Draft Notes from Site Visit at Kinder Morgan Power Plant on September 24, 2009

EPA conducted a site visit at Kinder Morgan Power Plant located in Jackson, MI on Thursday, September 24, 2009 to learn about the operations at the plant. Table 1, located at the

end of this memorandum , identifies the site visit participants.

This memorandum describes the information collected during the site visit.

Plant Overview

**•** The Kinder Morgan Power Plant (Kinder Morgan) is owned by Kinder Morgan Power Company, a subsi diary of Kinder Morgan, Inc.

**•** Kinder Morgan is a “demand dispatch” facility with peaking and intermediate load capacity. Kinder Morgan’s customer is Midwest Independent Transmission System Operator (MISO), an electricity wholesaler. Due to the depressed in dustrial load this year, Kinder Morgan has not run as much in the “reliability dispatch” mode. The plant’s typical peaking operations include starting up in the morning, following the load peaks throughout midday and into the evening, and then shutting dow n.

**•** Kinder Morgan is located in residential Jackson, MI. The plant employs 22 personnel responsible for operation and maintenance of the facility.

**•** Kinder Morgan’s 550 MW combined cycle system is unique to other systems because it was designed for a peaki ng plant. Kinder Morgan operates a hybrid combined cycle system, which includes six aeroderivative (jet) engines, one Frame 7EA combustion turbine, and two steam turbines. Kinder Morgan operates this system to serve an “intermediate load” market

nitch.

**•** K inder Morgan is a successful peaking plant because of its ability to quickly produce power. The plant is attractive to its capacity customer because of the high ramp rate available with this specific combined cycle system (40 MW/minute). If the plant is “ cold”, meaning it has not been run in 24 hours, it is able to ramp to full power in just over two hours. If the plant is “warm”, it only requires one hour to ramp to full power.

**•** Kinder Morgan was strategically built close to a natural gas line (also owne d by Kinder Morgan, Inc.) that runs across Michigan. Due to this location, Kinder Morgan can receive high quality natural gas to run the combined cycle system. Kinder Morgan is also placed close to two high voltage lines. The high voltage interconnect line allows Kinder Morgan to distribute and sell 90 percent of the power generated (10 percent would be enough to generate power for all of Jackson).

**•** MISO and Kinder Morgan Power Company operate under a capacity sale and tolling agreement. As described by Kin der Morgan plant personnel, the plant is protected by contract with the owner and the owner is protected by contract with the capacity customer (MISO). MISO owns Kinder Morgan’s capacity and purchases the fuel used to run the plant. Kinder Morgan plant p ersonnel pointed out that if Kinder Morgan were a merchant plant, it would need to purchase its own fuel, and likely would have been out of business due toPage 2

natural gas prices. Kinder Morgan Power Company covers the plant’s operation and maintenance (O&M) costs and also pays the property tax for the plant.

**•** MISO contracts Kinder Morgan for its ability to supply 550 MW of power when demanded. This means that even when the plant is not running, Kinder Morgan is still making a profit

because it is available t o run. If a unit is down for maintenance, Kinder Morgan loses money because the power that could be generated from that combustion or steam turbine is no longer available.

**•** MISO monitors the grid daily and reports to Kinder Morgan how much power they nee d, if they need it, and when they need it. The Kinder Morgan combined cycle system does not operate every day, and when it does operate, it is typically for only part of the day.

**•** MISO views Kinder Morgan as one combined cycle system that provides varyi ng amounts of power as needed. Kinder Morgan may only operate part of the combined cycle system (e.g., part of the combustion turbines and only one of the two steam turbines). When operating, each turbine cannot be run at less than 11 to 12 MW; however, no t all turbines must be run to generate the power.

**•** Kinder Morgan was a 15

- acre brownfield development. Kinder Morgan entered into a contract with the City of Jackson to tear down the Goodyear plant. Kinder Morgan used about half of the total property to b uild the plant. As part of the contract with the City of Jackson, all existing water and sewage infrastructure from the Goodyear plant was made readily available to Kinder Morgan, and Kinder Morgan has been able to discharge water to the local Publicly Own ed Treatment Works (POTW). They have never had a reason to develop a different drainage system (i.e., discharge to surface water).

