Intel Hydrogen Fluoride Releases

Intel Will Study Toxic Hydrogen Fluoride Releases As EPA Asks
Written by Jeff Radford
Sunday, 08 April 2012

Intel hopes to improve community acceptance of its efforts to reduce air pollution by enlisting some of Corrales’ elected officials for another round of emissions evaluation, this time for hydrogen fluoride (HF)
.

Last month, Intel’s Community Environmental Working Group (CEWG) completed setting up a process for computer modeling of pollution dispersion of HF. The plan calls for consultation with Mayor Phil Gasteyer and inclusion of Councillor John Alsobrook in directing the “Hydrogen Fluoride Spikes Study” process.

Alsobrook and Councillor Pat Clauser participated in an Intel emissions study two years ago to detect and measure the computer chip maker’s release of silica dust to the breathable air.

That earlier study had been sought by the federal Agency for Toxic Substances and Disease Registry (ATSDR) as a recommendation in its draft report for a Community Health Consultation which began in 2004. The final report has still not been released.

ATSDR was also interested in Intel’s releases of HF, a highly toxic chemical used in the manufacturing process here.

Toxicologists and industrial hygienists consider HF gas to be highly dangerous. The ATSDR reports, “The major health effect of chronic inhalation exposure to fluoride is skeletal fluorosis,” but notes the chemical “can cause bronchiolar ulceration, pulmonary hemorrhage and edema, and death. In addition, renal and hepatic damage have been observed in animal studies.”

ATSDR’s toxicity data also notes, “Fluorine gas is extremely irritating. The primary health effects of acute fluorine inhalation are nasal and eye irritation (at low levels) and death due to pulmonary edema (at high levels).”

According to the study process approved by Intel last month, the HF study proposal will also be submitted to ATSDR officials.

The process approved at the March 21 CEWG meeting notes that “a community-based task force will be established to conduct the spikes study. To build the task force, the CEWG will consult with the mayor of Corrales and the Village Council, and will advertise in the Corrales Comment. A list of potential participants will be drafted and sent to the council to review.

“A small committee consisting of Hugh Church [a representative from the American Lung Association’s New Mexico chapter], Mike Williams [of New Mexicans for Clean Air and Water] and John Alsobrook will convene to establish possible provisional levels [under which HF levels in the air would be considered insignificant]. The committee will survey the literature, establish a rationale and possible provisional level and report back to the CEWG. Once authorized by the CEWG, this report will be sent to the ATSDR for comment, and additional public input may be invited.”

The proposal goes to specify:

• the provisional level will be established as above;

- the task force will be formed as above;

- the task force will create a modeling protocol using the following process:

- use AERMOD as the modeling program; [AERMOD pollution plume dispersion modeling was developed by the EPA and the American Meteorological Society in the early 1990s, and was adopted by EPA as a preferred regulatory modeling method in spring 2000.]

- survey existing public data and determine what data to use in consultation with Class One and ERM [two consultants and emissions testing firms with Intel contracts];

- determine how to sample the data and the length of sampling;

- determine the report format and authors at this stage, before modeling is done;

- conduct a first-cut trial to test the model;

- revise the data as needed and run a second-cut trial if desired;

- refine the model based on first- and second-cut trials.”

After that, the resulting modeling protocol would be reported to Intel committee and to the Village Council. Finally, the actual computer modeling of HF releases would be run.

The above description of the process is ambiguous whether those procedures including capturing and analyzing new samples of HF releases from Intel’s scrubbers or whether the study will draw from existing data on samples, perhaps collected years ago.

The last step of the study process says, “The final report will be issued to the task force. Once the task force is satisfied with the report, it will be given to the CEWG. The CEWG will present the report at a public meeting and send it to the ATSDR and the Village Council.”

Hydrogen fluoride used or produced by Intel’s manufacturing process on the escarpment above Corrales is supposed to be largely removed from emissions to the air by acid gas scrubbers, or intense water sprays that strip the chemical from the exhaust flow.

