EPA Holds Intel Accountable

The following are comments from retired Los Alamos Labs chemist Fred Marsh on the recently-released 727-page EPA report on an 'unscheduled' inspection of the Intel Rio Rancho facility. It remains to be seen what action the New Mexico Environment Department will take. We have been demanding the replacement of Intel's sham permit for years with a major source permit.

"EPA is finally holding Intel and the New Mexico Environment Department accountable for decades of releasing poisons into the air nearby residents must breathe. A few examples from the NEIC/EPA report:

page 12. Intel's calculated release of ethyl lactate understated the actual release by 36%.

page 13. "Intel uses the same scrubber efficiency for all scrubbers, although they have different chemical loadings."

page page 14. "NEIC could not reproduce the data Intel used in its 2005 permit revision for scrubber efficiency."

page 16. "lack of correlation between inlet and outlet concentrations for hydrogen fluoride"

page 21. "Intel's use of high removal efficiency [for scrubbers] may not accurately account for total HAP emissions."

page 22. "no stack tests have been performed to determine if [sodium hydroxide] addition has any effect on scrubber removal efficiency."

page 24. "The potential to emit of HAPS is not practically limited by Intel's permit."

page 24. "Without an accurate test of operational units in the permit, it is unclear what units are subject to permit limits and requirements."

page 25. "NMED has set emission limits in the permit that cannot be exceeded by Intel under any circumstances." (Fred's comment: This shocking finding alone confirms what we have long claimed, and justifies replacing what Jim Shively called Intel's bust-proof permit.)

page 25. "Without short-term limits, Intel can have spikes in its emission profile that can lead to acute exposures of these chemicals." Fred's comment: This also confirms what we have been saying for the past two decades. I addressed spikes directly in my July 2000 EIB hearing testimony, which Barbara Rockwell included in "Boiling Frogs."

My EIB testimony on this subject was:

"The rate at which toxic pollutants are released also has a major role in their risk to public health. I'll demonstrate with an example involving hydrogen cyanide, which is used in gas chamber executions. According to the Chemical Warfare Commission, 300 milligrams of hydrogen cyanide per cubic meter is immediately lethal. However, the NIOSH toxicity data allow workers to be exposed to a 60-fold lower concentration of hydrogen cyanide for a 10-hour workday.

"This means that although an exposure to a 300-mg level for 10 minutes would kill you, an exposure to a 60-fold lower concentration for 60 times as long would have no adverse effects. The total exposures to cyanide are the same in these two cases; however, a short exposure to high concentrations is lethal, whereas a 60-times longer exposure at a lower concentration is not.

"This illustrates why high-concentration spikes are especially hazardous. Yet, Intel is not required by the revised [minor-source] permit to report such high-concentration spike releases. In fact, if you wanted to hide such high-concentration releases, the most effective means would be to use a long-term average -- such as the 12-month rolling average allowed by Intel's revised permit."