Performance Track Logo
OMB No. 2010-0032
Expiration Date 01/31/2010
2007 Performance Track Annual Performance Report

















Louisiana Pacific - Middlebury, Indiana
A050095
Year 3 Annual Performance Report
Member Since 2005 (1st Member Term)



























SECTION A: GENERAL FACILITY INFORMATION


Louisiana Pacific - Middlebury, Indiana

 
Louisiana-Pacific Corporation

  Mr. Tim Keenoy
  Plant Environmental Manager
  574-825-6548
  574-825-6547
  Tim.Keenoy@LPCorp.com


219 U.S. Highway 20 West
Middlebury
IN
46540


P.O Box 509
Middlebury
IN
46540


http://www.LPCorp.com (Corporate website)

100-499

326199


Manufacturer of pre-finished foamed plastic trim moulding. The plastic mouldings are pre-finished alternatives to traditional wood mouldings used around windows, doors and floors.

The plant is about 250,000 square feet in size and is located in an area of farmland and scattered residential housing. The total facility property area is about 35 acres.

No



SECTION B: ENVIRONMENTAL MANAGEMENT SYSTEM


No

No


June 2007
PT Independent Assessment Protocol
Specify:
Name: Marilyn Rash
Title: Compliance Systems Audit Manager
Organization: Louisiana Pacific Corp.
Policy, Planning, Implementation, Checking, Management
Entire Facility



No

June 2008



Yes

October 2007
Clean Air Act (CAA)
Clean Water Act (CWA)
Emergency Planning & Community Right-To-Know Act (EPCRA)
Resource Conservation and Recovery Act (RCRA)





In September, 2007 EPA Region V conducted an unannounced RCRA audit of our facility. No violations were found. In August 2006, a group of personnel from EPA Region V, EPA headquarters and IDEM conducted a Performance Track site visit. In September 2006, an Environmental Compliance Peer Review Audit was conducted by LP corporate staff and two LP plant environmental managers. The Indiana Office of Pollution Prevention and Technical Assistance performs confidential compliance audits annually. The last three of these audits were conducted in November 2005, November 2006 and October 2007. In March 2006, IDEM personnel conducted an unannounced multimedia audit of the plant. No violations were found. In December 2005, the Indiana Clean Manufacturing Technology and Safe Materials Institute audited the plant for pollution prevention opportunities. In December 2005, a self assessment for an EMS gap analysis was conducted by the plant environmental manager.


Yes


Yes

Mr.  Jim Kinzler
  Plant Manager


June 2007



SECTION C: ENVIRONMENTAL PERFORMANCE RESULTS



Goal 1: Louisiana Pacific - Middlebury, Indiana's first goal is to reduce the facility's generation of non-hazardous waste, specifically polystyrene with paper laminate.

In 2007, this project was in the "maintenance phase". We have significantly exceeded our goal.

We have exceeded our goal. This happened because we worked with our waste hauler to install a lid on the open top waste hopper (September 2005). This prevents precipitation from wetting the waste which reduced the overall weight of the waste.
We were able to accomplish the project to reduce the length of the raw trim moulding by one inch. This reduced the end trimming scrap from the off-line paper lamination process which resulted in a decrease of scrap to near the projected level.

The net weight of the waste in the hopper used for the collection of trimmings from the lamination department is the amount of waste. It is normalized by the amount of production (annual gross lineal footage processed) through the lamination department.

2004
2005
2006
2007
Landfill 161,232 121,063 111,354 95,557 Pounds

Total Non Hazardous Waste 80.62 60.53 55.68 47.78 n/a Tons


Normalizing Factor 1.0 1.1 1.27 1.19
Total Non Hazardous Waste 80.62 55.03 43.84 40.15 54.01 Tons

Gross lineal footage processed annually by the lamination department.




Goal 2: Louisiana Pacific - Middlebury, Indiana's second goal is to reduce the facility's generation of hazardous waste, specifically flammable solids.

This project was completed in 2005 and is now in the "maintenance" phase. The RCRA non-hazardous waste flammable solids waste stream is collected in drums and incinerated. This method of treatment is the best management practice for this waste stream as the facility does not wish to send solvent-contaminated disposables to the local landfill.

