_____________________________________________________________________________________________
Science
Applications
International
Corporation,
11251
Roger
Bacon
Drive,
Reston,
VA
20190
MEMORANDUM
To:
Paul
Shriner,
Shari
Goodwin,
and
Regno
Arulgnanendran
From:
John
Sunda
Date:
September
28,
2005
Subject:
Downtime
Duration
Input
and
Analysis
of
Manufacturing
Facilities
Introduction
As
part
of
the
review
of
downtime
durations
for
Phase
III
manufacturing
facilities,
EPA
evaluated
the
methodology
used
for
estimating
downtime
durations
at
Proposal.
The
methodology
used
at
Proposal
is
similar
to
the
one
used
in
the
Phase
II
rulemaking
for
electric
generators.
For
the
NODA,
EPA
initially
considered
the
reduction
of
downtime
durations
by
using
various
fractions
or
percentages
in
downtime
duration
used
at
Proposal
and
analyze
the
sensitivity
of
such
reductions
on
the
downtime
costs.
EPA
then
reviewed
in
detail
the
basis
for
the
downtime
duration
estimates
originally
developed
for
electric
generators
to
determine
whether
these
estimates
were
appropriate
for
manufacturing
facilities
and
whether
the
downtime
estimates
could
be
revised
to
reflect
site­
specific
features
applicable
to
manufacturers.

Differences
in
Downtime
Duration
Between
Phase
II
Electric
Generators
and
Phase
III
Manufacturing
Facilities
The
methodology
used
in
the
Phase
II
economic
analysis
for
incorporating
the
costs
associated
with
downtime
for
the
intakes
during
construction
assumed
that
only
a
few
facilities
had
an
alternative
to
shutting
down.
For
electric
generators
that
utilize
a
once­
through
cooling
system,
the
use
of
cooling
water
is
an
integral
part
of
the
entire
electricity
generation
process
and
therefore
any
reduction
in
water
use
will
result
in
a
reduction
in
power
generation.
Because
power
plants
essentially
rely
on
a
single
process,
a
shutdown
of
the
entire
process
is
the
most
logical
solution
when
the
need
arises
to
perform
major
construction
or
maintenance
operations
on
any
key
component
of
the
facility.
EPA
found
that
most
power
plants
shut
down
for
about
four
weeks
each
year
to
perform
routine
maintenance.
This
provides
a
window
of
opportunity
for
performing
modifications
on
the
intakes
simultaneously
during
the
shut
down
period
for
routine
maintenance.
Because
routine
plant
shutdown
for
several
weeks
was
common
for
power
plants,
the
cost
module
technology
scenarios
derived
for
Phase
II
electric
generators
focused
on
retaining
the
use
of
the
existing
pumping
equipment.
_____________________________________________________________________________________________
Science
Applications
International
Corporation,
11251
Roger
Bacon
Drive,
Reston,
VA
20190
Unlike
electric
generators,
manufacturing
facilities
typically
involve
numerous
sequential
processes
with
varying
water
requirements
for
the
processes
and
in
many
cases,
additional
water
requirements
for
plant
electric
power
and
steam
generation.
Many
large
manufacturing
facilities
not
only
have
multiple
types
of
processes,
but
also
have
multiple
parallel
process
trains.
Maintenance
operations
for
the
more
complex
operations
may
involve
the
shutdown
of
individual
process
trains
or
series
of
trains,
but
this
leaves
the
remainder
of
the
plant
in
operation.
The
sequential
processes
often
have
storage
capacity
for
the
intermediate
products.
The
ability
to
store
intermediate
product
facilitates
this
practice.
As
such,
the
need
for
electricity
and
process
steam
tends
to
be
continuous.
Because
of
the
wide
variety
of
process
arrangements
at
different
manufacturing
facilities,
there
is
the
potential
for
wide
variations
in
the
frequency
and
duration
of
whole
facility
shutdowns
between
the
various
manufacturing
sectors.
It
appears
that
the
larger,
more
complex
manufacturing
operations,
unlike
electric
generators,
are
less
likely
to
schedule
simultaneous
annual
shutdown
of
all
processing
units.

Input
from
Manufacturing
Facilities
In
order
to
determine
what
response
a
Phase
III
manufacturing
facility
would
have
if
faced
with
the
potential
interruption
of
intake
operations
to
implement
major
construction
or
retrofit
of
their
intakes,
six
manufacturing
facilities
were
contacted
in
August
2005.
The
objective
was
to
inquire
about
the
practices­
in­
place
at
these
facilities
and
the
measures
they
would
implement
to
minimize
interruption
of
the
manufacturing
processes
associated
with
major
construction
or
retrofitting
of
their
intakes.

