RRI Energy, Inc.

April 25, 2011

Steam Electric ELG Questionnaire

Request for Extension 

RRI Energy

Orion Power Midwest LP 

New Castle Power Plant

PO Box 325

West Pittsburg, PA 16160

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 18, 2010, RRI Energy, Inc. received the Steam Electric Questionnaire for the New Castle 

Plant, located in West Pittsburg, Pennsylvania. Orion Power Midwest is a subsidiary of RRI Energy, 

Inc. 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 gasfired 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 New Castle Plant. The response to all portions of the questionnaire, except Part G, is due 

September 16, 2010, 90 days after receipt. Part G is due October 16, 2010, 120 days after receipt. We 

hereby request an extension of the due date to December 15, 2010, 180 days after receipt for all 

portions of the questionnaire. RRI Energy and the New Castle Plant 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. 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 than 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 April 25, 2011

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 New Castle Plant in May of 2002. New Castle 

was originally a Penn Power generating station and then through merger, became a FirstEnergy 

facility. The plant was then briefly owned by Duquesne Light as part of an asset swap with 

FirstEnergy. Duquesne Light sold the New Castle Plant to Orion Power which in 2002 was 

purchased by Reliant Energy (later become 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 may likely be archived off-site. This means 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. 

• 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 that EPA has estimated. 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 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 
Ms. Jezebele Alicea April 25, 2011

U.S. Environmental Protection Agency Page 3 of 4

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.

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 to 

modify the existing water diagrams, due to the extensive detail requested by the ICR. We estimate 

at least another day per diagram required to conform or create acceptable diagrams. 

• Reporting Deadline Conflicts

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

due July 1st

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.

. 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 corporate staff is in short supply. The plant is 

currently in search of an Environmental professional to replace the incumbent who has already 

accepted and taken another position at a different plant. Given the pressing operating and 

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

preparing questionnaire responses. 

The New Castle Plant 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 

New Castle we are relying on corporate support until we can replace our Environmental 

professional and then we 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. 

• 120 days for leachate collection is too short. 

Analytical Method 1631 for mercury requires sample collection using the Method for Sampling 

Ambient Water for Determination of Trace Metals at EPA Water Quality Criteria Levels (Method 

1669) also referred to as “clean hands/dirty hands”. RRI Energy must subcontract this sample 

collection and analysis. The per-plant cost of this contracted sampling and analysis program may 

equal or exceed the EPA estimated total cost to respond to this ICR. We have initiated the process 

of obtaining qualified vendors for leachate sampling and analysis; however, there are a limited 

number of laboratories available to perform this work, and RRI Energy must compete with 

approximately 175 other plants to schedule this work. Not only are there contracting and sample 

collection backlog issues, but also the few laboratories that perform this work will not likely be 

able to meet 30-day turnaround. Based on the 30-day turnaround, 14 days of rainfall data and 28 

days of sampling, a total of 72 days are required to obtain the data after a laboratory is located and 
Ms. Jezebele Alicea April 25, 2011

U.S. Environmental Protection Agency Page 4 of 4

the appropriate sampling locations are located. Allowing 1 week to determine the number of 

samples that will be needed, 1 week to prepare an RFP and locate qualified bidders, 2 weeks for 

bidding, 1 week to finalize a PO, and 1 week to mobilize (total of 42 days) requires 114 days. 

This leaves only 6 days to complete the data review, finalize the form and submit it. If there is any 

loss or damage to samples, or if the laboratories are overloaded and cannot meet standard 

turnaround, the schedule will not be met. Further, samples will be collected during the dry season 

and there may be no leachate to collect. For these reasons the completion of Part G requirements 

mandates a minimum of at least 180 days, rather than 120 days. 

• Site Specific Issues

New Castle Plant operates as a seasonally operated facility. As such we maintain a minimal crew. 

The ICR data collection effort coincides with peak generation season, when our resources are most 

heavily taxed. 

As mentioned previously, the New Castle Environmental professional took another position at 

another plant earlier this year and a search is being conducted to replace this critical position on 

the New Castle Plant staff. While conducting this candidate search, the plant has requested limited 

support from the corporate office.

In closing, I would like to reiterate that RRI Energy and the New Castle Plant are fully committed to 

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

it 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,

Joe Dulovich

General Manager

New Castle Plant

724-535-1810

jdulovich@rrienergy.com

Copies:

R. Smith

S. Frank

K. Whelan