Department of Environmental Quality
Air Quality Division
OREGON TITLE-V OPERATING PERMIT APPLICATION REVIEW REPORT
Intel Corporation
5200 NE Elam Young Pkway, #AL4-19
Hillsboro, OR 97124-6497
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This permit review report is formatted to accommodate the permit
conditions and thus recommended to be reviewed simultaneously and
in direct reference to the permit line items. This review report
intends to convey all pertinent emission data, rules, policies,
theories and engineering assumptions used to construct the Oregon
Title-V Operating Permit (OTOP) 34-2681. The primary source of
information used to construct this permit is the referenced
application (No. 14659).
OTOP 34-2681 focuses on numerous permitting issues which include
a source specific RACT determination, increase in the boiler
PSELs, and the pre-approved changes and pollution prevention
protocols. Applicable regulatory standards and associated
monitoring, recordkeeping, reporting requirements, along with the
applicable conditions from the existing Air Contaminant Discharge
Permit (ACDP) are incorporated into the OTOP 34-2681 as outlined:
TABLE OF CONTENTS PAGE
Background Information 2
Permitted Activities 5
Emission Unit & Pollution Control Device Identification 5
Emission Limits and Standards 9
Plant Site Emission Limits 11
Source-Specific Conditions:
Source-specific RACT Standards 18
Pollution Prevention and 27
Pre-approved Changes TABLE OF CONTENTS PAGE
Aggregate HAP Emission Limit 30
Monitoring Requirements 30
Test Methods and Procedures 38
Recordkeeping Requirements 37
Reporting Requirements 38
Non-Applicable Requirements 38
General Conditions 38
Summary/Public Notice 39
Attachments:
PSEL Detail Sheets A1-A6
EU2 Baseline Capacity A7
Fig.1: VOC Monitoring A8
RACT Emission Data A9-A13
Toxic Substance Usage A14
BACKGROUND INFORMATION
The proposed Oregon Title-V Operating Permit (OTOP) replaces an
existing Air Contaminant Discharge Permit (ACDP) which was issued
on 4/19/93 and was originally scheduled to expire on 11/01/96.
The proposed OTOP applies to all existing and planned activities
at the Intel Aloha Campus occupying 54.5 acres of properties
located at 3585 Southwest 198th Avenue, Aloha, Oregon, 97007.
Mr. Sunlin Chou is currently identified as the primary
responsible official for the Aloha Campus operations.
Intel submitted a Land Use Compatibility Statement (LUCS) to
Washington County Department of Land Use & Transportation
(WCDLUT), and the Washington County signed and approved the LUCS
on 9/20/91. Other permits issued or required by the Department
for this source include NPDES permit 100917 for non-process
wastewater discharge. The process wastewater is discharged to
one of the Unified Sewerage Agency's (USA) wastewater treatment
plants of Washington County. This source is also a registered
large quantity hazardous waste generator; ORD 060591963. The VOC
emission calculations include monitoring of the hazardous waste
streams. Facility Description
Intel Corporation operates one of its semiconductor manufacturing
plants in Aloha, Oregon, hereby occasionally referred to as the
Aloha campus. There are five main buildings at the Aloha campus;
AL3, AL4, FAB4, FAB5, and D1. Buildings AL3 and AL4 are
primarily office buildings. Buildings FAB4 and FAB5 are the main
manufacturing facilities. The D1 currently serves as a
technology development facility, for newer generation of
semiconductors, which would gradually be converted to a
manufacturing facility. Besides these five main buildings, there
are several other (relatively small) buildings located on the
west side of the Aloha campus which are currently used by
contractors and consultants working for Intel.
The Aloha facility is located in a nonattainment area for ozone
and Carbon Monoxide (CO). The facility is a major (> 100
tons/yr) source of VOCs (ozone precursor), but is a minor (32
tons/yr) source of CO. Intel is also a minor source of Hazardous
Air Pollutants (HAPs).
This source is not subject to federal regulations for New Source
Performance Standards (NSPS), Prevention of Significant
Deterioration (PSD), or National Emissions Standards for
Hazardous Air Pollutants (NESHAPS).
Compliance History
The most recent facility inspections were conducted on 9/7/94,
9/21/93, and 5/18/92; and the source was found to be in
compliance with all existing ACDP conditions. A file review also
indicates, ever since the beginning of operation, no public
complaints were received by the Department. The permittee's
unblemished compliance history is one of the factors influencing
the level of compliance demonstration requirements established in
this permit.
Intel's (only) Operating Scenario
Intel has identified one operating scenario covering a broad
spectrum of semiconductor manufacturing operations. The
production steps traditionally include application of
photoresist, UV light exposure, developing, etch, deionized water
rinse, doping, and acid/solvent rinse steps. Under this one
operating scenario, the source operations are divided into three
emission units. Each identified emission unit (EU) is grouped
with respect to common applicable rule requirements, and this
grouping allows each EU to be regulated under uniform compliance
monitoring requirements. The semiconductor manufacturing processes emit VOCs from
chemicals/materials that they use. In terms of specific
processes, VOCs are emitted from the photoresist applications
(mainly spin coaters and developers), solvent cleaning stations,
and storage/handling operations. Over 90% of the plant site VOC
emissions come from the photoresist applications, and the
remaining 10% is mostly generated from the solvent cleaning
stations. These VOC generating processes located throughout the
Aloha campus are grouped under Emission Unit 1 (EU1).
The operating scenario at EU1 covers the plant site VOC
emissions, excluding a small amount of VOCs in the boiler flue
gases. Regulations pertaining to Intel's (non-fuel burning)
process VOC emissions are uniform, and by grouping the VOC
emission sources as one emission unit (EU1) eliminates any
ambiguity associated with the compliance demonstration with
respect to the PSEL and RACT, or applicability of New Source
Review (NSR) and Prevention of Significant Deterioration (PSD).
This would perhaps become increasingly more apparent as this
permit document is reviewed further.
The operating schedule is proposed at 24 hrs/day x 365 days/yr,
and this permit does not directly impose a cap on the production
rate. Instead the permit focuses on the actual VOC emissions by
strict enforcement of the VOC PSEL and RACT conditions. As will
be discussed in the PSEL section, the EU1's VOC PSEL essentially
represents a cap and it also serves as the starting point from
which to determine the NSR/PSD applicability. The RACT standards
proposed in this permit are also designed to limit VOC emissions
on a unit production basis. A combination of VOC PSEL and RACT
standards effectively regulates the permittee's actual VOCs
emissions.
Boilers are separated into two emission units (EU2 & EU3) based
on the size (industrial or commercial) category in which the pre-
determined fuel usage is the primary limiting factor for each
unit. Unlike the EU1 process VOC PSEL, the combustion PSELs
established for EU2 and EU3 boilers represent a cap on fuel
usage. All boilers are limited to burn natural gas only as
identified in the Intel's only operating scenario. The hourly
(short term) PSELs for EU2/EU3 boilers are based on each Emission
Unit's maximum capacity, and theoretically this maximum capacity
cannot be exceeded, unless the boiler is physically modified.
All EU2/EU3 boilers are operated below their operating capacity.
As discussed, annual operations of the EU2/EU3 boilers are
limited by the allowable natural gas usage, and these limits are
further reflected in the boiler PSELs. PERMITTED ACTIVITIES
1. Condition 1 acknowledges the permittee is allowed to
discharge regulated air pollutants only in accordance with
the limits and standards established in the Oregon Title-V
Operating Permit (OTOP) 34-2681. The effective date of this
permit is the date of the permit issuance.
2. Condition 2 makes a clear distinction between the state-only
enforceable conditions from those conditions enforceable by
both state and the U.S. EPA. All conditions in this permit
are enforceable by both the EPA and State, except those
conditions and associated monitoring specifically identified
in item 2.a. as state-only enforceable.
The monitoring (plus recordkeeping/reporting) requirements
associated with the state-only applicable requirements are
cited in item 2.a. by reference only, for reason that some
of these monitoring protocols are also used by the federally
enforceable conditions. Specific monitoring is extractable
by its association to specific applicable requirements.
A list of non-applicable rules and the summary of reasons
are provided in the Non-applicable requirements section,
toward the end of this permit.
EMISSION UNIT AND CONTROL DEVICE IDENTIFICATION
3. Existing air contaminant sources at the facility are grouped
as follow:
3.a. Emission Unit #1 (EU1)
Buildings AL3 and AL4 are primarily office buildings with no
measurable emissions (or worth measuring) and they are
listed here for identification purpose only. FAB4 and FAB5
are existing manufacturing facilities, and D1 is currently a
technology development center which will gradually become a
manufacturing facility.
Emission Unit #1 (EU1) in a physical sense is the entire
Aloha campus excluding EU2 and EU3 boilers. It includes all
non-fuel burning activities and processes at the Aloha
campus that emit VOCs. These activities/processes are
grouped as one emission unit since they emit the same
regulated air pollutant (VOCs), trigger the same applicable
requirements, and share the same compliance monitoring
protocols.
As listed in the permit item 3.a. (table), EU1 is divided
into three (3) stationary sources; EU1.1, EU1.2, and EU1.3.
FAB4 and FAB5 buildings share a common material flow
(distribution & waste collection) and they are combined to
comprise a stationary source EU1.1. The current emission
capacity of EU1.1 is 190 tons per year. The second
stationary source EU1.2 is the D1 building. It utilizes its
own material flow and employs newer technology. EU1.2 (D1
building) is currently under expansion and its projected
emission capacity is rated at 53 tons per year, and this is
the permitted capacity. As discussed, a stationary source
EU1.3 consists of AL3 and AL4 office buildings with no rated
emission capacity.
