to Intel and NMED
Chairman of the Board
|2200 Mission College Blvd.
Santa Clara, CA
HARMFUL TOXIC CHEMICAL RELEASES BY INTEL RIO RANCHO
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.
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
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.
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.
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.
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.
short stacks create considerable downwash, which brings toxic
pollutants to ground level in Corrales residential
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.
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.
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.
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
for Corrales Residents for Clean Air and Water (California
Heights, CA 95610