RRI Energy, Inc. June 22, 2010

Jezebele Alicea U.S. Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Avenue, NW

Mail Code: 4303T Washington, DC 20460 alicea.jezebele@epa.gov

Steam Electric ELG Questionnaire Request for Extension RRI Energy, Inc.

1000 Main Street Houston, Texas 77002

BY ELECTRONIC MAIL

Dear Ms. Alicea:

On June 18, 2010, RRI Energy, Inc. (RRI Ener gy) began receiving the Steam Electric Effluent Guidelines Information Collection Request (ICR) Qu estionnaire for several pl ants. In total, RRI Energy has been selected to receive the Steam Electric Questionnaire for 17 steam electric power plants, including all 11 of our coal-fired plants, lo cated in Pennsylvania and Ohio, and 6 of our gasfired plants, located in Pennsylvania, California, Missi ssippi and Florida. The purpose of this letter is to request an extension of the submittal due dates.

First, we thank EPA for extending the ICR response pe riod from 60 days to 90 days for the majority of the ICR parts. We understand that this was an effo rt to respond to industry concerns. However, RRI Energy is subject to unique conditions that require us to request an extension of the due dates for submittal of the questionnaire. The response to all po rtions of the questionnaire, except Part G, is due 90 days after receipt. Part G is due 120 days after re ceipt. We hereby request an extension of the due date to 180 days from receipt for all portions of the questionnaire. The resulting due dates would be December 15, 2010 for New Castle, Niles, Shawv ille, Indian River, Choctaw, Hunterstown and Mandalay and December 20, 2010 for plants receiving the ICR on June 21 or 22. RRI Energy and the affected plants are fully committed to complian ce with the applicable information collection requirements and the associated deadlines, but it is critically necessary that EPA approve this extension so that we can fully meet our legal obligations to supply the requested information.

As a merchant generator evolving in developing deregulated electricity markets, which has recently acquired these plants, and as a participant in a major merger, RRI Energy has specific issues with regard to the availability of information and the av ailability of knowledgeable individuals to compile information and to prepare, review and QA/QC th e questionnaires in the tim eframe specified. The operation of these generating plants in the open mark et is our only business. The primary coal-fired plants cited above constitute approximately 55% of our generating capacity, and an even higher percentage of our baseload operations. RRI Energy is staff constrained to supply the required data. Furthermore, the timing of the request conflic ts with other annual and semi-annual reportingMs. Jezebele Alicea June 23, 2010 U.S. Environmental Protection Agency Page 2 of 4

requirements, the burden of the questionnaire is far greater that EPA has estimated, and much of the requested information is not readily available, if at all. These reasons for an extension of time to complete the ICR are described in detail below.

• Merger and Reorganization

On April 11, 2010 RRI Energy and Mirant Corporation announced a merger which is expected to close before the end of 2010. While the merger is pending, both Mirant and RRI Energy operate as separate non-affiliated merchant power providers. The ongoing activities associated with the pursuit of the merger and the preparation for the integration require a significant effort on internal resources. These preparations directly impact employee availability to provide information required for the questionnaire for RRI Energy. The merger is particularly taxing upon the financial staff, who must also respond to all 17 ICR requests as most of the information required for Part I, as well as cost information requested in other Parts is held at the corporate level.

• Independent Power Producer – Staff Resources

Unlike, for example, a typical vertically in tegrated utility with a substantial corporate environmental, engineering and accounting staff, our workforce is operationally oriented. We do not have a large pool of qualified staff to temporar ily reassign to either suppor t the ICR effort or to fill-in while others are responding to the ICR.

• Independent Power Producer – Information Resources

As a merchant generator, RRI Energy has purchased or constructed the current generating fleet over the past 10 years. Moreover, the major ity of the current RRI generating assets changed ownership at least once prior to acquisition by RRI Energy. The availability of necessary records to respond to the ICR is significantly hampered by these numerous ownership changes. Such records, if they exist at all at RRI Energy, ar e frequently archived off-site. This means that facilities will have to perform intensive manual search es of paper records in file cabinets or boxes to try to reconstruct ICR require d information. It will also be extremely time-consuming to capture all of the aspects in the ICR. For ex ample, the facilities acquired from Orion have changed hands at least 3 times since 2000, from ei ther First Energy or Duquesne Light to Orion Power and then to RRI Energy.

• Information May Not Be Available

Much of the requested information is not readily available if at all, typical document retention requirements do not extend back to 2000 unless there is specific need to do so. The ICR contains many questions that require intensive record sear ches or otherwise impose significant burdens due to the age of the records. For example, several questions in Part C and Part D require respondents to estimate capital costs for ash handling sy stems and pond, impoundment and wastewater treatment systems that were installed since 2000. As previously noted, the flux on asset ownership and the ongoing merger activities compound the difficulty in responding to prior costs.

