Andersen Corporation is submitting this proposal to the Minnesota Pollution Control Agency (MPCA) and the U.S. Environmental Protection Agency (EPA) under EPA's Project XL. In broad terms, the intent of this project is to facilitate a continuation of Andersen's tradition of resource conservation. As the company approaches the new millennium, we are seeking to implement new production and product technologies that bridge the gap between mere compliance and environmental and economic sustainability. A successful XL project will help us meet that goal.

Andersen submits this proposal with the clear understanding that it requires Agency approval. In addition, our participation is contingent upon the successful negotiation of appropriate documentation that protects us from subsequent liability to MPCA, EPA, or third parties for actions taken pursuant to the XL agreement.


Among window and door manufacturers, Andersen has long been the market leader in developing and marketing products that advance the goals of environmental and economic sustainability. Andersen has pioneered the production of high-performance, long-lasting, energy-efficient windows and patio doors. Thus, our basic product line promotes energy efficiency and sustainability.

More recently, we worked with our suppliers to develop water-borne wood preservative formulations that provide the same product performance as their solvent-based predecessors. Since 1988, we have worked hard to replace old solvent-based preservative processes with new water-borne formulations.

Within the past few years, Andersen has developed the FibrexT waste-to-product technology. Using a combination of sawdust and vinyl, Andersen research and development efforts have created window components with performance characteristics similar to our existing vinyl-clad wood components. Currently, Andersen is using FibrexT technology in our RenewalT product line for the replacement window market and has begun the introduction of FibrexT components into some of our other existing products.

Finally, Andersen has been an environmental leader. We are proud of our achievements in the area of pollution prevention. In particular, we achieved an 85% reduction in releases of EPA 33/50 program substances in the period 1988-1995. Through calendar year 1996, and using 1988 as a baseline, we have reduced VOC emissions by 52%, reduced our Toxic Release Inventory emissions by 90%, and reduced solid waste landfilled by 96%. We developed and implemented an environmental management system before it was fashionable to do so and routinely conduct compliance audits of our facility. This environmental management system is a critical element of our XL proposal.

Andersen will continue our leadership position in developing durable, energy-efficient products with the most positive environmental impact. We further believe that the current regulatory structure discourages implementation of new technologies and creates disincentives for experimentation and innovation. We seek a permit that encourages, among other things, continued conversion to water-borne treatment and, potentially, coating technologies, expansion of our FibrexT production capacities, and experimentation with the ability to utilize waste streams in the production of FibrexT products. To summarize, Andersen believes an innovative regulatory structure will encourage and promote environmental performance.

Environmental Policy.

Since 1993, Andersen has operated pursuant to a corporate environmental policy. That policy has been modified several times to reflect the evolution of Andersen's thinking on environmental issues. The current policy states:

Andersen Corporation, an environmentally responsible citizen of the global community, recognizes its perpetual duty to:

Support the environmental goal to eliminate pollution at the source.

Conserve natural resources through reduction, reclamation, reuse and recycling of materials.

Develop long-lasting products that have a minimal effect on the environment.

Assure that its facilities, processes and products meet or exceed all applicable governmental standards and regulations relating to the environment.

Scope and Duration.

Andersen is seeking a 10-year multi-media agreement. We further propose that this agreement apply to all Andersen facilities in Bayport, Minnesota. This would include Andersen's existing manufacturing operations, as well as the currently-undeveloped Andersen property located approximately one mile southwest of Andersen's existing facility. Conceptually, our intent would be to regulate both these facilities in a manner that ensures a limited overall impact in Bayport and the surrounding region.

The Link Between Environmental Performance and Flexibility.

Andersen seeks a document which will help us further our goal of producing sustainable products in a sustainable manner. Our commitments to superior environmental performance and the regulatory flexibility we seek are addressed in more detail in subsequent sections. Nevertheless, we believe it is important to highlight the direct linkage between the two. In general, the flexibility we seek will allow us to more easily make the transition to more environmentally-friendly products and processes. As described below, flexibility facilitates increased reliance on low-solvent processes and will allow for further innovation with our waste-to-product technologies.

First, we believe the air permit structure we are proposing directly facilitates the transition to lower-emitting processes. As production expands, our current permit structure favors use of the older, solvent-based, "grandfathered" units rather than water-borne units that are subject to capacity limits. An emissions cap, coupled with a pound-per-unit limit, would allow us to maximize use of lower-emitting units and would more easily facilitate installation of additional water-borne processes as well as the continued transition to FibrexT technology, which does not require the use of liquid chemicals.

