18 July, 2005
Washington State Department of Ecology
Judy Schweiters, Industrial Section
P.O. Box 47706
Olympia, WA 98504-7600
Dear Ms Schweiters:
Thank you for allowing me to comment on the Intalco NPDES permit. I appreciate all of the hard work and time you and your colleagues put into the permit and into interfacing with the public to ensure that our concerns were answered during the comment period. Please note that our comments will be submitted in two parts: in addition to this letter, our legal counsel, Rick Poulin of Smith and Lowney, will be submitting comments on our behalf.
I also commend Ecology for bringing the herring bioassay to fruition. I believe this new test will help us all answer lingering questions about the impact of these industrial discharges on the Cherry Point herring stock, and will help us direct our energies to better protecting water quality.
I am also pleased with the implementation of action levels at the secondary treatment plant and stormwater pond. Writing this kind of oversight into the permit can help reduce pollution, and I hope that it proves to be effective.
That said, I also believe, that the draft permit is not as protective of our marine waters as it should be. My comments and concerns are found below:
Effluent Limits Permit Page 9-14:
Effluent Limits and Production: Fact Sheet Page 18, 19. According to the Fact Sheet and to an e-mail received from Ecology on 6-15-05, the limits for B(a)P, nickel, antimony, TSS, and aluminum limits are based on production. The production level that has been used is full production. It appears unlikely that Intalco will be at full production based on the fact that energy costs are high, Intalco is now operating at only 30%, and Intalco has requested a reduction in treatment efficiency when its workforce is less than 400. An article related to the high cost of energy and Intalco's usage is attached to these comments. This article underscores the doubt regarding Intalco's ability to reach and to remain in full production. It would be appropriate to have two or three sets of limits for the B(a)P, nickel, antimony, TSS, and aluminum, based on the actual production of aluminum. It is understood that the landfill leachate would be a constant regardless of production and that contribution from that source would have to be figured separately. We request that a strategy be implemented whereby limits vary with 33, 67, and 100% productivity. Additionally, why aren't fluoride limits also based on production (was this an oversight in the clarifying e-mail of 6-15-05)?
Allowing the removal efficiency of TSS and BOD to be 55%, when less than 400 persons are employed, is a weakening of the standards and should not be allowed.
Surface water quality criteria: Fact Sheet Page 25-28. A brief literature review has shown places where applicable standards are more stringent than those used or have applicable standards where none are used by the State of Washington. According to the EPA's National Recommended Water Quality Criteria: 2002, the recommended water quality criteria for protection of health should be 0.018ug/L not 0.031 ug/L for the following compounds: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k) fluoranthene, and chrysene. Please instate these more stringent limits to be protective of human health.
Values for many PAHs toxic to marine life have not been established for water quality criteria. The Canadian government has put forth extensive analysis and research into appropriate levels for some compounds in regard to aquatic life. The PAHs for which the Canadian government has set limits and where Intalco's effluent concentration exceeds those standards are as follows: benzo (a) pyrene (limit set at 0.01 ug/L; concentration <1ug/L), chrysene (limit set at 0.1 ug/L; concentration 0.4 ug/L). The Canadian government has also established a limit for fluoride of 1.5 mg/L based on human health and the fact that fish bioaccumulate fluoride. Excerpts from the Canadian government web page are included as an Appendix to these comments. It should also be noted that the Great Lakes Science Advisory Board also recommends 0.01 ug/L limit for aquatic life for benzo (a) pyrene. Please instate these more stringent limits and limits where they apply for water quality criteria.
In order to be in compliance with the surface water quality standard, "no toxics in toxic amounts", the chronic toxicity at Outfall 002 must be addressed. It is of grave concern that concentrations of pollutants within the effluent limits exhibit toxicity. The effluent limits allowed at Outfall 002 are too high. Working in conjunction with Intalco and implementing BMP's, effluent concentrations should be decreasing, and the actual limits should be reduced as well. A diligent practice of BMP implementation should reduce the toxicity of Outfall 002. In the event that this does not result in a decrease of toxicity, then further action must be taken. We request that Ecology put a re-opener clause into the permit if toxicity at Outfall 002 is not eliminated by the practice of BMPs. Under the re-opener, Ecology would set numerical effluent limits for Outfall 002 to ensure that this effluent is no longer toxic to marine organism. It is not a satisfactory outcome to test and retest organisms under a WET test regime, with no actual change in the effluent concentrations at the end of the pipe.
