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

EPA conducted a site visit at the Jackson Power Facility Kinder Morgan Power Plant located in Jackson, MI on Thursday, September 24, 2009 to learn abo ut 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 Mo rgan Power Plant (Kinder Morgan) is owned by AlphaGen Power LLC and operated by Kinder Morgan JPM Michigan Operator LLC ( JPM MO) Power Company, a subsidiary of Kinder Morgan, Inc

.

**•** JPF Kinder Morgan is a “demand dispatch” facility with peaking and intermediat e load capacity. JPF Kinder 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 load power demand in 2009 this

year
, JPF was not dispatched as often Kinder Morgan has not run a s much in the “reliability dispatch” mode. a s in 2007 and 2008. The plant’s typical peaking operations since the Jan 2009 launch of the MISO Ancillary Services Market h a ve include d starting all units up in the morning at a plant minimum (say 150

- 200 MWs)

, operating on automatic generation control ( AGC ) to follow ing the system demand for regulation or spinning reserve to satisfy peaking demand transients load peaks through out midday and some portion of a day or into the evening, and then shutting down bef ore midnight

.

**•** JPF Kinder 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’s Kinder Morgan’s 550 MW combined cycle system is unique to from other s ystems
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) combustio n 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 turbine s generator sets

. The JPF Kinder

Mor gan was designed operates this system to serve an “intermediate load ” and peaking

market ni che tch

.

**•** JPF Kinder Morgan is a successful peaking plant because of its ability to quickly produce power. The plant is attractive to its capacity and tolling custome r because of the high ramp rate available with this specific combined cycle system ( 4 0 30 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 three over two hours. If the plant is “warm”, it only requires just under one two
hour s to start

- up and to ramp to full power.Page 2

**•** JPF Kinder Morgan was strategically built close to a natural gas line ( also owned by Kinder Morgan, Inc.) that runs across Michigan. Due to this location, Kind er Morgan can JPF is a single fuel receive high quality “Pipeline N n atural g G as ” fired facility to run the combined cycle system

. JPF Kinder Morgan is interconnected to the 138KV High Voltage High Voltage transmission system via a lso placed close to two a pproximately one approximately

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 voltage this interconnect

. line allows Kinder Morgan to d istribute 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 c ustomer

. 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

customer customer (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 out explained that if JPF Kinder Morgan were a merchant plant, it would need to p urchase 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 customer MIS O contracts Kinder Morgan for has contracted for the its ability to supply facility Dependable Capacity 550 MW of power when demanded. This means that even when the plant is not running, JPF Kinder Morgan is still is potentially still making a profit becau se it is available to run. If a unit is down for maintenance or repair

, Kinder Morgan JPF is potentially vulnerable to a los e s money because the power that could be generated from that combustion or steam turbine is no longer available.

**•** The CSTA custome r participates in the MISO market monitors the grid daily and reports

to demands 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 JPF Kinder Morgan combined cycle syst em does not operate every day, and when it does operate, it is typically for only part of the day.

**•** The MISO market views JPF Kinder Morgan as a single one combined cycle system that provides varying amounts of power as needed. JPF responds to demand disp atch orders identifying the configuration in which the facility must run (number of units to be on

- line)

but JPF offers the flexibility K inder 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 capcaity capacity each turbine (e.g. LM6000PC minim u m is cannot be run at less than 11 to

12 MW s each) ; however, not all turbines must be ru n to generate the power.

**•** JPF Kinder Morgan was a 15

- acre brownfield development. As part of the overall project development

, the City of Jackson wanted the entire former Goodyear Tir e and Rubber Factory to be razed. Although the JPF occupies only 15

- ac res 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 wit h the City of Jackson to tear down the GoodyearPage 3

plant. JPF occupies Kinder 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 D evelopment A greement contract with the City of Jackson, all existing

water and sewa ge infrastructure from the Goodyear plant was made readily available to Kinder Morgan JPF , and Kinder Morgan JPF applied for and obtained a permit for regulated

W astewater discharges to has been able to discharge water to the local Publicly Owned

Treatment W orks (POTW). They have never had a reason to develop a different drainage system (i.e., discharge to surface water).

**•** The Kinder Morgan JPF plan t was constructed from March September 2001 when the

Constructor mobilized until to Nov Sept ember 200 2 1

, , and up on 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 the in 01 July 2002 Commercial Operation Date (COD). , prior to F inal C ompletion full 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 o n site due to its design large size

.