Second, the flexibility we seek under the solid and hazardous waste rules is intended to (1) encourage innovation in the waste-to-product capacity of the FibrexT technology and (2) facilitate implementation of successful production techniques utilizing additional waste streams. In particular, Andersen seeks to experiment with our ability to collect old window components, remove paint which may or may not contain lead, process any lead for productive reuse, and utilize the wood from those windows as feedstock for our FibrexT-based products.

Third, the flexibility inherent in this proposal facilitates environmental innovation. Andersen's commitment to continued innovation is not well served by burdensome recordkeeping or needless requirements which can be streamlined and/or addressed through Andersen's existing environmental management system.

Superior Environmental Performance.

Andersen proposes to continue our record of superior environmental performance through a series of commitments, some legally binding, some aspirational, but all subject to accountability through ongoing reports to Andersen's stakeholders. Andersen believes that superior environmental performance in this case begins with a recognition that we have achieved significant environmental results up to this point. In establishing a baseline by which to evaluate superior environmental performance, Andersen seeks no direct credit for those results but nevertheless we believe any evaluation of future results should be made in the context of Andersen's historical performance.

Further, as noted above, Andersen believes that superior environmental performance is the basic purpose of this project. The intent is to facilitate continued transition to water-borne preservative processes, low or non-hydrocarbon solvent coating systems, and implementation of FibrexT technology with, hopefully, an increasing waste-to-product component incorporated into the product makeup. All of this is in support of the continuing production of Andersen's long-lasting energy-efficient windows and doors.

During the course of this project, Andersen will welcome a specific evaluation of our performance and would intend to report on our performance in a variety of measures. Some specific suggestions follow:

Air Quality.

To ensure superior environmental performance in air quality, Andersen proposes to establish a 0.763 pound VOC per-unit-produced limit. In addition, Andersen proposes a project-wide cap of 2651 tons per year for VOC emissions. The pound-per-unit limit is based on actual emission rates at the time of our initial XL proposal (1994 data). The facility-wide cap is derived by multiplying the pound-per-unit limit times the maximum actual production achieved at the existing Bayport facility, adding 39 tons per year as the allowable minor modification amount, plus the existing 95-ton-per-year limit for the as-yet-unbuilt Andersen West facility. Our intent is that both these limits be legally enforceable through some mechanism and, by their nature, ensure superior environmental performance throughout the course of the project. In particular, the pound-per-unit limit functions to "lock in" our commitment to our newer, more environmentally-friendly processes and ensures that we will not utilize the excess capacity currently available in our solvent-based system. Andersen also intends to continue our efforts at pollution prevention, and we believe that during the duration of the XL agreement, our actual pounds of VOC per unit produced will continue to decrease below the legally-enforceable limit. We view this continued reduction as an aspirational commitment.

In addition, Andersen proposes a legally-enforceable commitment to exhaust all wood milling equipment through baghouse filter collectors, whether or not such control is legally required. Andersen will demonstrate that the filter systems represent Best Available Control Technology (BACT).

In addition, Andersen proposes to cap non-milling PM/PM10 emissions using the same methodology as that utilized for the VOC cap. As an aspirational commitment, Andersen will seek to reduce total PM and PM10 emissions over the course of the XL permit.

We also will monitor hazardous air pollutant emissions to assure that they continue to be below human health-risk thresholds based on a joint Andersen-MPCA-Minnesota Department of Health health risk evaluation.

Waste Issues.

Andersen proposes a commitment to continue our ongoing effort to reduce solid and hazardous waste generated at the facility. That commitment is reflected in our environmental management system. Andersen intends for any goals established pursuant to this process to be aspirational and not legally binding. Nevertheless, Andersen will continue our efforts to reduce waste generation and to find higher-end uses for our production by-products.

Andersen also will commit to an ongoing process to evaluate additional waste-to-product opportunities associated with our FibrexT technology. Although the results of any such process are uncertain, Andersen's desire is to find additional waste streams (old windows, as an example) which can be reclaimed and incorporated into FibrexT components.

Groundwater Remediation.

Andersen will continue to seek to explore and implement ways to enhance the groundwater remediation effort currently being implemented at the facility. In particular, we will continue to evaluate the effectiveness of the bioremediation system currently in place and continue to explore ways to improve the effectiveness of the system.

Environmental Management System.

Andersen will continue to abide by our environmental management system which includes several superior environmental performance elements. For example, the system provides for regular, independently-conducted on-site hazardous waste inspections, routine stormwater inspections, and team-conducted facility compliance audits. The system also contains elements such as Andersen's tank management plan, which includes procedures beyond those that are required by law.

Regulatory Flexibility.