3.b./c. Emission Unit #2 (EU2) and Emission Unit #3 (EU3)
Currently there is a total of sixteen (16) boilers, and two
(EU3.4 & EU3.5) more are planned to be installed during the
94/95 calendar year. This permit is for the total capacity
of 18 boilers. The electric boiler (EU2.8) has been omitted
for obvious reason. All (EU3) D1 boilers fall under the
industrial boiler category (10 to 100 million btu/hr) and
the rest (EU2) are commercial type (0.5 to 10 million
btu/hr). All EU2 and EU3 boilers are permitted to burn
natural gas only. In addition, all EU3 boilers would be
operated with the LowNOx control. Intel boilers' primary
function is to condition (dehumidify) a huge volume of air
circulating through clean rooms and to provide heat
throughout the Aloha campus.
EU2 Boiler ID Yr installed Max. BHP Fuel
EU2.1 FAB4 - #1 1977 66.7 n.gas
EU2.2 FAB4 - #2 1977 66.7 n.gas
EU2.3 FAB4 - #3 1977 66.7 n.gas
EU2.4 FAB5 - #1 1978 144.4 n.gas
EU2.5 FAB5 - #2 1978 144.4 n.gas
EU2.6 FAB5 - #3 1992 139.5 n.gas
EU2.7 FAB5 - #4 1992 139.5 n.gas
EU2.9 FAB5 - #6 1993 27.9 n.gas
EU2.10 FAB5 - #7 1993 93.0 n.gas
EU2.11 FAB5 - #8 1993 93.0 n.gas
EU2.12 AL4 - #1 1990 65.1 n.gas
EU2.13 AL4 - #2 1990 65.1 n.gas
EU2.14 AL4 - #3 1990 65.1 n.gas EU3 Boiler ID Yr installed Max. BHP Fuel
EU3.1 D1 - #1 1992 465 n.gas
EU3.2 D1 - #2 1992 465 n.gas
EU3.3 D1 - #3 1993 653 n.gas
EU3.4 D1 - #4 1994 465 n.gas
EU3.5 D1 - #5 1994 465 n.gas
Baseline Boilers 106 btu/hr (gal/hr)
EU2.1 (FAB4 - #1) 3 (22.8)
EU2.2 (FAB4 - #2) 3 (22.8)
EU2.3 (FAB4 - #3) 3 (22.8)
EU2.4 (FAB5 - #1) 6.5 (49.5)
EU2.5 (FAB5 - #2) 6.5 (49.5)
EU2 Baseline Capacity: 22 x 106 btu/hr (167 gal/hr)
Note the boiler capacity and chronological information
contained in this section shall be used to track changes in
the boilers' emission capacity since the baseline and
determine applicability of NSR/PSD when becomes necessary.
The baseline capacity of EU2 is based on the fuel oil usage
of 1.47 million gallons per year. Attachment A7 contains
estimation of emissions from EU2 boilers based on their
baseline oil capacity. The EU3 boilers did not exist during
baseline and therefore the baseline capacity of EU3 is set
equal to zero.
Also note that this permit review determined the EU3 boilers
to be non-NSPS boilers, pursuant to 40 CFR () Part 60.40c,
Subpart Dc, "Standards of Performance for Small Industrial-
Commercial-Institutional Steam Generating Units". The EU3
boilers, capable of burning natural gas (or LPG) only, do
not generate steam and they do not heat water or any other
materials that would be used in the heat transfer
operations.
4. VOCs Pollution Control Devices: Intel operates two pieces
of VOC emission control equipment. A wet scrubber (PCD1)
was installed and went into operation in late 1994. A wet
scrubber controls acetone and other water miscible VOCs
emitted from the FAB4 building. The scrubber effluent
containing water soluble chemicals is routed to one of the
wastewater treatment plants operated by Unified Sewerage
Agency of Washington County, and this wastewater discharge
is indirectly regulated by the Department through the pre-
treatment program.
The other major VOC control device (PCD26) is the Carbon
Concentration Condensation Unit (CCCU) and it is planned to
be installed and begin operations in 1995. PCD26 would be
dedicated to controlling VOC emissions from D1 building
(stationary source EU1.2).
- VOC emission control devices -
Pollution
Control
Device(PCD)
PCD
ID
Emission
Unit/Process
Controlled
Design
Parameters
Design
efficiency
Wet Scrubber
(Spray Tower)
PCD1
VOC emissions
from FAB4
building
(EU1.1)
Fgas = 6,000 acfm
FH2O = 100-150 gpm
Pdrop = 6.0 in. H2O
> 90%
Carbon
Concentration
Condensation
Unit (CCCU)
PCD26
VOC emissions
from D1
building
(EU1.2)
Fgas = 2,000 acfm
VOC removal efficiency is
rated above 90% but it is not
needed in the VOC CMB, see
detail description below.
PCD26 The CCCU (PCD26) is designed to treat an air stream
relatively dilute with low concentration of VOCs. The CCCU
utilizes a carbon adsorption/reactivation technology coupled
with a condenser to recover VOCs. The amount of VOCs
recovered from PCD26 is directly measurable, and this is the
reason the efficiency (source testing) is not a necessary
parameter to complete the (plant site) chemical mass balance
(CMB) used in this permit as the compliance monitoring
protocol.
The CCCU consists of a carbon adsorption tower, a desorption
tower, and a condenser laid out in series. Low
concentration solvent laden air enters the adsorption tower
from the bottom and cleaned air exits through the top. The
adsorption tower is constructed with a series of "tilted"
sieve trays designed to move (utilizing gravity force) solid
Bead Activated Carbon (BAC) from top tray to the next one
below and so on down to the bottom. VOC laden air stream
moving upwards fluidizes the BACs which in turn adsorbs VOCs
in the air stream. Carbon beads (BAC) laden with VOCs exit the adsorption tower
and enter the desorption tower, where a small (manageable)
volume of air laden with the VOC-stripping gas is introduced
to reactivate the BAC by desorbing/stripping VOCs from it.
Reactivated BACs are returned to the adsorption tower, in
which the cycle is continuous. The VOC laden air (with
stripping gas) stream exiting the desorption tower contains
enough VOCs and is routed to the condenser for efficient
recovery.
There are basically two control options available for highly
concentrated solvent laden air exiting the desorption tower:
thermal destruction or condensation. The condenser control
option (unlike thermal control) eliminates the formation of
by-product air pollutants, and it is the preferred method,
and the method chosen by Intel. The condenser option also
simplifies the VOC monitoring since the amount of solvent
recovered is readily measurable and becomes an inherent part
of the overall chemical mass balance. Of minor note, the
thermal control option would be subject to additional
monitoring requirement such as measuring the capture and
destruction efficiency, monitoring the operating
temperature, and the annual verification requirements.
EMISSION LIMITS AND STANDARDS
This section contains the applicable emission limits and
standards other than the PSEL and source-specific standards such
as RACT. These applicable limits/standards in this section are
further divided into three sub-categories: Table-I contains
those limits applicable to the entire facility, and Table-II
contains those limits applicable to the specific emission units
or pollution control devices identified, and lastly Table-III
contains those limits applicable to "insignificant" activities.
Conditions in this section are basically carry-over from the
existing Air Contaminant Discharge Permit (ACDP).
Facility-wide Limits and Standards
5. This condition reflects OAR 340-21-060(2) and is applicable
to all sources located inside Special control areas as
defined in OAR 340-21-010, or when ordered by the Department
in other areas. Intel is located inside Washington County,
within the Special control areas defined in the rules. 6. The (250 micron) particulate fall out standard is applicable
to all permitted sources located inside the tri-county area
that do not have specific industrial standards, and thus
applicable to Intel. The tri-county consists of Clackamas,
Multnomah, and Washington Counties.
7. This condition as written effectively addresses the odor and
other forms of nuisance conditions. This Condition (7.) as
written establishes a basis for regulating odor and other
unforeseeable nuisance problems that may arise in the
future.
8. This condition requires the permittee to implement the
appropriate procedures as outlined in their Source Emission
Reduction Plan (SERP) in the event an air pollution alert,
warning, or emergency episode, due to high formation of
ozone, is declared in the Portland area by the Department.
Emission Unit Specific Limits and Standards
9. The visible and grain loading standards of this condition
apply to any single air contaminant discharge point to the
atmosphere that originated from the fuel combustion sources.
Which means these standards are applicable to each and every
stack of the EU2 and EU3 boilers.
10. This "Operation & Maintenance" condition is applicable only
to PCD1 - the VOC wet scrubber. This condition effectively
replaces the existing Highest and Best condition in ACDP,
pursuant to OAR 340-28-600 (2)(e) and 340-28-620. This O&M
condition focuses on the source-specific maintenance and
work practice requirements for PCD1 that are deemed
appropriate for the Intel specific operations.
Operating parameters that influence the (PCD1) scrubber VOC
removal efficiency include the air exhaust from FAB4 (air
inlet to PCD1), its (PCD inlet) VOCs concentration, and the
scrubber water flow rate. The PCD1 inlet air flow and its
VOC concentration are basically dictated by the production
rate, and these are not the appropriate control parameters
to be regulated as the permit conditions. The water flow
rate is the design control parameter suited for the permit
O&M requirements.
The VOC removal efficiency varies with respect the water
flow rate, and the minimum water flow rates established in
items a. through c. ensure the water soluble VOC - acetone
removal rate of 90% or greater. The removal rates of other
water soluble VOCs maybe slightly less.
Emission Limits and Standards Applicable to Insignificant
Activities
11. The visible and grain loading standards established in
Condition 11. apply to any single air contaminant discharge
point (stack) to the atmosphere that originated from non-
fuel burning sources that include "categorical" and non-
categorical "aggregate" insignificant activities.