Monitoring Reductions: Permit Page 9-14, Fact Sheet Appendix O.
For nearly every parameter that has monitoring requirements, there has been a reduction in monitoring frequency. For some parameters, the reduction is quite large, going from as much as once a week to once per year! In some cases, Ecology has gone beyond what EPA recommended in its April 1996 guidance. Specifically, these additional reductions are seen at Outfall 001 for fluoride, copper, free cyanide, benzo(a)pyrene (B(a)P), oil & grease, and at Outfall 002 for fluoride, aluminum, and oil & grease. We request that you definitely do not reduce monitoring frequency beyond what EPA recommends, and that you do not reduce monitoring for B(a)P at Outfall 001 at all.
Fact Sheet Page 23, 41: B(a)P monitoring reduction. The detection limit of B(a)P is set at 0.001mg/ L (page 55, Permit). From the permit writer's handbook, it looks like this can be lowered one order of magnitude (The MDL is 0.023 ug/L and usually the PQL is 5x that amount or, in this case, 0.00015 mg/L) To get more meaningful data, this should be done. Since B(a)P is a known contaminant with a known source, and guidance states that monthly monitoring should be used given its concentration, please continue to require monthly monitoring at Outfall 001.
Fact Sheet Page 24: Cyanide Monitoring Reduction. Reduction in monitoring for cyanide should not be allowed. If there were a break in the triple lined landfill system, it would not be detected for as much as one year, under the current draft. Monitoring should be reinstated to twice a month, less frequent than the previous weekly monitoring, but not as infrequent as annual monitoring.
Outfall 001. Page 9. Permit Fact Sheet Page 22:
TSS Concentration Limit. The concentration limit should not be eliminated. According to the permit writer's manual, " In the absence of a concentration limit, a permittee would be able to increase its effluent concentration (i.e. reduce its level of treatment) during low flow periods and still meet its mass-based effluent limits."
In addition, the fact that the effluent regime at Outfall 001 will soon be affected by the addition of stormwater and the reclamation of PUD water for the Cogen facility may make the concentration limit more relevant and it may add more information than it does at present. Given these changing situations, the concentration limit may need to be revisited in the future, but it should not be eliminated.
Permit. Page 11, 28-34. Fact Sheet Page 21, 34:
Stormwater Allocation. By allowing the SAME amount of pollution to be discharged into Outfall 001 as was discharged into Outfall 002, and by not addressing the issue of toxicity at Outfall 002 by lowering the allowable amount of pollutants, Ecology is sanctioning dilution as an answer to pollution. Further, on page 34 of the Fact Sheet, it is stated "Ecology agrees that the best way to eliminate the toxicity from the Outfall 002 discharge is to redirect the stormwater Discharge at Outfall 002 into Outfall 001." This is unacceptable and constitutes backsliding. After Outfall 001 and Outfall 002 are commingled, it appears that there will be no incentive for Intalco to decrease the pollutant load from stormwater because Outfall 001 is sufficiently dilute to mask the toxin load. Prior to commingling, sampling, acute and chronic tests should still be required on the industrial stormwater fraction, and this should be the compliance point for the stormwater fraction of the effluent. The commingled effluent should also be subject to mass limits in addition to concentration limits and, of course, sampling, and acute and chronic tests.
Permit. Page 13, 14. Fact Sheet Page 9: Outfall 001
Sanitary discharge. A reduction in treatment efficiency for TSS and BOD removal from 65 to 55% from the sanitary lagoon, based on number of employees, should not be allowed. This reduction appears to constitute backsliding.
Permit Page 15. Fact Sheet Page 10:
Outfalls 011 and 012. There are no limits for Outfalls 011 and 012, nor does there appear to be any data in the fact sheet or permit about these outfalls. Please provide data for these outfalls. Implementation of BMPs is not sufficient to correct the problem of pollution. BMPs must be coupled with sampling and specified limits. Ecology needs to specify the limits of TSS, Al, and Fl that would represent a successful BMP strategy and must outline the conditions where a reduction in sampling strategy would be allowed. Reduction of this monitoring should not be allowed unless it can be shown that the source has been controlled, BMPs are established and will be ongoing, and the concentrations of TSS, fluoride, and aluminum are well within limits. Elimination of monitoring should not be allowed unless it can be shown that the source has been eliminated.
Permit Page 16.