The
inquiry
included
questions
about
the
occurrence
of
scheduled
plant
shut
downs
in
the
past,
modifications
of
plant
operations
to
reduce
water
use,
use
of
alternate
intakes
or
other
sources
of
cooling
water,
availability
of
alternate
power
sources
if
most
cooling
water
is
used
for
power
generation,
and
details
of
implementing
major
construction
or
rehabilitation
on
intakes.

Table
1
provides
a
summary
of
the
results
of
the
above
inquiry
along
with
the
facility
SIC
code.
Information
obtained
previously
from
two
additional
manufacturing
facilities
(
DOW
Chemical
Co.,
Freeport,
TX
and
Tosco
Refining
Co.,
Rodeo,
CA)
are
also
included
in
Table
1,
along
with
information
obtained
from
an
intake
technology
vendor.

In
general,
the
reported
plant
shutdown
periods
ranged
from
zero
downtime
for
many
chemical
manufacturers
to
30
to
50
days
for
refineries.
However,
the
refinery
downtime
occurred
less
frequently
than
shutdown
for
other
manufacturing
sectors
with
shutdowns
occurring
once
every
four
or
six
years
compared
to
an
annual
shutdown
for
other
manufacturing
sectors.
One
refinery
operator
indicated
that
no
downtime
has
been
scheduled
in
the
past.
However,
the
refineries
contacted
had
flexible
intake
arrangements
that
would
allow
major
construction
to
be
carried
out
without
incurring
any
additional
unscheduled
downtime.

The
chemical
manufacturers
reported
that
a
complete
shut
down
of
the
entire
plant
was
rare
because
these
facilities
provided
water
to
a
variety
of
operations
and
hence
shutting
down
the
intakes
completely
would
be
highly
problematic.
None
of
the
operators
would
speculate
on
a
potential
solution
but
suggested
that
an
engineering
solution,
such
as
installation
of
an
entirely
_____________________________________________________________________________________________
Science
Applications
International
Corporation,
11251
Roger
Bacon
Drive,
Reston,
VA
20190
new
intake
adjacent
to
the
existing
intake,
may
be
sought
to
minimize
the
duration
of
the
downtime.

The
fact
that
some
facilities
would
consider
an
engineering
solution
instead
of
a
complete
shutdown
implies
that
an
engineering
solution
would
probably
cost
less
than
shutting
down
the
plant
for
an
extended
period.
Praxair,
an
industrial
gas
manufacturing
plant,
reported
an
annual
shut
down
for
one
week,
but
because
the
intake
pumps
withdrew
water
from
a
common
channel,
the
facility
did
not
have
the
flexibility
reported
by
the
refineries.
The
Praxair
facility
also
has
a
contract
to
supply
intake
water
to
adjacent
industrial
facilities.
As
such,
chemical
manufacturers
similar
to
Praxair
with
limited
flexibility
for
plant
shutdown
may
opt
for
an
engineering
solution,
if
faced
with
potential
interruption
of
intake
operations,
instead
of
a
complete
shut
down
of
their
plant
operations.

Options
and
Alternatives
A
solution
for
a
larger
intake
using
technology
module
3
(
Addition
of
a
new,
larger
intake
with
fine­
mesh
and
fish
handling
and
return
system
in
front
of
an
existing
intake
system)
considered
under
Phase
II
for
electric
generators,
was
to
add
additional
intake
capacity
adjacent
to
the
existing
intake.
This
would
have
required
the
addition
of
new
pumps
and
the
necessity
to
devise
a
way
to
reduce
the
flow
in
the
old
pumps,
such
as
retrofitting
the
old
pumps
with
variable
frequency
drives
so
that
flow
in
each
intake
could
be
reduced.
This
scenario
would
substantially
reduce
the
downtime
requirements
because
each
pump
could
be
retrofitted
independently
and
the
new
adjacent
intake
could
be
constructed
while
the
existing
intakes
continue
to
operate.
Only
the
construction
step
of
tying
the
new
intake
piping
into
the
existing
piping
would
potentially
involve
brief
downtime
duration.
However,
many
electric
generators
are
located
in
close
proximity
to
urban
areas
with
limited
available
space
in
the
vicinity
of
the
existing
intakes.
Hence
the
construction
scenarios
for
the
technology
to
enlarge
the
total
screen
area
involved
constructing
and
connecting
the
new
intake
technology
directly
in
front
of
the
existing
screens
rather
than
adding
additional
intake
capacity
adjacent
to
the
existing
intake
as
described
above
for
electric
generators.
This
configuration
inevitably
results
in
the
need
to
shut
down
the
entire
intake
for
a
period
of
several
weeks
or
more
to
make
the
final
connection.

