Information Notice 2009-02, Biodiesel In Fuel Oil Could Adversely Impact Diesel Engine Performance

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Biodiesel In Fuel Oil Could Adversely Impact Diesel Engine Performance
ML083450280
Person / Time
Issue date: 02/23/2009
Revision: 0
From: Omid Tabatabai, Wolfgang R J
Office of New Reactors, Office of Nuclear Reactor Regulation
To:
Beaulieu, D P, NRR/DPR, 415-3243
References
IN-09-002
Download: ML083450280 (6)


ML083450280 February 23, 2009 NRC INFORMATION NOTICE 2009-02: BIODIESEL IN FUEL OIL COULD ADVERSELY IMPACT DIESEL ENGINE PERFORMANCE

ADDRESSEES

All holders of operating licenses for nuclear power reactors and fuel cycle facilities, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel; all current and potential applicants for an early site permit, combined license, or standard design certification for a nuclear power plant under the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 52, "Licenses, Certifications, and Approvals for Nuclear Power Plants"; all current holders of and potential applicants for construction permits under 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities"; and all licensees and potential applicants for new fuel cycle facilities under 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material."

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to alert licensees to the potential for diesel fuel oil to contain up to 5-percent biodiesel (B5), which could adversely impact engine performanc The NRC expects recipients to review the information for applicability to their facilities and to consider actions, as appropriate, to avoid similar problem However, suggestions contained in this IN are not NRC requirements; therefore, no specific action or written response is require

DESCRIPTION OF CIRCUMSTANCES

On June 19, 2008, the American Society for Testing and Materials (ASTM) International D02 Main Committee approved a revision to the conventional petrodiesel standard specificatio The revised standard, ASTM D975-08a, "Standard Specification for Diesel Fuel Oils," now permits No. 2 diesel fuel to contain up to a B5 blend and still be considered the same without labeling the blen The changes to this standard will take effect within 3 to 5 months after the October 13, 2008, publication date of the final standar The introduction of biodiesel blends into the No. 2 diesel fuel supply raises potential generic applicability and common-cause failure concerns because of the possibly adverse physical properties associated with biodiesel use in diesel engines including the safety-related emergency diesel generators (EDGs).

Examples of diesel engines providing functions important to safety include EDGs, diesel-driven fire pumps, diesel-driven auxiliary feedwater pumps, diesel-driven essential service water makeup pumps, diesel-driven instrument air compressors, security diesel generators, safe- shutdown facility diesel generators, diesel generators for emergency preparedness and response functions, and station blackout diesel generator The U.S. Department of Energy has stated that biodiesel blends of B5 or less do not cause noticeable differences in performance compared to No. 2 diesel fue However, for the reasons discussed below, a B5 blend could be problematic for EDGs and diesel engines that provide functions important to safet Cleaning Effect B5 can have a cleaning effect that loosens accumulated sediment in fuel oil storage tanks that previously stored conventional diesel fue This sediment can then plug filters and other equipment in the fuel oil syste To prevent the buildup of this sediment, licensees may take the following actions:

  • Clean fuel oil storage tanks before putting B5 in them.
  • Add and/or upgrade the filters in the fuel oil syste Licensees can expect to change and/or clean filters more frequently, especially during the early stages of B5 us Water B5 contains suspended particles of water from the manufacturing proces This water will, in time, fall out of suspension and form "dirty water" in the fuel oil storage tank, which eventually leads to the formation and growth of alga To prevent the formation of dirty water and the subsequent growth of algae, licensees may take the following actions:
  • Use a moisture dispersant and biocide in fuel oil storage tanks containing B5.
  • Add a fuel/water separator to the fuel oil system.
  • Keep fuel oil storage tanks topped off to minimize in-tank condensatio Biodegradation B5 is biodegradable, and the presence of water, heat, oxygen, and other impurities accelerate the degradation of the fuel suppl To avoid damage caused by fuel degradation, licensees may consider not using B5 if it has been stored for an extended period of time (approximately 3 to 6 months or longer).

