### steam

_ record - Re: ICR 90 da y Extension Request: R. M. He skett Station, Plant ID: 01194

To: Jezebele Alicea/DC/USEPA/US@EPA From: "Kuether, Kalle" <Kalle.Kuether@mdu.com> Date: 07/08/2010 02:17PM 

### 90 day Extension Request : R. M. Heskett Station, Plant ID: 01194 Attachments: Extension Request.pdf Pa g e 1 of 3

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...cc: "Krebsbach, Abbie" <Abbie.Krebsbach@mdu .com>, "Welte, Alan" <Alan.Welte@mdu.com>, "Stroh, Tony" <Tony.Stroh@mdu.com> Subject: ICR 90 day Extension Request: R. M. Heskett Station, Plant ID: 01194

Dear Ms. Alicea:

Montana-Dakota Utilities, Co. (Montana-Dakota) is requesting a 90 day extension for submittal of the Environmental Protection Agency (EPA) Information Collection Request (ICR ) questionnaire for the Steam Electric Power Generating Effluent Guidelines for R.M. Heskett Station (Heskett), Plant ID 01194.

Heskett is a substantially smaller power plant with only 100 MW. As such, the limited amount of staff at the plant are responsible for multiple operations and functions when com pared to larger power plants where there may actually be one or more dedicated employees for environmental wastewater compliance management. The plant staff that would be heavily involved in completing the ICR are already deeply involved in the day to day operations of the plant.

Under normal operating conditions, Heskett staff would have difficulty completing the ICR in the time specified. However, Heskett Unit 2 is currently in the middle of an unplanned outage to replace a section of high pressure secondary superheater piping and header, making it even less feasible for the plant to compile all the information requested in the ICR in the time specified. The piping was deemed unsafe to put back into service and requires immediate replacement. If all goes well and the piping is installed in the time projected, the unit is expected to be returned to service the first week in August.

Additionally, there is also a major Unit 1 outage scheduled to start August 14 th and ending on approximately Oct 8 th

. This outage was planned for earlier in the year but was postponed when the Unit 2 piping replacement became a priority. Major outages, although planned, absorb much time from staff and when they occur, do not allow enough time for staff to complete other unscheduled tasks that may come up. Outages are carefully scheduled years in advance to insure proper equipment, personnel and resources are available.

There are also other plant projects, such as an air polluti on control project for Unit 2 that is being implemented under the EPA’s Regional Haze Rule that requires plant staff time. Heskett staff has been working over the past year with the North Dakota Department of Health to plan this project.

As stated above, Heskett staff is currently under time constraints, mainly due to the outages. For Heskett to provide the EPA with complete and accurate information regarding the facility for the ICR, Montana-Dakota believes that an additional 90 day extension is necessary.

We appreciate your consideration in this matter. Please contact me if you would like to discuss our plant situation or if you have any questions. I can be reached by phone at 701-222-7657 or by e-mail at kalle.kuether@mdu.com

.
Sincerely,

Kalle Kuether 

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...Environmental Engineer



### Kalle Kuether

Environmental Engineer Power Production Montana-Dakota Utilities Co. 400 N 4th Street Bismarck ND 58501-4092 phone: 701.222.7657 fax: 701.222.7845 

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