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Minnesota Pollution Control Agency (MPCA)
Andersen Windows Proposal
ANDERSEN CORPORATION
XL PROPOSAL
Andersen Corporation is submitting this proposal to the Minnesota Pollution Control Agency pursuant to MPCA's Project XL pilot program. This proposal reflects Andersen's willingness to negotiate a document which makes enforceable Andersen's existing commitment to go beyond compliance with environmental regulations, in exchange for regulatory flexibility as described below. Andersen looks forward to working with the MPCA to create such a document.
Andersen submits this proposal with the clear understanding that it requires MPCA approval. In addition, Andersen's participation is contingent upon the successful negotiation of appropriate documentation that protects Andersen and the MPCA from subsequent liability to EPA or third parties for actions taken pursuant to the XL agreement.
I. SCOPE
Andersen proposes that this project be multi-media and apply to all Andersen Bayport facilities.
II. BEYOND COMPLIANCE COMMITMENTS
A. Air Emissions
1. VOCs
- Establish a 3,000 TPY VOC emission cap (reflects a ten percent reduction from a baseline established using the sum of a five year historical average of non-permitted emission units and permitted emission levels for permitted sources).
2. Particulate Matter
- Make enforceable a commitment to exhaust all milling equipment through bag houses. (Note: even if milling equipment is exhausted internally, it passes through a bag house).
3. Hazardous Air Pollutants
- Establish a HAP cap (tentatively considering a fifty percent reduction from five-year historical average).
- Provide express commitment to restrict hazardous air pollutant emissions to below human health risk thresholds based on joint Andersen/MPCA/MDH health risk evaluation.
4. Incinerators
- Permanently cease operation of waste incineration systems.
B. Waste
1. Solid Waste
- Provide commitment that less than 10 percent of all generated solid industrial wastes/by-products end up in landfill - greater than 90 percent are beneficially reused/reclaimed/recycled (dependent on continued operation/capacity of RDF facility).
- Commitment to evaluate waste reduction or higher value-added opportunities regarding industrial solid wastes/by-products until such point as continued evaluation appears to be achieving no significant additional results.
2. Nonhazardous Special Wastes/By-Products
- Commitment to evaluate waste reduction or higher value-added opportunities regarding currently-generated special wastes/by-products until such point as continued evaluation appears to be achieving no significant additional results.
3. Hazardous Wastes/By-Products
- Commitment to continue regular onsite hazardous waste inspections.
- Commitment to evaluate waste reduction or higher value added opportunities regarding currently generated hazardous wastes/by-products until such point as continued evaluation appears to be achieving no significant additional results.
C. Chemical Storage Tanks
Andersen proposes a commitment to abide by Andersen's existing Tank Management Plan which sets forth tank management procedures beyond those required by law.
D. Water
1. NPDES Discharge
- Commitment to not chlorinate water to outfalls.
2. Stormwater
- Commitment to undertake regular stormwater inspections.
3. Well Water
- Annually evaluate well water reduction opportunities.
4. Drinking Water
- Commitment to further sanitize well water utilized for drinking water purposes by year end 1997.
5. Groundwater
- Install and maintain a pilot bioremediation system to assist in the cleanup of the groundwater project. Continue to operate and maintain existing groundwater pump-out system until site closure standards are met.
III. FLEXIBILITY
In exchange for those enforceable commitments, Andersen would seek the following regulatory flexibility.
- The ability to add to or modify its facilities in any manner so long as such changes are within the limitations set forth in the document.
- Provide authorization to utilize sawdust, vinyl or removed window components as product input for composite product; authorization to remove old window paint and ship for reclamation.
- Terminate existing hazardous waste agreement and provide for closure of dip tank area within context of existing groundwater consent agreement without additional characterization or soil removal, and disposal of dip tank components for smelting or other beneficial re-use.
- Resolve existing NSR issues associated with dip tank area.
- Remove "penta" waste classification from dip tank clean-out sludges.
- Remove existing units/shift process constraints on Building 46 sawdust bag houses.
- Create streamlined process for management of small quantities of waste generated in testing of waste reduction opportunities or new product testing.
- Exempt projects consistent with this document from Environmental Review requirements.
- Provide advance authorization for conversion from wood to gas boilers.
- Streamline approvals for expansion of existing groundwater bioremediation project.
- Reduce sampling and analytical testing frequency on groundwater program for wells outside area of significant contamination.
- Reduce frequency of annual groundwater reports.
- Reduce frequency of drinking water testing.
IV. VERIFICATION
Andersen will implement a record-keeping/verification system to track inputs and outputs to verify compliance with XL limits. Andersen proposes that such record-keeping and tracking system report outputs in lieu of a separate TRI Form R report and air emission inventory.
As an example, Andersen proposes a system of tracking purchases of VOC emitting materials, applying an appropriate emissions factor to reflect material emissions or the presence of control equipment, and verifying compliance with the cap. For sawdust emissions, Andersen proposes a system to track actual sawdust emissions based on mutually agreed-upon emission factors derived by performing extended test runs (eight hours minimum) divided by the length of the run.
V. COMMUNITY ADVISORY COMMITTEE
Andersen proposes to establish a committee of local citizens to act as a liaison between Andersen and the local community in environmental matters.
VI. ENVIRONMENTAL MANAGEMENT SYSTEM
Andersen proposes to provide an enforceable commitment to establish and maintain an environmental management system which includes regular audits, and that such system replace current regulatory enforcement inspections by federal, state, and county inspectors.