Draft Notes from Site Visit at the Jackson Power FacilityKinder Morgan Power Plant on 

September 24, 2009

EPA conducted a site visit at the Jackson Power FacilityKinder 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 Jackson Power Facility (JPF)Kinder Morgan Power Plant (Kinder Morgan) is owned by 

AlphaGen Power LLC and operated by Kinder Morgan JPM Michigan Operator LLC 

(JPMMO)Power Company, a subsidiary of Kinder Morgan, Inc.

• JPFKinder Morgan is a “demand dispatch” facility with peaking and intermediate load 

capacity. JPFKinder Morgan’s provides 100% of the facility capacity for demand dispatched 

energy conversion services to a single customer is under a long term Capacity Sale and 

Tolling Agreement. The customer is the JPF Power Selling Entity (PSE) participating in the 

Midwest Independent Transmission System Operator (MISO) market, as an electricity 

wholesaler. Due to the depressed regional mfg / industrial loadpower demand in 2009this 

year, JPF was not dispatched as oftenKinder Morgan has not run as much in the “reliability 

dispatch” mode. as in 2007 and 2008. The plant’s typical peaking operations since the Jan 

2009 launch of the MISO Ancillary Services Market have included starting all units up in 

the morning at a plant minimum (say 150-200 MWs), operating on automatic generation 

control (AGC) to following the system demand for regulation or spinning reserve to satisfy 

peaking demand transients load peaks throughout midday and some portion of a day or into 

the evening, and then shutting down before midnight. 

• JPFKinder Morgan is located in zoned industrial property at the edge of residential Jackson, 

MI, within the City limits. The plant employs 22 personnel responsible for operation and 

maintenance of the facility.

• JPF’sKinder Morgan’s 550 MW combined cycle system is unique tofrom other systems

facilities because it was designed for a peaking plant. Kinder Morgan operates a employs a 

proprietary integrated hybrid combined cycle system, which includes of six aero-derivative 

(LM6000PC) combustion turbine generator sets(jet) engines, with one industrial (Frame 

7EA) combustion turbine generator set, all equipped with heat recovery steam generators and

in a single combined cycle facility sharing two steam turbines generator sets. The JPFKinder 

Morgan was designedoperates this system to serve an “intermediate load” and peaking 

market nichetch.

• JPFKinder Morgan is a successful peaking plant because of its ability to quickly produce 

power. The plant is attractive to its capacity and tolling customer because of the high ramp 

rate available with this specific combined cycle system (4030 MW/minute). If the plant is 

“cold”, meaning it has not been run in 24 hours, it is able to start-up and ramp to full power 

in just under threeover two hours. If the plant is “warm”, it only requires just underone two

hours to start-up and to ramp to full power.
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• JPFKinder Morgan was strategically built close to a natural gas line (also owned by Kinder 

Morgan, Inc.) that runs across Michigan. Due to this location, Kinder Morgan can JPF is a 

single fuel receive high quality “Pipeline Nnatural gGas” fired facilityto run the combined 

cycle system. JPF Kinder Morgan is interconnected to the 138KV High VoltageHigh 

Voltage transmission system viaalso placed close to two approximately oneapproximately 

one mile long high voltage lines which were constructed for the interconnection 

.interconnection. All capacity sale and tolling customer power delivery is via The high 

voltagethis 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 AlphaGen Power’s Lessee operates Company the JPF under the 

CSTA with their customer. operate under a capacity sale and tolling agreement. As 

described by Kinder Morgan JPF plant personnel, the plant Operator is protected by contract 

with the owner and the owner is protected by contract with the capacity sale and tolling 

customercustomer (MISO). The customer MISO “owns” the JPF’s Kinder Morgan’s 

capacity to convert natural gas fuel to electricity, and purchases the fuel used to run the plant. 

Kinder Morgan JPF plant personnel pointed outexplained that if JPFKinder Morgan were a 

merchant plant, it would need to purchase its own fuel, and likely would have been out of 

business due to natural gas prices. The owner Kinder Morgan Power Company covers the 

plant’s operation and maintenance (O&M) costs and also pays the property tax for the plant. 