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

million to build. Kinder Morgan Power Company decided to JPF was buil d t a power plan t o that would use natural gas as its fuel due to a number of market factors driving such independent power plant ventures. because it In general co mbined cycle n atural gas fired plants i s enjoy better thermal efficien cy more efficient . Natural gas produc es ing more kW/BTU than with coal , and are more flexib ly responsive in peaking markets availablt to the independent power industry . The plant was also required less capital expensive investment to
build than a coal plant: the same size coal plant would have cost about $1.5 billion at the

time

. Recently a Mic higan 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 Morgan JPF 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 f or such

additional investment

.

**•** Kinder Morgan JPF s taff 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 t o 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 stea m 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.Page 4

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

than water. The water c an erode ceramic coatings nozzles 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 keep s the mass air flow through the combustor from

cr acking to NOx

. from cracking.

**•** Kinder Morgan JPF 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 ef ficient 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 des ign characteristics

. If this When this engine was installed for simple cycle operat es ion in simple cycle mode, it would enjoy a poor heat rate. heat is lost a rapid rate

. At Kinder Morgan, JPF where the engine wor ks is installed in as a combined cycle sys tem, the combined cycle heat rate of this unit is consistent with the remain d er of the facility

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

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

but was selected for the relatively new proven DLN

- 1 “ dry low NO X ” capability version 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 a ircraft s and incorporate a number of technology improvements including have a cold end drive design.

**•** Kinder Morgan GE Aero Energy offers several enhancements for aero

- derivative combustion

turbine generator sets to improve the modifies the environment aro und 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 main tain engine performance in the stationary g r ound

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.

**•** JPF 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 and reliability of the jet engine

.

**•** Kinder Morgan GE Aero Energy incorporates installed a filter bag house 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 a n 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 and are the replacement of the aircraft the aircraft include thePage 5

re moval of the triple fan. Turbo Fan (th e propel ler ) with the 50MW electrical generator This fan is replaced with a and 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 can are programmed to create the proper angle of attack for air

delivered to s ubsequent rotating blades improving stall margins during transient acceleration

and deceleration allowing the core engine (gas generator) to be more r espons ive 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 P ressure T urbine 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

**•** JPF Kinder 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
maintain fills the JPF Kinder Morgan’s raw water tank and make up water supply to the primary JPF demand which is the evaporative cooling tower process s . When running at full capacity on a hot (design) day

, JPF Kinder Morgan requires a maximum of about six 5.4 million gallons per day of city water. Average daily dema nd is far less.

**•** JPF O&M staff Kinder 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 o ther 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 cooling towers.

**•** JP F Kind er Morgan operates a main cooling tower and an auxiliary coolin g tower. The auxiliary cooling tower is u sed in the summer to cool the condensers of the mechanical

chill ers providing chilled the water for the aeroderivative engines. This Auxiliary Circulating

water needs to be much cooler than the cooling water for the boiler system s, 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

.

**•** J PF Kinder 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 Morgan JPF does not use bleach for a number of reasons, one of

which is because the plant is located in a residential area and bleach truck s deliveries can be avoided reducing would be a hazard mishap potential

.Page 6

**•** JPF Kinder Morgan originally added sulfuric acid to the cooling towers, but found that the

sulfu ric 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 JPF Kinder Morgan switched to the alkaline chemistry , the leaching was slowed, increasing the margin by which and JPF Kinder 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 con tinuously 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 Morgan JPF 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 oil y and water discharge s are combined, and the combined

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

b ut if not the outfall of the low quality sumps passes is sen t through the oil/water separator

and before discharge d via the plant outfall to the POTW. JPF Kinder Morgan monitors the oil

water separator level alarms continuously via the DCS

, and th e is POTW outfall is continuously monitored at the DCS f or pH, temperature, and flow , and is also continuously

or periodically sampl ed and analy zed for other permit limits.

.

**•** The high quality sump collects boiler blowdown (from the heat recovery steam generators (HRSG s ) ) and steam piping condensate drains . Thi s water is sent to the cooling tower as make

- up . Additionally, condensate from the combustion turbine filter house cooling chilling is sent to the cooling tower at as much as about 300 gpm during hot humid near design su in

the su mmer conditions

.

**•** JPF Kinder Morgan staff stated that the combustion turbine compressors are washed with 4,000 or 5,000 gallons of water and detergent about tw ice o to four times per year to clean the compressor blades to maintain efficiency. A D irt and hydrocarbon (road vehicle exha ust, etc.) residue can build up on the compressor 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

.

**•** JPF Kinder Morga n stated that the combustion turbine combustors are not cleaned on

site rarely need to be cleaned

. With clean natural gas fuel only there are virtually no combustion by

- products/residues

, Any and contaminants debris /residue that able to enter s the

combustor s 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 chemistry the via continuous injection and blowdown.Page 7

**•** The Kinder Mor gan JPF steam turbine s 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, LLC 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 (Contra ctor to EPA) (703) 633

- 1659 elizabeth.sabol@erg.com