However, in the U.S. Environmental Protection Agency’s 2010 crackdown on Intel’s operations in Rio Rancho, the agency questioned the accuracy of Intel’s reported releases of HF and other acid gases. (See Corrales Comment Vol.XXIX, No.17 October 23, 2010 “EPA Inspection Report Slams Intel Air Pollution Permit”)

The combined report by the EPA and its National Enforcement Investigations Center (NEIC) details numerous instances in which Intel’s air pollution reporting was inadequate or possibly misleading. It stated, for example, that NEIC reviewed Intel’s accounting for emissions that occur during downtimes for the incinerators that burn off volatile organic compounds (VOCs) and organic Hazardous Air Pollutants (HAPs) such as HF.

“Intel included the downtimes in its volatile organic compound calculations, but did not account for downtimes in its Hazardous Air Pollutant calculations.… Intel failed to account for the downtimes in its Hazardous Air Pollutant emissions calculations in 2008 and 2009,” the report noted.

The citizens group Corrales Residents for Clean Air and Water (CRCAW) has always distrusted Intel’s use of emissions factors to report its toxic emissions, insisting that releases to the air be continuously monitored and measured rather than calculated using what they regard as phony, unverifiable multipliers.

Steve Martinez, a CRCAW member and professional data analyst, made that point when he reviewed the EPA report in 2010. “During their brief investigation, the EPA readily found two emission factors that were in error.

“If two emission factors were easily found to be erroneous in such a short period of time, one has to wonder how many of the dozens of other emission factors are also in error?

“And what is the true impact of all of the potentially erroneous emission factors on the total pollution volume emitted by Intel?”

Over and over, the EPA and NEIC teams slammed Intel’s data which “may not be valid for use in calculating Hazardous Air Pollutant emissions.”

One of those “areas of concern” cited by EPA involved the possible under-estimation of a particularly dangerous chemical, the acid gas hydrogen fluoride (HF). “Intel uses an average [acid gas] scrubber removal efficiency that was calculated from stack test results that do not relate to pH of the scrubber water liquid or water addition to the scrubber at the time of testing. Intel may be under-estimating HF emissions when the pH of the scrubber liquid is low.”

Another “area of concern” cited was that “Intel has changed its processes and chemical usage many times since the scrubber testing in 1995 and 1996. The facility continues to use scrubber efficiency testing from outdated processes for calculating current Hazardous Air Pollutant emissions, which could result in inaccuracies.”

EPA also alleged that “Intel continues to use the results of the unapproved and potentially inaccurate testing to calculate HAP emissions from scrubbers at the facility.”

The two agencies gave considerable attention to the inadequacy of the air pollution permit issued by the N.M. Air Quality Bureau. Reinforcing the criticism voiced for years by CRCAW members and homeowners near Intel, the NEIC team stated, “The N.M. Environment Department permit does not contain short-term (hourly, daily, monthly) emissions limits for volatile organic compounds and Hazardous Air Pollutants. Without short-term limits, Intel can have spikes in its emission profile that can lead to acute exposures of these chemicals.”

That situation is listed as one of the 15 “areas of concern” spelled out in the EPA-NEIC report.

The investigators documented the inadequacy of the permit noting that “NMED has set emissions limits in the permit that cannot be exceeded by Intel under any circumstances.” In essence, what critics have called a “bust proof” permit.

Meanwhile, Corrales residents who live near Intel continue to register complaints of illnesses they relate to exposure to Intel’s emissions. The villager who has logged most complaints over the past 20 years, Joy Tschawuschian, reported March 29 that she was experiencing “a strong, bitter chemical odor that drifted on this property while I was trying to prune roses.

“These chemicals caused an immediate headache, nausea and blurring vision.” As usual, she noted, Intel officials assured her that “everything is up and running” to treat their pollutants before discharge.