Material Incompatibility Brass, bronze, copper, lead, tin, and zinc in tanks and fittings may accelerate the oxidation process of B5, creating fuel insolubles or gels and salt Licensees should avoid using zinc linings, copper pipes and fittings, and brass regulators with B Licensees should verify that elastomeric materials, such as hoses, gaskets, and O-rings, and their inspection and maintenance, are compatible with B5 and its effect Temperature Protection Biodiesel components have higher cloud points (the temperature at which solid particles start to form, or gel) than standard (petroleum) diesel component The cloud point also varies considerably with the source of the biodiesel component, which is not specified in B5 blend Clouding may also combine with suspended particles of water and exacerbate adverse cold temperature concern Consequently, licensees should evaluate and ensure adequate low temperature protection for all diesel generator system component Housekeeping Biodiesel is a good solven If it is left on a painted surface long enough, it can dissolve certain types of paint Licensees should check for compatibility with paints they use, and should immediately wipe any B5 spills from painted surface

BACKGROUND

Applicable Regulatory Documents General Design Criterion 17, "Electric Power Systems," of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, requires that onsite and offsite electric power systems be provided to permit the functioning of structures, systems, and components important to safet In addition, General Design Criterion 17 contains requirements for system capacity, capability, independence, redundancy, availability, testability, and reliabilit Appendix B,

"Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50, establishes overall quality assurance requirements for the design, construction, and operation of structures, systems, and components important to safet Regulatory Guide (RG) 1.137, "Fuel Oil Systems for Standby Diesel Generators," Revision 1, issued October 1979, describes a method that the NRC staff finds acceptable for complying with the Commission's regulations on diesel fuel oil systems for standby diesel generators and assurance of adequate quality of diesel fuel oi RG 1.137 states that licensees should use Appendix B to American National Standards Institute N195-1976 as a basis for a program to ensure the initial and continuing quality of diesel fuel oil as supplemented by eight additional provisions in RG 1.137 for maintaining the properties and quality of diesel fuel oi Related NRC Generic Communications NRC IN 2006-22, "New Ultra-Low-Sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance," dated October 12, 2006, alerts addresses to the potential of new ultra-low-sulfur diesel fuel oil to adversely impact diesel engine performanc NRC IN 96-67, "Vulnerability of Emergency Diesel Generators to Fuel Oil/Lubricating Oil Incompatibility," dated December 19, 1996, alerts addressees to a finding that involves the degradation of the power block assembly of two EDGs caused by an incompatibility of the lubricating oil with a low-sulfur-content diesel fuel oi NRC IN 94-19, "Emergency Diesel Generator Vulnerability to Failure From Cold Fuel Oil," dated March 16, 1994, alerts addressees to a safety problem that could lead to the common mode failure of all emergency diesel generator units as a result of temperature-related changes in the fuel oi NRC IN 91-46, "Degradation of Emergency Diesel Generator Fuel Oil Delivery Systems," dated July 18, 1991, alerts addressees to the potential inoperability of multiple EDGs resulting from two common-cause degradations: (1) degraded diesel fuel oil delivery systems, and (2) the failure of the licensee to meet technical specification testing requirements intended to detect the potentially degraded quality of the diesel fuel oil stored on sit NRC Generic Letter 83-26, "Clarification of Surveillance Requirements for Diesel Fuel Impurity Level Tests," provides licensees with revised surveillance requirements for tests of the impurity level in diesel fuel oil to clearly reflect the relationship between the standard technical specification testing requirements for impurity levels in diesel fuel oil; guidance given in RG 1.137, Revision 1, and American National Standards Institute N195-1976 (ASTM D270, ASTM D975, and ASTM D2274); and the NRC staff review performed in accordance with Section 9.5.4 of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants."

DISCUSSION

The conventional petrodiesel standard specification, ASTM D975-08a, has been revised to permit No. 2 diesel fuel to contain up to a B5 blend and still be considered the same without labeling the blen Licensees may start receiving B5 in the near futur As described above, B5 has a number of characteristics that could potentially degrade or render inoperable the associated diesel engine or may create a condition that is inconsistent with current plant design and licensing base This B5 issue is of particular concern because it could potentially affect licensee diesel generators that are safety related and/or important to safety, thereby presenting a possible common-mode failur Licensees can evaluate the potential impacts of B5 and can act to ensure that their plants are consistent with the current design and licensing bases and to prevent the diesels from being rendered inoperable or significantly degrade

CONTACT

This information notice requires no specific action or written respons Please direct any questions about this matter to the technical contacts listed belo /RA/ /RA/ Timothy J. McGinty, Director Glenn Tracy, Director Division of Policy and Rulemaking Division of Construction Inspection and Office of Nuclear Reactor Regulation Operational Programs Office of New Reactors

/RA/

Daniel Dorman, Director Division of Fuel Cycle Safety and Safeguards Office of Nuclear Materials Safety and Safeguards

Technical Contacts: Robert Wolfgang, NRR Omid Tabatabai, NRO 301-415-1624 301-415-6616 e-mail: robert.wolfgang@nrc.gov e-mail: omid.tabatabai@nrc.gov Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collection IN 2009-02