Memo
to
Section
316(
b)
Phase
III
record
Re:
APPA
aerial
photo
of
Midwest
utility
Date:
May
17,
2004
From:
Paul
Shriner
"
Pugh,
Theresa"
<
TPugh@
APPAnet.
or
g>

05/
17/
2004
10:
56
AM
To:
John
Fox/
DC/
USEPA/
US@
EPA
cc:
"
Hyland,
Mike"
<
MHyland@
APPAnet.
org>
Subject:
Picture
tells
a
thousand
words
on
footprint
in
small
utilites
Dear
Mary:

Re:
Phase
III
Cooling
Water
Intake
Structure
Rulemaking
options
I
meant
to
send
you
the
aerial
photo
of
a
Midwestern
town
with
a
small
"
footprint"
to
show
you
how
hemmed
in
we
are
in
terms
of
land
(
and
often
water)
space
surrounding
the
plant.
Most
folks
think
of
large
utilities
with
huge
"
buffer
zones".
Our
folks
are
very
different
indeed.

You
asked
for
this
after
the
April
6th
conference
call
looking
at
Phase
III
issues.
I
am
sorry
that
I
neglected
to
do
this
immediately.
This
one
does
not
have
a
CWIS
but
I
am
trying
to
find
one
for
you
with
the
CWIS.
(
They
don't
typically
send
me
the
photo
of
the
water
because
it
is
the
land
footprint
or
access
that
dictates
often
the
ability
to
retrofit
at
the
facility).
As
you
can
see
the
plant
is
surrounded
by
smaller
industrial
or
commercial
buildings
and
it
appears
a
few
residential
houses.

Due
to
DHS
security
policy,
I
cannot
send
you
an
aerial
map
with
the
name
of
the
town.
But
it
is
a
small
utility
in
the
upper
Midwest.
I
can
tell
you
over
the
phone
if
you
like.
I
assume
that
you'd
want
to
put
this
in
the
Phase
III
docket.

There
is
an
aerial
photo
of
a
New
York
state
with
a
CWIS
that
I
will
try
to
get
to
you
shortly.
That
aerial
makes
a
great
point
because
the
plant
is
surrounded
by
a
highway,
bluff,
commercial/
industrial
area,
and
riverfront.

Thank
you
for
considering
this
issue,

Theresa
<<
Picture
to
go
with
comments.
doc>>
