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 11:42 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: 4303TWashington, 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 lett er, 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 si nce 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 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 regulatoryproposals (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