                               Site Visit Report

	Lake Road Plant
	1413 Lower 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 the cooling water intake structure (CWIS) technologies in use at facilities, including the site-specific 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.  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 by the KCP&L Greater Missouri Operations Company (KCP&L GMO).  It is located in an industrial section of St. Joseph, Missouri along the Missouri River on a compact site of approximately 40 acres.  Lake Road employs approximately 85 people and began operation in 1934.
      
      Cooling 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.  Lake 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 99 MW.  It is a baseload unit with an overall capacity utilization rate (CUR) of 85%.  The fuel source is a combination (80%/20%) of low/high BTU, low sulfur coal from the Powder River Basin in Wyoming and Colorado.  
      
      The facility typically has one routine maintenance outage during the spring and one in the fall that typically lasts 1-2 weeks.  

      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 capacity 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 baseload generating unit. The CWIS 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 velocity is 2.8 feet per second (fps).  In 1989, Lake Road added an anti-vortex device allowing it to lower the intake.  
      
      The CWIS 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 automatically rotate for cleaning. 
      
      In addition, as necessary, Lake Road introduces warm water prior to the CWIS which effectively prevents icing.  Facility representatives explained that they do not add biocides to prevent biofouling and that heavy scouring from debris helps keep the system clean.  
      
      Lake Road inspects its traveling screens annually.  It also cleans and rebuilds each screen every two years (one each year) during its routine maintenance outage period.  Divers inspect the screens annually.  Approximately every 2 years (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 any impingement, entrainment, or source water body characterization studies.  Following promulgation of the 2004 316(b) Phase II rule, Lake Road began an impingement study.  When EPA suspended that rule, Lake Road similarly suspended its impingement study.  Lake Road provided the results of its incomplete study as part of its response to EPRI's recent survey.  While Lake Road did not provide the results 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 and have been in operation for a considerable time period, the oldest since 1957.  The towers are wooden with wide-spaced metal frame fill.  Water for the steam generating boilers is withdrawn from groundwater wells.
      
      Facility representatives noted that closed-cycle cooling for the generating units would be possible, but highly costly 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 typically consists of tree limbs and stumps.  While the incoming water does not contain a lot of rocks, it does contain sand/mud and grasses.  During high debris conditions, operators rotate the screens continuously so that debris does not negatively impact operations.  However, because of debris build-up in the condenser, Lake Road typically cleans some portion of the condenser 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 by 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 beneficially uses all of its fly ash for fill and all of its slag for use in asphalt highways.  

13.0 Air Emissions Controls

      EPA did not collect information on air controls at Lake Road during its visit.
       
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." In addition, Lake 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.
      
      Facility representatives noted that KCPL GMO is a small company in the electricity producing arena that depends heavily on EPRI and UWAG for research and 316(b) representation.
      

Attachments

Attachment A		List of Attendees
Attachment B		Aerial Photo
Attachment C		Site Visit Photos
	


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
Mark Howell, KCP&L
Steven Brooks, KCP&L
Paul Ling, KCP&L
Bob Beck, KCP&L


Attachment B--Aerial Photo

Please see DCN 10-6525A accompanying this document.

Attachment C -- Site Visit Photos

Please see DCN 10-6525B through G accompanying this document.