Stormwater Pond Discharge: Given the toxicity at Outfall 002, I am curious if the action levels of TSS, Al, Fl are low enough. In a comparison of pollutant concentrations and toxicity from the WET tests, are these levels comparable to the LOEC or NOEC? They should definitely not be any greater.
Permit Page 16. Fact Sheet Page 9. Outfall 002.
The stormwater pond design. The pond used by Intalcodoes not appear to be AKART, because, according to our calculations, it does not meet the standards outlined in the Western Washington Stormwater Manual. The permit does not provide for treatment of the 91st percentile of runoff volume for a 24 hour period. Using the WWHM continuous flow model the volume of the stormwater treatment pond should be 24 acre-feet. This calculation was made assuming a developed unmitigated area of 200 impervious acres of roof and roadway (Intalco Works Stormwater Runoff Study Site Hydrologic Characterization, pg. 7 p6). The volume of the settling pond is 5.68 acre-feet, 4.2 times smaller than required. Given that stormwater is the largest cause of toxicity at Intalco, it is imperative that the stormwater pond be designed adequately. We request that a reassessment of the stormwater capacity be conducted, in accordance with what is now considered to be AKART as shown is the recent manual.
Certainly, under state law, Intalco should not be granted a mixing zone unless they employ AKART. This constitutes a major flaw in this permit.
Stormwater for industrial facilities should be treated in a manner consistent with the Industrial Stormwater General Permit. The General Permit requires that there be a Stormwater Pollution Prevention Plan (SWPPP) that can be reviewed by the public, and is subject to public comment. This is important because it is in the SWPPP where the best management practices intended to meet AKART are identified. And the General Permit requires (in section S 9.A.5) that industrial facilities either comply with the most recent version of the Western Washington Stormwater Management Manual (WWSMM) or demonstrate that their method of controlling stormwater runoff pollution provide equivalent protection to what is required in the WWSMM the when they update their SWPPPs.
Further, WAC 173-201A-400(10)(c), states:
"All mixing zones for storm water discharges shall be based on a volume of runoff corresponding to a design storm approved by the department." This reference to "a design storm approved by the department" must be taken to mean the design storm designated in the WWSMM.”
Permit Page 16. Fact Sheet Page 11:
Diversion of water. For pollutants that are measured in mg/ L, there should be a period of more frequent monitoring (2-4 times more frequent) after diversion, to characterize the compounds under the different regime. Reevaluation of the effluent may be necessary if toxins are near or above their respective limits.
Permit Page 18. Fact Sheet Page 28-30:
Mixing Zones. The acute and chronic dilution factors have changed, per the 1998 to the 2005 permit fact sheets, allowing a larger chronic dilution factor.
OLD NEW
Outfall 1 Acute 50 40
Outfall 1 Chronic 60 190
Outfall 2 Acute 8 5
Outfall 2 Chronic 24 50
The temperature analysis under the old dilution factor shows that there would be a temperature violation at the critical condition. Please note that the old permit did not have a limit, but should have. In addition, it is not clear that the newly modeled dilution factors are preferable to the old ones, and it is certain that they are less conservative and protective. Please explain why these values are more accurate than the old ones. For the model, please explain which values were used in the old versus the new model, where they came from, and why the new values should be used. As well, we recommend that Ecology re-explore these factors to ensure that they do not result in violations, such as the temperature criteria noted above.
Permit Page 39. Fact Sheet Page 9:
Anode contact cooling water. A mixing zone should not be allowed for contaminants from the anode contact cooling water because it is not apparent that treatment from the anode is AKART. Additionally, contaminants from the anode are persistent bioaccumulative toxins, such as benzo (a) pyrene, as well as other PAHs, nickel, and antimony. Some of these have been shown to adversely affect herring.
Trace PAHs (benzo (a) anthracene, benzo (a) pyrene, 3,4- benzofluoranthene, benzo (ghi) perylene, benzo (k) fluoranthene, chrysene, fluoranthene, indeno (1,2,3-cd) pyrene, and pyrene) have been found in the priority pollutant scan and in other sampling. Sediment sampling (page 37 of the Fact Sheet) found that PAH's exceeded the SQS and CSL at both outfalls. Given that the anode contact water discharges PAH's that are persistent bioaccumulative toxins, are known to affect living organisms, including herring, at very low levels, and may be above the SQS and CSL at the Outfalls, the discharge of these PAH's must be stopped. Since it is not known whether treatment of the anode contact water is AKART, a mixing zone should be disallowed for all PAHs, nickel, and antimony.
