In late 1993, Intel Corporation, the United States Environmental Protection Agency (EPA), and the Oregon Department of Environmental Quality (Oregon DEQ) joined in a partnership to evaluate opportunities to incorporate flexibility and pollution prevention in permits issued under Title V of the Clean Air Act as amended in 1990. This partnership provided a unique opportunity for multiple stakeholders to participate collaboratively on a pilot project to develop a facility specific "model" permit that incorporates pollution prevention as a permit condition.
Successfully completed in September 1994, the project created a draft Title V permit that will demonstrate the ability of pollution prevention to perform equally well in the reduction of air emissions as a traditional end-of-pipe controls. With this type of information, EPA may eventually establish Clean Air Act regulatory standards with a pollution prevention option, and not be restricted to only end-of-pipe control technologies.
The project demonstrated the value of partnerships between industry and governments in promoting pollution prevention and proactive environmental management strategies that support a company's economic viability while maintaining a high standard of environmental protection. Consistent with the objectives of EPA's Common Sense Initiative, a major objective of the project was to create a regulatory environment that fosters the adoption of pollution prevention strategies to reduce emissions and achieve regulatory compliance.
The partnership was formed as a result of an ad hoc effort by individuals attending an April 1993 conference on the role of the Clean Air Act in implementing pollution prevention technologies. In a formal effort to incorporate the ideas generated by the ad hoc group, EPA's Region 10 and Office of Air Quality, Policy, and Standards (OAQPS) initiated the Pollution Prevention in Permitting Pilot Project (also known as the "P4 Project").
In the months that followed, representatives from Region 10, OAQAPS, Oregon DEQ, Intel and the Pacific Northwest Pollution Prevention Research Center (PPRC) worked within the constraints of existing state and federal laws to craft a permit.
For the first several months of the project, EPA Region 10 staff worked with all stakeholders to gain input into the development of a purpose and process that would serve the needs of all participants.
By the first face-to-face meeting in November 1993, the organizations agreed they would come together as stakeholders to participate in a "workgroup" process. All stakeholders were given equal standing in the workgroup. The PPRCE participated as a neutral party, providing project support and assistance to workgroup members.
The workgroup agreed upfront on the project goals, and each stakeholder committed to meeting those goals. The group decided it would develop an implementable permit; identify regulatory barriers; document the process; and develop options and alternatives that could be useful to others. While acting as workgroup members, stakeholders would be expected to represent their interests in an open manner at all times. The group would seek to resolve issues to the satisfaction of all members. In addition, they agreed that materials developed during the project would not be released without full support from EPA, Intel, and Oregon DEQ management.
Intel Corporation is the world's largest manufacturer of semiconductors. The project focused on the company's Aloha Campus, in Aloha, Oregon, which is located on Intel's largest site. More than 6,500 employees work at the Oregon site, and approximately 2,000 people work at the Aloha Campus.
Opening in 1976, the Aloha Campus consists of five main buildings: two office buildings, two main manufacturing facilities, and one technology development facility. Eventually, the technology development facility will be converted into a manufacturing facility. New technologies developed at the technology development facility are deployed at Intel facilities throughout the world.
The Aloha Campus is located in a non-attainment area for ozone and carbon monoxide. Intel uses both volatile organic compounds and chemicals currently on the list of Hazardous Air Pollutants (HAPs) as specified under the Clean Air Act.
The site is classified as a major source for VOCs (190 tons releases per year); a minor source for organic and inorganic HAPs (less than 10 tons released per year for each); and a minor source of carbon monoxide. The campus operates boilers using natural gas as fuel.
The specific goals achieved include:
The draft permit, which is not final until the public review process has been completed, meets all federal and state requirements identified under the Clean Air Act, as amended in 1990, and those under development including Section 112(g); New Source Review, Part 70; and the Oregon State Implementation Plan. The permit is environmentally protective and fully enforceable under federal and state laws. It contains the following requirements:
Realizing that to implement pollution prevention, government must recognize opportunities that motivate industry to implement pollution prevention programs. Region 10 representatives assume industry makes decisions based on the economic advantages of pollution prevention. In determining the cost of pollution and, in turn, the benefit of pollution prevention, industry examines and balances four factors: the cost of inputs that cause environmental damage, the cost of polluting behavior, the cost of public concern, and the cost of adopting pollution prevention alternatives. In support of these assumptions, the P4 Project participants came to several conclusions:
Last Updated: January 16, 1996