3/27/13

Steve,

Per earlier discussions regarding the cost effectiveness estimates prepared for LSFO controls 

on Alcoa’s Wenatchee Potline No. 5, please find the estimates that were prepared using 

information that is currently available. The enclosed estimates reflect both the estimate Alcoa 

believes to be the proper cost effectiveness estimate, and the other estimate included herein 

reflects the assumptions and adjustments made by Region 10 to comparable cost effectiveness 

calculations during the Region’s evaluation of the Washington State’s Regional Haze SIP [77 

FR 76190].

If you have any questions after your review of the enclosed estimates, do not hesitate 

contacting me at either of the phone numbers provided below, or via e:mail.

Jimmy Jones

Alcoa Inc.

EHS Services

Phone No. (865)-977-3071

Cell No. (865)-548-8059

Attachments:

4/9/13

Steve,

Thank you for arranging the April 4th conference call to further discuss public 

comments received by EPA regarding Washington Ecology’s determination that the 

Alcoa Wenatchee facility is exempt from BART. We understand that EPA is 

considering whether to disapprove Ecology’s visibility modeling based on the use of 

a refined 500-m modeling grid rather than a 4-km screening grid.

Alcoa fully agrees with Ecology’s determination and believes that refined modeling 

for the Wenatchee facility was appropriate and necessary given the location of the 

facility, and the fact that a 4-km grid spacing does not properly represent the 

complex terrain and regional/local wind patterns.

In follow-up to our conversation, Alcoa plans to conduct no further analysis of 

emission controls, control costs or visibility impacts for Wenatchee until such time 

that EPA proposes and makes a final decision regarding Ecology’s visibility modeling 

for Wenatchee.

As discussed on the call, Alcoa is open to participating in technical discussions with 

EPA and Ecology modeling personnel if EPA seeks to make a more informed 

decision regarding appropriate modeling details for the Wenatchee facility.

Thanks again for arranging the call
Jimmy 

Phone No. (865)-977-3071

Cell No. (865)-548-8059

5/1/13

Steve,

We really don’t understand the EPA’s need for a new potline control cost estimate for 

the Wenatchee Smelter, given the existing quote was adequate for your proposed SIP 

action for Intalco; and given that there would be unnecessary costs for a potential 

vendor’s time and travel to develop a site specific bid specification and cost estimate. 

We acknowledge that the 2006 cost estimates may be “stale,” however, we also 

recognize that the 2006 potline control estimate will likely be lower than any 2013 

estimate. Our thinking is that if EPA bases their decision on the “stale” but lower 

control costs estimate, a more costly estimate in current dollars will only make the 

control costs more costly. This makes the usage of the old cost quote as the basis to 

prove that add-on controls are not cost effective easily justified.

After consulting with the rest of our team, we are willing to contact one of the original 

vendors to see if they are willing to provide us with some non-binding, generalized 

information indicating how much more the estimate for the overall cost of the 2006 

Tennessee control system would have gone up over the last seven years (e.g. 

approximately +% more now than originally quoted). If they are amenable to 

something of this nature, then you could adjust the 2006 costs accordingly.

If you think this approach would get you to where you want to be, let me know.

Jimmy

Phone: 865-977-3071

Cell: 865-548-8059

From: Body, Steve [mailto:Body.Steve@epa.gov] 

Sent: Tuesday, April 30, 2013 2:36 PM

To: Jones, James D.

Subject: EXT: Wenatchee BART

Jimmy... As we begin our BART analysis for the Alcoa Wenatchee Operation, one key 

item will be the cost of LSFO equipment. We feel that the old vendor quotes used for 

Intalco are too stale. I doubt vendors would provide EPA a quote, as we are not 

potential clients.

Is this something Alcoa could ask vendors and provide us the information? 

Steve 
5/13/13

Steve, 

We were informed earlier this morning by the vendor that we contacted in response to EPA’s 

request for updated scrubber cost information, that they had looked at the original proposal and 

concluded that the 2006 indicative proposal cost would have increased by approximately 20 –

25%, if they were to quote the same Tennessee project today. This is their “best guess” based 

on their current pricing and costs.

They explained that it is somewhat difficult for them to reach a firm conclusion on the exact 

amount of the increase because of what has happened since the original quote was prepared.

They indicated that in the latter half of 2006, there was a large and sudden global escalation in 

steel prices driven by demand in the Chinese market. After that run-up, prices receded 

somewhat and then remained flat or have increased slowly. This is relevant because carbon 

and alloy steel comprise a significant portion of a WFGD’s costs. Also, there has been a decline 

in demand for WFGD systems over the past five years and consequently, they don’t have a 

good, recent benchmark to use for comparison.

Today’s information affirmed our earlier belief, that the 2006 potline control estimate is lower 

than a comparable 2013 estimate. Even the “stale” estimate shows that at the substantially 

lower 2006 cost, the installation of a wet scrubber on Potline No. 5 at Wenatchee is not cost 

effective. Please refer to the cost effectiveness estimates that were provided via electronic mail 

to you on March 27. With this current information, it would appear that EPA should be able 

proceed with its analysis using the detailed 2006 information, knowing that using the “stale” 

estimate is justified by the fact that a more recent estimate would only make the outcome even 

less cost effective.

Hopefully this information enables you to move forward with your evaluation and response to 

comments on EPA’s proposed actions relative to the State of Washington’s Regional Haze 

State Implementation Plan.

Jimmy Jones

Alcoa Inc.

EHS Services

Phone No. (865)-977-3071

Cell No. (865)-548-8059