From: "Cain, Randy D." <RCAIN2@alleghenyenergy.com> 

 

 To: Jezebele Alicea/DC/USEPA/US@EPA 

 Cc: "Cannon, William E." <WCANNON@alleghenyenergy.com>, "Lapcevic, Joseph P." 

<JLAPCEV@alleghenyenergy.com> 

 

 Date: 07/06/2010 11:42 AM 

 Subject: Steam Electric Power Generating ICR - Rivesville Power Station (00997) - Extension Request 

July 6, 2010

Jezebele Alicea

USEPA

1200 Pennsylvania Avenue, NW

Mail Code: 4303T
Washington, DC 20460

RE: Questionnaire for the Steam Electric Power Generating Effluent

Guidelines

 Allegheny Energy

 Rivesville Power Station – Plant ID 00997

Dear Ms. Alicea:

Allegheny Energy’s Rivesville 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 1) and believe its breadth and depth of

information require more time to complete. In accord with the

instructions on the EPA cover letter, Allegheny Energy respectfully

requests an additional 30 days to provide responses.

There are three reasons for this time extension request.

First, Rivesville Power Station has been running very little because of

its position on the PJM dispatch curve, but is being maintained for

reserve capacity. As a result, staffing at the station has been reduced

to an absolute minimal three member staff (when necessary, employees

from a nearby Allegheny Energy station work at Rivesville). This

reduced staffing significantly hampers our ability to respond in the

time frame provided, particularly since Rivesville has been chosen to

complete the full ICR including Part G sampling.

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 Energy 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 Tailoring Rule), along 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