PLANT SITE EMISSION LIMITS
12. 12.a. EU1 PSEL
ANNUAL PSEL: The Aloha campus excluding D1 (EU1.2) was
constructed during 1976 through 1978, and the facility was
retroactively assigned an emission limit (PSEL) equal to the
1978 capacity to emit (190 tons VOC per year) in the first
Department issued Air Contaminant Discharge Permit. This
baseline emission rate of 190 tons of VOC per year is also
the permittee's current PSEL. It also serves as the
stationary source EU1.1 (FAB4 & FAB5) maximum capacity to
emit. A stationary source EU1.2 (D1) currently under (on-
going) expansion was recognized under previously issued
ACDP. The D1 building has the maximum emission capacity of
53 tons/yr, and it is the permitted capacity of this OTOP
34-2681.
The baseline PSEL of 190 tons/yr has been and continues to
comprise a cap on permittee's plant wide emissions, and it
shall be used as the basis for limiting source's VOC
emissions for various physical and operational changes that
are permitted and contemplated by this permit. This means
for the purpose of determining applicability of (major) New
Source Review (NSR) or Prevention of Significant
Deterioration (PSD), OAR 340-28-1900 through 340-28-2000,
the baseline capacity of 190 tons of VOCs per year is the
starting point. Accumulative VOC emission increases/
decreases which result in a net (actual) emission increase
greater than the Significant Emission Rate (40 tons/yr)
would trigger the NSR; and the BACT/LAER review would be
imposed on the stationary source that causes the increase.
Any increases less than SER but above the PSEL of 190
tons/yr, no matter how small, will trigger the permit
modification process.
EU1 Baseline Capacity = EU1 Current PSEL = 190 tons/yr.
WEEKLY PSEL: Pursuant to OAR 340-28-1020 (2), the short
term PSEL established in this permit is the weekly PSEL.
The weekly limit was determined to be most compatible with
source operations.
Intel normally operates their production lines continuously
for about 5 to 7 days. Chemicals applied at the production
lines have uniform solvent content (% VOC) that does not
fluctuate during the continuous weekly operations. The
level of VOC emission would be proportional to the
production rate. The weekly emission closely reflect the
sum of their daily emissions which are evenly distributed.
In the last ACDP renewal, the weekly VOC PSEL was set at 8.0
tons/wk. The 8.0 tons weekly PSEL reflects the maximum
weekly production rate extrapolated from the emission
monitoring conducted from 6/28/92 to 8/29/92 (ACDP data);
and it is retained in this OTOP.
HISTORY OF CHANGE TO VOC (EU1) PSEL: There have been no
Department approved VOC (EU1) PSEL increases or decreases
between the baseline year (1978) and this permit (1995).
The current EU1 PSEL remains at the baseline capacity of 190
tons/yr.
12.b. Boilers (EU2 & EU3) PSELs
BASELINE PSELs for EU2: The baseline boiler PSELs were
established based on the fuel usage of 399,000 gallons of
diesel. For the purpose of assigning diesel fuel usage
among the baseline EU2 boilers, the capacity ratio of each
boiler was used (see attached detail sheet A6). Note only
the total fuel usage affects the emission calculation. The
fuel combustion products (criteria pollutants) generated
(tons/yr) based on the fuel usage of 399,000 gallons of
diesel are summarized below:
PM10 SO2 NOx CO VOC
0.4 14.2 4.0 1.0 0.1
CURRENT PSEL for EU2: Intel is committed to fueling these
boilers with natural gas only. The short-term PSELs are
based on EU2's maximum fuel capacity. And based on proposed
natural gas usage the estimated annual EU2 emissions
(tons/yr) are:
PM10 SO2 NOx CO VOC
1.15 0.25 9.55 2.01 0.36
BASELINE PSEL for EU3: All existing and planned EU3 boilers
were/would be constructed after 1978, and therefore the
baseline PSEL for EU3 is set equal to zero.
CURRENT PSEL for EU3: All EU3 boilers are capable of
burning natural gas only. The short-term PSELs are based on
EU3's maximum fuel capacity. And based on forecasted
natural gas consumption the estimated annual EU3 emissions
(tons/yr) are:
PM10 SO2 NOx CO VOC
5.21 0.99 11.97 29.94 1.06
History of changes to the Boilers (EU2/EU3) PSEL
The ACDP addendum 1 issued on 3/7/89 increased the SO2 PSEL
to 16.4 tons/yr from the baseline rate of 14.2 tons/yr. The
EPA AP42 emissions factors for boilers have been updated,
and this permit reflects updated AP42 boiler emission
factors. The EU2 and EU3 boilers' baseline PSELs are
reconstructed to reflect these new AP42 emission factors.
Thirteen additional boilers (not counting the electric EU2.8
boiler) have been installed since the baseline year. In
this permit, Intel forfeited EU2 boilers' capacity to burn
oil and all boilers are now committed to burning natural gas
only.
Since the baseline year, a combined capacity of all EU2 and
EU3 boilers have increased by almost an eight fold from 22
to 166 million btu/hr. However, using only the natural gas
and retrofitting all D1 boilers with LowNOx burners would
minimize the increases, and in some case reduces, the boiler
emissions.
Based on the proposed fuel usage (see attachment A6), the
proposed EU2 & EU3 boilers' PSELs are estimated below. The
increase in emission of each pollutant is less than the
Significant Emission Rate (SER) as defined in OAR 340-20-225
(25). All units are expressed in tons per year:
Pollutant Baseline PSEL Increase SER
PM10 0.4 6.4 6.0 15
SO2 14.2 1.3 -12.9 40
NOx 4.0 21.6 17.6 40
CO 1.0 32.0 31.0 100
VOC 0.1 1.5 1.4 40
All particulates emitted from the boilers are regarded as
PM10. Note the SO2 PSEL has actually decreased since the
baseline while the capacity went up by almost an eight fold.
The short term (hourly) emissions reflecting the boiler
capacities are also calculated and summarized in attachment
A7.
Also note the EU2 and EU3 boilers emissions are initially
calculated to two significant figure, but conventional
rounding method was not applied to further discourage
unnecessary compliance problems that may arise in the
future. For example, the calculated value of SO2 PSEL was
actually 1.24 but is set at 1.3 (tpy) in the permit.
13. The aggregate limits for insignificant activities
established in this Condition reflect OAR 340-28-110 (5);
which sets the aggregate Particulate limit at 1.0 tons per
year and the aggregate HAP limit at 2.5 tons per year,
pursuant to OAR 340-28-1060(2). This condition basically
conveys the rule requirements (OAR 340-28-110(5)) that a
total combined emissions from all "aggregate insignificant
activities" cannot exceed the aggregate limits for each of
the regulated pollutants (Particulates & HAPs) identified:
Description of Current
insignificant activities
Regulated Air
Pollutants
Estimated
Emissions
(tons/yr)
Baghouses PCD3 & PCD4
for wafer grinding
operations
Particulates
0.2
Natural gas combustion
of EU2 & EU3 boilers
Organic HAPs
< 0.2
Process scrubbers,
Implant sources, etc.
Inorganic HAPs
0.6
This condition does not intend to limit "aggregate
insignificant activities" to only those currently identified
in the permit application. For same reason the permittee is
free to add more categorical insignificant activities to
their existing list (identified in the permit application).
The permittee can add more insignificant activities to their
existing list, even after the permit is issued, provided
that the aggregate limits established in the permit (or
rules) are not exceeded. The monitoring protocol for the
aggregate insignificant activities requires the permittee to
report semi-annually of the changed status (if any), at
which time the status change will undergo further Department
scrutiny.
Aggregate Particulate emissions: The only other criteria
pollutant, other than VOCs, generated from EU1 is
particulate and all particulate emissions from EU1 are
included in the "aggregate insignificant emissions". No
silicon crystals are grown at the Aloha campus. Intel
purchases thinly sliced wafers (size varies) with one side
having a mirror finished surface (chemically etched &
polished). The only silicon-particulate generating process
performed at the facility is grinding unpolished side of
wafer.
There are two baghouses (PCD3 & PCD4, each with 99.9%
control efficiency), located on the south side of FAB4
building, controlling the silicon particulate emissions.
The particulate emitted to the atmosphere from these
baghouses total about 0.02 tons/yr, and these emissions are
included in the "aggregate insignificant emissions".
EU1 PCD ID Yr installed Flow (acfm) Eff. (%)
FAB4 PCD3 1982 2,900 99.9
FAB4 PCD4 1982 2,900 99.9
Aggregate Organic HAP emissions: Organic HAPs emissions
from the EU2 and EU3 boilers were estimated using the
emission factors published in the OAQPS document; EPA-450/2-
90-011, second edition, October 1990.
EF C6H6 = 4% of total VOCs (0.04 x 2.8 lbs/106 ft3 ng.)
EF CH2O = 88.12 lbs per 1012 btu heat input for EU2 boilers
EF CH2O = 997 lbs per 1012 btu heat input for EU3 boilers
Combined HAPs emissions due to EU2 and EU3 natural gas
combustion total less than 0.2 tons/yr.
