1 Site Visit Report Lake Road Plant 1413 L ower Lake Road St. Joseph, MO 64502 March 3 , 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 th e 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 unde rstand cooling water use and specific issues or technologies that can affect 316(b) compliance. Lake Road was selected for a site visit due to its location on a large freshwater river
. 2.0 Facility Description Lake Road is owned and operated b y the KCP&L Gr eater Missouri Operations Company (KCP&L GMO ) . It is located in an industrial section of St. Joseph, Missouri along the Missouri River 1 on a compact site of approximately 40 acres. Lake Road employ s approximately 85 people and began operation in 1934
. C ooling and process water withdrawals from and wastewater discharges to the Missouri River are regulated under NPDES permit number MO0004898 which expired on June 12, 2008. L ake Road submitted its NPDES permit application in a timely manner and is awaiting renewal of its permit by the state. 3.0 Electricity Generation and Transmission Lake Road has one coal

- fired, steam

- electric generating unit with a generating capacity of 9 9 MW. It i s a baseload unit with an overall capacit y utilization rate (CUR) of 85%. The fuel source is a combination ( 8 0 %/2 0 %) of low/high BTU , low sulfur coal from the Powder River Basin in Wyoming and Colorado. 2 The facility ty

picall y has one routine maintenan ce outage during the spring and one in the fall that ty

pically lasts 1
- 2 weeks.

1 River velocity is 6

- 7 ft/s. 2 Facility representatives noted that the mixture helps to develop optimal bottom ash for resale, as w ell as meet a consent order for using low sulfur coal.2 Lake Road also produces, for sale, steam in one coal/gas, one gas and four oil/gas fed industrial boilers that have a total generating capacit y of 60.2 MW. 4.0 Cooling Water System and Intake Structure Lake Road has one CWIS that provides once

- through cooling water for the basel oad generating unit. The CWI S is fitted with a trash rack and two standard (i.e., coarse mesh 3/8”) traveling screens. In addition, 2 circulating water pumps, each rated at 28,000 gpm (total 80.6 mgd) , provide cooling water to the generating unit. The through

- screen velocit y is 2. 8 feet per second ( fps )
. In 1989, Lake Road added an anti

- vortex device allowing it to lower the intake. The CWI S has an adjustable bulkhead that can be raised or lowered to prevent debris from going over top of the screens and into the condenser. The screens rotate when the pressure differential across the screen reaches 3 to 4 inches allowing for cleaning with a high pressure spray that flows into a debris trough and discharges to the Missouri River. If this differential is not reached within a specified time limit, the screens automaticall y rotate for cleaning
. In addition, as necessary , L ake Road intr oduces warm water prior to the CWI S which effectivel y prevents icing. Facility representatives explained that they do not add biocides to prevent biofouling and that heavy scouring from debris helps keep the s ys tem clean. Lake Road inspects its traveli ng screens annuall y. It also cleans and rebuilds each screen every

two y ears (one each y ear) during its routine maintenance outage period. Divers inspect the screens annuall y. Approximately every 2 y ears (during a regularly

scheduled outage), Lake Road will clean the silt out of the CWIS. 5.0 Impingement and Entrainment Information Lake Road has not completed an y impingement, entrainment, or source water body characterization studies. Following promulgation of the 2004 316(b) Phase II rule, Lake Road b egan an impingement study
. When EPA suspended that rule, Lake Road similarl y suspended its impingement study. Lake Road provided the results of its incomplete study as part of i ts response to EPRI ’s recent survey
. While Lake Road did not provide the res ults of its incomplete impingement study during this site visit, facility representatives commented that the number of fish impinged during the study was low (3

- 4 fish collected in a 24 hour period). 6.0 Cooling Tower Feasibility Lake Road has three closed

- cycle cooling towers : one for each of the three turbines that receive steam from the six industrial boilers. These mechanical draft towers are small 3 and have been in operation for a considerable time period, the

3 The tow ers are two, thr ee, and four cells.3 oldest since 1957. The towers are wooden with wide

- spaced metal frame fill. Water for the steam generating boilers is withdrawn from groundwater wells. Facilit y representatives noted that closed

- cycle cooling for the generating units would be possible, but highl y costl y and problematic; across the KCP&L GMO portfolio, it is likely

some generating units would be forced to close. 7.0 Debris Handling Debris at Lake Road t ypically consists of tree limbs and stumps. While the incoming water does not contain a lot of rocks, it does contain sand /mud and grasses. D uring high debris conditions , operators rotate the screens continuously so that d ebris does not negativel y impact operation s. 4 However, because of debris build

- up in the condenser, Lak e Road ty picall y cleans some portion of the condens er each weekend. 8.0 Repowering/Future Uses Lake Road has no short term plans for re

- powering or upgrading. 9.0 Cooling Ponds Lake Road does not have any cooling ponds. 10.0 Ownership Lake Road is owned b y KCP & L GMO , a subsidiary of Great Plains Energy
. Kansas City

Power and Light Company is also a subsidiary

of Great Plains Energy
. Both subsidiaries operate under the KCP&L brand name. 11.0 316(a) EPA did not collect any

information on 316(a). 12.0 Ash Handling Lake Road beneficiall y uses all of its fly ash for fill and all of its slag for use in asphalt highway s. 13.0 Air Emissions Controls EPA did not collect information on air controls at Lake Road during its visit.

4 Lake Road has not experienced any shut downs due to debris.4

14.0 Additional Information Lake Road explained that the river bed in the Kansas City metro area is dropping. They referred to it as the “sinking river.” 5 Inaddition, L ake Road is limited by the Army Corps of Engineers in its ability to place structures that protrude into the river due to navigational requirements. Lake Road planned to rely on restoration for complying with the proposed 2004 Phase II rule. Facility

representatives commented that the State was also pushing them towards restoration. Facilit y representatives noted that KCPL GMO is a small company in the el ectricit y producing arena that depend s heavily on EPRI and UWAG for research and 316(b) representation
. Attachments Attachm ent A List of Attendees Attachment B Aerial Photo Attachment C Site Visit Photos

5 Lake Road does not know why the river is “sinking.”5

Attachment A -- List of Attendees Paul Shriner, EPA Headquarters Jan Matuszko, EPA Headquarters Jamie Hurley , EPA Headquarters John Dunn, EPA Region V II Mark Matthews, EPA Region VII Kelly Meadows, Tetra Tech Mark Howell, KCP&L Steven Brooks, KCP&L Paul L ing, KCP&L Bob Beck, KCP&L6

Attachment B -- Aerial Photo Please see DCN 10

- 6525A accompanying this document. Attachment C

— Site Visit Photos Please see DCN 10

- 6525 B through G accompan yi ng this document.