• Reporting Deadline Conflicts

Timing problems, such as increased paperwork burdens, are compounded for RRI due to the number of facilities that will be required to comp lete the ICR. The reporting burden for these plants is shared at the corporate level in sev eral departments, which means that one or twoMs. Jezebele Alicea June 23, 2010 U.S. Environmental Protection Agency Page 3 of 4

individuals must bear the burden for all of the facilities. In particular, the parent financial information will vary among the reporting facilities a nd must be prepared by a limited corporate

financial staff.

All 11 coal plants and several of the oil/gas plants will have quarterly emission reports due on July 30. This routine required data collection effort will task environmental a nd plant personnel at the

same time as the ICR. For most of the coal plants, the same personnel required to file quarterly reports will be immediately tasked with the semi- annual reports due in July through September. These mandatory deadlines directly compete with the ICR for limited technical resources.

Specific Operational and Environmental Issues In terfering With Time Completion Of The ICR:

Operational Issues

While site-specific issues are being addressed at the plant level, some of these that affect multiple operations are summarized below.

Many of our facilities are peaking or seasonal ope rations that are run with minimal crew. Plants such as Elrama, Niles, New Castle, Cool water, Mandalay, Chocta w, Hunterstown, and Brunot Island operate in peaki ng or seasonal mode. The ICR data collection effort coincides with peak generation season, when our resources at peaking plants are most heavily taxed. The burden of the ICR for these plants will be adde d to that of the already overtaxed corporate

staff.

Environmental Issues

In May 2010 Environmental Integrity Project Environmental, Defenders of Wildlife,

PennFuture and the Sierra Club announced their intent to file a Citizens suit for alleged violations of the Clean Water Act, Clean Streams Law and the Resource Conservation and Recovery Act at the Seward Generating Station. This litigation requires substantial time from the same resources needed to respond to the ICR. More importantly, attorney review of the ICR may be required to avoid conflicts or rel ease of information that is directly associated with the litigation response. Difficulties may be encountered with Attorney Client Work Products directly related to the lawsuit.

On 1/29/2010 EPA finalized Total Maximum Daily Loads (TMDLs) for the Conemaugh River, an impaired waterbody due to AMD. Th e rule requires improvements in the treatment and/or management of storm water and c ooling tower blowdown at the Conemaugh and Seward Generating Stations. TMDLs will likel y be included in Seward’s NPDES permits upon re-issuance in July 2010. Conemaugh’s NPDES permit may also be issued during the ICR data collection period. Station and Co rporate staff will be required to conduct engineering studies and implement changes to comply with the new regulation.

PADEP is proposing to establish new technolog y and water quality-based discharge limits on new and expanded outfalls for TD S and chlorides, respectively. The proposed regulation for TDS is expected to go final in June or Ju ly 2010. The proposed chloride water quality criterion is expected to be finalized in two to four months. Because effluent limits for existing dischargers will be based on the receiving stream ’s background concentrations and its capacityMs. Jezebele Alicea June 23, 2010 U.S. Environmental Protection Agency Page 4 of 4

to assimilate TDS and chlorides, RRI Energy en vironmental personnel ar e required to conduct studies to evaluate mass loadings of discha rges and stream modeling to assess our ability to comply with these new standards. RRI Energy stations with FGD scrubbers that include Conemaugh, Keystone, and Cheswic k Generating Stations may be impacted by these rules.

At the Conemaugh Generating Sta tion, environmental and engine ering personnel are actively installing a wastewater clarifier system to treat cooling tower blowdown as required under a 2004 Consent Order and Agreement (COA). Ou r compliance deadline for this project is February 1, 2011. Environmental personnel are also conducting detailed engineering studies of zero liquid discharge (ZLD) systems for the FGD purge water. Under a May 2010 amendment to the 2004 COA, these studies must be completed during the next few months so that RRI Energy and PADEP can evaluate and ma ke decisions on an appropriate path forward.

At the Shawville Generating Station, an e ngineering study is being conducted from July through September 2010 to evaluate thermal load ing on the West Branch of the Susquehanna River to ensure compliance with NPDES permitti ng conditions that will be effective in 2011.

At Cheswick Generating Station, an applicati on for a water quality management construction permit for the upgrade of the Monarch Mine wastew ater treatment system is scheduled to be completed between July and September of 2010. In addition, the commissioning of the FGD wastewater treatment system will be ongoing from June th rough August 2010.

At Keystone Generating Station, environm ental personnel will be completing permit application, procurement and construction over sight for a new Limestone Pile Storm Water Runoff Pond and for a major upgrade to the de mineralizer water treatment system and associated regeneration wastewater treatment system. In addition, a new Gypsum Area Runoff Pond is under construction through August 2010.

In closing, I would like to reiterate that RRI Ener gy and the affected plants are fully committed to compliance with the applicable information coll ection requirements and the associated deadlines, but it is critically necessary that EPA approve an ex tension for some, if not all, of the RRI Energy Plants selected to complete the effluent ICR so that we can fully meet our legal obligations pursuant to your information request. I look forward to your response.

Sincerely,

E.A. Feith, Vice President Environment and Safety RRI Energy, Inc.