In general, Andersen proposes to be able to undertake any projects or to add to or modify our facilities in any manner so long as such projects or changes are within the limitations established in the XL agreement. The following are specific areas of flexibility Andersen has identified:


Within the tons-per-year and pound-per-unit cap described previously, Andersen is seeking the authorization to modify our VOC-emitting processes without additional advance permitting requirements. We also seek the authorization to modify or add to our milling sources so long as those sources exhaust through the filter systems described above, and to modify our non-milling PM sources so long as total emissions from those sources remain below the PM/PM10 cap. Andersen also seeks to eliminate any historical synthetic minor limits governing VOC or particulate sources in favor of the limits described above.

Andersen does not seek waiver of any New Source Performance Standards and will comply with those standards to the extent they apply. Further, Andersen does not seek waiver of any NESHAP requirements and intends to comply with those requirements to the extent they apply to Andersen's facilities.


Andersen seeks advance authorization to experiment with the waste-to-product potential of our FibrexT technology. Initially, we have identified the possibility of utilizing old window components as product. We seek the ability to experiment with this process with a streamlined approach to any potentially-applicable solid and hazardous waste requirements. In particular, any old window take-back program will include experimentation with processes to remove lead and reclaim lead contained in window paint. Andersen seeks to manage any such waste streams without invoking RCRA treatment, storage or disposal facility requirements. Andersen also seeks authorization to implement on a production scale any successfully-demonstrated waste-to-product opportunities.

We also seek removal of the "penta" waste classification from our dip tank cleanout sludges and associated wastes. Although it has been many years since Andersen has used a pentachlorophenol formulation in our preservative processes, the dip tank sludges and associated wastes still bear that designation. As Andersen continues to phase in more environmentally-friendly preservative formulations, any waste resulting from that process still must be managed as a pentachlorophenol waste, even though the waste contains no pentachlorophenol.


Andersen seeks a consolidated approach for our existing groundwater remediation project and the potential closure of our dip tank area. The groundwater remediation project is intended to remedy contamination resulting from a railcar spill of preservative solution in the early 1980s. Andersen seeks to utilize this existing remediation system to meet any closure requirements associated with the dip tank area, without additional soil removal and with a streamlined means of disposal for any removed dip tank components.

Stakeholder Involvement Plan.

Andersen intends to implement a community advisory committee (CAC) to function as our local stakeholder group. Andersen will convene periodic meetings of the CAC to obtain comment on this proposal, as well as to brief the group on Andersen's progress during the duration of the XL agreement. Andersen's proposed stakeholder involvement plan is provided as an attachment to this proposal.

Environmental Management System.

As discussed previously, Andersen proposes to undertake our activities pursuant to our environmental management system. This system contains controlled written procedures that go beyond Andersen's regulatory obligations and includes regular facility audits. Andersen proposes that this system substitute for current regulatory enforcement inspections by federal, state, and county inspectors.

Pollution Prevention.

Andersen intends, as part of this project, to continue our ongoing pollution prevention efforts. Regardless of whether a particular substance is directly regulated as part of an XL agreement, Andersen will continue our process of reviewing all pollution prevention opportunities and will report on our pollution prevention progress.


We understand that the XL agreement will contain both legally-enforceable and aspirational requirements and will establish certain limits and goals for Andersen's performance. Andersen will ensure compliance with legal requirements and ensure implementation of processes to seek to meet aspirational goals through our environmental management system. Andersen will establish a recordkeeping system to ensure compliance, as well as accurate reporting of our environmental performance. While the nature and extent of such reporting will be subject to negotiation, Andersen will make any such reports available publicly and will specifically discuss our performance with our community advisory committee.

Basis for Project Acceptance.

We believe this proposal is appropriate for Project XL because it demonstrates directly the link between flexibility and environmental innovation. The ability to streamline a company's transition to more environmentally-beneficial products and processes is a concept worth proving and is transferable to other similar contexts. Andersen looks forward to working with MPCA and EPA to make that innovation happen.

TC2: 248009 v01 1/30/98

Attachment A

Flexibility Sought
The following is a preliminary list of those items which we have identified as areas of flexibility we will be seeking as part of our XL proposal. This list is not intended to be exclusive as other items may be identified as discussions progress.

Solid and Hazardous Waste Requirements

. Remove "Penta" waste classification from dip tank wastes

. Modify and revise existing closure requirements for dip tank area

. Authorize experimentation with waste-to-product potential of FibrexT with streamlined requirements for solid and hazardous waste management

. Authorize processing of lead paint from window take-back program without invoking RCRA TSD Program requirements


Air Requirements

. Waiver of state and federal modification/new source review permitting requirements relating to VOC and PM/PM10 sources

. Eliminate existing minor source permit limits for VOC and PM/PM10 sources

. Authority to permit non-contiguous sources as a single source for emissions cap/permitting purposes

. Replace certain existing tracking and monitoring obligations with streamlined mechanism for verifying compliance with permit obligations
TC2: 250875 v01 12/1/97

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