Note, that without a mixing zone, the effluent concentration of the following PAHs (likely to be in the anode contact water) will exceed the value for human health: benzo(a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (k) fluoranthene, chrysene, indeno (1,2,3- c,d) pyrene, and nickel.
Permit Page 40. Fact Sheet Page 28, 37:
Sediment Monitoring. It is not clear why a re-characterization study of sediments is needed. Timing the cleanup to take place after the beach landfills are completed appears to be fairly unimportant unless it is fairly certain that the source of much of the contamination is in those landfills. Please address.
Intalco should be required to conduct a clean up, and conduct sampling as part of the remediation plan, if additional information is needed. It is known that toxics in sediments are absorbed by benthic feeders and can be translated up the food chain. Bioassay results indicate only that the sediment samples were not toxic-- for a specific endpoint, for a specific test, for a specific organism, not that there are no adverse ecological effects.
No mention has been made as to whether there are ongoing discharges of these toxics. Any ongoing discharge of these (PAHs, PCBs, hexachlorobenzene, bis (2-ethylyhexyl) phthalate, dibenzofuran, and phenol) should be halted as part of source control measures because these sediments are on the 303 (d) list.
BMPS to alleviate stormwater toxicity Page 41-42, Appendix B:
Best Management Practices. Much of the toxicity at Outfall 002 will be reduced through the practice of BMPs at Outfall 002. For this reason, it is imperative that these BMPs be well-implemented. Items on the Appendix B list also do not have a deadline. Are all of the procedures and new protocols in place, are they due in two months or in a year from now? Please ensure that items on this list are completed in a timely manner. For items #32 and 33, we request weekly cleaning of each potline, stormwater ditch, and baghouse center. When I was out on the pier last, I noted that alumina dusted the pier fairly heavily in places, and that there were small holes in the pier grating. A vacuum regime would help eliminate some pollution here. Additional sweeping or vacuuming should be done in and around the pier and the silo storage area.
Fact Sheet Page 34: TI/RE Study. BMPs have been in place since June 2000 to address toxicity issues at Outfall 002. Since that time, there have been 3 acute toxicity failures and 5 chronic toxicity failures. It is not clear whether BMPs, as practiced, will lower toxicity at Outfall 002. Intalco has also been in varying stages of production since 2000, so it is not known how much production factors into toxicity. It would be useful for Ecology to analyze the variables of productivity, BMP implementation, toxicity, and aluminum, TSS, and fluoride concentrations, in order to gauge whether BMPs can actually reduce toxicity and the amount of toxins at Outfall 002.
Permit Page 44. Fact Sheet Page 38:
Ground Water. Given that fluoride, arsenic, and benzo(a)pyrene exceed the ground water quality standards, and that the stormwater pond and sanitary lagoons have native clay bottoms, it seems the ground water impact study should happen sooner rather than later. Specifically, the study of the stormwater pond should occur within the first 18 to 24 months of the permit. For the stormwater pond to be considered AKART, should it be lined? Please address.
Fact Sheet Page 37:
Fugitive Alumina Impact Study: The complaint regarding discharge of alumina during offloading was made in August 2003, nearly two years ago. In the Fact Sheet, it is stated that " Ecology is planning to issue an order under their air and water quality authorities…", but with no specific timeline. Ecology must adhere to a timeline. Far too much time has passed to not have addressed this concern. We request that Ecology issue an order within the next three months, and that Intalco complete the study within one year.
Appendix K Fact Sheet:
Reasonable Potential to Exceed Calculations: It has been noted that there are a fair number of "undetermined" determinations. In these cases, it appears that the water quality criteria is MUCH less than the detection limit and/ or the maximum concentration at the edge of the mixing zone. For many of these chemicals, it has been explained that they were actually not detected and are not expected to be in Intalco's effluent. For each undetermined finding, please annotate and verify that the chemical is not reasonably expected to be in Intalco's effluent. Additionally, the herbicides and/ or pesticides that Intalco uses for maintenance of grounds, potline ditches, etc have not been explicitly named. Please verify what these chemicals are and that they do not pose a problem in the Outfall.
In addition, the heading of "maximum concentration at edge of chronic mixing zone" used in the two Appendix K spreadsheets are very misleading. I understand that the formulas are different. Either the "maximum concentration at edge of chronic mixing zone" is a theoretical concentration or it is not. If it is, as it appears, a theoretical concentration, then Ecology should not be presenting two different models, and two different theoretical concentrations given the same verifiable parameters. The most conservative model should be used.