E, Benzene (C6H6) ÷ 0.04 tons/yr
E, Formaldehyde (CH2O) ÷ 0.09 tons/yr
Aggregate Inorganic HAP emissions: Inorganic HAPs
emissions are summarized in the Table below. Inorganic HAPs
are emitted to atmosphere through process scrubbers (PCDs),
and emissions from these "high efficiency" PCDs are very
small as noted below:
HAPs
DESCRIPTION OF ACTIVITIES
ESTIMATE
(tons/yr)
Arsenic
compounds
Doping, parts cleaning
trace
Chromium
compounds
Backside coating, etch
trace
Ethyl benzene
Negative litho process
trace
Ethylene glycol
Various dips, cleans & eq. cooling
trace
Phosphine
Implant source
0.02
Phosphorus
Implant source
trace
Hydrofluoric
acid
PCD2.1/2.2, PCD5, PCD6, PCD7, PCD8,
PCD9, PCD11, PCD19/20
0.09
Hydrochloric
acid
PCD2.1/2.2, PCD5, PCD6, PCD7, PCD8,
PCD9, PCD11, PCD16, PCD17, PCD19/20
0.40
Chlorine
PCD2.1/2.2, PCD7, PCD8, PCD9,
PCD19/20
0.09
Total Estimate
0.6
As noted above, controlled emissions of inorganic compounds
(mostly acids) from numerous high efficiency scrubbers are
small. Most of inorganic HAPs originate from the acid
baths, and vapors from the acid baths are routed to wet
scrubbers (PCDs) as listed in the following Table. Because
acids have strong affinity for water, the dilute acid bath
would not release significant amount of acids to begin with,
and when such emission is further controlled by wet
scrubbers, the acid emissions to the atmosphere are
virtually eliminated. This partly explains Intel's ability
to remain a minor source of (inorganic) HAPs. The following
Table lists all existing PCDs for non-VOC HAPs and their key
design parameters:
- Inorganic HAPs Emission Control Devices -
Pollution Control
Equipment(s)
PCD ID
Design Parameters
Year
Installed
Gas Flow
(acfm)
Pre. drop
(in. water)
Water Flow
(gpm)
Wet
Scrubber/Thermal
decomposition units
(Delatech 857)
PCD2.1
200
scfm
each
0.25
2.5
1993
PCD2.2
0.25
2.5
1993
Horizontal Wet
Scrubbers
(FAB4 SCO #1 - #5)
PCD5
19,050
2.5
120
1974
PCD6
19,050
2.5
120
1974
PCD7
19,050
2.5
120
1974
PCD8
20,000
2.5
120
1988
PCD9
5,000
2.5
50
1988
Vertical Acid
Scrubbers
(FAB5 SCO #1 - #4)
PCD10
19,000
< 3
20
1974
PCD11
"
< 3
20
1974
PCD12
"
< 3
20
1974
PCD13
"
< 3
20
1974
HPH Horiz. Scrubber
(FAB5 SCO #5)
PCD14
34,000
0.5
30
1993
D1 Horizontal Wet
Scrubbers
PCD15
60,000
scfm
each
2
500
1992
PCD16
2
586
1993
PCD17
2
586
1993
PCD18
2
500
1992
PCD19/
20
10,000
1.25
100
1992
PCD21
85,000
2.6
341
1994
PCD22
85,000
2.6
341
1994
PCD23
29,000
2.6
356
1994
SOURCE-SPECIFIC CONDITIONS
This "Source-specific Conditions" section of this permit is
reserved for special conditions/requirements applicable to the
permittee that are reflective of the source uniqueness. This
section is further divided into three subsections:
Condition No. Subsection
14. - 15. Source-specific RACT Conditions
16. - 18. Pollution Prevention and Pre-approved changes
19. (Synthetic Minor) HAP Emission Limits
14. REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT)
Applicability: Pursuant to Oregon Administrative Rules
(OAR) 340-22-104 (5), this permit proposes a source-specific
Reasonably Available Control Technology (RACT) standard for
affected operations at the Intel Aloha campus. The proposed
source-specific RACT standards need not be approved by the
Oregon Environmental Quality Commission (EQC) prior to EPA
approval since this source-specific requirement itself is
inherently a part of the State Implementation Plan (SIP) VOC
rules.
Procedure: The RACT portion of this permit issuance will
follow the procedural requirements of 40 CFR Part 51.102;
which include posting of public notice in the newspaper
followed by a hearing process. In addition, the RACT
portion of this permit needs to be posted on the secretary
of state notice to conform with the source-specific SIP
revision process. Once the public notice/hearing process is
completed, the proposed RACT standards are submitted to EPA
(Region X Office) for their review and approval. The
proposed RACT standards in this permit are not final, and
they are subject to change pending EPA action. Once EPA
approves the proposed RACT standards, the permittee has one
year from the date of notification by the Department of EPA
approval to comply with the applicable RACT requirements.
General background information: The Oregon SIP VOC Rules
(Division 22) include several categorical RACT standards
applicable to specific categorical sources residing inside
the designated nonattainment area. Division-22 also
includes a provision which requires other non-categorical
"affected sources*" to comply with the case by case (source
specific) RACT standard(s) established by the Department.
Intel is the only affected semiconductor manufacturer
currently operating in Oregon that became subject to a
source-specific RACT determination.
Most RACT determinations are based on EPA Control Technology
Guidelines (CTG), but there is no CTG developed for
semiconductor industry. However, similar source-specific
RACT determinations have been made by the other regulatory
agencies (outside Oregon), and this permit uses some of
their assessments (for comparative purpose only) as a
guideline to assess source-specific RACT standard for
certain Intel operations. Subsequently, the engineering/
technical evaluation coupled with the cost analysis dictated
the RACT standards in this permit.
* "Affected sources" are those stationary sources operating
inside nonattainment areas for which no categorical RACT
requirements exist and which have the potential emissions
before add-on controls over 100 tons of VOC per year.
The Portland area attainment status: The Portland area is
currently designated as a marginal nonattainment area for
ozone. However, one of the criteria for reaching the
attainment status is to not exceed the national ambient air
quality standard for ozone (0.125 ppm) more than once per
year on average over a three year period. For past three
years, Portland has been in compliance with the EPA
standard:
Year (Date) # Exceedances Conc. (ppm)
1991 (7/02) 1 0.129
1992 (8/17) 1 0.126
1993 0 < 0.125
The Department has also met the EPA deadline (November '93)
for the submittal of a plan to maintain compliance with the
ambient ozone standard. The (draft) plan does not amend the
existing RACT regulations.
The latest Department's emission inventory taken during the
1990 Ozone season indicates the industrial emissions
accounted for about 6 percent of total Portland area VOC
emissions. The VOC emissions in the following years follow
the same trend and the percentage would be very similar:
VOC Emissions
Source Type lbs/day Percent (%)
Stationary Point Sources 35,913 6
Stationary Area Sources 158,311 26
Biogenic Sources 91,462 15
Non-Road Mobile Sources 87,079 14
On-Road Mobile Sources 239,338 39
Total within Portland AQMA 612,103
No emission increase is proposed with the RACT assessment.
In fact the proposed RACT standard will (legally) prevent
Intel from increasing the level of pollutant emitted per
unit (wafer) production. The RACT standard combined with
the emission cap (PSEL) established in this permit represent
one of the most effective environmental protective measure
available, which can only help maintain the Portland
attainment status.
Initial RACT assessment (screening)
Semiconductor manufacturing processes performed at the Aloha
campus were initially divided into four (4) distinct
categories of operations; out of which only two () types of
operations are determined to be suitable candidates for
specific RACT assessment in this permit:
VOC storage, handling, and distribution
VOC waste collection and disposal
Solvent cleaning stations
Photoresist operations
VOC storage and handling: Drums (< 55 gal.) and smaller
carboys are used to deliver organic chemicals to the process
areas through a closed fill (hard piped) system, during
which displaced vapors (VOCs) are fed back to the waste bulk
(under-ground) storage tanks. Solvents in drums are pumped
through hard piping to a process unit where it is
quantitatively dispensed directly to the process equipment.
VOC Waste collection/disposal: Any excess and/or spent
materials from the process equipment are collected in a
closed capture unit and drained (piped) to the waste storage
vault.
The over-all controls provided in these first two categories
of Intel specific operations exceed RACT; A similar solvent
distribution/collection system (>95% efficiency) was
determined to be BACT by the California Air Resource Board
(CARB). This high degree of collection efficiency provided
by the enclosed solvent distribution/collection system is
one of the contributing factors that over 90% of all plant
site VOC emissions come from the photoresist processes, and
most of the remaining (10%) portion of VOC emissions is
generated from the solvent cleaning stations. By design,
VOC emissions from these tightly controlled solvent
distribution/collection operations are insignificant. This
is one of the deciding factors not to establish a separate
individual RACT standard for these solvent distribution/
collection operations: The level of control provided
already exceeds what the RACT would require, and a further
technical/economical review would become an academic
exercises at best. Furthermore, recognizing these
operations are actually a (supportive) part of the (main)
photoresist activities, it is better to regulate these
operations under the photoresist RACT standard.
It must be noted that omission (on paper) of these
solvent/waste distribution/collection operations from the
individual RACT assessment does not mean these operations
are being exempted from the RACT review. Instead, the RACT
standard set forth in this permit for the (main) photoresist
operation extends to the solvent distribution/collection
operations - which are essentially an auxiliary part of the
main photoresist operations. Of related topic, the photo-
resist RACT standard would also apply to VOC emissions from
the solvent cleaning stations, even though a separate RACT
(FBR) standard would indeed be established in this case.
The regulatory approach (RACT review) utilized in this
permit review allows the Department to focus on the latter
two () categories of operations where the environment
impact would be the greatest. In addition, it requires the
permittee to provide an additional (FBR) performance measure
at the solvent cleaning stations, even though VOC emissions
from cleaning stations are regulated by the (main) photo-
resist RACT standard.
In summary, the solvent distribution/collection activities
support the photoresist operations, and this fact
sufficiently acknowledges that these activities are indeed a
part of the photoresist operations and be regulated as such.
