Letter to Intel and NMED

 

March 5, 2004

 

Andrew S. Grove
Chairman of the Board

Intel Corporation

2200 Mission College Blvd.

Santa Clara, CA 9505

 

RE: HARMFUL TOXIC CHEMICAL RELEASES BY INTEL RIO RANCHO

 

Dear:

For over a decade, Corrales Residents for Clean Air and Water (CRCAW) has made every effort to hold Intel Rio Rancho accountable for the irresponsible releases of toxic chemicals that are harmful to the health of Corrales and Rio Rancho residents.  A chronology of events, 1980 to present, relating to CRCAW and Intel Rio Rancho is attached for your review.

The Corrales Air Toxics Task Force sponsored by the NM Environment Department is coming to a close in a few months.  CRCAW will make the recommendation that Intel’s minor-source permit be reopened and rewritten to include the following specific permit changes:

  • The current 12-month rolling average provides no protection, as it allows Intel to release its annual limit of each chemical compound in as short a time as Intel chooses, as long as the limit is not exceeded during any 12-month period.  Because exposures to high concentrations for short durations are especially hazardous, the rolling average should be replaced with hourly and daily emission limits.

  • The current “bubble” concept, in which the entire site is treated as one emission source should be replaced with individual limits on each RTO stack and each acid-gas system at each FAB.

  • Intel currently is allowed to calculate its reported emissions using unverified emission factors.  Calculations using these emission factors should be eliminated and replaced with continuous monitoring for all compounds used and their potential byproducts on each emission source, including all scrubbers and thermal oxidizer stacks if necessary, re-working of ducting and plenums to accomplish this should be a condition of the operating permit.

  • Because the measured efficiencies of the acid-gas scrubbers are often too low to significantly abate the toxic gasses they receive, either no control efficiency should be allowed for the gas scrubbers or the operating permit should require that Intel apply additional and effective abatement technology to improve the efficiencies of these units. The operating permit should specify the minimum efficiencies for each compound for each scrubber, as well as short and long term emission limits with continuous input and output monitoring to ensure the ability to determine compliance at all times, as is required.

  • Whereas manufacturer technical data shows (and this has been demonstrated in the Taiwan semiconductor industry) it is possible to maintain 100% up-time on thermal oxidizers, the operating permit should require that all Intel thermal oxidizers be provided with backup units to eliminate untreated emissions during all down times. The operating permit should also require that Intel draft for NMED approval and incorporation into the operating permit, switch-over procedures during preventative maintenance as well as unanticipated failures that ensure VOC destruction while minimizing byproducts of natural gas combustion.
  • The permit should require that Intel not only notify NMED of abatement equipment failures via 801 forms, but also make this information available to the public on the same schedule as required by the NMAC and Intel's operating permit. This should be done via a recorded phone message system, as well as posted on a publicly accessible Internet web site. Whereas Intel must notify NMED in advance of preventative maintenance on abatement equipment, the public should also be made aware of these opportunities for increased emissions via the same mechanisms as listed above. 
  • A minimum control efficiency of at least 90% should be imposed on the RTOs.

  • Intel’s short stacks create considerable downwash, which brings toxic pollutants to ground level in Corrales residential neighborhoods.  Intel should be denied the use of stack-height correction factors, which currently allow them to avoid the thresholds for individual pollutants in 20 NMAC 2.72 Air Toxics.
  • Intel emissions should be identified by species.  Because the toxicity’s of various compounds Intel is allowed to release can vary by factors of hundreds or more, hazardous pollution levels should not be given as “VOC expressed as propane” as is currently done, but as the measured amounts of each chemical compound.
  • Intel should accept permit revisions that would impose threshold values for toxic compounds at least as stringent as the ESLs used in Texas.  No permit should allow Intel to release toxic compounds that exceed accepted safe exposure levels, as Intel’s own FTIR measurements have shown it to be doing.  The absence of safe threshold limits for Intel emissions is unacceptable.

In summary, CRCAW, before exercising other options, presents these reasonable demands to you as Intel’s Executive Management and Board of Directors. CRCAW requires an immediate and direct commitment by Intel, by March 20, 2004, to remedy this hazardous situation through adoption of the above permit revisions.

If you would like to learn more about CRCAW and their efforts to make their community a safer place to live, please visit the CRCAW web site at www.faceintel.com/corrales.htm

Sincerely,

 

Ken Hamidi

Spokesperson for Corrales Residents for Clean Air and Water (California Office)

7349 Cross Drive

Citrus Heights, CA 95610