From: <Alicea.Jezebele@epamail.epa.gov>

To: "Kuether, Kalle" <Kalle.Kuether@mdu.com>

Date: 7/22/2010 11:20 AM

Subject: Re: ICR 90 day Extension Request: R. M. Heskett Station, Plant ID: 01194

Attachments: pic13799.gif; Extension Request.pdf

Greetings,

EPA has reviewed your extension request for the steam electric effluent

guidelines questionnaire for the Montana-Dakota Utilities (MDU) R. M.

Heskett facility. The deadline for your plant to submit Version 2 of

the completed questionnaire is extended to October 15, 2010.

If you need assistance during the completion of the steam electric

questionnaire, please contact the steam electric helpline via e-mail at

steamhelp@erg.com or by phone at 1-877-353-7560.

Sincerely,

(Embedded image moved to file: pic13799.gif)

 

 From: "Kuether, Kalle" <Kalle.Kuether@mdu.com> 

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

 Cc: "Krebsbach, Abbie" <Abbie.Krebsbach@mdu.com>, "Welte, Alan" <Alan.Welte@mdu.com>, 

"Stroh, Tony" 

 <Tony.Stroh@mdu.com> 

 

 Date: 07/08/2010 02:18 PM 

 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 compared 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 14th and ending on approximately Oct 8th. 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 pollution 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

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

 (See attached file: Extension Request.pdf)