Once again, thank you for your hard work on this permit and for the opportunity to comment.
Sincerely,
Wendy Steffensen
North Sound Baykeeper
Enclosures
Attachments:
From Canadian government website:
http://wlapwww.gov.bc.ca/wat/wq/BCguidelines/fluoride/index.html
FLUORIDE
Recommended Criteria: Marine
The total fluoride concentration of marine waters should not exceed 1.5 mg/L (Anon, 1973; and Anon, 1968).
Rationale: Marine
The natural fluoride level in unpolluted open ocean water is in the 1.3 to 1.4 mg/L range (McNeeley et al., 1979; Benefield et al., 1982; Bewers, 1971; and Warner et al., 1975). In estuarine areas, the levels are usually lower due to dilution by fresh water unless fluoride pollution occurs upstream. Marine organisms accumulate fluoride even at ambient ocean levels and accumulation rises markedly if higher fluoride levels are present. Biomagnification also occurs as fluoride moves up the food chain, at about 1 order of magnitude per level (Stewart et al., 1974). Estimated safe levels of fluoride in the diet of man, based on blood plasma levels, are 0.053 to 0.076 mg/kg (Rose and Marier, 1977). Based on this intake level, approximately 70 mussels would contribute the full daily fluoride intake limit for man if they were grown in normal seawater with fluoride levels of 1.3 mg/L (Barbaro, 1981).
Mullet living in normal seawater had measured fluoride levels of 1.8 mg/kg wet weight in muscle tissue; levels in other tissues were an order of magnitude higher (Milhaud et al., 1981). At this level, a 70 kg man could get his full daily fluoride limit from as little as 2 kg of fish. Blue crab muscle tissue may reach 2.5 mg/kg wet weight of fluoride when the water does not exceed a normal 1.5 mg/L F. At this level, daily intake of about 1.5 kg of crab meat would meet the dietary fluoride limit or 2.0 kg of crab meat would meet the total fluoride limit from all sources.
A 100 kg seal eats about 3 kg of fish per day (a 600 kg steller sea-lion about 15 kg per day). At the upper safe limit of 0.076 mg/kg of fluoride (Rose and Marier, 1977), this works out to (100 x 0.076)/3=2.5 mg/kg fluoride in the fish. The mean fluoride level in the fish tissues consumed by seals and sea-lions is in excess of 2.5 mg/kg when the fish are grown in open, unpolluted seawater. For high energy-using predators like eagles, which also live on fish, the problem is even more acute. There is no extra capacity for seawater to accept additional fluoride. For marine and estuarine environments, "there is evidence that fluorides are accumulative in organisms. It is tentatively suggested that allowable levels should not exceed those for drinking water" (Anon, 1968).
From Candian government website: www.gov.bc.ca/wat/wq/Bcguidelines/pahs
Among PAHs studied, B(a) P was found to be the most toxic. Five percent of sand sole eggs exposed to 0.1 ug/L B(a)P in water (as compared to 0% in control fish) showed gross abnormalities such as overgrowth of tissue originating from the somatic musculature, and arrested development (Hose, et all, 1982). Also, the hatching success of eggs exposed to 0.1 ug/L B (a)P (average = 28.1%; range = 7% to 67.6%) was significantly lower than that of controls (average = 57%; range = 21.6% to 89.6%).
6.9 Criteria from other jurisdictions
There is a growing concern about PAHs due to the toxic and carcinogenic properties of certain of these substances. Concern is also increasing because of the lack of definite environmental information on these compounds despite the advance of detection technology (e.g., GC/MS, HPLC). Thus, while there is a need for established PAH criteria, few agencies have been able to venture forth with any definite quantitative values (Table 25)
From studies conducted in the Great Lakes basin, GLSAB (1983) recommended that levels of B[a]P not exceed 1.0 µg/g in sediment (dw) and organisms (ww) serving as food items for the protection of aquatic life. This report also suggested that levels of B[a]P be less than 0.01 µg/L in the water column.
The USEPA (1980) did not establish PAH criteria for the protection of aquatic life. The criteria recommended by the agency were related to the protection of human health from ingesting contaminated water and contaminated organisms living in it.