• The CSTA customerMISO contracts Kinder Morgan for has contracted for the its ability to 

supply facility Dependable Capacity550 MW of power when demanded. This means that 

even when the plant is not running, JPFKinder Morgan is still is potentially still making a 

profit because it is available to run. If a unit is down for maintenance or repair, Kinder 

MorganJPF is potentially vulnerable to a loses money because the power that could be 

generated from that combustion or steam turbine is no longer available. 

• The CSTA customer participates in the MISO market monitors the grid daily and reports 

todemands dispatch of the JPF Kinder Morgan how much power they need, if they need it, 

and when they need it.in response to market opportunity. The JPFKinder Morgan combined 

cycle system does not operate every day, and when it does operate, it is typically for only 

part of the day. 

• The MISO market views JPFKinder Morgan as a singleone combined cycle system that 

provides varying amounts of power as needed. JPF responds to demand dispatch orders 

identifying the configuration in which the facility must run (number of units to be on-line) 

but JPF offers the flexibility Kinder Morgan may only to operate only part of the combined 

cycle system (e.g., part of the combustion turbines and only one of the two steam turbines). 

When operating, each individual generator set must remain above its design minimum 

capcaitycapacity each turbine (e.g. LM6000PC minimum is cannot be run at less than 11 to 

12 MWs each); however, not all turbines must be run to generate the power. 

• JPFKinder Morgan was a 15-acre brownfield development. As part of the overall project 

development, the City of Jackson wanted the entire former Goodyear Tire and Rubber 

Factory to be razed. Although the JPF occupies only 15-acres of the approximately 70 acre 

former Goodyear brownfield, and Kinder Morgan Power Company (the EPC) only procured 

approximately 30 acres of the brownfield to develop the JPF, the overall project responded to 

the City’s desire entered into a contract with the City of Jackson to tear down the Goodyear 
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plant. JPF occupiesKinder Morgan used about 15 acres of the total Goodyear brownfield 

with approximately 15 additional acres of ‘buffer’ land included in the contiguous JPF site. 

The remaining roughly half of the property continues to be owned by the post Goodyear 

property owner from whom the JPF site was purchased.half of the total property to build the 

plant. As part of the Development Agreementcontract with the City of Jackson, all existing 

water and sewage infrastructure from the Goodyear plant was made readily available to 

Kinder MorganJPF, and Kinder Morgan JPF applied for and obtained a permit for regulated 

Wastewater discharges tohas been able to discharge water to the local Publicly Owned 

Treatment Works (POTW). They have never had a reason to develop a different drainage 

system (i.e., discharge to surface water). 

• The Kinder MorganJPF plant was constructed from MarchSeptember 2001 when the 

Constructor mobilized until to NovSeptember 20021,, and upon successful demonstration of 

Dependable Capacity achieved Substantial Completion, closed on the sale of the facility to 

AlphaGen Power and the plant went commercial under the CSTA on thein 01 July 2002

Commercial Operation Date (COD). , prior to Final Completionfull operation was achieved 

in . In September 2002, Kinder Morgan closed with the contractor.and the constructor 

demobilized. 

• Most equipment for the plant was built off site. The Frame 7EA generator set had to be 

mostly constructed assembled on site due to its designlarge size. 

• The 550 MW Kinder MorganJPF combined cycle plant cost on the order of about $250 

million to build. Kinder Morgan Power Company decided to JPF was buildt a power planto

that would use natural gas as its fuel due to a number of market factors driving such 

independent power plant ventures. because itIn general combined cycle natural gas fired 

plants is enjoy better thermal efficiency more efficient. Natural gas producesing more 

kW/BTU than with coal, and are more flexibly responsive in peaking markets availablt to the 

independent power industry. The plant was also required less capital expensiveinvestment to 

build than a coal plant: the same size coal plant would have cost about $1.5 billion at the 

time. Recently a Michigan utility announced a plan Kinder Morgan estimated that to build

an 800 MW clean coal plant would at a cost of about $4 billion.

Combined Cycle System

• Kinder MorganJPF uses only a low sulfur fuel (Pipeline Natural Gas) natural gas to fuel the

at the facility combustion turbines. JPF Kinder Morgan does not use a liquid fuel because it 

would add complexity to the of the changes in air permitting process while also impacting 

that it would require a number of other market considerations limiting potential ROI for such 

additional investment.

