From: <Alicea.Jezebele@epamail.epa.gov> To: "Cain, Randy D." <RCAIN2@alleghenyenergy.com> Date: 7/21/2010 1:32 PM Subject: Re: Steam Electric Power Generating ICR - R. Paul Smith Power Station (09615) - Extension Request Attachments: pic20189.gif Greetings, EPA has reviewed your extension requ est for the steam electric effluent guidelines questionnaire for the Allegeny Energy R. Paul Smith Power Station. The deadline for your plant to submit Version 2 of the completed questionnaire is extended to October 15, 2010. If you need assistance during the completion of the steam electric questionnaire, please contact the steam electric helpline via e-mail at steamhelp@erg.com or by phone at 1-877-353-7560. Sincerely, (Embedded image moved to file: pic20189.gif)

From: "Cain, Randy D." <RCAIN2@alleghenyenergy.com> To: Jezebele Alicea/DC/USEPA/US@EPA Cc: "Cannon, William E." <WCA NNON@alleghenyenergy.com>, "Lapcevic, Joseph P." <JLAPCEV@alleghenyene rgy.com> Date: 07/06/2010 11:45 AM Subject: Steam Electric Power Generating ICR - R. Paul Smith Power Station (09615) - Extension Request

July 6, 2010

Jezebele Alicea USEPA 1200 Pennsylvania Avenue, NWMail Code: 4303T Washington, DC 20460 RE: Questionnaire for the Steam Electric Power Generating Effluent Guidelines Allegheny Energy R. Paul Smith Station – Plant ID 09615

Dear Ms. Alicea: Allegheny Energy’s R. Paul Smit h Power Station received the EPA Questionnaire for the Steam Electric Power Generating Effluent Guidelines on Friday, June 18, 2010. We have reviewed the ICR questionnaire (Version 2) and believe its breadth and depth of information require more time to complete. In accord with the instructions on the EPA cover lett er, Allegheny Energy respectfully requests an additional 30 days to provide responses. There are three reasons for this time extension request. First, R. Paul Smith Power Station just recently received a draft NPDES permit from MD MDE that is going to public hearing in late July. Preparation for this more immediate public hearing precludes Allegheny Energy and station staff from spending time preparing responses to the ELG ICR. In addition, Allegheny Energy initiated a merger with FirstEnergy of Akron, Ohio, on February 11, 2010. In order to support the merger and thoroughly explore the resulting synergies of the combined company numerous employees of Allegheny Energy were sent to Akron at the end of May for approximately a three month period. This has decreased an already lean staff to continue conducting business as usual in addition to responding to such inquiries as this ICR. Compounding the problem is potential attrition of Allegheny En ergy Corporate Services staff in anticipation of job loss associated with the combination of the two companies. Already, one key engineer that would have extensively worked on the ICR as left the company.Finally, the unprecedented issuance of a number of new regulatory proposals (e.g. CCRs, GHG MRR, GHG Ta iloring Rule), al ong with other ICRs (i.e. HAPs MACT and PCB) by EPA and state regulatory agencies has also added to the difficulty to provide thorough and meaningful responses by our limited staff. An additional 30 days would allow for Allegheny Energy and power station staffs to not only gather the necessary data required to support the ICR, but also would provide time to review the submittal for completeness and consistency. This additional 30 days in the response time will most likely lessen the need for further inquiry by EPA’s contractor (ERG) for purpose of explanation of the responses provided and possibly supplemental information request to aide clarification. Thank you for considering this request. Sincerely, Randy Cain

Randy Cain Environmental Affairs Manager Allegheny Energy 800 Cabin Hill Drive Greensburg, PA 15601 phone: 724-838-6004 fax: 724-830-7711 e-mail: rcain2@alleghenyenergy.com