Notes from Site Visit at the Jackson Power Facility on September 24, 2009 

 EPA conducted a site visit at the Jackson Power Facility located in Jackson, MI on 

Thursday, September 24, 2009 to learn about the operations at the plant. It should be noted that 

at the time of the site visit the plant was called Kinder Morgan Power Plant, but the plant has 

since changed its name to Jackson Power Facility. 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) is owned by AlphaGen Power LLC and operated by JPM 

Michigan Operator LLC (JPMMO). 

 JPF is a “demand dispatch” facility with peaking and intermediate load capacity. JPF 

provides 100% of the facility capacity for demand dispatched energy conversion services to a 

single customer 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 depressed regional mfg 

/ industrial power demand in 2009, JPF was not dispatched as often as in 2007 and 2008. 

The plant’s typical peaking operations since the January 2009 launch of the MISO Ancillary 

Services Market have included starting all units in the morning at a plant minimum (say 150-

200 MWs), operating on automatic generation control (AGC) to follow system demand for 

regulation or spinning reserve to satisfy peaking demand transients through some portion of a 

day or into the evening, and then shutting down before midnight. 

 JPF 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 550 MW combined cycle system is unique from other facilities because it employs a 

proprietary integrated hybrid combined cycle system of six aero-derivative (LM6000PC) 

combustion turbine generator sets with one industrial (Frame 7EA) combustion turbine 

generator set, all equipped with heat recovery steam generators in a single combined cycle 

facility sharing two steam turbine generator sets. The JPF was designed to serve an 

“intermediate” and peaking market niche. 

 JPF 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 (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 

hours. If the plant is “warm”, it requires just under two hours to start-up and ramp to full 

power. 

 JPF was strategically built close to a natural gas line that runs across Michigan. JPF is a 

single fuel “Pipeline Natural Gas” fired facility. JPF is interconnected to the 138KV High 

Voltage transmission system via two approximately one mile long high voltage lines which 
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were constructed for the interconnection. All capacity sale and tolling customer power 

delivery is via this interconnect. 

 AlphaGen Power’s Lessee operates the JPF under the CSTA with their customer. As 

described by 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. The 

customer “owns” the JPF’s capacity to convert natural gas fuel to electricity, and purchases 

the fuel used to run the plant. JPF personnel explained that if JPF 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 covers the plant’s operation and maintenance (O&M) costs 

and also pays the property tax for the plant. 

 The CSTA customer has contracted for the ability to supply facility Dependable Capacity 

when demanded. This means that even when the plant is not running, JPF is potentially still 

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

is potentially vulnerable to a loss 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 daily and demands dispatch of the JPF 

in response to market opportunity. The JPF 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 JPF as a single 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 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 capacity (e.g. LM6000PC minimum is 11 to 12 

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

 JPF was a 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 to tear down 

the Goodyear plant. JPF occupies 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.. As part of the Development Agreement with 

the City of Jackson, existing water and sewage infrastructure from the Goodyear plant was 

made readily available to JPF, and JPF applied for and obtained a permit for regulated 

Wastewater discharges 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 JPF was constructed from September 2001 when the Constructor mobilized until 

September 2002, and upon successful demonstration of Dependable Capacity achieved 

Substantial Completion, closed on the sale of the facility to AlphaGen Power and went 

commercial under the CSTA on the 01 July 2002 Commercial Operation Date (COD). Final 

Completion was achieved in September 2002, and the constructor demobilized. 
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 Most equipment for the plant was built off site. The Frame 7EA generator set had to be 

mostly assembled on site due to its design. 

 The 550 MW JPF combined cycle plant cost on the order of $250 million to build. JPF was 

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

independent power plant ventures. In general combined cycle natural gas fired plants enjoy 

better thermal efficiency producing more kW/BTU than with coal, and are more flexibly 

responsive in peaking markets availably to the independent power industry. The plant 

required less capital investment 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 to build an 800 

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

Combined Cycle System

 JPF uses only a low sulfur fuel (Pipeline Natural Gas) at the facility. JPF does not use liquid 

fuel because it would add complexity to the air permitting process while also impacting a 

number of other market considerations limiting potential ROI for such additional investment. 

 

 JPF 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. JPF stated that 10 MW of heat recovery steam is potentially 

available from each 50 MW combustion turbine. Three MW of this 10 MW steam 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. 

 

 JPF uses steam for NOX suppression because it is less damaging to the engine than water. 