**•** The Kinder Morgan plant was constructed from March 2001 to November 2001, and the plant went commercial in July 2002, prior to full operation. In September 2002, Kinder Morgan closed with the contractor.

**•** Most equipment for the plant was built off site. The Frame 7EA had to be mostly constructed on site due to its large size.

**•** The 550 MW Kinder Morgan combined cycle plant c ost about $250 million to build. Kinder Morgan Power Company decided to build a power plant that would use natural gas as its fuel because it is more efficient. Natural gas produces more kW/BTU than coal. The plant was also less expensive to build than a c oal plant: the same size coal plant would cost about $1.5 billion. Kinder Morgan estimated that an 800 MW coal plant would cost about $4 billion.

Combined Cycle System

**•** Kinder Morgan uses a low sulfur natural gas to fuel the combustion turbines. Kinder M organ does not use a liquid fuel because of the changes in air permitting that it would require.

**•** Kinder Morgan stated that the approximate electric generating capacities of the components of the combined cycle system are as follows: 40 to 50 MW for each of the six aeroderivative combustion turbines, 70 to 90 MW for the Frame 7EA combustion turbine, and 105 MW for each of the two steam turbines. Kinder Morgan stated that 10 MW of steam power isPage 3

produced from each 50 MW combustion turbine. Three MW of this 10 MW steam produced is put back into the turbine for NO X suppression, and 1.5 MW of this 3 MW consumed is gained back in additional power generation.

**•** Kinder Morgan uses steam for NO X suppression because it is less damaging to the engine

than water. The water can erode ceramic nozzles throughout the engine, which would cost about $10,000 every 25,000 hours to replace. Steam is injected into the combustor through injectors placed around the circumference of the combustor. The boundary layer of steam

supp lied in the combustor keeps the NOx from cracking.

**•** Kinder Morgan operates one Frame 7EA combustion turbine that runs most efficiently at full capacity during peak hours. This engine is not efficient running at half capacity, but is efficient at turning on and off and running at full capacity. As designed, this engine was less efficient because of counter flow and hot end drive design. When this engine operates in simple cycle mode, heat is lost a rapid rate. At Kinder Morgan, where the engine works as a

c ombined cycle system, all of the heat loss is recovered and the engine is more efficient.

**•** When installed at Kinder Morgan, the Frame 7EA engine was a relatively old technology, but

the “low NO X ” version was relatively advanced.

**•** The aeroderivative engi nes are more efficient than the previously discussed Frame 7EA because they were originally built to be efficient for aircrafts and have a cold end drive design.

**•** Kinder Morgan modifies the environment around the areoderivative engines in order to make

it as efficient as possible and increase its life span. Kinder Morgan chills the air flowing through these engines (simulates how the engine would run at 40,000 ft). In order to accomplish this, Kinder Morgan chills the air that enters the filter house to 48 or 50 degrees F by chilling the water that flows through the radiators before the filters.

**•** Kinder Morgan also burns cleaner fuel than an aircraft engine. Burning natural gas instead of kerosene, as would be burned in an aircraft, also increases the life span of the jet engine.

**•** Kinder Morgan installed a filter baghouse on each engine in order to keep any debris, dirt, or stones from entering the engine. This also makes the life of the engine longer compared to an engine operating on a runway or at 40,000 ft with debris flying through it.

**•** Other differences between the engine designs for the combined cycle system and the aircraft include the removal of the triple fan. This fan is replaced with a small, low pressure compressor (supercharger) load shaft that drives the generator.

**•** The aeroderivative engine is designed to be variable. This means that each nozzle in the engine can be turned to directly affect the blades. The nozzles pivot to steadily increase acceleration. The design of the engine also creates a boundary layer of air and steam. This allows for cooling where combustion starts at the tip of the nozzle, making the engine more

efficient.

