By Eric Maddy
The SCORE

A task force charged with investigating and possibly recommending appropriate stack heights for new facilities at Intel hopes to be able to make a public presentation within two months.

The group, a sub-committee of the Community Environmental Working Group, will soon begin evaluating materials and plans to make a presentation at one of the next two CEWG meetings on Dec. 19 or Jan. 16, 2008. The group regularly meets on the third Wednesdays of the month at Your Place or Mine, 3301 Southern Blvd., but met on the third Monday this month in consideration of the Thanksgiving holiday.

The CEWG was founded in 2004 as part of a series of recommendations from a task force report from the New Mexico Environmental Department, which had spent several months looking at emissions fro Intel’s plant in Sandoval County. Having adopted a mission statement of “Striving for Continuous Environmental Improvements at Intel,” the group began organizing in August 2004. Intel pays for the meeting site and a professional facilitator to guide the meetings, but membership is voluntary.

John Bartlit of the New Mexico Citizens for Clean Air & Water chairs the Working Group. Other members include Hugh Church of the American Lung Association; Lane Kirkpatrick, a Corrales resident; Edward Pineda of Rio Rancho; Gordon Ross of Pueblo los Cerros; and Mike Williams, a member of New Mexico Citizens for Clean Air and Water.

Intel has two permanent members in the working group: Community relations manager Teresa Fleming and Sarah Chavez. an environmental engineer.

Church, Pineda and Williams, all of whom have various technical expertise in their backgrounds, will gather information and may offer recommendations depending on what the discover. “I can envision that you’ll get different answers for different questions,” Williams said. “Are you asking about oxides and nitrogen, or some of the particulate matter that has a chance of sticking if it gets down around the surface? If you’re not worried about what happens down around the fence line (bordering Intel on the east side from Corrales) or each household out in the community that might be a different answer.

“We might be able to do some modeling and tell you the implications, but you might have to decide what’s best given that information.”

Said Bartlit: “They’re saying the answer is not the best answer for every house. There’s an optimum stack height for each house, in some sense.”

As part of its retooling of the factory in preparation to produce 45 nanometer computer chips, Intel is phasing out thermal oxidizers currently in place and using new technology that will be in a central location in the factory.

Part of the requirement for a technical permit revision t from the NMED to allow the changes at the plant called for modeling of the new technology. The modeling was done at a height of 23.2 meters, which is the current height Intel uses for its stacks.

Several residents, especially down wind who live in Corrales, want the stacks to be taller in an attempt to further disperse the pollutants that come out of the factory.

Chavez said the permit revision also include a note that saying “we would work any issues of stack height through the CEWG.” Much of Monday’s meeting was spent deciding on that process.

“The NMED is not going to make the decision on the stack heights,” Chavez said. “This group will decide on what is the appropriate stack height.

“We know that there are concerns, that people want a taller stack. They thought they should have taller stacks to better protect our health. If NMED says we need to come back and do additional modeling, we’ll do additional modeling. It shouldn’t really impact their approval of the permit because we meet the ambient air quality standards, which is what they are required to enforce.”

Corrales resident Lynne Kinis said submitting the permit revision without the stack heights, then seeking additional information and/or recommendations from the CEWG, “is yet another stall tactic,” as if Intel was saying, “We will keep the same stack heights and if there is a problem or if somebody wants to readdress this we will do some more modeling.

“The stack heights as they are now is not the proper height. You’ve been requested for months to look at a much higher stack height for health reasons, as you stated, and you’re coming back with the same stack height. How are we supposed to interpret that?”

Chavez said, “Intel is committed to coming up with some stack height taller than what we modeled based on some agreement by this group. We’re not trying to avoid increasing the stack height. We just want to make sure everyone is in agreement with how tall we should make our stacks.

“We wanted to go ahead and submit the permit revision because the modeling meets the technical requirements as far as the technical revision goes. We’re committed to do something beyond that, and go look at the stack heights to figure out what is the appropriate height for these sources.

“But we don’t want to just go pick – we’re going to make it 10 meters taller and people still complain. We want to have some process by which we go in and decide what the appropriate stack height is.

“I don’t want to leave the impression that we are trying to stonewall anybody or not do what we committed to do. The state doesn’t have jurisdiction over how tall we make our stacks. That’s not what they are looking at.”

Williams said taller stack heights don’t necessarily mean better air quality.

“In the past there were cases where people used taller stacks to emit more and more stuff, and there turned out to be a number of problems with that. It doesn’t necessarily control concentrations the way you might think it does,” he said. “Particularly, it makes it more likely that a place will be affected by more than one stack and when you add the two together you have problems.

“So basically the (EPA) agency said you could only get credit in the modeling for ‘good engineering practice stack heights.’ More than that and they are not going to consider what that does to your ambient standard because some people were using it as an excuse not to put controls in.

“The whole idea of a tall stack is that the stuff diluters further as it gets downwind of the maximum concentration. But we’re asking a little bit different question: What would happen to community members who are not necessarily at the maximum point, which might be quite close to the boundary or inside the boundary?

“In the simplest situation, if you were out in the countryside and you don’t have any buildings around and you have a taller stack, indeed you reduce concentrations. Except a lot of the time you will be in what is called a limited mixing situation where stuff comes out, mixes until it reaches the inversion level. In that situation, there is basically no change – it doesn’t matter what the stack height is. As long as it is less than the inversion height, you get the same concentrations.

“We have a little more complicated situation because we have buildings. Buildings give you a lot of mixing and (pollutants) can’t spread out wider and reduce the concentrations, which is what you are trying to get with a taller stack. Conceivably, if you get the stack heights a little higher you get above the building influence, and the stuff will drift out in a stable flow without much spreading. Then as the sun comes up and mixes things down on the ground, that could actually be worse. But if you get it down on the ground that means it doesn’t go further downwind.

“It’s still likely that if you increase the stack height you’ll reduce the concentration, but sometimes in some situations it wouldn’t. And you’ll see less and less effects as you get further away. You’ll have the biggest effect if you change the stack heights if you’re close,

Added Church: “How good is good engineering practice?” He said he found an “alleged definition" in federal regulations with respect to stack heights: They “shall not exceed 2 1/2 times the height of such source unless the owner or the operator of the sources demonstrates, after notice  and opportunity for public hearing, to the satisfaction of the administrator that a greater height is necessary. In no event can the administrator prohibit any increase of any stack height, or restrict in any manner the stack height of any source.’

“I thought that was sort of curious. If somebody wants to raise the stack heights just because they feel it ought to be, they’re not going to prevent it from happening. But if it doesn’t make sense to do it, by good engineering practice, it sort of seems you’re not going to get anywhere.”

Intel’s stacks are currently 23.2  meters tall, but no one was quite sure of the height of the buildings that produce the pollutants, including four company representatives in the room. Since no one was certain if Intel was less than or near the 2 1/2 times ratio in the federal regulations cited by Church,  “You could argue that they are not currently using  good engineering practice,” Williams said.

That’s when Pineda suggested the idea of a task force to investigate the question.

“The way to do this is put this through a model, using different equations, to determine the most efficient height, whether it is more, the same or less,” he said. “But it requires quite a bit of analysis to find the most effective stack height.”

More information about the group can be found at:

 http://www.intel.com/community/newmexico/cewg.htm