Air Quality

Intel air quality permit application Information meeting Feb. 19, 2015 Hillsboro

George Davis | Oregon Department of Environmental Quality

Good Neighbor Agreement The Good Neighbor Agreement will be an agreement between Intel, Neighbors for Clean Air and Northwest Environmental Defense Center • DEQ is not a party to the Settlement Agreement • Memorializes 2014 Settlement Agreement commitments .

Good Neighbor Agreement Air Toxics Emissions Inventory Air Toxics Emissions Testing (supplements DEQ-required testing) Modeling Protocol Air Toxics Risk Assessment Emission Reductions (if necessary, based on Risk Assessment) Ambient Monitoring (in community) Emissions Monitoring (as appropriate)

Good Neighbor Agreement Next Air Quality Advisory Committee Meeting: March 18 at Brookwood Library (www.oraqac.com)

ALS (Lou Gehrig’s disease) DEQ is aware of the news story that alleges a connection between the semiconductor manufacturing industry and the incidence of ALS or Lou Gehrig’s disease. DEQ does not have the medical expertise to investigate this allegation. If you have questions about the news story you can contact:

Julie Early-Alberts Program Manager, Assessment Unit Environmental Public Health Services Oregon Health Authority

971-673-0438

Permit application history • Intel applied for Title V permit in 2012 • Info meetings and hearing were held • Violations discovered in late 2013 • DEQ fined Intel, issued a Mutual Agreement

and Order (MAO) early 2014 • MAO allows continuing construction and

operation • MAO required submittal of Type 4 permit

application by 12/31/2014 • MAO also required other actions

NO2 • 3 pollutants in 1

• NO2 as NO2 • NO2 as ozone precursor • NO2 as PM2.5 precursor

• May be subject to different requirements for NO2 / ozone / PM2.5

Mutual Agreement and Order Mutual Agreement and Order is a type of

enforcement action • Requires corrective actions • MAO was issued in February 2014 Required: • Emissions testing for fluorides and HF • Submit ACDP application by Dec. 31, 2014 • Submit air quality analysis for F- and HF • Submit control technology review for F- and

HF

Permits, ACDP and Title V Air permits cover 2 areas: • On-going operation of a facility • Construction (new or expanding facilities) DEQ issues 2 types of air permits: • Air Contaminant Discharge Permits (ACDPs)

• Dual-purpose: on-going operation, and construction approval

• Title V • Single purpose: on-going operation

Permits, ACDP and Title V Intel needs two permits: 1st: ACDP

May be referred to as construction, Type 4, or New Source Review

permit 2nd: Title V permit:

Follows ACDP, will replace ACDP

Permits, ACDP and Title V ACDP • ACDP will cover all of the following:

• All requested emission increases • Construction approval • BACT for NO2 and CO

• This is the permit we’re talking about tonight

Permits, ACDP and Title V Intel also required to apply for Title V permit • Title V permit comes after the ACDP

• Will replace the ACDP • Will include everything covered by the ACDP

• Intel applied for Title V permit in 2012 • On hold • Work on Title V will resume after ACDP is

issued Intel also required to apply for Title V permit

Permit process 1. Info meeting (tonight) 2. Draft ACDP 3. Public notice for ACDP 4. Hold hearing for ACDP 5. Issue ACDP 6. Resume work on Title V permit 7. Public notice for Title V permit 8. Hold hearing for Title V permit 9. Issue Title V permit Intel also required to apply for Title V permit

What was required for this permit application • Best Available Control Technology (BACT)

analysis for NO2, CO • Air quality analysis for NO2, CO, PM10 and

PM2.5

In addition (required by the MAO) • Control Technology analysis for Fluorides (F-)

and Hydrogen Fluoride (HF) • Air quality analysis for F- and HF Intel also required to apply for Title V permit

Source testing Source testing also known as stack testing • Emissions are tested inside the stack • Tells how much is being emitted Testing is done for specific pollutants • Not possible to test for “everything” For the permit application, Intel tested for: • NOx, CO from boilers and VOC emission control

devices (RCTOs) • F- and HF from process scrubber stacks Intel also required to apply for Title V permit

Emissions ACDP ACDP application must include all emission sources • Includes emission sources not included in permits

at this time: • Small natural gas burning equipment • Emergency generator & fire pump engines • Cooling towers • Road dust

Intel also required to apply for Title V permit

Emissions Title V permit If rules change as expected, ACDP and Title V permit will include all emission sources except: • cooling towers and road dust See Intel Emissions Summary handout

Air quality analysis (modeling) Required as part of permit application: • PM10, 24 hour • PM2.5, 24 hour and annual • CO, 1 hour • NO2, 1 hour and annual Require by MAO: • Fluorides (F-), annual • Hydrogen fluoride (HF), annual Intel also required to apply for Title V permit

Insert Program – Use Master Slide

Air quality analysis

Results: Result μg/m3

Standard μg/m3

PM10 24-hour: 71.27 150

PM2.5 24-hour: 34.90 35

PM2.5 annual: 10.13 12

CO 1-hour: 8,712 40,000

NO2 1-hour: 168.04 188

NO2 annual: 28.31 100

Air quality analysis Fluorides and hydrogen fluoride No National Ambient Air Quality Standards for fluorides - or hydrogen fluoride • Oregon: Benchmark for hydrogen fluoride (14 μg/m3)

• No Benchmark for fluoride • Some states have reference levels for fluoride -

• California, New Hampshire, Massachusetts, Texas • Levels range from 6 to 27 μg/m3

Intel also required to apply for Title V permit

Source testing Source testing also known as stack testing • Emissions are tested inside the stack • Tells how much is being emitted Testing is done for specific pollutants • Not possible to test for “everything” For the permit application, Intel tested for: • NOx, CO from boilers and VOC emission control

devices (RCTOs) • F- and HF from process scrubber stacks Intel also required to apply for Title V permit

Insert Program – Use Master Slide 6. Air quality analysis

Result μg/m3

Benchmark or reference level

μg/m3

HF annual: 0.50 14 F- annual: 0.38 6 to 27

Fluoride and hydrogen fluoride

Best Available Control Technology (BACT) BACT is the best emission control available • Generally means the best that is actually in use

somewhere • Must be commercially available, and usable for

the process being considered BACT is not: • Zero emissions Intel also required to apply for Title V permit

Best Available Control Technology (BACT) Process to reach a result Step 1 – Identify all available control options Step 2 – Eliminate technically infeasible options Step 3 – Rank the remaining control options Step 4 – Evaluate economic, energy, and environmental impacts Step 5 – Select Best Available Control Technology Intel also required to apply for Title V permit

BACT for NOx • Natural gas fired boilers • Natural gas fired VOC control devices

(RCTOs) • Application proposes that boilers and RCTOs

be equipped with low-NOx burners • Small fuel burning equipment – not cost-

effective • Emergency generator and fire pump engines

– use modern, low-emitting engines Intel also required to apply for Title V permit

BACT for CO • Natural gas fired boilers • Natural gas fired VOC control devices (RCTOs) • Trade-off with NOx: low COhigh NOx • Application proposes good burner design and

good operating practices • Small fuel burning equipment – not cost-effective • Emergency generator and fire pump engines –

use modern, low-emitting engines Intel also required to apply for Title V permit

Control technology for fluoride and hydrogen fluoride BACT analysis not required, but analysis generally followed BACT method • Existing control system is packed-bed liquid

scrubbers • Two other systems were evaluated • Application indicates both not technically

feasible • Continue using the existing control system Intel also required to apply for Title V permit