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Site Visit Report

Labadie Plant

10 Labadie Power Plant Road

Labadie, MO 63055

March 4, 2009

1.0 Background and Objectives

The Environmental Protection Agency (EPA) is in the process of developing 

316(b) cooling water intake structure requirements that reflect the best technology

available (BTA) for minimizing adverse environmental impact for all existing 

power plants and manufacturing facilities. As part of this process, EPA staff is 

visiting electric generators and manufacturers to better understand the cooling 

water intake structure (CWIS) technologies in use at facilities, including the sitespecific characteristics of each facility and how these affect the selection and 

performance of CWIS technologies. EPA is also visiting facilities to better 

understand cooling water use and specific issues or technologies that can affect 

316(b) compliance. Labadie was selected for a site visit due to its location on a 

large freshwater river.

2.0 Facility Description

Labadie is located on a 2000 acre site1in Labadie, Missouri, about 50 miles west 

of St. Louis and on the Missouri River. The facility began operations in 1970 and 

employs approximately 300 people.

Labadie is owned and operated by Ameren. The facility’s NPDES permit 

(MO0004812) expired March 17, 1999.

3.0 Electricity Generation and Transmission

Labadie consists of 4 identical coal-fired2generating units and has a total 

generating capacity of 2450 MW (one third of Ameren’s baseload capacity). 

These units came on line sequentially from 1970 to 1973. The facility’s capacity

utilization rate (CUR) is approximately 82%.

The transmission system is owned by Ameren but is operated by a different 

business unit.

 

1 The facility recently purchased a 1000 acre tract for storing its scrubber waste.

2 The facility’s coal comes via rail from the Powder River Basin in Wyoming. Originally, the facility used 

coal from Illinois, but switched to a lower sulfur coal in 1997. The facility uses 10-11 million tons of coal 

per year.
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4.0 Cooling Water System and Intake Structure

Labadie has one CWIS that withdraws once-through cooling water from the 

shoreline at the edge of the navigational channel on the Missouri River. The 

CWIS has a design intake flow (DIF) of 1233 million gallons per day (mgd) and 

an average actual intake flow (AIF) of 1178 mgd. The CWIS has a common trash 

rack3and 8 intake bays (2 per unit), each with a single circulating pump and 

coarse mesh (3/8” mesh) traveling screen.4 The screens automatically rotate 

every 8 hours or when a pre-determined head differential is reached. The design 

intake velocity of the CWIS is 1.2 feet per second (fps).

Facility representatives noted that the new traveling screens incorporate design 

elements to reduce maintenance, such as eliminating screen foot shafts and 

sprockets and using shaft-mounted gear reducers.

When necessary to prevent icing, Labadie discharges heated effluent into the 

intake structure between the intake bar rack and the traveling screens.

5.0 Impingement and Entrainment Information

Ameren conducted impingement studies at all of its Phase II facilities in 2005 and 

2006. During the sampling period, Labadie conducted 24 hour impingement 

sampling every other week for a year for a total of 26 sampling events. 

Approximately 93% of the fish collected at Labadie were shad and drum. The 

sampling estimated an annual impingement total of approximately 100,000 fish. 5

6.0 Cooling Tower Feasibility

Labadie has not considered retrofitting to a closed-cycle recirculating system 

(CCRS). Facility representatives expressed concern about possible outage times 

and the complexity of tie-in. They also raised concern about the space required 

for towers in light of the space required to handle scrubber wastes.

7.0 Debris Handling

At the facility, the Missouri River has an average flow of 64,000 cfs (41,364 

mgd), with high silt levels6and an average water velocity of approximately 9 

miles per hour (13.2 fps). The height of the river is controlled by the Army Corps 

 

3 A new trash rack was installed in 2006; see Section 7.0 for more information.

4 The original traveling screens were 1⁄2” mesh. The current screens were replaced in 2007 as part of 

regular maintenance. To facilitate future CWIS upgrades, the facility purchased screens that can be 

modified to include fish buckets and a separate fish return trough.

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Facility representatives noted that the sampling was conducted prior to installing the new trash rack and 

screens; they stated that impingement rates are likely lower now. Also, the annual estimate includes 

moribund fish.

