Seward Power Plant 

595 Plant Road 

New Florence, PA 15l44 

(814) 446-4650 

June 24, 2010 

Steam Electric ELG Questionnaire 

Request for Extension 

Reliant Energy Mid Atlantic 

Seward Generation Station 

New Florence, PA 

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 received the Steam 

Electric Questionnaire for the Seward Generating Station, located in New Florence, 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 Seward Generating Station. The response to all portions of the 

questionnaire, is due September 19, 2010, 90 days after receipt. We hereby request an extension 

of the due date to December 18, 2010, (180 days) for all portions of the questionnaire. RRI 

Energy and the Seward 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, that 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 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. 

 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. The Seward plant that was originally acquired in November 1999 

has been substantially replaced with a new plant that began operation on October 31, 2004. 

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. 

 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: 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. 
Ms. Jezebele Alicea June 24, 2010 

U.S. Environmental Protection Agency Page 3 of 4 

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 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 may 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 to modify and update existing water diagrams, 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. 
Ms. Jezebele Alicea June 24, 2010 

U.S. Environmental Protection Agency Page 4 of 4 

 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 

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 

In May 2010, Environmental Integrity Project, counsel for PennEnvironment, 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 reissuance in July 2010. Conemaugh’s NPDES permit may also be issued during the next 3 to 4 

months. 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 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