Environmental Performance
VOC Performance Ratio
VOC PAL
Non-Milling Particulate Cap
XL Reports
In developing Andersen's XL project, Andersen proposed an innovative measurement to track Volatile Organic Compound (VOC) air emissions per standard measure of production, known as the performance ratio. Historically, Andersen made significant environmental improvements, and large reductions in the future could be incrementally more difficult. Therefore, performace ratio is based on measuring and reporting actual environmental performance based on production levels. It prevents a return to historic methods and processes and encourages Andersen to continue to make environmental improvements.
On an annual basis, Andersen calculates the performance ratio. It is then compared to the CAC Limit, the Project Limit, and the Reward Level.
The CAC Limit will serve at the main limit for evaluating Andersen’s ongoing environmental performance. The CAC Limit is an average of the prior five years’ performance ratios. It was established at the onset of Andersen’s XL project in the Final Project Agreement, and under the XL Permit, will be adjusted every three years. The CAC Limit can be reduced, but it cannot go below the Reward Limit nor can it increase without Community Advisory Committee approval. If Andersen’s annual performance ratio exceeds the CAC limit, Andersen will notify the Community Advisory Committee, and together they will establish a corrective action plan to bring the performance ratio back below the limit. This establishes the important role of the community stakeholder group in ensuring superior environmental performance.
The Project Limit is set at two standard deviations above the CAC Limit. If the annual performance ratio exceeds the Project Limit, Andersen could be removed from EPA’s XL Program.
The Reward Level is set at two standard deviations below the CAC Limit. The Reward Level will not increase and will only decline if Andersen remains below it for three consecutive years. If the facility operates below the Reward Level, it will potentially receive rewards defined in the Final Project Agreement as recognition by EPA and MPCA, addition of other innovative projects under XL, and/or extension of the project duration.
Volatile Organic Compound (VOC) air emissions are capped at a level of 2,397 tons per year under the Plantwide Applicability Limit (PAL). The PAL was established based on past actual emissions at the time of the permit application. Because of pollution prevent projects since that time, Andersen has continured to significantly reduce VOC emissions and operate under the PAL level.
Compliance with the VOC PAL is demonstrated under the XL Permit on a monthly basis as a 12-month rolling sum. This is reported to the Community Advisory Committee on a Semi-Annual Basis (Each January and July).
Particulate emissions from non-milling sources are initially capped at a level of 84 tons per year (Phase 1 limit), and will eventually decrease to 55 tons per year (Phase 2 limit) after one full year of operation of the new boilers installed in 2007. During the first year of operation of the new boilers, the Non-Milling Particulate Cap will proportionally decrease on a monthly basis.
The cap was established for non-milling operations based on past actual emissions at the time of permit application. Because of pollution prevention projects since that time, Andersen has continued to significantly reduce non-milliing particulate emissions and operate under the cap limits.
Compliance with the Non-Milling Particulate Cap is demonstrated under the XL Permit on a monthly basis as a 12-month rolling sum. This is reported to the Community Advisory Committee on a Semi-Annual Basis (each February and August).
Semiannual XL Reports:
1st Half 2006 XL Report
2nd Half 2006 XL Report
Semiannual PAL Reports:
1st Half 2006 PAL Report
2nd Half 2006 PAL Report
