RRI Energy, Inc. 

June 24, 2010 

Steam Electric ELG Questionnaire 

Request for Extension 

Keystone Generating Station 

Shelocta, PA 15774 

Jezebele Alicea 

U.S. Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Mail Code: 4303T 

Washington, DC 20460 

alicea.jezebele@epa.gov 

BY ELECTRONIC MAIL 

Dear Ms. Alicea: 

On June 21, 2010, RRI Energy, Inc. (RRI Energy) was notified that we would receive the Steam 

Electric Questionnaire for the Keystone Generating Station, located in Shelocta, Pennsylvania. In 

total, RRI Energy has received 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 gas-fired 

plants, located in Pennsylvania, California, Mississippi and Florida. 

The purpose of this letter is to request an extension of the due date for submittal of the questionnaire 

for the Keystone Generating Station. The response to all portions of the questionnaire, except Part G, 

is due September 22, 2010, 90 days after receipt. We hereby request an extension of the due date to 

December 21, 2010 for all applicable portions of the questionnaire. RRI Energy and the Keystone 

Generating Station 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 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 

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. 
Ms. Jezebele Alicea June 24, 2010 

U.S. Environmental Protection Agency Page 2 of 4 

 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. 

 Independent Power Producer – Staff Resources 

Unlike, for example, a vertically integrated public utility with a substantial corporate 

environmental, engineering and accounting staff, our workforce is entirely dedicated to the safe 

and reliable operation of RRI power producing facilities. 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. Thus the ICR represents another significant level of effort for staff with 

other job responsibilities. 

 Independent Power Producer – Information Resources 

As a merchant generator, RRI Energy has owned most of the current coal-fired generating 

facilities for less than 10 years. We acquired the Keystone Generating Station on [May, 2000]. 

Moreover, all 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, would likely be 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 Reliant Energy. In 

addition, both Conemaugh and Keystone are subject to unique ownership arrangements that 

further complicate the availability of information, especially financial data. 

 Information May Not Be Available 

Much of the requested information is not readily available if at all: 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 Effort 

The burden of the ICR is far greater than EPA has estimated: The EPA Burden Statement grossly 

underestimates the time (196 man-hours) and cost ($12,573) for each steam electric station when 

compared to RRI’s real world estimated time of 710 man-hours and cost of $59,000 per station. 

In particular, the ICR states that a previous water balance as provided in form 2C of an NPDES 

permit application may be used for the water balance, and merely updated by hand mark up to 
Ms. Jezebele Alicea June 24, 2010 

U.S. Environmental Protection Agency Page 3 of 4 

match the ICR terminology. This statement implies that only minor effort is needed to provide an 

adequate water balance, and reflects a very limited understanding of the complexity of the task at 

hand. For example, one of the first items required is to indicate each steam electric generating unit 

with a block. Other unit processes that are referenced, such as ash handling systems, FGD systems 

and SCR systems are required to be included on the water balance and labeled to match the forms. 

These units are frequently grouped, or not represented on NPDES water balance diagrams. In 

particular, the generating unit itself is frequently not part of the water balance diagram, frequently 

all units are shown in the aggregate. Flows are similarly combined, and may not be tracked in the 

detail required for the ICR. 

Many of these contributing flows will require estimation. Similarly, ash handling processes may 

be combined, as well as FGD wastewater. Thus, most water balances contain neither the detail, 

nor the space required to include such detail with a hand markup and will require significant 

updating. Updating water balance information and plant diagrams to meet the ICR labeling 

requirement alone represents a 40 to 80 hour task per plant, due to the extensive detail requested 

by the ICR. We estimate another day per diagram required per plant to conform or create 

acceptable diagrams. 

We estimate that a total of 7,800 man-hours will need to be allocated just for eleven coal-fueled 

generating stations within the 90-day response deadline. 90 days is simply not sufficient for RRI 

Energy to effectively respond to the questionnaire. 

 Reporting Deadline Conflicts 

The timing of the questionnaire conflicts with our TRI annual reporting requirements, which are 

due July 1st. The data collection that is required to complete the questionnaire requires experienced 

personnel who are in limited supply to gather such information. In the midst of semi-annual 

reporting and corporate reorganization, our staff are in short supply. Given the pressing operating 

and compliance burdens on the facilities, there is limited or no reservoir of personnel to apply to 

preparing questionnaire responses. Key members of our staff will not be available to begin work 

on the Steam Electric Questionnaire until after the July 1st TRI reports are submitted. 

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 

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. 

 Site Specific Issues 

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 
Ms. Jezebele Alicea June 24, 2010 

U.S. Environmental Protection Agency Page 4 of 4 

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 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 cooling tower blowdown and/or FGD scrubbers 

including Keystone Generating Station may be impacted by these rules. 

At Keystone Generating Station, environmental personnel will be completing permit application, 

procurement and construction oversight for a new Limestone Pile Stormwater Runoff Pond and 

for a major upgrade to the demineralizer water treatment system and associated regeneration 

wastewater treatment system. Currently, a new Gypsum Area Runoff Pond is under construction 

through August 2010. In addition, performance testing of the Flue Gas Desulfurization (FGD) 

Wastewater Treatment Plant (WWTP) will be ongoing during this same time. This requires 

extensive support from plant personnel to ensure that the performance of the FGD WWTP 

complies with vendor specifications and environmental permit conditions. 

In closing, I would like to reiterate that RRI Energy and the Keystone Generating Station 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 so that we can fully meet our 

legal obligations pursuant to your information request. I look forward to your response. 

Sincerely, 

James Lafontaine 

General Manager 

Keystone Generating Station 

Copies: 

R. Smith 

S. Frank 

K. Whelan 

others