This project was completed in 2005 and is now in the "maintenance" phase.
The plant's spent solvent hazardous waste used to be an F-listed waste. Items contaminated with the F-listed waste were handled as a hazardous waste. A campaign to reduce the toxicity of the spent solvent was implemented several years ago. When the solvent was reclaimed, a low HAP's solvent was purchased to make up for the reclamation yield loss of about 20%. Over a period of years, the concentration of F-listed consituents in the solvent decreased significantly allowing the F-listing to be dropped. The solids items such as gloves and rags contaminated with the spent solvent were also allowed to drop the F-listing. These materials were then evaluated for hazardous waste characteristics and were found to be RCRA non-hazardous. In 2005, one drum of material was sent out as hazardous waste before the determination was finally completed.

The amount of hazardous waste flammable solids generated in a year is the waste quantity. It is normalized by the amount of production (annual gross lineal footage processed) from the print department as most of this waste stream is generated by this department.

2004
2005
2006
2007
Incineration 5,038 458 0.00 0 Pounds

Total Hazardous Waste 2.52 0.23 0.00 0.00 n/a Tons


Normalizing Factor 1.0 .97 0.73 0.56
Total Hazardous Waste 2.52 0.24 0.00 0.00 0.00 Tons

Annual lineal footage of moulding printed in the print department.





Goal 3: Louisiana Pacific - Middlebury, Indiana's third goal is to reduce the facility's total (non-transportation) energy use.

We continued to increase our energy reduction practices in the plant. We determined that we did not need to run the dehumidifier(s) in our flowcoat paint department. Lights are now turned off in areas of the plant where people are not routinely present. The light switches in many offices and rest rooms have been replaced with motion detectors. The HVAC in our print/lamination department was again adjusted to reduce heating and cooling requirements. The air handling unit for the maintenance department is turned off during 2nd and 3rd shifts. The setpoints on the thermostats on the plant's space heaters were turned down. We continued to emphasize energy reduction during our environmental training sessions.

We continue to actively pursue the reduction of energy usage. The drive motors on three extruders were replaced with more energy efficient substitutes. Another section of our roof was renovated with a better insulation rating. The air make-up units have been adjusted to use less outside air resulting in a decreased need to heat the air. T8 fluorescent lamps/fixtures are the new plant standard whenever a fixture is replaced. Reduced energy use is reinforced during environmental training sessions.
Improved efficiency in the extrusion department (by scheduling longer runs) and a focus on energy reduction consciousness resulted in a decrease in the use of electricity. The usage of natural gas increased due to an increase in the second shift operation resulting in the need to run additional air makeup units. The plant is continuing with the campaign to replace the existing roof with a more energy-efficient roof.

Note: 2004 Natural Gas usage was changed from 15,420 MMBtus to 16,052 MMBtus. The change is to allow the dates of the natural gas bill and monthly heating degree dates to coincide.

The amount of energy used is the usage of electricity (kwh converted to MMBtu) added to the usage of natural gas (ccf converted to MMBtu). The energy usage is normalized by the amount of production in the extrusion department (annual gross lineal footage extruded) and by the number of heating/cooling degree days.


42,197 40,364 39,609 34,492 MMBtus
42,197.00 40,364.00 39,609.00 34,492.00 MMBtus

RFC West


EPA will be determining the greenhouse gases associated with the generation of the steam that you purchase. We will be contacting you for additional information regarding the source of the steam generated.
Btus
42,197.00 40,364.00 39,609.00 34,492.00

16,052 16,434 11,659 10,492 MMBtus
16,052.00 16,434.00 11,659.00 10,492.00

464.17 444.00 435.70 379.41 n/a
57,784.83 56,354.00 50,832.30 44,604.59 n/a
58,249.00 56,798.00 51,268.00 44,984.00 n/a
9,580.48 9,221.41 8,812.57 7,692.04 n/a
9,580.48 9,221.41 8,812.57 7,692.04 n/a


1.0 .98 0.933 0.848
58,249.00 57,957.14 54,949.62 53,047.17 56,465.00 MMBtus
9,580.48 9,409.60 9,445.41 9,070.80 9,432.96 MTCO2E

Annual gross footage of moulding extruded adjusted for cooling/heating degree days





Goal 4: Louisiana Pacific - Middlebury, Indiana's fourth goal is to reduce the facility's VOC emissions.

VOC reductions exceeded our goal due to three factors: we claimed a full year of VOC reduction for our largest volume paint (in 2006 we used this paint for only 1/2 the year), we eliminated the use of a surface primer on some of our paper-laminated mouldings and the production volume of our wet printed mouldings continued to decline (this process has higher VOC emissions per foot of product).

