City of Chandler
Wastewater Quality Division
Mail Stop 396
P.O. Box 4008
Chandler, AZ 85224-4008
Re: Comments on the Upcoming Renewal of the Industrial User Permit for Intel Corporation (Industrial User Permit No. 009)
Dear Permitting Staff,
We, the undersigned organizations and individuals, urge the City of Chandler to consider the following comments on the wastewater discharge permit for Intel’s Ocotillo Campus, located at 4500 S. Dobson Road, Chandler, Arizona (Industrial User Permit No. 009). Intel’s permit expires on June 30, 2026. We are submitting these comments in advance, so they can be considered before the permit is renewed and finalized.
The semiconductor industry uses and releases many harmful chemicals into our waterways, including per- and polyfluoroalkyl substances (PFAS). PFAS are highly persistent, mobile in the environment, and build up in people and wildlife over time. These chemicals are toxic and linked to serious health problems, including cancer, heart disease, and birth defects.[1],[2]
The Ocotillo Campus is Intel’s largest hub in the United States, covering a massive 700 acres of land, including six semiconductor manufacturing facilities (or “fabs”), in the City of Chandler.[3] Given its expansive size and the risks associated with PFAS, it is critical that the City of Chandler thoroughly plan for and manage PFAS discharges from this site.
Although the facility uses reverse osmosis to treat its wastewater, the permit does not require PFAS monitoring or set any limits or enforcement requirements for these harmful chemicals. Without such requirements, there is no assurance that PFAS discharges are being properly identified, monitored, or controlled.
The City of Chandler has been overseeing Intel’s production for decades, but PFAS has only recently become subject to regulatory and policy action, as the science has grown clearer. Other states and publicly owned treatment works (POTWs) have begun to monitor and set requirements for PFAS; it’s time for the City of Chandler to take similar action.
We urge the City of Chandler to consider the following recommendations:
- 1. The City of Chandler should provide a public comment period and hold a public hearing.
- The City of Chandler does not provide an opportunity for the public to weigh in when a pretreatment permit is being renewed. Given the scale of the facility and the known risks associated with its wastewater discharges, including PFAS, it is essential that the City of Chandler solicit public comments and hold a public hearing to ensure meaningful public engagement on the Industrial User Permit for Intel. Nearby and affected communities deserve to be informed and have a voice.
- 2. The City of Chandler should require Intel to submit a PFAS Action Plan.
- The City of Chandler should require Intel to develop a PFAS Action Plan, requiring Intel to fully disclose all the PFAS that it uses, generates, or expects to be in its effluent. Through the development of a PFAS Action Plan, the City of Chandler would better understand the types and quantities of PFAS present in its wastewater. A robust PFAS Action Plan would also help inform the monitoring requirements, minimization efforts, and treatment technologies necessary to effectively monitor, manage, and eliminate PFAS discharges.
- 3. The City of Chandler should update the permit to require, at minimum, that Intel conduct quarterly monitoring for PFAS using EPA Method 1633.
- PFAS monitoring is essential to understand the specific PFAS compounds present in Intel’s wastewater and to evaluate the effectiveness of its treatment processes. EPA has made it clear that states and POTWs do not have to wait for EPA to finalize its PFAS standards before they can take action. States and POTWs already have the authority to address PFAS in wastewater discharges immediately.[4]
- Since December 2022, EPA has directed states to use quarterly monitoring for 40 different PFAS compounds (EPA Method 1633). Quarterly monitoring using this method is already required at other Intel facilities, including at Rio Rancho, New Mexico and the Ronler Acres and Aloha campuses in Portland, Oregon. More broadly, numerous other POTWs require the monitoring of PFAS from the semiconductor industry. Therefore, the permit should be amended, at minimum, to require that Intel conduct quarterly PFAS monitoring using EPA Method 1633.
- 4. The City of Chandler should update the permit to require additional wastewater monitoring methodologies.
- The City of Chandler should revise the permit to require more robust wastewater monitoring methodologies. Given that there are thousands of types of PFAS, of which over one hundred PFAS are known to be used by the semiconductor industry, and new PFAS are constantly being introduced, testing for 40 compounds is inadequate for identifying the full suite of PFAS in semiconductor wastewater discharge.
