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Intel to EPA

Intel Corporation
5000 W. Chandler Boulevard
Chandler, AZ 85226-3699

(602) 554-8080


September 23, 1996

Ms. Carol Browner, Administrator
Mr. Fred Hansen, Deputy Administrator
Mr. David Gardiner, Assistant Administrator, U.S. EPA
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460

Ms. Felicia Marcus, Regional Administrator
U.S. EPA Region 9
75 Hawthorne Street
San Francisco, CA 94105

RE: Intel Corporation Project XL

Dear Administrators Browner, Hansen, Gardiner and Marcus:

During the past several weeks a number of letters and numerous comments have been directed to EPA and to Intel concerning the Project XL pilot at our Ocotillo site in Chandler, Arizona. We are most appreciative of the energy invested by members of the local community in Arizona and groups and individuals outside of Arizona to provide thoughtful review of the Intel project. We firmly believe that the level of response and comment is indicative of the open stakeholder involvement process we at Intel have sought and delivered for Project XL.

In the course of reading the letters and comments, it is apparent to us that there is incorrect information circulating about our project. Project XL has been a complex negotiation among multiple stakeholders, including local community residents, regulators, and Intel. In the course of this negotiation, works in progress have been developed, circulated and revised numerous times. It is not altogether unexpected to find incorrect information out there. Since we believe it is important to ensure that commenters and other members of the public have access to factual information, we wish to clarify a few of the more serious inaccuracies circulated in several letters objecting to our Project XL. There are other comments which can be addressed as needed.

Fact: Intel has received no regulatory waiver in Project XL.

From the very beginning the Intel Project XL Stakeholder Team agreed to this premise: there would be no violations of existing laws or regulations. The draft air quality permit conditions developed by the Project XL Stakeholder Team provide only for operational flexibility currently allowable under federal, state, and local laws and regulations. The preapproval for equipment installation and construction of a new fabrication facility is founded within the context of two requirements:

An enforceable commitment to remain below all the emissions caps; and
An enforceable commitment to install emissions control equipment defined in advance in the permit.

The Project XL Stakeholder Team has found no reason why this flexibility with these conditions cannot now be granted under existing regulations without Project XL, and the regulators have deemed this to be within the scope of current federal, state and local law.

Fact: There is no shifting of risk, either to the community by promoting the use of non-HAPs, toxics, or to Intel manufacturing employees through increased exposure to toxic chemicals.

The emissions caps for Hazardous Air Pollutants (HAPs) are a total of 10 tons for all inorganic HAPs added together, and a total of 10 tons of all organic HAPs added together. The caps are not 9.9 tons for each HAP, as has been stated in at least two letters to Administrator Browner. We have constructed a synthetic minor source for HAPs.

There is no motivation or incentive in the XL agreement for Intel to avoid HAPs regulation by substituting other, non-regulated toxic chemicals. Even though the current regulations of the Clean Air Act Amendments of 1990 would allow such substitution with no consequence, the Intel XL Stakeholder Team agreed to go beyond existing requirements and ensure that any toxic chemicals (whether defined as a HAP or not) be evaluated on a health risk basis. If that evaluation shows a potential for impact on public health from a particular chemical, Intel commits to setting an appropriate emissions PSEL for that chemical.

Fact: Intel's emissions factors are not secret

Intel is considered by many, including environmental advocacy organizations such as Don't Waste Arizona, to be open, honest and disclosive with the community. Intel was forthright in discussing openly with the Project XL Stakeholder Team and others in the community the results of scrubber testing conducted at another Intel facility. We revised previous estimates of HAPs emissions upward to account for the new data. While we must protect confidential business information in accordance with existing rules and regulations, we have been up front in disclosing to the public the methods used to determine our emissions factors so that they can validate that they are scientifically defensible and conservative. In addition, representatives from federal, state and local regulatory agencies can at any time inspect our facilities and our records, check our calculations and determine whether our emissions factors and reported emissions are correct.

Fact: Intel has committed significant resources to source reduction through a technology-forcing Design-for-Environment strategy in the Project XL agreement.

The emissions caps established in the Project XL agreement require that Intel invest significant resources in designing new processes for use at the Ocotillo site which can meet those emissions caps. In addition to being an expensive proposition, this commitment is fraught with technology risk. Intel is committed to driving source reduction, not through the standard paradigm of pollution prevention, but through the even more powerful vehicle of Design-for-Environment (DFE). This means that Intel Technology development experts must not only design new technology to create faster and more powerful microprocessors, they must design new processes to produce lower environmental emissions. Next generation processes are always more complex than prior generations -- with complexity comes a larger number of process steps. Intel is committing in this XL agreement to limit the emissions of two factories to minor source limits, despite the fact that the next generations of technology will be more complex. DFE works -- we reduced volatile organic chemical (VOC) emissions in the new process at FAB 12 by 40% compared to the previous process generation. Long term, Intel's environmental performance results include a 50% reduction in hazardous waste since 1985, while we grew from a $1 billion to a $16 billion company.

Fact: The water reclamation and reuse goals in the Intel project drive significant reductions in fresh water demand, while requiring that any recharge to groundwater meet drinking water standards.

The innovative partnership between Intel and the City of Chandler has created an opportunity for reusing city wastewater at the Intel facility and reclaiming used process water from Intel. After Intel treats this process water, the city treats it again to drinking water standards. Only then is that purified water used to recharge the aquifer. This system is designed to protect (and one could argue, enhance) the quality of the existing groundwater resource. The net impact of the water reuse and reclamation goals in the XL agreement is a reduction in Intel's fresh water use from a projected 3-6 million gallons per day to a projected 1 million gallons per day. In addition, the recharge by the city of Chandler is performed under an Aquifer Protection Permit issued by the state of Arizona.

Thank you for your support and attention to the Intel Project XL. We are open to discussing any questions you, your staffs or any members of the public may have about our project. For more information please contact either Tim Mohin at (202) 626-4399 or Angela Boggs at (602) 554-1497.


Angela Boggs
EHS Regulatory Issues Manager

Tim Mohin
Government Affairs Manager

cc: Distribution

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