Instead of a separate RACT standard for these auxiliary
activities, a universal RACT standard, applicable to all
phase of semiconductor manufacturing, better serves the
Department/permittee from the enforcement/practical stand
point. A similar rationale applies to the solvent cleaning
stations. Only difference is that the FBR control required
at the solvent cleaning stations serves as an additional
layer of protection. RACT Standard for Solvent Cleaning Stations
Solvent cleaning and degreasing operations at Intel are
executed on a small scale with open area (top dimension)
ranging from 2 to 4 ft2. Size-wise, Intel's solvent
cleaning/degreasing stations don't even come close to
industrial size cold cleaners, open-top vapor degreasers, or
conveyorized degreasers. However, the solvent cleaning
operations, regardless of their size, are functionally
similar. They all use solvents in either vapor or liquid
phase to remove impurities from the product surface. The
operational goal of any cleaner or degreaser is common, and
this is the rationale for applying the CTG developed for
"conventional" organic solvent cleaners/degreasers to
Intel's "small scale" solvent cleaning operations.
Recommended CTG standards in general consist of proper
operating procedures, and additional control devices. The
CTG document (EPA-450/3-78-120) recommends conveyorized
degreasers smaller than 21.5 ft2 of air/vapor interface; and
open-top vapor degreasers smaller than 10.8 ft2 of open area
be exempted from having to add a major control device such
as refrigeration/condenser. Pursuant to the guidelines set
forth in the referenced CTG, the RACT assessment in this
permit is therefore based on proper operational procedures.
The most common and effective operational procedures applied
to the cleaning/degreasing operations include controlled
Freeboard Ratio (FBR) and covers. FBR is defined as the
freeboard height (depth) divided by the width of the
(usually rectangular shape) open top. Higher FBR reduces
diffusional (VOC) losses by lessening the effect of
(ambient) air current on the air/solvent interface zone.
Covers obviously prevent natural drafts and reduce solvent
evaporative losses.
Approximately 90% control efficiency can be achieved with a
0.7 FBR and covers for the sinks. The test results compiled
in "Air Pollution Engineering Manual (1992, p. 352-357)
further supports the effectiveness of the FBR control.
Table 1 (Attachment A9) lists various control equipments for
cleaners and their control efficiencies taken from the CARB
report. Intel also furnished historical source test data
(Attachments A10 through A13) to characterize VOC
evaporative losses from their operational areas where parts
cleaning operations are performed. In establishing the RACT standards for Intel's solvent
cleaning stations, a further observation (of source
uniqueness) is necessary. There are a few solvent cleaning
stations at Intel that are not conventional in a sense that
these stations resemble a typical laboratory (or kitchen)
sink: It consists of a sink and over-head hood with built-
in fan, a solvent faucet, and a typical drain system. The
parts are cleaned in running solvents (from the faucet) and
the waste solvents are immediately drained (piped to the
waste storage vault). If there is no solvent left standing
in the sink, the FBR/cover control requirements simply do
not apply. Therefore the FBR control is applicable only
when parts are cleaned by immersion. The following RACT
performance standards (permit language) are appropriated for
Intel's solvent cleaning operations:
þ The freeboard ratio must be equal to or greater than
0.7 if parts are cleaned by immersion.
þ A cover must be provided during idle periods if the
sink contains any free standing solvents.
þ The cleaners are exempt from these RACT requirements if
they use non-VOC solvents as defined in OAR 340-22-100.
RACT Standard for Photoresist Operations
Reiterating, the photoresist operation is the single largest
source of VOC emissions at the Aloha campus, generating
approximately 90 percent of total plant site VOC emissions.
Traditionally the photoresist processes are categorized into
two sub-categories termed "positive" and "negative" (terms
used throughout this review report). Both the positive and
negative photoresist processes use solvents in their spin
coater operations, but only the negative photoresist process
uses solvents in the development stage. Historical data
confirms the negative process emits a significantly greater
amount of VOCs then the positive process.
The (California) Bay Area Air Quality Management District
(BAAQMD) has designated the positive process as RACT; since
in terms of VOC emissions, the positive process translates
to the equivalent of 90% abatement for the negative process.
In other words, the RACT control for the negative process is
either providing the 90% equivalent emission control or a
conversion of the negative to the positive system.
The existing photoresist machines at the Aloha campus are
all based on the positive technology, except for one
negative unit. VOC emissions from the negative process are
approximately 11 tons/yr (tpy), and the cost of controlling
this emissions to the level of the positive technology (1.1
tpy) was shown to be beyond the cost acceptable for a RACT
cost increment. The control cost of thermal destruction was
also estimated to run well over $10,000/ton/yr.
Following BAAQMD, the alternative (to thermal control)
looked at is the conversion. However, the conversion from
negative to positive was also determined to be not cost
effective for Intel. The cost of conversion would run into
well over $10,000/ton/yr (based on quotes from the equipment
vendors). The Department generally acknowledges the control
cost greater than $10,000/ton/yr to be excessive for RACT.
From the cost stand point, the permittee (Intel) is exempt
from having to provide the RACT level (equivalent to their
positive process) control to their negative system. And
since the positive system itself is considered equivalent to
RACT, the source-specific RACT assessment for Intel could
end at this point. However, this RACT review went a step
beyond the straight conversion, and the other control
alternatives are explored on a plant wide basis:
First of all, recognizing the positive photoresist process
units significantly outnumber "one and only" negative unit
at the Aloha campus. This opens up the possibility of over-
controlling (tweaking, P2, etc.) each and every positive
units (already considered RACT equivalent) to a degree such
that it would not be considered cost excessive. Over-
controlling "many" positive units even to a small degree;
beyond what the RACT would require, to the extent that is
equal to or greater than the under-controlled level from
"one and only" negative unit; could easily yield the net
result being equal to or greater than the RACT equivalent
control across the entire plant. For instance, providing
numeric value to a given example, over-controlling VOC
emissions from each and every 100 positive units by 0.1 tons
(total 10 tons) would more than offset the total under-
controlled amount of 5 tons from one (1) negative unit.
This is accomplished by, in lieu of having separate
standards for the positive and the negative, establishing
one common universal standard for both the positive and
negative system. This universal RACT standard, which is
based on (cleaner) positive technology, is also applicable
the negative process performed at the Aloha campus. Thus
the permittee can only comply with this universal RACT
standard by providing over-control at the positive units.
This basically illustrates the Bubble (OAR 340-28-1030)
concept. In addition to the Bubble concept, the universal RACT
standard serves another purpose. Consider the dynamic
nature of the semiconductor industry. Unlike traditional
smoke stack industries, the semiconductor technology, and
the manufacturing process which it is based on, rapidly
changes with respect to time. The manufacturing processes
may no longer be based on so-called the positive/negative
photoresist technology. From the enforcement perspective,
it is highly desirable to have a definite regulatory control
over Intel's future operations, as well as their existing
operations.
The universal RACT standard proposed in this permit is
applicable to all existing positive and negative systems, as
well as all future wafer manufacturing processes, regardless
of the technology a new system may rely on. The proposed
RACT standard will encourage Intel to promote the pollution
prevention, such as incorporation of necessary process
equipment design/changes and chemical substitution, during
the research and development stage. Furthermore, this
universal RACT standard eliminates the need to separately
monitor the chemical usage (emissions) of the positive from
the negative. This greatly simplifies the chemical mass
balance (enforcement tool) needed to determine permittee's
compliance status with respect to the RACT standard.
Intel's historical emission and production data were
evaluated and the most appropriate time period that
accurately represent Intel specific positive photoresist
technology was determined. The year selected is 1985
because it was the year the positive process at the Aloha
campus incorporated the (source-specific) EBR and cuprinse
steps. These unique EBR/cuprinse designs significantly
reduced the VOCs emissions from the "traditional (those
without)" positive photoresist process. The positive
process units at the Aloha campus continue to utilize these
source-specific EBR/cuprinse technologies.
VOC emissions Production
59.97 tons 181,300 normalized
8" (inch) wafers
The above emission and production data is the extent to
which the public document such as this review report can
(legally) disclose. Chemical and production specific
information necessary for compliance determination are
available at the plant site for Department/EPA inspections. Based on the above emission data from the Intel specific
positive system with the EBR/cuprinse design, the universal
source-specific RACT standard applicable to Intel's entire
spectrum of wafer manufacturing processes is:
2 X 10-4 lbs VOC per cm2 Wafer Processed
þ The permittee must achieve real reductions in actual
VOC emissions consistent with the proposed RACT level
(2X10-4 lbs VOC/cm2) of control. The proposed RACT
standard, directly tied to actual production rate,
provides an assurance that source cannot utilize non-
production or equipment downtime credits in their
emission calculations to show compliance with the VOC
PSEL. A proposed RACT is essentially a performance
standard independent of PSEL and it directly limits the
amount (lbs) of VOC emitted per specific amount (cm2)
of wafer production.
þ The proposed RACT standard applicable to the current
technology employed by Intel extends to all future
technologies contemplated and adopted by Intel and
utilized at the Aloha campus.
RACT Averaging Time
The short term PSEL proposed in this permit is weekly and it
was determined to be most compatible with the source
operations, pursuant to OAR 340-28-1020(2). The RACT
averaging period needs to be consistent with the VOC PSEL
short-term monitoring period and is therefore based on
weekly also.
The RACT compliance determination is essentially based on
the wafer start (processed; not the final number of finished
product) and CMB. The ratio of the amount (lbs) of VOC
emitted in a week period is taken against the amount (cm2)
of wafer start in that same week period. The result is
measured against the permitted RACT standard to determine
the permittee's compliance status.
The wafer production lines continuously operate for about 5
to 7 days. Raw chemicals/solvents used in wafer production
have uniform VOC content (%), and the production rate (and
thus VOC emission rate) remains consistent throughout the
weekly production cycle. This means weekly emission is
essentially the sum of daily (hourly) emissions, if such
(hourly/daily) measurement is viable. In fact, the RACT
averaging period could (legally) stretched to a month since
a monthly emission would also closely reflect the sum of
daily emissions during that same month. However, a weekly
period is determined to be the shortest practical period
most compatible with the source operations, and thus the
averaging period selected in this permit.