The water can erode ceramic coatings in the engine’s hot section, potentially requiring hot 

section maintenance at $15,000 hour intervals versus the $25000 hour interval expected with 

steam injection. Steam is injected into the combustor through the fuel nozzles around the 

circumference of the combustor. The boundary layer cooling from the steam supplied in the 

combustor helps keep the mass air flow through the combustor from cracking to NOx. 

 JPF operates one Frame 7EA combustion turbine that runs most efficiently at full capacity 

but is capable of turndown to 50% capacity while maintaining NOx emission control. An 

older design, this engine is less efficient than the LM6000s because of several factors 

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

for simple cycle operation it would have a poor heat rate. At JPF where the engine is 

installed in a combined cycle system, the combined cycle heat rate of this unit is consistent 

with the remainder of the facility. 

 When installed at JPF, the Frame 7EA engine was a relatively old technology, but was 

selected for the relatively new proven DLN-1 “dry low NOX” capability 

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

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

technology improvements including cold end drive design. 
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 GE Aero Energy offers several enhancements for aero-derivative combustion turbine 

generator sets to improve the engine’s operating environment in order to make it as efficient 

as possible and to increase its life span. JPF chills the air flowing through these engines to 

help maintain engine performance in the stationary ground level power generating 

application on hot days. In order to accomplish this, 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 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. 

 GE Aero Energy incorporates a filter house on each engine to keep foreign objects from 

entering and possibly damaging the engine. 

 Other differences between the aircraft engine and the stationary power combined cycle 

system are the replacement of the aircraft Turbo Fan (the propeller) with the 50MW 

electrical generator and a small low pressure compressor (which functions as a supercharger) 

 The GE aero-derivative engine is a variable geometry engine. Variable stator vanes in the 

variable speed core engine High Pressure Compressor are 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 

 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 

 JPF receives all of its water from the City of Jackson. A municipal water tower, located 

nearby helps provide gravity head and surge capacity to maintain the JPF raw water tank and 

makeup water supply to the primary JPF demand which is the evaporative cooling tower 

process. When running at full capacity on a hot (design) day, JPF requires a maximum of 

about 5.4 million gallons per day of city water. Average daily demand is far less. 

 

 JPF stated that 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 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 water for the aeroderivative engines. This Auxiliary Circulating water needs to be 

cooler than the cooling water for the boiler system 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. 
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 JPF uses an Electro-Brom bromine product, which is generated from electrolysis on site as 

the biocide for the cooling tower systems. 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 deliveries 

can be avoided reducing hazard mishap potential. 

 JPF originally added sulfuric acid to the cooling towers, but found that the sulfuric acid 

caused a fast rate of leaching of arsenic from the copper/chrome/arsenic (CCA) pressuretreated lumber used in the cooling tower construction. After JPF switched to the alkaline 

chemistry, the leaching was slowed, increasing the margin by which JPF is able to meet the 

POTW’s 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 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 oily water discharge is most likely to be intercepted in the low 

quality sump secondary containment system, but if not the outfall of the low quality sumps 

passes through the oil/water separator before discharge via the plant outfall to the POTW. 

JPF monitors the oil water separator level alarms continuously via the DCS, and the 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 chilling is sent 

to the cooling tower at as much as 300 gpm during hot humid near design summer 

conditions. 

 JPF staff stated that the combustion turbine compressors are washed with 4,000 or 5,000 

gallons of water and detergent about two to four times per year to clean the compressor 

blades to maintain efficiency. Dirt and hydrocarbon (road vehicle exhaust, etc.) residue can 

build up on compressor blades, decreasing the efficiency of the engine. The water wash 

drains to the low quality sump, and is discharged to the POTW via the oil water separator. 

 JPF stated that the combustion turbine combustors are not cleaned on-site. With clean natural 

gas fuel only there are virtually no combustion by-products/residues, and contaminants able 

to enter the combustor via the filter house and engine compressor is usually incinerated 

during operation. 

 JPF stated that cleaning of the HRSGs is not necessary due to maintenance of good chemistry 

via continuous injection and blowdown. 
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 The JPF steam turbine condensers are cleaned about once per year. Wash water and 

recoverable foam balls are used to clean soft 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-Wayne Frey Jackson Power Company, LLC (517) 841-5710 wayne_frey@kRon Jordan EPA/Office of Water (202) 566-1003 jordan.ronald@Jezebele AliceaVirella EPA/Office of Water (202) 566-1755 alicea.jezebele@Sarah Holman ERG (Contractor to EPA) (703) 633-1661 sarah.holman@Elizabeth Sabol ERG (Contractor to EPA) (703) 633-1659 elizabeth.sabol@