We have made progress on this goal by approving a replacement paint with lower VOCs for our highest volume paint. We continue to work with suppliers on UV-cured coatings but it is unlikely that this project will be successful in the near future.
We worked with three different suppliers of UV-cured coatings in 2005. None of them had much success working with our cellular plastic substrate due to the coatings attack on the surface. Two of the suppliers have since dropped the project. We will look for additional suppliers to work on this project. Also, we will try to reduce the amount of VOC's in our largest volume waterbase coatings.

The amount of volatile organic compounds (VOCs) are tracked and reported as required by the plant's air permit. The total annual emissions of VOCs are normalized by the amount of production in the extrusion department (annual gross lineal footage extruded).

 
 
2004
2005
2006
2007
Actual Quantity (per year) 20.44 19.40 18.16 12.58 n/a Tons

Normalizing Factor 1.0 0.98 0.945 .815
Normalized Quantity 20.44 19.80 19.22 15.44 18.40 Tons

VOC emissions are fairly equally distributed between three departments: extrusion, flowcoat and print. Thus, annual gross footage of moulding extruded will be the normalizing factor.








In the table below, please provide a narrative summary of progress made toward EMS objectives and targets other than those reported as Environmental Performance Goals. You may limit the summary to environmental aspects that are significant and towards which progress has been made during the reporting year.

Do you have additional environmental aspects to report?   No







SECTION D: PUBLIC OUTREACH AND PERFORMANCE REPORTING


The plant is a plastics processor (extrusion) with some finishing operations. Because this is a relatively clean industry, environmental concerns are minimal. Reaction to catastrophic events including evacuation of nearby residents are detailed in the plant's hazardous waste contingency plan. Also, potential incidents such as spills which may impact the community are listed in the plant's aspects & impacts analysis. The plant's EMS team includes members from the local community.

Environmental SOP 603 was written to insure that bulk truck transfer of solvents to/from storage tanks is performed in the safest possible manner with plant personnel present. The plant's Spill Prevention, Control & Countermeasures plan includes weekly inspection of all tanks and transformers on the property. The plant voluntarily performs an annual wastewater sampling and analysis to insure compliance with the local sewer ordinance.

The Middlebury Fire Department is given a plant tour every year. The results of the annual wastewater analysis is shared with the superintendent of the local POTW. The plant issues press releases of important environmental events for the plant. In 2007, the commissioner of IDEM visited the plant to acknowledge the plant's acceptance as charter members into the Indiana Environmental Stewardship Program. The plant environmental manager is one of two industry members of the Elkhart County Solid Waste Advisory Committee.

Press Releases, Building Lobby, Other
Please Specify Other: Copy of 2006 APR in Middlebury Public Library








OMB No. 2010-0032

SECTION E: SELF-CERTIFICATION OF CONTINUED PROGRAM PARTICIPATION FOR ANNUAL PERFORMANCE REPORT


The U.S. Environmental Protection Agency is not yet in a position to accept electronic signatures and therefore requests a faxed, signed copy of the Section E page. Please complete Section E online, then print Section E using the link on the Overview page. Section E should be signed by the senior manager of your facility and faxed it to the Performance Track Information Center at (617) 354-0463.

On behalf of Louisiana Pacific - Middlebury, Indiana, I certify that:

  • I have read and agree to the terms and conditions as specified in the National Enviromental Performance Track Program Guide. This facility, to the best of my knowledge, continues to meet all program criteria;

  • I have personally examined and am familiar with the information contained in this Annual Performance Report. The information contained in this report is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete;

  • My facility has an environmental management system (EMS), as defined in the Performance Track EMS criteria, including systems to maintain compliance with all applicable federal, state, tribal, and local environmental requirements, in place at the facility, and the EMS will be maintained for the duration of the facility's participation in the program;

  • My facility has conducted an objective assessment of its compliance with all applicable federal, state, tribal, and local environmental requirements; and the facility has corrected all identified instances of potential or actual noncompliance; and

  • Based on the foregoing compliance assessments and subsequent corrective actions (if any were necessary), my facility is, to the best of my knowledge and based on reasonable inquiry, currently in compliance with applicable federal, state, tribal, and local environmental requirements.

I agree that EPA's decision whether to accept participants into or remove them from the National Environment Performance Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's acceptance or removal decision. I am the senior manager with responsibility for the facility and am fully authorized to execute this statement on behalf of the corporation or other legal entity whose facility is part of the National Environmental Performance Track program.

______________________________________________________
Mr. Jim Kinzler
Plant Manager
Louisiana Pacific - Middlebury, Indiana
219 U.S. Highway 20 West
Middlebury, IN 46540
P.O. Box 509
Middlebury, IN 46540
A050095