Provisional sediment quality objectives for PAHs in Burrard Inlet, British Columbia, were recently published by Nijman and Swain (1990). These objectives were derived from apparent effect threshold (AET; i.e., sediment concentration of a selected chemical above which statistically significant biological effects always occur) values developed for Puget Sound, Washington, generally using an application factor of 0.1. They also took into account values from relatively uncontaminated areas. For most PAHs (except fluorene, dibenzo[a,h]anthracene, and pyrene), the objectives proposed by Nijman and Swain are lower than the ER-L values (i.e., sediment concentration at the low end or the 10th percentile concentration of the range in which effects had been observed) determined by the National Oceanic and Atmospheric Administration (NOAA) (Long and Morgan, 1990).
The interim criteria for PAHs proposed by the Washington Department of Ecology (WDOE - Table 25) are expressed on the basis of organic carbon; hence, as such, they can not be compared with criteria proposed by other jurisdictions. To carry out a comparison with other jurisdictions, the WDOE interim criteria were expressed on a dry weight basis, assuming an organic carbon content of 1.0% for the sediment (conversion factor used is: µg/g oc= 0.01 µg/g dw sediment). The results (not shown) indicated that the WDOE interim criteria (expressed on sediment basis) were up to 9 times higher for some PAHs than the ER-L values determined by NOAA.
Article on energy usage, Intalco, and the Bonneville Power Administration.
JOHN STARK
THE BELLINGHAM HERALD
July 1, 2005
A Bonneville Power Administration plan that would provide less power to Northwest aluminum smelters beginning in fall of 2006 may make it difficult for Alcoa Intalco Works to survive.
"The facility is at considerable risk under this scenario," said Kevin Lowery, Alcoa Inc.'s director of corporate communications at its Pittsburgh headquarters.
The Alcoa Intalco Works smelter west of Ferndale now provides high-wage jobs to 475 workers.
A DECLINING INDUSTRY
• Before 1995, aluminum smelters and other direct service industries got more than 3,000 megawatts of Bonneville Power Administration power.
• That would be almost enough to power three cities the size of Seattle today.
• As the region grew and demand for cheap hydropower increased, BPA gradually cut back its allocation to power-hungry aluminum smelters, and many were forced to shut down.
Lowery said the local smelter already has power costs that are 50 percent higher than the global average in an industry where power costs represent 25 percent of all expenses. Under the plan announced Thursday by BPA administrator Steve Wright, those costs would likely go still higher, Lowery said.
Intalco's current power supply contract with BPA expires Sept. 30, 2006. After that, BPA plans to stop providing any of its low-cost hydroelectric power to Intalco and other direct-service industrial customers, BPA spokesman Mike Hansen said.
Instead, for the five-year period beginning Oct. 1, 2006, BPA will provide a financial subsidy to Intalco and the other direct-service industries.
Hansen explained the deal like this:
# Intalco will purchase its power in the marketplace, and BPA will pay the company to compensate it for some portion of the difference between its market power costs and the lower-cost BPA hydropower.
# The payment will be no more than $12 per megawatt, and will cover no more than 320 megawatts of power purchases for Intalco parent Alcoa. Alcoa officials have said they need 625 megawatts to operate both the Intalco and Wenatchee smelters at capacity.
# BPA will spend no more than $59 million per year on the subsidies to Intalco and other affected industries.
Lowery said the deal isn't as bad as some previous proposals from BPA officials and public power utilities, who would prefer to get as much cheap power as possible for themselves and their ratepayers. But it is nowhere near enough to guarantee the viability of Intalco or another Alcoa smelter in Wenatchee.
Alcoa will do its best to keep its Intalco smelter operating, but if market prices for power are too high and the market prices for aluminum are too low, the Northwest smelters become money-losing propositions, Lowery said.
"If it's not competitive for us to operate a facility based on market conditions, we idle it," Lowery said.
He added that the subsidized limit of 320 megawatts is not enough to operate both Washington state smelters. Taken together, the smelters here and in Wenatchee account for 3,350 direct and indirect jobs, Lowery said.
Hansen said BPA doesn't want the smelters to close, but the agency doesn't have a legal obligation to provide them with power. The more cheap BPA power that goes to Alcoa, the less that is available for the publicly owned utilities that provide electricity to Seattle, Tacoma, Everett and many other places in the Northwest, including Blaine and Sumas. That means higher electric bills for consumers in those places.
The cost of the BPA subsidy to Alcoa and other industries is expected to raise the cost of power to those utilities about $1 a megawatt, Hansen said. At current BPA power rates, that is about 3 percent.
"It's our position that we provide as much of a benefit as we can, to give them (aluminum companies) a shot at operating and maintaining these jobs," Hansen said.
