1 Site Visit Report Labadie Plant 10 L abadie 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 re flect 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 (CWI S) technologies in use at facilities, including the site

specific characteristics of each facility and how these affect the selection and performance of CWI S technologies. EPA is also visiting facilities to better unders tand 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 site 1 in Labadie, Missouri, about 50 miles west of St. L ouis and on the Missouri River. The facility began operations in 1970 and employ s approximately

300 people. Labadie is owned and operated b y Ameren. The facility ’s NPDES permit ( MO0004812 ) expired March 17, 1999. 3.0 Electricity Generation and Transmission Labadie consists of 4 identical coal

- fired 2 generating 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 f acility ’s capacity utilization rate (CUR) is approximately 82%. The transmission sy stem 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 Pow der River Basin in Wyoming. Originally, the facility used coal from Illinois, but switched to a low er sulfur coal in 1997. The facility uses 10

- 11 m illion tons of coal per year.2

4.0 Cooling Water System and Intake Structure Labadie has one CWI S that withdraws once

- through cooling water from the shoreline at the edge of the navigational channel on the Missouri River . The CWI S has a design intake flow (DIF) of 1233 million gallons per day (mgd) and an average actual intake flow (AIF) of 1178 mgd. The CWI S has a common trash rack 3 and 8 intake bay s (2 per unit) , each with a single circulating pump and coarse mesh ( 3/8 ” mesh ) traveling screen. 4 The screens automaticall y rotate every 8 hours or when a pre

- determined head differential is reached. The design intake velocit y of the CWI S is 1.2 feet per second (fps). Facilit y 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 ye ar for a total of 26 sampling events. Approximately

93% of the fish collected at Labadie were shad and drum. The sampling estimated an annual impin gement total of approximately 100,000 fish. 5 6.0 Cooling Tower Feasibility Labadie has not considered retrofitting to a closed

- cy cle recirculating sy stem (CCRS). Facility

representatives expressed concern about possible outage times and the complexity

of t ie

- 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 levels 6 and an average water velocity of approximately

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

3 A new trash rack was installed in 2006; see Section 7.0 for more information. 4 The original traveling screens w ere 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 mo difie d to include fish buckets and a separate fish return trough. 5 Facility representatives noted that the sampling was conducted prior to installing the ne w trash rack and screens; they stated that impingement rates are likely low er now . Also, the annual est im ate includes mo ribund fish. 6 The maximum measured total suspended solids (TSS) concentration in the Missouri River in 2008 w as 2300 m g/L while the average TSS concentration for 2007/2008 w as 328 mg/L.3 of Engineers. Itis highest in the spring/summer to accommodate navigational requirements. River height can vary significantl y between the winter and summer. Labadie’s CWI S encounters elevated debris loads in the spring and fall, as leaf debris is heav y 7 and flows are often higher. In winter, icing is a concern; the facility installs an ice barge from November to March. The f acility has had significant problems with debris in the past. I n 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, preferabl y, when the river height allowed for navigation, a crane fitted on a barge. Because debris

- related issues frequently affected operation and even brought it dangerousl y close to losing all units, Labadie upgraded its CWI S during 200 5
- 2006 . Firs t, 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 CWI S so that the face of the trash rack is now flat and flush with the front of the CW IS

—there are no longer any protrusions for bulkheads or other features that previously created eddy

currents, trapping debris at the CWI S. A mechanical trash rake was also installed; it can handle large volumes of debris, including logs. 8 Since the new t rash rack has been installed, the facility has not experienced an y problems with debris loading. 9 Second, as explained in Section 4.0, L abadie replaced its existing traveling screens at a cost of approximately $2.8 million. Finally , it re

- designed an exi sting sediment barrier wall. In the 1980s, the facility installed a sediment barrier wall and underwater vanes to redirect debris and sediment away

from the CWI S; the vanes have noticeabl y reduced the amount of pea gravel and sand in the CWI S. As part of the 2006 modifications, L abadie removed a section of the coffer dam sheet piling that remained from the work conducted during the early 1980s

. This essentiall y removed a restriction in the flow channel immediately in front of the bar screen such that und erwater debris could flow through instead of being trapped b y 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 aw ay by the current. 9 Facility representatives also noted that the through

- screen velocity at the trash racks is much low er with the new trash rack; it remains much cleaner, maintaining the open area and keeping the intak e velocity low er.4 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 pre

clean the trash rack and increase traveling screen rotation speeds. Labadie noted that it had reduced i ts total MW losses associated with pump losses due to debris significantl y from 77,000 MW h 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 b y 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 cy cle, 3 hy droelectric, and 10 combustion turb ines 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 fl y ash is sold for beneficial uses (mainly concrete). Ameren has an i nternal 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 b y state agencies. 13.0 Air Emissions Controls EPA did not collect any

information on air emissions controls.5

14.0 Additional Information Facilit y representatives stated that they had begun to evaluate inta ke 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 b e installed. The screens would have a design through

- screen velocit y 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 scree n 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 eas y retrofit to incorporate Ristroph modifications. Facilit y represent atives 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 fresh water 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. Facilit y representatives also noted that Ameren was generally in favor of the structure of th e 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 compl iance towards the 2004 rule)  offer finality

for selecting a technology (i.e., limit any

additional technology

requirements)  retain the same standards for appl yi ng entrainment requirements (i.e., not on freshwater rivers and lakes)  consider ation 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 Facilit y representatives noted that the timing of implementation in the proposed rule is important; research and testing is necessary to ensure the reliability of6 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)7

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 L itzinger, Ameren David Fox, Amer en Mike Romano, Ameren Nancy Morgan, Ameren Mike Hanneken, Ameren Mike Smallwood, Ameren Mike Bollinger, Ameren

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Attachment C

— Site Visit Photos Please see the attached materials

. Attachment D

—

Ameren PowerPoint Presenta tion (March 4, 2009) Please see the attached materials. Attachment E

—

Am eren Rulemaking PowerPoint Presentation (March 4, 2009) Please see the attached materials.