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 Energy) began receiving the Steam Electric Effluent 

Guidelines Information Collection Request (ICR) Questionnaire for several plants. 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, located in Pennsylvania and Ohio, and 6 of our gasfired plants, located in Pennsylvania, California, Mississippi 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 period from 60 days to 90 days for the majority of 

the ICR parts. We understand that this was an effort 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 portions of the questionnaire, except Part G, is due 

90 days after receipt. Part G is due 120 days after receipt. 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, Shawville, 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 compliance 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 availability of knowledgeable individuals to compile 

information and to prepare, review and QA/QC the questionnaires in the timeframe specified. The 

operation of these generating plants in the open market 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 conflicts with other annual and semi-annual reporting 
Ms. 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 integrated 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 temporarily reassign to either support 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 majority 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, are frequently archived off-site. This means that 

facilities will have to perform intensive manual searches of paper records in file cabinets or boxes 

to try to reconstruct ICR required information. It will also be extremely time-consuming to 

capture all of the aspects in the ICR. For example, the facilities acquired from Orion have 

changed hands at least 3 times since 2000, from either 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 searches 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 systems 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 complete the ICR. The reporting burden for these 

plants is shared at the corporate level in several departments, which means that one or two 
Ms. 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 and 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 and 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 Interfering 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 operations that are run with minimal crew. 

Plants such as Elrama, Niles, New Castle, Coolwater, Mandalay, Choctaw, Hunterstown, and 

Brunot Island operate in peaking 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 added 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 release 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. The rule requires improvements in the treatment 

and/or management of storm water and cooling tower blowdown at the Conemaugh and 

Seward Generating Stations. TMDLs will likely 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 Corporate staff will be required to conduct 

engineering studies and implement changes to comply with the new regulation. 

PADEP is proposing to establish new technology and water quality-based discharge limits on 

new and expanded outfalls for TDS and chlorides, respectively. The proposed regulation for 

TDS is expected to go final in June or July 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 capacity 
Ms. Jezebele Alicea June 23, 2010 

U.S. Environmental Protection Agency Page 4 of 4 

to assimilate TDS and chlorides, RRI Energy environmental personnel are required to conduct 

studies to evaluate mass loadings of discharges and stream modeling to assess our ability to 

comply with these new standards. RRI Energy stations with FGD scrubbers that include 

Conemaugh, Keystone, and Cheswick Generating Stations may be impacted by these rules. 

At the Conemaugh Generating Station, environmental and engineering personnel are actively 

installing a wastewater clarifier system to treat cooling tower blowdown as required under a 

2004 Consent Order and Agreement (COA). Our 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 make decisions on an appropriate path forward. 

At the Shawville Generating Station, an engineering study is being conducted from July 

through September 2010 to evaluate thermal loading on the West Branch of the Susquehanna 

River to ensure compliance with NPDES permitting conditions that will be effective in 2011. 

At Cheswick Generating Station, an application for a water quality management construction 

permit for the upgrade of the Monarch Mine wastewater 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 through August 2010. 

At Keystone Generating Station, environmental personnel will be completing permit 

application, procurement and construction oversight for a new Limestone Pile Storm Water 

Runoff Pond and for a major upgrade to the demineralizer 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 Energy and the affected plants are fully committed to 

compliance with the applicable information collection requirements and the associated deadlines, 

but it is critically necessary that EPA approve an extension 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.