Memo
to
section
316(
b)
Phase
III
record
Re:
downtime
unlikely
at
large
manufacturer
with
multiple
intakes
Date:
August
12,
2004
From:
Paul
Shriner
Contents
of
original
email
message
For
certain
compliance
technology
options,
EPA
estimates
that
the
intakes
may
need
to
be
shut
down
for
a
period
of
time.
The
survey
indicates
your
facility
normally
operates
24/
7
365
days
per
year.
Does
your
facility
ever
shut
down
for
maintenance
activities
such
that
the
intake(
s)
would
not
be
needed
for
a
period
of
time?
If
so,
how
often
and
for
how
long?
If
you
had
to
shut
down
one
or
more
intakes
for
a
non­
emergency
retrofit
lasting
days
or
weeks,
how
would
you
do
it
in
order
to
minimize
economic
impacts
due
to
lost
production?
Is
the
information
you
provide
unique
to
this
facility
or
is
it
somewhat
representative
of
other
similar
facilities?
Thank
You,
John
Sunda
Science
Applications
International
Corporation
11251
Roger
Bacon
Drive
Reston,
VA
20190
Responses
Q:
Does
your
facility
ever
shut
down
for
maintenance
activities
such
that
the
intake(
s)
would
not
be
needed
for
a
period
of
time?
A:
Our
facility
is
operational
24
hours
a
day,
7
days
a
week.
Only
when
maintenance
is
necessary
do
we
take
a
portion
out
of
service
for
a
very
brief
time.

Q:
If
so,
how
often
and
for
how
long?
A:
We
never
completely
shut
down.

Q:
If
you
had
to
shut
down
one
or
more
intakes
for
a
non­
emergency
retrofit
lasting
days
or
weeks,
how
would
you
do
it
in
order
to
minimize
economic
impacts
due
to
lost
production?
A:
Our
facility
includes
approximately
80
facilities
and
numerous
research
and
development
facilities.
Our
intake
structures
are
equipped
with
multiple
pumps
to
ensure
continuous
operation.
A
retrofit
would
cause
a
significant
interruption
to
our
facilities.
Even
though
we
would
not
shut
down
everything
at
once,
it
would
result
in
a
significant
economic
loss.
We
have
never
shut
down
everything
at
once.
We
would
need
to
engineer
a
solution
to
shut
down
for
a
retrofit,
if
it
were
required.
The
cost
estimate
for
the
engineering
and
resulting
facilities
impact
would
be
part
of
the
engineering
package.
I
would
not
want
to
guess
at
the
cost
without
additional
engineering
studies.

Q:
Is
the
information
you
provide
unique
to
this
facility
or
is
it
somewhat
representative
of
other
similar
facilities?
A:
I
do
not
believe
this
is
unique
to
facilities
of
our
size.