In
contrast
to
electric
generators,
large
manufacturing
plants
tend
to
be
expansive
and
such
facilities
may
have
available
space
for
alternative
technology
installation
practices.
For
a
Phase
III
manufacturing
facility,
depending
on
the
site­
specific
conditions,
an
approach
to
retrofit
independently
with
a
new
adjacent
intake
being
constructed
while
the
existing
intakes
continue
to
operate
could
potentially
result
in
similar
or
even
lower
downtime
costs
compared
to
the
total
costs
incurred
for
Phase
II
electric
generating
facilities.
For
certain
sectors
of
manufacturing
facilities
which
do
not
have
scheduled
shutdowns
for
routine
maintenance
and
consequently
may
incur
higher
shutdown
costs,
alternative
technology
scenarios
that
include
additions
and
or
modifications
to
the
existing
pumps
may
prove
to
be
less
costly.

In
the
case
of
a
refinery,
EPA
has
found
that
one
facility
was
able
to
install
the
equivalent
of
technology
module
4
(
Addition
of
passive
fine­
mesh
screen
system
(
cylindrical
wedgewire)
near
shoreline
with
mesh
width
of
1.75
mm)
with
no
downtime
by
connecting
the
new
passive
screens
to
each
pump
one
at
a
time.
_____________________________________________________________________________________________

Science
Applications
International
Corporation,
11251
Roger
Bacon
Drive,
Reston,
VA
20190
TABLE
1.
RESULTS
OF
FACILITY
CONTACTS
CONCERNING
DOWNTIME
DURATION
AND
ALTERNATE
SOLUTIONS
Facility
Name
and
Location
SIC
Codes
Downtime
Frequency
Downtime
Duration
Other
Solutions
Comments
BP
Refinery,
Toledo,
OH
2911
Once
every
4­
6
years
40­
50
days
Two
intake
channels
can
be
retrofitted
independently
with
no
downtime.
Would
modify
water
use
for
third
smaller
intake.

DOW
Chemical
Co.

(
Formerly
Union
Carbide)­

Taft
Plant,
Hahnville,
LA
2869
None
NA
Would
use
an
engineering
solution.

No
details
of
potential
solutions
or
costs
were
given.

PPG,
Lake
Charles,
LA
2812
2869
2816
None
NA
Have
multiple
pump/
screen
channels
and
can
work
on
them
independently.
Can
shut
down
intakes
RS2
&
RS3
but
shutdown
of
intakes
CRW1
&
CRW2
would
require
shutdown
of
Chlorine­
Alkali
manufacturing
units
resulting
in
$
2M
lost
revenue/
day.
Adding
a
new
adjacent
intake
is
a
possible
option.
Note
that
CRW1
&

CRW2
have
the
highest
flow
and
highest
screen
velocities.

Tosco
Refining
Co.,

Bayway,
NJ
2911
Once
every
4
years
30
days
Has
two
intakes,
could
alternate
between
the
two
except
during
summer
months
(
May­
Oct).
Each
intake
has
4
or
5
separate
intake
trains,
which
can
be
modified
independently.

Praxair
Inc,
Niagara
Falls,

NY
2813
Once
a
year
7
days
Pumps
draw
from
common
intake
well.
No
easy
solution.
Also
provides
water
to
neighboring
industries.
In
the
survey
they
indicated
having
3
intake
bays.
They
have
contracted
to
supply
water
to
adjacent
industries.
_____________________________________________________________________________________________

Science
Applications
International
Corporation,
11251
Roger
Bacon
Drive,
Reston,
VA
20190
Facility
Name
and
Location
SIC
Codes
Downtime
Frequency
Downtime
Duration
Other
Solutions
Comments
DOW
Chemical
Co.,

Freeport,
TX
2869
None
NA
Would
use
an
engineering
solution.
Survey
data
suggests
only
saltwater
portion
operates
continuously.

Pfizer,
Groton,
CT
2833
None
NA
Would
consider
reducing
flow
to
<
50
mgd.
Have
only
one
intake­
no
easy
solution.
Have
emergency
generators
to
replace
lost
power
but
would
still
need
steam.

Tosco
Refining
Co.,
Rodeo,

CA
2911
None
scheduled
NA
They
were
able
to
install
new
Tscreen
intakes
without
downtime.

Johnson
Screens
Intake
(
Technology
Vendor)
NA
NA
NA
In
their
experience,
facilities
with
multiple
intakes
or
multiple
parallel
intake
trains
are
able
to
work
on
a
portion
of
the
intake
system
while
keeping
a
part
of
the
intake
system
still
functioning.