6 The maximum measured total suspended solids (TSS) concentration in the Missouri River in 2008 was 

2300 mg/L while the average TSS concentration for 2007/2008 was 328 mg/L. 
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of Engineers. It is highest in the spring/summer to accommodate navigational 

requirements. River height can vary significantly between the winter and 

summer.

Labadie’s CWIS encounters elevated debris loads in the spring and fall, as leaf 

debris is heavy

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and flows are often higher. In winter, icing is a concern; the 

facility installs an ice barge from November to March.

The facility has had significant problems with debris in the past. In 1993, the 

facility had to shut down 3 units and reduce generation by 50% at another due to 

unusually high debris loading, which clogged the intake screens and limited the 

ability to withdraw cooling water. In 2005, the trash rack collapsed due to debris 

accumulation. At that time, plugging of the trash rack was a major problem at the 

facility. Labadie cleaned the trash rack via a crane located on a small boat in 

front of the trash rack or, preferably, when the river height allowed for navigation, 

a crane fitted on a barge. 

Because debris-related issues frequently affected operation and even brought it 

dangerously close to losing all units, Labadie upgraded its CWIS during 2005-

2006. First, Labadie installed a new trash rack during the 2005-2006 winter 

season with additional design features to improve debris handling. Primarily, the 

facility altered the CWIS so that the face of the trash rack is now flat and flush 

with the front of the CWIS—there are no longer any protrusions for bulkheads or 

other features that previously created eddy currents, trapping debris at the CWIS. 

A mechanical trash rake was also installed; it can handle large volumes of debris, 

including logs.8 Since the new trash rack has been installed, the facility has not 

experienced any problems with debris loading.9

Second, as explained in Section 4.0, Labadie replaced its existing traveling 

screens at a cost of approximately $2.8 million.

Finally, it re-designed an existing sediment barrier wall. In the 1980s, the facility

installed a sediment barrier wall and underwater vanes to redirect debris and 

sediment away from the CWIS; the vanes have noticeably reduced the amount of 

pea gravel and sand in the CWIS. As part of the 2006 modifications, Labadie 

removed a section of the coffer dam sheet piling that remained from the work 

conducted during the early 1980s. This essentially removed a restriction in the 

flow channel immediately in front of the bar screen such that underwater debris 

could flow through instead of being trapped by the sheet piling. 

 

7 A small tributary creek at the western border of the facility drains a 30 square mile wooded area, 

contributing a large volume of leaves directly at the intake.

8 An automated cleaning cycle takes about 4 hours or an operator can manually remove debris. Debris is 

returned to the river downstream of the CWIS, where it is quickly carried away by the current.

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Facility representatives also noted that the through-screen velocity at the trash racks is much lower with 

the new trash rack; it remains much cleaner, maintaining the open area and keeping the intake velocity 

lower.
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A debris filter was installed for Unit 4, but is no longer used. This debris filter 

was located near the Unit 4 condenser and was not associated with the CWIS.

Facilities representatives stated that the 2006 modifications had significantly

reduced their debris issues. When high debris periods are expected, operators preclean the trash rack and increase traveling screen rotation speeds. Labadie noted 

that it had reduced its total MW losses associated with pump losses due to debris 

significantly from 77,000 MWh in 2003 to 1,244 in 2008. 

8.0 Repowering/Future Uses

Currently, Labadie has no plans for re-powering or upgrades.

9.0 Cooling Ponds

There are no cooling ponds on site.

10.0 Ownership

Labadie is owned by Ameren, an investor-owned company. Ameren UE has 2.4 

million customers located throughout Illinois, Iowa, and Missouri. Ameren owns 

a total of 10 coal, 1 nuclear, 1 combined cycle, 3 hydroelectric, and 10 

combustion turbines facilities.

11.0 316(a)

EPA did not collect any information on 316(a).

12.0 Ash Handling

Labadie has one large ash pond onsite. Approximately 50-75% of the bottom ash 

and 75-85% of the fly ash is sold for beneficial uses (mainly concrete).

