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EPA to Arizona DEP and Maricopa ESD

SAN FRANCISCO, CA 94105-3901

November 6, 1996

Karen Heidel, Deputy Director
Arizona Department of Environmental Quality
3033 North Central Avenue
Phoenix, Arizona 85012

Al Brown
Maricopa County Environmental Services Department
2406 South 24th Street, Suite E-204
Phoenix, Arizona 85034

RE: Intel Corporation XL Project

Dear Ms. Heidel and Mr. Brown:

I want personally to thank and commend you and your staffs for the commitment, effort and time which have been devoted to the Final Project Agreement and revised Air Quality Permit for Intel Corporation's FAB-12 site in Chandler, Arizona. I would also like to share a few thoughts about the resulting Air Quality Permit for the Intel FAB-12 site, and about the extensive and critical stakeholder process that was integral to the Permit.

The Air Quality Permit complies with Maricopa County's (MCESD) rules and regulations, and is based on an interpretation of the rules and regulations that provides for increased operating flexibility for Intel with less permitting oversight than MCESD has traditionally exercised. The flexibility is primarily achieved through establishing site-wide emissions limitations for the criteria and hazardous air pollutants and preapproval of modifications for the five-year permit term.

First, I wish to emphasize that these permit conditions are experimental. The permit conditions have been crafted as part of the Environmental Protection Agency's Excellence in Leadership Project that stresses the experimental nature of such projects. These types of conditions, therefore, should not be considered immediately transferable to other permit applicants until we have had an adequate opportunity to evaluate if the goals of the Project are being achieved. At that time, which may be several years, you may be able to revise the County's rules and regulations to reflect the successful aspects of the revised Air Quality Permit in a way that is transferable to other facilities within the same industrial segment, or possibly even to other industries.

Second, the Air Quality Permit conditions were recommended to Maricopa County following a lengthy stakeholder process in which the interests of Chandler residents and non-governmental organizations were represented. The flexibility in the Air Quality Permit conditions would not have been considered to be sufficient without the additional substantial efforts that Intel is undertaking to achieve environmental benefits. Intel has agreed to stringent permit conditions for modeling public health impacts at its property boundary and for reporting to the public on its air emissions. In addition to these permit requirements, Intel has set forth a number of extremely ambitious environmental goals that is will seek to achieve over the next five years.

While these additional goals are voluntary, Intel is accountable to the public for achieving or failing in these goals. These goals were also established through the public stakeholder process, and therefore, reflect the priorities of the residents who are directly affected by the FAB-12 site. For the Intel FAB-12 FPA, the public participation process was enforceable under the air permit.

I understand that other permit applicants may request you to include conditions allowing flexibility that are similar to those in the revised Air Quality Permit for Intel's FAB-12 site. EPA would strongly object to the inclusion of such conditions until two prerequisites are satisfied: 1) there has been an opportunity to evaluate the effectiveness of all of the air permit conditions to achieve superior environmental performance as anticipated; and 2) the conditions that an applicant is requesting have been subject to the extensive stakeholder participation that occurred with Intel's Project XL. Lastly, the applicant should have a clear understanding of what aspects of their project will be enforceable and which will be voluntary commitments.

Please feel free to call me to discuss this matter, and again, thank you for your generous cooperation in the Intel XL Project. You may reach me at (415) 744-1001.


John Wise
Deputy Regional Administrator

cc: Steven Herman, Office of Enforcement and Compliance Assurance
Lisa Lund, Office of Policy and Planning Evaluation
Intel Corporation
5000 W. Chandler Boulevard
Chandler, AZ 85226-3699

(602) 554-8080

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