• Kinder MorganJPF staff 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 heat 

recovery steam power is potentially available from produced from each 50 MW combustion 

turbine. Three MW of this 10 MW steam produced is put back into the turbine for NOX

suppression, and 1.5 MW of this 3 MW consumed is gained back in additional power 

generation.
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• Kinder MorganJPF uses steam for NOX suppression because it is less damaging to the engine 

than water. The water can erode ceramic coatingsnozzles in throughout the engine hot 

section, potentially requiring hot section maintenance at 15K hour intervals vice the 25K 

hour interval expected with steam injection.which would cost about $10,000 every 25,000 

hours to replace. Steam is injected into the combustor through the fuel nozzles injectors 

placed around the circumference of the combustor. The boundary layer cooling from the of 

steam supplied in the combustor helps keeps the mass air flow through the combustor from 

cracking to NOx. from cracking.

• Kinder MorganJPF operates one Frame 7EA combustion turbine that runs most efficiently at 

full capacity during peak hours but is capable of turndown to 50% capacity while 

maintaining NOx emission control. This engine is not efficient running at half capacity, but is 

efficient at turning on and off and running at full capacity. An older design, As designed,

this engine is was less efficient than the LM6000s because of several factors including 

counter flow and hot end drive design characteristics. If this When this engine was installed 

for simple cycle operatesion in simple cycle mode, it would enjoy a poor heat rate.heat is 

lost a rapid rate. At Kinder Morgan,JPF where the engine worksis installed in as a combined 

cycle system, the combined cycle heat rate of this unit is consistent with the remainder of the 

facility.all of the heat loss is recovered and the engine is more efficient.

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

but was selected for the relatively new proven DLN-1 “dry low NOX” capabilityversion was 

relatively advanced. 

• The aero-derivative engines are more efficient than the previously discussed Frame 7EA 

because they were originally built to be efficient for aircrafts and incorporate a number of 

technology improvements including have a cold end drive design.

• Kinder MorganGE Aero Energy offers several enhancements for aero-derivative combustion 

turbine generator sets to improve the modifies the environment around the areoderivative 

engine’s operating environment in order to make it as efficient as possible and to increase its 

life span. Kinder Morgan JPF chills the air flowing through these engines (simulates how the 

engine would run at 40,000 ft) to help maintain engine performance in the stationary ground 

level power generating application on hot days. In order to accomplish this, Kinder Morgan

JPF chills the air that enters the engine through the filter house to 48 or 50 degrees F by 

chilling the water that flows through the radiators before the filters. 

• JPFKinder 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 and 

reliability of the jet engine.

• Kinder MorganGE Aero Energy incorporates installed a filter baghouse on each engine in 

order to keep any foreign objects debris, dirt, or stones from entering and possibly damaging 

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 aircraft engine designs for the and the stationary power 

combined cycle system andare the replacement of the aircraft the aircraft include the 
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removal of the triple fan. Turbo Fan (the propeller) with the 50MW electrical generator This 

fan is replaced with aand a small, low pressure compressor (which functions as a 

supercharger) load shaft that drives the generator.

• The GE aero-derivative engine is a variable geometry engine designed to be variable. This 

Variable stator vanes in the variable speed core engine High Pressure Compressor means that 

each nozzle in the engine canare programmed to create the proper angle of attack for air 

delivered to subsequent rotating blades improving stall margins during transient acceleration 

and deceleration allowing the core engine (gas generator) to be more responsive to load 

changes on the electrical generator 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 available to do work in the 

Low Pressure Turbine which is driving the generator at synchronous speed. The increase in 

hot gases allows the generator to do more work, which results in more power.

Water Use and Wastewater Generation/Treatment

• JPFKinder Morgan receives all of its water from the City of Jackson. A municipal water 

tower, located nearby helps to provide 21 ft of gravity head, and surge capacity to 

maintainfills the JPF Kinder Morgan’s raw water tank and makeup water supply to the 

primary JPF demand which is the evaporative cooling tower processs. When running at full 

capacity on a hot (design) day, JPF Kinder Morgan requires a maximum of about six5.4

million gallons per day of city water. Average daily demand is far less.