Summary: The RACT standard established in this permit
(#14.a.) for the photoresist operations is actually the
universal (plant-wide) standard applicable to the entire
spectrum of semi-conductor manufacturing performed at the
Intel Aloha campus. The Free Board Ratio (FBR) established
in this permit (#14.b.) is applicable only to the solvent
cleaning stations, and it essentially serves as a built-in
performance standard that further encourages (additional
layer of) emission control from the permittee. Condition
14.c. is to be used as a vehicle to trigger the RACT
standards proposed in Conditions 14.a. and 14.b. once the
Department receives an approval from EPA.
15. Condition 15. provides conditional compliance schedule, a
mechanism necessary to establish alternative RACT controls
acceptable to (or recommended by) EPA, to be used in the
event the proposed standards are disapproved. Note that
this "conditional" compliance schedule is triggered only if
the proposed standards in 14. are disapproved by EPA.
POLLUTION PREVENTION AND PRE-APPROVED CHANGES
Permit conditions 16. through 18. represent an attempt to
incorporate pollution prevention conditions in the Title-V
operating permit and provide the permittee operating flexibility
to meet pollution prevention goals and objectives by pre-
approving a narrowly defined set of changes. The Department
views this as a trial project and an opportunity for the
Department to gain a wealth of information on the viability and
effectiveness of including pollution prevention requirements in a
Title-V operating permit.
16. Pollution Prevention
The pollution prevention condition requires the permittee to
develop and implement a pollution prevention program and
submit reports on implementation of the program.
16.a. Implementation of the program, as established in
item 16.a., is fairly short and designed to implement the
pollution prevention quickly upon issuance of this permit.
16.b. The program consists of at minimum the following
program elements:
16.b.i. A description of the process the permittee
will use to introduce pollution prevention into their
decision-making procedures;
16.b.ii. a partnership/agreement the permittee will
establish with its material suppliers to minimize
hazardous air pollutants and volatile organic compounds
from the raw materials and products;
16.b.iii. a partnership/agreement the permittee will
establish with its equipment vendors to minimize
hazardous air pollutants and volatile organic compounds
using pollution prevention in equipment design;
16.b.iv. development of a data collection system
appropriate for evaluating pollution prevention
effectiveness;
16.b.v. development of an employee training program
to promote pollution prevention at the permitted
facility; and
16.b.vi. a statement of commitment to pollution
prevention at the permitted facility.
16.c. Item c. is a provision for changing elements in
the pollution prevention program, differentiating between
minor changes that can be made immediately and reported in
the annual report and major changes which require 30 day
notification prior to change and a demonstration of need for
the change. A major change is eliminating a program
element, such as the employee training program.
Modification of a program element, such as a change to the
training program, is considered a minor modification.
16.d. The permittee is required to develop a detailed
annual report that outlines progress made during the
preceding calendar year. As this detailed report will
contain market-sensitive information, it will be kept at the
site and made available to Department representatives for
inspection at the facility. The permittee shall also submit
an executive summary of the detailed annual report. The
annual report during the last year of this permit shall
contain a summary of the project and a self-evaluation of
the effectiveness of the program. 17. Pre-approved Changes
Through pre-approval of a narrowly defined set of changes,
Intel and Oregon DEQ will expedite the administrative
procedural requirements of minor new source review (OAR 340-
28-2270). These pre-approvals do not involve increase in
emissions or major modifications, and definitely do not
represent an exemption to any applicable requirement. These
conditions are drafted to be fully protective environment
and to promote pollution prevention.
17.a. Item a. states the approved changes only extends
to VOC emitting activities at stationary sources EU1.1 and
EU1.2. The only other remaining stationary source (EU1.3)
at EU1 consists of two office buildings which are listed in
the permit for identification purpose only.
17.b. Item b. strictly prohibits the permittee from
adding a new stationary source.
17.c. Item c. states all new or modified activities must
continue to comply with the VOC PSEL. This condition also
binds the permittee to do the pollution prevention as
specified Condition 16.
17.d. Item d. prohibits addition of a new Pollution
Control Device, and it also prohibits the permittee from
making changes to existing VOC control devices (PCD1 &
PCD26) such that the performance (control efficiency) would
be degraded.
17.e. Item e. states all new or modified activities must
continue to comply with the source-specific RACT standard.
17.f. Item f. states the permittee cannot deviate from
the existing compliance monitoring requirements established
for the VOC PSEL and RACT Conditions.
17.g. On top of all the restrictive criteria specified
in items a. through f., item g. is established to further
insures that no new applicable requirement is triggered.
17.h. Item h. directs the permittee to the appropriate
monitoring and reporting that they must abide by.
18. This condition is a sunset provision which conveys that the
pollution prevention (16.) and pre-approval (17.) conditions will
expire at the expiration date of this permit unless there is a
mutual agreement between the permittee and the Department to
continue. 19. AGGREGATE HAP EMISSION LIMIT
The aggregate combined Hazardous Air Pollutants (HAPs) limit
of 10 tons/yr for each organic and inorganic HAPs set forth
in this section comprises a cap on the permittee's total
HAPs emissions. It limits the permittee's potential to emit
and categorizes the permittee as a minor HAP source. As
long as the permittee operates within the HAP limits set
forth in this section, the permittee retains the minor HAP
source status and thus not subject to provisions set forth
in OAR 340-32-300 through 340-32-4500.
The minor HAP source status was initially determined from
the permit application (specific chemical usage is
confidential and all records are kept at the plant site and
are made available to the Department representative). A
review indicates the HAP minor source status was determined
(conservatively) by using the HAP usage data and not the
emission data for certain chemicals. Toxic substance usage
data are provided in Attachment 14 (A14).
The emission cap set forth in this section is actually more
stringent than what the applicable rule requires: OAR 340-
32-120 defines a major source as one that has the potential
to emit, considering control, in the aggregate, 10 tons/yr
or more of any individual HAP or 25 tons/yr or more of any
combination of HAPs. The 10 tons/yr emission cap in this
permit applies to emissions of a total combined organic
HAPs, and similarly a separate 10 tons/yr emission cap
applies to inorganic HAPs emissions.
The individual organic or inorganic HAP emission can never
exceed 10 tons/yr since the combined emissions of either
organic or inorganic HAPs must remain below the 10 tons/yr
cap. Therefore the permit compliance demonstration
requirements do not require monitoring of individual HAPs.
(This is an excellent trade-off, more stringent limit for
easy of monitoring, and perfectly legal) Only the aggregate
amount needs to be known to determine the permittee's
compliance status with respect to the 10 tons/yr aggregate
limits set forth in this permit.
MONITORING REQUIREMENTS
Monitoring requirements provided in this section are the primary
tools used by the permittee and the Department to assess the
permittee's compliance status. Monitoring requirements in this
section are divided into six (6) parts: Condition 20. specifies
the monitoring related to the facility-wide applicable
requirements. Condition 21. specifies the monitoring related to
those applicable requirements targeted at specific emission
unit(s). Condition 22. deals with the monitoring associated with
the limits applicable to "insignificant" activities. Condition
23. outlines the compliance determination for the (EU2 & EU3)
boiler PSELs. Condition 24. is reserved for the monitoring
associated with the VOCs and HAPs PSELs and the source-specific
RACT requirements. And lastly Condition 25. identifies
monitoring related to the pre-approval condition.
20. "Facility-wide" Monitoring
Before individual monitoring protocol associated with the
applicable standards (that are targeted at "particulate"
emissions) in this section is judged solely by its content,
a through understanding of what is actually being regulated
is necessary, as this influences the level of monitoring
related to such activities. The only notable particulate
generating processes performed at the Aloha campus is the
wafer grinding operations. As discussed extensively
(considering the subject is insignificant) in item 13. of
this review report, the wafer grinding operations are
controlled by PCD3 and PCD4 baghouses, and the emissions
from these baghouses total about 0.02 tons/yr.
20.a. This Condition establishes the monitoring
protocols for the process fugitive dust control requirements
set forth in Condition 5., the 250 micron particulate
fallout standard set forth in Condition 6., and the
odor/nuisance standards set forth in Condition 7.
Intel is an insignificant source of particulate emissions;
the only notable particulate emissions come from PCD3 and
PCD4 and these baghouses are incapable of emitting
particulate matters larger than 250 micron. The source also
has an excellent compliance history (no permit violation nor
public complaints to this date) which also influence the
level of compliance demonstration requirement set forth in
this permit.
Monitoring requirements consist of complaint investigations
as they occur and the subsequent reporting in the semi-
annual report. For example, the Department may request
Intel to investigate upon receiving complaints from the
public; or Intel may initiate the investigation themselves
upon receiving complaints related to referenced permit
conditions. The permittee is also subject to the Department
and/or EPA inspection, which is another vehicle for
compliance determination. 20.b. This Condition requires the permittee to keep a
summary of actions taken during an air emergency episode
declared in the Portland area by the Department for ozone.
20.c. A periodic monitoring requirement for the facility
wide limits (PSELs) for insignificant activities consists of
an inspection every six month to confirm that no significant
change(s) has been made such that the aggregate
insignificant limits would be exceeded. The permittee is
also required to quantify the emissions from insignificant
activities once per permit period, preferably at the time of
permit renewal.
21. "Emission Unit Specific" Monitoring
21.a. The 0.1 gr/scf grain loading and the 20% opacity
standards are federally and state enforceable conditions
that apply to all fuel burning equipments. These standards
therefore apply to all EU2 and EU3 natural gas burning
boilers.
Again, the nature and characteristics of an affected
emission source must be considered and then reviewed with
respect to the intent and (occasionally) history of
applicable standards in order to develop a meaningful
monitoring requirement. The grain loading and opacity
standards cited above were developed in the early seventies
in order to regulate the boilers fueled by wood wastes,
coal, and heavy residual oils, that are generally operated
without any control.