- The City of Chandler should consider additional wastewater monitoring requirements, beyond EPA Method 1633, to identify all PFAS present in Intel’s wastewater. For example, the City of Chandler should require periodic non-targeted analysis to measure discharges of PFAS that may not be effectively removed by reverse osmosis. This approach has been used at the 3M facility in Cottage Grove, Minnesota. For more information on this, see CHIPS Communities United’s detailed comments submitted on the Analog Devices industrial user permit located in Camas, Washington.
- 5. The City of Chandler should require Intel to use destruction technologies to eliminate PFAS at the source.
- It is especially important to control PFAS at point sources such as Intel. While other industries are already being regulated with PFAS restrictions and bans, the semiconductor industry claims that PFAS are essential throughout the fabrication process. As semiconductor production continues to grow and evolve, the industry should be required to eliminate PFAS discharges.
- Reverse osmosis does not destroy PFAS and instead generates a concentrate containing high levels of PFAS that must be transported off-site for disposal. This concentrated waste stream poses numerous environmental and public health concerns. A growing variety of technologies exist which are capable of destroying PFAS.[5] As one of the most advanced chip making facilities in the world, Intel should be required to use treatment methods that destroy PFAS.
- 6. The City of Chandler should establish a goal of zero discharge of PFAS.
- Managing PFAS through limits for one chemical at a time will take years, delay critical protections, and may encourage the creation of alternatives that are just as harmful to skirt around protections. Given the persistent, bioaccumulative, and toxic nature of PFAS, the City of Chandler should require a zero-discharge goal for PFAS from all industrial uses. Every additional release of PFAS builds up in the local, regional and global environment, leading to contamination of drinking water supplies, fish, wildlife, livestock, and in humans.
- 7. The City of Chandler should require public reporting of monitoring results to ensure transparency and accountability.
- Public access to monitoring data ensures transparency, accountability, and public trust. The City of Chandler should require monitoring data be reported and posted to an easily accessible public website within 30 days of collection. Timely posting will build public trust in the effectiveness of minimization and treatment efforts and allow for the early detection of emerging issues.
Overall, the City of Chandler must hold Intel accountable for its PFAS pollution by strengthening PFAS monitoring, reporting, and treatment requirements within its Industrial User Permit. The public must be given transparent information and sufficient time to participate in the upcoming renewal of Intel’s wastewater discharge permit. None of these proposed recommendations would prevent Intel from continuing to produce chips. By addressing these concerns, the City of Chandler will hold industry accountable for its known wastewater discharges and help to protect nearby communities from further PFAS contamination.
Sincerely,
Arizona AFL-CIO
Bend the Curve
Center for Public Environment Oversight
CHIPS Communities United
Citizens for Smart Growth
Clean Water Action / Clean Water Fund
Organized Power In Numbers
Sierra Club Grand Canyon Chapter
Tonatierra
Tucson’s Environmental Justice Task Force
UNCAGE, United Chips Against Global Exploitation
[1] EPA, “Our Current Understanding of the Human Health and Environmental Risks of PFAS”,
https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks
[2] CDC, “How PFAS Impacts Your Health”, https://www.atsdr.cdc.gov/pfas/about/health-effects.html?CDC_AAref_Val=https://www.atsdr.cdc.gov/pfas/health-effects/index.html
[3] Intel, “Explore Intel: Ocotillo”, https://www.exploreintel.com/ocotillo
[4] EPA, Addressing PFAS Discharges in NPDES Permits and Through the Pretreatment Program and Monitoring Programs (Dec. 5, 2022), https://www.epa.gov/system/files/documents/2022-12/NPDES_PFAS_State%20Memo_December_2022.pdf
[5] U.S. Department of Defense-funded PFAS demo projects show promise for remediation and destruction (A. Reese, Waste Dive, Dec. 1, 2025) https://www.wastedive.com/news/dod-pfas-destruction-disposal-demos-waste/805991/
Competition to destroy ‘forever chemicals’ heats up (B. Erikson, Chem & Eng, News, Mar. 4, 2024) https://cen.acs.org/environment/persistent-pollutants/Competition-destroy-forever-chemicals-heats/102/i7