**•** Acceleration in the core engine generates an increase in hot gases. The increase in hot gases allows the generat or to do more work, which results in more power.Page 4

Water Use and Wastewater Generation/ Treatment

**•** Kinder Morgan receives all of its water from the City of Jackson. A municipal water tower, located to provide 21 ft of gravity head, fills Kinder Morgan’s raw water tanks. When running at full capacity, Kinder Morgan requires about six million gallons per day of city

water.

**•** Kinder Morgan stated that even though their combined cycle system configuration is unique, the wastewater generated is similar to othe r combined cycle systems. The steam turbines and related equipment are similar to all other steam turbines. A water flow diagram for the plant is provided in Att achment 1 of this memorandum.

**•** The cooling water requirement is provided by mechanical draft co oling towers.

**•** Kinder Morgan operates a main cooling tower and an auxiliary cooling tower. The auxiliary cooling tower is u sed in the summer to chill the water for the aeroderivative engines. This water needs to be much cooler than the cooling water for th e boiler systems, which is cooled by the main cooling tower. There are underwater agitators in the corners of the cooling

tower structure to prevent the water from freezing in the winter.

**•** Kinder Morgan uses an Electro

- Brom bromine product , which is gener ated from electrolysis on site, for corrosion inhibition in the cooling towers. Kinder Morgan does not use bleach because the plant is located in a residential area and bleach trucks would be a hazard.

**•** Kinder Morgan originally added sulfuric acid to th e cooling towers, but found that the sulfuric acid caused a fast rate of leaching of arsenic from the arsenic/copper/chrome

pressure

- treated lumber used in the cooling tower construction. After Kinder Morgan

switched to the alkaline chemistry , the leachin g was slowed, and Kinder Morgan was able to meet the POTW’s arsenic permit limits.

**•** Cooling tower blowdown, the main wastewater generated at the plant, is discharged to the POTW. The blowdown is generated continuously when the plant is running, but the fl ow rate varies significantly depending on power production.

**•** There are two sets of sumps/drains at the Kinder Morgan site: a low quality and a high quality sump.

**•** The low quality sumps collect water from all floor drains, the catch basins for the oil belo w the transformers, and the catch basins underneath the steam turbines (there just in case of an oil leak). The oil and water discharges are combined, and the combined stream is sent through the oil/water separator and discharged via the outfall to the POT W. Kinder Morgan monitors this POTW outfall for pH, temperature, and flow.

**•** The high quality sump collects boiler blowdown (from the heat recovery steam generators (HRSG)) and steam piping condensate. This water is sent to the cooling tower. Additionall y, condensate from the combustion turbine filter cooling is sent to the cooling tower at about 300 gpm in the summer.Page 5

**•** Kinder Morgan stated that the combustion turbine compressors are washed with 4,000 or 5,000 gallons of water and detergent about twice pe r year to clean the compressor blades to maintain efficiency. A hydrocarbon residue can build up on the blades, which ultimately affects the life of the engine. The water wash drains to the low quality sump and is discharged to the POTW.

**•** Kinder Morgan st ated that the combustion turbine combustors rarely need to be cleaned. Any debris/residue that enters the combustors is usually incinerated during operation.

**•** Kinder Morgan stated that cleaning of the HRSGs is not necessary due to the continuous injection and blowdown.

**•** The Kinder Morgan steam turbines are cleaned about once per year. Wash water and foam balls are used to clean any precipitate that has formed on the condenser tubes. The wash water is combined with the low quality sump water and ultimately discharged to the POTW.Table 1. Site Visit Attendees

Name Organization (Representing) Telephone E

- mail

Wayne Frey Kinder Morgan Power Company (517) 841

- 5710 wayne_frey@kindermorgan. com

Ron Jordan EPA/Office of Water (202) 566

- 1003 jordan.ronald @epa.gov

Jezebele Alicea

Virella EPA/Office of Water ( 202 ) 566

- 1755 alicea.jezebele@epa.gov

Sarah Holman ERG (Contractor to EPA) (703) 633

- 1661 sarah.holman@erg.com

Elizabeth Sabol ERG (Contractor to EPA) (703) 633

- 1659 elizabeth.sabol@erg.com