Natural gas is one of the cleanest fuels available, and
visible/particulate emissions from natural gas combustion
are insignificant when compared to combustion of oil, coal,
or wood wastes. Visible emissions, other then heat wave
during cold weather, from natural gas combustion are
virtually non-detectable to the human eye. It is safe and
reasonable to conclude (assume) that the 20% opacity
standard would not be exceeded during natural gas
combustion.
Grain loading from natural gas combustion would generate
particulates (all considered to be PM10) at a level below
the grain loading standard of 0.1 g/scf, corrected to 12%
CO2 (stoichiometric feed of air). EPA AP42 indicates 12 lbs
of particulate is generated from million (106) ft3 of
natural gas combustion. First of all, this AP42 data is
believed to be a conservative figure. In reference to 40
CFR, Part 60, Appendix-A, Method 19; a million ft3 of
natural gas combustion based on stoichiometric feed would
yield 9.15 x 106 ft3 of dry flue gases:
106 ft3 x (1050 btu/ft3) x Fd = 9.15 x 106 dscf
where Fd = 8,710 dscf/106 btu
Twelve pounds (12 lbs) of particulates in 9.15 x 106 dscf of
flue gases are equivalent to grain loading of about 0.01
g/scf.
12 lbs x 7000 g/lb ÷ 0.009 gr/scf < 0.1 gr/scf.
9.15 x 106 dscf
Even a conservative EPA AP42 figure of 12 lbs/106 ft3
indicates the average grain loading from natural gas
combustion is less than 10% of the rule standard of 0.1
gr/scf.
In conclusion, as long as the permittee uses natural gas
only, the 20% opacity and 0.1 g/scf grain loading standards
would be met. The compliance demonstration requirements
include necessary monitoring and reporting of type(s) of
fuel used and its consumption rate(s). In the event the
permittee elect to use fuels other then natural gas (oil for
instance), the permit must be opened to incorporate
necessary applicable requirements, such as OAR 340-22-010 to
340-22-0250, and to modify compliance demonstration
requirements, pursuant to item a.iii.
21.b. Periodic monitoring requirements established in
this condition perfectly adequately demonstrate the
compliance status with respect to the O&M requirements set
forth for PCD1:
21.b.i. The water pressure drop across packing is
directly influenced by the water flow rate, and
therefore the pressure drop in place of actual water
flow rate is an acceptable substitute (monitoring
parameter). The water flow rate can also be obtained
from the pump curve. The key parameter to monitor and
record, per this condition, is the changed status of
the water flow rates; to and from 75, 100, and 125 gpm.
21.b.ii. In conjunction with the scrubber water flow
rates determined in item b.i. above, the inlet air flow
to PCD1 is needed to determine the compliance status
(i.e., one is useless without the other). The key
parameter to look for is the changed status of the air
flow rates; to and from 5,500, and 6,500 scfm.
Also note that, although both the water (b.i.) and air
(b.ii.) flow rates are needed to determine the compliance
status, the permittee is not obligated to record both items
each time the change is made. It is because the minimum
compliance level (water flow) corresponding to a given air
flow is just that - the minimum. The necessary water flow
rate corresponding to a certain gas flow rate need not be
shifted downwards just because the gas flow is decreased
from one level to the next. However, the opposite is not
true. The necessary water flow rate corresponding to a
certain gas flow rate needs to be shifted upwards when the
gas flow is increased from one level to the next. If the
permittee decides to keep the water flow at its maximum
(above 125 gpm), then no shifting (monitoring) what-so-ever
is necessary. This is not a suggestion, but simply a detail
explanation of what the permit requires. Suppose such
practice would no doubt be discouraged in the dry region
where water is particularly precious.
22. "Insignificant Activities" Monitoring
The grain loading standard of 0.1 gr/scf (11.a.) and the 20%
opacity limit (Condition 11.b) apply to non-fuel burning
sources. However, as discussed earlier (see Review #20) the
measurable particulate emissions from the Aloha campus total
about 0.02 tons annually. The fact that semi-conductor
manufacturing must be performed inside the clean room
environment, a significant amount of capital is spent just
to clean the ambient air routed to the process area, is an
indication that such operation does not even come close to
the particulate/visible emission standards set forth in this
permit. Furthermore, the most, if not all, solvents (VOCs)
emitted from the Aloha campus are believed to be colorless,
which leads to believe the visible (opacity) emissions would
not be a major concern.
Periodic monitoring requirements consist of a visible
emission survey once every six month to conform with the
semi-annual compliance certification protocol. In addition
the source is subject to the Department/EPA inspections,
which further ensures the permittee's compliance performance
toward the 0.1 gr/scf and 20% opacity standards would be
measured and potentially changed if deemed necessary.
23. "EU2/EU3 Boilers PSEL" Monitoring
The boiler emissions are calculated based on natural gas
usage and the appropriate emission factors. The EU3 boilers
are equipped with LowNOx control, and comparatively EU3
boilers' Nox emissions are much less than EU2 boilers. See
emission detail sheets; attachments A1 through A6.
23.a. The annual emission is determined by multiplying
annual fuel usage to appropriate EF listed in the Table.
All Efs are the AP42 data, except EU3 boiler's NOx and CO
Efs which are based on manufacturer data, verified by source
test.
23.b. The monthly emission is determined by multiplying
monthly fuel usage to appropriate EF listed in the Table.
The EU2/EU3 boilers' monthly limits are based on the sum of
each boiler's maximum capacity, and theoretically this
maximum capacity can never be exceeded. As long as no
physical modification is made to the boilers, the capacity
remains the same. In actual practice, all boilers are
operated well below their maximum capacity.
23.c. The natural gas usage is obtained on a monthly
basis from the monthly bill assessed by the gas company.
This means that the monthly natural gas usage information
would not be available at the end of each month, and the
EU2/EU3 emission calculations would be delayed accordingly.
24. Monitoring related to "source specific" Applicable
Requirements
This condition determines the permittee's compliance status
with respect to the VOC PSEL and RACT conditions, and the
aggregate HAP limits. They are combined here because
numerous same parameters are shared by all. The language of
this condition is specifically written to accommodate the
source-specific types of conditions and unique parametric
monitoring needs.
Annual VOC emissions are determined from the chemical mass
balance as specified in items a, b, and c. However, the
nature and complexity of Intel's manufacturing processes
interfere with the direct monitoring of VOC emissions in a
short-term (weekly) basis. The weekly emission monitoring
is best accomplished by a combination of direct and indirect
measurements.
This permit utilizes the bi-monthly VOC emission factor (EF)
calculated based on the actual solvent usage and the actual
production figures from the previous two month. The bi-
monthly EF will be updated every two month to reflect the
most recent process changes. This is needed to compensate
for the on-going process changes. Weekly emission is then
estimated by multiplying EF to weekly production output.
The proposed VOC weekly emission monitoring, although
indirectly measured, is proven to produce consistent and
accurate emission data. As shown in Figure-1 (attachment
A8), the EF dependent monitoring closely reflect the actual
emissions. Furthermore, the actual emission monitoring is
not omitted in this permit, but rather it is delayed for a
short period (two month) of time.
The VOC monitoring also contains a built-in quality
assurance measure. The accuracy of each EF is verified at
the end of each monitoring period (2 months) by comparing
the EF dependent emissions (2 month sum of item g.) to the
actual emissions obtained from the actual bi-monthly solvent
monitoring as specified in items a, b, and c.
Item d. establishes the monitoring requirements necessary to
verify the permittee's (synthetic) minor HAP source status.
Item d. calls for separation of organic HAPs from the
inorganic HAPs. The 10 tons/yr annual cap set forth in this
permit is based on a monthly rolling average, continuously
averaged over previous 12 month period. This means the
permittee must be able to demonstrate each month that their
aggregate annual HAPs emissions during the previous 12 month
period was below the 10 tons/yr cap. Of related topic,
emissions from the aggregate insignificant activities must
be included in the HAP emissions calculations of item d.,
but the actual quantification of aggregate insignificant
activities is only done once per permit period, per 20.c.ii.
Items e. through h. are further necessary to determine
compliance status with respect to the RACT standard of 2X10-
4 lbs VOC/cm2, and in order to update the bi-monthly EF and
determine weekly emissions.
Item i. specifies monitoring scheme related to the RACT FBR,
and item j. sets the criteria under which the permittee
shall conduct the RACT monitoring.
Lastly, item k. establishes source testing requirements for
PCD1. There was no source testing requirement in the
previously issued ACDPs since the chemical mass balance
alone was perfectly adequate to estimate the plant site VOC
emissions. Now with the control equipments PCD1 & PCD26 in
place, at minimum the PCD1 efficiency is necessary to
complete the chemical mass balance equation. No source
testing is required on PCD26 (as discussed in #4.) because
the amount of solvent recovered is directly measured to
complete the mass balance.
25. Monitoring related to Pre-approval
This condition specifies the methods used to verify whether
new VOC emitting activities and/or changes made to the
existing VOC emitting activities at the stationary sources
EU1.1 and/or EU1.2 comply with the criteria set forth in
Condition 17.
Verification with respect to the criteria set forth in
Conditions 17.a., 17.b., and 17.d. through 17.g. must be
done on a six-month basis, and these are straight forward.
The permittee needs to include in the semi-annual report a
summary of these inspection results.
As specified in Conditions 25.a. and 25.c., verification
with respect to the criterion set forth in Condition 17.c.
is a bit more involved. The permittee must determine
whether or not the maximum combined capacity to emit of each
stationary source at EU1 has been increased beyond the
weekly PSEL. The permittee must also monitor the changes in
the maximum capacity to emit of EU1 on a six month basis.