Ameren has an internal team that conducts inspections of all earthen dams and 

similar structures. Due to a dam failure at the Taum Sauk pumped storage facility

in 2005, Ameren instituted rigorous inspections at all facilities. Facility

representatives noted that Ameren’s inspections are more stringent than those 

conducted by state agencies.

13.0 Air Emissions Controls

EPA did not collect any information on air emissions controls.
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14.0 Additional Information

Facility representatives stated that they had begun to evaluate intake technologies 

for compliance with the 2004 Phase II rule. One approach was to install coarse 

mesh wedgewire screens; a bulkhead wall would be constructed approximately 20 

feet in front of the existing intake and 30 screens extending for 328 feet would be 

installed. The screens would have a design through-screen velocity of 0.5 fps. 

This approach had a projected cost of $195 million ($2002). 

Labadie also evaluated coarse mesh Ristroph screens (including a new fish return) 

and a modular inclined screen with 2mm bar spacing. Ristroph screens had a 

projected cost of $4 million and the modular included screen had a projected cost 

of $570 million. 

While Labadie did not settle on a compliance approach, when it replaced its 

screens in 2007, it purchased screens that would allow for an easy retrofit to 

incorporate Ristroph modifications.

Facility representatives voiced concerns over the use of fine mesh at a large 

freshwater river site such as Labadie. They noted high debris levels, icing, the 

ability to expand the CWIS, and unknown reliability of fine mesh screens as 

impediments. They requested that additional research be conducted to verify that 

fine mesh screens can be appropriate for facilities on a nationwide basis. They

also noted that large freshwater rivers are similar to freshwater lakes in terms of 

the level of impingement and entrainment; as such, these facilities merit a more 

site-specific approach.

Facility representatives also noted that Ameren was generally in favor of the 

structure of the 2004 rule. They requested that the proposed rule contain a 

number of features:

 retain the site-specific flexibility of the 2004 rule

 utilize recent impingement studies showing small fish counts

 consider cost implications (including monies spent on compliance towards 

the 2004 rule)

 offer finality for selecting a technology (i.e., limit any additional 

technology requirements)

 retain the same standards for applying entrainment requirements (i.e., not 

on freshwater rivers and lakes)

 consideration of through-plant entrainment survival

 retain the calculation baseline, allowing for credits for selecting an 

appropriate intake location and for upgrading equipment

 allow adjustments for naturally moribund species

Facility representatives noted that the timing of implementation in the proposed 

rule is important; research and testing is necessary to ensure the reliability of 
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intake technologies. They agreed that two permit terms should be sufficient, but 

would want to coordinate with the state permitting authority.

Attachments

Attachment A List of Attendees

Attachment B Aerial Photos

Attachment C Site Visit Photos

Attachment D Ameren PowerPoint Presentation (March 4, 2009)

Attachment E Ameren Rulemaking PowerPoint Presentation (March 4, 2009)
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Attachment A--List of Attendees

Paul Shriner, EPA Headquarters

Jan Matuszko, EPA Headquarters

Jamie Hurley, EPA Headquarters

John Dunn, EPA Region VII

Mark Matthews, EPA Region VII

Kelly Meadows, Tetra Tech

Steve Whitworth, Ameren

Mark Litzinger, Ameren

David Fox, Ameren

Mike Romano, Ameren

Nancy Morgan, Ameren

Mike Hanneken, Ameren

Mike Smallwood, Ameren

Mike Bollinger, Ameren
Copyrighted page/s removed. Copyrighted material is not available in 

Regulations.gov since it may not be reproduced without consent of 

the copyright holder. 

Contact the EPA Docket Center’s Public Reading Room to view 

or receive a copy of this document. 

Requests for copies may be made as follows: 

In person/writing: 

Environmental Protection Agency, Docket Center 

1301 Constitution Ave NW, 2822T, Room 3334 

Washington, DC. 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov 
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Attachment C—Site Visit Photos

Please see the attached materials.

Attachment D—Ameren PowerPoint Presentation (March 4, 2009)

Please see the attached materials.

Attachment E—Ameren Rulemaking PowerPoint Presentation (March 4, 2009)

Please see the attached materials.