 

• JPF O&M staffKinder Morgan stated that even though their combined cycle system 

configuration is unique, the wastewater generated is similar to other 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 Attachment 1 of this memorandum.

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

• JPF Kinder Morgan operates a main cooling tower and an auxiliary cooling tower. The 

auxiliary cooling tower is used in the summer to cool the condensers of the mechanical 

chillers providing chilled the water for the aeroderivative engines. This Auxiliary Circulating 

water needs to be much cooler than the cooling water for the 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 if the plant is idle and not 

rejecting heat to the cooling towers.

• JPFKinder Morgan uses an Electro-Brom bromine product, which is generated from 

electrolysis on site as the biocide for the cooling tower systems., for corrosion inhibition in 

the cooling towers. Kinder MorganJPF does not use bleach for a number of reasons, one of 

which is because the plant is located in a residential area and bleach trucks deliveries can be 

avoided reducing would be a hazard mishap potential. 
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• JPFKinder Morgan originally added sulfuric acid to the cooling towers, but found that the 

sulfuric acid caused a fast rate of leaching of arsenic from the arsenic/copper/chrome/arsenic 

(CCA) pressure-treated lumber used in the cooling tower construction. After JPFKinder 

Morgan switched to the alkaline chemistry, the leaching was slowed, increasing the margin 

by which and JPFKinder Morgan was is able to meet the POTW’s arsenic permit limits for 

Arsenic in the plant outfall..

• 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 flow 

rate varies significantly depending on power production and thermal loading of the Cooling 

Towers.

• There are two sets of sumps/drains at the Kinder MorganJPF 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 below 

the transformers, and the catch basins underneath the steam turbines (there just in case of an 

oil leak). Should this low quality drain system become contaminated by an oil leak before 

detection and mitigation, the The oily and water discharge s are combined, and the combined 

streamis most likely to be intercepted in the low quality sump secondary containment system,

but if not the outfall of the low quality sumps passes is sent through the oil/water separator 

and before discharged via the plant outfall to the POTW. JPFKinder Morgan monitors the oil 

water separator level alarms continuously via the DCS, and theis POTW outfall is 

continuously monitored at the DCS for pH, temperature, and flow, and is also continuously 

or periodically sampled and analyzed for other permit limits..

• The high quality sump collects boiler blowdown (from the heat recovery steam generators 

(HRSGs)) and steam piping condensate drains. This water is sent to the cooling tower as 

make-up. Additionally, condensate from the combustion turbine filter house coolingchilling

is sent to the cooling tower at as much as about 300 gpm during hot humid near design suin 

the summer conditions.

• JPFKinder Morgan staff stated that the combustion turbine compressors are washed with 

4,000 or 5,000 gallons of water and detergent about twiceo to four times per year to clean 

the compressor blades to maintain efficiency. A Dirt and hydrocarbon (road vehicle exhaust, 

etc.) residue can build up on thecompressor blades, decreasing the efficiency which 

ultimately affects the life of the engine. The water wash drains to the low quality sump, and 

is discharged to the POTW via the oil water separator. 

• JPFKinder Morgan stated that the combustion turbine combustors are not cleaned onsiterarely need to be cleaned. With clean natural gas fuel only there are virtually no 

combustion by-products/residues, Any and contaminantsdebris/residue that able to enters the 

combustors via the filter house and engine compressor is usually incinerated during 

operation. 

• JPF staff Kinder Morgan stated that cleaning of the HRSGs is not necessary due to 

maintenance of good chemistrythe via continuous injection and blowdown.
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• The Kinder MorganJPF steam turbines condensers are cleaned about once per year. Wash 

water and recoverable foam balls are used to clean soft any precipitate that has deposits 

(slime) formed on the water side of 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 Jackson Power Company, LLCKinder 

Morgan Power Company (517) 841-5710 wayne_frey@kindermorgan.com

Ron Jordan EPA/Office of Water (202) 566-1003 jordan.ronald@epa.gov

Jezebele AliceaVirella 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