If no increase is noted from the previous level, no further
action is necessary. If any increase has occurred, the
permittee shall submit Notice of Completion containing the
required information as specified in item 25.c.i. through
25.c.iv.
TEST METHODS AND PROCEDURES
The permittee is not subject to the test methods and procedures
identified in this section until the Department or EPA formerly
requests/orders the permittee to do so. The Department/EPA may
find valid to request such additional test in the (rare) event
the specific monitoring protocols identified in the monitoring
section are no longer deemed appropriate or adequate to determine
compliance status with respect to the associated applicable
requirements.
RECORDKEEPING REQUIREMENTS
Recordkeeping requirements in this permit are drafted pursuant to
OAR 340-28-2130(3)(b). As was the case with the ACDP records,
all records related to the OTOP 34-2681 compliance monitoring
must be kept at the plant site for at least 5 years.
REPORTING REQUIREMENTS
Reporting requirements in this permit are drafted pursuant to OAR
340-28-2130(3)(c). Under the Source-specific Reporting
Requirements of Condition 32., the fuel usage data per item 32.e.
is used to estimate the annual emissions from the EU2/EU3
boilers. Items 32.f. through 32.j. report the compliance status
with respect to the VOC PSEL and RACT conditions; and item 32.k.
(state enforceable only) provides a summary of compliance status
with respect to the rolling HAP limits.
The annual (PSEL) emissions reported for criteria pollutants are
based on calendar year, and the compliance status is determined
at the end of the year. However, the annual aggregate emissions
reported for (HAPs) per item 32.k. are based on rolling monthly
average. The compliance status with respect to the annual
(synthetic minor) HAP limit is determined at the end of each
month; and this means a total of 12 compliance determination per
year will be made with respect to the annual HAP limits set forth
in Condition 19.
NON-APPLICABLE REQUIREMENTS
Non-applicable rules and corresponding explanation are provided
in this section. These are self-explanatory, and no detail
discussion is provided.
GENERAL CONDITIONS
The "General Conditions" section lists additional applicable rule
requirements that permittee must adhere to, as with any other
permit conditions, and these requirements in general are common
among all Title-5 sources.
SUMMARY/PUBLIC NOTICE
The proposed permit will be placed on public notice. There are
three distinct proposals in this permit, of which each proposal
requires public notice and/or hearing as follows:
Increase in boiler PSELs, Condition 12.b. requires public
notice, and a hearing will be scheduled if requested by
public in adequate number.
The pollution prevention and pre-approved changes, as
outlined in Conditions 16. through 18., require posting of a
public notice and possible hearing if requested by public in
adequate number.
Source-specific RACT requirements set forth in Conditions
14. and 15. must follow the procedural requirements of 40
CFR Part 51.102; which include posting of public notice in
the newspaper, followed by a hearing process regardless of
the public request/participation. In addition, as this is a
source- specific SIP revision, a secretary of state notice
must also be filed, which may coincide with the public
notice issued per 40 CFR Part 51.102.
GDY
November 3, 1995
F342681R
Table 1
Control Equipment and Control Efficiencies
VOC Control Equipment Control Efficiencies (%)
Cold Cleaner (low volatility)
cover 55 - 80
mechanically assisted cover and
spray and agitation control 50 - 90
Cold Cleaner (high volatility)
cover 55
mechanically assisted covers and
spray and agitation controls 70
Batch-loaded Vapor Cleaner
cover 45 - 60
mechanically assisted covers and
spray and agitation controls 60 - 75
Conveyorized Vapor Cleaner
cover 25
mechanically assisted covers and
spray and agitation controls 60
Carbon Absorbers 40 - 95a/
Refrigerated Chillers 10 - 40b/
Higher Freeboard Ratio 25 - 50c/
Use of Non-VOC Solvents 100
a/ A typical value is about 40 percent.
b/ For a batch-loaded vapor cleaner.
c/ Based on a baseline freeboard ratio of 0.5 for batch-loaded
vapor cleaners. Increasing the ratio from 0.5 to 0.75 and
1.0 results in about 25 and 50 percent emission reduction,
respectively. ATTACHMENT A
STACK TEST SUMMARY
N/A = Not Applicable
USAGE EMISSIONS
TEST SOURCE/STACK CHEMICAL (LB/HR) (LB/HR) %EVAP
FAB 4:
1 Degreaser IPA 0.83 0.0762 9.18
Hood Fan TCA 0.46 0 0
Acetone 0.27 0.0038 1.43
Freon N/A 0.0050 0
HMDS N/A 0.0009 0
Cyclohex N/A 0.0001 0
Cel Acet N/A 0.0004 0
Xylene N/A 0.0005 0
The hood was used for 15 minutes to clean D&W
parts.
2 Degreaser IPA 1.37 0.1384 10.10
Hood Fan Freon 0.55 0.0016 0.30
Acetone N/A 0.0013 0
Methyl CelN/A 0.0003 0
TCA N/A 0.0053 0
CTC N/A 0.0002 0
Cyclohex N/A 0.0001 0
Cel Acet N/A 0.0012 0
Xylene N/A 0.0003 0
The hood was used for 1 hour to degrease 30 parts.
1 Solvent Hood Cel Acet 18.8 0.0342 0.18
Fan NBA 2.16 0.0008 0.4
Xylene 3.38 0.0178 0.53
Acetone N/A 0.0003 0
IPA N/A 0.0038 0
Freon N/A 0.0004 0
Methyl CelN/A 1.5775 0
TCA N/A 0.0003 0
Cyclohex N/A 0.0001 0
Chloroben N/A 0.0010 0
Sink was used for 5 hours. Poured 43 gallons of
waste resist. USAGE EMISSIONS
TEST SOURCE/STACK CHEMICAL (LB/HR) (LB/HR) %EVAP
2 Solvent Hood Cel Acet 20.11 0.3484 1.74
Fan NBA 2.31 0.0026 31.32
Xylene 3.53 1.1055 0.11
Acetone N/A 0.1837 0
IPA N/A 0.0053 0
Methyl CelN/A 0.0030 0
TCA N/A 0.0003 0
Cyclohex N/A 0.0001 0
Chloroben N/A 0.0010 0
Sink was used for 6 hours. Poured 46 gallons of
waste resist.
1 Small Solvent Acetone 1.10 0.6341 57.65
Hood IPA N/A 0.0009 0
Freon N/A 0.0001 0
HMDS N/A 0.0016 0
NBA N/A 0.0036 0
Chloroben N/A 0.0108 0
Cel Acet N/A 0.1099 0
Xylene N/A 0.0607 0
Used for 2 hours.
2 Small Solvent Acetone 1.10 0.4235 38.51
Hood IPA N/A 0.0013 0
NBA N/A 0.0005 0
Cel Acet N/A 0.0178 0
Xylene N/A 0.0635 0
Used for 2 hours.
FAB 5:
1 Degreaser IPA 1.86 0.0824 4.43
Hood Freon 0.27 0 0
TCA 0.23 0.0223 9.72
Acetone 0.14 0.0884 63.21
HMDS 0.03 0 0
NBA N/A 0.0001 0
Cel Acet N/A 0.0027 0
Xylene N/A 0.0011 0
Hood used 7 separate occasions.
USAGE EMISSIONS
TEST SOURCE/STACK CHEMICAL (LB/HR) (LB/HR) %EVAP
2 Degreaser HMDS 0.53 0.0027 0.51
Hood Acetone N/A 0.0443 0
IPA N/A 0.0734 0
Methyl CelN/A 0.0025 0
TCA N/A 0.0183 0
Cyclohex N/A 0.0029 0
NBA N/A 0.0001 0
Chloroben N/A 0.0001 0
Cel Acet N/A 0.0016 0
Xylene N/A 0.0009 0
Hood used once.
1 Solvent Hood Acetone 12.48 0.2037 1.63
Cel Acet 0.01 0.0226 226.89
Xylene 0.001 0.0087 871.69
NBA 0.001 0.0002 23.54
M-pyrrol 0.40 Not Tested
IPA N/A 0.0020 0
Freon N/A 0.0001 0
TCA N/A 0.0043 0
Hood used 8 times.
2 Solvent Hood Acetone 0.93 0.2606 28.03
Cel Acet 0.02 0.0177 88.96
Xylene 0.003 0.0103 344.08
NBA 0.003 0.0001 3.49
M-pyrrol 0.40 Not Tested
IPA N/A 0.0013 0
TCA N/A 0.0159 0
Chloroben N/A 0.0004 0
1 Degreaser Hood TCA 0.92 0.117 12.71
Downstairs IPA 0.55 0.065 11.82
Acetone 0.55 0.072 13.09
NBA N/A 0.002 0
Cel Acet N/A 0.001 0
Hood used once to degrease parts.
USAGE EMISSIONS
TEST SOURCE/STACK CHEMICAL (LB/HR) (LB/HR) %EVAP
2 Degreaser Hood TCA 0.92 0.0349 3.79
Downstairs IPA 0.55 0.0097 1.76
Acetone 0.55 0.0069 1.25
Freon N/A 0.0007 0
NBA N/A 0.0036 0
Cel Acet N/A 0.0010 0
Xylene N/A 0.0005 0
Trimethyl N/A 0.0020 0
Hood was used once to degrease parts.
CHEMICAL NAME INDEX
IPA Isopropyl Alcohol
TCA 1,1,1, Trichloroethane
NBA N Butyl Acetate
M-pyrrol 1-Methyl-2-Pyrrolidone
Cel Acet Cellosolve Acetate
Freon Freon 113
Cyclohex Cyclohexanone
Chloroben Chlorobenzene
Methyl Cel Methyl Cellosolve
HMDS Hexamethyldisilazane
CTC Carbon Tetrachloride
Trimethyl Trimethylbenzene
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